ML20217F086
| ML20217F086 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/30/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217F076 | List: |
| References | |
| 50-295-97-19, 50-304-97-19, NUDOCS 9710070367 | |
| Download: ML20217F086 (5) | |
Text
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s NOTICE OF VIOL.ATION Commonwealth Edison Company Docket Nos. 50-295; 50-304 Zion Nuclear Generating Station License Nos. DPR 39; DPR-48 During an NRC inspection conducted from July 19 through August 29,1997, five violations of i
NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Acticns," NUREG-1600, the violations are listed below:
1.
10 CFR Part 50, Appendix B, Criterion 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, procedures, or drawings.
System Operating Instruction 11. " Diesel Generator Service Water System Lineup,"
Revision 3, Appendix B-2, requires that the 2A DIG [ Diesel Generator) Lube Oil Cooler SW [ Service Water) inlet Pressure Indication Isolation Valve, 2SW1814, be closed.
Operating Special Procedure 97-014, " Mitigative Actions to prevent a Nitrogen Bubble Forming in the Reactor Head," Revision 1, Section 5.6.b, specifies that the volume control tank pressure be maintained less than 2 psig.
Zion Administrative Procedure 400-01B, " Foreign Material Exclusion (FME) Program,"
Revision 4, Section G 2.a(5), requires that all system and equipment openings be protected with a suitable FME device during work and while the FME zone is unattended.
Contrary to the above, activities affecting quality were not accomplished in accordance with applicable precedures or instructions in the following instances:
On August 9,1997, the inspectors found the 2A emergency diesel generator lube a,
oil cooler service water inlet pressure indication isolation valve,2SW1814, out-of-position cpen.
b.
On August 6,1997, the inspectors identified that the volume control tank pressure was maintained at approximately 10.8 psig.
On August 28 and 29,1997, the inspectors identified that FME devices were not c.
installed to protect the upstream side opening of the lower and upper bearing supply 1 ne flanges for the 1 A service water pump while the area was unattended.
This is a Severity Level IV violation (Supplement 1). (50-295/97019-01; 50 304/97019-01) 2.
Technical Specification 6.2.1.a requires that written procedures be prepared, implemented, and maintaine.d for procedures recommended in Appendix A of Regulatory Guide 1.33, Rovision 2, February 1978.
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, specifies equipment control as an example of an administrative procedure.
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- s Notice of Violation '
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i Zion Administrative Procedure 300-01, " Conduct of Operations," Revision 4,Section X.A, 4-
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states, in part, that the operations department is responsible for and has operational
- authority over all plant systems and equipment, except as stated in Station Policy 2-11,
" Configuration Control."
Station Policy 2-11. " Configuration Control," dated April 7,1997, requires, in part, that-plant equipment may be operated by personnel outside of their operational authority if the equipment has been verified to be within a placed out-of-service boundary, specifmally held for that work group, or the manipulation is controlled by an applicable procedure or
' work instruction that requires and provides a record of specified information, including the licensed shift supervisors determination of the final position.
Contrary to the above, on August 27,1997, an engineering contractor operated the 2C service water pump lower bearing supply isolation valve, 2SWO624, without authorization from the operations department, an applicable work request, an out-of-service requet,1, a procedure, or a work instruction which fulfilled the requirements of Station Policy 211.
This is a Severity Level IV violation (Supplement I). (50 304/97019-02) 3.
Technical Specification 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, specifes emergercy core cooling system and emergency power tests as examples of surveillance test procedures.
Periodic Test 2A-RT, " Safety injection System Tests During Refueling," Revision 0, Section 5.1, Step 23, states, in part, that if the safety injection pump head calculated in Step 22 is not within the set value range, then stop the 'A' safety injection pump.
Technical Specification Surveillance 3.8.1.10-1, " Loss of Offsite Power Testing of Diesel Generators During Refueling for Unit 1," Revision 4, Section 8.2.C, Step 26, requires that
"]E another section of this test will be performea next, THEN Steps 25 and 26 may be N/A'd [ Marked as Not Applicable);" otherwise, place the " Fire Alarm" control switch in the
" Normal" position.
-Technical Specification Surveillance 3.8.1.10-1, " Loss of Offsite Power Testing of Diesel Generators During Refueling for Unit 1," Revision 3, Gection 8.2.8, Step 2, requires, in
- part, that approximately 2 seconds after bus 148 is deenergized, test switch SS1 is to be placed in the " Test" position.
