View source for A98024, Responds to NRC Re Violations Noted in Insp Repts 50-295/97-02 & 50-304/97-02.Corrective Actions:Pmt,Pt 10-3, Containment Isolation Phase B Testing, Was Assigned to WR 960104192 at Time of Failure on 971202

{{Adams
| number = ML20203H688
| issue date = 02/26/1998
| title = Responds to NRC Re Violations Noted in Insp Repts 50-295/97-02 & 50-304/97-02.Corrective Actions:Pmt,Pt 10-3, Containment Isolation Phase B Testing, Was Assigned to WR 960104192 at Time of Failure on 971202
| 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 = 50-295-97-02, 50-295-97-2, 50-304-97-02, 50-304-97-2, ZRA98024, NUDOCS 9803030291
| title reference date = 01-21-1998
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 7
}}

=Text=
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        ,        , hon. il (d W er> 2Y i, m - u. nio ZRA98024 Febmary 26,1098 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:           Document Control Desk

==Subject:==
SUPPLEMENTAL REPLY TO NOTICE Oli VIOLATION NRC Inspection Report No. 50-295/304 97025(DRS);
Zion Generating Station, Units 1 & *i ;
NRC Docket Numbers 50-295 & 50-304

==Reference:==
(1) 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 Notice of Violations (2) Letter from J. C. Brons (Comed) to USNRC, dated February 20,1998, Comed Response to NRC Routine Resident Inspection Report 50 295/304-97025 and Notices of Violation (minus response to violation number 50-295/403 97025-07)
Gentlemen:
In the reference (2) letter, Comed requested and was granted an additional 6 days to prepare a more comprehensive response to violation numt -- 50-295/304-97025-07. This letter and its attachments constitute Comed's reply to violation n,             295/304 97025-07 in accordance with applicable regulations. Attachment A to this letter r., ides the reasons for the violations, the corrective actions taken, and a statement of full compliance. Attachment B to this letter identifies all commitments made by Zion Station in this response.
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Should you have any questions concerning this response, please contact Mr. Robert Godley, Zion Station Regulatory Assurance Manager, at (847) 746-2084, extension 2900.
f Sincerely.
Join       . rons Site Vice President                                                                                                             -
Zion Generating Station Attachments ec:          Regional Ad' ministrator, USNRC - Region Ill Senior Project Manager, USNRC - NRR Project Directorate 11: 2                                                      ,
NRC Senior Resident inspector, Zion Generating Station Ollice of Nuclear Facility Safety - IDNS
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Attachment A to ZRA98024
     .              P;ge I of 4 SUPPLEMENTAL REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50 295/97025(DRS); 50 304/97025(DRS)                             ,
VIOLATION 4 (50-295/304-97025-07h 10 CFR Part 30, Appendix B, Criterion XI, " Test Control," requires that a test program shall be established to assure that all testing required to denwnstrate that structures, systems, and components willperform satisfactorily in service is identified andperformed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contrary to the above, from October 4 through December 2,1997, the licensee did not identify or perform a post maintenance test pr the replacement of relay SIXl AX, to assure that the rehtyperformed satisfactorily in service.
This is a Severity LevelIV violation (Supplement 1). (30-!w97023-07)
Admission or Denial of the VipJn114n Comed admits the violation.                                                                     .
Reason for the Violation The reason for this violation was insufficient Laining for the appropriate personnel involved in the post maintenance testing (PMT) process aller numerous procedures had been changed to reflect work control process changes. Various procedures affecting PMT respensibilities were changed from the time work request (WR) #960104192 (for_ the replacement of relay SIXI AX) was initially analyzed and when the work was completed.
As a result, there was not a_ clear and concise understanding by the appropriate personnel on who assigns PMTs and assures that adequate PMTs are performed. Barriers specific to the work control PMT process also failed.
Discussion:
On January 22,1997, WR 960104192 was prepared by an Electrical Maintenance (EM)
Work Analyst to inspect and replace as necessary U-2 relay SIXI-AX. The package was routed in EWCS for review and approval to a Lead Analyst and for informational review to a System Engineer. WR was made ready (status 45) by a Lead Analyst. The System Engineer acknowledged receipt on the EWCS route list; however, he did not assign a PMT. ZAP 40016E " Work Request Package Initial Review and Approval (EWCS),"
revision (rev.) 2, dated June 2, 1995, and ZAP 40016F " Post Maintenance Verificationfresting," rev. 3 stated that System Engineers were to review work requests, determine PMT requirements, and then assign PMT as necessary. Per procedure there was no guidance to assign a PMT when a work request is initiated.

Attachment A to ZRA98024
                       . P ge 2 0f 4 SUPPLEMENTAL REPLY TO NOTICE OF VIOLATION IN NRC                                                                                                                                    !
INSPECllON REPOP.T 50 295/97025(DRS); 50 304/97025(DRS)
The cause of this failed barrier was that procedure ZAP 40016F was inadequate in that it permitted the Ph1T to be assigned anytime prior to paper closure. No expectations were set for Systam Engineers to perform this function during initial review.
On September 1,1997, during the parts procurement process, an EM Work Analyst identified in an electronic work control system (EWCS) note field (EWCS panel M232)
                         "need PMT requirements from system engineer". ZAP 40016F does not specifically address change or additions to a work package or when a PMT is to be added to the WR.
No follow up was done to ensure that a PMT was assigned. The Work Analyst did all that he was required to do per procedure. The cause of this failed barrier is the same as above in that ZAP 40016F allowed the PMT to be assigned anytime prior to paper closure.
On October 4,1997, WR 960104192 was electronically brought to status '50' (working) by an EM Supervisor. Per ZAP 4001611 " Performing Work on an Approved Work Request (EWMS)," rev. 7, certain criteria should have becu met for a Maintenance First Line Supervisor to change a WR to status '50'. The EM Supervisor should not have taken the WR to status '50' because all criteria had not been met in that an Operations Work Control SRO had not verified PMT, The EM Supenisors had not been given training on the new work control process and ZAPS that controlled these processes. As a result, there was a lack of knowledge and understanding on the part of the EM Supenisor about the revised procedures and work control process. This was a failed barrier in that procedure changes had been implemented without providing adequate training to the appropriate personnel on procedure changes required for the work package control process.
On October 4,1997, an EM work crew took the hard copy of WR 960104192 to the Operations Work Control Center (OWCC, for review and authorization to start work to replace relay SIXI-AX.                                                                                                                                                                         Per ZAP 1200 11 " Operations Work Control Center Guidelines," rev. 2, dated August 7,1997, an OWCC SRO shall review work packages prior to authorization. The review is to include adequacy of PMT The work package was to be initialed and dated by the SRO performing the review. The WR was not initialed and dated by Operations and there was no PMT assignal. It is unknown which individual in Operations was given the work package to review. At the time only a few Operations SRO/LSSs had been given a tailgate session concerning the procedure revisions (the revisions had been in effect for approximately two months). This was a failed barrier in that a procedure had been implemented without providing adequate i                        training in a timely manner to all the appropriate personnel.

Attachment A to ZRA98024
    *   ,   Ppge 3 0f 4 SUPPLEMENTAL REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50 295/97025(DRS); 50 304/97025(DRS)
Corrective Steps Taken and thsultr, Achieved A PMT, PT 10 3 " Containment isolation Phase 11 Testing", was assigned to WR 960104192 at the time of failure on December 2,1997.
ZAP 40016F was revised (rev. 5) on July 28,1997, to transfer responsibility of assigning PMTs from System Engineers to Work Analysts during initial work package preparation and review. Work Analysts were trained on this procedure change during the week of July 21,1997.
On October 31, 1997, a memorandum was issued to Electrical, Mechanical, and inrtmuent Maintenance First Line Supervisors by the Master Electrician /Mect,anic stating that work packages shall be brought to status "50"(working) by Operations. This process was proceduralized in a revision to ZAP 4001611 (rev. 8) on December 5,1997.
The purpose of this revision was to prevent Maintenance First Line Supervisors from changing WR to status '50' (working) except on certain specified equipment such as non plant equipment, facilities maintenance, cranes, sceurity pre-fab work, etc.
On October 24, 1997 a letter was issued to station personnel from the Work Control Manager. The letter stated that work packages me to be both pre-field work reviewed and post field work reviewed by an outage work control center (OWCC) Senior Reactor Operator (SRO)(PMT is one of the items to be reviewed by the SRO). The letter further stated that work packages are to be delivered to a central location both prior to work being performed and aller work is complete.
ZAP 1200-1I was revised (rev. 2) on August 7,1997, to include an OWCC SRO review of work packages prior to authorization. This review is to include adequacy of PMT and requires an initial and date by the SRO perfonning the review. Licensed operators (SRO/LSS) received awareness training on the revised procedures concerning PMT requirements and responsibilities related to the OWCC during cycle 7 of licensed operator requal training.
ZAP 1200-11 was revised (rev. 3) on November 17,1997, to clarify the work package review and closure process for the OWCC SRO. Changes to this procedure included the steps of the work package closure process in sequential order including the hard copy and electronic routing, review, authorization, and approval.
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Attachment A to ZRA98024
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          , Ppge 4 of 4 SUPPLEMENTAL REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT f')-295/97025(DRS); 50-304/97025(DRS)
K Correcti >e Steps That Will be Taken to Avald Further Violations A review of the procedure cF ige implementation process will be performed. The intent of this review v.ill be te lentify if process improvements are needed to ensure that i           procedure revisions are reviewed and the necessary training established prior to ptocedure implementation. This review will be completed by April 5,1998.
Date When Full Compliance Will he Achieved Zion Station is currently in full compliance.
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Attachment B to ZRA98014
              .   - PpgeI # 1 SUPPLEMENTAL REPLY TO NO^ilCE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97025(DRS); 50-304/97025(DRS)
COMMITMENTS IDENTIFIED IN TlilS REPLY TO NOTICE 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 described to the NRC for the NRC's information, and are not regulatory commitments.
Please contact Mr. Robert Gouley, Zion Generating Station Regulatory Assurance Manager, if there are any questions regarding this document or any associated regulatory comm 8'     ...
Commitment:                                                                      I Committed Date j (or Outage):
A review of the procedure change implementation process will be ' April 5,1998 performed. The intent of this ceview will be to identify process improvements to ensure that procedure revisions are. reviewed ard .he                                    ,
necessary trainmg established prior to procedure implementation. This review will be completed by April 5,1998.
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