IR 05000373/1996020

Insp Repts 50-373/96-20 & 50-374/96-20 on 961207-970206. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support

ML20137J763
Person / Time
Site:	LaSalle
Issue date:	03/26/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137J734	List: IR 05000373/1996020 ML20137J730 ML20137J746
References
50-373-96-20, 50-374-96-20, NUDOCS 9704040117
Download: ML20137J763 (21)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli ,

Docket Nos: 50-373, 50-374 License Nos: NPF-11, NPF-18 Report Nos: 50-373/96-20, 50-374/96-20 Licensee: Commonwealth Edison Company Facility: LaSalle County Station, Units 1 and 2 ,

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Location: 2601 N. 21st Road 1 Marseilles, IL 61341 l Dates: December 7,1996 - February 6,1997

Inspectors: M. Huber, Senior Resident inspector K. Ihnen, Resident inspector C. Matthews, Illinois Department of Nuclear Safety Approved by: Marc Dapas, Chief, Projects Branch 2 j Division of Reactor Projects i l

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9704040117 970326 PDR ADOCK 05000373 o PDR

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• Based on discussions with control room operators, the inspectors identified that

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some operators do not have confidence in the licensee's formal problem ,

identification process as a means of resolving identified problems, and hence, they i do not use the process. (Section 04.4)

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i * The inspectors identified that a control room operator did not use the most current

] revision of a procedure attachment tc record surveillance test data. The operator did not thoroughly self-check to ensura, that he was using the correct revision. Use

- of incorrect procedure revisions was a xevious licensee identified concern for i

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which the licensee had implemented action. (Section 04.5) I i e An operator did not exhibit a questioning attitude when he suspected that he had

, missed a step in the waste sludge tank transfer procedure. After identifying that the direction in a procedural step was not consistent with the existing system ,

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configuration, the operator assumed he had inadvertently missed a step in the

procedure and opened a valve without first evalue. ting the consequences of this j action. This resulted in a rapid, uncontrolled tank level increase. The failure of the operator to follow the waste sludge tank transfer procedure was considered a violation. (Section 04.6)

e An operator took appropriate actions during a surveillance test to prevent over-

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!' pressurization of high pressure core spray system piping upon observing abnormal l equipment conditions. The operator's actions reflected a thorough knowledge of *

operating restrictions in the surveillance test procedure and HPCS system ,

configuration. (Section 04.7) )

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. e A non-licensed operator did not exhibit an appropriate questioning attitude when

" confronted with an out-of-service (OOS) description that did not match equipment labeling. Consequently, the operator removed the wrong breaker from service. A

! violation was identified for an inadequate OOS instruction. The discrepancy

! between the OOS checklist description and actual equipment labeling may be i indicative of other problems such as the adequacy of the OOS database from which

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OOS checklists are compiled, and the adequacy of plant labeling. Out-of-service errors have been a recurrent problem. (Section 04.8)' ],

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Maintenance i

i e The inspectors identified that an inservice test procedure for the residual heat  ;

i removal system pumps did not require that a repeatable reference flow rate be )

established. Based on a review of historic pump test data, the inspectors  !

concluded that this procedural weakness did not result in a n inadequate inservice j test of an RHR pump. (Section M1.2) l l

e Site Quality Verification personnel appropriately cha' anged the licensee's line

i organization regarding the practice of using blanket work requests to accomplish  ;

various work activities. Personnel in the SQV organization recognized that this i practice could result in bypassing the formal work control process, similar to what

occurred during the June 1996 service water event. (Section M7.1) i

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. EXECUTIVE SUMMARY LaSalle County Station, Units 1 and 2 NRC inspection Report 50-373/96-20; 50-374/96-20 This inspection included aspects of licensee operations, maintenance, engineering, and  !

plant support. _ The report covers an eight-week period nf inspection activities by the 'l resident staf ;

I Licensee performance during this inspection period was characterized by instances of 4

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procedural non-compliance, lack of knowledge regarding existing system configurations =

and configuration changes resulting from surveillance testing,'and the failure to self-chec These human performance deficiencies along with configuration control problems tint involved removing the wrong component from service and continuing concerns with the work control process, which were identified during this inspection period, indicate that licensee corrective actions in these areas have not been effective to dat Plant Operations e The inspectors identified a procedural violation involving the failure to secure an electrical breaker cubicie door to the switchgear frame upon removing the l

associated breaker from service. Although the licensee concluded that the as-found condition of the Division 3 switchgear did not constitute an operability concern, the i licensee decided to install missing bolts and secure bolts that were loose to restore l the switchgear to its original configuration. (Section 02.1)

e A non-licensed operator opened the wrong valve while conducting a fire protection surveillance test causing a deluge o't the Unit 1 auxiliary transformer. A violation j was identified for the failure to frilow the surveillance test procedur i (Section 04.1)

e The inspectors observed that a control room operator and unit supervisor were not l

. sware of residual heat removal (RHR) system configuration changes initiated by '

equipment operators in the plant while conducting a surveillance tes i

. Consequently, the operators did not know why an alarm, which was identified as

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an expected alarm in the surveillance procedure, annunciated in the control roo The inspectors also identified that another control room operator could not explain why certain RHR system valves were in specific positions because he did not know  ;

that selected portions of the RHR system had been permanently removed from i r service. (Section 04.2)

e in general, operators adequately conducted the shift tumovers observed by the

, inspectors. However, in one instance, the performance of a non-licensed operator

. during a shift tumover briefing did not meet the expectations of licensee

management. The inspectors observed that the operator was unable to communicate work priorities, equipment status, or protosms requiring resolution to the rest of the shift. (Section 04.3)

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. Plant Suonort ,

• The licensee changed the wide range gas monitor low flow trip setpoint to restore the system to operable status using an appropriate procedure. (Section R2.1)

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Report Details Summarv of Plant Status Unit 1 was in a forced outage for the entire inspection period and Unit 2 remained shut

, down for a refueling outage. The licensee continued to keep both units shut down to perform design basis configuration reviews and to address equipment and human performance problem !

4 1. Operations '

f 01 Conduct of Operations i

. 01.1 General _ Comments (71707) -

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The inspectors conducted frequent reviews of ongoing plant operations using intpection Procedure 71707. Walkdowns were performed in the main control

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room, emergency diesel generator rooms, auxiliary electrical equipment rooms, !

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safety-related pump rooms, the residual heat renoval system heat exchanger 1- rooms, the reactor building, the turbine b6 dig, Division 1., 2, and 3 switchgear l '

rooms, and the radwaste facility. The inspectors also discussed the status of the '

plant with operating shift personnel in the control room and reviewed shift logs, out-of-service tags, and control board instrumentatio I

< 1 O2 * Operational Status of Facilities and Equipment  !

j 02.1 Division 3 Safetv-Related Switchaear Seismic Concerns l 1  : insnaction Scone (37828)

The inspectors examined the lineup and status of the Division 3, switchgear during

[ a walkdown of the high pressure core spray (HPCS) syste l

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l Observations and Findincs l l

! On December 26,1996, the inspectors identified that some Unit 1, l i

Division 3, switchgear cubicle door bolts were not properly tightened and were l i hanging loose in the associated bolt holes. The function of the bolts is to secure )

the cubicle doors to the switchgear frame. The inspectors determined that the

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associated HPCS breakers were appropriately positioned for the existing plant conditions and that the cubicle doors were secured closed by door handles. The inspectors subsequently identified that bolts were not installed in the cubicle doors

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, for the Unit 2, Division 3 switchgear. The bolts had been removed and the holes plugged. The inspectors discussed their observations with the licensee, f

Operators tightened the Unit 1, Division 3, switchgear cubicle door bolts and performed an operability evaluation to address seismic qualification con:: erns with

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. the missing bolts in the Unit 2, Division 3 switchgear. The licensee determined that ;

. seismic qualification requirements were satisfied because the door handles secured ,

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the cubicle doors to the switchgear frame. However, the licensee decided that

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bolts should be installed to restore the switchgear to its original configuration. Due

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to a difference in the switchgear design, missing bolts in the cubicle doors was not an issue with Division 1 and 2 switchgea j On January 21,19g7, the inspectors identified that a bolt on the Unit 1, Bus 143,

Cubicle 3 door was hanging loose and was not engaged with the switchgear fram '

I 'niis cubicle contained an out-of-service breaker which had been disconnected. The

. Inspectors noted that LaSalle Operating Procedure (LOP) AP-11, " Racking-out a *

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4160 Volt Motor Operated Air Circuit Breaker," Revision 8, requires that operators secure the breaker cubicle door on Division 3 switchgear by tightening the bolt i located in the top right hand corner of the door whenever the associated breaker '

has been racked-out and removed from service. The failure to secure this bolt on the Unit 1, Bus 143, Cubicle 3 door when the associated breaker was racked-out, j as required by LOP AP-11, is considered an example of a violation of Technical )

Specification 6.2.A.a, as described in the attached Notice of Violaticn (50-373/96020-01a; 50-374/36020-01a).

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The licensee failed to follow LOP-AP-11 upon removing a breaker from servica in

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that the associated cubicle door bolt was not secured. The inspectors also

identified other examples of missing bolts and bolts that were not secured.

l However, the inspectors did not determine if the missing or non-secured bolt conditions constituted additional examples of a violation of LOP-AP-11 since the F inspectors were not aware of the procedural requirement at the time and therefore ,

, did not note whether the associated breakers were racked-out. Although the  !

j licensee concluded that the as-found condition of the Division 3 switchgear did not

' constitute an operability concern, the licensee decided to install 'nissing bolts and secure bolts that were loose to restore the switchgear to its original configuratio Operator Knowledge and Performance

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04.1 Onerator Failure to Follow a Procedure Results in Unit Auxiliary Transformer (UAT)

DfAlat l insoection Scone (92701. 71707)

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On February 1,1997, a non-licensed operator inadvertently actuated the Unit 1 UAT deluge system while performing a fire protection system surveillance test in accordance with LaSalle Operating Surveil lance (LOS) FP-M4, " Fire Protection Sprinkler 'and Deluge System Valve Lineup and Alarm Check," Revision 20. The inspectors reviewed the subject surveillance procedure, interviewed operations and l management personnel, and evaluated the adequacy of licensee short-term l cotractive action !

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b. Observations and Findinas After starting the intermediate jockey pump, the operator opened the manual deluge

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. valve instead of the inspector's test drain valve. As a result, the fire suppression system sprayed the UAT with water and both diesel fire pumps started in order to maintain fire suppression header pressure. Operators stopped the deluge and reset

, the system actuation circuitry after determining that the wrong valve had been

< opene At the time of the deluge event, Unit 1 electricalloads, including the residual heat

, removal system which was providing core cooling, were being supplied by both the i main power transformer and the UAT. The UAT did not trip as a result of the deluge and therefore, offsite power to Unit 1 was not lost. Following the j inadvertent deluge, operations and engineering personnel visually inspected ths

transformer and did not identify any apparent problems. The licensee initiated action requests to perform a more thorough inspection and to analyze the transformer oil. The licensee determined that the operator had reviewed the .

surveillance procedure before commencing the surveillance test. However, this was

. the first time that the operator had performed th;s particular surveillance test. The <

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licensee considered the failure to self-check, the lack of supervisory oversight, and i the fact that the inspector's test drain valve was not labeled, to be contributing causes for the human performance even In response to the deluge event, the licensee increcsed operations management oversight of the operating crews by instituting around-the-clock observations of

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management's expectation that pr'ocedures be followed and that changes to a procedure be initiated if the procedure was inadequate, before continuing with an evolution.

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The failure of the non-licensed operator to follow LOS-FP-M4 is considered an example of a violation of Technical Specification 6.2.A.a., as described in the attached Notice of Violation (50-373/96020-01b; 50-374/96020-01b). Conclusigna l The inspectors concluded that the operator error which caused the deluge could have impacted plant operation if the UAT had tripped and a problem developed preventing the fast transfer to the Station Auxiliary Transformer. This would have resulted in a loss of power to the RHR system, interrupting shutdown cooling until power to the associated Unit 1 buses had been restored via alternate sources.

2 04.2 Onerators Not Fully Coanizant of Plant Confiauration Inanection Scone (71707)

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The inspectors observed a control room operator performing surveillance test LOS-RH-01, "RHR [ residual heat removall (LPCI [ low pressure coolant i

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injection]) and RHR Service Water Pump and Valve Inservice Test for  !

l Operational Conditions 1,2,3,4, and 5," Revision 36, and verified that test i i acceptance criteria were appropriate and satisfied. The inspectors also  ;

discussed the status of plant equipment with control room operator l

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< Obstsrvations and Findinos

The inspectors observed that the low system pressure annunciator for RHR  !

loop B actuated during the surveillance test. The control room operator j involved in the surveillance test responded to the alarm in accordance with i

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, the annunciator responsa procedure. In response to questions by the inspectors regarding the cause of the alarm, both the operator and the unit j supervisor stated that they did not know why the alarm had actuated and .J

that they were not aware of any plant activities which could have caused .

, the alar Subsequently, an equipment operator invo!ved in the surveillance test informed the control room operator that the RHR loop C waterleg pump discharge valve had been isolated per LOS-RH-01. l. oops B and C of.the RHR system share a common water 4 leg pump. Isolating the RHR loop C waterleg pump discharge valve caused loop B

RHR system pressure to decrease and actuation of the associated low pressure annunciator. The inspectors identified that LOS-RH-01 contcined a note stating

that the low system pressure alarm for RHR loop B should be expected when the !

RHR loop C waterleg pump discharge valve is shu .

j .. During a routine walkdown of the Unit 2 control room operating panels, the

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inspectors questioned the control room operator about the position of various RHR system valves, specifically, the RHR heat exchanger steam inlet valves and the RHR heat exchanger vent valves which were used in the steam condensing mode of the RHR system. The licensee had previously removed various components of the RHR l system which were used in the steam condensing mode of operation, from service '

permanently. However, the operator was not aware of this and therefore could not

explain the reason for the observed valve position indications. The unit supervisor *

i provided the inspectors with the requested information, j Conclusions

A control room operator and unit supervisor were not aware of RHR system j configuration changes initiated by equipment operators in the plant while conducting a surveillance test. Consequently, the operators did not know why an

- alarm, which was identified as an expected alarm in the surveillance procedure, ennunciated in the control room. Another control room operator could not explain why certain RHR system valves were in specific positions because he did not know

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that selected portions of the RHR system had been permanently removed from

service. Based on discussions with licensee management, the inspectors

! determined that the operators' performance did not meet management

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04.3 Non-licensed Ooerator Not Prenared for a Routine Shift Briefino Insoection Scone (71707)

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The inspectors observed individual operator and shift turnover briefings and evaluated the effectiveness of these briefings in ensuring that tfw oncoming i operating crew was fully cognizant of plant conditions before assuming shift responsibilitie Observations and Findinas

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in early February 1997, the inspectors observed a shift briefing in which a non-2 licensed operator did not meet established licensee expectations for the conduct of a shift brief. The non-licensed operator had not conducted a turnover with the off1oing shift operator before the formal shift briefing, and therefore, he did not ,

know what the operating shift priorities were for the day, the status of plant <

equipment, and what equipment problems needed to be resolved. The operator did, however, conduct a tumover with the off-going operator before assuming his shift duties. Operations management in attendance at the shift briefing recognized that  ;

the operator did not brief shift personnelin a manner consistent with their i expectation l The inspectors noted that licensee management revised the format for conducting a shift briefing during this inspection period. Management required both oncoming shift licensed and non-licensed operators to conduct a one-on-one turnover briefing with off-going operators. The oncoming operator was then expected t communicate pertinent information such as emergent issues, work priorities for the day, equipment status, and special logs that are required for abnormal conditions, l to the rest of the shift during the formal shift tumover briefing.

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.in general, operators adequately conducted shift turnovers observed by the inspectors. However, in one instance, the performance of a non-iicensed operator i

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during the formal shift briefing did not meet the expectations of licensee i management. The inspectors observed that the operator was unable to communicate work priorities, equipment status, or problems requiring resolution to the rest of the shif .4 L[ censed Ooerators Reluctant to Write Problem identification Forms (PlFs)

' Insoection Scone (71707)

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During control room observations and tours, the inspectors discussed the licensee's

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problem identdication and resolution process with control room operators.

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. . Observations and Findinas On January 22,1997, during a control room tour, the inspectors discussed the PlF process with control room operators. The inspectors asked the operators to

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, provide them with the form used by operators to document a problem and initiate ~

appropriate corrective actions. The operators were unable to provide the inspectors ,

with the requested form.. The unit supervisor then told the operators how to locate l

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c PlF. One of the control room operators stated that he didn't write a PIF when he identified a problem. The operator informed the inspectors that he would discuss  !

the problem with the person in the licensee's organization who could fix it. The l operators also stated that it was not worthwhile to write a PlF because the licensee

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does not fix identified problem .)

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}- Conclusions Some operators do not have confidence in the licensee's formal problem

identification process as a means of resolving identified problems, and hence, they )'

! do not use the process.

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4 04.5 incorrect Procedure Revision Used Durina Surveillance Testina

' inanection Scone (71707)

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On December 27,1996, the inspectors observed a licensed control room operator

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perform LOS-RH-01, "RHR (LPCI flow pressure coolant injection]) and RHR Service i Water Pump and Valve inservice Test for Operational Conditions 1,2,3,4 and 5,"

Revision 36, and discussed the procedure with the operator.

Observations and Findinas f During the performance of the RHR system inservice test, the operator used a

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controlled copy of surveillance procedure LOS-RH-01. The operator recorded test data on Attachment 1B, " Unit 1 B RHR & RHR Service Water System Operability

and inservice Test," Revision 35, to LOS-RH-Q1. The inspectors identified that the L operator used the correct procedure revision but used an incorrect revision of l

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attachment 18. The licensee issued LOS-RH 01 in November 1996, however, before the operator actually conducted the surveillance test, the licensee revised the procedure to incorporate changes in the data that needed to be recorded. Although the operator

, verified that he had the correct procedure revision, he did not perform a thorough ,

self-check to ensure that he was using the correct attachment revisio l The licensee had previously identified a problem with the use of incorrect procedure

revisions and had implemented action to address this issue. The inspectors

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concluded that this specific example had minor safety significance. The differences

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between Revision 36 and Revision 35 were minimal and the operator recorded all

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required da!a during the' surveillance test. The operator subsequently transferred  ;

the test data to the correct attachmen l 4 Conclusions ,

The inspectors identified one additional example of a previous licensee identified )

l concern involving the use_of incorrect procedure revisions. A control room operator did not verify that he was recording surveillance test data on the most current l revision of an attachment to the surveillance procedure. The operator did not meet I the licensee's expectations for thorough self-checking.

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04.6 Uncontrolled Wasta Sludos Tank Level increase Due to Personnel Error l 5 inanection Scone (92701,71707)

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On January 31,1997, a rapid water level increase occurred in the waste sludge

tank. The inspectors reviewed LOP-WX-06, " Establishing a Waste Sludge Tank  !

i Transfer Loop," and interviewed involved personne j

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I Observations and Findinas q I

4 A radweste operator inadvertently skipped a page in LOP-WX-06 while transferring the contents of the waste sludge tank for further processing and disposal. The operator began transferring the tank inventory in accordance with step F.7.b on

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page 4 of the procedure, howe,ver, he then went from step F.7.b. to step F.9.a. on

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page 6, inadvertently skipping steps F.8.a through F.8.1 on page 5. As a result, the operator did not secure the transfer, close the waste tank outlet valves, and begin

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to flush the transfer lines with " clean" cycled condensate water as prescribed in the

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- steps on page 5 of the procedure. When the operator reached the procedural step which directed him to close the cycled condensate flush valve to secure the transfer line flush, he noticed that the valve was already in the closed position.

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! Assuming that he had missed the procedural step to open this valve, the operator opened the valve. The operator then reviewed the procedure to determirm what step directed him to open the valve. With the cycled condensate flush valve open,

a flow path through the open waste tank outlet valves existed resulting in a rapid,

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uncocrolled tank levelincrease. While reviewing the procedure, the operator noted the increasing level and isolated the flush water before the tank overflowe ! Conclusions l

The inspectors concluded that the operator did not exhibit a questioning attitude when he suspected that he had missed a step in the waste sludge tank transfer procedure. After identifying that the direction in a procedural step was not consistent with the existing system configuration, the operator assumed he had j

' inadvertently missed a step in the procedure and opened a valve without first l

- - !uating the consequences of this action. The failure of the operator to follow l

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J waste sludge tank transfer procedure, LOP-WX-06, is considered an example of

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. a violation of Technical Specification 6.2.A.a, as described in the attached Notice -i

of Violation (50-373/96020-01c; 50-374/96020-01c).

04.7 Survedlance Observation j

, Innosction Scone (71707)

The inspectors observed the licensee conduct surveillance test LOS-HP-01, Attachment 1 A, " Unit 1 High Pressure Core Spray System Operability and inservice

Test," and reviewed the test procedure. The inspectors also reviewed instrument

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maintenance records to determine if permanently installed instruments used during HPCS surveillances were appropriately calibrr,te Observations and Findinas l During the surveillance test, an operator closed the HPCS waterleg pump

, discharge valve to isolate the waterleg pump and re-direct flow through the

, pump minimum flow line in accordance with LOS-HP-Q1. This caused l waterleg pump discharge pressure to increase. The operator was aware of 1 the 90 psig discharge pressure limit specified in the procedure to prevent

, piping over-pressurization. Consequently, the operator re-opened the pump

, discharge valve before discharge pressure exceeded 89 psig. The licensee l' attributed the unexpected discharge pressure increase to a partially blockod i minimum flow line. This issue is considered an unresolved item (50-373/96020-02) pending NRC review of the licensee's final root cause j analysis and corrective actions, Conclusions The inspectors concluded that'an operator took appropriate action to prevent i over-pressurization of HPCS piping upon identifying abnormal equipment l l

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conditions. The operator's actions reflected a thorough knowledge of '

operating restrictions in the surveillance test procedure and HPCS system configuration.

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04.8 Batterv Charner Out-Of-Service (OOS) Error i

l Insnaction Scone (92701, 71707)

i On December 27,1996, the licensee identified that a non-licensed operator removed the wrong isolation breaker from service for the Unit 2, Division 2,

, 125 VDC battery charger. The inspectors reviewed OOS #960015064 and LOP-DC-01, " Energizing, Startup, and Shutdown of a Battery Charger."

a Ohnervations and Findinas A work analyst prepared an OOS for the Unit 2, Division 2,125 VDC battery

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charger to support the replacement of a voltage potentiometer on the charger. The

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N- licensee intended to remove the battery charger DC supply breaker to the DC bus

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l" from service, however, the equipment operator (EO) removed the battery charger

DC output breaker from service instead. These breakers are in series in the line

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from the bettery charger to the DC bus. Operations personnel discovered the OOS .

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error during the next operating shift before electrical maintenance personnel began l working on the battery charge i

The instructions in LOP-DC-01 for removing a battery charger from service were

- clear, but did not include any specific breaker numbers. The procedure directed the i operator to open the charger AC input breaker, open the charger DC output breaker, i 1 open the charger DC supply breaker to the DC bus or distribution panel, and then open the AC distribution panel supply breaker for the battery charge !

The description on the OOS checklist for the battery charger DC supply breaker to

the DC bus did not match the actual equipment labeling in the plant. The OOS checklist specified " battery charger DC load, circuit 2D", whereas,.the battery i charger DC output breaker was labeled "DC Power CB-2" and the battery charger

DC supply breaker to the DC bus was labeled "125 VDC Battery Charger 2BA Main

Feed."

i - Conclusions  ;

! The inspectors concluded that the EO did not demonstrata an appropriate i questioning attitude when confronted with an OOS description that did not match equipment labeling. This discrepancy may be indicative of other problems such as ,

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the adequacy of the OOS database from which OOS checklists are compiled, and the adequacy of plant labeling. Out-of-service errors involving the removal of the

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50 373/96016; 50-374/96016. The inspectors concluded that OOS #960015064

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was inadequate in that it did not ensure that the correct battery charger circuit

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breaker was removed from service. This is considered a violation of 10 CFR Part

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50, Appendix B, Criterion V, as described in the attached Notice of Violation (50-374/96020-03).

! 11. Maintenance

} M1 Conduct of Maintenance

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! M1.1 General Comments I Inspection Scone (62703)

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s Using inspection Procedure 62703, the inspectors observed portions of the r following c.sintenance activities:

-o Work Request (WR) 960119335, " Replace Filters, investigcte Cause of Failure"

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-- e WR 960111710, "1E22C002, Pump Internal Inspection and Repairs as Needed" .

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j b. Observations and Findinos For the observed maintenance activities, licensee personnel performed work in l accordance with work instructions and maintenance procedures. A problem

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I identified during other maintenance activities is discussed in Section M7.1 of this report.

e t M1.2 Residual Heat Removal System Surveillance Procedure Weakness l

Insoection Scone (61726)

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The inspectors observed operators conduct surveillance test LOS-RH-01, "RHR

(LPCI [ low pressure coolant injection]) and RHR Sorvice Water Pump and Valve Inservice Test for Operational Conditions 1,2,3,4 and 5," Revision 36.

i b. Observations and Findings l

The inspectors identified a weakness in procedure LOS-RH-01 which is used to i determine if the RHR pumps satisfy American Society of Mechanical Engineers l

(ASME) Code,Section XI, testing requirements. The inspectors noted that the l procedure requires operators to establish a flow rate greater than or equal to the minimum flow rate prescribed in the Techn'::al Specifications, but does not specify

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that operators establish a repeatable reference flow rate as required by the ASME

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Code. The ASME Code requires that the pump be operated at a specified reference

! value for a given pump performance parameter, such as flow rate, each time that an inservice test is conducted. Once this reference operating condition has been established, . selected pump performance parameters are measured and compared to appropriate acceptance criteria. The inspectors identified that LOS-RH-01 did not require operators to establish a repeatable reference flow rate within a prescribed i tolerance band (based on instrument accuracies and the readable precision of the l flow rate indicator).

) The inspectors reviewed RHR pump testing data for the past year and did not find i any examples where the actual flow rate established for the test was outside of an

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acceptable band. The inspectors also reviewed testing methodologies used by the licensee to evaluate the performance of other safety-related pumps arxi did not

Identify any deficiencies.

Conclusions

. The inspectors considered the absence of a requirement in LOS-RH-Q1 to establish i a repeatable reference flow rate to be a procedural weakness. However, based on a review of historic pump test data, the inspectors concluded that this procedural

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weakness did not result in an inadequate inservice test of the RHR pump. At the

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j~~ end of the inspection period, the licensee was in the process of revising LOS-RH-Q1 1 to incorporate an appropriate reference flow rate acceptance ban l M7 Quality Assurance in Maintenance Activities j M7.1 Sita. Quality Verification Personnel Question Corrective Actions

~ Inspection Scone (40500)

Site quality verification (SOV) personnel recommended that the scope of work performed by the consolidated facilities maintenance (CFM) organization be limite The inspectors reviewed the circumstances surrounding an event which precipitated

this recommendation.

' Qbservations and Findinas A system engineer initiated a problem identification form upon discovering a ,

disabled latching mechanism on fire door 149 without a fire impairment permi I i The fire marshall wrote a permit after being notified of the degraded fire barrier by l the system engineer.

) The licensee determined that CFM personnel disabled the door at the request of

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radiation protection (RP) personnel to support maintenance activities. This was

accomplished using a blanket work request. The licensee used blank.et work requests to perform repetitive work tasks. In this case, RP personnel had j determined that with Unit 1 in cold shutdown, the adjoining room was not a high

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radiation area, and therefore, fire door 149 was not required to be operable in order to control access to the room. However, the licensee did not evaluate the impact

[' of disabling the door with respect to fire protection requirements. Personnel from 4 the CFM organization disabled the door without taking the actions prescribed in I

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LaSalle Administrative Procedure (LAP) 900-16, " Fire Protection Equipment and l

Fire Barrier impairments," for an inoperable fire barrier. The failure to follow LAP 900-16 is considered an example of a violation of Technical Specification 6.2.A.a.,  ;

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as described in the attached Notice of Violation (50-373/96020-01d; 50-374/96020-01d).

Personnel in the SOV organization raised the concern that the work activity i

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associated with disabling the door was not screened through a formal work control l process. Maintenance personnel did not generate appropriate work control i documents and performed work that had not been authorized by the work control ,

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center resulting in the failure to establish a required fire impairment permit. Site  !

Quality Verification personnel compared this example of a work control process deficiency to similar problems which precipitated the service water event discussed in NRC inspection Report 50-373/96009; 50-374/96009, and questioned the j adequacy of corrective actions implemented following that event.

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- Based on these concems, SOV' personnel recommended that the scope of work performed by CFM personnel be limited until the licensee had completed an l evaluation of the roles and responsibilities of the CFM organization. The licensee ,

then directed maintenance personnel to stop performing work using blanket work l

requests. After completing a review of the event involving the disabled fire door,

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the licensee concluded that the practice of using blanket work requests to j i accomplish repetitive work tasks could result in inadequate control of work l

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activities and that this practice would no longer be conducted in thr4 sea of the ,

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plant referred to as the " power block." The licensee plans to ree! ace blanket work ;

l requests with pre-approved work requests that contain specific guidance on the l

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scope of authorized work and define what work activities require screening per the '

10 CFR 50.59 proces l

l Conclusions

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I The inspectors concluded that SOV personnet appropriately challenged the i 4 licensee's line organization regarding the practice of using blanket work requests to

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accomplish various work activities. Personnel in the SOV organization recognized,

that this practica could result in bypassing the formal work control process, similar L to what occurred during the June 1996 service water event. As a result, the )

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i licensee initiated appropriate corrective actions to address this programmatic j concer ,

{ lit Engineering j E2 Enginsedng Support of Facilities and Equipment

{ E2.1 Control Room Ventilation Radiation Monitor Loale Desian Chanae Concerns Inspection Scone (92701. 37551)

On January 3,1997, the licensee notified the NRC that a modification of the control room ventilation system radiation monitoring logic did not meet single failure criteria and that an unreviewed safety question existed. The inspectors discussed

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the issue with the engineering personnel.

Observations and Findinos

During the review of Technical Specification interpretations, the licensee identified

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that a modification to the actuation logic for the main control room atmospheric control system (MCRACS) in 1993 created an unreviewed safety question. The licensee also identified that the modification to the MCRACS actuation logic created

, a condition where the system would not meet single failure criteria per the design basis described in the Updated Final Safety Analysis Report.

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. The MCRACS was originally installed with four radiation detectors, two per train.

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The system was designed such that one detector in either ventilation intake duct

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l- could initiate both trains of the emergency makeup and pressurization portions of-the control room and auxiliary electric room (AEFR) ventilation systems, in the j event of a high radiation condition. To prevent spurious actuations, the licensee modified the system logic to require actuation of two monitors for initiation of the I

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emergency pressurization portion of the control room and AEER ventilation system j This modification involved circuit rewiring and introduced the potential for a single i failure by connecting the two trains electrically. A short in the logic circuit would y not be identified until the system actuated. The short could cause a loss of power i

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to the circuit, preventing actuation of the control room and AEER emergency

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pressurization system. In addition, the licensee determined that an reviewed safety question existed because the probability of equipmont failure was increased when l

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the number of monitors required to actuate MCRACS increased.

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At the end of the inspection period the licensee was still in the process of evaluating the safety consequences of this identified condition. This issue is -

l considered an unresolved item (50-373/96020-04; 50-374/96020-04) pending NRC

< review of the licensee's completed evaluation of the safety consequence ;- IV. Mant Suncort

R2 Status of Radological Protection and Chemistry (RP&C) Facilities and Equipment

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R2.1 Wide Ranae Gas Monitor (WRGM) Setooint Chanae

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a. Insnection Scone (71750)

> i The inspectors reviewed the circumstances surrounding a setpoint change for the l

!:;okinetic flow rate alarm on the WRG j b. Observations and Findinas

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The WRGM measures the radioactivity of gaseous effluent releases from the plant

through the main exhaust stack. Due to low isokenetic flow, the WRGM was repeatedly shutting down. On December 13,1996, the inspectors learned that the WRGM had been inoperable for approximately 30 days and discussed this with the Unit 1 control room supervisor. The unit supervisor informed the inspectors that after consulting with the WRGM system vendor, the licensee reduced the low flow

trip setpoint on the WRGM, which restored the monitor to an operable statu The inspector reviewed LaSalle Chemistry Procedure 730-6, " General Atomic

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Process Radiation Monitor Data Base Layout," which proceduralized the changes to WRGM setpoints. The inspectors noted that the reduced low flow setpoint was within the allowable limits specified by the procedur i

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I- Conclusions The licensee changed the WRGM low flow trip setpoint to restore the system to an operable status using an appropriate procedure which specified the low flow trip setpoint limits.

V. Management Meetings X1 Exit Meeting Summar '

The inspectors presented the results of their inspection activities to licensee

management at an exit meeting on February 6,1997. The licensee acknowledged

, the findings presented. The inspectors asked the licensee if any materials examined during the inspection should be considered proprietary. No proprietary information

! was identifie ,

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X3 Management Meeting Summary

)' On December 23,1996, and January 3,1997, the NRC held public management meetings with Commonwealth Edison in the NRC Region ill office. Participants discussed the results of the licencee's independent Safety Assessment (ISA) at LaSalle and Zion. NRC personnel prepared meeting notes from the January 3 meeting. These meeting notes will be placed in the NRC public document roo During the December 23 meeting, the licensee described the ISA process and

, emphasized the high experience level of the ISA team members. The licensee described various plant performance and personnel deficiencies identified during the '

ISA and _ indicated the intent to develop additional improvement plans. The licensee planned to make the ISA report available on the public docket.

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PARTIAL LIST OF PERSONS CONTACTED e

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' 'W. Subalusky, Site Vice President ,

- 'F. Decimo, Plant General Managar

• L. Guthrie, Unit 1 Plant Manager

'S. Smith, Unit 2 Plant Manager

'J. Mcdonald, SOV Safety Assessment Manager i 'A. Javorik, System Engineering Supervisor

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'D. Boone, Health Physics Supervisor .

'P. Barnes, Regulatory Assurance Supervisor s  :

• Present at exit meeting on February 6,1997.

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INSPECTION PROCEDURES USED

. IP 37551 Onsite Engineering

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IP 40500 Effectiveness of Licensee Controls in identifying, Resolving, and Preventing ,

Problems -

IP 61726 Surveillance Observation IP 62703 Maintenance Observation

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IP 71707 Plant Operations IP 71750 Plant Support Activities

, IP 92701 Followup -

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. ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-373/374-96020-01 a VIO Failure to follow switchgear OOS procedure 50-373/374-96020-01 b VIO Failure to follow fire protection surveillance procedure 50-373/374-96020-01c VIO Failure to follow waste tank transfer procedure 50-373/374 96020-01d VIO Failure to follow fire impairment procedure 50-373/96020-02 URI Review of HPCS waterleg repairs 50-374/96020-03 VIO Inadequate OOS for battery charger 50-373/374-96020-04 URI Review significance of MCRACS design change problem I

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'7 LIST OF ACRONU -> USED AC Alternating Current AEER Auxiliary Electric Equipment Room ASME- American Society of Mechanical Engineers )

CFM Consolidated Facilities Maintenance '

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DC Direct Current EO Equipment Operator HPCS Hi0h Pressure Core Spray

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ISA - Independent Self Assessment .

LAP LaSalle Administrative Procedure

. LOP LaSalle Operating Procedures

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LOS LaSalle Operating Surveillance LPCI Low Pressure Coolant injection

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'MCRACG Main Control Room Atmospheric Control System NRC Nuclear Regulatory Commission

OOS Out-Of Service i

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PDR Public Document Room

' PIF Problem identification Form RHR Residuail Heat Removal

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RP Radiation Protection i l SOV Site Quality Verification I

. TS Technical Specification

UAT Unit Auxiliary Transformer

• . URI Unresolved item '

, VAC Volts - Alternating Current VDC Volts - Direct Current <

VIO Violation .l

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WR Work Request

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