ML20210S435
| ML20210S435 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/06/1987 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20210S388 | List: |
| References | |
| 50-295-86-32, 50-304-86-32, NUDOCS 8702170634 | |
| Download: ML20210S435 (7) | |
See also: IR 05000295/1986032
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports-No. 50-295/86032(DRP); 50-304/86032(DRP)
Docket Nos. 50-295; 50-304
Licensee:
Comsonwealth Edison Company
P. 0. Box 767
Chicago, IL 60690
Facility Name: -Zion Nuclear Power Station, Units 1 and 2
Inspection At:
Zion, Illinois
Inspection Conducted:
December 10, 1986 through January 16, 1987
Inspectors:
.M'. M. Holzmer
P. L. Eng
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Approved By:
B. L.
urgess, Chief
.2 /6/6
ReactorProjectsSection2A
Date
. Inspection Summary
Inspection on December 10, 1986 throuch January 16, 1987 (Inspection Reports
No. 50-295/86032(DRP); No. 50-304/66022(DRP))
Areas Inspected:
Special, unannounced resident inspection of licensee action
follow?ng the identification of two series connected containment isolation
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valves being left open.
Results:
Two violations were identified (violation of containment
integrity requirements of Technical Specification 3.9.5 and the action
requirements of Technical Specification 3.0.3; and violation of 10 CFR 50,
Appendix B, Criterion III for failure to establish measures sufficient to
ensure that applicable design requirements (manual Demineralized Water (DW)
containment isolation valves) were included in the containment isolation valve
list in the Technical Specifications).
These violations are being considered
for escalated enforcement.
8702170634 870206
ADOCK 05000295-
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DETAILS
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1.
-Persons Contacted
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- G; Plim1,' Station Manager-
E. Fuerst, Superintendent,' Production-
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.T. Rieck, Superintendent, Services. ~
- W. Kurth, Assista'nt Station Superintendent,L0perations-
L. Pruett,-Unit 1 Operating Engineer
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-N. Valos, Unit 2 Operating Engineer-
M.;Carnahan, Training Supervisor
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Cascarano, Technical Staff-Supervisor
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- C.. Schultz, Regulatory Assurance Administrator
~V. Williams, Station Health. Physicist-
- J. Yost, Quality Control Inspector
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- J. Rappaport, Quality. Assurance Auditor
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R. Lane, Primary Group Leader,. Technical Staff
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T. Broccolo, Assistant to Assistant Station Superintendent, Operations
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The' inspectors also met with Operations Department personnel during the
inspection.
- Indicates. persons present at exit interview.
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Actions on Previously Identified Items
2.
(Closed) Unresolved Item (295/86028-04;304/86028-04) Loss of Containment
Integrity Due to Manual Containment Isolation Valves (CIVs) left open.
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This item was' unresolved pending the results of a Region III Enforcement
Board. This event is discussed.in detail in Paragraph'4 of this report.-
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This-Unresolved Item is considered closed.
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3.
Licensee Event Reports (LER) Followup
Through direct observations, discussions with licensee personnel,'and
review of records, the following event report was reviewed to determine
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that reportability requirements were fulfilled, immediate corrective
action was accomplished, and corrective action to prevent recurrence had
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been accomplished in accordance with Technical Specifications.
The LER
listed below is considered closed:
UNIT 2-
LER N0.
DESCRIPTION
f
86020
Violation of Containment Integrity, Manual
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Containment Isolation Valvas Open
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This LER was reviewed as part of the inspection into a Unit 2 containment
. integrity violation which is discussed in detail in Paragraph 4 of this
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4.
Violation of Containment Integrity Due To Containment Isolation Valves
(CIVs) Left Open
a.
Event Chronology
-On January 20, 1986, Unit 2 left cold shutdown.
The DW. system had
been used in containment for routine outage activities such as
decontamination following refueling. Two series manual containment
isolation valves (CIV), 20W0030 and 20W0038, were opened to permit
the use of DW in the containment during the outage.
It is believed
that the valves were left open following the outage.
On November 30,
1986, Unit 2 was operating at 99.5% power with no abnormal
conditions. An audit of chained, locked valves in response to IE
Information Notice 86-55 was being conducted.
During the audit,
the Unit 2 DW CIVs (20W0030 and 20W0038) were discovered to be
open by the shift foreman.
The valves were immediately closed upon
discovery.
Afterwards,theshiftforeman(SF)discussedhis
findings with the shift engineer (SE) who understood the foreman to
say only that the valves were not locked.
On December 9, 1986, the
.same SE and SF performed a containment integrity check on Unit _1,
which was in an outage at the time.
discovered open.
