IR 05000373/1997013

Insp Repts 50-373/97-13 & 50-374/97-13 on 970827-1023.No Violations Noted.Major Areas Inspected:Engineering Including Licensee Sys Functional Performance Review Program

ML20199F974
Person / Time
Site:	LaSalle
Issue date:	11/18/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199F956	List: IR 05000373/1997013 ML20199F951
References
50-373-97-13, 50-374-97-13, NUDOCS 9711250055
Download: ML20199F974 (20)

Text

{{#Wiki_filter:. d U.S. NUCLEAR REGULATORY COMMISSION REGION 111 Docket Nos: 50 373, 50 374 License Nos: NPF 11, NPF 18 Report Nos: 50 373/97013(DRS); 50-37 t/97013(DRS) Licensee: Commonwea!th Edison Company Facility: LaSalle County Station, Units 1 and 2-Location: 2601 N. 21st Road Marseilles,IL C1341 Dates: August 27 through October 23,1997 Inspector: Eric Duncan, Reactor Engineer

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Approved by: Mark Ring, Chief Lead Engir.oers Branch Divisie, of Reactor Safety

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EXECUTIVE SUMMARY

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LaSalle County Station, Urris 1 and 2 NPC Inspection Report 50 373/97013; 50-374/97013 Eng! casting

* The inspector reviewed 'ho licensee's System Functional Performance Review (SFPR)

program and concluded that the number and significance of items identified during the reviews indicated that the program had been offective in identifying problems. (Section E2.1)

* The inspector reviewed the licensee's implemoetion of the Engineering Assurance Group (EAG) function and concluded that the EAG ihoroughly and critically reviewed 10 CFR 50.59 screenings and safeiy evaluations completed at the station. (Section E.7.1)
* The inspector reviewed the licensee's corrective actions to address a failure to revise relay setting order data sheets follow:ag a modification installed in May 199 (Section E8.10)     l
* The inspector reviewed the licensee's assessment of the inservice testing (IST) program i and concluded that significant programmatic problems axisted. (Section E8.14) i l

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. Report Details E101 rise of Enforcement Discretion ) I Violations described in Sections E8.10 and E8.11 of this report are based upon licensee ! activities which were identified after, but occurred prior to the licensee announcing, la December 1996, an extended shutdown of the LaSalle County Station. These violations satisfy the appropriate criteria in Section Vll.B.2, " Violations identified During Extended Shutdowns or ; Work Stoppages," of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600, and Notices of Violation (NOVs) are not being issued for these violations because the criteria specified in Section Vll.B.2 were met, which allows enforcement discretion to be applied. Specifically, in reference to the two violations, enforcement action wes not considered necessary to achieve remedial action, the violations would not be categorized at Severity Level I, and the violations were not willful. In addition, actions specified in Confirmatory Action Letter Rlil-96-0088 effectively prevent the licensee from starting up LaSalle County Station without implicit NRC approva Ill. Engineering E1 Conduct of Engineering E Information Notice 87-10 Review IDSRCGliQn Scooe The inspector reviewed the licensee's response to information Notice 87-10, * Potential for Waterhammer During Restart of Residual Heat Removal Pumps." Qhsco(ations and Findings The inspector reviewed the licensee's response to Information Notice 87-10 related to the potential for waterhammer in the residual heat removal (RHR) system if a Loss-Of-Coolant-Accident (LOCA) concu rent with a Loss-Of Offsite Power (LOOP) were to occur while the RHR system was aligned for suppression pool cooling (SPC).

Information Notice 87-10 Descriotion Information Notice 8710, * Potential for Water Hammer During Restart of Residual Heat Removal Pumps,* was issued on February 11,1987 to alert licensee's to the potential for waterhammer in the RHR system. The specific condition of concem involved a dei,lgn basis LOCA coincident with a LOOF, with one or more RHR loops in the suppression pool cooling mod During the power loss and subsequent valve re-alignment, portions of the RHR system could void because of the draindown to the suppression pool as a result of piping and equipment elevation differences. A waterhammer may occur in those RHR loops that were in the SPC mode when the RHR pumps restart after the diesel generators re-

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energize their respective busses. As a result, the integrity of the RHR system could be in jeopardy, which could endanger all modes of RHR, including low pressure coolant injection (LPCI).

