ML20125C684

Insp Repts 50-295/92-23 & 50-304/92-23 on 921005-29. Violations Noted.Major Areas Inspected:Mods & Design Changes Including Engineering & Technical Support

ML20125C684
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	12/03/1992
From:	Burgess B, Gleaves W, Lerch R, Salehi K, Shembarger K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20125C660	List: ML20125C658 ML20125C676 ML20125C684
References
50-295-92-23, 50-304-92-23, NUDOCS 9212140035
Download: ML20125C684 (13)

See also: IR 05000295/1992023

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U.S. NUCLEAR REGULATORY COMMISSION'

REGION III

Reports No. 50-295/92023(DRS); NO. 50-304 / 92023 (DRS)

Docket Hos. 50-295; 50-304 Licenses Nos. DPR-39; DPR-48

Licensees Commonwealth Edison Company

Opus West III

1400 Opus Place - Suite 300-

Downers Grove, IL 60515

Facility Namet Zion Nuclear Generating Station, Units 1 and 2

Inspection Att Zion, Illinois

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Inspection conducted: October 5 - 29, 1992

Inspectors: R? }$, ///%*tW _ / 2 - / - 12

. R. H. Lerch Date

8,A1. baw r.rt?, t-t 1-91

K. Shembarger

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Date

f.' A b x<yt rint t: -2-12

K. Salehi Date

f.' Af, fc/?e g s?rr r*-2~92

W. Gleaves Date

/5 s 0

-Approved By: t'[bN-[.Ilua; ~ ._ /J /?/72.

B. L. Burgess,/ Chief Date

Operational Programs Section

Insoection Summary-

Inspection conducted from October 6 - 29, 1992 (Recorts

No. 50-293/92023fDRSir No. 50-304/92023(DRS))

Ar.p_gg Insoected: Announced, routine, safety inspection of

modifications and design changes (MC 37700) including engineering

and technical support.

Resulta Engineering performance was-good. The__ review of

modification packages found them to be thorough and correct.

-Management actions to increase engineering involvement in the-

site was a strength.- A licensee initiative, the Integrated

Reporting Program included.a look for engineering performance

9212140035 921204

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PDR ADOCK 05000295

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trends. Some areas of weakness were noted including the

temporary alteration program and post-maintenance testing.

A violation was written for an inadequate 20 CFR 50.59 safety

evaluation of a temporary alteration (paragraph 3.2).

A violation was written for lack of a post-maintenance test

(paragraph 3.4.a). Other findings were a lack of trending of

component performance data (paragraph 4.1), failed safety rollef

valve tests not reported (unresolved item - paragraph 3.4.b),-and

inadequate procedural guidance for performing materials

engineering technical evaluations and alternate replacement parts

evaluatione (open item - paragraph 3.3).

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REPORT DETAILS j

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1. Commonwealth Edison Comoany

+R. Tuetken, General Manager

+T. Joyce, Station Manager

+K. Ainger, Site Engineering Supervisor

+S. Bakhtiari, Design Engineering Supervisor, Mechanical

+G. Beale, OPEN Administrator

+R. Chrzanowski, Technical Staff Supervisor l

+T. Cromeans, Technical Staff Engineer l

+K. Dickerson, NRC Coordinator

+P. Donavin, Nuclear Engineering Supervisor,

Mechanical / Structural

+C. Grasser, Quality Verification Staff

+D. Plauck, Technical Staff Engineer

+G. Ponce, Quality Control Staff

+B. Scharping, Technical Staff Engineer

+S. Stimac, Nuclear Licensing Administrator

+W. Stono, Performance Improvement Director

+D. Wozniak, Technical Superintendent

U.S. Nuclear Reculatory Commission

+B. Burgess, Chief, operational Programs Section

+J. D. Smith, Senior Resident Inspector

+ Denotes those present at the exit meeting on

October 22, 1992.