At this time the SE and SF realized that open DW
valves 20W0030 and 20W0038.had violated containment integrity for
Unit 2.
This event was reported pursuant to 10 CFR 50.72.
b.
Root Cause Analysis
The following are root causes or contributors to this event:
(1) Although often used during outages for routine decontamination
and maintenance activities, 2DU0030 and 20W0038 were not
included in any System Operating Instruction (S0I) valve lineup
or in any General Opereting Procedure (G0P), thus sufficient
Administrative Controld did not exist to ensure that these
valves were closed priol to entering Mode 4.
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(2) Neitheroutofservice(0}S)tagsnornon-routinevelvelineups
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were used to control or document that these valves were not in
their normal position.
00S tags are not typically used for
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administrative control during outages, because the licensee
relies on valve line-ups when leaving Mode 5.
(3) The two DW valves were identified as CIVs in the FSAR; however,
they do not appear on the CIV list contained in the TS.
(4) These valves were not explicitly identified as CIVs in licensee
training programs associated with containment isolation and
containment inter,rity.
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(5)' Communications between the shift engineer and shift foreman
were not clear enough to permit the shift engineer to realize.
.that the valves were not only unlocked, but out of. position.
c.
Immediate Corrective Action
'(1) Valves 2DW0030 and 20W0038 were closed immediately after they
were discovered to be open on November 30, 1986.
(2) The violation of containment integrity was reported immediately
after realization that the DW valves were containment isolation
valves nine days after valves were discovered open on December 9,
1986.
(3) All demineralized water valves inside the Unit 2 containment,
outside of the missile barrier have been verified to be closed.
(4) The. isolation valve seal water (IVSW) S0I valve lineup has been
revised to include DW0030 and DW0038 for both units.
(5) All. manual containment isolation valves required to be closed
by the FSAR were verified closed.
(6) Locks or caps were placed on additional manual CIVs to ensure
that all manual CIVs listed as normally closed during operation
are locked in the closed position.
(7) A memo was prepared and distributed to all Zion security badge
re-stating the station policy with respect to
holders,ine valve lineups and valve manipulation by other than
non-rout
operating personnel.
(8) S01-4 was revised to include a step requiring management
verification that accumulator fill Valve SI 8961, which is
also a manual CIV, is closed following manipulation.
This
is the only containment isolation valve manipulated as part
of the main text of an 50I.
d.
Long Term Corrective Action
(1) A revision to the TS is being prepared to u)date the list of
CIVs and bring the TS into agreement with tie FSAR.
(2) Placards will be placed on easily accessible manual containment
isolation valves identifying such valves as CIVs and requiring
notification of the Shift Engineer prior to opening.
(3) G0P-1 was revised to include a specific step requiring
verification that those manual containment isolation valves
which may not be verified by a specific S0I valve lineup are
closed prior to leaving cold shutdown.
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-(4)The station ~will review:thetuse of DW inside containment'and
revise' appropriate procedures to close 2DW0030 and 20W0038-
after they are no. longer. required to be open.
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(5) Procedures a' dressing use of DW'inside containment will'be-
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revised tojprohibit its use above cold shutdown.
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(6) AnOnsiteRaviewwillbeperformedtodocument(justification
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for permitting operations above cold shutdown with certain
manual containment isolation valves open.
(7) Revision of.the CIV list, Technical Staff Surveillances-(TSSs),
and 50I lineups to include all containment isolation test / drain
valves, requiring them to~ be locked closed if they lead to a
header or.to be closed and capped.
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(8) A review of the relevant corrective actions associated with
previous abnormal valve lineup events, the containment
differential pressure equalizing valve, IRV-85,'and the service
water. supply to the IB auxiliary feedwater (AFW) pump event,
will be made to ensure that all corrective actions have been
implemented.
(9) The shift foreman and shift engineer involved in this event
will undergo refresher training on containment integrity,
containment isolation, and the isolation valve seal water
.(IVSW) and penetration pressurization (PP) systems.
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(10)-Training will be conducted on the current procedure governing-
'non-routine ~ valve lineups.
(11) A review of training materials and lesson plans associated with
containment integrity, the containment isolation function, the
IVSW system and the PP system will be conducted for both
licensed and non-licensed operator training programs.
A
discussion of the DW valve event and of the indications which
should have alerted personnel that the subject valves were
containment isolation valves will be added to the appropriate
-lesson plans.
e.
Safety Significance
ThIZioncontainmentisalarge, dry,atmospherictype
containment with a free air volume of 2.715 E+6 cubic feet.
