IR 05000295/1978020

IE Inspec Repts 50-295/78-20 & 50-304/78-22 on 780809-11, 16-17,23-25,30-31,0901,07-08 During Which 1 Item of Noncompliance Was Noted:Preparation for Refueling

ML20197B748
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	10/04/1978
From:	Boyd D, Knop R, Riden M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20197B720	List: IR 05000295/1978020 ML20197B715 ML20197B739
References
50-295-78-20, 50-304-78-22, NUDOCS 7811080074
Download: ML20197B748 (11)

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. O U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-295/78-20; 50-304/78-22

i Docket Nos.: 50-295; 50-304 License Nos.: DPR-39; DPR-48  ;

I Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion Site, Zion IL

. Inspection Conducted: August 9-11, 16-17, 23-25, 30-31 and September 1, 7-8, 1978

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Inspector (s):

NW D. C. Boyd 7y' . 7y l

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/h M. D. Ride Y-26-73 l

,/ e ( 3-25) 7 "M-Y

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Approved By:

9c6 o R. C. Knop, Chie // ' S ~ /

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Reactor Projects Section 1

'f Inspection Summary Inspections on August 9-11, 16-17, 23-25, 30-31 and September 1, 7-8,

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1978, (Report No. 50-295/78-20; 50-304/78-22)

Areas Inspected: Routine, unannounced inspections in the following areas: Review of plant operations; procurement; records, preparation for refueling; physics testing; 10 CFR 21; and diesel generator performance. Also a special announced inspection was conducted to re, view the licensee responses to specific IE Bulletins and Circular These inspections involved 180 manhours of inspection by three NRC inspector Results: Of the eight areas inspected, no items of noncompliance were found in seven areas, and one item of noncompliance was found in the area of preparation for refueling. One unresolved item was identified in the review of the licensee responses to IE Circulars and Bulletin M1 -

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DETAILS Persons Contacted N. Wandke, Plant Superintendent

• • Leider, Assistant Plant Superintendent L. Soth, Administrative Assistant

• C, Schumann, Operating Engineer

• R. Ward Operating Engineer

• • E. Fuerst, Operating Engineer

• • J. Marianyi, Technical Staff Supervisor

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• J. Gilmore, Shift Engineer Flowers Shift Engineer Miosi, Instrument Engineer Schultz, Training Supervisor Harl, Quality Assurance Supervisor R. Ungeren, Assistant Technical Staff Supervisor I F. Lentine, Assistant Technical Staff Supervisor l

• • P. Kuhner, Quality Assurance Technician l

• • J. Campbell, Technical Staff Engineer i E. Campbell, S.N. M. Peterson, Nuclear Engineer P. LeBlond, Technical Staff Engineer D. Walden, Fuel Handling Foreman W. Dean, Technical Staff Engineer

• J. Koske, Technical Staff Engineer

• Denotes those present at the September 8, 1978, Exit Interview j

• • Denotes those present at the August 25, 1978, Exit Interview Status of Previous Items of Noncompliance and Unresolved Items The inspector reviewed action taken on the following items of inspection reports number 50-295/77-03, 50-304/77-05, 50-304/78-11, and 50-295/78-1 l A previously identified infraction on recalibration of excore axial imbalance detector system at least every three effective full power months was closed ou Zion procedure TSS 15.6.2 was used to document the performance of the recalibrations within the required schedule. There are no further concern l Previously reported unresolved items on core thermal power

calculation and shutdown margin determination were closed ou The licensee's response to inspection reports 50-295/77-03 and 50-304/77-05 provided information I l-2- I

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assuring that their method for calculating core thermal power was conservative. During the month of August 1978, the inspector reviewed the. control room graphs used for shutdown margin calculation to insure that the graphs were being revised to include the required value Implementation of this item has been confirmed. There are no further concern c. A previously identified unresolved item on the documentation of refueling' equipment interlocks checkout was closed ou Zion Station fuel handling department, fuel tool inspection form #7 was revised on June 1, 1978, to include the checkout of these interlock There are no further Concern d. An unresolved item, regarding the timeliness of reporting an unintentional removal from service of a containment spray pump was identified in IE Report No. 50-295/78-1 Continued review and discussion of this matter indicates that the licensee performed responsibility in all aspects of this event and did meet the intent of the reporting requirement. Thus, no citation is warranted. A reasonable doubt existed as to whether the containment spray pump had actually been rendered inoperable. The Operations Shift Foreman who controlled the system lineup during the battery replacement was unavailable for discussion (sequestered on Jury Duty) thus the actual position of the mode switch during the battery change out could not be immediately establishe A second contributing factor to the delay in reporting this event was the fact.that the specific circuitry involved had never been tested.in the " manual mode" to determine if an automatic containment. spray pump start would occur on a safeguards. signal. The previous safeguards testing to verify automatic response including the preoperational testing, had always been performed with the mode switch in the " automatic position".. Other safeguards components, such as the safety injection pumps and the diesel generator automatically respond to a safeguards signal with the mode switch in either the manual or the automatic position Thus, a special test was prepared and performed which verified that placing the mode switch in " manual" did result in defeating the automatic response to a safeguards signa The immediate corrective action was to affix a permanent tag'to the mode switch which cautions that the

