ML20011E016
| ML20011E016 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/27/1989 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9002070019 | |
| Download: ML20011E016 (16) | |
Text
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g' G 3 Ubommonwe56n Edison gd:. _.,... '
Zion Generating Station.'
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,101 Shiloh Blvd.
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- Zion, Illinois 6000*i Telephone 312/746 2084 x
December 27, 1989
' Mr. - A'. ; Bert Dayi s.-
. Regional-Administrator
-U.S.; Nuclear Regulatory Commission
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. Region III-1799 Roosevelt Road-Glen Ellyn,--IL--60137
Subject:
Zion Nuclear Power Station, Units 1 and 2
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License Nos. DPR-39 and DPR-48 ci Response _to Inspection Report Nos. 50-295/89030 and 50-304/89030
- t@C_. Docket Nos. 50-295 and 50-304 1
Reference:
a). November 15, 1989 letter from H. J. Miller to Cordell Reed U
Dear:
Mr. Davis:
1The ' letter referenced.above transmitted the results of a routine c'<fety
?!
inspection conducted by Mr. I :T. -Yin and Ms. V. P. Lougheed of your staf f ffrom September 11 through' October 18, 1989,- of Activities at the Zion. Nuclear:
M Power Station.-- During the course _ of this inspection, it was determined that
- certain activities appeared to~ be-in violation of NRC requirements. LAn
.p extention-'to the due date of'the' response-until December 27, 1989 was granted i
- during.a December.12, 1989-telephone conversation between H. P. Phi!11ps;and "G.~ E.:-Trzyna.- Our response-to the violation is prov_ided in the Attachment to
)
.this21etter.
- Please direct any questions'that you may have regarding this matter co
. this-office.
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Very truly yours, i
Y b T. J. Kovac s
U
-Nuclear Licensing Hanger cc:
Resident Inspector - Zion f f
-Chandu Patel -;NRR i
9002070019 691227
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DEC 28 W L
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., a VIOLATIOfLla:-
10 CFR Part 50, Appendix B Criterion XVI, states-that meunres shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and-equipment,'and nonconformances are promptly identified and corrected.
In the. case of significant conditions adverse to quality, the measures shall-assure that the cause of the condition is determined and corrective action taken to preclude repetition.
The identification of the significant condition-adverse to quality, the cause of the condition, and corrective action token shall be documer.ted and reported to appropriate levels of management.
-l Contrary to the above, instructions to implement corrective measures for deficiencies at cable tray routing points R598 and 1095S were not i
applicable to the deficiency, resulting in the failure of the deficient conditions to be corrected after identification.
C0ilqCTIVE ACTION TAKEN AND RESULTS ACHIEVEQ:
Paragraph _3;g. (page 9) of the inspection report lists 5 corrective actioft
. commitment' made by the Zion Station on September 14, 1989.
These commitments'and the current status of each are listed below.
(1) Hork instructions for the craf t would be improved and additional engineering involvement would be provided in the areas of deficient condition evaluation and. technical resolution to the identified problems.
Bechtel Hork Analysts, assigned to the engineering responsibilities, would be quallfled b) CECO.
-STATUSi Complete-Zion Station presently employs an engineer with the responsibility.of reviewing.all work instructions for cable pan system-discrepancies on which work has not yet been performed.
Engineering involvement in the area:of deficiency condition evaluation and technical resolution are required by procedure and are being monitored by the cognizant engineer.
Bechtel work analysts have been qualified by CECO.
(2) Additional instructions to the craft and QC inspectors would be provided on how to document the work and inspection performed.
STATUS: Complete A September 15, 1989 memo from CECO's Engineering and Construction -
Nuclear Operations to Bechtel Corp. provides the required documentation detail to the craf t and QC inspectors.
i (3) CECO and S & L engineering staff would perform sample verification on approximately 10% of all the more significant cable deficiency rework that had already been completed.
Based on the results, CECO would determine the need to expand the scope of verification.