Licensee CorrectiveAgilons As documented in inspection reports 50-373/93030; 50-374/93030 and 50-373/94022; 50-374/94022, following NRC concerns that Information Notico 87-10 had not been adequately aduressed, the licensee performed additional analysis and testing and concluded that the potential for severe waterhammer was possible. In response, the licensco revised operating prr:edures to place the LPCI pump in manual start in lieu of the original automatic start desig Subsequently, as discussed in inspection report 50-373/95003; 50-374/95003, the inspectors determined that the licensee's safety evaluation associated with the procedure changes was inadequate and failed to identified an unroviewed safety question. The report also indicated that the licensee had directed Sargent and Lundy (S&L) to perform a detailed waterhammer analysis to determine if the previous compensatory measures were necessary. The analysis was completed and concluded that the compensatory actions were not necessar Insoector Revis During this inspection, the inspector reviewed the waterhammer analysis prepared by S&L as EMD-067982, * Evaluation of Potential Water Hammer in Residua' Heat Removal )J System,* Revision 0, dated February 18,1994. The report concluded that although a waterhammer would occur, the RHR system woulo maintain its pressure boundary integrity, structural stability, and functional capatnlity dunng the waterhammer even However, the inspector also noted that plastic deformation and ovalization of system piping as well as a snubtor failure were expected to occu As a result, the inspector more closely reviewed the licensee's analysis and questioned the methodology which the licensee employed in the calculation including the basis for the assumptions made, the basis for the analysis acceptance criteria, actions to address an expected snubber failure, and actions to address the conclusion that although the piping would remain intact, American Society of Mechanical Engineers (ASME) code requirements would not be rilet. The inspector discussed these issues with licensee personnel. At the end of the inspection, licensee efforts to review the calculation to address the inspector's concems were in progres This is an inspection followup item (50-373/97013-01; 50 374/97013-01) pending further NRC review, c. Concintons The licensee's analysis to support operability of the RHR system in the event of circumstances as described in Information Notice 87-10 contained questionable

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assumptions as well as other information which required further review. An inspection followup item was opene E2 Engineering Support of Facilitates and Equipment E System Functional Performance Review (SFPR) Results InsnectionEcone The inspector reviewed the licensee's System Functional Performance Review program which was implemented tc, establish a level of confidence that celected systems important to safe and reliable operation could demonstrate functional performance consistent with the design basis, prior to plant restar ObicIyalions and Findings Proarammatic Standatd Review The inspector reviewed the programmatic standard used to implement the SFPR program. The inspector determined that the SFPR program consisted of two phase Phase 1 involved a pilot effort focused on the review of five systeins to assess the nature and significance of any identified problems which could affect the ability of the systems to perform their design required functions. Phase 2 included completion of the documentation associated with the five systems reviewed during the phase i pilot effort, and completion of the SFPR program for additional systems based on the results of the ) phase 1 effort. Subsequently, the licensee completed phase 1 and established the scope of phase 2 to include a total of 42 systems for SFPR revie The :nspector reviewed the methodology prescribed by the SFPR program. The I follow'ng was identified:

* For each function and sub function of the system, the following would be performed during the SFPR review: 1) identification of how each sub-function was achieved,2) identification of the achievement criteria traceable to a design basis document which confirm that components were capable of accomplishing their required functions, and 3) identification of the spec!fic surveillances or other tests which demonstrate that components met achievement criteria. This data was to be captured on a System Function Evaluation Matri *

Throughout the implementation of the SFPR program, all new and/or previously identified problems or issues were to be documented on issue Resolution Sheets. Recommended actions to resolve the identified issue were then classified es either a restart required action (to be accomplished prior to restart), short term action (to be accomplished after restart, but prior to the end of the next refueling outage), or long-term action (to be accomplished sometime after the next refueling outage after restart), l 5 l l

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o A Systems independent Review Group (SIRG) was established to provide

 - independent reviews of the implementation of the SFPR program. The
 - objectives of these reviews were to ensure the following:
 +- That the identification of system functions, the definition of system boundaries and interfaces, and the document reviews were of adequate approach, depth, and scop .

That the scope of the review of routine testing and operational observations of the systems were of sufficient depth to ensure that the system was capable of performing its design functio . That issue identification and resolution activities implemented as part of this program were adequate to assure that problems were identified and appropriately resolved, insoector Review-The inspector reviewed the results of the SFPR reviews against the licensee standards discussed above,

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System Function Evaluation Matrix The inspector reviewed the System Function Evaluatior. Matrix for the Reactor Core

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isolation Cooling system and Core Standby Cooling System. The inspector concluded

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that the matrix effectively captured the design function and sub function of these systems, including how each function was accomplished; identined achievement criteria traceable to a design basis document which confirmed that components were capable of accomplishing their required functions; and identified the specific surveillances or other tests which demonstrated that components met achievement criteria, identification and Prioritization of issues Early in the implementation of the SFPR program and prior to this inspection, the inspector reviewed the administrative process established to document the observations and findings during a system review. Overall, the inspector concluded that the SFPR documentation process adequately caotured the actions completed during the review and focused the findings appropriately on issues required to be resolved prior to unit restart. However, the inspector identified the following: e Walkdowns, interviews, and document reviews were not administratively tracked via a checklist or any other similar method to ensure completion during s system revie , e Documented reviews, interviews, and walkdowns (activity records) were not numbered for future reference.

