ML20126G637

Responds to NRC Re Violations Noted in Insp Repts 50-295/92-23 & 50-304/92-23.Corrective Actions:Licensee Will Review All Safety Evaluations for Active Temporary Alterations Installed Prior to 910701

ML20126G637
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	12/31/1992
From:	Kovach T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9301040176
Download: ML20126G637 (5)

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il f' / O_. ?y Crmmtnw:alth 1400 Opus Place -Edison -

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-t December 31,1992 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk

Subject:

Zion Nuclear Power Station Unit 1 and 2 Response to inspection Report 50-295(304)/92023 NRC Rocket.NumbeL50 291and10sj04

Reference:

H. J. Miller letter to Cordell Reed dated December 4,1992, transmitting Inspection Report 50 295(304)/92023.

Enclosed is the Commonwealth Edison Company CECO) response to the subject violations which were transmitted with the referenced (letter and Inspectio One violation concerns the adequacy of a safety evaluation. The other violation concerns the performance of post maintenance testing.

If there are any questions or comments regarding this response, please contact Sara Reece-Koenig, Compliance Engineer, at 708/515-7250.

Sincerely, L Jo/

T.J. Kovach [

Nucloar Licensing Manager Attachments cc: A. Bert Davis, Regional Administrator - Region ill C. Shiraki, Project Manager, NRR J. D. Smith, Senior Resident inspector, Zion l

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RESPONSE TO NOTICE CF VIOLATION - '

NRC INSPECTION REPORT NOS, i 50-295/92023;50-304/92023  ;

- VIOlallOli(295(304)/92023-01) 10 CFR 50.59 (b)(1) requires that records of changes made in the facility as described 1,1 the safety analysis report must include a written safety evaluation '

which provides the bases for the determination that the change does not involve an unreviewed safety question.

Contrary to the above, the 10 CFR 50.59 safety evaluation for temporary alteration 90-053, " Bit Outlet Valve Leakage Reroute to RCDT", dated June 9,1990, was not -

adequate to provide a basis for the determination that this temporary alteration did not involve an unreviewed safety question.

This is a Severity Level IV violation (Supplement 1).

BEASONEOfLTHEJlOLAllON Commonwealth Edison Company (CECO) acknowledges the violation. The safety evaluation performed for Temporary Alteration 90-053 " Bit Outlet Valve Leakage -

Reroute to RCDT" dated June 9,1990 did 'not explicitly state that failure of the rel!ef valve on the leak off line had been considered in review of possible f ailure -

modes for the Temporary Alteration. This safety evaluation was completed on May 14.1990, prior to revision of the safety evaluation training program at Zion in 1991.

Although CECO acknowledges the violation, CECO does not believe that this particular safety evaluation s reoresentative of the quality of safety evaluations currently performed at Zion' Stat on. During the August,1991 Routine NRC Inspection of Design Changes and Modifications (Inspection Reports Nos.

50 295/91014; 50-304/91014), the inspectors singled out the safety evaluations performed for Temporary Alterations for their improved quality. Several 1991-

= safety evaluations were described in this report as " excellent in terms of depth of' safety issues evaluated". .

During the inspection which discovered this violation,- the inspection team _ indicated that while they were not fully familiar with the findings of the 1991 NRC inspection, it was their opinion that the quality of 1991 and 1992 safety evaluations at Zion has been inconsistent. - Since Zion has made significant efforts to impmve in this area and previous feedback from NRC Inspectors has been positive, this statement is of--

concern to CECO. . During the inspection exit, Zion management personnel questioned this observation. The inspectors indicated that no one particular safety evaluation stood out, but that in~a number of evaluations, the detail provided for -

explaining the evaluating engineer's thought process could have been greater.-

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- HESPONSE TO NOTICE OF VIOI.ATION .

NHC lNEPECDON REPORT NOS.

5029C@2023; 50-304/92023 t

CORRECTIVE AGJJONJAKEti ANDJ3ESUlXSACHIEVED An enginwring evaluation wa9 performed on October 2),1902 during the Inspectiort Based on inis evaluation it was detmmined that an unreviewed safety qu9Mion for Temporary Alteration 90-053 did not exist. As indicated in the innpectbn report, this information was shared with the inspectero at that ilme. ,

CORRECTIVE ACTIONJOEEJAXENJOAVOID EUBIUERNIOLATION .

The Zion Statk,n Technical Staff will review all safety evaluations for active bmporary alterations installed prior to July 1,1991. This revlow will be completed.

by May 31,1993.

