IR 05000373/1986046

Insp Repts 50-373/86-46 & 50-374/86-46 on 861230-870127. Violations Noted:Failure to Assure Procedure Adequacy & Failure to Maintain Sys Status

ML20211F811
Person / Time
Site:	LaSalle
Issue date:	02/14/1987
From:	Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211F769	List: IR 05000373/1986046 ML20211F765 ML20211F784
References
50-373-86-46, 50-374-86-46, IEB-82-02, IEB-82-2, NUDOCS 8702250202
Download: ML20211F811 (12)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-373/86046(DRP); 50-374/86046(DRP)

Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: LaSalle County Station, Units 1 and 2 Inspection At: LaSalle Site, Marseilles, IL Inspection Conducted: December 30, 1986 through January 27, 1987 Inspectors: M. J. Jordan R. A. Kopriva J. A. Malloy Approved By: . hief 2,dt/'s7 '

Reactor Projects Section 1C Date /

Inspection Summary Inspection on December 30, 1986 through January 27, 1987 (Reports No. 50-373/86046(DRP); 50-374/86046(DRP))

Areas Inspected: Routine, unannounced inspection conducted by resident inspectors of licensee actions on previous inspection findings; operational safety; surveillance; maintenance; training; Licensee Event Reports; unit trips; security; fire protection; refueling; and closing of IE Bulletin 86-0 Results: Of the 11 areas inspected, two violations (one with two examples)

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were identified in two areas (Failure to assure procedures are adequate and system status is maintained - Paragraph 3c and failure to adhere to procedures

- Paragraph 4b. ) The licensee's performance in following procedures and performing correct verifications continued to be a problem during this inspection. Failure to recognize systems not being operable also occurred during this inspection. The outage planning and scheduling has been effective such that the current refueling outage is on schedule.

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DETAILS Persons Contacted

• G. J. Diederich, Manager, LaSalle Station

• R. D. Bishop, Services Superintendent J. C. Renwick, Production Superintendent D. Berkman, Assistant Superintendent, Work Planning

• W. Huntington, Assistant Superintendent, Operations

• P. Mannicg, Assistant Superintendent, Technical Services T. Hammerich, Assistant Technical Staff Supervisor

W. Sheldon, Assistant Superintendent, Maintenance

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J. Atchley, Operating Engineer R. W. Stobert, Quality Assurance Supervisor D. Enright, Quality Assurance Engineer

• Denotes personnel attending the exit interview on January 27, 198 Additional licensee technical and administrative personnel were contacted by the inspectors during the course of the inspectio . Licensee Action on Previous Inspection Findings (92701)

(Closed) Open Item (373/8100-141): This open item tracked the NRC issued Order confirming licensee commitments on Emergency Response capability for LaSalle Unit 1 (dated February 21,1984) and the Unit 1 License Condition 2 No. 4, Attachment The licensee was required to implement the upgraded Emergency Operating Procedures (E0Ps).

In Inspection Report 374/86042, the inspector determined that the licensee's upgraded E0Ps were prepared and implemented in accordance with their NRC approved procedures generation package. This inspection identified additional open items; however, these open items are tracked in that Inspection Report (374/86042). This open item is considered closed.

j (Closed) Open Item (373/8100-140): This open item tracked the NRC issued Order confirming licensee commitments on Emergency Response capability for LaSalle Unit 1 (dated February 21,1984) and Unit 1 License

! Condition 2 No. 4, Attachment 2. The licensee was required to submit I

a procedures generation package to the NRC for upgraded Emergency Operating Procedures (EOPs). The licensee submitted the procedure generation package via a June 28, 1985, letter from H. L. Massin to l H. R. Denton. The submittal was completed via a July 30, 1986, letter i

from C. M. Allen to H. R. Denton. This item is considered closed.

l (Closed) SER License Condition 2.C.(25)(d) (373/8100-130): In l Inspection Report 373/86035, the remaining open portion of the license

! condition regarded the fire door stop modifications. Six questionable

! door stops existed. The licensee's Quality Control (QC) Department j inspector obtained a sample of an approved fire door stop and compared l the approved configuration to the six questionable field installed door

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stops. The QC inspector found the six configurations to be acceptabl The licensee also obtained an Underwriters Laboratories (U.L.) letter stating that the metal portion of the replacement seals conformed to U.L. listed specifications. NRR reviewed this issue and concluded that the installation of these six fire doors now conforms to applicable NRC fire protection guidelines and requirements and that the intent of license condition 2.C.(25)(d) has been satisfied with respect to these six doors. This item is considered close No violations or deviations were identified in this are . Operational Safety Verification (71707) The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the inspection period. The inspector verified the operability of selected emergency systems, reviewed tagout records, and verified proper return to service of affected components. Tours of Units 1 and 2 reactor buildings and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, excessive vibrations, and to verify that maintenance requests had been initiated for equipment in need of maintenanc The inspector, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the station security pla The inspector observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection control During the month of January 1987, the inspector walked down the accessible portions of the following systems to verify operability:

Unit 1 and 2 Hydrogen Recombiner Unit 1 and 2 Standby Gas Unit 2 Diesel Generator On December 20, 1986, LaSalle Unit 1 cleared the last of their control room panel annunciators / alarms, therefore, obtaining a BLACK BOARD. The station has been working toward this achievement since the Unit 1 startup in September after having been shut down for eleven months for a refueling / maintenance / modifications outag Unit 1 is currently at 90% of rated powe On January 3, 1987, at approximately 6:00 p.m., the licensee, while shutting the unit down for a 21 week refueling outage, performed a level drop test on the Static-0-Ring (SOR) level 3 switche The unit scrammed satisfactorily and all systems functioned as expected. The switches actuated from a low reactor vessel level of 10.3 inches to a high of 19.2 inches. The licensee checked the calibration on the level transmeter that corresponded to the 10.3 inch switch and found it to be reading low by approximately

.9 inches. Thus, the switch actuated at approximately 11.2 inches with a Technical Specification low limit of 11.0 inche _-

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On January 5, 1987, at 5:30 p.m. with the unit shut down and.at zero (0) pressure, the licensee performed their second reactor water level drop test. The level drop test was performed to check out the actuation of the Static-0-Ring switches used to initiate a reactor scram on low reactor water level. All switches performed as expected, ranging from 18.4 to 20.1 inches of wate The Technical Specification Limiting Condition for Operations (LCO)

for these switches-is 11.0 inches. The unit will remain shut down

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for the next 21 weeks as the licensee has just started their first refueling / maintenance outage on this uni On January 5,1987, at 6:10 p.m. CST, the licensee was performing the Unit 2 Division II 125 VDC battery discharge test (LTS-700-7).

A Degraded Equipment Log (DEL) entry on the battery charger was made at 8:20 a.m. on January 5,1987, when the battery charger capacity test was in progress and the Unit 1/ Unit 2 Division II 125V direct current (DC) buses were crosstied and a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time clock was in effect. The Shift Control Room Engineer (SCRE) did not make a DEL entry for the batteries being inoperable due to the discharge test, believing the batteries were already considered inoperable due to the surveillances being performed on the battery charge At 11:10 p.m. on January 5, 1987, a Technical Staff Engineer informed the Shift Engineer (SE) that LTS-700-7 was complete (the discharge test.) The Technical Staff Engineer supplemented the Battery Equalizirg Charges procedure LOP-DC-07 with hand written instructions so as not to exceed the battery charger amperage limiter while recharging the batterie On January 6,1987, at 7:55 a.m., the Division II battery was taken

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off float charge and placed on an equalizing charge per a Technical Staff handwritten instruction which was not part of the approved procedure. The Equipment Operator (E.0.) took individual cell specific gravities on the pilot cells of the battery and noticed they were very low (1.170 and 1.180), but assumed he was to follow the handwritten instructions and uncrosstie the unit DC buse The applicable Technical Specification limit was specific gravity greater than or equal to 1.195. Consequently the battery was degraded and should have been considered inoperable. At 8:06 on January 6, 1987, the crosstie breakers were opened. With the crosstie breakers open between Unit 1 and Unit 2 Division II and the Unit 2 Division II battery inoperable, the Unit 2 Division II DC electrical distribution system was inoperable but not declared inoperabl The Unit 2 Division II 125 VDC system supplies power to several systems needed for continued operation of Unit 1 including the Unit 2 Division II Diesel Generator (D/G) and the Unit 2 Standby Gas Treatment (SBGT) System initiation logic for starting these systems on loss of normal power and/or accident condition . _ . _ _ - - _ _ .. . . -.

