IR 05000373/1997007

Insp Repts 50-373/97-07 & 50-374/97-07 on 970510-0627. Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support

ML20217B439
Person / Time
Site:	LaSalle
Issue date:	08/29/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217B414	List: IR 05000373/1997007 ML20217B406 ML20217B425
References
50-373-97-07, 50-373-97-7, 50-374-97-07, 50-374-97-7, NUDOCS 9709250014
Download: ML20217B439 (21)

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U.S. NUCLEAR REGULATORY COMMISSION i

t REGION 111

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Docket Nos.:

50 373, 50 374 i

License Nos.:

NPF 11, NPF 18 Report Nos:

50 373/97007, 50 374/97007 Licensee:

. Commonwealth Edison Company Facility:

LaSalle County Station, Units 1 and 2 Location:

2601 N. 21st Road Marseilles, IL 01341 Dates:

May 10 June 27,1997

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inspectors:

M. Huber, Senior Resident inspector

~ J. Hansen, ResMent inspector R. Crane, Resloont inspector E. Duncan, Reactor Inspector, Region lli D. Muller, Operator Examiner, Region ill C. Mathews, Illinois Department of Nuclear Safety Approved by:

Melanie A. Galloway, Acting Chief t

Division of Reactor Projects Branch 2 ADONO

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EXECUTIVE SUMMARY LaSalle County Station, Units 1 and 2 NRC Inspection Report 50 373/97007; 50 374/97007 This inspection report includes aspects of licensee operations, maintenance, engineering

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and plant support. The report covers a seven week period of inspection conducted by the resident staff.

Licenseo performance during this inspection period was characterized by human performance errors, inadequate procedures and failure to follow procedures, challenges to plant personnel due to scheduling weaknesses, and several operational events late in the inspection period including two examples of non conservativo decisions by operations shif t management.

Plant Ooprations The inspectors identified a violation in which operators did not immediately declare

the 1B residual heat removal pump inoperable and take appropriate actions, contrary to procedure, following a failure of the pump to meet surveillance acceptance criteria. Further, operations shift management exhibited a non-conservative approach to safety system operability and Technical Specification implementation by not promptly declaring the pump inoperable. (Section 01.1)

The inspectors identified a second instance of non conservativo decision making by

operations shift management that occurred when a radioactive waste discharge was initiated without resolving questions concerning the operability of lake blowdown flow indication. (Section 01.2)

An unexpected trip of the station's Unit 1 unit auxiliary transformer occurred while

taking metering pot fuses out of service on the main power transformer. The inspectors were concerned that licensed operators failed to evaluate the effects of removing equipment from service on the plant. (Section 01.3)

Mainte.apaq1t The inspectors determined that, while improvements in the scheduling and

completion of maintenance activities have been noted, schedule development and implementation continued to challenge plant personnel. (Section M1.1)

The inspectors identified that the licensee did not provide adequate post-

meintenance test requirements following air start motor repiccement on the *0" emergency diesel generator resulting in a violation. The licensee took prompt corrective actions. The licensee had based the post-maintenance test on a Technical Specification clarification which lacked adequate technical justification.

The inspectors were concerned that the Technical Specification clarification reviews

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previously performed by the licensee had not identified and addressed the

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inadequate technical justification. (Section M4.1)

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The licensee was on schedule in its implementation of actions in the restart plan

regarding temporary alterations (TALTs). However, the inspectors identified

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numerous deficiencies with the adequacy and implementation of LaSalle Administrative _ Procedure 240-06, " Temporary Alterations," Revision 35, and some TALTs in the plant were not included in the TALT program. The inspectors

-Identified two non cited violations regarding the TALT program.--(Section E1.1)

Plant Sucoort

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The inspectors identified a contaminated area where coverings had not been

installed on floor g stings to limit contamination migration to clean areas. This is an

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additional example of a previous violation. (Section R4.1)

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The inspectors identified a violation regarding the labeling of tygon tubing used on

contaminated systems. The inspectors also determined a lack of knowledge among plant personnel concerning the labeling of tygon tubing used on contaminated

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systems. (Section R4.2)

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Report Details Summarv of Plant Status Unit 1 was in cold shutdown for a forced outage during the entire inspection period, and Unit 2 remained shut down for a refueling outage with all fuel removed. The licenseo continued to keep both units shut down to perform design basis configuration reviews and to address equipment and human performance problems.

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Conduct of Operations 01.1 failure to Declare 18 Residual Heat Removal (RHR) Pumo Inocerable Per Procedure Followina Failure to Meet Technical Soecification (TS) Accentance Criteria

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10metion Scone (71707)

The inspectors reviewed the control room unit logs, RHR surveillance test packages, and Instrument calibration packages and interviewed plant

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personnel regarding the failure of the 1B RHR pump to meet the Technical Specification acceptance criteria while performing surveillance testing.

