ML20245G949

Informs That Allegation RIII-88-A-0140 Considered Closed. Licensee 890526 Response to NRC Request for Info Acceptable

ML20245G949
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/21/1989
From:	Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
Shared Package
ML20245G953	List: ML20245G949 ML20245G963
References
RIII-88-A-0140, RIII-88-A-140, NUDOCS 8906290330
Download: ML20245G949 (2)

Text

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4 JUN 21 1989 -

Docket No. 50-295.'

Docket No. 50-304 Commonwealth Edison Company ATTN: Mr. Cordell Reed Senior Vice President-

' Post Office Box 767.

Chicago, IL- 60690 Gentlemen:

We have reviewed your response regarding an allegation we forwarded to you for investigation by our letter dated April 21 1989 (attached). Our correspondence requested you to describe what actions have been or are being

.taken to ensure that Temporary Change documents are legible and can be followed without placing undue stress on personnel using these instructions.

In addition, we also requested you to describe the bases for partially stroke

-testing service system Motor Operated Valves for periodic Technical Specifi-

.ciation operability testing.

Your letter of May 26,- 1989 (attached) indicated that your investigation of Temporary Change legibility was substantiated. We understand that concerns l

with. temporary procedure changes were identified in Inspection Report Nos. 50-295/88023(DRP); 50-304/88023(DRP) and are currently being tracked as an open item to be reviewed during future inspections. In regards to our second request, we accept your bases. for partially stroke testing service system motor operators valves (MOVs) for periodic Technical Specification operability testing. No violations of NRC re Weconsiderthisallegation(RIII-88-A-0140)quirementswereidentified.

closed.

Sincerely, w stano6 hr W.D. Ehder" W. D. Shafer, Chief Reactor Projects Branch 1 Attachments: As stated L See Attached Distribution k Dobk [

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Commonwealth Edison Company 2 JUN 21 1983 j i

l Distribution cc w/ attachments:

T. J. Maiman, Vice President, PWR Operations T. Kovach, Nuclear '

Licensing Manager T. Joyce, Station Manager ~

Chandu Patel, Project Manager, NRR DCD/DCB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public y Utilities Division Mayor, City of Zion C. Weil, RIII J. Hinds, RIII I

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Docket No. 50-295 Docket No. 50-304.

Commonwealth Edison Company ATTN: Mr. Cordell Reed Senior Vice President l Post Office Box 767 Chicago, IL 60690 Gentlemen:

The U.S. Nuclear Regulatory Commission recently received two allegat3ons concerning activities at the Zion Nuclear Power Plant (RIII-88-A-0140).

Details of this allegation are provided for your review and followup.

We request that the results of your review and disposition of these matters be submitted to Region III within 30 days of the date of this letter,. We request that your response contain no personal privacy, proprietary, or safeguards information so it can be released to the public and placed in the NRC Public Document Room. If necessary, such infonnation shall be contained in a separate attachment which will be withheld from public disclosure and the affidavit required by 10 CFR 2.790(b) must accompany your response. l The enclosure to this letter should be controlled and distribution limited to personnel with a "need to know" until your investigation of the allegation has been completed and reviewed by NRC Region III. The enclosures to this letter are considered as Exempt from Public Disclosure in accordance with Title 10, Code of Federal Regulations, Part 2.790(a). However, in accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, excluding the enclosures, will be placed in the NRC Public Document Room.

The responses directed by this letter and the accompanying ent.losures are not subject to the clearance procedures of the Office of Management and Budget i as required by the Paperwork Reduction Act of 1980, PL 96-511.

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TTACHMENT CON 10 2.790 rmation Upon ion This

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Commonwealth Edison Company 2 APR 21 1999 Your cooperation with us is appreciated. We will gladly discuss any questions you may have concerning this information.

Sincerely, l

Original signed by E. G. Greenman Edward G. Greenman, Director Division of Reactor Projects

Enclosure:

Allegation Details (Enclosure Contains 10 CFR 2.790(a)

Information) cc w/o enclosure:

T. J. Maiman, Vice President, PWP, Dperations T. Kovach, Nuclear Licensing Manager T. Joyce, Station Manager Chandu P. Patel, Project Manager, NRR DCD/DCB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division Mayor, City of Zion ACHMENT CO 10 7 onnation RIII .6 II Rh!

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A ent'contains g 0 CFR 2.790.information O Summary of Allegation (RIII 88-A-0140)

Allegation:

1. That copies of the Temporary Change Cover sheets reproduced for users are, in some cases UNREADABLE and that directions given in some of the temporary changes are difficult to follow.

2. That some procedures produced for users are difficult to read or are j otherwise difficult to follow because of poor temporary change execution j (layout, cross-outs, legibility).

3. That partial stroking of service system motor operated valves (MOVs) has been employed in periodic Technical Specification (T3) operability testing.

