IR 05000295/1986011

Insp Repts 50-295/86-11 & 50-304/86-10 on 860414-0613. Violations Noted:Failure to Follow Operating Procedures & Conduct Required Tech Spec Surveillance on Control Room Ventilation Charcoal Filter

ML20207F359
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	07/14/1986
From:	Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207F309	List: IR 05000295/1986011 ML20207F304 ML20207F344
References
50-295-86-11, 50-304-86-10, NUDOCS 8607220525
Download: ML20207F359 (18)

Text

U.S. NUCLEAR REGULATORY COMMISSION

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REGION III

Reports No. 50-295/86011(DRP); 50-304/86010(DRP)

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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: April 14 through June 13, 1986 Inspectors: M. M. Holzmer L.p.Kan,ter Approved By:

< + ~ ~ . ut ai B. L. Burgdss,rChief I/'// /%

Reactor Projects Sect * , 2A Date Inspection Summary Inspection on April 14 through June 13, 1986 (Reports No. 50-295/86011(DRP);

50-304/86010(DRP))

Areas Inspected: Routine, unannounced resident inspection of licensee action on previous inspection findings; Unit 1 trip on loss of EHC;1oss of engineered safety features logic due to pulled fuses; failure of the IB main steam check valve; Unit 1 Unusual Event due to excessive reactor coolant system leakage; Unit 2 trip on loss of the 2B main feedwater pump; missed surveillance of control room makeup charcoal filter; operational safety and engineered safety feature (ESF) system walkdown; surveillance; maintenance; licensee event reports (LERs); training; IE Bulletin followup; and Region III requests. In addition, this report documents the April 29, 1986, meeting between the licensee site and corporate staffs and the NRC Pegion III staff regarding operation with incorrect negative flux rate reactor trip setpoints and regarding the December 14, 1985, loss of residual heat removal even Results: Of the 15 areas inspected, no violations or deviations were identified in 13 areas, and two violations were identified in the remaining two areas (failure to follow operating procedures - Paragraphs 5 and 9; and failure to conduct a technical specification required surveillance on the control room ventilation charcoal filter - Paragraph 9).

86072:20525 060715 PDR ADOCK 05000295 G PDR

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DETAILS

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1. Persons Contacted

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• G. P11m1, Station Manager

• E. Fuerst, Superintendent, Production

• T. Rieck, Superintend (nt, Services

• Kurth, Assistant Station Superintendent, Operations ,

R. Johnson, Assistant Station Superintendent, Maintenance s J. Gilmore, Assistant Station Superintendent, Planning ,

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R. Budowle, Assistant Station Superintendent, Technical Services L. Pruett, Unit 1 Operating Engineer N. Valos, Unit 2 Operating Engineer M. Carnahan, Training Supervisor

• R Cascarano, Technical Staff Supervisor

• C. Schultz, Regulatory Assurance Administrator -

V. Williams, Station Health Pnysicist '-

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

• J. Rappaport, Quality Assurance Engineer -

• J. Lafontaine, Maintenance Staff Engineer .

• Indicates persons present at exit intervie .

2. Licensee Actions On Previous Inspection Findings ,

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(Closed) Open Item (304/86005-09): Missed 14 Day Approval of Temporary Procedure Change. This was considered an open item pending review of the completed corrective action package (see Inspection Reports No. 295/86005:

304/86005 for further details). On June 9, 1986, the procedure change to Zion Administrative Procedure (ZAP), 5-51-4, Procedure Control and Approval became effective. The resident inspector reviewed the change and found it adequat '

(Closed) Unresolved Item (304/85043-04): Improperly Installed Check '

Valves in Reactor Containment Fan Cooler (RCFC) Motor Heat Exchanger "

Housing Drains. This was considered an unresolved item pending further evaluation of the safety significance of the even The licensee's Station Nuclear Engineering Department (SNED) evalua'tod the effects that the installation and orientation of these check valves had on the operability of the RCFC motors. Results from this investigation showed that the RCFC motors would have operated properly even with the check valves installed backwards. Calculations showed that the total amount of water that could have collected inside the RCFC motor enclosure during accfdent conditions would have had no detrimental effect on the operability of the RCFC motor. The calculations and assumptions were reviewed by the NRC . ,

resident inspector and appeared to be adequat The check valves in all five Unit 2 RCFC motor housing drain lines have been re-installed in the proper directio ,

