ML20247A792
| ML20247A792 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/01/1989 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20247A796 | List: |
| References | |
| NUDOCS 8909120214 | |
| Download: ML20247A792 (6) | |
See also: IR 05000295/1989018
Text
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,r% , p r,y ,3 ,,_ p ,. , r - << , 4 i l '.l Y; '_h lQ .e ' ' p . ' - , g- ,s- y y. , . ~ ' _ , f' f > 1 00cket No. 50-295L ' > " ' ( . .2 LDocketiNo; 50-304' s , Y .l' t,e e - - a , + Ey 4 6 Commonwealth Edison,' Company fJ* ' ,: ,; W f ' ATTN: Mr; Cordell. Reed- V ' ' - [, m, sSenior:Vice President ' 4 ' ~ + s iJ , y : Post Office' Box.767n "O - . %w x"l Chicago,illi 60690 - ~ ' ' ' ' , V v , , , I' " , ! Gentlemen: ' ' q c a m ';. , , . , .- - .. .. ,- . , . , . .. ' y4 s.. . W WThisire,fers'to"the special' maintenance (team inspection conducted by- lMrSZL Falevitse and others of this- office on June 19-23, July:17-21, and;24, f + (, >- , ?. 1989. 3 This: inspection _ covered l activities at the Zion. Nuclear. GeneratingL s me ( Ro g'~~Stationp. Units 11and2,:asauthorizedbyNRC10perating.Licens'es'No.DPR-39and~m No.~ DPR-48e and thezinspection findingsnthat were discussed.with Mr. T. Maiman1C ' -[yM< !and 'otherslof your staff at ths " conclusion' off the ins.p ction/ 1~
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, , .; s, ,, . , , . . ~ ,~ (" A , "The inspection was!conductedeto assess and evaluate your< support and ~ Implementation of maintenance' to' assure that' plant structures,E systems, and : . .
- components.if/ maintenance was accomplished, effective, and adequately;asses
a" , reliably perform on: demand. '7 / determine. % S ( bylyourlown quality. verification process. N'
. , <, , , G N Thelenclosed copy of'our' inspection report identifies. specific areas examined , " A during the' inspection. Within these areas, the inspection consisted of a qF- .-selective examination of_ procedures andTrepresentative records, observations,, > " L and) interviews with personnel. In an attempt to focus,on'thos'e activities that- ! are most fiskt significant, insights'from the. Zion Nuclear Generating Station -
- Probabilistic Risk' Assessment Study were used to select systems and components
,, 7 .important;to; safety.
o .. ~ . -The1 inspection team. concluded that maintenance at-Zion Nuclear Generating n .Statio'n was,'in general," satisfactorily performed, however, based on.the deficiencies identified, significant improvements in the maintenance program ' ", ', are warranted. The' Executive Summary highlights our inspection findings and t LSection 3.0 of the inspection. report provides a synopsis of your maintenance ' > ' ' 4 . program' o . . .
