IR 05000295/1986031

Insp Repts 50-295/86-31 & 50-304/86-31 on 861230-870103. Violation Noted:Failure to Implement Procedures for Radiation Monitor Surveillances

ML20211Q762
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/18/1987
From:	Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211Q697	List: IR 05000295/1986031 ML20211Q693 ML20211Q743
References
TASK-A-26, TASK-OR 50-295-86-31, 50-304-86-31, NUDOCS 8703030178
Download: ML20211Q762 (13)

Text

{{#Wiki_filter:. U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-295/86031(DRP); 50-304/86031(DRP) Docket Nos. 50-295; 50-304 License Nos. 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: December 30, 1986 through February 2, 1987 Inspectors: M. M. Holzmer P. L. Eng Approved By: p.i&L LM% L. Forney, 8d/P[[7 Reactor Projects Section 1A Date Inspection Summary Inspection on December 30, 1986 through February 3, 1987 (Report Nos. 50-295/86031(DRP); 50-304/86031(DRP)) Areas Inspected: Routine, unannounced resident inspection of licensee action on previous inspection findings; summary of operations; pressurizer pressure below 2205 psig; environmental qualification deficiencies; February 3,1987, shutdown due to main steam isolation valve (MSIV) operator hydraulic leak; . cold weather preparations; missed radiation monitor surveillances; operational l safety verification and engineered safety feature (ESF) system walkdown; surveillance; maintenance; licensee event reports (LERs); training; Region III request followup; January 26, 1987, Management Meeting in Region III office Results: Of the 13 areas inspected, no violations or deviations were identified in 12 areas, and one violation was identified in the remaining area (failure to implement procedures for radiation monitor surveillances - paragraph 8).

The violation identified was of more than minor safety significance;however, there was no immediate threat to public health or safet I ,  : G703030178 B70221 PDR G ADOCK 05000295 pun

DETAILS Persons Contacted

*G. Pliml, Station Manager
*E. Fuerst, Superintendent, Production
*T. Rieck, Superintendent, Services
* 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
* Stone, Quality Assurance Supervisor
*J. Tiemann, Engineer, Primary Group
* Indicates persons present at exit intervie . Licensee Action on Previous Inspection Findings (92701) (0 pen) Unresolved Item (295/86013-06; 304/86012-07): Erratic Reed Switch Position Indication For Reactor Coolant System (RCS) Head Vents. The RCS head vents are manufactured by the Valcor corporation. The licensee had planned to have a representative of the Valcor Corporaticn visit the site during the current Unit 1 outage to improve the reliability of the valve position indication, and to replace internal springs which were subject to hydrogen embrittlement (see IE Information Notice 86-72). The spring replacement involved cutting open the valve's welded housing. It was estimated that such activity would require more time than the licensee had budgeted at this point in the current Unit 1 outage, and the licensee was going to delay the work until the next Unit 1 refueling outage. At the request of the resident inspector, a meeting was held, at which the licensee agreed to determine whether the position indication work might be performed during the current outage. Representatives of Valcor are expected to inspect the reactor head vent valves during the period February 6-8, 1987, at which time the plan of action regarding the remote position indication deficiencies will be define (Closed) Open Item (295/86028-06; 304/86028-06): Training review on containment isolation valves (CIVs). The inspector reviewed the licensee's training lesson plans for the training segments pertinent to CIVs and the containment isolation function for both licensed and nonlicensed operators. It was determined that sufficient training had been given to plant personnel to have prevented the December 10,

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1986, containment violation event; however, modifications to the

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training associated with this subject are planned. This matter is discussed further in paragraph 13 of this repor No violations or deviations were identifie . Summary of Operations Unit 1 The unit remained shutdown for the entire reporting period for a refueling and maintenance outage. The unit is scheduled to be on line on February 22, 198 Unit 2 The unit operated at full power until 5:45 a.m. on February 3,1987, when the unit was shut down to repair one of two solenoid trip valves for the D main steam isolation valve (see paragraph 6). The unit remained off line for the remainder of the reporting perio . December 30, 1986, Unit 2 Pressurizer Pressure Below 2205 Psig (93702) On December 30,1986, at 3:35 a.m. , with Unit 2 operating at full power, a Nuclear Station Operator (NS0) observed that pressurizer pressure was 2055 psig. It was subsequently determined that the pressurizer pressure master controller (2PHC-455K) was in the manual mode instead of automatic as is normally the case. Normal pressurizer pressure is 2235 psig, and Technical Specifications require corrective actions within six hours if pressurizer pressure is below 2205 psig. To correct the condition, the Unit NS0 fully closed the pressurizer spray valves and energized the pressurizer backup heaters. Pressurizer pressure returned to normal at 3:53 a.m., after which 2PHC-455K was returned to automatic. The process computer provided an alarm when pressure reached 2200 psig, but no control bor.rd annunciator was received for the low pressurizer pressur A review of the computer point history for unit 2 revealed that 2PHC-455K shifted from automatic to manual at about 12:28 a.m. No cause of the shifting was identified, and 2PHC-455K will be tested during the next Unit 2 refueling outage, which is expected to begin in early March,198 In response to this event, the license has:

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Issued a standing order to require NS0's to check the computer alarm trips on an hourly basi Assigned a contractor to review the alarm typer inputs to eliminate superfluous alarms and make the printout more meaningful to operator Provided additional training to the unit NSO involved in the even , _ . .- .

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Initiated a modification review to determine the feasibility of providing a low pressurizer pressure annunciator which would be

. independent of the mode of 2PHC-455 The inspectors expressed concern that the low pressure condition existed for over three hours as indicated by control room chart recorders, yet remained undetected by the unit ilS0 or his supervisors. The modification to add a low pressure annunciator will be considered an Open Item pending the results of the licensee's feasibility review (304/86031-01-(DRP)).

No violations were identified. One Open Item was identifie . January 15, 1987 Environmental Qualification Deficiencies (93702) On January 15, 1987, the licensee informed the resident inspector that two EQ deficiencies were identifie Raychem butt splices for the Unit 1 charging pump room cooler fan motors were found to be improperly installed. The licensee found that the body shim had been installed over the conductor breakout (instead of under, as required by Raychem instructions).

- Auxiliary feed water (AFW) flow transmitters (one for each Unit) were found to have terminal board connections where qualified EQ splices were to have been locate On January 6,1987, the licensee provided the Station Nuclear Engineering Department (SNED) reports regarding these EQ deficiencies, including their justifications for continued operations (JCOs) and a request that SNED review their report In their JC0 for the improperly made Raychem butt splices, the licensee stated that leakage currents may result in the .

event of a high energy line break (HELB), but the harsh environment was high radiation only, and that leakage currents to ground or phase to phase would not cause fan motor failure or breaker trip. Furthermore, the splices are in closed splice boxes and are thus protected from direct impingement during HEL In their JC0 for the AFW flow transmitters, the licensee noted that the harsh environment for the terminal boards was high radiation only, and that this would have no detrimental effect on the terminal board connection This is considered an Unresolved Item pending review of the licensee's JC0s and determination of the root cause of the EQ deficiencies (295/86031-01; 304/86031-02(DRS)). One Unresolved Item was identified.

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_ _ _ February 3, 1987, Unit 2 Shutdown Due To Main Steam Isolation Valve Solenoid Trip Valve Leakage (93702) At 1:15 a.m. on February 2, 1987, the licensee identified hydraulic oil leakage on one of the two trip solenoid valves for the 20 Main Steam IsolationValve(MSIV). MSIVs are held open by hydraulic fluid which is supplied to the underside of the operating MSIV piston from the hydraulic oil reservoir by means of a pump and accumulator system. Loss of hydraulic oil from the identified leak would have eventually emptied the hydraulic oil reservoir and caused the 2D MSIV to stroke close At 1:35 a.m. the licensee initiated a ramp down of Unit 2 because the MSIV hydraulic oil reservoir was nearly empty. At 1:54 a.m., the trip solenoid valve was isolated, stopping the hydraulic oil leak. Isolating the trip solenoid valve placed Unit 2 in a four hour action requirement to be in the Hot Shutdown Mode in accordance with Technical Specifications 3.4.4, Table 3.4-1, item I At 2:00 a.m., the licensee declared an Unusual Event (UE) in accordance with their Generating Stations Emergency Plan (GSEP). The shutdown was co,apleted at 5:45 No violations or deviations were identifie . Cold Weather Preparations (71714) The inspector reviewed the surveillance which was initiated in November 1986. TSGP-43 for winter 1986-87 was incomplete when it was reviewed by the inspectors because some areas of the plant had not been inspected by the licensee. An NRC inspection of the Unit 2 main steam isolation valve (MSIV) valve houses during recent sub-zero weather revealed that the B and D MSIV house was very cold in spite of the completion of the applicable portions of TSGP-43. This information was provided to the licensee for correctio No violations or deviations were identified.

