ML20235U233
| ML20235U233 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/25/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3627K, NUDOCS 8710130419 | |
| Download: ML20235U233 (5) | |
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...n f _Y Commonwealth Edison.
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/ One First National Plaza, Chicago, liiinois.
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(J-[- Address Reply to: Post Offes Box 767 0 P'g v
g Chicago, Illinois 60690 0767
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September 25, 1987-j l
-Mr. A. Bert Davis Regional Administrator-U.S. Nuclear Regulatory Commission Region ~III 799 Roosevelt Road Glen Ellyn, IL 60137 i
Subject:
Zion Nuclear. Power Station Units 1 and 2
. Response to Inspection Report Nos.
50-295/87-15 and 50-304/87-18
]{RC Docket'Nos. 50-295 and 50-304
Reference:
August 26, 1987 letter from C.E. Nore1ius to Corde1l 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 July 2-30, 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 responses to there violations are provided in the Attachment to this letter.
In addition, the referenced letter also expressed concern regarding the adequacy of the administrative programs controlling LER. content'and the-performance of action commitments at Zion Station.. Commonwealth Edison
.j Company's response to these concerns is outlined below.
I The Zion Station Regulatory Assurance Staff has the responsibility i
I for-assuring:that corrective-actions provided to'the NRC either;have been completed or will.be tracked to completion.
As discussed in'the attached violation response, the LER's author relied excessively on preliminary, verbal communication. The Regulatory Assurance Staff was not required to
.i verify the' performance of LER corrective actions reported as' complete.
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As a result, the Regulatory Assurance Staff will now conduct an independent LER review / verification to ensure that any specified corrective j
action has been completed. This will provide an additional' administrative check to help ensure complete accuracy in the content of Zion's LER's.
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A. B.: Davis
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LSzptember 25, 1987
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With-regard'to Zion's-program for. tracking commitments, a review'of- '
the current program's effectiveness has been conducted.. This review
~j concluded that Zion Station does have an effective commitment; tracking system. This system.is currently tracking an average of~350 commitments,
' with roughly 100 additions _or' deletions per month.
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Unfortunately, in the LER in question, the. tracking system was
- never initiated due to the' mistaken belief-that the commitment was already' completed. This deficiency has been effectivelyLaddressed'as discussed above and~in the attachment.
If you have any further questions on this matter, please direct il
- them to Commonwealth Edison Company's' Nuclear Licensing Department.
i Very truly yours,
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l L. D. Butterfield j
Nuclear Licensing Manager i
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ATTACHMENT f
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q ZION NUCLEAR POWER STATION /
RESPONSE TO NOTICE OF VIOLATION
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L VIOLATION #1
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ITEM OF NONCOMPLIANCE 1
As a result of the inspection conducted from July'2-30, 1987, and m' l
in accordance with 10 CFR part 2, Appendix C - General Statement sf Policy andprocedureforNRCEnforcementActions(1985),thefollowing[viclation l
was identified:
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10 CPR 50, Appendix B, Criterion XVI, as implemented by t N.
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licensee's approved Quality Assurance Topical Report CE-1-A, requires that.
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measures beNstablished to assure that conditions adverne to quality are
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promptly identified and corrected.
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Contrary to the above, a condition adverse to quality wa.[Y>date Nt
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identified, but not promptly corrected.
The corrective actionfan
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the maintenance department's computerized work instruction system,' has reported as completed in Licensee Event Report (LER) 295/87005'01, dated April 3, 1987, even though the action had not been accomplished.
j CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED 4
e.
The occurrence discussed in this violation was the result of i
reliance on verbal communication regarding the pro 1> sed LER corrective N
actions. Specifically, the LER author utilized information obtained during a discussion of possible solutions in the course of preparing commonwea)th Edison's internal potentially Significant Event Report. An erroneous j 3
'j assumption was made that this action would be completed prior to the LM 's tssuance.
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Once this discrepancy was discovered, the proposed entry to the maintenance department computerized work request system was made promptly.
CORRECTIVE ACTION TO BE TAKEN TO EDID FURTHER VIOLATION Zion Station management reviews all LERs for content, technical merit, and appropriateness of corrective actions. The Regulatory Assurance i
Staff, which participates in the review of all LERs, has responsibility for assuring thai. corrective actions provided to the NRC either have been H
completed or will be tracked to completion. To avoid further violation, the Regulatory Assurance staff will complete an independent verification that the corrective action has been taken.