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f '(Closed) Unresolved Item (295/86005-02): February 16 and March 19, 1986

, uJnplanned Gaseous Releases. Both events were consolidated into one

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/' Unresolved Ite *

On February 16, 1986, the Zion Station experienced an unplanned gaseous y ', release at 5:25 p.m. while the operators were making up to the Refueling Water Storage Tank (RWST) on Unit 1. This was considered an Unresolved Item pending determination of why valve 1FCV-VC111B was open. The release was caused by a missed step in Station Operating Instruction (50I) 2, which

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required that IFCV-VC1118 be verified closed during makeup to the Unit 1 RWST (see Inspection Reports No. 295/86005; 304/86005 for details). Makeup

- stop valve 1FCV-VC111B is normally closed, however, during the dilute or alternate dilute mode of operation this valve opens. After talking with

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the individual that performed S0I-2, the inspector determined the individual 4 ' was diluting at the time of the even .

On March 19, 1986, an unplanned gaseous release occurred at approximately 6:30 a.m. while the operators were making up to the Unit i Volume Control Tank (VCT). This was considered an Unresolved Item pending location of the deviation report. The release was caused by leakage through IVC 8119, a relief valve on the letdown heat exchanger, (see Inspection Reports

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No. 295/86005; 304/86005 for details). Radiation Protection (RP) personnel

• ( sampled the room and found no abnormal leakage. The maximum instantaneous release rate was 2.95 percent of the allowable Technical Specification (TS)

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AEeviationreportwasneverinitiatedforthisevent. Past practice of the station has been to report this type of event through the deviation report process; however, Zion Administrative Procedure (ZAP) 15-52-1, Part C, Deviation and Reportable Event Reporting, Non-Reportable Events, which contains the guidelines the licensee utilizes for writing a deviation

' report, does not address this type of event under the deviation (non-reportable) category. The guidelines for Deviation and Reportable Event Reporting in the ZAP appear to generally define the types of events that would be reportable as significant deviations from accepted normal operation. Thus, it was determined that a deviation report was not required. A work request was written and repair work was done on the valv No violations or deviations were identifie . Summary of Operations

. Unit 1 The unit operated at power levels up to 100 percent until May 4, 1986, when the unit tripped from 55 percent reactor power due to loss of electro-hydraulic control system fluid pressure (see Paragraph 4). Following repairs, the unit was made critical at 7:25 p.m. on May 6, 1986, and was tied to the i .- grid at 1:35 a.m. on May 7, 1986. On May 9, 1986, the unit was shut down from 60 percent reactor power due to a failure of the B loop main steam check

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valve (see Paragraph 6). Following replacement of the B loop main steam i

, check ~ valve, the unit was returned to normal operating temperature and

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pressure (Mode 3) in preparation for a reactor startup. On May 16, 1986, while in mode 3, a 25 gpm packing leak from one of the two pressurizer spray valves occurred (see Paragraph 7), and the unit pressure and

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temperature were reduced until the leak could be isolated. An Unusual Event was declared in accordance with the licensee's Generating Stations

