ML20247A822

Notice of Violation from Insp on 890619-23 & 0717-21 & 24. Violations Noted:Electrolyte Levels for Battery 212 Verified Between Full & Low Level Line & Wrong Procedure Used to Repair Limitorque Operator for Valve 2MS006

ML20247A822
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:
Shared Package
ML20247A796	List: IR 05000295/1989018 ML20247A792 ML20247A822
References
50-295-89-18, 50-304-89-17, NUDOCS 8909120219
Download: ML20247A822 (5)

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a NOTICE OF VIOLATION.

Commonwealth Edison Company Docket Nos. 50-295; 50-304 I Zion Station, Units 1 and 2 I I

-As a result of the' inspection conducted on June 19-23, July 17-21, and 24, _

1989, and in accordance with 10 CFR Part 2, Appendix C - General Statement of-Policy and Procedure for NRC Enforcement Actions (1988), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion V, as described in Section 5,.of Topical Report CE-1A, Revision 55, and as implemented by Quality Assurance Manual, Section 5, requires that activities affecting quality be prescribed by i documented instructions, procedures and drawings, and that those activities be accomplished in accordance with those instructions, procedures and drawings. 1 Contrary to the above:

a. Surveillance Procedure PT-30, Paragraph 5.2, required that the electrolyte levels in station batteries be verified to be between 1/4 inch below the full line and the low level line. However, electrolyte levels for battery No. 212 were verified to be between-the full line and the low level line, which resulted in acceptance of'the levels even though the procedural requirements were not met (295/89018-02A; 304/89017-02A).

b. The wrong procedure was used during repair of the Limitorque operator for Valve 2MS006 (295/89018-02B; 304/89017-028).

c. Procedure E022-1, " Inspection and Maintenance of Limitorque Valve Motor Operators," Revision 1, did not provide adequate instructions to prevent miswiring of the torque switch associated with Valve 2MS006 (295/89018-02C; 304/89017-02C).

d. Maintenance personnel failed to document the lifting and landing of leads as required by ZAP 3-5-1, " Temporary Alteration Program,"

Revision 26, during corrective maintenance performed on the 1B Energency Diesel Generator. (295/89018-02D; 304/89017-02D).

This is a Severity Level IV violation (Supplement 1).

2. 10 CFR 50, Appendix B, Criterion XVI, as described in Topical Report CE-1A, Revision 55, and as implemented by Quality Assurance Manual, Section 16, requires that measures be established to assure conditions adverse to quality are promptly identified and corrected.

In the case of significant conditions adverse to quality, the measure I

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i l Notice'of Violation- 2 shall. assure that the cause.of the condition is determined and.

corrective action taken to preclude repetition.

' Contrary to the above, the licensee failed to:

-a. Take. timely and effective corrective action to ensure that adequate work instructions were provided in work requests. This had been

' identified as a violation during a 1986 NRC inspection and remained uncorrected (295/89018-01A; 304/89017-01A).

L b. Provide timely corrective action to correct dc battery to bus circuit l breaker failures. A history of problems in reliably closing the l: breakers on the first attempt was initially identified on work requests dated October 10,'1987. However, since all. breakers' had successfully closed on the second attempt, the work requests were never completed, even after vendor representatives indicated the

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l: problem appeared to be worn bearings (295/89018-01B; 304/89017-01B).

l c. Provide timely or. adequate corrective action on known problems in post-maintenance testing, temporary modifications, and work control.

.These recurring problems were identified in-September 1987, and again in February 1989, during self-assessments (295/89018-01C; 304/89017-01C).

! d. Take adequate and timely corrective action to maintain and test the 2A Auxiliary Feedwater pump turbine overspeed mechanism for l

approximately 17 years, or successfully test the 1A Auxiliary Feedwater pump turbine overspeed mechanism in 1987. The vendor recommended testing once a week. The necessity of the tests was previously made known to the licensee by General Electric Company in July 1986, by the NRC in Information Notice 88-67, by the licensee's own Safety System Functional Inspection in September 1988, and by an INPO assessment team in February 1989.