Documents reviewed included:

LaSalle Administrative Procedure (LAP) 100 29, " Conduct and Review of

Station Surveillances," Revision 6 LaSalle Technical Staff Procedure (LTP) 600 4, "American Society of

Mechanical Engineers (ASME)Section XI inservice Testing of Pumps and Valves," Revision 14 LaSalle Operating Surveillance (LOS) RH 01, "RHR Low Pressure Coolant

injection (LPCI) and RHR Service Water Pump and Valve Inservice Test for Operational Conditions 1, 2,3,4, and 5," Revision 38 LaSalle Instrument Maintenance Procedure (LIP) RH 5028, " Unit 1 RHR

Pump 1B/1C Flow Indication Refuel Calibration," Revision 1 LIP RH 603B, " Unit 1 RHR Pump 1B/1C Discharge Pressure Indication Refuel

Calibration," Revision 0 b.

Observations and Findinat On June 13,1997, at 10:20 s,m., with Unit 1 in Operational Condition 4, Cold Shutdown, Unit 1 control room operators were unable to obtain the discharge pressure required by TS for the 18 RHR pump during performance of LOS RH 01, a LPC; modo surveillance. The TS acceptance criteria required the pump to develop Dreater than or equal to 130 psig discharge pressure with the system flow established at greater than or equal to 7200 gpm. The pump only achieved

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129 psig discharge pressure at 7200 gpm. This failure would have put the pump in the required action range of ASME Section XI.

Shift management directed performance of a calibration check of the pump test instrumentation instead of imrnediately declaring the pump inoperable. At 4:00 p.m., operators declared the 18 RHR pump inoperable for the LPCI mode of operation; however, the operators did not declare the pump inoperable for the shutdown cooling (SDC) mode of operation. Operators initiated a problem identification form (PIF) which requested engineering to evaluate the operability of the 18 RHR pump in the SDC mode of operation rather than taking a system view of the test f ailure and assuming the pump was inoperable for all operational modes.

On June 14,1997, the 18 RHR pump f ailed the surveillance test a second time when the pump did not develop the discharge pressure required by TS, and operators declared the 1B RHR pump SDC mode of operation inoperable at 10:20 a.m. With less than two operable SDC loops, operators entered Action a. of TS 3.4.9.2 which required that operability be demonstrated of at least one alternate SDC method within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Operations personnel completed LaSalle System Operating Procedure (LOP) RH 17, " Alternate Shutdown Cooling," Revision 10, at 10:30 a.m. which ensured an alternate SDC method.

Subsequently, on June 14, the instrument maintenance technicians performed a second flow calibration verification and left the as left calibration points at the center of the calibra' ion tolerance band. At 10:45 p.m. on June 14,1997, the 18 RHR pump achieved a satisfactory discharge pressure of 134 psig with system flow established at 7200 gpm. At 6:10 a.m. on June 15,1997, the operators declared the 1B RHR pump operable for the LPCI and SDC modes of operation.

Guidance in NUREG 1482, " Guidelines for Inservice Testing at Nuclear Power Plants," NRC Staff Position Number 8, " Starting Points for Time Periods in Technical Specification Action Statements," clarifies the intent of TS in relation to ASME code requirements by specifying that as soon as the data is recognized as being within the ASME required action range of Table IWP3100 2, the pump must be declared inoperable, and the technical specification action statement time must be started. The NUREG specifies that recalibrating the instruments involved and re-running the test to show the pump is still capable of fulfilling its function are an alternative to replacement and repair, not an additional action that can be taken before declaring the pump inoperable. Step F.6.b of LTP 600 4 incorporated the NUREG guidance, requiring that the pump be declared inoperable and appropriate actions be taken as specified in the limiting conditions for operation in the technical specifications when the pump was confirmed to be in the required action range.

The licensee's f ailure to promptly declare the pump inoperable after the initial TS f ailure was not a conservative approach to safety system operability, in addition, the eventual decision to declare the pump inoperable for the LPCI mode but not the

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SDC mode was also nonconservative and did not recognize the TS 4.0.5 l

requirement that ASME inservice testing (which did not differentiate between system modes) applies to operability of TS equipment.

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The failure to promptly declare the 1B RHR pump inoperable for the LPCI and SDC modes of operation in accordance with LTP-600 4 is a violation (50 373/97007 01)

of 10 CFR 50, Appendix B, Criterion V, as described in the attached Notice of Violation (NOV).

