ML20203G191
| ML20203G191 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/11/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Brons J COMMONWEALTH EDISON CO. |
| References | |
| 50-295-97-18, 50-304-97-18, NUDOCS 9712180074 | |
| Download: ML20203G191 (2) | |
See also: IR 05000295/1997018
Text
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Decm ber 11, 1997
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Mr. J. Brons
Site Vice President
Zion Generc. ting Station
Commonwealth Edison Company
101 Shiloh Boulevard
Zion,IL 60099
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS. 50-295/97018;
50-304/97018
Dear Mr. Brons:
This will acknowledge receipt of your letter dated November 3,1997, to our letter dated
October 2,1997, transmitting a Notice of Violation associated with the above mentioned
inspection report at the Zion Nuclear Power Stat:an Units 1 and 2. We have reviewed your
corrective actions and have no further questions at this til.1e. These corrective actions will be
examined during future inspections.
Sincerely,
Original Signed by J. Jacobson
John A. Grobe, Director
Division of Reactor Safety
Dockei No. 50 295
Docket No. 50-304
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Enclosure:
Ltr dtd 11/3/97, J. Brons, Comed
to USNRC w/ enclosure
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See Attached Distribution
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DATE
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OFFICIAL RECORD COPY
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9712100074 971211
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J. Brons
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Deccriber 11, 1997
cc w/ encl:
O. Kingsley, Nuclear Generation Group
President & Chief Nuclear Officer
M. Wallace, Senior Vice President,
Corporate Services
H. G. Stanley, Vice President,
PWR Operations
Liaison Officer, NOC-BOD
D. A. Sager, Vice President,
Generation Support
D. Farrar, Nuclear Regulatory
Services Manager
I. Johnson, Licensing Operations Manager
Document Control Desk Licensing
R. Starkey, Plant General Manager
R. Godley, Regulatory Assurance
Supervisor
Richard Hubbard
Nathan Schloss, Economist,
Office of the Attorney General
Mayor, City of Zion
State Liaison Officer
State Liaison Officer, Wisconsin
Chairman, Illinois Commerce Commission
Distribution
Docket File w/enci
Rlli PRR w/enct
Rill Enf. Coordinator w/enct
PUBLIC IE-01 w/enct
SRI, Zion w/enct
TSS w/enci
LPM, NRR w/ enc!
J. L. Caldwell, Rlli w/enci
R. A. Capra, NRR w/ enc!
DRP w/enci
A. B. Beach, Rlil w/enci
DOCDESK w/enci
DRS w/enci
G. E. Grant, Rlll w/enct
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ZRA97060
November 3,1997
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U. S. Nuclear Regulatory Commission
Washington, D.C. 20555
Attention:
Document Control Desk
Subject:
Commonwealth Edison Reply to Notice of Violation in NRC Inspection
Report Number 50-295/304 97018;
Zion Nuclear Power Station Units I and 2;
NRC Docket Numbers 50-295 and 50-304
Reference:
Letter to J. Brons (Comed) from G. E. Grant (USNRC) dated October 2,
1997, NRC Inspection Report 50-295/970!8,50-304/97018 and Natice of
Violation
Gentlemen:
By letter dated October 2,1997, the NRC cited Commonwealth Edison (Comed) as being
in _violadon of regulatory requirements. The referenced Inspectic Report cited two
Severity Level IV violations. The first violation pertains to the failure to implement
timely and effective corrective actions. The second violation involves two examples of
the failure to establish appropriate measures to control parts or components which did not
conform to design requirements in order to prevent their inadvertent use or installation.
This letter and its attachments constitute Comed's reply to the referenced Notice of
Violation in accordance with applicable regulations.
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ZRA97060
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November 3,1997
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Page 2 of 2
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Attachment A to this letter provides the reasons for the violations, the corrective actions
- laken, and the date when full compliance will be cchieved. Attachment B to this letter
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identifies all commitments made by Zion Station in this response.
Should you b3ve any questions conceming this response, please contact Robert Godley of
my staff at 847 746 2084 cxtension 2900.
Sincerely,
hm
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ohn C. Brons
Jite Vice President
Zion Nuclear Station
Attachments
cc: Regional Administrator, USNRC - Region til
Senior Project Manager, USNRC - NRR Project Directorate 1112
Senior Resident inspector, Zion Nuclear Station
'frice of Nuclear Facihty Safety IDNS
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ATTACllMENT A to ZRA97060
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Page 1 of 8
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Response to Notice of Violation in Inanection Renort 20 295/304 970111
YIOLATION: 50 295/304 97018 03
10 CFR Part 30, Appendix B, Criterion X11, requires, in part, that measures shall be
established to assure that conditions adrase to quality, stach asfailures, malfsmettons,
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deficiencies, deviations, and nonconformances are promptly identifled and corrected. In
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the cases of significant conditions adverse to quality, the measure shall ensure that the
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cause of the condition is determined and corrective action taken to preclude repetition.
