A98009, Responds to NRC Re Violations Noted in Insp Repts 50-295/97-02 & 50-304/97-02.Corrective Actions:Wa Pope Raychem Training Documentation Was Reviewed for Contractor Electricians Who Installed Raychem Splice on 970724

Responds to NRC Re Violations Noted in Insp Repts 50-295/97-02 & 50-304/97-02.Corrective Actions:Wa Pope Raychem Training Documentation Was Reviewed for Contractor Electricians Who Installed Raychem Splice on 970724

ML20203H692
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/26/1998
From:	Brons J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-295-97-02, 50-295-97-2, 50-304-97-02, 50-304-97-2, ZRA98009, NUDOCS 9803030293
Download: ML20203H692 (18)

Text

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Zila 98009 February 26,1998 U. S. Nuclear Itegulatory Comraission Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Iteply to Notices of Violation and Apparent Violations NitC Inspection Iteport No. 50 295/304 97023(DitS), EA 97-606; Zion Generating Station, U J's 1 & 2; NitC Docket Numbers 50 295 & 50 304 Iteference; Letter to O D. Kingsley (Comed) from O, E, Grant (USNI(C), dated January 27,1998, NitC Inrpection Iteport 50 295/304 97023, EA 97-606, transmitting five cited Notice of Violations and three Apparent Violatiens Gentlemen:

Ily lett:r dated January 27,1998, the NitC cited Commonwealth Edison (Comed) as being in violation of regulatory .equirements, This letter and its attachments constitute Comed's reply to the referenced Notice of Violations (NOV) and Apparent Violations (AV) in accordance with applicable regulations. Attachment A to this letter provides Comed's response to violations 1,2, 3, and 4 as cited in the NOV and includes the reasons for the violations, the corrective actions taken, and a statement of full compliance, Attachment B to this letter provides Comed's response to the AVs and includes the reasons for the apparent violations, the corrective actions taken, and a statement of full compliance, in addition, Attachment 11 includes Comed's response to violation 5 of the NOV since it is closely related to the AVs Attachment C to this letter identifies all commitments made by Zion Station in (nis response, t

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ZRA98'009 February 26,1998 Page 2 of 2 1 affirm that the content of this transmittal is true and correct to the best of my knowledge, information and belief. In some instances these statements are not based on my personnel knowledge, but on information furnished by other Comed employees, contract empbyees and consultants. Such information has been reviewed in accordance with company practices, and I believe it to be correct.

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

Sincerely,

) _

, . om . rons l site Vice Prer,ident

.Mion Nuclear Station Subscribed and sworn to before me, a Notary Public in and for the S; ate oft dlhi&J and County* of /h #c, ,this d'd day of d dtalia 1,19ff.

A1,si Y tt j Notary Public

'0FFIC IL SEhle-

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THERESAI.SIM ']L Notary Public, State ofIllinois GiyCommissionExpires 7/13/99f Attachments ,

I cc: Regional Administrator, USNRC - Region Ill Senior Project Manager, USNRC - NRR Project Directorate 111-2 NRC Senior Resident inspector, Zion Generating Station OITice of Nuclear Facility Safety - IDNS

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Attachment A to ZRA98009 Page1of10 REPLY TO NOTICE OF VIOLATION IN NRC  :

INSPECTION REPORT 50 295/97023; 50-304/97023 VIOLATION 1 (50-295/304-97023-05):

10 CFR Part 30, Appendix B, Criterion 11. " Quality Assurance Program," states, in part,  ;

that a quality assurance pro ~ ram be establishedfor activilles afecting quality and that c the program shall provide for indoctrination and training of personnel performing activities affecting quality as nece.uary to assure that suitable proficiency is achieved and maintained.

Contrary to the above, as ofJuly 24,1997, the licensee failed to ensure that training i provided to selected contractor craft and quality control inspection personnel performing i

' Raychem splice applications, an activity afecting quality, was adequate to assure that qualifications and suitable profielency were achieved and maintained.

This is a Severity IV violation (Supplement 1) (50-295(304)/97023-05),

- Adminnion or Denial of the Violation Comed admits the violation.

