ML20012G332
| ML20012G332 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/18/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9302240120 | |
| Download: ML20012G332 (3) | |
Text
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\\. Ccmmonw=lth Edison
( li 1400 opus Place m
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Downers Grove, Illinois 60515 I
February 18,1993 i
U.S. Nuclear Regulatory Commission t
Washington, D. C. 20555 Attention: Document Control Desk
Subject:
Zion Nuclear Power Station Unit 1 and 2 Response to inspection Report 50-295/92031 NRR_D_ocke1NumbeL@l91i.
Reference:
B. Clayton letter to L. DelGeorge dated January 19,1993 transmitting Inspection Report No.
50-295/92031 Enclosed is the Commonwealth Edison Company (CECO) response to the Notice of Violation (NOV) which was transmitted with the referenced letter and inspection Report. The NOV cited one Severity Level IV violation related to the failure of personnel to perform an independent verification of the position of a motor driven Auxiliary Feedwater pump discharge isolation valve. CECO's response is provided in the attachment, if your staff has any questions or comments regarding this response, please refer them to Sara Reece-Koenig, Compliance Engineer, at (708) 663-7250.
Sincerely, tat 8k
<[ W deu D.L. Farrar u Nuclear Regulatory Services Manager Attachment cc:
A. Bert Davis, Regional Administrator - Region lil i
J. D. Smith, Senior Resident inspector, Zion 1
C. Shiraki, Project Manager, NRR 220008 I
/{A i
ZNLD/2172/1 9302240120 930218 i
r PDR ADOCK 05000295 V
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6TTACHMENT I
RESPONSE TO THE NOTICE OF VIOLATION NRC INSPECTION REPORT 50-295/92031 (DRP)
VIOLATION (50-295/92031-01)
Technical Specification 6.2.1 requires that written procedures including applicable checkoff lists covering normal startup, operation, and shutdown of the reactor and other systems and com >onents involving nuclear safety of the facility shall be prepared, implemented, anc maintained.
Zion Administrative Procedure, ZAP-0, revision 6, " Conduct of Operations", paragra,+
5.3.12 requires that an independant verification of proper safety-related system line-up be performed following equipment retum to service.
Contrary to the above, on October 2,1992 the licensee f ailed to perform an independent verification of the position of the Unit 1,1B motor driven auxiliary feedwater (AFW) pump discharge isolation valve (1FW0038) following valve realignment and return to service.
This is a Severity Level IV violation (Supplement I).
i BEASON FOR THE VIOLATION Commonwealth Edison Company (CECO) acknowledges the violation.
Failure to perform a proper independent verification of the position of the 1B motor driven AFW Pump discharge isolation valve following valve realignment and return to service was the result of personnel error. The ZAP-0, Revision 5 ' Conduct of Operations' requirement for performing independent verifi5ation was not adhered to.
COBBECTIVE ACTIONS TAKEN AND RESULTS ACHIEVEQ Operators re-opened the valve within approximately five minutes of discovering the mispositioning.
To verify proper position of other locked safety-related valves, PT-41 " Locked Valve Audit" was performed for both Unit 1 and Unit 2.
ZNLD/2172/2
AUACHMENI RESPONSE TO THE NOTICE OF VIOLATION NRC INSPECTION REPORT 50-295/92031 (DRP)
COBBECTIVE AQ_I1ONS TAKEN AftD RESULTS ACHIEVER (continued)
Zion Station, through its Integrated Reporting Program, performed an extensive Root Cause Analysis of this event. The Root Cause Analysis effort was performed as a level ll investigation. This level of investigation necessitated senior management leadership, a multi-discipline review, and corporate involvement. The review determined that since the Auxiliary Operators involved had been previously trained on the proper method of performing an independent verification, the root cause of the event has been categorized as a personnel error.
COBEECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION A Lessons Learned initial Notification (LLIN) on the event was disseminated to all other CECO nucler sites on October 22,1992.
Appropriate disciplinary actions were taken for individuals involved.
Senior Management expectations for independent verification performance were reinforced by the Assistant Superintendent of Operating.
The appropriate procedures have been revised to require running both motor-driven pumps and verifying flow to each steam generator when splitting and unsplitting headers.
This event will be included in the annual Equiament Attendant training on INPO Significant Opersting Experience Report (SOER) 85-2 " Valve Mispositioning Events involving Human Error". Changes to the training plan to include discussion of this specific event were completed on February 16,1993.
The appropriate recommendations of SOER 85-2 are being re-evaluated. This re-evaluation will be complete by March 31,1993.
RATEMiiEN FULL CQMELIANCE WILL BE ACHIEVED Zion Station is currently in full compliance.
ZNLD/2172/3
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