IR 05000373/1979006
| ML19338B798 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/15/1979 |
| From: | Dettenmeier R, Maura F, Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19338B796 | List: |
| References | |
| 50-373-79-06, 50-373-79-6, NUDOCS 7905070027 | |
| Preceding documents: |
|
| Download: ML19338B798 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT RECION III Report No. 50-373/79-06 Docket No. 50-373 License No. CPPR-99 Licensee:
Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name:
La Salle County Station, Unit 1 Inspection At:
La Salle Site, Marseilles, Illinois Inspection Conducted:
January 30-31, February 1, 7-8, 1979
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1;..Metors:
. A. Maura y
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L R. W. Dettenmeier U
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Approved By:
Chief 3 [ 5/ 79 Nuclear Support Section 1
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Inspection Sue =tary
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s Inspection on January 30-31, February 1, 7-8, 1979 (Report No. 50-373/79-06)
Areas Inspected:
Routine, unannounced inspection of preoperational test program organization and ad=inistration; previous unresolved ite=s; pre-operational test pro 6edures and test results; licensee events. The inspec-tion involved 72 inspector-hours'on site by two NRC inspectors.
8e Results: Of the five areas inspected, no Items of Nonco=pliance or Deviations were identified in three areas. Three Items of Noncompliance (2 Infractions - failure to comply with 10 CFR 50 Appendix B, Criterion V - Paragraphs 5.b and 7, and f ailure to comply with 10 CFR 50 Appendix B, Criterion XIV - Paragraph 6; and one Deficiency - inadequate procedure -
Paragraph 5.d) were identified in two areas.
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DETAILS
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1.
Persons contacted
- R. Holyoak, Station Superintendent
- G. Diederick, Station Assistant Superintendent
- E. Spitzner, Administrat$ ve Assistant
- R.
Bishop, technical Staff Supervisor
- J. Kodrick, QA Mechanical Coordinator
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- H. Hentschel, Lead Thermal Engineer G. Groth, Flushing Coordinator The inspectot also interviewed other licensee 'e=ployees including members of the technical, operating and QA staf f; and e=ployees of Morrison Company.
- Denotes those attending the exit interview.
2.
Licensee Action on Previous Inspection Findings (Open) Unresolved Item (373/78-23-01) Battery chargers recharge time. The licensee plans to amend the FSAR to state that the battery chargers have sufficient capacity to charge each battery to at least 95% capactiy within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The licensee was asked
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to define, in specific gravity values, what constituted "at least
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95% capacity" and to determine how he plans to demonstrate how the chargers met the requirement.
(Open) Inspection Follovpp Item (Inspection Report F 73/78-14)
Unit 2 shroud head. The inspector obtained a cop)
.he General Electric analysis of the red plastic caps and the 1 e.ic covet
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burned in the fire involving the Un't 2 shroud head on September 20, i
1977. The results in ppm were:
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F Cl S
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Plastic cap 22.2 5.5 130 134
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Plastic cover 25.8 6.4 121
As previously stated in Inspection Report No. 373/78-14, RIII will review the results of the cleanup being performed on the shroud head.
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3.
Preoperational_ Test Program
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The inspector reviewed the latest revision to the Startup Manual procedures (as of January 31, 1979) to ensure the changes did not conflict with FSAR com=itments.
Of the 64 preoperat'onal tests and syste= demonstrations re-quired to be completed prior to fuel loading the licensee has co=plete'd writing 60 test procedures and has approved 29 for use.
Six syste=s or partial systems have been turned over 'for pre-operational testing.
Six preoperational tests were in progress as of January 31, 1979.
4.
Review of Preoperational Test Procedure
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PT-LP-101, Revision 0, " Low Pressure Core Spre;," preoperational test procedure was reviewed and found to meet the requirements set forth in Reg Guide 1.68, the FSAR and the Startup Manual.
5.
