ML20246Q166
| ML20246Q166 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/23/1989 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0259T, 259T, NUDOCS 8909110370 | |
| Download: ML20246Q166 (5) | |
Text
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$Commonwefith Edison--
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t 72 West Adams Street, Chicago, Ilknois O d o y 4 e c.w -
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.N " / Address Reply to: Post DEcdlfdix~767~
..Nd Chicago, Illinois 60690 - 0767 August 23, 1989 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 s
License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304 Response to Inspection Report No. 50-295/89015
'and 50-304/89015
Reference:
. July '24, 1989 letter from H.D. Shafer to Cordell Reed
Dear Mr. Davis:
The letter referenced above transmitted the results of a routine safety inspection conducted by Mr. M. Holzmer and others of your staff during the period from May 9 through June 29, 1989, of activities at Zion Station.
During the course of this inspection, it was determined that certain activities appeared to be in violation of NRC requirements. Your letter of July 24, 1989 informed us of three Notices of Violation. One Violation was addressed during the course of the inspection, and no additional response is required. The response to the two remaining Violations is provided in the Attachment to this letter.
Please direct any questions that you may have regarding this matter
..to this office.
Very truly yours, V//
W T. J.
' vach Nuclear Licensing Manager
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cc:- Resider;t Inspector --Zion g
Chandu Patel - NRR-t
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y ATTACHMENT 1.
yJDL&Il0B:
10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company's Quality. Assurance Topical Report, CE-1-A, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstance.
Contrary to the above, as of March 9, 1989, Zion Station did not have appropriate prescriptive instructions or procedures for sampling of safety-related fuel oil for the emergency diesel generator storage tanks.
As a result, four samples were missed during the last two years.
(295/89015-07(OPP); 304/89015-07(DRP)
This is a Severity Level IV violation (Supplement 1).
RESP _QESE TO VIOLATION NO.1 Zion Station has reviewed the information contained in paragraph 12
.of the Inspection Report and agrees with its content.
No additional information is required.
2.
yl0LATION:
10 CFR 50, Appendix B, Criterion XVI. which is implemented by the Commonwealth Edison Quality Assurance Manual, states that measures shall be established to assure that conditions adverse to quality are promptly identified, and the identification, cause, and corrective action shall be documented and reported to appropriate levels of management.
Contrary to the above:
a.
Conditions adverse to quality were not promptly identified and corrected as reported in LER 304/88009 in that procedural changes to prevent a recurrence of the reactor trip as reported in Inspection Report 295/86023(DRP); 304/86022(DRP) have not been fully l
implemented.
(295/85015-04(DRP); 304/89015-05(DRP) b.
Condittens adverse to quality, the cause, and the correcM ve action taken, were not documented and reported in LER 304/88017 in that post-maintenance verification to prevent reversed electrical connections were not addressed.
(295/89015-05(DRP);
304/89015-05(DRP))
c.
Conditions adverse to quality, the cause, anst the corrective action taken, were not documented and reported in LER 295/89001 in that the report does not address the procedure wh'.ch caused a damper to i
reposition nor the failure to initiate a Deviation Report.
l (295/89015-06(DRP); 304/89015-06(DRP))
This is a Severity Level IV violation (Supplement 1).
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RESPONSE TO VIOLATION NO. 2 Zion Station has several administrative procedures to assure that 10CFR50, Appendix B, Criterion.XVI is met.
These procedures include:
~ ZAP 15-52 Deviation and Reportable Event Reporting LAP'15-52 Deviation Report, Handling and Preparation ZAP 15-52-3.- Licensee Event Report, Handling and Preparation ZAP 15-52-4
_ Zion Station Potentially Significant Event Report ZAP.15-53 Processing Discrepancy Records Zion Station has reviewed the identified procedures and determined that the procedural ~ guidance is consistent with 10 CFR.50 Appendix B criteria and that.no changes to the program are required.
However,.it appears that the broad area of identification, documentation and reporting of conditions adverse to quality needs to be strengthened.
Additional resources have been added to the Regulatory Assurance staff to ensure that these areas are addressed.
The response to our evaluation of the specific examples provided in support of the Violation are each addressed separately.
Violation 2. Daracraoh (a)
Corrective Action Taken and Results Aculevedi Zion Station had committed on a previous occasion (LER 304/86019) to review all non-safety related Instrument Maintenance (IM) procedures.
The purpose.of the review was to define those procedures which could adversely affect reactor operations.
The review identified ninety-two (92) procedures that required clarification.
