ML20137L809

Responds to NRC Re Violations Noted in Insp Repts 50-295/85-31 & 50-304/85-32.Corrective Actions:Discussions Held W/Shift Supervisors to Ensure Understanding That Notification Must Be Given within 4 H of Occurrence

ML20137L809
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	12/05/1985
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8601280094
Download: ML20137L809 (3)

Text

'

o. , N Commonwe:lth Edison

/ 2 First National Plaza Chicago lihnom k

)] ong Address Reply to Post Othee Box 767 (j/ Chicago, l!linois 60690 December 5, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL. 60137

Subject:

Zion Station Units 1 and 2 Response to Inspection Report Nos. 50-295/85-031 and 50-304/85-032 NRC Docket Nos. 50-295 and 50-304

Reference:

N. J. Chrissotimcs letter to Cordell Reed dated November 8, 1985

Dear Mr. Keppler:

This letter concerns the routine safety inspection of activities at Zion Station conducted on September 4 through October 7, 1985 by M.M. Holzmer, L. E. Kanter, J. N. Kish, and R. A. Hasse. The referenced letter indicated that certain activities appeared to be in noncompliance with NRC requirements.

Commonwealth Edison Company's response to the Notice of Violation is provided in the Attachment to this letter.

If you have any further questions on this matter, please direct them to this office.

Very t ly yours,

_a - _1 ,

D. L. Farrar Director of Nuclear Licensing Attachment cc: NRC Resident Inspector - Zion 8601280094 851205 0969K PDR ADOCK 05000295 G pDn DEc 6 35

%Est' \

t s_

ATTACHMENT ZION NUCLEAR POWER STATION UNITS 1 AND 2 RESPONSE TO NOTICE OF VIOLATION ITEM OF NONCOMPLIANCE As a result of the inspection conducted on September 4 through October 7, 1985 and in accordance with the Ceneral Policy and Procedures for NRC Enforcement Actions (10 CFR Part 2. Appendix C), the following violations were identified:

1. 10 CFR 50.72(b) states in part, "(2) . . . the licensee shall notify the NRC as soon as practical and in all cases, within four hours of the occurrence of any of the following:

(ii) Any event or condition that results in manual or automatic actuation of any engineered safety feature (ESF). ...

2. 10 CFR 50.73(a) states in part, "(1) The holder of an operating-license for a nuclear power plant (licensee) shall submit a Licenseo Event Report (LER) for any event of the type described in this paragraph within 30 days after the discovery of the event . . . (2) The licensee shall report. . . .

(iv) Any event or condition that resulted in manual or automatic actuation of any Engineered Safety Feature (ESF). ...

Contrary to the above,

1. The licensee failed to notify the NRC within four hours of the occurrence for the following two events:

a. The ESF actuation on August 2, 1985 when all three Unit 1 PP air compressors auto started. A four hour ENS telephone notification was made-on August 30, 1985.

b. The ESF actuation on September 9, 1985 when Unit 2 containment purge valves were inadvertently shut when the jumpers were removed from the purge valve circuitry. A four hour ENS telephone notification was made approximately seven hours after the event occurred.

2. The licensee failed to eubmit an LER within 30 days for the following two events:

a. .The ESF actuation on May 27, 1985 when an improper sequence of operations resulted in an inadvertent closure of several Train A Containment Isolation Valves. A Deviation Report reclassification j was submitted October 7, 1985, and an LER will follow.  !

l

b. The ESF actuation on August 2, 1985 when all three Unit 1 PP air I compressors auto started. An LER was submitted on September 10, 1985.

I t'

,o *

• Corrective Action Taken and Results Achieved:

To insure that the requirement to make an KNS notification within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was fully understood by all Shift Supervisors, the Assistant Superinten-dont Operations hold discussion sessions with all Shift Supervisors to clarify

.the rule and remove any misunderstandings. The discussions with the Shift-Supervisors have emphasized a conservative approach which will result in reporting actuation of any ESF or ESS component unless it is part of a preplanned sequence. A follow up memo was also sent to all Shift Supervisors and Shift Overview Superintendent's (SOS) to restate our conservative approach to this reporting requirement until additional guidance can be given to the shift in the form of an On-Site Review and list of components-which will fall under this reporting requirement.

The immediate corrective action in the case of May 27, 1985 closure of several containment isolation valves was to reclassify the event to reportable on Oct. 7, 1985 after extensive discussions with the resident NRC inspectors. In the case of the auto start of the PP air compressor as soon as it was recognized that this event was reportable it was so classified and a Licensee Event Report was processed.

Corrective Action to be taken to avoid further violation:

An On-Site review is being prepared to define the ESF components and a listing of those components will be included for the use of Shift Supervisors in evaluating events to determine reportability under'10CFR50.72.

The recent heightened emphasis on the ESF actuation reporting requirements will insure that these events are identified as they occur and that they will be reported in accordance with 10CFR50.72 and'50.73. In addition to this Zion's recent reemphasis on root cause analysis and depth of review will help identify errors in classification early enough to reclassify them and make the required report within the required time.

Date when full compliance will be achieved:

The station is in full compliance at this time. The On-Site Review defining the ESF components will be completed by December 20, 1985.

0969K

[