ML19325C975
| ML19325C975 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/29/1989 |
| From: | Trzyna G COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0306T, 306T, NUDOCS 8910180246 | |
| Download: ML19325C975 (8) | |
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}' Commonwealth Edison NO 1
,(;i 72 West Adams Street, Chicrgo, Illmois f(.} J '[ _ '
i Address R ply to: Post OlhcTB6T76E v
Chicago,1;linois 60690 0767 y
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September 29,'1989:
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~Mr. A.:Bert~ Davis-Regiona1'Administratorc
-U.S. Nuclear Regulatory. Commission-l Region III-
-799 Roosevelt 1 Road W
' Glen Ellyn.IL---60137 i
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Subject:
Zion Nuclear Power Station, Units l'& 2 1
. License Nos..DPR-39.and DPR-48
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Response.to Inspection Report Nos.
50-295/89013 & 50-304/89013 NRC Docket Nos'. 50-295 and 50-304
Reference:
May 30 1989 letter from EG Greenman to Cordell Reed-
Dear.Mr. Davis:
The letter referenced above concerns a routine safety inspection-conducted by Mr. M. Holzmer and others of your staff during the period of
' March 18 through May 8, 1989, of. activities at Zion Nuclear Power Station. -No violations lof NRC requirements were identified during the course.of this
.Insp?ction.
However, a request was made to provide both long and short term corrective actions to the weaknesses identified in the " Maintenance" section ofJthe report. The: Attachment to this'1etter provides the information that-you. requested..
Please. direct any questions that 99 have-regarding this matter m
to this office.
T V,"
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G.E. Trzyna Nuclear Licensing Administrator G4\\
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Chandu Patel-NRR Senior Resident Inspector-Zion 8910180246 890929 PDR ADOCK 0500o295 i
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This is the Station's response to the "significant' weaknes'.i" identified in the
~Mainte, nance area during the subject inspection'.
The' response will-initially address the; global issues of work package 1mprovement and. aggressive preventative maintenance.
Each issue will be outilned with respect to the Station's action plans for improvement.
The response will continue by addressing'the specific issues identified in the
. subject report.
210tLita.Llon'.s.Re_spoastio the Global..Issuti 3
Zion Station has identified-the following weaknesses in work packages:
Package Consistency L*
Required DetallLof Hork Instructions Required Detail of Documentation-of Hork Completed Coordination of Hork between Departments Identification of Root-Cause L
Identification of Rework Up-Front Problem Identification i.e. Work Requested, Procedure Adequacy These' weaknesses are being addressed via the corporate Conduct Of Maintenance L
(COM)' document.
This is recognized to be a leng-term comprehensive program to-bring Zion's Maintenance program to the standards of Excellence. With this consideration,-interim actions are in place and under development to assure 1
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progress 1s being made in the proper direction.
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Zion's " Performance Improvement Plan" (PIP) is the mechanism being used to track the progress of the action plans in place and being developed to support L
-the'COM_1mplementation.
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. Internal evaluation of the effect of action plans on the performance of the
. maintenance activitief !:: Or._ ongoing process. Additionally, corporate conducts self-assessments to verify the stations progress on the implementation of the COM.
The next,self-assessment will be conducted November 1989.
Integrated throughout the COM is the concept of the work package preparer's involvement in the execution and documentation of the work in addition to preparation of the work package.
This is the key to the success of the program. _ Corporate reorganization of the maintenance departments (Introspect) has increased the number of work analysts (work package preparers).
The ratio g'
of one work analyst to one foreman has been established.
Based on this ratio, 4
Zion has been authorized ten additional work analysts.
Six of these positions
-have bee'n filled and the remaining are in the process of being filled.
Interviews of personnel are currently being conducted.
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N l-The-need for?thefone to one ratto is based on the responsibilities and actions detailed in the COM and summarized-below:
1The. work analyst via the. analysis of maintenance section of the COM
-assembles the work package while considering the following:
~ Nature of Problem Description of'as-found conditions witu suspected cause p
Review of history for rework concerns In addition, the work analyst specifies the Post-Maintenance testing c
required.
