IR 05000295/1988019
| ML20206M147 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 11/25/1988 |
| From: | Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206M139 | List: |
| References | |
| 50-295-88-19, 50-304-88-19, NUDOCS 8811300449 | |
| Download: ML20206M147 (21) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos. 50-295/88019(DRP);50-304/88019(DRP)
Docket Nos. 50-295; 50-304 License Nos. DPR-39; DPR-48 i Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion, IL Inspection Conducted: August 24 through November 10, 1988 Inspectors: M. M. Holzmer P. L. Eng *
T. Tongue :
Of. ):~s.w fn= ,
Approved By: J. M. Hinds, Chief N- Ji- 6 8 '
Reactor Projects Section lA
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Date Inspection Summary j Inspection from Aug"*t 24 through November 10, 1988 (Report No /88019(DRP); be-304/86019(DRP))
Areas Inspected: Routine, unannounced resident inspection of licensee ac'. ion C on previous inspection findings; summary of operations; October 8,1988, Unit 2 reactor trip; October 12, 1988 Unit 2 reactor trip; October 19, 1988, i'
Unit 2 power operated relief valves (PORV) valve block sl!ppage; determination of motor driven auxiliary feedwater pump (MDAFP) inoperability due to ;
anti-pump circuitry; operational safety verification and engineered safety '
feature (ESF) system walkdown; surveillance observation; maintenance ,
observation; LERs; training; quality program effectiveness; and followup on i Part 21 notification on Cooper-Bessemer fuel nozzle tip Results: Of the 13 areas inspected, no violations or deviations were identified ,
in 11 areas, and two violations were identified in the remaining 2 areas l (inadequate corrective actions for maintenance of boric acid tank (BAT) boric ,
acid concentration - paragraph 8; failure to maintain pump vibration treasure- !
ment points - paragraph 9.) While not indicative of nonconservative coerations, :
the first violation demonstrated a failure by the plant staff to implement ;
aggressive actions to ensure that boric acid concentration did not drift ;;elow required limits, despite previous similar occurrences. A second concern was identified in that when BAT concentration was identified to be below required t
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limits, the licensee did not initiate a power ramp down during the two hour i
c G811300449 881125 DR ADOCK0500g{j5
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and 35 minute period when the plant was on a four hour LCO cloc The licensee exited the LCO by restoring BAT concentration to within limits with one hour and 25 minutes remaining. While this approach to operations was not strictly conconservative, it left little margin for errors or unexpected prob' ems had efforts to return SAT concentration to within limits been uns9ccessful. The second violation resulted from lack of coordination of activities conducted by different departments. A related concern was the licensee's continued performance and evaluation of surveillance tests without obtaining test data is required by the ?rocedure. Four new unresolved items were identified as follows: (1) determination of cause for reactor trip -
paragraph 5, (2) evaluation of licensee actions regarding snti-pump feature effects on ESF components - paragraph 7, (3) determination of adequac certain environmentally qualilled (EQ) splices - paragraph 8, and (4)y of verification methods for remote position indicators for valves - paragraph !
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DETAILS
. Persons Contacted
- +*G. Pliml, Station Manager
- E. Fuerst, Superintendent, Production
- T. Rieck, Superintendent, Services W. Kurth, Assistant Station Superintendent, Operations
- R. Johnson, Assistant Station Superintendent, Maintenance
- J. Gilmore, Assistant Station Superintendent, Planning
- R. Budowle, Assistant Station Superintendent, Technical Services
- N. Valos. Unit 2 Operating Enginee-M. Carnahan, Unit 1 Operating Engineer
- R. Cascarano, Technical Staff Supervisor A. Ockert, Training Supervisor
- D. Felz, Quality Assurance Inspector V. Williams, Station Health Physicist C. Schultz, Quality Control Supervisor
- +*W. Stone Regulatory Assurance Supervisor W. T'Niemi, Master Mechanic A. Bless, Regulatory Assurance Enginear
- B. Soares, ISI/IST Group Leader
- W. Palmer, Financial Coordinator
+T. Vandevoort, Quality Assurance Superintendent, Zion Station
- Indicates persons peter.: at the exit interview on October 14, 198 + Indicates persons present at the exit hterview on November 7,198 # Indicates persons present at the exit interview on November 10, 198 . Licensee Actions on_ Previous Inspection Findings (92701, 92702)
(Closed) Open Item (295/85022-02(DRP); 304/85023-01(DRP)): Problems with implementation of the modification which installed the system particulate iodine and noble gas (SPING) radiation monitors. Based on a review of avai)able records and through interviews with licensee personnel, the inspec. tor detemined that identified discrepancies were corrected. This item is close (Closed) Open item (295/86028-02(DRP); 304/86028-02(ORP)): Automatic start of OC Component Cooling (CC) pump. This was apparently caused by vibrations induced in the black cut timer relay by personnel working in the associated relay cabinet. The inspector verified that Electrical Maintenance procedure E-023-1 "Eagle Signal Timer Inspection and Lubrication Procedure" had been modified to irclude a precaution to use extra caution while servicing safeguards timers. This item is close (Closed) Violation (295/86022-01(DRP)): Boric acid solution was not on continuous recirculation through the boric acid tank for a period in excess of four hours on July 23, 1986. The inspector reviewed the liceasee's implementation of corrective actions for verification and found the folicwing:
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' Zion Administrative Procedure (ZAP) 14-51-2 "Inspection Test and Operating Status--Tagging of Equipment," was modified to ensure that independent field verification of boric acid system lineups would be performed.
