IR 05000295/1985031

Insp Repts 50-295/85-31 & 50-304/85-32 on 850904-1007. Violation Noted:Failure to Meet Reporting Requirements of 10CFR50.72 & 50.73 for ESFAS Actuations

ML20198F313
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	11/07/1985
From:	Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198F302	List: IR 05000295/1985031 IR 05000904/2010007 ML20198F297
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.E.1.1, TASK-TM 50-295-85-31, 50-304-85-32, NUDOCS 8511140321
Download: ML20198F313 (11)

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U.S. NUCLEAR REGULATORY COMMISSION j

REGION III

y Reports'No. 50-295/85031(DRP); 50-304/85032(DRP)

Docket Nos.150-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonw'ealth 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: September 4 through October 7, 1985 Inspectors: M. M. Holzmer L. E. Kanter

.J. N. Kish R.-A. Hasse h Y b .-, g

_ Approved By

C. W. Hehl, Chief Reactor Projects Section 2A Dat Inspection Summary Inspection on' September 4 through October 7, 1985-(Reports No. 50-295/85031(DRP);

F0-304/85032(DRP))

Areas Inspected: Routine, unannounced resident inspection of licensee. action on previous' inspection findings; 10 CFR 21 Report; station' management changes; failure to meet reporting requirements; construction fatality; containment integrated leak rate test valve verification; operational safety and ESF walkdown;~ surveillance; maintenance; LERs; TMI follow-up. The inspection involved a total of 318 inspector-hours onsite including 57 inspector-hours onsite during off-shift Results: Of the nine areas inspected, no violations or deviations were identified in eight areas, and one violation was identified in the remaining area (failure to meeting reporting requirements of 10 CFR 50.72 and 10 CFR

'50.73 - three examples).

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DETAILS Persons Contacted

• Plimi, Station Manager

• T. Rieck, Superintendent, Services

• E. Fuerst, Production Superintendent

• K. Kofron, Assistant Station Superintendent, Maintenance R. Budowle, Assistant Superintendent, Technical Services

• J. Gilmore, Unit 2 Operating Engineer L. Pruett, Unit 1 Operating Engineer W. Kurth, Assistant Superintendent, Operating M. Carnahan, Training Supervisor

• R. Cascarano, Technical Staff Supervisor A. Ockert, Assistant Technical Staff Supervisor

• C. Schultz, Regulatory Assurance Administrator R. Aker, Station Health Physicist

• J. Ballard, Quality Control Supervisor W. Stone, Quality Assurance Supervisor

• D. McHenamin, Quality Assurance Engineer

• Indicates persons present at exit intervie ' Licensee Actions on Previous Inspection Findings (OPEN) Open Item (304/84-26-03): Delta Flux Calculation Program Not Operable. The licensee has not fully implemented one corrective action item concerning the computer program revision. This item will remain open pending complete implementation of corrective actio (CLOSED) Unresolved Item (304/85-29-03): Inadvertent Closure of Unit 2 Blowdown Isolation Valves. This item is closed and covered in Paragraph of this repor (CLOSED) Noncompliance (295/84-19-07; 304/84-20-07): Failure to purchase safety-related materials in accordance with the licensee's QA program requirements. The licensee performed an extensive receipt inspection of the safety injection pump including verification of clearances and shaft balance to assure the pump met performance requirements. The one nonconformance report issued by the manufacturer was reviewed and approved by the licensee. The licensee also reviewed the manufacturers special process procedures and performed a review for suitability of applicatio A review for suitability of application for the three other items identified in this noncompliance were also performed by the license Changes have also been made to procurement procedures to better define the required content of purchase documents. The inspector was satisfied that the specific hardware involved was acceptable for use and that the procedure revisions should prevent recurrence of the proble '