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Between 7:55 a.m. and'11:08 a.m. on January 6, 1987, the licensee was performing a containment isolation surveillance LES-PC-202 for Unit This surveillance periodically auto starts both Standby Gas Treatment trains (Unit 1 and Unit 2). When the isolation signal was received as part of the surveillance, the procedure instructed the operator to place Unit 1 SBGT train control switch in pull to lock (PTL) which renders the system inoperable. This was done periodically throughout the surveillanc With the Unit 1 SBGT system inoperable in PTL and the Unit 2 Division II DC electrical distribution system inoperable, this presented a situation in which both SBGT systems would have been considered inoperabl The safety significance of this was minimal because the licensee was performing the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance run on the Unit 2 Division II D/G and whenever the Unit 1 SBGT system was in PTL, the Unit 2 SBGT system was running, therefore, not requiring the initiation logics for these system On the afternoon of January 6,1987, the licensee realized that the Unit 2 Division II batteries had been inoperable and not crosstied to Unit 1 Division II electrical system. A set of data was taken (specific gravity and voltage) on the inoperable battery. Based on this data and the Unit 2 Technical Specification table 4.8.2.3.2-1, footnote 2, the batteries were declared operable at 6:30 p.m. on January 6, 1987. A seven day time clock was entered because Table 4.8.2.3.1-1, footnote 2 allows operability provided parameters are restored to within limits within 7 day CFR 50, Appendix B, Criteria VI, " Document Control", states in part, "These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release

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... . 10 CFR 50 Appendix B, Criterion XIV, " Inspection, Test and Operating Status" requires measures be established for indicating the operating status of system Contrary to the above, LTS-700-7 and LOP-DC-07 were found inadequate in not declaring the Unit 2 Division II 125V batteries inoperable and in contributing to the loss of the status of the Unit 2 Division III electrical distribution system. This is considered a violation (374/86046-01(DRP)).

One violation with two examples was identified in the review of this functional are . Monthly Surveillance Observation (61726)

The inspector observed Technical Specification required surveillance testing and verified for actual activities observed that testing was performed in accordance with adequate procedures, that test instrumen-tation was calibrated, that limiting conditions for operation were met,

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that removal and restoration of the affected components were accomplished, that test results conformed with Technical Specification and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspector witnessed portions of the following test activities:

LOS-DG-M2 Unit 2 Diesel Generator Operability Test (2A D/G)

LOS-FP-M4 Units 1 and 2 Fire Protection Sprinkler and Deluge System Valve Lineup and Alarm Check LOS-DC-Q2 Unit 2 Charging Requirements and Battery Readings for the Safety Related 250 VDC and 125 VDC Batteries LOS-HG-SAI Unit 2 Post-LOCA Combustible Gas Control System Semi-Annual Functional Test LIS-NB-201 Unit 2 Reactor Vessel Low Water Level Scram and Primary Containment Isolation Calibration The following observations were noted: On January 5, 1987, at 11:40 p.m., the licensee initiated the performance of LTS-800-5 which is the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run of the Unit 2 "A" Diesel Generator (D/G). Upon completion of the 2A D/G 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run, the licensee is required to open bus #242Y which will simulate a bus undervoltage condition, and verify that the 2A D/G automatically starts and loads on simulated loss of offsite power. When the 2A D/G 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run was complete and the 2A D/G had stopped after being shut down, the 242Y bus was immediately deenergized per LTS-800-5. The 2A D/G did not automatically start as expecte The equipment operator noted that the starting relays picked up but the air start motors did not turn. The 2A D/G was declared inoperabl Portions of LOS-AA-WI, " Technical Specifications Weekly Surveillances,"

were performed to satisfy offsite power line up requirements for the 2A D/G being inoperable. After further investigation, it was found that the air start motors have a built in lock out feature when the diesel generator oil pressure is above a certain setpoin Because the attempt to start the diesel generator was performed immediately after the D/G shut down, the residual oil pressure was still above the lock out set point. Testing the D/G and the lock out relay revealed that it took approximately two to three minutes for the oil pressure to diminish enough to drop below the lock out relay set point. At that time the relay picked up and the D/G started as expected. Because prior testing of the D/G had not been performed in the past with as much expediency, this condition

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had not been revealed. The licensee has made the appropriate notations for this condition with respect to the 2A D/G, and is pursuing the possibility that this condition could be generic to the remaining D/G onsite as well as at other nuclear station The licensee's actions will be followed. -This is considered an openitem(374/86046-02(DRS)). On January 22, 1987, the licensee reported to the resident inspector a verification had been improperly performed on a valve lineup for a local leak rate test (LLRT). During the evening of

