IR 05000373/1988010

Insp Rept 50-373/88-10 on 880324-0425.Violations Noted.Major Areas Inspected:Defueling Activities

ML20151Z964
Person / Time
Site:	LaSalle
Issue date:	04/29/1988
From:	Azab B, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151Z951	List: IR 05000373/1988010 ML20151Z947 ML20151Z959
References
50-373-88-10, NUDOCS 8805060022
Download: ML20151Z964 (7)

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U.S. NUCLEAR REGULATORY Com ISSION REGION III ,

Report No. 50-373/88010

, Docket No. 50-373 License No. NPF-11 Licensee: Comonwealth Edison Company P.O. Box 767 Chicago, IL 60690 '

Facility Name: LaSalle County Station, Unit 1 Inspection At: LaSalle Site, Marseilles, Illinois

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' Inspection Conducted: March 24 through April 25, 1988 ,

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Inspector: Beth A. Azab 28 88

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Approved By: Monte P. Phillips',' Chief f 8- !

Operational Programs Section Dat'e / !

Inspection Sumary

Inspection on March 24 through April 25, 1988 (Report No. 50-373/88010 (DRS))

. Areas Inspected: Routine announced safety in'spection of defueling activities .

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Results: One violation was identified for failure to follow shift change and ,

log keeping procedure ,.

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s DETAILS Persons Contacted

'_ Commonwealth Edison Company

• Diede' rich, Station Manager

• D. A. Brown, Quality Assurance Superintendent

• Cray, Instrument Maintenance Department, Lead Foreman

• R. Huntington, Serviceu Superintendent

+ F. Manning, Assistant Superintendent, Technical Services

• J. Marcis, Site Engineering Supervisor

• V. Masterson, Fuel Handling Foreman

• A. McVey, Technical Staff, Assistant Lead Nuclear Engineer

+ Miller, Technical Staff, Lead Nuclear Engineer

+^ C. Renwick, Production Superintendent

+* Schmeltz, Assistant Superintendent of Operations

+* C. Settles, Regulatory Assurance U.S. NRC

+* A. Kopriva, F.esident Inspector

+ R. Rescheske, Reactor Safety Inspector

+ C. Wright, Chief, Operations Branch The inspector also interviewed other licensee personnel during the course of the inspection including members of the operations and technical staf * Denotes persons attending the exit meeting of April 5, 198 + Denotes persons attending the second exit meeting of April 21, 1968, held via teleconferenc . T.,uesing Activities The inspector reviewed a number of completed procedures relating to defueling activities for procedural adequacy and compliance with Technical Specifications, particularly Section 3/4.9 which deals with refueling operations. The following procedures were reviewed and found adequate:

• LFP-100-1, "Master Refuel Procedure, Revision 1 * LTP-1100-6, "Duties of the On-site Nuclear Observer," Revision 6

• LTP-1600-26, "General Procedure for Fuel Transfers within the Station," Revision 12 and Attachment C: "Nuclear Component Transfer List," completed March 26, 198 * LFS-100-4, "Core Alteration Shiftly Surveillances," Revision 6, performed March 19-23, 198 .

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• LAP-100-29, "Refuel Platform Main Hoist Interlocks Check for Core Alterations," Revision 3, performed March 25, 198 * LOS-AA-S1, "Unit 1 Shiftly Surveillance," Revision 23, performed March 19-23, 198 * LIS-NR-301, "Unit 1 Source Range Monitor Rod Block Functional Test Data Sheet (Unit 1 NOT in "RUN" Mode)," Revision 4, performed March 19, 198 * LIS-NR-302, "Unit 1 Intermediate Range Monitor Rod Block and Reactor Scram Functional Test Data Sheet (Reactor in Startup-Shutdown-Refuel Modes)," Revision 5, compler.ed March 18, 198 * LIS-NR-303, "Unit 1 Average Power Range Monitor Rod Block and Scram Functional Test," Revision 7, completed March 18, 198 The inspector witnessed defueling activities on the refuel floor performed by both refueling crews and in the control room during day shift. The fuel was handled safely and in ac:ordance with written procedure Communications between the refuel bridge and control room were very good:

The control room was informed of stach separate fuel handling step performed. The inspector also observed good housekeeping practices on the refueling bridge and near the open reactor cavity.

