IR 05000295/1989038
| ML19332F035 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/07/1989 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19332F033 | List: |
| References | |
| 50-295-89-38-EC, 50-304-89-34, NUDOCS 8912130303 | |
| Download: ML19332F035 (4) | |
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g U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
l Reports No. 50-295/89038(DRP);50-304/89034(DRP)
Docket Nos. 50-295; 50-304 Licenses No. DRP-39; DPR-48 Licensee: Commonwealth Edison Company-P. O. Box 767 Chicago, IL 60690 i
Facility Name:
Zion Nuclear Power Station, Units 1 and 2 Meeting Location: NRC Region III Office, Glen Ellyn, Illinois
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Meeting Conducted: November 17, 1989 Type of Meeting: ' Enforcement Conference Approved By:
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Reactor Pro ects Branch 1 Date
Heeting Summary j
Meeting on November 27, 1989 (Reports No. 50-295/89038(DRP);
I No. 50-304/89034(DRP)J
'j Subjects Discussed: A discussion relating to the inoperability of the
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emergency diesel generators (D/Gs) ventilation system, the apparent violation,
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and the' licensee's perspective and corrective actions.
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Results: The disposition of the apparent violation associated with D/G
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inoperability will be presented in subsequent communications.
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Enforcement Conference Participates Commonwealth Edison Company (CECO)
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C. Reed Senior Vice President K. L. Graesser General Manager PWR Operations L. D. De1 George Assistant Vice President, Quality Program and Assessment T. P. Joyce Zion Station Manager G. E. Trzyna Nuclear Licensing Administrator T. A. Rieck Technical Superintendent, Zion T. J. Kovach Nuclear Licensing Manager T. J. Saksefski Zion Regulatory Assurance R. J. Squires Nuclear Safety G.O. Zion A. J. Ockert Training Supervisor
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D. J. Miller-Regulatory Assurance Supervisor K. K. Morer Regulatory Assurance P. L. Barnes Performance Improvement K. A. Ainger Zion Project Engineer A. J. Amoroso Nuclear Engineering P. LeBlond Assistant Superintendent Operations, Zion
'J. Madden Technical Staff, Zion A. M. Polek Attorney Nuclear Regulatory Commission C. J. Paperiello Deputy Regional Administrator E. G. Greenman Director, Division of Reactor Projects J. A. Grobe Director of Enforcement W. D. Shafer Chief, Branch 1, DRP
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J. M. Hinds Chief, Projects Section lA B. A. Berson Regional Ccunsel J. D. Smith SRI Zion R. J. Leeman Resident Inspector-Zion A. M. Bongiovanni Resident Inspector-Zion C. Patel Project Manager M. P. Phillips Chief, Operational Programs Section C. H. Weil Enforcement Specialist D. R. Calhoun Reactor Engineer J. A. Holmes Reactor Engineer 2.
Enforcement Conference Details On November 17, 1989, an enforcement conference was held at the NRC Region III office in Glen Ellyn, Illinois, with the individuals listed above participating. The enforcement conference was a result of an NRC inspection conducted from October 18 through November 6, 1989 (Inspection Reports No. 295/89036(DRP);304/89032(DRP)).
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,7 Discussions ~at the enforcement conference included: inoperability of the D/Gs as a result of the D/G room ventilation system fans being in pull-to-lock, the apparent violation, and the licensee's corrective i
actions.
The'NRC Region III staff summarized the inspection, apparent violation of regulatory requirements, and other regulatory concerns. The concerns discussed by the Region III staff. included an inadequately performed 10 CFR 50.59 review that did not include the Engineered Safety Feature
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(ESF) functions of providing cooling to the D/G during a Loss-Of-Coolant l
Accident (LOCA) or loss of off-site power; an incomplete and insufficient l
review of IN 87-09, " Emergency Diesel Generator Room Cooling Design j
Deficiency" for applicability at the Zion Station; ineffective corrective
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actions to address restrictive interpretation of Technical Specifications;
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and untimely technical support to the operations staff, j
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The licensee presented a chronology of events, starting before 1980 to i
the present, on the decision process that was used to determine D/G operability.
The licensee has traditionally used only Technical
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Specifications (TS) to determine operability.
However, the interpretation used by the licensee for determining
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operability was narrowly scoped; only addressing operability from the aspect that the equipment would run and perform its intended function.
l In May 1980, a concern, relating to the ability of the D/G to run without room ventilation, was raised. As a result, a test was conducted
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and-indicated that the D/Gs could run and function as required with l
no room. ventilation at elevated room temperatures.
The concern was justifiably removed.
In January 1985, a report was written to document i
the performance of the 1980 test, however, this report and its conclus-l ions have been unattainable.
In August 1988, the licensee was informed
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that.an engineering evaluation needed to be performed to establish the
operability of the D/Gs when the maximum design room temperatures are i
exceeded, due to the licensee's inability to locate the 1985 report,
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which documents verification of D/G operability determination.
In a May 1989, enforcement conference involving the process used for l
determining operability; the licensee committed to revise, PT-14, an operability surveillance procedure, to include a method for identifying support functions in order to make better operability determinations.
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Ir August 1989, the documentation concern was converted into an operability concern. The Assistant Superintendent of Operations (AS0),
e through implementing the upgraded PT-14 process, concluded that the D/G room ventilation system was not a necessary support function; therefore, the D/G was determined to be operable. During this determination, the AS0 identified a disparity between the FSAR and the TS.
In September 1989, an action plan was initiated to re-address the missing documentation concern of the 1980 test.
In October 1989, after discussions with the NRC, the D/G room ventilation systems was determined to be a support function; therefore, the D/Gs were declared inoperable.
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The licensee also presented an evaluation of the safety significance of operating the D/G without ventilation. The licensee presented an engineering analyses that was performed to prove that the components critical to D/G operation would remain operable at room temperatures in excess of the components maximum rated operating temperatures.
The licensee presented the following corrective actions.
SHORT TERM Senior Operating Management will review equipment status daily.
- Upgraded PT-14 procedure fully implemented by December 1, 1989
Technical staff engineers will review work requests for operability considerations
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A matrix will be developed by January 1,1990, that will identify required support equipment / functions and relate those to the i
appropriate equipment / Technical Specification section LONG TERM
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A complete matrix will be developed by July 1, 1990.
The inconsistency between the Technical Specification and the FSAR, relative to the D/G ventilation system will be resolved.
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Conclusion NRC review of the information presented in the enforcement conference i
concluded that with the DGs ventilation system fans in pull-to-lock, the D/Gs were inoperable.
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