Preoperational Test Results The inspector reviewed the results of the testing performed as of February 7, 1979, on the 250 VDC and 24/48 VDC systems.
During the review it was noted that:
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a.
The ' 50 VDC battery acceptance test was terminated when c
the terminal voltage reached 217 volts. Step 10.3.B.h of Procedure PT-AF-102, DC Distribution required that the discharge rate be maintained until a ter=inal voltage of 210 volts was reached.
The licensee indicated the reason for ter=inating the' test at 217 volts was that one cell had already reached the 1.0 volt limit and a few others
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were approaching 1.0 volts and he preferred to terminate the test rather than ju=per the low voltage cells as allowed by the procedure.
b.
tie necessary procedure change authorizing test termina-tien at 217 volts was.not approved prior to terminating g
the test at 217 volts.
Startup Manual procedures LSU 500-1, steps F.1, F.7.c and F.9, and LSU 500-2, steps F.1 and F.2, establish the methods to be used to change a test procedure.
This
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failure to follow the procedure change methods in Startup
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Manual procedures is contrary to 10 CFR Part 50, Appendix B, Criterion V, end QA Manual Quality Procedure 11-2, Section 5.4, and is considered to be an exa=ple of an Item of Nonce =pliance (373/79-06-01) of the Infraction level.
The licensee stated his intention to utilize Section 13
" Evaluation of Test Results," of the test procedure to
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include minor changes to the existing procedure. There-fore, when management reviewed and approved the test
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results it would be approving the minor changes. If management did not approve the changes at that time, the required sections of the test would have to be performed again.' The inspector stated this after the fact review of minor chan:;es was not in accordance with LSU 500-2 and it did not meet the requirements for te=porary procedure changes as given in ANSI N18.7.
The inspector stated that to place such pressures on management (to approve changes late in the preop program when having to rerun sections of tests which could cause delays in the fuel loading date) could result in deficiencies in the test program.
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c.
The terminal voltage of 210 volts for the 250 VDC battery acceptance test is part of the acceptance criteria listed
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in Data Sheet 12.la.
Since the test failed to meet this
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acceptance criteria, this is an Unresolved Item (373/79-
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06-02) pending resolution by the licensee and further reviewbytheinspecyor.
d.
No specific gravity correction for changes in electrolyte..
1evel during thc tests were applied since the electrolyte
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leael was not recorded. The battery manufacturer's manual,
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referenced in Section 4.7 of the preoperational test pro-cedare, recommends that when taking hydrometer readings the electro, yte level referenced to the high level line
be recorded for prcyer evaluation of the specific gravity
"a value. Because of the" lack of a r7: ire =ent in the pro-cedure to record electrolyte level and to apply the cor-rection to the specific gravity the procedure is considered to be inadequate. The inadequacy of the procedure is contrary to 10 CFR 50, Appendix B, Criterion V and QA Manual Quality Requirement No.11 and is considered to be an Item of Noncompliance (373/79-06-03) of the Deficiency level.
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One of the acceptance criteria during the test was that e.
the changes in specific gravity, start vs. finish of test, be less than 0.110.
For the 24/48 VDC battery 1DC32E it was noted that Cell No. 4 results were 0.106 and for battery 1DC31E Cell No.11 results were 0.104.
Since the change in electrolyte level was not recorded, no correction was calculated. However, the inspectors checked the electrolyte level on February 7, 1979, and noted it was between the high and low lines and in some cases at least 1/4" below the high level line.
If one assumed
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the level at the start of the test was at the high level
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line, a correction of 1/4" would cause the results for Cell No. 4 to be 0.112 and for Cell No. 11 to be slightly
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higher than 0.110, and both cells would exceed the stated acceptance criteria.
This is an Unresolved Item (373/79-06-04) pending resolution by the licensee and further review by the inspector.
6.
Flushing and Cleanliness Control a.
