ML20214Q006
| ML20214Q006 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/16/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1894K, NUDOCS 8609240136 | |
| Download: ML20214Q006 (3) | |
Text
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'N g y g g g 2 One First Nabonel Plaza, Chicago, Illinois
/ Address Reply to: Post Omco Box 767 Nd Chicago, Illinois 60690 0767 September 16, 1986 l
Mr. James G. Keppler l
Regional Administrator i
U.S. Nuclear Regulatory Commission l
Region III i
799 Roosevelt Road l
Glen Ellyn, IL 60137 l
l
Subject:
Zion Nuclear Power Station Units 1 and 2 Response to I&E Inspection Report Nos.
50-295/86-012 and 50-304/86-011 NRC Docket Nos. 50-295 and 50-304 References (a): July 3, 1986 letter from C. W. Hehl to Cordell Reed.
(b): July 25, 1986 letter from D. L. Farrar to J. G. Keppler.
Dear Mr. Keppler:
This letter concerns the routine safety inspection conducted by M.
L. McCormick-Barger of your office on May 5 through June 5, and June 11, 1986, of activities at Zion Nuclear Power Station. Reference (a) indicated that certain of our activities appeared to be in violation of NRC require-ments. Reference (b) supplied Commonwealth Edison Company's response to this violation. Subsequent conversatons with members of your staff have indicated the need to expand upon our initial response. Commonwealth Edison Company's revised response to this violation is contained in the Attachment to this letter.
If any additional questions arise concerning this matter, please contact this office.
Very t uly yours,
= :q D. L. Farrar Director of Nuclear Licensing Im Attachment cc: Region III Inspector - Zion J. A. Norris - NRR SEP181986 8609240136 860916 1894K PDR ADOCK 05000295 1 I G
PDR h b/
a ATTACHMENT ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION ITdM OF NONCOMPLIANCE As a result of the inspection conducted on May 5 through June 5, 1986, and June 11, 1986, and in accordance with 10 CFR Part 2, Appendix C -
General Statement of Policy and Procedure for NRC Enforcement Actions (1985),
the following violation was identified:
10 CFR 50, Appendix B, Criterion XI as implemented by the Commonwealth Edison Corporate Quality Assurance Manual, requires that testing be performed in accordance with written test procedures and that test results be documented and evaluated to assure that test requirements have been satisfied.
l Contrary to the above:
a.
The licensee performed an inadequate results evaluation for Technical Staff Surveillance Procedure TSS 15.6.51, "Zero Power Physics Measurements Following Refueling," performed for Unit 2 Cycle 9 on January 27-29, 1986, in that the independent review of the calculation of the critical operations restrictions to assure a negative moderator coefficient failed to detect that there were two errors present in the calculation. The failure to identify and correct the errors had minor safety significance.
b.
Testing was not performed in accordance with written test procedures in that:
(1) Procedure steps were skipped (not signed nor performed before proceeding to the next step) during the performance of the l
following test procedure:
i.
TSS 15.6.51, "Zero Power Physics Measurements Following Refueling,"
performed for Unit 2 Cycle 9 on January 27-29, 1986: Steps 7.7.b and 7.9.b.
i (2) Procedure steps at the end of surveillance procedures were not signed off prior to proceeding to an operational phase for which the surveillances were required to be performed:
TSS 15.6.54, " Isothermal Moderator Temperature coefficient Measurements," performed for Unit 2 Cycle 9 on January 27-29, 1986: Steps G.1, G.2 and G.3.
TSS 15.6.55, " Rod and Boron Worth Measurements," performed for Unit 2 Cycle 9 on January 27, 1986: Steps A.S.6, A.5.6.1 and B.5.ll.
o
, (3) The Station Nuclear Engineer signed a step in'TSS 15.6.51 that stated, " Based on Rod Worth Measurements adequate shutdown margin exists," prior to the time that the procedure steps related to evaluating rod worth measurements had been signed in procedures TSS 15.6.53, " Boron Endpoint-Measurement," TSS 15.6.55, " Rod and Boron Worth Measurements," and TSS 15.6.51, "Zero Power Physics Testing Pollowing Refueling."
This is a Severity Level V violation (Supplement I).
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Changes are being baplemented to the startup testing procedures to l
require a performance review signature as a prerequisite to continued reactor operations or reactor startups.
In addition, procedure changes are being made to allow the intended procedural flexibility of performing steps in a non-sequential order in specific instances.
In addressing the inadequate results evaluation, the corrective action taken immediately was to re-review and correct the identified errors. Secondly, the impact of the errors was evaluated and found to have no safety significance.
To address the concern with the errors made in the MTC calculations, two measures are being taken.
First, the relationship between the Isothermal Temperature coefficient (ITC) and the Moderator Temperature coefficient (MTC) is being added to the ITC Measurement Procedure. Secondly, a new procedure is being developed for the calculations used to provide operational guidac?:
for maintaining a negative MTC.
New members of the Nuclear Group are being given formalized, documented training. Strict procedure adherence is required end aanagement reviews are currently being performed.
i l
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION The completion of the procedure changes addressed above will ensure that the station will be performing tests in accordance with written test procedures. All personnel in the Nuclear Group have reviewed the incidents leading to this violation and have been reminded in group discussions of their responsibilities to perform and review procedures carefully and completely. The responsibility of procedure adherence will be reinforced at the next startup testing preview meeting where the upcoming tasks of the Nuclear Group are examined, reviewed, and discussed.
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l DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The changes to the procedures described above will be implemented prior to Unit One startup currently scheduled for January 3, 1987, 1894K
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