A97040, Forwards Response to NRC Re Violations Noted in Insp Repts 50-295/97-13 & 50-304/97-13.Corrective Actions: Operations Manager Met W/Each Shift Manager & Other Key Supervisors to Point Out Accountability Re Overtime

Forwards Response to NRC Re Violations Noted in Insp Repts 50-295/97-13 & 50-304/97-13.Corrective Actions: Operations Manager Met W/Each Shift Manager & Other Key Supervisors to Point Out Accountability Re Overtime

ML20217A012
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	09/15/1997
From:	Brons J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-295-97-13, 50-304-97-13, ZRA97040, NUDOCS 9709190043
Download: ML20217A012 (36)

Text

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/inti (artierating 5tati4 m 101 $hihih Houlesarti non n m m e r i ri w.wos i ZRA97040 September 15,1997 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Commonwealth Edison Reply to Notice of Violation in NRC Inspection Report Number 50 295/304-97013(DRP);

Zion Nuclear Power Station Units 1 and 2; NRC Docket Numbers 50-295 and 50-304

Reference:

Letter to J. H. Mueller (Comed) from G. E. Grant (USNRC) dated August 15, 1997. NRC Inspection Report 50-295/97013, 50-304/97013 and Notice of Violation Gentlemen:

By letter dated August 15, 1997, the NRC cited Commonwealth Edison (Comed) as being in violation of regulatory requirements. The referenced Inspection Report cited three Severity Level IV violations. The first violation involves licensed operators routinely exceeding overtime limitations to accomplish operations department work activities. The second violation involves three examples in which personnel did not perform activities as required by procedures, with two of the examples related to the Unit I containment fire. The third violation involves three examples of falsification of records which occurred between May 1994 and October 1995. As discussed in the Notice of Violation (NOV), Zion Station is not required to respond to this third violation since the referenced Inspection Report accurately reflects our corrective actions and position. This letter and its attachments constitute Comed's reply to the referenced Notice of Violation in accordance with applicable regulations.

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ZRA97040 September 15,1997 Page 2 of 2 Attachment A to this letter provides 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.

A response to Example (a) of Violation 50-295(304)/97013-03 is not included in this submittal. Comed requested an additional week beyond the 30 day response for the above reference in order to prepare a more comprehensive response to this violation example, By discussion with the Region 111 Branch Chief, the additional time was granted. Comed will reply to Violation 50-295(304)/97013-03 Example (a) by September 22,1997.

Should you have any questions concerning this response, please contact Robert Gxiley of my staff at 847-746-2084 extension 2900.

Sincerely, 1

ohn C. Brons Site Vice President Zion Nuclear Station Attachments cc: Regional Administrator, USNRC - Region 111 l Senior Project Manager, USNRC - NRR Project Directorate III-2 Senior Resident Inspector, Zion Nuclear Station Office of Nuclear Facility Eafety - IDNS s

ATTACHMENT A to ZRA97040 -

Page 1 of 6 J-i Resnonse to Notice of Violation in inspection Report 50-295/304-97013 i

VIOLATION: 50-295(304)/97013-02 i

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l Technical Specification (7S) 6.2.1.1 requires tiuit written procedures be prepared, -

implemented, ami maintainedfor working hours of the Shift Engineer, Shift Control Room Engineer, Shift Foreman, andNuclear Station Operator such that the heasy use of i overtime is no: routinely required.

J

i. Zion Administrative Procedure 200-01, " Station Organi:ation," Revision 4, Table IA, clarifies the relationship of TS organi:ation nomenclature to corresponding plant l procedure titles. Specipcally,1S 6.2.1.1 nomenclature refers to the fcdlowing plant-

! procedure position titles: Shift Afanager, Shift Control Room Engineer, Shift 7'e chnical l Advisor, Unit Supervisor, Licensed Shift Supervisor, and Nuclear Station Operator.

i l Zion Administrative Procedure 200-04, " Overtime Guidelines," Revision 2, Section F.4.b.

l. requires that unless approval is grantedper this procedure, an individualis not permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in am' 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-l hour pericxt, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all excluding shift turnover j time.

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L Contrary to the above, the inspectors identified thatfrom Afarch 10 through Afay 18, 1997, overtime in excess of the guidelines without approval was routinely used to accomplish operations department work activities. The inspectors reviewed gatehouse access records for four Shift Afanagers, three Unit Supervisors, and three Nuclear

Station Operators and identiped 83 examples of overtime in excess of the guidelines without approvalincluding: one example of an individual working greater than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24-hourperiod, three examples ofindividuals working greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-i day period, and 79 examples ofindividuals working greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period, all excluding shift turnover time.

1 This is a Severity LevelIV violation (Supi dement 1).

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ATTACHhiENT A to ZRA97040 Page 2 of 6 ADMISSION OR DENI Al, TO Tile VIOLATION Comed admits the violation.

REASON FOR Tile VIOLATION The reason for this violation is inadequate management oversight in the implementation of the station's overtime guidelincs within the Operations Depanment. Additionally, Operations Senior hianagement failed to aggressively pursue Site Quality Verification (SQV) identified overtime control issues.

hianagement's independent investigation of this concern validated the NRC's finding and further identified that a majority of the procedure deviations were isolated to a subset of management indisiduals. The nature of the deviations involved the failure of these individuals to obtain pre-approval for all overtime deviations, as required by the procedure.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACillEVED The Operations himager has personally met with each Shift hianager and other key supervisors tc point out their accountability in administering overtime. In addition, to ensure all Operations clearly understand those expect nons directly from the Operations hianager a Standing Order was issued.

The Standing Order clarifies past misunderstandings and directs the Supersisor to identify in advance if a shift turnover process will result in exceeding the procedural time constraint of thineen hours. The offgoing shift personnel are required to obtain Operations hianager's (or his specific designee) pre-approval. The Department Head and Supervisor do not have authority to approve deviations without first obtaining the Operations Manager pre-approval. The Operations hianager will then ensure compliance is in accordance with ZAP 200-04.

8 CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTilER VIOLATIONS The Operations Manager will verify compliance with ZAP 200-04 by performing weekly 100% samples of Operations Department Management personnel performance as related to ZAP 200-04, including a review of the number of hours worked and the quality of overtime deviations submitted. Deviations of the procedural guidelines will be viewed as personal performancc deficiencies and the appropriate actions will be administered. This process will continue until the Operations Manager is satisfied that the problem has been corrected. Weekly random samples will be conducted then itler, at which point an evaluation will be made on the need to continue or modify the sampling.

l l

ATTACHMENT A to ZRA97040 Page 3 of 6 An automated. system for tracking hours worked by Operations personnel has been developed and is currently undergoing final testing and validation. This system allows for the electronic timekeeping of hours worked (including overtime), and enables management to ascenain violations as well as predict upcoming situations in which an individual employee is at risk to violate the procedural guidelines. This system will be implemented by December 1,1997.-

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Zion Station is currently in full compliance.

i . . . . .