Reason for the Viola3q The reason for this violation is a failure to rigorously document contractor craft and quality control personnel training which demonstrated their proficiency relative to Raychem splice applications.

Proper documentation of Raychem training perfonned by the contractor, W. A. Pope, was inconsistent as a result of a lack of understandi:ig on the part of the individuals administering the training. The training administered to the contractor electricians consisted of classroom training instructed by a supervisor knowledgeable in Raychem applications and a practical demonstration of splice installation performed in the field by the electricians. The supervisor responsible for the classroom training also provided overview of the practical demonstration. The supervisor documented the overall training i

- but oid not distinguish between the classroom traimng and the practi:al demonstration

_ portion of the training. The documentation provided was not in compliance with the contractor training requirements established in Commonwealth Edison Nuclear Station Work Procedure (NSWP) -C-02, which requires that all training must be documented.

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Attachment A to ZRA98009 Page 2 of 10 REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97023; 50-304/97023 The quality control (QC) inspector in question had successfully completed the certification program; however, the training records were not updated to specifically identify the training completed in Raychem splicing. The individual providing the training for the QC it.spector failed to submit the Training Administration System (TAS) data entry form, which documented the formal classroom lecture and on-the job training (0JT), to the Braidwood Station Training Center which is the repository for completed QC training records.

Corrective Steps Taken and Results Achitytd r

W. A. Pope Raychem training documentation was reviewed for the contractor electricians who installed the Raychem splice on July 24,1997. It was determined that the contractor electricians who installed the splice had participated in both the classroom training and the practical demonstration. The training documentation was revised to properly reflect both portions of the Raychem splice training.

The Zion Station QC Department conducted a review ofinspector certification packages and updated documentation, as applicable. Zion QC inspector certification packages are now in compliance with procedure NSQCP-2, Revision 3," Comed and Vendor Nuclear Quality inspector Qualification and Certification Procedure."

Corrective Steps That Will he Taken to Avoid Further Violations Future Rayci.em splice training for contractor electricians will be conducted in accordance with the Zion Station Electrical Maintenance appro zed lesson plan which requires classroom training, practical demonstration, and a written examination.

Date When Full Compliance Will be Achieved ,

Zion Generating Statie's is currently in full compliance.

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Attaclunent A to 7.llA98009 I l' age 3 of 10 ItEPLY TO NOTICE OF V101 ATION IN NitC INSPECTION 11EPoltT 50-295/97023; 50-304/97023 y_IQLATION 2 (50 295/334-97023-0I);

10 CFR Part 50, ilppendix B, Criterion l', " Instructions, Procedures, and Drawings,"

states, in part, that activilles a[]ecting quality shall be appropriate to the circumstances and shall be prescrlhed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures and drawings.

Procedure 7:1P 920-01, " Site Scaffolding Procedure," revision I, step G.3.h requires that site engineering provide a review within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> indicating that the sca))idding was seismically constructed Contrary to the above, f<dlowing erection of scaffcAding adjacent to the 2H diesel generator oil storage tank on ilugust 28, 1997, the engineering review for seismic adequacy, an activity affecting quality, was not performcd until September i2, I997, a period exceeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

This is a Severity Level ll' violation (Supplement 1) (50-295(301)/97023 01).

Adminkin or penial of the Vioinths Comed admits the violation.

Rea<on for the Vioht11st The reason for this violation is inadequate communication. The scaffbid erector Ihreman was aware of the requirement to notify site engineering and request seismic inspection of the scallbiding, llowever, due to poor communication between the crews involved in the scaftbid construction, site engineering structural engineers did not receive timely notification that the scalrolding adjacent to the 211 diesel generator oil storage tank was completed and required seismic inspection.

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Attachment A to ZRA98009 Page 4 of to REPLY TO NOTICE OF VIOLATION IN NRC

! INSPECTION REPORT 50-295/97023; 50-304/97023 i

Corrective Steps Taken and Results Achieved in November of 1997, the W. A. Pope (Zion's Construction Contractor) scaffold erector foreman began using a log to provide input to the structural engineers as to which scaffolds are being eremi and as a method to communicate scaffold construction status 4

between work crews. Additionally, the scaffold erector foreman conducts a person to ,

person meeting with the structural engineer each working day in which the log has been updmed to review which scaffolds require a seismic inspection. Once the seismic inspection is performed, the structural engineer enters the appropriate information into the scaffold log indicating that the seismic inspection is complete. The scaffold erector .

foreman performs a daily review of the scafTold log to ensure that the structural engineer has performed and documented the seismic inspection within the stipulated 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time

- period.

In early 1998, responsibility for scaffold erection was transferred from the W. A. Pope Company to the Zion Station Mechanical Maintenance Department. The practice of usir.g the scaffold log and conducting review meetings with the structural engineer remains in place. The daily person to person interface between the scaffold foreman and the structural engineer, in conjunction with the use of the log book, establishes a set of .

checks and balances to prevent missed seismic inspections.

Corrective Stens That WilRe Taken to Avoid Further Violations ZAP 920-01, " Site ScalTolding Procedure," will be revised to proceduralize use of the scaffold log. This revision will be completed by April 15,1998.

Date When Full Compliance Will be Achieved Zion Generating Station is currently in full compliance.

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Attachment A to ZRA98009

[ Pa;c5of10 REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97023; 50-304/97023 1

VIOldTION 3 (50-295/304 97023-0.JA. 03Bu 10 CFR Part 50, Appendix B. Criterion XVI , requires, in part, that measures be established to assure that conditions adverse to quality, such asfailures, malfunctions, .

deficiencies, deviations, and nonconformances are promptly identified and corrected in the cases ofsignificant conditions adverse to quality, the measure shall ensure that the cause ofthe condition is determined and corrective action taken to preclude repetition.

Contrary to the above,

a. The licenseefailed to assure that corrective actions taken wouldpreclude repetition of deficiencies in the oil sample program, a significant condition adverse to quality identijled in the August ]996 Engineering and Technical Support inspection. Specifically, the licenseefailed to trend and analy:e pump oil samples for the 'OE' component cooling water pump annual oil samples in 1995,1996, and 1997; the 2A and 2B charging pumps monthly oil samples in June and August i997; and the 2A safety mJecilon pump 18 month oil samples in June 1997. Also the licensee c fidled to write a problem identification form (PIF) in November i99S when the 2A containment spray pump was identified as having an uncceptable oilsample.

b. The licensee failed to assure that long standing and repetitive out-of tolerance instrument issues, a condition adverse to quality, was corrected A violationfor out oftolerance instruments was previously cited in August 1996 and the problems were again identified in September 1997.

Specifically in February 1997, during performance ofsurveillance IMTS-2F-434, " Instrument Maintenance Transmitter Surveillance," the output

, for reactor coolant flow transmittes 2FI' 434 was found outside of the regs; ired acceptance criteria value and the licenseefailed to initiate a PIF, although this transmitter had previously failed in October i996. The +

transmitter failed for a third time in July 1997, indicating corrective actions to the previousfcdlure were not adequate.

This is a Severity Levei IV violation (Supplement 1). (50-295(304)/97023-3A, 50-295(304)/97023-38)

Admission or Denial of the Violation Comed admits the violation. ,

. Attechment A to ZRA980'0 Page 6 of 10 REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97023; 50-304/97023 Violation Exa.nple a:

Reason for the Violation (

Lube oil samples were taken but due to the informal undocumented process in place at the time, there is no assurance that the samples were shipped to or received by the Oil ,

Analysis Group at the System Material Analysis Department (SMAD). Specifically, the ,

samples that were not delivered to the SMAD lab are as follows: OA Component Cooling 3 SC) Pump samples taken May 18,1997; OC CC Pump samples taken May 6,1997; OE .

CC Pump samples taken May 6,1997; 2A Safety injection Pump samples taken June 5,  !

