ML20035A745
| ML20035A745 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 03/24/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9303290240 | |
| Download: ML20035A745 (3) | |
Text
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ON Ccmm:nwn:lth Edison
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l / 1400 Opus Place v' ' Downers Grove, lifinois 60515
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l March 24,1993 i
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US Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk
Subject:
Zion Nuclear Power Station Unit 1 and 2 Response to inspection Report 50-295/92035; 50-304/92035 NRC Docket Numbers 50-295 and 50-304
Reference:
' B. Clayton letter to L. DelGeorge dated February 23.1993 transmitting inspection Report Nos.
50-295/92035; 50-304/92035 Enclosed is the Commonwealth Edison Company (CECO) response to the Notice of Violation (NOV) which was transmitted with the reference letter and Inspection Report. The NOV cited one Severity Level IV violation related to the failure to meet the minimum ANSI qualification for an instrument Maintenance i
Supervisor. CECO's response is provided in the attachment.
If your staff has any questions or cornments regarding this response, please -
refer them to Marcia Jackson, Compliance Administrator, at (708) 663-7287.
Respectfully, k2Q D.L. Farrar Nuclear Regulatory Services Manager MJ:scl:typg 4-6 Attachment l
cc:
A.B. Davis, Regional Administrator-Rill J.D. Smith, Senior Resident inspector-Zion C. Shiraki, Project Manager-NRR i
9303290240 930324 PDR ADOCK 05000295 G
PDR rGo /
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y RESPONSE TO NOTICE OF VIOLATION i
l NRC INSPECTION REPORT NOS. 50-295/92035; 50-304/92035 I
i l-VIOLATION 4
l 10 CFR 50.9 requires that information required by statute, or the Commission's L
regulations, orders, or by license conditions to be maintained by the licensee shall be complete and accurate in all material respects.
Technical Specification 6.5.2.J requires that records relative to the training and
-l qualification for current members of the station staff be main;ained for the duration l
of the Operating License.
Contrary to the above, on May 20,1991, certification records relating to the-qualification of an instrument mechanic supervisor contained inaccurate information on the work experience of the subject supervisor. Specifically, credit was given for.
l a full two years experience while a fluid systems engineer when the individual had only worked 20 months, and credit was given for one full-year of experience while a research assistance when the individual had only eight months experience (295/92035-01(DPRP); 304/92035(DRP).
This is a Severity Level IV violation (Supplement IV).
REASON FOR THE VIOLATION Commonwealth Edison Company (CECO) acknowledges the violation. Inattention to detail by station personnel resulted in the erroneous crediting of eight months of l
experience to an Instrument Maintenance Supervisor. CECO believe's however, that j
the significance of this violation is substantially mitigated when facts surrounding the document in question are considered.
I Specifically, the ANSI qualification requirements for the position of instrument Maintenance Supervisor., as delineated by ANSI N18.1-1971 section 4.3.2, are a high school diploma and four years (48 months) of applicable experience. The document in question indicated that at the time of his appointment, the individual concerned had a Bachelor of Science degree in Nuclear Engineering from the University of Illinois and five and a half years (66 months) of applicable experience.
When the eight months identified in the violation as being erroneously credited are subtracted, the total applicable experience is 58 months, which is 10 months in excess of the ANSI requirement.
As can be seen above, the applicable experience accumulated by the individual concerned easily met the ANSI requirements. The instrument Maintenance
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department head, who reviewed the document prior to submission to the Station Manager.for approval, did not identify the rounding-off of the experience time as a i
concern since the total for the exact numbers was well in excess of the required minimum.
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RESPONSE TO NOTICE OF VIOLATION l
NRC INSPECTION REPORT NOS. 50-295/92035; 50-304/92035 (Continued)
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED j
On October 22,1991, Zion Administrative Procedure (ZAP) 5-51-19 (now ZAP 200-06) was approved. This procedure titled " Personnel Qualifications". includes a requirement for each CECO employee at Zion Station to have on file a Personnel i
History, Education, and Experience Resume. In addition, it also requires that prior to promotion or transfer into an ANSI designated position, both the cognizant department head and the Quality Control department will verify that the individual meets the pre-requisites for the position as set forth in ANSI N18.1-1971. The i
addition of the Quality Control department to the review process provides a critical j
and independent evaluation of the individual's qualification to the ANSI standard.
A memorandum from the Human Resources Supervisor to all department heads, emphasizing the above requirements of ZAP 5-51-19, was issued on August 18,
-l 1992.
i Personnel responsible for the preparation and review of the document in question were made aware of the importance of attention to detail with regard to the documentation of qualifications required by Technical Specifications and the ANSI 1
N18.1-1971 standard.
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l CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER VIOLATION i
A station experience report describing this violation and corrective actions will be issued for review by all department heads and departmental training coordinators i
by May 31,1993.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Zion Station is currently in full compliance.
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