ATTACilMENT A to ZRA97040 Page 4 of 6 VIOLATION: 50-295(304)/97013-03 10 CFR Part 50, Appendix B, Criterion l', " Instruct:was, Procedures, and Dratrings,"

requires that activities affecting quality be prescrced by documented instructions, procedures, or dra> rings of a type appropriate to the circumstances and that these activities he accomplished in accordance svith these instructions, procedures, or drasvings.

Zion Administrative Procedure 900-05, " Control, Use, and Storage of Flammable an1 Combustible Liquids and Aerosols," Revision I, Section F.7, requires that adequate natural or mechanical ventilation is ensured in areas uhere flammable liquids or aerosols are to be used Zion Administrative Procedure 400-14, " Equipment and 1ool Storage in Safety Related Areas," Revision 0, Attachment B.5, requires that items schich do not meet the height-to-svidth ratio (less than or equal to Isro) and are not stored in an approved h> cation must be seismically restrained Zion Administrative Procedure 900-03," Station Fire Brigade," Revision 3, Section G.1, requires that any person discovering apre is to immediately report it to the control room.

Contrary to the above, activities affecting quality trere not accomplished in accordance svith applicable procedures or instructions in thefollosring instances:

a. On May 24,1997, mechanical maintenance personnel did not ensure that adequate natural or mechanical ventilation tras established schile applying a pammable hibricant to the Unit I reactor vessel studholes; consequently, apash fire residted

b. On May 19,1997, the inspectors idennfied that a deconning machine and a storage cabinet svere not stored in approved locations and did not meet the required height-to-svidth ratio, nor had the equipment been seismically restrained

c. On May 24,1997, upon observing afire in the Unit I containment building, a Radiation Protection Technicianfailed to immediately report thefire to the control room.

7his is a Severity Level 1l' violation (Supplement 1).

ATTACHMENT A to ZRA97040 Page 5 of 6 A.DMISSION OR DENIAI, TO Tile VIOL >ATION Comed admits the violation.

I Violation Example a:

Per discussion with NRC Region 111 staff, response to this example will be submitted at a later date.

Violation Example b:

! REASON FOR Tile VIOI.ATION The reason for this violation is that little or no training has been provided to Operations,

, Maintenance, Construction, and Radiation Protection Department personnel regarding the requirements of ZAP 400-14," Equipment and Tool Storage in Safety Related Areas." A lack of knowledge of the procedural requirements for the temporary storage of equipment and tools in safety related, seismic areas of the plant (among Comed and contract personnel), resulted la improper storage of the deconning machine and storage cabinet.

i Additionally, Attachmem C of ZAL 400-14 identifies permissible storage areas and maximum allowable height of stored items for the specific areas, however, the actual plant areas are not identified by floor markings or signs.

CORRECTIVE ACTIONS TAKEN AND RESUI TS AClllEVED The deconning machir.e and storage cabinet have been relocated to seismically approved

! locations.

Requests were issued to the Training Department to evaluate to need to perform periodic administrative procedural requirement training as part of the Operations, Maintenance, Construction, and Radiation Protection Department Continuing Training Programs.

CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTilER VIOLATIONS Tailgate sessions will be conducted with personnel from the Operations, Maintenance, Construction, and Radiation Protection Departments to explain the requirements for the temporary storage of equipment and tools in safety related, seismic areas. These sessions will be completed by December 1,1997.

Storage areas indicated in ZAP 400-14 will be identified with floor markings and signs describing neight restrictions for the specific areas by December 1,1997.

ATTACilh1ENT A to ZRA97040 Page 6 of 6 DATE WilEN Fill,1, COMPI, LANCE WII,1, BE ACillEVED Zion Station is currently in full compliance.

/

Violation Example c:

REASON FOR TIIE VIOL,ATION Upon hearing an explosion-type sound, and subsequently determining that there was a fire in the Unit I reactor cavity, the Radiation Protection Technician (RPT) felt an overriding sense of urgency to render assistance and to protect the individuals working in the cavity.

The RPT knew that his supervisor was available and would be in a position to notify the control room of the fire while he assisted the hiechanical hiaintenance workers to safety.

CORRECTIVE ACTIONS TAKEN AND RESill,TS ACIIIEVED The Radiation Protection hianager conducted tailgate sessions with the Radiation Protection Technicians to discuss the conditions surrounding this event and to stress tile imponance ofimmediately reporting the discovery of a fire to the Control Room.

CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FliRTilER VIOL,ATIONS This event will be covered with Radiation Protection Technicians and Supervisors as pan of the operating experience section of the next cycle of Radiation Protection Continuing Training.

DATE WilEN Flil.1, COMPl. LANCE WII,1, BE ACillEVED Zion Station is currently in full compliance.

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ATTACilhtENT B to ZRA97040 Page1ofI r

1 List of Commitments Identified in this Violation Respo_p.g 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 notify Mr. Robert Godley, Zion Station Regulatory Assurance Manager, of any questions regarding this document or any associated regulatory commitments.

Commitment Committed Date or l

Outage 4

The Operations Manager will verify compliance with ZAP 200-04 None by performing weekly 100% samples of Operations Department Management personnel performance as related to ZAP 200-04, including a review of the number of hours worked and the quality of overtime deviations submitted. Deviaf os of the procedural guidelines will be viewed as personal performance deficiencies and the appropriate actions will be administered. This process will continue until the Operations Manager is satisfied that the problem j has been corrected. Weekly random samples will be conducted thereafter, at which point an evaluation will be made on the need to continue or modify the sampling.

An automated system for tracking hours worked by Operations December 1,1997 personnel has been developed and is currently undergoing final testing and validation. This system allows for the electronic

! timekeeping of hours worked (including overtime), and enables

management to ascertain violations as well as predict upcoming

situations in which an individual employee is at risk to violate the procedural guidelines. This system will be implemented by December 1,1997, 4

Tailgate sessions will be conducted with personnel from the December 1,1997

Operations, Maintenance, Construction, and Radiation Protection Departments to explain the requirements for the temporary ctorage of equipment and tools in safety related, seismic areas These sessions will be completed by December 1,1997.

