ML20215C940
| ML20215C940 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/11/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 2079K, NUDOCS 8610100534 | |
| Download: ML20215C940 (4) | |
Text
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-- -) One First National Plaza, Chic +y. Illinois
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Commonwealth Edison 7
,f Address Reply to: Post Offce Box 767 ks
Chicago, Illinois 60690 0767 September 11, 1986 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 Report Nos. 50-295/86013 and 50-304/86012 NRC Docket Nos. 50-295 and 50-304
Reference:
August 13, 1986 letter from W. G. Guldemond to Cordell Reed.
Dear Mr. Keppler:
This letter concerns the routine safety inspection conducted by M.
M. Holzmer and L. E. Kanter of your office on June 16 through July 28, 1986, of activities at Zion Nuclear Power Station. The referenced letter indicated that certain of our activities appeared to be in violation of NRC requirements. Commonwealth Edison Company's response to this violation is contained in the Attachment to this letter.
If any questions arise concerning this matter, please contact this office.
Very truly yours, yGe D. L. Farrar Director of Nuclear Licensing im Attachment cc: Region III Inspector - Zion J. A. Norris - NRR 8610100534 860911
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PDR ADOCK 05000295 G
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q ATTACHMENT ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION ITEM OF NONCOMPLIANCE As a result of the inspection conducted on June 20 through July 1, 1986, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1985), the following vioaltion was identified:
4 1.
10 CFR 50 Appendix B, Criterion V, as implemented by the Commonwealth Edison Quality Assurance Program requires that instructions, procedures, or drawings shall include appropriate quantitive or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, on June 16, 1986, the licensee identified that calibration procedures for LIS-CS44 and LIS-CS45 did not include appropriate quantitative acceptance criteria for determining that important activities were satisfactorily accomplished, in that:
- The acceptance criteria for calibration of these instruments assumed the use of a constant specific gravity of 1.3, when the actual specific gravity varied over a range of 1.3 to 1.45, and
- The acceptance criteria for calibration of these instruments neglected the two inch difference in the zero reference level between the Dubbler level indication system and the magnetrol level indication 4
system.
I This violation resulted in a violation of Technical Specification 3.6.1.E which requires the NaOH in the spray additive tank be maintained at a minimum concentration of 30% by weight and a minimum level of 85 inches, and that should the tank be out of service for a period greater than eight hours, the reactor shall be brought to the cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in that during June 1986, the NaOH in the Unit 1 and 2 spray additive tanks was at a level below 85 inches for a period greater than eight hours, and the units were not brought to the cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This is a Severity Level IV Violation (supplement I).
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r 00RRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
On June 16, 1986, during calibration of U-l Containment Spray additive tank level transmitters it was discovered that the magnetrol capacitance type tank level transmitters ILIS-CS44 and ILIS-CS45 were indicating higher than actual. The instruments, which have a calibration frequency of every refueling outage, are calibrated using a density dependent bubbler system. The bubbler system indicated a level of 83 inches, while the level transmitters were reading of over 90 inches. The Technical Specifications [TS] section 3.6.1.E require a minimum level of i
85 inches (2660 gallons). Upon discovery of low level in the U-l tank, U-2 Containment Spray additive tank was checked and found to be also below the minimum required volume of NaOH solution. Both tanks were restored to the minimum level required by TS within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, which is the allowable time for the spray additive tanks to be out of service with the reactor critical.
On June 18, 1986, it was realized that the bubbler system measurements might not have been accurate due to their dependency on density. The concentration assumed in the calibration procedures was not representa-l tive of the tank contents. An immediate notification call was made on June 18, 1986 at 16:45 hours to notify the NRC that U-1 was in a Limiting condition for Operation on June 16, 1986. Tygon tubing was attached temporarily to monitor the level in the tanks.
Although level in both tanks was found to be low, calculations show that, due to the spray additive tank concentrations being higher than the minimum TS concentration of 30%, sufficient NaOH concentration would have been supplied to the containment via the Containment Spray system to comply with the iodine removal requirements of FSAR section 14.3.5.4.
Since the bubbler system and the Tygon indication are density dependent, several density measurements were taken after both tanks were agitated to ensure uniform NaOH concentrations. This allowed more accurate level measurements to be obtained.
Other chemical tanks were also examined to verify that there was no problem in maintaining volume and concentration of the solution within the limits of the Technical Specifications. No deviations were found.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATIONS:
(1) Several revisions are being made to the calibration procedures for LIS-CS44 and LIS-CS45 to compensate for the density changes and other nonconservative assumption:: in the existing procedure. These revisions include;
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. a) The spray additive tanks will be agitated and sampled prior to calibration to ensure that the solution is homogeneous, b) A tygon tube will be also used as a reference to obtain the actual level in the tank during calibration.
c) The two inch difference between zero reference points for the bubbler and the capacitance level indication system will be compensated for during calculations if the bubbler system is used for calibration.
(2) The procedure governing the filling and sampling of the containment spray additive tanks will be changed to require mixing after filling and prior to sampling. This will prevent stratification within the tank.
(3) An investigation is in progress to find an alternate level indication system which does not rely on density for calibration.
A modification may be initiated to replace the existing capacitance level indicatirn system upon sucessful completion of the investigation. This potential modification will be tracked by the station's commitment list.
DATE WHEN PULL COMPLIANCE WILL BE ACHIEVED:
The above mentioned procedural changes will be completed by October 31, 1986.
The investigation into an alternate level indicating system will be completed by March 31, 1987.
If a modification is initiated, the work will be completed by the end of the second refueling outage after Maren 31, 1987 for each unit.
2079K m