The resu_1 tant procedure revisions were reviewed and prioritized.
To date, 89 of the 92 identified procedures have completed the review process.
The reu ;or trip documented in LER 304/88009 resulted when an IM technician used one of the identified procedures that had not finished the revision process.
CCLr_r a LtlyLAcilpD_Io_Be_ lake rLlo_Ayold DitheLVicht.toni The three remaining procedures are still in the revision process.
To prevent adverse reactor transients, a Caution statement has been incorporated to each procedure as interim corrective action to advise IH technicians that care must be taken when using this procedure and to provide appropriate information to prevent a reactor transient ~.
D. ate When Full Complinte Hill De Achityrdi Zion Station is in full compliance at this time.
,, n *.
Violation 2. 'oaraaraoh (b1 COIrKtjve Action Taken andlesults Achieved:
LER 304/88017 described an event where Reactor Cavity Vent Fan 2A was running backwards. -A revised LER will be submitted to provide information that was not documented in the original;LER.
The revised LER will 1) provide sufficient.information to conclude there was no significant impact on safety, 2) clearly define fan run times, 3) clarify operating modes during reversed fan operation and, 4) define the method used for
-determining the absence of abnormal temperature excursions.
(#295-100-89-01505)
In addition, the revised LER will address the procedure change to Motor Control Center Inspection (E016-1) which now includes ~a post maintenance rotation verification.
Coryective Action To Be Taken To Avoid further Violation:
No further action to be taken.
Date When Full Como11ance Hill Be Achieved:
Zion Station will be in full compliance on September 20, 1989.
Violation 2. naraaraoh (c)
CQrItttive Action Taken and Results Achieved:
LER 295/89001 described an event where OBN Service Water Area Vent Fan Aircraft Damper was found open. A revised LER will be submitted to provide information that was not documented in the original LER.
The revision will address why the procedure responsible for the manipulation of safety-related equipment did not verify the results.
(#295-100-89-01506)
In addition the revised LER will indicate the tardiness to write the DVR l
was due to a p9rsonnel error; the personnel were counsered; and that this I
is not a recurring problem.
CorrectiveJction ToJe TaFa1 lip _Ayrtid_FJrther VLqlatiODI No further action to be taken.
I Date Hjgto__F.ujLCornAliance Hill Be Achieved:
i c ptember 20, 1989.
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Zion Station will be in full compliance on e
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3.
VIOLATION:
E Technical.. Specification Administrative Controls Section 6.2.1 states that y
written procedures including applicable checkoff lists covering-items P
listed below shall be prepared, implemented and maintained: Abnormal l
startup, operation, and shutdown of the reactor and other systems components involving nuclear safety of the facility.
Zion. Administrative Procedure-(ZAP) 14-51-2, Rev. 4, Inspection, Test, and Operating / Tagging of Equipment, Out Of Service (005) card sheet for' system
- clearances are to ensure steps are performed in proper sequence.
Night orders' issued on May 9, 1989 also listed the sequence of valve manipulations.for valve clearance to be performed.
Contrary to the_above, on May 9, 1989, two licensed shift supervisors
. reviewed, and approved,.an 005 card sheet with an improper sequence. When performed, this resulted in an uncontrolled gas release.
(295/84015-01(DRP);-304/89015-01(DRP))
Belponse To Violation No. 3 Corrective Action Taken And Results Achig.yedi An Error Evaluation Committee meeting was convened on May 17, 1989 to discuss and review the personnel aspects of this event. The root causes were determined to be inadequate communication; inadequate job planning, and inadequate control of Out Of Service evolutions, specifically the i
failure to implement sequencing of Out Of Service evolutions on " partial clears" of~an Out Of Service.
The committee also identified a similar concern about the mechanism used to clear portions of plant modifications.
The Operators were counseled by senior station management on the importance of proper communications, planning, and control of Out of. Service sequencing.
Corrective Action To Be Taken To Aypid Further Violation:
a.
-The requirement to address the applicability of the need for special sequencing evolutions will be implemented in the program for Partial Clears and Modification Temporary Clears.
(#295-200-89-05201) b.,
Caution statements will oe added to SOI-70 to alert operators to the l
potential for gaseous effluent releases during evolutions concerning l
m!xed bed demineralizers.
(#295-200-89-05202) j QLte_Hhen Full Compilante Hill fielchigy.gd:
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a.
Changes to the programs governing Partial Clears and Modification i
Temporary Clears will be completed by December 31, 1989.
'b.
501-70 will.be revised try by December 31, 1989.
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