Subsequent to the Maintenance Team Inspection and NRC's inquiry, the licensee conducted a static test of the linkage and valve mechanism on July 22,1989, for the 1A Auxiliary Feedwater pump turbine with unsuccessful results. Maintenance had to be performed on the overspeed trip mechanism before a successful test was obtained. The inspectors were informed that the tests for the 2A Auxiliary Feedwater pump turbine were successfully completed on July 23, 1989 (295/89018-01D; 304/89017-01D).

This'is a Severity Level IV violation (Supplement 1).

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f Notice of Violation 3 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) the corrective actions that have been taken and the results. achieved; (2) the corrective actions 1that-will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

Dated I N2 - b N?f H. J.. Miller, ctor Division of R or Safety i

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j EXECUTIVE'

SUMMARY

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'An announced NRC-team inspection of maintenance was' conducted at Zion Nuclear i Generating Station durin'g the period of June 19-23, July 17-21, and 24, 1989.

The inspection was conducted to evaluate the extent that a maintenance program had been established and implemented at Zion to assure the preservation or

. restoration of the availability and reliability of plant structures, systems, and. components'to operate.on demand. Three major areas were assessed including overall plant performance as affected by maintenance, management support of maintenance, and implementation. To accomplish this task, several maintenance related activities were evaluated to determine if maintenance was accomplished, effective, and self-assessed.

Strengths

.The-inspection . team noted specific strengths in the areas of: housekeeping and plant-improvement; upgrading of Instrumentation and Control procedures; 1 preventive maintenance improvements including vibration monitoring; development of a comprehensive training matrix for technical staff engineers; and health physics support of large maintenance activities.

Weaknesses The i_nspection team noted specific weaknesses. Most of the weaknesses were

. identified in the area of management involvement; specifically, inadequate attention to non safety-related activities and balance of plant equipment, inadequate or lack of corrective action to address recurring problems.such as testing of the Auxiliary.Feedwater pump turbine overspeed trip mechanisms and the failure of six battery-to-dc-bus circuit breakers to close on the first attempt, lack of a comprehensive. trending program for corrective maintenance, lack of QC involvement in corrective maintenance activities, and making ' changes to plant goals that enabled goals to be met. Another weakness identified was in the area of Engineering Support, which was based on the level of system awareness and technical knowledge of system engineers, lack of involvement in analysis of generic problems, post-maintenance testing and root cause analysis, lack of incorporation of vendor recommendations into maintenance procedures, and failure to include all components requiring preventive maintenance in.the preventive maintenance program. Weaknesses associated'with the performance of maintenance included: numerous instances of failure to follow procedures and instances of inadequate planning of jobs including Health Physics involvement in routine maintenance activities.

Conclusion Based on the review of past work activities, observations of ongoing work activities, work controls, and attempts at self-assessment, the inspectors determined that electrical, mechanical, and instrument and control maintenance, and support activities were, in general, adequately performed to maintain operability of components at a level commensurate with their function.

However, based on the deficiencies noted, significant improvements in the maintenance program are warranted. Additionally, some of the activities identified were in violation of regulatory requirements.

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• CONTENTS

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Section Pag a

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. Persons Contacted. . . . ; . . . . . . . . . . . , ... . . . . . 3 2.0 Licensee Action on' Previous Inspection Findings. . . . . . . . . 3~

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. Introduction to the Evaluation and Assessment of Maintenance'. . 4 p 3.1 Performance Data and System Selection. . . . . . . . . . . . . . 5 4

. 3.1.1 Historic Date. . . . . . . . . . . . . . . . . . . . . . . . . . 5 3.1.2 System Selection.. . . . . . . . . . . . . . . . . . . . . . . .