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STATUS: _ Complete An approximate 10% sample _ verification has been completed by-both CECO ond S & L engineering staffs.
Because of additional deficiencies noted in the rework during these sample verifications, CECO engineering has expanded this verification to 100% of the cable deficiency rework performed prior to the implementation of the program upgrades described above. These deficiencies will be corrected in conjunction with'the remaining cable deficiency _ rework.
4 These sample verifications will be completed by_ December 29, 1989.
(4) CECO would continue to perform sample verification of completed work after the program upgrades discussed above were implemented.
STATUS: On-going 7
CECO will perform periodic sample verifications of comple'ed work to l
assure that deficiencies are adequately addressed.
The cognizant
}
engineer will, as required by procedure, document deficiencies for analysis and resolution.
1i (5) ' Instruction to the craft would be provided stating that they were not s
L to alter as-found conditions, including placing cable tray covers or l
sheet metal found in the vicinity onto the cable trays.
STATUS: Complete n
A SepNmber 26, 1989 memo from the Station Manager to:all station and contractor employees describes that work is not to be performed in-L the p1 ant.without' adequate documentation, as appropriate.
Employees are encouraged to refer to their supervisor if they have questions about whether formal work instructions are required.
CORRECTIVE ACJION TO BE TAKEN TO AVOID FURTHER V10LATI0ti:
A documented supplemental cable pan walkdown will be~ performed for those discrepancies where work has not been performed to ensure the adequacy of work instructions. Hork-. instructions will be enhanced as deemed appropriate.
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- A supplemental walkdown is not required for Unit-1 containment discrepancies since an additional walkdown to ensure work instruction adequacy was performed prior to work request generation.
A supplemental walkdown is also not required for housekeeping discrepancies requiring the removal of debris / foreign neterials froin cable trays since the present work instructions are considered acceptable.
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All pending Nuclear Hork' Requests (NHR's) for cable pan system
. discrepancies are presently being reviewed.for work instruction adequacy..
After the above mentioned supplemental =walkdown is performed, the enhanced' work instructions.will be attached to the IHR's and reviewed by the cognizant Technical ' Staff Engineer prior to releasing the NHP's for implementation.
Due to the'large population of cable pan system discrepancies, corrective actions will be conducted and prioritized per electrical installation zones.
The above described methodology will ensure the adequacy of work instructions prior to performing work for a specific electrical instellation zone.
This methodology will prevent recurrence of the subject violation.
D&]LHBEiLLULLCOMP11ANCE HLLL BE ACHIEVED:
The supplemental walkdown will be completed by June 1, 1990.
The
' additional sample verifications will be completed by December 29, 1989, a,
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p 110 CFR Part 50, Appendix _3, Criterion XVI, states that measures shall be established to assure that conditions' adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective materla1 and equipment, and nonconformances are promptly identified and corrected.
In the event of significant conditions adverse to quality, the measures shall assure that the canse of the' condition is determined and corrective action taken to preclude repetition.
The idantification of the significant.
condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to-appropriate
-levels of ma'nagement.
I Contrary ~to the above, based on walkdowns of the cable trays which were completed in January 1989, the licen:ee's contractor had identified 38 conditions where~ cables with.different segregation codes were routed together; however, there was no documentation identifying the cause of the condition, its significance, nor that the condition had been reported to
-the licensee.
1 CQl@ECTIVE ACTION TAKEN_AND_RESULTS ACHIEVED:
!~
At' the time of the NRC's inspection a systematic program was in place to identify pcssible. segregation violations for potential safety i
L significance.
These segregation violations were-identified and summarized i
L in the meetings on preliminary walkdown review between Sargent & Lundy and
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CECO. A number of these possible violations required additional Information such as cable identity and termination' points.
The secondary 1
walkdowns for additional information were in progress at the time of the NRC inspection.
These additional walkdowns are difficult and time consuming because the Zion cables are not identified in the cable trays and often penetrate fire stops which must be breached to trace'the routing =
-path.