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' The inspector discussed these findings with licensee personnel who subsequently  w revised the SFPR programmatic standard to clarify instructions for the identification, classification, and tracking of item During this inspection, the inspector deterinined that the licensee had completed the problem identification phase of the SFPR program. The inspector reviewed the licensee's SFPR findings and identified the following:
* The licensee identified a total of 642 items requiring resolution prior to Unit i restart, and 1123 items requiring resolution following Unit i restart The inspector sampled these items and concluded that based on the nature of the items, the licensee's SFPR process was thorough and had effectively identified problem * The licensee identified numerous s:qnificant issues requiring resolution prior to restart. These issues inr:luded:
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Potentia! Major Dog adation of Both Primary and Secondary Containment e inoperable Main Control Room (MCR) and Auxiliary Electric Equipment Room (AEER) Ventilation Syr,tems

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Inoperable Turbine P,viiding Vertilation System

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Inoperable Pressure Boundary Leak Detection System

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Inoperable Drywel Hydrogen Monitoring System

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Single Fr.aure Vult erability in the Essential Service Water System

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Unreliablo Turbine Driven Feed Pump Trip Function and Design Control Problems With Srv. sed Control System

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Incomplete Testing of Essential Battery for Station Blackout Loading

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Safety-Related Motor-Ooerated Valve (MOV) Thermal Overload Protection inadequately Bypassed The inspector reviewed these items and concluded thaiin addition to the identification of numerous restart items, the SFPRs also dentified a number of significant item Systems Indeoendent Review Grouc fSIRG) Observations The inspector observed numerous SIRG meetings during the course of the SFPR reviews. Overall, the inspector concluded that the SIRG effectively provided an independent review of the system matrices as well as the SFPR findings. The inspector noted, howcycr, that discussions during the SIRG meetings occasionally digressed to include consideration of cost in the development of solutions to problems which was outside the scope of SIRG responsibilities. This was particularly evident during discussions regarding the reactor vessellevel control system. The inspector subsequently discussed this concern with licensee personnel. Following that discussion, no fulther problems were note _ - - _ _ _ _ __ __ . - _ _ _ _ _ - _ _ . _ - .

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. Conclusions
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The inspector concluded that the number and significance of items identified during the SFPRs indicated that the program had been effective in Mentifying problems associated with the systems reviewe E7 Quality Assurance in Engineering Activ!tles E7.1 Engineering Assurance Grouo Review lusoection Scong The inspector reviewed the activities of the Ucensee's Engineering Assurance Group (EAG). In particular, the laspector reviewed the licensee's implementation of the EAG charter tr. rough the review of the results of the EAG review of approximately 10010 CFR 50.59 screenings and safety evaluation Observations and Findinas Bactornund As a result of the HRC Independent Safety inspection at Dresden in November 1996 which pointed out weaknesses in the oversight of site engineering activities, and as committed to in Comed's March 28,1997, letter in response to NRC concerns pursuant ,. to 10 CFR 50.54(f), Engineering Assurance Groups (EAGs) directly reportable to the Site Engineering Manager were established. This additional assurance function was deemed necessary to provide independent oversight of the expanded accountabilities of the site engineering organization since assuming design change authority from the Architect E,ngineering firm Engineering Assurance Groun Charter At LaSalle, a six-member EAG was established and implemented on April 15,1997. As indicated in the charter, the objective of the EAG was to improve the technical quality of selected engineering products through the following:

* In-process oversight of 10 CFR 50.59 screenings and safety evaluations, operability evaluations, and regulatory responses such as Notices of Violation (NOVs) and Licensee Event Reports (LERs); and finished product oversight of
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design change activities such as design change packages, temporary alterations, setpoints changes, and calculation * Using a combination of experienced LaSalle personnel and senior industry-experienced personne * Providing feedback to improve the quality of the specific engineering product being reviewe I