Cleanliness Control of Flushed Systems The licensee representatives responsible for cleanliness and flushing prior to system acceptance for operation stated that verbal co=munication from the cognizant construction engineer was the only indication of a need
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L to recheck the cleanliness status of a previously flushed
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system or portion of a system following additional work, rework, or modifications. The licensee indicated a review is underway to develop an improved method for controlling the cleanliness of m system or part of a system which has been flushed.
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b.
Cleanliness Status Indication
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The licensee had not developed a method for indicating the cleani,in,ess status of a system or portion of a system once it has been flyshed. Persons in,the operation as well as construction groups stated that a method for i
. physically identifying previously flushed or cleaned systems or part of systems did not exist. During the inspector's tour of the facility it was apparent that there was no method being used, such as tags, cards, stamps, etc., to identify the cleanliness status of any of the systems or portions of the systems.
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QA Manual Quality requirement 14.0, " Inspection. Test and Operating Status," Section 14.1 states that:
"This system will also provide for indicating the quality or operating sta'us during construction and plant opera-c tions. Markings, tags, labels, forms, log book or other suitable means are used to identify the operating status of parts and equipment to preclude inadvertant bypassing of the insrections and tests required prior to their use."
This lack of a method for indicating the cleanliness status of a system or part of a system after it has met the clean-liness tests for flushing is inconsistent with the QA manual and with 10 CFR Part 50 Appendix B, Criterion XIV, and is considered to be an Item of Noncompliance (373/79-06-05)
of the Infraction level.
7.
Use of Tagging Procedure in RHR System The inspectors reviewed an event which occurred on January 10, 1979, involving the failure to use the out-of-service tagging procedure on Resil:al Heat Removal System line 1RH26AA-4"'when a spool piece was removed to install valve lE12-F065A. The
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inspector interviewed Construction and Operations personnel
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involved in the event and reviewed procedures, equipment outage
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checklists and o.:-of-service and shift engineer logs.
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review revealed that:
a.
An integrated flush,was accomplished on the Residual Heat Removal System and interconnecting systems on
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August 15, 1978.
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b.
Valve 1E12-F065A for RHR line IRH26AA-4" was not available for installation prior to the integrated flush.
The
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licensee's contractor initiated Mechanical Revision Directive 540-992 which called for the installation of a spool piece in line 'lRH26AA-4".
The installation of the
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spool piece allowed line 1RH26AA-4" to be flushed and provided a desired flow path for the integrated flush.
c.
Since valve 1E12-F065A was part of the original construction plans, no new authorization or verification was needed to install it in place of the spool piece.
On January 10, 1979, the licensee's contractor initiated work to remove the spool piece fro = 1ine 1RH26AA-4". At this time, the
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valve lineup was such that.ine 1RH26AA-4" was pressurized
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by a head of water from a nearly full condenser hotwell.
When the licensee's contractor cut into 1RH26AA-4" line for the removal of the spool piece, water sprayed the nearbv RHR pump and motor, transmitter panels and instrumentation in the area. No personnel injuries were noted.
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d.
A review of the out-of-service log and equipment outage checklists for the period of December 1,1978, to January 10, 1979, indicated that an outage had not been initiated nor had out-of-service tags been issued or cleared to isolate 1RH26AA-4" line prior to initiating work for removal of the spool piece. The licensee's contractor was unaware of the status of that line in the RHR system and also failed to inspect or atte=pt to verify that 1RH26AA-4" line was depres-surized or drained, e.
Construction instruction 1-2-G-1 for use of out-of-service cards states:
"When construction on an addition to the station faci-lities, which has not been released for operation, has progressed to the point where the equipment being worked on could be livened from a source under the jurisdiction ed=
of the Generating Stations Department, the Coc=onwealth Edison supervisor in charge of the construction work
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must request that a MASTER OUT OF SERVICE CARD (and related OUT OF SERVICE CARDS, if required) be placed in his na=e, at all points of isolation".