There are possible explanations for the segregation violations that may become apparent after the cables have been identified.
Even though the Cable Separation Criteria Violations (CSCV's) were not documented by telephone memorandum, CECO was informed by'way of active engineering participation in the initial walkdown discrepancy evaluation process.
This participation is well documented in the Discrepancy-Resolution Summaries of each walkdown package. An initial evaluation of 1
the Cable Discrepancy Reports revealed no significant issues and in many 3
instances required additional walkdowns to identify specific cables. This participation'is; required by Project Instruction (PI) ZI-43.
For each of-the walkdown discrepancies that was determined to require engineering analysis, which would inc1Ma all discrepancies requiring a CSCV to be generated, a meeting was held between CECO and Sargent & Lundy to propose l
a possible resolution (e.g. analyze the discrepancy, perform secondary L
walkdown for additional information, add cable tray covers, etc.).
Based on these preliminary evaluations no immediate safety concerns were identified.
The results of these meetings were distributed in the form of meeting minutes and Discrepancy Resolution Summaries to the CECO Nuclear Engineering Project Engineer and Cognizant Engineer, and to the Zion Station Technical Staff Supervisor and Cognizant Engineer.
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Excerpts from meetings held in February and March of 1989, which document the discussion of routing points.k278 and_2412E,.and provide examples of.
the above process, are provided in Attachment A.
_ All 4dentified CSCV's have been initiated and forwarded to off-site engineering for analysis. While the inspection report indicates that 38 conditions existed where-cables with different segregation codes were routed.togethr-further review hat shown a total of only 34. _The 34 CSCV's are doca.danted and pending review.
CORRLCIIVE ACTION TO_BE TAKEN TO AV01.0 FURTHER_VIOLAIl0E:
l Since all initial walkdowns for identifying cable pan system discrepancies have been performed, with exception of the Unit 2 containment reactor head bridge (which will be performed during the upcoming Unit 2 refueling outage scheduled to commente March 22, 1990),' the Station is confidentL that all cases of cable separation criteria violations have been identified.
However, if any additional cable separation criteria violations are identified by supplemental walkdown or engineering analysis, they will be evaluated according to PI-ZI-50.
DAIL}ltlEtLLULLCOMPLIARCE HILL BE___ ACHIEVED:
.The secondary field walkdown of potentially discrepant unidentified cables will be complete by March 9, 1990.
The Offsite Engineering Analysis for the CSCV's will be complete by April 13, 1990.
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=y10LATJON Ic:-
10 CFR i' art-50, Appendix B,. Criterion XVI, states that measures shall be established to assure that conditions adverse to quality, such as 1
failures, malfunctions, (eficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In
- the event of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.. The identification of the significant condition adverse.to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.
Contrary to the above, although the significant deficient condition of reactor coolant pump 2A high vibration had been corrected, the measures taken to preclude repetition were inadequate in that they failed to R
address the reactor coolant pumps in Unit 1, failed to evaluate the-effects of the cause of the deficient conditions on the steam generator bumpers, and failed to document the identificatio" of the deficiency.
CORRECILYLACJ10N TAKEN A' D RESMLTS ACHlIVED:
N Zion'has reviewed vibration records for all Unit I reactor coolant pumps; no adverse trends-were identified.
While the inspection report indicates that 8 T-Shaped support orackets were left in place in Unit 1, further review indicates that only 5 of the brackets were unintentionally lef t in Unit I containment during the last operating cycle.
Zion Station Discrepancy Report 89-0112 now documents the' identification and disposition of. these five temporarily installed T-Shaped support i
brackets.
The support brackets were promptly removed-and an engineering evaluation initiated.
The engineering evaluation concluded that the overall effect.of the support brackets being left in place during the last operating. cycle was minimal and that no significant damage to equipment or structures-had occurred.