Other persons were contacted as a matter of course during

the inspection.

2. Licensee Action on Previous InsDection Findinas

2.1 (Closed) Unresolved Item 295/90030-23: Inadequate

engineering evaluations of modifications. The Diagnostic

Evaluation Team (DET) questioned the validity of engineering

evaluations performed for modifications after 1989. There

were-two modifications needing additional review of the

design _ change process. One-case was related to wrong

orifice plates being installed in the 2B emergency diesel

generator-(EDG) lube oil and jacket water cooler. The other

was related to a maintenance valve installed in the reactor

containment fan cooling (RCFC) isolation return header,

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The EDG cooler orifice was a fabrication error which was ]

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detected and corrected by the licenseo prior to installation

and was not a design error. The RCFC maintenance valve

was installed prior to 1989 and therefore was outside the

time period in question. A review of the modification

package and station procedures showed that the DET concern

for a single failure Nas evaluated and appropriate

administrative contrc s were in place. Thlu item was

closed.

2.2 focen) Violg$lon 295/91014-01 Inadequate technical input

for procurement specifications of modifications. The

response and corrective actions to this violation were

reviewed. Part of the licensee's response to this violation

referenced their Eng?7ecring Assurance program Assessment.

This program was self-initiated and examined the licensee's

overall procurement process with special emphasis on

technical input into procurement documents. The Engineering

Assurance Program Assessment report, number EA-91-04,

documented six deficiencies regarding the inadequacy of

providing and reviewing technical input in the procurement

process including generation of procurement specifications.

This report specifically requested that designated design

superintendents develop procedures (QE-83 and QE-51H) to

minimize these six deficiencies.

The inspectors review of the generated procedures, QE-83

(approved in 1991) arid QE-51H (currently in the approval

, process), showed that the procedures did not address the six

deficiencies. The author of the QE-83 procedure, the main

procedure to address these concerns, had not been aware of

! the EA-91-04 report, and therefore did not specifically

address the six deficiencies. The inspectors discussed

these concerns with the licensee staff and they stated that

they would review and modify those precedures as appropriate

, for the response to the EA-91-04 findings. This item

remained open.

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3. The Ouality of the Enaineerina A9tivities

The quality of E&TS management and staff activities was good

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with some weaknesses. Modification packages, and

, evaluations of deviations were typically thorough and

correct. Weaknesses were found with temporary alterations,

a lack of evaluation of component performance data, and

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replacement parts evaluations. This was based on

inspector's reviews, observations, and interviews regarding

routine and reactive engineering functions. Areas reviewed

included modifications, temporary alterations, system

engineer activities, deficiency reports, licensee event

reports, and others.

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3.1 110A1f.1.qit1Rn Packngan

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Modification packages and design engineering performance

were good. Twelve modification packages weto reviewed for

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such items as design assumptions, supporting calculations,

safety evaluations, post-modification testing, and

unroviewed safety questions. No significant concerns were

identified with the modification packages reviewed.

a. The inspectors examined the licensee's modification

package, M-22-2-30-555A/B, replacing Grinnel hydraulic

anubbers with Lisega snuhtars. The inspectors

i ovaluated the licensee's snubber reduction program

developed and coordinated by the Mechanical and

Structural Support (M&S) organization in the corporate

Nuclear Engineering Department. The review identified

a thorough and active involvement by the licensee's M&S

i organization in the snubber reduction program including

performance of the design analysis for two systems.

The inspectors found the extent and quality of the

licensne's effort in this activity to be excellent,

b. The inspectors identified a concern with modification

M22-2-80-47. This modification replaced the starting

air compressors for the emergency diesel generators.

