IR 07100011/2012016

Notice of Violation from Insp on 971011-1216.Violations Noted:Procedures Were Not Appropriate to Circumstances in Listed Instances

ML20199A232
Person / Time
Site:	Zion, 07100011  File:ZionSolutions icon.png
Issue date:	01/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199A230	List: IR 07100011/2012016 ML20199A225 ML20199A246
References
50-295-97-25, 50-304-97-25, NUDOCS 9801270160
Download: ML20199A232 (3)

Text

._

.,-. - . - - - _. - - - - - . - - - - _ - __ -- -_-

i4 i

!

l

?

.

!

NOTICE OF VIOLATION Commonwealth Edison Company Dookat Nos: 50 296;805304 ;

! Zion Nuclear Generating Station Uoenas Nos: DPR-30; DPR-46

'

During an NRC inspecuan conducted on October 11 through December 16,1997, Ave violadons of NRC requirements were idenU6ed. In accordance with the " General Statement of Policy and  ;

'

• Procedure for NRC Enforcement Aouons," NUREG 1600, the violations are listed below:

i CFR Part 50, Appendia B, Crtierion V, "InstrucGone Procedures, and Drawings," I requires that acuvities aNeoling quality be prescribw ey documented instructions, i

,

procedures, or drawings of a type appropriate to the circumstances and be =+-:-T-7?.ed in accordance with these instructions, piecedures, or drawine l i

Centrary to the above, procedures were not appropriate to the circumstances in the following instances: ,

i On October 12,1997, System Operating instruc6on 61F, " Splitting Service Water Header for Maintenance," Revision 0, was not g-x+i':': lo the circumstances, in that, it did not provide appropriate guidance to ensure that M+y ^ service water flow was maintained to the 2B emergency diesel generator while spiltting l the service water headers. Cor.rg,0i, the operating shift inadvertently made i the 2B emergency diesel generator inoperabl t i' On December 2,1997, Periodic Test 10 3, " Containment isolation Phase B Testing," Revision 12, was not appropriate to the circumstances, in that, it did not provide appropriate guidance for testin0 the Train 'A" Division 7 contairwrant i isolation and componerd actuation circuitry energized from safety irgection relay SIX 1 A. Consequently, the relay SX1 did not i - .ei&= as expected in Secuon 5.1, Step 1 l This is a Severity Level IV violation (Supplement 1) (50 295/97025 01; 50-304/97025-01)

, CFR Part 50.72(b)(2)(l) requires that the lioersee shall notify the U.S. Nucinar  ;

i Regulatory Commist. ion as soon as practical and in all cases, within four hours of the occurrence of any event found while the reactor is shut down, that, had it been found

, while the reactor was in operation, would have resulted in the nuclear power plant, '

.

- including its principal safety baniers, being seriously degraded or being in an unanalyzed

'

condluon that significanUy compromises piani safet Contrary to the above, on October 16,1997, at 1730, en0ineering department personnel i

informed the Shift Manager that the %-inch piping penetration line from the reactor coolant drain tank to the auto gas analyzer was not seismically supported and was thus .

Inoperable. Had this condition been found while the reactor was in operation, the piard .

would have been in an u erd,2ed condition that would have compromised a principle ,

piard safety banier (containment); however, the licensee did not make the noti 6 cation unell 1504 on October 17,199 ,

This is a Severity Level IV violation (Supplement I). (50-304/9702504)

Y N P

G-So b 95 PDR ,

'

i

,w,,.- .,-.m,-. , , , . . . . - . . . . - , . - . . ~ . - + - , . . . - ~ . _ . - , , , - . , . , , . . . . - _ _ . - . 4m -- . '-

_ _ _ _ _ _ ___- _

,

t

• ;

i

!

i Noboe of Violation -2-  :

i l CFR Part 50, Ayrr e, Criterton V, ' instructions, Procedures, and Drawings,"

i requires that edivities aNecting quality be presortbed by documented instructiers,  !

procedures, or drawings of a type 5Fs+i'" to the circumstances and be =9:+g"M  !

, in anoordance with these instructions, procedures, or dreadng j Zion Generating Station Mainteranos Procedure E006-2, "HFA Raisy inspection and  !

A4ualment,' Revision 7. Sectit i H. Steps 8.2 and 8.3, requires that the relay be installed l 2 ar.d ro6erminated per the applicphl6 ;fA Relay Data Shee l HFA Relay Data Sheet for relay Q1 AX apecises that the wire from the reset coll, wire 2C #12, be connected to Terminal 1 ,

Contrary to the above, on Oc6ober 4, igg 7, while replacing relay SIX1 AX in accordance ,

with E006 2, "HFA Relay inspection and A4ustmord,' Revision 7, electrical maintenance  ;

, '

personnel connected the wire from the reset ooil, wiro 2C #12, to Terminal 10 (a spare

!

terminal)insteso of Terminal 12.

, .

This is a Severity Level IV vio46 Con (Supplement 1) (50 304/g7026 06)  :

4, 10 CFR Part 50, Appendix S, Crtierlon XI, " Test Control,' requires that a test program shall be established to assure that all testing required to demonstrate that structures,  ;

+

, systems, and components will perform satisfactor#y in service is identined and performed '

in accordance with written test procedures which incorporate the requirements had aooeptance limits contained in applicable design document l l- Contrary to the above, from October 4 through December 2, igg 7, the licensee did not i i identify or perform a post-malrdenance test for the replacement of relay SIX1 AX, to

assure that the relay performed satisfactor#y in sordo j This is a Severity Level IV violation (Supplement 1). (50 304/g702647)

"

l CFR Part 50, Appendix 8, Criterion lil, " Design Control,' requires, in part, that measures shall be establieed to assure that applicable regulatory requiremords and the l

l design basis, as denned in 50.2 and as speci6ed in the license application, for those ,

'

structures, systems, and components to which Appendix B applies are correctly translated into specifications, drawings, procedures, and instructions. Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that originally ,

-

u pufwmed the original desig Zion Updated Final Safety Analysis Report, Revised May igg 6, Section 9.4.1.2, ' System h-4" =i, states:

"

"Retum air passes through the control boards into a retum duct system which is connected to outlets at the top of the boards."

'

I l Zion drawing M-315, ' Control Room HVAC [ Heating, Ventr.ation and Air Conditioning)

l System, EL 642'-0"," Revision E, depicts the exhaust plenum connected through ducts to the top of each of the control boards in the control roo ,

+

,e - .--=,c--se,-,

s

-

l'

Notice of Violation -3-Contrary to the above, on June 13,1997, inspectors identified that numercus control room ventilation system ducts asscGated with cooling the control boards were not installed as specified by drawing M-315 since original corStructio This is a Severity Level IV violation (Supplement 1). (50-295/97025-10; 50-304/97025-10)

4 Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document control Desk, Washingtor; D.C. 20555, with a copy to the Regional Administrator, Region lil, and a copy to th9 NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This ,

reply should be clearly rnar4ed as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for (Se violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in the Notice, an order or a Demand for Information rnay be issued as to why the license should not be modified, suspended, or revoked, or why such other

- action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response tim If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-000 Because your response will be placed in the NRC Public Document Room (PDR), to the extent porsible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your

response that deletes such information if you request withholding of such material, you mni specifically identify the poitions of your response that you seek to have withheld and provide in i detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of privacy or provide the information required by g 10 CFR Part 2.790(b) to support a request for withholding confidential commercial or financial info!mation). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR Part 73.2 Dated at Lisle, Illinois this 21st day of January 1998 i

$ _