IR 05000295/1986028

Insp Repts 50-295/86-28 & 50-304/86-28 on 861118-1229.No Violations or Deviations Noted.Two Items Re Containment Integrity & Technical Support Ctr (TSC) HVAC Potentially Involve Escalated Enforcement.Major Area Inspected:Tsc HVAC

ML20209H457
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/26/1987
From:	Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20209H360	List: IR 05000295/1986028 ML20209H356
References
50-295-86-28, 50-304-86-28, NUDOCS 8702060058
Download: ML20209H457 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. 50-295/86028(DRP);50-304/86028(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, Illinois Inspection Conducted: November 18 through December 29, 1986 Inspectors: M. M. Holzmer P. L. Eng L. E. Kanter Approved By:

ReactorProjectsSection2A f //b6k2 Date'

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Inspection Summary Inspection on November 18 through December 29, 1986 (Reports No. 50-295/86028(DRP);

50-304/86028(DRP))

Areas Inspected: Routine, unannounced resident inspection of licensee action on previous inspection findings; 1A Reactor Coolant Pump transportation incident; Technical Support Center (TSC) HVAC not able to meet design requireme'nts; automatic start of 18 Service Water Pump; loss of containment integrity; automatic start of OC Component Cooling Pump; room cooler fans not envirc.' mentally qualified; operational safety and Engineered Safety Feature (ESF) system walkdown; surveillance; maintenance; training, TMI item followup and an allegatio Results: Of the 11 areas inspected, no violations or deviations were identifie Two items (loss of containment integrity and TSC HVAC not able to meet design requirements) potentially involve escalated enforcement.

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DETAILS 1. Persons Contacted

• Plim1, 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 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 Physicist J. Ballard, Quality Control Supervisor W. Stone, Quality Assurance Supervisor

• J. Rappeport, Quality Assurance Auditor

• J. Yost, Quality Control Inspector

• Indicates persons present at exit intervie . Summary of Operations Unit 1 The unit remained shutdown for a refueling and maintenance outage for the entire period. The unit is expected to be on line in February 198 Unit 2 The unit operated at full power for the entire perio . Unit 1 "A" Reactor Coolant Pump Transportation Incident On November 17, 1986, Westinghouse shipped the refurbished 1A Reactor Coolant Pump (RCP) motor from Cheswick, Pennsylvania to Zion Station via truck (International Transport Company). Because the shipment was oversized

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and overweight, special routing for the shipment was necessary. Prior to leaving Cheswick, survey results indicated that dose rates measured on contact with the box containing the RCP motor were less than 0.1 mrem /h No smearable contamination on the plastic wrapper covering the motor inside the box was detecte On November 24, 1986, as the truck proceeded along the approved route on Interstate 74 (I-74) near Champaign, Illinois, the top of the box housing

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the pump motor hit a bent catwalk support beam for an overhead road sign, resulting in damage to the top of the box and partially tearing the plastic wrapper covering the moto .- .

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After the driver pulled off the road to inspect the damage, a passing

. State of Illinois vehicle also stopped to investigate and the State Police were notified. The shipment was inspected and released by the State Police, as reported in Champaign County Illinois, State Police Report No. 10-86-1249. The driver called his dispatcher for further instructions and was told to proceed to Zio The driver continued with his shipment alonci the prescribed route until he stopped for dinner at a restaurant in Palatine, Illinoi Upon leaving the restaurant, he observed that his truck was surrounded by several Palatine police and fire vehicle This incident is described in Palatine police Report No. 86-L-2416-96. The Palatine police department notified the Emergency Services and Disaster Agency, who in turn, notified Commonwealth Edison. The shipment was subsequently surveyed and released. The shipment arrived at the Zion station at approximately 9:00 a.m. on November 28, 1986.

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Surveys were performed on the box and its contents by licensee personnel on its arrival at the Zion station. Dose rates on contact with the box were measured less than 0.2 mrem /h No smearable contamination was found on the inside of the box or on the plastic covering the moto The hi hest smearable contamination was found inside the motor windings at roug ly 26400 dpm/100 cm2 , and ?050 dpm/100 cm 2 on the bottom of the motor ram Preliminary inspection for damage to the motor revealed peening of the top edge of the flywheel and apparent minor damage to the oil cooler.

