ML20054H934

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IE Insp Repts 50-295/82-12 & 50-304/82-10 on 820401-0514. Noncompliance Noted:On 820402,operators Observed Routinely Bypassing Gripper Tube Up Interlock in Nonemergency Situations
ML20054H934
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 06/07/1982
From: Burgess B, Connaughton K, Hayes D, Hinds J, Mcgregor L, Waters J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20054H927 List:
References
50-295-82-12, 50-304-82-10, NUDOCS 8206250219
Download: ML20054H934 (10)


See also: IR 05000295/1982012

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-295/82-12(DPRP); 50-304/82-10(DPRP)

Docket No. 50-295; 50-304

License No. DPR-39; DPR-48

Licensee: Commonwealth Edison Company

P.O. Box 767

Chicago, IL 60690

Facility Name: Zion Nuclear Power Station, Units 1 & 2

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Inspection At: Zion Site, Zion, IL

Inspection Conducted: April 1 through May 14, 1982

Inspectors:

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Reactor Projects Section IB

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Inspection Summary

Inspection on April 1 through May 14, 1982 (Reports No. 50-295/82-12(DPRP);

50-304/82-10(DPRP)

Areas Inspected: Routine unannounced-resident inspection of licensee action

on previous inspection items, radioactive releases, RCS temperature limits,

Rad Monitor Task Force, Confirmatory Order Application, Anonymous Allegation,

Change in F , Steam Generator Inspection and Repair, Instrument Air Task

Force, Refueling Operations, Operational Safety Verification, Monthly

Maintenance Observation, Monthly Surveillance observation and Licensee

Event Reports. The inspection involved a total of 432 hours0.005 days <br />0.12 hours <br />7.142857e-4 weeks <br />1.64376e-4 months <br /> by five NRC

inspectors including 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> onsite during off-shifts.

Results: Of the areas inspected one item-of noncompliance (improper by-

passing of Refueling Interlocks, paragraph 4) was identified.

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8206250219 820610

DR ADOCK 05000g

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DETAILS

1.

Persons Contacted

  • K. Graesser, Station Superintendent
  • E. Fuerst, Assistant Station Superintendent,' Operations

G. Plim1, Assistant Station Superintendent, Administrative

and Support Services

R. Budowle, Unit 1 Operating Engineer

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J. Gilmore, Unit 2 Operating Engineer

  • L.

Pruett, Assistant Technical Staff Supervisor

P. LeBlond, Assistant Technical Staff Supervisor

A. Miosi, Technical Staff Supervisor

B. Schramer, Station Chemist

F. Ost, Health Physics Engineer

C. Silich, Technical Staff Engineer, ISI

  • B.

Harl, Quality Assurance Engineer

  • T.

Lukens, Quality Control Engineer

B. Kurth, Master Instrument Mechanic

  • Denotes those present at the exit meeting of May 14, 1982.

2.

Summary of Operations

Unit 1

Unit i remained shut down for a scheduled refueling outage during the

entire inspection period. The outage is currently scheduled to be.

completed June 3, 1982.

Unit 2

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Unit 2 operated at power levels up to 100% during the inspection

period. At times power level was limited to less than 50% due to

high conductivity levels in the secondary system. The licensee

believes the conductivity levels are caused by some type of organic

compound as opposed to contamination with lake water. On April 9,

1982 during surveillance testing of the auxiliary feed pumps (AFP)

the secondary system did become contaminated with lake water when a

service water cross connect valve leaked lake water into the AFP

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suction. The AFP's injected the water into the steam generators and

the condensate storage tank. Conductivity levels of 68 micro-mho/cm

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were measured in the steam generators. The unit was shutdown and cooled

down as required by station procedures. After cleaning up the secondary

systems, Unit 2 was made critical April 13, 1982 and tied to the grid

April 14, 1982.

3.

Licensee Action on Previous Inspection Items

Open Item (50-295/82-04-01): Corrective action for components wetted

during flooding of reactor cavity.

As of the end of the inspection

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period the licensee had received a Westinghouse letter stating that

plant conditions and chemical levels in the refueling water should

preclude reaching concentrations that would raise concern for reactor

vessel materials. The letter also suggested monitoring ventilation

loading as a precaution against loss of reflectivity of the mirror

insulation. The station is to receive the results of additional

analysis by the Station Nuclear Engineering Department and the

Systems Materials Analysis Department. Since further information

is required on this matter, the item will remain open. This item

must be resolved prior to plant heat up.

(50-295/82-12-01)

(Closed) Open Item (50-295/82-04-03) Loss of RHR on February 23, 1982:

Further discussions with operations personnel have indicated that there

was no loop seal in the reactor vessel level tubing. The level indi-

cation appears to have been valid. The exact cause of the loss of

RHR suction cannot be determined but it is suspected that the RCS may

have been drained too fast.

