ML20210S435

Safety Insp Repts 50-295/86-32 & 50-304/86-32 on 861210- 870116.Violations Noted:Violation of Containment Integrity Requirements & Failure to Establish Measures Sufficient to Ensure Applicable Design Requirements

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: ML20210S384 ML20210S435
References
50-295-86-32, 50-304-86-32, NUDOCS 8702170634
Download: ML20210S435 (7)

See also: IR 05000295/1986032

Text

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports-No. 50-295/86032(DRP); 50-304/86032(DRP)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48

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

%/~

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

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

PDR ADOCK 05000295-

G

PDR _

l

L , - . , . . _ , - . - - - - . - - - - . _ _ . - - .- .- - - . . ~

. .. -. . . . . -. - .- - _ .- . . . -

m

'

.

-

A g. 'I

-

..

,

. .

~

-

DETAILS -

,

1. -Persons Contacted

'

• G; Plim1,' Station Manager-

L. E. Fuerst, Superintendent,' Production-

. -

.T. Rieck, Superintendent, Services. ~

• W. Kurth, Assista'nt Station Superintendent,L0perations-

L. Pruett,-Unit 1 Operating Engineer ,

-

-N. Valos, Unit 2 Operating Engineer-

M.;Carnahan, Training Supervisor .

• R Cascarano, Technical Staff-Supervisor

[~ *C.. Schultz, Regulatory Assurance Administrator

~V. Williams, Station Health. Physicist-

'

• J. Yost, Quality Control Inspector

'

<

• J. Rappaport, Quality. Assurance Auditor

R. Lane, Primary Group Leader,. Technical Staff . . . .

T. Broccolo, Assistant to Assistant Station Superintendent, Operations

!

The' inspectors also met with Operations Department personnel during the

inspection.

,

• Indicates. persons present at exit interview.

~

I

2. Actions on Previously Identified Items

(Closed) Unresolved Item (295/86028-04;304/86028-04) Loss of Containment

Integrity Due to Manual Containment Isolation Valves (CIVs) left open.

'

b 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.-

This-Unresolved Item is considered closed.  ;

.

e

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

that reportability requirements were fulfilled, immediate corrective

!

action was accomplished, and corrective action to prevent recurrence had

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

-

Containment Isolation Valvas Open -

p

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

. report,

]

t-

4-

'

2

-

.

"

.-,64=--9wga w w w- e.-w-,-.,. y-v- * - ,er , ,,vey .wa+.ws- .. es ----+y- ,.,et..w e.,q,,ys. ,----w= m e--e.gevws q' y yt-wr v e r,--w me-- y e w-9

e

ye ws,*-v,--4p -ep---c--"

.

.

.

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. The DW CIVs for Unit I were

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.

'

.

(2) Neitheroutofservice(0}S)tagsnornon-routinevelvelineups

were used to control or document that these valves were not in

their normal position. 00S tags are not typically used for '

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.

3

. .

. - - - - - - - - - - - - - - - - - - - .

.

.

.

p

(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

non-rout valve lineups and valve manipulation by other than

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.

4

_ _ . _ - _ _ _

'

, -N- ,

.' -

\.

..

x .

.

. .

~~

' -(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.

'

(5) Procedures a'ddressing use of DW'inside containment will'be-

revised tojprohibit its use above cold shutdown.

2

(6) AnOnsiteRaviewwillbeperformedtodocument(justification

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.

-

(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.

(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): -

• \

t

5

.. .- - . . - - . -

.

-.

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.

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

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

!

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

'

l

,

i

6

~

p g.  %

g .

]

'

-

"

to place i

the ~ reactor lin. hot 1 shutdown within the following four:

-hours. ' Reactor operations'of Zion Unit 2 above cold shutdown 1from?

y

1986 through' November 30 .1986,~ with Unit 2 containment-

January

integrity 20,iolatedduetotheopenClVs20W0030:and2DW0038is

. .

v

considered ~a violation and is under consideration for escalated -

'

-

) l

enforcement (304/86032-01). _

requires'that measures-shall-

- 10CFR50;AppendixB,CriterionIII,bleregulatoryrequirgsents'and

beLestablished to assure that applica

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. 1~

Failure to comply with this quality assurance requirement-is

~

.

considered a violation. This is considered a violation and:is under

review for escalated enforcement.(295/86032-01; 304/86032-02).

.

,

Two violations?and no deviations were identified. These violations

are considered Unresolved Items pending NRC review for escalated

f enforcement.

e

'

15. Exit Interview-

.

.

$ -

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-~

L throughout the month of January,1987, with Mr. G. Plim1. The. ins

'

also discussed the likely. informational content of the inspection pectors

report

with regard to documents or processes reviewed by the inspector during i

,

the-inspection. The licensee did not identify any such documents or i

processes as proprietary.

m

-

1

-

s

i

l:

+

'-

.

y

v

7

.

\