~Some"of,the mos.tlsignificant weaknesses were: ' ' w {l.; a r il; ' Instances of inadequate and untimely corrective action: . . ~ , . .. j pg . . a Aniauxiliary feedwater pump turbine overspeed trip mechanism had j ' 4
n ~y l not been tested or maintained.for approximat . 17 years. Another i ' 3 . auxiliary feedwater pump ti,rbine overspeed trip mechanism was tested 4 j. a
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, _ _ _ _ _ , -':. w SEP 1 1989 . Commonwealth Edison Company 2 L in April 1987, with inconclusive results, and function due to lack of maintenance during a s.recently failed to , ' , tatic test. The failure of these overspeed trip mechanisms had the potential to significantly overpressurize the pump discharge piping. The necessity for such tests was previously made known through vendor information, an NRC information notice, your own and INP0 assessments. . Significant deficiencies'were not always documented and properly
addressed. For example, on more than one occasion the technical staff and electrical department appeared to accept the recurrence of a battery to bus circuit breaker failure to close on the first ~ attempt. Adequate documentation of these failures or a root cause evaluation to correct the degraded condition did not exist. . Previously identified ~NRC violations have not been adequately
addressed in the areas of work instruction adequacy, bypassing of QC hold points,-and radiological controls. 2. . Instances of failure to specify' post maintenance test requirements.for safety-related and non safety-related components and systems. 13. Instances of failure to follow procedures, or inadequate procedures, that resulted in: .a miswired torque switch on an auxiliary feedwater pump. turbine main steam inlet valve that subsequently tripped on thermal overload; an incorrect procedure in a work package that was used to perform the maintenance activity; and three of six unplanned reactor trips at Zion in 1988. 4. Instances of inadequate engineering support and involvement in maintenance as indicated by the problems and examples discussed.above. System engineers did not adequately evaluate and correct generic
problems such as failure of battery to bus circuit breakers to close on the first. attempt. . i Lack of-an aggressive review of vendor recommended maintenance activities that resulted in components being excluded from the preventive maintenance program. 5. Lack of management aggressiveness in implementing the maintenance program, including balance of plant. This resulted in instances where items classified as high priority work were not completed for an extended time period and were not technically justified. During this inspection, certain of your activities appeared to be in violation of NRC requirements, as specified in the enclosed Notice. A written response is required. We are particularly concerned with your actions regarding the turbine driven auxiliary feedwater pump overspeed mechanism failure, f Violation 295/89J18-01D; 304/89017-01D. We request that your response { to the violation specifically address all corrective actions you have I taken to ensure that this problem has been resolved. i I l i _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . . _ . I
, _ . _ -_ - , __-- -- . _ _ - - _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ . %- l j - l CommonwealthNdisonCompany 3 SEP 1 1989 , 'In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the : l NRC Public Decument Room. 1 l The responses directed by this letter and the accompanying Notice are not ' subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. } l We will gladly discuss any questions you have concerning this inspection. ' Sincerely, CRIGINAL SIGNED BY HUBERT J. MILLER H. J. Miller, Director Division of Reactor Safety Enclosures: 1. Notice of Violation 2. Inspection Reports , No. 50-295/89018(DRS); .No.'50-304/89017(DRS) cc w/ enclosures: T. J. Maiman, Vice President, PWR Operations T. Kovach, Nuclear Licensing Manager T. Joyce, 5tation Manager DCD/DCB (RIDS) Licensing Fee Management Branch l Resident Inspector, RIII -Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division Mayor, City of Zion Chandu Patel, Project Manager, NRR David Rosenblatt, Governor's Office of Consumer Services , Commissioner J. R. Curtiss, OCM/JC ' K. Hart, NRR/LPEB - Director, Division of Reactor ' Safety, RI, RII, RIV, RIV l RIII RI I - RIII- RIII RIII RIII Tb ns- Y/ )$ q*i,%vok
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) i Falevits/ims J onski Cooper H Ms Martin (3/f/89 iller ! , 8/3o/89 8/p/89 8/30/89 8/3V89 9/f /89 '
N_ __ __ - _ _
- -- . . _ ' .E o , s ' RE ' [ UNITED . STATES . [[ ' "k, ' NUCLEAR' REGULATORY COMMISSION !
