ML20215C942

Responds to NRC Re Violations Noted in Safety Insp Repts 50-295/86-11 & 50-304/86-10.Corrective Actions: Mod Check Sheet Revised to Include Step to Insure Labeling of New Components

ML20215C942
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	08/13/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1974K, NUDOCS 8610100537
Download: ML20215C942 (6)

Text

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\ " ') One First Address National Reply to: Post Plaza Chicago, Office Box 767 Illinois k./ Chicago, Illinois 60690 - 0767 August 13, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Zion Nuclear Power Station Units 1 and 2 Response to I&E Inspection Report Nos.

50-295/86-011 and 50-304/86-010 NRC Docket Nos. 50-295 and 50-304

Reference:

July 15, 1986 letter from W. G. Guldemond to Cordell Reed.

Dear Mr. Keppler:

This letter concerns the routine safety inspection conducted by Messrs. M. M. Holzmer, and L. E. Kanter of your office on April 14 through June 13, 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 responses to these two violations are contained in Attachments 1 and 2.

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

Very tru y yours, A

m D. L. Farrar Director of Nuclear Licensing Im Attachments cc: Region III Inspector - Zion J. A. Norris - NRR AUG1 4 %G 8610100537 860813 1974K PDR ADOCK 05000295 G PDR

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ATTACHiWbrF 1 1

ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION ITEM OF NONCOMPLIANCE As a result of the inspection conducted on April 14 through June 13, 1986, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CPR Part 2, Appendix C (1985), the following violations were identified:

1. Technical Specification 6.2.A states in part, " Detailed written procedures including applicable check off lists covering items listed below shall be prepared, approved, and adhered to:"

" Normal startup, operation, and shutdown of the reactor and other systems and components involving nuclear safety of the facility." and

" Preventive and corrective maintenance operations which could have an f

effect on the safety of the facility."

a. Operating procedure SOI-31, Main Steam, Step 3.6.5, CAUTION requires that prior to removing the DC solenoid fuses for the main steam isolation valve (MSIV) solenoids, the operator verify the correct fuses by checking the appropriate drawing.

b. Zion Administrative Procedure, ZAP 2-51-1, Origination and Routing .

of Work Requests, requires the following:

- The Operating Shift Supervisors are required to record the tests and specify who will perform the tests upon the completion of the repair work, by checking the appropriate box.

- The Operating Engineer is to make a final review of the work request, then sign and date the appropriate block.

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- The Master Mechanic / Maintenance Staff Engineer is to review the work request and initial to indicate receipt and acceptance.

- The Operating Shift Supervisor (SRO licensed only) is to sign the block that gives authorization to start the work.

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r-Contrary to the above:

a. On May 5, 1986, with Unit 1 in Mode 3 (Hot Shutdown), an equipment operator failed to follow operating procedure s0I-31 in that he attempted to remove the MSIV DC solenoid fuses, but failed to check the appropriate drawing prior to removing the fuses. As a result, the operator inadvertently removed the fuses to both trains of engineered safety features-(ESP) logic, rendering both trains of ESF logic inoperable for a period of approximately three minutes.

b. For Zion Work Request Z-48625, dated March 2, 1986, for the replacement of the control room makeup HEPA filter:

- The oper2 ting Shift Supervisor failed to record the test and specify who will perform the test upon completion of the repair work in that he checked the incorrect box on the work request form,

- The Operating Engineer reviewed, signed and dated the appropriate block; however, in his review he failed to realize that a surveillance test was required,

- The Maintenance Staff Engineer who reviewed the work request, failed to initial the form to indicate receipt and acceptance, and

- Shift authorization was not obtained prior to the work and the block was not signed.

Corrective Action Taken and Results Achieved

a. 1. Disciplinary action has been taken against the individuals who failed to follow the procedure.

2. All shifts have been spoken to reaffirming the need to follow procedures.

3. Licensed personnel and equipment operators have been made aware of this event in routine retraining and by placing a report of the event in Required Reading Package 86-06.

