IR 05000295/1989004

Discusses Safety Insp Repts 50-295/89-04 & 50-304/89-04 on 890105 & Forwards Notice of Violation

ML20236B740
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/08/1989
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
Shared Package
ML20236B744	List: IR 05000295/1989004 ML20236B746
References
NUDOCS 8903210259
Download: ML20236B740 (3)

Text

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MAR 8 1989 Docket No. 50-295 Docket No. 50-304 EA 89-25

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. Commonwealth Edison Company I ATTN: Mr. Cordell Reed Senior Vice President ,

Post Office Box 767 i Chicago, IL 60690 _

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Gentlemen:

This refers to our. letter dated January 24, 1989, which forwarded the results of a special safety inspection conducted to review Licensee Event Report (LER) l No. 88011 which identified unconnected secondary undervoltage contact wiring j for Breaker No. 2484. The inspection also reviewed the surveillance testing of 4 the secondary undervoltage and station blackout AFW actuation channels, and the; 'l modification testing of the secondary undervoltage modification and the Appendix R required EDG control power isolation switch modification. The NRC  !

Inspection Reports 50-295/89004(DRS) and 50-304/89004(DRS) indicated there were i two apparent violations. .The letter also stated that we were evaluating appropriate enforcement actions for these violation ]

The evaluation has been completed and the NRC staff has determined that certain i of your activities appear to be in violation of NRC requirements, as specified in the enclosed Notice. The first violation consists of two examples of improper installation, construction testing and modification functional testing involving the secondary undervoltage modification for both units and the EDG control power isolation switch modification for both unit The second violation consists of two examples of inadequate Zion Technical Specification (TS) required channel functional testing of the AFW secondary undervoltage actuation channel logics and the AFW station blackout actuation channel logics for both unit We have consk.ered the additional information you provided at an Enforcement Conference held in the Region III office on February 9, 1989, between Mr. T. Maiman and others of your staff and Mr. A. B. Davis and members of the Region III and NRR staffs. Your presentation indicated that the new modification program should prevent the recurrence of inadequate modification installation and functional testing; and that the single loss of any affected equipment would not prevent the safe shutdown of either unit. Redundant equipment as  ;

well as manual actions were available to initiate auxiliary feedwater or to  !

energize the safety-related electrical busses. We therefore categorize each of i the above violations as a Severity Level IV violation. A written response is require '

8903'10259 2 890308 PDR ADOCK 05000295 O PDC 1 (

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Commonwealth Edison Company 2 MAR 8 1989 The NRC acknowledges the improvements that the Zion Station has made in implementing a new modification program. The two wiring errors described in the ins.pection report were discovered during walkdowns for other modification However, we are concerned about the safety-related modifications that were installed prior to the implementation of the new modification program. We request that in your response to the modification testing violation, you describe the measures you are taking or plan to take to ensure that previous safety-related modifications were correctly installed and adequately teste The NRC acknowledges that the Zion Station is presently pursuing enhancements to their surveillance testing program. However, we feel that clarification of the Technical Specification (TS) instrumentation testing requirements and TS instrumentation definitions and how they come together to accomplish surveillance testing may be necessary to prevent the recurrence of inadequate actuation channel surveillance testing. In your response to the surveillance testing violation, we request that you deccribe the measures you are taking or plan to take to determine whether wn Technical Specification (TS) surveillance tests reflect the proper interpretation of TS definition Your reply to this letter and the results of future inspections in this area will be con:;idered in determining whether escalated enforcement actions may be appropriate if similar violations are identified during future inspection In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosure, and your response to this letter will be placed in the NRC Public Document Roo The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51 We will gladly discuss any questions you have concerning this matte

Sincerely, L,;.3;l1 E:5 CY E JI J. U ' l Hubert J. Miller, Director Division of Reactor Safety ,

Enclosure: Notice of Violation See Attached Distribution Wr d RIIIp A RIIII RIII RIII R RI RIII BM,,;k 03/06/89 M S'

caraner 03/07 /89 03/c1/89 dh 03/07/89 r e 03/06/89 r

Sh~/89 Of 11 r 03/ /89

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Commonwealth Edison Company 3 MAR 8 1989 Distribution  !

cc w/ enclosure:  !

T. J. Maiman, Vice President,  ;

PWR Operations- 3 H. Bliss, Nuclear {

Licensing Manager j T. Joyce, Station Manager C. Patel, NRR ,

l DCD/DCB (RIDS)

Licensing Fee Management Branch J. Lieberman, OE J. Goldberg, OGC L. Chandler, OGC T. Murley, NRR D. Crutchfield, NRR Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division Mayor, City of Zion l

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