1
-CORRECIIVE ACTION TO BE-TAKEN TO AVOID FURTHER VIOLATION:
To prevent recurrence, Station Procedure P/RC000-1N, " Removal and
-Installation of the Primary Manway Cover on the Steam Generators", has been revised to ensure the. removal of the temporarily installed support brackets.
This procedure revision was implemented on October 21, 1989.
In addition, Zion will provide a memo to all station personnel, emphasizing the requirement to report and document deficient or discrepant i
conditions, as prescribed by station procedures.
D&IEElELEULL_C0tiELIARCLHlLL BE ACHILYED:
The memo to all personnel to recort and document deficient or discrepant conditions will be distributed by 12/31/89.
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10 CFR 50.59(b)(1) requires that the licensee shall maintain records of changes-in the facility or procedures to the extent that these changes constitute changes in the facility or procedures as described in the safety analysis report.
The licensee shall also maintain records of tests which are conducted and are not described in the safety analysis report.
These records must include a written safety evaluation which provides a bases for the determination that the change or test ~does not involve an unreviewed safety question.
Contrary to the'above, the licensee failed to perform a written safety evaluation for the following example where changes were made to the facility.or procedures as described in the safety analysis report, or i
where tests were conducted which were not described in the safety analysis 1
-report:
Temporary Alteration 88-022 involved the intentional breaking of the quench line from the Residual Heat Removal pump to the pump seals which resulted in a valve originally installed for normal maintenance becoming the post-LOCA ECCS pressure boundary.
The quench line is i
shown on Figure 9.4.1-1 of the Updated Final Safety Analysis Report (UFSAR), and the performance of this alteration may affect the operations of the RHR pump, which is described in Srction 9.4.2.2.2 of the UFSAR.
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l CDEECllE.ACH0N TAKEN AND RESULTS ACHIEVID:
'The quench line and valve mentioned in this part of the notice of violation is shown on Figure 9.4.1-1 of the UFSAR.
The quench line runs from the pump suction through the normally closed valve to the seal gland i
~
' vent _ tap; as such, the valve mentioned is part of the pressure boundary.
L Leakage through-this valve,.both before and after alteration, would leak 1
to the atmosphere which is a condition bounded by analysis in the UFSAR.
Modifications to' this system should have been considered a change to the j
l facility as described in the SAR and should have beer; addressed in a i
l safety evaluation (10 CFR 50.59(a)(2)),
Hhen identified during the SSOMI visit, a safety evaluation on Temporary Alteration 88-022, answering 10 CFR 50.59(a)(2) was performed and reviewed by On-Site Review. The safety evaluation concluded that no unreviewed safety question existed.
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.o, CORRICU.VE_AC110R_ID_BE_I MEN ~TO AVOID FURTHER VIOLATION:
. Zion Administrative Procedure ZAP 2-54-5 will be revised to specify that
' alterations to drawings contained in the UFSAR are to be considered' changes to the UFSAR.
As mentioned in the following general discussion of safety evaluations,
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l Zion is actively participating in the corporate. task force on safety i.
evaluations.
The Technical Staff supervisor and assistants have been sensitized to the need for adequate safety evaluations'.
DALLNRDLEULL f0HELIMCEllLLBLActl1EVID:
ZAP 2-54-5 will be revised by January 31, 1990.
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Y10LATION 2b:
10 CFR 50.59(b)(1) requires that the li'censee shall maintain records of changes in~the facility or procedures to the extent that the changes constitute changes in the facility or procedures as described in the safety arealysis report..The licensee shall also maintain records of tests which are conducted and are not described in the safety analysis report.
These records must include a written safety evaluation which provides the bases for the determination that the change or test does not involve an unreviewed safety question.
Contrary to the aoove, the licensee failed to perform a written safety evaluation for the following example where changes were.made to the facility or procedures as described in the safety analysis report, or _
where tests were conducted which were not described in the safety analysis report; Procedure Change Request HMSP-89-001 was implemented to allow the performance of a surveillance test of the main steam safety valves while the reactor was at power - a test not described in the UFSAR.
