IR 05000373/1997011
| ML20212B316 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/15/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212B296 | List: |
| References | |
| 50-373-97-11, 50-374-97-11, NUDOCS 9710280045 | |
| Download: ML20212B316 (22) | |
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U.S. NUCLEAR REGUt.ATORY COMMISSION REGIONlli Docket Nos:
50 373; 50 374
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Ucense Nos:
NPF 11 NPF 18 Report No:
60-373/97011(DKD); 60-374/97011(DRP)
Licensee:
Commonwealth Edison Company Facility; LaSalle County Station, Units 1 and 2 Location:
2001 N. 21st Road Marseillee,IL 61?41 Dates:
June 28. August 8,1997 Inspect:>rs:
D. Calhoun, Acting Senior Resident inspector J. Hansen, Resident inrpector R. Crane, Resident inspector C. Mathews, Illinois Department of Nuclear Safety Approved by:
Anton Vegel, Acting Chief, Projects Branch 2 Division of Reactor Projects l
9710200045 971015 PDR ADOCK 05000373
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EXuCUTIVE SUMMARY LaSalle County Station, Units 1 and 2 NRC Inspection Report 50-373/g7011(DRP); 50-374/g7011(DRP)
This inspection report includes aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6 week period of inspection conducted by the resident staff.
OntIAll0DI The inspectors identified that the licensee failed to implement adequate corrective actions
for a previously identified violation concoming the emergency diesel generator (EDG)
cooling water strainer backwash procedure. The licensee did not verify the adequacy of the procedure prior to its implementation, in addition, operations and engineering personnel did not recognize the effect of the incorrect handle length on operability.
(Section 01.1)
The shift manager demonstrated a lack of questioning attitude when seismic operability
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issues with equipment in switchgear rooms and the main control room were r...) promptly addressed. Also, the inspectors determined that plant management was not effective in performing oversight responsibilities for the identified seismic concerns. Manngement did not challenge or confirm the applicability of a previously completed generic seismic evaluation to the current situation. (Section 01.2)
The licensee's efforts to remove operator work arounds from the plant was a positive
initiative. However, the inspectors identified some deficiencies with implementation of the Improvement program. (Section 02.1)
Operations personnel accepted the poor material condition of the scram solenoid pilot
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valves, which resulted in a reactor scram during a surveillance test. (Section 02.2)
The inspectors identified a violation for the operator's failure to follow an administrative
procedure during post modification testing. The operator did not perform all the procedure steps as required. (Section 03.1)
The out of service (OOS) program remained an area of concern due to the personnel
errors and procedural problams that were noted by the Inspectors during the inspection period. (Section 03.2)
MR!QlelL8E9 The inspectors determined that personnel errors resulted in missed surveillance testing.
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Implementation of the surveillance program continued to be an area of concem.
(Section M3.1)
Maintenance and engineering personnel were unfamiliar with the procedure used for
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performing troubleshooting of equipment failures. Operations personnel communicated the need to use the procedure before any steps in the procedure were misse6.
(Section M4.1)
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Engineerino Engineering personnel did not recognize that unenchored equipment in the control room
was a seismic concem and did not determine the operability of the 1 A emergency diesel ponerator cooling water system until questioned by the inspectors. (Section E2.1)
Engineering personnel did not ensure training and procedure revisions were completed
prior to placing the control room seismic monitoring system back in service following a modification. This demonstrated a lack of attention to detail and some weaknesses in the licensee's modification process. (Section E2.2)
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The licensee was slow in identifying a broken fuel pin due to a number of deficiencies in
the control and oversight of nuclear material. Specifically, licensee personnel demonstrated a lack of questioning attitude, the special nuclear material piece count procedure was inadequate, and the fuel pin canister was stored in an inappropriate
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Etport Details Summary of Plant Status During this inspection period, the licensee maintained Unit 1 in cold shutdown (Mode 4) for a forced outage and Unit 2 remained shut down for a refueling outage with all fuel removed from the reactor.
LOperations
Conduct of Op3 rations 01.1 lagdecuate Corrective Actions for Ensurina a Manual Backwash Function a.
Insoection Scope f71707)
The inspectors reviewed the material condition of the 1 A emergency diesel generator (EDG) cooling water and 1 A residual heat removal (RHR) service water (SW) strainers.
The inspectors interviewed operations and engineoring personnel and reviewed applicable procedures which included:
LaSalle Operating Procedure, (LOP) DG-04 " Diesel Generator Special
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Operations," Revision 21 LOP RH 14. " Backwash of the Residual Heat Removal Service Water Strainers,"
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Revision 7 b.
Observations and Findina On July 8,1997, the licensee de-energized a non safety related 4100 volt bus for planned maintenance. De-energization of this bus resulted in the loss of power to the 1 A EDG cooling water strainer automatic backwash function. Operations personnel determined that the 1 A EDG remained operable because a manual backwash could be performed if needed. A control room panel alarm wo aid aler1 the operators of a strainer high differential pressure condition.
j On July 9,1997, the inspectors revles y the manual backwash procedures for the 1 A EDG cooling water and RHR SW strainers. The procedures specified the use of a handle, which was attached to the each of the strainers, to perform a manual backwash.
