ML20005F512
| ML20005F512 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 10/02/1989 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9001160348 | |
| Download: ML20005F512 (10) | |
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- Commonwealth Edison
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72 West Adams Street, Chicago, Illinois =
- g y y-l Address Reply to
- Post Ctfice Box 7B7~.
. Chicago. Illinois 60690 0767.
- 'g October 2, 1989 Mr~.
A'. Bert Davis
-Regional Administrator-
,0.S. Nuclear Regulatory Commission
~ Region III.
799 Roosevelt Road
- Glen Ellyn, IL = 60137
Subject:
- Zion' Nuclear Power Station Units 1 and=2
. Response to Notice of Violations ~as Issued in IR Nos.- 50-295/89018 and 50404/89017
-Licen!e Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304 References (a):. September 1,1989 letter from H.J. Miller to Cordell Reed.
(b): September 29, 1989 telephone conversation between J. Hinds and G.E. Trzyna.
Dear Mr. Davis:
.The above referenced letter transmitted the results of a special.
maintenance team inspection conducted by Mr. Z. Falevits and others of your l
office on various dates during the June and July, 1989, of activities at Zion Nuclear Power Station. During the course of this inspection, it was: determined lthat certain activities appeared to be.in violation of NRC requirements.
In-1 addition, the cover letter which accompanied the Inspection Report addressed a i
specific concern about the failure of the mechanical overspeed mechanism of the turbine driven Auxiliary Feedwater pump to perform its-intended function.
I Our response to'this concern is contained in our response to Violation 2.d.
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Our response to the Violations are contained in the Attachment to i
this letter, except for the response to Violation 2.b.
This violation is related to the untimely corrective action that was taken to correct the failures of the DC battery to bus circuitry interface.
This problem has been long-standing in nature and Commonwealth Edison has procured new DC breakers which were intended to address the problem. Unfortunately, however, these y
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A.B. Davis October 2, 1989 breakers were procured from the Satin America Corporation and are included in the suspect population of potentially counterfeit breakers.
Therefore, Commonwealth Edison must reevaluate the corrective action that will be taken-to address the concern with the DC breaker.
This complication was discussed 1
in Reference (b) and an extension of. thirty (30) days was granted to develop an action plan with the appropriate corrective action.
Please direct any questions that you may have regarding this matter to this office.
Very truly yours, T. J.
vach Nuclear Licensing Manager im cc:
C. Patel - Project Manager, NRR Senior Resident Inspector - Zion 0307T:2 i
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-VIOLATION:
10 CFR 50, Appendix B, Criterion V, as described in Section 5, of Topical Report CE-1A, Revision 55, and as implemented by Quality Assurance
. Manual, Section 5, requires that activities affecting quality be prescribed by documented instructions, procedures and drawings, and that thoso activities be accomplished in accordance with those instructions, procedures and drawings.
Contrary'to the above:
- a... Surveillance Procedure PT-30, Paragraph 5.2, required that the t
electrolyte levels.in station batteries be verified to be between 1/4 inch below the full line and the low level line.
- However, L
electrolyte. levels for battery No. 212 were verified to be between the full-line and the low level line, which resulted in acceptance of the levels even though the procedural requirements wete not met (295/69018-02A; 304/89017-02A).
b.
The wrong-procedure was used during repair of the Limitorque operator for Valve 2M5006 (295/89018-02B; 304/89017-028).
c.
Procedure E022.-1, " Inspection and Maintenance of Limitorque Valve Motor Operators", Revision 1, did not provide adequate instructions to prevent miswiring of the torque-switch associated with Valve 1
2MS006 (2S5/89018-02C; 304/89017-02C).
L d.
Maintenance personnel failed to document the lifting and landing of l
1eads as required by ZAP 3-5-1, " Temporary-Alteration Program",
Revision 26, during corrective maintenance performed on the IB l
Emergency Diesel Generator-(295/89018-02D; 304/89017-02D).