1997; and 2A and 2B Charging Pump samples taken June 13,1997, and August 4,1997, i The Oil Sampling and Analysis Program was significantly weakened by the elimination of the Lube Oil Coordinator position. As a result, Zion station was not able to adequately analyze and trend tube oil performance. In response to this concern, an action plan was

. developed to reestablish this position in October 1996. Personnel attrition contributed to i the delay in implementation of this action plan until March 1997. At that time, an owner of the Program was identified and a commitment was generated with a specific timeline

- for each action step required. This commitment established December 31,1997, as the date when full compliance would be achieved. This fmal date was met as well as all interim dates specified for each action plan step.

Corrective Steps Taken and Results Achieved An owner of the Oil Sampling Program was designated in March of 1997. An action plan to reestablish the Oil Sampling Program was initiated in October 1996 and completed in December 1997, The administration of the program is controlled by ZAP 300-12A,

" Station Oil Sampling Program," which now includes a process to identify, track and trend the resolution of abnormal oil analysis results. It also includes requirements for generating Problem identification Forms (PIF) when the analysis results identify an issue or adverse trend.

Corrective Steps That Will be Taken to Avoid Further Violations No further actions are deemed necessary.

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' Attachment A to ZRA98009 Page 7 of to Rl!P!,Y TO NOTICl! OF VIDI ATION IN NRC INSPECTION Rl! PORT 50 295/97023; 50 304/97023 Date Whtn. Full Compliance Will be Achieved

^

Zion Generating Station is currently in full compliance.

Violation Example h:

((tgangfor the Violallen The reason for this violation is a failure to fully develop and implement an instrument out of tolerance (OOT) piogram. At the time of the inspection, the program was initiated and included a database to track OOT instruments but did not include written guidance for the evaluation ofinstrument drin.

With regard to reactor coolant (RC) How transmitter 2FT 434, the evaluation that was performed indicated that the threshold for generating an RC flow transmitter DOT PIF was too low and the OOT was not a failure to meet safeguards system requirements. On September 22, 1997, adverse trend PlF Zl997-00755 on RC Flow inmsmitters OOT problems was closed by stating that the trend was increasing but that all occurrences were still within design margins and the cycle to cycle drift was random. This PlF did conclude that the transmitters were " wearing out and that they should be replaced, as planned.

during the next opportunity." Engineering Requests (l!Rs) 9606959 and 9605447 wcre written to replace the Unit i end 2 RC Flow tmnsmitters, respectively, during the next outages. Subsequently, the PIF threshold for RC Flow transmitter OOT issues was raised to a more reasonable level by means cf ER 9705115.

Corrective Steps Taken and Results .Achitted An Instrument Out Of Tolerance program has been implemented. The program presently in place at Zion trends OOT occurrences for technical specification and safety-related instruments. Those instruments that support engineered afety feature (liSF) and RP functions are additionally trended by the as-found and as IcR calibration values (regardless ofif a PIF is needed). I l

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- Attachment A to ZRA98009 -

l Page 8 of to REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97023; 50-304/97023 Corrective Steps That Will be Taken to Avoid Further Violations No further actions are deemed necessary.

i Date When Full Compliance Will he Achieved Zion Generating Station is currently in full compliance.

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Attachment A to ZRA98009 - >

Page 9 of 10 REPLY TO NOTICl! OF VIOLATION IN NRC INSPECTION REPORT 50 295/97023; 50 304/97023 VIOLATION 4 L40-295/304 97023-0411 10 CFR S0.46(a)(3)(II). states, in part, thatfor each change to or error discovered in an acceptable evahtation model the licensee shall report the nature ofthe change or error to the Commission.

Contrary to the above, as ofAugust 1997, the licenseefailed to report to the Commission discrepancies identified in the 1992 emergency core cooling system small break loss of coolant accident analysis.

This is a beverity Level IV violation (Supplement 1) (30 295(304)/97023-04).

Admission _or_ penial of the Violation ComFd admits the violation, jitason for the Violation The corporate Nuclear I uct Services (NFS) 10 CFR 50.46 reporting procedure and i Problem Identification Form (PIF) threshold and standard corrective actions procedure were in error in that they did not address poter.tial 10 CFR 50.46 reporting requirements for the case where an evaluation of a change against the 10 CFR 50.46 analysis of record demonstrates that the " change" is conservative.

