IR 05000295/1985036

Insp Repts 50-295/85-36 & 50-304/85-38 on 851008-1118. Violation Noted:Failure to Notify NRC within 4 H of ESF Actuation on 851010

ML20138J438
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	12/09/1985
From:	Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138J422	List: IR 05000295/1985036 ML20138J419 ML20138J425
References
50-295-85-36, 50-304-85-38, NUDOCS 8512170523
Download: ML20138J438 (8)

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U.S.' NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-295/85036(DRP); 50-304/85038(DRP)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39;DPR-48 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: October 8 through November 18, 1985-Inspectors: M. M. Holzmer L. E. Kanter J. N. Kish Ant % N(mes &

Approved By: C. W. HeT , Chief /A/1/ts" ReactorProjectsSection2A Date Inspection Summary Inspection on October 8 through November 18, 1985 (Reports No. 50-295/85036(DRP);

50-304/85038(DRP))

Areas Inspected: Routine, unannounced resident inspection of licensee action on previous inspection findings; review of reporting requirements; actuation of service water pump; corrective action system review; operational safety and engineered safety feature (ESF) system walkdown; surveillance; maintenance; licensee event reports (LERs). The inspection involved a total of 375 inspector-hours onsite including 55 inspector-hours onsite during off-shift Results: Of the eight areas inspected, no violations or deviations were identified in seven areas, and one violation was identified in one area (review of reporting requirements).

8512170523 851210 PDR ADOCK050g25

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DETAILS Persons Contacted l

• G. P11m1, Station Manager  !

• E. Fuerst, Superintendent, Production

• T. Rieck, Superintendent, Services ,

• Kurth, Assistant Station Superintendent, Operations

• K. Kofron, Assistant Station Superintendent, Maintenance L. Pruett, Unit 1 Operating Engineer J. Gilmore, Unit 2 Operating Engineer N. Valos, Rad Waste Operating Engineer

• Budowle, Assistant Superintendent, Technical Services M. Carnahan, Training Supervisor

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

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• C. Schultz, Regulatory Assurance Administrator R. Aker, Station Health Physicist n *J. Ballard, Quality Control Supervisor D. Kaley, Quality Control Engineer

• W. Stone, Quality Assurance Superviser

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D. McHenamin, Quality Assurance Engineer  ;

• L. Holden, Regulatory Assurance Engineer

• Indicates persons present at exit intervie . Licensee Action on Previous Inspection Findings [

(Closed) Open Item (295/85022-01): LER 295/85-19 has been resubmitted and reviewed. The inspector is satisfied with the corrective actio ;

(Closed) Open Item (304/85029-04): Procedure ZCP-304 " Containment Radioactive Releases" permitted considerable flexibility in establishing a setpoint. This resulted in a valve being below the setpoint necessary to complete the purg The shift Control Room Engineer reported the incident to the Radiation Chemistry Foreman as difficulty with the monitor's alarm setpoints and not as a high alarm condition. As a result of this, no verification gas sample was obtained. A sample taken 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> prior to the start of the purge, verified noble gas activities within acceptable limit A revision to ZCP-304 was implemented on August 27, 198 This established setpoints for each unit to be used when purging above

' Cold Shutdown (CSD). In addition, radiation chemistry and control room personnel were reminded of the importance of communication and j follow-up of Radiation Monitor events. This was achieved through both a memorandum and discussions on this event and others of similar nature with each shift at the training facility by the Assistant Superintendent of Operation <

No violations or deviations were identified.

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. . Summary of Operations Unit 1 Unit 1 operated at power levels up to 100% throughout the inspection period. On October 21, 1985, power was reduced to 50 percent to allow for the filling of IB RCP oil reservoi Unit 2 Unit 2 remained in cold shutdown undergoing a refueling outage throughout the inspection perio . Failure to Meet Reporting Requirements y On October 10, 1985, while performing a source calibration, a spike on 2RIA-PR40 (Unit 2 vent stack particulate,' iodine and noble gas monitor-SPING) occurred when the pulse generator was energized. This resulted in shutting the four containment purge isolation valves. Containment isolation is an engineered safety feature (ESF) actuation. Approximately <

22.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> later the event was classified as reportable and an emergency notification system (ENS) telephone call was made .

