ML20247K420

Responds to Violations Noted in Insp Repts 50-295/89-04 & 50-304/89-04.Corrective Actions:Visually Verified That Secondary Undervoltage Contact for Remaining 480 Volt Transformer Feeder Breakers Properly Wired

ML20247K420
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/11/1989
From:	Kovach T COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
0073T, 73T, NUDOCS 8906010294
Download: ML20247K420 (8)

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l'I R ,u 7;Q* Commonwealth Edison l J;f . :1 .,

' f i '7 72 West Adams Street, Chicago, Illinois v- ;p 4 v - Addrrss RIply to: Post Office Box 767 ii Chicago, Illinois 60690 - 0767 April 11, 1989 Mr..A. Bert Davis i

< Regional Administrator.

U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Zion. Nuclear Power Station Units 1 and 2 g License Nos. DPR-39 and DPR-48, Response.

to Inspection Report Nos. 50-295/89004 and 50-304/89004 NRC Docket Nos. 50-295 and 50-304 References (a): January 24, 1989 letter from H.J. Miller to Cordell Reed.

(b): March 9, 1989 letter from H.J. Miller to Cordell Reed..

Dear Mr. Davis:

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Reference (a) transmitted the results of a special inspection that I was conducted by Mr. D.' Butler of your staff on January 5, 1989, of certain l

~ activities at Zion Station. The same transmittal also notified us of your

! intention to request an Enforcement Conference to discuss the inspection findings. An Enforcement Conference was held in the Region III office on February 9, 1989. The evaluation of the results of the information presented at the Enforcement Conference and from previous submittals were used to compile Reference (b).

Reference (b) indicated that certain activities appeared to be in violation of NRC requirements. The responses to these violations are provided in the Attachment to this letter. Your cover letter also expressed a concern about two additior.al issues (1) adequacy of installation and testing of safety-related modifications that were installed prior to the implementation 8906010294 890411 APR 1;9999 PDR ADOCK 05000295 Q PDC q

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., o A.D. Davis April 11, 1989 of the new modification program; and (2) corrective action that is occurring or planned to address any inconsistencies between Technical Specifications (T.S.) surveillance tests and proper interpretation and application of the T.S. definitions. Per your request, each of these concerns is addressed in the response to the respective violation.

Please direct any questions that you may have regarding this matter to this office.

Very truly yours,

/ $We T. J. vach Nuclear Licensing Manager 1m Attachment cct NRC Resident Inspector - Zion i

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10 CFR 50, Appendix D, Criterion XI, requires that a test program be established to assure that all testing. required to demonstrate that systems and components will perform satisfactorily in service is identified and performed. Test results shall be documented and evaluated to assure that. test requirements have been satisfied.

Contrary to the above:

a. In May 1985 (Unit 1) and January 1986 (Unit 2), the licensee failed to adequately test the secondary undervoltage modification by testing the actual secondary undervoltage contacts that auto-close the 480V transformer feeder breakers for both units.

As a result, the licensee failed to detect the unconnected secondary  ;

undervoltage wires on Unit 2 480V transformer feeder breaker No.

2484. In addition, the licensee failed to demonstrate the I

operability of the Unit 2 2B motor driven AFW pump in the event of a secondary undervoltage condition.

b. During the Unit 2 1985 refueling outage and the Unit 1 1986 refueling outage, the licensee failed to adequately test the Appendix R required emergency diesel generator (EDG) electrical isolation control switch modification.

As a result, the licensee failed to detect the original construction wire had been incorrectly left in parallel with the Unit 1 EDG 1B l

isolation switch contact 43/MCB (C6/D6). The failure to electrically

{ isolate the 1B EDG contrcl power could have prevented the local startup of the IB EDG in the event of a disabling control room or cable spreading room fire.

CORRECTIVE ACTION _TAKEN AND RESl&TSMED:

a. Immediate corrective action was to visually verify that the secondary I undervoltage contact for the remainin!; 480V transformer feeder breakers was properly wired. This was completed on November 11, 1988.