, January 17, 1987, a technical staff engineer performed a LLRT on

. a Unit 2 Low Pressure Core (LPCI) Injection Testable Check valve (2E12-F024A). Upon completion of the test, the Test Engineer reviewed the valve lineup sheet and found a stop valve to a pressure switch (2E12-F350A) had not been verified during the test nor during return of the valve to the original positio The Test Engineer was in the drywell for the test and had requested that an operator position three valves outside the drywell. The instrument stop valve was one of the three valves he requested to be repositioned. The operator outside the drywell did not understand that the stop valve was to be positioned and failed to position the stop valve in accordance with the procedure. The Test Engineer and an operator in the drywell, upon completion of the test, exited the drywell to perform the post test valve lineu The drywell operator did not realize the instrument stop valve needed to be checked and did not verify or reposition it. The Test Engineer checked the stop valve as being open and assumed the operator who exited the drywell with him had positioned it after the test before he got to the valve. Later in the evening, the Test Engineer discovered the missing signature for positioning of the valve during the test and after the test. He then initialed as the first verifier and falsely initialed another engineer as the second verifier. On January 18, the second engineer was reviewing the valve lineup and noted his initials for the valve which he did not verify. He confronted the Test Engineer on January 19, 1987, with the facts and the Test Engineer lined out the improper initials and requested another engineer to go out and verify the proper valve position. This third engineer proce which,eded was the to correct verify the currenthowever, position; valve position as was he also being open,into talked verifying that the valve was closed during the test which he had not witnessed and backdated both initials to Saturday the 17t The preceding discussion of events was uncovered as a result of the licensee's review of this issue.

i The licensee will reperform the LLRT on the valve, and has taken disciplinary action against the Test Engineer. The licensee has also counselled the third engineer on how to make proper verifications. Additional corrective action is currently under review. Improper verifications is a current concern with the licensee and an enforcement conference with the utility was conducted on this subject on February 13, 1987.

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-The instrument checkoff sheet for LTS-900-4, " Low Pressure Coolant Injection (LPCI) Pressure Isolation Valves Water Leak Test",

required the instrument stop valve (2E12-F350A) to be closeo and verified by two people. Technical Specification 6.2.A requires the licensee to adhere to detailed procedures, including checkoff list Item 7.in the lists of procedures of Technical Specification 6.2.A is for surveillance and testing requirements. Contrary to the above, the checkoff sheet for LTS-900-4 was not adhered to 'in that the instrument stop valve was not closed and verified by two people. This is considered a violation (373/86046-01(DRP);

374/86046-03(DRP)). This violation is under consideration for escalated enforcement action and, therefore, is not cited in the Notice of Violation accompanying this repor One violation and one open item were identified during review of this functional are . Monthly Maintenance Observation (62703)

During the inspection period, the inspector observed portions of the following maintenance activities:

The change out of the #111 valves on the Control Rod Drive (CRD)

Hydraulic Control Units (HCU's) #58-27, 22-55, 46-43, and 34-43 on Unit Alignment of motor driven reactor feed pump on Unit Control Rod Drive suction / drive filter change ou The following observations were noted:

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' On January 20, 1987, at approximately 2:25 p.m., the licensee reported the actuation of the emergency control room ventilation system. A contractor, who was pulling electrical cable for a

modification on Unit 2, bumped a breaker which caused the loss of power to two radiation monitors for the control room ventilation system. Upon loss of the radiation monitors, the emergency control

! room ventilation system started. The cause of the problem was identified and normal control room ventilation was restored by 2:40 p. No other systems actuate The inspector discussed with the licensee the controls on erecting scaffolding over or around safety related equipment. The licensee does not perform any engineering evaluation as to the effects of the scaffolding failure during a seismic event nor does the licensee know what the consequences of a failure may have on the operability of safety equipment. The licensee has forwarded this issue to their i corporate office for review and corrective action. The controls

on scaffolding erection around safety equipment and/or the engineering evaluation as to the effects of the failure will remain l an open item (373/86046-02(DRP); 374/86046-04(DRP)).

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. The resident inspector also discussed with the licensee the controls over manual closure of.a valve with a limitorque operator. When a valve was given a close signal remotely, the limitorque setting-closed the valve onto its seat-with a set force depending on the closure limitorque setting. 'If the valve had some seat leakage, the licensee may authorize the valve to be closed down further using the manual operator in lieu of the limitorque operato Since closure of the valve using the manual operator does not-limit the seating force, the inspector questioned whether the valve can,still be considered operable because the opening torque may not be sufficient to lift the valve off its seat. The licensee is evaluating the actions to be taken when using the manual operator on valves with a limitorque operator. This will remain as an open item (373/86046-03(DRP); 374/86046-05(DRP)).

