ML20212A274

Responds to NRC Re Violations Noted in Safety Insp Repts 50-295/86-05 & 50-304/86-05.Corrective Actions: Radiation Chemistry Foreman Counseled on Correct Interpretation of Tech Spec Requirement

ML20212A274
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/27/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1811K, NUDOCS 8607280151
Download: ML20212A274 (4)

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} 72Commonwealth Edison Chic'go, Illinois Z__.

West Adams Street, (N '" Address Reply to: Post Office Box 767 Chicago, Illinois 60690- 0767 June 27, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

ZionNuclearPowerStationUnits1and2[

Response to I&E Inspection Report Nos. I 50-295/86-005 and 50-304/86-005 NRC Docket Nos. 50-295 and 50-304

Reference:

May 29, 1986 letter from C. E. Norelius to Cordell Reed.

Dear Mr. Keppler:

This letter concerns the routine safety inspection conducted by Messrs. M. M. Holzmer, L. E. Kanter, and J. N. Kish of your office on February 15 through April 14, 1986, of activities at Zion Nuclear power Station. The referenced letter indicated that certain of our activities appeared to be in violation of NRC requirements. Commonwealth Edison Company's response to this violation is contained in Attachment 1.

The referenced letter also requested that Commonwealth Edison Company provide a summary of the actions taken at Zion Station in response to the recent discovery of non-conservative setpoints for the Negative Flux

' Rate Reactor Trip. The actions taken, and their relationship to the other Commonwealth Edison stations, are described in Attachment 2.

The course of action described in Attachment 2 is intended to accomplish more than just address this isolated incident. This action plan l will result in the performance of more comprehensive and systematic safety evaluations which will both address this specific issue and reduce the future potential for similar events.

If any questions arise concerning this matter, please contact this office.

Very truly yours, O D. L. Farrar g rector of Nuclear Licensing Im Attachment cc: Region III Inspector - Zion y ggg$

J J. A. Norris - NRR i

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a ATTACWWNT 1 ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION ITEM OF NONCOMPLIANCE As a result of the inspection conducted on February 15 through April 14, 1986, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions", 10 CFF Part 2 Appendix C (1985), the following violation was identified

10 CPR 50 Appendix B, Criterion XVI, as implemented by the Commonwealth Edison Quality Assurance Program requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected, and that in the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, on December 8, 1985, a condition adverse to quality, a missed surveillance for reactor coolant iodine following a 15%

power change occurred on Unit 1, and the licensee failed to assure that corrective action was taken to preclude repetition, as indicated by a similar event on Unit 2 on March 2, 1986 Corrective Action Taken and Results Achieved:

The Rad-Chem foreman involved was counselled on the correct interpretation of the technical specification requirement and the event was discussed at the weekly department meeting for the Radiation Chemistry department. There have been no further occurrences related to this technical specification.

Corrective Action to be taken to avoid further Violation:

Zion Chemistry Procedure (ZCP) 301-6 " Power Change Iodine Surveillance" has been developed to document and assure compliance to Technical Specification 4.3.6. Its accompanying form was also added to ZCP 401.

Date when full compliance will be met:

Both procedure changes were submitted to On-Site Review on June 13, 1986 and are expected to be issued by August 15, 1986.

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I ATTACHPENT 2 The immediate response to the discovery of non-conservative Negative Flux Rate Trip Setpoints (NFRTS) was to process an emergency Technical Specification change and to alter the setpoint to the correct value. This was accomplished on February 24, 1986. In addition, Commonwealth Edison is supporting the WOG in its effort to justify the complete removal of the NPRTS. A plant specific analysis is expected to be available in the Fall of this year.

The need to closely examine the thoroughness of the various safety evaluations performed for Zion was recognized prior to this event. Thus, this occurrence reinforced the need and provided a focus for this review.

Representatives from the appropriate Commonwealth Edison departments have met to discuss this issue. Agreement has been reached that a more formal method of reviewing potential safety analysis interactions needs to be developed. This concern applies to all reviews performed under 10 CPR 50.59 including proposed plant modifications, procedure changes, changes to safety analyses, and normal reloads. Clearly, the alteration of reactor protection setpoints as a result of a revised dropped rod analysis would fall under this class of reviews.

A descriptive listing of all pertinent PSAR input parameters, assumptions, and analytic methodologies is being prepared. This list will be incorporated into Zion's safety reviews for safety analyses, reloads, and modifications providing a more comprehensive method of reviewing this area.

The development of this list involves a large amount of effort and is expected to be finalized by early 1987.

If the Zion effort described above proves beneficial, then its extension to the other Commonwealth Edison PWR stations will be considered.

The three BWR stations currently utilize a General Electric prepared list similar to the descriptive list being prepared for Zion. Thus, the personnel performing the required reviews for the BWR stations already have access to this information.

Byron and Braidwood may well eventually benefit from Zion's experience. All three stations currently utilize similar methodology for approving their reloads. However, Byron and Braidwood have undergone no changes in their FSAR safety analyses, while Zion has made numerous changes. Thus, the potential for disparity between the approved safety analyses and the plant's configuration is substantially less at Byron and Braidwood. In addition, these facilities have recently undergone the normal review of setpoints associated with plant construction and startup.

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Zion Station is currently completing a detailed comparison between the Westinghouse setpoint study for Zien and the values currently in use.

This review provides assurance that the appropriate setpoints are currently in use. The disparity in the NFRTS was uncovered as a part of this review.

In summary, the current status of the setpoints in use at Zion is being verified through the Westinghouse setpoint study comparison discussed above. Future alterations will be reviewed utilizing a safety parameter descriptive list to better ensure the continued setpoint validity. If Zion's experience is positive, this concept will be extended to Byron and Braidwood, which utilize similar reload methodology to Zion.

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