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1 ZAP-10-53-3 '"Shift Relief and Turnover," was revised to incorporate j INPP guidelines in order to improve the shif t turn-over process and orerator awareness of overall plant statu The out-of-service card sheets were rearranged alphabetically by unit and by system for improved review of system status, Periodic Test (PT) Procedure PT-14 "Inoperable Equipment Surveillance Tests," implements a unit log sheet listing required surveillance tests. It also has Appendix A which lists special surveillances, required intervals and the applicable Technical Specifications, System Operating Instruction (501) -3 "Boron Recycle System," was modified to assure that the existing boric acid anc spent fuel pool system status boards are kept up to date. The inspector verified that the instruction is under Section 6 "Precautions," of the procedur This item is considered close (Closed) Open Item (295/86019-06(DRP); 304/86018-05(DRP)): Licensee corrective actions for Licensee Event Report (LER) 295/85021-01 required a change to 50I-63 "Electrical Power and Lighting," requiring operators to review Zion Electrical Distribution (LED) -2 "120 VAC Instrument Distribution" precautions in order to prevent inadvertent interruption of power to the source range nuclear instrumentation and cycling reactor trip breakers. The inspector reviewed 501-63 and verified that pertinent sections required the operator to review the precautions of ZED-2. In addition, the inspector verified that the precaution in ZED-2 is appropriate. This item is close (Closed) Violation (295/86011-01 (DRP)): Loss of both trains of engineered safety feature (ESF) logic due to pulled fuses. The licensee modified ZAP 5-51-3 "Procedure Periodic Review" to include a check list for periodic procedure review of operating procedures. This includes
"Human Factor" items and also references INPO Gnod Practice Item OP-21 The inspector reviewed the latest revision of ZAP 5-51-3 for verification. This item is close (Closed) Violation (295/84013-01(DRP); 304/84013-02(DRP)): Failure to control flamable or combustible materia The licensee developed and implemented a fonn for issuance and control of flamable/ combustible materials in safety related areas. In addition, the licensee has implemented specific controls for storage and use of flamable and combustible liquids in accordance with Chapter 5 of National Environnental Policy Act (NEPA) #30 "Flamable and Comoustible Liquids
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i Code." This was implemented through ZAP 04 "Station Housekeeping / Fire l
i Protection." The use of NEPA #30 for control of flamable or combustible materials is approved by NUREG 0800, NRC Standard Review Plan, Branch
, Technical Position 9. This item is close _ (Closed)UnresolvedItem(304/88016-01(ORpH: Review of licensee's therinal stress analysis for auxiliary feedwater (AFW) piping. The
subject analysis was received on August 15, 1988 thereby fulfilling the last item of Confirmatory Action Letter (CAL) CAL-RIII-88-017-1. The CAL was lifted by letter from A. B. Davis to C. Reed, dated August 3, 1988, with the understanding that the subject analysis would be provided to the resident inspector office.
- The subject analysis assessed the effects of thermal cycling on the Unit 2 AFW piping conducted during corrective maintenance activities associated with backleakage from the steam generators as discussed in inspection report 295/88013; 304/88014 The inspector noted that the pipe stress use factor due to themal cycling of the Unit 2 AFW piping during the current fuel cycle was determined to be 0.488. When the use factor reaches a value of 1, the safety margin inherent in the pipe strass analysis begins to be compromised. Since the use factor of 0.488 was achieved during the current Unit 2 fuel cycle alone, the inspector asked whether cumulative thermal cycling over the life of the plant had been evaluated. The licensee stated that such an evaluation had not been conducted; however, non-destructive examination (NDE) was scheduled for the Unit 2 refueling outage beginning October 13, 1988, and that the affected piping would be inspected more frequently in the future. This practice would ensure that pipe degradation would be identified prior to catastrophic failur Review of the NDE results of the AFW piping and l the administrative controls to assure that affected piping will be '
inspected more frequently in the future is an Open Item (304/88019-01(DRP)).
Discussions between Pressurized Water Reactor Engineering (PWRE) and the inspectors were necessary to determine whether the licensee's analysis adequately addressed the inspectors' concerns. The cases analyzed, including initial conditions and basic assumptions were not well documented in the stress report in that some terms were not defined, e.g., the system configuration used for the "norual operations," and "two unique reverse flow rates." The inspectors also noted that the graphs depicting component heat up rates did not identify which configuration was analyzed. Consequently, additional efforts were necessary to evaluate the adequacy of the analysis. The inspectors noted that the analysis had been performed in a relatively cort time frame in response to the referenced CAL. This item is close fClosed Unresolved Item (295/87009-01(DRS); 304/87011-02(DRS)):
installation of environmentally qualified (EQ) trarsmitters with electrical leads landed on non EQ termina'. blocks. This item was unresolved pending NRC review for compliance with IQ enforcement guidance. By letter from A.B. Davis to J.J. O'Cor nor dat.ed October 19, 1988, the NRC transmitted a Notice of Violation for these
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installations. The violation was classified as EQ Category C. This item is close No violations or deviations were identified. One Open Item was identifie . Sumary of Operations
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Unit 1
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The unit operated at power levels up to 99% until October 25, 1988, when j the Unit was shut down to Mode 3 to modity ESF logic circuitry. Circuit ;
modifications were completed and the unit brought back on line on November 4,1988.
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i Unit 2 (
, The unit operated at power levels up to 99% for the entire inspection
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period until October 8, when the reactor tripped from 56% power. The ,
l unit was subsequently made critical and tied to the grid on October The unit then operated at power levels up to 99% power until the unit '
tripped on October 12, from 94% power. Since the unit was scheduled to
- begin its refueling outage on October 13, the licensee opted to begin the outage immediately following the trip. The refueling outage is currently
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scheduled tc end on December 22, 198 '
No violations or deviations were identified, f October 8,1988 Unit 2 Reactor Trip (93702) I e
! On October 8,1988, at 2:52 a.m., Unit 2 tripped from 56% power on high !'
