ML20245F170

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Responds to NRC 890526 & 0619 Ltrs Re Violations Noted in Insp Rept 50-295/89-19.Corrective Actions:Standing Order Issued on 890601 to Administratively Control Future Failures of 1(2)MOV-CS0049 or 1(2)MOV-CS00050
ML20245F170
Person / Time
Site: Zion File:ZionSolutions icon.png
Issue date: 07/21/1989
From: Kovach T
COMMONWEALTH EDISON CO.
To: Davis A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8908140190
Download: ML20245F170 (6)


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Chicago, Imnas CCC3C - 07C7 July 21, 1989 Mr. A. Bert Davis Regional Administrator U. Nuclear Regulatory Commission Degion III 799 Roosevelt Road Glen Ellyn, IL 60137 y

Subject:

Zion Nuclear Power Station Unit 1 Response to Inspection Report Nos. 50-295-89019 License No. .DPR- 3 9 NRC Docket Nos. 50-295 __

Referencet (a) May 26, 1989 letter from EG Greenman to Cordell Reed (b) June 19, 1989 letter from EG Greenman to Cordell Reed De3r Mr. Davist Reference (a) transmitted the results of a special inspection thst was conducted by Mr. M. Holzmer of your staff during the ptriod of March 17 through May 10, 1989 of certain activities at Zion Station. The terults of this inspection indicated that an apparent violation cf NEC requirements snay have occurrcd. An Enforcement Conference was held in the Reglen III office on May 31, 1989. The evaluation of the results of the information presented at the Enforcement Conference was transmitted to us in Reference (b).

Reference (b) indicated that certain activities appeared to be in violation of NRC requirements. The response to the Violation is provided in the Attachmenr. to this letter. Your cover letter also expressed a concern about two additional issues: (1) Failure of the Operating Ftaff to make an appropriate LCO-determination; and (2) Lack of Station Technical Staff personnel involvement with LCO determinations. Commonwealth Edison agrees that enhancement to the methodology that is currently in place to make capability LCO determinations are warranted. To that end, a Task Force was assemblod to provide recommendations to improve the decision-naking procesc.

The results of this effort are expected to be completed by August 31, lo89.

l However, in the interim, Zion Station has taken site specific corrective actions to address program inadeguncles. These actions are describe 6 in the response to the vloistion.

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A.B5 Davis July 21, 1989 l

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v' Your cover 1satter also discussed an Oct.ober 1, 1989 ew witment t.o terminate t.lae administrative mechani'am currently being uced to address the crecific itasue of operability of CS0049/50, The Station is vtilizing this process to prevent a recurrence of the event until a nermanent solution can b6 6efined. A telephone diticussion which occurred on July 19, 2909 between h .

D., Shafer and P.C Lnfuond regarding this commitment conc 2nded that it would v

be prudent to maintain the temporary administrative contro.1 stechanism in place

, repond Getober 1, 198b if necessary, to prevent recurrence. It is our

. ; .catierst.aud!ng that this agreement meets with your appreal.

N. flerse ditect aSy questions that you tuny have regar. Wag this matter

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Very trtdy yours, y y --

7. J. jfo'vach Nuclesa Lied?.3ing Manager GET/ sci ces Resident Xnspector-Zion
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, l' !TL919Lhant Techtfeal Spec 3fication 3.6.1.B requires that three containment spray sysurmw shall be optaMe for pressure reduction whenever the reactor is L optektiwy except as- opeelfied in 3.6.1.C. 3

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'Techtplcul Specification 3.6.1.C requires that from and af ter the time that one of the three co:ctriment spray systems for pressure reduction is made er found to be inopeintif. for any reason, reactor operation is permissible only during the sueneed$ng 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> provided that during those 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> the Tymaining contairwent spray systems and four f an coolers are operable.

Contrary to the aft"9, Dolt 1 q arated at power levels up to 100% from j March }), I?P.9, unt31 Herch 18, 1989, a period in excess of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, while the 1/i- cot Birtwat spray system was inoperable due to the Iallure of IMOV+Cb0049 to croke during testing.

TMs is a Feverity Level; IV violation (295/09017-03(DRP)) (Supplement 1).

CfaEIINI_ACT10N _2140.L1)!R.EUSULTS ACHIEYEDt The fo33owing site-specific actions were taken to expeditiously address the concerns

1. E13pilng.Rtder_.11Aund ZegaIfina CS-0049 A standing order was issued on June 1, 1989, to administratively control any future failures of 1(2)MOV-CE0049 or 1(2)MOV-Cr0050 until their inclusion into the existing Zion Technical 6pecificat. ions can be eccomplit;hed. This order instittites _s 7-day LCO clock for Unit operation while above cme shutdown. This cloc'c was esprof.say implemented to reflect the importance of RHR containment spray during i.hu recirculation phase of a LOCA.

