ML17201Q408
| ML17201Q408 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/04/1989 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17201Q407 | List: |
| References | |
| 50-237-88-29, 50-249-88-30, NUDOCS 8904180102 | |
| Download: ML17201Q408 (5) | |
Text
NOTICE OF VIOLATION Commonwealth Edison Company Dresden Station - Units 2 and 3 Docket Nos. 50-237; 50-249 Licenses No. DPR-19; -DPR 25 As a result of the inspection conducted on January 23-27, February 6-10, and February 16, 1989, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1988), the following violations were identified:
- 1.
10 CFR 50, Appendix B, Criterion XVI, as implemented by Commonwealth Edison Company's Quality Assurance Program, as described in Section 16 of Topical Report CE-lA, requires that measures be established to assure conditions adverse to quality are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measure shall assure that the cause of the condition~is determined and corrective action taken to preclude repetition.
Contrary to the above:
The cause of 4.16kV breaker failure was inadequately evaluated for the Unit 2 Low Pressure Coolant Injection Pump 1-'D 11 in February 1988.
An adequate evaluation would have identified that maintenance of 15 Unit 2 and 3 breakers was not performed at the requi~ed frequency.
Two 4.16kV b~eakers, which supplied the motors for Unit 2 Containment Cooling Service Water pumps, were last overhauled in 1976.
The cause of Unit 3 Isolation Condenser Makeup valve failure in July 1988 was inadequately evaluated.
Failure to perform preventive maintenance was not identified as a contributing factor.
Preventive maintenance had not been perform~d on Unit 3 250 Vdc motor control centers, 3A and 38 *s i nee 1975.
These motor contra l centers supply power to HPCI torus suction valves.
Auxiliary switches (SBM) for Unit 2 and 3 4.16kV breakers and breaker cubicles were not replaced even though the switches had a history of failure since 1982 and were at or near end of_ life.
(237/88029-02, 249/88030-02)
This is a Severity Level IV violation (Supplement 1).
- 2.
10 CFR 50; Appendix B, Criterion V, as implemented by Commonwealth Edison Company's Quality Assurance Program, as described in Section 5 of Topical Report CE-lA, requires that activities affecting quality be accomplished in accordance with documented instructions, procedures, or drawings.
Contrary to the above, an engineering evaluation was not performed prior to removal of a plug connector during performance of electrical*work on Unit 2 (WR 073948), and prior to the installation of a jumper during performance of instrumentation and control work on Unit 3 (WR 081632) as required by Procedure OAP 7-4, "Control of Temporary System Alterations, 11 Revision 11.
(237/88029-03, 249/88030-03)
This is a Severity Level IV violation (Supplement I).
With respect to Item 1, pursuant to the provisions of 10 CFR 2.201, you are required to submit to his office within thirty days of the date of this Notice.
a written statement or explanation in reply, including for each violation:
(1) the corrective actions that have been taken and the results' achieved; (2) the. corrective actions that will be taken to avoid further violations; and (3) _the date \\'Jhen full compliance will be achieved.
Consideration may be given to extending your response time for good caus~ shown.
With respect to Item 2, the inspection showed actions had been taken to correct the identified violation and to prevent recurrence.
Consequently, no reply to the violation is required and we have no further questions regardjng this matter.
!U))'
n.i::,1 4 Dated 1989 Hub t J. Mi 11 er, Di rector Division of Reactor Safety
EXECUTIVE
SUMMARY
An announced NRC team inspection of maintenance was conducted at the Dresden Nuclear Power Station duringthe period of January 23-27, February 6-10, and 16, 1989.
The inspaction was conducted to evaluate the extent that a maintenance program had been established arid implemented at Dresden and to assure the preservation or restoration of the availability and reliability of plant structures, systems, and components to operate on demand.
Three major areas were assessed including overall plant performance as affected by maintenance, management support of maintenance, and implementation.
To accomplish this task, several maintenance related activities were evaluated to determine if maintenance was accomplished, effective, and self-assessed.
Strengths The in~pection team noted specific strengths in the areas of:
management commitment to improve maintenance through the Maintenance Improvement Program (MIP); strong preventive maintenance program for safety-related valves; aggres-sive resolution of 4.16kV breaker Tuf-L6c bushing problem; use of a probabilistic risk assessment type evaluation of the High Pressure Coolant Injection system; development of a new post maintena~ce testing program; communication between operations and maintenance; traceability of material used; personnel training matrix; calibration of measuring and test equipment before and after critical pl~nt instrumentation calibrations; instrument setpoint trending program; equipment identification; knowledgeable and dedicated personnel in MIP; periodic-corporate assessment of MIP; Motor Operated Valve (MDV) procedures were detailed and incorporated lessons learned; feedback system to work analysts; use of mockup in training; MDV team concept; and low backlog of corrective maintenance items.
Weaknesses The inspection team noted specific weaknesses; however, none had immediate impact on system/component operability. *Weaknesses were identified in the areas of:
failure to adequat~ly evaluate 4.16kV breaker and Unit 3 250 Vdc motor control center failures; lack of plant aging consideration for 4.16kV breakers and auxiliary switches; 4.16kV breaker maintenance performed prior to October 1988 not technically evaluated; slow progress in establishing an equipment trending program; lack of resources to close Program Analysis Data Sheets; work initiated without an adequate engineering review; incomplete histories for completed work requests; high threshold for initiating work requests; inadequate work planning that caused job delays; electrical components not in preventive maintenance program; performance indicators did not measure effectiveness of maintenance; no coordinator for electrical vendor source documents; procurement from unapproved source; and inadequate testing of 480 Vac thermal overloads.
Conclusion Results of this inspection showed overall satisfactory performance in the establishment and implementation of an effective plant maintenance process by the licensee at the Dresden Nuclear Power Station.
Based on the review of past
work activities, observations of ongoing work activities, work ccintrols, and attempts at self-assessment the inspectors determined that overall, electrical, mechanical, and instrument maintenance and support activities were adequately-performed to maintain operability of components at a level commensurate with the components 1 function.
However, some of the activities identified above were in violation of regulatory requirements as noted.
Sections 2.6 through 2.8 of inspection report provides a more complete summary of the maintenance process.
- 1.
- 2.
2.1 2.2 2.3 2.3.l 2.3.2 2.3.3 2.3.4 2.3.5 2.4 2.4.1 2.4.2 2.4.3 2.4.4 2.5 2.6 2.7 2.8
- 3.
4:
'Appendix CONTENTS Cover Sheet..........
Inspection Summary and Re~ults.
1 2
Persons Contacted..............
3 Introduction to the Evaluation and Assessment of Maintenance. 3 Historical Data..................
4 Description of Maintenance Philosophy.......
5 Review and Evaluation of Maintenance Accomplished.
6 Backlog Assessment and Evaluation.......
6 Review and Evaluation of Completed Maintenance 8
Engineering Support..
23 Work Contra l.....
26 Personnel Control...
27 Observation of Current Plant Conditions and Ongoing Work Activities...
Observation of Material Condition...
Observation of Ongoing Work Activities Radiological Controls.........
Maintenance Facilities, Material Control, and Control of 28 28 32 36 Tools and Measuring Equipment.............
38 Licensee 1 s Assessment of Maintenance (Quality Verification).. 41 Overa 11 Pl ant Performance.....
42 Management Support of Maintenance.
43 Maintenance Implementation 45 Unresolved Items 47 Exit Meeting.......
47 A: