ML20210B365
| ML20210B365 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/21/1987 |
| From: | Turbak M COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 2536K, NUDOCS 8702090139 | |
| Download: ML20210B365 (9) | |
Text
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X Commonwealth Edison
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/ Address Reply t Post Office Box 767 O
One Fird National Plaza. Chicago, Illinois sV Chicago, Ilhnois 60690 0767 January 21, 1987 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Zion Nuclear Power Station Units 1 and 2 Response to I&E Inspection Reports Nos. 50-295/86-22 and 50-304/86-20 NRC Docket Nos. 50-295 and 50-304
Reference:
December 22, 1986 letter from C. E. Norelius to Cordell Reed.
Dear Mr. Keppler:
This letter concerns the routine safety inspection conducted by M. M.
Holzmer, L.E. Kanter, P.R. Wohld and P.L. Eng of your office on September 26 through November 17, 1986, of activities at Zion Nuclear Power Station. The referenced letter indicatod that certain of our activities appeared to be in violation of NRC requirements. Commonwealth Edison Company's responses to these violations are contained in Attachments 1 and 2 to this letter.
In addition, the referenced letter expressed concern regarding the level of operator awareness of the plant's status and the adverse effects of blown annunciator fuses. Commonwealth Edison Company concurs with these observations and initiated actions in late 1986 to rectify these conditions.
These actions are described in Attachment 3.
If there are any questions concerning this matter, please contact this office.
Very truly yours, N. S. d M. S. Turbak Operating Plant Licensing Director im Attachments cc: Region III Inspector - Zion J. A. Norris - NRR 8702090139 870121 2536K PDR ADOCK 05000295 G
PDR JAN 2 8 TJ87
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ATTACHMENT 1 ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION VIOLATION:
As a result of the inspection conducted on September 26 through November 17, 1986, and in accordance with 10CFR Part 2. Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1985), the following violation was identified:
Technical Specification Limiting condition for Operation 3.8.1.E.2 requires that the boric acid solution shall be in continuous recirculation through the boron injection tank (BIT) except during testing. Technical Specification 3.0.3. requires that action be initiated to place the unit in at least Hot Shutdown within the following four hours if a Limiting Condition for Operation and/or associated Action requirements cannot be satisfied.
t contrary to the above, on July 23, 1986, for a period of about five hours, the boric acid solution was not in continuous recirculation through the Unit 1 BIT due to an improper valve alignment, and no action was initiated to place the unit in at least Hot Shutdown within the following four hours.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
The immediate corrective actions taken as soon as the flow condition was discovered was to verify the boric acid system lineup which identified the improper valve alignment. The lineup was immediately restored to establish a flowpath for the recirculation of the Unit 1 BIT.
In addition, the licensed individuals involved in the incident have reviewed the occurrence and fully understand the significance of reviewing existing system lineups prior to performing any additional Out-of-Service lineups.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION:
Commonwealth Edison Company has initiated a number of corrective actions in response to this event. These actions are described below:
1.
Procedure changes to the System Operating Instructions and the Out-of-Service Procedure (ZAP 14-51-2) have been submitted to ensure that Independent Verification of Boric Acid System Lineups will be performed in the field.
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- 2.
The Shif t Relief and Turnover procedure (ZAP 10-52-3) is being revised to more closely conform to INPO guidelines.
This upgrade of the shif t turnover process will enhance operator awareness of overall plant status. The revised procedure will help ensure a more formal and thorough exchange of information.
3.
The Out-of-Service card sheets will be arranged by system and unit to facilitate a review of the existing plant status.
4.
The PT-14 procedure (Inoperable Equipment Surveillance Tests) will be revised to allow a convenient method of review by unit number of the list of inoperable Technical Specification equipment.
5.
The system status boards associated with the boric acid and spent fuel systems that are already in place, will be proceduralized to administratively state the requirement to maintain the status boards up-to-date when changing these system lineups.
Actions 1 and 5 are directed at this specific event. However, Actions 2, 3 and 4 are intended to upgrade the operator's awareness of the plant's status. Thus, there is substantial overlap between the corrective actions described above and the programs outlined in Attachment 3.
DATE WHEN FULL COMPLIANCE WILL BE MET Actions 1, 2, 4 and 5 will be complete by April 30, 1987. Action 3 will be complete by June 30, 1987.
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r ATTACHNENT 2 ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION VIOLATION:
As a result of the inspection conducted on September 26 through November 17, 1986, and in accordance with 10CFR Part 2. Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1985), the following violation was identified:
10 CFR Part 50, Appendix B, Criterion III requires that measures shall be established to assure that applicable regulatory requirements and the design basis for systems to which Appendix B applies are correctly translated into specification and procedures.
Contrary to the above, between November 1979 and February 24, 1986, the licensee failed to establish measures to assure that the correct basis for the setpoints of the negative flux rate reactor trip were translated into the Zion Technical Specifications (TS) and into calibration Procedures No. N41E, No. N42E, No. N43E and No. N44E, " Power Range Nuclear Electronics" in that the TS and calibration procedures called for negative flux rate trip setpoints of
-15 percent power change with a five second time constant instead of -5 percent power change with a two second time constant as was used in the Westinghouse design basis.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
The discrepancy in the NFRT setpoints was originally discovered on February 21, 1986 as a result of an ongoing CECO / Westinghouse review of Zion's setpoints. The immediate action was to re-establish the restrictions on automatic rod control that had been in effect from November 21, 1979 to January 7, 1985. This action was consistent with Commonwealth Edison Company's erroneous understanding of the basis for the NFRT setpoints.
On February 24, 1986, Commonwealth Edison Company concluded that the then existing NFRT setpoint of 15%/5 see was improper. The immediate action l
taken was to request an emergency Technical Specification change and to modify the NFRT setpoint1 to the proper value of 5%/2 sec.
This emergency request was approved by telecon at 4:30 p.m. on February 24, 1986.
The NFRT setpoints were modified that came evening.
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J A number of actions have been taken in the intervening time period since February of 1986. These ongoing programs, which are more approximately discussed below under " Corrective Actions to be Taken", include; 1.
Completion of the overall Zion Station Setpoint review that was responsible for the discovery of the NFRT discrepancy.
2.
Development of enhanced methodologies for facilitating the review of design basis information.
3.
participation in the Westinghouse Owner's Group (WOG) effort to justify the elimination of the NFRT.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION:
The three corrective actions mentioned above have been initiated since the occurrence of this event.
Substantial progress has been made in each of these three areas. However, final resolution for each program has not occurred. The history and status of each of the three programs is provided below.
program #1 The identification of the error in the negative flux rate trip setpoint resulted from questions raised during the technical review of the Westinghouse Setpoint Study.
Investigation of issues other than the NFRT has progressed to find no other conflict with the Technical Specifications. A Zion Station On-Site Review of the Westinghouse Sotpoir.t Study is currently underway with completion of the review planned by June 30, 1987.
program #2 A safety review is performed prior to any plant modification or setpoint change. As part of the safety review process, the engineer evaluates whether changes to procedures, setpoints, or system componento could impact the design basis of the plant and, therefore, affect any FSAR Chapter 14 analyses. Similarly, any proposed change to the design basis (safety analysis) is also reviewed for its offect on the existing plant.
Zion Station, in conjunction with General Office design and support departments, decided that additional resources should be made available to engineers for purposes of performing a safety review. This decision did not result from any direct deficiency in the current safety review process.
However, through the use of reformatted information from the FSAR Chapter 14 analyses and/or through new automated resources available on computer, some enhancements can be made to the safety review.
Some of the actions taken in pursuit of this objective are briefly described below.
- A meeting was held on April 30, 1986 with representativos from the Station Nuclear Engineering Department (SNED), Nuclear Fuel Services (NFS).
Nuclear Safety (NS), Nuclear Licensing (NLA), and Zion Station to discuss what type of enhancements could be made to the safety review process.
It was decided that it would be helpful to put the pertinent FSAR information into a consolidated format designed specifically for the purpose of being used in a safety review.
SNED and NFS assumed the responsibility to develop an FSAR interface document that would provido a checklist of components and setpoints which are used in the plant safety analysis.
As SNED and NFS began to accumulate the needed FSAR information, it became apparent that the resources nooded woro not available within Commonwealth Edison to complete the task in a timely manner.
In Octoboe, 1986, SNED identified a computer-based product available from Westinghouse that could assist in performing safety evaluations. A demonstration was held in November, 1986, which confirmed that this product could meet the program objectivos.
Commonwealth Edison intends to purchase this Westinghouse product by March 31, 1987. Westinghouse requires a set-up period of approximately six months which will be followed by one month of Edison acceptance testing.
PROGRAM #3 Commonwealth Edison is also involved in another long-term activity as a member of the Wostinghouso Owners' Group that should precludo this specific NFRT sotpoint violation from recurring. The Owners' Group to sponsoring the Dropped Rod Protection Modifications Program with a primary objectivo of providing a conslatont basic and defenso for the elimination of the NFRT for plants such no Zion that rely on the NFRT for dropped rod protection. A high confidence for success exists for this program. This confidence is based on a koonor understanding and analysis which illustrato that the inherit defenson in the Westinghouse NSSS are adequato for reactor protection from the dropped rod event. The program to divided into three phases:
Phase 1 -
Demonstrate feasibility of climination of the NFRT.
Phase 2 -
Expand the analyses and submit WCAP to the NRC for approval and licensing cupport.
Phano 3 -
Utilition preparo plant-opecific submittals for NFRT elimination after NRC generic approval.
The Owners' Group program to currently near the completion of Phaco 2.
The submittal of the WCAP planned for March, 1987.
Assuming:
a standard NRC review period for the WCAP, an additional four montho to prepare the Zion-specific submittal, and timo for NRC review of the Zion submittall the elimination of the NFRT could be completed by the end of 1988.
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Although Edison is engaged in the Owners' Group NFRT riimination activities, these efforts should not be construed to be actions required to correct a deficiency. Rather these efforts are made to remove unnecessary conservatisms which, if performed previously, would have resulted in avoidance of the current violation.
DATE WHEN FULL COMPLTANCE WILL BE MET:
As discussed above; 1.
The setpoint study review will be complete by June 30, 1987.
2.
The computer-based safety review aid will be available for use by October 31, 1987.
3.
The NFRT is expected to be eliminated by December 31, 1988.
ATTACHMENT 3 Commonwealth Edison Company was aware of' chose deficiencies prior to this event and had begun to develop corrective actions. However, the events of July 23, 1986 have accelerated our efforts.
A short discussion of Zion Station's current programs for increasing operator awareness of the plant's status and for addressing blown annunciator fuses is provided below; Operator Awareness Zion Station already has administrative systems in place that keep operators aware of plant status.
Among these systems are the following:
Jumper / Lifted Lead / Block /Bypaso log Out-of-Service log (00S log)
Caution Card log pT-14's (Inoperable Equipment Surveillance Testo)
Shif t Relief and Turnover procedure Shift logs However, the loss of BIT recirculation flow han illuminated the need to further enhance these existing systems.
The corrective actions outlined in addressed both the specificu of the violation and the more general problem of operator awareness. Thus, those actions directed solely at increasing the operator's overall awareness of plant status are revisited here.
1)
The Zion administrative procedure for 00S jobs (zap 14-51-2; Inspection, Test, and Operating Status Tagging of Equipment) will be changed to require a Shift Supervisor signoff that current OOS jobs have been reviewed to ensure that their offect is considered prior to issuing new OOS jobs. To facilitate this review, the Out-of-Service Card Sheets will be arranged by system and unit. This will allow a convenient method of reviewing existing 003 jobo and to evaluate their offect in relation to additional OOS jobs.
As an added benefit, this new method of arranging 003 Card Shoots will allow a convenient method of reviewing system 00S status, which will be particularly valuable during unit outages as a tool to track nyctem status and work that in outstanding. These changco will be in place by the end of the Spring / Summer 1987 Unit 2 refueling outage.
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2)
The PT-14 procedure (Inoperable Equipment Surveillance Tests) will be revised to allow a convenient method of review by unit number of the list of inoperable Technical Specification equipment. This procedure will be revised by April 30, 1987.
3)
The Shif t Relief and Turnover procedure (ZAP 10-52-3) is being revised to more closely conform to INPO guidelines. This.
upgrade of the shif t turnover process will enhance operator awareness of overall plant status. The revised procedure will be in place by April 30, 1987.
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,s Annunciator Blown Fuses This problem has been under investigation for some period at Zion Station. While progress in specifying the problem has been made, the final resolution has not been determined. The events of July 23, 1986 has resulted in increasing the priority of this effort. The specific actions that reflect this priority increase are discussed below:
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1)
This problem has been added to Zion's Recurring Station Problem (RSP) list. The RSP program provides a mechanism to address the r
station's most outstanding problems on a priority basis and to ensure that these problems receive regular and visible management attention.
2)
A Standing Order has been issued that requires annunciator lamp testing on a daily basis.
3)
A Standing Order has been issued that requires ground checking each week if the grounds on a DC bus exceed a nominal value.l This action reduces the threshold for requiring ground checking and thus provides a mechanism to maintain the DC bus grounds at
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4 a lower value than previously. Grounds on annunciator circuits is the major reason that annunciator lamp checks have at times resulted in blown fuses. This Standing order will help to regularly maintain grounds on a DC bus at a lower value and thus reduce the possibility of blowing fuses during annunciator lamp testing.
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