View source for A97075, Responds to NRC Re Violations Noted in Insp Repts 50-295/97-22 & 50-304/97-22.Corrective Actions:Configuration Control Root Cause Investigation Was Completed in Nov 1997

{{Adams
| number = ML20197F991
| issue date = 12/23/1997
| title = Responds to NRC Re Violations Noted in Insp Repts 50-295/97-22 & 50-304/97-22.Corrective Actions:Configuration Control Root Cause Investigation Was Completed in Nov 1997
| 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 = 50-295-97-22, 50-304-97-22, ZRA97075, NUDOCS 9712300347
| title reference date = 11-28-1997
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 16
}}

=Text=
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ZRA97075 December 23,1997 -
U. S. Nucle.tr Regulatory Commission Washington, D.C. 20555 Attention:          Document Control Desk

==Subject:==
Commonwealth Edison Reply to Notice of Violation in NRC Inspection Report Number 50-295/304-97022 (DRP);
Zion Nuclear Power Station Units I and 2; NRC Docket Numbers 50-295 and 50-304

==Reference:==
Letter to J. Brons (Comed) from G. E. Grant (USNRC) dated November 28,1997, "NRC Inspection Report No. 50-295/97022 (DRP),
50-304/97022 (DRP) and Notice of Violation" Gentlemen:
By {{letter dated|date=November 28, 1997|text=letter dated November 28,1997}}, the NRC cited Commonwealth Edison (Comed) as being in Jolation of regulatory requirements. The referenced Inspection Rerort cited four Severity Level IV violations. The Grst violation involves three examples of deficiencies in the implementation of the out-of-service (OOS) program. The second violation pertains to the failure to provide appropriate guidance to the operators to test the autostart inhibit circuitry for the OC component cooling water pump and to respond to a loss ofinstrument bus 213 event. The third violation relates to the establishment of the nucler instrumentation power range rate trip setpoint greater than that allowed by the Technical Specincation Limiting Safety System Setting. The fourth violation involves the failure to maintain the minimum number of operable power range rate trip channels or comply with the Technical Speci6 cation Actisn Statemens.
The Operations Manager has recognized the cortinuing cht.llenges to the OOS process at
             - Zion Station, including those identified in previous inspections. It is also recognized that previous corrective actions, while addressing specific issues, have not been effective at preventing recurrence of these types of events. To address the programmatic OOS weakness. the Operations Manager has appointed an OOS Process Director charged with                '
implementing an improvement plan that achieves desired results prior to Unit 2 restart.        (
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c ZRA97075 December 23,1997
          ;          Page 2 cf 2 Attachment A to this letter provides the reasons for the violations, the corrective actions taken and results achieved, the corrective actions that will be taken to avoid further violations, and the date when full compliance will.be achieved. Attachment B to this letter identifies 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 cxtension 2900.
Sincerely,
                      .c John C. Brons JSite Vice President Zion Nuclear Station Attachments cc: Regional Administrator,USNRC- Region 111 Senior Project Manager, USNRC - NRR Project Directorate 111-2 Senior Pasident Inspector, Zion Nuclear Station Oflice of Nuclear Facility Safety - IDNS
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ATTACilMENT A TO ZRA97075
        ; Page 1 of 12 --
             .                                 ATTACilMENT A-BESPONSE TO NOTICE OF VIOLATION IN NRC INSPECrlON REPORT 50-295/304-97022 VIOLATlON: 50-295/304-97022-01 Technical Specepcation (TS) 6.2.1.a requires that written procedures be prepared, implement:d, and maintainedforprocedures recommended in Appendix A of Re; latory Guide 1.33, Revision 2, February 1978.
Appendix A ofRegulatory Guide 1.33, Revision 2, February 1978, specupes equipment control, e.g., locking and tagging, as an example ofan administrative procedure.
Zion Administrative Procedure 300-06, "Out ofService Process," Revision 15, requires that equipment control be implemented to protect personnel and equipment during testing and maintenance activities on systems or components.
Zion Administrative Procedure 300-06; "Out ofService Process," Revision 15, Appendix B, " Lifting OOS Techniques,"specipes, in part, that equipment be returned to service in accordance with Ihe applicable system operating instruction.
System operating instruction 63N, "480V Breaker Racking Operations," Revision 4, Step 5.2.9, specupes, in part, that the controlpower kmfe switch he closed.
Out of-service No. 970009345, required the iA emergency diesel generator train "A "
main starting air check valve test tap isolation valve,1DG0169, to have been placed and maintained in the uncapped and open position.
      ~
Out-of service No. 970007778, required the 2B residual heat removal heat exchanger bypass valve, 2Ril8726B to have been placed and maintained in the closedposition.
Contrary to the above:
: a.      On September 10, I997, while returning the OAfire pump breaker to service in accordcmce with out-of-service No. 970009297, a non-licensed operator did not close the controlpower kmfe switch as required by system operating instruction 63N, ".180VBreaker Racking Operations,'' Revision 4, Step 5.2.9.
: b. On October 2,1997, while clearing out-of-service No. 970009345, a non-licensed operator identiped that the 1A EDG train "A " anain starting air check valve test tap isolation valve, IDG0169, was not in the required out-of-service position, in tha! the valve was capped and open.

l ATTACilMENT A TO ZRA97075 Page 2 of 12
: c. .        On October 10, 1997, while investigating the inability to depressuri:e the 2B residual heat removal train, an operator identified that the 2B residual heat removal heat exchanger bypass valve, 2RH8726B, was not in the position required by out-of-service No. 970007778, in that the valve was 20 of a turn open.
This is a Severity Levelll' violation (Supplement 1).
ADMISSION OR DENI AL TO Tile VIOLATION Comed admits the violation, with the exception of example 50-295/304-97022-Olc.
Violation Examplc 50 295/304 97022-01a:
REASON FOR Tile VIOI.ATION.
The reason for this violation example was an OOS process weakness compounded by personnel error. The knife switch was not listed on the OOS checklist for restoring the breaker, and the Zion Administrative Procedure (ZAP) 300-06,"Out of Service Process,"
did not require the knife switch to be listed. The Equipment Operators (EOs), who were trained and in the past successfully performed the OOS evolution, did not follow System Operating instruction (sol) 63N (revision 4) "480V Breaker Racking Operations,"
section 5.2 step 9, which states: "CLOSE Control Power knife switch OR INSTALL fuse (s), as applicable."
CORRECTIVE ACTIONS TAKEN AND RESULTS ACillEVED Zion Administrative Procedure ZAP 300-06,"Out of Service Process," has been revised to provide clear direction to list on the OOS checklist all components that are manipulated to establish a zone of protection. Since this procedure change took affect, there have been no reported occurrences of this type of error.
The operators were counseled following the event on failure to follow SOI-6?N for racking the breaker and the discussion included the importance of following procedures.
There have been no further reports of procedural noncompliance by these operators since the counseling took place.
CORRECTIVE ACTIONS TO HE TAKEN TO AVOID FURTilER VIOLATIONS Recognizing that two operators made the same error, consideration was given to a training weakness. Therefore, a corrective action has been identified requiring that the Non-Licensed Operator Training !erson plans include direct current (DC) control power, that breaker OOSs shall include tags on the DC fuses / knife switches, which manual L        .. ..                   _ -     ___ _ - ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

  ?            ATTACIIMEN1 A TO ZRA97075 Page 3 ef 12
            . breakers in the plant have DC control power, and how failure to close DC control power ca'n affect plant response to breaker trip signals. This corrective action is scheduled to t e completed March 30,1998.
Violation Exampic 50-295/304-97022-01b:
REASON FOR TIIE VIOLAIION The reason for this violation example is that the OOS process was not adhered to because an OOS configuration was changed without authorization. It is believed the cap was replaced by maintenance personnel in support of the Foreign Material Exclusion (FME)
Program. Additionally, the configuration control process as delineated in Station Policy 2-11, " Configuration Control," was violated when that unauthorized individual manipulated plant equipment without guidance or permission from Operations.
The OOS was hung on the valve handle of IDGul69. Approximately 3 to 4 inches above the valve is a cap connected to a vent by a chain. The vent is a standpipe positioned 4              vertically.
CBRRECTIVE ACTIONS TAKEN AND RESULTS AClllEVED 1              During the week of October 17,1997, the OOS Process Director discussed the event with the maintenance supervisor of the work in the area. The mai.nenance supervisor then discussed the event with the workers who were in the area of the equipment and others routinely assigned to this work area.         The discussions included c review of the ceafiguration control policy. There have been no similar occurrences reponed since this action was taken.
CORRECTIVE ACTIONS TO HE TAKEN TO AVOID FURTIIER VJOLATIONS A configuration control root cause investigation was completed in November 1997. This investigation included corrective actions to update the Configuration Control Policy 2-11,              j which reemphasizes operational limitations of plant equipment. The corrective actions for the configuration control investigation will be completed prior to Unit 2 Restart.
The FME Program Nuclear Station Work Procedure (NSWP) A-03, " Foreign Material Exclusion," will be reviewed as part of the OOS Process Recovery Plan. This review will ensure that the OOS process is in compliance with the FME NSWP A-03. The OOS process will be changed as needed. This applicable portion of the OOS Process Recovery
              - Plan will be completed prior to Unit 2 Restart.
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ATTACl! MENT A TO ZRA97075 Page 4 of 12
    ,. Viplation Exampie 50-295/304-97022-01c:
Zion Station denies this violation example as an OOS process violation and considers this-event as a plant material condition problem that was identified by the OOS process.
Discussiqrn Investigation into the event determined that the 2B residual heat removal heat exchanger bypass valve,2Ril8726B was closed using reasonable force and tagged OOS (OOS No.
970007778). During the 2B residual heat removal train depressurization evolution it was discovered that the valve was not providing complete isolation (valve leakby). _ A force multiplier was used to drive the valve tighter into the seat resulting in an additional 2/3 of the valve wheel turn for the valve to provide full isolation. Upon further review, it was determined that the valve was in poor material condition.               An Action Request (970076725) and Work Request (970107577-01) were initiated to repair the poor material condition of this valve.
An Operator Work Around (97036) was entered into the Work Around data base and an Engineering Request (ER9708921) was initiated to address the material condition problem of this valve and seven (7) additional RilR system valves with similar problems.
The Electronic Work Control Systcm (EWCS) dah base has also been updated to alert Operators to the potential leakby of the eight (8) valves (includes 2RH8726B) any time they are used as OOS isolations.
The Operations Manager has recognized the continuing challenges to the OOS process at Zion Station, inc'uding those identified in previous inspections. It is also recognized that previous corrective actions, while addressing specific issues, have not been effective at preventing recurrence of these types of events. To address the programmatic OOS weakness, the Operations Manager has appointed an OOS Process Director. The OOS Process Director has responsibilities that include developing all department's OOS event response program, development of the OOS Process Recovery Plan, performing OOS process monitoring, coordinating OOS corrective actions, and continually assessing the OOS program's effectiveness, which includes makmg changes as needed. Actions have begun and the completion of the applicable portions of OOS Process Recovery Plan is a Unit 2 restart item.
DATE WHEN FULL COMPLI ANCE WILL HE ACillEVED Zion Station is currently in full compliance.

c        ,
A'ITACilMENT A TO ZRA97075 Page 5 of 12                                                                                 :
               ,   VIOLATION: 50-295/304-97022-02 10 CFR Part 50, Appendix B, Criteria l', " Instructions, Procedures, and Drawings,"
requires that activities afecting quality be prescrl bed by documented instructions, procedures, or drawings ofa type appropriate to the circumstances ana be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, procedures were not appropriate to the circumstances in the follawing instances:
: a.       On September i9, !997, Operating Special Procedure 97-039, " Test ofAutostart inhibit Circuitryfor Bus 149 Pumps," Revision 0, was not appropriate to the circumstances, in that it did not provide appropriate guidancefor testing the autostart inhibit circuitry ofthe OC component cooling water pump; consequently, the DC component cooling water pump breaker did ne: close automatically as expected in Step 2.6.
: b.       On September 22,1997, Abnormal Operating Procedure 8.1, " Loss ofInstrument Bus, " Revision 19(G), was not appropriate to the circumstances, in thatfor a loss ofpower to instrument bus 213 it did not direct appropriatefollow-up :ctionsfor the unavailability ofthe boric acid transkr pumps, which could have resulted in a positive reactivity additionfollowing a volume control tank automatic makeup, or for the continuous cycling ofthe 2A residual heat removalpump minimumflow valve, which could have caused the pwnp to operate in a runout condition or damaged the motor operator on the valve.
This is a Sevwty Level ll* violation (Supplement 1).
ADMISSION OR DENI AL TO Tile VIOLATION Comed admits the violation.
Violation Exampie 50-295/3P4-97022-02a:
REASON FOR Tile VIOLATION The reason for inappropriate procedural guidance contained in Operating Special Procedure (OSP) 97-039 " Test of Autosta- Inhibit Circuitry for Bus 149 Pumps," was personnel error due to a failure to comply with Zion Administrative Procedure (ZAP) i10-02, " Process Procedure Control," which requires that the technical reviewer of the procedure be on: other than the individual who drans or originates the procedure.

