ML20196J131

Notice of Violation from Insp on 880414-0603.Violation Noted:Surveillance Test Procedure PT-4A Contained No Acceptance Criteria for Steps 5,8 & 10 & PT-4B Contained No Acceptance Criteria for Steps 3,5,7 & 9

ML20196J131
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/24/1988
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20196J125	List: IR 05000295/1988012 ML20196J119 ML20196J131
References
50-295-88-12, 50-304-88-13, NUDOCS 8807060329
Download: ML20196J131 (4)

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', NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-295 Docket No. 50-304 .

As a result of the inspection conducted during the period April 14 through June 3, 1988, and in accordance with 10 CFR Part 2,-Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1987), the following violations were identified:

1. 10 CFR 50, Appendix 8,^ Criterion V,'as implemented by Commonwealth Edison Company's NRC-approved Quality Assurance Topical Report, CE-1-A, requires in part that activities affecting quality be prescribed by procedures of a type appropriate to the circumstances and which include appropriate acceptance criteria for determining that important' activities have been satisfactorily accomplished.

a. Contrary to the above, surveillance test procedures PT-4A, "Source ,

Range Functional Test," contained no acceptance criteria for steps  !

5, 8, and 10, and PT-48,"Intermediate Range Functional Test,"

contained no acceptance criteria for steps 3, 5, 7, and 9.

b. Contrary to the above, the licensee's surveillance test procedure PT-2L, "Accumulator Backup Check Valve Leak Check," performed on April 23, 1988 and April 30, 1988, was inappropriate to the '

circumstances in that the units for measured test data and the associated acceptance criteria were not the same, and a conversion factor between test data units and acceptance criteria units was not  ;

contained in the procedure. l i

c. Contrary to the above, Revision 9 to test procedure PT-210, .

"Aircraft Fire Detection System Test," dated April 18, 1988, was l inappropriate to the circumstances in that the note in step 2 of the revised procedure states, f

"Verify at least one hour before testing that heat trace for D/G intake damper's air lines and actuators is plugged in..."  ;

This results in a failure to test the as-found system condition if icing conditions are present in the D/G (diesel generator t ventilation) intake damper air supply lines with the heat trace i initially unplugged. I i

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8807060329 880624 i l hDR ADOCK 05000295  !

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'. Notice of Violation 2

d. Contrary to the above, the licensee's main steam safety valve (MSSV) test procedure P/M003-5N, "Bench Testing Section XI Safety / Relief Valves for Use on Vapor / Gases," performed during refueling outages from 1978 to 1988, was inapprop'riate to_the circumstances and included inappropriate acceptance criteria; the set ~ pressure

-tolerance of + 2% listed in the procedure did not meet the set pressure tolerance of + 1% listed in Table 4.7-1 of the facility' Technical Specifications.

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

2. Zion Technical Specification 6.2.1.G requires that surveillance tests be conducted in accordance with written procedures.

Contrary to the above, on April 30, 1988, surveillance test PT-2L, -

"Accumulator Backup Check Valve Leak Check," was not conducted in accordance with the written test procedure in that;

a. The licensee failed to record the safety injection pump discharge pressures and the time at which valve 1 SI 8961 was closed as required by step 3 of PT-2L and by step 11 of Appendix Al to PT-2L, respectively.

b. The licensee failed to determine leak rates for all four Unit 1 accumulator backup check valves using the safety injection pump prior to determining the leak rate for the 1A accumulator backup check valve using the hydrostatic test pump as required by procedure change request T0-88-350 to PT-2L.

c. The hydrostatic test pump used during valve testing was not disconnected as required by step 14 of Appendix Al to PT-2L.

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

3. 10 CFR 50, Appendix B, Criterion XVII, as implemented by Commonwealth Edison Company's NRC-approved Quality Assurance Topical Report, CE-1-A, in Quality Procedure (QP) 17-51, requires that test records be retrievable.