.Section 13.4.4 of the UFSAR indicated that post-startup Surveillance and testing requirements will be as described in the Technical
. Speci fications.
For this test, Technical Specification Section 4.7.1 states that ten valves will be tested at each refueling outage.
However,.the tests actually performed were while the reactor was at power, thereby constituting a test not described in the UFSAR.
CORRECIlYLACIIDLIAKEN AND RES11LTS ACH11XED:
Main Steam Safety Valve tests are listed in the Zion UFSAR, Table 13.3-1, in a section covering those tests performed after initial core loading and prior to initial criticality.
The test itself, however, is not described.
Periodic testing of the MSSV's is not addressed specifically in the UFSAR except as discussed generally in section 13'.4.4 with regard to all post startup and testing requirements.
Section 13.4.4 simply references the requirements set forth in the Technical Specifications.
Tech Spec 4.7.1 requires refueling outage-testing frequencies of the MSSV's. Our interpretation of definition 1.40, Refueling Cycle or Outage, (which is 4"
supported by the Tech. Spec definition from our original. Tech Spec's, definition J Refueling Outages) allows the testing of MSSV's at power.
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However, we agree that UFSAR Section 14.2.5-1 does not discuss the increased probability of an accidental depressurization-due to this testing.
Thus a safety evaluation should have been performed which addressed the increased probability of an accident described in the SAR.
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The current method of testing was performed twice previously. At that time Zion'did not have a procedure in place which included safety evaluation screening.
Therefore, for each_of these tests safety evaluations pursuant to 50.59(a)(2) were performed that concluded that no unreviewed safety question existed.
Since that time, Zion's safety evaluation procedure was revised to provide for a screening process which determines whether 50.59(a)(2) should be addressed.
Zion is developing a maintenance procedure P/MS014/033-1 "On-Line Testing.
of the MSSV's" for use when performing this surveillance test.
Prior to the next refueling outage a formal safety evaluation will.be performed in-conjunction with approval of this procedure. UFSAR 14.2.5-1 will be updated with the results of this formal safety evaluation.
CORRECIlVE ACTION TO BE TAKEN TO PREVENT FURTHER VIOLATION:
Zion Administrative-Procedure (ZAP) 2-54-5 will be revised to provide for the following:
The safety evaluation screening criteria will include a summary of 50.59(a)(1) which will note that tests described in.the UFSAR must-he
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'As mentioned in the following general discussion of saf4ty evaluations, j
. Zion is actively participating in the Corporate Task Force on safety
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evaluations.
In addition, Zion's Technical Staff supervisor and assistants have been sensitized to the need for adequate safety evaluations.
DATE HHEN FULL COMPLIANCE WILL BE ACHIEVED:
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ZAP 2-54-5 revisions will be complete by January 31, 1990.
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-Maintenance procedure P/MS014/033-1 and its associated safety evaluation-j will be completed prior to performing online MSSV testing at the next refueling outage, currently scheduled to commence March 22, 1990.
The I
change to UFSAR 14.2.5-1 will be included in the June, 1990 update j
i submittal.
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10 CFR 50.59(B)(1) requires that the licensee shall maintain records of 2
changes in-the facility or procedures to the extent that these changes constitute changes in the facility or procedures as described in the safety analysis report.
The licensee shall also maintain records of tests 3
which are conducted and are not described in the safety analysis report.
l These records must include a written safety evaluation which provides the bases for the determination that the changes or. test does not involve an.
unreviewed safety question.
Contrary to the above, the licensee failed to perform a written safety evaluation for the.following example where changes were.made to the facility or procedures as described in the safety analysis report, or where tests were_ conducted which were not described in the safety analysis report:
Temporary Alteration 89-010 supplied a temporary power feeder from a non-vital electrical source for the heat tracing _of.the pressure sensing lines from the boric acid transfer pumps.
Section 9.2.2.6.35 of the UFSAR described the electrical heat tracing for lines containing highly concentrated boric acid solution,.and indicated that these lines were to be powered from vital electrical supplies.