The inspectors identified that a manual backwash could not be performed on the 1 A EDG cooling water strainer due to interfernnce from an adjacent structural steel beam. The inspectors informed the operations management of this deficient condition. Operations personnel declared the 1 A EDG inoperable after confirming a manual backwash could not be performed as specified by the backwash procedure, LOP DG-04. The shift mancger subsequently declared the 1 A EDG operable after maintenance personnel shortened the handle.
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The inspectors had the following concoms:
Violation (50 373/96009-02a; 50 374/96009-02a) was issued on January 24,
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1997, for the licensee's failure to assure that LOP DG-04 and LOP RH.4 contained specific instructions for the proper placement of the manual backwash handle and adequate instructions for performing a manual backwash. The licensee's corrective sections for the lack of specific instructions included revising these procedures. However, after LOP DG-04 was revised, licensee personnel did not verify that the manual backwash could be performed as specified in the revised procedure.
The problem with the excessive handle length was previously identified by the
licensee on February 17,1997. The licensee initiated action request No. 970017246 to reduce the length of the handle so it could be used to perform the manual backwash. However, the work was not completed until the inspectors questioned the operability of the stralners on July 9,1997.
The failure of the licensee tc implement corrective actions to ensure that the manual backwash could be performed in accordance with the manual backwash procedure, LOP DG 04, was considered a violation of 10 CFR Part 50, Appendix B, Criterion XVI, as described in the attached Notice of Violation (50 373/9701101).
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ponclusions The licasee failed to implement adequate corrective actions for a previously identified violation concerning the manual stralner backwash procedure LOP DG 04. In addition, operations and engineering personnel did not recognize the potsntial effect on system operation when the incorrect handle length was identified.
01.2 k!ntimelv Operability Assessment for Seismic Concems with Unsecured Eautoment a.
jnipection Scope f71707)
The inspectors reviewed tile licensee's actions to address extraneous unsecured equipment that had the potential to adversely impact safety related equipment and place the plant outside its design basis. The inspectors interviewed operations and engineering personnel and reviewed the applicable station policy and other related documentation.
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Observations and Findinas On July 10,1997, the inspectors informed the control room supervisor (CRS) that some equipment located in the main control room (MCR) was unsecured and could potentially affect the MCR panels during a seismic event. The CRS did not take appropriate actions to address this potential operability issue. As a result, an initial operability determination for this condition was not made until July 15,1997. In addition, the correct determination regarding operability was not made until July 23,1997. The inspectors noted that the discrepant condition was brought to operations management attention on several occasions as specified below:
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I On Juh 15,1997, regulatory assurance personnel notified operations support staff
and engineering personnel of the potential operability concem. Operations i
personnel initiated a problem identification form (PlF), No. L1997 04500, on July 17,1997, to notify plant managemord about the problem. During the review i
of the PlF, the licensee lacorrecty concluded that a 1991 evaluation for unsecured equipment bounded the currerd cond# tion. However, the inspectors identified that the current condition was not bounded since the unsecured equipment was located in unapproved areas. Plant management reviewed this PlF and also did
not challenge or confirm the applicability of the 1991 generic evaluation.
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On July 15,1997, engineering personnel identified a concem with an unsecured
cabinet in the auxiliary electric equipment room. The licensee recognized the
issue as an operability concem and notified the NRC as required por 10 CFR
Par 150.72.
On July 23,1997, engineering personnel identified concems with unsecured
equipment in the control room. The licensee notified the NRC of the issue as
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required per 10 CFR Part 50.72.
On July 24,1997, engineering personnel identified that unenchored equipment in -
the switchgear room for both Unit 1 and Unit 2 could impact the function of safety equipment during a seismic event. The shift manager had the unenchored
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equipment removed but did not evaluate this condition until Ju!y 29,1997. The licensee notified the NRC as required by 10 CFR Part 50.72.
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LaSalle Administrative Procedure (LAP)-220 5, " Equipment Operability Determination,"
Revision 5 Step F.2.a. required that personnel notify the shift manager of any possible operability issues. Step F.2.d of LAP 220 5 required the shift manager to determine the operability of safety related systems within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The failure of the licensee to make the initial operability determination for the control room and switchgear rooms within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was considered an example of a violation of 10 CFR Part 50, Appendix B, Criterion V, as described in the attached Notice of Violation (50 373/9701102a; 50 374/9701102a).
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in addition, the int.pectors identified a discrepancy between the information contained within the operability assessment completed on July 25,1997 and the NRC event notification made on July 23,1997. The licensee's event notification stated that squipment which could have been damaged by the unanchored equipment was not required in the current mode. However, tne licensee documented in the operability assessment that EDG equipment which was required in the current mode, could be affected. The licensee corrected the information as required.