10 CFR 50, Appendix B, Criterion XVII, as implemented by Commonwealth Edison Company's NRC-approved Quality Assurance Topical' Report, CE-1-A, in Quality Procedure 17-51, and by Zion Administrative procedure (ZAP) 10-52-2, "Operating Log Books," steps B.1.d, B.1.e, C.1.h and C.1.m, requires that abnormal surveillance results, actions taken to correct the abnormal results, and unusual system alignments be recorded in the appropriate operating logs.

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a. Contrary to the above, Unit 1 surveillance test records associated

- with the test procedure PT-2L, "Accumulator Backup Check Valve Leak Check," performed on April 29, 1988, and with one of the three PT-2L test procedures performed on April 30, 1988, were not retrievable,

b. Contrary to the.above, the licensee failed to record the following Unit 1 activities and conditions in the operating logs as follows:

(1) Inability to complete performance of PT-2L, "Accumulator Backup Check Valve Leak Check," on April 29 and April 30,

. 1988.

(2) Actions taken to flush the accumulator discharge lines on April 30, 1988, in an effort to reduce backup check valve leakage, and the deviation from System Operating Instruction 50I-4, "Safety Injection and Containment Spray," valve lineup for flushing the accumulator discharge lines.

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

4. 10 CFR 50.9 requires that information provided to the Commission by a licensee as required by the Commission shall be complete and accurste.

Contrary to the above, the licensee's letter dated February 3, 1988, which contained the NRC-required response to a Notice of Violation issued by the Commission on January 4, 1988, was inaccurato in that it stated that a review of test procedure PT-2L, "Accumulator Backup Check Valve Leak Test," was performed, and no deficiencies were identified; however, at the time of the response, the licensee had identified a deficiency in that procedure. The units for measured test data and the associated acceptance criteria for check valve leak rates in the procedure were nut the same, and a conversion factor between test data units and acceptance criteria units was not contained in the procedure. This resulted in the inability to determine valve operability during performance of the test procedure on April 29 and 30, 1988.

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

5. 10 CFR 50, Appendix B, Criterion III, as implemented by the licensee's NRC-approved Quality Assurance Topical Report, CE-1-A, in QP 3-51,"Design Control for Operations - Plant Modifications," requires that design changes be treated with the same design control measures as the original design, including appropriate approvals. QP 3-51, Attachment A, "Definition of a Modification and Phases of Testing," states that plant modifications are controlled using QP 3-51.

'. Notice of Violation 4

-Contrary to the above, a modification involving the addition of plug-in heat tracing and blanket insulation to instrument air lines supplying diesel generator room ventilation intake dampers and their associated damper air operators for the 1A,1B, 0, 2A, and 2B diesel generator rooms was performed in about 1984, and this modification was not controlled using QP 3-51.

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

6. Technical Specification 4.4.2 states that instrument channel functional i

check frequency requirements for safeguards instrumentation and control l

channels are as specified in Table 4.4-1. Table 4.4-1 requires channel functional testing of permissive P-12 on a quarterly frequency and channel functional testing of the automatic start of auxiliary feedwater l pumps from a station blackout signal on a refueling frequency.

a. Contrary to the above, quarterly channel functional testing of permissive P-12 was not performed from initial operation to June 3, 1987, for Unit 1, and from initial operation to the startup from the summer 1987 refueling outage for Unit 2.

b. Contrary to the above, functional testing of the automatic start of auxiliary feedwater pumps from a station blackout signal was not performed on a refueling frequency from February 25, 1983, until April 22,1988, for Unit 2, and from Fepruary 25, 1983, until the startup from the spring 1988 refueling outage for Unit 1.

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

With respect to item 1.a. the inspection showed that action had been taken to correct the identified violation and to prevent recurrence. Consequently, i no response to item 1.a of this Notice is required, and we have no further questions regarding this matter. With respect to items 1.b 1.c. 1.d, 2, 3, l 4, 5, and 6, 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 I statement or explanation in rep'y, including for each violation: (1) correc-tive action taken and the results achieved; (2) corrective action to 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.

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JUN 2 4 $88 . =sd Dated E. G. Greenman, Director Division of Reactor Projects

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