IR 05000373/1986030

Insp Repts 50-373/86-30 & 50-374/86-31 on 860722-24.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings & Electrical Activities, Including Work Requests

ML20205B034
Person / Time
Site:	LaSalle
Issue date:	08/05/1986
From:	Falevits Z, Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20205B009	List: IR 05000373/1986030 ML20205B004
References
50-373-86-30, 50-374-86-31, NUDOCS 8608110506
Download: ML20205B034 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-373/86030(DRS);50-374/86031(DRS)

Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690 Facility Name: LaSalle County Station, Units 1 and 2 Inspection At: LaSalle Site, Marseilles, Illinois Inspection Conducted: Jul 22-24, 1986

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Inspector: ZelTg Falevits f/5/f6 Date d%d Approved By: James W. Muffett B/k8b Date I_nspection Summary Inspection on July 22-24, 1986 (Reports No. 50-373/86030(DRS)1 50-374/86031(DRS))

Areas Inspected: Routine unannounced inspection of licensee action on i previous inspection findings, inspection of electrical activities including work requests and documentation of lifted leads and temporary jumper Modules 92701, 92702 and 51055 were employed during this inspectio Results: Of the areas inspected, no violations or deviations were identifie PDR ADOCK 05000373 G PDR

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e DETAILS 1. Commonwealth Edison Company (CECc)

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• G. J. Diederich, Station Manager

• R. D. Bishop, Services Staff Superintendent J. C. Renwick, Production Superintendent W. E. Sheldon, Assistant Superintendent Maintenance T. A. Hammerich, Assistant Tech Staff Supervisor

• J. L. Spangler, Electrical Maintenance Engineer R. J. Cozzi, Q.A. Engineer U.S. Nuclear Regulatory Commission (NRC)

• J. Jordan, Senior Resident Inspector J. C. Bjorgen, Resident Inspector R. A. Kopriva, Resident Inspector In addition to the above, other licensee and contractor personnel were contacted during this inspectio * Denotes the persons who attended the exit meeting on July 24, 1986.

2. Action on Previous Inspection Findings (Closed) Violation (373/85026-01): During a previous inspection conducted in August,1985, the in::pector noted that Unit 1 drywell temperatures near safety-related components exceeded Technical Specification 3.7.7. limits, and the environmental qualification requirements, this condition existed for at least seven months. The licensee's original correlation study used to assure compliance with the temperature limitations imposed by the Technical Specifications and E.Q. requirements was found to be erroneous. Also during the original violation, the containment monitoring recorders in the control room did not alert the plant staff to the excessive drywell temperatures. A special report to the commission required by T.S. 3.7.7, was not submitte The inspector reviewed the corrective action taken by the licensee to resolve the deficiencies previously identified by the inspecto The licensee has subsequently forwarded a special report to document all temperature excursions which occurred during the period January 1984 to August 1985. (DVR 1-1-85-166). The licensee has issued a permanent station procedure (LTP-300-17)

to clearly define data gathering, handling, and reporting requirement .

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Environmental qualification limits were recalculated to correlate more closely with the 150 F limit in Technical Specification 3. The licensee also evaluated the remaining qualified life of components that have exceeded the previous environmental qualification threshold limit temperatures. During the Unit 1 ;

