ML20126D717

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Responds to NRC Re Violations Noted in Insp Repts 50-295/92-25 & 50-304/92-25.Corrective Actions:Licensee Will Issue an Operating Experience Rept Emphasizing Importance of Acceptance Criteria & to Be Thorough in Evaluating Data
ML20126D717
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 12/18/1992
From: Kovach T
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9212280123
Download: ML20126D717 (4)


Text

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. .~~ 1400 Opus Pleco Downers Grove, Illinois 60515 December 18, 1992 U.S. Nuclear Regulatory Commission Nashington, D. C. 20555 Attn: Document Control Desk

Subject:

Zion Nuclear Power Station Unit I and 2 Response to Inspection Report 50-295(304)/92025 NRC Docket Number 50-295 and 50-304

Reference:

H. J. Hiller letter to Cordell Reed dated November 20, 1992, transmitting Inspection Report 1 50-295(304)/92025.

Enclosed is Commonwealth Edison Company's (CECO) response to the subject violation which was transmitted with the referenced letter.

The violation cencerns the establishment of acceptance criteria, the evaluation of test results and issuance of discrepancy reports when established acceptance criteria is not met.

If there are any questions or comments regarding this response, please contact Sara Reece-Koenig, Compliance Engineer, at 708/515-7250.

Very truly yours,

, f swv f; T. J. Kovach Nuclear Licensing Manager SRK/1k Attachments cc: A. Bert Davis, Regional Administrator - Region III C. Shirakt, Project Manager, NRR

-J. Smith, Senior Resident Inspector, Zion i

l 9212200123 921210 PDR ADOCK 05000295~ -l 0 .PDR- ,l ZNLD/2378/1 l'

AUAQiMENI REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 295/92025; 304/92025 VIOLATION:

10 CFR 50, Appendix B, Criterton XI, requires that a test program be established to assure that all testing required to demonstrate that components will perform satisfactorily is identified and performed in accordance with test procedures which incorporate the requirements and acceptance limits contained in the applicable design drawings. Test results must be documented and evaluated to assure that test requirements have been satisfied.

Contrary to the above, during the performance of the 18 month inspection and maintenance activities conducted March through June 1992 on the emergency diesel generators: (1) the licensee failed to perform an adequate evaluation of generator winding insulation resistance measurements obtained on diesel generators IA and IB that did not meet the acceptance criterta; (2) the acceptance criteria for calibration of the Magsense Card on the "0" EDG was not met and the licensee failed to evaluate the discrepancy; (3) acceptance criteria were not specified for the EDG rotor to stator air gap measurements or the phase to phase winding insulation resistance data recorded by the craft.

This is a Severity Level IV violation (Supplement I).

REA50 M OR lHEMIOLA110ti Commonwealth Edison Company (CECO) acknowledges the violation.

The failure to perform an adequate evaluation of generator winding insulation resistance on the 1A and IB Emergency Diesel Generators (EDGs) and the failure to detect and resolve the Magsense card acceptance criteria discrepancy were due to the fact that both the lead worker and the supervisor were not meticulous in their follow through in the evaluation of test data and the submission of Discrepancy Reports where appropriate.

The lack of acceptance criteria in procedure P/E009-2N for the EDG rotor to stator air gap measurement was due to the fact that acceptance criteria was not provided for in the vendor manual for the EDG The measurements were included in the procedure so that they would be available for review by the cognizant electrical maintenance supervisor and Technical Staff engineer.

A contributing cause to this lack of acceptance criteria in procedure P/E009-2N is that the Zion Administrative Procedure (ZAP 110-01) governing procedure content and format does not address requirements for considering inclusion of acceptance criteria in Electrical Maintenance procedures.

J ZNLD/2378/2 L

ALTACHMENI REPLY TO NOTICE OF VIOLATION .

-NRC INSPECTION REPORT 295/92025; 304/92025 CORREC11VElC110UAKEtLANDlESULISlCRIEVID The insulation resistance readings and calculations performed for the 1A and IB EDG were evaluated and found acceptable by CECO's corporate Systems Operational Analysis Department (SOAD). ,

The Magsense acceptance criteria was reviewed and a new acceptance criteria has been developed by the Zion Diesel Group engineers. Based on their review it has been determined that the as-found/as-left reading of 2.198 Vdc is acceptable. This criteria is located in procedure P/E009_-2N and will be updated during the revision of that procedure currently in progress.

To correct the lack of acceptance criteria for the air gap measurement between the stator and the rotor, the Original Equipment Manufacturer >

(OEM) was contacted and requested to provide an acceptance criteria for the air gap dimension. The OEM has provided acceptance criteria which has been reviewed and approved by SOAD. lne appropriate procedure changes have been initiated.

On October 19, 1992 a meeting was held between the Master Electrician and all Electrical Maintenance supervisors. This meeting reviewed in detati the circumstances leading to the issuance of this violation and the importance of acceptance criteria and the need to ensure proper evaluation of test data and generation of Discrepancy Reports when appropriate. Each supervisor was directed to review this violation with their Bargaining Group Lead Electrician and to reinforce the standards for documenting test results and understanding the importance of acceptance criteria.

COBRECIlVElC11000lLIAKEL10lV01D._EURIREU101&Il0N To ensure that all required acceptance criteria for the EDG inspection procedure P/E009-2N have been identified and are based on current vendor recommendations, IEEE Standards, and SOAD requirements, the procedure was sent to SOAD for a technical review. This review has been completed and procedure P/E009-2N is currently undergoing revision.

Zion Administrative Procedure (ZAP) 110-01 " Procedure Content and format" will be changed to ensure that the inclusion of necessary acceptance criteria is considered whenever Electrical Maintenance department procedures are rewritten or new Electrical Maintenance department procedures are developed.-

Zion Station will issue an Operating Experience Report on this violation and corrective actions. The report will emphasize the importance of acceptance criteria and the-need to be thorough in evaluation of test data. The requirements for issuance of Discrepancy Reports will also be addressed. This report will be reviewed with the Zion Technical Staff and-all Zion Maintenance departments. This report will be issued for review by February 15, 1993.

INLD/2378/3:

. a. --, .. .. - . . .

l AITACitMENI REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 295/92025; 304/92025 DATL Hii E fL f U L L 30ME L IANC LHILL. BLAClil EVER The revision of procedure P/E009-2N will be completed by February 28, 1993.

The change to ZAP 110-01 will be completed by February 28, 1993.

Zion Station will be in full compliance by February 28, 1993.

INLD/2378/4

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