ML20137L943

Responds to NRC Re Violations Noted in Insp Repts 50-295/85-36 & 50-304/85-38.Corrective Actions:Onsite Review Prepared to Define ESF Components & Listing of ESF Components Will Be Used to Determine Reportability

ML20137L943
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/08/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1033K, NUDOCS 8601280146
Download: ML20137L943 (3)

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^N Commonwealth Edison f One First National Pizza. Chicego. litinois O' Address Riply to: Post Office Box 767 Chicago, lltinois 60690 January 8, 1986 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. 50-295/85-036 and 50-304/85-038-NRC Docket Mos. 50-295 and 50-304

Reference:

M. J. Chrissotimos letter to Cordell Reed dated December 10, 1985

Dear Mr. Keppler:

• This letter concerns the routine safety inspection of activitics at Zion Station conducted on October 8 through November 18, 1985 by M.M.

, Holzmer, L. E. Kanter, and J. N. Kish. 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 truly yours, l

l D. L. Farrar i Director of Nuclear Licensing i 1m Attachment i

ec: NRC Resident Inspector - Zion i

8601280146 860108 PDR ADOCK 05000295 G PDR i 1033K

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ATTACHMENT ZION NUCLEAR POWER STATION UNITS 1 AND 2 RESPONSE TO NOTICE OF VIOLAiI_0_N(

ITEM OF NONCOMPLTANCE As a result of the inspection conducted on Octolar 8 through November 18, 1985 and in accordance with the General Policy and Procedures for NRC Enforcement Actions (10 CFR Part 2 Appendix C), tt.) following.

violations were identified:

10 CFR 50.72(b) stater in part, "(2) . . . the licensee sh.tli 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 (ESP). . . ."

Contrary to the above, the licensee failed to notify the NRC within four hours of the occurrence for the following ever.t.

a) The ESF actuation on October 10, 1985, when Unit 2 containment purgo valves shut from a spike on the radiation monitor, 2RIA-PR40. A required four hourz ENS telephone verificaiton was not made until approximately 22.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the event.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:

To ensure that the requirement to make an ENS 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 shif t Supervisors, the Assistant Superin-tendent Operations held discussion sessions with all Shift Supervisors to clarify the rule and remove any misunderstandings. The discussions with the shif t 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 Shif t 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.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION:

An On-Site review has been prepared to define the ESF components and a listing of those components has been included for the use of Shift Supervisors in evaluating events to determine reportability under 10 CFR 50.72.

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l The recent heightened emphasis on the ESF actuation reporting l requirements will insure that these events are identified as they occur and

that they will be reported in accordance with 10 CFR 50.72.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

The station is in full compliance at this time. Implementation of 4

the on-site review of a list of ESF components as identified by the Zion FSAR has been held off at the request of the NRC Resident Inspector. Discussions are planned for January 16, 1986 between Zion Station, Commonwealth Edison Licensing Department Zion Resident NRC Inspector, and Region III NRC Office

! regarding the Zion ESF list as it appears in.the Zion FSAR.

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