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Contrary to the above,
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From 1991 to 1997, the licensce's engineering design processfailed to update
a.
operat ng procedure ECA 0.0, Revision 23, " Loss of All AC Power," to inchide
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various DC loads that must be shed off the bus, unur certain design busis
conditions, as determined by de.l;n calculation 225 P 007h-001, "1231'dc
Battery Load Profile Analysis " The potential to operate the plant beyond the
battery design basis existed.
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b.
From 1992 to 1997, the licenseefailed to dispositionjour operabillty evaluation
compensatory actions that allowed operatfort of the co.nponent cooling system
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down to .10*F. The ll>ue used this evaluation to justify operating below the
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70*Flimit identified in the precautions ofthe system operatingprocedure.
This is a Severity L.evelll' violation (Supplement 1).
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AllA11SSION OR 1)ENIAL TO Tile VIOLATION
Comed admits the violation.
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ATTACllMENT A to ZRA97060
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Page3of8
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Violation Example at
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REMON FOR THE VIOLATION
The reason for this violation example is a failure, on the part of the Engineering
Department, to ensure that the results of calculation 22S B 007E-001, "125 Vdc Battery
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Load Profile Analysis," dated December 31,1991, were effectively comrnunicated to the
Operations Procedures Group for incorporation into procedure ECA 0.0," Loss of all AC
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Power." This calculation was issued by ABB impell Corporation and included, within
the body of the calculation, the following statement: "hfodifications to existing Zion
Station procedures are recommended to incorporate the load shedding actions identified
by this calculation." Effectively, this recommended procedural modification added only
two more loads to the DC Bus 112 load shedding requirements. No evidence of
transmittal of this recommendation to 4 Operations Procedures Group !s contained in
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the calculation, in addition, this reconmdation to modify existing procedures was not
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contained la the ECA-0.0 procedure change files.
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As discussed in our Febmary 6,1997, response to the Nuclear Regulatory Commission's
request for information under 10 CFR 50.54(f), Zion Station recognized the need to
improve design and configuration programs. 4e also recognized that there was the
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potential to identify additional design and configuration control deficiencies as part of our
actions to improve engineering support. This discrepancy between the 125 Vdc battery
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load profile analysis and the various station procedures which were affected by the
analysis was identified by engineering personnel as part of the Zion Design Basis
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!nitiative, which is among the design and configuration improvement programs.
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CORRECTIVE ACTIONS TAKEN AND RESULTS AClllEVED
The battery load shedd:ng actions identified in calculation 22S B 007E 001 were
incorporated into Revision 25 of Procedure ECA 0.0 on July 14,1997.
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A review of other procedures which could be affected by the calculatien 22S B 007E 001
recommendations was corupleted. As a result of this review, procedures ECA-0.1," Loss
of all AC Power Recovery Without Si Required," the Unit 1 Annunciator Response
hianual (ARhi) for Panel 16, and the Unit 2 ARhi for Panel 16 were revised to reflect
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the battery load shedding action recommendations of calculation 22S B-007E 001.
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ATTACllMENT A to ZRA97060
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Page 3 of 8
The Design Basis initiative was implemented to address updating the existing Design
Basis Document (DBD) process at Zion and includes development of additional DBDs.
Additionally, the Zion Design Basis initiative includes validating existing and plara -d
DBDs for adequacy, correctness, and consistency with the Updated Final Safety Analysis
Report (UFSAR), plant procedures, and other applicable design documents such as
calculations. The Design Basis initiative also addresses critical catculation control and
any necessary reconstitution,
A corporate Nucleu Engineering Procedure (NEP)-12 03," Nuclear Design Information
Transmittali :NDl'f)," was issued October 31, 1994. This procedure applies to the
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transmittal of nuclear plant design information between personnel of different
departments and requires formal transmittal for design information extracted from design
documents, tests, walkdowns, licensing basis documents, etc.
CSRRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTIIER VIOLATIONS
No additional .;rrective actions are required.
DATE WilEN Full > COMPLIANCE Will HE ACHIEVED
Zion Station is in full compliance at this time.
