ML20205A403

Safety Insp Repts 50-295/86-16 & 50-304/86-15 on 860709-10 & 29.No Violations or Deviations Noted.Major Areas Inspected: Environ Qualification Concerns Re Raychem Splices & Licensee Action on Previous Insp Findings

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: ML20205A370 ML20205A403
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

Inspector: A. S. Gautam i Bh/M

Date

d%C

Approved By: J. W. Muffett, Chief D 86

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

1. 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

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J. J. Reddy, Site Engineer

c. Nuclear Fuel Services (NFS)

K. Avng, Consultant

R. Tsai, Consultant

• Denotes those present during the interim site exit meeting on

July 10, 1986.

1. 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

Regulatory Guide 1.79. 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-

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exclude the above items in question from their EQ list and does not

require these items for shutdown following a Design Basis Accident.

b. (Closed) Open Item (304/85-06-02): This item addressed the lack of

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instructions'in licensee EQ procedures for the upgrading of replacement

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

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in these boxes.

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

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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

noncompliance in the future, the licensee in Attachment 2 of their

i September 20, 1985, response, and during this review, committed to

installing splices on all 10 CFR 50.49 designated instrumentation

! circuits susceptible to leakage currents.

L The licensee also conducted a documented review on the effect of

i 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

L control the air operated containment isolation valves and PORVs.

. These valves return to the required position automatically during a

i " loss of power" to isolation valves, therefore concerns relative to

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significance of leakage currents are mitigated. In Attachment 2 of

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 -

! 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 l

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circuits in separate terminal blocks / splices, conduits or penetrations. ,

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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i 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

j 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,

1985.

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In order to avoid such a noncompliance in the future, the licensee l

states in their Procedure E022-1 Inspection and Maintenance of

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Limitorque EQ Motor Operated Valves, September 6, 1985, Section 1 f

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

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profile for a Zion MSLB; performing an analysis subjecting

in-containment replacement equipment to this MSLB profile; and

comparing the resulting calculated temperature profile to the existing

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Zion two hour profile of 271*F. The NRC accepted this approach to

resolving this issue. r

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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; ,

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.

4 The licensee stated that based on their onsite review, OSR/031/86

Revision 1, dated May 23,'1986, of the operational assessment of Raychem

splices at the Zion Station, the above discrepancies were being reviewed

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for reportability under 10 CFR Part 21, 50.72 or 50.73. During this

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 off circuits in relatively

l 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

Class IE and EQ splices. 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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