ML20205A403
| ML20205A403 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/06/1986 |
| From: | Gautam A, Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20205A373 | List: |
| References | |
| 50-295-86-16, 50-304-86-15, NUDOCS 8608110362 | |
| Download: ML20205A403 (7) | |
See also: IR 05000295/1986016
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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Reports No. 50-295/86016(DRS); 50-304/86015(DRS)
Docket Nos. 50-295; 50-304
Licenses No. DRP-39; DPR-48
Licensee:
Commonwealth Edison Company
Post Office Box 767
Chicago, IL 60690
Facility Name:
Zion Nuclear Power Station, Units 1 and 2
Inspection At:
Zion, IL
Inspection Conducted:
July 9, 10, and 29, 1986
Bh/M
Inspector:
A. S. Gautam
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Date
d%C
Approved By:
J. W. Muffett, Chief
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Plant Systems Section
Date
Inspection Summary
Inspection on July 9, 10, and 29, 1986 (Reports No. 50-295/86016(DRS);
50-304/86015(DR5))
Areas Inspected:
Routine announced safety inspection by a regional inspector of
licensee actions on previous inspection findings, and review of potential
environmental qualification concerns regarding Raychem splices.
Results:
No violations or deviations were identified; however, an ongoing NRC
review is being performed to evaluate the impact of discrepancies found in the
EQ designated Raychem splices.
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DETAILS
1.
Persons Contacted
a.
Commonwealth Edison Company
- G. Plim1, Station Manager
- T. Rick, Superintendent Services
- W. Stone, Station QA Supervisor
- R. N. Cascarano, Technical Staff Supervisor
- T. Printz, Technical Staff
- J. Ballard, QC Supervisor
- P. LeBlond, Licensing
- F. G. Lentine, SNED
- M. Baily, Station EQ Coordinator
- T. Broccolo, Operating
- R. J. Budowle, Administration
L. Holden, Regulatory Assurance - Zion
b.
Sargent and Lundy (S&L)
M. Rankhorst, Site Engineer
J. J. Reddy, Site Engineer
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c.
Nuclear Fuel Services (NFS)
K. Avng, Consultant
R. Tsai, Consultant
- Denotes those present during the interim site exit meeting on
July 10, 1986.
- Denotes those present during the exit meeting on July 29, 1986.
2.
Licensee Action on Previous Inspection Findings
a.
(Closed) Unresolved Item (304/85-06-01):
This item addressed NRC
concerns regarding the removal of post accident monitoring equipment
(TER Items 41, 79, 80, 81, 82 and 83) by the licensee from their EQ
list without appropriate technical justification.
Attachment 3 of the licensee's September 20, 1985, response addressed
correspondence with NRR related to the removal of these items.
During
this NRC review it was concluded that at the time the licensee
initiated their EQ program certain confusion existed as to the
distinction between items covered by IN 7901B, 10 CFR 50.49 and
Consequently, all items were placed on one
list to respond to Information Notice 79-01B.
The above items in
question were later determined by the licensee to be Regulatory
Guide 1.97 items and removed from their EQ program to be covered
under an ongoing 1.97 review.
The licensee reported the removal of
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these items to be in keeping with the evolution of their program,
and that-these items were subsequently qualified.
Draft EQ binders
have been prepared for these items and the licensee plans to complete
a review of 1.97 items by August 1987.
The licensee continues to-
exclude the above items in question from their EQ list and does not
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require these items for shutdown following a Design Basis Accident.
b.
(Closed) Open Item (304/85-06-02):
This item addressed the lack of
instructions'in licensee EQ procedures for the upgrading of replacement
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equipment to 10 CFR 50.49 requirements.
During this review the NRC
inspector reviewed CECO site procurement arocedure ZAP 4-51-1 dated
August 29,1985,"EstablishinggualityRequirementsforRequestsfor
Purchase and Requisition Cards.
The purpose of this procedure is
to assure that_ appropriate technical requirements and quality
requirements are met during procurement of equipment used during the
operation and maintenance of the Station.
The inspector observed
that Section C.II.1 of this procedure had been revised to now require
the Technical Staff EQ Coordinator to determine if EQ, equipment
requirements are applicable during procurement of equipment.
c.
(Closed) Violation (304/85-06-05):
This violation addressed the
qualificationofjunctionboxesinsidethecontainmenthavingtop
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conduit entries.
The NRC was concerned that during an accident, the
containment spray flow could cause failures in instrument and control
circuits on terminal blocks due to leakage current between terminals
in these boxes.
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The licensee conducted a reinspection of applicable top conduit entry
boxes and during this review stated that all instrument circuits
susceptible to leakage currents which are required to operate during
and after an accident, have beeti removed from terminal blocks.