The licensee permanently located unenchored equipment in the MCR, auxiliary electric equipment rooms, and all switchgear rooms prior to 1990. The permanent storage of this equipment constituted a design change to the facility because the licensee did not
= consider the resulting seismic implications. The licensee's failure to identify the unenchored equipment in the MCR, the auxl!!ary electric equipment rooms, and all switchgear rooms as a design change was considered a violation of 10 CFR Part 50, Appendix B, Criterion lli (50 373/9701105; 50 374/97011-05). However, the NRC is not citing this violation because it satisfies the criteria delineated in Section Vll.B.2 of the
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NRC's enforcemM policy (HUREG 1600). Specifically, the licensee has ontored an i
extended shutdown; enforcement action is not considered necessary to achieve remedial
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action; the violation is based upon activkies of the licensee prior to the events leading to
the shutdown; the violation would not be categottred at Severity Level ll; the violation was
not willful; the lloonsee's decision to restart the plant requires implicit NRC concurrence; i
and aNhou0h the violation was not identified by the licensee, the violation meets the other orMoria and enforcement action was not needed to achieve remedial action.
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Condusion
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The shift manager's deley in reporting the operability issue with equipment in ownchgear j
room and control room demonstrated a lack of questioning attitude. Also, in this case,
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licensee managemord was not effective in performing hs oversight responsibilities, in their review of a PlF for seismic concems, management did not challenge or confirm the applicability of the 1991 generic seismic evaluation.
l 01.3 Assessment of Performance indicators
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Insoection Soone (71707)
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% licensee's response to the 10 CFR Part 50.64(f) letter dated March 28,1997, l
delineated performance indicators that would be used to trend and monitor plant
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performance. During this inspection period, the inspectors reviewed the performance Indicator data as reported through June 1997. The inspectors interviewed operations and
corrective action department personnel, observed corrective action program (CAP)
processes, analyzed CAP quantitative data, and reviewed the following documents:
LaSalle County Nuclear 8tation Unit 1/ Unit 2 Restart Plan, dated May 16, igg 7
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LAP 1500-04, " Site Program For Tracking of corrective Action," Revision 21
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Nuclear Station Work Procedure (NSWP) A 16, " Comed Nuclear Division
Integrated Reporting Program," Revision i
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Observptions and Findinos l
The inspectors determined that the data used to described the performance indicators L
was consistent with the definition of the performance indicators. The inspectors performed a metailed review of the operator work around and overdue corrective actions i
performance indicators as well as the licensee's implementation of the CAP program and concluded the following:
The operator work around (OWA) performance indicator accurately reflected the
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current status of the OWAs However, the inspectors identified numerous deficiencies with the OWA process as discussed in Section 02.1.
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The method used 'o gather ared report overdue corrective actions was
inconsistent. For example, restart action plan hem 3.1 required that th9 number
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of overdue corrective actions be maintained less than 15 per quarter. The licensee monitored this performu indicato." on a weekly basis, items whicn-l
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t t,eoame overdue on a weekday would not be considered as overdue if the hem was completed later in the wook. This resulted in en inacoutste indicator for overdue corrective actions. 91:: rsy, station management changed the -
reporting frequency to dai$
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Procedure LAP 15004 allowed department manager subordinates to sign for i
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(Josure or extension approval when the department manager was off-site. The CAP manager identified that this practice was excessively used and initiated
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tighter administrouve controls. The inspectors considered the CAP manager's
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acuons WW ' since this practice resulted in non-uniform closure and
uncontrolled extensions.
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.The inspectors identified that nuclear trackbg system (NTS)
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No. 373103 96-04501 had been extended from January 15,1998, to June 15,
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1998. The NTS Nem involved a review of an information Notice which the
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licensee had adequately addressed in response to a Generic Letter. The inspectors determined that the extension was not needed since the hem was
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completed. The inspectors also noted that management lid not challenge the
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extension and that the extension was i.ot screened agL.st restart critetta as
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specified in the resteet plan.
The inspectors identified that some actions closed to other tracking programs
such as action requests or engineering requests were back-logged or could be deleted without a review by plant management. This could resun in restart Hems no'. being completed. The licensee was evaluating potential administrative
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enhancements to prevent this type of discrepancy.
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Conclusion i
Ahhough some conoems were identified with the performance indicators which were used
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to assess corrective action timeliness and operator work arounds, the performance i
indicators were consistent with plant conditions and personnel performance. The l
licensee had taken or planned several actions to improve the management oversight of the CAP and the reliability of the data.
of Operational Status of Facilities and Equipment
02.1 OperatorWork Arounds
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Inacection Scone (71707)
i The inspectors assessed the licensees's implementation of the OWA program. The
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inspectors interviewed plant personnel, conducted plant walkdowns, and reviewed applicaole procedures and documentation wnich included:
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LaSalle County Nuclear Station Unit 1/ Unit 2 Restart Plan, dated May 16,1997,
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- Restart Action Plan item 1.2A, operator Work Arounds -
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. LaSalle Nuclear Station Operating Department Memorandum No.14, " Operator
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Work Around Process," Revision 1, dated January 20,1997.-
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Observations and Find %tt
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The inspectors reviewed the licensee's implemer;tation of the OWA process and noted the following:
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. The operations support supervisor was not familiar with the operator work around
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process memorandum shhough the supervisor was tasked with its -
implementation.
The inspector identified the OWA charts and graph & were not posted as specified
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by the memorandum. This error did not create any adverse conditions, but reflected inattention to detail.