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(CLOSED) Noncompliance (294/84-19-08; 304/84-20-08): Inadequate receipt inspection of a safety injection pum The receipt inspection failed to detect that the pump had been built under a QA program not approved by the licensee. It also failed to detect that all documents required to be submitted to the licensee had not been received. The licensee subsequently reviewed and approved the QA program under which the purrp had been buil The missing documentation was obtained and reviewed and found to be acceptable. Procedure revisions have been made to improve the receipt inspection process and additional training has been provided to receipt inspection personne No violations or deviations were identifie . Summary of Operations Unit 1 Unit 1 operated at power levels up to 100% for the inspectior, perio Unit 2 Unit 2 started the inspection period at 42% power, and was coasting down in preparation for a 131 day refueling outage. At 12:27 a.m. September 5, 1985 the generator tripped off the grid on reverse power, with the reactor at less than 10% power. At 1:00 a.m. September 5, 1985, the reactor was manually tripped in accordance with the shutdown procedure. The shutdown was accomplished without event and all systems functioned normally. The unit is currently in cold shutdown undergoing a refueling outag No violations or deviations were identifie . Licensee Report Submitted Pursuant to 10 CFR Part 21 On September 27, 1985, during an inspection of Environmentally Qualified (EQ) motor operated valve (MOV) operators, the licensee discovered that four Limitorque valve operators had nonqualified wiring. The licensee notified Region III on September 30, 1985, after concluding that the condition was reportable pursuant to 10 CFR Part 21, and submitted a written report on October 4, 198 The nonqualified wiring consists of four wires which connect the MOV operator limit switches with the torque switch. The wires found were different from the wiring tested by Limitorque. The four valves found with this problem are 2M0V-SI8813 and 2M0V-SI8814 (safety injection pump miniflow recirculation valves), 2M0V-8923B (refueling water storage tank to safety injection pump 2B suction valve), and 2MOV-9010A (safety injection pump 2A to cold leg injection header. Other Unit 2 EQ M0V operators may also have this type of wire. Unit 1 EQ MOV operators were verified not to have this type of wiring during the previous refueling outage, though the problem was not reported pursuant to Part 21 at that tie _

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. Environmentally induced failure due to'use of this wire is caused by loss of integrity of the insulatio If the insulation were to degrade, a

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short circuit of the torque switch could resul With the torque switch

' inoperable,-if the. valve were repositioned, the valve would stroke to the

, full open or full closed position and the motor would remain energized causing the valve motor thermal overload trip to actuate and possi'leo motor operator damage could resul lThe licensee intends to submit a followup report to provide additional details.- -This is. considered an Unresolved Item pending review of the licensee's followup report, the associated corrective action, and Jdetermination of whether the reporting requirements of Part 21 were met (304/85032-01).

No violations or deviations were identified. One Unresolved Item was identifie . Station Management Changes On September 3, 1985, the following station management changes were announced:

K. Graesser - From Station Manager to Vice President of the Nuclear Stations Divisio G. Plim1 - From Assistant Superintendent, Operating to Station Manage E..Fuerst - From Assistant Superintendent, Operating to Production Superintenden W. Kurth - From Assistant Superintendent, Technical Services to Assistant-Superintendent, Operatin On September 23, 1985, the following station management changes were announced:

R. Budowle - From Unit 1 Operating Engineer to Assistant Superintendent, Technical Service L. Pruett - From Operating Engineer to Unit 1 Operating Enginee N. Valos - From Assistant Operating Engineer to Operating Enginee . Schultz - From Assistant Technical Staff Supervisor to Regulatory Assurance Administrato No violations or deviations were identifie l

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6. Failure to Meet Reporting Requirements During this period, three events were reviewed for which the licensee did not appear to adhere to the reporting requirements of 10 CFR 50.72 and 50.73: On May 27, 1985, while performing PT-10, Safeguards Actuation Test, Unit 2, an inadvertent closure of several train A containment isolation valves resulted from an improper sequence of operation Specifically, Steps 4N.22 and 4N.23 were overlooked causing several isolation valves to close. This was verified through discussions with shift personnel. Containment isolation is an Engineered Safeguards Feature (ESF). A four hour ENS telephone notification was made by the shift engineer as required by 10 CFR 50.72, and a deviation report (DVR) was initiated. On May 27, 1985, the DVR was cancelled and no LER drafte The event was reclassified on October 7, 1985, as a result of an investigation by the resident inspector and a DVR was initiate On August 2, 1985, all three penetration pressurization (PP) air compressors auto started due to low supply pressure from the instrument air system. This low pressure condition was caused by a spurious high vibration trip of the instrument air compresso The auto start of the PP air compressors is an ESF and both a four hour ENS telephone notification and a thirty day written report are required. Approximately one month after the event the licensee reclassified the event during a routine review and a ENS telephone call was made and an LER initiated. The LER written was issued on September 10, 1985, after the required thirty day On September 9, 1985, the Unit 2 containment purge valves were inadvertently shut when Electrical Maintenance (EM) personnel removed the jumpers from the purge valve circuitry. The jumpers were utilized to bypass the trip of the containment purge fans when the plant was above cold shutdown (CSD) conditions. Closing of the containment purge valves is an ESF. Shift management classified the event as reportable approximately seven hours later and an ENS telephone call was then made, three hours beyond the 10 CFR 50.72 reportability requiremen For certain events, 10 CFR 50.72 requires a four hour ENS telephone notification and 10 CFR 50.73 requires a thirty day written repor CFR 50.72(b)(2)(ii) and 10 CFR 50.73(a)(2)(iv) both require that any event or condition that results in a manual or automatic actuation of any ESF is reportable with the exception of a preplanned sequence during testing or reactor operatio The events discussed in subparagraphs b and c fail to meet the requirements per 10 CFR 50.72 and the events discussed in subparagraphs a and b fail to meet the requirements of 10 CFR 50.73. These items are considered a Violation (295/85031-01; 304/85032-02).

