IR 05000295/1989019
| ML20245F062 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 06/16/1989 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20245F026 | List: |
| References | |
| 50-295-89-19-EC, NUDOCS 8906280028 | |
| Download: ML20245F062 (4) | |
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U.S. NUCLEAR REbdLATORY COMMISSION p
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REGION III
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a-Report No. 50-295/89019(DRP)-
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Docket No. 50-295-License No. DPR-39
- Licensee: Coninonwealth Edison Company
. Post Office Box ~767 Chicago, IL-60690 Facility Name: Zion Nuclear Power Station, Unit 1 Meeting Location:
NRC Region III Office, Glen Ellyn, Illinois
- Meeting Conducted: May 31, 1989 Type of Meeting: Enforcement Conference Approved By:
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d-/[rN 4. D. Shafer, Thief-Date Reactor Projects Branch 1
- Meeting Summary Enforcement Conference on May 31, 1989 (Report No. 50-295/89019(DRP))-
Subjects Discussed: A review and discussion relating to containment spray
. valve 1 MOV CS-0049 being inoperable and rendering'one train of the containment spray system unable to function in the recirculation mode and the application of' Technical Specification action statements to this condition.
Results: One violation of Technical Specifications was identified for operating with one train of containment spray. inoperable.
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DETAILS 1.
Enforcement Conference Participants Commonwealth Edison Company (CECO)
T. Maiman, Vice President PWR Operations L. O. DelGeorge, Assistant Vice President, Quality Programs and Assessment K. L. Graesser, General Manager, PWRs T. Joyce, Station Manager, Zion W. R. Kurth, Production Superintendent, Zion T. J. Saksefski, Regulatory Assurance P. LeBlond, Assistant Superintendent, Operations, Zion J. A. Tiemann, Zion Technical Staff Primary Group Leader R. Squires, Nuclear Safety D. Elias, PWR Projects Man o r P. L. Barnes, PWR Regulatory Assurance Engineer R. A. Flessner, Administrative Engineer, PWR Operations S. Trubatch, Consultant, Tenera T. J. Kovach, Nuclear Licensing Manager M. S. Turbak, Performance Improvement Manager K. B. Ramsden, Reactor System Engineer - NFS G. Trzyna, Nuclear Licensing Administrator Nuclear Regulatory Commission - Region III C. J. Paperiello, Deputy Regional Administrator W. L. Forney, Deputy Director, Division of Reactor Projects D. R. Muller, Project Director W. D. Shafer, Chief, Reactor Projects Branch 1 R. W. Cooper, Chief, Engineering Branch, Division of Reactor Safety J. M. Hinds, Jr., Chief, Reactor Projects Section 1A M. M. Holzmer, Senior Resident Inspector, Zion B. A. Berson, Regional Counsel R. M. Lerch, Reactor Engineer, DRP, Branch 1 0. R. Calhoun, Project Inspector 2.
Enforcement Conference On May 31, 1989, an enforcement conference was held at the NRC Region III office in Glen Ellyn, Illinois, with the individuals listed above particir,ating. The enforcement conference was a result of an NRC inspcetion conducted from March 17 through May 10, 1989 (Inspection keport No. 50-295/89017). The enforcement conference was announced in a letter and meeting notice to the licensee dated May 22, 1989.
Mr. Paperiello began the meeting by stating that the purpose of the enforcement conference was to discuss an apparent violation found by the resident inspector, to provide the licensee the opportunity to offer addi-tinnal facts concerning the apparent violation, and to discuss NRC concerns.
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Mr. Holzmer presented the chronology of events and expressed the NRC concerns which were that'the licensee takes an excess,1vely restrictive interpretation of the Technical Specification and that design basis-information available to operating decision makers is incomplete and difficult to access.
Mr. Maiman commented that CECO was aware of the Generic Letter-(GL)
about to be issued which will provide guidance foi actions to be taken-in addressing operability questions.
He also noted CECO's commitment to respond appropriately to the GL and discussed what CECO would do on a corporate basis in dealing with the issue.