negative flux rate when control rod C-11 dropped into the core while the Ifcensee was troubleshooting a rod control system urgent failure. All (
) safety systens functioned properly following the trip and the plant was 4 stabilized in Mode The urgent failure occurred while performing periodic rod exercise tests }
required by Technical Specifications (TS). Rod C-11 dropped when the -
stationary gripper coil fuse was pulled during troubleshooting. Pulling 4 the fuse to the stationary gripper coil while an ur;ent failure is ;
present would not normally cause the control rod to drop because the i urgent failure should cause the moveable gripper coil to be energiz t holding the rod in place. Investigation by the licensce revealed a fault i on the pulser / oscillator card in the rod control logic cabinet. This ;
fault appears to explain both the urgent failure alarm and the dropping >
of rod C-11 when the stationary gripper coil fcse was removed. The faulted logic card was replaced and the rod control system retested l satisfactorily, i
The licensee restarted Unit 2 following xenon decay. In addition to the f faulted card, problems with some rod control fuses were also noted in :
- connection with the rod exercise tests. The licensee replaced the i i
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necessary fuses prior to startup. Additional information pertaining to this event can be found in par 1 graph 11 of this report.
- No violations or deviations were identifie . October 12,1988 Unit 2 Reactor Trip (93702),
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On October 12,1988, at 1:36 p.m. , U..it 2 tripped from 94% power due to a
]. turbine trip. The turbine trip was caused from an apparent low condenser vacuum input to the turbine protection syste i Prior to the turbine trip, an instrument mechanic (IM) was performing a calibration of the low condenser vacuum alarm pressure switch. Operators had previously noted that the alarm did not sound when the setpoint was reached and had initiated a work request for an alam calibration. The IM proceeded to the low vacuum alam sensing line where he initially had
, some difficulty locating the correct pressure switch because components in the area were not labelled. The alarm sensing line taps off of the turbine trip block which senses condenser vacuum directly. The turbine trip block, upon sensing low condenser vacuum, generates a turbine trip for turbine protection. The IM did not isolate the alam sensing line
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from the turbine trip block, therefore when the alam pressure switch fitting was disconnected, the turbine trip block was vented to atmospher resulting in te turbine tri l Review of the LER including identification of the root cause and associated corrective actions will be tracked as an Unresolved Item (304/88019-02).
No violations or deviations were identified. One Unresolved Item was
- identifie . October 19, 1988 Unit 2 PORY Valve Block Slippage (93702)
On October 19, 1988, at approximately 11:00 p.m., with Unit 2 in cold t
shutdown, and pressurizer level at 80%, a licensed operator noted that both pressurizer power operated relief valves (PORVs) indicated close The licensee was aligning plant systems for the containment integrated leak rate test (ILRT) which required that instrument air to the Unit 2
. containment be isolated and that the RCS be vented to containmen PORVs are air operated valves which fail closed upon loss of air, therefore, the licensee had installed mechanical valve blocks on the valve stems in order to maintain low terperature over pressure (LTOP) protection. Zion Technical Specification (TS) 3.3.2.G requires that 2 PORVs be operable
, and capable of relieving reactor coolant system (RCS) pressure with a l setpoint of 435 psig or RCS pressure be less that 100 psig and pressurizer level less than 25%.
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containment and verified that the valve blocks had slipped allowing the
! PORVs to go closed. The licensee successfully blocked both PORVs open
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using a different valve block design at approximately 8:30 a.m. and exited the TS limiting condition for operation (LCO).
j The inspector reviewed the status of the RCS and the associated available
.j vent paths and determined that due to the unusual ILRT valve lineups, two
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alternate vent paths existed. Evaluation of plant configuration against LTOP accident initiators revealed that sufficient RCS overpressure
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protection was available for both the heat and mass addition accident Since two alternate operable RCS overpressure relief paths of sufficient capacity were in place, the licensee concluded that LTOP protection was i not compromised.
! The inspector noted that a mechanical block similar to those initially i
used on the PORVs had previously failed to perform its function as documented in LER 295/87016. The licensee noted that the valves of 1 interest were of a different design in that the valve discussed in the
LER was a motor operated valve, while the PORVs are air operate However, review of the LER in light of failure of the PORV blocks revealed that additional concerns regarding installation of mechanical valve blocks need to be addressed. The licensee stated that it would l conduct further investigations of appropriate methods for blocking I
valves, including discussions with various valve manufacturers.
i Determination of appropriate valve blocking methods by the licensee is l considered an Open Item (295/88019-01(DRP); 304/88019-03(DRP)).
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No violations or deviations were identified. One Open Item was identified.
- Determination of MDAFP Inoperability Due to Anti-Pump Circuitry (9370L 1 37700, & 37828)
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l On October 25, 1988, at approximately 11:30 a.m., the licensee determined that a deficiency in the control circuit for the motor driven l auxiliary feedwater pumps (MDAFPs) would prohibit the MDAFPs for both
units from performing their functions in the event of a loss of off site
! power (LOSP). Unit I was at 50% power and Unit 2 was in a refueling
' outage. As a result, the licensee declared both NDAFPs for Unit 1 inoperable and brought the unit to Mode 3 Hot Shutdown.
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CHRON0 LOGY l
l The licensee had successfully perfomed Technical Staff Surveillance i (TSS) 15.6.35, " Manual Actuation of the Safety Injection and Safe
! Shutdown Systems and Diesel Generator Loading Test " and TSS 15.6.43, "
i Endurance Testing of Diesel Generator During Refueling," (TSS 43) and
. although the test data met test acceptance criteria, results were j forwarded to Pressurized Water Reactor Engineering (PWRE) for infoma-j tion at the request of an engineer who had recently transferred from
[ Byron Station.
