ML20149H785
| ML20149H785 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/23/1994 |
| From: | Tuetken R COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9412290263 | |
| Download: ML20149H785 (3) | |
Text
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Zion Generating Station 101 Shiloh Blvd.
Zicm,lilinois 60099
. Telephbne 708 / 746-2084 December 23,1994 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn:
Document Control Desk
Subject:
Zion Nuclear Power Station Units I and 2; NRC Docket Numbers 50-295 and 50-304; NRC Inspection Report Number 50-295/94020; 50-304/94020
Reference:
J. M. Jacobson letter to R. P. Tuetken dated December 2,1994 transmitting Notice of Violation Enclosed is the Commonwealth Edison (Comed) response to the Notice of Violation (NOV) transmitted in the referenced letter and discussed in the subject inspection report. The NOV cites one Severity Level IV violation in which changes in the design basis difTerential pressure discussed in the Updated Final Safety Analysis Report Section 6.3.2.2.5 and Table 6.3-11 did not receive a written safety evaluation and were not documented as a change in the facility.
if you have any questions or require additional information, please contact Goran Stojkovich, Regulatory Compliance Engineer, at (708) 746-2084, extension 2009.
Sincerely, b
R.
. Tuetken Site Vice President Zion Station cc:
J.13. Martin, Regional Administrator, Region til C. Y. Shiraki, Zion Project Manager, NRR J. R.. Roton, Senior Resident inspector, Zion Station g
j 9412290263 941223 PDR ADOCK 03000295 O
r-A'lTACIIMENT Notice of Violation Response VIOLATION: 295(304)/94020-01 10 CFR 50.59(2)(b)(1) states, in part, that the licensee shall maintain records of changes in the facility and of changes in the procedures made pursuant to this section, to the extent that i
these changes in the facility are as described in the safety analysis report. These records 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, changes in the design basis differential pressures discussed in the Updated Final Safety Analysis Report Section 6.3.2.2.5 and Table 6.3-11 have not received a written safety evaluation and have not been documented as a change in the facility.
This is a Severity Level IV violation.
REASONS FOR THE VIOLATION Comed acknowledges the violation.
The reason for the violation is management deGeiency. Some Motor Operated Valve (MOV) design changes performed subsequent to 1991 relied on input provided by the MOV Program engineers using MOV design basis input parameters. Results of the design basis input parameter review were not reconciled with the Updated Final Safety Analysis Report (UFSAR).
UFSAR Table 6.3-11 identined that certain MOVs were designed to operate at a differential pressure equal to reactor coolant system (RCS) pressure,2750 psid. In 1991, MOV design basis input parameters, which were on site reviewed (OSR), indicated that the actual design differential pressures were lower than those described in Table 6.3-11. This information was not reconciled with UFSAR Section 6.3.2.2.5 or Table 6.3-11. The safety evaluations for a number of Generic Letter 89-10 and MOV motor brake removal modifications performed subsequent to 1991 did not identify that the design differential pressure had been reduced from the UFSAR value of 2750 psid. Instead, these modiGeations identified that these valves are required to operate at lower differential pressures during design basis events.
Although UFSAR Table 6.3-11 was not identified as requiring revision as a result of the 10 CFR 50.59 safety evaluation process, the error did not pose any safety significance. This conclusion is based on the fact that the differential pressure calculations went through a formal OSR which verified their accuracy based on design basis events. However, this information was not properly fed back into the UFSAR. The modifications to the valves referenced in the table were properly designed using the approved differential pressures.
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ATTACIIMENT Notice of Violation Response CORRECTIVE STEPS TAKEN AND RESULTS ACIIIEVED A commitment was generated to revise UFSAR Table 6-3.11 and Section 6.3.2.2.5 and to submit the revisions to Zion Regulatory Assurance. This information will be incorporated as part of the Zion 1995 UFSAR update.
The engineering organization responsible for MOV Program design changes has been consolidated on-site at Zion Station and roles and responsibilities have been defined clearly.
All future MOV modifications will be performed by the Design Engineering Department with input from the MOV Program Engineering Group.
CORRECTIVE STEPS TIIAT WILL HE TAKEN TO AVOID FURTIIER VIOLATIONS The resulting differential pressures identilled during the review of the MOV design basis input parameters will be reconciled with UFSAR Table 6.3-11 by the end of the first quarter of 1995 to determine whether any further changes to the UFSAR may be necessary.
This event (i.e. calculations using design basis input parameters differing from UFSAR values) will be discussed at Maintenance Engineering, Design Engineering and System Engineering department meetings to heighten the awareness of engineers involved in interdisciplinary design reviews.
All Zion personnel qualified to prepare and/or review safety evaluations are required to attend 10 CFR 50.59 safety evaluation training. This training will include a discussion of this event during 1995.
DATE WIIEN FULI, COMPLIANCE WAS ACIIIEVED Zion Station was in full compliance on December 22,1994 when the on-site Design Engineering Department completed a 10 CFR 50.59 safety evaluation documenting the change to UFSAR section 6.3.2.2.5 and Table 6.3-11.
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