The wiring discrepancy on 480V transformer feeder breaker No. 2484 was corrected on December 9, 1988. Functional testing of the secondary undervoltage contacts for both Unit I and Unit 2 480V transformer feeder breakers was performed satisfactorily on January 6, 1989.

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E t To assure'that other undetected wiring errors did not. exist as a result of;the. secondary undervoltage modification, a visual walkdown of'the wiring and'a review of modification test for adequacy were conducted on January 18, 1989. : No additional wiring errors were found as a result of the walkdown. Additional testing will be required as a result of the modification test review. This testing will.be: included as part of the follow-up corrective actions.

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b. Immediate corrective action was to verify'that a similar discrepancy did not exist on the other EDG isolation switches. This inspection was completed on June 21, 1988. Instructions were also provided to the Operating department on emergency actions to be taken in the event of a fire in the control room. On June 29, 1988 the wiring

error wasLcorrected and a functional test of the isolation switch performed satisfactorily.

Improvements have been made in the modification program since these modifications were installed, which should prevent the recurrence of inadequate modification installation and functional testing.' These improvements include increased modification inspections, including three separate walkdowns, and a wiring verification for electrical. modifications.

Improvements in testing include formal guidelines for modification test-writing, a mo'dification' test review which is independent of the 10 CFR 50.59 review and increased consideration of operating mode'and interactions.with other components during testing.

CORRECTIVE ACTION'TO BE TAKEN TO AVOID FURTilER VIOLATION:

A high level of confidence that safety related systems, including those modified under the old modification process, are correctly i>istalled and have been adequately tested, is afforded by the following factors:

~ 1. These safety-related systems operate, and have operated properly in the past, during normal and off normal plant operations. The systems operate properly as designed when challenged, assuming no component failures.

2. While'this violation identified an inadequacy in our surveillance testing program, the majority of. safety related components are adequately tested during periodic surveillance.

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To further ensure that existing safety related systems are properly installed, an Action Plan has been develepod to identify all relay contacts in safety related systems and to ensure that the contacts are tested, either through surveillance procedures or through other testing.

This Action Plan is described in the response to Violation f2.

DATE WHEN FULL CQ}iPLIANCE WILL_RE_l{ET The station will be in full compliance by the end of the 1991 Unit 2 Refueling Outage.

2. VIOLATION:

Technical Specification 4.4.2 requires that testing of safeguards l

instrumentation and. control channels be performed as specified in Table 4.4.1.

Table 4.4.1 requires the auxiliary feedwater (AFW), station blackout and secondary undervoltage actuation channel logics be functionally tested in accordance with Technical Specification Definition 1.9.b.

Definition 1.9.b states, in part, " Logics - the application of input signals, or the operation of relays or switch contacts, in all the .

combinations required to produce the required decision outputs including the operation of all actuation. devices. Where practicable, the test shall include the operation of the actuated equipment as well (i.e., pumps will be~ started, valves operated, etc.)".

Contrary to the aboves

a. The licensee failed to adequately test the station blackout logic contacts that auto-close the 480V transformer feeder breakers. -This condition existed from initial plant construction to January 1989.

b. The licensee failed to adequately test the secondary undervoltage logic contacts that auto-close the 480V transformer feeder breakers.

This condition existed from the time of installation of the contacts (May 1985-Unit 1; January 1986-Unit 2) tc, January 1989.

As a result, the licensee failed to detect the unconnected secondary undervoltage wires on Unit 2 480V transformer feeder breaker No. 2484.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:

Functional testing of the station blackout logic contacts and secondary undervoltage logic contacts which autoclose the 480V transformer feeder breakers was completed satisfactorily on January 18, 1989.