ATTACllMENT A TO ZRA97075 Page 6 of 12 Discussion:
The individual who contributed in writing OSP 97-039 became distracted when drafting the procedure, and he failed to note the significance of an electrical contact critical to the sequence of the steps in the procedure. Ilis familiarity with the procedure contributed to his lack of focus and led in part to the error both in drafting and in reviewing the procedure. The procedure required a technical review only, therefore, there was no independent review performed. The individual fully understood the error later and self-identified the cause of the event. Contributing to this error is the fet that, although qualified in accordance with current station policy to perform electrical technical reviews, this was the first procedure this individual had drafted and reviewed that involved the detailed use of electrical prints. The individual's experience with procedure review was limited to operational procedures, which did not involve cl:ctrical print detail, rather than special test procedures.
This same individual performed the technical rev3w of the procedure, contrary to ZAP 110-02, " Process Procedure Control," which states that the reviewer will be one other than the person who draf1s the change. The individual stated he was unaware of the requirement, though he had acknowledged in October 1995 for having read applicable administrative procedures which specify that the reviewer conducts an independent review and that the reviewer is a person other than the draller.
As a result, during performance of OSP 97-039, Section                     2,  " Component Actuation / Verification." the OC CC pump breaker did not close automatically as expected in step 2.6. The operators stopped the testing and restored equipment to normal configuration it determined that the procedure would not work as written, in that, the closure signal for the OC CC pump breaker was being inhibited by the manual actuation of relay SX1 in accoidance with step 2.1.
Violations concerning procedural deficiencies and failure to provide operating procedures that contain guidance appropriate to the circumstantes have been documented in previous inspections. It is recognized that previous corrective actions, while addressing specific issues, have not been etTective at preventing recurrence of procedural inadequacies, personnel qualification for performing technical reviews, and training issues. It is recognized that corrective actions are required to address the issues of personnel cualification and training of technical reviewers.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACillEVED The individual involved was counseled in the proper requirements for performing technical reviews. There were no other procedures that this individual both drafled and reviewed.

_                                         _                                             m l'     ATTACilMENT A TO ZRA97075 Page 7 of 12 On September 19,1997, OSP 97-039 was revised and a technical review was performed to' ensure the changes were correct. OSP 97-039 was parformed again and the evolution was successfully completed.
CORRECTIVE ACTIONS TO BE TJKEN TO AVOID FURTHER VIOLATIONS To strengthen the existing technical reviewer qualification process, a program to address the itsue ofinadequate technical reviews of procedures has been initiated. This program will address the repetitive nature of inadequate procedures and the procedure review process which have been cited in previous violations. Technical reviewer qualification standards will be established and training will be performed to ensure that management expectations are clearly communicated. The program will be designed to ensure that quality improvements can be measured in Zion Station technical procedures. The program is scheduled to be complete by May 29,1998.
Violation Example 50 295/304-97022-02b:
BEASON FOR Tile VIOLATION The reason for this violation example was a failure to identify that Abnormal Operating Procedure (AOP) 8.1, " Loss of instrument Bus," required revision during the design modification process which replaced the Boric Acid System. The level of detail needed to address the circumstances under which the AOP would be used was not fully understood. This modification (M22-0-87-027) converted the existing high concentration Boric Acid System to a lower cancentration.
Additionally, there was a failure to recognize the need to include the cycling of the 2A RHR pump miniflow valve 2MOV-Ril610 on a loss of instrument bus power. The reason for this was an inadequate technical review process. The reaction of this valve to a loss of instrument power was an expected occurrence; howes er, no information involving the valve cycling condition was included in AOP 8.1.
Discussion:
During the initiation of the design process to install the Boric Acid System various procedures were reviewed to determine whether they may be arTected by plant modifications. The boric acid system modification was declared operational during July of 1992 for Unit I and January of 1993 for Unit 2. The procedures governing the modification process which were in place at that time had checklists for various technical interfaces which affected procedures. During the procedure review process, AOP 8.1 had not been identified for the design impact of the boric acid transfer pumps not starting on a loss ofinstrument bus 213.