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The previous OWA coordinator had not ensured a timely review of PlFs for l
identifying potential OWAs. The licensee subsequently reviewed 36 PIFs and identified 6 additional OWAs.
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fdtoplusions The licensee's efforts to resolve the OWA problem was a positive initiative. However, the inspectors identified some deficiencies with implementation of the program.
02.2 lnadvertent Unit i Scram Durina Surveillance Testina
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Inspection Scope (71707)
j On July 23,1997, a reactor scram occurred on Unit 1 while performing a surveillance i.
test.- The reactor was not operating and was in cold shutdown (Mode 4) with all control rods fully inseded at the time of the scram. The inspectors reviewed the surveillance procedure being performed when the scram occurred, LaSalle Electrical Maintenance Surveillance (LES)-PC-108, " Main Steam isolation Actuation Logic System Functional Test,"_ Revision 4. In 3ddition, the inspectors interviewed cperations and engineering personnel, and evaluated plant data related to the scram, b.
Observationspnd Findinas
.While electrical maintenance personnel weie performing surveillance test LES-PC-108, a reactor scram signal was generated when the scram discharge volume level reached the high level scram setpoint. The licensee determined that air leaks on the scram solenoid pilot valves (SSPV) and degraded SSPV diaphragms allowed water to leak through the
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scram valves to the scram discharge volume. The surveillance procedure test is a functional test of the main steam isolation logic.
During discussions with the operators, the inspectors noted that the annunciator for scram pilot valve air header low pressure alennet during the test The operators stated that this alarm was anticipated during this test due to the air leaks on the SSPVs. This deficient material condition of the SSPVs was identified by the licensee in 1994 and long-term corrective actions (discussed in Section E2.1) were initiated. The operators stated
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that the matsrial condition concem was discussed six weeks prior to this event when
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operators identified the SSPVs were leaking significantly while hanging an out-of-service.
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Condusion
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Operations personnel continued to accept the poor material condition of the SSPVs which resulted in a reactor scram. - The decision by operations personnel to perform the test z without addressing the longstardng material condition concem demonstrated a lack of '
recognition of potential adverse affects of equipment problems.
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03:
Operations Procedures and Documentation
' 03.1 Inacorocriste Marking of Procedurpi Steps as Not Applicable (NA)in Surveillance i
Procedures a.
InsnectierLScont(7_1101)
The inspectors observec post-modification testing of the 1B EDG, reviewed documentation of test results, and interviewed operations personnel. Procedures
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LAP-100 40, " Procedure Use and Adherence Expectations," Revision 11
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LAP 10029, " Conduct and Review of Station Surveillance," Revision 6
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DCP [ design change package) 9600568 TEST, " Modification Test for DCP
g6005G81B Diesel Generator Voltage Regulating Circuit Test," Revision 4 i
LaSalle Operating Surveillance (LOS)-HP-Q1, "HPCS [high pressure core spray]
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System inservse Tsst," Revision 34
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LOS-DG-M3, "1 B(28) Diesel Generator Operability Test," Revision 35
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Observctions and Findinas On July 29,' 1997, the insp6ctors observed portions of DCP 9600568 TEST which included the concu7ent performance of LOS-DG-M3 and LOS-HP-Q1. Step F 7.5 of
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DCP g600568 TEST required that the HPCS pump be shut down by completing LOS HP-Q1, Attachment 1, Step 16._ The nuclear station operator, following discussions with the CRS, marked Substep 16.e as "NA" because this action would be completed
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fan has shutdown, then place the 18 DG cooling water pump control switch in normal
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after stop." The operator completed the remaining steps and exited LOS-HP-Q1.
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The inspectors questioned the CRS as to whict; brocedure allowed Substep 16.e to be marked as "NA." The CRS indicated that Step B.6.1 of LAP-100-40 allowed him to mark steps as "NA" within a surveillance procedure when performing a partial surveillance.
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However, the inspectors identified that LOS HP-Q1 was not being performed as a partial surveillance and that Step 16.e performance was required. Step B.6.2 of LAP-100-40 required that all numbered steps in an operating surveillance be performed in sequence.
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an example of a violation of 10 CFR Part 50,' Appendix B, Criterion V, as described in the attached Notice of Violation (50 373/97011-02b; 50 374/97011-02b). In addition, the
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j inspectors determined that the restrictions on the use of NA were not discussed during licensed operator training.
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The inspectors also reviewed procedure LAP 10040 and noted contrary guidance in Steps B.6.1 and 8.5.2. - 8tep D.6.1 allowed a supervisor to designate steps to be -
wTC'.ed within a subsection as required to perform a partial surveillance. However, Step 8.5.2 required the supervisor to use a Temporsty Procedure Change for the same
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task. The licensee revised the procedure to eliminate the contradiction.
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Conclusions The inspectors concluded that during the post modification testing, the steps in the
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procedure were inappropriately marked as "not applicable" by the operators as discussed -
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in the attached Notice of Violation, in this case, the error occurred due to the lack of training and inconsistent guidance on the procedure change process provided to operators.
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03.2 Continued Out-of-Service (OOS) Implementation Problems a.