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* Conveying lessons teamed using coaching and tutorial techniques to improve the technical capabilities of engineering personne Scooe of Licensee Review The inspector itermined thtt the EAG performed an in-process review of 100 percent of all 10 CFR 50.59 screenings and safety evaluations, operability evaluations LERs,
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and NOVs. In addition, final product reviews of design change packages, temporary alterations, setpoint changes, calculations, and root cause reports were conducted b monthly by a contracto Categorization ar.d Centent of Findings The inspector determined that in accordance with the EAG charter, discrepancies identified during the performance of oversight activities would be categorized to allow monitoring of improvement. Categories used in the EAG 10 CFR 50.59 oversight review record to document review findings included the following:

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_ The change is clearly and completely describe * The reference list is complet + The licensing / design basis is clearly stated, acce: ate, and complet + The evaluation of the licensirg/ design basis issues is complet . The justification basis and rationale for the conclusion is adequately stated and appropriat The inspector determined that in accordance with the EAG charter, documents reviewed were classified as follows:

* A: No comment + B: Comments that would improve the quality of the product. However, uality is acceptable as presented without revising the documen * C: Changes required to the document to achieve acceptable qualit * D:

, Major deficiency. Requires revision of the document to ensure adequacy for present us * E: Violation of design or licensing basis. Requires revision of the document to assure adequacy for present use, insoection Rev, lag The inspector reviewed approximately 100 EAG oversight review records for completed 10 CFR 50.59 screenings and safety evaluations. Overall, the inspector concluded that

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on the basis of the comments in the oversight record, the EAG thoroughly and critically reviewed 10 CFR 50.59 screenings and safety evaluations completed at the statio However, the following deficiencies were identified:

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Classifica; ion Grades Did Not Always Correlate to Discrepancies The inspector identified 14 cases where the reviewer assigned a *B" category to a 10 CFR 50.59 screening or safety evaluation, althcagh the reviewer also identified bat the justification basis and rationale for the conclusion was no; satisfactorily stated or was inappropriat In addition, the inspector identified 3 cases where the reviewer assigned a "B* category to a 10 CFR 50.59 screening or safety evaluation, although the reviewer also identified that the change was not satisfactorily clear or completely described, in one case in particular, the reviewer commerded that the changes were not clear and that it did not appear that the preparer understood the change The inspector was concemed that the assigned category grade did ret , appear to correlaie with the discrepancies identified. The inspector dscussed this with the EAG manager who stated that although the category may be marked as unsatisfactory, the intent was not to indica'e that the document necessarily required re'dslon, bunstead that enhancements to linprove the quality of the docume t wero identifie . Subsequently, the inspector identified that many c'.her oversight records identified enhancement comments although the respective category was gradert as satisfactor The inspector concluded that the use of unsatisfactory in the assignment m of category grades was inconsistently applied. In addition, me inspector j concluded that the use of unsatisfactoiy as a category grading tool was e confusing since an unsatisfactory grade implied that a revision to the document was required, which was not what the licensee intende * Some Auministrative Errors Were identified r The inspector identified some cases in which required blocks in the oversight record were not compleW as required. For example, one case was identified where the five discrepancy category blocks were not filled in to indicate whether the category was satisfactory or not sat nactor Subsequently, the licensee identified 10 additional cases where this occurred. Also, althouga N oversight review record form required that the items identified as deficient be related to the discrepancy category by identiiication of the applicable category number, the reviewers seldom complied with this convention. As a result, it was frequently diff; cult to > understand the basis for the comments in the oversight recor Overall, the inspectors concluded that although these deficiencies were minor, it indicated that at times appropriate attention to detail was not exercised by the EAG reviewer ___ _ _ _ _ - _ - _ _ _ _ _ _ _ - - . _ - _ . .

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 * Followup Discussions Were Not Documented The inspector identified cases in whi:h the oversight record contained questions for the preparer. However, the resolution to those questions was not addressed in the oversight record. Therefore, the assigned grade could not be evaluated by
 -- the inspector for appropriateness, since information obta!ned in followup discussions was not captured in the oversight review recor c, . _ Conclusions The inspector concluded that the licensee had satisfied commitment 176 of their March 28,1997, :etter submitted in response m NRC questions pursuant to 10 CFR 50.54(f) which stated that a engireering assurance function muld be create The inspector also concluded that although some administrative and classification weaknesses were identified, the EAG thoroughly and critically reviewed 10 CFR 50.59 screenings and safety evaluations completed at the statio E8 Miscellaneous Engineering issues E (Closed) Violat[on 50-373/93300-02: 50 374/93300-02: Inadequate Testing of Reactor

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 - Protection System (RPS) Bus Trips After Change To 3 Second Time Delay. The inspector verified that the corrective actions described in the licensee's response letter, dated May 13,1994, were reasonable and complete. No similar problems were