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Conclusions The inspectors identified a violation in which operators did not immediately declare the 10 RHR pump inoperable and take appropriate actions, contrary to procedure, following a failure of the pump to meet TS surveillance acceptance criteria.

Operations shift manageraent exhibited a non conservative approach to safety system operability and TS implementation by waiting almost 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to declare the pump inoperable for the LPCI mode and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to declare the pump inoperable for the SDC modo, while pursuing the calibration accuracy of test instrumentation as a possible cause of the failure.

01.2 Radwaste Dischame Started While Operability of the Dischame Instrumentation Was in Question a.

Insnection Scone (71707)

The inspectors reviewed the preparations, procedures, and equipment necessary to support the June 18,1997, discharge of Radwaste Discharge Tank 1WF05T.

Documents reviewed included:

LOP WF 20, "Radwaste Discharge Tank Discharge to the Lake Blowdown

Line," Revision 24 LOP-WL 04," Lake Level and Blowdown Flow Control," Revision 14

LOS WL-01, " Lake Blowdown Flow Indicator Channel Functional Test,"

Revision 11 b.

Observations and Findinas The licensee identified that on June 18,1997, the control room supervisor (CRS)

commenced a radwaste discharge of Radwaste Discharge Tank 1WF05T while the operability of the lake blowdown flow instrumentation required to start the discharge was in question. The controlling procedures used during the discharge were LOP-WF 20 and LOP-WL-04. LaSalle System Operating Procedure WL-04 defines operability of the flow instrumentation to be determined, in part, by a current and satisf actory quarterly surveillance of the instrumentation. The licensee met this requirement on June 18,1997.

However, before commencing the discharge, the licensee had identified an 8000 gpm discrepancy between the lake blowdown flow indication and calculated lake blowdown flow using remote valve position. This 8000 gpm discrepancy varied from the definition of operability contained in the quarterly surveillance procedure LOS WL-01, " Lake Blowdown Flow Indicator Channel Functional Test,"

Revision 11. Limitation and Action Steps E.2 and E.3 of LOS WL-01 state that the

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flow indicator must agree with the calculated flow within plus or minus 7000 gpm to be considered operable. The CRS atttimpted to contact the cognizant modification and system engineers regarding the discrepancy but was not successful and subsequently commenced the discharge. The CRS did not consult with the shift manager regarding the flow instrumentation operability concern before initiating the discharge. While commencing the discharge was not in conflict with the definition of operability of the flow instrumentation as defined in LOP WL 04, the decision to do so with an outstanding operability question represented a non conservative operational approach.

The discharge was stopped by the oncoming shift manager af ter he was informed of the 8000 gpm flow discrepancy. The licensee recalculated the lake blowdow..

flow using locallake blowdown valve position and calculated a discrepancy of 5600 gpm. As corrective action, the licensee planned to resolve the difference between its instruments reading local and remote lake blowdown valve position.

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Conclusions While this event is of minimal safety significance, the inspectors were concerned that operations shift management demonstrated non conservative actions by commencing the radwaste discharge before the questions concerning operability of the flow instrument were resolved. Shift control room personnel did not discuss the issues to the depth necessary for comprehensive analysis and did not include the shif t manager in discussions.

01.3 Trin of TR 141 Unit Auxiliarv Transformer (UAT) on Unit 1 a.

Inspection Scone (717011 The inspectors reviewed the unexpected trip of the station's Unit 1 UAT which occurred during the placement of an out-of service (OOS) instruction on the main power transformer (MPT).

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Observations and Findinas Summarv of Event On June 21,1997, the licensee initiated OOS 970005993 to place the Unit 1 main turbine generator in layup condition. At this time, the MPT was powering the UAT (backfed). As a result, when the main generator metering pot fuses were removed in accordance with the OOS instruction, the Unit 1 UAT tripped as designed. Although the UAT responded properly, operations personnel failed to foresee this consequence. Power to Unit 1 equipment was momentarily lost while the electrical buses automatically re aligned to the station auxiliary transformer (SAT).

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l Licensee investination Results i

In response to this event, the licensee conducted a prompt investigation to i

determine the sequence of events, root cause, and coirective actions. The -

inspectors reviewed portions of the licensee's preliminary prompt investigation report, including planned corrective actions. During the review of the report, the inspectors noted the following:

i Licensed operators responsible for generation of the OOS instruction failed

to recognize that the UAT was being powered (backfed) from the MPT and,

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as a result, f ailed to identify that removal of the metering pot fuses would l

cause the UAT to trip, t

Licensed operators responsible for the approval of the OOS instruction were

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focused on safety of personnel conducting the planned maintenance and

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f ailed to adequately consider the consequences of the OOS Instruction on plant equipment.-

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The licensee wrote the OOS instruction within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the planned work

and did not walk it down before implementation.