Inspection Scope (62707 The inristors reviewed severallicensee identified OOS error events. The inspectors interviewed the operations manager and work control personnel. The licensee's investigation report of the event and applicable PIFs were also reviewed.
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Observations and Findinos
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OOS. Software Pronram Did Not Prevent Premain emoroval for Eauloment Relean l
On July 15,1997, mechanical maintenance department (MMD) personnel completed work
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request No. 960088443-01. The MMD supervisor incorrectly released the associated OOS (No. 9700003833) to operations personnel for final clearance. The work control
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center operator identified that some work was outstanding on this OOS and did not i
remove the OOS, The licensee performed a prompt investigation and determined that the MMD supervisor should have released the OOS only for work request No. 960088443-01, not for final clearance. Be electronic work control station program was not designed to wam an individual that iher work requests remained open on an OOS. The licensee initiated actions to investigate adding this feature to the electronic
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work control system program.
Inadvertent Drainane of the Cveled Condensate Tank (CCT)
On July 26,1997, operations personnel inadvertently drained 9,000 gallons of water from the CCT to the turbine building sump. Prior to the drain event, operations personnel commenced clearing the condensate system OOS No. 970003833. Operators restored power to the hotwell emergency reject valve controller which caused the hotwell emergency reject valve,1CD015, to reposition full open. Control room personnel received an emergency reject annunciator, observed a decrease la CCT level and placed
- tha hotwell reject controller to the automatic position. This caused 1CD015 to close i
which stopped the CCT level decrease. The licensee identified that the air supply valve it
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to the controller was not placed in the proper as-left position after maintenance in December 1996. Although the licensee's corrective actions were appropriate, this inadvertent dralnage event resulted from deficiencies in the OOS program.
Other OOS oroblems The licensee had generated a number of PIFs regarding OOS problems including:
(1) Bus drop outages affecting work in progress; (2) all affected equipment not identified as part of an OOS; and (3) wrong equipment identified to be affected by an OOS.
c.
Conclusion The licensee has not implemented a fully effective OOS program as evidenced by continuing personnel errors and procedural problems that were identified in the licensee's
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implementation of the OOS program, The OOS program remains an area of concem.
11. Mainterlangt M3 Maintenance Procedures and Documentation M3.1 Continued Problems in Imolementina Surveillance Program a,
inspection Scooo (62703)
The inspectors reviewed testing requirements for the 1 A RHR pump and three process radiation monitors (PRM) (RHR Service Water A PRM, RHR Service Water B PRM, and Reactor Building Closed Cooling Water PRM). The inspectors interviewed operations and engineering personnel and reviewed the following procedures:
LAP-100 29, " Conduct and Review of Station Surveillance," Revision 6
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LOS-PR-M2, " Service Water, RHR Service Water, and RBCCW [ reactor building
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closed cooling water) Process Radiation Monitors Source Check," Revision 6 LOS RH-Q1, "RHR (LPCI) [ Low Pressure Coolant Injection] and RHR Service
Water Pump and Valve Inservice Test for Operational Conditions 1,2, 3,4, and 5," Revision 38 b.
Observations and Findinas During this inspection period, the licensee failed to perform two surveillance tests as required by Technical Specifications. In the first instance, on July 18,1997, the licensee identified that required testing of the 1A RHR pump had not been performed within the allowable testing interval. Operators performed LOS-RH-Q1 on April 22,1997, and found the pump to be in the alert range due to low differential pressure..This alert status required the pump be tested no later than June 18,1997. A clerk failed to route the surveillance to the inservice test engineer for review. As a result, the engineer was not aware of the need to increase the testing requirement for the pump to twice per quarter.
The licensee determined that the 1A RHR pump had been inoperable between June 18
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and Juh 17,1997, due to the failure to perform the increased testing, Licensee corrective actions included changes to procedures that govem conduct of the surveillance and inservice testing programs and counseling of the involved individuals.
In the second instance, on July 28,1997, the licensee identified that LOS-PR M2, which the licensee used to perform source checks on four PRMs, had not been performed within the required frequency. The licensee determined that on July 3,1997, operators performed a portion of LOS-PR-M2 specifically for the Service Water PRM following maintenance. The test was correctly identified as a partial surveillance. However, on July 7,1997, an operations department surveillance coordinator inappropriately categorized the partial surveillance as a completed survoillance in the computer scheduling program. As a result, the scheduling program automatically computed the next performance of LOS-PR M2 using July 3,1997, as the previous completion date.
The Offsite Dose Calculation Manual Table 12.2.12 required a monthly source check for the RHR service water A and B PRMs. The monthly source check was required to be performed prior to July 19,1997. The failure to perform a source check on the RHR service water A and B FRMs within the required surveillance interval was considered a violation of Technical Specification 6.2.A.f as described in the attached Notice of Violation (50-373/97011 04; 50-374/97011-04),
Although missed surveillances has been a problem within the last two years (Inspection Report 50-373/97003; 50 374/97003), inspectors determined that the cause of the first example described above, failure to route the test results to the inservice test engineer, was sufficiently different than that of the previous occurrences. Therefore, this non-repetitive, licensee-Identified and corrected violation is being treated as a Non-Cited Violation of Technical Specifiention 4.0.5, consistent with Section Vil.B.1 of the NRC Enforcement Policy (50 373/9701103), However, the cause of the second example, mistaking a partially completed surveillance test as a full test, is similar to the cause of a previous violation (50 373/97003-03) for a missed surveillance. Therefore, the second example is being cited.
c.