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CORRECILVLACIION TAKEN AND RES_ULTS AC111 EYED:
Temporary Alteration 89-010 included a preliminary safety review as required by procedure.
The review specifically and correctly referenced the applicable section of the UFSAR which reads " heat tracing is considered a vital load and is operable from dissel generators". However, the review incorrectly stated that this section was not changed.from its description in the'UFSAR and concluded that 50.59(a)(2) did not apply, In this case the same conclusion may have been reached had 50.59(a)(2) been answered and the screening process not used.
Station review of the safety evaluation did not identify this error. Hhen identified during the SSOHI visit the proper evaluation was completed.
On-site Review concluded that no unreviewed safety question existed.
CORRECTIy1_ ACTION T0__BE TAKEN TO PREVENT FURTHER VIOLATION:
Hork requests have been written to supply the heat tracing with vital feeds per the initial design criteria.
As mentioned in the general discussion of safety evaluations, Zion is actively participating in the Corporate Task Force on safety evaluations.
In addition, Zion's Technical Staff supervisor and assistants have been sensitized to the need for adequate safety evaluations.
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DAILfMDLIULL. COMPLIANCE HILL BE ACHIEVED:
These work requests should be completed by March 31, 1990.
4 GQlE[MLDISCUSSJON OF SAFETY EVALUATION PREPARATION:
In general the NRC agrees that Zion's evaluations are more thorough and provide a higher level of documentation detail than a number of years ago.
Zion Station recognizes, however, that the answers on our screening criteria (ZAP 2-54-5) do not contain the detail desired. As such, this procedure will be revised to eliminate confusion that has arisen in its:
use. As pointed out during this inspection, in our temporary alteration of the RHR quench line, separate individuals reached different conclusions from the screening criteria, caused by either ambiguous questions or wrong, j
answers to those questions.
Zion feels that this is unacceptable. Also, as currently written in our screening criteria, more emphasis is placed on i
conclusions requiring 50.59(a)(2) to be answered than not answering 50.59(a)(2).
Zion is on record committing to revise it's safety evaluation procedure (ZAP 2-54-5) as a result of the Zion management meeting with the NRC on November 14, 1989.
This revision should clarify what is being asked and will incorporate the " lessons learned" as a result u
of this violution. As discussed above, ZAP 2-54-5 will be revised by l
January-31,.1990.
To assure ourselves that an unreviewed safety question was not inappropriately screened out all procedure changes involving tests or experiments performed since our screening process was implemented will be sampled on a 101. basis.
If any unreviewed safety question is found this sampling will be expanded.
This sampling will be completed by March 31, 1990 - All safety related modifications currently have a safety evaluation performed by off-site engineering so no further_ review is-deemed necessary.
In addition all safety related temporary alterations
. installed greater than 60 days also have a' safety evaluation performed by off-site engineering so no further review is deemed necessary.
Any time a change is made in the plant, whether it be.to a procedure, a test, or to a piece of equipment, a written safety evaluation l's
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performed. A screening criteria is used to determine whether a change is i
being made to the' facility as described in-the UFSAR.
The station's screening procedure provides a written record of.the basis for determining whether 10 CFR 50.59(a)(1) applies.
Hhen the screening criteria conclude that a change to the facility as described in the UFSAR is being requested, the standard 50.59 questions are asked and answered.
This provides a determination if an unreviewed safety question exists or if a change to the Technical Specifications is. necessary. Utilization of the screening process has enabled Zion to devote more attention to those i
changes which are materially important to plant safety and are required to be evaluated per 50.59(a)(2).
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If the change requested is a temporary alteration, a technical evaluation is performed by members of the Technical Staff.
The technical evaluation verifles-proper design and installation and evaluates the effects upon other equipment.
All On-Site Reviews, including those associated with Temporary Alterations, are evaluated by Technical Staff Supervisor or assistants.
