ML20235T794
| ML20235T794 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/21/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8710130219 | |
| Download: ML20235T794 (3) | |
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- ~k Commonwealth Edison M
M A* t One First Ndional Plaz?, Chicago, Illinois pri Address Reply to: Post Offica Box 767 I
Chicago, Illinois 60690 0767 August 21, 1987 Mr. A. Bert Davis 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 Inspection Report Nos.
50-295/87-16 and 50-304/87-16 NRC Docket No. 50-295 and 50-304
Reference:
Tuly 22, 1987 letter from W.L. Forney to Cordell Reed-
Dear Mr. Davis:
This letter is in response-to the inspection conducted by M.M.
Holzmer, N. Williamsen, and P.L. Eng of your office on June 2 through July.1, 1987, of activities at Zion Nuclear Power Station.- The referenced letter indicated that certain activities appeared to be in noncompliance with NRC requirements. Commonwealth Edison Company's response to this violation is provided in the Attachment to this letter.
A five day extension was obtainod from W.L. Forney upon receipt of the referenced letter due to a delay in mailing.
If-you have any further questions on this matter, please direct them to this office.
Very Truly Yours, i
h L. D. Butterfield Nuclear Licensing Manager cs Attachment cc: NRC Resident Inspector - Zion J. A. Norris - NRR a
(i O 2 4 1987
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ATTACHMENT l
ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION 1
ITEM OF NONCOMPLIANCE As a result of the inspection conducted on June 2 through July 1, 1987, 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:
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10 CFR 50, Appendix B, criterion V, as implemented by the licensee's approved Quality Assurance Topical Report CE-1-A, requires that activities affecting quality be accomplished in accordance with documented procedures. Zion administrative procedure ZAP-3-51-1 requires that the originator of a work request identify the equipment name and its location on the work request form and that the operating shift supervisor review the information for completeness and accuracy.
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Contrary to the above, activities affecting quality were not accomplished in accordance with documented procedures in that for work requests Z56525, Z59405 and Z60054, dated February 3, April 22 and May 12, 1987, respectively, the work request originators incorrectly identified I
equipment locations for valves 2SW0010 and 2SWO0ll, and the operating shift supervisor's review failed to identify the incorrect equipment location.
l COfiRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
The event associated with the violation addressed above resulted in flooding of the 2A and 2B standby diesel generator fuel oil tank rooms.
Fuel oil tanks 2A and 2B were sampled and analyzed for water and sediment.
The fuel oil from both tanks was found to be acceptable. The fuel tanks, tank welds, and support structures were examined by the Station's In Service Inspection group and were found to be satisfactory. The fuel oil transfer pump motors were disassembled and repaired.
Station management reviewed the requirements of the procedure which governs the work request program, ZAP 3-51-1 (Origination and Routing of Work Requests), in the context of this event. This review specifically included a comprehensive discussion of steps A.1, which directs the work i
request originator to hang a tag on or near the affected equipment, step 1
A.2, which requires the originator to specify the work location, step A.10, which requires the operating shift supervisor to review the work request for completeness and accuracy, and step A.53, which requires the maintenance foreman to review the job, job site, and the work package. Per the ZAP, hanging of tags is recommended but not mandatory. Consideration was given to requiring equipment tags for all work requests, but this was determined to be impractical due to the inaccessibility of plant areas during operation.
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I The review concluded that the zap, as written, does provide j
adequate guidance for work to be requested and performed in accordance with j
the company's Quality Assurance program.
It was noted that the ZAP is written in general rather than specific terms. The review also concluded that a more highly detailed procedure would not be desirable because the j
work request program would lose the flexibility needed to accommodate the I
variety of circumstances under which work is requested.
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The event itself was reviewed to determine the need for changes in the work requesi program.
It was noted that the work location was incorrectly specified by the originator, and that the shift supervisor review did not identify the error.
The event was discussed with the work request originator and with Operating Department management.
It was also noted that many other unusual circumstances associated with this event were necessary for its occurrence.
In particular, there were two rooms of identical appearance in adjoining locations with identical equipment inside. At the time of the event, work requests were open on both valves in both rooms by the same work group.
In addition, these valves are check valves, which are not labelled.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOIATION:
Zion Station is taking the following steps to improve the work control process. A new administrative procedure, ZAP 10-52-6, has been initiated, establishing standards for labelling of components throughout the plant. A new position, the Station Label Coordinator, has been created and filled. ZAP 3-51-1 will be revised to include instructions for the work crew to ensure positive identification of equipment prior to commencing work. This positive identification may be by means of an equipment tag, or by other means as appropriate. The Maintenance Department will develop guidance to assist in the positive identification of plant equipment.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The ZAP on equipment labelling has been initiated and will be implemented by December 1, 1987. The program to improve labelling in the plant is ongoing, and is expected to take several years to complete. The changes to zap 3-51-1 will be implemented by February 15, 1988. The guidance for positive equipment identification will be developed by February l
15, 1988.
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