Conclusions Personnel errors resulted in missed surveillance testing. Implementation of the surveillance program continued to be an area of concem.
M4 Maintenance Staff Knowledge and Performance M4.1 Troubleshootino of the 1B EDG Output Breaker Voon the Failure to Close s.
Inspection Scope (62703)
The inspectors observed troubleshooting activities following the failure of the 1B EDG output breaker to closa during modification testing. The inspectors interviewed operations, engineering, and maintenance personnel, and reviewed applicable procedures including:
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i LOS-DG-M3, "1B(28) Diesel Generator Operability Test," Revision 36
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LaSalle Technical Procedure (LTP) 5001, " Diesel Generator Output Breaker
Troubleshooting Procedure," Revision 7-LAP-100 40, " Procedure Use and Adherence Expectations," Revision 11
b. -
Observation and Findinas On July 24,19g7, operations personnel were performing post-modification testing on the
1B EDG, when during the test, the 1B EDG output breaker failed to close. Operations
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_ personnel contacted electrical maintenance and engineering personnel and instructed
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them to use LTP 5001 to conduct troubleshooting activities as specified by LOS-DG-M3.
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Although instructed to obtain a copy of LTP 5001, the individuals of the troubleshooting
- team arrived at the jobsite without the procedure and proceeded to check the synchronization relay and the control fuses. When an operations supervisor realized that i
LTP 5001 should be used for troubleshooting activities, all troubleshooting activities were terminated. Subsequently, licensee personnel obtained a copy of the procedure and proceeded with the troubleshooting activities. The licensee determined that operator error in racking in the breaker caused the breaker not to close.
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Violation (50 373/g6010 01; 50-374-g6010-01) had been issued previously for the failure of system engineering and electrical maintenance personnel to follow LTP-5001 during troubleshooting activities on the 0 EDG output breaker, in reviewing this issue, the inspectors determined that the licensee had classified LTP-500-1 as an "lNFORMATION" level procedure. A procedure with this classification was not required to be at the work
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site and was expected to be performed from memory. The inspectors reviewed LTP-500-
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1 and found the procedure contained a significant number of steps which would be very l
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difficult to accomplish from memory, j
l c.
Conclusions Although operations personnel were cognizant of the procedure that was to be used when performing troubleshooting activities, maintenance and engineering personnel were not familiar with its purpose, Operations personnel communicated the need to use the procedure to the personnel performing the troubleshooting activities prior to any missed procedural steps that could have led to poor root-cause analysis for the problem under
!
Investigation.
Ill Enaineerina i
i E2 Engineering Support of Facilities and Equipment L
E2.1 Enaineerina Personnel Suocort in Addressina Daily Issues
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a.
inspection Scope (37551)
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I The inspectors assessed engineering personnel's involvement in the identification and j
resolution of daily plant issues. The inspectors interviewed engineering personnel and i
reviewed applicable procedures and documentation.
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Observations and Findmos
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The inspectors reviewed the followmg engineering issues:
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Handle Deficiency on the 1 A EDO Coolina Water Strainer As discussed in Section 01.1, the system engineer did not aggressively resolve the 1A EDG cooling water strainer handle length discrepancy. Between October 18,1996, and
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February 17,1997, the licensee had written four separate action requests on this.
deficiency. ~ The system engineer did not recognize that the deficient condition adversely affected system operation.
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Non seismically Secured Equipment in Various Locations of the Plant As discussed in Section 01.2, engineering personnel were proactive in identifying unanchored equipment in the auxiliary electric equipment room and batteries rooms.
However, engineering personnel did not recognize the same operability concem existed in the control room.
i LeaMna SSPVs Problems with the SSPV diaphragm have been a concem since 1994. The licensee
- determined that the "Buna-N" diaphragms were subject to hardening which prevented a proper seal. - The licensee had planned to replace the diaphragms in the Spring 1996
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' outage; however, appropriate replacement diaphragms were not available. The system engineer was actively involved in planning repair activitias. The licensee planned to replace all of the diaphragms on both units prior to the unit's restart which was considered to be appropriate, c.
Conclusion
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Concems with unenchored equipment in the plant and with the 1 A EDG cooling water strainer handle identified by engineering personnel were not property addressed in a timely or thorough manner. The engineering personnel did not recognia e that unanchored equipment in the control room was a seismic concem and did not determine the operability of the 1 A EDG cooling water system until questioned by the inspectors.
Engineering involvement in the SSPV issue was appropriate.
E2.2 Seismic Monitorina System Modification Imoroneriv Closed a.
inspection Scope (37551)
. On June 29,1997, operations personnel identified that the MCR seismic monitoring
>
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system alarm and system operating procedures did not reflect recent modifications made to the system, The inspectors interviewed operations and engineering personnel and l reviewed the following documents:
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. LOP-88-01, " Seismic Monitoring System Startup and Shutdown," Revision 3
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Operating Abnormal Procedure (LOA) 1PM10J-B503, " Seismic OBE/SEE
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- - [ Operating Basis Earthquake / Safe Shutdown Earthquake] LVL [ LEVEL] /
Exceeded," Revision 8 LOA 1PM10J-8504, " Strong Motion Beismic instrument System initiated,"
. *
Revision 6
DCP 94-00128, " Seismic Monitoring OPA11J Replacement," dated May 5,1994 -
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LAP-130019, " Controlled Design Changes," Revision 2 e
b. -
Observations and Findinas The licensee installed a new control room seismic monitoring system under.
DCP 94-00128.-_ Th6 system was declared operable on June 28,1997. On June 29,'
1997, operations personnel received a spurious seismic alarm during a thunderstorm and determined that the alarm proceduras were not accurate. The system was declared -
The inspectors reviewed the modification package and the implementation schedule and identified the following concems:
The inspector determined that the modification schedule did not include
completion and issuance of procedures for system operation. As a result, the MCR seismic monitoring system had been improperty retumed to service after engineering personnel closed out the modification (DCP 94-00128) on June 28,
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1907. The control room copies of procedures LOA 1PM10J-8503 and
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4-LOA 1PM10J-B504 were not revised to reflect the new modification end were -
deficient. Operators did not have applicable procedures to respond to a seismic
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alarm.-
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. The design engineer delineated required training for operations personnel prior to
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system operation on Attachment F. " Training Required as a Result of a Design.
Change," of LAP 1300-19. The design change coordinator irw.orrectly marked that the training had been completed. However, the inspectors identifed that the
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operator training had not been approved nor initiated until June 30,1997, which was two days after the MCR seismic monitoring system was originally declared operable. The licensee stated that the training delay was due to problems with
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system design and int,tallation.
The licensee determined that personnel error resulted in a delay in posting the revised procedures for this modification. Corrective actions included completing training on the new system and ensuring the revised procedures were distributed prior to re-declaring
- the seismic system operable. The failure to property maintain LOA-1PM10J B503 and -
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LOA 1PM10J-B504 to respond to an earthquake is centrary to Technical -
Specification 6.2.A.a and was considered a Non-Cited Violation, consistent with Section Vll.D 1 of the NRC Enforcement Policy (50 373/97011-06).
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Conclusions The inspectors concluded that engine * ring personnel did not ensure training and procedure revisions wera completed prior to closing out the MCR seismic monitoring system modification. This demonstrated a lack of attention to detail and some deficiencies in the licensee's modification process.
E3 Engineering Procedures and Documentation E3.1 Inadeguate Spent Fuel Pool Inventory Procedure and Weak Manaaement Oversloht Resulted in the Failure to Tirr.elv Identify a Broken Fuel Rod Section a.
Inspection Scope f37551)
The inspectors observed the licensee's actions following the discovery of a broken section of a fuel rod in the Unit 2 spent fuel storage pool. The inspectors reviewed the applicable procedures and interviewed plant and corporate personnel. Documents reviewed included:
LTP-1300-2, "Special Nuclear Material Piece Count inventories," Revision 12
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Commonwealth Edison Company, Nuclear Material Control Procedure No. 4
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(NP-4), " Physical Inventories of Nuclear Fuel and Other Special Nuclear Material (SNM) Items," dated May 2,1994 LaSalle Limited Procedure (LLP)-97-025," Unit 2 Fuel Pool Cleanup Project,"
.
Revision 0 b.
Observations and Findinas On July 17,1L97, during performance of the Unit 2 fuel pool cleanup project, the fuel handlers identified a broken section of a fuel rod, about 3-feet in length, resting in the bottom of empty control blade storage cell, SR3-A-2. The licensee determined that the broken fuel rod section was part of a fuel rod removed from a Unit 1 fuel bundle, LYF289, which had been reconstituted on May 30,1989. In November 1990, the fuel rod was moved to storage cell SR3-B-0. The licensee could not determine the date when the fuel pin broke. The inspectors noted that storage SR3-B-0 was in a high traffic area of the fuel pool which may have contributed to the fuel pin damage. The licensee's immediate corrective actions included:
Verification that the cladding on the section of broken rod was intact. However,
the licensee could not verify all pellets were contained within the cladding due to inoperable support systems necessary operate the fuel handling equipment and move the fuel.
Determination that the radiological hazards from stray pellets or gaseous releases
were negligible.
Performance of a criticality assessment which concluded that the spent fuel pool
remained subcriticai.
91P
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Training for all fuel handlers and nuclear engineers on the disco, y of the broken
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pin.
-The inspectors noted that the Nuclear Materials coordinator (NMC) had rocc ded the storage cell SRS-A-2 as empty during previous fuel pool inspections. Also, tr,a fuel handlers and NMC did not question why a fuel rod stored in SRS-A-2 was severed. The licensee determined that the broken fuel rod was not identified during the quarterty inventories because the original configuration of the fuel rod was not documented in sufficient detail. Personnel performing the inventories know that one of the rods in
. SRS A 2 was missing a lower end plug. This would cause the rod to sit lower in the storage canister, Therefore, the fuel handling personnel did not notice that a section of a fuel rod was missing.