S- ' REClON lli D f_ 1799 ROOSEVELT ROAD , . CLEN ELLYN, ILLINOIS . 60137
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SEP 11989 ' ~-Docket No; 50-295 Docket No. 50-304: , Commonwealth Edison Company ' ATTN: Mr. Cordell Reed. Senior Vice President R' iPost Office Box 767 i . Chicago, IL -60690 , Gentlemen: .This' refers to the special maintenance team inspection conducted by Mr. .Z. Falevits and others of this office on June 19-23, July 17-21, and 24, 1989. This inspection covered activities at the Zion Nuclear Generating Station, Units 1 and 2, as' authorized by NRC Operating Licenses No. DPR-39 and No. DPR-48 and_the inspection findings that were discussed with Mr. T. Maiman and.others of your staff at the conclusion of the inspection. .The inspection was conducted to assess and evaluate your support and implementation of' maintenance to assure that plant structures, systens, and . , components reliably perform on demand. Various activities were evaluated to E determine if maintenance was accomplished, effective, and adequately assessed by your own quality verification process. The' enclosed ' copy of our inspection report identifies specific areas examined 'during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel. In an attempt to focus on those activities that are most risk significant, insights from the Zion Nuclear Generating Station l Probabilistic Risk Assessment Study were used to select systems and components important to safety. The inspection team concluded that maintenance at Zion Nuclear Generating Station was, in general, satisfactorily performed, however, based on the deficiencies identified, significant improvements in the maintenance program are warranted. The Executive Sumary highlights our inspection findings and j Section 3.0 of the inspection report provides a synopsis of your maintenance program. Some of the most significant weaknesses were: 1. Instances of inadequate and untimely corrective action: An auxiliary feedwater pump turbine overspeed trip mechanism had
not been tested or maintained for approximately 17 years. Another i ' auxiliary feedwater pump turbine overspeed trip mechanism was tested l i - _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ . - _ - _ . _____. - __ _. __
_ - -_- _ - _ - - _ - - __ _ -- - - - - ' , * " . T. S .' / SEP- 11989 ' Commonwealth Edison Company 2 > , in April 1987, with inconclusive results, and recently failed to function due to lack of maintenance during a static. test. The failure of these overspeed trip mechanisms had the potential to significantly overpressurize the pump discharge piping. The necessity for such tests was previously made known through vendor information, an NRC information notice,.your own and INP0 assessments. ~ ignificant deficiencies were not always documented and properly S
addressed. For. example, on more than one occasion the technical staff and electrical department appeared to accept the recurrence of a battery to bus circuit breaker failure'to close on the'first attempt. Adequate. documentation of these failures or.a root cause evaluation to correct the degraded condition did not' exist. Previously. identified NRC violations have not been adequately
addressed in the areas of work instruction adequacy, bypassing of QC hold points, and radiological controls. l 'l 2. Instances of ' failure to specify post maintenance test requirements for ' safety related and non safety-related components and systems. . 3. Instances of failure to follow procedures, or inadequate procedures, that resulted in: a miswired torque switch on an auxiliary feedwater pump turbine main steam inlet valve that subsequently tripped.on thermal overload; an' incorrect procedure in a work package that was used to perform the maintenance activity; and three of six unplanned reactor trips at Zion in 1988. 4. Instances.of inadequate engineering support and involvement in maintenance as indicated by the problems and examples discussed above. System engineers did not adequately evaluate and correct generic
problems such as failure of battery to bus circuit breakers to close on the first attempt. - Lack of an aggressive review of vendor recommended maintenance
activities that resulted in components being excluded from the -preventive maintenance program. 5. Lack of management aggressiveness in implementing the maintenance program, including balance of plant. This resulted in instances where items classified as high priority work were not completed for an extended time period and were not technically justified. During this inspection, certain of your activities appeared to be in violation of NRC requirements, as specified in the enclosed Notice. A written response '; is required. We are particularly concerned with your actions regarding the l turbine driven auxiliary feedwater pump overspeed mechanism failure, l Violation 295/89018-01D; 304/89017-010. We request that your response ] to the violation specifically address all corrective actions you have taken to ensure that this problem has been resolved. ___=__ -- - __ _ l
_ _ _ _ _ - - - - - - _ _ _ _ _ _ _ _ _ ! o 1 Commonwealth Edison Company 3 In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC Public Document Room. The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. We will gladly' discuss any questions you have concerning this inspection. Sincerely, ' ~ . J. Miller, Director Division of Reactor Safety Enclosures: 1. Notice of Violation 2. Inspection Reports No. 50-295/89018(DRS); No. 50-304/89017(DRS) cc w/ enclosures: T. J. Maiman, Vice President, PWR Operations T. Kovach, Nuclear Licensing Manager T. Joyce, Station Manager DCD/DCB (RIDS) Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division Mayor, City of Zion Chandu Patel, Project Manager, NRR David Rosenblatt, Governor's Office of Consumer Services Commissioner J. R. Curtiss, OCM/JC K. Hart, NRR/LPEB Director, Division of Reactor Safety, RI, RII, RIV, RIV j }}