This is a Severity Level IV Violation (Supplement 1).
RESEQRSE TO VIOLATION 1.a CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The immediate corrective action taken was to determine the operability of the batteries with high electrolyte levels in the cells.
Technical Staff engineers verified the batteries to be operable.
A clarification of the intent of battery level check was made to PT-30
" Station Battery Record - Fe.ithly Quarterly Equalizing Charge".
The note also requires notification of the Tech. Staff engineer if overfill occurs while adjusting cell electrolyte level.
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This event was: reviewed with the individuals involved,- describing the
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responsibility for understanding each procedural step with emphasis on the importance.of folloeing procedures.
CORRECTIVE' ACTIONS TO BE TAKEh TO PREVENT FURTHER VIOLATIONS Maintenance has formed a hark Practices Committee, whose charter
,through the Corporate Conduct of Maintenance Directive is to formulate corrective actions for problems related to work performance.
This c'ommittee is described in the Zion PIP'(Performance Improvement Plan) and includes specific long term action plans and shorter term interim
- actions.
Notice of this violation has been included to the references used by the Work Practices Committee for long term corrective actions intended to prevent violations for " Failure to follow Procedures".
In addition, Maintenance has formalized tours conducted by both Senior and Department management to provide oversight on ongoing work
' practices.
l DATE HHEN FULL COMPLIANCE HILL BE ACHIEVED The Nort Fractices Committee is scheduled to complete their charter
-by the end of the'first quarter of 1990.
(Commitment defined formally within Zion PIP Manual) f RESPONSE TO VIOLATION 1.b i
L COR3ECTIVE ACTION TAKEN AND RESULTS ACHIEVED L
The two procedures referenced in this event are P/H016-5N and P/M016-6N. A side by side comparison of both procedures was performed to determine whether the " incorrect" procedure had steps which would if perfornied, result in the operability of the valve being questioned. This g
review determined that the procedures are essentially the same and although the~" Incorrect" procedure was attached to the work package, no i
operability concerns resulted.
CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIQHS Halntenance has formed a Hork Packages Comniittee, whose charter through the Corporate Conduct of Haintenance Directive is to formulate corrective L
actions for problem involving work packages. This committee is described l
In the Zion PIP n o includes specific long term action plans and shorter term interim actions.
Notice of this violation has been included to the
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references used by the Hork Packages Committee for long term corrective l-actions intended to prevent violations for " Failure to Develop Adequate Work Packages".
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In addition, Maintenance will perform a review of both procedures n
P/M016-5N and P/M016-6N to determine if, in fact, separate procedures are-t warranted. -This review will be completed by November 30, 1989, i
DATE HHEN FULL' COMPLIANCE HILL BE ACHIEVED The Work Packages Committee is scheduled to complete their charter by the end of the first quarter of 1990.
(Commitment defined formally with Zion PIP Manual)
The review of Procedures P/M016-5N and-P/M016-6N will be completed by-November 30, 1989.
(Commitment # 295-100-89-018N0V1)
I RESPONSE TO VIOLATION 1.c CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED P.MS0006 was, repaired on July 13, 1989 under Work Request Z-83483.
The valve was then: tested and declared operable.
Training has been conducted with all personnel in the Electrical Maintenance Department. 'The training included a demonstration of how to
. determine proper contact-points using actual-torque switches.
CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS-l Procedure E02201, " Inspection and Maintenance of Limitorque Valve Motor' Operators"_ has included an Attachment F.
Attachment F is a reference diagram which allows differentiation between old and new style torque switches.
The Attachment F will be i W sed to illustrate proper contact placement.
To' prevent miswiring of contacts, steps for d'. connecting and reinstalling torque switches will require the wires be labelled per the connect / disconnect data sheet.
-DATE HHEN FULL COMPLIANCE HILL BE ACHIEVED The revision to E022-1 will be completed and in use after this refueling outage and no later than January 19, 1990.
