ML20235U165

Responds to NRC Re Violations Noted in Insp Repts 50-295/86-30 & 50-304/86-30.Corrective Actions:Environ Qualification Variations Rept Filed W/Station Engineering Dept & Deviation Rept Initiated

ML20235U165
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/12/1987
From:	Farrar D COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
3196K, NUDOCS 8710130391
Download: ML20235U165 (3)

Text

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... - - Common ;ealth Edison f

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One First Natiord Plaza, Chicago, Illinois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 0767 June 12, 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.

No. 50-295/86-30 and 50-304/86-30 .

NRC Docket Nos. 50-295 and 50-304

References:

(a) January 30, 1987 letter from J.J. Harrison

'to Cordel1 Reed (b) May 15, 1987 letter from J.J. Harrison to Cordell Reed

Dear Mr. Davis:

This letter is in response to the special safety inspection conducted by A.S. Gautam and M.J. Kopp of your office on December 30, 1986 through January 14, 1987, of activities at Zion Nuclear Power Station. i Reference (a) transmitted the results of this inspection and identified one )

significant Environmental Qualification -(EQ) deficiency. Reference (b)

! classified that EQ deficiency as a Level IV violation. Commonwealth Edison l ' Company's response to this violation is provided in the Attachment to this-letter.

3 i If you have any further questions on this matter, please direct l

them to this office.

Very truly yours, l

\ /.

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$r D. L. Farrar Director of Nuclear Licensing l

Attachment cc: NRC Resident In.npector - Zion J. A. Norris - NRR 3196K 8710130391 870612 ' g PDR ADOCK050g2 G '

l JUN 151WI f50/

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s ATTACHMENT ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION ITEM OF NONCOMPLIANCE As a result of the inspection conducted on December 30, 1986 through January 14, 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:

10 CFR 50.49 Paragraph (f) requires each item of electrical equipment j important to safety to be qualified by testing and/or analysis.

l 10 CFR 50.49 Paragraph (j) requires a record of the qualification  !

documentation of EQ equipment to be maintained in an auditable form to permit verification that the equipment is qualified for its application and meets its performance requirements during an accident.

Contrary to the above, cubicle cooler fan motor lead splice / cable assemblies used in 10 CFR 50.49 designated applications were spliced with various types of non-EQ tapes utilizing sections of non-EQ PVC cable. The licensee identified this deficiency and initiated a program 4 to replace these assemblies. The licensee also stated that based on l l additional industry data available on radiation and aging tests I

performed on PVC cable these splice / cable assemblies were qualifiable.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED l

The non-qualified motor splices and polyvinyl chloride (PVC) wiring were i discovered as part of a general inspection of all environmentally l qualified splices at Zion Station. They were discovered in motors l qualified under the Division of Operating Reactors (DOR) Guidelines. At the time of discovery, Unit 1 was in a refueling outage and Unit 2 was  ;

at power operation.  !

Upon discovery of the non-qualified conditions, as required by the Station's EQ program, an EQ variations report was filed with Commonwealth Edison Company's Station Nuclear Engineering Department i (SNED) and a deviation report (DVR) was initiated. These reports contain a safety analysis and an operability assessment. Based on the safety analysis and operability assessments, the Zion Station Tech Staff determined the cubicle cooler fans with non-qualified splices and wiring would work properly during the design basis accidents and Unit 2 continued operation was justified.

r .

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED: (continued)

All Unit 1 cubicle cooler fan motor splices which were not qualified were replaced with environmentally qualified splices. The undocumented lead wires between the motor junction boxes and the cubicle cooler junction boxes were replaced with qualified wires. The splices and wiring were reinspected to insure a qualified installation. The cubicle cooler fan motors were then tested as part of the operability test of the associated I pumps. All test results were satisfactory. This work was completed prior l to returning Unit I to power operation.

Unit 2 cubicle cooler fan motor leads and splices are being inspected as I part of the Sprir.g,1987 refueling outage. All cubicle cooler fan motors ,

and leads will be environmentally qualified before the Unit is returned to power operation.

Since the PVC wiring and some of the non qualified splices were " internal wiring" on the fan cooler assemblies, walk down inspections of all similar environmentally qualified, " skid mounted" equipment has been performed.

No additional internal wiring problems were found.

< CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION Procedure changes will be made to the cubicle cooler fan motor inspection procedure, E-028-1, to include the motor junction boxes and associated leads in the procedure for future work on the cubicle coolers. This-  !

procedure change will be in place before the next refueling outage at Zion '

Station.

As discussed above, Unit 2 cubicle cooler fan motor leads and splices are being inspected as part of the Spring, 1987 refueling outage. All cubicle cooler fan motors and leads will be environmentally qualified before the Unit is returned to power operation.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED All cubicle evoler fan motor splices will have been inspected and any non-qualified splices replaced by 09/01/87. The necessary procedure changen will be completed by 02/01/88.

3196K

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