The foreman on the job inputs on:
Corrective action adequacy Concurrence of suspected cause or need for additional investigation l
(RootLCause Determination)
Corrective Action to prevent recurrence as well as supervising the L
. job performance i
To close the loop the work analyst and maintenance foreman reviews the
. completed work package as a joint responsibility for appropriate and complete information to be entered into the Hork History data program.
The action plans that follow are being used to implement the programs that s
have been highlighted above:
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- The addition of Hork Analysts (previously addressed) l Hork Analysts Pre-Job Checklists and Guidelines have been issued to add l
consistency to the work packages.
(Maintenance Memo #32 addresses this-
-item).
i Standard chronology log of work performed is in. place in a draft format.
l l-The formal imple:nentation of this item will be complete February 1990.
Additionally, two working committees have been formed, a Hork Packages
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l-Committee and a Work Practices Committee, whose f.harter through the l
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. Corporate Conduct of Maintenance is to formulate additional corrective l
-actions for problems related to their specific assigned areas.
These committees are described in the Zion PIP and includes long term and interim actions, along with appropriate management monitoring and i
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evaluation of the actions, j
i Since the status of these issues is continually changing, specific status for j
each issue is addressed in the Zion PIP manual.
i The Maintenance Department has defined the scope of the Preventative Maintenance (PM) program and proceduralized it with ZAP 13-52-6, " Preventative Maintenance Program".
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- Areas _ in;the_ action. plan for improvement include:
Thermography program-
- Lube 011' Analysis program
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. Reliability-centered Maintenance System Analysis program
- Harehouse PM program Equipment Performance Monitoring program Training of station personnel with respect to P.M. programs.
These programs are all in progress at this time, llon_S.tition's Reiponse to the Specif.lc Issne.1 The above stated discussions demonstrate that the programmatic weaknesses in the Maintenance area are being addressed in the long and short term.
The following information addresses the specific items that were highlighted in
-the_ Inspection Report that. lead to the overall Maintenance area concern.
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CQEERN The 2 MOV CS0008 motor operator spring pack was replaced twice, once with and-once without using a station traveller.
(Note: A station traveller is a document that'provides work instructions).
In the case without the traveller, a mechanical maintenance (MM) person recorded the spring pack replacement using his initials in Electrical Maintenance (EM) procedure E022 in a portion-of the procedure that was-designated to be "omitted" i
before the job was begun. MM procedure P/M016-2N, " Disassembly, Inspection-and Reassembly of Environmentally Qualified Limitorque j
' Operators, SMB-00 and SMB-000" which is to be used for spring pack change out was not' referenced or used in either case.
~ RESPONSE-Hork analysts Pre-Job Checklists and Guidelines address this concern.
' CONCERN i
P/M016-2N and P/M016-6N." Removal / Installation of Limitorque Operators Size SMB-000" have both had procedure change requests outstanding since November 25, 1987.and August 31, 1988, respectively.
P/M016-2N has not yet been placed on the-. HANG work. processor.
RESPONSE
These specific procedure changes have been completed.
However, the j
enhancement of MOV procedures is on-going.
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,.CONCERM
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- P/M016-6N does not' adequately address snugness of the lock __ nut on the end.
'of.the spring pack.
.RESECESE; The snugness of the lock nut has been addressed in all applicable MOV i
. procedures. As found and As left information is required.
COEERN i
-After;the spring pack was changed out on~ March-17,. ems attempting to continue MOV' troubleshooting experience problems not encountered on March 15.- Causes for a MOV-declutch lever deficiency and motor operator handwheel spinning off the stem are unknown.
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RESPONSE
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~ The'Hork' Analyst and Maintenance Foreman relationship and responsibilities as
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previously discussed addresses this concern.
.1 CONCERN 1
3 Hork performed under direction of the March 28 traveller was documented on.
.the HR as specified in-traveller. Specifically, Step 4' called for investigation-of the:cause of the valve binding-and required that the mechanic?" document work performed on work request." The work was recorded
.by the valve vendor who accompanied the mechanic on the-job and noted the h
-work performed on his. work: document.
The vendor's one'page record was cincluded in the work-package; however, vendor. representative assistance records are not_ required to be captured in work packages.
~RESE0 HSE 1
.. The Work' Analyst a'id Maintenance Foreman joint responsibility to review the h
completed package and.' determine appropriate Hork History along with a standard L
chronology log of work performed addresses this concern.