Corrective Actions In response to the event, the licensee directed that no shif t personnel would be allowed to perform work related to any OOS instruction until they fully understood the event, as well as licensee management's expectations regarding Implementation e

of the OOS program. To meet this expectation, licensee management required i

operations personnel to accomplish the following training actions:

Review the prompt investigation report.

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Review the document, "How We Assure Operations Control of Plant

Equipment," which contained the following licensee management expectations:

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Personnel will walk down all new OOS instructions before execution.

Scheduled activitics must have an OOS instruction assigned at least

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to execution.

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A senior reactor operator (SRO) will perform an additional review on

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all OOS instructions with a greater awareness of configuration control.

Personnel will perform a review of all pending OOS !nstructions

before implementation.

Review the following management expectations:

i Operations personnel are responsible for equipment configuration

during OOS preparation, review, and approval.

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The nuclear station operator (NSO) is responsible for considering the

condition of the plant at the time the associated OOS instructions will be placed.

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Senior reactor operators reviewing the OOS instructions are required

to determine tholt effect on the configuration of plant equipment.

• Read and sign a memorandum entitled, " Safety Takes Precedence Over

Everything Else," to acknowledge understanding of the errors that resulted in the trip of the UAT and that safety must not be compromised for any reason.

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Conclusions

The inspectors were concerned that licensed operators failed to evaluate the effects on the plant of removing equipment from service. However, the licensee's corrective actions were appropriate.

Operator Knowledge and Performance 04.1 Plant Labelina and Out of Service Deficiengiga a.

IDantGlion Scooe f 71707)

The inspectors verified the implementation of portions of OOS 970000466 to support work on the "B" control rod drive (CRD) pump by touring the Unit 1 CRD pump room. The inspectors also reviewed LAP 900 48, " Writing and Hanging an Out of Service," Revision 4.

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Qbservations and Findinas On June 6,1997, the inspectors identified several plant labeling and OOS instruction implementation deficiencies during a walkdown of the CRD pump room.

The deficiencies included:

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Several equipment identification tags were missing from valves in the "A"

and "B" trains of the CRD system. The inspectors found two of the missing equipment tags on the pump room floor.

The inspectors identified that OOS 970000466, implemented by operations

departmer,t personnel on May 6,1997, and verified by maintenance personnel prior to commencing work, had OOS cards attached to valves that did not have equipment identification labels. The inspectors did not identify any cards attached to the wrong equipment. Operations department management had initiated Operations Memorandum Number 19, "Out of Service Expectations," Revision 6, dated May 5,1997, to delineate management expectations regarding the placing of OOS cards on equipment that had improper or inadequate labeling. Attachment B gave operators

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direction to ensure equipment was correctly identified and labeled prior to attaching an OOS card to any component.

One OOS card had been destroyed, and a second card was partially illegible

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One OOS card was detached from the valve. Plant personnel rolled the card

and pushed it between the packing gland follower and valve body to keep

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the card on the valve. The inspectors observed that the valve was not easily identified as being OOS.

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Operations personnel entered the room once per shift to inspect operating

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equipment but f ailed to identify or correct the deficiencies. Also,

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maintenance personnel had been working in the room for several shif ts but had not recognized or corrected the deficiencies, i

The inspectors informed operations personnel of the missing cards and equipment identification tags, and the operations personnel took appropriate actions.

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Conclusiong The inspectors identified that plant personnel had not identified and corrected all examples of equipment labeling deficiencies despite several opportunities to do so.

The inspectors concluded that plant personnel had not fully implemented management expectations regarding the placing of OOS cards.

II. Maintenance M1 Conduct of Maintenance

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' M1.1 Schedule issues Continue to Challenae Plant Personnel

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insnection S.goce (62707)

During the inspection period, the inspectors reviewed the station work schedule, i

researched schedule changes, and verified implementation of scheduled activities.

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Observations and Findinas

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The inspectors identified severalissues regarding the work schedula and schedule implementation including:

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In general, the plant outage schedule became a more effective tool to

support work completion. The Outage Scheduling Group had responsibility for schedule maintenance so scope additions and changes were controlled

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by one organization which permitted greater schedule stability. Also, daily

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I schedule meetings and updates presented at the plan-of-the-day meeting promoted schedule importance and adherence.

The licensee did not schedule adequate time for development of OOS

instructions and the associated walkdown. The licensee identified the lack of time to perform an OOS instruction walkdown prior to implementation as a contributor to the June 21,1997, UAT trip. (See Section 01.3.)