Emergency Plan (GSEP). Because the licensee was unable to repair the suspected valve packing leak, the valve was left in the isolated condition, and the unit was returned to operation on May 18, 1986. The unit operated at power levels up to 100 percent for the remainder of the inspection perio Unit 2 The unit operated at power levels up to 100 percent until 5:17 p.m. on May 19, 1986, when the unit tripped from full power due to a loss of the 2B main feedwater (FW) pump (see Paragraph 8). The 28 FW pump was lost when an instrument mechanic inadvertently secured control power to the 2B FW pump while preparing to work on a modification to the 2C FW pump control syste After the cause of the trip was determined, the unit was made critical at 20:14 p.m. on May 19, 1986, and was tied to the grid at 4:12 a.m. on May 20, 1986. The unit operated at power levels up to 100 percent for the remainder of the inspection perio No violations or deviations were identifie . May 4,1986, Unit 1 Reactor Trip Due to Loss of Turbine Electro-Hydraulic Control (EHC) System Fluid pressure On hay 4, 1986, Unit 1 tripped from 55 percent steady state reactor power while plant personnel were conducting EHC system troubleshooting in accordance with Procedure PT-102, Intercept and Reheat Stop Valve Tes The EHC cycle times had been excessively short due to internal system hydraulic fluid leakage. The troubleshooting was being performed in an attempt to cycle check valves in order to allow them to reseat. After one of the test group pushbuttons had been held down for about three minutes, the EHC system pressure decreased due to the combined effects of the test pushbutton and the internal system leakage. The decreased pressure was insufficient to keep the governor valves open, and turbine load decreased by about 200 megawatts (MW) while the governor valve demand signal increased as the system attempted to restore the governor valves to the correct position. When the mismatch between the demand signal and impulse pressure reached 20 percent, the EHC system transferred from the impulse pressure feedback activated (IMP-IN) mode to the impulse pressure feedback de-activated (IMP-0UT) mode, as designed. This action froze the gcvernor valve demand signal at about 72 percent. When EHC fluid pressure reached the setpoint for starting the second EHC pump, the pump started and EHC pressure rose rapidly, causing the governor valves to open to the demand signal. Turbine load increased rapidly to about 800 MW, and the reactor tripped as designed on high nuclear instrumentation (NI) positive flux rat The turbine load decrease was attributed to the combined effects of the test procedure and the internal system leakage which exceeded the capacity of one EHC pump. In addition, the setpoint of the pressure switch which starts the second EHC pump had drifted from 1350 psig to 930 psig, delaying the start of the second EHC pump. The EHC system low pressure alarm setpoint had also drifted downward from 1450 psig to 1025 psig, preventing operators from receiving proper advance warning of the pressure degradatio *

The EHC system low pressure alarm switch was replaced due to excessive wear and the backup pump start switch was recalibrated. Their calibration

frequencies will be increased from once in four years to once each refueling outage. Several fluid system internal leaks were identified and repaire Additional inspections for internal fluid leaks will be conducted during the 1986 summer refueling outage. The use of PT-102 for the conduct of EHC related valve stroking during unit operation has been prohibited by a standing order until after additional repairs are made during the summer refueling outage to reduce EHC fluid leakag No violations or deviations were identifie . May 5,1986, Unit 1 Loss of Both Trains of Engineered Safety Features (ESF)

Logic Due to Pulled Fuses On May 5,1986, both trains of ESF logic for Unit I were lost when an operator inadvertently pulled the wrong fuses. Unit I was in mode 3 (hot shutdown) following a reactor trip (see Paragraph 4) with the main steam isolation valves (MSIV) shut for EHC system troubleshooting. As required by instruction S01-31, Main Steam, if the MSIVs are to remain closed for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the fuses to the DC solenoid valves must be remove After being directed to remove the fuses, the equipment operator (E0)

proceeded to the auxiliary electric room and inadvertently removed the fuses to the ESF logic power circuit. Removal of the ESF fuses resulted in a " Safeguards Loss of Power" alarm in the control room. The shift foreman (SF) immediately went to the auxiliary electric room to stop the E0 from proceeding further, but the E0 had already removed all four train A fuses and had removed three out of four train B fuses. After determination that re-insertion of the fuses would not result in a safety injection signal, the fuses were re-inserted, restoring ESF logi The event was attributed to a failure to follow a caution statement in S01-31, which requires the operator to verify the correct fuses by comparing the actual fuse labels to the appropriate station drawing. Technical Specification (TS) 6.2.A.1 requires adherence to procedures involving operation of systems and components important to safety. Failure to follow this 50I-31 caution statement is considered an example of a violation of TS 6.2.A.1 (295/86011-01).

A contributing factor to the error was the fact that the caution statement was not specific in that it did not provide the appropriate drawing numbe In addition, the ESF fuse holders were not labelle The SF, reactor operator, and E0 were disciplined for the failure to follow S0I-31. A temporary change to S01-31 was implemented to clarify the caution statement. "Dymo" tape labels were installed to mark the ESF fuse During the outage, a walkdown of the auxiliary electric room will be conducted to correct any fuse labelling deficiencie In the long term, the station intends to establish a program and procedure to improve station labelling.

