ML20236K931

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Responds to NRC Re Violations Noted in Insp Repts 50-295/87-10 & 50-304/87-13.Corrective Actions:Electronic Items Identified & Resealed or Repackaged to Exclude Air Contamination & Light & Pump Inlets & Outlets Plugged
ML20236K931
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 07/30/1987
From: Butterfield L
COMMONWEALTH EDISON CO.
To: Davis A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
3415K, NUDOCS 8708100056
Download: ML20236K931 (4)


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  • Commenw:dth Edisin C One First National Plaza. Chicago, liknots OO Address Reply to: Post OFce B'oT7C Chicago, Ilknois 60690 0767 July 30, 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.

50-295/87-10 and 50-304/87-13 NRC Docket No. 50-295 and 50-304

Reference:

June 30, 1987 letter from J. J. Harrison to Cordell Reed

Dear Mr. Davis:

This letter is in response to the inspection conducted by T. E.

Vandel and others of your office on May 11-21, 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 these violations are provided in the Attachment to this letter.

l If you have any further questions on this matter, please direct them to this office.

Very truly yours, p L. D. Butterfield Nuclear Licensing Manager l Cs Attachment cc: NRC Resident Inspector - Zion J. A. Norris - NRR 3415K 8708100056 070730 PDR ADCCK 05000295 b3 jQ " 1 k O PDR yFc /

e ATTACHMENT ZION NUCLEAR POWER STATION RESPONSE TO NOTICE OF VIOLATION VIOLATION 1 ITEM OF NONCOMPLIANCE As a result of the inspection conducted on May 11-21, 1987, and in accordance with 10CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1985), the following violation was identified:

10CFR 50, Appendix B, Criterion XIII, as implemented by Section 13.0 of the Commonwealth Edison Company Topical Report, CE-1-A requires that measures be established and implemented to centrol and preserve material and equipment in accordance with work and inspection instructions to prevent damage or deterioration. When necessary, special protective environments, specific moisture content levels, and temperature levels, shall be specified and provided.

Contrary to the above, nine examples of inadequate preservation, protection, and control of material and equipment in storage were identified in the main warehouse.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:

The following actions have been taken to improve storage of materials:

All electronic items have been identified and resealed or repackaged to exclude air contamination and light.

Pump inlets and outlets have been plugged or protected.

l l Threaded snubbers parts have been cleaned capped, plugged and l provided with thread protection.

, A special cabinet and anti-static storage container has been l ordered to store printed circuit boards vertically and as an added

protection from airborne contaminants and temperature extremes.

The delivery door at the north end of the warehouse is kept closed.

Pump impellers and machined surfaces have been protected to the extent feasible.

All shelf life items have been reviewed and all discrepancies have been corrected.

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I CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION:

Zion stores Department has implemented an aggressive and comprehensive program to ensure the storage of safety related items is in compliance with the following instructions and procedures; ANSI Standard l N45.2.2-1973, Zion administrative procedures No. ZAP 13-52-1, 13-52-2, and Stores Instruction - Generating Station Operating No. 2. In addition to this review program, the following actions are planned:

A sign will be posted on the north delivery door stating that the door is to remain closed.

All circuit boards will be identified and repackaged in anti-static j wrapping, bags or edgeliners. >

An inventory of all safety related items is currently in progress to identify discrepancies in the computer data records.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

All pending corrective actions discussed above will be completed by October 1, 1987.

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VIOLATION 2 ITEM OF NONCOMPLIANCE As a result of the inspection conducted on May 11-21, 1987, and in accordance with 10CPR part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1985), the following violation was I identified:

10CFR50, Appendix B, Criterion XVI, as implemented by Section 16.0 of the Commonwealth Edison Company Topical Report CE-1-A requires that measures be established and implemented to assure that conditions adverse to quality such as deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, inadequate or incomplete corrective action was taken to resolve deficiencies identified by internal quality assurance audits of the control, preservation, protection, and information requirements for. material and equipment in storage.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:

A complete walkdown has been performed in the safety related and regulatory related areas in regards to the shelf life program. All stored components requiring shelf life controls have been identified and cor rective action taken on those items that were identified as being deficient. The computer has been updated and the master file is current and up to date.

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a q The items with expired shelf-life found by the inspector, while they should have been removed from the shelf, would not have been issued for j use in the field because of a long standing practice for material issue in l the stores department which requires the verification of shelf-life as one l of the final actions prior to issue.

CORRECTIVE ACTION TO DE TAKEN TO AVOID FURTHER VIOLATION:

Training will be held for all stores personnel on the implementation and importance of the shelf-life program.

The shelf-life program will be revised to include a requirement that documentation for shelf-life extensions be kept as part of the shelf-life record for the specific item.

DATE VHEN FULL COMPLIANCE WILL BE ACHIEVED:

These actions will be completed by October 1, 1987 l

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