IR 05000295/1992030
| ML20034G218 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 03/05/1993 |
| From: | Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Delgeorge L COMMONWEALTH EDISON CO. |
| References | |
| GL-89-10, NUDOCS 9303090194 | |
| Preceding documents: |
|
| Download: ML20034G218 (2) | |
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!!.AR 5 1993 l
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Docket No. 50-295 Docket No. 50-304 Commonwealth Edison Company
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ATTN:
Mr. L.
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DelGeorge, Vice President i
Nuclear Oversight and Regulatory
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Services Executive Towers West III
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1400 Opus Place, Suite 300 Downers Grove, IL 60515
Dear Mr. DelGeorge:
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORTS NO.
50-295/92030(DRS); NO. 50-304/92030(DRS))
This will acknowledge receipt of your letter dated February 25, 1993, in response to our letter dated January 26, 1993, transmitting a Notice of Violation associated with Inspection Reports No. 50-295/ 9203 0 (DRS) and No. 50-
304 /92030 (DRS).
These reports summarized the results of the
Generic Letter 89-10 motor operated valve inspection at your Zion Nuclear Power Station.
We have reviewed your corrective actions and have no further questions at this time.
These corrective actions will be examined during future inspections.
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sincerely,
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G.
C. Wright, Chief
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Engineering Branch See Attached Distribution I
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I 9303090194 930305 PDR ADOCK 05000295 i,!
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Commonwealth Edison Company
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Distribution i
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R. Tuetken, Site Vice President T. Joyce, Station Manager
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Kaplan, Regulatory Assurance Supervisor i
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Farrar, Nuclear Regulatory
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Services Manager
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cc w/1tr dtd 02/25/93:
DCD/DCB (RIDS)
OC/LFDCB T.
Scarbrough, NRR C.
Shiraki, LPM, NRR
Resident Inspectors-Byron, I
l Braidwood, Zion l
Richard Hubbard i
Mayor, City of Zion I
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W. McCaffrey, Chief Public Utilities Division LPM, NRR Robert Newmann, Office of Public Counsel, State of Illinois Center Robert M. Thompson, Administrator Wisconsin Division of Emergency Government State Liaiscn Officer Chairman, Illinois Commerce Commission
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Commonwsalth Edison
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A 1400 Opus Place
Downers Grove, tilinois 60515
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V February 25,1993
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U.S. Nuclear Regulatory Commission Washingtor>, D. C. 20555
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Attn: Document Control Desk Subject:
Zion Nuclear Power Station Unit 1 and 2 Response to inspection Report 50-295(304)/92030 NRC Docket Number 50-295 and 50-304 Reference:
G. C Wright letter to dated January 26,1993, transmitting Inspection Report 50-295(304)/92030.
Enclosed is Commonwealth Edison Company's (CECO) response to the subject violation which was transmitted with the referenced letter.
I The violation concerns failure to promptly evaluated test data.
If there are any questions or comments regarding this response, please contact Sara Reece-Koenig, Compliance Engineer, at 708/515-7250.
Very truly yours, i
D. Farrar Nuclear Regulatory Services Manager Attachments
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A. Bert Davis, Regional Administrator - Region til cc:
Clyde Shiraki, Project Manager, NRR J. D. Smith, Senior Resident inspector, Zion
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ZNLD/2516/1
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ATTACHMENT
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REPLY TO NOTICE OF VIOLATION
NRC INSPECTION REPORT
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295/92034;304/92034
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VJQL. ATION:
10 CFR 50, Appendix B, Criterion XI, requires, in pad, that a test program be
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established to ensure that all testing required to demonstrate that components will
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perform satisfactorily in service is performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in the applicable design documents, and that test results shall be documented and l
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evaluated to assure that test requirements have been satisfied.
Contrary to the above, as of January 4,1993, the licensee had not evaluated the 1992 outage to results of the 17 dp tests that were completed during the Spring (50-295/92030-02 demonstrate that the MOVs would perform their safety function
(DRS); 50-304/92030-02 (DRS)).
This is a Severity Level IV violation (Supplement 1).