/ identifie E8.2 -(C40 sed) Violation 50-373/93300-03: 50-374/93300-03: Inadequate Electrical Power Monitoring (EPM) Assembly Calibration Procedure. The inspector verified that the corrective actions described in the licensee's response letter, dated May 13,1994, were reasonat,le and complete. No similar problems were identifie ' E8.3 (Cicsed) Violation 50-373/93300-04: 50-374/93300-04: Inadequate Reacter Recirculation Pump Operating Procedure. The inspector verified that the corrective actnins described in the licensee's response letter, dated May 13,1994, were , recsonable t nd complete. No similar problems were identifie E8.4 (Closed) Violation 50-373/93300-05: 50-374/93300-05: Failure to Follow Equipment Operability Debrmination Procedure, The inspector verified that the corrective actions described in the licensee's respense letter, dated May 13,1994, were reasonable and complete. No similar problems were identifie E8.5 (Clcsed) Violation 50-373/93300-06: 50-373/93300-0Q: Inadequate Degraded Equipment Log Procedure. The inspector verified that the correctivo actions described in the licensee's response letter, dated May 13,1994, we:e reasonable and complet ' No simitar problems were identifie __

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E8.6 (Closed) Violation 50-373/93300-07: 50-3]A/93300-07: Inadequate Instruction Regarding Relay Setting Order Tolerances. The inspector verified that the corrective actions describec8 in the licensee's response letter, dated May 13,1994, were reasonable and complete. No similar problems were identifie E8.7 (Closed) Violation 50-373/93300-08: 50-374/93300-08: Improper Control of Measuring Devices. The inspector verified that the corrective actions described in the licensee's response letter, dated May 13,1994, were reasonable and complete. No similar problems were identifie E8.8 [Qated). Deviation 50-373/93036-05: 50-374/93036-05- EPM Time Delays Above Final Safety Analysis Report (FSAR) Requirements. The inspector verified that the corrective actions described in the licensee's response letter, dated May 13,1994, were reasonable and complete. No similar problems were identifie E8.9 (Closedl.bSDection Followun Itern 50-373/93036-07: 50-374/93036-07: Evaluation of RPS EPM Time Dela Of Up To 6 Second At discusscd in inspection report 50-373/93036; 50-374/93036, a concern raised by the inspector was whether RPS equipment operating with voltage and frequency values outside of the acceptable range for more than the 4 seconds maximum value specified by General Electric (GE) could be damaged, thus affecting their ability to perform their RPS safety functio The licensee stated that based on GE documentation provided to Susquehanna Station, RPS loads could tolerate EPM assembly trip dalsy times of up to 7.2 seconds and due -{ to the similarity of GE Boiling Water Reactor RPS equipment, it was LaSalle's engineering judgement that an RPS EPM assembly trip delay time of up to 6 seconds was justified. Subsequently, GE concluded that an RPS EPM assemb;y time delay of 6 seconds for undervoltage, overvoltage, and underfrequency was acceptable with one exception related to an HMA relay that provided the 135 pounds per soucre inch gauge (psig) reactor pressure interlock for RHP shutdown cooling. In response, the licensee performed an engineering evaluation of the worst case effect of an RPS bus powar disturbance on the RHR shutdown cooling pressure interlock and concluded that the potential effects on the interlock relay were not sign;ficant. An inspection followup item was opened pending NRC review of the licensee's action During this inspection, the inspector determbed that the EPM time delay relays, including the relay associated with the reactor pressure interlock for shutdown cooling, were reset to within the FSAR requirement of 0.1 to 3.0 seconds. In addition, the licensee recently completed a System Functional Performance Review (SFPR) for the Reactor Protection Systein. This comp.ahensive review included a detailed review of the issue described above. During that review, the licensee verified that licensee procedures required calibrCion of the P.PS EPM assemblies including time delays associated with underfrequency, undervoltage, and overvoltage. This inspection followup item is close . <