(Commitment #
295-100-89-018 NOV2) 0307T:5 s
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i RESPONSE TO VIOLATION 1.d~
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The Instrument and Control Department has developed a troubleshooting procedure (IMTS-1 " Electronic Loop Troubleshooting / Repair for Safety Related Loops") which requires that. lifted and landed leads be documented.
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The LInstrument and Control Department will be required to use this procedure whenever troubleshooting efforts involve the lifting and landing of' leads.-
CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIQHS Maintenance has formed a Hork Practices Commitive, whose charter through the Corporate Conduct of Maintenance directive is to formulate L
corrective actions for problems related to work performance.'
This committee is described in the Zion PIP and includes specific long term action-plans and shorter term interim actions.
Notice of this violation has been' included in the references used by the Work Practices Committee' for long termLcorrective actions intended to prevent violations for "Fallure to follow Procedures".
DATE HHEN FULL COMPLIANCE WILL BE ACHIEVEQ The Work Practi:es Committea is scheduled to complete their charter by the end of the 'frst quarter of 1990.
(Commitment defined formally within Zion PIP Manual) 0307T:6 r.
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a 10 CFR 50, Appendix XVI, as described in Topical Report CE-1A, Revision 55, and as implemented by Quality Assurance Manual, Section 16, 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 abovt, the licensee failed to:
a.
Take timely and effective corrective action to ensure that adequate work instructions were provided in work requests.
This had been identified as a violation during a 1986 NRC inspection and remained uncorrected (295/89018-01A; 304/89017-01A).
b.
Provide timely corrective action to correct dc battery to bus circuit breaker failures. A history of problems in reliably closing the breakers on the first attempt was initia'ly identified on work requests dated October 10, 1987.
However, since all breakers had successfully closed on the second attempt, the work requests were-never completed, even after vendor representatives indicated the problem appeared to be worn bearings (295/89018-01B; 304/89017-018).
O c.
Provide timely or adequate corrective action on known problems in post-maintenance testing, temporary modifications, and wolk control.
These recurring problems were identified in September 1987, and again in February 1989, during self-assessment (295/89018-01C; 304/89017-01C).
d.
Take adequate and timely corrective action to maintain and test 2A Auxiliary Feedwater pump turbine overspeed mechanism for approximately 17 years, or successfully test the 1A Auxiliary Feedwater pump turbine overspeed mechanism in 1987.
The vendor recommended testing once a week.
The necessity of the tests was previously made known to the licensee by General Electric Company in July 1986, by the NRC in Information Notice 88-67, by the licensee's own Safety System functional Inspection in September 1988, and by an
-INP0 assessment team in February 1989.
Subsequent to the Maintenance Team Inspection and NRC's inquiry, the licensee conducted a static test of the linkage and valve mechanism on July 22, 1989, for the 1A Auxiliary Feedwater pump turbine with unsuccessful results. Maintenance had to be performed on the overspeed trip mechanism before a successful test was obtained. The inspectors were informed that the tests for the 2A Auxiliary Feedwater pump turbine were successfully completed on July 23, 1989 (295/89018-OlD; 304/89017-010).
Thi', is a Severity Level IV Violation (Supplement 1).
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RESPONSE TO VIOLATION 2.a CDERECTIVE ACTIDN *iAKEN'AND RESULTS ACHIEVEQ Commonwealth Edison formally issued a. Corporate Conduct of-Maintenance (CCOM) directive early in 1989.
Each of the six Nuclear
-Stations-has been tasked with development of pilot implementation programs for portions of that directive.
Zion Station's portion of the CCOM includes upgrades in work package preparation.
The pilot program covers improved = work package-format, Post Maintenance Testing (PMT) requirements,.
and work instructions.
To adequately implement the CCOM, Zion has identified the need for
-additional Hork Analysts. -Ten.a,ditional positions were authorized and to date six have been filled.