4.

Bypassing of Refueling Interlocks

On April 2, 1982, while witnessing fuel handling operations, the

inspector observed operators routinely bypassing an interlock when

moving fuel modules from one core location to another. After with-

drawing a module high enough to clear the core, the operators would

use the interlock bypass switch to override the interlock that pre-

vents bridge and trolley drive operation except when the gripper

tube up position switch is actuated. The bridge and trolley could

then be driven to the new core location with the fuel module not

fully withdrawn into the mast.

Through conversations with operators

the inspector determined that the bypassing of this interlock was

routine practice when moving fuel modules from one core location to

another.

Technical Specification 6.2.A states that " detailed written procedures

including applicable checkoff lists covering items listed below

(Refueling Operations) shall be prepared, approved and adhered to."

Zion Station Fuel Handling Instruction FHI-13 precaution 3.1 states

" Interlock bypasses are for use either in emergencies or to permit

operation in areas where there may be obstructions to free travel

of the mast."

Contrary to the above, on April 2,

1982 operators were observed

routinely bypassing the gripper tube up interlock.

This violation was inspector identified.

This item is designated as Open Item 50-295/82-12-02 pending verifi-

cation of the licensee's corrective action.

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5.

Release of April 27, 1982

At about 1:40 p.m. April 27, 1982 a very small gaseous release of

unknown origin occurred. The release was seen on the recorder for

the auxiliary building vent monitor and was too small to be seen

by any other monitor. The licensee calculated that the total

activity was 120 millicuries with a maximum release rate of about

0.6% of the Technical Specifications limit.

The licensee was unable to determine the source of the release.

No items of noncompliance were identified.

6.

Establishment of Lower RCS Temperature Limit

In response to inspector concerns the licensee's nuclear engineering

group determined that the shutdown margin calculations used during

cold shutdown are based on a minimum expected RCS temperature of

68*F. It is possible to cool the RCS lower than 68 F using RHR during

winter months. The licensee has initiated changes to station pro-

cedures GOP-1 and PT-0 to establish 68*F as the lowest allowable RCS

temperature.

No items of noncompliance ;ere identified.

7.

Review of Rad Monitor Program

The inspector reviewed the licensee's program to improve the perform-

ance and reliability of the plant radiation monitors. The program

was implemented in May of 1981. The Unit 1 operating engineer receives

a daily report of rad monitors that are out of service. He reviews

the report and investigates any monitors that have been removed from

service since the previous report.

He is also responsible for expediting

the repair and restoration of failed monitors. Usually there is a weekly

meeting of representatives from operations, technical staff, instrument

maintenance and radiation protection to determine if there have been any

repetitive malfunctions that need long term corrective action and to

ensure that there are no delays in returning monitors to service.

The need for long term corrective actions is referred to the Rad Monitor

Task Force. The task force determines what actions to take,' initiates

the action, and tracks its status. The Task Force consists of the

Assistant Superintendent for Technical Support, the Unit 1 Operating

Engineer, the cognizant Technical Staff Engineer, the Lead Health

Physicist and either the Master Instrument Mechanic or a foreman.

Task force meetings are held every six weeks and formal minutes are

kept.

Some examples of the actions taken by the rad monitor task force are

as follows:

1.

Replacement of multi point recorder with pen recorders for

several important process monitors.

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2.

Institution of a program to silver plate copper contacts to

prevent the corrosion buildup that was causing monitor

failures.

3.

Initiation of a modification to provide reflash alarm circuitry

for the control board on a rad monitor alarm.

4.

Replacement of nylon gears that had exhibited a high failure

rate with steel gears in the check source mechanism of certain

monitors

The licensee has also implemented some of the recommendations contained

in a study of the radiation monitoring system done by Stone and Webster

issued in March of 1981.

Licensee calculations indicate that there has

been a reduction in the average number of rad monitors out of service

on a given day from 7.8 in November and December of 1981 to 5.5 in

January and February of 1982.

No items of noncompliance were identified.

8.

Confirmatory Order Requirements as Applied to Crevice Flushing

The February 29, 1980 Confirmatory Order Item A.3 issued to Zion

Station requires that the licensee conduct a low pressure gross leak

test of containment prior to any start up from cold shutdown condi-

tions. As part of the sequence for the Unit i return to operation,

the licensee plans to perform crevice flushing on the steam generators.

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This evolution requires reactor coolant pump heat up to about 230*F

followed by rapid steam off of the S/G which will cool down the RCS

to below 222*F.

This sequence is repeated several times for each

steam generator. The whole process will take about a week and is

followed by a cooldown to remove temporary S/G hand hole plates, with

heat up to criticality temperature to follow immediately thereafter.