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ATTACilMENT A to ZRA97060
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P:ge 4 of 8
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Violation Example b:
llEASON FOR Tile VIOLATION
The reason for this violation example is that the System Engineer and Group Leader
assurued that they were in compliance because they had provided disposition for each of
the four recommended compensatory measures contained in the 1992 Component
Cooling (CC) Water System Minimum Temperature Evaluation (Chron #183011 dated
March 9,1992). Ilowever, they were not in compliance since the actions taken to
disposition the compensatory measures had not been documented via a formal
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mechanism. This resulted in what appeared to be a failure to take the requisite steps to
allow the CC system to be operated down to 40'F
CORRECTIVE ACTIONS TAKEN AND RESULTS ACillEVED
The System Engineer and the Group Leader involved in this event were counseled in
accordance with station policies.
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Engineering has issued a supplement to the March 9,1992 CC Minimum Temperature
Evaluation to provide a formal, documented disposition for each of the recommended
compensatory measures which allow the CC system to be operated down to 40'F.
CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTIIER VIOLATIONS
The CC Water System Operating Instruction (S01)-6 will be revised to allow a lewer
operating limit of 40'F for the system. This revision will be completed by December 15,
1997.
The circumstances surrounding this event and Engineering Management expectations
regarding fornul documentation requirements will be discussed with Engineering
personnel during weekly tailgate sessions. These sessions will be completed prior to Unit
2 restart.
DATE WilENJULL COMPLI ANCE WILL HE ACIIIEVED
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ZLm Station is in full compliance at this time,
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ATTACilMENT A to ZRA97060
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Page 5 of 8
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VIOLATION: 50-295/30L97018-05
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10 CFR Part 30, Appendix B, Criterion XV, requires, in part, that measures shall be
established to control materials, parts, or components which do not conform to
requirements in order to prevent their inadvertent use or installation. These measures
shall include, as appropriate, procedures for identification, documentation, segregation.
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anddisposition.
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Contrary to the above, the Zion Station measures to control materials were inadequate
and did not prevent Installation ofthefollowing:
From about 1992 to 1997, high eficiency particulate air (llEPA) filters
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a.
containing aluminum in exce:: of the design basis limits, were installed inside
Units I and 2 containments.
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b.
In February and April 1997, nonscismically qualifled starting solenoids were
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installed in the starting circuitry of the IC and 2C diesel contcInment spray
pumps, respectively.
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This is a Severity Level IV violation (Supplement 1).
ADMISSION OR DENIAL TO THE VIOLATION
Comed admits the violation.
Violation Example a:
REASON FOR Tile VIOLATION
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This violation example is the result of a weakness in the parts selection ponion of the
work package preparation process.
Specifically, the work analysts involved ih
development of the work packages for filter replacement between 1992 and 1994 did not
use the design specification for llEPA filters in the Containment Charcoal Filter Units
(CCFUs) (Sargent & Lundy Specification X 2284) to identify the appropriate non-
eNminum containing replacement filters. Instead, they used informal and uncontrolled
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guidance to identify the replacement filters. The informal guidance was provided by
Engineering but was not verified to be accurate against controlled documentation, namely
the llEPA filter design specification.
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ATTACilMENT A to ZRA97060
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Pcge 6 of 8
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The work package preparation procedure in use at the time required the work analyst to
either select identical replacement parts or obtain a technical evaluation for the proposed
alternate parts, liowever, the procedure was inadequate in that it did not provide the
work analyst with a method or guidance to verify that the replacement itern was identical
to the original item.
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CORRECTIVE ACTIONS TAKEN AND RESULTS ACillEVED
Unit 2 Containment Charcoal Filter Unit liEPA filters were replaced with non aluminum
containing IIEPA filters on August 14,1997.
A work history review was conducted and it was concluded that, other than the aluminum
IIEPA filten in the CCFUs, no additi' nal aluminu n was added by non modification,
pennanent part replacements associated with containment work performed since January
1994 (the date of the last inventory of aluminum in the reactor containment buildings).
Zion Station has implemented a Suitability of Application Guideline to assist the work
analysts with the selection of proper replacement parts for preventive and corrective
maintenance (non modification replacements). Further, this Suitability of Application
Guideline requires the work analyst to verify that replacement items meet the design and
procurement requirements as specified in the applicable controlled documentation
(Comed Electrical Installation Standards, Sargent & Lundy X specs, etc.).
The
Suitability of Application Guideline also provides the work analyst with direction as to
when a replacement part can be deemed identical to the original and when a non identical
or attemate replacement part requires evaluation prior to installation.
CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTIIER ,IOLATIONS
Unit I Containment Charcoal Filter Unit IIEPA filters containing aluminum will be
replaced with non aluminum containing IIEPA filters prior to Unit I startup.
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The attributes of the current Suitability of Application Guideline will be incorporated into
applicable- Zion Station Work Package Preparation and Procurement Evaluation
procedures during the first quarter of 1998.