One violation and no deviations were identified. The violation consisted of three example _

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.. ' Construction Fatality

'.On-October 7,1985, fall while working on attheabout new 9:00 interim a concrete radwaste finisher storage was killed facility. The in a

, victim was working from a manlift, and fell 45 feet. Paramedics were on

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the scene at about 9:07 a.m. and worked until 9:45 a.m. without obtaining

a response. The victi'n was transported to Victory Memorial Hospital in Waukegan, Illinois where he was pronounced dead on arrival.

An investigation was initiated to determine the cause of the acciden ~

No vio1ations'or deviations were identifie . Containment Integrated Leak Rate Test Valve Verification On September 14, 1985, seve'ral system valve lineups for the Unit 2 Containment Integrated Leak Rate Test (CILRT) were verified by both the resident and region based inspectors. Details on the CILRT will be addressed in Inspection Reports No. 50-295/85033; 50-304/8503 No violations or deviations were identifie . Operational Safety Verification and Engineered Safety Features System Walkdown

.The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators from September 4 through October 7, 1985. During these discussions and observations, the inspectors ascertained that the operators were alert, fully cognizant of plant conditions, attentive to changes in those conditions, and took prompt' action when appropriate. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return-to service of affected components. Tours'of the auxiliary and

'tuteine buildings were conducted to observe plant equipment conditions,

-including potential fire hazards, fluid leaks, and excessive vibrations

and to verify that maintenance requests had been initiated for equipment-in need of maintenance.

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The inspectors by observation and direct interview verified that the

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physical security activities were being implemented in accordance with

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'the station security pla The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection control From September.4 to October 6, 1985, the inspectors walked down the accessible portions of the Auxiliary Feedwater, Component Cooling and Diesel Generator systems to verify operability. The inspectors also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barreling.

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These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under Technical Specifications,10 CFR and administrative procedure No violations or deviations were identifie . Monthly Surveillance Observation The inspector observed Technical Specifications required surveillance testing on'the Auxiliary Feedwater system and verified that testing was performed in accordance with adequate procedures, that test

. instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conforrad with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspector also witnessed or reviewed portions of the following test activities:

-TSS 22-2 Steam Generator Eddy Current Examination, Unit 2 PT-7-Auxiliary Feedwater Pumps Tests and Checks PT-7A Starting Procedure for Motor-Driven Aux FW Pump Lube Oil Pumps No violations or deviations were-identified.

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1 Monthly Maintenance Observation Station maintenance activities on 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 performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by

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qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemente Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment

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I L maintenance which may affect system performance.

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The following maintenance activities were observed or reviewed:

2B Diesel Generator

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1C Service Water Pump Auxiliary Feedwater Systems Requests for 1984 and 1985 No violations or deviations were identifie .' Licensee Event Reports (LER) Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that-reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specifications. The LERs listed below are considered closed:

Unit 1 LER N DESCRIPTION 295/85-16 Actuation of Fire Protection Containment Isolation Valve due to broken control air line 295/85-27 Use of Unapproved Procedure 295/85-28_ Failure to Periodically Test Service Bus Undervoltage Start of Steam Driven Auxiliary Feedwater Pump 295/85-28-01 Failure to Periodically Test Service Bus Undervoltage Start of Steam Driven Auxiliary Feedwater Pump 295/85-30 Auto Start of PP Air Compressors 295/85-31 Failure of PP System to Maintain Required Pressure Unit 2 LER N DESCRIPTION 304/85-05 Failure to Periodically Test Service Bus Undervoltage Start of Steam Driven Auxiliary Feedwater Pump

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304/85-05-01 Failure to Periodically Test Service Bus Undervoltage Start of Steam Driven Auxiliary Feedwater Pump

.304/85-14 2B DG Overspeed Trip with 2B RHR Pump Inoperable .