, Additional inspection on December 1 and 2, 1986 by Westinghouse

representatives revealed no significant damage to the pump motor with the exception of the upper oil pot alarm switch mechanism and its

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associated flange. The alarm switch was replaced. Pump testing will be completed per the previously defined outage schedul No violations or deviations were identifie . November 21, 1986, Notification that the Technical Support Center (TSC)

was not Able to Meet Design Requirements On November 21, 1986, the licensee informed the resident inspector that i their computer their TSC couldand not miscellaneous be demonstratedventilation to meet system its design (0V),iteria.which cr The supplies licensee found that some of the rooms supplied by the OV system were not atapositivepressurewithrespecttoadjoiningareas,resultinginthe potential for air leakage into the 0V system from the auxiliary buildin In the event of high airborne activity following an accident, the TSC could become uninhabitable.

l This discovery occurred during the licensee's followup of a Seatember 11, 1986 event in which a release of airborne radioactivity into tie auxiliary building resulted in noble gases reaching both the control room and the i

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TSC, the respective ventilation systems of which had been placed in the accident mode because of previously identified design problem The licensee has initiated the following corrective actions:

• Leakage paths from the auxiliary building into the 0V and PV (control room HVAC) systems were identified and closed by bubble type dampers or blank flange * Flow balance testing of the essential portions of the OV syste * Issuance of a report identifying conclusions and proposed changes from the OV flow balance testing. The final report will include

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all necessary calculations needed to demonstrate the original design

, requirements have been met. Scheduled completion of this report is expected by February 13, 198 * Investigation of the feasibility of temporarily blanking off the interfaces between the 0V and PV systems, as well as permanent modifications to separate the 0V and PV system * Ensuring that procedures adequately specify the requirement to close the door between the control room and TSC in the event of an acciden * Revision of the P and ID to accurately reflect as-built conditions of the PV syste * Review of the original installation and design control of the PV system relative to the requirements of 10 CFR 50 Appendix B, Criteria 3-11 whichwereineffectatthetimeofinstallatio This is considered an Unresolved Item pending completion of NRC inslection into the potential design control deficiencies and the adequacy of t1e licensee'sGDC19 analysis (295/86028-01;304/86028-01). If the results of the inspection indicate potential for escalated enforcement, the matter will be referred to a Region III enforcement boar One Unresolved Item was identifie . November 28, 1986, Automatic Start of the OC Component Cooling Pump i On November 28,1986,at3:22p.m.,withUnit1incoldshutdown(Mode 5)

and Unit 2 operating at full power, the OC Component Cooling (CC) pump started at about the time that an electrician closed the bus 149 relay logic cabinet door. The licensee believes that either vibrations from the closing of the door caused a contact associated with the bus 149 blackout timer to momentarily close or that a contact of the blackout timer was inadvertently bumped during maintenance activities in the cabinet. Closing the right contact could cause the OC CC pump to start.

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All other equipment operated properly, and the DC CC pump was secured a short time later. Because of the automatic actuation of the OC CC pump (an ESF), the licensee reported the event pursuant to 10 CFR 50.7 The licensee will revise Procedure E023-1, to provide a list of "out of service" components to prevent inadvertent actuation of ESF components during this maintenance procedur This will be considered an Open Item pending NRC review of the licensee's completed investigation and corrective actions (295/86028-02; 304/86028-02).

No violations or deviations were identifie One Open Item was identifie . December 5, 1986, Automatic Start of the IB Service Water Pump OnDecember5,1986,withUnit1incoldshutdown(Mode 5),theUnit1 reactoroperator(NS0)movedtheIBServiceWater(SW)pumpcontrolswitch from the pull to lock" position to the "after trip" position and the 1B SW pump automatically starte The licensee determined that the start resulted from the bus 148 blackout timer, which is an Engineered Safety Feature (ESF) and the licensee reported the event pursuant to 10 CFR 50.7 An investigation by the licensee disclosed that the start occurred following a series of events which began when bus 148 was de-energized for maintenance 198 De-ener on December voltage circui 1,t (as designed)gizing which enabledbusthe 148 actuated bus the degraded 148 blackout circuitry grid by means of a latching relay (UVL8). With the UVL8 contacts closed, blackout load automatic starts are enabled and will occur if power is available. The UVL8 latching relay contacts normally remain closed (mechanically latched)