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E8.10 (Closed) Unresolved item 50-373/93036-06: 50-374/93036-C6: Inadequate Coordination of Relay Trip Time Interval As discussed la inspection report 50-373/93036; 50-374/93036, the licensee determined that in May 1992, new RMS-9 (solid state) trip units were installed on the main feed breakers for ;30 volt switchgear 136X,136Y,236X, and 236Y. However, the setting specified in the relay setting order (RSO) data sheats for the transformer ground overcurrent relays (IAC-60) and 4.16 kilovolt side phase overcunent relays (CO-4) were inadvertently not leset to coordinate with the newly installed RMS-9 trip unit Subsequently, the licensee performed an operability evaluation and concluded that the system was operable. to addition, the licensee ccmmitted to adjust the IAC-60 overcurrent relay settings and the CO-4 overcurrent relay settings. An unresolved item was opened pending NRC revie During this inspection period, the inspector verified that setpoint changes for the affected relays had been accomplished. The failure to revise the RSO data sheets for the LAC-60 and CO-4 relays was an example where the design basis was not translated into specifications as required by 10 CFR 50, Appendix B, Criterion lil, " Design Control," and was a violation. However, because this violation was based upon activities prior to the events leading to the current extended plant shutdown and satisfy the criteria in Section Vll.B.2," Violations identified During Extended Shutdowns or Work Stoppages," of the ~ General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, a Notice of Violation is not being issue (50-373/97013-02(DRS); 50-374/97013-02(DRS)) W n This unresolved item is close E8.11 [ Closed) Licensee Event Reoort (LER) 50-373/97017-0Q: Deficiencies identified in Testing of the Residual Heat Removal (RHR) Pump Suppression Pool Spray Flow Using instruments Not included in a Calibration Program Due to Management Deficienc As described in LER 50-456/97017, the Ucensee identified on April 16,1997, a deficiency in how the RHR suppression pool spray line flow rate was determine Specifically, the licensee identified that flow recorders installed in 1994 on Unit 1 and Unit 2 to verify that RHR suppression pool spray flow met technical specification requirements, had not been adoad to the calibration program and had never been calibrated, in add" ion, following identification of the issue, the Unit 1 recorders were found to be out of tolerance. Because the effect of using the out of tolerance trend

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recorders on the supprossion pool spray flow readings was not fully known and the extent to which they were used was not fully determinable being subjact to memory, the licensee conservatively reported this event as a condition prohibited by the technical specification As part of the licensee's immediate corrective actions, a temporary procedure change was issued to delete an option to use the trend recorders for measuring suppression pool spray flow c:.til the recordars could be calibrated. Subsequontly, the Unit 1 and .

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 'Jnit 2 trend recorders were calibrated and added to the licensee's calibration progra To prevent recurrence of a similar type problem, tho licensee placed the responsibility for preparation and review of operating procedure revisions with the operating procedures group and required thet surveillance procedures for components tested to fulfill ASME code requirements also be reviewed by the inservi'.e testing coordint/.o '

Finally, the licensee ensured that no additional uses of the trend recorders to measure > data to meet technical specification requirements for other surveillances existe Tine inspector reviewed this event, including the licensee's corrective actions, and + concluded that these corrective actions appeared appropriate to correct the problem and prevent recurrence. The inspector also noted that although the LER discussed that the licensee was unable to specifically determine when the trend recorder or the flow indicator was used since the surveillance procedure does not require that the indicating device be identified, the licensee did not revise the surveillance procedure to avoid this particular problem in the future. However, since the trend recorders were added to the calibration program, the inspector considered this issue to be of relatt..ely minor significanc The failure to include the trend recorders in the calibration program was a violation of 10 CFR 50. Appendix B, Criterion Xil," Control of Measuring and Test Equipment," which required that measures be established to ensure that instruments used in activities affecting quality were properly calibrated to maintain accuracy within acceptable limit ' However, because this violation was based upon activities prior to the events leading to the current extended plant shutdown and satisfy the criteria in Section Vll.B.2,

 " Violations identified During Extended Shutdowns or Work Stoppages," of the " General g  Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement i  Policy), NUREG-1600, a Notice of Viutation is not being issue (50 373/97013-03(DRS); 50-374/97013-03(DRS))

E8.12 (Closed) LER 50-374/96006-00: Unit 2A and 2B RHR Service Water Pumps Not Tested Per ASME Section X This issue was discussed in detail in NRC inspection report 50-373/96011; 50-374/96011. No new issues were revealed by the LE E8.13 (Closed) LER 50-373/96019-00: Residual Heat Removal System Containment Spray Isolation Valves Not Tested According to ASME Section XI Requirements Due to Personnel Erro As described in LER 50-373/96019, during an assessment of the inservice testing (IST) program, the licensee identified that testing methods specified for the Unit 1 RHR containment spray isolation valves were inTnsistent. Specifically, one train of motor-operated valves (MOVs) was being tested by timing the opcning stroke of the valves whereas another train was tested by timing the closing strok The licensee determined that the root cause of the problem was a human performance error which occurred during a surveillance revision. ' pecifically, an engineer who