Operations department personnel were not always prepared to implement

the schedule. During a scheduled decrease in vessellevel, the level decreased to the low end of the desired range because an administrative OOS instruction necessary to implement actions required to maintain vessel level had not been prepared.

Improper changes to the plant work schedule resulted in the TS surveillance

test being scheduled past the maximum TS-allowed completion date (critical due date). On May 21,1997, the operations department work planner identified that the predefined work requests for the TS-required "0" EDG monthly run had been removed from the normal schedule. The outage scheduling planners had inappropriately bundled the surveillance test with work scheduled for an EDG outage that was beyond the critical due date of the surveillance. The operations department work planner added the monthly diesel run back to the normal schedule but did not generate a PlF or inform licensee management of the scheduling error. The TS scheduling error had significance due to several TS surveillance tests being missed during the last year. Plant management discussed the concern with work planners and eliminated the ability of the outage scheduling planners to rem:,ve TS surveillance tests from the normal plant schedule. Corrective actions taken by licensee management were appropriate.

A work control center SRO identified in a recent PlF that a higher quality scheduling product should be provided to the operations department. The SRO had identified several scheduling problems including:

preceding tasks not being kept with the primary task when the primary task

was rescheduled, support activities remaining on the schedule after the task had been

canceled, uctivities scheduled to be accomplished during an outage not rescheduled

when the outage was rescheduled, and clearing of an OOS scheduled when the equipment was not ready to be

returned to service.

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Conclusiong While improvements in the scheduling of activities and work completion have boon notod, scheduto development and implomontation continued to challengo plant

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personnel, particularly operations personnel.

M4 Maintenance Staff Knowledge and Performance M4.1 lt.adanuato Post maintenanco_Testina Followina EDG Air Start MotoLBcofacement a.

[unpoetion Scopo (017201 The inspectors observod portions of the post maintenance testing performod on the

"0" EDG and reviewod the completed test to ensuro TS oporability, b.

Qhantvations and Findinatt On June 20,1997, the inspectors identified that Work Roquest No. 970040757,

"Replaco/Robuild Air Start Motors," did not require a timod start following replacement of all four air start (notors as part of the post maintenance testing performed on the "O" EDG, Operations personnel had completed Attachments 01 and 02, "O Diosol Generator Idle Start," of LOS DG M1, "O Diosol Generator Operating Tost," Revision 33. The proceduro directed the local operator to overtido

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the fuel ra;ks and warm the EDG to normal operating temperatures at

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approximately 500 revolutions per minuto, then slowly bring the EDG up to operating speed. Technical Specification 4.0.1.1.2.a.4 required that the EDG be able to attain rated frequency and voltage within 13 seconds following recoint of a start signal. The fallero of the work toquest to specify adequato post maintenance testing to onnuto TS surveillance requirements woro mot is a violation of 10 CFR Part 50, Appendix 0, Critorion V, as described in the attached Notico of Violation (50/373 97007 02; 50/374 07007 02).

Tho inspectors questioned why the 13 second start time was not verified because the replacement of air start motors could af fect EDG start timo. The licensoo provided Technical Specification /Licenso Clarification 02 90, Revision 1, May 19,1990, which indicated that the EDG start timo did not requi o validation t

following replacement of the air start motors providing a liko for liko replacement was performed and the air start motors woro either (1) now or (2) inspected, rebuilt, and tested in accordance with specilled maintenanco proceduros. The in=poctors requestod the licensoo to provido technical justification to support this TS clarification, but the licensoc was unable to provido it. Thus, licensoo management decided the "O" EDG start time should be validated. The licensoo satisfactorily start timo testod the "O" EDG on each bank of air start motors. The licensee planned to start time test its EDGs following replacement of the air start motors until a technical justification supporting not performing a timod EDG start is developed or located.

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Tho licensee identified that a satisfactory timed start had been performed on the 1 A EDG bank A air start motors following the most recent replacement of the air start motors and that the bank B air start motors would be entered in the degraded equipment log until testing was completed.

The absence of a justification to support Technical Specification / License Clarification 02 90 was not identified as an issue during extensive Technical Specification clarification reviews performed by the licensee in 1990. These reviews and their results are described in Licensee Event Report 373/96013 and NRC Inspection Reports 50 373/90010; 50 374/90010 and 50-373/96011; 50 374/90011.

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Conclusions The licensee implemented Technical Specification / License Clarification 02 90 without adequate technical justification which resulted in inadequate post-maintenance test requirements following EDG air start motor replacement. The inspectors were concerned that the Technical Specification clarification reviews previously performed by the licensee had not identified and addressed this problem.