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ESF equipment is required to be operable in mode 3. Removal of the ESF fuses caused the loss of all automatic and manual safeguards actuation

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capabilit Except for containment spray, which requires an ESF signal to start, each ESF component could have been manually started or aligned from the control board. Train A was inoperable for a period of approximately five minutes, and train B was inoperable for approximately three minutes. Normal indication and alarm functions for ESF equipment were availabl One violation and no deviations were identifie . May 9, 1986, Unit 1 Shutdown to Repair the IB Main Steam Check Valve On May 8, 1986, at about 2:40 p.m. with Unit I at about 55 percent power and increasing at about 0.25 percent per minute, the B loop delta-T deviation alarm was received. By 3:00 p.m. the B loop delta-T had increased from the alarm setpoint of 2 percent to approximately 4 percen Operating personnel stopped the power increase at about 58 percent, and suspected that the B loop T-cold instrument had failed "as is". The reactor protection bistables associated with that instrument were placed in the tripped condition, and the power increase was resumed. At about 3:35 the nuclear station operator (NS0) stopped the power increase at about 60 percent after having observed abnormally low readings on nuclear instrumentation power range channels N41 and N42, and abnormally high readings for B loop T-ave and steam generator pressur Technical staff personnel verified a normal flux pattern by conducting a flux map which was completed at about 8:00 Other parameters were checked, and a failure of the B loop main steam (MS) check valve was verified. At 10:30 p.m. a reactor shutdown was commenced, and at 3:00 on May 9, 1986, the unit was in mode After the plant was cooled down, an inspection of the IB MS check valve was performed. The valve disk was found detached from the pivot arm and partially blocking the steam line. The retainer and associated spring pack were not found and were presumed to be in the steam lin The valve disk was replaced. An analysis was performed to determine whether the loose parts could possibly damage the turbine, and the results indicated that at 100 percent steam flow, the retainer would not reach the turbine inlet. The licensee intends to inspect the remaining three MS check valves on Unit 1 during the summer 1986 refueling outage. This is an Open Item pending NRC review of the inspection results. (295/86011-02)

No violations or deviations were identified. One Open Item was identifie . May 16, 1986, Unusual Event and Delay of Unit 1 Startup Due to Excessive Reactor Coolant System (RCS) Leakage On May 16, 1986, at about 5:30 a.m., with Unit 1 at normal operating temperature and pressure in mode 3 (hot shutdown), the licensee declared an Unusual Event (UE) due to an identified RCS leak rate in excess of the

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10 gpm Technical Specification limit. The source of the leak appeared to be blown packing on the 8 loop pressurizer spray valve (IPCV-RC06). The

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leakage was directed to the pressurizer relief tank (PRT) by means of leakoff piping. The increase in PRT inventory caused the PRT rupture disk to fail, and the leakage spilled out to the containment floor and into the containment sump. The leak rate was estimated to be about 25 gp The licensee conducted a cooldown and depressurization of the unit and closed the isolation valves for IPCV-RC06, terminating the Unusual Even The licensee was unable to make repairs to the spray valve due to a stuck packing lantern ring, and returned the unit to operation on May 18, 1986, with the B loop spray valve isolated. Because the licensee was unable to remove the lantern ring, it was not clear whether the spray valve or one of its isolation valves was the source of the leakage. All three valves will be examined and repaired as necessary during the summer refueling outag Pressurizer pressure control is maintained using the D loop spray valv No violations or deviations were identifie . May 19,1986, Unit 2 Reactor Trip Due to Loss of the 2B Main Feedwater Pump On May 19, 1986, at 5:17 p.m. with Unit 2 operating at 99 percent reactor power, the 28 main feedwater pump (MFP) control power was inadvertently de energized causing the 28 MFP to run back to minimum speed. The resulting transient caused the level in the A steam generator to reach the 10 percent low-low level reactor trip setpoin The reactor tripped as designed, and all safety systems functioned normall The 2B MFP control power was inadvertently secured by an instrument mechanic (IM) who had intended to de-energize the control power to the 2C MFP. The licensee is in the process of upgrading the turbine driven MFP controls for both units, and had modified the 2B MFP controls. The post-modification testing for the 2C MFP was in progress at the time the IM was instructed to de-energize 2C MFP control power. The licensee has evaluated the event, and this is considered an Unresolved Item pending review of the licensee's investigation and corrective actions (304/86010-01).

