View source for A98008, Responds to NRC Re Violations Noted in Insp Repts 50-295/97-25 & 50-304/97-25.Corrective Actions:Revised Procedure SOI-61F to Reflect Need to Verify Position of 2MOV-SW0023 & Revised Procedure PT-10-3 to Provide Guidance

{{Adams
| number = ML20203A854
| issue date = 02/20/1998
| title = Responds to NRC Re Violations Noted in Insp Repts 50-295/97-25 & 50-304/97-25.Corrective Actions:Revised Procedure SOI-61F to Reflect Need to Verify Position of 2MOV-SW0023 & Revised Procedure PT-10-3 to Provide Guidance
| 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 = 50-295-97-25, 50-304-97-25, ZRA98008, NUDOCS 9802240130
| title reference date = 01-21-1998
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 12
}}

=Text=
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ZitA98008 February 20,1998 U. S. Nuclear llegulatory Commission Washington, D.C. 20555 Attention:                Document Control Desk

==Subject:==
REPLY TO NOTICES OF VIOLATION NRC Inspection Report No. 50 295/304 97025(DRS);
Zion Generating Station, Units 1 & 2; NRC Docket Numbers 50 295 & 50-304

==Reference:==
Letter to O. D. Kingsley (Comed) from G. E. Grant (USNRC), dated January 21,1998, NRC Routine Resident inspection Report 50-295/304 97025 and Notices of Violation l                                  Gentle..ien:
1 Ily {{letter dated|date=January 21, 1998|text=letter dated January 21,1998}}, the NRC cited Commonwealth Edison (Comed) as being in violation of regulatory requirements. This letter and its attachments constitute Comed's reply to l                                  the referenced Notices of Violation in accordance with applicable regulations. Attachment A to l                                  this letter provides the reasons for the violations, the corrective actions taken, and a statement of full compliance. Attachment il to this letter identifies all commitments made by Zion Station in this response.
A response to violation 50-295(304)/97025 07 is not included in this submittal.                    Comed reques'ed an additional 6 days beyond the required 30 day response for the above referenced                    ,
violation in order to prepare a more comprehensive response. By discussion with the Region til Ilranch Chief, the additional time was granted. Comed will reply to Violation 50-295(304)'97025 07 by February 26,1998.
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ZRA98008 Page 2 c[2 '
Should you have any questions concernhg this response, please contact Mr. Robert Godley, Zion Station Regulatory Assurance hianager, at (847) 746-2084, extension 2900.
Sincerely, 0-(IZion
       . itehn    C. Ilrons Vice President Generating Station l
l Attachments ec:     Regional Administrator, USNRC - Region ill Senior Project hianager, USNRC - NRR Project Directorate 1112 NRC Senior Resident inspector Zion Generating Station Omce of Nuclear 1 acility Safety - IDNS
                   .                                                                                U

,                                   Attachment A to ZRA98008                                                                                  l Page 1 of 9                                                                                               j REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50 295/97025(DRS); 50 304/97025(DRS)                                      .
VIOL,ATION 1 (50 295/304-97025-01):
10 CFR Part 30, Appendix B Criterian l', " Instructions, Proccchires, and Drawings,"
requires that acth'llles affceting quality be prescribed by docurnented instructions, procedures, or drawings ofa t)pe appropriate to the circurnstances and be accornplished                    ;
in accordance with these instructions, procedures, or drawings.
Contrary to the above, procedures were not appropriate to the circurnstances in the following instances:
: a.        On October 12,1997, Systern Operating Instruction 61F, " Splitting Service ll'ater Headerfor Maintenance," Revision 0, was not appropriate to the circwnstances,                    ,
in that, it did not provide appropriate guidance to ensure that adequate service                l waterflow was maintained to the 2B emergency diesel generator while splitting                   '
the service water headers. Consequently, the operating shift Inadvertently inade the 2B cinergency diesel generator inoperable.
: b.        On December 2,1997 Periodic Test 10-3, " Containment isolation Phase B 7'esting," Revision 12, was not appropriate to the circumstances, in that, it did noi provide appropriate guidance fbr testing the Train "A" Division 7 containment isolation and component actuation circuitry energi:cdfrom safety injection relay SIX IA. Consequently, the relay SX1 did not de-energi:e as expected in Section 5.1, Step 17.
This is a Severity Level ll' violation (Supplement I), (50-295/97025 01; 50 304/97025                  .\
01)
Admission or Denial of the Violation Comed admits the viokion.
Reason for the Violation Comed has recognized that the failure to provide operating procedures that contain guidance appropriate to the circumstances is an adverse trend As such, Comed has                          ;
performed an adverse trend investigation on the multiple occurrences of inadequate operating procedures. The investigation has determined that the events have a common cause in that the technical review process is inadequate.
This is evidenced by the failure of multiple barriers in the procedure review and approval process, technical reviewers' failure to perform technical reviews effbetively in

Attachment A to ZRA98008 Page 2 0f 9 REPLY TO NOTICE Of VIOL.ATION IN NRC INSP'ECTION P" PORT 50 295/97025(DP.S); 50-304/97025(DRS)
         +
accordance with ZAP 110-02 " Procedure Process Control," ZAP 110-03 " Procedure Validation /' ZAP $00-02 "On Site Review and Investigative function," or ZAP 500-08
           " Technical Review and Control," and lack of effective training for technical renewers that would ensure effective process implementation.
Discussion:
On October 12,1997, the operating department was performing sol-61F on the normally cress-tied Unit 1/ Unit 2 service water (SW) system. Per sol-61F orv"                                s personnel closed the emergency diesel generator (EDG) SW supply he                                          c iet isohtion valve (OMOV SW0009). This action inadvertently isolated . V .                               ~ " sDG because the procedure did nct verify that the EDG cross-tie valve                            '
n   .,su23) was in the proper position. When the equipment operator verified                                  . SW system lineup, he discovered that service water to the 2B EDG was isolated because the cross-tie valve was in the closed positior. when it should have be n in the open position 2MOV-SW0023 was placed in the open position returning th ' aDG to tm operable status.
On December 2,1997, during the performance of PT-10-3, section 5.1, operators identified that relay SIX 1 A had not de-energized as expected in step 17 of the procedu: 2.
It was determined that the procedure would not work as written, in that the rclay remained energized through a seal in contact and a manual reset button until the reset button was actuated in step .' 1.
In both these events the technical review for the procedures was not adequate to identify that the procedures would not work as written.
Correctivy Stens Taken and Results Achieved The appropriate procedure chan tes were made to SOI-611' to reflect the need to verify the position of 2MOV-SWOO23 (unit 2 eme:gency diesel generator service water cross-tie valve).
The appropriate procedure change.s were made to PT-10-3 to provide guidance for testing the train "A" division 7 containment isolation and component actuation circuitry energized from safets injection relay SIX 1 A.
Corrective Steps That Will he Taken to Avoid Further Violations As committed in the Comed response to NRC Inspection Report Number 50-295/304-97022, violation numb <.r 50-295/30> A7022-02, a qualified technical reviewer program will be established. Tha program w!D melude technical reviewer qualification star.d9rds l
1 s    -n                                                                             .-

Attachment A to ZRA98008 Page 3 of 9 REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97025(DRS); 50-304/97025(DRS) and training. The program will also be designed to ensure that quality improvements can be measured in Zion Station technical procedures.
The Administrative Support Supervisor will develop and maintain a Technical Reviewer Reference Manual that will delineate the approved source and location of refeience material for Technical Reviews.
The System Engineering Department 1 lead will revise ZAP 500 02, "On-Site Review and
[-
Investigative Funuion," and ZAP 500-08, " Technical Review Control," to require
           - documentation by reviewers in the appropriate checklists / signature pages that they have used the relevant drawings, when applicable.
l           The System Engineering Department llead will verify that all cmrently qualified l-          Te::hnical Reviewers acknowledge that they have re-re:d and understand the current revisions oi ZAPS 110-01, i 10-02,110-03,120-04,500-0.' ,500-08, and 500-09.
            ! Late When Full Compliance Will be Achieved Zion Generating Station is currently in fall compliance.
1