It is-the belief of Zion Station that the additional manpower will allow a more thorough review of the work packages.
In addition, a-draft work package checklist has been created and i.s undergoing a trial implementation.
The final version of the checklist will be implemented for all work packages by December 31, 1989.
CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS Maintenance has formed a Hork Packages Committee, whose charter through the Corporate Conduct of Maintenance Directive is to formulate corrective action for problems related to wu k packages.
This committee is described in the Zion PIP and includes specific long term action plans and shorter term interim actions.
Notice of this violation has been included in the references used by the Work Packages Committee for long term corrective action intended to prevent violations for "Faiiure to Develop Adequate Work Instructions".
DATE WHEN FULL COMPLIANCE HILL DE ACHIEVED The Hork Packages Committee is scheduled to complete their charter by the end of the first quarter of 1990.
(Commitment defined formally within Zion PIP Manual)
Final version of the work package checklist will be fully implemented by December 31, 1989.
(Commitment 295-100-89-018N0V3)
RESPONSE TO VIOLATION 2.b The response to this Violation will be provided within thirty (30) days as granted during a September 29, 1989 telephone conversation between J.A.
Hinds and G.E. Trzyna.
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-r RESE0![SE TO VIOLATION 2.c CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Each finding from the Production Services Maintenance Self Assessment report has been entered into the Nuclear Tracking System (NTS) commitment data bank in order to track to completion resolution of these findings.
. Action plans are currently-in place or are being written to drive the implementation of the Conduct of Maintenance directive at Zion.
(At the end of 1989', 3 chapters of the Conduct of Maintenance are expectcd to be
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fully imolemented).
CORRECTIVE ACTIONS T0 BE TAKEN TO PREVENT FURTHER VIOLATIONS.
-The action plans in place or being developed will have, as an integral part, interim measures to address findings from these assessments.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The Conduct of Maintenance Directive is planned to be fully implemented at Zion by the end of 1991, contingent on corporate analysis.
RESPONSE TO VIOLATION 2.d CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED
' Changes to PT-7, " Auxillary Feedwater System Checks and Tests", have-been incorporated to test the overspeed trip mechanism in manual fashion.
This PT is run monthly and both AFH turbines have been tested under this procedure since the change went into effect in July of 1989.
Both the Unit 1-'and Unit 2 AFH turbine overspeed mechanism trip tests, performed as part of PT-7, have been successful.
CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS In addition, TSGP-50, " Auxiliary Feedwater Turbine Overspeed Test",
has been revised and is going through on ',ite review.
This test is a physical overspeed of the AFH turbine and will be performed with the pump uncoupled from the turbine.
The original test identified some control problems that needed to be addressed to allow a more controlled speed increase. Once approved, it is anticipated that the Unit 1 AFH turbine will be tested before the end of the year (1989) and Unit 2 price to or i
during the March 1990 unit outage.
Both procedure changes have vendor concurrence as to adequacy, given the frequency of operation of the pumps.
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r The' trip linkages are currently inspected and lubricated on an every other refueling outage frequency.
This inspection and lubrication frequency will be changed to once per operating cycle, In addition, Zion.
es is investigating the best methodology to provide lubrichtion to the trip linkage monthly;.the frequency.at which these pumps operate. Therefore, with the added testing and greater frequency of lubrication, a higher level of confidence as to operability will result.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVEQ The revision to TSGP-50 will be completed by November 30, 1989.
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~(' Commitment #. 295-100-89-018NOV4) The physical overspeed test on the Unit 1 AFH turbine will be conducted on or before 31DEC89 (Commitment
- 295-100-89-018NOV5).
The physical overspeed test on.the Unit 2 AFH turbine'will be-conducted before 31HAR90.
(Commitment-#
295-100-89-018NOV6) The investigation to determine the best methodology to provide lubrication to the telp linkages will be completed by November 30, 1989.. (Commitment # 295-100-89-018NOV7) l l
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