4. The modification check sheet has been revised to include a step to ensure that labeling of new components added per the modification is addressed when implementing a design change.

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5. The procedure for MSIV shutdown (SOI-31, Section 3.6) has been rewritten to clarify the correct fuses to be removed.

6. Temporary labeling was installed on both units. In addition, permanent labeling was installed on Unit 2 during a recent shutdown.

7. All station personnel were spoken to reaffirming the need to follow procedures.

b. 1. The SCRE and Operating Engineer were reinstructed on the testing requirements of the Technical Specifications related to filter testing.

2. The Mechanical Maintenance department has been assigned responsibility for filter changeouts to ensure that this work follows the normal work request procedure. The stationman department is no longer coordinating this work.

i Corrective Action To Be Taken To Avoid Further Violation

a. 1. Zion Administrative Procedure 5-51-3 will be rewritten to include a checklist for periodic procedure review of operating procedures.

, This checklist will include " human factor" type items that are to be addressed in the procedure review. An INPO Good Practice, INPO 84-020 (OP-210), will be reviewed when writing this procedure.

2. The labeling associated with the Unit One MSIV fuses will be permanently improved.

3. A walkdown of the frequently manipulated fuses in the Unit 1 Auxiliary Electric room will be conducted to ensure that they are appropriately labeled. Any deficiencies identified will be corrected on both units.

b. 1. Cognizant individuals, including Shift Management, Operating Engineers, and licensed personnel, will be made aware of this event in routine retraining and by placing a report of the event in the Required Reading Package.

Date When Full Compliance Will Be Achieved October 15, 1986.

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ATTACHIENT 2 ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION ITEM OF NONCOMPLIANCE As a result of the inspection conducted on April 14 through June 13, 1986, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CPR Part 2, Appendix C (1985), the following violations were identified:

Technical Specification 4.17.1.C requires that the control room makeup adsorber system shall be demonstrated operable. Technical Specification 4.17.1.C requires that the control room makeup HEPA filter be efficiency tested after each complete or partial replacement of the filter bank.

Contrary to the above, the control room makeup HEPA filter was replaced on March 7, 1986, and the system was returned to service without the system demonstrated system operability until efficiency testing approximately 40 days after the replacement.

Corrective Action Taken and Results Achieved:

1. The SCRE and Operating Engineer were reinstructed on the testing requirements of the Technical Specifications related to filter testing.

2. The Mechanical Maintenance department has been assigned responsibility for filter changeout work requests. The Stationman department is no longer coordinating this work.

3. Placards have been placed on all safety related filter housing doors (both HEPA and charcoal filters) outside of containment to remind personnel of the filter testing requirements in Technical Specifications.

Corrective Action To Be Taken To Avoid Further Violation:

1. Cognizant individuals, including Shift Management, Operating Engineers, and licensed personnel, will be made aware of this event in routine retraining and by placing a report of the event in the required reading

_ package.

l 2. Two periodic tests PT-18, (Control Room Charcoal Booster Fans Tests) and i PT-19 (Fuel Building Ventilation Test) will be revised to include filter l testing requirements.

3. Annunciator Response manuals for panel 20 and 21 of the control room and for local ventilation panels ILP22, 2LP22, and OLPl? will note the testing requirements should the filters need replacement.

4. Placards will be placed on the safety related filter housing doors inside containment to remind personnel of the filter testing requirements in Technical Specifications.

5. The Assistant Superintendent for Maintenance will instruct the Mechanical Maintenance Work Analyst to notify Technical Staff of all filter changeout work, via work instructions on the work request.

Date When Full Compliance Will Be Achieved Action #4 will be completed during the next refueling outage for each unit. The current schedule calls for a September, 1986 Unit 1 outage and a March, 1987 Unit 2 outage. Actions 1, 2, 3, and 5 will be completed by October 15, 1986.

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