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The inspector identified two concerns in the area of radiological P.ontrols which were referred to regional radiation protection inspectors who were on site at the time of tre inspectio Two Area Radiation Monitors (ARM) located on the refuel floor bad calibration stickers that were older tt.an the required 18 month calibration perio One ARM 5ad a calibration sticker dated 198 The licensee produced the calibration data sheets for the ARMS which were performed within the spei:ified time period. The licensee stated that they no longer uso calibration stickers and are in the process of removing them when the instrument is calibrated, The inspector observed licensee personnel in street clothing leaning over a railing that acted as the barrier between a clean and contaminated area to observe fuel movements on the refuel floo The top of the railing had magenta and yellow tape on it and

! contaminated area signs were posted on the side of the railin No violations or deviations were identified in this area.

! Intermediate Range Monitors Operability l During defueling activities the licensee had two Intermediate % nge

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Monitors (IRMs) on the same trip system declared inoperable which is one more than allowed by Technical Specification 3.1.1. The following is a chronology of events:

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• March 13 'D' IRM read lower than the others on Range 10 during the reactor shutdown and was declared inoperable on the Degraded Equipment Log. After the reactor scram

'D' IRM read the same as the others, so it was not bypassed, but still declared inoperable. Because it was not bypassed some operations staff thought it had been upgraded from inoperable to degraded status,

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although an entry.was made in the Degraded Equipment Log (DEL) indicating that the 'D' IRM was inoperabl '

• March 15 'F' IRM was de'clared inoperable and bypassed because it spiked high and caused a spurious half scra There are a total of eight IRMs, four per trip system; with both 'D' and 'F' IRM on the same trip syste The plant was in Mode 4, and was required to have two

. operable IRMs per trip system per Technical Specification 3. * March 17 The plant entered Mode 5 (Refueling Mode) and was required per Technical Specification 3.3.1 to have three operable IRMs per trip system. However, both

'D' and 'F' IRM were still declared inoperable,

• therefore only two IRMs were operable on trip System B. The action for having less than the number of IRMs required is to suspend all operations involving core alterations and insert all insertable control rods within one hour. All control rods remained inserted since the scram on March 1 * March 19 Core alterations began, cor.trary to the action statement of Technical Specification 3. * March 25 Instrument Mechanics (IMs) requested permission to perform their weekly functional tests on the IRM The SCRE then realized that two IRMs were entered inoperable on the DEL and started to investigat Core alterations were suspended because operating personnel realized they were not in compliance with Technical Specification'3. The IMs inspected 'F' IRM and found a loose connector, which could have caused the spikin 'F'

IRM passed its functional test end was declared operable and core alterations were commence The IMs performed both a calibration and functional test on 'D' IR The calibration as-left and as-found values remained unchanged and the functional test passed.

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• March 28 'D- IRM was upgraded from inoperable to degraded status pending a calibration during startup testin The basis for the upgrade was a passed functional test and no detection of abnormalities during calibration and trouble-shootin The purpose of the IRMs during Refueling Mode is to provide a rod block function which is an automatic protection against an operational error, such as pulling two adjacent rods and obtaining an. inadvertent criticality. The IRMs dc not provide a count rate during refueling; Source Range Monitors -(SRMs) provide that function. The Technical

, Specification definition of operability states that a component or device is operable when it is c@able of performing its intended functio Since no adjustment was made to 'D' IRM between the time it was declared inoperable and the time it passed the IRM functional test, Surveillance LIS-NR-302, .and it was never placed in bypass; there is a question as to whether '0' IRM was ever technically inoperable (incapable of performing its intended function). Because '0' IRM was probably always operable, as indicated by an instrument calibration and functional tests performed, a violation of Technical Specification 3.3.1 did not exis The main concern with this incident was that of procedural and administrative errors that resulted in a Mode change without the required instrumentation operable and, more importantly, operating personnel not aware that they were in noncompliance with Technical Specifications for eight day As corrective action, the licensee wrote a draft procedure to verify compliance with Technical Specification requirements prior to Mode change from Condition 4 to 5. The %cident was partially due to the fact that some operating personnel were unaware that the IRM operability requirement went up for a Mode 4 to 5 change, where most equipment requirements normally become less restrictive when coming down in Modes. The draft procedure was comprehensive in that it addressed all the systems and components required for Mode 5 and should prevent another Mode 4 to 5 change without the required equipment operable, s However, the writing of a Mode change procedure did not address the fact that several operating procedures were previously in place to verify that Technical Specification requirements for equipment operability were being met, but these procedures were not followed. Procedure LAP-200-3,

