ML20054J719
| ML20054J719 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 06/09/1982 |
| From: | Douglas E COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20054J708 | List: |
| References | |
| 4298N, NUDOCS 8206290488 | |
| Download: ML20054J719 (3) | |
Text
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Ccmm::nwasith Edisan one First National Plaza. Chicago, lltinois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 Jun e 9, 1982
)
Mr. Jame s G. Keppler, Regional Administrator Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Roa(1 Glen Ellyn, IL 60137
Subject:
Zion Station Units 1 and 2 Response to I.E.
Inspection Report Nos. 50-295/82-03 and 50-304/82-03 NRC Docket Nos. 50-295 & 50-304 Reference (a):
J.
G. Keppler letter to Cordell Reed dated May 10, 1982.
Dear Mr. Keppler.
Reference (a) contained the results o f an inspection conducted by Mr. K.
A.
Connaughton of your of fice on January 15 and 19, 1982, o f activities at Zion Station.
During that inspection, certain activities appeared to be in noncompliance with NRC require-ments.
The Attachment to this letter provides the Commonwealth Edison Company response to this Notice o f Violation.
To the best of my knowledge and belief, the statements con-
~
tained in the Attachment and are true and correct.
In some respects these statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison employees.
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 yours, f.0a 7 --
E.
Douglas Swartz Nuclear Licensing Administrator 1m Attachment cc:
Region III Inspector - Zion SUBSCRIBED and SWORN to before me this kpl day of b;
1982 4
Notary Public 3t110 N
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8206290498 B20625
{DRADOCK05000 4298N
o ATTACHMENT COMMONWEALTH EDISON COMPANY ZION STATION UNITS 1 and 2 Response to Notice o f Violation Items o f Noncompliance 10 CFR 50.59 states, in part:
The licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that such changes constitute j
changes in the facility as described in the safety analysis report or constitute changes to procedures as described in the safety analysis report.
These records shall include a written safety evaluation which provides the bases for determination that the proposed change does not involve an unreviewed safety question.
10 CFR 50, Appendix B, Criterion V states, in part:
Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instruction, procedures, or drawings.
Contrary to the above:
The licensee changed the low suction pressure trip switch setpoints for the IC, 2A, 28 and 2C auxiliary feedwater pumps without following prescribed procedures (Zion Administrative Procedure ZAP 3-52-1) and without performing required written safety evaluations.
As a result of this violation, on November 26, 1981, the 28 and 2C auxiliary feedwater pumps were discovered to trip on low suction pressure following a manual start with discharge flow throttled to 100% of design flow.
The ability to pass surveillance (operability) tests was unimpaired.
Remedial action was taken within Technical Specification Action Statement time limits.
Corrective Action Taken and Results Achieved TFe low suction pressure switch trip setpoints for the 1C, 2A, 2B and 2C auxiliary feedwater pumps were restored to their original I
setting the same day the problem was discovered (Novemeber 26, 1981).
The low suction pressure switch trip setpoints for the 1A and 18 auxiliary feedwater pumps were also checked and found to be set correctly.
All calibration data sheets for the auxiliary l
feedwater pump suction pressure switches were returned to their original values.
In addition, a memorandum was circulated to all Instrument Maintenance department management personnel to ensure that each individual was aware of the problem which occurred.
The memorandum further amplified that there are no provisions in the-
4 " Change of Instrument Setpoint" procedure (ZAP 3-52-1) which allows a setpoint to be. changed without a completed setpoint change form, even if the change is in the conservative direction.
All Instrument Maintenance department management personnel were also required to review Z AP 3-52-1 titled " Change o f Instrument Setpoint", and an entry was made in their training file to reflect this.
Corrective Action to be Taken to Avoid Further Noncompliance The scope o f Zion Administrative Procedure Z AP 3-52-1, titled
" Change o f Instrument Setpoint", will be expanded to cover changes of safety related instrument scaling (which includes range changes, and changes in gains, biases, and lead / lag settings).
Date When Full Compliance Will be Met The licensee is in full compliance at the present time.
Th e procedure change to ZAP 3-52-1 described above will be completed by
. August 1, 1982.
4298N