refueling outage the licensee located the cause of the local hot l spots in the vicinity of the SRV's and implemented various i modifications to correct the proble Licensee's corrective actions in this area were found to be adequate to maintain the drywell temperatures to within Technical Specifications and E.Q. limits, presuming that applicable procedures are followe b. (Closed) Violation (373/85026-03): This violation concerned licensee's failure to establish adequate surveillance and work procedures for monitoring drywell temperatures and evaluating the data note The inspector reviewed licensee's corrective action including a field inspection and a review of actual procedure implementatio The licensee has written station procedure LTP-300-17 to govern drywell temperature data collection and followup. Routine performance of activities controlled by this procedure is scheduled as part of the station general surveillance progra The procedure includes temperature trigger set points and guidelines for accelerated data gathering when higher than normal temperatures are encountered. The procedure also includes a mechanism for formal transmittal of temperature data to the engineering department for evaluation and approval of changes to the acceptance criteri The procedure also specifies required notifications and engineering evaluations to be performed if E.Q. limits are exceeded. In addition to issuing procedure LTP-300-17, the licensee has also revised the drywell close out procedure (LOP-DW-01) to require that the Maintenance Foreman in charge of the work perform an inspection of the work location when the work has been completed. This inspection will insure that work performed inside the drywell (such as insulation seal tight, hangers, and fire proofing on structural steel) will not result in any deterioration of equipment or components in the are (0 pen) Unresolved Item (374/8404-03): This item concerned sensing lines to instruments, 2PDI-VY009 and 2PDI-VY026, which were observed by the inspector to be disconnected, while test reports indicated that these instruments were verified to be connected and back in service. These pressure differential indicators are classified as nonsafety-related, however they are mounted inside safety-related racks. The inspector raised the concern that since these devices are classified nonsafety, (not requiring category I, QA/C.C. review)

and are mounted inside safety-related racks, any work performed on the nonsafety devices might affect the safety-related portion

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of the panel. Therefore, consideration should be given to classifying the work performed on the nonsafety devices mounted on safety-related equipment as safety-related work so that QA/QC review will be require During this inspection the inspectors discussed this matter with the licensee. The licensee indicated that several available engineering options are being considered to resolve this issu The licensee stated that the inspector will be informed as to the resolution of this issue pending licensee action, this item remains unresolve (Closed) Violation (373/85039-01;374/85040-01): The original violation found that the licensee failed to document correctly or omitted documenting electrical jumpers on terminations which were shown on schematic and connection diagram Required jumpers were documented as N/A on the station traveler and consequently were not appropriately identified and inspected. In addition, the inspection records failed to reference a schematic drawing or a connection diagram and revision and/or date as required. During this inspection the inspector examined licensee's corrective action in response to this violation which included a comprehensive review of all records generated during the initial stages of the inspection of limitorque valve motor operator The licensee noted that all discrepancies in the inspection packages were identified and corrected. An actual reinspection of the valves in the field was conducted by the licensee to resolve the discrepancies noted during the review. Further guidance was developed by the licensee to document all jumper inspections. During the reinspection, the licensee replaced several jumper wires which were not clearly identifie . Subsequent to the NRC inspection, all inspections performed have utilized the revised documentation requirements. The inspector selected three limitorque valves for inspection of this functional area (see Paragraph 3 for details). The licensee's actions in this area are adequate to close this ite (Closed) Violation (374/85013-05 (Part b)): During a previous inspection the inspector noted that Logic Diagram M-5444 sh 2, dated tune 15, 1977, did not contain the " Caution" stamp required by pro;edure LAP-810-5 on all drawings which are not to be used for maintenance, operation, design, or other activitie Corrective action taken by the licensee included a review on Logic Block Diagrams contained in the Central File Facilit Only one discrepancy was noted out of a total of greater than 200 Logic Diagrams reviewed. This appears to be an isolated occurrence. The licensee's actions in this area are adequate to close this ite (0 pen) Violation (374/85013-05 (Part a)): This item concerns lifted lead No. LL130 which was shown as restored to normal on the Temporary System Change Log although the lead was observed

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by the NRC inspector to be lifted and tagged inside the pane During this inspection the inspector selected several entries in the licensee's Temporary System Change Lo a comprehensive review of the items selected (g and conductedrefer to Para 3. Review of Maintenance Work Activities _ _(Work Reguests) The inspector selected several completed Work Request (WR)

packages for review of applicable procedures and drawings used and adequacy of work and test performed. The following packages were reviewed and field inspected:

(1) Work Request No. 52547 dated November 8, 1985, associated with inspection conducted to verify internal wiring in limit switch compartment of "Drywell Vent and Purge Outbound Isolation Valve 2VQO35."