The concern was that local humidity levels were not

clearly specified as part of the environmental

considerations in the procurement specifications. This ,'

omission contributed to the vendor delivering

equipment, that during operation, allowed moisture to

condense in the compressor and drain into the crankcase

oil. Tainted oil E-1s observed by the licenseo

maintenance personnel who took immediate action to

determine the cause of the contamination and to replace

the oil. Licensee technical personnel, with the

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support of the vendor,. analyzed the problem, took

appropriate interim measures, and planned for long term

fixes. Water in the compressor oil did not have an

immediate impact on its operability.

The lack of humidity requirements in the procurement

specification was an example of an inadequate

, specification for which violation 295/91014-01 Vas

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previously 1scued (See paragraph 2.2). Since

corrective actions for the violation were not fully

implemented to prevent this reoccurrence, a violation

is not being issued.

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c. Tne modifications examined in this inspection were as

follows:

• M22-2-87-02C, Increase Steam Generator Blowdown

capacity

• M22-1-88-47C, Replace Diesel Generator Starting

Air Compressor

• M22-2-89-029, Replacing Fuel Transfer Switches

• M22-1-90-09, Replace SI 9012 Cneck Valve with

Different Valve

• M22-2-90-555A and B, Hydraulic Snubbers

Replacement

• M22-1-90-557, Replacing Valve Trim of PCV VC131

• M22-90-559, Cable Tray Siderails Support

Enhancement

• M22-0-90-568C, Heat Exchanger Vent and Drains

• P22-1-91-09A, RC Containment Isolation

• M22-1-91-00VB and C, Containment Isolation Valves

for ILRT

• M22-1-91-576 A, B, or C, MOV Repairs per Generic

Letter 89-10

• M22-1-92-508, Replacing the MCC Cubicle for PP Air

Compressor

No violations or deviations were identified in this area.

3.2 Temporary Alterations (TA)

The inspectors found the temporary alteration (TA) program

adequate with several weak areas. Although training in the

completion of safety evaluations was increased in 1991, the

safety and technical evaluations from 1991 and 1992 were of

inconsistent quality with varying degrees of detail.

Individual TAs were installed that were minor design

modifications and were not given the more detailed review of

the modification process. The age of many TAs and the total

number of active TAs exceeded the goals of the TA program.

Although the TA program was well defined by procedure and

trended by the monthly report, the licensee did not make

progress towards achieving the TA program goals,

a. The inspectors reviewed the temporary alteration

program as outlined in Zion Administrative Procedure

(ZAP) 3-51-4 dated November 14, 1991, titled " Temporary

Alteration Program". The inspectors also reviewed the

September 1992 monthly TA status report, ZAP 2-54-5,

Rev. O, dated Auguot 20, 1992 titled " Safety Review and

Approval", and 14 TAs dated from February 1989 to

July 1992. Individual TAs were reviewed for their

adherence to programmatic and regulatory requirements.

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b. The inspectors reviewed TA 90-053 " CIT Outlet Valve

Leakage Reroute To RCDT" dated June 9, 1990, that had a

possible unreviewed safety question. The TA instalied

a lesh off line to route wator leaking past valves

2MOV-SI-8801A(B) to the reactor coolant drain tank

rather that thermally cycling the cold leg injection

check valves. The rafety evaluation acknowledged a

potential for water hammer, however, it failed to

evaluate a failure of the relief valve on the leak-orf

line draining a portion of the high head injection

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(HHI) lines. The temporary leak-off drain was in a low

! point in the system and an approximate 0.11

l gallons / hour was leaking through the relief valve body. ,

A portion of the HHI line could drain between the

monthly PT-20 stJoke test of the MOV-8801 valves which

i might have resulted in a water hammer affecting all

four injection lines. The inadequacy of t: 1 safety

evaluation was a violation of the requirements of 10

CFR 50.59 (295/92G23-01(DRS)), An engineering

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evaluation performed by the licensee on or about

! October 21, 1992, determined that an unreviewed sefety

question did not exist. 3ased on pipe temperatures,

the licensee concluded that the relief valve Icakage

came from the MOV-8801 valves. That leakage was judged

sufficient to keep the injection lines full.