' Missed Surveillances on Radiological Instrumentation (71702) On March 24, 1986, the Commission issued an amendment to the licensee's TS addressing Radiological Effluent Technical Specifications (RETS) to be implemented on September 24, 1986. The RETS defined limiting conditions for operation (LCOs), surveillance requirements and required actions associated with both effluent and area monitors. In early October, the licensee issued two LERs addressing missed RETS required surveillance These LERs are: 295/86038-00 Missed Surveillances on Technical Support Center Area Radiation Monitor 304/86022-00 U2 Containment Vents without Shiftly Containment Atmosphere lodine Samples

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. In both cases, surveillances were missed because neither the portable area monitor in the Technical Support Center (TSC) nor the iodine monitoring channel (Channel 3 on 2RIA-PR-40) on the U2 contair. ment vent line had previously been included in the TS surveillance requirements, and because the licensee failed to add these instruments to their surveillance program prior to the implementation date of the RET Discussions with members of the Health Physics (HP) group revealed that the portable monitor in the TSC was used for information only and that the licensee had not expected the TSC portable area monitor to be included in the RETS. In addition, monitoring of the iodine of the containment vent line had previously been performed only by grab sampl A modification was performec in 1982 to replace the formerly installed monitor with a SPING, which has the capability to continuously monitor iodine. Surveillance requirements for the iodine channel were included in the RETS; however, manual grab samples are routinely taken prior to each vent and redundant monitors IPR 09B and 2PR09B were operabl Consequently, failure to perform these surveillances had no safety significanc Section 6.2.1 of the TS requires that surveillance and testing requirements be incorporated into written procedures. Investigation revealed that although the RETS had been reviewed during the six month period between receipt of the TS change and the date of its implementation, procedures to delineate, track and ensure surveillance testing per the RETS requirements, and the calibration procedures for the TSC area monitor and the Unit 2 SPING channel 3 were not in plac Failure to prepare, implement and maintain procedures for surveillances delineated in the TS is considered to be a violation (295/86031-02; 304/86031-03(DRP)). The licensee has taken the following corrective actions:

- Procedures addressing the daily channel checks and monthly source checks for the portable TSC area monitor are being reviewe Daily channel checks are being tracked by operations and rad / chem until procedures are in place for the TSC area monito Iodine sampling was conducted on a shiftly basis until the Units 1 and 2 SPINGs were calibrate Both Units 1 and 2 SPING iodine channels were calibrated and returned to servic A post implementation review of the RETS is being conducted to identify any additional surveillance requirements required by RETS, and to verify that such surveillances are addressed by appropriate procedure One violation and no deviations were identifie .

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. Operational Safety Verification and Engineered Safety Features System Walkdown (71707, 71710)

The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators from December 30, 1986 through February 2, 1987. During these discussions and observations, the inspectors ascertained that the operators were generally alert, fully cognizant of plant conditions, attentive to changes in those conditions, and took prompt action when appropriat The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the auxiliary and 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 selected physical security activities were being implemented in accordance with the station security plan.

' The inspectors observed plant housekeeping /claanliness conditions and implementation of radiation protection controls. From December 30, 1986 through February 2, 1987, the inspectors walked down the accessible portions of the Chemical and Volume Control System on Unit 1 and portions of the Main Steam System for both Units 1 and 2 to verify operability.

' The valve houses for the Unit 2 main steam isolation valves (MSIV) were found to have excessive hydraulic oil leaks from the MSIV operator 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 inspectors observed the Unit 2 shutdown on February 3, 1987. The inspectors observed that the operators referred to and followed the correct operating procedures, that the shutdown was performed in accordance with Technical Specifications requirements, and that at least one senior reactor operator (SR0) was at the Unit 2 controls to direct the shutdow Communications and supervisory controls were adequat No violations or deviations were identifie . Monthly Surveillance Observation (61726) < The inspector observed Technical Specifications required surveillance testing on the Residual Heat Removal, Chemical and Volume Control, and Safety Injection Systems to determine whether testing was performed in accordance with adequate procedures, test instrumentation was calibrated, limiting conditions for operation were met, removal and restoration of the affected components were accomplished, test results conformed with , technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and whether any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne . . . .. . . - _ _ _ - _ _ _ _ . -- _ . _ _ . .- ._ _. . - -

