ML20236J421
| ML20236J421 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 10/16/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3713K, NUDOCS 8711060105 | |
| Download: ML20236J421 (4) | |
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[ I Q#J kj l Address Reply to: Post Offico Box 76TI J
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y' Mr.:A..BertLDavis'-
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-Regional Administrator'
'Dl U.S? Nuclear; Regulatory Commission
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4 oRegion.III?
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Subject:
1 Zion: Nuclear Power Station Units 1 and 2 Response ~to. Inspection.Repo: 1 Mos.
50-295/87-17 and-50-304/87-19 NRC Docket No. 50-295 and 50-304' D
Reference:
LSeptember 17,.1987-letter from W.L. Forney
- to Cordell Reed
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Dear Mr. Davis:
. i This letter is in response to the: inspection conducted by i
iM.M. Holzmer, N. Williamsen,~and P.L. Eng'of your office'on-July 31 through September,3,-1987, of activities at Zion Nuclear Power Station. The.
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referenced-letter indicated that certain activities appeared to'be in noncompliance with NRC' requirements. Commonwealth Edison Company's response to this violation.is:provided ir. the Attachment to this letter.
As ditrcussed in the Attachment, this violation'is directly related to a previously identified issue at.% ion Station..LA meeting'was held on June 16,! 1987, at Zion Station with the Senior. Resident Inspector and Commonwealth Edison personnel. This meeting resulted in the identification.
of the'need for' additional. discussions between Commonwealth Edison. Company, NRC ~ Region III, Land NRC - NRR. Commonwealth' Edison' Company agreed to
' coordinate the required. meetings.
Thus, commonwealth Edison Company is requesting that a meeting be
-held.to discuss the proposed ' resolution. We will contact NRC '- Region III personnel to arrange'this meeting.
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If you have any further questions on this matter, please direct
-I them to this office.
1 Very truly yours, j
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L. D. butterfield
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Nuclear Licensing Manager
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Attachment G
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NRC. Resident Inspector - Zion
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J. A.'Norris - NRR
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I 3713K 8711060105 871016 PDR ADOCK 0500 5
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%My RESPONSR TO NOTICR OF VIOLATION
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,h1 iTBMOhfNONCOMPUTANCR' h' t u yh Iks~aresul'tofthe}inspectionconductedonJuly31'through 4
L September 3,11987, sand in accordance with 10 CPR part 2, Appendix C m q [' '
' General Statement of. Policy'and procedure forcNRC Enforcement Actions i'r'
' (1985), the following violation 'was~ identified:
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. Technical Specification.4.8.3 requires that when the reactor is in
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~ Modes'l or 2 (power operation;or' hot standby, respectively) and onefof the itwo residual heat removal pump systems is~ inoperable,-then the remaining 4
- i residual heatxremovalisystem, both centrifugalicharging pump system, and' y
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both safety injection pump systems,, including the standby AC-and DC power
< supplies, shall-be. demonstrated to be operable'immediately and daily 4
Lthereafter.
Contrary to the above, on August 20, 1987, while Unit I was in Mode
~1, one of the two residual heat removal pump systems became inoperable, in j
1 lthat duringisafeguards; testing valve 1 MOV-RH 8700B. failed to stroke open on
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.a safety' injection signa as: designed, but the remaining residual heat removal system, both centrifugal charging pump systems, and both safety u
injection pump systems, including the standby AC and DC power supplies, were I
-not demonstrated to be operable'until August 26, 1987.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEEEg
]1 Zion Station has carefully. reviewed the events surrounding the above Notice of Violation.. Valve 1 MOV-RH8700B,.the Residual Heat Removal
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.(RHR) Train B suction isolation valve, is required to be.open to allow the i
RHR system to take suction from the Refueling Water Storage Tank (RWST) in
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response to a postulated'LOCA.
In' addition, MOV-RH8700B is required to be open during cooldown operations to allow the RHR system to remove decay heat.