Those individuals have been sensitized to the issue-of adequate safety evaluations through their involvement in the issues contained in this Notice of Violation. Until such time as the administrative procedure governing safety evaluations is revised, the Technical Staff Supervisor and assistants will ensure that close management attention is given to-the subject of adequate safety evaluations. An SRO. licensed Technical Staff assistant supervisor has been assigned to Commonwealth Edison's corporate committee on safety evaluations.
Guidance provided by NSAC 125 will be
.I used by the committee to set company policy with regard to safety evaluation performance.
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ATTACHMENT A Cable System Halkdown Summary of Resolutions Eartilges 22E-2-310L_22E-0-3061 and 22E-0-3083 The following is a tabulation of the discrepancies from the walkdown of the 22E-2-3206, 22E-0-3061 and 22E-0-3083 drawings that required an engineering analysis.
The cable tray routing point (node) is listed along with a description of the discrepancy and a suggested course of resolution.
It should be noted that some tray nodes have more than one discrepancy, that do not require an engineering analysis.
The Station has initiated Nuclear Hork Requests to resolve these items.
Each routing point in these packages with a separation discrepancy has been checked against the existing group of Criteria Exception Requests (CERs) to determine if the discrepancy has previously been reviewed by engineering and apprcved.
Some of the resolutions
-involve installing cable tray covers; a current installation drawing for identifying the tray nodes ' hat require covers at the Station needs to be developed.
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Halkdown Packags_22E-2-3206 1.
Routina Points (RTG PTS.) 2696EA. 2696EA. 2696EB and K278 Durriotion - Tray nodes 2696EA(2P), 2696EB(2P), and K278(29K) are not installed per the design drawings.
Node 2696EA routes cables to 1
Electrical Penetration E41; K278 routes cables to penetration E45.
The 1
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trays for 2696EA and K278 are not installed per the drawings because of the relocation of penetrations E41 and E45. Penetration E41 is installed where E45 was to be installed (per the original design drawings); E45 is installed where E41 was originally located.
(See attached sketch on page l
2).
Node 2696EA is identified in the-field as 2696EB; 2696EB is l
identified as 2696EA. An unidentified section of tray is installed above-l K278 which also routes cables to penetration E45.
Relohttion - Halkdown.and analyze 2696EA, 2696EB, K278, and the short section of unidentified tray per PI-ZI-43.
Initiate a NHR to relabel 2696EA and 2696EB with the correct routing point numbers.
Determine what cables are routed in the short section of unidentified tray in order to update the Cable Information System (CIS-3) and the cable tabulation drawings. A record revision to drawing 22E-2-3206 (Revision "R" May 24, 1978) documents the as-built location of penetrations E41 and E45.
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t i 4 ATTACHMENT:A (Continued) q i
c.:
Commonwealth Edison Company l
Zion Station - Units 1 and 2 Notes'of Meeting - January 26, 1989 1
j Halkdown Package _22E-0-3077 j
10.
RTG. PT. RS65 1:
No action is-required for this discrepancy.
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- 11. RIG. PT.'2412E
,U Proceed per PI-ZI-43.
1 ACTION:
S & L (Field,. Structural, Electrical)
[. '
- 12. 'RTG. PT. 2411B Proceed per the proposed resolution.
/
ACllDH:
S & L (Field, Structural, Electrical) i i
13.
RTG. PTS. 2004F. 2400L (2404F. 2400E)
Revise drawing 22E-0-3077 per the proposed resolution.
R ACTION:
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RTG. PT. 2428F 1
No action is required for this item.
A NHR has been initiated to j_
install tray covers.
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RTG. PT. 2461EE l.
.15.
1 Proceed per PI-ZI-43.
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ACTION:
S & L (Field, Structural, Electrical) 1
.l 16.
RTG. PT. 833E I
/
-a)
Develop and issue a generic barrier detail.
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b)
Initiate a NHR to install the tray barrier upon completion of action item a.
r j.
l ll u
1.
17950(15)-
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