4. That the justification for partial stroking service system MOVs provided by the Technical Staff to the operators is inadequate.

We believe that to adequately resolve these issues, the following as a minimum must be addressed:

a. Describe what actions have been or are being taken to improve the temporary change process to the end that procedum changes are legible and can be followed without placing undue stress on the users.

b. Describe the basis for partially stroke testing service system MOVs for periodic TS operability testing.

In your response, include the details of your plan including the size of the temporary change cover sheet sample examineo, the service systems examined, and the methodology employed to support a conclusion that the concerns are or are not substantiated. If substantiated, provide your corrective actions to address the immediate concern and actions to prevent recurrence.

These items are forwarded as an indication of the minimum effort that would resolve this issue'but are not intended to limit or prevent your pursuit of other additional measures you determine are appropriate for addressing the allegation.

10 ttachment cont na 2.790 nformation W l a me, .

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, 72 West Adams Street, Chicago Ilhnois 1.'-

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10 CFR 2.790 INFORMATION Mr. A. Bert Davis Regional Administrator WITHHOLD FROM PUBLIC DISCLOSURE U.S. Nuclear Regulatory Commission Region III 799 RooseW it Road Glen Ellyn, IL 60137

Subject:

Zion Nuclear Power Station Units 1 and 2 License Nos. DPR-39 and DPR Response to Allegations RIII-88-A-0032, RIII-88-A-0081, RIII-88-A-0140, RIII-88-A-0161, RIII-88-A-0168 and RIII-88-A-0169 NRC Docket Nos. 50-295 and SC-304 References (a): April 11, 1989 letter from E.G. Greenman to Cordell Reed (A11eoation RIII-88-A-0032).

(b): April 21, 1989 letter from E.G. Greenman to Cordell Peed (Allegation RIII-88-A-0081).

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@)_:fApril.21, 1989: letter from E.G. Greenman jo iCordell. Reed (Allegation RIII-88-A-0140)>

(d): April 11, 1989~ l'etter from E.G. Greenman to Cordell Reed (Allegation RIII-88-A-0161 and RIII-88-A-0169).

(e): April 10, 1989 letter from E.G. Greenman to Cordell Reed (Allegation RIII-88-A-0168).

Mr. Davis:

The referenced letters transmitted the above referenced allegations to Commonwealth Edison for our investigation and response. The due dates for a number of the allegations have been extended in telepone co ve'rsations between Mr. J. Hinds and G. Trzyna.

8906290335Ogh94 10 INFORMATION MARKIN ADOCK O DOES NOT APPL ER PD9 PNV L 0 I OM THE E URE" W2stL 70 br O ffD W L*c:ty yo n'**tv Do E Cd'* ~rs Kt'e'

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A.B. Davis May 26, 1989 y '

The responses to the allegations are contained in the attachments to this letter. The Attachments to this letter contains.Information that'is

-Exempt from Public Disclosure in accordance with 10 CFR 2.790(a).

Please direct any questions you may have regarding this matter to this office.

Very truly yours, T. J. Kovach Nuclear Licensing Manager Im Attachments cc Zion Resident Inspector 10 CFR 2.790 INFORMATIO .SURE WITH D FROM PUBLIC DI gh "100 2.790 INFO TION MARKING NOT APPLY WHEN S LETTER 0118T DO SEPARATE FROM THE E OSURE"

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SUMMARY

. OE._ALLIGAIIDti RIII-88-A-0140 4-ALLEGATION:

1. That copies of the Tc,nporary Change Cover sheets reproduced for users are, in some cases, UNREADABLE and that directions given in some of the temporary changes are difficult to follow.

2. That some procedures produced for users are difficult to read or are otherwise difficult to follow because of poor temporary change execution (layout, cross-outs, legibility).

3. That partial stroking of service system motor operated valves (MOVs) has been employed in periodic Technical Specification (TS) operability testing.

4. That the justification for partial stroking service system MOVs provided by the Technical Staff to the operators is inadequate.

We believe that to adequate resolve these issues, the following, as a minimum, must be addressed:

a. Describe what actions have been or are being taken to improve the temporary change process to the end that procedure changes are legible and can be followed without placing undue stress on the users.

b. Describe the basis for partially stroke testing service system MOVs for periodic TS operability testing.

In your response, include the details of your plan including the size of the temporary change cover sheet sample examined, the service systems examined, and the methodology employed to support a conclusion that the concerns are or are not substantiated. If substantiated, provide your corrective actions to address the immediate concern and actions to prevent recurrence.

These items are forwarded as an indication of the minimum effort that would resolve this issue but are not intended to limit or prevent your pursuit of other additional measures you determine are appropriate for addressing the allegation.