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1 IMOV-RH8700B is only closed when:
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'e) train B is out of service for maintenance, I
b). the RHR system is aligned to take suction from the containment recirculation sump after LOCA, or I
'c) to test the confirmatory open signal during the Safeguards Actuation Performance Test.(pT-10).
I Otherwise, this valve is maintained in the open position by
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procedure. There are no automatic close functions for this valve, and if l
the valve is not fully open, a monitor status light comes on.
The light is j
l located in a panel which has no lighted indicators during normal plant
-operation.
The transmittal of the inspection report and notice of violation includes as'a reference a June 29,'1983 memorandum concerning a similar p
. occurrence at Dresden Station. However, the Dresden valve (1501-5D) was o
both an ECCS valve and a containment isolation valve. This case differs 1
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A.B. Doris ' October 16, 1987 significantly from Zion's IMOV-RH87008, which is not a containment isolation valve.
In addition, IMOV-RH8700B is maintained by procedure in the open position for all normal operat.ing conditions and is only closed by use of a control switch at the main control board.
i Thus, IMOV-RH8700B has two distinct safety functions. These are:
i a) automatically opening in response to a safety injection signal to allow EHR cold leg injection.
I b) closing in a response to a manual control switch during switchover
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operations following a LOCA.
i 1MOV-HH8700B was placed in the open position with it's operator l
. energized on August 20, 1987, intending to fully preserve both of the safety i
functions described above.
IMOV-RH8700B continued to be considered fully l
operable while in this condition.
The actions taken en August 20, 1967 described above were based on
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Zion Station's cutront understanding of the relationship between thrt
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operability of multiple actuation signals, component operability, and actuation channel operability. This issue had previously been identified as requiring clarification at Zion Station. Most recently, the forced Unit 2 shutdown on February 3, 1987, due to the loss of Train B actuation
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capability to 2D MSIV highlighted this need.
A proposed resolution was developed and presented to the Senior Resident Inspector at a June 16, 1987, meeting held at Zion Station. This meeting was also attended by representatives from Commonwealth Edison Company's corporate office.
The meeting attendees acknowledged that an additional clarification meeting with NRC - Region III, and potentially NRC - NRR, was necessary to j
smoothly implement the proposed resolution. Commonwealth Edison Company j
agreed to coordinate this effort. Unfortunately, this meeting has not yet been held.
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However, on August 25 at 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br />, this valve was taken out of service to repair a misadjusted torque switch. Due to a cognitive error by the licensed shif t supervision, the requirements of Zion Technical.
Specification section 4.8.3 were not met until approximately 1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br /> on j
August 26, 1987. This event, described in LER 87-15-00, dated 09/24/87, i
would render the valve inoperable regardless of how one views the relationship between actuation circuitry and component operability.
The appropriate tests were immediately initiated upon discovery and the valve's repair was expedited.
IMOV-RH-87008 was returned to service later on that same day.
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A.B. D vis October 16, 1987 j
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION i
A statement will be added to PT-10 to instruct the operating i
department to immediately~ review any failure of a valve to respond to a confirmatory signal. Additionally, in accordance with the corrective i
actions for.LP,R 87-15-00, the Zion Administrative Procedure (ZAP) for taking l
equipment out of service, ZAP 14-51-2, and PT-14, " Inoperable Equipment i
Surveillance Tests", will be revised to require the operator to explicitly j
consider both the immediate and subsequent operational impact resulting from j
the removal of equipment from service.
Finally, the clarification meeting discussed above will be held to resolve the larger issue of the relationship between component operability and the multiple actuation signals that are a feature of Zion's design.
DATE WHEN FULL COMPLIANCB WILL BE ACHIEVED I
The corrective actions for LER 87-15-00 will be completed by 11/09/87.. The meeting arrangements will be completed by 12/1/87.
The added I
statement for PT-10 will be 1mplemented by 12/31/87.
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