A post-trip review was conducted following the trip, and the licensee commenced a reactor startup at 10:14 p.m. on May 19, 1986. The unit was tied to the grid at 4:12 a.m. on May 20, 198 No violations or deviations were identified. One Unresolved Item was identifie . Missed Surveillance of Control Room Charcoal Filter Following Replacement On November 18, 1985, based on the findings of a Quality Assurance (QA)

audit, a Discrepancy Record (DR) was initiated which stated, in part, that stationmen had been changing safety related heating, ventilation and air conditioning (HVAC) filters without a work request (WR). Until the audit, the licensee had initiated safety related filter replacements either via a telephone call or a non production work request form. This form was unlike the standard WRs utilized for repair wor ~

Corrective actions included distribution of a memorandum from the Stationman Supervisor to all Stationman Foremen, stating that all safety related filter

replacements could only be done under a WR addressed to the Mechanical Maintenance (MM) Departmen Filter replacements would be performed by stationmen with followup WR processing completed by the MM departmen Implementation of these corrective actions was completed on January 16, 198 On March 2,1986 Periodic Test (PT) 18, Control Room Charcoal Booster Fans Test, was performed which indicated that the control room makeup HEPA filter had a high differential pressure, (2.24 inches water column'

compared to the maximum 2.0 inches water column as specified in PT-18).

Upon review of PT-18, the shift control room engineer (SCRE), initiated a WR, Z-48625, to replace the filter. The "N0 Test Required", and the "YES for TS Required" boxes were marked on the form. The TS reference number associated with this filter system was also written on the WR, however, it did not reference the specific section, (i.e., 3.17 was written, not 3.17.1 C). The operating engineer reviewed, signed, and forwarded the WR to the mechanical maintenance (MM) department without making any change The MM's realized that the stationman group normally change these type of filters and routed the WR to that departmen On March 7, 1986, the filters in question were changed by the stationman group. This was done without obtaining permission from Operations Department, as required by station procedures. The maintenance foreman signed and dated the WR on April 13, 1986, and placed it in the WR completion basket in the control roo On April 23, 1986, the SCRE reviewed the W Because of the lack of several authorization signatures, he was unable to close out the WR. He attached a note and routed it to the Operating Engineer (OE). The OE requested the technical staff system engineer to investigate an apparent problem with the way WR Z-48625 was handled. The OE routed the WR to the appropriate system engineer since he typically handled work that involved filter replacements and coordinated with the testing contractor that ran the efficiency tes The system engineer identified that no efficiency testing was performed on the filter system after replacement, as is required by Technical Specification (TS) 4.17.1.C. After discussion with station management and the Zion Nuclear Licensing Administrator the system was considered to be in a seven day limiting condition for operation (LCO) per TS 3.17.1.A. The l efficiency testing was satisfactorily completed by a contractor the same

day.

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On May 9, 1986, an onsite review group discussed the corrective actions needed to prevent recurrence, among which were the reevaluation of which work group would perform filter replacements and the tracking method for l work done. It was decided that the procedure implemented in January was I

still the most effective, however a more formal process should be used to l

inform the appropriate group of their responsibilitie _

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• Licensee Corrective Actions

' A copy of the Licensee Event Report (LER) on this event will be routed to all personnel and to all licensed individuals. This will be accomplished through the routine required reading package for operators. In addition, the requirements of Technical Specifications 3.17.1.A and 4.17.1.C will be integrated into the retraining program for all licensed individual . The licensee will fully implement the corrective actions stated in the November 1985 DR in addition to the MM foreman accompanying the stationman on the job. When the work is completed, the MM department will complete the appropriate WR

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processing, including notification to the technical staff of all filter replacement wor . Revision of the associated periodic tests and local annunciator response procedures that involve safety related filter replacements will be made to address instructions concerning the need to test these type of ventilation filter . Permanent placards will be posted on all doors and panels which provide access to safety related filters. The placards will state that a test is required after filters have been replace Safety Significance Because the HEPA filters passed their efficiency test, it can be assumed that they would have performed their safety function from the time they were installed March 7, 1986 until they were tested on April 24, 198 Poor licensee management of the corrective actions imposed by the DR appeared to be a contributing factor to the event even though the corrective action to verify that safety related red tags were being maintained for quality documents was effective. The licensee has performed numerous safety related filter replacements. However this was the first time a work request was initiated for this type of work after the DR. This appears to be the only known example of a missed surveillance of control room makeup HEPA filter c. Enforcement Technical Specification 4.17.1.C requires that the control room makeup HEPA filter be efficiency tested after each complete or partial replacement of the filter ban Failure to perform efficiency testing of the control room makeup HEPA filter until approximately 40 days after their replacement is considered a

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violation of TS 4.17.1.C (295/86011-03;304/86010-02).