FESPONSE TO ALLEGATION PARTS 1 AND 2:

Sixty-six open temporary procedure change cover sheets attached to working copies and in the shift engineer books found in the Technical Support Center (TSC) were reviewed for legibility. Four of the sixty-six cover sheets reviewed were found to be illegible. This translates into approximately six percent. Three illegible cover sheets were due to copies being made from carbon copies of the cover sheet. The other illegible cover sheet was a carbon copy flied in the shift engineer book. Based on these results the concerns were found to be substantiated.

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WITHHOLD F ISCLOSURE w

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The four illegible cover sheets were replaced with legible copies.

Discussions were held with the Administration Procedure Clerk concerning this matter. He will, on a daily basis, make legible copies of temporary procedure  ;

changes written during off-normal working hours and distribute them j appropriately. This will prevent recurrence.

During the 1988 fall refueling outage the NRC resident inspectors and station personnel identified similar concerns with temporary procedure changes. Those concerns included poor format, information deleted or distorted due to reproducing, and illegibly written instructions. The station placed procedure reviewers on shift in the TSC (adjacent to the control room) around the clock for the duration of the outage. It was the responsibility of the reviewers to ensure temporary procedure changes were legible, completed and processed correctly, and that steps were clearly understandable to the user. To accomplish this the reviewers examined temporary changes written on shift using guidelines developed by the Operating Procedure Coordinator.

Recognizing the need to procedurally require legibility and clarity l in temporary procedure changes. Zion Administrative Procedure (ZAP) 5-51-5

" Procedure Content and Format" has been revised to include a secti,on on temporary procedure changes. This revision is currently in On-site Review.

This revision will require procedure writers to ensure temporary changes are legible when steps are added to a procedure. When steps are being deleted from a procedure, writers will be required to line out using a straight edge i such that the deleted information can still be read. Writers will also be required to show, in a consistent format, where the temporary change fits into the body of the procedure. Another step will require the writer to ensure that information is not deleted during copying. This revision will provide procedure users with legible, easy to follow temporary procedure changes in a consistent format. This revision will be implemented by June 1, 1989, with training conducted for procedure coordinators and the clerical staff by June 30, 1989.

ALLEGATION PART 3:

That partial stroking of service system motor operated valves (MOV's) has been employed in periodic Technical Specification (TS) operability testing.

RESPONSE

We find this allegation to be substantiated in that, where permitted by Technical Specifications (TS), partial valve stroking is performed to satisfy TS operability testing.

A wd 10 . N PUBLI LOSURE l

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• E111-88-A-0140 4.

A review of Technical Specification (TS) and Periodic Tests (PT) was performed to determine if there existed a case where Service Water (SW)

MOV's were being partially stroked and used to determine Technical Specification operability. Two different procedures are used to determine value operability. One procedure requires full stroke testing to determine operability. The other procedure; PT-9, " Service Water Valves Operability Checks" partially strokes the reactor containment fan cooler (RCFC) outlet MOV's. Technical Specification 4.8.7.A.2 allows that

" Performance will be acceptable if valve motion is indicated upon actuation."

In addition to the review performed above, a complete review of all testing required for Service Water MOV's was done. Two areas were found that required change or further evaluation.

The first area for review was ASME Sect. XI requirements with regard to the proper method for testing each valve. Zion Station has contracted with an independent consultant for the review of our IST program. As part of this review the SW MOV's will be evaluated for ASME Sect. XI testing requirements. A final report to the Station is due by October 31, 1989.

Appropriate changes to our IST program will be made upon receiving and evaluating this report.

The second area reviewed was post maintenance testing. Technical j Specification 4.9,3.A states that, upon returning the valve to service, a

" cycling test" must be performed. Although these post maintenance cycling tests have been documented on work requests, changes have been initiated 4 to station procedures to provide better documentation and will be in place by August 31, 1989. A temporary change to PT-9 will be implemented by June 15, 1989, h require full stroke testing when determining valve l operability.

ALLEGATION PART 4:

That the justification for partial stroking of service system MOVs provided by the Techni. cal Staff to the Operators is inadequate.

EESPONSE:

Whenever questions arise about meeting Technical specifications, a i i

review of the appropriate TS is performed and a timely response given to l l Operating. However, this allegation is substantiated in that responses to l these type of questions may not always reach the originator. In the future, j

l. Zion Station will implement a new program for processing and handling engineering guestions. This new program will give direction for the review, disposition and documentation of engineering questions including notification i of disposition to the originator. Implementation of this new program is being '

tracked by commitment 4295-100-88-00307.01 and will be in place by August 31, 1989. A memo will be issued to the Operating Department to inform them of the ,

I new program. This memo will be issued by June 15, 1989.

hj R 9 Eto IN ' 4 WITHHO P ISCLOSURE 0118T/12-14 7 D'