ML20034F104
| ML20034F104 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/25/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-10, NUDOCS 9303020284 | |
| Download: ML20034F104 (4) | |
Text
Commonwraith Edison r
r 1400 Opus Place
,V 6
Downers Grove, Illinois 60515 s
February 25,1993 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn: Document Control Desk
Subject:
Zion Nuclear Power Statiail 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 L. DelGeorge 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.
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.
t I.
Very truly yours, i
i W
D. Farrar t
Nuclear Regulatory Services Manager l
L Attachments cc:
A. Bert Davis, Regional Administrator - Region ill Clyde Shiraki, Project Manager, NRR J. D. Smith, Senior Resident inspector, Zion I
r 9303020284 930225 DR ADDCK 0500 5
NO ZNLD/2516/1
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ATTACHMENT i
REPLY TO NOTICE OF VIOLATION i
NRC INSPECTION REPORT i
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295/92034;304/92034 l
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VIOLATION:
f 10 CFR 50, Appendix B, Criterion XI, requires, in part, that a test program be established to ensure that all testing required to demonstrate that components will perform satisfactorily in service is performed in accordance with written test i
procedures which incorporate the requirements and acceptance limits contained in j
the applicable design documents, and thnt test results shall be documented and j
evaluated to assure that test requirements have been satisfied.
Contrary to the above, as of January 4,1993, the licensee had not evaluated the results of the 17 dp tests that were completed during the Spring 1992 outage to demonstrate that the MOVs would perform their safety function (50-295/92030-02 (DRS); 50-304/92030-02 (DRS)).
This is a Severity Level IV violation (Supplement 1).
REASONIOR_THE_VJOLAIlON l
i Commonwealth Edison Company (CECO) acknowledges the violation.
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'l 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 Corporate Engineering personnel as to the responsibilities for accom 3lishing the l
requirements of White Paper 108. This was the first time that White 3 aper 108 i
was to be utilized at Zion Station.
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 j
criteria is currently the only approved criteria for CECO under the Generic Letter 89-10 Program and is consistent with previous Station policy for MOV testing.
As of this date, CECO is unaware of any indestry-wide accepted methodology for 1
extrapolation of dp test data for MOVs tested at less than 100% design basis dp for the purpose of determining the capability of a MOV to perform its safety
[
function under design basis conditions. VOTES equipment was utilized during the Spring 1992 Unit 1 Outage to gather data that would ultimately allow validation of a methodology for the purpose of performing such a determination.
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ZNLD/2516/2
ATTACHMENT l
REPLY TO 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 toolin 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.
j COBBEGIIVEACIlONSTAKEN AND_BESULISACHIEVED 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 MDV Program.
COBREGIIVEACIlONSIO_BEJAKENIQAVOID FUBIHEB3aQlAILONS l
CECO and Zion Station are currently reviewing the resu!ts of the 17 MOV dp tests using the technical guidance of White Paper 108. These reviews will be completed by April 5,1993.
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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i ZNLD/2516/3
ATTACHMENT l
REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 295/92034;304/92034 (continued) 1 CORRECJ1VE ACTIOESIOEEIAKENIO AVQlDIRBTtiER_VIDIATIRNS(continued)
CECO will continue to pursue implementation of the requirements of Generic Letter 89-10. As data gathering techniques are validated and the data collected is fully analyzed, acceptance enteria will be developed and incorporated into CECO corporate and station procedures as necessary. In the interim, acceptance criteria currently provided in station procedures and Technical Specifications will continue to be utilized for operability determinations.
DATE WHEN_FULLf,O_MPlJANCE_WILL BEACHIEVED 1
Zion Station will be in full compliance by April 5,1993.
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