ML20199G327

Notice of Violation from Insp on 970908-1216.Violation Noted:As of 970724,licensee Failed to Ensure That Training Provided to Selected Contractor Craft & Quality Control Insp Personnel Performing Raychem Splice Applications

ML20199G327
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/27/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199G198	List: ML20199G194 ML20199G327 ML20199G346
References
50-295-97-23, 50-304-97-23, EA-97-606, NUDOCS 9802040258
Download: ML20199G327 (3)

Text

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1 NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50 295;50-304 Zion Nuclear Power Plant License No: DPR-39; DPR-48 EA 97-606 During an NRC inspection conducted on September 8 through December 16,1997, five violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

1. 10 CFR Part 50, Appendix B, Criterion ll," Quality Assurance Program," states, in part, thet a quality assurance program be established for activities affecting quality and that the program shall provide for indoctririation and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Contrary to the above, as of July 24,1997, the licensee failed to ensure that training provided to selected contractor craft and quality control inspection personnel performing Raychem splice applications, an activity affecting quality, was adequate to assure that qualifications and suitable proficiency were achieved and maintained.

This is a Severity IV violation (Supplement 1).

2. 10 CFR Part 50, Appendix B, Criterion V," Instructions, Procedures, and Drawings," states, in part, that activities affecting quality shall be appropriate to the circumstances and shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance Nth these instructions, procedures and drawings.

Procedure ZAP 920-01," Site Scaffolding Procedure," revision 1, step G.3.b requires that site engineering provide a review within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> indicating that the scaffolding was seismically conctructed.

Contrary to the above, following erection of scaffolding adjacent to the 28 diesel generator oil storage tank on August 28,1997, the engineering review for seismic adequacy, an activity affecting quality, was not performed until September 12,1997, a period exceeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

This is a Severity Level IV violation (Supplement I).

3. 10 CFR Pcrt 50, Appendix B, Criterion XVI, requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, and nonconformances are promptly identified and corrected in the cases of significant conditions adverse to quality, the measure shall ensure that the cause of the condition is determined and corrective action taken to preclude repetition.

9802040258 900127 PDR ADOCK 05000295 G PDR

4 Notice of Violation 2 Contrary to the above,

a. The licensee failed to assure that corrective actions taken would preclude _

repetition of deficiencies in the oli sample program, a significant condition adverse to quality identified ire the August 1996 Engineering and Technical Support inspection. Specificially, the licensee failed to trend and analyze pump oil samples for the "OE" component cooling viater pump annual oil samples in 1995,1996, and 1997; the 2A and 2B charging pumps monthly oil samples in June and August 1997; and the 2A safety injection pump 18 month oil samples in June 1997. Also the licensee failed to write a problem identification form (PIF)in November 1996 when the 2A containment spray pump was identified as having an unacceptable oil sample,

b. The licensee failed to assure that long standing and repetitive out-of-tolerance instrument issues, a condition adverse to quality, was corrected. A violation for out of tolerance instruments was previously cited in August 1996 and the

! problems were again identified in September 1997, Specifically in February

' 1997,during performance of surveillance IMTS-2F-434," Instrument Maintenance Transmitter Surveillance," the output for reactor coolant flow transmitter 2FT 434 was found outside of the required acceptance criteria value and the licensee failed to initiate a PlF, although this transmitter had previously failed in October 1996. The transmitter failed for a third time in July 1997, indicating corrective j actions to the previous failure were not adequate.

This is a Severity Level IV violation (Supplement 1).

4. 10 CFR 50.46(a)(3)(ii), states, in part, that for each change to or error discovered in an acceptable evaluation model the licensee shall report the nature of the change or error to the Commission.

Contrary to the above, as of August 1997,the licensee failed to report to the Commissin discrepancies identified in the 1992 emergency core cooling system small break loss of coolant accident analysis.

This is a Severity Level IV violation (Supplement 1).

5. 10 CFR 50.73, paragraph (2) requires, in part, that licensees report any event or condition that was outside the design basis within 30 days after discovery of the event.

Contrary to the above, after discovery on September 30,1996, the licensee failed to report within 30 days that during 125 Vdc crosstie configurations, which occurred numerous times since 1975, the supply battery would not have sufficient capacity to support both buses during a limiting basis event, a condition outside the design basis of the plant. This condition was reported on August 5,1997.

This is a Severity Level IV violation (Supplement 1).

Notice of Violation 3

5. 10 CFR 50.73, paragraph (2) requires, in part, that licensees report any event or condition that was outside the design basis within 30 days after discovery of the event.

Contrary to the above, after discovery on September 30,1996, the licensee failed to report within 30 days that during 125 Vdc crosstie configurations, which occurred numerous times since 1975, the supply battery would not have sufficient capacity to support both buses during a limiting basis event, a condition outside the design basis of the plant. This condition was reported on August 5,1997.

This is a Severity Level IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, Comed is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region Ill, and a copy to the NRC Resident inspector at the Zion Station within 30 days of the date of the letter transmitting the Notice of Violation (Notice). This reply should be clearly marked as a

" Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken to avoid further violations; and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, an order or Demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response l

time.

Dated at Lisle, Illinois, this 27th day of January 1998

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