c. Fourteen TAs reviewed were:

(1)88-119 Unit "0V & PV Systen Felief Dampers"

(2)89-005 Unit 1 "1C FWP Recirc Valve 1 FCV-FW20"

l (3)89-074 Unit 2 "2A Aux FW Pump Lube Oil Cooling

Line"

(4)90-053 Unit 2 " Bit Outlet Valve Leakage Reroute

to Root"

(5)90-056 Unit 2 "2A charging Pump Shaft

Mcnitoring"

(6)91-059 Unit 0 " Alternate Make-up System"

(7)92-001 Unit 1 "4KV Bus Voltage Less than 2990"

(8)92-007 Unit 1 " Install Blower with New Oil

Sight Glass" ,

(9) 92-0016 Unit 0 " Door Alarm for Laundry Trailer"

(10)92-065 Unit 0 " Replace Aux. Bldg. Sump Pump OC"

(11) 92-0071 Unit 2 " Jumper Out Aircraft Crash Damper

Contacts for 2B D/G

(12)92-072 Unit 1 " Disable HX Cooling Water Low

Pressure Trip for Reactor Coolant Sample

Shut Off Valves in #1 Rad Sample System"

(13) 92-0073 Unit 2 "2B RCP Standpipe Low Level Alarm

Lead Lift"

(14)92-076 Unit 1 " Lift Incore Thermocouple R-05

Leads in 1CB116"

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As stated in paragraph 3.2.b, one violation was identified

in this area.

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3.3 Parts Assessmenig

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A brief review of parts evaluations and the parts evaluation

process was performed. Although an overall assessment of

, the parts evaluation program was not made, the following two

concerns were identified:

a. The review and approval process for downgrading parts

from safety-related to nonsafety-related did not

require review from licensed operations personnel or

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system engineers. Without including the system experts

- and individuals with an operations background in the

parts classification process, the adequacy of the

review to determine the safety function (s) of the

part's parent component within a system may be lacking.

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b. The inspectors' identified that the lack of a

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definition for the terms interface, interchangeability,

safety, fit, form, and function introduced

inconsistencies in their use. This was evident in

technical evaluation Z-90-06-1243-00 for a valve in the

diesel generator system. The technical evaluation

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indicated that the part fit, form, or function had not

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changed when w stiffer spring was being used in the

, valve supplied by the vendor. Initial discussions with

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several pacts evaluators revealed that changing the

spring stiffness was not considered a change to the

, form or fit of the spring. However, further discussion

with the evaluators on the definition of the terms

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been changed. The adequacy of procedural guidance for

performing material engineering technical evaluations

and alternate replacement parts evaluations is

considered an open item. (295/304/92023-02(DRS))

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j One open item was identified in this area.

3.4 Correctino De(igiencies and Adverse Trends

In general, the corrective action of engineering

deficiencieu and adverse trends was good. Weakness was

identified in that root causes determinations, and

! coordination between system engineers and specialty groups

within the technical staff were not always adequate. The

l inspectors reviewed numerous Deviation Reports (DVR),

Discrepancy Records (DR) and Problem Identification Forms

(PIF) to evaluate the level and quality of engineering

involvement in correcting drficiencies. Based on the

j review, several concerns were identified.

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l a. DVR 22-1-91-142 was written as a result of an interlock

failure identified on December 28, 1991, during the

performance of PT-2C-D-ST, "ECCS Valve Stroke and

Interlock Test (Heatup)". Valve 1MOV-SI8804A

(discharge valve from RHR pumps to charging pumps)

failed to open with 1MOV-RH8701 (suction valve from RCS

to RHR pumps) closed. The DVR evaluation concluded

that inadequate maintenance on 1MOV-RH8701 was the root

cause. Electricians failed to recognize the

requirement to adjust the rotor with the interlock

contacts. The inspectors identified that an additional

contributor was inadequate testing following

maintenance performed on 1MOV-RH8701 in March, 1991.

