IR 05000295/1989036
| ML19325F250 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 11/09/1989 |
| From: | Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19325F249 | List: |
| References | |
| 50-295-89-36, 50-304-89-32, NUDOCS 8911170219 | |
| Download: ML19325F250 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
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Report Nos. 50-295/89036;50-304/89032(DRP))
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Docket Nos. 50-295; 50-304 License Nos. DPR-39; DRP-48 i
' Licensee: Commonwealth Edison Company.
P. O. Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Unit 1 Inspection At: Zion, II.
, Inspection Conducted: October 18 through November 6,1989 Inspectors:
R. J. Leemon W. J. Kropp Approved By:
J. M. Hinds, Chief NOV 91999 Re;actgr /Jro cte Section IA Date y
(H.D MtA '%
Inspection Summary Inspection from October 18 - November 6,1989 (Report Nos. 50-295/89036; 50-304/87032(DRP))
Xreas Inspected: Special, unanc.ounced resident inspection of the failure to declare the diesel generators inoperable when the diesel generator room ventilation systems were out of service.
Results:
In the area inspected, one violation was identified (Technical Specification violation - operation with diesel generators inoperable for
a period in excess of the action requirements). The licensee failed to initiate a Technical Specification time clock when the diesel generator room ventilation systems were inoperable. The ventilation systems perform a safety function as described in the Updated Final Safety Analysis Report; however, this function is not s aecified in the Technical Specification.
The licensee did not consider t1at a necessary safety supporc system was lost when the diesel generator room ventilation systems were taken out of service and that the diesel generators were therefore inoperable,
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8911170219 891109
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PDR ADOCK 05000295
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DETAILS
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1.
Persons Contacted T. Joyce, Station Manager
W. Kurth, Superintendent, Production P. Le31ond, Assistant Station Superintendent, Operations
W. Stone, Regulatory Assurance Supervisor
T. Saksefski, Regulatc,ry Assurance Engineer
T. Rieck, Technical Superintendtnt
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W. T'Niemi, Technical Staff Supervisor
E. Fuer;t, Zion Project Manager, Nuclear Operations.PWR Projects
Department J. Smith, Senior Resident Inspector
R. Leemon, Resident Inspector
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A. Bongiovanni, Resident inspector
- Indicates persons present at the exit interview on November 6, 1989.
Discussions were also held with members of the Technical Staff.
2.
Operation of Unit I and Unit 2 with the Diesel Generators' (DG)
Ventilation Systems (71707)
a.
Background Each DG room has a ventilation system that is described in the U) dated Final Safety Analysis Report (UFSAR), Section 9.10.6.
The U SAR states that each DG room ventilation system is designed to limit the maximum room ambient temperature to 115 degrees F.
Alto, the system is identified as part of engineered safeguards and is required to operate for all loss o' off-site power conditions.
Each DG room ventilation system consist of a ventilation fan, inlet damper, ductwork, instrumentation and associated contrni circuits.
l The inlet dampers also perform a function as aircraft crash dampers I
as described in UFSAR, Sections 9.10.6, and 9.10.9, and USFAR question 2.28.
The DG room ventilation systems are not specifically identified in the Technical Specification (TS); but, based on the description in the UFSAR are considered a necessary support system
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l for DG operability. The inlet dampers' function as a aircraft crash damper is addressed in TS surveillance requirement, 4.17.2.1.b.
Thic i
surveillance required verification every six months that the dampers
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would close in two seconds.
If the damper failed to close in two l
seconds the TS required the damper to be placed in the closed
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position.
The closure of the damper to comply with this TS requirement also resulted in the DG room ventilation system's inability te meet the engineered safeguard function described in the UFSAR.
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Due to hardware problems with the inlet dampers, the TS surveillance requirement for the aircraft crash damper was not consistently met.
The licensee initiated a modificction to the inlet damper controls to increase the reliability. The modification included a change to the failure mode of the all DG room ventilation inlet dampers from fail
"open" to fail "close".
b.
Event. Chronology 5/27/80 - Special test on 2B DG performed for Sargent & Lundy to determine rocm temperature rise.
(To date, licensee has not been ab'e to farnish test procedure or results)
3/15/89 1A and IB 00 vent dampers taken out-of-service (005) for modification No. 1-86-5 to replace 3-wd.v solenoid and i
fliller valves with a 4-way solenoid.
3/20/89 2A and 2B DG vent fan dampers taken 00S for modification No. 2-86-5 to repla:e 3-way solenoid c.1d Miller valves with a 4-way solenoid.
5/24/89 TS change 89-10 to remove aircraft crash requirements mailed for Off-Site review. This change was initiated due to a TMI DCRDR concern.
6/16/89 2A and 28 DG vent fan dampers fail stroke time wnile being tested in conjunction.with modification 2-86-5.
6/19/89 TS change 89-10 off-site review compieted.
7/18/89 TS chance 89-10 submitted to NRR.
8/10/89 1A and 18 DG vent fan dampers returned to service after completion of modification 1-86-5.
9/08/89 Telephone conference call between licensee and NRR to discuss TS change 89-10.
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10/19/89 Resident staff discussed with licensee the out of service of the 2A and 28 DG room ventilation systems.
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I After discussions with the resident staff the licensee concidered another test similar to the 1980 DG room l
temperature test.
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l 10/20/89 Resident inspectors witnessed monthly TS surveillance on j
28 DG. DG room temperature exceeded the UFSAR temperature r
of 115*F.