FSAR Section 14.3.5, " Environmental Consequences of a loss of
Coolant Accident", addresses offsite dose rate calculations using
the assumption that containment integrity is maintained and the
associated leak rate is .1 wt % per day for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
after the accident.
Technical Specifications r'. ate that containment
integrity exists when (among other requirements):
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All penetrations required to be closed during accident
conditions are either:
a.
Capable of being closed by an OPERABLE automatic
containment isolation valve system,'or
b.
Closed by manual valves, blind flanges, or deactivated
automatic valves secured in their closed position.
The Demineralized Water system is a non-safety related, non-seismic
system with the exception of the portion of piping at the
containment penetration up to and including the subject containment
isolation valves.
If a design basis earthquake had occurred while
these valves were open, the integrity of the non-seismic portion
of the DW. system could have been breached with an open path for
radioactive release becoming available to the auxiliary building
or turbine building.
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An analysis of the resultant containment leak rate was performed
for the NRC by EG&G, Idaho, which assumed pipe shear just inside
the DW containment penetration, both-DW CIVs open, and pipe shear
just after the second DW CIV. The calculated containment leak rate
was approximately 200 times greater than the limit specified in TS
and used in the accident analyses, (i.e., less than or equal to
0.10% by weight of the containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at _47 psig).
0.10 weight % per day corresponds to-a flow rate of approximately
475 SCFH and the calculated leak rate was 100,000 SCFH.
Probabilistic Risk Analysis (PRA) calculations performed by an NRC
contractor (EG&G) indicate that the probability of an a,ccident
related fatality due to an offsite release associated with a very
strong seismic event, subsequent loss of AC power and a resultant
reactor coolant pump seal LOCA increases threefold from 1E-8 per
year to 3E-8 per year.
The licensee performed an analysis which indicates that for a design
basis LOCA, with missile shear of the inside DW pipe, and coincident
loss of offsite power, the increase in site boundary dose is
negligible. Their analysis assumes N system leakage inside turbine
building of approximately 1 gpm, and gap iodine release source term.
f.
Enforcement
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TS 3.9.5 requires that containment integrity shall not be
violated when a nuclear core is installed in the reactor unless
the reactor is at cold shutdown and the shutdown margin is greater
than.1% delta k/k. The definition of containment integrity requires
the closure of all containment penetrations, required to be closed
during accident conditions, by either operable automatic valves, or
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by closed manual valves, blank flanges, or closed, deactivated
automatic valves. TS 3.0.3 requires that if a limiting condition
for operation cannot be met, actions shall be taken within one hour
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to place the ~ reactor lin. hot 1 shutdown within the following four:
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-hours. ' Reactor operations'of Zion Unit 2 above cold shutdown 1from?
January 20,iolatedduetotheopenClVs20W0030:and2DW0038is
1986 through' November 30 .1986,~ with Unit 2 containment-
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integrity v
considered ~a violation and is under consideration for escalated -
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enforcement (304/86032-01).
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10CFR50;AppendixB,CriterionIII,bleregulatoryrequirgsents'and
requires'that measures-shall-
beLestablished to assure that applica
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- the design bases for systems to which Appendix B applies are; correctly
translated into specifications and procedures.
The licensee" failed
- to establish measures sufficient to ensure that Valves.20W0030 ande
20W0038,'~which were identified in'both the FSAR and the design
drawings as containmentLisolation valves,-were correctly incorporated: Yw%*
intoithe containment isolation valve list in' Table'4.9-3 of-the'
facility Technical Specifications.
In addition, these valves were
not included in any operating procedures which would have ensured
that these valves were closed prior.to leaving cold shutdown.
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Failure to comply with this quality assurance requirement-is
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considered a violation.
This is considered a violation and:is under
review for escalated enforcement.(295/86032-01; 304/86032-02).
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Two violations?and no deviations were identified.
These violations
are considered Unresolved Items pending NRC review for escalated
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enforcement.
15.
Exit Interview-
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The inspectors met with licensee representatives (denoted in' Paragraph 1)
throughout the inspection period and at the' conclusion of the inspection
on. December-29, 1986, as documented in Inspection Reports No. 295/86028
-and No. 304/86028 to summarize the scope and findings of the inspection
- activities. The status of proposed enforcement actions were discussed-~
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throughout the month of January,1987, with Mr. G. Plim1.
The. ins
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also discussed the likely. informational content of the inspection pectors
report
with regard to documents or processes reviewed by the inspector during
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the-inspection.
The licensee did not identify any such documents or
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processes as proprietary.
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