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.. . prepared a revision to LaSalle Operating Surveillance RH-02, *RHR (LPCI) and RHR Service Water Valve Inservice Testing for Operating, Startup and Hot Shutdown Conditions," failed to ensu'e that the most recent revision was revised and, as a result, inadvertently re-introduced an error in the surveillance that had been previously identified and correcte As part of the licensee's immediate corrective actions, the implementing surveillance was revised to test the containment spray isolation valves in the closed direction in accordance with the IST program and the engineer and technical reviewer involved were counsded. As part of the licensee's long-term corrective actions, in addition to the in-progress assessment of the IST program, the licensee planned to perform a self-assassment of the operating procedure revision preparation and review proces A supplement to this LER was issued on April 4,1997, and ic discussed below. This LER is close E8.14 (Ocen) LER 50-373/96019-01: Residual Heat Removal System Containment Spray isolation Valves Not Tested According to ASME Section XI Requirements Due to Personnel Erro The licensee completed the IST program assessment discussed in LER 50-373/96019-00 and identified numerous problems in the IST program. As a result, LER 50-373/96019 Lupplement 1 was issued on April 4,1997. In flat supplement, six major IST code non-compliance irsues were identified which includod two required systems not in the program, pump vibration criteria not in compliance with program requirements (11 pumps), Emergency Core Ccoling System strainer backwash valves (9) not manually , cycle tested, lift-off force testing not performed for vacuum breakers (2 cases), leakrate tests not extrapolated to functional pressures (feedwater check valves), and valves not appropriately stroke time tested (46 examples).

, The licensee identified the root cause of the problems noted above as personnel erro Specifically, the licensee concluded that the documents and procedures that govemed the IST program were incorrectly revised when the second 10-year plan was developed due to a misinterpretation of some requirements as well as incorrect assumptions and decisions on other requirements. In addition, a management review of the updated plan failed to detect the deficiencie The licensee reviewed each individual non compliance and in each case concluded that no structure, system, or ccmponent was rendered inoperable due to these error As part oi the licensee's corrective actions, the specific problems idcntified were corrected through program and/or procedure revisions by exoerienced IST personnel, or were being pursued through the initiation of ASME code relief requests. In addition, the licensea planned to prepare an IST basis document to identify the basis for application of IST requirements for components tested, and planned to revise the station IST p.'ocedure to clearly define responsibilities of personnel involved in the IST progra _. . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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. This LER is open pending additional revie E8.15 (Closed) LER 50-373/96020-01: Potential Waterhammer Concerns of Residual Heat Removal Service Water System Division 2 Piping This issue was discussed in detail in NRC inspection report 50-373/97008; 50-374/97008 for which an apparent violation was identified, and enSrcement discretion was granted under Section Vll.B.6," Violations Under Special Circumstances," of the

" General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600. No new issues were revealed by the LE E8.16 (Open) LER 50-373/97021-00: Undrainable Low Areas in the Drywell Floor Resulting in a Degradation of the Leak Detection System (LDS) Due to increased Delays in Detection of Unidentified Leakag As discussed in the subject LER, the licensee conducted a review of the functional capability of system, nportant to safe and reliable operation through System Functional Performance Reviews (SFPRs). During that effort, a review of Problem identification Form 94-295 was performed and discovered that a concem regarding the accumulation of water on the drywell floor had been identified. Following additional rewow, the SFPR team concluded that the ability of the drywell floor to accumulate water was inconsistent with the UFSAR description. Specifically, the licensee's response to UFSAR question 212.17 stated that there were no undrainable low points in the primary or secondary containment which would result in a delay in the detection of leakage. C atrary to this description, there were undrainable areas which would result in the delay of the detection of leakag During the licensee's investigation of this problem, an additional problem related to the reliability of instrumentation associated with portions of the LDS was identif;e Regulatory Guide 1.45 required that the sensitivity and response time for the LDS should be adequate to identify a leakage rate of 1 gallon per minute in less than 1 hou To meet this requirement, a capacitance probe was used to measure instantaneous sump level which was electronically converted to a flow rate. H7 wever, operating experience had demonstrated that the capacitance probe frequently drifted and was unreliable. As a result, the recurrent failure of the electronic levelindication resulted in the LDS not meeting design basi., requirement As part of the licensee's immediate corrective actions, the LDS was declared inoperabl In addition the licensae planned the following long-term action * Resolution of the discrepancy between the as-built configuration of the plant and the description contained in response to UFSAR question 212.1 * Improving the relisbility of the sump level monitoring instrumantatio * Confirming that there were no other holdup volumes in the containment which could result in unacceptable delays in the detection of unidentified leakag i

