ML20195C853

Responds to SALP 7 Repts,Per .To Assure Aggressive & Timely follow-up of App R Items,Assistant Fire Marshall Appointed & Engineer Employed W/Responsibility for Fire Protection Sys

ML20195C853
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	10/19/1988
From:	Reed C COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20195C841	List: ML20195C835 ML20195C844 ML20195C853
References
NUDOCS 8811040013
Download: ML20195C853 (3)

Text

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/ ) One First Natonal Ptara. Chicago. Ill.nois

- Address Reply to: Post Office Box 7D' Chicago, Ilunois 60690 October 19, 1988 e ,

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Mr. A.B. Davis Regional Administrator ,

U.S. Nuclear Regulatory Commission  !

799 Roosevelt Road [

Glen Ellyn, IL. 60137 -

Dear Mr. Davist j i Subject Zion Station Units 1 and 2 Response to SALP 7 Report {

e HEC D9sks_L.M91._50-295 and 50 301

/

References August 23, 1988 letter from A. Bert Davis to Cordell Reed [

The referenced letter provided the report of the NRC's SALP 7 [

evaluation for Zion Station. In addition to soliciting our written comments, s the scject report specifically requested that Commonwealth Edison address corrective actions relative to improving performance in the Engineering / Technical Support area and the management controls to be I implemented that will ensure completion of the remaining Appendia R ,

requirements. These items are addressed as follows:

Enginetting4Itshniemi su ppntt j The SALP Board recommended increasing management attention in this area to ensure technical rigor, attention to detail, timely resolution of problems, and attention to regulatory requirements. Completion of the following corrective actions will resolve those concerns  ;

I On September 9,1988, a Technical Issues Task Group was appointed by [

the Station Manager. The charter of that group was to provide an action plan  !

for timely resolution of technical issues in an orderly manner, improving i engineering attention to detail, and improving the attention to regulatory j requirements for technical staff personnel. The task group's charge, in part, i is to determine how technical issues are assigned, due dates are established,  !

and the method in which those items are tracked to completion. The members [

appointed to that group are Assistant Superintendent - Technical Servicts [

(Chai rinan), Regulatory Assurance Supervisor, Technical Staff Supervisor, pWR I Section Engineer. Technical Statf Primary Group Leader, and the Statf Assistant to the Assistant Vlee President for Licensing and Plant Support Services.

To date three task group meetings have been held to detail the scope of the group, establish target dates for the completion of activities, perfoam f an in-depth moview of the SALP 7 report, and identify solutions to the {

concerns raised. A final report will be issued to the Station Manager by L 11/30/88, with implementation of the reconnendations contained therein to I

follow. ,

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• In order to become more proactive to 'ho station's needs, Commonwealth Edison's Engineering Department was reorganised to include an on-site group that would participate in daily (pWRE) station issues. The daily and weekly department head meetings, QA esits, and NRC esits are routinely attended by the on-site PWRE group. Beginning in June, 1988 technien1 review meetings have been held approximately monthly at the station with members of the on-site and off-site PWRE organisations and station personnel. Significant prsjects, technical studies and larger modifications are reviewed.

i As an additional measure, en esperienced engineer has been assigned {

by the corporate office to perform an evaluation of the engineering and a technical support organlaations in the corporate office and at the sites.

This individual will evaluate the relative merits of different types of I organisations (e.g., project vs. functional), and will review recent organisational changes made by VEPCO, PSEGG, and other utilities. It is '

espected that recommendations for improvement will be developed by the second quarter of 1989.

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'l Recognising the need for responsiveness to NRC initiatives, formalised weekly meetings between NRC resident inspectors and key upper 1 management personnel have been instituted at the request of the Station Manager. The Production Superintendent, Services Superintendent, and Regulatory Assurance Supervisor are participants in those meetings. The purposes of those meetings art twofold. First, it is the vehicle used to i apprise NRC of station identified technical issues needing resolution during the current weeks and, secondly, it is a forum NRC can use to have concerns addressed. Minutes of those reviews are developed, and resulting action items r J

3 are assigned to the cognizant Department Head. Each action item is reviewed i at the weekly staff meeting and is tracked to closure. A significant l3 outgrowth of those meetings has been the implementation of senior management i

plant tours with the Senior Resident Inspector. ,

i The SALP report was reviewed in depth with senior station management, L I PWR Engineering and Zion's Technical Staff in order to apprise those personnel i of HRC's attention to detail concerns.  ;

j To strengthen and re-define performance espectations, an engineering [

i applications course has been given to 30 technical staff members during the month of August, 1988. The course, lasting five days, included such topics as i the conduct of testing, a critique of actual tests performed by students, a i l review of actions to be taken with regard to test ananalles, and instruction as to how to review and evaluate test results.

' ZAP 5-51 5 Procedure Content and Tornat" has been revised, in part.

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to prescribe the content and format of and to provide uniformity within 7echnical Staff procedures. Key components of this procedure change were to require consideration of acceptance criteria, precautions

nd limitations.

i instructional notes and definition of steps. This change provides consicteney

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in the preparation of system tests performed by technical staff personnel.

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3 During th3 SALP 7 period sin peoplo woro cddsd to th? StCtion's technical staff, with four additional personnel budgeted for 1989.

Racognising the need for technical familiarity with the operating perameters of the plant, four SRO licenses are maintained by key members of the technical staff. The report correctly suggests an average of three years experience on the technical staff. However, many of the members of the technical staf f bring significant experience f rom other areas of the Cornpany, such that thr.

average Company experience level approximates 8 years. The reassignment of ,'

Senior Control Room Engineers to key positions in the technical staff has and l will continue to strengthen the operational knowledge of the station technical staff.

Technical staff personnel knowledge of regulatory requirements will l be increased by additional training in the Comonwealth Edison Quality ,

Assurance Manual. The training, conducted by an experienced meuber of the Corporate Quality Assurance Department, will focus on the programatic ,

weaknesses identified in the SALP report. The training is expected to begin In the first quarter 1989 and will be mandatory for all members of the >

station's technical staff and FWR Engineering staff. While these corrective 1

l actions will strengthen Technical Staff training, it should be noted that '

during the SALP 7 period Technical Services Training received INPO  !

accreditation. To date, approalmately 25 current rnembers of the technical .

stafI have completed the IPPO and systems descriptions modules. l 13_C flLM. App e ndix_R_implem e nt a t i o n To assure timely completion of Appendix R ltems. Zion Station has

• incorporated the:m into the Station's commitment tracking system (NTS). Each month a report is generated, by department, listing all commitments requiring l cornpletion during the upcoming month. The Nuclear Tracking System is reviewed  !

l weekly by senior station management to assure that priority items are l j cornpleted on tirne.

1 7 To assure aggressive and timely follow-up of Appendia R ltems, an  !

l Assistant rire Marshall has been appointed and an engineer has been employed l with responsibility for the fire protection system, i 1

In addition, the Zion fire protection items are the top priority of ,

J the Corporate rire= Protection Engineer. He is espected to spend approximately [

j 40% of his time assisting the station in closing out those items. f

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rinally, until Appendia R cormitments are completed, a monthly status ,

report is being issued bi the fire Protection Engineer to assure that the

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current status is comunicated to the appropriate levels of managernent. The status reports are reviewed bi-monthly t,y the Production Superintendent, 4

Techn* col Staf f Supervisor and the FWR Engineering Project Engineer.

l N~c , _

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Cordell Reed Senior Vlee President j f

! cc: NRC Resident inspector. Zion 5234K j l

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