Specifically, PT-2C-D-ST was not performed as part of

the post-maintenance testing. The failure to perform

adequate post-maintenance testing is a violation of

10 CFR 50, Appendix B, Criterion XI-

(295/92023-03(DRS)). The inspector identified three

additional factors which contributed to the

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significance of this violation. First, the DVR

l evaluation failed to identify inadequate post-

maintenance testing as leading to the failure. Second,

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! review of subsequent maintenance performed on the RHR

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pump suction valves revealed that in July, 1992, limit

switch maintenance was once again performed on one of

the valves without the requirement for the interlock

test. Finally, with the interlock inoperable, the ECCS

was degraded for nine months in its ability to be lined

l up for cold leg recirculation.

I b. DVR 22-1-92-039 and DR 92-0045D were generated when two

of three pressurizer safety valves set pressures were

outside the Technical Specifications allowable band.

The DVR evaluation indicated that a root cause analysis

l of the valve failures could not be performed since the

technical staff was not notified of the failure until

l after the valves received maintenance. The corrective

action established to ensure a root cause analysis

could be performed in the future was to add a step in

, the valve testing procedure to notify the technical

staff if problems were encountered during testing.

Since a step already existed to notify the inservice

inspection (ISI) group within the technical staff, the

corrective action tracking item was closed out without

action. During review of the event, the inspector

determined that the ISI group was properly notified,

but fie information was only documented in a log and

was r et analyzed, trended, or communicated to the

prima , systems group within the technical staff. As

a result, the inspector concluded that the corrective

actions taken to prevent recurrence were inadequate.

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! The inspectors questioned whether this event was

j reportable to1the NRC. The two relief valves-lifted

during testing more:than 5% below the specified set. D

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point. This was at or close to the set point-for the  !

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power-operated relief valves with a potential for'

q simultaneous _ lifting. A revi'ew of the reporting

! guidance provided in NUREG 1022, Rev 1, was not-

l conclusive as to the reportability of relief valves. ,

! found out of. tolerance when a plant is shut down. This

matter was reviewed with the licensee staff who

j acknowledged that their reportability guidelines did

not address relief valves being significantly out of

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tolerance. This concern is an unresolved item under-

review by the NRC (295/92023-04(DRS)).

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j^ c. PIF 304-554-91-CAT 4-150 was generated when the 2B SI-

pump suction valve failed to stroke open on October-31,

i 1991, during performance test FT-2A, " Safety Injection

j system Tests". During trouble shooting, 4

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3 strip charts indicated abnormally high current during

} valve closure, before the torque switch contacts

opened. The 1991 PIF evaluation noted that a strip

j chart from July, 1990 also showed an abnormally high

l rise in current prior to torque switch-trip, but failed

to recognize this as unacceptable.- Rather, it-

! characterized the chart as a trend. The procedure for

! evaluating strip charts was re"iewed.and found to lack

, detailed guidance. Procedural guidance:and train 4.ng-

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relating to MOV strip charts is considered an open-

item. (304/92023-05(DRS))

!* One violation, one unresolved. item, and one oran item were

j identified in this area.

l 4. Extent of Encinegrina Involvement

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Through interviews with operations, maintenance, design

l engineering,;and technical staff personnel, and review of

! various technical staff. engineering positions, the-

l inspectors concluded that, overall, the extent of

l engineering involvement in support of the station was good.

