View source for A97067, Provides Detailed Response as Committed to in Util Ltrs to NRC & 1103 Re Violations Noted in Insp Repts 50-295/97-19 & 50-304/97-19.Corrective Actions:Sys Engineering Personnel Briefed on Need to Ensure Offsite Svc

{{Adams
| number = ML20199H436
| issue date = 11/21/1997
| title = Provides Detailed Response as Committed to in Util Ltrs to NRC & 1103 Re Violations Noted in Insp Repts 50-295/97-19 & 50-304/97-19.Corrective Actions:Sys Engineering Personnel Briefed on Need to Ensure Offsite Svc
| author name = Brons 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 = 50-295-97-19, 50-304-97-19, ZRA97067, NUDOCS 9711260113
| title reference date = 09-29-1997
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 6
}}

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* ZRA97067 November 21,199i U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:            Document Control Desk

==Subject:==
Response to NRC's Request for Information Regarding an Adverse Trend in Zion's Configuration Control Processer; Zion Generating Station, Units 1 & 2; NRC Docket Numbers 50 295 & $0-304

==References:==
: 1. Letter to J. II. Mueller (Comed) from G. E. Grant (USNRC), dated August 28,1997 NRC Inspection Report No. 50-295/97016, 50 304/97016 and Notice of Violation
: 2. Letter to USNRC from J. C.11rons (Comed), dated September 29, 1997. Reply to Notice of Violation in NRC Inspection Report No.
50-295/304-97016
: 3. Letter to J. Brons (Comed) from G. E. Grant (USNRC), dated September 30,1997, NRC Inspection Report No. 50-295/97019 (DRP),50 304/97019(DRP) and Notice of Violation
: 4. Letter to USNRC from J. C.13rons (Comed), dated November 3, 1997, Reply to Notice of Violation in NRC Inspection Report No.
50 295/304 97019(DRP)
Gentlemen:
In reference I, you expressed concern over Zion Station's equipment configura' ion
          - control processes and requested that Comed address its (1) action to detennine the scope of the configuration control problems; (2) short term corrective actions to arrest the adverse trend; and (3) long term corrective actions to prevent recurrence including
           . cxpected completion dates. The following provides our detailed response as committed         jT Aj to in Comed's letters to NRC dated September 29 c.nd November 3,1997, (references 2
,.          and 4, respectively).                                                                              ;
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7,RA97067 Page 2 0f 5 Actiont<) to determine the scope of the configuration control problems As a result of the Operations department identifying out of position valves and the NItC's discovery of two valves out-of position (documented in the August 28, 1997, inspection iteport (reference 1)), the Operations department conducted valve verificttion on portions of selected systems to detennine the extent of the configuration control problem at Zion Station. As a result of this process, additional configuration control problems were discovered, including finding ten valves out of their proper System Operating instruction (SOI) position. As a result of these findings, a Configuration Control Manager was named to investigate this specific problem and a plant wide walkdown was conducted to verify the position of valves and proper alignment of systems that are important to the safe shutdown of Unit 2 and the Spent Fuel Pit, and to determine the scope of the configuration control problems at Zion Station.
Using the existing SOls, a subset of valves that would verify alignment of the systems and valves neeJed fbr safe shutdown was identified and on August 13,1997, the valve alignment venfication (i.e . walkdown) for safe shutdown configuration control began.
Safe shutdown valve lineup was completed on September 2,1997, at which time valve lineups fbr startup of Unit 2 were begun with dual verification for valves.           The verification results were reviewed by the Shutdown Risk Manager who provided an evalumion to confimi the systems and valves verified on Unit 2 and the Spent Fuel Pit wuc conect.
As a result of these valve verifications and walkdowns a root cause investigation was conducted. The root cause investigation was completed on October 16,1997, and it detennined that the root cause ofZion's configuration control problem was a lack of clear management expectations for component manipulations and the absence of an Sol valve lineup for all station conditions.
Short term corrective actions completed (1)      The Mechanical Maintenance department conducted tailgate sessions to heighten awareness of procedural requirements for peer verification when performing maintenance activities (including valve manipulation)in support of the Operations deparanent. Additionally, Mechanical Maintenance management provided the expectation that maintenance personnel will be assigned to perfonn the peer verification function for maintenance activities.
(2)      The Operations Manager emphasized the importance of configuration control and c                        adherence to configuration control Station Policy 2-11 to each work group at Zion
!                        Station. Management expecte' ions for verification and documentation of any l
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4 7,lt\97067 Page 3 of 5 identitled station configuration control problems were communicated to all shifts of the Operations depanment. Each work group confirmed to the Operations Manager that its people had all been contacted and understood . Zion's (onfiguration control policy.
(3)      System Engineering personnel were briefed on the need to ensure that offsite service technicians or visitors, working under their direction at Zion Station, incierstand cunent station configuration control rules and policy.
j.2Dg term corrective actions to be completed Currently, system walkdowns for va;ves and components required for startup of Unit 2 and the comnion plant are 99.9% complete, with nine valves remaining to be verilled because of outstanding corrective work. Thirty nine of the 64 SOls have been revised to show the curnnt plant configuration and identify those valves that are verified for shutdown risk. These 39 Sols, which will also reference any authorized deviation to that configuration, am currently undergoing on site review.
Further, administrative control chanres have been initiated that include changes in management expectations and policies, and training packages on configuration control are under development for management expectations related to administrative control, station events, and corrective actions. Specific long term corrective actions are as follows:
(1)      A 100% walkc.own with dual verification of valves and components required for startup of Unit 2 and the common plant will be conducted. This action will be completed prior to startup of Unit 2.
(2)      Valve lineup procedure discrepancies, identified in the 100% walkdown and verification of valves and components required for startup of Unit 2 and the common plant, Wil be corrected. This action will be completed prior to startup of Unit 2.
(3)      Skty four Sois will be revised to show the current plant configuration and identify those valves that are verified for shutdown risk and will reference any authorized deviation to that configuration. This action will be completed prior to startup of Unit 2.
(4)     The Shili Operations Supervisor will revise Station Policy 211 to include management expectations for configuration control of components during shutdown and other mod:s This will include which depanments may manipulate

