IR 05000295/1985020

Insp Repts 50-295/85-20 & 50-304/85-21 on 850530-0701. Violation Noted:Failure to Return Valve ICC9499 to Normal Operating Status,Resulting in Spill of Approx 6,000 Gallons Component Cooling Water on Containment Floor

ML20133B718
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	07/24/1985
From:	Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133B608	List: IR 05000295/1985020 IR 05000530/2007001 ML20133B606
References
50-295-85-20, 50-298-85-20, 50-304-85-21, NUDOCS 8508060246
Download: ML20133B718 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Report Nos. 50-295/85020(DRP); 50-304/85021(DRP)

i Docket Nos. 50-295; 50-304 License Nos. DPR-39; DPR-48 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 l Inspection At: Zion, IL Inspection Conducted: May 30 through July 1, 1985 Inspectors: .M. M. Holzmer F. R. Dunaway L. E. Kanter J. N. Kish r

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.C.hrigt, Chief

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Approved By /

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eactor Projects Section 2A i Inspection Summary Inspection on May 30 through July 1, 1985 (Report Nos. 50-295/85020(DRP);

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50-304/85021(DRP))

Areas Inspected: Routine, unannounced resident inspection of licensee action on previous inspection findings; organization and administration; component cooling relief valve lif ting; plant startup from refueling; startup testing modified systems; operations verification & ESF walkdown; surveillance; maintenance; licensing activities; LERs; and region requests. The inspection

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involved a total of 420 inspector-hours onsite including 114 inspector-Lours

onsite during off-shift Results: Of the 10 areas inspected, no violations or deviations were identified

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in 9 areas, and 1 violation was identified in the remaining area (component f' cooling relief valve lifting-Paragraph 5).

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DETAILS

. Persons Contacted

• K. Graesser, Station Manager

• G. Plim1, Superintendent, Production

• T. Rieck, Superintendent, Services

• E. Fuerst, Assistant Station Superintendent, Operations

• K. Kofron, Assistant Station Superintendent, Maintenance R. Budowle, Unit 1 Operating Engineer J. Gilmore, Unit 2 Operating Engineer L.~ Pruett, Rad Waste Operating Engineer W. Kurth, Assistant Superintendent M. Carnahan, Training Supervisor R Cascarano, Technical Staff Supervisor A. Ockert, Assistant Technical Staff Supervisor

• C. Schultz, Assistant Technical Staff Supervisor R. Aker, Station Health Physicist

• J. Ballard, Quality Control Supervisor D. Kaley, Quality Control Engineer

• W. Stone, Quality Assurance Supervisor D. McMenamin, Quality Assurance Engineer

• Indicates persons present at exit interview on July 1,198 . Licensee Action On Previous Inspection Findings (Closed) Unresolved item (295/85002-06; 304/85002-06(DRS)):

Verification of auxiliary feedwater flows following surveillance testin The licensee performed PT-7 " Auxiliary Feedwater System Checks and Tests" on May 31, 1985. The procedure was modified to run the "B" pump following the setting of the feedwater throttle valves for "C" pump flow conditions. Test results verified that the "B" pump provided the flow required by the Technical Specifications to each steam generator with the valves set for "C" pump operations, as is normally the case. This item is considered to be close . Summary Of Operations Unit 1 The unit began the period in cold shutdown in a maintenance and refueling outag Initial criticality for the cycle was achieved at 8:25 a.m. on June 14, 1985, and the unit was tied to the grid at 4:47 p.m. on June 18, 1985 and operated at poser levels up to 89%.

At 4:45 a.m. on June 26, 1985, an Unusual Event was declared for Unit 1 due to an unisolable leak of approximately 3 gpm on the pressurizer vent valve,'1RC-8056. The Unit was ramped down, allowing entry into the containment, and the leak secured by placing the valve in the full closed position. The Unusual Event was terminated at 2:05 p.m. on June 26, 198 L _ , _ _ - _ _ _ _ - .

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On' June 27, 1985, the unit was ramped down and brought off-line at 8:05 p.m. for maintenance on the 1C Feedwater Regulator Valve. At 8:20 .an Urgent Failure Rod Control Alarm was received and to avoid operating with a positive moderator coefficient the unit was manually tripped at 8:35 p.m. on June 27, 198 j On June 29, 1985, at 4:41 a.m., the unit tripped while in hot stand-by

(Mode 2) with the reactor at.1% power. The cause of the trip was attributed to a steam flow / feed flow mismatch with the ID steam generator !

less than 25% level. This condition was brought about in part by maintenance activities on the IC feedwater regulating valve that were ;

going on at the time. After repairs the unit went critical at 7:25 on June 29 and was placed on-line at 00.50 a.m. on June 30. The unit operated at up to 50% power for the remainder of the inspection perio Unit 2 The unit operated at power levels up to 93% for the entire inspection period. No trips or unscheduled shutdowns occurre l Organization and Administration 4

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The inspector reviewed personnel and organizational changes to station