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The anti-pump concern was identified by the licensee during followup of an anomaly on the CCW pur:p breaker position trip chart trace. TSS 43 removes power to an Engineered Safety Featurr , (ESF) bus while at
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) the same time, simulat'ng station blackout condition for that bus. A
- station blackout results in tripping breakers to 4160 volt ESF component i Consequently, the CCW pumps coasted down, resulting in the CCW discharge a
header low pressure condition. This trip signal remains until the
associated diesel generator energizes the ESF bus. Under normal circumstances, low CCW header pressure results in an auto start signal to
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the available CCW pumps to bring header pressure back to normal operating i values. If simultaneous close and trip signals were present for the CCW
{ pump breaker, the anti-pump feature would and seal in, inhibiting CCW pump start until the breaker closure signa * is remove !
l The anti-pump actuation of the "stripped" CCW pump did not inhibit the t blackout sequenced CCW pump start because the second available CCW pump auto started and removed the low discharge header pressure condition
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before the blackout start of the pump being tested was required. TSS 43
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had historically been performed with at least three CCW pumps running to I stlpport plant conditions; however, during this TSS 43, only two CCW pumps l were running. CCW pump circuit breaker traces initially showed that the i pumps were tripped off from the blackout signal and almost immediately
- received a auto start signal from the low discharge header pressure
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signal.
i j This current trace anomd y, coupled with the recent issuance of IE i Infomation Notice 88-)S, " Disabling of Diesel Generator Output Circuit j Breakers by Anti-Pumr. Circuitry " caused the licensee to perfom more i detailed reviews of those circuits for which conflicting pump logics
! could occur. The licensee identified that simultaneous start and trip signals would actuate the anti-pump feature and inhibit pump starts for auxiliary feedwater (AFW), service water (SW) and CCW system SW pumps
. receive auto start signals on a low discharge header pressure as do the i CCW pumps, however, a review of the pump control logic circuitry revealed
- that signals generated from a blackout do not actuate the anti-pump i feature for SW. Further investigation revealed that the SW anti-pump
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circuitry is actuated on a 2/2 degraded voltage on any one engineered safeguards features (ESF) bus.
1 With regards to AFW, the licensee identified that a blackout signal in conjunction with a low low steam generator condition would invoke the
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anti-pump fer.ture. Given that a station blackout with the Unit at 100%
! power results in an essentially instantaneous low low steam generator level due to level shrink, the licensee decided to declare both motor l
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driven AFW pumps (MDAFPs) inoperable and to comply with TS 3.7.2. The i TS requires that with two MDAFPs inoperable, one pump be restored within j 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or the unit brought to Mode 4 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The unit 1 was shut down and stabilized in Mode The turbine driven AFW pump was
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i l Following discussions with Westinghouse, the licensee concluded that with l the Unit in Mode 3, a blackout would not cause a steam generator level shrink of sufficient magnitude or quickly enough to invoke the anti-pump feature. Therefore, the MDAFPs could be declared operable in Mode 3 and l
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cool down to Ptode 4 was not necessary. This conclusion was discussed between Region !!! and NRR who concurred with the licensee's positio CORRECTIVE ACTIONS A standing order was issued to ensure that operators were infonned of anti-pump circuitry effects on the pertinent systems and a modification was performed to the Unit I logic circuitry. Modifications to the corresponding Unit 2 circuits will be completed prior to the end of the current refueling outag FINDINGS The inspectors witnessed portions of the modification installation and ,
the post modification tests. On October 30, an inspector from the regional office was dispatched to conduct further investigations of this event. Review and determination of the adequacy of the licensee's actions regarding resolution of anti-pump circuit effects on ESF componentsisanUnresolvedItem(295/88019-02(DRS);304/88019-04(DRS)).
At the conclusion of the post modification testing for ESF bus 149, the inspectors noted that the Operations Analysis Division (OAD) electronic timer used for setting the Agastat relays which allow resetting of the blackout and safety injection (SI) timers appeared to behave erraticall Observed anomalies included arbitrary addition or subtraction from indicated times. All the Agastat relays were reset using a calibrated stopwatch. The licensee stated that all safety related equipment which required timing was verified operable using approved plant procedures and calibrated equipment controlled and administered by the plan Discussions with members of the Northern Division 0AD staff indicated that the electronic timer was seldom used on Agastat relays and that System OAD in Maywood would perform tests to deternine the cause and frequency of the electronic timer discrepancies. Completion of OAD's investigation and review by the inspector is an Open Item (295/88019-03; 304/88019-05(DRP)).
On November 125-88, the OD 2,1988, component while preparing)to cooling start (CC pump modification automatically test TSSP started. The pump start occurred when the control board switch for the OD CC pump was moved from the pull-to-lock to the after-trip position, which should not have caused a pump start. A preliminary investigation revealed that a metal shaving had faller onto the train A safety injection (SI) timer for bus 148, shorting across a contact pair associated with the safeguards start of the OD CC pump. The shaving was recoved alleviating the p roblem. Additional inspection on this event will be performed during review of the licensee's LE No tiolation. or deviations were identified. One Unresolved item and one Open item w ' identifie _ _ _ _ _ _ _ - _ _ _ _ _ _ . _ _ _ _ ________-_ _ - _ _ _ _ _
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, Operational Safety Verification and Engineered Safety Features System Walkdown (71707, 61715 & 71710) '
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The inspectors observed control room operations, reviewed applicable logs and ,.unducted discussions with control room operators from August 24 -
through flovember 14, 1988. During these discussions and observations, the inspectors ascertair.ed that the operators were alert, cognizant of l plant conditions, attentive to changes in those conditions, and took !
prompt action when appropriate. The inspectors verified the operability l of selected emergency systems. Tours of the auxiliary building, turbine i building and crib house were conducted to observe plant equipment :
conditions, including potential fire hazards, fluid leaks, and excessive l vibrations and to verify that maintenance requests had been initiated for l equipment in need of maintenanc The inspectors by observation and direct interview verified that selected l physical security activities were being implemented in accordance with [
the station security pla ;
The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. From August 24 to fiovember 14, 1968, the inspectors walked down the accessible portions i of the service water and auxiliary feedwater systems to verify !
