ML20202D929

Notice of Violation from Insp on 970830-1010.Violation Noted:On 970910,while Returning QA Fire Pump Breaker to Svc IAW out-of-svc Number 970009297,non-licensed Operator Did Not Close Control Power Knife Switch as Required

ML20202D929
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	11/28/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20202D918	List: ML20202D914 ML20202D929 ML20202D940
References
50-295-97-22, 50-304-97-22, NUDOCS 9712050188
Download: ML20202D929 (4)

Text

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NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos: 50-295; 50-304 Zion Nuclear Generating Station License Nos: DPR-39; DPR-48 During an NRC inspection conducted on August 30 through October 10,1997, four 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. Technical Specification (TS) 6.2.1.a requires that written procedures be prepared, implemented, and maintained for procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, specifies equip,mnt control, e.g., locking and tagging, as sin example of an administrative procedure.

Zion Administrative Procedure 300-06, "Out of Service Process," Revision 15, requires that equipment control be implemented to protect personnel and equipment during testing and maintenance activities on systems or components.

Zion Administrative Procedure 300-06, "Out of Service Process," Revision 15, Appendix B, " Lifting OOS Techniques," specifies, in part, that equipment be retumed to service in accordance with the applicable system operating instruction.

System operating instruction 63N, "480V Breaker RacKag Operations," Revision 4, Step 5.2.9, specifies, in part, that the control power knife switch be closed.

Out-of-service No. 970009345, required the 1A emergency diesel generator train 'A' main starting air check valve test tap isolation valve,1DG0169, to have been placed and maintained in the uncapped and open position.

Out-of service flo. 970007778, required the 2B residual heat removal heat exchanger bypass valve,2RH87263, to have been placed and maintained in the closed position.

Contrary to the above:

a. On September 10,1997, whhe retuming the OA fire pump breaker to service in accordance with out-of-service No. 970009297, a non-licensed operator did not close the control power knife switch as required by system operating instruction 63N, "480V 3reaker Racking Operations," Revision 4, Step 5.2.9.

b. On October 2,1997, while clearing out-of-service No. 970009345, a nortlicensed operator identified that the 1A EDG train "A" main starting air check valve test tap isolation valve,1DG0169, was not in the required out of service position, in that the valve was capped and open.

9712050188 971128 1 PDR ADOCK 05000295 G PDR

i Notice of Violation 2-

c. On October 10,1997, wl.;1e investigating the inability to depressurize the 2B residual heat removal train, an operator identified that the 2B residual heat removal heat exchanger bypass valve,2RH87268, was not in the position required by out-of service No. p70007778, in that the valve was 2/3 of a tum open.

This is a Severity Level IV violation (Supplement ).

(No. 50-295/97022-01; 50-304/97022-01)

2. 10 CFR Part 50, Appendix B, Criteria V," Instructions, Procedures, and Drawings,"

requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and be accomplished in accordance with these instructions, proc 6dures, or drawings.

Contrary to the above, procedures were not appropriate to the ciret.mstances in the following instances:

a. On September 19,1997, Operating Special Procedure 97-039, " Test of Autostart inhibit Circuitry for Bus 149 Pumps," Revision 0, was not appropriate to the circumstances, in that it did not provide appropriate guidance for testing the autostart inhibit circuitry of the OC component cooling water pump; consequently, the OC component cooling water pump breaker did not close automatically as expected in Step 2.6.

b. On September 22,1997, Abnormal Operating Procedure 8.1, " Loss of Instrument Bus," Revision 19(G), was not appropriate to the circumstances, in that for a loss of power to instrument bus 213, it did not direct appropriate follow-up actions for the unavailability of the boric acid transfer pumps, which could have resulted in a positive reactivity addition following a volume control tank automatic makeup, or for the continuous cycling of the 2A residual heat removal pump minimum flow valve, which could have caused the pump to operate in a runout condition or damaged the motor operator on the valve.

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

(No. 80-295/97022-02; 50 304/97022-02)

3. TS 3.1.1 requires that the setpoints for the reactor protection system are presented in Table 3.1-1.

TS Table 3.1-1 requires, in part, that the power range rate trip setpoint be 5 percent of rated neutron flux /2 seconds. In addition, the setpoints bo t established tolerances for instrument channel and setpoint errors as specified in " Zion NSSS (Nuclear Steam Supply System] Setpoint Evaluhtion, Protection System Channels, Eagle 21 Version," but the instruments shall not be set to exceed a Limiting Safety System Setting.

TS 2.1.1.C, " Limiting Safety System Sctting," requires that the power range rate trip be set at less than or equal to 5 percent of rated flux in 2 seconds.

I

Notice oiViolation Contrary to the above, dur,og tha calibration of power range channel 2N 42 en February 6,1993, and power range channel 2N-43 on May 16,1994, the licensee set the power range rate trip setpoint at 5 t' and 5.1 percent of rated flux in 2 seconds, respectfully.

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

(No. 50-304/97022-03)

4. TS 3.1.2 states, in part, that for all on line testing or instrumentation failure, plant operation shall be permitted in accordance with Table 3.1-1.

TS Table 3.1-1 requires for the power range rate trip, a minimum of three operable channels, except that for channel testing, calibration, or maintenance the minimum number of channels may be reduced by one for a maximum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; otherwise, the unit should be in hot shutdown within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Contrary to the above, while calibrating power range channels on April 26,1993, and August 1,1994, the licen.ee did not have 3 operable power range raie trip channels for periods of 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />,15 minutes and 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />,28 minutes, respectfully; and the Unit 2 was not placed in hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

This is a Severity Level IV violatior' (Supplement 1).

(No. 50-304/97022-04)

Pursuant to the provisions of 10 CFR Part 2.201, Commonwealth Edison Company is hereby required to cubmit a written statement os explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy te the Regional Administrator, Region lil, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice (Notice).

This rer'y should be clearly marked as a " Reply to a Noticc" 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 resporse may reference orinclude previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in the Notice, an order or a 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 De taken. Where good cause is shown, consideration will be given to extending the response time.

Because ycur response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deietes such information. if you requod withholding of such mattrial, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for yo.'r claim of withholding (e.g., explain why the disclosure of information will

Notice of Violation create an unwarranted invasion of privacy or provide the information required by 10 CFRPart 2.790(b) to support a request for withholding confidential commerchi or fnancial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR Part 73.21.

Dated at Usle, Illinois this 28th Cay of November 1907 1

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