A97050, Responds to NRC Re Violations Noted in Insp Repts 50-295/97-13 & 50-304/97-13.Corrective Actions:Issued Nuclear Operations Notification to Other Comed Nuclear Facilities & Will Review & Evaluate Training Re Procedures

Responds to NRC Re Violations Noted in Insp Repts 50-295/97-13 & 50-304/97-13.Corrective Actions:Issued Nuclear Operations Notification to Other Comed Nuclear Facilities & Will Review & Evaluate Training Re Procedures

ML20217D505
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	09/29/1997
From:	Brons J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-295-97-13, 50-304-97-13, ZRA97050, NUDOCS 9710030251
Download: ML20217D505 (6)

Text

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'lClhl4M ONi ZRA97050 September 29,1997 U. S. Nuclear Regulatory Commission l Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Commonwealth Edison Reply to Example (a) of NRC Violation Number

, 50-295/304-97013-03; l Zion Nuclear Power Station Units 1 and 2; i NRC Docket Numbers 50-295 and 50-304 l

References:

(1) Letter to J.11. Mueller (Comed) from G. E. Grant (USNRQ dated August 15, 1997, NRC Inspection Report 50-295/97013, 50-304 07013 and Notice of Violation (2) Letter from John C. Brons (Comed) to USNRC dated September 15, 1997, Comed Reply to Notice of Violation in NRC Inspection Report Number 50-295/304-97013 (DRP)

Gentlemen:

By letter dated August 15, 1997, the NRC cited Commonwealth Edison (Comed) as being in violation of regulatory requirements. On September 15,1997, Comed provided its reply to Violations 50-295/304-97013-02,50-295/304-97013-05 and Examples (b) and (c) of Violation 50-295/304-97013-03, as cited in the Reference (1) Notice of Violation (Reference 2). By discussion with the Region 111 Branch Chief, Comed requested and was granted an additional week beyond the 30 day response in order to prepare a more

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comprehensive response to Violation 50-295/304-97013-03 Example (a). On September 22,1997, Comed requested and was granted additional time to provide the response, per ]46[

a telephone conversation with the Region Ill Branch Chief. This letter and its attachments constitute Comed's reply to Example (a) of Violation 50-295/304-97013-03 in accordance with applicable regulations.

9710030251 970929 ADOCK 050002 S DR i {lll l u nkom o.nyu m I

i ZRA97050 September 29,1997 Page 2 of 2 Attachment A to this letter provides the reasons for the violations, the corrective actions taken, and a statement of full compliance. Attachment B to this letter identifies all commitments made by Zion Station in this response.

Should you have any questions concerning this response, please contact Robert Godley of my staff at 847-746-2084 extension 2900.

Sincerely, ohn C. Brons Site Vice President Zion Nuclear Station Attachments cc: Regional Administrator,USNRC-Region 111 Senior Project Manager, USNRC - NRR Project Directorate 111-2 Senior Resident inspector, Zion Nuclear Station Office of Nuclear Facility Safety - IDNS j

K:/ COMPLY /CG NOV/V971303a DOC 1

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ATTACilMENT A to ZRA97050 Page1of3

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Response to Notice of Violation in Inspection Report 50-295/304-97013 VIOLATION: 50-295(304)/97013-03 Exampic (a) 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

requires that actisitics affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and that these activities be accomplished in accordance with these instructions, procedures, or

drawings.

1 Zion Administrative Procedure 900-05, " Control, Use, and Storage of Flammable and l Combustible LiquWs und Aerosols," Revision 1, Section F.7, requires that adequate i natural or mechanical ventilation is ensured in areas where flammable liquids or j aerosols are to be used Contrary to the above, activities afecting quality were not accomplished in accordance with applicable procedures or instructions in thefollowing instances:

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a. On May 24,1997, mechanical maintenance personnel did not encure that adequate natural or mechanical ventilation was established while applying a flammable lubricant to the Unit I reactor vesselstud holes; consequently, aflash fire resulted This is a Severity Level IV violation (Supplement 1).