"Shift Change," Revision 15, required both the off-going and on-coming Shift Engineers to review the DEL. It also required the on-coming SCRE to review and discuss the DEL with the off-going SCRE. Both 'D' and 'F'

IRMs were listed as being inoperable it the DEL in Mode 5 for eight days without any operating personnel discovering it in their shiftly reviews of the DEL. The procedure also instructed the off-going Shift Engineer to log in the Shift Engineer's Log when it was declared inoperabl Procedure LAP-220-2, "Unit Operators' Log," Revision 13, stated that the log should include a descriptive chronology for the main events of the

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shift, such as, new OEL entrie The 'D' IRM DEL entry was not documented in either the Shift Engineer's Log or the Unit Operators' Lo Procedure LAP-220-4, "0egraded Equipment Log," Revision 2 required the Operating Engineer review the DEL weekly "to ensure that Technical Specification requirements are being met . . ." and to document this review by making a line entry in the DEL. The Operating Engineer signed the DEL signifying that he reviewed it on March 11 and 25, thereby missing a weekly review signature during the eight day period in question, and not ensuring Technical Specification requirements were being met as instructed by procedur The above examples are considered a violation (373/88010-01(DRS)) of Technical Specification 6.A.2.1, which states that written procedures shall be prepared, approved and adhered t . Corrective Actions The inspector reviewed the additional corrective actions discussed in the exit meeting conducted on April 21, 1988, with operations personnel at the site on April 25, 1968. The additional corrective actions were a result of the licensee's investigation of the inciden The licensee is making the following revisions to Procedure, LAP-220-4, "Degraded Equipment Log,"

Revision 3:

• Instructions to place red tags on inoperable technical specification or safety related equipment on control room switches and indicators are being incorporated into the procedure. The tags will clearly designate to the operators during panel walkdowns the equipment that is inoperabl * The Operating Engineer's weekly DEL review is being expanded to allow other off-shift personnel, who were not responsible for maintaining the log, to review the DEL for compliance with Technical Specification requirement * Attachment B of the procedure is being revised to add spaces for documenting changes in equipment status, and documenting the date and time red tags on inoperable equipment have been placed and remove * Attachment F of the procedure is being revised to require operating personnel to clearly delineate whether the equipment is inoperable or degraded. Also, the dates red tags are placed and removed will be logged on this attachmen * A new Attachment, I, "0egraded Equipment Status Change History," is being created to clearly track status changes of equipment and provide reliable information to the operating staff concerning the status of equipmen _

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The operating staff will be trained on the revisions to the DEL procedure and the use of red tags either in pre-shift briefings or by a required reading packag The licensee is also considering reformatting their Technical Specification Surveillances to help eliminate possible noncompliances with Technical Specifications. The text of the required steps will be moved to the Attachments, so that it is on the back of the page preceding the data. The location of the text will not interfere with the data, and will allow the requirements to be readily available to both the data taker and reviewer. The surveillances will also be broken down by operating modes to eliminate possible errors regarding different requirements for the various modes, and excessive use of N/A's when in a mode where the surveillance is not applicable. The licensee's Weekly Technical Spacification Surveillance procedure has been reformatted and is currently undergoing a trial period. Daily and Shiftly Technical Specification Surveillances may be reformatted, pending the results of using the new Weekly Surveillanc The above corrective actions will be further reviewed by the NRC during followup of the violation identified in this report as appropriat No violations or deviations were identifie . Quality Assurance Effectiveness The inspector interviewed Quality Assurance personnel during the inspection. Two Quality Assurance personnel witnessed defueling activities performed by both defueling crews. An audit of the completed refueling procedures was expected to be performed after the completion of refueling activities which would include a check for Technical Specification requirements and surveillances. The violation previously discussed could not have reasonably been expected to be identified by the Quality Assurance organization and their review of refueling activities appeared to be adequat . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection on April 5, 1988, and summarized the scope and findings of the inspection. The licensee acknowledge the statements made by the inspector with respect to the violation (denoted in Paragraph 3). 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 stated that no material reviewed by the inspector was considered proprietar A second exit meeting was held on April 21, 1988, via teleconference, to discuss the licensee's corrective actions for the IRM operability incident. Details of the corrective actions are discussed in Paragraph 4, 7