ML20235U066
| ML20235U066 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/04/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3553K, NUDOCS 8710130344 | |
| Download: ML20235U066 (5) | |
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[#\\ Commonwealth Edison
/ One Firct National Plaza Chicago, Illinois
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J Addiess Reply to: Post Office Box 767 v
\\Q. Chicago, Illinois 60690 - 0767 September 4, 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 Unit 1 Response to Inspection Report No.
50-295/87-013 NRC Docket No. 50-295
Reference:
August 4, 1987 letter from C.E. Norelius to Cordell' Reed
Dear Mr. Davis:
This letter is in response to the inspection conducted by M.M.
Holzmer, N.R. Williamsen, and P.L'. Eng of your office on May 8 through May 12, 1987, of activities at Zion Nuclear Fowcr Station.
The referenced letter indicated that certain activities appeared to be in noncompliance with NEC 1
requirements. Commonwealth Edison Company's response to these violations are provided in the Attachment to this letter.
A fourteen day extension was obtained from C.E. Norelius 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, j
very truly yours, l
k L. D. Butterfield Nuclear Licensing Manager 1m Attachment cc: NRC Resident Inspector - Zion J. A. Norris - NRR 01go g 87 h 295
'Y 3553K SEP 8108T fft:
4 ATTACHMENT ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION VIOLATION #1 As a result of the inspection conducted on May 8 through May 12, 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:
Technical Specification 6.2.1.A requires that written procedures be implemented covering operation of systems and components involving nuclear safety of the facility.
SOI-31, Main Steam, requires that prior to removing main steam isolation valve (MSIV) trip solenoid valve DC control power fuses, the MSIV hydraulic pump must be de-energized.
Contrary to the above, written procedures covering operation of systems and components involving nuclear safety of the facility were not implemented in that on April 30, 1987, the Unit 1 MSIV trip solenoid DC control power fuses for all four MSIVs were removed before the four MSIV hydraulic pumps were de-energized, causing all four MSIVs to fail open.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
A.
Standing Order #87-11 was issued that requires in part:
1.
Prior to performing any plant evolution determine if a procedure exists for that task and review it prior to beginning the job.
If no procedure exists to cover the evolution then review of the
" Precautions and Limitations" of the associated System Operating Instructions is required to see if any apply to the evolution at hand.
ii. The OFFGOING NSO on a Unit is to record the procedure number and step (s) in effect on the " Unit operator Turnover Sheet".
The oncoming NSO on a Unit is to review the procedure step (s) that are in effect before relieving the OPPGOING NSO.
B.
Warning Plaques were installed at the fuse locations and the hydraulic pump MCC locations warning the operator of the sequential requirements of this operation.
l C.
The additional restrictions discussed in A.ii have subsequently been incorporated into the administrative procedure governing shift turnover activities.
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-v 2-D.
A set of' usage instructions has been incorporated in the General Operating procedures-(GOP). These instructions provide specific guidance regarding
.the use of'00ps including the requirement to sign-off individual steps upon completion.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION:
Th'e additional restrictions discussed in A.i above will be incorporated into the administrative procedure governing. station organization:2. This procedure change is in the-final stages of' review'and l
preparation.
.I PATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The procedure change regarding'the restrictions of A.i above will be implemented by October 1, 198~1.
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.. VIOLATION #2 As a result'of the inspection conducted on May 8 through May 12, 1987, and in accordance with 10 CFR Part 2,. Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1985), the following
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violation was identified:
1 10 CPR Part 50, Appendix B, Criterion V, as implemented by the licensee's approved quality assurance (QA) Topical Report CE-1A, requires that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings.
Steps II.A.6 and II.A.8 of procedure ZAP 14-51-2, " Inspection, Test'and Operating Status-Tagging of Equipment",. require that for out of service (OOS) card preparation, the z
l Licensed Shift Supervisor and Equipment Attendant / Equipment Operator /NSO (Nuclear Station Operator) ensure that, for the work to be performed, all necessary points of isolation are addressed.
Contrary to the above, activities affecting quality were not accomplished in accordance with documented instructions, procedures, or drawings, in that on April 30, 1987 an OOS card was prepared for Unit 1 main generator repairs and all necessary points of isolation for the MSIV portion of the OOS were not addressed, l
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
The additional points of isolation were added to the original OCS job and the intended generator repairs were then made without further incident.
CORRECTIVE ACTf0N TO BE TAKEN TO AVOID FURTHE'R VIOLATION:
A.
The practices utilized at Zion Station for out-of-Services will be l
reviewed,. This review will include consideration of generating uniform methods of taking major equipment out-of-service.
Since the potential I
l exists for the creation of an extremely large number of Standard 005, along with an associated filing and retrieval system, the scope and schedule for any program alterations will be addressed upon completion of I
the review.
B.
Additional training will be provided to all licensed operating shift members. This training will describe the existing OOS practices and the associated precautions.
C.
The Zion Administrative Procedure (ZAP) governing OOS operations will be expanded to include additional guidance. This guidance will include information regarding the identification and treatment of all points of isolation that may be involved with a given OOS.
A l 1 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The review of OOS practices will be completed by December 31, 1987.
The additional training and procedure changes discussed in B and C above will be completed by February 29, 1988.
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