Attachment A to ZRA98008                                                                      ,
Page 4 of 9 REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50 295/97025(DRS); 50-304/97025(DRS)
V10LATIOE_2 (50-295/304 97025-0411
}
10 CFR Part 50.72(b)(2)(1) requires that the licensee shall notify the U.S. Nuclear Regulatory Commission as soon as practical and in all cases, withinfmar hours of the occurrence of any eventfound while the reactor is shut down, that, had it been fi>und while the reactor was in operation, would have resulted in the nuclear power plant, including its principal safety barries, being seriously degraded or being in an unanaly:ed condition that sigmficantly compromises plant safety.
Contrary to the above, on October 16,1997, at i730, engineering department personnel inbrmed the Shift Manager that the 3/4 inch piping penetration line from the reactor coolant drain tanic to the auto gas analy:er was not seismically supported and was thus inoperable. Had this condition beenJimnd while the reactor was in operation, the plant would have been in an unanaly:ed condition that would have compromised o principle plant safety barrier (containment); however, the licensee did not make the notification until 1501 on Ociober 17,1997.
This is a Severity Level ll' violation (Supplement 1). (30-30 l/97025-04)
Admission or Denial of the Violation Comed admits tht violation.
Reason for the Violation The Unit Supervisor (US) who reviev.ed the problem failed to check thoroughly for reportability issues and did not assess the cutire situation. He immediately referenced :he technical specifications and satisfied himself that the event did not involve missing a technical specific'ition surveillance. The US failed to associate the event with reportability under the other sections of 10 CFR 50.72. Rather, he evaluated the problem as an issue that required resolution prior to leaving the existing mc,de of operation, declared line 2DT040-3/4 inoperabic in the log at 2338, and ei not report the condition immediately to the Shift Manager.
Additionally, the shift manager assumed the US had dispositioned the issue properly. F.e did not challenge the log entry or the PIF that he signed on the issue with respect to re, artability because the US had noted that the problem had to be addressed prior to leaving mode 5.
J
* ttachment A to ZRA98008 l         Page 5 of 9 l
REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50 295/97025(DRS); 50-304/97025(DRS)
Corrective Stcos Taken and Results Achieved The next Shin Manager made the required ENS notification.
Both the Unit Supervisor and the Shin Manager were counseled and reprimanded for their failure to review thoroughly the impact of this event with respect to the reportability requirements. Communicating problems promptly to the Shift Manager was emphasized -
to the Unit Supervisor.
Operations management made this event known to the other Unit Supervisors cad Shift Managers to emphasize the need to communicate problems promptly within the shift, to check carefully fhr all reportability criteria, and to review log entries with a more challenging attitude.
Corrective Stens That Will be Taken to Avoid Further Violations No further corrective actions are deemed necessary.
Date When Full Compliance Will be Achieved Zion Station is currently in full compliance.
G w         .~                                                  .      .

Attachment A to ZRA9800s Page 6 of 9 REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97025(DRS); 50-304/97025(DRS)
VIOLATION 3 (50-295/304 97025-06h 10 CFR Part P, Appendix B, Criterion l', " Instructions, Procedures, and Drawings,"
requires that activities afecting quality be prescribed by documented instructions, procedures, or drawings ofa ,pe appropriate to the circumstances and be accomplished in accordcnce with these instructior.;, procedures, or drawings.
Zion Generating Station Afaintenance Procedu:e EOOS-2, "HFA Relay inspection and Adjustment," Revision 7, Section H, Steps 3.2 and 8.3, requires that the relay be installed and referminatedper the applicahle HFA Relay Data Sheet.
HFA Relay Data Sheetfor relay SIXl AXspecifies that the wirefrom the reset coil, wire 2C #12, he connected to Terminal 12.
Contrary to the above, on Oct . er 4,1997, while replacing relay SIX! AXin accordance with E005-2, "HFA Relay insp .an and Adjustment," Revision 7, electrical maintenance personnel connected the wirefrom the reset coil, wire 2C #12, to Terminal 10 (a spare           ,
terminal) instead of; :rminal 12.
This is a Severity Level 11' violation (Supplement 1). (50-304/97025-06)
Admission or Denial of the Violation Comed admits the violation.
Reason for the Violation The reason for the violation is inadequate work practices by the electricians involved in the event. The electricians incorrectly assumed that the wiring diagram (22E-2-4473) provided enough guidance to reterminate the relay and used the wiring diagram instead of following the guidance contained in procedure E005-2.
The wiring diagram 22E-2-4473 did not provide the level of d: tail necessary to properly identify the correct terminal locations for reconnecting the relay. The actual relay has terminals located one behind the other and are not depicted as three diraensional on wiring diagram 22E-2-4473 thus creating putential confusion of terminal location if only the wiring diagram was used. The drawing on HFA Relay Data Sheet in procedure E005-2 showed the layout of the terminals in a three dimensional contiguration.
I U

Attachment A to ZRA98008 Page 7 of 9 REPLY TO NOTICE OF VIOLATION IN NRC INSP'ECTION REPORT 50 295/97025(DRS); 50-304/97025(DRS)
Corrective Steps Taken and Results Achieved The SIX1 AX relay was correctly rewired.
1 The electricians involved in the event were counseled on the importance of procedure     ,
adherence and not over-relying on the wiring diagrma to provide enough guidance on       I reterminations. The importance cf having a questioning attitude was also stressed.
A tailga:e session was held with tne E!ectrical Maintenance Department describing the circumstances surrounding this event and the importance of procedure adherence and not over-relying on the wiring diagram to provide enough guidance on reterminutions. The importance of having a questioning attitude was also stressed.
To ensure that reterminations were currently being performed correctly, station Management temporarily performed verification on reterminations of safety related equipment. During the perfonnance of this process no descripancies were identified.
Corrective Steps That Will he Taken to Avoid Further Violations No funher actions are deemed necessary.
Date When Full Compliance Will be Achieved Zion Generating Station is currently in full comphance.