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The inspectors observed selected Technical Staff Surveillance tests associated with the full flow test effort on Unit 1. Tests witnessed were: TSSP-59-86, Maximum Delta P (pressure) Stroke Tests for M0V-VC8110, 8111, 8105 and 8106 TSSP-80-86, Charging and SI Check Valve Verification Test /MOV Delta P Test TSS 15.6.85, RHR Check Valve Verification The inspectors made several observations which were discussed with members of the plant staf Since the initial plant conditions assumed for the test did not match actual plant conditions, a special appendix had to be added to the test to determine boron injection tank (BIT) boric acid concentration and to verify that the BIT was solid. Under normal circumstances, this data is easily obtained by observing recirculation flow between the BIT and the 0A boric acid tank (0A BAT) and tapping into the recirculation flow sample line; however, both recirculation flow and the 0A BAT had been out of service for outage related maintenance activities for several weeks. The test group was unaware of the condition of the 0A BAT and that verification that the BIT was solid and determination of the boron concentration in the BIT could not be performed as specified in the procedur Procedure review of the BIT cold leg injection portion of TSSP-80-86, revealed that the precautions required prior to starting the 1A charging pump to ensure that the pump would not start under runout or dead head conditions were not imposed on the IB charging pump prior to IB pump start. Members of the test group stated that these differences would neither affect test results nor damage the IB pump.

' Step 8.1.0 of TSSP-80-86 requires the isolation of the BIT cold leg injection loop with the highest flow in order to verify that the total flow through 3 loops exceeds 275 gallons per minute as required by TS 4.8.4.B. After obtaining the flow rate for 3 loop flow, a temporary procedure change was required to restore 4 loop flow conditions for testing of the IB charging pum Procedure changes to TSSP-80-86 were required at test completion to allow system restoration of the affected systems at the l discretion of operations personnel to support the plant ! configuratio While none of the observations noted above affected the test results, it was noted that a significant amount of time was spent discussing procedural deficiencies and writing temporary procedure changes. This l 8  ;

. resulted in members of the test group and necessary support staff spending a significant amount of time waiting for issuance of procedure changes. The inspectors noted that the test procedures delineated above had been reviewed and approved; however, validation efforts had been ineffective as evidenced by the number and type of temporary procedure changes required during the conduct of the tests. The inspectors noted that had an effective test validation been performed prior to test performance and had the test group been aware of the status of the BIT recirculation flow path, a significant amount of time could have been save The inspectors noted that despite the length of time spent performing the test, test group personnel were conscientious in that deviations from the test procedure were documented appropriately through station procedure change requests. Members of the test group responded appropriately to concerns raised by members of operations and interfaced well with shift personne No violations or deviations were identifie . Monthly Maintenance Observation (62703) 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; 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:

- 1A Diesel Generator Overhaul and Refueling Surveillance
- 18 Diesel Generator Repair These systems had not been returned to service by the close of the inspectio No violations or deviations were identifie l

. 12. Licensee Event Reports (LER) Followup (92700) Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specifications. The LERs listed below are considered closed: UNIT 1 LER N DESCRIPTION 86038-00 Missed Surveillances on TSC Portable Area Monitor 86041-00 Turbine Building Air Sampler Found Inoperable UNIT 2 LER N DESCRIPTION 86022-00 U2 Containment Vents without Shiftly Containment Atmosphere Iodine Samples 86024-00 Pressurizer Low Pressure Transient Due to Pressure Controller Shifting to Manual Regarding LERs 295/86038 and 304/86022, a violation will be issued for failure to implement surveillance procedures. These two events are discussed in detail in paragraph 8 of this repor Regarding LER 304/86024, this event is discussed in detail in paragraph 4 of this repor No other violations or deviations were identifie . Training (41701) 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 classroom, simulator, or on-the-job training received before the event i 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 The training received by members of the plant staff involved with the containment violation item discussed in inspection report 295/86028; 304/86028 contained sufficient content to have prevented the occurrenc Discussions with the licensee's training department staff revealed that

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although the different aspects of containment and the isolation function are adequately addressed in various portions of the licensed operator training, a new summary discussion of all the different aspects of containment integrity will be added to the training program for both licensed and non licensed operator Events reviewed included the events discussed in this report. In addition, LERs were routinely evaluated for training impact. The inspectors noted that copies of the LER associated with the containment integrity event described in inspection report 295/86028; 304/86028 had been incorporated into the latest edition of required reading. No other events reviewed this period were found to have significant training deficiencies as contributor Two training sessions were attended by the resident inspectors as follows:

 " Respiratory Training" - Training content and supporting teaching aids were pertinent and succinct. The instructor was well versed in the subject matter and was able to answer all questions raised by the class. The exam given at the conclusion of the class was of sufficient difficulty to ensure that a passing grade was indicative of subject matter comprehensio ' Control Room Professionalism" - This pilot class was developed by Westinghouse at the request of Zion plant management in an effort to improve control room conduct. Class content addresses the attributes of a professional and those benefits which can be derived from professional performance. Discussion of recent events involving operator errors in industries other than nuclear power were included. The training session presentation included various audio visual training aids, including video tape excerpts from the series, "In Pursuit of Excellence." At the conclusion of the pilot i

class, comments were solicited from those in attendanc . Followup On Region III Requests (92701) Actions In Response To Unresolved Safety Issue (USI) A-26, " Reactor Vessel Pressure Transient Protection For Pressurized Water Reactors" In a memorandum from C. E. Norelius dated January 16, 1987, resident inspectors were directed to perform Temporary Instruction 2500/19 regarding licensees' responses to USI A-26. TI 2500/19 was developed by IE Headquarters, and was validated by inspections performed at the Zion and D. C. Cook plants. Results of the inspection at Zion are documented in Inspection Report 295/86024 and 304/86023. This item is considered close , No violations or deviations were identified.

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. 15. January 26, 1987 Management Meeting Regarding Evaluation of Zion Station Performance (30702) On January 26, 1987, a management meeting was held between members of tre licensee's site and corporate staffs and the NRC Region III staff in the Region III offices in Glen Ellyn, Illinoi The meeting was held to discuss the licensee's evaluation of Zion Station's performance and identified trends noted during 198 The licensee stated that as a result of several events which occurred at Zion Station during the last six months, they were concerned that performance at the station may be declining. The licensee described the reviews performed at the end of 1986 to determine any adverse trends and summarized the results of their review. The licensee stated that although the number of personnel errors did not appe r to be increasing, the significance of the errors was increasing. The licensee also noted that too many procedural deficiencies were identified, involving human factors considerations, level of detail, and activities for which no procedures existed, and that operator awareness of plant status needed improvement. Their action plan to address these findings was then describe Mr. Keppler stated that the NRC was pleased that the licensee took the initiative to request the meeting and candidly discuss their program for identification and correction of weaknesses. He further stated that the NRC would closely follow their actions, and that we would focus on results in terms of plant performanc 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 this inspection is discussed in paragraph . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. One Unresolved Item disclosed during this inspection is discussed in paragraph . Exit Interview (71714) The inspectors met with licensee representatives (denoted in Paragraph 1) throughout the inspection period and at the conclusion of the inspection on February 3, 1987 to summarize the scope and findings of the inspection activities. The licensee acknowledged the inspectors' comments. 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 '0'

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ATTACHMENT 1 LIST OF ATTENDEES JANUARY 26, 1987 MANAGEMENT MEETING Commonwealth Edison Company C. Reed, Vice President, Nuclear Operations D. Galle, Assistant Vice President and General Manager, Nuclear Stations Division L. O. DelGeorge, Assistant Vice-President, Engineering and Licensing N. Kalivianakis, Division Vice-President, Nuclear Stations L. F. Gerner, Regulatory Assurance Superintendent M. S. Turbak, Operating Plant Licensing Director S. L. Trubatch, Staff Attorney P. C. LeBlond, Licensing Administrator, Zion Station F. G. Lentine, Zion Project Engineer, Station Nuclear Engineering Department E. J. Fuerst, Superintendent of Production, Zion Station G. Plim1, Plant Manager, Zion Station NRC Region III J. G. Keppler, Regional Administrator A. B. Davis, Deputy Regional Administrator C. E. Norelius, Director, Division of Reactor Projects R. F. Warnick, Chief, Reactor Projects Branch 1 W. L. Forney, Chief, Section 1A, DRP B. L. Burgess, Chief, Section 2A, DRP R. M. Lerch, Project Inspector, Section 1A M. M. Holzmer, Senior Resident Inspector, Zion Station P. L. Eng, Resident Inspector, Zion Station l l l l l l

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