4 Corrective Steps Taken and Results Achieved Letter ZRA97055, dated November 11,1997, provided a supplement to the Annual 10 CFR 50.46 Report. This letter provided the annotation of the Peak Clad Temperature (PCT) evaluation which resulted in the net non-credited - benefit as required by 10 CFR 50.46 for reporting significant differences. This letter also meluded a statement that Comed was evaluating the conr.istency between Zion Station plant characteristics associated with the other SBLOCA analysis parameters and the analysis of record assumptions.

Attachment A to ZRA98009 Page 10 of 10 REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50 295/97023; 50-304/97023 NFS procedure NFS T-02, Rev. O, dated November 7,1997, "NFS PlF Threshold and Standard Corrective Actions," was revised to include the provision to include in the ,,

10 CFR 50.46 annual report (or 30 day report, if necessary), any evaluation (PCT change) regardless of magnitude or benefit. The PIF procedure is the appropriate mechanism to initially identify and track an evaluation since the procedure requires that a PlF be initiated and a Nuclear Tracking System (NTS) item be assigned when t,n analysis is performed or a discrepancy is discovered. NFS procedure NFS-T-01, "10 CFR 50.46 Reporting," also identifies the need to report within the proper time frame any PCT -

evaluation regardless of the significance. NFS-T-Oi is a new procedure that has been approved for final use and is replacing NFS procedure NEP-16-63 dated February 24, 1995," Reporting Requirements for 10 CFR 50.46."

Corrective Stens That Will be Taken to Avoid Further Violations No further actions are deemed necessary.

Iltts When Fuj1 Compliance Will be Achieved Zion Genenting Station is currently in full compliance.

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.\ttachment B to 7.RA98009

- P ge I of 5 RE 'LY TO APPARENT VIOLATIONS IN NRC INSPECTION REPORT 50 295/97023, sn.304/97023 VIOLATION 5 (50-295/304 9702310):

10 CFR 50.73, paragraph (2) requires, in part, that licensees report any event or condition that was outside the design basis within 30 days after discovery ofthe event.

Contrary to the above, after discovery on September 30, 1996, the licensee failed to report within 30 days that during 125 l'dc crosstle conpgurations, which occurred numerous times since 1975, thu supply battery would not have sufficient capacity to support both buses during a limiting basis event, a condition outside the design basis of the plant. This condition was reported on August 5,1997.

This is a Severity I.evel ll' violation (Supplement 1) (50-295(304)/97023-10).

APPARENT V10L4 TION (eel 50-295/304-97023-07):

. The inspectors concluded that the licensee failed to: take prompt and aggressive corrective action to address a design depclency which was idennfled during a calcula:lon performed in September 1996. This calculation concluded that it was not acceptable to cross-tie 125 l'dc buses and supply the design basis accident duty cyclefor these cross-tied buses. The inspectors informed the licensee that this is cons.Jered an apparent violation of10 CFR Part 50, AppendLr B, Criterion Xi'1, " Corrective Actions"(eel 50-295/304/97023-07(DRS)).

APPARENT VIOLATION (EEI 50-295/304-97023-0Jh The inspectors concluded that the itcensee failed to: ensure that the design basis (calculation results) was correctly translated into appropriate operations, engineering and testing procedures and documents. This is considered an apparent violation of 10 CFR Part 50, Appendix B, Criterion lit, " Design Control" (eel SG-295/304/97023-08(DRS)).

APPARENT VIOLATION (EEI 50-295/304-97023-09):

The inspect >rs concluded that the licenseefailed to: adhere to the requirements of TS 3.15.2.E which stated that, "From and aper the date that one 125 l'dc battery and/or its distribution systemfor a unit (111,1I2, or 01ifor unit I; 211, 212 or O 'Ifor unit 2) is not operable, the reactor ofthat unit shall be placed in 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 /> unless the battery and/or its distribution system is soon made operable. "

This is considered an apparent violation of153.15.2.E. (eel 50-295/304/97023-09(DRS)).