Technical Specification 6.2.A states in part, " detailed written procedures including applicable check off lists covering items listed below shall be prepared, approved, and adhered to:

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' Preventive and corrective maintenance operations which could have an effect on the safety of the facility."

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Zion Administrative Procedure, ZAP 3-51-1, Origination and Routing of Work Requests, requires the following: The operating shift supervisors are required upon the completion of the repair work, to record the tests and specify who will perform the tests by checking the appropriate bo The operating engineer is to make a final review of the work request, then sign and date the appropriate bloc The master mechanic / maintenance staff engineer is to review the work request and initial to indicate receipt and acceptanc The operating shift supervisor (SRO licensed only), is to sign the block that gives authorization to start the wor TS 6.2.A.6 was not adhered to in that for Zion Work Request Z48625, dated March 2, 1986: The incorrect box was checked for the test required /no test required section of the work request form by the SCRE (operating shift supervisor). The operating engineer reviewed, signed and dated the appropriate block. However, in his review he failed to realize that a surveillance test was not require The maintenance staff engineer who received the work request failed to initial the for Shift authorization to start work was not obtained, and the block was not signe The above are considered additional examples of a violation (295/86011-01; 304/86010-03).

Two violations and no deviations were identifie . Operational Safety Verification and Engineered Safety Features System

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The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators from April 14 through June 13, 1986. 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 component Tours of the auxiliary and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and

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l to verify that maintenance requests had been initiated for equipment in

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need of maintenance. In response to the event described in Paragraph 5,

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a walkdown of the Unit 1 auxiliary electric room was conducted to assess labelling of fuse holders. Several examples of unlabelled fuse holders were identified and provided to the plant manager for corrective actio The inspectors by verified observation and direct interview verified that selected 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. The painting program in the auxiliary building is nearly complete in the common hallways, and progress was made in movement of non-essential equipment and materials out of the auxiliary buildin From April 14, 1986, to June 13, 1986, the inspectors walked down the accessible portions of the auxiliary feedwater and service water systems to verify operabilit 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 The May 9, 1986, reactor shutdown due to the failure of the B loop main steam check valve was observed in its entiret Shift supervisors closely supervised operations activities and were continuously aware of the status of the plant. The procedure for shutdown of the reactor, GOP-4, was open and referenced frequently by shift supervisors, nuclear station operators (NS0), equipment operators, and equipment attendants. Communications were thorough and feedback was routinely sought by shift supervisors when giving instructions to members of the shif No violations or deviations were identifie . Monthly Surveillance Observation The inspector observed Technical Specifications required surveillance testing on the engineered safety features actuation and auxiliary feedwater systems and verified that testing was performed in accordance with adequate procedures, the 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-5, Reactor Protection Logic Test

- PT-7A, Starting Procedure For Motor Driven Auxiliary Feedwater Pump Lube Oil Pump

- PT-10, Safeguards Actuation Test l

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In addition to the above, the following procedures were reviewed:

- PT-15, Reactor Containment Fan Cooler Test

- PT-158, Reactor Containment Fan Cooler Refueling Outage Test 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 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; fcnctional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were 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 determine status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance activities were observed or reviewed:

- Repair of the 1C feedwater regulating valve

- Replacement of the IB main steam check valve disk Following completion of maintenance on the 1B main steam check valve, the inspector verified that these systems had been properly returned to servic 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

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LER N DESCRIPTION

85-007-01 Potential Unmonitored Release of Airborne Activity Through IFCV-RV85B 86-007 Instrument Air Containment Isolation Valve IA0V-IA01A Closed 86-011 0 Diesel Generator Inadvertent Start During Surveillance Test 86-017 Missed Surveillance Of Control Room Make-up HVAC HEPA Filters86-018 Unit 1 Reactor Trip Due To EHC Hydraulic Fluid Pressure Problem UNIT 2 LER N DESCRIPTION 86-011 Reactor Trip Caused By Noise In Nuclear Instrumentation System 86-012 Inadvertent ESF Actuation - Manual Start Of 2B Auxiliary Feedwater Pump 86-013 Failure To Meet Technical Specification For Lower Limit of Detection on Fire Sump Activity Regarding LER 295/86-017, " Missed Surveillance of Control Room Make-up HVAC HEPA Filters," a violation will be given for this event (see Paragraph 9 of this report). This LER is considered close Regarding LER 304/86-013, " Failure To Meet Technical Specification (TS) For Lower Limit Of Detection (LLD) On Fire Sump Activity", the licensee's corrective actions were reviewed and considered acceptable. This violation of Technical Specifications 4.11.2.b (Table 4.11-1) was identified by the licensee as part of the corrective actions for a prior event. This is considered a licensee identified violation; considered to be low safety significance; was reported as requried; corrective action will be forthcoming within a reasonable time; and that could be reasonably expected to have been prevented by the licensee's corrective action for a previous violatio Based on these factors no citation will be issued (304/86010-04).

As a result of the calculated limit for a worst case dilution flow rate, it was determined that the fire sump LLD level would still be ten times less than the 10 CFR 20 Appendix B discharge limit to an unrestricted are One licensee identified violation was identifie .

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14. Training

During the inspection period, the inspector reviewed abnormal events and unusual occurrences which may have resulted, in part, from training deficiencies. Selected events were evaluated to determine whether the classroom, simulator, or on-the-job training received before the event was sufficient to have either prevented the occurrence or to have 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 Events reviewed included the events discussed in Paragraphs 6,7, and 8 of this repor In addition, LERs were routinely evaluated for training impac Training deficiencies were found to contribute to the May 19, 1986, Unit 2 reactor trip, in that the instrument mechanic who de-energized control power to the running main feedwater pump, and his supervisor were unaware of the status of modifications on the Unit 2 feedwater pump The individuals involved were qualified for the work to be performed, but needed additional information (status of the modifications in question)

if the trip was to have been avoided. The remainder of the events reviewed were not found to have significant training deficiencies as contributors. The plant shutdown conducted for Unit 1 on May 9, 1986, was observed in its entirety, and all personnel involved appeared to have been properly trained to perform their function Lessons learned were factored into the training program in response to a potential unmonitored release path (LER 295/85007-01), and the March 11, 1986, Unit I reactor trip due to the reactor trip breaker not being fully racked into place (LER 295/86012-00).

Two training sessions for all plant personnel were attended by the resident inspectors. The training involved the use of new whole body frisking booths for the auxiliary building, and a review of good health physics practice Several of the topics were addressed in response to findings by INPO, NRC, and quality assurance audits. In addition, one training session covering the plant modification program was attended by one resident inspecto These training sessions were informative and professionally presented.

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No violations or deviations were identifie . IE Bulletin Followup l

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For IE Bulletin 79-01 and its supplements concerning environmental qualification of Class IE equipment, the inspector verified that the licensee's response had been inspected and found acceptable by Region III and headquarters inspectors as documented in Inspection Reports No. 295/85006 and 304/85006. This Bulletin and its supplements are closed in this report for tracking purposes onl No violations or deviations were identifie _ _ _ . _ -

1 Inspection of NRC Region III Requests

, In response to a January 30, 1986, event at Browns Ferry 3, the resident inspectors were instructed to determine whether cracks existed on aluminum housings for diesel generator (DG) shaft driven pumps. The Browns Ferry DGs were manufactured by the Electro-Motive Division of General Motors, and the cracks appeared to be caused by steel inserts which were press fit into the aluminum housing The inspector verified by conversations with the cognizant technical staff engineer that there are no aluminum housings for shaft driven pumps on the Zion DGs. Zion's DGs are manufactured by Cooper-Besseme Response to this request is considered complet In a memorandum dated April 28, 1986, all resident inspectors were directed to perform the inspection defined in IE Manual procedure TI 2515/75. The inspection involved determination of whether Limitorque motor operated valve operator wiring was environmentally qualified and assessment of the licensee's response to IE Information Notice 86-0 IE Information Notice 86-03 resulted from a 10 CFR Part 21 report initiated by Zion Station which identified wiring which could not be identified as environmentally qualified as required by 10 CFR 50.4 Corrective actions for this issue have already been taken by the licensee, and these actions were reviewed and found acceptable in Inspection Reports No. 295/85041 and 304/85042. Response to this memorandum is considered complet In a memorandum dated March 27, 1986, resident inspectors were directed to verify that the licensee had received Generic Letter 85-15 regarding the deadline for implementation of environmental qualifica-tion (EQ) requirements. The inspector verified that the licensee had received the subject Generic Letter, and that it was disseminated to the appropriate individuals who were aware of the deadline of November 30, 1985. EQ modifications to Unit I were complete by November 30, 1985, at which time Unit 2 was in a refueling outag Unit 2 EQ modifications were complete prior to startup at the end of the outage. Response to this memorandum is considered complete.