The standing erder will remain in effect. ubtil either appropriate controls are 1.ncluded into Clon's Technical Specificati9ns, or an evaluation of the result.s of the 'Iecunical Specification review described below indicates that such cor/rois are unwarranted.

2. 2mperarylrmedgInfhange 10_ET 14 "IncQLporate ECUipmcat_EuryR11]Datt j

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This ac tion E vohet a temporary change to Zion's PT-14, which was implemented on June 7, 1989., Tuls change modified the form associated with PT-14 % gr ovide more physical space to better docwnent the logic associated sit b declaring equipc ent inoperable. The pre-existing PT-14 contained directions to consider Zion's AOPs, EOPs, and the FSAR, in addition to the Technical Specifications themse]ues. This change to the form provieeG for easier docwnentation of that review.

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3. CRN1MniCAL19n D.f_.the Event _Lg_Qpfgating Pe1.5.DAR21 Tha results of the Enforcement Conference, the logic behind the temporary change to PT-14, and the future direction of Zion Station on the issue of operability was discussed in a June 7,.1989 letter from the Assistant Superintendent for Operations to all Shift Supervisors and Operating Engineers. This information was also reviewed with all Operating crews by the Assistant Superintendent for Operations during routino informational discussions.

CQRRECIIVE_ACTIO!!_TO BE TAKEN TO AVOID FURIllEILyl.QLATION:

The following corrective actions include Corporate and Zion-specific initiatives to address the concernt CHIpDI.nte _InitiatiXS TAS]Lfpree RegArding_.DpSIAl2111ty A task force comprised of a mixture of personnel from both the nuclear stations and the corporate offices has been formed to review Commonwealth Edison's Nuclear Operation policy regarding the assessment of operability. This task force vill compare Com anonwealth Edison's existing practices to the NRC'c current operability interpretation and will recommend policy revisions to address any discrepancies. An implementation plan will also be provided.

Lion _ Specific Initiatives

1. UpgIndtL9_f_EI.JA, "Ingperahlm_ Equipment _S.urys_illann2_JAsis".

A pre-existing effort was in progress to upgrade the quality of PT-14 review in general. This effort involved a broader scope than the narrow issue of Technical Specification operability. It introduces the concept of an Equipment Failure Status Diagnostic Chart to accist in distinguishing between failures involving fire protection equipment, radiation monitors, or Technical Specification equipment. It also distinguishes between equipment that involves entry into Technical Specification LCO and equipment that is characterized as " Degraded" and whose failure does not involve any additional surveillance or entry into a time clock.

While this effort does not directly address the issues related to this violation, it does produce a much-needed upgrade to the formality of Zion's PT-34.

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2. UpgaLda_D.f. Zinn'1_I,CH_patanninstipa_CapAbl.111111 Concurrent with the Task Force evaluation, Zion is revising its administrative process for determining the proper course of action in response to the failure of a vmponent. This revision will represent a significant alteration to Zion's current approach to these matters.

The revised process will provide for a two phase review of any observed component failures, discrepancies or deficiencies

1. An initial assessment will be performed by on-shift personnel. This assessment will decide if an entry into a Technical Specification LCO is appropriate. This determination will consider both the "specified function" and the " support function" of a given component, as described in Definition 1.27 of Zion's Technical Specifications. The inclusion of " support function" is the area which requires the most upgrading at Zion Station.
2. The initial assessment which was performed by on-shif t personnel will result in a Yes or No determination of an LCO condition. In order to address the concern in your cover letter regarding the adequacy of technical oversight, at a minimwn, a subsequent review of ell "No" determinations will be performed by off-shift personnel. This review will consider both the adequacy of the initial, on-shift assessment and whether any add 2tional actions aie required. Examples of potential additional actions are

- Expedited maintenance activity

- Technical Specification change

- Procedure changes

- FSAR changes

- 10CFR50.59 reviews The above process is currently under development. While there may be some alteration from the framework describef f above, the final product is not anticipated to differ significantly.

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3. TaghninnLEpfrificBliD11_heYicw of Recirnuli:Ltann_fhas funchinn Zion Station will review recirculation phase functions for possible inclusion in Technical Specifications. Standardized Technical Specifications will be used as a reference in the Jeview. Our evaluation will also include a rev!cw of the Byron /Braidwood Technical Specification for potential applicabi2ity to Zion. Based upon the results of this review, a Technical Specification change will be submitted, if appropriate.

DATE. RITIL Fil L h_CDtiRLI ANCE_W Rh_L R_t4 ET :

The task force review of operability issues will be completed by f August 31, 1989.

The FT-14, " Inoperable Equipment Surveillance Tests" procedure upgrade w1J1 be completed by August 1, 1989.

The process of upgrading Zion's LCO determination capabilities is currently under development. The first draft of this process is expected to be completed by August 1, 1989. The final draft is to be submitted to On-Site Review by September 1, 1989. Implementation of the revised program will be completed by October 31, 1989.

The recirculation phane Technical Specification eview will be completed by October 1, 1989.

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