, pumps will only respond to a safeguards signal while in the automatic position. Appropriate procedure changes have also been mad l L - - - -

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once it was established that the preventative maintenance I activities had in fact rendered one of the three i containment spray pumps inoperable, the licensee reported the event to the NRC in LER 50-295/78-66.

I There are no further concern .

l Review of Plant Operations Partial tours of the plant were made during each inspection da Primary emphasis was given to observations in the control room. Thes'e observations included the verification of proper manning, verification that key operating parameters are maintained within acceptable limits, verification that key emergency systems are properly aligned for automatic response; and verification that the system and component surveillance is I performed in accordance with facility technical specification This portion of the inspection also included the review of ,

control room logs and data sheets, shift supervisor-shift

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foreman logs, miscellaneous auxiliary log j During this reporting period the inspector attended two plant l

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staff morning planning meeting l No items of regulatory concern were identified in this area.

• Procurement An inspection was conducted to determine whether the purchase of components, materials and supplies used for safety related functions, is in conformance with the licensee's approved quality assurance program and implementing procedures.

e During this inspection, the inspector reviewed the following modification packages to assure that the procurement specifications used had received proper approval, quality control inspection and hold point requirements, and proper certification records; modification number 76-64, Core Spray Check Valves; Modification 78-9, Control Rod Drive Quick Disconnects;75-109, Steam Jet Air Ejector Rupture Disc. All modification packages were found to be in good order. The staff control procedures in this area appear to be well defined and implemente The Station Quality Control Group performs many audits including

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inspection of components upon delivery, storage of materials,

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issuance of materials from the station receiving group, adherence to code and procedure on installation, functionr1 testing and non-destructive examination of welds. These audits appear to be very thorough, and they are performed by a qualified staff consisting of eleven person _

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l The inspectors toured the materials receiving and storage area and observed the receiving area, the locked holding area for non-conforming materials, the tagging of certified materials, and the record keeping files. A full time (day shift) Quality Control pe: son is assigned to the receiving area to assure that the naterfsl received is as specified and that any certification

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documentat. ion is also provide No items of regulatory concern were identifie . Records

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An inspectior. was conducted to determine if the licensee's program for the control, storage, retention, and retrieval of records and documents is in conformance with technical specifications and approved procedure It was determined that the required plant records are maintained in their original form in the master files for one calendar yea Then thes'e records are micro filmed for storage in the records vault. The inspector verified the retention and retrieval capabilities by reviewing records of the following systems:

-Electrical systems, penetrations, cable specifications, splice certification Periodic test records for the emergency core cooling syste Calibration data for the containment pressure transmitter Periodic test data for the primary coolant syste Included in the above inspection was the verification that records of modifications to systems were properly maintained and that system master "as built" drawings, and procedures are maintained in a current statu It was also verified that system modifications and design changes are systematically incorporated into the plant training progra It was determined the* adequate records are generated regarding reactor opc-ation and equipment performance to permit r.eview to detect long term equipment degradation or adverse trends. The licensee identifier the requirements and responsibilities for these reviews in the plant administrative control procedure The inspector periodically verifies that these reviews are s being conducte No items of regulatory concern were identifie l

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l Preparation for Refueling The inspector examined the licensee's refueling procedures and records for receint inspection of new fuel, and provisions for !

fuel transfer and cr_a verification. The inspector witnessed i portions of the new fuel receipt inspection to verify adherence l to approved procedures. During inspection of fuel assembly l number F-57 a foreign screw from the hold down pad was observed on the upper nozzle of the fuel assembl I Section 6.2.A.i of the Zion Technical Specifications requires that detailed written procedures including applicable checkoff lists covering refueling operations be prepared, approved, and )

adhered t l Inspectica procedure FHI-03, "New Fuel inspection", item 6.33 and the attached data sheet requires, in part, that any discrepancies observed (i.e., foreign material, stains, or deep i scratches) on the upper nozzle during the inspection be l