I No violations or deviations were identifie . April 29, 1986, Management Meeting Regarding Incorrect Settings For l Negative Flux Rate Reactor Trip Setpoints and December 14, 1986, Loss of Residual Heat Removal Pumps On April 29, 1986, a Management Meeting was held between members of the licensee's site and corporate staffs and the NRC Region III staff in the Region III offices in Glen Ellyn, Illinois. The meeting was held to discuss the events leading to the operation of Zion Units 1 and 2 with the negative flux rate trip (NFRT) setpoints set incorrectly, and to discuss the licensee's corrective actions to prevent recurrence of the December 14, 1986, event during which both residual heat removal (RHR) pumps were lost while the unit was in mode 5 (cold shutdown).

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The licensee presented the event chronology and correspondence history for the NFRT setpoint issue for the purpose of clarifying and providing detail

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for NRC Region III management and staff. The event chronology began wit a 1979 notification by Westinghouse to the licensee of the potential for operation with NFRT set nonconservatively for certain rod drop accidents on some Westinghouse plants. The history was complex lengthy and appeared ,

to involve both lack of specificity in communications from Westinghouse, and incorrect assumptions by the licensee. NRC Region III commented that the issue would be examined in future inspections by Region III inspectors,

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and expressed appreciation for the presentatio The licensee then gave a presentation of their corrective actions for the loss of RHR event. These actions included procedure changes to operations procedures used during cold shutdown and refueling conditions, modifications to reactor vessel level indicating systems to increase their reliability, and training for operators. Statements regarding which of these actions

would be complete prior to the Unit I summer 1986 refueling outage were also provide '

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No violations or deviations were 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

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this inspection is discussed in Paragraph 6.

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19. Unresolved Items

, Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items, violations, or

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deviations. One Unresolved Item disclosed during this inspection is discussed in Paragraph . Licensee Identified Violations In accordance with 10 CFR Part 2, Appendix C, General Statement of Policy and Procedure for NRC Enforcement Actions, the NRC will not generally issue a notice of violation for a violation that meets all of the following tests: It was identified by the licensee; It fits in Severity Level IV or V;

, It was reported, if required; It was or will be corrected, including measures to prevent recurrence, within a reasonable time; and It was not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous

violation.

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One licensee identified violation disclosed in this inspection is discussed in Paragraph 13 of this repor *

21. Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the inspection period and at the conclusion of the inspection on June 13, 1986, to summarize the scope and findings of the inspection activities. The licensee acknowledged the inspectors' comment The inspector 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 proprietary, but stated that, until they review the report, they could not be certain whether any of the information contained in the report was proprietary.

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ATTACHMENT 1

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LIST OF ATTENDEES APRIL 29, 1986, MANAGEMENT MEETING Commonwealth Edison Company N. J. Kalivianakis, Vice President, Nuclear Division L. F. Gerner, Regulatcry Assurance Superintendent P. C. LeBlond, Nuclear Licensing Administrator, Zion M. S. Turbak, Director, Operating Plant Licensing F. G. Lentine, Station Nuclear Engineerir.g Department D. M. Lawrence, Station Nuclear Engineering Department R. J. Squires, Staff Engineer, Nuclear Safety Department T. A. Rieck, Superintendent, Services R. J. Budowle, Assistant Superintendent, Technical Services C. J. Schultz, Regulatory Assurance Admiriistrator A. J. Ockert, Assistant Technical Staff Supervisor R. E. Lane, Primary Systems Group Leader, Technical Staff R. Y. Chin, Assistant to the Technical Staff Supervisor NRC Region III C. W. Hehl, Chief, Operations Branch B. L. Burgess, Chief, Projects Section 2A C. A. VanDenburgh, Acting Chief, Test Programs Section M. M. Holzmer, Senior Resident Inspector, Zion L. E. Kanter, Resident Inspector, Zion M. L. McCormick-Barger, Inspector, Test Programs Section J. F. Suermann, Project Manager, Projects Section 2A i.

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