ML20126F903
| ML20126F903 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/28/1992 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 9212310193 | |
| Download: ML20126F903 (2) | |
See also: IR 05000295/1992025
Text
_ - _ - _ -
_
_
.
r
'
DEC 2 81992
Do'cket No. 50-295
,
Docket No. 50-304
Commonwealth Edison Company
ATTN:
Mr. Cordell Reed
Senior Vice President
Licensing Department-Suite 300
Opus West III
1400 Opus Place
Downers Grove, IL
60515
Dear Mr. Reed:
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORTS NO.
50-295/92025(DRS); 50-304/92025(DRS))
This will acknowledge receipt of your letter dated
December 18, 1992, in response to our letter dated November 20,
1992, transmitting a Notice of Violation associated with
Inspection Reports No. 50-295/92025(DRS) and No.
50-304/92025(DRS).
Thece reports summarized the results of the
assessment and evaluation of the emergency diesel generator and
electrical systems at your Zion Nuclear Power Station.
We have
reviewed your corrective actions and have no further questions at
this time.
These corrective actions will be examined during
future inspections.
Sincerely,
pr(rnai E H y! W " M '. Zns
.#t
H. .J.
Miller, Director
I
Division of Reacter Safety
See Attached Distribution
4ED
Lfgf;,
95
6
RIII
RIII
RII;bH
"YML
'gfaq
~~yftGCfO
RII4
RIII
RIII
[
gV
4
1
Falevits/jk
Farber
Gardner
Ring
Martin
Miller
12/28/92
12/p /92
12/21 /92
12/26/92
12/24/92
12 /Z4 / 92
3a
310' i
(
9212310193 921228
/i
'
D
ADOCK 05000295
/S i
G
M
_
_ _ _ _ _ _ _ _ _ - -
__
=
<
,
.
1
Commonwealth Edison Company
2
DEC 2 81932
.
Distribution
cc:
M.
J.JWallace, Chief, Nuclear
Operating Officer
T.
Kovach, Nuclear Licensing
Manager
R. Tuetken, Site Vice
President
S.
Kaplan, Regulatory
Assurance Supervisor
T. Joyce, Station Manager
cc W/ltr dtd 12/18/92:
DCD/DCB (RIDS)
OC/LFDCB
Resident Inspectors-Byron,
Braidwood, Zion
R.
DeFayette, RIII
D.
Funk, RIII
Richard Hubbard
Mayor. City of Zion
J. W.
McCaffrey, Chief
Public Utilities Division
.
C.
Shiraki, LPM, NRR
Robert Newmann, Office of Public
Counsel, State of Illinois
'
Center
Robert M.
Thompson, Administrator
Wisconsin Division of Emergency
Government
State Liaison Officer
J
l
l
1
--
.
. _ - - -
.
.
...
--
-
-
-.
. -
, ,
. . n.
- . - - -
-n
, , -
T,
'Crmm!nwealth Edistni
- -
1400 Opus Place
'
. . Downers Grove, Illinois 60515
.
,
,
.
December 18, l_992
'
-
U.S. Nuclear Regulatory Commission
- Washington, D. C,
20555
i
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
,
-
l
Reference:
-H. J. Miller l'etter to Cordell-Reed' dated
- _
November 20, 1992, transmitting Inspection-Report
,
!
50-295(304)/92025,-
c
!-
1
"L
.
.
Enclosed is Commonwealth = Edison Company's-(CECO) response to:the. subject-
violation which was transmitted with the referenced letter.
The violation-concerns:the establishment of a'cceptance: 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 708/5.15-7250.
'
Very truly yours,.
,
wk h
,
T. J. Kovach
Nuclear Licensing _ Manager
-
SRK/lk=
Attachments--
.
.
.
cc:$hE5ErMDavlsgRegionalAdministrator-Region:III
C..Shiraki. Project Manager. NRR-
J. Smith, Senior Resident Inspector, Zion
.
-.
.
-
' OM /MG/
-
9 % Q (JI Q
f
ZNLD/2378/1-
1
,#
.
!
-
.
611AQiMMI
,
.
REPLY TO NOTICE OF VIOLATION
NRC INSPECTION REPORT
295/92025; 304/92025
VIOLATION:
10 CFR 50, Appendix B, Criterion 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 insv'; tion resistance
measurements obtained on diesel generators lh and 18 that did not meet the
acceptance criteria; (2) the acceptance criteria for calibration of the
Megsense 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 o' " 9 phase to phase winding
insulation resistance data recorded by the cra;=
This is a Severity Level IV violation (Supplement I).
RM10LE)R THE VIOLATION
,
Commonwealth Edison Company (CECO) acknowledges the violation.
The failure to perform an adequate evaluation of generator winding
insulation resistance on the iA and 1B Emergency Diesel Generators (EDGs)
and the failure to detect and resolve the Magsense card acceptance
criteria discrepancy were cue 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 Renorts 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.
ZNLD/2378/2
I
- - _ - _ _ - _ - _
_
_
,!
.
"
.
AIIACHMERI
.
'
REPLY TO NOTICE OF VIOLATION
NRC INSPECTION REPORT
295/92025; 304/92025
C0HECIIYLACIION TAKEN AND RESULTS ACHIEVED
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 ace ptance criteria which has
been reviewed and approved by SOAD.
The 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 detail
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 Di~screpancy 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.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION
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 ano 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.
ZNLD/2378/3
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _
-
7-
.
.-
- --------
_ _ _
__
9
7, .
-
,
AIBCilBEllI-
,
REPLY TO NOTICE OF VIOLATION
-
-
NRC INSPECTION REPORT
295/92025; 304/92025
DATE WHEN FULL COMPLI_ANCE WILL BE ACHIfyID
'*
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,
ZNLD/2378/4
. . . . . . .
.
.
..
__