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- The inspector noted that the licensee planned to discuss the results of the corrective actions in a suppleniental LE E8.17 (Closed) Insoection Followuo item 50-373/95003-03: Safety Classification Change of Pipe Stru As discussed in inspection report 50-373/95003; 50 374/S5003, the inspector questioned the re-classification of High Pressure Core Spray system pipe strut HP08-1008X when the piping the strut was attached to was abandoned in plac ~

b Based on discussions with licensee personnel and o review of ASME Section XI, * Rules - for Inservice inspection of Nuclear Power Plant Components," the inspector determined that the re-classification of pipe strut HP08-1008X was appropriate. The safety-related boundary for the associated system was changed as part of a modification to abandon in place a section of pipe beyond the newly designed boundary valve. Because the strut , was attached to this portion of the system, it was deleted from the sciety-related Inservice inspection Program. However, it was added to the nonsafety-related seismic category. This ws3 consistent with the other supports in comparable situations. This inspection followup item is close VI. Management Meeting X1 Exit Meeting Summary The inspector presented the results of these inspections to Fcensee management listed below at an exit meeting on October 23,1997. The licensee acknowledged the findings presente The inspector asked the licensee if any materials examined during the inspection should be considered proprietary. No propriatary information was identifie ,,g, W F- ?

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i PARTIAL LIST OF PERSONS CONTACTED Comed - W. Subalusky Site Vice President . G. - Poletto . Site Engineering Manager * W.; Eifert _ . Engineering Assurance Group Manager P. Barnes ' Regulatory Assurance Manager

: W. - Kirchoff Engineering Assurance Group M -. Peters - Engineering Assurance Group T. Hammrich Design Engineering R. Gremchuk System Engineerin ' J.-- Damron_ System Eng*aring G. Swihart Regulatory Assuranco INSPECTION PROCEDURES USED
' IP 17550 Engineering
- IP 37551 Onsite Engineering
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, ITEMS OPE.NED, CLOSED, AND DISCUSSED Ooened 50-373/97013-01; 50-374/97013-01 IFl information Notice 87-10 Review 50-373/97013-02; 50 374/97013-02 NCV Inadequate Coordination of Rela Trip Time 50-373/97013-03; 50-374/97013-03 NCV RHRS Valves Not Properly Tested GQSnd 50-373/93300-02; 50 374/93300-02 VIO Inadequate Testing of RPS Bus Trips 50-373/93300-03; 50-374/93300-03 VIO Inadequate EPM Assembly Calibration Procedure 50-373/93300-04; 50-374/93300-04 VIO Inadequate Reactor Recirculat:on Pump Procedure 50-373/93300-05; 50-374/93300-05 VIO Operability Determination Procedure Not Followed 50-373/93300-06; 50-374/93300-06 VIO Inadequate Degraded Equipment Log Proced"' 50-373/93300-07; 50-374/93300-07 VIO Inadequate Instruction Regarding RSO Toler.%s 50-373/93300-08; 50-374/93300-08 VIO Improper Control of Measuring Devices 50-373/93036-05; 50-374/93030-05 DEV EPM Time Delays Above FSAR Requirements 50 373/93036 06; 50-374/93036-06 URI Inadequate Coordination of Relay Trip Time 50-373/93036-07; 50-374/93036-07 IFl Evaluation of RPS EPM Time Delay 50-373/97017-00 LER RHR Pump Suppression Pool Spray Flow Testing 50 374/96006-00 LER RHR Service Water Pumps Not Properly Tasted 50-373/96019-00 LER RHR Valves Not Properly Tested 50-373/96020-01 LER RHRSW Division 2 Waterhammer Concems 50-373/95003-03 IFl Safety Classification Change of Pipe Strut Discu1Eed 50 373/96019-01 LER RHR Valves Not Properly Tested 50-3'73/97021-00 LER Undrainable Low Areas in Drywell Floor

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  ' LIST OF ACRONYMS USED-AEER_ Auxiliary Electric Equipment Room ASME American Society of Mechanical Engineers CFR Code of Federal Regulations DR Division of Reactor Safety EA Engineering Assurance Group EPM Elect.ical Power Monitoring FSAR- r aial Safety Analysis Report GE General Electric-lFl !nspection Followup Item  ~;

IST Inservico Testing LDS- Leak Detection System LER Licensee Event Report-LOCA Loss of Coolant Accident-LOOP Loss of Offsite Fower LPCI Low Pressure Coolant injection MCR Main Control Room . MOV Motor-Operated Valve NOV- Notice of Violation PDR Public Document Room . ,. RHR Residual Heat Removal RHRSW Residual Heat Removal Service Water . RPS Reactor Protection System RSO Relay Setting Order S&L Sargent and Lundy SFPR System Functionel Performance Review SIRG Systems Independent Review Group , ' SPC Suppression Pool Cooling UFSAR Updated Final Safety Analysis Report ,

. URI Unresolved item
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