COEERN j
Environmentally _ qualified power cables for Limitorque.SMB-000 MOVs can be s damaged during routine maintenance and inspections when the limit switch cover is replaced.dur to the small clearances involved.
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BESPONSE
'A caution statement in procedure E022-1 has been included to address pinched wires _in the housing, t
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'Hork performed on alleviating interference between piping and MOV declutch lever was not documented.
RESPONSE
- The Work Analyst and Maintenance foreman joint responsibility to review the completed package and determine appropriate Work History along with a standard chronology log of work performed addresses this concern.
CDECERti The " work performed" section of HR-Z 81308 did not record the cause of the failure.
2 SS9351A failed due to a broken packing gland stud, and not a j-
. body to bonnet leak. The person who wrote the HR was unable to accurately R
identify the source of the leak due to poor access and large quantitles of l
steam blowing from the valve. The cause of the failure was recorded in the package, but the " work performed" section of the HR is used for screening purposes in pre-job planning.
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RESPONSE
As previously discussed in the one to one Hork Analyst to Foreman ratio section of this response, these type of items will be covered, i.e.
Nature of Problem As found Conditions-Hork History-Review-
. Post Maintenance lesting Corrective Action Adequacy CONCERN 2 SS9351A had body to bonnet leaks repaired in July 1987 and December 1988, but the valve had not been submitted for entry into the licensee's preventive maintenance (PM) program.
The licensee's automated " rework" function would not identify this valve as a reliability outiler unless two or more' work requests are submitted for a component in a 12-month period or less.
RESPONSE
The Problem Analysis Data Sheet (PADS) as described in Section 16 of the COM-addresses this type of rework and would allow for PM consideration.
Action Plans for PADS are defined in the PIP.
Full implementation is scheduled for January 1990.
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CQHCERN The broken stud on valve 2 SS9351A was not retained for failure analystr.
. RESE0EE The Work Analyst and Maintenance Foreman joint responsibility to review the completed package and determine appropriate Work History along with a standard chronology log of work performed addresses this concern.
C0EEBH Preventive maintenance for sample system valves needs increased attention.- The only PM activities for these two valves are for the ASCO solenoid-for the valve air operator and the position indication switches.
The technical staff system engineer had not submitted any sample system valves for entry into the PH program during the 1 and I/2 years that he had been the system engineer.
RESEQHSE Improvements In the PM program previously discussed in this response address mechanisms to include and identify areas for increased attention.
The PM Action Plans are included in.the PIP.
00HCERN No documentation other than a signature in the " test complete" section of the HR was found for the operating department's post maintenance stroke test of 2 SS9351A.
This stroke test was required prior to returning the valve to service. A stroke test was performed and documented by the maintenance crew as directed by Step 7 of the maintenance traveller.
RESPONSE
The Test Complete signature on the Work Request documents the identified testing has been satisfactorily completed.
CONCEBN The following items identified in your findings are all related to the systematic maintenance problems.
Documentation of the repair for 2 SS9356A packing leak repair was inconsistent and confusing.
The " workman's job notes" on the HR stated that there.was no packing leak on the valve, but that a body to bonnet leak existed.
The mechanic for the job recorded only that packing rings were added in the " work performed" section of the HR.
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No " workman's job notes" were recorded for the repair of 2 SS9351A, although the " work performed" section was completed.-
Pre-job planning for-the repair of 2 SS9356A did not include inspection of the valve while the. leak was' active (the leak only existed while the valve-was stroked open).
The work analyst for the job looked at the valve while l
It was closed, and stated that a packing leak existed and that a body to bonnet leak might have existed, but that it was difficult to tell because of the:large amounts of boron encrusted around the valve stem and bonnet.
1 No persons interviewed observed the valve leak before it.was isolated for
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repair.
L Repair of 2 MOV CS0008 took from March 15 through April 14, 1989.
The valve was officially returned.to service on AprlI~- 19, 1989, the length of.
time required.'to repair the valve was due in part to work package 1
_ turnovers between shop foremen and between the Mm and EH departments.
Another contributor appears to be the inconsistency in documentation of work performed from crew to crew, RESE01SI
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l The previous responses detailing our Action Plans are designed to address these systematic issues.
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