IR 05000373/1988012

Insp Repts 50-373/88-12 & 50-374/88-11 on 880404-06 & 0503. Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings & Drywell Temp Monitoring Program Review

ML20196J324
Person / Time
Site:	LaSalle
Issue date:	06/28/1988
From:	Falevits Z, Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20196J248	List: IR 05000373/1988012 ML20196J242 ML20196J307
References
50-373-88-12, 50-374-88-11, NUDOCS 8807060360
Download: ML20196J324 (6)

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U.S. NUCLEAR REGULATORY C0?HISSION

REGION III

Reports No. 50-373/88012(DRS);50-374/88011(DRS)

Docket Nos. 50-373; 50-374 Licenses No. NPF-11;_NPF-18

' Licensee: 'Comonwealth Edison Company Post Office Box -767 Chicago, IL 60690 Facility Name: LaSalle County. Station, Units 1 and 2 Inspection At: LaSalle Site, Marseilles, Illinois Inspection Conducted: April 4-6 and May 3,1988 Inspector: Zeli W

Falevits Date

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k b 8 Approved By: Ronald N. Gardner, Chief P1 ant Systems Section Date Inspection Summary Inspection on April 4-6 and May 3, 1988 (Reports No. 50-373/88012(DRS);

'No. 50-M4/880ll(DRS))

Areas Inspected: Routine, announced safety inspection of licensee action on previous inspection findings; and drywell temperature monitoring program review (92700, 92701, 92702, 41400).

Results: ' Of the two areas inspected, no violation or deviation was identified in one area; ane violation with two examples (Paragraphs 3.b and .c): (1)

failure to promptly correct a potential significant deficiency for more than five months; and (2) failure to obtain and transmit temperature data to BWRED for evaluation on a daily basis when trigger set pointt were exceeded; and one violation (Paragraph 3.d)-for failure to submit a Special Rep'+ within the time frame required by Technical Specification 3.7.7.a were identified in the remaining area.

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8807060360 880628 PDR ADOCK 05000373--*

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DETAILS Persons Contacted CommonwealthEdisonCompany(CECq),

• J. Diederich,. Station Manager

• R. Huntington, Services Superintendent -

• D. A. Brown, QA Superintendent

• T. A. Hamerich, Technical Staff Supervisor

• W. J. Marcis, Site Engineering Supervisor

+*M. Richter, Technical Staff Supervisor

+*A. M. Lucietto, Technical Staff Environs

• C. Sprunger, Technical Staff Environs

• A. C. Settles, Regulatory Assurance U.S. Nuclear Regulatory Commission (USNRC)

• A.-Kopriva, Resident Inspector in addition to the personnel listed above, other licensee and contractor personnel were contacted during this inspectio * Denotes personnel attending the April 5,1988 interim exit intervie + Denotes personnel attending the May 3, 1988 exit meetin . Action on Previous Inspection Findings (Closed) Unresolved Item (374/84004-03(DRS)): This item concerned the misclassification and lack of review requirements of work performed on nonsafety-related components mounted in safety-related cabinets. Subsequently, LaSalle "Work Request" Procedure LAP-1300-1 was revised to assure that proper measures were being taken to control ,

work performed on non-safety components mounted in safety-related cabinets. The inspector reviewed Revision 38 of Procedure LAP-1300-1 and found the corrective action taken to be acceptable, (Closed) Unresolved Item (373/85026-02(DRS): This item related to the licensee's untimely action taken to evaluate the anomalies and test results of three representative cables taken from the drywel The cables were tested under loss of coolant accident conditions to determine their suitability for use at LaSall During a previous inspection, the inspector noted thet the test results were received in February 1985; however, as of August 1985, no action had been taken to evaluate the test results. During this review, the inspector was informed by CECO that the anomalies noted resulted due to the fact that S&L engineers submitted the wrong acceptance criteria for the tes The test results were subsequently justified through an analysis performed by S&L. This analysis concluded that the cables tested were

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qualified for use at the LaSalle plant. The licensee attributed the delay in reviewing the test results to lack of resources at the tim This item is considered resolve , . _ . , . . . ~ - - - . , . _ _ _ __

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. Drywell Temperature Monitoring Program Review The inspector conducted a routine inspection to review the licensee's-implementation of the program to monitor, document, evaluate and report higher than expected drywell temperatures.- This review included a field inspection and observation of drywell temperature data monitored by two recorders-located in the Unit 2 Reactor Building; temperature monitored by Control. Room CM recorders and Technical Specification related temperatures taken through the use of toggle switches in the Main Control Roo The inspector observed an actual field implementation of Procedure LTP-300-17, Revision 4, which governs drywell temperature data collection to ensure that environmentally qualified equipment in the drywell_ does not exceed its rt'naining qualified life. The procedure included temperature trigge setpoints and guidelines for accelerated data gathering when n193 .r.than normal temperatures are encountered inside the drywell. Routine performance of activities controlled by this procedure was scheduled as part of the station general surveillance program. The procedure included a mechanism for formal transmittal of temperature data to the engineering department for evaluation and approval of changes to the acceptable criteria and set trigger point The procedure also specified required notifications and engineering evaluations to be performed if EQ limits were exceede Due to high drywell temperature problems experienced at the LaSalle plant in the past, the licensee has committed in correspondence with the NRC and during previous NRC and licensee management meetings to implement an augmented temperature monitoring program and closely monitor actual drywell temperatures to assure that safety-related equipment does not degrade beyond predefined threshold During the review of the Units 1 and 2 drywell temperature i

data collected by the licensee's Technical Staff for the months of November 1987 through February 1988, the inspector determined that some of the data taken daily and weekly in the Control Room and at the locally mounted continuously reading recorders was not obtained as required by Procedure LTP-300-17 (Step F.1).

In November 1987, the licensee noted that one of the two (east)

drywell temperature recorders was inoperable. The licensee failed to effectively initiate appropriate corrective measures to repair and place the recorder back in service. As of the date of this inspection-(six months from the date the recorder became inoperable),

the recorder has not been repaired. In addition, during the period between November 1987 and February 1988, the licensee failed to employ alternate means of acquiring the drywell temperature data which was transmitted by 14 sensors to the failed recorder, and required by Step F.3.c of Procedure LTP-300-17. This data is normally used in environmental qualification evaluations to ensure that

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sufficient remaining qualified life exists for safety-related-components located inside the drywell. On February 10, 1988, the licensee resumed taking data using a hand held fluke meter, Drywell temperature Procedure LTP-300-17, step F.4, requires that if a trigger setpoint is exceeded for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, temperature data be communicated to BWRED on a daily basis and a re-analysis of remaining qualified life be performed within seven day Contrary to the above requirement, the inspector noted that during the period of November 1987 to March 1988, the licensee failed to obtain and transmit daily temperature readings from sensor 1TE-VP211 (located by MSIV "D") to BWRED for evaluation. Sensor ITE-VP211 has indicated temperatures which were above the trigger setpoint for an extended period of tim Based on the findings noted in b. and c. above, the inspector informed the licensee that failure to promptly identify and correct deficiencies which are adverse to quality and assure that corrective action is taken to preclude repetition for significant conditions adverse to quality is a violation of 10 CFR 50, Appendix B, Criterion XVI (373/88012-01(DRS)). This is a repeat violation (see NRC Inspection. Reports No. 50-373/85026 and 50-374/86018), The inspector noted that on June 29, 1987, temperature element 2TE-VP204 located by SRVs D&J exceeded the Technical Specification limit of 150*F by 3 F. The licensee failed to submit a Special Report within the timewith in accordance frame required 10 CFR by)Technicca 50.73(a (2)(1). The Specification licensee attributed 3.7.7.a. and this event to personnel error and subsequently issued LER-87-017 on September 25, 198 Based on the above finding, the inspector informed the licensee that failure to adhere to Technical Specification 3.7.7 requirements constituted a violation (374/88011-01(DRS)). This is also a repeat violation (see NRC Inspection Report No. 50-374/85026).