Storage areas indicated in ZAP 400-14 will be identified with floor December 1,1997 markings and signs describing height restrictions for the specific areas by December 1,1997.

This event (fire in the Unit I reactor cavity) will be covered with None

Radiation Protection Technicians and Supervisors as part of the 1

operating experience section of the next cycle of Radiation Protection Continuing Training.

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ZRA97040 September 15,1977 U. S. Nuclear 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 97013(DRP);

Zion Nuclear Power Station Units 1 and 2; NRC Docket Numbers 50-295 and 50-304

Reference:

Letter to J.11. Mueller (Comed) from G. E. Grant (USNRC) dated August 15, 1997. NRC Inspection Report 50-295/97013, 50-304/97013 and Notice of Violation Gentlemen:

By letter dated August 15, 1997, the NRC cited Commonwealth Edison (Comed) as being in violation of regulatory requirements. The referenced Inspection Report cited three Severity Level IV violations. The Grst violation involves licensed operatore routinely exceeding overtime limitations to accomplish operations department work activities. The second violation involves three examples in which personnel did not perform activities as required by procedures, with two of the examples related to the Unit I containment Gre. The third violation involves three examples of falsification of records which occurred between May 1994 and October 1995. As discussed in the Notice of Violation (NOV). Zion Station is not required to respond to this third violation since the referenced Inspection Repdrt accurately reflects our corrective actions and position. This letter and its attachments constitute Comed's reply to the referenced Notice of Violation in accordance with applicable regulations.

si , . ,

., ZRA97040 September 15,1997 Page 2 of 2 Attachment A to this letter provides 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.

A response to Example (a) cf Violation 50-295(304)/97013-03 is not included in this submittal. Comed requested an additional week beyond the 30 day response for the above reference in order to prepare a more comprehensive response to this violation-example. By discussion with the Region til Branch Chief, the additional time was granted. Comed will reply to Violation 50 295(304)/97013-03 Example (a) by September 22,1997.

'Should you have any questions conceming this response, please contact Robert Godley of my staff at 847-746-2084 extension 2900.

Sincerely, ,

' ohn C. Brons

' Site Vice President Zion Nuclear Station Attachments cc: Regional Administrator, USNRC - Region IU Senior Project Manager, USNRC '- NRR Project Directorate Ill 2 l

Senior Resident inspector, Zion Nuclear Station i

Office of Nuclear Facility Safety - IDNS

ATTACHMENT A to ZRA97040 Page1of6 Response to Notice of Violation in insocction Report 50-295/304 97013 VIOLATION: 50-295(304)/97013-02 Technical Specipcation (IS) 6.2.1.1 requires that uritten procedures be prepared, implemented, and maintainedfor uvrking hours of the Shift Engineer, Shift Control Room Engineer Shift Foreman, anJ Nuclear Station Operator such that the heary use of overtime is not routinely required.

Zion Administrative Procedure 200-01, " Station Organi:ation," Revision 4, Table IA, clartfes the relationship of TS organi:ation nomenclature to corresponding plant procedure titles. Specipcally, TS 6.2.1.i nomenclature refers to the follouing plant procedure position titles: Shift Afanager, Shift Control Room Engineer, Shift Technical Advisor, Unit Supervisor, LicensedShift Supervisor, andNuclear Station Operator.

Zion Administrative Procedure 200-04, " Overtime Guidelines," Revision 2, Section F.4.b.

requires that unless approval is grantedper this procedure, an individual is not permitted to unrk more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all excluding shift turnover time.

Contrary to the above, the inspectors identified thatfrom Afarch 10 through Alay 18, 1997, overtime in excess of the guidelines withcut approval was routinely used to accomplish operations department uvrk activities. The inspectors reviewed gatehouse access records for four Shift Managers, three Unit Supervisors, and three Nuclear Station Operators and identiped 83 examples of overtime in excess of the guidelines without approvalincluding: one example of an individual uvrking greater than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24-hour period, three examples ofindividuals working greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 day period, and 79 examples ofindividuals working greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period, all excluding shift turnover time.

This is a Severity Levelll' violation (Supplement 1).

J

- ATTACHhiENT A to ZRA97040 Page 2 of 6 ADMISSION OR DENIAL,TO Tile VIOL.ATION Comed admits the violation.

REASON FOR TiiE VIOI,ATION The reason for this violation is inadequate management oversight in the implementation of the station's overtime guidelines within the Operations Depanment. Additionally, Operations Senior Management failed to aggressively pursue Site Quality Verification (SQV) identified overtime control issues.

Management's independent investigation of this concern validated the NRC's fmding and further identified that a majority of the procedure deviations were isolated to a subset of management individuals. The nature of the deviations involved the failure of these individuals to obtain pre-approval for all overtime deviations, as required by the procedure.

CORRECTIVE ACTIONS TAKEN AND RESUI,TS ACTIIEW;.Dl i The Operations Manager has personally met with each Shin Manager and other key supervisors to point out their accountability in administering overtime. In addition, to ensure all Operations clearly understand those expectations directly from the Operations Manager a Standing Order was issued.

The Standing Order clarifies past misunderstandings and directs the Supenisor to identify in advance if a shin turnover process will result in exceeding the procedural time constraint of thirteen hours. The offgoing shin personnel are regmred to obtain Operations Manager's (or his specific designee) pre-approval. The Department Head and Supervisor do not have authority to approve deviations without first obtaining the Operations Manager pre-approval. The Operations Manager will then ensure compliance is in accordance with ZAP 200-04.

CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTIIER VIOLATIONS The Operations Manager will verify compliance with ZAP 200-04 by performing weekly 100% samples of Operations Department Management personnel performance as related to ZAP 200-04, including a review of the number of hours worked and the quality of overtime deviations submitted. Deviations of the procedural guidelines will be viewed as personal performance deficiencies and the appropriate actions will be administered. This process will continue until the Operations Manager is satisfied that the problem has been corrected. Weekly random samples will be conducted thereafter, at which point an evaluation will be made on the need to continue or modify the sampling.

ATTACHMENT A to ZRA97040 Page 3 of 6 An automated system for tracking hours worked by Operations personnel has been developed and is currently undergoing final testing and validation, This system allows for the electronic timekeeping of hours worked (including overtime), and enables management to ascertain violations as well as predict upcoming situations in which an individual employee is at risk to violate the procedural guidelines. This = istem will be implemented by December 1,1997.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Zion Station is currently in full compliance.