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reccrde l Contrary to the above, when performing Unit 1, cycle 4, new I fuel inspection on August 16, 1978, the fuel inspector and handling foreman completed the data sheet for assembly number F-57 I without recording that foreign material was observed on the upper nozzl I Physics Testing Procedures An inspection was performed to determine if measurements and results of physics tests were in accordance with the facility's technical specifications and consistent with NRC requirements in the following areas: Core Thermal Power Determinatior Control Rod Worth Measurement Determination of Reactor Shutdown Margin Isothermal Temperature Coefficient of Reactivity Measurement

, Power Coefficient of Reactivity Measurement j Target Axial Flux Difference Calculation

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Incore/Excore Detector Calibration

' Serveillance of Core Power Distribution Limits-6-

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The inspector verified that the frequency of evaluations was as prescribed by the plant technical specifications. Each measurement was performed in accordance with the latest approved procedure. The difference between some measured and predicted values of WCRP-9246, Unit 2, Cycle 3, core physics, exceeded the design acceptance crf*eria for boron endpoint, control rod worths and hot channel tactors. Discrepancies were i properly accounted for in report FP-CW-433, modified cc2:nents en WCRP-9246, and the licensee's summary of Unit 2, Cycle 3, ;

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startup physics testing result An investigation was conducted to determine if the licensee i had implemented the incore/excore detector calibration for the previous year. The inspection revealed that the monthly ,

calibration check tends to exceed the 1% Technical Specification l difference which requires the recalibratinc to be performed )

at a frequency more often than specified in '. facility l Technical Specification Based upon the inspector's reviews and interview:. no items of regulatory concern were i82ntified in these inspection area l Reporting of Defects and Noncompliance - Part 21 Reports An inspect 1on was conducted to determine whether organizations and individuals subject to Part 21 regulations have established and are implementing procedures and controls to assure the reporting of defects and noncomplianc During the inspection the following items were verified: The Part 21 requirements are incorporated into the Company Quality Assurance Progra The Part 21 posting requirements for the station have been me Controls have been implemented to assure that procurement documents for safety related materials specify that the provisions of Part 21 appl Previous inspections at other Commonwealth Edison Company Nuclear Stations have verified other aspects of adherence to Part 21 are employed on a compt.y wide basi l Emergency Diesel Generator Performance

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An inspection was conducted at the Zion Station on August 23-25, 1978, which included a review of the operation of the diesel l generstors under various postulated conditions. It was determined, i I-7-l l

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following discussions and a review of prints and logic diagrams with cognizant members of the Technical Staff, that

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it is not possible to overload a tiesel generator by either manually placing too much load on it or by an operator failing to manually shed load during an emergency situatio There are tuo key reasons for this. First, during a loss of offsite power situation, where the emergency power is being  ;

supplied by the diesel generators, interlocks prevent any cross loading from other buses to the safeguards _ busse Secondly, the safeguards buses are designed such that if all ,

loads possible were placed in operation, it would still not l overload any one of the diesel generator In the event of a loss of offsite power, all loads on the I safeguards buses would be automatically shed. The " blackout )

sequencer" would then automatically load the buses (after at speed and voltage). Manual loads could then be started as decired. If any safety injection (S.I.) was then initiated there would be no load shedding, the S.I. would simply )

auto-start any S.I. equipment that was not already operatin However, due to the system design and the diesel generator capacity no overload of the diesels is possible, and no operator action to shed load is require These particular design capabilities are verified by actual testing at the start of each refueling outag . Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on i September 8, 1978, and summarized the scope and findings of I the inspection and discussed the resolution of unresolved items (

and the item of noncomplianc An exit interview was held on August 25, 1978, with licensee representatives (denoted in paragraph 1), the following was discussed: the scope of findings of the inspection regarding l IEB 77-05,77-05A,.77-06. 78-02, 78-04 and electrical equipment )

qualifications were discussed pertaining to the evaluation of 1 l

IE circular 78-08. The licensee stated that the evaluation for IE circular 78-08 would be completed by October 2, 197 ..

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Section 11 Prepared by: J. Hughes Reviewed By: R. L. Spessard, Chief Engineering Support Section 1 1. Licensee Action on IE Bulletins The Rill insp~ector res.ewed licensee responses to IE Bulletin Nos.: 77-05,77-05A, 77-06, 78-02 and 78-04 and verified that:

licensee management firwarded copies of the bulletins to appropriate onsite mat egement representatives; information discussed in the licensee's response was accurate; and action taken, if any, was as described in the response The inspector determintd that the licensee had performed a systematic review of the facility to ensure that no connectors, electrical penetrations, terminal blocks or limit switches of the types identified in the bulletins were installed in safety related systems, Qualification of Electrical Connetcors (IE Bulletins 77-05 and 77-05A).