^
Contrary to the above:
On June 9,1997, the safety injection pump head calculated in Step 22 was not a.
within the set value range and the operators failed to stop the 2A safety injection l
pump.
's Notice of Violation 3-b.
- On July 29,1997, during performance of Technical Specification Surveillance 3.8.1.101, Section 8.2.C, Step 26 was marked as N/A without the specified condition being met.
On July 24,1997, during performance of Technical Specifx:ation Surveillance c.
3.8.1.10 1, Section 8.2.B, an engineer placed test switch SS I in the ' Test" -
position prior to bus 148 being doenergized, which resulted in an inadverient engineered safety feature actuation.
l This is a Severity Level IV violation (Supplement 1) (50 295/97019-03; 50-304/97019-03) 4.
Technical Specification 6.2.1.a requires tisat 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 procedural j
adherence as an example of an administrative procedure.
Zion Administrative Procedure 100-07, "Use of Procedure," Revision 4, Section 2, requires, in part, that if the procedure cannot be performed as written, stop the evolution, place the system in a stable and safe condition, and, if the needed procedure change is not editorial, revise the procedure prior to continuing with the evolution.
Zion Administrative Procedure 100 07, "Use of Procedures," Revision 4, Section 6, requires, in part, that steps without conditional statements marked as not applicable (N/A) shall be approved by a management supervisor, the reason that the step was marked l
N/A be annotated, and the annotation be signed and dated.
Contrary to the above:
On July 19,1997, Operating Special Procedure 97-023, " Flushing the Component a.
Cooling Water Surge Tanks / System for Reduction in Copper Concentration,"
Revision 0, could not be performed as written, in that the component cooling -
water surge tank was not draining as expected. The licensee failed to stop the evolution, place the system in a stable and safe condition, and revise the procedure prior to continuing with the evolution.
b.
On August 13,1997, the inspectors identified that Operatitig Special Pre cedure 97-014, " Mitigating Actions to Prevent a Nitrogen Bubble Forming in me Reactor
= Head," Revision 2, Step 6, which provides guidance for maintaining letdown flow and volume control tank temperature and pressure, was improperly annotated as i
not applicable (N/A). A management supervisor had not approved marking the step as N/A, did not annotate the reason that the step was marked N/A, and did not sign and date the annotation.
On July 24 and 29,1997, the inspectors identified that Technical Specification c.
Surveillance 3.8.1.10-1, Revisions 3 and 4 respectively, Section 8.2.A, Step 12, which requires containment ventilation and purge to have been secured or verified
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-Notice of Velation.
secured, were improperly annotated as N/A, in that a management supervisor had not approved marking the step es N/A, annotated the reason that the stop was marked as N/A, or signed and dated the annotation.
This is a Severity Level IV violation (Supplement l). (50 295/97019 04; 50 304/97019-04) 5, 10 CFR Part 50, Appendix B, Criteria X, " Inspection," requires, in part, that a program for inspection of activities affecting quality be established and executed by or for the organization performiog the activity to verify conformance with documented instructions, procedures, and drawings for accomplishing the activity.
Maintenance Procedure M03017 " Anderson - Greenwood Check Valves, inspection and Overhaul," Revision 0, Section 8.5, " Valve Installation," requires, in part, that a final cleanliness inspection shall be performed, then the check valve shall be installed into the system.
Contrary to the above, on July 26,1997, the quality control inspection conducted for the installation of the 1B emergency diesel generator train 'A' starting air check valve, 1DG0121, was not adequate to verify conformance with the maintenance procedure M030-17, in that a manufacturers material specification tag lodged between the check valve body and air system pipe flange was not identified. This tag subsequently caused -
an air leak voich resulted in a delay in the restoration of the 1B emergency diesel l
generator to service.
This is a Severity 1.evel IV violation (Supplement I), (50 295/97019-07)
Pursuant to the provisions of 10 CFR Part 2.201, Commonwealth Edison Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region ill, 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 of Violation (Notice). This reply should be clearty marked as a " Reply to a Notice of Violation" and should irclude 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 response may reference or include 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 be taken. Where good cause is shown, consideration will be given to extending the response time.
Because your 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 deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of privacy or provide the information required by 10 CFR Part 2.790(b) to support a request for withholding confidential commercial or financial 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 Lisle, Illinois this 30th day of September 1997 6
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