View source for A97037, Responds to NRC Re Violations Noted in Insp Rept 50-295/97-12.Corrective Actions:Revised Station Procedures Which Required Enhancements & Completed Preventive Maint on Sequence Timers Using Electrical Maint Procedure E023-1

{{Adams
| number = ML20217M310
| issue date = 08/18/1997
| title = Responds to NRC Re Violations Noted in Insp Rept 50-295/97-12.Corrective Actions:Revised Station Procedures Which Required Enhancements & Completed Preventive Maint on Sequence Timers Using Electrical Maint Procedure E023-1
| author name = Mueller J
| author affiliation = COMMONWEALTH EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000295, 05000304
| license number = 
| contact person = 
| document report number = 50-295-97-12, ZRA97037, NUDOCS 9708220146
| title reference date = 07-17-1997
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 6
}}

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     .         ,/Jiin.11 N W r19 .''C m w a.2m, ZRA97037 August 18,1997 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:           Document Control Desk

==Subject:==
Commonwealth Edison Reply to Notice of Violation in NRC Inspection Report Number 50 295/97012 Zion Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-295 and 50 304 Gentlemen:
lly {{letter dated|date=July 17, 1997|text=letter dated July 17, 1997}}, the NRC cited Commonwealth Edison (Comed) as being in violation of regulatory requirements. The referenced Inspection Report cited two severity level IV violations with one violation containing one example of inadequate corrective actions. This letter and its attachment constitute Comed's reply to the referenced Notice of Violation in accordance with applicable regulations.
Attachment A to this letter provides the reasons for the violations, the corrective actions taken, and the date when full compliance was achieved. Attachment 11 to this letter contains all commitments made by Zion Station in this response.
Should you have any questions concerning this response, please contact Robert Godley of my staff at 847-746-2084 extension 2900.
Sincerely,
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J.ll. Mueller Site Vice President
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f Zion Nuclear Station Attachments cc:      Regional Administrator, USNRC -- Region 111 Senior Project Manager, USNRC -- NRR Project Directorate 1112 Senior Resident inspector, Zion Nuclear Station Ollice of Nuclear Facility Safety -- IDNS 9708220146 970818 PDR                                                                                 *
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l . ATTACilMENT A to ZRA97037 Page1of4 Ruponse to Notice of Violation in inspection Report 50-295/97012 YIOt.ATION: 50 295/97012 01 Technical Speelfication 6.2.1.a requires that written procedures he prepared, implemented, and maintainedfor procedures recommended in Appendix A of Regadatory Guide 1.33, Revision 2, February 1978.
Appendix A of Regulatory Guide 1.33. Revision 2 February 1978, specifles loss of electric power (and/or degraded power sources) as an example of a procedure for responding to an emergency or other significant event.
Contrary to the above, on March 11,1997, the licensee identifled that a procedure did not exist for responding to a loss of offsite power that resulted when the Unit I system cmxiliary transformer tripped.
This is a Severity Level 11' l'iolation (Supplement 1).
ADMISSION OR DENI AL TO Tile VIOLATION Comed admits the violation.
REASON FOR Tile VIOLATION PIFs initiated subsequent to the event initially identified the apparent cause as no procedure existed to direct the Operator actions. The subsequent investigation, however, identified the existence of procedures to restore safety ftinctions of various plant equipment should they not occur automatically, While procedures to restore various plant systems existed, there was a lack of integrating guidance provided to the Operators in prioritizing the sequence to restore lost functions in modes 5,6 or defueled. It was also identified that some of those procedures needed to provide Operators better direction when restoring plant systems and equipment in modes 5,6 or defueled.
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* ATTACilMENT A to ZRA97037 Page 2 of 4 CORRECTIVE ACTION TAKEN AND RESULTS ACillEVED A number of station procedures which required enhancement were revised prior to performance l       of their specilie evolution. For example, the ibliowing procedures were revised: Sol 63A, "345 i
KV Operations;" SOI 6311. "linergizing 4 KV Non ilSF Buses from the SAT;" and Sol-63D,
        " Transferring 4 KV l!SS Ilusses from iteserve feed to Normal Feed."
CORRECTIVE ACTIONS TO HE TAKEN TO AVOID FURTilER VIOLATIONS A procedure (flowchart) will be developed to direct the operator through the various procedures in a prioritized sequence to restore lost functions in modes 5, 6 or defueled. This will be completed by October 17,1997.
DATE WIIEN FULL COMPLIANCE WILL HE AClllEVEl}
Full compliance will be achieved upon implementation of the procedure (flow chart).