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organization effected since May 11, 1984, and verified that the ,

qualifications of the persons selected for each position conformed to the specific requirements of ANSI N18.1-1971 and Regulatory Guide 1.8-September 1975. On March 18, 1985, a major restructuring of station l organization was effected. The altered structure of the station organization, including lines of authority and responsibility, was examined and determined to be in compliance with the requirements of the licensee's Quality Assurance program. The current structure, however, l 1s at variance with Table 6.1.1 of Zion Technical Specifications. A proposed license amendment to correct this aberration has not yet been submitted to the Office of Nuclear Reactor Regulation (NRR) for approva This licensing issue is further addressed in paragraph 1 No violations or deviations were identifie . Component Cooling Relief Valve Lifting

! At approximately 7:40 p.m. on May 17, 1985 the OE Component Cooling pump '

was removed from service for maintenance (Unit I was in cold shutdown and l l Unit 2 waa'at 99% power). The resulting pressure transient caused the ,

relief valve (ICC9428) to the Component Cooling side of the excess letdown heat exchanger to lift. As a result of the operation of the

. relief valve, Unit 2 experienced a low Component Cooling surge tank level l alarm and decreasing surge tank level. Make-up to the surge tank was ( immediately started and soon thereafter the open relief valve was identified and isolated, thereby terminating the event.

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Approximately 6000 gallons of component cooling water leaked out of the relief valve during the incident.

. Tuice before, on February 3, 1984 and February 16, 1985, Component l Cooling System relief valves lifted and failed to re-seat, spilling l component cooling water on the containment floor. Subsequent investigation revealed the nozzle rings on the relief valves had been set incorrectly, preventing the valves from re-seating once lifte With Unit 1 in cold shutdown for refueling, and repair of the valvo ICC9428 pending, the relief valve was isolated in accordance with a change in the System Operating Instruction (SOI)-6, in which the normal positien of the manual isolation valve (1CC9499) was changed from open to close The Unit 1 outage included a ten year ISI hydrostatic test of the Component Cooling System piping which included relief valve ICC942 This test was covered in Tech Staff Surveillance Procedure (TSS)

15.6.96.23-1. The TSS changed the position of the valve from closed to open to allow testing of that part of the system. After the test was completed, however, the Restored Valve Line-Up Procedure (Appendix C of the TSS) did not contain provisions to restore valve ICC9499 to its normal position per S01- Valve ICC9499 was left open, thereby unisolating relief valve ICC9428, which led to the event on May 17, 198 CFR 50, Appendix B, Criteria V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances....."

Technical Staff Surveillance (TSS) 15.6.96.23-1, Appendix C, was inappropriate in that it did not contain instructions to return valve ICC9499 to its normal operating status (CLOSED) as specified in the System Operating Instruction (SOI)-6. This is considered a violation as noted in the Appendix (295/85020-01).

No other violations or deviations were identifie . Plant Startup From Refueling The inspector reviewed changes to the licensee's administrative controls and startup procedures, walked down the Containment Spray and RHR systems, verified that technically adequate ar.d approved procedures were used during the startup, verified that changes in plant mode were made in accordance with Technical Specifications, and witnessed selected physics test The following procedures were reviewed and observed in progress:

I Procedure Title GOP-0 Documentation Requirements and Review for Plant Startup GOP-1 Plant Heatup l

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GOP-2 Plant Startup i TSS 15.6.26 Control Rod System Checkout TSS 15.6.43-1 Endurance Testing of Diesel Generator during Refueling TSS 15.6.5 Zero Power Physics Measurements Following Refueling i_ .TSS 15.6.52 Initial Criticality after Refueling and Nuclear l' Heating Level l PT-4A Source Range Channel Functional Test PT-4B Intermediate Range Channel Functional Test PT-4C Power Range Channel Functional Test No violations or deviations were identifie : Startup Testing - Modified System l The inspector verified that testing of modified safety related systems or l- components was conducted in accordance with approved procedures which met l regulatory requirements, reviewed completed test records and evaluation of test.results, and verified that procedure changes were reviewed in accordance with regulatory requirement Testing for_the following modifications was inspected:

Modification Title M22-1-84-04 Reactor Trip Breaker Shunt Trip Modification M22-1-84-18 keplace 5-Valve Manifold RV-85 With Single Isolation Valve M22-1-84-40 Switch RCFC Dampers to one flow path The following procedures were reviewed:

I l Procedure Title TSGP - 39 Reactor Trip Breaker Manual Trip Switch Test i

TSGP - 37 RCFC Pre-Op Test i

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With regard to Modification M22-1-84-40, this modification permanently placed the Reactor Containment Fan. Cooler (RCFC) Dampers in the accident

. mode and removed the HEPA filters and moisture separators. From an installation and operability standpoint no violations were identifie Licensing issues arising from this modification are addressed in paragraph 1 L

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, e No violations or deviations were identifie . Operational Safety Verification and Engineered Safety Features System Walkdown The inspectors observed control room operations, reviewed applicable logs

_and conducted discussions with control room operators from May 30 through July 1,11985. During these discussions and. observations, the inspectors ascertained that the operators were alert, fully cognizant of plant conditions, attentive to changes in those conditions, and took prompt action when appropriate. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the auxiliary and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenanc The inspectors by observation and direct interview verified that the physical security activities were being implemented in accordance with the station security pla The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. From May 30, 1985 to July 1,1985, the inspectors walked down the accessible portions of the Auxiliary Feedwater and Component Cooling systems to verify operability. The inspectars also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barrelin These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under Technical Specifications,10 CFR and administrative procedure .