operabilit '
i These reviews and observations were conducted to verify that facility I operations were in conformance with the requirements established under :
Technical Specifications,10 CFR, and administrative procedure (
i FINDIfiGS [
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- The inspNtors reviewed the licensee's training lessin plans and e
,nmcedures for plant operation during refueling whilo in mid loop configuration. The inspectors noted that the licenste was voluntarily conforming to the guidelines and recommen1ations delineated in the Westinghouse Owner's Group guidelines. Some of the recommendations included refresher training of opetstors on abnomal operating procedures regarding mid loop operatnns and discussion of the Diablo Canyon April,1987 loss of RCS 10ventory event; provision of at least two operable reactor vessel tr.armocouples during reduced RCS inventory operations; availability of wn operable independent level indication systems during mid loop cnd drain down operations; provision of two means of addin inventery to RCS as a backup to the residual heat removal (RHR)g pumps, end provision for closure of containment within 30 minutes should tae need arise. Implementation of the recormendations was adequite and properly documente Two scaffolds were found erected near the Unit 1 feedwater regulating valves and an access ladder was found tied to the feedwater regulating valve instrursent sensing lines, during a routine walk through of the plant. Investigations revealed that a new Zion Adminstrative Procedure (ZAP) 8. "Use of Scaffolding
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and Ladders," was issued on July 28, 1988; however, the scaffolds
and ladder observed by the inspector had been erected prior to j implementation of the new ZAP. Additional scaffolding concerns were identified in the 1A residual heat removal pump room, crib house and Unit 2 containment.
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The licensee stated that a designated Scaffold Coordinator had been appointed to ensure that all scaffolding in the plant was erected securely and in a manner that did not endanger plant equipment. The inspector suggested that remedial actions to protect plant equipment might be necessary for scaffolding erected before issuance of the ZAP The licensee acknowledged the inspector's coments and stated that all scaffolding would be reinspected in light of the inspector's corr.nents and observation At approximately 9:15 a.m. on September 16, 1988. Unit 2 entered a four hour limiting condition for operation LC0 required by TS 3.2.1.F. when the boron concentration of the OC boric acid tank (BAT) was found to be less than 11.5 weight percent (w/o) boro The licensee resampled several times while adding batches of boric acid to restore the boron concentration of the OC BAT to within TS limits. The licensee exited the LCO at 11:50 a.m. when OC BAT concentration reached 11.6 w/ The OC BAT has been continuously diluted for several months due to leakage of water into the BAT, requiring frequent boric acid additions in order to maintain OC BAT concentration within TS required limits. On May 28. and August 4,1988, similar incidents of OC BAT boric acid concentration being found below the TS minimum occurred. The licerace's corrective actions for these previous events included issuance of a Standing Order (50) re. quiring increased BAT sampling frequency, more frequent acid additions and instructions to maintain OC BAT boric acid concentration well above the minimum value of 11.5 w/o. These corrective actions were not effective to prevent recurrence of low OC BAT boric acid concentration. Failure to implement effective corrective actions to preclude recurrence of low OC BAT boric acid concentration is a violation of 10 CFR 50, Appendix B, Criterion XVI (304/88019-06(DRP)).
- The inspectors also expressed concern that Unit 2 was two and one half hours into a four hour LCO, and the unit remained at 100%
power. At 11:50 a.m. when a sanple of OC BAT was found within TS limits, the licensee would have had only 1 hout and 25 minutes in which to conduct an orderly shutdown and dilute the reactor coolant system to the cold shutdown baron concentration had the sample yielded a concentration less than 11.5 w/o. The licensee stated that OC BAT samples indicated an increasing trend in the boric acid concentration, and that BAT concentration was expected to be within specifications before the expiration of the LCO. The licensee also stated that ruping reactor pct:er down only to return to full power after OC BAT boric acid concentration had been restored to TS limits was not a good operating practic ?
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The inspector stated that while the licensee did not violate ,
TS requirements, there was little margin for error had the 11:50 l sample result been below the minimum TS required value. In addition, !
the inspector stated that ramping down and back up was no less conservative than load follow operations practiced at the station, except for power ramp rates. The inspectors noted that the licensee's delay in initiating a ramp down while not "nonconservative",
was less conservative than NRC expectations. The licensee is i reviewing their operating policy to determine whether changes need to be made to eddress the inspector's concer Some operating documentation deficiencies were noted in that operators were not initiating Standing Orders prior to performing (
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duties on shif t. In addition, temporary changes to procedure MI-1 l
"Isolating and Draining the Reactor Coolant Loops" were made in a manner which did not delete superseded steps and pages, required !
renumbering of all subsequent steps, and made use of scotch tape to l implement changes. Confusion resulting from procedure changes was ;
considered a weakness during the previous SALP evaluation. A letter i was issued to provide more specific directions to individuals who .
execute changes to procedure On October 16, 1988, the licensee identified that an ESF valve, (
0 FCV-SW54, the service water (SW) strainer backwash isolation '
valve, was in the mid position when it should have been fully ope l Because the licensee was unable to promptly determine whether or '
not the valve had stroked from an ESF signal, the event was i conservatively reported to the NRC on the Emergency Notification i System (ENS). When the resident inspector was informed, the ;
licensee was asked in what position the valve would remain until l repairs could be completed. The licensee stated that the valve was :
left in the open position. Because the ESF position of the valve !
is closed, the resident inspector suggested that the licensee review {
their decision, after which, the valve was declared inoperable and !
left in the closed position until the completion of repair Additional followup of this event will be performed during a review !
of the licensee's LE !