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BEASONf_OBJEIELVJIOLAIlON
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j Commonwealth Edison Company (CECO) acknowledges the violation.
CECO agrees that the results of the 17 differential pressure (dp) tests were not fully analyzed in a timely manner. The failure to fully analyze these test results in a timely manner was due to a misunderstanding between Zion Station and CECO i
Corporate Engineering personnel as to the responsibilities for accom alishing the
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requirements of White Paper 108. This was the first time that White ? aper 108 i
was to be utilized at Zion Station.
n CECO would like to clarify that the test results were promptly evaluated against the acceptance criteria established for operability. Specifically, all valves were
successfully stroked in both the open and closed directions. This acceptance criteria is currently the only approved criteria for CECO under the Generic Letter
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l 89-10 Program and is consistent with previous Station policy for MOV testing.
l As of this date, CECO is unaware of any industry-wide accepted methodology for
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extrapolation of d;> test data for MOVs tested at less than 100% design basis dp
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for the purpose of determining the capability of a MOV to perform its safety
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function under design basis conditions. VOTES equipment was utilized during the
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Spring 1992 Unit 1 Outage to gather data that would ultimately allow validation of a
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i methodology for the purpose of performing such a determination.
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ATTACHMENT
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REPLYTO NOTICE OF VIOLATION NRC INSPECTION REPORT 295/92034;304/92034 (continued)
At the time of the 17 dp tests in question, CECO Technical Document " White Paper 108 - Differential Pressure Testing Guidelines" was the only technical guidance available to Zion Station for evaluation of dp test data. White Paper 108 was intended to serve as a tool for providing feedback and aid in development acceptance criteria for the CECO MOV Program.
Zion Station made the decision to pursue testing of MOVs at less than 100%
design basis dp in an effort to take an active role in developing of CECO's overall MOV Program. The data gathered in these first attempts at testing MOVs at maximum attainable dp would serve as a useful tool in the validation of engineering assumptions and provide a basis for the development of future guidelines and acceptance criteria.
CECO has established as its goal, the development of a MOV Program which will meet or exceed all of the requirements of Generic Letter 89-10 in the most expeditious time frame reasonably achievable. To this end, CECO is actively involved in industry initiatives and working closely with major vendors to identify and resolve issues.
COBBECTIVE ACTIONS TAKEN AND RESUI,,ISAClilEV_JiQ CECO has recently reorganized its corporate MOV organization in an effort to enhance support to all CECO nuclear stations. As a part of this reorganization, a dedicated engineer from the corporate MOV organization has been assigned for each site. This is intended to provide for a closer working relationship and enhanced communications between CECO's corporate MOV organization and the Zion Station Technical Staff engineers responsible for Zion's MOV Program.
COR_ REC _TIVE ACTIONS TO BE TAKEN TO AVOID FURTHER VIOLATIONS CECO and Zion Station are currently reviewing the results of the 17 MOV dp tests using the technical guidance of White Paper 108. These reviews will be completed i
by April 5,1993.
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Zion Station will utilize the draft " VOTES Test Report Review Guide" Revision 1, dated April 21,1992 for evaluation of data collected during the recently completed Unit 2 refueling outage. Tracking of the evaluation of this data will be incorporated into a Management Action Plan designed to coordinate improvements to the Zion MOV Program.
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ATTACHMENT
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REPLY TO NOTICE OF VIOLATION
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NRC INSPECTION REPORT 295/92034;304/92034 (continued)
COBREC_TIVEAGIlONSJO_DEJAKENJDORDIDIUBIliEBXIOLAllONS
CECO will continue to pursue implementation of the requirements of Generic Letter i
89-10. As data gathering techniques are validated and the data collected is fully analyzed, acceptance cnteria will be developed and incorporated into CECO
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corporate and station procedures as necessary. In the interim, acceptance criteria currently provided in station procedures and Technical Specifications will continu to be utilized for operability determinations.
DATE WHEN_EULL_CDMPil ANCE_VdLLBEACHIEVED
Zion Station will be in full compliance by April 5,1993.
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