Room temperature approached 120*F with room
doors open at the time of the surveillance. ihe 2B DG room I
temperature alarm function was inoperable and no compensatory action to monitor room temperature was initiated by the licensee.
Room temperature was lost due to isolation of air to the inlet damper as part of the 00S.
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I-10/25/89
"0" DG aircraft crash d:mper failed TS closure time at 12:30 p.m.
Damper was placed 00S and ventilation fan was pull-to-lock (PTL).
10/25/89 Temporary Lif t of 00S for 2A, 28, and "0" DG aircraf t crash dampers.
Licensee' requested Waiver of Compliante for closure time of dampers. The dampers were opened and the systems were returned to service, c.
Safety Significance The design basis (UFSAR) states th'at the DG room ventilation systems were designed to limit the maximum ambient in the DG rooms to 115 degrecs F.
The resioent staff observed, on October 20, 1989, j'
during the monthly TS surveillance en.28 DG, that the temperature in
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the' room was 118 degrees and the d.scharge of the air cooler for the 28 diesel generator was 148 degrees F.
The diesel generater had been running for about I hour with the DG room doors opened to t'ie turbine
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building. The room temperature was measured just inside the DG door and may not have been a true indication of the overall room temper 6ture.
Elevated DG room temperatures could affect DG reliability to provide e!ectrical power to the safeguard busses during a loss of off-site power.
d Concerns The licensee cppears to have a restrictive application of Technical Specifications requirements to support systems. When a safety function of a component's support system described in the UFSAR was lost and the support system was not describea in the TS, the affected component was not declared inoperable. A similar concern was identified in inspection report 50-295/89017 and was discussed during an enforcement conference on May 31, 1989. Also, a 50.59 review for a modification to change the failure mode of the DG room ventilation inlet darnpers from fail "open" to fail "close" only discussed the function of the inlet dampers as aircraft crash dampers and did not address the damper's engineered safeguard function as a supply to DG room cooling during loss off-site power.
e.
Enforcement TechnicalSf2)"A",1(2)"B"and"0"(common)dieselgenerators(DG)ecification
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that the I L
L shall be operable.
From and after the date that one of the DGs for a unit is made or found inoperable, reactor operation on that unit is
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permissible only during the succeeding / days provided that the other
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i two DGs are available. Technical Specification 3.0.3 requires that if a LCO and/or ACTION requiiements cannot be satisfied, action shall be initiated within one hour to place the unit in at least HOT SHUTDOWN within the following 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and in at least COLD SHUTDOWN within the following 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Technical Specification 1.27 (definitions) states that a system, subsystem, train, r.nponent or u
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device shall be operable or have operability when it is capable of l
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performing its specified sunction(s) and when all necessary attendant instrumentation, controls, electric power, cooling or seal water, lubrication or other auxiliary equipment that are required for the function (s) ystem, train, component, or device to perform its system, subs are also capable of performing their related. support function (s). Also, the Updated Final Safety Analysis Report (UFSAR),
Section 9.10.6.2.?, states that each DG room ventilation system is designed to limit the maximurn room ambient to 115 degrees F.
It further states that this system is part of the engineered safeguards Tne licensee had the IA, 18, 2A, 28 and "0" (common) power conditions.
and is required to operate for all loss of off-site DG rooms ventilation systems out of service during the following periods:
UNIT 1 1"A"----March 15 to August 10, 1989 1"B"----March 15 to August 10, 1989 UNIT 2 2"A"----June 7 to October 25, 1989 l
2"B"----June 7 to October 25, 1989 UNIT 0(0071 MON)
"0"-----June 6 to July 7,1989 October 25, 1989 from 12:30 p.m. to 5:30 p.m.
For the time frames identified above, the licensee did not declare the
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Therefore, the licensee failed to enter TS 3.0.3 from March 15 to August 10, 1989, for Unit 1 and June 7 to October 25, 1989, for Unit 2 when more than one DG were inoperable at the same time. Also, on Oc.tober 20, 1989, during the ?B DG TS monthly v veillance test the tenperature as measured inside the DG room reachec 118 degrees F as i
observed by the NRC residents. This is considered an apparent violation (295/89036-01; 304/89032-01).
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Corrective Actions The immediate corrective action consisted of the licensee's request for a weiver of compliance to the TS requirement that pertaincd to the aircraft crash damper closure time. 1he waiver was granted by NRR on October 25, 1989. The darrpers for the 2A and 28 DG that had been failed closed oue to not meeting the TS requirement clo::bre time were opened and the DG room ventilation systems were.eturned to service on October 25, 1989 at 5:40 p.m.
The long term corrective action was discussed in the waiver of coropliance document dated October 27, 1989 that required the licenses to install a modification to impt]ve namper closure tiaes. Also, further information concerning toe TS change was requested.
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One apparent' violation and no deviations were identified.
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3.
ExitInterview(30703)
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-The inspectors met w'ith licensce representatives (denoted in Paragraph 1)
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throughout the inspection period and at the conclusion of the inspJction on November 6.-1989, to summarize the scope and findings of the inspection
activities.
The licensee acknowledged the inspectors' comments. -The
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inspectors also discussed the likely informational content of the
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intpection report with regard to documents or' processes reviewed by the
. inspectors during the inspection. The licensee did not identify.any such documents or processes as proprietary.
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