If the proposed actions are described in the LER as incomplete, then the corrective actions will be placed in the company's computer $ zed commitment tracking system, y
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The prochdure governing the preparation and issuance of LERs at Zion Station will be changed to reflect the addition of the independent review / verification.
DATE WHEN JULL COMPLIANCE WILL BE ACHIEVED The piacedure change described above will be implemented by December 10, 1987.
s VIOLATION #2,
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ITEM OF HONCf g IANCE As,a result of the inspection conducted from July 2-30, 1987, and in accordarreo with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedurit.for NRC Enforcement Actions (1985), $he following violation was identifibdr
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10 CPR 50,' Appendix B, Criterion XVI, as implemented by the l
licensee'n ap3 roved (mality Assurance Topical Report CE-1-A, requires that
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measures be escobLished to assure that conditions adverse to quality are
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promptly identified and corrected.
10 CER 50, Appendix B, Criterion XI, as
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implemented by the licensee's approved Quality Assurance Topical Report
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CE-1-A, Sections QP 12-51 and QP 12-1, requires that testing, required to l
demonstrate equipment operability, be performed using test procedures which j
assure that> controlled and calibrated test instrumentation is used.
j Centrary to the above, a condition adverse to quality was identlfied but not promptly corrected in that, on July 20, 1987, the licM.see obtained valve stroke times without requiring and documenting the rse of a calibrated, traceable stopwatch for valve operability determination. This practice was followed despite the fact that a violation
, written on February 7, 1985, identified that th9 licensee was using a rxocalibrated, nontraceable stopwatch to obtain valve stroke times for component operability demonstration.
CORRECTIVE ACTION TAKEN AND RESULT 3 ACHIEVED:
A review was conducted of the existing stopwa.tch calibration practices.at Zion Station to determine the potential safety significance of l
this violation. The results of this review are outlined below.
Zion Station received a similar Level V violation associated with Inspection Report Numbers 50-295/85-02 and 50-304/85-02. Commonwealth ndison Company acknowledged this violation in the response (4/9/85 Farrar to Keppler) and committed to the implementation of a procedure to calibrate stopwatches utilized to measure valve stroke times.
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5 Zion Station has retained the appropriate documentation regarding the verification of stopwatch. accuracy since early 19651 This documentation den.onstrates that Zion Station's stopwatches have been' checked against a
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( synchronous clock ~
en by normal line frequency for a period of five minutes. Since nunnal system frequency varies less than 0.1 cycles, the maximum frequency - induced error ovdy five minutes corresponds to 0.5 seconds. This potential error is equjyalent.in magnitude to the error associateC with normal human reaction, time.
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In addition, the proc (dWal accept'ance criteria has been ? I second I
over the five minute (300 sec.)' timing periol.
Errore Of *.his magnitude I
will produce minute inaccuracies in the meast3rement of Zion'e valve stroke j
times, which are typically less than 120 seconds. Thus, there is no potential for any significant, undetected st45 watch inaccuracies.
4 TheoverallconcluNionofthisviolationreviewisthattherewas no safety significance involved. The use of a synchronous clock, d ile not in compliance with Commonwealth Edisco Company's QA program, provides a technically adequate check on' stopwatch accuracy.
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I CORRECTIVE ACTION TO BE TnKEN TO AVOTD FURTHER VIOLATIONt I
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Zion Station recognizov that the synchronous clock is not directly traceable to the National Bureau of Standards (NBS). A{terefore, a procedure is being developed to calibrate Zion's stopwatches against an NBS traceable
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Zion Station is also reviewing di Periodic Tests (pts) for I
references to measurement and teut equi pent (MTE) utilized to determine equipment operability. All appropriate' pts will include the requirement to list the MTE identification number to allow subsequent traceability.
The use of Zion's computers as measuring devices is also under review. The applicability of Commonwealth Edison Company's Q.A. program is being considered.
Finally, a corporate review of,the Q.A. requirements is being conducted to determine the feasibility of generating specific guidance regarding stopwatch calibration.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIFyVEp The implementation of a revised, NBS traceable calibration procedure, the PT review and revision, and the computer review will be completed by December 10, 1987.
The feasibility review of the Q.A. program changes will be completed by March 1, 1988.
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