- Material condition tours identified numerous oil, steam and water f leaks, and several concerns associated with safety related cabling !
in the 579' elevation Unit 2 pipe chase. An additional tour was [
conducted with a Sargent and Lundy engineer and a licensee engineer [
in this space to catalog all cabling concerns. It was verified that !
all identified concerns were already recorded by licensee I inspections as a result of findings during the 550MI (In:pection Report 295/88003(ORS)), although the licensee elected not to label the discrepancies in the fiel There was a decline in the material condition of some spaces in the plant, especially the crib house, where packing leakage from both the motor driven fire purp and service water strainer backwash valves caused water to cover large areas of the floor in the service
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water pump ba In addition, the number of alarming annunciators, or inoperable instruments in the control room is higher than in the past. The licensee took interim corrective actions to stop the SW 1eaks in the crib house, which improved the condition of the SW pump bay. A review of completed annunciator work was also done, which resulted in the removal of about 25 unnecessary work request j stickers from the control boar Several tours were conducted in the unit 2 containment, one of which i was done with the Services Superintendent. These tours identified
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numerous discrepancies including corrosion, leaks, housekeeping,
! cabling, radiation protection, spare parts controls and scaffolding i deficiencies. Subsequent to the tour with the Services Superintendent,
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the statien initiated a program to improve the containment material condition. The resident inspectors will continue to monitor plant material condition during the Unit 2 outage to assess the effective-ness of the licensce's progra Improverents were noted in the HVAC room on the 617' elevation of the auxiliary building and in the Unit I and Unit 2 purge rooms where material condition crews had worked. Tours with the material condition coordinator, the Master Mechanic, and other members of management and crafts appeared to result in an incrcised sensitivity to the plant material conditio One violation and no deviations were identifie . Monthly Surveillance Observation (61726)
The inspector observed Technical Specifications required surveillance testing on the service water system and the Unit 2 atmospherir. relief valves and detennined whether testing was perforved in accordance with adequate procedures, whether test instrumentation was calibrated, whether limiting conditions for operation were met, whether removal and restoration of the affected components were accotiplished, whether test
- esults confonned with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and whether any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspector also witnessed portions of the following test activities
PT-27 Hiscellaneous Valve Tests PT-8B Monthly Operability Test of Service Water Purps TSSP 121-88 Functicnal Test of Bus 147 Segnent of H22-1-88-79 TSSP 122-88 Functional Test of Bus 148 Segment of it22-1-88-79 TSSP 125-88 Timing Verificaticr. and Adjustment of Agastat Time Delay Relays- for 2 out of 3 Service Bus Under Voltage IMP-NR-12 Intermediate Range Compensated lenization Chamber Resistance and Voltage Ser' ity Test
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Observations concerning testing performed under the TSSPs delineated i above is discussed in paragraph 7 of this repor !
I Findings ,
- Deviation Report (DVR) 1-88-109, dated September 7, 1988 documented environmental qualification (EQ) variations on 4160 volt (4KY) '
motor From March 1,1988 to June 15, 1988 inspections were performed on all Unit 1 and 2 EQ 4KV motor splices. Of the 48 .
splices inspected (3 per motor), 27 were replaced due to improper configuration or improper voltage rating. The motors which required '
splice replacement were:1C, 28, 2C auxiliary feedwater (AFW) pump motors, 1A, 1B, 2A, 2B residual heat removal (RHR) pump motors, and j the 18 and 2A charging (CV) pump motors. Several concerns were raised in the DVR which are considered to warrant additional !
inspection by NRC. Resolution of the identified EQ d:sficiencies in !
DVR 1-88-109 is considered an Unresolved Item (295/88019-04(ORS); [
304/88019-07(ORS)). F
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During perfomance of PT-27, the inspector observed an operator !
repeatedly attempting to stroke a stuck motor operated valve l (2 MOV-MS 0017). The inspectors verified by interview that some j operators and senior reactor operators would consider it acceptable l to record stroke tirms other than the initial as-found stroke time ;
for test documentation. A standing order was issued to clarify the l misunderstanding held by some operators, and to require that the !
first attempt for valve stroke timing be recorded as the as-found !
value, Final resolution of and training on the licensee's testing (
policy for stroke timing of valves is considered an Open Item pendingNRCreview(295/88019-05;304/88019-08(DRP)) {
- The inspector inquired as to whether the licensee met the l requirements of IWV-33C0 of Section XI of the ASME Cod IWV-3300 i requires that remote position indicators (RPIs) for those valves in I the Itcensee's inservice testing program be verified to accurately !
reflect the position of the valve once every two years. The (
licensee stated that RPIs located in the control room were periodically verified; however, procedures to verify RPIs located in any other plant locations, including the remote shutdown panels did ,
not exist. The inspe: tor noted that this practice was employed at j all of the comonwealth Edison (CECO) plants and infomed the licensee that the NRC's concern regarding this matter had been [
transmitted by letter from E. G. Greenman to C. Reed dated 7 i
September 15, 1988. The licensee acknowledged the inspector's !
concern and stated that verification of those RPIs located in places !
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other than the control room would not be pursued until CECO had reached a corporate decision regarding RPI verification. Resolution of testing for those RPIs not located in the control roon: is ,
considered to be an Unresolved Item (295/88019-06; 304/88019-09 t (DRP)).
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In preparing for the Unit 2 containtrent integrated leak rate test (ILRT), the licensee was planning to use temporary leak stopping methods (Fumanite) to reduce identified steam generator (SG)
handhole leakage. In discussing this proposed repair, the resident inspector suggested that this course might not be prudent, since this appeared to represent a compromise of the as-found conditions for the test. After additional discussions with Regional and Headquarters NRC personnel, the licensee elected to conduct the ILRT without applying Furmanite to the SG handhole leaks. The test results were found to be within acceptable limit No violations or deviations were identified. One Open item and two Unresolved Items were identifie . Monthly Maintenance Observation (62703)
Station maintenance activities en safety related systems and components listed below were observed or reviewed to ascertain whether they were conducted in accordance with approved procedures, regulatory guides industry codes or standards and in conformance with Technical Specification The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were perforred prior to returning corponents or systems to service; quality contrni records were maintained; activities we*e accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemente Work requests were reviewed to detemine status of outstanding jobs and to assure that priorMy i t : m gned to safety related equipment maintenance which may affect system perfomanc Ths following nintenance activities were observed or reviewed:
Work Request Description Z 73641 1C Service Water Puep Z 74567 2B Auxiliary Feedwater Purp Impingenent Shield Z 73245 Block on PORY 455C Z 73244 Block on PORY 456 Ceficiencies regarding work requests Z 73243 and Z 73244 are discussed in paragraph 6 of this repor Work request Z 73641 was written to investigate a "rubbing" noise noted while the IC service watar (SW) pump was running. Following investiga-tion by the rechanical maintenance departrent, it was detemined
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that the noise was due to the motor windings and preparations to return ,
, the pump to service were made. The licensee nornally performs a post !
