ML20059A265
| ML20059A265 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/14/1990 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20059A257 | List: |
| References | |
| IEIN-86-073, IEIN-86-73, IEIN-89-007, IEIN-89-7, NUDOCS 9008220182 | |
| Download: ML20059A265 (2) | |
Text
.
.o NOTICE OF VIOLATION l
Commonwealth Edison Company Docket No. 50-295 Docket No. 50-304 As.a result of the inspection conducted on November 27 through December 8, 1989, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enfcrcement Actions (1989), the following violation was identified:
1.
10 CFR Part 50, Appendix B, Criterion XVI, requires that measures shall be established to assure that conditions adverse to quality, such as failures, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken to preclude repetition shall be documented and reported to appropriate levels of management.
Contrary to the above, established measures failed to assure that the cause of a significant condition adverse to quality, fretting of emergency diesel generator (EDG) small diameter tubing due to vibration, was promptly identified and corrective action taken to preclude repetition.
Specifically:
A.
The licensee had experienced fretting as a problem for the Cooper-Bessemer KSV 16-T emergency diesel generators (EDGs) as early as 1975. On January 19, 1985, a steel fuel oil line on the 1A EDG failed due to rubbing and rendered the EDG inoperable. The fuel line was replaced, but the root cause of the failure was not corrected to preclude repetition, l
B.
On February 15, 1985, the 0 EDG was shutdown during testing due to i
a lube oil leak caused by vibration induced fatigue. The leak was repaired, but the root cause of the failure was not~ corrected to a
preclude repetition.
l C.
On August 20, 1986, the licensee was sent NRC Information Notice' 8 73, "Recent EDG Problems," which described how extensive wear and fuel leaks had occurred on a KSV-16-T EDG at Nine Mile Point due to vibration. The licensee evaluation stated that it was not applicable to Zion, though the EDGs at Zion are model KSV-16-T.
Consequently, corrective actions were not implemented.
D.
In January 1989, an oil supply jumper line failed on the 2A EDG, This jumper line was replaced, but the root cause of the failure was not corrected to preclude repetition.
E.
On January 25, 1989,- the licensee was sent NRC Information Notice 89-07, " Failures of Small-Diameter Tubing in Control Air, Fuel Oil, and Lube Oil Systems Which Render.EDGs Ino>erable." 1his Information Notice discussed how breaks or crac4ing of small diameter tubing due to vibration could render EDGs inoperable, and noted that the replacement of copper with stainless steel had not been effective in solving the problem at Cooper.
The IN concluded that the cause of the problem was due to inadequate design or 9008220ie2 900814 PDR ADOCK 05000295 s
0 PDC
+
)
c,-
4 1
l Installation of supports. The licensee's evaluation of this IN stated that the problem was not applicable to Zion because they had replaced the tubing with stainless steel, even though the IN indicated that this corrective action had not been effective in preventing leaks due to vibration-induced fretting.
F.
In June 1989 the NRC resident inspectors identified to the licensee that they had observed evidence of small tube rubbing caused by engine vibration.
This was documented in I,ispaction Report No. 50 295/89015; 50-304/89015 as open item 03. No action was taken to promptly identify the extent of damage to the EDGs or to take corrective action.
The licensee's failures to implement corrective actions resulted in the identification during this inspection. that &1l five Cooper-Bessemer KSV-16 T emergency diesel generators had fretting of small-diameter fuel and lubricant tubing due to their being located in close proximity with other piping and structural portions of the EDG.
The extent of the fretting inicuded a severed oil jumper line and many examples of oil leaks.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending the rasponse time for good cause
- shown, t
9 I4 96
( 0 k h 40f
~
Dated' Hubert
'J.' Miller, Director Division of Reactor Safety i
t i
, - - - -