I

. - ATTACHMENT A to ZRA97040 f Page 4 of 6 VIOLATION: 50 295(304)/97013-03 10 CFR Part So, Appendix B, Criterion l', "Instntctions, Procedures, and Drauings,"

requires that activities affecting quality be prescribed by documented instructions, procedures, or drawmps of a type appropriate to the circumstances and that these activities be accomplished in accordance with these mstructions, procedures, or drawings.

Zion Administratiw Procedure 900-05, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols," Revision I, Section F.7, requires that adequate natural or mechanical ventilation is ensured in areas where flammable liquids or aerosols are to be used.

Zion Administrative Procedure 400-14, " Equipment and Tool Storage in Safety Related Areas," Revision 0, Attachment B.5, requires that items which do not meet the height-to-width ratio (less than or equal to two) arut are not stored in an approved location must be seismically restrained.

Zion Administrative Procedure 900-08," Station Fire Brigade " Revision 3, Section G.1, requires that any person discovering a fire is to immediately report it to the control room.

Contrary to the above, activities affecting quality were not accomplished in accordance with applicable procedures or instructions in thefollowing instances:

a. On May 24,1997, mechanical maintenance personnel did not ensure that adequate natural or mechanical ventilation was established while applying a flammable lubricant to the Unit I reactor vessel stud holes; consequently, aflash fire resulted.

b. On May 19,1997, the inspectors identified that a deconning machine and a storage cabinet were not stored in approved locations arut did not meet the reqtaired height-to-width ratio, nor had the equipment been seismically restrained.

c. On May 24,1997, upon observing afire in the Unit I containment building, a Radiation Protection Technicianfailed to immediately report thefire to the controlroom.

This is a Severity LevelIV violation (Supplement 1).

ATTACilhiENT A to ZRA97040 Page 5 of 6 ADMISSION OR DENIAL TO Tile VIOLATION Comed admits the siolation.

Violation Example a:

Per discussion with NRC Region 111 stafl', response to this example will be submitted at a later date.

Violation Example b:

REASON FOR TIIE VIOLATION The reason for this violation is that little or no training has been provided to Operations, hiaintenance, Construction, and Radiation Protection Department personnel regarding the requirements of ZAP 400-14," Equipment and Tool Storage in Safety Related Areas." A lack of knowledge of the procedural requirements for the temporary storage of equipment and tools in safety related, seismic areas of the plant (among Comed and contract personnel), resulted in improper storage of the deconning machine and storage cabinet.

Additionally, Attachment C of ZAP 400-14 identifies permissible storage areas and maximum allowable height of stored items for the specific areas, however, the actual plant areas are not identified by floor markings or signs.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACIIIEVED The deconning machine and storage cabinet have been relocated to seismically approved locations.

Requests were issued to the Training Department to evaluate to need to perform periodic administrative procedural requirement training as part of the Operations, hiaintenance, Construction, and Radiation Protection Department Continuing Training Programs.

CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER VIOLATIONS Tailgate sessions will be conducted with personnel from the Operations, hiaintenance, Construction, and Radiation Protection Departments to explain the requirements for the temporary storage of equipment and tools in safety related, seismic areas. These sessions will be completed by December 1,1997.

Storage areas indicated in ZAP 400-14 will be identified with floor markings and signs describing height restrictions for the specific areas by December 1,1997.

_ _ _ _ _ _ _ - _ _ _ _ _ _ - l

ATTACHMENT A to ZRA97040 Page 6 of 6 DATE WIIEN FULL COMPl. LANCE WILI, BE ACillEVED Zion Station is currently in full compliance.

Violation Example c:

REASON FOR TIIE VIOLATION Upon hearing an explosion-type sound, and subsequently determining that there was a fire in the Unit I reactor cavity, the Radiation Protection Technician (RPT) felt an overriding sense of urgency to render assistance and to protect the indisiduals working in the cavity.

The RPT knew that his supenisor was available and would be in a position to notify the control room of the fire while he assisted the Mechanical Maintenance workers to safety.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The Radiation Protection Manager conducted tailgate sessions with the Radiation Protection Technicians to discuss the conditions surrounding this event and to stress the importance ofimmediately reporting the discovery of a fire to the Control Room.

CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER VIOLATIONS This event will be covered with Radiation Protection Technicians and Supenisors as part of the operating experience section of the next cycle of Radiation Protection Continuing Training.

DATE WIIEN FULL COMPLIANCE WILL BE ACillEVED Zion Station is currently in full compliance.

l l

,. - ATTACHhiENT B to ZRA97040 Page1of1 List of Commitments identified in this Violation Response 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 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 The Operations hianager will verify compliance with ZAP 200-04 None by performing weekly 100% samples of Operations Department hianagement personnel performance as related to ZAP 200-04, including a resiew of the number of hours worked and the quality of overtime desiations submitted. Deviations of the procedural guidelines will be viewed as personal performance deficiencies and '

the appropriate actions will be administered. This process will continue until the Operations hianager is satisfied that the problem has been corrected. Weekly random samples will be conducted thereafter, at which point an evaluation wul be made on the need to continue or modify the sampling.

An autcmated system for tracking hours worked by Operatior.s December 1,1997 personnel has be:n developed and is currently undergoing final testing and va!idation. This system allows for the electronic timekeeping of hours worked (including overtime), and enables management to ascertain violations as well as predict upcoming situations in which an individual employee is at risk to violate the procedural guidelines. This system will be implemented by December 1,1997.

Tailgate sessions will be condacted with personnel- from tne December 1,1997 Operations, hiaintenance, Construction, and Radiation Protection Departments to explain the requirements for the temporary storage of equipment and tools in safety related, seismic areas. These sessions will be completed by December 1,1997.

Storage areas indicated in ZAP 400-14 will be identified with floor December 1,1997 markings and signs describing height restrictions for the specific areas by December 1,1997.

This event (fire in the Unit I reactor cavity) will be covered with None Radiation Protection Technicians and Supervisors as part of the operating experience section of the next cycle of Radiation Protection Continuing Training.

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ZRA97040 September 15,1997 U. S. Nuclear Regulatory Commission Washington,11C. 20555 Attention: Document Control Desk

Subject:

Commormealth lidison Reply to Notice of Violation in NRC Inspection Report Number 50 295/304 97013(DRp);

Zion Nuclear Power Station Units 1 and 2:

NRC Docket Nurnbers 50 295 and 50 304 i

Reference:

Letter to J.11. hiuciler (Comed) from G. E. Grant (USNRC) dated August 15, 1997. NRC Inspection Report 50 295/97013, 50 304'97013 and Notice of Violation Gentlemen:

Ily letter dated August 15, 1997, the NRC cited Commonwealth Edison (Comed) as being in violation of regulatory requirements. The refeienced inspection Report cited three Severity Level IV violations. The fli.t violation involves licensed operators routinely exceeding overtime limitations to aca mplish operations depanment work activities. The second violation involves three examples in which personnel did not perfonn activities as required by procedures, with two of the examples related to the Unit I containment fire. The third violation involves three examples of falsitication of records which occurred between hiay 1994 and October 1995. As discussed in the Notice of Violation (NOV), Zion Station is not required to respond to this third violation since the referenced Inspection Report accurately reflects our corrective actions and position. This letter and its attachments constitute Comed's reply to the referenced Notice of Violation in accordance with applicable regulations.

(

4 6 ZRA97040 September 15,1997 Page 2 of 2 Attachment A to this letter provides 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.

A 'esponse to Example (a) of Violation 50 295(304)/97013 03 is not included in this submittal. Comed requested an additional week beyond the 30 day response for the above reference in order to prepare a more comprehensive response to this violation example. By discussion with the Region til Branch Chief, the additional time was granted. Comed will reply to Violation 50 295(304)M7013 03 Example (a) by September 22,1997.

Should you have any questions concerning this response, please contact Robert Godley of my staff at 847-746 2084 cxtension 2900.

Sincerely, n

I ohn C. Brons

! Site Vice President

/ Zion Nuclear Station

- Attachments 2 cc: Regional Administrator, USNRC - Region Ill Senior Project Manager, USNRC - NRR Project Directorate 1112 Senior Resident inspector, Zion Nuclear Station Office of Nuclear Facility Safety IDNS b

m.m._ a . _ . . _ _ _ _ . _-_ _ m__--___

.m_

ATTACllMENT A to ZRA97040 Page 1 of 6 Resnonse to Notice of Violation in Inspection Report 50 295/304 97013 VIOLATION: 50 295(304)/97013 02 li'chnical Spec @ cation (15) 6.2.1.i re<ptires that uritten procedures be prepared.

Implemented, and mamiainedfor uorking hours of the Shp Engineer, Sh$ Control Room Engmeer, Sh@ Foreman, and Nuclear Station Operator such that the heasy use of overtime is not routinely required.

Zion Administrath'e Procedure 200-01, " Station Organi:ation," Revision 4, Iktble IA, claripes the relationship of IS organi:ation nomenclature to corresponding plant procedure titles. Specipcally, 15 6.2.1.1 nomenclature refers to the following plant procedure position titles: Sh@ Afanager, Shift Control Room Engineer, Shift Technical Advisor, Unit Supervisor, Licensed Shift Supervisor, arulNuclear Station Operator.

Zion Administrative Procedure 200-04, " Overtime Guidelines," Revision 2. Section F.4 b.

requires that unless approval is grantedper this procedure, an Individual is not permitted to uvrk more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 1 hour perial, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period, all excluding sh$ turnover time.

Contrary to the above, the inspectors idennfied thatfrom Alarch 10 through Afay 18, 1997, overtime in excess of the guidelines without approval was routinely used to accomplish operations department work activities. The inspectors reviewed gatehouse access records for four Shift Afanagers, three Unit Supervisors, arut three Nuclear Station Operatoes and ident@ed 83 examples of overtime in excess of the guidelines without approwlincluding: one example of an truhvidual working greater than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hourperiad, three examples ofirubriduals working greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 day period, arul 79 examples ofindividuals working greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period, all excludmg sh@ turnover sime.

This is a Seversty Level 1l' violation (Supplement 1).

ATTACllMENT A to ZRA97040 Page 2 of 6 i ADMISSION OR DENIAL, TO Tile VIOL.ATION I

ComHd admits the violation.

i REASON FOR Till: VIOL.ATION s

The reason for this violation is inadequate management oversight in the implementation of the station's overtime guidelines within the Operations Department. Additionally, Operations Senior Management failed to aggressively pursue Site Quality Verification (SQV) identified overtime controlissues, Management's independent investigation of this concern validated the NRC's finding and further identified that a majority of the procedure deviations were isolated to a subset of management individuals. The nature of the deviations involved the failure of these individuals to obtain pre-approval for all overtime deviations, as required by the procedure.

CORRECTIVE ACTIONS TAKEN AND RESUI,TS ACillEVED The Operations Manager has personally met with each Shif) Manager and other key supenisors to point out their accountability in administering overtime. In addition, to ensure all Operations clearly understand those expectations directly from the Operations Manager a Standing Order was issued.

The Standing Order clarifies past misunderstandings and directs the Supenisor to identify in advance if a shift turnover process will result in exceeding the procedural time constraint of thirteen hours. The offgoing shift personnel are required to obtain Operations Manager's (or his specific designee) pre approval. The Department 1-lead and

! Supervisor do not have authority to approve desiations without first obtaining the

! Operations Manager pre approval. The Operations Manager will then ensure compliance is in accordance with ZAP 200-04.

CORRECTIVE ACTinNS TO BE TAKEN TO AVOID FURTIIER VIOL.ATIONS l

The Operations Manager will verify compliance with ZAP 200-04 by performing weekly 100% samples of Operations Department Management personnel performance as related to ZAP 200-04, including a resiew of the number of hours worked and the quality of overtime deviations submitted. Deviations of the procedural guidelines will be siewed as personal performance deficiencies and the appropriate actions will be administered. This process will continue until the Operations Manager is satisfied that the problem has been corrected. Weekly random samples will be conducted thereatler, at which point an evaluation will be made on the need to continue or modify the sampling.

l

ATTACllMENT A to ZRA97040 Page 3 of 6 An automated system for tracking hours worked by Operations personnel has been developed and is currently undergoing fmal testing and validation This system allow s for the electronic timekeeping of hours uorked (including overtime), and enables management I to ascertain violations as well as predict upcoming situations in which an individual employee is at risk to violate the procedural guidelines. This system will be implemented by December 1,1997.

DATE WilEN Ftti I, COMpl. LANCE WII,1,110 ACIIIEVED 1

Zion Station is currently in full compliance.

i

ATTACl! MENT A to ZRA97040 l' Page 4 of 6 i YlOLATION: 50-295(304)/97013 03 j

1 10 CFR Part 30, Appendix B, Criterion l', " Instructions, Procedures, and I)tawings,"

!' requires that acthities affecting quality be prescribed by documented instructions, procedures, or drawings of a ope appnq>riate to the circumstances and that these j activities be accomphshed in accordance with these instructions, procedures, or

drawings, i Zion Administrathc Procedure 900-03, " Control, Use, ard Storage of Flammable and i Combustible 1,lquhls and Aerosols " Revision 1. Section F.7, requires that adequate 1 natural or mechanical ventilation is ensured in areas where pammable hquhls or aerosols are to be used.

l

} Zion Administrative Procedure 400-14, " Equipment and Tool Storage in Safety Related l Areas," Revision 0, Attachment B.3, requires that items which do not meet the height to-l width ratio (less than or equal to two) and are not stored in an approwd location must be i seismically restrained.

i

! Zion Administrative Procedure 900 08," Station Fire Brigade," Revision 3, Section G.),

i requires that any person discovering a fire is to immediately report it to the control i

room, i

Contrary to the above, activities affecting quality uere not accomplished in accordance i with applicable procedures or instructions in thefollowing instances:

i I

1 l a. On Aim' 24, I997, mechanical maintenance jntsonnel did not ensure that 1

adequate natural or mechanical ventilation was established u hile applying a l flammable lubricant to the Unit I reactor wssel stud holes; consequently, afash j l

fire resuhed. ,

4 h

! b. On Afar 19, J997, the inspectors idennfied that a deconning machine wula 1

storage cabinet were not stored in approwd locations and did not meet the required height to-width ratio, nor had the equipment been seismically restrained.

I

c. On Afay 24, J997, upon observing apre in the Unit I containment building, a l.

Radiation Protection Technicianfailed to immediately report thejire to the

controlroom.

l 1his is a Severin

• 1.ew!Il' violation (Supplement 1).

I 4

1

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ATTACilhiENT A to ZRA97040

. Page5of6 ADMISSION OR DENIAL TO Tile VIOI.ATION Comed admits the siolation.

Violation Example a:

Per discussion with NRC Region 111 staff, response to this example will be submitted at a later date.

1 Violation Example b:

REASON FOR Tile VIOLATION The reason for this violation is that little or no training has been prosided to Operations, 4

hiaintenance, Construction, and Radiation Protection Depanment personnel regarding the i requirements of ZAP 40014," Equipment and Tool Storage in Safety Related Areas." A lack of knowledge of the procedural requirements for the temporary storage of equipment and tools in safety related, seismic areas of the plant (among Comed and contract

. personnel), resulted in improper storage of the deconning machine and storage cabinet.

Additionally, Attachmant C of ZAP 40014 identifies permissible storage areas and maximum allowable height of stored items for the specific areas, however, the actual plant

, areas are not identified by floor markings or signs.

, CORRECTIVE ACTIONS TAKEN AND REStillrS ACHIEVED The deconning machine and storage cabinet have been relocated to seismically approved locations.

Requests were issued to the Training Department to evaluate to need to perform periodic administrative procedural requirement training as part of the Operations, hiaintenance, 3

Constructiva, and Radiation Protection Department Continuing Training Programs.

CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FliRTilER VIOLATIONS

! Tailgate sessions will t>e conducted with personnel from the Operations, hiaintenance, Construction, and Radiation Protection Departments to explain the requirements for the temporary storage of equipment and tools in safety related, seismic areas. These sessions will be completed by December 1,1997.

Storage areas indicated in ZAP 400-14 will be identified with floor markings and signs describing height restrictions for tne specific areas by December 1,1997.

,, -, -m - , - -

, -n -- -

ATTACllMENT A to ZRA97040 Page 6 of 6 DATE WilEN Flfi,1, COMPI. LANCE WII.1, HE ACIIIEVED Zion Station is currently in full compliance Violation Example c:

REASON FOR TIIE VIOL,ATION

Upon hea.-ing an explosion type sound, and subsequently determining that there was a fire in the Unit I reactor cavity, the Radiation Protection Technician (RPT) felt an overriding sense of urgency to render assistance and to protect the individuals working in the cavity.

The RPT knew that his supenisor was available and would be in a position to notify the control room of the fire while he assisted the Mechanical Maintenance workers to safety.

i CORRECTIVE ACTIONS TAKEN AND REStil,TS ACillEVED 1

The Radiation Protection Manager conducted tailgate sessions with the Radiation Protection Technicians to discuss the conditions surrounding this event and to stress the i importance ofimmediately reporting the discovery of a fire to the Control Room.

4 CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FllRTIIER VIOI.ATIONS This event will be covered with Radiation Protection Technicians and Supenisors as part of the operating experience section of the next cycle of Radiation Protection Continuing Training.

DATE WilEN Flit,1, COMPl.I ANCE WII I. HE ACIIIEVED Zion Station is currently in full compliance.

i s

4

0 g, , . ATTACHMENT B to ZRA97040 Page1of1 f List of Commitments identined in this Violation Response 4

~

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 l Comed. They are described to the NRC for the NRC's information and are not regulatory I commitments. Please notify hir. Robert Godley, Zion Station Regulatory Assurance I hianager, of any questions regarding this document or any associated regulatory

! commitments

! Commitment Committed Date or Outage l The Operations hianager will verify compliance with ZAP 200-04 None by performing weekly 100% samples of Operations Department hianagement personnel performance as related to ZAP 200 04, j including a resiew of the number of hours worked and the quality of overtime deviations submitted. Deviations of the procedural

, guidelines will be siewed as personal performance deficiencies and

the appropriate actions will be administered. This process will l continue until the Operations hianager is satisfied that the problem i has been corrected. Weekly random samples will be conducted

! thereafler, at which point an evaluation will be made on the need to l continue or modify the sampling.

1 An automated system for tracking hours worked by Operations December 1,1997 i personnel has been developed and is currently undergoing final l testing and validation. This system allows for_ the electronic

timekeeping of hours worked (including overtime), and enables management to ascertain violations as well as predict upcoming situations in which an individual employee is at risk to violate the I procedural guidelines. This system will be implemented by December 1,1997.

Tailgate sessions will be conducted with personnel from the December 1,1997 l Operations, hiaintenance, Construction, and Radiation Protection Departments to explain the requirements for the temporary storage of equipment and tools in safety related, seismic areas. These sessions will be completed by December 1,1997, i

Storage areas indicated in ZAP 400-14 will be identified with floor December 1,1997 l

markings and signs describing height restrictions for the specific areas by December 1,1997.