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! 4.1 Technical Staff

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l Involvement by the technical staff was good with respect to

l knowledge.of assigned systems, system walkdowns and daily

i -plant status. However, the following weaknesses were

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a. Component trending performed by the-technical staff was

! minimal. Although component. failures were logged, in

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the= cases of the out-of-tolerance rellaf valves and

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the Mov motor currents, an analysis of information was

not performed that could have been used to improve

component reliability.

b. System engineer involvement in' correcting deficiencies

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for components within their system was lacking when

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specialty groups (such as the MOV and ISI groups)

within the technical staff were ultimately responsible

for the review. As a result, system engineers were-not

always aware of component problems within their system,

c. Improvement was noted by operations and maintenance

personnel in the system engineers' understanding of

. system-related procedures. Interviews indicated,

however that lack of comprehensive system knowledge

places some system engineers at a disadvantage when

dealing with operations and maintenance.

4.2 Site Engineering

Site engineering was established on site in 1992 with

technical staff engineers and design engineers relocated

from the corporate office in Downers Grove, Illinois.

Interviews with site design engineers indicated that the

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engineers were finding the proximity to the site and other

station engineering groups beneficial for resolving issues.

4.3 Encineerino Manacement

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Jngineering management involvement was evident. Significant

changes had been made to improve engineering functions,

however, two areas inspected were weak. The initiatives and

weaknesses are discussed below.

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a. The reorganization of the engineering groups included

relocating personnel to the site and establishing a

site engineering organization. It also separated

responsibilities for most modifications from the

technical staff and gave them to specific engineering

groups.

b. Management had increased its expectation that engineers

review the products of engineering contractors. The

design engineering staff members interviewed were aware

of this expectation and were performing these reviews.

As a result, substantive comments were being

transmitted to the contractors. This is significant

and positive since the licensee is transferring its

primary engineering services contract from Sargent

and Lundy to ABB Impell.

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c. The temporary alteration (TA) program had several

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indicators of weak performance. As discussed in

paragraph 3.2, the station was not meeting its goals

for either the total number of TAs (approximately 60

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were active) or age (17 were over 2 years old). The

safety and technical reviews were not always rigorous

enough to support the potential impact an alteration

might have. Also, periodic reviews of TAs appeared to

provide little or no enhancement of TA safety or

reliability. This area was discussed with the licensee

managers who stated that specific plans would be

developed for the elimination of each TA and that the

evaluation and review programs for TAs would also be

examined. The licensee is also developing a procedure

for " exempt modifications" which will provide a more

efficient process for minor modifications. This may

alleviate the motivation to use TAs for design changes.

d. The licensee formed a performance monitoring group in

the technical staff. This group will correlate

• equipment performance data from all station departments

and issue periodic reports on trends. This group will

also be responsible for implementing trending to meet

the maintenance rule which will be based on reliability

studies. These studies were not completed and it will

, be a couple years before this program is working.

Based on the weaknesses observed by inspectors with

equipment trending for relief valves and MOVs, the

licensee missed opportunities to avoid equipment

i failures by not performing more evaluation of equipment

. performance data.

e. The licensee had initiated an " Integrated Reporting

Program" consolidating most of the stations problem

reports. The program created a single problem report

mechanism using a " Problem Identification Form (PIF)."

The data in this program allowed the licensee to

identify some specific performance indicators for

different organizations. The indicators for

engineering were newly established, but the program

demonstrated the ability to identify trends which may

lead to problems in areas such as foreign material

, exclusion and radiological controls.

No violations or deviations were identified in this area.

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5. Unresgived Items

Unresolved items are matters about which more information is'

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required in order to ascertain whether they are acceptable

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items, violations, or deviations. An unresolved item

disclosed during the inspection is discussed in

Paragraph 3.4.b.

6. Qpg1 Items

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Open items are matters which have been discussed with the

licensee, which will be reviewed further by the inspector,

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and which involve some action on the part of the NRC or

licensee or both. Open items disclosed during the

, inspection are discussed in Paragraphs 3.3.b. and 3.4.c.

Exit Meetina

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4 The inspectors met with the licensee representatives (see

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Paragraph 1) on October 29, 1992, to conclude the

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inspection. The inspectors summarized the inspection

purposa, scope, and findings. The licensee acknowledged the

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information and did not identify any information as

proprietary.

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