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I 7,RA97067
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Page 4 cf 5                                                                                                        l valves and components and under what conditions. This action will be completed prior to startup of Unit 2.
(5)     The Operations Manager will establish additional management expectations regarding shutdown conditions and the role of System Operating Instructions (Sols) or other documented methods of con 0guration deviation. This action will be completed prior to startup of Unit 2.
(6)     The Training department will develop training packages on configuration control that will be given at department tailgate meetings by those departments that bring in offsite service technicians or visitors who may perfonn work at the station.
These training packages will deal with management expectations related to administrative control, station events, and corrective actions. This action will be completed prior to startup of Unit 2.
(7)      The Maintenance Staff department will revise ZAP 200-03, " Control of Non.
Station Personnel," to include configuration control policy (Station Polley 211) in the requirements for all work perfbrmed by onsite non station personnel. This action will be completed prior to startup of Unit 2.
Upon completion of these ongoing long tenn corrective actions, we believe that the potential ihr future configuration control problems at Zion will be minimized.
The almvc listings of short term and long tenn corrective actions pertains to actions of a general or programmatic nature that address Comed's response to NRC (and Comed) equipment configuration control concerns at Zion Station. Long term corrective actions (l.c., commitments) are identified in Attachment A to this letter. Additional actions of a more specific nature were provided in Comed's September 29 and {{letter dated|date=November 3, 1997|text=November 3,1997, letter}}s, in response to individual NRC cited violations in inspection Report Nos. 50-295/304 97016 and 50-295/304-97019(DRP)(reference 3), respectively, in regard to Comed's November 3,1997. Reply to Notice of Violation in NRC Inspection Report No. 50 295/304 97019(DRP) (refuence 4), we committed to completion of five actions associated with configuration control. Because of adjustments                          ;
to the schedule for startup of Unit 2, the commitment date for fbur of the actions has been changed to " Prior to startup of Unit 2." This change is reficcted in long term corrective action items (2), (3), (4), and (5), above. The previous commitment dates were 12/4/97, 1/1/98,12/1/97, and 12/4/97, respectively.

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Should you have any questions concerning this response, please contact' Robert Godley, Zion Station Regulatory Assurance Manager, at (847)746 2084, extension 2900.
Sincerely,                                                                                                  l l
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John C. Ilrons                                                                                              !
Site Vlec Paesident -                                                                                      -i Zion Generating Station                                                                                     ;
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                       . ec:       Regional Administrator, USNRC - Region 111 Senior Projut Manager, USNRC - NRR Project Directorate 1112                                        i NRC Senior Resident inspector, Zion Generating Station -
                                 ' Ollice of Nuclear Facility Safety - IDNS                                                           :
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61.TACllMENT A to ZRA97067                                                                               l Page1of1                                                                                                 )
l 1
COMMITMENTS IDENTIFIED IN Tills                                                  ;
RESPONSE TO NRC'S REQUEST FOR INFORMATION The following table identifies 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 NkC's information and are not regulatory commitments. please 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 100% walkdown with dual verification of valves and components Prior to stanup of required for startup of Unit 2 and the common plant will be conducted.          Unit 2 Valve lineup procedure discrepancies, identified in the 100% walkdown Prior to stanup of and verification of valves and components required for startup of Unit 2 Unit 2 and the common plant, will be corrected.
Sixty four Sols will be revised to show the current plant configuration Prior to startup of and identify those valves that are verified for shutdown risk and will Unit 2 reference any authorized deviation to that configuration.
The Shill Operations Supervisor will revise Station Policy 2-11 to              Prior to startup of include management expectations for configuration control of                    Unit 2 components during shutdown and other modes. This willinclude which departments may manipulate valves and components and under what conditions.
         'I he Operations Manager will establish additiorni management Prior to startup of expectations regarding shutdown conditions and the role of System Unit 2 Operating Instructions (SOls) or other documented methods of configuration deviation.
The Training department will develop training packages on Prior to startup of configuration control that will be given at department tailgate meetings Unit 2 by those departments that bring in ofTsite service technicians or visitors who may perfbrm work at the station. These training packages will deal with management expectations related to administrative control, station events, and corrective actions.
The Maintenance StalT department will revise ZAP 200-03, " Control of Prior to startup of Non Station Personnel" to include configuration control policy (Station Unit 2 Policy 21l)in the requirements for all work performed by onsite non-station personnel.
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