Attachment 11 to ZRA98009 Page 2 of 5 REP 13 TO APPARENT VIOLATIONS IN NRC 1NSPEC'. N REPORT 50-295/97023,50-304/97023 Admission or Denial of the Violations Comed admits the violations.

Heuon for the Violatior-Discussion:

Zion Technical Specification (TS) Section 3.15.2.E was revised in 1975 to allow for one battery assigned to a unit in cold shutdown to fulfill the operability requirements of a battery assigned to an operating unit by utilizing the cross-tic breakers. This provision was initiated to allow for testing of the common battery and charger. The basis for this 1975 TS amendment was not clearly documented, in September 1996, detailed battery calculations were perfonned to model the cross-tic configurations. Specifically, Calculation 22-11-007E-026 Revision 0 (Capability of the 125 VDC Ilatteries to Supply the DC Cross tie Load) evaluated the allowable battery loading in tue cross tic configurations and concluded that load restrictions need to be placed on the batteries to racet design basis duty cycle requirements and assure adequate voltage at the load terminals. The calculation conclusions show that a DC cross-tied bus with a disconnected battery cannot meet its requirements for a design basis event. In addition, electrical current through the cross *ie connection must be maintained below 85 amps to ensure the bus with the connected battery can fulfill its design basis requirements.

Subsequent to issuance of Calculation 22-Il-007E-026 a number ofinappropriate actions and missed opportunities occurred. This was caused by a failure of Engineering, Operations, and Regulatory Assurance personnel to rec ~;nize the significance and operability implications of the calculation in light of pcst Aation practices for battery and battery charger testing, initially, Engineering failed to recognize the past operability ramifications of the DC cross-tie calculation when it was issued on September 30, 1996. The calculation concluded that the station battery capacity was insufficient to support the cross-tie methodology employed at Zion for battery testing and maintenance. Subsequently, Engineering did not issue a pr oblem Identification Form (PIF) to report the discrepant condition and the operability limitations for the station batteries.

I

Attachment B to ZRA98009 Page 3 of 5 REPLY TO APPARENT VIOLATIONS IN NRC INSPECTION REPORT 50-295/97023,50-304/97023 The station battery test procedure (TSS 15.6.38C) was revised to incorporate the conclusions of DC cross-tie calculation 22 B-007E-026 Revision 0 within weeks of the cal culation being completed; however, the procedure revision did not adeqte.tely address the 01.erability of the DC buses. This inadequate procedure revision was due to a failure on the part of System Engliseering to fully comprehend the operability implications of the calculation in addition, since the system engineers were not completely aware of the operability ramifications of the calculation, they failed to recognize the need to revise the corresponding procedure for DC system operation, Syst Operating instruction (SOI) -

63K. ,

On February 14,1997, Engineering issued PIF 97-0850 stating that operating procedures involving cross-ties for the 125 VDC Batteries ba not been revised to reflect the results of the cross-tie calculation. This PIF also stated that it is not acceptable to cross-tic a battery from a unit in modes 5,6 or defueled to supply the comp!ete design basis duty cycle for the same division of the opposite unit in modes 1 throagh 4. The Shill Engineer who screened the PlF inappropriately concluded that the 125 VDC batteries were operable and therefoic the event was not reportable. The Operations Department believed that the 125 VDC cross-tied buses were operable as long as the surveillance procedures were followed.

Engineering issued PIF 97-1156, dated March 4,1997, again stating that it is not acceptable to cross tie a battery from a unit in modes 5,6 or defueled to supply the complete design basis duty cycle for the same division of the opposite unit in modes I through 4. Once again, the Shift Engineer who screened the PIF inappropriately concluded that the 125 VDC batteries were operable and therefore the event was not reportable. Additionally, the Regulatory Assurance Department reviewed this PIF and detemiined that the event was not reportable based on the inappropriate conclusion that the batteries were operable; not all possible single-failure scenarios were considered during the Regulatory Assurance Department review.