Although Ceco considors the current quality of Safoty Evaluations performed at Zion S;atbn to be adequate, the Zion Statien Quality Verification department has scheduled an audit which willinclude a review of recent safety evaluations. This review will focus on the quality, cons;stency, and thoroughness of documentation in safoty evalue.tlons performed at Zion since July 1,1991. This audit is scheduled to be performed during the first hah'of 1003.

DATEkVHEftEUllCOMPilANCEWILLDEACHIEVED Full compliance was achloved en October 21,1992 upon completion of the engincoring evaluation.

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L RESPONSE TO NOTICE OF V)OlATION NRC INSPECTIG 4 REPORT NOS.

50-295/92023;!!0 004/t%'023 VIOLATION. (295/92023 03) 10 CFR 50, Appendix B, Greerlon XI, Test Control, states in part, that a test proDram shall be established to assure that all testing required to dernonstrato that structures, systems, and components will perform satisf actorily in service is identitled and performed in accordance with written test procedures.

Contrary to the above, on March 22,1991, adequato testing required to demonstrato that components perform satiefactorily was not performed following maintenance on valve 1MOV RH8701. The maintenance work disabled a valvo interlock which was not verified by post maintenance testing.

This is a Soverity Level IV violation (Supplement I).

REASON EOR 3HEXIOLATION Commonwea;th Edison Com 3any (CECO) acknowledges the violation. Post Maintenance TestinD (PMT)"ollowing maintenance on valve IMOV RH8701 on March 22,1991 was performed. However, this testing was not adequale to fully test the interlock function associated with the valve. The test specified by the Liconned Shift Supervisor (LSS) was Technical Staff Surveillance (TSS) 15.6.115 "MOV RH8701 & 8702 Backloakage Test". In addition to this test, the LSS should have speciflad that Porlodic Test (PT 2C D-ST *ECCS Valve Stroke and interlock Test and ECCS Continuity Test Durin)g Heatup" bo perfortned.

The root cause analysis performed for Zion Station Deviation Report (DVR) 22-1-91-142 determined the root cause of tho interlock failure to be inadequate maintenance. The subject inspection report found that the DVR did not identify as

, a contributor the inadequacy of Post Maintenance Testing following maintenance on 1MOV BH8701. CECO concurs that this contributor should have been identified in the DVR.

. The subject inspection report also indicated that an addit!onal factor contributing to the sl0nificance of the violetkin lo that in July 1992, Imit r, witch maintenance was once again performod on a MOV RH8701 valve whhout the roc ulrement for tho.

interlock test. While the work request in question did not spectly that PT-2C-D ST was required,it did specify performance of "PT 2C". The PT-2C serios of proc 3duros includes in it PT 2C-D ST. The limit switch maintenance in question was performed on July 25,1992 and perfonnance of PT-2C-D ST was completed on July 26,1992 prior to closing out tne work package.

COBRECT1YE ART 10ftIAKEN AN D_S EStJLTS. ACi llEVED A .

On December 29,1991 the limit switches and rotor position for 1MOV RH8701 were adjusted and PT-20 0-ST was performed satisfactorily.

. On Juna 15,1992 the Zion Operability Determination Manual (ZODM) for the Residual Heat Removal System was approved. ' This manual is designed to assist Operating personnelin detemTining the operability status of the system, included in this document are a listing of the applicable tests for determining operability.

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, . RESPONSE TO NOTICE OF VIOLATION NRC INSPECTK)N REPORT NOS.

50-20f:/02023; 60404/92023 CODRECTAYH ACIlONIOEEJAKENIQAVOID.EURTHEILVIOLATION l A letter from the Assistant Supedntendent for Operations (ASO) to all1.lconsed Shift Supervisors revie'aing this violation and corrective actions was issued on Dacomber 31,1992. This letter stressed the importance of conducting proper post

, maintenance testing to ensure operabill!y of affected systems and cources of guidance availab!o negarding PMT requirements.

The Regulatory Assurance Supervisor will review this r> vent with the Station's Root Cause commities. The need to ensure that all contributing causes are identiflod beforo an investigation to accepted as complete will be stressed. This review will be completed by January 31,1993.

DATE_WHEN EULLCOMPLIANCE WILL BE ACHIEVfiO Full compliance was achieved on Doc 9mber 29,1991 with the satisfactory completion of PT 2C D ST.

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