ML20059E963
| ML20059E963 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/06/1994 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9401130087 | |
| Download: ML20059E963 (4) | |
Text
i
. T Commonwealth Edison
- f A i 1400 Opus Place
'V Downers Grove. ilhnors 60515 January 6,1994 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk Subject Brent Clayton letter to R. Tuetken dated December 7,1993 transmitting i
Notice of Violation (NOV) in NRC Inspection Report 50-295(304)/93020.
NRC Docket Numbers 50-295 and 50-304 Enclosed is the Commonwealth Edison response to the subject Notice of Violation (NOV).
The NOV cites one Severity Level IV violation with two examples; failure to maintain one Emergency Diesel Generator operable or to suspend fuel movement, and the failure to clear an Out of Service within the administrative limits.
If you have any questions or require additionalinformation, please feel free to contact Marcia Jackson, Regulatory Performance Administrator at (708) 663-7287.
Respectfully, h
Dennis Farrar Nuclear Regulatory Services Manager I
cc:
J. B. Martin, Regional Administrator, Rill C. Y. Shiraki, Project Manager, NRR J. D. Smith, Senior Resident, Zion Station k.' v.vmr.p'ppsJacnwic93020 wpl j '" N 4d113OOB7 940106 I
/d PDR ADOCK 05000295
/
D I
G PDR Q
j
i VI,OLATION: 295(304)/93020-01 A/B l
During an NRC inspection conducted on October 12 through November 23,1993, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions",10 CFR Part 2, Appendix C (1993), the violation is listed below:
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 components involving nuclear safety to the facility shall be prepared, implemented, and maintained.
Zion Administrative Technical Specification 3.15.1 requires that fuel movements be suspended if all emergency diesel generators to a unit are inoperable.
Zion Administrative procedure 300 06A " Returning Equipment to Service" requires that, upon completion of work, the out-of-service cards be removed before the activity is cleared in the outage editor and before closing out PT-14 " Inoperable Equipment Surveillance Tests" Contrary to the above:
A.
On November 3,1993, removal of fuel from the Unit 1 reactor vessel was not suspended when all Unit 1 emergency diesel generators were rendered inoperable due to the isolation of service water to the generators.
d B.
Although an out-of-service for residual heat removal valve 1MOV-Sl8804A, was clearcd in the outage editor on August 25; the PT-14 was closed on i
August 27 and the out-of-service cards were not removed until August 30.
This is a Severity Level IV violation (supplement 1).
VIOLATION: 295(304)/93020-01 A 11EASONS FOR THE VIOLATIOR (EXAMPLE A) i The reason for the violation is apparently ineffective work performance from the Licensed Shift Supervisor (LSS) and the Out-of-Service (OOS) Team Leader.
These performance problems resulted in a failure to adhere to established Zion Station work practices and procedures.
At approximately 1455 on November 3,1993, without reviewing the current protected path configuration or the OOS paperwork, the LSS directed two "A" men to close service water valve OMOV-SW0008. Contrary to Administrative Technical Specification 3.15.1, this rendered both 1 A and 1B EDG's inoperable. The OOS Team Leader requested that the LSS attempt to accelerate the work to isolate the l
ss rvice water system to 18 diesel while he sought approval from Site Engineering t close the OMOV-SW0008 valve which
vias controlled under a separate OOS. Accelerating the schedule to isolate service water to 1B diesel without seeking the appropriate approval from the Outage Planning Coordinator and the closing of OMOV-SW0008 without the appropriate review and concurrence of Site Engineering, are not work practices acceptable to Zion Station. These poor work practices rendered both emergency diesel generators inoperable.
l C_QBilECIIVEJlEPSlaKEILAND_flESMLIS AClilEVER (EXAMPLE A)
At 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> on November 3,1993, OMOV-SW0008 was manually opened. It was further determined that Unit 1 was defueled at 1549 and the Unit was no longer in Technical Specification controlled mode. Therefore, the unit 1 was in violation of technical specification 3.15.1 for approximately 54 minutes.
The Licensed Shift Supervisor and OOS Team Leader involved in this event have been counselled regarding the importance of clear and concise communications.
Meetings were held with the operations crew to cover this event and to stress the need for clear and concise communications.
The Outage Planning Coordinator issued a letter to the Operations Department and appropriate work groups in other departments notifying personnel that all schedule changes must be reviewed and approved by the outage planning coordinators.
As a corrective action for this event, and as part of Zions programmatic efforts to reduce shutdown risk, placards were placed on the control boards, in the ESF Bus rooms, and on key equipment in the field to ensure that protected paths are clearly and easily identified.
C_QBBECTIVE SlEP_S TO BE_IAKEN TO_A_V_QJD FURTHER VIOLATIONS j
(EXAMPLE A)
The Assistant Superintendent of Operations will reinforce performance standards regarding the OOS Program to all Licensed Shift Supervisors. This action will be completed by March 31,1994.
DATE WHEN_EULL COMELIAliCE_WJLLJE_ACHl.E_VEQ (EXAMPLE A)
Zion Station was in full compliance on November 3,1993 when when Unit 1 was defueled.
1
- - ~_
... -.._~
Violation 295(304)/93020-018 REASOMS FOR THE VIOLATION (EXAMPLE B)
The reason for the violation is a management deficiency because an effective method of verifying the status of OOS's associated with the Inoperable Equipment Surveillance Test (PT-14) was not procedurally implemented.
l Two contributing reasons for this violation were identified. First, no existing mechanism required the expeditious return of the OOS paperwork associated with an administrative LCO time clock. A second contributing reason was that the shiftly control board walkdowns did not challenge the presence of the OOS card on 1MOV-Sl8804A and failed to identify that it was a problem.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED (EXAMPLE B)
P The OOS on 1MOV-Sl8804A was cleared at 0740 on August 30,1993.
A Licensee Event Report was issued on September 29,1993.
The Master Electrician has counselled the Electrical Maintenance Supervisor on the importance of clearing OOS paperwork as soon as a job has been completed.
CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS (EXAMPLE B)
Surveillance procedure PT-14 will be revised to require a second confirming method of verifying that the applicable OOS's have been cleared.
The Work Planning Department will develop a method for verifying and tracking the status of all work associated with LCO's.
I ie Assistant Superintendent of Operations will review and clarify expectations on the performance of control board walkdowns.
DATli WHENllLLL COMPLIANCE WILL BE ACHIEVED (EXAMPLE B)
Surveillance procedure PT-14 will be revised by April 30,1994.
The verification and tracking mechanism for work associated with LCO's will be implemented by April 30,1994.
The Assistant Superintendent of Operations will complete the review and clarification of performance standards for control board walkdowns by March 31, 1994.
Zion Station will be in full compliance by April 30,1994.
U e,e.e
,r,.*
,m--~
s---,
- + -,, -,.
va~
-we
,em---
s w--e1 v-,'