In a conference call on May 5, 1982 between licensee representatives,

the Zion Licensing Project Manager, and the Senior Resident Inspector,

it was concluded that the heatups required for crevice flushing did

not constitute a start up and that the low pressure gross leak test

of the confirmatory order need not be repeated. This-conclusion was

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also based on the assumption that none of the systems previously

tested have been disturbed, otherwise they must be re-tested.

No items of noncompliance were identified.

9.

Anonymous Allegations

On May 5, 1982 an anonymous caller alleged to the Senior Resident

Inspector that contractor employees were drinking at lunch time and

returning to the site inebriated. Unit I was in a refueling outage

at the time with a large number of contractor employees on site.

The licensee intensified its monitoring of employees entering the

facility, increased the awareness of the contractor's management,

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and monitored contractor areas and parking lots. No instances of

improper conduct were observed.

No items of noncompliance were identified.

10.

Changes in Unit 1F

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The 498 tubes currently plugged in the Unit 1 steam generators exceed

the assumed 1% tubes plugged in the most recent ECCS/LOCA analysis.

Using Westinghouse sensitivity study, relationships between percent

tubes plugged and peak clad temperature, and between peak clad

temperatures and F the licensee has determined that a new F limit

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of 2.13 will accomodate the effect of the tube plugging. The "80

case" analysis for Unit I cycle 7 shows a maximum expected F of

2.091.

Since this is below the new proposed limit of 2.13, surveil-

lance using the Axial Power Distribution Monitoring System will not

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be required. The licensee intends to submit and obtain approval for

a Technical Specification change establishing 2.13 as the new F limit

for Unit 1.

Approval of this change will be required prior to Unit 1

start up.

No items of noncompliance were identified.

11.

Unit 1 Steam Generator Tube Repair and Plugging

Due to primary to secondary tube leakage and damage to the ID S/G

tube ends (see Inspection Report 50-295/82-04; 50-304/82-04) an

extensive tube examination and repair program was conducted during

the current refueling outage. All tubes in all four steam generators

were examined using eddy current testing and helium leak testing.

The number of tubes plugged in the A, B, C and D steam generators

was 116, 120, 103 and 133 respectively. These numbers include the

94 row 1 tubes plugged in each generator due to concerns of generic

problems in this row.

As a result of the damage to the tube ends by

loose parts in the primary system, all but 296 tubes in the ID steam

generator hot leg side required repair. The repair consisted of

re-ro111ac the tube ends to re-establish circularity and permit eddy

current probing.

Further details of the steam generator work are

contained in Inspection Reports 50-295/82-10 and 50-295/82-08.

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No items of noncompliance were identified.

12.

Review of Instrument Air Program

Zion Station has had a history of air operated valves failing to

operate when the solenoid operated air control valves became stuck

in their existing position. This was found to be caused by contam-

inants, primarily oil, in the instrument air system which interacted

with the solenoid valve seals. The licensee has taken various actions

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to correct this program (see Inspection Reports 50-295/81-29; 50-304/

81-27.) One of the licensee's actions was to institute a program to

improve the reliability of the instrument air compressors. There are

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three instrument air compressors and two'are required to supply normal

instrument air system loads.

Thus, if more than one instrument air

compressor is out of service, it is necessary to cross tie instrument

air to the service air system. The service air system has proven to

be the source of most of the oil'in the instrument air system.

The program to improve the instrument air system reliability is admin-

istered by the instrument air task force. The task force is comprised

of the Assistant Superintendent for Administrative and Technical

Services, the Assistant Superintendent for Maintenance,,a Representa-

tive from the Operations Department and the' cognizant Technical Staff

Engineer. Meetings are held every three months and formal minutes are

kept. The task force functions to identify problems, initiate correc-

tive action-and assign responsibility for follow-up concerning matters

affecting the reliability or quality of instrument air system. One of

the first actions taken was to establish a preventative maintenance

program for the instrument air compressors. The compressors are over-

hauled every six months using a specific checklist. They have also

been balanced using a vibration analyser. A trending program has been

established which logs the duration of any crosstie between instrument

and service air systems. Since July of 1981 when the trending began,

the systems have been cross connected for a total time of about 1.7

days. The inspector will continue to monitor the effectiveness of

the licensee's program.

No items of noncompliance were identified.

13.

Refueling Activities

The inspector verified that prior to the handling of fuel in the core,

all prerequisites required by the licensee's procedures had been com-

pleted and verified that during.the outage the periodic testing of

refueling related equipment was performed as required by Technical

Specifications; the inspector observed two shifts of the fuel handling

operations (removal, inspection and insertion) and, except as noted

in paragraph 4, verified the activities were performed in accordance

with the Technical Specifications and approved procedures; verified

that containment integrity was maintained as required by Technical

Specifications; verified that good housekeeping was maintained in

the refueling area; and, verified that staffing during refueling was

in accordance with Technical Specifications and approved procedures.

