View source for A98026, Responds to NRC Re Violations Noted in Insp Repts 50-295/97-32 & 50-304/97-32.Corrective Actions:Disciplined Individuals Involved & Distributed Ltr to Personnel Discussing Event & Lessons to Be Learned

{{Adams
| number = ML20217E355
| issue date = 03/27/1998
| title = Responds to NRC Re Violations Noted in Insp Repts 50-295/97-32 & 50-304/97-32.Corrective Actions:Disciplined Individuals Involved & Distributed Ltr to Personnel Discussing Event & Lessons to Be Learned
| 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 = 50-295-97-32, 50-304-97-32, ZRA98026, NUDOCS 9803310016
| title reference date = 02-25-1998
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 5
}}

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* Zion Generating .Atation                                                                        l n''    *
         .        101 shiloh floulesard Zion.11. 60&M T9" Teisennam6 7RA98026 March 27,1998 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:        Document Control Desk

==Subject:==
Reply to Notice of Violation NRC Inspection Report No. 50-295/304-97032(DRP),
NRC Docket Numbers 50-295 & 50-304

==Reference:==
Letter to O. D. Kingsley (Comed) from G. E. Grant (USNRC), dated February 25,1998, NRC Inspection Report 50-295/304-97032 and Notice of Violation Gentlemen:
By {{letter dated|date=February 25, 1998|text=letter dated February 25,1998}}, the NRC cited Commonwealth Edison (Comed) as being in violation of regulatory requirements. This letter and its attachments constitute Comed's reply to the referenced Notice of Violation (NOV) in accordance with applicable regulations. Attachment A to this letter provides the reasons for the violation, 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.
C' r,r 's J 98033.10016 980327
* PDR      ADOCK 05000295 G                          PDR A t nkom o>mp.m>

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,a ZRA98026 March 27,1998                                                                              ,
Page 2 of 2                                                                                i Should you have any questions concerning this response, please contact Robert Godley of my staff at 847-746-2084 extension 2900.
               'incerely,                                                                                )
1 Q(L-ohn C. Brons Site Vice President Zion Nuclear Station Attachments cc:     Regional Administrator, USNRC - Region III Senior Project Manager, USNRC - NRR Project Directorate III-2 NRC Senior Resident Inspector, Zion Generating Station Office of Nuclear Facility Safety - IDNS i
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         ...                     . Attachment A to ZRA98026
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Page i of 2 REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97032,50-304/97032 VIOLATION 50-304/97032-01:
Technical Specification 6. 2.1.a requires that written procedures be prepared, implemented, and maintainedfor procedures recommended in Appendix A ofRegulatory Guide 1.33, Revision 2. February 1978.
Appendix A of Regulatory Guide 1.33, Revision 2. February 1978, specifies equipment control, e.g., locking and tagging, as an example ofan administrative procedure.
Zion Administrative Procedure 300-06, "Out ofService Process," Revision 17, Appendix B, "Lilling Out-Of-Service Techniques, " specifies, in part, that equipment be returned to service in accordance with the applicable system operating instruction.
System Operating Instruction-10E, " Aligning Auxiliary Feedwater System For Split Header Lineup, " Revision 9, specifies the positions of the 2B auxiliaryfeedwater pump discharge isolation valve, 2Fil'0038, and the 2B auxiliaryfeedwaterpump discharge stop valve, 2Fil'0042, as locked closed.
Contrary to the above, on January 7,1998, the licensee returned to service both valves 2Fil'0038 and 2Fil'0042 in the locked open position instead of the locked close position specified in applicable System Operating Instruction-10E.
This is a Severity IV violation (Supplement 1). (50-304/97032-01)
Admission or Denial of the Violation Comed admits the violation.
Reason for the Violation The reason for this violation is a failure on the part of the individuals who prepared and reviewed the final clear to consider whether the valve positions listed in'the System Operating Instruction (SOI) Valve Lineup (SOI-10, Appendix A-2," Auxiliary Feedwater Valve and Electrical Lineup") were the correct return to service (R/S) positions for the plant conditions. They simply transferred information from the valve lineup to the final clear without analyzing the functional requirements of the system or the impact of the valve positions.

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            ,   Attachment A to ZRA98026 Page 2 of 2 REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/97032,50-304/97032 The preparer and reviewer of the Final Clear incorrectly believed that it was sufficient to consider only the SOI Valve Lineup and therefore failed to consult the applicable sol (s) for the existing conditions of the plant: SOI-10E," Aligning Auxiliary Feedwater System l               For Split Header Lineup," and SOI-10D," Placing Steam Generators in Wet Layup."
l A contributing cause is the fact that the Valve Lineup procedure SOI-10, Appendix A-2 did not state the required positions of 2FWOO35 and 2FWOO37 (Auxiliary Feedwater (AFW) Discharge Header Cross-Connect Valves),2FWOO38 ("B" AFW Pump Discharge Isolation Valve) and 2FW0042 ("B" AFW Pump Discharge Stop Valve) to begin unit startup. The listed positions for the four valves are appropriate for Mode 1 (normal header lineup) but not unit startup (split header lineup). Valve lineups are typically used to align system components in a position to support unit startups.
Corrective Steps Taken and Results Achieved The individuals involved in the preparation and review of the final clear for OOS #
970014102 were disciplined for their actions (and inactions) in accordance with station policy.
A letter discussing this event and the lessons to be learned has been sent from the Operations Manager to each individual member of Zion Operations Shift and OWCC management presently qualified to prepare and/or review OOS and R/S documents. Each such member of Zion Operations Management signed the letter indicating that he has read and understands the letter, and returned the letter to the Operations Manager. The letter summarized management expectations regarding the OOS process, as demonstrated by this event, including the use of ALL applicable SOls, not just the SOI Valve Lineups, fbr return-to-service information.
Corrective Steps That Will be Taken to Avoid Further Violations Valve Lineup Sdl-10, Appendix A-2 will not be revised to indicate the correct valve positions for 2FW0035,2FWOO37,2FWOO38 and 2FWOO42 for unit startup conditions (Split Header Alignment) because this system is no longer required at Zion Station.
Date When Full Compliance Will be Achieved Zion Generating Station is currently in full compliance, i
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         . Attachment B to ZRA98026 PageiofI COMMITMENTS IDENTIFIED IN THIS REPLY TO NOTICE OF VIOLATION
           ' The following table identifies those actions committed to by Comed in this document.
Any other actions discussed is 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 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):
None                                                                      None}}