I CORBECTIVE ACTION TO BE TAEEN TO AVOID FURIliKE_VlQIATLQti The approach taken by Zion Station to prevent recurrence of inadequate l

surveillance testing consists of two basic parts. The first part is a L review of Tech Spec surveillance requirements for Reactor Protection and l Safeguards to ensure compliance. This review will identify initiating relay contacts and support contacts necessary to perform the specific safeguards function, identify the applicable test and section which actuates the contacts for each required plant condition, and will confirm that the surveillance frequency of the test is consistent with the surveillance frequency listed in the Tech Spec.

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This review will, in effect, identify all logic or actuation paths and the applicable relay' contacts in that path.

The second part will, based on the contact function, determine the appropriate testing to be performed for all of the contacts identified'in.

the first review.

PWR Engineering and Zion Station have developed a philosophy for testing relay contacts on Safety Related Systems. The philosophy identifies three test interval categories that all Safety Related contacts fall into:

1. Parlpdic' Testing as Required by Tech Spang These relay contacts provide logic or actuation functions during accidents. The function of these contacts should be verified during Tech Spec periodic testing.

2. Long Term Periodic Testino not associated with' Tech Specs These relay contacts provide. good design features, and if they fail,

'may' cause components to malfunction. They do not directly actuate components but may provide important secondary functions such as inhibits on level and pressure autostarts for anti-pump, and SI trips and inhibits on D/G output breakers. .These relay contacts are not associated with a Tech Spec testing requirement but should be tested periodically.

3. One_ Time Teste.d Contacts These relay contacts perform secondary functions and provide additional design features. The failure of these relay contacts will not result in a component malfunction unless a specific additional failure occurs. These include computer points, alarms, and manual override inhibits on valves, pumps, and fans during LOCA conditions.  ;

To ensure that these contacts function properly and are properly installed, these contacts should be verified to have been tested at least one time.

Using this philosophy, all applicable safety-related relay contacts will be identified and placed in the appropriate categories. This identification process is being implemented in two s3parate phases.

The first phase has been completed and consisted of reviewing all Reactor Protection and Safeguards relay contacts, applicable Tech Spera, ar.d supporting periodic tests. This review produced a list of potentially untested relay contacts.

. .,_. -S-31 The second phase performs-a comparison between existing surveillance procedures and wiring schematics for-Safety Related Systems. Those relay contacts which appear not to be tested during surveillance testing will be placed on another potentially untested contact list. This review is expected to be completed by October 31, 1989.

The list of contacts. identified from these reviews will be analyzed and placed in the categories listed above.

Fer those relay contacts placed in Category 1, the applicable surveillance

. procedure will be revised or a new procedure written. If the relay or contect cannot be readily isolated or set up for testing, a modification may be proposed.

For those relay contacts placed in category 2, existing procedures may be revised as necessary. If no test exists, one will be written and an appropriate testing interval will be determined.

For those relay contacts placed in category 3, previously performed modification or pre-op tests will be reviewed to determine if the relay contact has ever been tested. If not, a one time test will be. written and performed.

The above reviews and testing will be accomplished in accordance with the following Action Plan 1989 Unit 1 Refueling Outage Testing of Unit I relay contacts identified during either the phase 1 or phase 2 review, which are placed in Category 1, will be completed.

1990 Unit 2 Refueling Outage Testing of Unit 2 relay contacts identified during either the phase 1 or phase 2 review, which are placed in Category 1, will be completed.

1991 Unit 1 Refueling Outage Testing of relay contacts p* aced in Categories 2 or 3 for Unit I will be completed.

1991 Unit 2 Refueling Outage Testing of relay contacts placed in Categories 2 or 3 for Unit 2 will be cotaple ted.

Additionally, a Tech Spec change will be submitted which places Sections 3.4/4.4 of the current Tech Specs in the same format as Standard Technical Specifications. This will result in an additional review of these sections to insure compliance of surveillance testing with Tech Spec requirements.

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This review and testing program will ensure that equipment is installed as designed and that required periodic testing of relays and contacts is identified and accomplished.

DATE WHEN FULL COMPLIANCE WILL BE MET:

The station will be in full compliance by the end of the 1991 Unit 2 Refueling Outage.

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