No violations or deviations were identifie . Monthly Surveillance Observation The inspector observed Technical Specifications required surveillance -

testing on the Containment Spray and Component Cooling systems and verified that testing was performed in accordance with adequate l procedures, that test instrumentation was calibrated, that limiting conditions for operation were mot, that removal and restoration of the affected components were accomplished, that test results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspector also witnessed portions of the following test activities:

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PT-4A Source Range Channel Functional Test PT-4B Intermediate Range Channel Functional Test PT-4C Power Range Channel Functional Test No violations or deviations were identifie . Monthly Maintenance Observation Station maintenance activities on safety related systems and components listed below were observed or reviewed to ascertain whether they were conducted in accordance with approved procedures, regulatory guides industry codes or standards and in conformance with Technical Specification i The following items were considered during this review: the limiting l f conditions for operation were met while components or syst6ms were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemente Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance activities were observed or reviewed:

0 Diesel Driven Fire Pump No violations or deviations were identifie . Licensing Activities Certain licensee licensing activities examined by the inspectors during this period, specifically in regard to Station Management Organization (paragraph 4) and Unit 1 RCFC Damper Modifications (paragraph 7), were conducted in a sequence inconsistent with previous activitie With respect to Station Management Organization, the licensee implemented changes to station management structure prior to submission of a proposed amendment to Technical Specifications and prior to approval by the Office of Nuclear Reactor Regulation (NRR) of such an amendmen t' With respect to Unit 1 RCFC Damper Modifications, the modification

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rendered accomplishing Technical Specification required surveillance testing on those dampers impracticable. The purpose of the surveillance

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r was to verify that the dampers were free to move from their normal position to the accident position. The modification, however, placed the dampers permanently in the accident position. The proposed amendment to' Technical Specifications to delete the now unnecessary surveillance requirement was not approved by NRR prior to restoration of Unit I to operatio These variations in the processing'of license amendments by the licensee L are designated as an Unresolved Item (50-295/85020-02;'50-304/85021-01).

A licensee response to this item, specifically addressing circumstances leading to these departures from established processes as well as steps i to preclude recurrence, is necessary to permit resolution of the ite . Licensee Event Reports (LER) Followup Through direct observations, discussions with licensee personnel, an review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and ccrrective action to prevent recurrence had, been accomplished in accordance with Technical Specifications. The LERs listed below are considered closed:

, UNIT 1 LER N DESCRIPTION l 295/85-04-01 Failure of 1MOV-SI8812 A&B 295/85-14 Failure of Air Ejector Off-Gas Monitor; RE-0015 295/85-15 Partial Loss of Component Cooling 295/85-17 Failure of Safety Related Snubbers UNIT 2 LER N DESCRIPTION 304/85-10 Missed Boric Acid Transfer Pump Surveillance 304/85-11 Missed Shiftly Surveillance of the Monitor Panels With regard to LERs 304/85-10 and 304/85-11 Failure to Perform Required Technical Specification Surveillances on Boric Acid Transfer Pump and Monitor Panels, these items are considered a single licensee identified violation for which no citation will be issued -(50-304/85021-02).

With regard to LER 295/85-15 " Partial Loss of Component Cooling," this item is described in Paragraph 5 of this repor i .

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, a No other violations or deviations were identifie . Followup Of Region III Requests TI 2515/67 - Survey of Licensee's Response to Selected Safety Issues l

Mispositioned Control Rods In a memorandum from C.E. Norelius dated April 18, 1985, all resident inspectors were requested to conduct an inspection of their respective stations procedures and training concerning mispositioned control rod In accordance with the above request the inspectors reviewed station emergency procedures ard conducted interviews with nuclear station operators and the training supervisor. Procedures l describing recovery from a mispositioned rod and inoperable rod position indicators are utilized. Training is also provided detailing proper movement of control rods, the consequences of improper movement, and consequences of operating with a mispositioned ro No violations or deviations were identifie . Unresolved Items Unresolved items are matters about which more infermation is required in order to ascertain whether they are acceptable items, violations or deviations. One Unresolved Item disclosed during this inspection is f discussed in paragraph 1 . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the inspection period and at the conclusion of the inspection on July 1, 1985 to summarize the scope and findings of the inspection activities. The licensee acknowledged the inspectors' comments. The

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inspector also discussed the likely informational content of the

inspection report with regard to documents or processes reviewed by the

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inspector during the inspection. The licensee did not identify any such I documents or processes as proprietary.

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