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A TTACllMENT A to ZRA97050 Page 2 of 3 ADMISSION OR DENIAL TO TIIE VIOLATION Comed admits the violation.

REASON FOR TIIE VIOLATION 4

The reason for this violation example is a lack of rigor in the development and review of the work package for the stud hole cleaning and lubrication evolution. The flammability of the propellant used in the spray lubricant and the potential for the cleaning machine to act as an ignition source were not identified or evaluated during the work request package i assembly process, as required by ZAP 400-ItiD, " Work Request Package Assembly (EWMS)." Subsequently, the need to provije additional or forced ventilation, or to separate the lubrication and cleaning activities (that is, removal of ignition sources, such as the cleaning machine, prior to aerosol lubcicant application) as would be required by ZAP 900-05 was not recognized. Compounding this situr.'!on was the fact that a herculite tarp had been placed in the reactor head flange / boot area to prevent the spread of contamination and to facilitate foreign material exclusion (FME). Aerosol lubricant vapors were entrapped in the stud holes since the tarp restricted free ventilation around the perimeter of the vessel flange. The investigation into the cause of the event identified that the practice of skirting the reactor head flange / boot area in conjunction with application of the flammable lubricant had been in place for a few years. Therefore, the potential for a flash fire in the reactor vessel stud holes may have existed prior to the Unit

! flash fire on May 24,1997.

A contributing cause was the failvee.to discuss the flammability of the lubricant and identification of the cleaning machine as a potential ignition source with the work group at the pre-job brief.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACIIIEVED Zion Station issued a Nuclear Operations Notification (NON), dated May 28,1997, to notify other Comed nuclear facilities of the conditions and concerns surrounding this event.

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ATTAC11 MENT A to ZRA97050 Page 3 of 3 Requests were issued to the Training Department to review and evaluate the training associated with administrative procedural requirements for assessment, identification, and resolution of work environment hazards and to include identified enhancements in the Work Analyst and Maintenance Continuing Trairing Programs. Specific procedures.

under consideration include: ZAP 400-16D, " Work Request Package Assembly (EWMS)"; ZAP 400-16H, "I erfomling Work on an Approved Work Request"; ZAP 900-03," Fire Prevention for Transient Fire Loads"; ZAP 900-04," Fire Prevention when Welding, Cutting, or Grinding (llot Work)"; ZAP 920-05, " Personal Safety and llealth Responsibilities"; and ZAP 900-05, " Control, use, and Storap of Flammable. and Combustible Liquids and Aerosols."

Maintenance Procedure RC001-1, " Reactor Vessel Closure IIcad Installation," was revised to ensure that a liEPA ventilation unit is in place and running during the lubrication process, stud hole cleaning is performed prior to any stud hole lubrication, and any ignition sources in the closure head area are eliminated prior to lubrication of the stud holes.

The Mechanical Maintenance Department pre jnb brief checklist has been revised to include a requireinent for discussion of ZAP 900 05, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols," issues during the brief.

CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER VIOLATIONS Individuals performing work under ZAP 400-16D," Work Request Package Assembly,"

and ZAP 400-16E,'" Work Request Package Initial Review and Approval," will receive formal training on their specific roles and responsibilities within these procedures. This training will be completed as part of the next cycle of Work Analyst Continuing Training.

DATE WHEN FULL COMPLIANCE WILL HE ACIIIEVED

' Zion Station is currently in full compliance.

' ', ATTACilMENT B to ZRA97050 Page1ofi List of Commitments Identified in this Violation Response The following table identifies those actions committed to by Comed in this document.

Any other actions discussed in this submittal represent intended or planned actions by Comed. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify Mr. Robert Godley, Zion Station Regulatory Assurance Manager, of any questions regarding this document or any associated regulatory commitments.

Commitment Committed Date or.

Outage Individuals performing work under ZAP 400-16D, " Work Request None Package Assembly," and ZAP 400-16E, " Work Request Package Initial Review and Approval," will receive formal training on their specific rales and responsibilities within these procedures. This training will be completed as part of the next cycle of Work Analyst Continuing Training.

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