l
      . ATTACilMENT A to ZRA97037 Nge30f4 VIOLATION: 50 295/97012 02 10 CFR Part 30. Appendit B, Criterion Xi'1, " Corrective Actions," requires that rneasures be established to assure that conditions adverse to quality are promptly identiped and corrected, and in the case of significant conditions adverse to quality, that rneasures be established to assure that the cause of the condition is determined and corrective action taken to preclude recurrence.
Contrary to the above, from January 20,1996, through March 11, 1997, the licensee did not implement timely and effective corrective actions to prevent the recurrence of sequence timer maljimettons, a condition adverse to quality. Speelfically, the corrective actions specified in the licensee's level 2 root cause investigation. Nuclear Tracking System No. 295 200 96 CAT 2 003, for recurring sequence timer malfunctions, were not completedprior to thefa!!ure ofthe division 17-2 safe shutdown tirner to reset on March 11,1997.
This is a Severity Level ll' Violation (Supplement 1).
ADMISSION OR DENI AL TO Tile VIOLATION Comed admits the violation.
REASON FOR Tile VIOLATION The Corrective Action Program existing at the time of this violation did not drive actions to closure in a timely manner. The program also did not provide for an evaluation of safety sigreificance when commitment due dates were moved.
CORRECTIVE ACTION TAKEN AND RESULTS AClllEVED Preventive maintenance has been completed for the Unit 2 sequence timers. The timers ivere successfully tested using Technical Staff Special Procedures (TSSP)-076-96, TSSP-070-96, and TSSP 07196. Preventive maintenance has been completed on the Unit I division 17 and 18 timers using Electrical Maintenance Procedure E023-1.

o     ATTACllMENT A to ZRA97037 Itge 4 of 4 in May 1997, Comed implemented a Nuclear Operations Division wide Corrective Action Program (CAP). That program is designed to correct deficiencies such as those identified in this violation. Elements of the new CAP that address corrective action timeliness include Corrective Action Review Board, the Condition Review Group, and Effectiveness Reviews. This was previously docketed in response Notice Of Violation 50 295/304 97002. To improve line management involvement in CAP, approval for extending significant commitment due dates must be approved by the Plant General Manager, in addition, accountability meetings are held when significant corrective actions become overdue.
         - CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTilER VIOLATIONS EITectiveness reviews are being performed for approximately 70 significant events that occurred in 1996 to reduce the risk of repeat events. These reviews will be completed by November 15, 1997, Preventive maintenance of sequence timers will be completed each refueling outage.
DATE WilEN FULL COMPLIANCE WILL BE ACillEVED Zion Station is in full compliance at this time.
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.      ATTACllMENT 11 to ZRA97037 14ge I ((1 Listof Commitments identified in this Violation Response The following table identilles those actions committed to by Comed in this document. Any other actions discussed in this submittal represent intended or planned actions by Comed. They are described to the NRC for the NRC's information and are not regulatory commitments. I' lease notify Mr. Robert Godley, Zion Station Regulatory Assurance Manager, of any questions regarding this document or any associated regulatory commitments.
Commitment                                                              Committed Date or Outage-A procedure (flowchart) will be developed to direct the operator       October   17,1997 through the various symptom based procedures in a prioritized sequence to restore lost functions in modes 5,6 or defueled.
Effectiveness reviews are being performed for approximately 70 November 15,1997 significant events that occurred in 1996 to reduce the risk of repeat events, l'reventive maintenance of sequence timers will be completed each     ZlRIS,Z2R15 refueling outage.
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