One item of noncompliance (paragraph 4) was identified.

14.

Operational Safety Verification

The inspector observed control room operations, reviewed applicable

logs and conducted discussions with control room operators-during

the months of April and May 1982. The inspector verified the'oper-

ability of selected emergency systems, reviewed tagout records and

verified proper return to service of affected components. Tours of

Unit 1 containment, the auxiliary building, the crib house and the

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turbine building were conducted to observe plant equipment conditions,

including potential fire hazards, fluid leaks, and excessive vibra-

tions and'to verify that maintenance requests had been initiated for

equipment in need of maintenance. The inspector by observation and

direct interview verified that the physical security plan was being

implemented in accordance with the station security plan.

The inspector observed plant housekeeping / cleanliness conditions and

verified implementation of radiation protection controls. During the

month of April, the inspector walked down the accessible portions of

the cold leg accumulator system to-verify operability. The inspector

also witnessed portions of the radioactive waste system controls

associated with radwaste shipments.

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 procedures.

No items of noncompliance were identified.

15.

Monthly Maintenance Observation

Station maintenance activities of safety related systems and compon-

ents listed below were observed / reviewed to ascertain that they were

conducted in accordance with approved procedures, regulatory guides

and industry codes or standards and in conformance with Technical

Specifications.

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; functional testing and/or calibrations were

performed prior to returning components or systems to service; quality

control records were maintained; activities were accomplished by

qualified personnel; parts and materials used were properly certified;

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radiological controls were implemented; and, fire prevention controls

were implemented.

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 performance.

Maintenance on the following components was observed / reviewed:

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a.

Unit 1 cold leg accumulator valves

b.

Unit 1 safety injection pump 1B

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Unit i refueling water storage tank

d.

Unit 1 boron injection tank

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Unit 2 reactor vessel level monitoring system

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"O" diesel generator

Following completion of maintenance on the O diesel-generator, the

inspector verified that it had been returned to service properly.

No items of noncompliance were identified.

16.

Monthly Surveillance Observation

The inspector observed Technical Specifications required surveillance

testing on all four RHR pumps and safety injection pumps and verified

that testing was performed in accordance with adequate procedures,

that test instrumentation was calibrated, that limiting conditions

for operation were met, that removal and restoration of the affected

components were accomplished, that test results conformed with Techni-

cal Specifications and procedure requirements and were reviewed by

personnel other than the individual directing the test, and that any

deficiences identified during the testing were properly reviewed and

resolved by appropriate management personnel.

The inspector also witnessed portions of the following test activities:

ECCS full flow test of the RHR and SI systems

No items of noncompliance were identified.

17.

Licensee Event Reports Followup

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 Speci-

fications.

Unit 1

LER NO.

DESCRIPTION

82 03 (update)

Failure of 1A RHR Suction Valve to Open During

Surveillance

82 16

Tave Summator Out of Tolerance

82 17

1A RC Cold Leg Temperature Amplifier Failed Low

Unit 2

LER S0.

DESCRIPTION

82-06

2D SG Level Transmitter Out of rolerance

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82 08

Failure of 011 Battery Charger

No items of noncompliance were identified.

18.

Senior Resident Inspector Position

During the inspection period Mr. Joseph R. Waters was permanently

assigned as.the Zion Senior Resident Inspector.

19.

Augmented Inspection Coverage

During the inspection period the following NRC personnel were

temporarily assigned to Zion Station to augment the resident

inspector coverage:

B. L. Burgess (Resident Inspector-Prairie

Island NPS), K. A. Connaughton, (Reactor Inspection-Region III),

L. G. McGregor (Senior Resident Inspector-Braidwood NPS) and

J. M. Hinds (Project Inspector-Region III).

It is anticipated that

such augeented resident inspector coverage will continue through

August 1982.

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20.

Meetings, Offsite Functions

April 22-23, 1982

Zion SALP Board Meeting Region III Offices

Glen Ellyn, Illinois

April.28-29, 1982

Senior Resident

Region III Offices

Meeting

Glen Ellyn, Illinois

May 3,

1982

Meeting with Licensee

Commonwealth Edison

Management on results

Corporate Headquarters

of special inspection-

Chicago, Illinois

into allegations con-

cerning operation of

Nuclear Plants

21.

Exit Interview

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The inspector met with licensee representatives (denoted in paragraph

1) throughout the month and at the conclusion of the inspection on

May 14, 1982 and summarized the scope and findings of the inspection

activities.

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The licensee acknowledged the inspector's comments.

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