The
licensee reported that these circuits have been subsequently spliced
with qualified materials so as to mitigate NRC concerns relative to
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10 CFR 50.49 designated instrumentation circuits.
To avoid further
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noncompliance in the future, the licensee in Attachment 2 of their
September 20, 1985, response, and during this review, committed to
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installing splices on all 10 CFR 50.49 designated instrumentation
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circuits susceptible to leakage currents.
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The licensee also conducted a documented review on the effect of
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cumulative leakage currents on the operation of control circuits which
are required to function in an accident environment. The affected
control equipment components _were identified to be solenoids which
control the air operated containment isolation valves and PORVs.
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These valves return to the required position automatically during a
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" loss of power" to isolation valves, therefore concerns relative to
significance of leakage currents are mitigated.
In Attachment 2 of
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their September 20, 1985 submittal, and during this review, the
licensee stated that operation of the PORVs was not required until
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after the period of the chemical spray, at which time leakage current
fell to an insignificant level. The licensee also stated that in the
event that any fuses failed due to leakage current during the period
of containment spray, adequate controls and procedures existed to
replace these fuses, which are located in easily accessible mild
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environment locations.
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In order to avoid a future noncompliance relative to the above
failures of control circuits, the licensee stated that they continue
to be committed to installing instrument, control, and power EQ
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circuits in separate terminal blocks / splices, conduits or penetrations.
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The licensee also continues to be committed to install control devices
that fail to the accident position following a loss of power.
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d.
(Closed) Violation (304/85-06-06): This violation addressed the
installation of plastic shipping caps on Limitorque valve operator
gear case grease relief valves in Zion Unit 2.
This configuration
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was not qualified in the equipment's qualification documents.
The
licensee took immediate corrective action and had the shipping caps
removed from all affected valves in both Zion units by January 18,
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1985.
In order to avoid such a noncompliance in the future, the licensee
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states in their Procedure E022-1 Inspection and Maintenance of
Limitorque EQ Motor Operated Valves, September 6, 1985, Section 1
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that,"Checkthatgearhousinggreasereliefispresentandunobstructed
for inside containment units.
The licensee has recently compiled
additional qualification information.which indicates that the presence
of a shipping cap in the above application would not affect the
operation of Limitor%ue valves during an accident.
e.
(Closed) Unresolved Item (304/85-06-09): .This item addressed NRC
concerns regarding the lack of a specific in-containment Main Steam
Line Break (MSLB) profile, !.o be used for qualification reviews of
10 CFR 50.49 designated replacement equipment.
In their December 27,
1985, response the licensee committed to identifying the in-containment
equipment currently in Zion's EQ program; evaluating the temperature
profile for a Zion MSLB; performing an analysis subjecting
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in-containment replacement equipment to this MSLB profile; and
comparing the resulting calculated temperature profile to the existing
Zion two hour profile of 271*F. The NRC accepted this approach to
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resolving this issue.
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During this review the licensee presented a July 8, 1986, report of
the results of an evaluation by Nuclear Fuel Services (NFS) confirming
the severity of temperature peaks in the Zion containments during a
MSLB.
The analysis applied computer code CONTEMPT LT-2G; utilized the
methodology of WCAP-8822 for mass and energy release data calculations;
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applied EQ requirements of NUREG 0588 with a heat transfer coefficient
four times larger than the UCHIDA correlation as suggested in
NUREG 0588; and matched the conservative assumptions in the Zion
FSAR.
The objective of this analysis was to calculate the maximum
surface temperature of a one square foot 0.25" thick piece of carbon
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steel, subjected to a Zion MSLB in the containment for a conservative
106 seconds.
This analysis represented.the maximum temperature that
could be experienced by any in-containment EQ related equipment at
Zion during a full double ended steamline rupture downstream of the
steamline flow restrictor at 102% reactor power.
Based on the
resulting evaluated transient, the licensee determined that the
surface temperature of the carbon steel component reaches a peak
temperature of approximately 290*F in 106 seconds, after which it is
cooled by containment spray. -Thus the total time the component is
above the existing Zion high temperature profile is only 35 seconds.
The licensee stated that under actual conditions the component would
not exceed 271*F.
Based on a review of the assumptions and conservatisms of the above
analysis and the existing qualification of in-containment equipment,
the NRC concluded that the existing Zion severe accident environmental
profile was acceptable.
The licensee will include this analysis in
their EQ files for reference during procurement of replacement
equipment.
2.
Review of Raychem Splices
On June 26, 1986, the NRC issued IE Information Notice No. 86-53, " Improper
Installation of Heat Shrinkable Tubing," in response to generic concerns
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regarding the installation of Raychem heat shrink tubing. On May 23, 1986,
the licensee informed the Zion NRC senior resident inspector that the.
following three major problems had been identified with in-line splices
having Raychem tubing in 10 CFR 50.49 designated applications in Units 1
and 2:
Improper lengths relative ~ to qualified configurations.