j naintenance run to ensure that motor leads havi. been connected properly l 1 and to identify any gross probbms with the pump prior to running the t I
pump PT to detemine pump operability. The inspector witnessed the post 1 maintenance pump run end noted that the points used to obtain pump l vibration data were missing. These vibration monitoring points consist
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of yellow circles of paint approximately 1 inch in diameter. Vibrations measurements are normally taken by placing a magnetic vibration transducer j on the pump or motor directly on the yellow circl l
) Vibration measurenents are required in order to detemine pump !
4 operability as defined in Subsection !WP of Section XI of the American !
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Society of Hechanical Engineers' (ASME) Boiler and Pressure Vessel Cod l Vibration measurements are position dependent and Subsection !WP-4160 of ;
Section XI requires that provisions be made to duplicate measurement !
i positions for those instruments which are position sensitive. SW pumps !
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are subject to the requirements of Section XI. The licensee stated that !
I the vibration point markings had been inadvertently painted over during i
! the painting of the crib house which took place during the week uf !
) May 16, 198 '
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Review of the periodic test procedure PT-88, "Monthly Operability Test
- of Service Water Pumps," revealed that locations for measuring vibration [
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data were in most cases not specified in sufficient detail to ensure that i the same paints were consistently used. The inspector also noted that i
, several SW monthly operability tests had been perforned after May 16, i
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j 1988 and asked the licensee how SW pump operability had been demon- l
, strate The inspector and the licensee's vibration coordinator i reviewed the licensee's SW pump vibration spectra which were obtained ;
l both before and after the pumps were painted, and determined that the '
SW pumps were operable. The inspector noted that the licensee had ;
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previously experienced a missed surveillance which was attributed to i
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painting activities as documented in Licensee Event Report 295/8604 {
< t j 10 CFR 50 Appendix B, Criterion !!, requires in part that programs be ;
3 established and implemented to assure that activities affect;ng quality I i are accomplished under suitably controlled conditions which are !
j comensurate with the importance of the activity to safety, j I Contrary to the above, an effective program was not implemented to assure I that painting activities did not advectly impact surveillance testing !
- of the service water pumps in that painting cf the service water pumps !
] resulted in the removal of vibration measurement points on the pumps !
] used to demonstrate pump operability. The licensee's failure to maintain !
j suitable test conditions by properly controlling painting activities is !
j considered to be a violation (295/88019 07; 304/88019-10 (DRP)). [
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The licensee completed marking of the SW pumps on September 2,1988, and verified that all other pumps requiring vibration treasurement points were prcperly marked. A temporary procedure change to Zion Administrative Procedure (ZAP) 10-52-6, "Valve Tagging, Painting, Labeling and Pipe ;
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Marking Procedure," was isst ! nob.r 13, 1988, to caution painters !
with regards to painting ovm v cic measurement points. The i temporary procedure change w n e S in effect until a permanent procedure change is issue ; 1:..ng of those personnel currently responsible for painting plant equipment with regards to this event was completed on October 18, 1988, and a discussion of this event will be ,
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incorporated into the training for new personnel. The licensee has also }
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reviewed the painting specifications for the remainder of the planned r painting activities and will incorporate a requirement that members of [
the operating staff walk down the areas to be painted both before and ;
after painting to assure that no required marki.igs are removed. This c violation fulfills the requirements of 10 CFR :. therefore, no response !
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to this violation is require !
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Following completion of maintenance on the IC Service Water Pump and 28 1
.: Auxilicry Feed.;ctar Pump Impingement Shield the inspector verified that :
1 these systems had been returned to service properl l
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One violation and no deviations were identifie '
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i 11. Licensee Event Reports (LERs) Followup (92700) !
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Through direct observations, discussions with licensee personnel, and
) review of records, the following event reports were reviewed to determine i that reportability requirements were fulfilled, that imediate corrective l
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action was accomplished, and that corrective action to prevent recurrence ;
j had been accomplished in accordance with Technical Specifications. The LER listed below is considered closed: f
- UNIT 2
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LER N TITLE 1 !
88007 Reactor Trip While Troubleshooting Rod Control System Urgent Failure j
! Regarding LER 304/88007, the licensee attributed the reactor trip to a {
} procedural deficiency which allowed operators to pull and replace rod f
- control system fuses without assessment of technical consequences. This l l was compounded by the failure of both the pulser / oscillator and
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associated alarm circuit cards. The licensee's corrective actions were i reviewed and considered prompt and thorou3h. This LR is closed.