ATTACllMENT A TO ZRA97075 Page 8 of 12
            . CORRECTIVE ACTIONS TAKEN AND RESilLTS ACillEVED On September 28, 1997, Comed evaluated the adequncy of AOP 8.1 using various simulator scenarios to determine the impact of the BAT level instrumentation omission i
from AOP 8.1. As a result, AOP 8.1 was revised on November 7,1997, to recognize and provide appropriate follow-up actions for the loss of boric acid transfer pumps and additionally for the continuous cycling of both trains of the RHR pump minimum flow valve during a loss ofinstniment bus.
The process used to manage ,,lant modifications have been improved significantly since the design modification to the t>oric acid system documented in modification M22-0               027. Current modification procedures are in place that cover the design process and interfaces.                                                                 These are Nuclear Engineering Procedure (NEP)-04-01, " Plant Modifications," ZAP 510-02," Plant Modification Program," and ZAP 510-02C," Exempt Change Program." included in these procedures are instructions for design interfaces and design change checklists to ensure applicable procedures are not overlooked.
Design Engineering was moved on site in 1992 improving communication and Zion Station involvement during the modification process.
CORRECTIVE ACTIONS TO HE TAKEN TO AVOID FilRTIIER VIOLATIONS i
A program to address the issue of inadequate technical reviews of procedures has been initiated. This program will address the repetitive nature of inadequa'e procedures and the procedure resiew process which have been cited in previous violations. Technical reviewer qualification standards will be established and training will be performed to ensure that management expectations are clearly communicated. The program will be designed to ensure that quality improvements can be measured in 7 ion Station technical procedures. The program is scheduled to be complete on May 29,1998.
DATE WilEN FULL COMPLI ANCE Wil L HE ACIIIEVED Zion Station is currently in full compliance.
L

ATTACilMENT A TO ZRA97075                                                                       'l
                   - Page 9 of12
                   .VI;OLATION: 50-295/304 97022                     TS 3.1.1 requires that the setpointsfor the reactorprotection system are presented in Table 3.1 1.
i                   TS Table 3.1 1 requires, in pLrt, that the power range rate trip setpoint be 5 percent of L                  rated neutronJha/2 seconds. In addition. the setpoints be established tolerancesfor instrument channel 'and setpoint errors as specified in "ZionNSSS [ Nuclear Steam Supply System] Setpoint Evaluation. Protection System Channels, Eagle 21 Version, " but
(                   the instruments shall not be set to exceed a Limiting Safety System Setting.
TS 2.1.1.C, " Limiting Safety System Setting. " reqaires that the power range rate trip he       i set at less than or equal to 5 percent ofratedflux in 2 seconds.
Contrary to the above, during the calibration ofpower range channel 2N-42 on February 6,1993, andpower range channel 2N-43 on May 16,1994, the licensce set the power range rate trip setpoint at 5.6 and 5.1 percent ofratedJha in 2 seconds, respectfully.
1his is a Severity Level IV violation (Supplement I).
ADMISSION OR DEN!AL TO TIIE VIOLATION Comed admits the violation.
REASON FOR TIIE VIOL,ATION The reason for this violation was a misinterpcetation of the "++" note in Technical Specification (TS) Table 3.1-1. This note referenced the " Zion Nuclear Steam Supply
                   . System-(NSSS) Setpoint Evahntion, Protection System Channels, Eagle 21 Version, which contained the setpoint calculation methodology. This calculation established an
                    " allowable value" of 6.5%. As a result, engineering utilized the allowable value of 6.5%
to request a change to the procedure which allowed a setting above 5%, even though the -
TS Limiting Safety System Setting (LSSS) was 5%. Contributing to this event'was a weakness in the technical review process which did not' identify the misinterpreted-allowable value.
                    " Allowable value" accounts for instrument drift between instruuent calibration and the.
maximum as found value that ensures the safety analysis _would not be violated. This allowable value is predicated upon the as left value being within the 'l S limit.