until a reset signal occurs, even if the degrade grid condition clears when bus 148 becomes re-energized. Since all blackout loads had been taken out of service prior to bus 148 being de-energized on December 1, 1986, no equipment starte On December 3, 1986, after the maintenance activity was completed, testing was conducted without the blackout loads being placed back on the bu After the tests, with bus 148 blackout loads still out of service, the 480 volt motor control center feeder b'reaker (1481) was closed. This energized the blackout sequence timer which completed the logic (in combination with UVL8) to energize blackout loads through relays SDX/18-1 and SDX/18- On December 4, 1986, the "out of service" on the IB SW pump was cleared and the control switch was placed in the "after trip" position which normally would not cause the pump to start. However, since the SDX relay associated with the IB SW pump was energized and the UVL8 relay had not been reset, the pump automatically started as would have occurred had any bus 148 blackout load been returned to service.

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This is considered an Open Item pending the completion of the licensee's investigation and subsequent review by the NRC resident inspectors (295/86028-03;304/86028-03).

No violations or deviations were identifie One Open Item was identifie . December 10, 1986, Loss of Containment Integrity Due to Manual Valves Left Open On November 30, 1986, with Unit 2 operating at 99.5%, the licensee discovered two series containment isolation valves (CIVs) to be open '

in the demineralized water (DW) system. The valves were immediately closed upon discover During an audit of chained, locked valves in response to IE Information Notice 86-55, two valves in the DW system, 2DW0030 and 2DW0038, were discovered to be open by the shift foreman and were closed immediately because they were known to be normally closed valves. Afterwards, the shift foreman discussed the matter with the shift engineer who understood the foreman to say only that the valves were not locke The DW system is a non safety-related, non-seismic system with the exception of the portion of piping from the containment penetration up to and includingthesubjectcontainmentisolationvalves. Although often used during outages for routine decontamination and maintenance activities, these valves Instruction were (501) notlineup valve at that ortime, in anyincluded General in any System Operating Operating (GOP),

Procedure thus sufficient Administrative Controls did not exist to ensure that 2DW0030 and 20W0038 vere closed prior to entering Mode 4. If a design basis earthquake had occurred while these valves were open, the non-seismic portion of the DW system could have failed, creating an open radioactive release path. Assuming total pipe shear at both ends of the penetrations, with the valves open, the containment leakage rate would have been approximately 20 weight percent per day at 47 psig. Technical Specification (TS) 3.10 specifies allowable containment leak rate as less than or equal to 0.10 percent weight of the containment air per day at 47 psi TS 3.9.5 recuires containment integrity to be met whenever a reactor core is installec, unless the reactor is in cold shutdown (Mode 5) with greater than 1% shutdown margin. If this cannot be met, the action requirements of TS 3.0.3 specify shutdown within five hours. The licensee believes that the DW containment isolation valves may have been open since the unit left cold shutdown on January 20, 198 This event was further complicated by the failure on the part of the licensee to recognize that these valves were containment isolation valves until nine days after they were found open. The licensee informed the Senior Resident Inspector of the containment integrity violation on December 9, 1986, and reported the event pursuant to 10 CFR 50.7 _ _ _ - _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ .

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Three concerns were identified during the subsequent inspection:

. Unit 2 operated at power for 314 days with two series CIVs open The violation of containment integrity was not recognized until nine days after discovery.

' The TS are deficient in that CIVs identified in the FSAR are not identified in the T !