Mr. Kurth briefly discussed the Emergency Core Coolant Systems (ECCS)
and a chronology of events, giving a detailed explanation of the decision making process regarding the Technical Specification operability of 1 MOV CS-0049 (CS-0049) from March 11 to March 18, 1989. He discussed how CS-0049 became inoperable due to its failure to stroke fully open and the valve's interface function with the residual heat removal (RHR)
system. The licensee's reiew of the Technical Specifications concluded that because CS-0049 is not specifically identified, no time clock was required on CS train A.
In response to the valve being inoperable, the licensee initiated the required paper work to investigate the cause of l
the failure, document the event, and deternine other applicable operabili+y requirements.
In addition to CS-0049 being inoperable, the licensee reported that valve SI-8811B was declared inoperable on March 14, 1989, when it failed to' stroke open. With SI-8811B inoperable the "B" RHR pump is isolated from its suction source during the recirculation mode,
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thereby rendering train "B" of the RHR system inoperable including
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recirculation containment spray (CS). Unit I was then placed in a 7-day Limiting Condition for Operatian (LCO) required-for the RHR system.
Both trains of recirculation containment spray were thus inoperable for approximately 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />.
Injection phase CS was operable during this time.
Mr. Ramsden presented the safety significance of the event, an engineering analysis showing that without any recirculation function of containment spray, the injection phase of containment spray and three containment fan coolers would maintain containment temperature and pressure below the design limits.
Mr. Kurth presented the following corrective actions.
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Immediately implement an administrative 7-day LC0 to address recirculation containment spray to maintain consistency with
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Standardized Technical Specifications.
Review recirculation phase functions for possible inclusion in technical specifications using Standard Technical Specifications as guidance by October 1, 1989.
Upgrade the Inoperable Equipment Procedure (PT-14).
Zion will participate in a Corporate Task Force to review and implement the recommendation contained in the forthcoming Generic Letter regarding equipment operability.
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l Mr. Paperiello thanked thalicensee fo-their presentation.
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The conference' was then adjourned.
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Conclusion NRC review of. the information presented in the enforcement conference l
concluded that.the containment spray system LC0 of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> applies when
CS-0049 is inoperable based on the T.S. as written and the_ accident
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H mitigation-function of the valve / system in the FSAR. Because the TS l
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. bases fnr CS differs from the bases for RHR, the LC0 for RHR is not
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appropriate for a containment spray function. However, it is logical
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that since the RHR pump provides the motive force in the recirculation mode of containment spray, the LCOs for the two systems should. be consistent. Operation with one train of containment spray inoperable-where the LC0 was not satisfied is a violation as described in Inspection Report 295/89017(DRP). This had no immediate safety significance based on the redundant containment cooling capability available with contain-ment fan coolers. The failure to initiate an LCO clock and the failure of station technical staff to challenge the LC0 determination was a significant safety concern. Therefore, this matter was concluded to. be a violation as contained in the enclosed Notice (295/89017-01(DRP)).
Review of~the administrative LC0 7-day clock, implemented as immediate corrective action, concluded that this is an acceptable short term corrective action. The 7-day clock is consistent with Byron and Braidwood TS, however, review of Westinghouse Standardized TS.
NUREG-0452, Revision 4 dated Fall 1981, and the Westinghouse Owners Group-MERITS T.S. dated March 1989, identified restoration times for one train of containment spray or ECCS (including RHR) of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The bases states that the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LC0 is based on engineering judgement for reasonable repair times and also does not address loss of only recirculation function. The licensee committed to evaluate the merit of a change'to TS by October 1, 1989. This evaluation should justify the application of the Byron /Braidwood TS to Zion and consider.the desirability of consistency with the Westinghouse Owners Group Standardized Technical Specifications. Resolution of this TS discrepancy is an Open Item (295/89019-01(DRP)).
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Open Items Open Items are matters which have been discussed with the licensee which will be reviewed further by the inspector and which involve some action on the part of the NRC or licensee or both. Three Open Items disclosed during this inspection are discussed in paragraphs 2, 9 and 10,
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