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ho violations or deviations were identifie ,
12. Training (41400, 41701) l I
During the inspection period, the inspectors reviewed abnormal events and :
unusual occurrences which may have resulted, in part, from training deficiencies. Selected events were evaluated to determine whether the ;
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classroom, simulator, or on-the-job training received before the event i was sufficient to have either prevented the occurrence or to have r
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mitigated its effects by recognition and proper operator actio Personnel qualifications were also evaluated. In addition, the inspectors determined whether lessons learned from the events were incorporated into the training progra l One concern regarding operator training regarding stroke timing of v61ves
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is discussed in paragraph 9 of this repor i Another concern was identified following the October 5,1988 Unit 2 i
reactor trip in that operators were allowed by procedures to replace fuses without being qualified to evaluate the technical consequences of
. their actions. In addition, a knowledge deficiency was identiftad in that operators did not know that a reading of 180 millivolts across a
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stationary gripper coil fuse was nonnal and acceptable. This is discussed in paragraph 5 of this repor Following the October 5,10 event, the inspector observed a SRO
- candidate during a systein check out on the control rod systems. The j candidate demonstrated in-depth knowledge of both the system design and
- operational parameters. The licensed SRO asked several questions, all of which the candidate answered satisfactoril As noted in paragraph 8 operator training lesson plans were reviewed regarding the use of abnomal operating procedures regarding mid loop
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reactor coolant system (RCS) cperations, the April 1987 Diablo Canyon loss of RCS inventory event, and other measures to be taker to reduce the
- probability of a loss of RCS inventory event during the Unit 2 refueling outage.
! A NGET refresher training was attended by the resident inspector, during i which the inspector verified that the required topics were covered clearly, with ample opportunity for discussion and questions. A test was adminstered for the purpose of issuance of NGET cards. The session i and examination were professionally administere Two training sessions were attended by the resident inspectors.
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13. Quality Program Effectiveness (92702 and 36100)
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! - The licensee's corrective actions to prevent the occurrence of boron
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concentrations in the OC BAT from falling below the TS required l
value were ineffective as discussed in paragraph 8. Corrective actions for NRC findings were found to be acceptable as discussed in paragraph 2.
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- The licensee did not act in a highly conservative manner when in a LCO for OC BAT on September 16, 1988 (see Paragraph 8). In
! addition, when the licensee discovered that the steam jet
- impingement shield for the IB AFW pump wc3 discovered to be l incorrectly installed, the licensee incorrectly concluded that the
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pump should still be considered operable. The basis for this
! conclusion was that the impingerent shield (which is described in i
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Chapter 10 of the Updated Final Safety Analysis Report (UFSAR)) was
, not mentioned in the TS bases or in the accident analyses in
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Chapter 14 of the UFSA The inspector stated that the NRC's position was that while the
) accident for which the shield is installed to protect against (high
, energy line break in the auxiliary building) was not a design basis
aci.ident as described in the accident analyses, the shield was still installed to meet certain desi Final Safety Analysis Report (gn requirements FSAR). as described The inspector stated thatineach the case in which it is identified that the plant does not conform to
design requirements must be evaluated on its own merits, and that
- the considerations should not be limited to design basis events or
- the TS bases.
l It should be noted that the licensee perforred the impingement j shield repair promptly, and that the operability review was
! perforTned within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of identification of the problem. This i review was clearly documented, including the basis for any decisions
- reached and the plan for corrective actions.
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On October 4,1988, the NRC was notified pursuant to 10 CrR Part 21
- by the manufacturer of the licensee's diesel generators ()G),
i Cooper-Bessemer, that cracks were found in Cooper-Bessemer DG fuel
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injector nozzle tips after a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run at the Byron station. The cracked fuel nozzle tips were sinilar to those reported at the South Texas Project in August 1987. The inspectors verified that the licensee had been notified of the problem and had determined that none of the suspect parts rentioned in the Cooper-Bessemer letter were in stores at the Zion Statio In a @ tion, the nozzle tips (16 each) were visually inspected for the 2A and 28 DGs which are receiving periodic maintenance this outage. The licensee plans to perform similar inspections on the ODG later this outage, and on the Unit 1 DGs during the next Unit I refueling outag No violations or deviations were identifie . October 5 - 6, 1988 Site Visit by Branch 1 Senior Resident Inspectors (30702)
On October 5 - 6, 1988, the senior resident inspectors (SR!s) from the other comonwealth Edison nuclear generating stations met at the Zion Emergency Operations Facility (EOF). During their visit, the SRIs toured Zion station. Their observations were shared with rerbers of plant managersent at a meeting in the EOF on October 6,198 No violations or deviations were identifie . October 19, 1988 Site Visit by Recional Administrator (30702)
On October, 19, 1988, a plant tour was conducted by the senior resident inspector for Mr. A. Eert Davis, Regional Adminstrator, Region III;
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Mr. William L. Forney, Deputy Director, Division of Reactor Projects and l
- 4r. Julian M. Hinds, Jr., Chief Reactor Projects Section 1A. Following !
the plant tour, Messrs. Davis, Forney and Hinds met with the Vice President l l of PWR Operations, the plant manager and trerters of the plant staf I Mr. Davis noted that until recently, plant trips and unplanned safety 1 i system actuations had been very low and plant performance was goo !
Mr. Davis also noted that plant material condition had significantly !
improved since his last visit; however, much work remained to be done in order to meet the rising standards of the industry. Mr. Davis suggested that the plant contact other licensee's in an effort to exchange ,
experiences and good practices which could be implerrented at Zio l
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7:o violations or deviations were identifie (
16. Open Items (
Open Items are matters which have been discussed with the licensee which ;
will be reviewed further by the inspector and which involve some actW !
on the part of the NRC or licensee or both. Four Open Items disclosed i during this inspection are discussed in Paragraphs 2, 6, 7 and ;
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17. Unresolved items Unresolved items are matters about which more infortnation is required !
l in order to ascertain whether they are acceptable items, items of i i noncortpliance or deviations. Four Unresolved items disclosed during this i inspection are discussed in Paragraphs 5, 7, 8 and [
1 Exit Interview (30703)
l The inspectors met with licensee representative $ (denoted in Paragraph 1) i
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throughout the inspection period, on October 14, 1988 Noverr.ber 7,1988, i and on Novernber 10,198P, to sumarize the scope and findings of the inspectier, activitie The licensea acknowledged the inspectors' (
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coments. However, the licensee disagreed with the inspectors' i assertions that its decision to not ramp Unit 2 down during a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> LCO !
was not highly conservative. This decision is discussed in paragraph 6 !
of this report. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents or processes as proprietary.
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