On August 6,1997, during a Technical Specification review discussion conducted between the Regulatory Assurance Department, Design Engineering, and System Engineerirg, it was concluded that past pract?ces of battery and battery charger testing had rendered busses inoperable and the station had failed to report operation prohibited by Technical Specifications. PIF Zl997-01081 was written on August 6,1997, by Regulatory Assurance documenting the issue and identifying that a reportabililty concern existed. Licensee Event Report (LER) number 1-97-018, dated September 5,1997, was issued to report the failure to recognize that the 125 VDC buses were inoperable during unit cross-ties due to the inadequate 1975 TS revision.

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Attachment 11 to ZRA98009 Page 4 of 5 REPLY TO APPARENT VIOLATIONS IN NRC INSPECTION REPORT 50-295/97023,50 304/97023 1.ER number 1 97-016 was is;ued September 12,1997 to report a failure to recognize that 125 VDC buses were inoperable when the 111 and 211 buses were cross-tied for surveillance testing on August 15,1997.

In summary, Zion Station failed to take prompt and aggressive corrective action to address a design deficiency identified in the September 1996 calculation because System Engineering failed to secognize the operability ramifications of the calculation (Apparent Violation 97023-07). Since System Engineering did not fully comprehend the operability implications of the calculation, they did not ensure that the calculation results were properly translated into the DC system operating instruction, the stntion battery test procedure, or the battery surveillance procedure (Apparent Violation 97023-07). The st,thn did not comply with TS 3.15.2.E again due to a failure to understand the operability concerns identified in the calculation and a belief within the Operations Department that the 125 VDC cross-tied buses were operable as long as the surveillance procedules were fbliowed (Apparent Violation 97023 09). The reason for the failure to report operation outside the design basis is as described above for Apparent Violations 97023-07, -08, and -09 (Violation 97023-10).

4 Corrective Steps Taken and Results Achieved LER numbers l-97-016 and I 97-018 were issued to report the the failure to recognize that the 125 VDC buses were inoperable during unit cross-ties.

System Engineering discussed the conclusions of the cross tic calculation with Design Engineering to ensure full understanding. Design Engineering issued Nuclear Design Information Transmittal (NDIT) ZDE-97 086 on September 10,1997, which emphasized the operability conclusions of the calculation.

The operability condition of DC buses, when cross-tied, has been communicated to the Operations department by System Engineering. DC System Operating instruction SOI-63K has been revised to state that evolutions that isolate a station battery will make the associated bus inoperable and that a battery on a shutdown unit shall not be used to supply a DC bus on an operating unit via the cross-tie.

Station llattery surveillance procedures TSS 15.6.3CA (125 VDC Battery Perfo~mance Test) and TSS 16.6.38C (Station Battery Service Test) have been revised to incorpo ate the conclusions of the DC calculation.

Attachment B to ZRA98009 Page 5 of 5 :

REPLY TO APPARENT VIOLATIONS IN NRC INSPECTION REPORT 50 295/97023,50 304/97023

' Corrective Stens That Will be Taken to Avoid Further Violations

)

No further actions are deemed necessary.

Date When Full Comoliance Will be Achieved -

Zion Generating Station is currently in full compliance.

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'J Attachment C to ZRA98009 Pageiofi COMMITMENTS IDENTIFIED IN Tills REPLY TO NOTICE OF VIOLATION AND APPARENT VIOLATIONS -

The following table identifies those actions committed to by Comed in this document.

- Any_ other actions discussed is this submittal represent i_ntended or ;,lanned actions by Comed. They are described to the NRC for the NRC's information, and are not regulatory commitments. Please contact Mr. Rcbert Godley, Zion Generating Station Regulatory Assurance Manager, if there are any questions regarding this document or any .

associated regulatory commitments.

Commitment: Committed Date (or Outage):

Future Raychem splice training for contractor electricians will be Nonc conducted in accordance with the Zion Station Electrical Maintenance approved lesson plan which requires classroom training, practical demonstration, and a written examination.

ZAP 920 01, " Site Scaffolding Procedure," will be revised to April 15,1998 proceduralize use of the scaffold log. This revision will be completed by April 15,1998.

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