1 ATTACllMENT A TO ZRA97075 Page 10 of 12
        . Discussion:
On February 1,'1993, the power range nuclear instrumentation procedures for Unit 2 were revised to incorporate changes resulting from the installation of the Westinghouse Eagle 21 Reactor Protection System. The revision to the procedures changed the setpoint tolerances from 5% to 5% plus 1% minus 0%.
Although it was not documented, it is believed this " allowable value" was used as the
          - basis for changing the setpoint tolerances in the Instrumen Mair,tenance Nuclear          >
Instrumentation System (NIS) Power Range Rate Trip calibration procedures 2N-41 through 2N-44, from 5%, to 5% (plus 1%, minus 0%). The procedure changes to 2N-41 through 2N-44 allowed an instrument technician to " set" the setpoint for this instrumentation as high as 6%. Howeser, the LSSS in Technical Specifications limits the setpoint tolerances to 5%. Because of this condition, Channels 2N-42 and 2N-43 were considered technically inoperable when they were set above 5%, contrary to the TS.
CORRECTIVE ACTIONS TAKEN AND RESUI,TS ACitiEVFJD The Unit 2 Instrument Maintenance (IM) Procedures for NIS Power Range Rate Trip tolerraces were revi:.ed on August 14,1997, and are now consistent with the Technical Specification LSSS.
All Unit 2 Power Range Rate Trip channels have been recalibrated to the proper values.
_CJO_BBECTIVE ACTIONS TO HE TAKEN TO AVOID FURTilER VIOLATIONS Zion Station Technical Specifications will be replaced with the Improved Technice.
Specifications (ITS), which explicitly incorporates the allowable se point methodology for all reactor protection channels.
The Unit 1 instrument Maintenance (IM) Procedures for NIS Power Range Rate Trip tolerances will be revised prior to the restart of Unit 1. Unit 1 Power Range Rate Trip channels were never adjusted since the new procedures have been in place.
A program to address the issue of inadecuate technical reviews of procedures has been initiated. This program will addr:ss the repetitive nature ofinadequate procedures and the procedure review process which have been cited in previous violations. Technical reviewer qualification standards will be established and training will be performed to ensure that management e.xpectations are clearly coimunicated. The program will be designed to ensure that quality improvements can be measured in Zion Station technical procedures. The program is scheduled to be complete on May 29,1998.
DATE WIIEN FULL COMPLIANCC WILL HE ACIIIEVED Zion Station is currently in full compliance.

ATTACilMEN T A TO ZRA97075 Page 11 of 12
      . VIOLATION: 50 2951394-97022-04 753.1.2 states, in part, thatfor all on line testing or instrwnentationfailure, plant operation shall be permitted in accordance with Table 3.1 1.
15 Table 3.1-1 requiresfor the power range rate trip. a minimum ofthree operable channels, except thatfor channel testing. calibration, or maintenance the mininnun rumber ofcitannels may be reduced by onefor a marimum of 2 hours: otherwise, the unit should be in hot shutdown within 4 hours.
Contrary to the above, while calibrating power range channels on April 26,1993, and August 1,1994, the licensee did not have 3 operable power range rate trip channels for periods of 9 hours,15 minutes and 7 hours, 28 minutes, respectfully; and the (Jnit 2 was not placed in hot shutdown within 6 hours.
7his is a Se verity I.crel IV violation (Supplement 1).
AD41SSION OR DENI AL TO TIIE VIO_lATION Comed admits the violation.
BEASON FOR Tile VIOL ATION The reason for this violation was that the procedure to calibrate the Nuclear instrumentation System (NIS) char.nel 2N-42 and 2N-43 incorrectly allowed the power range trip setpoint be set " ;reater than the Technical Specification (TS) Limiting Safety System Setting (LSSS) of 5% as discussed in violation 50 295/304-97022-03. Because of this condition, Channels 2N-42 and 2N-43 were considered technically inoperable when they were set above 5%, contrary to the TS.
Cor.tributing to this event was a weakness in the technical review process which did not identify the misinterpreted allowable value.
Discussion:
On two occasions, April 26,1993, and August 1,1994, Nuclear Instrumentauon System (NIS) channel 2N-41 was taken Out-of-Service (OOS) for calibration. While 2N 41 was OOS, channels 2N-42 (ou April 26,1993) and 2N-43 (on Au;;ust 1,1994) .were technically inoperable because their setpoint tolerances had been set during the previous c,uarter to greater than the Technical Specification (TS) Limited Safety System Setting (LSSS) of 5%. Since 2N41 was OOS for greater than 6 hours when 2N-42 and 2N-43 were considered inoperable, only two NIS channels were considered operable, which was less than the minimum degree of redundancy required by TS Table 3.1-1 (columns 3 and 4), as referenced with the "+++" and "* *" footnotes in the TS.

