ML20246P486

Responds to NRC Re Violations Noted in Insp Repts 50-295/88-21 & 50-304/88-21.Corrective Actions:Package Addressing out-of-tolerance Condition Reviewed & Training on Zap 15-53-1, Processing Discrepancy Records, Held for QC

ML20246P486
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/07/1989
From:	Bliss H COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8903280230
Download: ML20246P486 (4)

Text

1 i Commonwealth Edison

[ cc ) One First N7,,tional Plaza, Chictgo, Illinois h

• i O '7 Address Reply to: Post Office Box 767 j/ . Chicago, Ilknois 60690 March 7, 1989

'Mr. A..Bert Davis j Regional Administrator j U.S. Nuclear Regulatory Commission Region III W 799 Roosevelt Road' .

Glen Ellyn, IL 60137 I

Subject:

Zion Nuclear Power Station, Units' 1 and 2 License Nos. DPR-39 and DPR-48 Response to Inspection Report Nos. 50-295/88021-and 50-304/88021 HRC Dockat Nos. 50-295 and 50-304

Reference:

February 7, 1989 letter from B. Clayton to Cordell Reed Dear Mr. Davist This letter is in response to the inspection conducted by Mr. M.

Holzmer of your staff from June 18 through 27, 1988; August.3 through-September 12, 1988; and January 23 through 27, 1989 of activities at the Zion Nuclear Power Station. During those inspections, certain activities appeared to be in violation of NRC requirements. The response to.the violations are provided in the Attachment to this letter.

Please direct any questions that you may have to this office.

Ver uly yours, b

H.E i 1 Nuclear icensing Manager j i

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. ATTACHMENX l

Yiolationi

1. 10 CFR 50, Appendix B, Criterloa V as implemented by Commonwealth.

. Edison Company's NRC approved Quality Assurance program, CE-1-A,'

requires that activities affecting quality-shall be prescribed and accomplished by procedures appropriate to the circumstances,

a. ZAP 15-53-1, " Processing Discrepancy Records," step 1.1 requires that a Discrepancy Record (DR) be initiated for all discrepancies.

b. ZAP 15-52-1, " Deviation and Reportable-Event Reporting," step.

IV.A.4 requires that station personnel who observe or identify-a deviation initiate a Deviation Report (DVR).  ;

i Contrary to the above, activities affecting quality were not accomplished by appropriate. procedures in thats j a. On March 25 and April 11, 1988, discrepancies were identified in that all 20 Unit 1. main steam safety valves failed to meet; acceptance criteria for tests performed on March 10 through 29, 1988, and DRs were not initiated for any of the failures.

b. During the period March 11 through May 20, 1988, station personnel observed or identified a deviation, in that all 20 main steam safety valves failed to meet acceptance. criteria in the non-conservative direction, and no Deviation Report was initiated.

This is a Severity Level IV violation (Supplement 1).

CQ.r.rective Attigng_,Taken and Regnitg_Ach.inyedi )1 1

Zion Station acknowledges the Violat. ion.

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3 The response to the Violation is formated with subparts (a) and (b) l to correspond to the individual concerns of the Violation. j

a. The Quality Control (QC) Supervisor reviewed the package which addressed the out-of-tolerance condition and determined that a Deviation Report (DVR) should be initiated rather than a Discrepancy Record (DR). This determination was made because the valves that were out-of-tolerance are Technical Specification valves, and ZAP 15-53-1 requires that a DVR rather than a DR, be utilized as the appropriate reporting mechanism. DVR 22-1-88-074 was initiated on May 20, 1988.

b. A deviation report was not submitted immediately because ,

although variou.4 responsible station personnel were aware of- I the problem they variously assumed either that the DVR had been initiated or that another person was initiating it. The fact that it hadn't been initiated was discovered by on-site QA Department on May 20, 1988, at which time'DVR 22-1-88-074 was initiated.

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Carrective Action 6_to be Taken'to Avoid Further ViolaL12RS1

a. Training on ZAP:15-53-1 " Processing Discrepancy Records" was held for the QC. Department and also on the proper way to

. perform receiving inspection incorporating the lessons learned from this violation. Also,- the Mechanical Maintenance procedure which addresses the testing of Main Steam Safety Valves (MSSV) has been revised to require that a DVR be. )

initiated whenever as found setpoints are out-of-tolerance.

b. Onsite Quality Assurance personnel conducted training on the.

Importance of proper documentation of events. This training included a review of Quality Assurance's responsibility of ensuring that appropriate reports such as DR's and DVR's are promptly processed, and if necessary, initiate the report themselves. Additionally, the circumstances surrounding this i I

case have been discussed with members of-Quality Assurance at the other stations.to minimize the potential of a similar occurrence. ]

l Date When Full Compliance Will be Achievedt

a. The Station is in full compliance as of March 3, 1989.

b. The station is in full compliance as of March 3, 1989. l I

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Y_lolations

2. 10 CFR 50, Appendix B, Criterion IV as implemented by. Commonwealth Edison Company's NRC approved Quality Assurance program requires i that measures shall be established to assure that applicable -

regulatory requirements,-design bases, and.other requirements which are necessary to assure adequate quality are suitably included or referenced in documents for procurement of material, equipment and j services.

l Zion Administrative Procedure, ZAP 4-51-1, " Establishing Quality Requirements For Requests for Purchase and Requisition Cards," step C.I.2 requires that the Department Head or designee ensures that a j request for purchase is properly merked as ASME code related, and i includes technical engineering requirements. I contrary to the above, requests for purchase numbers ZN0018 and ZN0018A dated January 8, 1988 and March 13, 1988 respectively, failed to be properly marked as ASME Section XI for code related testing, or to include technical engineering requirements for main steam safety valve lift setpoint testing. j 1

This is a Severity Level IV violation (Supplement 1).

1 Car.rentive Actions Taken and Results Achievedi, Zion Station acknowledges the violation.

The safety valve test data, which was supplied by Crosby Valve Company, regarding equipment that was procurred by Purchase Order No. ZN0018 and ZN0018A was reviewed by Technical Staff personnel to verify that the l applicable ASME code requirements were satisfied.

C.orrective Actions to be Taken to Avoid Further Violati.qng1 Quality Control personnel will be instructed to question the originator of the purchase order if they (OC) are unsure if all the purchase requirements are listed or referenced. Additionally, the NRC inspector was concerned about the specific technical knowledge of personnel who are  :

responsible for ensuring that the requirements are included under the QA program. This concern will be brought to appropriate corporate personnel to develop an action plan for any necessary additional guidance.

Also, a change to ZAP 4-51-1, " Establishing Quality Requirements l for Requests for Purchase and Requisition Cards," will be implemented to I include Technical Staff responsibility for verification that applicable requirements are included or referenced on Request for Purchase and-computerized order forms.

Dats When Full Compliance will be Achievedi.

Full compliance will be achievod by May 1, 1989.

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