10 CFR 50.72 requires a four hour ENS telephone notification for any event or condition that results in a manual or automatic actuation of any ESF with the exception of a preplanned sequence during testing or reactor operation. Failure to make a required ENS notification within four hours is considered a violation (304/85038-01).

One violation and no deviations were identifie The violation consisted of one exampl . Actuation of 18 Service Water Pump On October 15, 1985 during the performance of PT-9 " Service Water Valve Operability Checks" on Unit 1, the IB service water pump automatically started due to low pressure in the service water header. The low pressure was caused by cycling the header cross-tie valve, OMOV-SW0003, as required by PT-9. At the time, the IC service water pump was out-of-service for repairs contributing to the low pressure in the heade This event was not initially designated as reportable. However, after further investigation, it was classified as reportable because of the auto-start being recognized as an ESF actuation. The ENS telephone call was made five hours and 45 minutes after the event in lieu of the required four hour The licensee has since revised their position, stating the auto-start of the IB service water pump is not reportable per NUREG-1022 and the Zion FSA This system is not classified as an ESF system per the Zion FSA Pending review of this situation by the NRC Regional Office and the resident inspectors, this item is considered an Unresolved Item (295/85036-01).

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No violations or deviations were identifie One unresolved item was identifie . Corrective Action System Review Over recent months resident inspectors observed a declining trend in the overall quality of corrective action system report These include l Deviation Reports (DVR) and Licensee Event Reports (LER). In some cases, determination of root cause appeared to be incomplete, and in other

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cases, the corrective actions recorded did not appear to address all of I the apparent problems in the LER or DVR text. Station management was informed of this observation in a series of meetings with the resident i inspectors during the month of September.- Specific examples were

, presented to the licensee during this time. The licensee agreed that

! some improvement was warranted, and stressed to department heads the need to improve the quality of these investigation During a review of an October 18, 1985 input to the Zion Systematic Assessment of Licensee Performance (SALP) report from the Office for Analysis and Evaluation of Operational Data (AE00) the resident inspectors noted that over the assessment period, there were other

examples of weak root cause identification and corrective actions. In

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addition, LER quality had not yet improved significantl The AE0D report and one recent example were presented to the licensee on October 24, 1985 and the licensee was requested to review the report and prepare an action plan to improve performance in this area. A meeting was held on October 28, 1985 during which the licensee's plan was presente The plan included actions to improve both corrective action system investigations as well as ENS notification timeliness (see paragraph 4).

i Actions to improve DVR/LER quality included a review of the requirements l of 50.73, a review of NUREG-1022 and its supplements (which provide interpretations and case examples of reporting requirements), development of an operating shift DVR/LER worksheet to obtain relevant facts sooner, and speed up the investigation process, training for all individuals who perform DVR/LER investigations, and revisions to procedures and instruction Most of the licensee's actions are expected to be completed by late December 1985. A significant improvement has already been noted. This matter is considered an Unresolved Item pending the completion of the licensee's action plan and review of the results by NRC (295/85036-02; 304/85038-02).

No violations or deviations were identifie One Unresolved Item was 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 October 8 through November 18, 1985. During these discussic.ns 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

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of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the auxiliary and turbine 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 maintenanc The inspectors by observation and direct interview verified that the 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 control From October 8, 1985 to November 18, 1985, the inspectors walked down the accessible portions of the OA Waste Gas Compressor room, 1C charging pump room, 1A and 1B SI pump room, component cooling water system, auxiliary feedwater system, relay house and switchyard to verify operability. The inspectors also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barrelin 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 5pecifications required surveillance testing on the volume control tank level 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 conformed 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 portions of the following test activities:

• PT-2I Centrifugal Charging Pump Test and Check

• PT-9 Service Water Valves Operability Checks

• Reactor Vessel Outlet Nozzle Examination Using ISI Tool No violations or deviations were identifie . Monthly Maintenance Observation Station maintenance activities on safety-related systems and components listed below were observed or reviewed to ascertain whether they were