111. EnsimiLng E1 Conduct of Engineering E1.1 Temocrarv Alteration (TALT) Pronram Conduct a.

Insnection Scone (3753.11 The inspectors reviewed the status of Restart Action Plan Item 1.28 and implementation of LaSalle Administrative Procadure (LAP) 240-06, " Temporary Alterations," Revision 35, dated April 12,1997, to assess the licensee's conduct of the TALT program. In addition, the inspectors conducted plant walkdowns to identify u.. authorized TALTs.

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Observations and Findinas Restart Action Plan lmolementation Revio_yt A total of 54 TALTS existed (23 for Unit 1 and 31 for Unit 2). Of these,19 TALTS on Unit 1 and 14 TALTs on Unit 2 addressed equipment or system deficiencies.

The remaining TALTS supported maintenance or refueling activities or supplied station heating during the dual unit outage.

The inspectors determined that the licensee's implementation of temporary alteration initiatives defined in Restart Action Plan item 1.28 was on schedule. The inspectors verified that in accordance with the Restart Action Plan the licensee had identified the TALTs to be removed prior to startup of both units. The licensee had

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also identified the TALTs in place to support Plant Outages L1F3S and L2R07 that required rernoval before the completion of those outages. The licensee was in the process of resolving the eight TALTs planned to be closed in L1F35. The licensee had closed one of the two TALTs identified for resolution in L2R07 and was In the process of closing the remaining TALT. The licensee had developed an action plan to address these TALTs open on January 31,1997, including resolution, schedule for tornovel, and assignment of responsibility. The Station Manager also received a monthly review of TALT status.

J_emocrary Alteistion Procedure and imolementation Review The inspectors reviewed LAP 240 06 to assess the licensee's implementation of the TALT program, including TALT initiation and tracking documentation. During this review, the licensee could locate only two Quarterly and no Semi Annual TALT Assessment Reports. LaSalle Administrative Procedure 240 06 required these reports to be created and forwarded to specific managers for review. These reports provided increased licensee management focus on TALT status and resolution.

Although the procedure required documentetion of other administrative status reviews and audits to be retained as plant records, no similar requirement existed for these reports. Therefore, the inspectors were unable to determine if the missing reports had over been generated and thus, whether the licensee had followed these LAP requirements. The inspectors reviewed the most recent Quarterly TALT Assessment Report and determined the information presented was in accordance with the LAP.

The inspectors considered the fo" awing aspects of LAP 240 06 to be confusing and increasing the opportunity f' r implementation errors:

The procedure included numerous forms related to TALT program

implementation as attachments. However, the procedure did not clearly identify when some attachments were expected to be completed during the processing of a temporary alteration. For example, the procedure left completion of Attachment N, " Design Impet Review Checklist," to the discretion of the temporary alteration coordinator. However, the procedure contained no objective criteria to aid in determining whether completion of the checklist was required.

Attachment N, " Design impact Review Checklist," Part II, contained a series

of questions designed to aid in identifying potentialimpacts of the TALT If any questions were answered "Yes," then the attachment directed that the questions be addressed in the safety evaluation. However,17 out of 71 questions welo worded such as to make it unnecessary to address the associated impact in the safety evaluation. For example, question B.17 of Attachment N stated, "Have the rules for single failure criteria been applied correctly?" A *No" answer would not require that an evaluation for this

impact be performed but would not meet the intent of the question, i.e., to

perform a safety evaluation for single failure criteria. The licensee had completed Attachment N checklists for 5 of the current TALTs. The l

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inspectors determined that potentialimpacts associated with the 17 questions were not applicable to these 5 TALTs.

LaSalle Administrative Procedure 240 06 failed to clearly identify when some attachments were to be completed and to provide correct direction with regard to evaluating potential TALT impacts. These failures are considered a violation of 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

which requires activities affecting quality be prescribed by procedures appropriate to the circumstances (50 373/97007 03; 50 374/97007 03). These f ailures constitute a violation of minor significance and are being treated as a non-cited violation, consistent with Section IV of the NRC Enforcement Policy.

Plant Walkdown Results The inspectors identified the following plant alterations which were not entered into the TALT system or shown on plant drawings. The licensee confirmed that these items constituted TALTs and were required to be controlled in accordance with LAP 240 06. The licensee subsequently removed the unauthorized TALTS.

Emergency Diesel Generator (EDG) Air Box Drain Alteration

The licensee had modified the air box drain piping fr. We Unit 0,1 A,2A, 1B, and 2B EDGs with tygon tubing extending from we piping to drains.

Fuel Pool Cooling Pump Alteration

The license had modified the Unit 1 nonsafety related fuel pool cooling pumps with a combination of copper and plastic tubing extending from the casing vent valves to a drain connection.

Service Water System Alteration

The licensee had modified a nonsafety related service water system connection with a 3-foot length of tygon tubing which extended from an open ended pipe.

Step E.1 of LAP 240 06 stated that this procedure is applicable to all TALTs. The failure to apply the administrative controls required by LAP 240 06 to the EDG air box drain elteration is considered a violation of 10 CFR Part 50, Appendix 8, Criterion V, " Instructions, Procedures, and Drawings," which requires activities affecting quality be prescribed and accomplished by procedures (50 373/97007-04; 50-374/97007-04). This failure constitutes a violation of minor significance and is being treated as a non cited violation, consistent with Section IV of the NRC Enforcement Policy.

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Conclusions The inspectors concluded that the licensee was implementing actions to address temporary alterations on schedulo in accordance with the Restart Action Plan, i

However, the inspectors identified some aspects of LAP 240-06 which were not appropriate and three unauthonzed temporary alterations in the plant.

IV. Plant Suonort R4 Staff Knowledge and Performance in Radiological Protection & Chemistry (RP&C)

R4.1 Improper Contamination Boundarv increased Possibility of Soread of Contamination lo Clean Area a.

Incoection Scoco (71750)

The inspectors toured the reactor building on May 14,1997, and observed the construction of boundarios for several contaminated areas.

b.

Observations and Findina The inspectors observed that a clean area in the reactor building raceway basement existed under a contaminated area grating. Step F.2.f of LaSalle Radiation Protection Procedure (LRP) 57216, " Construction of Radiologically Posted Areas and Step Off Pads Areas," Revision 1, requires that washable plastic or cloth be installed on floor grating within a contaminated area to prevent the spread of contamination to a non-contaminated area below.

Workers had established a non-contaminated area in the basement of the raceway to facilitate containment tendon inspection and torquing. Upon completion of this work, the RP technician removed the shield blankets on the grating in the contaminated area without returning the non contaminated basement of the reactor building raceway to a contaminated status. The inspectors informed the RP technician responsible for the reactor building who subsequently replaced the shield blankets and verified that the non contaminated area was free of contamination.

The inspectors concluded that the RP technician was unfamiliar with this requirement. The inspectors had identified a previous failure of the licensee to comply with LRP-5721-6, Step F.2.f, as a violation of TS 6,2.A,a (50 373/97006-01c; 374/97006-01c) issued in NRC Inspection Report 97006.

The inspectors determined that the licensee had not had sufficient time to implement corrective actions following identification of the violation late in the previous inspection period. Therefore, this is an additional exemple of the above-referenced violation.

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Conclusions

i The licensee's corrective actions on May 14,1997, to ensure required coverings l

i were placed on floor gratings to limit contamination migrating to clean arean were appropriate and timely.

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R4.2 Imoroner Tvoon Tubina labelina increases Possibility of Soread of Contamination a.

Inspection Scone (717501 f

The inspectors toured the turbine building and evaluated the licensee's adherence to radiation work practices during leak testing of the Unit 1 feedwater heaters,

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Observations and Findina

On June 6,1997, the inspectors observed equipment installed to support the i

i performance of LaSalle Limited Procedure (LLP) 97 023, "High and Low Pressure Heater Tube Leakage Test Using Condensate Booster System," Revision O. The inspectors found the testing was completed and that testing personnel were no

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longer in the area. The inspectors identified that several tygon hoses attached to

the Unit 1 feedwater heaters failed to indicate that the contents were potentially

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contaminated. Step F.9.a.1 of LAP 900 8, " Hose Identification and Control,"

Revision 17, requires that all tygon tubing used on contaminated systems be identified with " Internal Contamination" stickers. The failure to mark the hoses as potentially contaminated as required by the procedure was an example of a

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violation of TS 6.2.A.a, as discussed in the attached Notice of Violation (50 373/97007 05; 50 374/97007 05). The inspectors discussed the unmarked hoses with RP department personnel who informed the inspectors that the tygon

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tubing should be marked and that they would do so.

During additional discussions, an RP supervisor informed the inspectors that the RP department had been notified of the test performance in accordance with

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LLP 97-023 and that RP personnel were present when the tygon tubing was installed, but f ailed to labelit as required. Radiation protection department personnel walked down the reactor and turbine buildings and identified several additional instances of unmarked tygon tubing. The licensee marked all hose: as required.

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The inspectors interviewed an instrument maintenance supervisor and a system engineer involved with the test and identifieo that neither was aware that the tygon-tubing was required to be marked as potentially contaminated. The instrument

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maintenance supervisor indicated that the requirement to mark tygon tubing used on a contaminated system as potentially contaminated would be communicated to instrument maintenance personnel.