                 ' ATTACllMENT A TO ZRA97075 Page 12 of 12
            .      On February 1,1993, the power range nuclear instrumentation procedures for Unit 2 were revi .ed to incorporate changes resulting from the installation of the Westinghouse Eagle 21 lleactor Protection System. The revision to the procedures changed the setpoint ec lerances from 5% to 5% plus 1% minus 0%. This change allowed an instrument technician to set tne MIS channels above the 5% TS setpoint. The procedure change incorporated a misinterpreted footnote in the existing TS that led to an incorrect setpoint tolerance for the power range channels to be placed in the procedure. This was not uncovered in the technical review process in place at the time for reasons that cannot be determined.
CORRECTIVE ACTIONS TAKEN AND RESUI,TS ACillEVED.
Similarly, as discussed in violation 50-?95/304-97022-03, the Unit 2 Instrument
,                   Maintenance (IM) Procedures for Nuclear instrumentation System (NIS) Power Range i                   Rate Trip tolerances were revised on August 14,1997, and are now consistent with the Technical Specification (TS) Limiting Safety System Setting (LSSS).
All Unit 2 Power Range Rate Trip channels have been recalibrated to the proper values.
CORRECTIVE ACTIONS TO IlE TAKEN TO AVOID FURTIIER VIOLATIONS Zion Station Technical Specifications will be replaced with the Improved Techical Specifications (ITS), which explicitly incorporates the allowable setpoint methodology for all reactor protection channels.
A program to address the issue of inadequate technical reviews of procedures has been initiated. This program will address the repetitive nature of inadequate procedures and the procedure review process which have been cited in previous violations. Technical reviewer qualification standards will be established and training will be perfonned to ensure that management expectations are clearly communicated. The program will be designed to ensure that quality improvements can be measured in Zion Station technical procedures. The program is scheduled ta be complete on May 29,1998.
The Unit 1 Inatrument Maintenance (IM) Procedures for NIS Power Range Rate Trip tolerances will be revised prior to the restart of Unit 1. Unit 1 Power Range Rate Trip channels were never adjusted since the new procedures have been in place.
DATE WIIEN FULL COMPLI ANCE WILL IlE ACillEVED Zion Station is currently in full compliance.

j -
ATTAClihiENT 13 to ZRA97075 Page 1 of 2 I
Ilst of Commitments identined in this Violation Resnonse The following table identines thc; 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. Please notify hir. Robert Godley, Zion Station Regulatory Assurance hianager, of any questions regarding this document or any associated regulatory commitments.
Commitment                                                               Committed Date or Outage Non l.icensed Operator Training lesson plans will irclude DC hlarch 30,1998 control power, that breaker OOSs shall include tags on the DC fuses / knife switches, which manual breakers in the plant have DC control power, and how failure to close DC control power can affect plant response to breaker trip signals.
Zion Station Technical Specifications (TS) will be replaced with the Unit 2 Restart Improved Technical Specitications (ITS), which explicitly incorporates the allowable setpoint methodology for all reactor protection channels.
The PhlE Program Nuclear Station Work Procedure (NSWP) A-03, Unit 2 Restart
          " Foreign hiaterial Exclusion," will be reviewed as part of the OOS Prccess Recovery Plan. This review will ensure that the OOS process is in compliance with the FhtE NSWP A-03. The OOS process will be changed as needed.
A con 0guration control root cause investigation was completed in      Unit 2 Restart November 1997. This investigation included corrective actions to update the Configuration Control Policy 2-11, which reemphasizes operational limitations of plant equipment. The corrective actions for the con 6guration control investigation will be completed prior to Unit 2 Rectart.
Completion of the applicable portions of the OOS Process Recovery      Unit 2 Restart Plan which includes addressingprogrammaticweaknesses.
A program to address the issue ofinadequate technical reviews of       hlay 29,1998 procedures has been initiated. This program will address the repetitive nature ofintjequate procedures and the procedure review process which have been cited in previous violations. Technical

A1TACllMENT B to ZRA97075 Page 2 of 2 rbviewer qualification standards will be established and training will be performed to ensure that management expectations are clearly communicated. The program will be designed to ensure that quality improvements can be measured in Zion Station technical procedures.
The Unit 1 instrument Maintenance (IM) Procedures for NIS Power                       Unit 1 Restart Range Rate Trip tolerances will be revised.
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