The concerns identified above are being considered for escalated

. enforcement actions, the severity levels of which de)end on the results of analyses of the safety consequences of the event. T11s is considered an

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Unresolved Item pending determination of the severity levels of the above identified concerns by a Region III Enforcement Board (295/86028-04;304/86028-04)

One Unresolved Item was identifie . December 15, 1986, Notification that Safety Related Room Cooler Fans were not tnvironmentally Qualified

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On December 15 1986, the licensee informed the resident inspector that the1AResiduaiHeatRemoval(RHR)pumproomcoolerfanmotor(oneof

, three) was found to have s lices and power leads which were not environmentally qualified EQ). Thenon-EQspliceswere.foundinthemotor junctionbox,andinthefeldjunctionboxforthefancoolerpackag The non-EQ power leads were located between the two splices discussed above, and consisted of three 18" long PVC coated wires in flexible condui The RHR pump room harsh environment, as stated in the licensee's EQ program is high radiation only and is estimated to be 2x10E6 RAD. One of the three fan cooler motors may be inoperable without rendering the RHR aump

inoperable. With all three room cooler fans inoperable, the RiR pump would not be able to meet its design basi When licensees identify EQ deficiencies related to equipment or systems covered by the Technical Specifications (TS), they must either:

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o Repair the deficiency within the period stated in the TS,

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• Shut down the plant as required by the TS if repairs cannot be completed in the time permitted, or

• Provideajustificationforcontinuedoperation(JCO)which establishes either that the equipment will perform its intended

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safety function, or that equipment failure will not result in significant degradation of any safety function or provide misleading information to the operator.

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On December 9 and 15, 1986, the licensee provided the Station Nuclear Engineering De)artment (SNED) reports regarding the splices and power leads having t1e EQ deficiencies, including their JC0s and a request that SNED review their reports. In their JC0s, the licensee stated that the splices and wires were undocumented with respect to their environmental qualifications, but that fan cooler motor operability would not be affected and that the fan coolers were therefore operable. The re) ort also indicated that unqualified wires and splices similar to tiose found on the 1A RHR pump room cooler fans also exist on the centrifugal charging Jump, safety injection pump and containment spray pump room cooler fans. 3ecause the licensee has concluded that the EQ deficiencies do not affect room cooler operability, no additional action has been take This is considered an Unresolved Item pending review by NRC Region III s)ecialists of the licensee's JCOs, determination of the root cause of tie EQ deficienc enforcement of E , issues (295/86028-05; 304/86028-05).and finalization of the N One Unresolved Item was identifie . Operational Safety Verification and Engineered Safety Features System Walkdown During the period of November 18 through December 29, 1986, the inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators. During these discussions and observations, the inspectors ascertained that the caerators were alert, fully cognizant of plant conditions, attentive to c1anges in those conditions, and too( prompt action when appropriate. The inspectors verified the operability of selected emergpncy 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 to verify tlat maintenance requests had been initiated for equipment in need of maintenance. Findings that resulted from these tours were promptly resolved by the license 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 also observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls, which included a walk down of the accessible portions of the auxiliary feeJwater and auxiliary electrical distribution 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 No violations or deviations were identifie '

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10. Monthly Surveillance Observation The inspector observed Technical Specifications required surveillance testing on the safety injection and containment spray additive systems and verified that testing was performed in accordance with adequate procedures, that limiting conditions for operation were met, 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-2E, " Spurious Valve Actuation Group De-energization Check"

• PT-6A, "Na0H Spray Additive Tank Checks" In addition, the ins ContainmentSpray,"pectorreviewed50I-4,"SafetyInjectionand Section 4-10, in connection with PT-6 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 industry codes or standardswith and approved procedures,th in conformance wi Technicalregulatory guides Specification '

The following items were considered during this review: whether the limiting conditions for operation were met while components or systems were removed from service; whether approvals were obtained prior to initiating the work; whether activities were accomplished using approved procedures and were inspected as applicable; whether activities were accomplished by qualified personnel; whether parts and materials used were properly certified, and whether fire prevention controls were implemente The following maintenance activities were observed or reviewed:

• IB Diesel Generator Repair

• 011 Battery Replacement

Neither of these systems had been returned to service before the end of the inspection perio No violations or deviations were identifie *

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12. Training 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 or on-the-job training received before the event was classroom, sufficient to simulator,ther have ei prevented the occurrence or to have mitigated its effects by recognition and proper operator action. Personnel cualifications were also evaluated. In addition, the inspectors cetermined whether lessons learned from the events were incorporated into the training progra Events reviewed included the events discussed in this report. Review of the DW event disct.ssed in Paragraph 7 found that training deficiencies may have contributed to the event occurrence in that operations failed to recognize the DW valves as CIV's. Review of licensed operator trainin on CIV's is considered an Open Item (50-295/86028-06; 50-304/86028-06)g .