The RIII ins:ector reviewed D. G. O'Brien drawings R19D2430G Revision D, hA9D2226G Revision F and R19D2227G Revision (unknovn).

(1) Pin type connectors are not utilized with electrical penetrations at Zion Station Nos. 1 and (2) Connections to the electrical penetration feed thru conductors (pigtails) utilize catae splices, not connector (see paragraph 2 below) Qualifications of Electrical Penetrations (IE Bulletin 77-06)

(1) The RIII inspector reviewed documentation for D. G. O'Brien type electrical penetrations which included:

(a) Design Specification (Sargent and Lundy X 2308);

(b) D. G. O'Brien Instruction Manual (No. 1031);

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(c) Production test reports;

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(d) D. G. O'Brien (DGO) prototype test reports for electrical penetration assemblies (DGO Report No. C19QA051 dated August 31,1971; DG0 Repor t No. C19QA052 dated September 2, 1971 and DGO Report No. C19QA058 dated February 25, 1972);

i (e) Review of applicable DGO electrical drawings (see paragraph a. above).

(2) Design Specification (Sargent and Lundy X2308) paragraph 10.C.J oclineated environmental test conditions in which equipmer.c must remain operabic during and after a design basis accident. The conditions include temperature, pressure, humidity, steam, chemical (water) spray and radiation exposur (3) D. G. O'Brien protot:.pe test reports, mentioned in subparagraph (1)(d) above, did not include chemical (water)

spray or redircion exposure test result Subsequent to the inspection, or August 28, 1978, the RlII inspector was provided information from IE headquarters that D. G. O' Brier., Ir.c. had previously provided the NRC with an engineering analysis concerning radiation and chemical (water) spra Both IE headquarters and Nuclear Reactor Regulation had previously concurred with D. G. O'Brien's analysis. Therefore, the analysis n port was not reviewed by the RIII inspecto Qualification of Terminal Blocks (IE Bulletin 78-02)

By reviewing electrical drawings 22E-1-4945K and L; 22E-1-4945E, F, G and H; 22E-1-45495A; and 22El-4942C, D, E e-d F the RIII inspector verified that terminal blocks w Tot installed in the following circuits: Pressurizer P.<.esure, Pressurizer Level, Containment Pressure and accumulator Tank Level Transmitter Qualification of Limit Switches (IE Bulletin 78-04)

The RIII inspector reviewed S&L drawing M-54 Revision N, to verify that the three valves (VC8149A, B and C) mentioned in the licensee's response to the bulletin were not required to provide a safety functio The valves are located in the discharge line of the regenerative heat exchanger (RCS Letdowr.).

Valve VC8152, located outside containment, provides isolation

/ of RCS Letdow No items of noncompliance were identifie (

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2. Licensee Action on IE Circular 78-08 The licensee stated that evaluation of IE Circular 78-08, pertaining to electrical transmitters, motors, valve operators and other components has not been completed. The licensee's schedule for completing the evaluation is October 2, 1978, and these items will be reviewed during a subsequent inspection after completion of the evaluatio Qualification of electrical cable splices is described below: '

(1) Electrical installation specification S6L X2329 requires

, that all cable termination materials for containment electrical penetrations be provided by the electrical penetration manufacture (2) D. G. O'Brien the penetration manuf acturer's drawing R19D2227G Revision (unknown) for electrical penetration assembly,' type 4.1 and 4.lA, 600 Volt Instrumentation (normal plus post accident duty), specifies Raychem RT-876 j heat shrink tubing and Raychem S-1024 tape for cable splices inside containmen (3) D. G. O'Brien drawing R19D2430G Revision D, electrical penetration type 6.1, 600 volt, power and control service (normal and post accident duty), specifies Kerite Kit No. DS-1001 for cable splices inside containmen (4) The RIII inspector determined that documentation was not available at the site for environmental qualification of safety related electrical cable splices used inside containment as specified in subparagraphs (2) and (3)

abov This matter is unresolve (295/78-01; 304/78-01).

No items of noncompliance were identifie Note: The areas inside containment were not observed by the RIII inspector due to radiation limits inside containment. However, these areas will be observed during a subsequent inspection to be performed following completion of the licensee's evaluatio .

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