The fuel inventory and piece count procedure did not require documentation of the visual configuration of disassembled or partialitems not contained in a sealed container. The failure to provide adequate acceptance criteria h perform an inventory of nuclear fuel in the spent fuel pool was considered a violation of 10 CFR Part 50, Appendix B, Criterion V (50-373/9701107; 50-37N9701107). However, this issue was licensee-identified and
- was considered a Non-Cited Yolation, consistent with Section Vil.B.1 of the NRC
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The inspectors also noted that Site Qelity Verification and Corporate Nuclear Fuels
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Services personnel had not performed an audit in this area since 1989. By the end of the inspection, the licensee had not relocated the fuel pins or initiated actions to identify loose fuel pellets. This issue is an Inspection Followup item (50 373/97011-08;
-50 37W97011-08) pending completion of these long term corrective actions.
c.
Conclusions
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The inspectors concluded that the licensee was slow in identifying the broken tuel pin due to a number of deficiencies in the control and oversight of nuclear material. Specifically, the NMC and fuel handling personnel demonstrated a lack of questioning attitude, the special nuclear material piece count procedure was inadequate and the fuel pin canister was stored in an inappropriate location.
V. Manacement Meetinos
.
I X1 Exit Meeting Summary
- The inspectors presented the results of these inspections to licensee management listed below at an exit meeting on August 11,1997. The licensee acknowledged the findings presented. The inspectors asked the licensee if any materials examined during the inspection should be considered proprietary. The licensee identified none, X3 ManagemeM Meeting Summary -
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On July 2,1997, NRC staff met with Commonwealth Edison personnel at the emergency operating facility in Mazon, Illinois to discuss the LaSalle Restart Plan and the licensee's
. experience with the implementation of the plan.
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PARTIAL UST OF PERSONS CONTACTED fdElfd
W. Subalusky, Site Vice President
- F. Decimo, Plant General Manager
L Guthrie, Unit 1 Piant Manager
- 8. Smith, Unit 2 Plant Manager J. Mcdonald, Site Quality Verification / Safety Assessment Manager N. Hightower, Health Physics Supervisor
- P 3ames, Regulatory Assurance Supervisor
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- * Present 'at exit meeting on August 11.1997.
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INSPECTION PROCEDURES USED IP 37551 -
Onsite Engineering IP 62703 Maintenance Observation IP 71707 Plant Operations ITEMS OPENED, CLOSED, AND DISCUSSED Open 50-373/97011 01 VIO Failure to implement effective corrective actions for the inability to perform a manual backwash function on the 1 A EDG cooling water strainer 50-373/374-97011-02a VIO Failure to evaluate unanchored equipment located in the control room sad switchgear rooms in a timely manner 50 373/374-97011-02b VIO Failure to perform all procedure steps as specified by administrative procedure LAP-100-40 50-373/97011-03 NCV Failure to test the RHR pump within the required increased surveillance frequency 50-373/374 97011-04 VIO Failure to complete surveillance testing on two process radiation monitors as required 50-373/374-97011-05 NCV Unsecured equipment in control room and other rooms 50-373/374-97011-06 NCV Failure to issue 3dequate procedures required to respond to a pnssible seismic event 50 373/374-97011-07 NCV Failure of the fuelinventory and piece count procedures to provide adequate acceptance criteria to perform an inventory of nuclear materialin the spent 50-373/374-97011-08 IFl Review licensee's corrective actions for potentially missing fuel and identification of loose fuel Closed 50-373/97011-03 NCV Failure to test the RHR pump within the required increased surveillance frequency 50-373/574-97011 05 NCV Unsecured equipment in control room and other rooms 50-373/374-97011-06 NCV Failure to issue adequate procedures required to respond to a poss!ble seismic event-
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50 373/374-97011-07-
-NCV Failure of the fuel inventory and piece count procedures to provide adequate acceptance criterta to perform an -
inventory of nuclear materialin the spent fuel pool
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- UST OF ACRONYMS USEO -
CAP _ Corrective Action Program
- CCT - Cycled Condensate Tank
-.CRS Control Room Super /a DCP Design Change Package EDG Emergency Diesel Generator'
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- HPCS High Pressure Core Spray IDNS ' iltnois Department of Nuclear Safety-IFl inspector Followup item
LAP LaSalle Administrative Procedure LES LaSalle Electrical Maintenance Surveillance
LLP LaSalle Limited Procedure
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LOA ~ Operating Abnormal Procedure -
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. LOP - LaSalle System Operating Procedure -
LTP LaSalle Technical Staff Procedure i-LOS _ LaSalle. Operating Surveillance MCR - Main Control Room -
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- MMD Mechanical Maintenance Department NA Not Applicable
NMC Nuclear Material Coordinator
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NRC Nuclear Regulatory Commission NTS Nuclear Tracking System 008 Out Of Service OWA ' operator Work Around Pi Performance Indicator PlF Problem identification Form
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POR NRC Public Document Room PRM Process Radiation Monitor RHR Residual Heat Removal SNM Special Nuclear Material
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SSPV Scram Solenoid Pilot Valve '
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SW. Service Water i
URI Unresolved item -
VIO Violation -
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