This event (fire in the Unit I reactor casity) will be covered with None 4

Radiation Protection Technicians and Supersisors as part of the i operating experience section of the next cycle of Radiation j Protection Continuing Training.

1 s

t .nnu. o w t a!ali i h. n a . .n.p n s

/ n in i .4 na r.ating st.at o n) ilii sinh liit.iulisard f ,. ,n n o. r c . ,-

m 3.- n,2.ist ZRA97040 September 15.1997 U. S. Nuclear 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 97013(DRP);

Zion Nuclear Power Station Units 1 and 2; NRC Docket Numbers 50 295 and 50 304

Reference:

Letter to J.11. Mueller (Comed) from G. E. Grant (USNRC) dated August 15, 1997. NRC Inspection Report 50-295/97013, 50 304/97013 and Notice of Violation Gentlemen:

By letter dated August 15, 1997, the NRC cited Commonwealth Edison (Comed) as being in violation of regulatory requirements. The referenced inspection Report cited three Severity Level IV violations. The Orst violation involves licensed operators routinely exceeding overtime limitations to accomplish operations department work activities. The second violation involves three examples in which personnel did not perform activities as required by procedures, with two of the examples related to the Unit I containment Gre. The third violation involves three examples of falsification of records which occurred between May 1994 and October 1995. As discussed in the Notice of Violation (NOV), Zion Station is not required to respond to this third violation since the referenced Inspection Report accurately reDects our corrective actions and position. This letter and its attachments constitute Comed's reply to the referenced Notice of Violation in accordance with applicable regulations.

,, , ,c

ZRA97040 September 15,1997 Page 2 of 2 Attachment A to this letter provides 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.

A response to Example (a) of Violation 50 295(304)/97013 03 is not included in this submittal. Comed requested an additional week beyond the 30 day response for the above reference in order to prepare a more comprehensive response to this violation example. By discussion with the Region til Branch Chief, the additional time was granted Comed will reply to Violation 50 295(304)/97013 03 Example (a) by September 22,1997.

Should you have any questions conceming this response, please contact Robert Godley of my staff at 847 746 2084 extension 2900.

Sincerely,

[ ~

Jchn C. Brons ISite Vice President Zion Nuclear Station Attachments ec: Regional Administrator, USNRC - Region 111 Senior Project Manager, USNRC NRR Project Directorate 11! 2 Senior Resident inspector, Zion Nuclear Station Office of Nuclear Facility Safety IDNS

=

ATTACl{ MENT A to ZRA97040 l' age 1 of 6 Resnonse to Notice of Violation in inspection Renort 50-295/304 9't013 VIOLATION: 50 295(304)/97013 02 Technical Spec $ cation (IS) 6.2.1.1 requires that uritten procedures be prepared, .

implemented, and maintainedfor uorking hours of the Sh{ft Engineer, Sh{ft Control Room Engineer Shift Foreman, and Nuclear Station Operator such that the heasy use of osertime is not routinely required.

Zion Administrative Procedure 200-01, " Station Organi:ation," Revision 4 Table 1A, clarifies the relationship of TS organi:ation nomenclature to corresponding plant procedure titles. Spec @cally, 15 6.2.1.1 nomenclature refers to the follouing plant procedure position titles: Shaft Afanager, Shift Control Room Engineer, Shift Technical Advisor, Unit Supervisor, Licensed Sh{ft Supervisor, and Nuclear Station Operator.

Zion Administrative Procedure 200-04, " Overtime Guidelines " Revision 2, Section F.4.b, requires that unless approwlis grantedper thisprocedure, an individualis notpermitted to uork more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> perkd, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> peri <d, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all excluding shift turnover time.

Contrary to the above, the inspectors ident@ed thatfrom Afarch 10 through Afay 18, 1997, overtime in excess of the guidelines without approval uns routinely used to accomplish operations department work activities. 1he inspectors revieued gatehouse access records for four Sh{ft Afarutgers, three Unit Supervisors, and three Nuclear Station Operators and ident@ed 83 examples of overtime in excess of the guidelines without approvalincludmg: one example of an hdividual working greater than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> perkd, three examples ofindividuals working greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 ,

day pericd, and 79 examples ofindividuals working greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, all excluding sh{ft turnover time.

. 1his is a Severity Levelli' violation (Supplement 1).

ATTACllhiENT A to ZRA97040 Page 2 of 6 AD5flSSION OR DENIAL TO TIIE VIOI.ATION Comed admits the violation.

REASON FOR Tif E VIOI.ATION The reason for this violation is inadequate management oversight in the implementation of the station's overtime guidelines within the Operations Department. Additionally,

! Operations Senior hianagement failed to aggressively pursue Site Quality Verification (SQV) identified overtime control issuet 4

hianagement's independent investigation of this concern validated the NRC's finding and further identified that a majority of the procedure deviations were isolated to a st.bset of management indisiduals. The nature of the deviations involved the failure of these individuals to obtain pre approval for all overtime deviations, as required by the procedure.

CORRECTIVE ACTIONS TAKEN AND RESUI,TS ACillEVED The Operations hianager has personally met with each Shill hianager and other key supenisors to point out their accountability in administering overtime. In addition, to ensure all Operations clearly understand those expectations directly from the Operations hianager a Standing Order was issued.

The Standing Order clarifies past misunderstandings and directs the Supenisor to identify in advance if a shift turnoser process will result in exceeding the procedural time i constraint of thirteen hours. The offgoing shift personnel are required to obtain

- Operations hiancger's (or his specific designee) pre approval. The Department Head and Supenisor do not have authority to approve deviations without first obtaining the Operations hianager pre approval. The Operations hianager will then ensure compliance is in accordance with ZAP 200-04.

CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTilER VIOLATIONS The Operations hianager will verify compiiance with ZAP 200-04 by performing weekly

. 100% samples of Operations Department hianagement personnel performance as related to ZAP 200-04, including a review of the number of hours worked and the quality of overtime deviations submitted. Deviations of the procedural guidelines will be siewed as personal performance deficiencies and the appropriate actions will be administered. This process will continue until the Operations hianager is satisfied that the problem has been corrected. Weekly random samples will be conducted thereafter, at which point an evaluation will be made on the need to continue or modify the sampling.

,, ATTACHMENT A to ZRA97040 Page 3 of 6 An automated system for tracking hours worked by Operations personnel has been developed and is currently undergoing final testing and validation. This system allows for the electronic timekeeping of hours worked (including ovenime), and enables management to ascertain violations as well as predict upcoming situations in which an individual employee is at risk to violate the procedural guidelines. This system will be implemented by December 1,1997.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Zion Station is currently in full compliance.