Thelicenseeandhibcontractorfailedtouseconstruction instruction 1-2-G-1 on a livened portion of the RHR Systed'.
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This failure to follow procedures is contrary to the require-
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ments of 10 CFR 50 Appendix B, Criterion V, and is considered to be an exa ple of an.Ite= of Noncompliance (373/79-06-06)
of.the Infra tion level.
8.
Condensate / Condensate Booster Event
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The inspectors reviewed an event which occurred on January 10, 1979, involving the condensate and condensate booster system.
The inspectors interviewed Construction and Operation personnel involved in the event and reviewed out-of-service and shift engineering logs, procedures, and equipment outage checklists used during the outage for valves 1FW0llA and 1FWO11B (feedwater flow control valves).
The,. review revealed that:
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a.
An outage had been initiated for work on valves 1FW0llA and B.
b.
An outage had also been initiated on the "C" and "D" con-
densate and condensate booster pu=ps.
This outage was co=pleted on January 10, 1979.
In order to verify ce=ple-tion and adequacy of the work perfor=ed, the
"C" condensate and condensate booster pu=ps needed to be started.
c.
In order to start and run "C" condensate and con,asate booster pumps portions of the syste= covered in the outage for valves IFW0llA and 1FWO11B needed to be returned to service. The cognizant Construction engineer in charge of the work was apparently unaware of the status of valves 1FW0llA and B and requested the Shift Engineer to release the outage for the 1FW0llA and B valves. The outage was then cleared by the Shift Engineer on valves 1FW0llA and B in order to start "C" condensate and condensate booster pumps. The cognizant Construction engineer verified that all personnel were clear of the area at the time that the out-of-service tags were removed. However, he did not verify that the outage on 1FW0llA and B had been completed or that the work area had been lef t in a safe configuration.
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d.
When "C" condensate and condensate booster pumps were started, water sprayed through the partially disassembled 1FWO11A and B
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valves covering the floor area with about three inches of water.
During discussions with the licensee, the licensee stated that it was the implied intent of the out-of-service tagging procedure, that the Construction engineer in charge of the work was required to verify that the work area was left in a
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safe configuration as well as verify that all personnel were
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cleared of the area.
The licensee stated that since FSAR
Table 3.2-1, " Structures, Equipment, and Component Classifi-cations", does not require the feed and condensate system to the Q'uaiity Assurance requir.e=ents of 10 CFR Part 50, meet Appendix B, then the NRC should not have concerns related toa these systems and components.
This matter will be reviewed
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further to determine if the feed and condensate system is exempt from 10 CFR Part 50, Appendix B, requirements.
This is an Unresolved Item (373/79-06-07) pending completion of this review.
9.
Facility Tour The inspector toured the refueling area on January 30, 1979.
The air at that time was heavily charged with dust, grinding and welding
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fumes, etc. The fuel received as of January 30',~ 1979, has remained sealed in its protective plastic bag, therefore, the inspectors had no concern as to its cleanliness. The inspector stated the area as found was considered to be unacceptable for fuel inspec-tion and channeling when the plastic bags have to be removed.
No other concerns were identified.
10.
Unresolved Items Unresolved Items are matters about which more information is required in order to ascertain whether they are acceptable items, Items of Nonco=pliance or Deviations. Unresolved Items disclosed during the inspection are discussed in Paragraph Sc Se and 8d.
11.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on February 8, 1979. The inspectors su=marized the purpose and the scope of the inspection and.the findings.
The licensee representatives:
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Acknowledged the statements by the inspectors with respect:
to the Items of Noncompliance (Paragraph 5, 6, and 7).
b.
Stated that the requirements of level "A" cleanliness as
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floor area prior to removal of the plastic liners nn the fuel for fuel inspection and channeling (Paragraph 9).
c.
Stated that a method to ensure the battery chargers meet the requirement to charge each battery to at least 95%
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capacity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, including a definition of what constitutes 95% capacity, will be developed (Paragraph 2).
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