The apparent root cause for the deficiencies noted above in b., c.,

and d. are attributed to the Technical Staff failure to follow procedures and the lack of management attention to detail. The inspector also detennined during this review that for the deficiencies noted in b. and c., the following steps in Procedure LTF-300-17, Revision 4, were not carried out (between November 1987 and February 1988): C .1, E. 2, E . 4.1, E . 7, F.1.3, F. 4.a . a nd F. 4.b . In addition, the trigger setpoint specified in the procedure for Sensor 1TE-VP210 (at safety relief Valve "G") was incorrect (150 F instead of actual 170 F), consequently, the temperatures recorded were above the trigger setpoint. A daily report was not submitted to BWRED for review and evaluation as required by the procedure. This was determined to have no safety significance. Tte effectiveness of the licensee's training program regarding procedure adherence is also questionabl .

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Of particular concern to the inspector was the fact that the licensee had been cited previously on identical issues in Report No. 374/86018 (failure to follow procedures which require quarterly submittal of collected drywell temperature data to SNED for review and evaluation), and Report No. 373/85026 (numerous violations and a deviation related to inadequate controls of the drywell temperature pre ~am and for failure to obtain drywell temperature data between

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December 1984 and August 1985).

During a subsequent meeting with licensee engineering and management staff, the licensee informed the inspector of the corrective measures that would be taken to addre;s the noted deficiencie The inspector examined licensee activities to address this proble Corrective action included the following:

(1) review of operator rounds and surveillances to obtain some of the missing data; (2) performance of EQ evaluations by BWRED for the last quarter of 1987 which indicated that no EQ concerns or abnormalities were noted; (3) licensee evaluation of this event and determination that the safety consequences of this problem were minimal since the missing data had no major impact on the EQ evaluations performed by BWRED; (4) the present system engineer and the imediate supervisor had been counseled on this event; (5) complete revision of Procedure LTP-300-17 to clearly define data gathering, handling and reporting requirements; and (6) proposed training of additional ergineers to carry out the tasks associated with the drywell temperature monitoring progra The proposed and accomplished corrective action appear to address the noted deficiencies. However, greater emphasis must be given to adherence to procedure requirements, The inspector raised the concern and requested that the licensee review the event and determine whether the failure to obtain temperature data from the 14 sensors constituted a potential unreviewed safety question; and whether some regions not monitored in the drywell could have seen higher temperatures than expecte The licensee conducted an EQ evaluation by extrapolating the missing data using other sensors in close proximity. The inspector was informed by the licensee that the lack of temperature data input for the EQ evaluation required more conservative calculations which

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may provide shorter EQ lifetime for the safety-related equipment insi.de the drywell. The licensee informed the inspector that the EQ evaluations performed from the' available data for the last quarter of 1987 revcaled no EQ concerns or abnormalities. The inspector requested that the licensee submit the calculated EQ data associated with Sensor ITE-VP211 to the NRC for review. The licensee agreed to submit the data sometime in May 198 The-inspector also conducted a visual inspection inside the Unit I drywell of selected electrical cables and components for signs of thermal-damage. While examining the condition of piping insulation, the inspector noted that craft personnel had been stepping on top of the reflective insulation which insulated ~the MSIV lines and other hot pipings. The inspector observed the following defici 1cies:

(1) large reflective insulation gaps ~ were noted specifically by the MSIV's; (2) broken conduit coupling at Solenoid Valve ICM050; (3) broken seal tight-conduits at Junction Boxes 1JB476C and 1JB1356 by SRV 1821-F013V; (4) insulation of white / black conductor of Cable 1NB733 in Junction Box IJB427C appeared to be uneven; and (5) Namco seal assemblies at the MSIV's (A, B, C and D) limit switches were loosene Further review indicated that work requests associated with the above findings had not been written prior to this inspection. The licensee informed the inspector that prior to drywell closure and unit startup the noted deficiencies would be corrected. This item is considered unresolved pending licensee action and NRC review (373/88012-02(DRS)). Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violation. An unresolved item disclosed during this inspection is discussed in Paragraph . Exit Interview The Region III inspector met with licensee representatives (denoted under Paragraph 1) at the conclusion of the inspection on May 3,1988. The inspector summarized the purpose and findings of the inspection. The licensee acknowledged this information. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licenset did not identify any such documents / processes as proprietar