.___.a__.__:a_____.____-

ATTACHMENT A to ZRA97040 Page 4 of 6 VIOL > TION: 50 295(304)/97013 03 10 CFR Part 30. Appendix B, Criterion l', " Instructions, Procedures, and Drawings,"

requires that activities affecting quality be prescribed by documented instructions, procedures, or drauings of a type appropriate to the circumstances and that these activities he accomplished in accordance with these instructions, procedures, or drauings.

Zion Administrathe Procedure 900 05, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols " Revision I, Section F.7, requires that adequate natural or mechanical ventilation is ensured in areas where flammable hqukh or aerosols are to be used.

Zion Administrathe Procedure 400-14, " Equipment and Tool Storage in Safety Related Areas," Revision 0, Attachment B.3, requires that items uhich do not meet the height-to-

. u idth ratio (less than or equal to two) and are not stored in an ppproved location must be seismically restrained Zicn Administrative Procedure 900-08," Station Fire Brigade," Revision 3, Section G,1, requires that any person discovering a fire is to immediately report it to the control room.

Contrary to the above, activities affecting quality were not accomplished in accordance u ith applicable procedures or instructions in thefollowing instances:

a. On Afay 24,1997, mechanical maintenance personnel did not ensure that adequate natural or mechanical wntilation was established while ppplying a flammable lubricant to the Unit I reactor wssel stud holes: consequently, afash fire resulted.

b. On May 19,1997, the inspectors identsped that a deconning machine and a storage cabinet were not stored in approved locations arul did not meet the required height to-width ratio, nor had the equipment been seismically restrained

c. On May 24,1997, upon observing afire in the Unit I containment building, a Radiation Protection Technicianfailed to immediately report thefire to the controlrorm.

This is a Severity Level Il' violation (Supplement 1).

\

ATTACllMENT A to ZRA97040 Page 5 of 6 e

ADMISSION OR DEMAl,TO Tile VIOL,ATION Comed admits the violation.

Violation Example a:

Per discussion with NRC Region 111 stalT, response to this example will be sub~itted at a later date. s Violation Example bt .

REASON FOR Tile VIOI.ATION The reason for this violation is that little or no tiaining has been provided to Operations, Maintenance, Construction, and Radiation Protection Department personnel regarding the requirements of ZAP 40014," Equipment and Tool Storage in Safety Related Areas." A lack of knowledge of the procedural requirements for the temporary storage of equipment and tools in safety related, seismic areas of the plant (among Comed and contract personnel), resulted in improper storage of the deconning machine and storage cabinet.

Additionally, Attachment C of ZAP 40014 identifies permissible storage areas and rnaximum allowable height of stored items for the specific areas, however, the actual plant areas are not identified by floor markings or signs.

CORRECTIVE ACTIONS TAKEN AND RESUI,rS AClllEVED The deconning machine and storage cabinet have been relocated to seismically approved locations Requests were issued to the Training Departmcat to evaluate to need to perform periodic administrative procedural requirement training as part of the Operations, Maintenance, Construction, and Radiation Protection Department Continuing Training Programs.

CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FUIEl!ER VIOL ATIONS Tailgate sessions will be conducted with personnel from the Operations, Maintenance, Construction, and Radiation Protection Departments to explain the requirements for the temporary storage of equipment and tools in safety related, seismic areas. These sessions will be completed by December 1,1997.

Storage areas indicated in 2.AP 40014 will be identified with floor markings and signs describing height restrictions for the specific areas by December 1,1997.

ATTACilhiENT A to ZRA97040 Page 6 of 6 DATE WilEN Flfl.1, C051Pl.l ANCE Wil.1,llE ACillEVED Zion Station is currently in full compliance.

Violation Example et REASON FOR Tile VIOL,ATION Upon hearing an explosion type sound, and subsequently determining that there was a fire in the Unit I reactor cavity, the Radiation Protection Technician (RPT) felt an overriding sense of urgency to tender assistance and to protect the individuals working in the cavity.

The RPT knew that his supenisor was available and would be in a position to notify the control room of the fire while he assisted the hiechanical hiaintenance workers to safety.

CORRECTIVE ACTIONS TAKEN AND REStil,TS ACillEVED The Radiation Prote: tion hianager conducted tailgate sessions with the Radiation Protection Technicians to discuss the conditions surrounding this event and to stress the importance ofimmediately reporting the discovery of a fire to the Control Room.

CORRECTIVE ACTIONS TO IIE TAKEN TO AVOID FliRTIIER VIOI.ATIONS ,

This event will be covered with Radiation Protection Technidans and Supenisors as part of the operating experience section of the next cycle of Radiation Protection Continuing Training.

DATE WilEN Flfl.I, CON 1Pl.l ANCE Wil.I,llE ACillEVED Zion Station is currently in full compliance.

',.* ATTACllMENT B to ZRA97040 Page1of1 UgLof Commitments identified in this Vlotation Resnonse 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 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 The Operations hianager will verify compliance with ZAP 200 04 None by performing weekly 100% samples of Operations Department hianagement personnel performance as related to ZAP 200 04, including a review of the number of hours worked and the quality of overtime deviations submitted. Deviations of the procedurel guidelines will be viewed as personal performance deficiencies and the appropriate actions will be administered. This process will continue until the Operations hianager is satisfied that the problem has been corrected. Weekly random samples will be conducted thereafler, at which point an evaluation will be made on the need to continue or modify the sampling.

An automated system for tracking hours worked by Operations December 1,1997 personnel has been developed and is currently undergoing fmal testing and validation. This system allows for the electronic timekeeping of hours worked (including overtime), and enables management to ascertain violations as well as predict upcoming situations in which an individual employee is at risk to siolate the procedural guidelines. This system will be implemented by December 1,1997.

Tailgate sessions will be conducted with personnel from the December 1,1997 Operations, hiaintenance, Construction, and Radiation Protection Departments to explain the requirements for the temporary storage of equipment and tools in safety related, seismic areas, These sessions will be completed by December 1,1997.

Storage areas indicated in ZAP 40014 will be identified with floor December 1,1997 markings and signs describing height restrictions for the specific areas by December 1,1997.

This event (fire in the Unit I reactor casity) will be covered with None Radiation Protection Technicians and Supenisors as part of the operating experience section of the next cycle of Radiation Protection Continuing Training.