ML20058H994
| ML20058H994 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 07/16/1982 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20058H989 | List: |
| References | |
| 4539N, NUDOCS 8208090132 | |
| Download: ML20058H994 (4) | |
Text
- - - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _
N Commonwealth Edison f
O
/ One First Nationit Pitza. Crucago, !!hnois 7 Addrzss R: ply to: Post Offica Box 767 I
s
,\\
j' Chicago, Illinois 60690 July 16, 1982 Mr. James G. Keppler, Regional Administrator 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 Response to I.E.
Inspection Report No. 50-295/82-08 NRC Docke t No. 50-295 Reference (a):
June 18, 1982, letter from C. E. Norelius to Cordell Reed.
Dear Mr. Keppler:
Re ference (a) contained the results of an inspection conducted by Mr. W. J. Key o f your of fice on March 3-5, 8-12, 17, 18, 22, 23, 25, 31, April 1-5, and May 19, 1982, o f activities at Zion Station.
During that inspection, certain activities appeared to be in noncompliance with NRC requirements.
The Attachment to this letter provides Commonwealth Edison's response to the Notice o f Violation.
To the best o f my knowledge and belief, the statements con-tained in the attachment are true and correct.
In some respects these statements are not based on 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 further questions regarding this matter to this Very truly yours, L. O.
DelGeorge Director of tOclear Licensing Attachment cc:
Zion Resident Inspector SUBSCRIBED and SWORN,to before me this
//o N. day af
/)6 /z t-1982 4A lN; 0 -
O M
Notary Public VUL 10 tw 4539N 8208090132 820804 i
PDR ADOCK 0500029S o
pg
1 ATT AC HMEN T COMMONWEALTH EDISON COMPANY ZION STATION UNITS 1 and 2 Response to Notice o f Violation 10 CFR 50, Appendix 8 Criteria V states in part that, " 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 instructions, procedures, or drawings.
Technical Specification Section 6.2. A s tates in part that, "De tailed written procedures.....shall be prepared, approved and adhered to for preventative and corrective maintenance operations which could have an affect on the safety of the facility."
The licensee 's Topical Report CE A, Revisi.on 20, Section 2.2, commits to the Regulatory Position of Regulatory Guide 1.39 - 3/73 which endorses ANSI N45.2.3-1973.
ANSI N45.2.3-1973, Section 2.1 states, for zones I, II and III, a written record of the entry and exit of all personnel and materials shall be established and maintained.
Westinghouse Electric Corporation Procedure MRS 2.2.2 Gen-2, Revision 3, Section 2.0 states, " Nozzle covers are used to prevent foreign materials from entering the primary loop during the performance o f in-channel head work."
Section 3.0 states, "It shall be the responsibility of the job coordinator or platform supervisor to insure that the temporary nozzle covers are installed and removed properly..."
Westinghouse procedure MRS 2.2.2 Gen-6, Revision 4, Section 3.2.1, states, "The utility shall designate a responsible representative to accompany the coordinator on an inspection tour of the work area to view first hand conditions of the area prior to signing the process control sheet."
Section XII o f the process control sheet contains sections for signof f by (W) and the utility for removal of nozzle covers.
Contrary to the above, during the 1981 eddy current examination o f s team generators, performed by CONAM, no material accountability procedures for materials and tools entering the system were in use, nor was there surveillance by the QC department of activities when the steam generator was open.
This failure to follow procedures resulted in a nozzle cover being left in the ID steam generator which damaged the tube ends extending through the tube sheet.
In addition, on March 17, 1982, during observation of tubes being marked for plugging, the inspector noted that the nozzle cover had not been installed as required by procedure MRS 2.2.2 Gen-2 in the cold leg of steam generator IC while tools and equipment were inside and in use.
l L-
. Corrective Action Taken and Results Achieved Daring the 1982 Unit 1 refueling outage, Zion's Quality Control Depart-ment (QC) increased the number o f surveillances and personnel involved in monitoring the steam generator work.
Cover screens were fabricated to go in place of the manway covers.
Each had a sign attached stating that QC must be notified befcre removing.
By doing so, administrative control was maintained over all entries into the channel head.
Many of the steam generator entries were viewed by QC by means o f a video camera.
All logs of equipment taken in and out of the channel head were monitored shif tly, and nozzle cover integrity was verified shiftly.
Procedures were re-reviewed and additional QC instruction (hold point information) was added to make clear that QC was to perform the final channel head inspections prior to close-up.
By these measures Zion was able to account for all nozzle covers used by both Westinghouse and CECO and monitor the equipment and tools taken into the channel head.
Corrective Action to be Taken to Avoid Further Noncompliance A station procedure will be written to govern the control of personnel, tools, and equipment entering the reactor coolant system and the steam generator channel heads in particular.
The procedure is envisioned to cover, as a minimum, the following controls:
QC will be present when the manway covers are removed and will assure that the cover screens or venting equipment are placed over the manway openings until such time as the nozzle covers are installed.
Cover screens will be in place over the manway openings when work is not being performed.
Personnel and tool accountability logs will be required for entry into the channel head.
Each nozzle cover will be permanently identified with a number.
This number will be used to show which nozzle cover was installed in a given steam generator.
A steel cable (lanyard) will be attached to each nozzle cover and an appropriate structural member outside of the steam generator.
This will ensure the nozzle cover is secure and minimize the possibility of the lanyard breaking, should the nozzle cover be upset in the channel head.
Upon job completion, a f ter the contractor and licensee representative have verified removal of parts and tools, QC will make the last channel head entry for a cleanliness inspection and remove the nozzle Covers.
1
. Date When Full Compliance Will' be Met Additional controls were immediately established during the 1982 Unit 1 refueling outage to increase tool, equipment, and-nozzle cover cccountability.
The licensee will be in full compliance by November 1, 1982, following the completion of the control procedure and hardware revisions to the nozzle covers.
4539N