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ATTACilMENT A to ZRA97060
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Pcge 7 of 8
DATE WIIEN FULL COMPLIANCE WILL BE ACillEVED
Full compliance will be achieved following replacement of the Unit 1 Containment
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Charcoal Filter Unit ilEPA filters with non aluminum containing HEPA filters. This
replacement will occur prior to Unit I startup.
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Violation Example b:
REASON FOR TIIE VIOLATION
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The reason for this_violatloa example is that a " Determining Ordering Classification"
evaluation perfonned by the Technical Staff System Engineer in 1987 failed to identify
the special seismic report requirements prior to the purchase of the replacement
solenoids. Both the UFSAR and the Containment Spray Pump Design Specification (X-
2247) indicate that all components of the Containment Spray Pump system are designated
as "Scismic Class I," meaning that seismic qualification report documentation
requirements should have been included in the procurement requirements for the
solenoids. The System Engineer in 1987 did not have a thorough understanding of the
design and procurement requirements for the solenoids since he had been at Zion Station
for approximately one month and had not received any fonnal or substantive training
before he was requested to perfonn the Determining Ordering Classification evaluation.
Furthennore, the procurement process in effect at the time did not require second
verification of the System Engineer's Determining Ordering Classification evaluation.
Another reason for this violation example is that the parts replacement process was not
sufficiently comprehensive to ensure the suitability of application for par'.s "end use."
The process allowed parts to be specified for use and installed prior to determining the
suitability of application.
CORRECTIVE ACT10ES TAKEN AND RESULTS ACIIIEVED
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The process for reviewing part and material procurement requirements was changed
significantly in 1990. For example, the "Detemiining Ordering Classification" form was
replaced by Zion Administrative Procedure (ZAP) 510-08. This procedure provides the
methodology and guidance for the performance of evaluations for new and replacement
parts, materials, and components.
Additionally, ZAP 510 08 requires independent
preparation, review, and approval of procurement evaluations. - Also, the responsibility
for perfonning procurement evaluations has been transferred from System Engineering to
the Zion Central Parts Group where they are perfomied by a group of Procurement
Engineers.
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ATTACllMENT A to ZRA97060
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P ge 8 of 8
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Seismic testing of a Cummins Part Number 3055737 solrnoid was successfully
completed on hiay 20,1997, by Nuclear Logistics Inc. (NLI). Zion Parts Evaluation
Zl997-0087-01 was subsequently completed to document the results of the seismic
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testing and to approve the use of the replae: ment solenoid for both the Unit I and Unit 2
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Containment Spray diesel engines.
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As described under the corrective actions taken for Violation Example "a," Zion Station
has implemented a Sultability of Application Guideline to assist the work analyst with the
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selection of proper replacement parts - for preventive and corrective maintenance.
hianagement expectations regarding use of the Sultability of Application Guideline were
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communicated to the Work Analysts, hiaintenance Supervisors, and hiaintenance Parts
Specialists by means of tailgate sessions.
CSRRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER VIOLATIONS
The attributes of the current Suitability of Application Guideline will be incorporated into
applicable Zion Station Work Package Preparation and Procurement Evaluation
procedures during the first quarter of 1998.
DATE WilEN FULL COMPLI ANCE WII L BE ACilIEVED
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Zion Station is in full compliance at this time.
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ATTACllMENT D to ZRA97060
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1.lat of Commliments identined in thia Vlointion Responu
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The following table identifies those actions committed to by Comed in this document.
Any other actions discussed in this submittal represent intended or planned actions by
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Comed. They are described to the NRC for the NRC's informatio'i and are not regulatory
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commitments. Please notify Mr. Robert Godley, Zion kation Regulatory Assurance
Manager, of any questions regarding this document or ey associated regulatory
commitments.
Commitment
Committed Date or
Outage
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The CC Water System Operating Instruction (SOI)-6 will be
December 15,1997
revised to allow a lower operating limit of 40'F for the system.
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This revision will be completed by December 15.1997.
Unit 1 Containment Charcoal Filter Unit HEPA filters containing
Prior to Unit I startup
aluminum will be replaced with non aluminum containing HEPA
filters prior to Unit I startup.
The attributes of the current Suitability of Application Guideline
First quarter of 1998
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will be incorporated into appilcable Zion Station Work Package
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Preparation and Procurement Evaluation procedures during the first
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quarter of 1998.
The circumstances surrounding this event and Engineering
Prior to Unit 2 restart
Management
expectations regarding
formal
documentation
requirements will be discussed with Engineering personnel during
weekly tailgate sessions. These sessions will be completed prior to
Unit 2 restart.
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