ML20137M422

Responds to NRC Re Violations Noted in Insp Repts 50-295/85-20 & 50-304/85-21.Corrective Actions:Relief Valve 1CC9428 Identified as Source of Leak & Isolated.Valve Restoration line-up Segment of TSS 15.6.96.23-1 Reviewed

ML20137M422
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	08/28/1985
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
0566K, 566K, NUDOCS 8601280270
Download: ML20137M422 (3)

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[,O N Commonwealth Edison ons First N;tionti Plus Chicago, litinois F k O 7 Address Reply to: Post Office Box 767 ,

/ Chicago, Illinois 60690 -l August 28, 1985 l Mr. James G. Keppler

Regional Administrator U.S. Nuclear Regulatory Commission Region III

799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Zion Nuclear Power Station Units 1 and 2 Inspection Report Nos. 50-295/85-20 and 50-304/85-21 i

Reference:

July 30, 1985 letter from C. E. Norelius to Cordell Reed.

Dear Mr. Keppler:

This letter is concerned with the results of a routine safety inspection conducted by F. R. Dunaway, M. M. Holzmer, L. E. Kanter, and J.  :

N. Kish of your office. This inspection involved the activities at Zion Station from May 30, 1985 through July 1,-1985. The referenced letter indicated that certain activities appeared to be in violation with NRC requirements. Commonwealth Edison Company's response to the Notice of Violation is contained in the attachment to this letter.

The referenced letter also expressed concern regarding two recent 4

changes to the facility in which changes to the Technical Specifications were not obtained prior to implementation. While these two instances, station reorganization and RCFC modification, may appear to nave involved l, variations from established processes, Commonwealth Edison Company feels that both issues have been handled appropriately. These items are discussed separately below.

The management reorganization was coordinated by Commonwealth Edison upper corporate management. The changes required a substantial degree of confidentiality during the planning stages. Thus, it was difficult to request Technical Specification changes that reflected these pending personnel moves and still ensure the orderly implementation of the new structure.

Region III upper management was briefed on the pending changes prior to their implementation.- Commonwealth Edison Company intends to continue this practice to ensure continued good communication with Region III management. ~ Also the structure of any pending moves will be discussed j as early in the process as possible.

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I J. G. Keppler August 28, 1985 In addition, a Technical Specification change request incorporating the new structure was prepared and submitted in a timely manner. This amendment request was submitted on June 25, 1985.

With regard to the issue of the RCFC modification, the Commonwealth Edison Corporate Quality Assurance Manual assigns the responsibility to the Station Nuclear Engineering Department (SNED) for the performance of the safety evaluation required by 10 CFR 50.59. This includes a determination of whether the proposed modification involves a change to the Technical Specifications.

SNED performed the required reviews and determined that the modification to the RCFCs did not require a' change to the Technical Specifications. This determination, which included an evaluation of the af fected Technical Specification sections, was documented in the required Modification Approval Letter dated Januar- 28, 1985. This was approximately five months prior to the unit startup.

In addition, Commonwealth Edison Company's treatment of this modification was discussed on May 31, 1985 in a telephone conversation between P. C. LeBlond (CECO) and J. A. Norris (NRC/NRR). Mr. Norris concurred with the handling of the RCFC modification.

If any further questions arise concerning these matters, please ,

direct them to Commonwealth Edison's Nuclear Licensing Department.

Very truly yours, L. O. DelGeorge-Assistant Vice President im Attachment cc: NRC Resident Inspector - Zion J. A. Norris - NRR 0566K 6

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I ATTACFNE'N T ZION NUCLEAR POWER STATION UNITS i and 2 RESPONSE TO NOTICE OF VIOLATION ITEM OF NONCOWLIANCE:

10 CFR 50, Appendix B, Criteria V, states in part, " Activities affecting quality shall be prescribed by documented instruction, procedures, or drawings, of a type appropriate to the circumstances...."

Contrary to the above:

Technical Staff Surveillance (TSS) 15.6.96.23-1, Appendix C was inappropriate in that it did not contain instructions to return valve ICC9499 to its normal operating status (CLOSED) as specified in the System Operating Instruction (SOI)-6. Failure to return this valve to its normal operating status resulted in lifting relief valve ICC9428 and spilling approximately 6,000 gallons of component cooling water on the containment floor.

CORRECTIVE ACTION TAKEN APO RESULTS ACHIEVED The relief valve ICC9428 was identified as the source of the leak and isolated. The valve restoration line-up segment of TSi 15.6.96.23-1 was reviewed against the latest revision of the (S01)-6 and it was determined that valve ICC9499 should have been in the (CLOSED) position. Valve ICC9499-was closed and the valve restoration line-up is being revised to coincide with the latest revision of (SOI)-6.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOW LIANCE To avoid further noncompliances two corrective actions are currently being undertaken. First, the TSSs which require a valve line-up are being changed to reflect the latest revision of the SOIs. The Technical Staff Engineer performing the test must verify that the valve restoration line-up coincides with the latest revision of the SOIs before proceeding with the test. The changes to the TSSs are to be completed before they are performed during the Fall 1985 Unit 2 outage.

Second, Zion Administrative Procedures ZAPS which control procedure writing and content will be changed to require the use of the latest valve line-up revision in all future procedure changes or original procedures.

DATE WHEN FULL COPLIANCE WILL BE MET The-applicable TSSs and ZAPS will'be revised by September 30, 1985.

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