7 3.2 . Description of. Maintenance Philosophy. . . . . . . . . . . . . . 7

3. 3. Observation of Current Plant Conditions and Ongoing Work Activities. . . . . . . . . . . . . . . . . . . . 7

3. 3.1 ; Current Material Condition . . . . . . . . . . . . . . . . . . . 7 3.3.2. Ongoing Work Activities. . . . . . . . . . . . . . . . . . . . 10 3.3.2.1 Ongoing Electrical Maintenance . . . . . . . . . . . . . . . . 10 3.3.2.2 Ongoing Mechanical Maintenance . . . . . . . . . . . . . . . . 13 3.3.2.3 Ongoing Instrument and Control Maintenance . . . . . . . . . 14 3.3.3 Radiological Controls. . . . . . . . . . . . . . . . . . . . .

16 3.3.4 Maintenance Facilities, Material' Control, and Control of Tools and Measuring Equipment . . . . . . . . . . 19 3.3.4.1' Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . 19 3.3.4.2 l Material , . Equipment, and Tool Control . . . . . . .. . . . . . . 19 3.3.4.3 Control and Calibration of Measuring and Test Equipment . . . . 21 3.4 Review and Evaluation of Maintenance Accomplished. . . . . . . 21 3.4.1 Backlog Assessment and Evaluation. . . . . . . . . . . . . . . 21 3.4.1.1 Corrective Maintenance Backlog . . . . . . . . . . . . . . . . 22 3.4.1.2 Preventive' Maintenance Backlog . . . . . . . . . . . . . . . . 22 3.4.2 Review and Evaluation of Completed Maintenance . . . . . . . . 23 3.4.2.1 Past Electrical Maintenance. . . . . . . . . . . . . . . . . . 23 3.4.2.2 Past Mechanical Maintenance. . . . . . . . . . . . . . . . . . 25 3.4.2.3 Past Instrument and Control Maintenance. . . . . . . . . . . . 29 3.5 Maintenance Worx Control . . . . . . . . . . . . . . . . . . 30 3.6 Engineering Support of Maintenance . . . . . . . . . . . . . . 31 3.6.1' Engineeri ng Support. . . . . . . . . . . . . . . . . . . . . . 31 3.6.2 Technical Support. . . . . . . . . . . . . . . . . . . . . . . 32 3.7 Maintenance and Support Personnel Control. . . . . . . . . . . 34 3.8 Review of Licensee's Assessment of Maintenance . . . . . . . . 35 3.8.1 Audits and Surveillance. . . . . . . . . . . . . . . . . . . . 35 3.8.2 Review of Maintenance Self-Assessment and SSFI . . . . . . . . 36 3.8.3 Effectiveness of Corrective Action . . . . . . . . . . . . . . 36 4.0 Synopsis . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 4.1- Overall Plant Performance. . . . . . . . . . . . . . . . . . . 37 4.1.1 Performance Indicators . . . . . . . . . . . . . . . . . . . . 37 4.2 Management Support of Maintenance. . . . . . . . . . . . . . 37 4.2.1 Management Commitment and Involvement. . . . . . . . . . . . . 37 4.2.2 Management Organization and Administration . . . . . . . . . . 38 4.2.3 Technical Support. . . . . . . . . . . . . . . . . . . . . . 39 4.3 Maintenance Implementation . . . . . . . . . . . . . . . . . . 40 4.3.1 Work Control . . . . . . . . . . .. . . . . . . . . . . . . . 40 4.3.2 Plant Maintenance Organization . . . . . . . . . . . . . . . . 40 4.3.3 Maintenance Facilities, Equipment and Material Control. . . . . 41 4.3.4 Personnel Control. . . . . . . . . . . . . . . . . . . . . . 41 5.0 Open Items . . . . . . . ...................41

- 6. 0 Exit Meeting . . . . . . . . . . . . . . . . . . . . . . . . 41 Appendix A: Acronyms

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