Attachment A to ZRA98003 Page 8 of 9 REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97025(DRS); 50-304/97025(DRS)
VIOLATION 5 (50-295/304-97a25-10):
10 CFR iart 30, Appendix B, Criterion Ill, " Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as d: fined in 30.2 and as specified in the license application, for those structures, systems, and components to which Appendix B applies are cor ectly translated      ^
into specifications, drawings, procedures, and instructions. Design changes, including field changes, shall be subject to design control measures commensurate with those applicJ to the original design and be approved by the organi:ation that originally performedthe originaldesign.
Zion Updated Final Safety Analysis Report, Revised Afay 1996, SectL.s 9.4.1.2, " System Description," states: " Return air passes through the control boards into a return duct system which is connected to on.tlets at the top of the boards. "
Zion drawing Al-315, " Control Room HVAC [ Heating. Ventilation and Air Conditioning]
System. EL. 642'-0"," Revision E, depicts the exhaust plenum connected through ducts to the top ofeach ofthe control boards in the control room.
l Contrary to the above, on June 13, 1997, inspectors identifled that numerous control room ventilation system ducts associated with cooling the control boards were not installed as specified by drawing Al-315 since original construction.
7'his is a Secerity Level IV viohuion (Supplement i). (50-295/97025-10; 50-30./97025-10)
Admission or Denial of the Violation Comed admits the violation.
Reason for the Violation The reasons for this violation cannot be determined. This event occurred during original construction activities. It is believed that there was an inadvertent onwsion by the field engineer or installer to update drawing M-315 during pre-operational /startup teeting (circa 1971) to reflect the actual installed condition.
The as-built locations of the exhaust ducts do not agree with the information shown on drawing M-315. The marked-up drawing M-315 used for the original testing and balancing of'he Control Room IIVAC system in 1971 indicates the as-built locations of the exhaust ducts. Fitis drawing's information was walked down on July 31,1997, to i

Attacament A to ZRA98008 Page 9 of 9
                      .             .                                  REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97025(DRS); 50-304/97025(DRS) verify the exhaust duct locations. The current as-built locations of the exhaust ducts are in agreement with the as-built locations shown on the marked-up drawing used for the original 1971 testing and balancing.
Corrective Steps Taken and Results Achieved Safety Evaluation number 97-1290 was written to evaluate changing drawing M-315 to reflect the current as-built configuration of the control room HVAC system exhaust ducts l           from the top of the main control boards. The evaluation concluded that the as-built l           configuration of the control room ventimtion system would not affect its ability to fulfill the required safety functions (i.e. the control board temperature profiles were bounded by the UFSAR allowable maximum temperatures by a large margin).
Drawing Change Request (DCR) #970444 was issued to change drawing M-315 to reflect the current as-built configuration. The drawing was subsequently revised under revision R, dated January 12,1998.
Corrective Steps That Will he Taken to Avoid Furth.- r Violations No further corrective actions are deemed necessary.
Date When Full Compliance Will be Achieved Zion Station is curren'!y in full compliance.
0

Attachment B to ZRA98008 Page 1 of 1                                                                                                    ,
                 .      ,   REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97025(DRS); 50-304/97025(DRS)
                                                                                                                     +
COhihilTMENTS IDENTIFIED IN Tills REPLY TO NOTICES OF VIOLATION 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 desenbed to the NRC for the NRC's information, and are not regulatory commitments.
Please contact Mr. Robert Godley, Zion Generating Station Regulatory Assurance Manager, if there are any questions regarding this document or any associated regulatory commitments.
Commitment:                                                                                   Committed Date (or Outage):
As committed in the Comed response to NRC Inspection Report                                   May 29,1998 Number 50-295/304-97022, violation number 50-295/304-97022-02, a qualified technical reviewer program will be established. This program l     will include technical reviewer qualification standards and training. The program will also be designed to ensure that quality improvements can I
be measured in Zion Station technical precedures.
The Administrative Support Supervisor will develop and maintain a June 1,1998 Technical Reviewer Reference Manual that will delineate the approved source and location of reference material for Technical Reviews.
The System Engineering Department licad will revise ZAP 500-P. April 15,1998 "On Site Review an d Investigative Function," and ZAP 500 3,                                                '
       " Technical Review Control," to require documentation by reviewers in the appropriate checklists / signature pages that they have used the relevant drawings, when applicable.
The System Engineering Department llead will ver.fy that all currently May 5,1998 qualified Technical Reviewers acknowledge that they have re-read and understand the current revisions of ZAPS 110-01, 110-02, !10-03, 120-04,500-02,500-08, and 500-09.                                                                                 1
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