.304/85-16 Test Not Performed In Accordance with Section XI-of ASME Code-

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Regarding LER 304/85-16, the-LER itself is considered closed for administrative purposes. Pending further inspection by a Region III

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specialist of apparently inadequate corrective actions related to concerns previously identified. in -Inspection Report 50-304/85002(DRS),' '

.the' matter will.be followed as an Unresolved Item (304/85032-03).

'No violations or deviations were identified.. One Unresolved Item was

. identifie .--TMI Action Plan Item Followup-II.E.1.1 - Auxiliary Feedwater (AFW) System Evaluation NUREG-0737, " Clarification of THI Action Plan Requirements" specified the-following actions:

a.- Perform a simplified AFW system reliability analysis that uses event-tree and fault-tree logic techniques to determine the

. potential for AFW system failure under various loss of main feedwater-transient conditions. Particular emphasis is given to determining potential failures that could result from human errors, common causes,

-single-point vulnerabilities, and test and maintenance outages; ,

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- Perform a deterministic review'of the AFW system using the acceptance criteria of Standard Review Plan Section 10.4.9 and associated Branch Technical Position ASB 10-1 as principal guidance; and c.- . Reevaluate the AFW system flow rate design bases and criteri Commonwealth Edison (CECO) letter dated December 15, 1980 from J. S. Abel i to D. G. Eisenhut responded to the above stating that the licensee had -

supplied the required infonnation and analyses in a letter dated March 18, 1980 from W. F. Naughton to D. G. Eisenhut and awaited NRC's revie In a letter dated January 8, 1982 from E. D. Swartz to D. G. Eisenhut the licensee stated that all NUREG-0737 requirements for this item had been met and that one long term modification was still in progress, namely installation of AFW check valves to prevent steam generator blowdown in the event of an AFW pipe ruptur NRC documented their review and approval of the licensee's submittals in ,

a letter dated January 21, 1983, from S. A. Varga to L. O. DelGeorg This letter contained, as enclosures, amendments to the AFW technical specifications and stated that NRC's review of Item II.E.1.1 was

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considered complete. The letter also noted "the Commonwealth Edison Company commitment to evaluate and take appropriate action on the common header pipe with postulated break problem."

In a letter dated August 23, 1984, the licensee submitted the results of a probabilistic risk assessment (PRA) which evaluated the effect of the proposed addition of AFW check valves on AFW system unavailability. The evaluation was performed for two configurations with and without the new check valves. The results of the evaluation follow:

Zion Auxiliary Feedwater System Unavailability Analysis w/o check valves 4.3 x 10E-5 Analysis w/ check valves 1.3 x 10E-5 Zion PRA 4.2 x 10E-6 It was concluded that the addition of the check valves on the auxiliary feedwater system supply lines to the steam generators would not reduce the system unavailability significantl The licensee concluded that since the proposed modification would not improve AFW system availability, they would not install the AFW check valves. In a letter dated December 6, 1983 from P. L. Barnes (CECO) to H. L. Denton the licensee stated that the Technical Specifications issued on January 21, 1983 were in conflict with Confirmatory Order Item E.I.c. To date there has been no resolution of this issu .

Item II.E.1.1 is considered close However, resolution of the appaient conflict between Item E.1.c. of the Confirmatory Order and the AFW system Technical Specifications is considered an Open Item (295/85031-02; 304/85032-04).

No violations or deviations were identifie One Open Item was identifie . 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 action on the part of the NRC or licensee or both. One Open Item disclosed during this inspection is discussed in Paragraph 1 . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations. Two Unresolved Items disclosed during this inspection are discussed in Paragraphs'4 and 1 . . _

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1 Exit Interview

~The inspectors met with licensee representatives (denoted in Paragraph 1)-

throughout the inspection period and at the conclusion of the inspection on October 7, 1985 to summarize the scope and findings of the inspection activities. .The licensee acknowledged the inspectors' comments. The inspectors also discussed the likely. in19rmational content of the inspection report with-regard to documenta or processes reviewed by the inspectors during the inspection. The licansee did not identify any such documents or processes as. proprietar . .. . - - -- . -. - - . --

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