No violations or deviations were identifie One Open Item was identifie . TMI Action Plan Item Followup II.B.2 - " Design Review of Plant Shielding and Environmental Qualifications of Equipment for Spaces / Systems Which May Be Used in Postaccident Operations" This itemmonitors radiation encompassed plant shielding, and environmental control of qualifications room plantventilation,ipmen equ Inspection Reports 295/82-27; 304/82-24, 295/83-07; 304/83-06, and 295/84-08; 304/84-08, dealt with those issues associated with plant shielding, control room ventilation and radiation monitors. As stated in the referenced reports, the licensee's actions regarding these topics were satisfactory with the exception of those items identified in the referenced reports. These open items are being tracked under TMI Item III.D.3.4, " Control Room Habitability Requirements."

The adequacy of the licensee's Environmental Qualification (EQ) program was assessea in a Safety Evaluation Report (SER) dated December 14, 1982, by the Office of Nuclear Reactor Regulation (NRR). The SER also reviewed the licensee's program against the requirements of IE Bulletin (IEB) 70-01,

" Environmental Qualification of Class IE Equipment," IEB 79-01B, which included the NRR, Division of 03erating Reactors (DOR) guidelines, NUREG-0588, and the Commission iemorandum and Order CLI-80-2 As documented in Inspection Reports 304/85006 and 295/86016; 304/86015, inspectionswereconductedofthelicensee'simplementationoftheirEQ program per the requirements of 10 CFR 50.49 as well as their implementation of EQ corrective action commitments made as a result of deficiencies identified in the December 14, 1982 SER.

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Discussions with Mr. that Region III, revealed A. Gautam of the inspection Division efforts of Reactor indicate Safety that the (DRS),'s licensee EQ program is satisfactory, and that implementation of the EQ program for-Unit 2 was acceptable. Consequently, the only remaining inspection activities required to close this item consist of a field verification of equipment installation on Unit 1 per the EQ program requirements. A memorandum requesting assistance from DRS for field inspection was sent to the Regional Office on December 19, 1986. This item remains open pending completion of the inspection effort on Unit No violations or deviations were identifie . Allegation The licensee was requested in a letter dated October 1, 1986, to investigate an allegation regarding the amount of time contractor employees were required to remain in containment. The allegation stated that certain contractors required workers to remain in containment for periods up to four hours without a restroom break. The licensee was requested to com)lete their investigation and inform Region III of the results by Decem)er 31, 198 In response to the letter, the licensee reviewed radiolo work practices with appropriate contractor su)ervision.Based gicalon control this and review the licensee determined that none of t1e contractors required workers to remain in containment for periods of four hours. Additionally, the stated policy regarding restroom breaks was to provide permission upon request regardless of the amount of time spent in containment. This information was provided to Region III verbally on January 2, 1987 and documented in a letter to the Region dated January 5, 1987. During the telecon the licensee was requested to interview Commonwealth Edison and contractor employees at the craft level regarding the potential for or knowledge of misuse of restroom privileges. The results of these interviews were provided to Region III on January 12, 1986. Of the workers interviewed, not one could identify misuse of restroom breaks or had knowledge of contractors requiring extended work intervals in Containmen Based on the above interviews with contractor craft and review of contractor work practices, the allegation could not be substantiate . Open Items Open Items are matters which have been discussed with the licensee which will be reviewed further by the inspector and which im/olve some action on the part of the NRC or licensee or both. Three Open Items disclosed during this inspection are discussed in Paragraphs 5, 6, and 1 '

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1 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. Three Unresolved Items disclosed during this inspection are discussed in Paragraphs 4, 7, and . [xitInterview The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the inspection period and at the conclusion of the inspection on December 29, 1986 to summarize the scope and findings of the inslection activities. The licensee acknowledged the inspectors' comment T 1e 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