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conducted in accordance with approved procedures, regulatory guides

industry codes or standards and in conformance with Technical

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. The following items were considered during this review: the limiting

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conditions for operation were met while components or systems were l removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were

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inspected as applicable; functional testing and/or calibrations were

performed prior to returning components or systems to service; quality i control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified;

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radiological controls were implemented; and fire prevention controls were implemented.

l Workrequestswerereviewedtodeterminestatusofoutstandingjobsand l

to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance activities were observed or reviewed:

IC Service Water Pump ( 1ASafetyInjectionPump I 2A and 2C Main Steam Isolation Valve Modifications

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l FollowingcompletionofmaintenanceontheSafetyInjectionPump '

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the inspector verified that this system had been returned to service properl No violations or deviations were identifie . Licensee Event Reports (LER) Followup l 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, immediate corrective  ;

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action was accomplished, and corrective action to prevent recurrence had been accrmplished in accordance with Technical Specifications. The LERs  ;

listed below are considered closed: ,

UNIT 1 LER N DESCRIPTION

295/85-19-01 Reactor Trip and Inadvertent ESF Actuation [

295/85-29 Diesel Generator Room Aircraft Crash Dampers t 295/85-32 Inadvertent Closure of Containment Isolation Valves During PT-10 6 ,

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LER N DESCRIPTION 295/85-32-01 Inadvertent Closure of Containment Isolation Valves During PT-10 295/85-33 Missed Quadrant Power Tilt Ratio Surveillance i

295/85-34 Temporary Procedure Change Not Signed by Station Superintendent In 14 Days 295/85-35 Missed Notification to NRC of Quarterly Liquid Release in Excess of 2.5 Curies UNIT 2 LER N DESCRIPTION 304/85-12-01 Closure of Purge Valves from High Radiation Signal 304/85-15 Diesel Generator Room Aircraft Crash Dampers 304/85-17 Unit 2 Purge Valves Closure 304/85-19 Inadvertent Trip of Unit 2 Purge in Cold Shutdown With regard to LER 304/85-19, " Inadvertent Trip of Unit 2 Purge in Cold Shutdown", the LER will be closed. However an Open Item will be issued pendinginvestigationofthecauseofthecIrcuitdefecttobeaddressed in a supplemental LER (304/85038-03).

With regard to LER 304/85-17, " Unit 2 Purge Valves Closure," a violation was given for this event in report 295/85031; 304/85032 for failure to make an Emergency Notification (EN) within four hours. This LER is close With regard to LER 304/85-12-01, " Closure of Unit 2 Purge Valves From a High Radiation Signal", the LER will be closed, corrective action was adequate. For details on the event, see paragraph 2 of this repor With regard to LER 295/85-29 and 304/85-15, the licensee will submit documentation stating their position on the operability of the diesel generators with inoperable aircraft crash dampers. This is considered an Open Item (295/85036-03; 304/85038-04).

With regard to LER 295/85-33, the licensee will submit a revised LER elaborating on root cause and corrective action. This is considered an Open Item (295/85036-04).

No violations or deviations were identifie . .

1 Site Visit by Comnissioner Zech On October 17, 1985 Comissioner Lando Zech conducted a routine tour of the Zion Nuclear Generating Station. The commissioner was accompanied by his Technical Assistant, Mr. David Humenansky and Mr. James G. Keppler, Region III Administrator. They toured the control room and auxiliary building. After the tour the commissioner met with Commonwealth Edison officials to discuss topics of mutual interes . 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. Three Open Items were disclosed during this inspection and are discussed in paragraph 1 . Unresolved Items Unresolved items are matters about which more information is required in l order to ascertain whether they are acceptable items violations or deviations.-TwoUnresolvedItemsweredisclosedduringthisinspection and are discussed in paragraphs 5 and . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the inspection period and at the conclusion of the inspection on November 18, 1985 to summarize the scope and findings of the inspection activities. The licensee acknowledged the inspectors' comment The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents or processes as proprietar .

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