Station Traveler dated November 5,198 Procedure LAP-1300-1 Revision 27, Attachment "D" dated November 13, 198 Procedure LAP-1300-1 Revision 27, Attachment "J" dated November 19, 198 Procedure LEP-GM-102 Revision 8, dated November 8, 198 Procedure LEP-GM-124 Revision 0, dated November 8, 198 * Post Maintenance Electrical Tests, dated November 5, 198 Int / Ext. Wiring diagram 1E-2-4392AD, Revision "L."

Schematic diagram 1E-2-4096AB, Revision "E."

Documentation associated with this package appeared to be complete in documenting inspection results, QC reviews, and tests performe Discrepancies identified during this inspection were noted on a comment sheet attached to the station traveler which also documented the proposed resolution and corrective action take The inspector conducted a visual inspection of various components using the schematic and connection diagram to determine if field installation conformed to the design drawing requirements, and to review the implementation of the requirements of WR No. 52547. No apparent deficiencies were noted, Work Request No. 52489 dated October 10, 1985, associated with inspection conducted to verify internal wiring in limit switch compartment of " Reactor Water Cleanup Isolation Valve 2G33-F001."

The inspector reviewed the following associated documents:

Station Traveler dated November 26,198 .

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M0V Wire inspection checklist dated December 10,198 Figure 9, maintenance / modification procedure dated October 21, 198 Procedure LAP-1300-1 Revision 27, Attachment D dated November 2, 198 Post maintenance Electrical Test dated November 25,198 Post maintenance Checklist LAP-1300-1 Revision 27, Attachment "J" dated December 10, 198 * Procedure LEP-GM-102 Revision 8, dated October 7, 198 Procedure LAP-810-11 Revision 14, dated November 5, 198 Comment and discrepancy shee Int./ Ext. wiring diagram 1E-2-4391AE Revision Schematic diagram 1E-2-4228AK Revision Electrical Installation drawing IE-2-3525 Revision Documentation associated with this package appeared to be complete in documenting inspection results, Q.C. reviews, and tests performe During the field inspection and review conducted, the inspector noted that limit switch contacts No. 4, No. 7, and No. 8 have been wired in a loop configuration that is No. 4 to No. 7, No. 7 to No. 8, and No. 8 back to No. Although the field wiring conforms

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to the wiring shown on wiring diagram 1E-2-4391AE Revision P, this configuration might lead to problems if the valve circuitry is modified in the future. The inspector informed the licensee of his concern. The licensee indicated that he will refer this item to its engineering department for review and resolutio c. Work Request No. 52489 dated November 23,1985, associated with inspection conducted to verify internal wiring in limit switch compartment of "Drywell Cooling Outboard Isolation Valve

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2WR029." q The inspector reviewed the following associated documents:

Mov Wire Inspection Checklist dated November 23, 198 Procedure LEP-GM-102 Revision 8, Attachment A dated October 7,

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Procedure LAP-1300-1 Revision 27, Attachment J dated November 23, 1985.

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Station Traveler dated October 23, 198 Post Maintenance Electrical Tests dated November 2, 198 Procedure LAP-1300-1 Revision 27, Attachment "D" dated November 1, 198 Int / Ext. Wiring diagram 1E-2-4388AD Revision "J" Schematic diagram 1E-2-408ZAF Revision "F" Documentation associated with this package appeared to be complete in documenting inspection results, Q.C. reviews, and tests performe During the field inspection, the inspector noted that the field torque switch designations did not conform to the designations indicated on the schematic and connection diagrams. The licensee indicated that work request No. 59993 will be written to correct the discrepant switch designations. No further deficiencies were identifie The inspector noted that licensee's documentation and approach to resolution of identified deficiencies has been improve . Review of Temporary System Changes The inspector reviewed the licensee temporary system changes such as electrical jumpers and lifted leads as delineated in station procedure LAP-240-6 Revision 11, entitled " Temporary System Changes." The inspector selected entries No. 1-114-83, No. 1-143-83, and No. 1-790-84 from the Temporary System Change Log book located in the shift engineers offic The inspector conducted a field inspection to ascertain whether the log accurately reflects the field change The following conditions were observed:

(1) Attachment B of procedure LAP-240-6 Revision 4 log number 1-790-84 documented a temporary jumper installed in MCC 135X-1 compartment G4 between points X2 and OL. This jumper was installed on August 30, 1984. Field inspection indicated that the temporary jumper is placed in the proper position and is ;

properly tagged. This jumper was installed to bypass the thermal overload for valve 1G33-F040 (RWCU Return to Feedwater Isolation Valve) so that the thermal overload will not trip the valve during its operation. The inspector noted that a caution card was placed on the unit I switch controlling valve 1G33-F040 but Unit 2 switch for valve 2G33-F040 did not have the caution card placed by it to indicate to operator that the thermal overload is being bypassed. Subsequently, the licensee initiated the required documentation to place the caution tag on the Unit 2 switc L

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(2) Attachment B of procedure LAP-240-6 log number 1-114-83 documented lifted leads LL 241, 242, 243, 244, 245, 246, 247, 249, 250, 252, 253, 257, 258, 259, and 260 which were installed on March 23, 198 (a) LL 257 and 258 were placed on temporary jumper No. 320 located inside H Recombiner panel 2PLF3J compartment

CB1 (b) LL 241, 242, 243, 244, 245, and 246 were placed on both sides of the Raychem splice made to bypass the feed breaker which was found to be not qualified for the environmen The inspector questioned the fact that all the lifted lead tags were placed on either the temporary jumper (No. 320) or on the both sides of the Raychem splice and none of the leads were lifte (c) Unit 1 panel 1PLF3J contained an identical setup as the Unit 2 pane (d) Panel 1PLF3J contained a caution tag which referred to Jumper log No. 1-114-83. Attachment A of LAP-240-6 entitled Temporary System Change log Unit 1, but log entry on this attachment contained LL numbers from both Units 1 and (e) J 309, 310, 311, 312, 313, 314, 315, 316, 317, and 318 had been restored on Attachment B, log No.- 1-114-83 on December 3, 1985 and October 31, 1985 but Attachment A does not note date of restoration or authorization to restore these connection (f) Item F.1.e of procedure LAP-240-6 states that the

" Temporary System Change Form," Attachment B, is maintained in the shift engineer's office. During this inspection the inspector noted that the Attachment B, of log No. 1-114-83 was givcn to the craftsman for an extended period of time. Attachment "B" was not found in the log

during this inspectio (g) Procedure LAP-240-6 Paragraph (3.a.2) requires that a physical audit of all temporary changes more than one week old be conducted to assure proper installation as described l

by the appropriate Attachment B documentation. However,

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no required time interval for conducting this audit has been se (h) Paragraph 3, b and c of procedure LAP-240-6 requires that for temporary changes longer than three months the Tech

! Staff Supervisor perform an engineering evaluation to determine if a permanent modification should be mad <

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Presently there is no requirement for the Tech Staff engineers to formally submit their engineering evaluation to the shift engineer. This may allow temporary changes to exist for extended periods in violation of the intent of the procedur (i) The inspector noted that many so called temporary changes were installed in the field prior to 198 Many of these modifications are still in plac (j) During the inspection, it was discovered that certain temporary modifications (as delineated in the Temporary jumper log) were not identified on the associated aperature cards. The leads to a situation in which individuals referring to the aperture cards would not be aware of the Temporary jumper or modifications in progres This item is considered unresolved pending licensee and NRC further review (373/86030-01,374/86031-01)

5. Unresolved items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraph . Exit Interview The inspectors met with the licensee representatives at the conclusion of the inspection on July 24, 1986, and summarized the scope and findings of the inspection. The licensee acknowledged the statements made by the inspectors. The inspectors also discussed the likely infonnational

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content of the inspection report with regard to documents reviewed by the inspector during the inspection. The licensee did not identify any such documents as proprietary.

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