No violations or deviations were identifie . Training (41400)

The inspector, through discussions with personnel and a review of training records, evaluated the licensee's training program for operations and maintenance personnel to determine whether the general knowledge of the individuals was sufficient for their assigned task In the areas examined by the inspector no items.of concern were identifie No violations or deviations were identifie . Licensee Event Reports (92700)

Through direct observations, discussions with licensee personnel, and review of records, the following Licensee Event Reports (LER's) wen reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specification (Closed) 374/86019-00 - S0R switch LS-2821 N038A used for Reactor Low Level confirmed ADS permissive was found out of tolerance in excess of the reject limit. The switch was replaced with a new calibrated switc (Closed) 373/85066-01 - The Unit 1 feedwater check valve (inboard valve

, 1821-F010A) failed its Local Leak Rate Test. The valve was repaired j and local leak rate tested again. The subsequent leakage test was j acceptable.

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(Closed) 373/86043-00 - Unit scram. A half-scram was present on "A"

, channel of Reactor Protection System (RPS) due to surveillance when a second half-scram was received on "B" channel of RPS due to spurious upscale spike from the main steam line process radiation monitor.

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(Closed)_373/86042-00 - During performance of LOS-HP-Q1 (HPCS Inservice Test), the HPCS water leg pump discharge check valve failed to close on reverse flow as designed. The valve was disassembled, cleaned, reassembled, and successfully cycled. The cause of the valve not closing was an accumulation of magnetite on the valve dis (Closed) 373/86041-00 - Reactor Water Cleanup (RWCU) isolation due to spurious differential temperature signal. The signal that caused the isolation cleared immediately. When it was determined that no leaks existed, the RWCU system was restarte (Closed) 374/86018-00 - A Static-0-Ring (SOR) differential pressure switch used for Reactor Core Isolation Cooling steam line high flow isolation failed. The SOR switch had a tear in the diaphragm. The switch was replace No violations or deviations were identifie . Unit Trips (93702)

On January 26, 1987, at 11:35 a.m. (CST), Unit 1 scrammed from approximately 88% power. The scram was due to a turbine tri Initial investigation indicated that the turbine tripped due to high excitation of the generator. All systems functioned as expected. No other ECCS actuations occurre No violations or deviations were identifie . Security (71707) I On January 9,1987, at 1:40 p.m. CST, a Commonwealth Edison employee noticed an odor on a contractor's clothing and suspected that the person had used or been around someone smoking marijuana. At that time, security was informed and the person questioned. No drugs were found. The person was asked to submit to a urine test. The person indicated he was willing to take the test and proceeded to leave the site with intentions of going to the local clinic. As soon as the person was outside of the main access facility (protected area), the person indicated he did not want to take the test and decided to qui Security immediately pulled his badge, terminating site access and has placed the person on securities' list of persons not allowed access to the sit On or about January 23, 1987, a contractor contacted station security personnel to inform them that some contractor personnel were bringing alcoholic beverages on site via refilled soda bottles. Station security notified the inspectors of this condition and of their corrective / compensatory measures. The security force has also been asked to increase their observations of personnel in the plant who may be under the influence or otherwise unfit for duty. The resident

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inspector will follow up on the actions of the security force pertaining to this subject during the remainder of the Unit 2 refuel outage. The licensee's actions, to date, appear adequate and responsiv No violations or deviations were identifie . Fire Protection (64704)

On January 22, 1987, at approximately 9:00 p.m., the inspector witnessed a routine fire drill. The drill simulated a wood fire in the turbine building. Observations included control room activities for initiation of the drill and the response and actions of the fire brigade as they responded to the alarms. The drill was executed wel No violations or deviations were identifie . Refueling (71711)

The inspector observed portions of the defueling of the Unit 2 reactor core. The entire core load was unloaded. Operation of the fuel moves, communications between the defueling personnel and control room, and documentation of the defueling were executed wel The refueling outage will consist of fuel exchange and some major modifications such as replacement of the primary containment isolation dampers, alternate rod insertion, increased drywell cooling, inspection of the feedwater headers, and some ISI and IST inspection No violations or deviations were identifie . Closed IE Bulletin 86-02 (92703)

On January 22, 1987, the licensee submitted results, conclusions, and long term actions pertaining to the Static-0-Ring switches. With regard to IE Bulletin 86-02: Static-0-Ring differential pressure switches, the licensee had previously responded to all items requiring response except for " Actions Required of All Licensees", item #6, long term corrective actions to be take The licensee has formally submitted a long term corrective action plan for review, therefore, completing their commitments of IE Bulletin 86-02. This item is close No violations or deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in paragraphs 4 and .-

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14. Exit Interview (30703)

The inspectors met with licensee representatives (denoted in Paragraph 1) throughout the month and at the conclusion of toe inspection period and summarized the scope and _ findings of the inspection activitie The licensee acknowledged these findings. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents or processes as proprietar .

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