ML20038B653
| ML20038B653 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 11/23/1981 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20038B648 | List: |
| References | |
| NUDOCS 8112080466 | |
| Download: ML20038B653 (4) | |
Text
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Commonwealth Edison -
'C'
. ~ One First National Plua, Chicago, Ilknois v
') Address Reply to: Post Office Box 767 j. Chicago, Illinois 60690 November 23, 1981-Mr. James G..Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137.
Subject:
Zion Station Units 1 and 2 IE Inspection Report Nos.
50-295/81-22 and 50-304/81-18 NRC Docket Nos. 50-295/304 References (a):
Oc tobe r. 2 3, 1981 letter from C. E. Norelius to C. Reed 1
Dear Mr. Keppler:
Reference (a) provided the results of an inspection conducted by Messrs. M.
Gildner, J. Peschel, and K.
Connaughton on September 15 and 21-24, 1981 a t Zion.
During that inspection certain activities were found to be not in compliance with NRC requirements.
Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation attached to' reference (a).
It was also requested that we address an NRC concern regarding the threshold for identification of discrepancies to be reviewed and corrected in accordance with our Corrective Action System.
The four Quality Procedures listed in Attachment 8 to this letter constitute Commonwealth Edison's Corrective Action System for operating reactors.
They prescribe -the manner in which appropriate corrective action will be taken for all deficiencies identified as a result of inspections, tests, audits, malfunctions, etc.
They are applicable to items reportable to the NRC but are in no way limited to those items.
Items which must be reported to the NRC constitute a small percentage of the total number handled according to these procedures.
The " dim bulb" circuit design problem identified in reference (a) should have been detected in testing the modification.
Such problems are to be reviewed and corrected in accordance with Quality Procedure 3-51, " Design Control for Operations - Plant Modifications."
Design problems that are not identified during testing but become apparent after the equipment is operational are to be reviewed in accordance.with Quality Procedure 15-52, " Nonconforming Materials Parts and Components for Operations
- Deviations and Comments."
This is the manner in which the circuit 8112080466 811203 PDR ADOCK 05000295 G
- problem was eventuallly handled.
As discussed in Attachment A, steps are being taken to improve the testing of modifications to assure that in the future such problems are identified prior to making modified equipment operational.
To the best of my knowledge and belief the statements contained herein and in the attachrc4.it are true and correct.
In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employes.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Please address any further questions regarding this matter to this office.
Very truly you s,
. it?
L.O.
DelGeorge Director o f Nuclear Licensing Attachment cc:
Zion Resident Inspector SUBSCRIBE 0 and SWORN to before e this JYM day of 1981
~Q w n a.Qn k
~ Notary Puolic 2940N
ATTACHMENT A Response to Notice ' o f Violation Violation 10 CFR 50, Appendix B, Criterion III' states, in 'part,
" Design changes,. including field changes, shall be subject to design control measures commensurate with those applied to-the original i
design and be approved by the organization 'that performed the original design unless the applicant designates another responsible organization".
r Quality Procedure No. 3-51, " Design Control for Operations
- Plant Modifications" assigns specific responsibilities to the Station Nuclear Engineering Marager.
Action ll.b. requires.the l
Station Nuclear Engineering Manager to, " Provide all test criteria.,
i functional descriptions and engineering information necessary to prepare the required test procedures."
1 Contrary to the above, the Station Nuclear Engineering Department (SNED) did not provide test criteria-necessary to insure that testing of circuits af fected by modifications M22-1-80-24 and M-22-2-80-24 would be commensurate with that~ applied to the original design.
Further the station staff did not follow the SNED recommendation that the modified circuits be functionally tested.
j' Corrective Action Taken and Results' Achieved 1
The subject modifications have been independently reviewed by Commonwealth Edison's Station Electrical Engineering Department.
Their evaluation has been oiscussed witn Zion station personnel, Station Nuclear Engineering Department personnel, and others i
r involved in the original modification design.
Wiring changes will be installed and tested during the the scheduled 1982 refueling outages.
During the interim period, the local indicating lamps will be removed.
Corrective Action to be Taken to Avoid Further Noncompliance Station Nuclear Engineering Department will review with the project groups the need to evaluate requirements and specify adequate criteria for testing when a modification is approved for installation.
Written guidance for specification of testing i
criteria will also be developed and made available to these
. engineers.
Date When Full Compliance Will Be Met Discussions with the project groups will be held by December 20, 1981.
Written guidance for the specification of test criteria will be available by January 29, 1982.
2940N 1
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ATTACHMENT B' Quality. Assurance Procedures for Assurance of Corrective Action at Operating Reactors 1.
Quality Procedure 15-51, Nonconforming Materials,' Parts and Components for Operations - Spare Parts
& Materials Scope:
This procedure applies to discrepant items (spares, materials, consumables, parts, and. components) identified during receiving inspection and in Station Stores.
~
2.
Quality Procedure 3 5-52, Nonconforming Materials, Parts and Components for Operations - Deviations and Comments Scope:
This procedure applies to procedures, administrative 4
controls and materials, equipment, components, or parts installed for use which have become operational.
3.
Quality Procedure 15-53, Nonconforming Materials, Parts and Components for Operations - Inspection and Test i
Scope:
This procedure applies to reporting nonconformances of inspection and test requirements for plant equipment.
including its materials, components and parts identified during plant maintenance and testing to declare equipment operable.
l 4.
Quality Procedure 16-51, Corrective Action for Operations -
Corrective Action System Scope:
This procedure applies to the issuance of Action Item i
Records to follow the completion of corrective action resulting from:
1.
Deviation and Reportable Occurrence Reports (Ref. QP 15-52) 2.
Discrepancy Records (Ref. QP15-51 & QP 15-53) 3.
Commitments to the NRC and resulting modifications 4
(Re f. QP 3-51) 4.
Program Review and Audit Deficiencies i
5.
Iter.s and modifications the Station Superintendent considers vital for the operation of the plant (Ref.
QP 3-51) 2940N
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