Fiberglass braid material not stripped back, and found under the
splice.
-Improper bending of tubing.
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The licensee stated that based on their onsite review, OSR/031/86
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Revision 1, dated May 23,'1986, of the operational assessment of Raychem
splices at the Zion Station, the above discrepancies were being reviewed
for reportability under 10 CFR Part 21, 50.72 or 50.73.
During this
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inspection the inspector reviewed the above document to determine
operability of affected EQ equipment, assessed corrective action, witnessed
installation of new splices in the field, and assessed the impact of the
unqualified EQ splices on the continued operation of the plant. .The
following conclusions were drawn:
a.
Onsite Review OSR/031/86 Revision 1
The licensee examined various Raychem splices in Zion Unit 2.
The
above document assessed the operability of 12 types of EQ components
that could potentially have defective splices.
Justifications for
operability of-these splices included splices contained in gasketed
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conduit fittings and conduit enclosures, the effect of the lack of
control functions of certain affected circuits, the effect of the lack
of problems with some Unit 1 circuits due to identical conforming
installations in the Unit 2 containment, the effect of valves which
fail in the safe position, and the actuation of circuits in relatively
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non harsh environments.
The NRC inspector informed the licensee that
additional information and reviews were needed to confirm the
licensee's evaluation; however, the inspector had no immediate
concerns regarding the operability of equipment associated with
these circuits.
An ongoing review is being performed by the NRC relative to the
operability of the equipment associated with these EQ splices.
During this review the inspector determined that adequate Raychem
instructions were available for proper installation of these splices;
apparently these instructions were not followed.
The licensee was
informed that in accordance with the guidance in Generic Letter 85-15,
enforcement action will be considered, in that the licensee should
have known these splices were unqualified prior to the November 30,
1985, EQ deadline.
Pending further review this is an unresolved
item (295/86016-01(DRS); 304/86015-01(DRS)).
b.
Corrective Action
During this review the licensee committed to replacing or qualifying
through testing and analysis all unqualified Raychem splices in
Zion Units 1 and 2.
After examining the licensee's onsite review
discussed in Paragraph 2.a, the inspector identified certain splices
which were not adequately justified, and that could compromise the
immediate safety of the plant.
The licensee followed up by replacing
40 splices, including those affecting the Main Steam Isolation Valves
and Auxiliary Feed Water System to avoid compromising the integrity
of these systems in Unit 2 prior to start up, and committed to
continue to work on accessible Unit 2 splices after startup.
Corrective action on those splices for which there is no immediate
safety concern, and which are not accessible during Unit 2 operation,
shall be completed during the Unit 2 refueling outage in February 1987.
All corrective action for Unit 1 shall be completed during its
upcoming five month refueling outage starting September 4, 1986.
The licensee confirmed the above commitments during the exit meeting.
Pending review of their corrective action, this is an open item
(295/86016-02(DRS); 304/86015-02(DRS)).
c.
QC Reviews
During this review the NRC inspector observed that new Raychem splices
were being installed in the field without adequate site quality
control (QC) inspections.
The splices reviewed by the NRC inspector
in the field required several Raychem components to be installed on
the splice in accordance with specific Raychem instructions.
The NRC
inspector was concerned that a lack of QC hold points and appropriate
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records could lead to unqualified configurations, such as those being
currently replaced.
Based on discussions held with the site QC, QA,
and technical staff management, the licensee committed to establishing
a checklist and hold points .for QC reviews cn all splices having stub
connections, and committed to documenting QC inspections on all
Licensee actions shall be reviewed relative
to independent QC reviews for compliance to 10 CFR 50 Appendix B
during a future inspection.
Pending the above review.this is an
openitem(295/86016-03(DRS);304/86015-03(DRS)).
3.
Open Items
Open items are matters which have been discussed with the licensee, which
will be reviewed further by the inspector, and which involves some action
on the part of the NRC or licensee or both.
Open items disclosed during
this inspection are discussed in Paragraphs 2.b and 2.c.
4.
Unresolved Items
An unresolved item is a matter about which rr. ore information is required
in order to ascertain whether it is an acceptable item, an open item, a
deviation, or a violation.
An unresolved item disclosed during this
inspection is discussed in Paragraph 2.a.
5.
Exit Interview
The Region III inspector met with licensee representatives (denoted under
Paragraph 1) at the conclusion of the inspection on July 29, 1986.
The
inspector summarized the purpose and findings of the inspection.
The
licensee acknowledged this information.
The inspector also discussed
the likely informational content of the inspection report with regard
to documents or processes reviewed by the inspector during the inspection.
The licensee did not identify any such documents / processes as proprietary.
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