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Conclusions The inspectors concluded that plant personnel demonstrated a lack of knowledge of

the requirements regarding the labeling of_ tygon. tubing used on contaminated

systems.

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VI. Managemerit Meetinas

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X1 Exit Meeting Summary

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- The inspectors presented the results of these ir

,ect ons to censee management listed below at exit meetings on June 27, an just 25,1997. The licensee acknowledged the findings presented.

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The inspectors asked the licensee if any mater, t examined during the inspection should be considered proprietary. The licensee identified none.

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PARTIAL LIST OF PERSONS CONTACTED

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'W Subalusky, Site Vice President

'J. Giesker, Executive Assistant

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'L Guthrie, Unit 1 Plant Manager i

'S. Smith, Unit 2 Plant Manager

• G. Benes, Licensing Administrator

+ 'D. Farr, Operations Manager t

+ 'P. Higgins, Outage Manager

+ 'J. Mcdonald, Site Quality Verification (SOV)/ Safety Assessment Manager

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+ 'G. Poletto, Site Engineering Manager

'D. Rhodes, Chemistry Manager

'M ' Dougherty, Construction Superintendent

'D. Rief, Fuel Handling Supervisor

• E. Connell, Design Engineering Supervisor

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?J. Pollock, Support Engineering Supervisor

'R. Chrzanowski, ISEG Supervisor

'R. McConnaughay, Shift Operation Supervisor

'J. Burns, Operations Support Supervisor

• D. Held, Shif t Manager

• J. Kennedy, Supply Management

"J. Drago, NRC Coordinator

+ P. Barnes, Regulatory Assurance

+ F. Dacimo, Plant Manager

+ J. Sch Jster, Lead Chemist

+ R. Hebterman, Maintenance Manager

. ts. Riffer, CAP Manager

+ R. Pr.mieri, System Engineering Manager

+ C.. danblanc, Radwaste Manager

'G Kinder, MMD Parts Analyst

+ B. Eifort, EAG Manager

+ J. Henry, Operations

+ A. Magnafici, Restart Group

-+ J. Arnould, Engineering NRG

- * M.' Parker, Acting Branch Chief

"N. Shah, Regional inspector

+ 'J. Hansen, Resident inspector

'C. Mathsws, Illinois _ Department of Nuclear Safety

+ M. Galloway, Acting Branch Chief

+ R. Crane, Resident inspector

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'. Present at exit meeting on June 27,1997.

+ Present at_ exit muting on August 25,1997

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INSPECTION PROCEDURES USED IP 37551 Onsite Engineering IP 61726 Surveillance Observation IP 62707 Maintenance Observation

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IP 71707 Plant Operations IP 71750 Plant Support Activities ITEMS OPENED, CLOSED, AND DISCUSSED i

.QRE 50 373/97007 01 VIO Operator f ailure to implement TS action as required 50 373/374 97007 02 VIO Inadequate post maintenance testing of "0" EDG

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50 373/374 97007 03 NCV Inadequate procedures for temporary alterations 50 373/374 97007 04 NCV Failure to implement controls for a temporary alteration 50-373/374 97007 05 VIO Imprcper labeling of contaminated systems

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LIST OF ACRONYMS USED AOV Air Operated Valves ASME American Society of Mechanical Engineers CRD Control Rod Drive CRS Control Room Supervisor

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DRP Division of Reactor Projects j

DRS Division of Reactor Safety EDO - Emergency Diesel Generator FSAR Final Safety Analysis Report LAP LaSalle Administrative Procedure

LCO Limiting Condition for Operation LER Licensen Event Report i

LGP LaSalle General Procedure

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LIP LaSalle Instrument Maintenance Procedure

LlS LaSalle instrument Surveillance LLP LaSalle Limited Procedure

LMP - LaSalle Mechanical Maintenance Procedure LOP LaSalle System Operating Procedure LOS LaSalle Operating Surveillance LRP LaSalle Radiation Protection Procedure

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LPCI Low Pressure Coolant injection LTP LaSalle Technical Staff Procedure MPT Main Power Transformer NCV' Non Cited Violation

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NRC Nuclear Regulatory Commission NSO Nuclear Station Operator OOS Out Of Service PlF Problem identification Form PDR NRC Public Document Room RHR Residual Heat Removal RP Radiation Protection

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SAT Station Auxiliary Transformer SDC Shutdown Cooling SM Shift Manager SQV Site Quality Verification SRO Senior Reactor Operator

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TALT Temporary Alteration TS-Technical Specification UAT Unit Auxiliary Transformer VIO : Violation WCC -Work Control Center.

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