IR 05000373/1999001

From kanterella
Jump to navigation Jump to search
Insp Repts 50-373/99-01 & 50-374/99-01 on 990106-0216.No Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering & Plant Support
ML20207J909
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 03/10/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207J895 List:
References
50-373-99-01, 50-373-99-1, 50-374-99-01, 50-374-99-1, NUDOCS 9903160431
Download: ML20207J909 (21)


Text

.,,.

..

.-.

.

... -

- -

-

- - - -.

.

.

- - -.

.

-

-

,

.

,

,

'

U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket Nos:

50-373,50-374 License Nos:

NPF-11, NPF-18

,

Report No:

50-373/99001(DRP); 50-374/99001(DRP)

Licensee:

Commonwealth Edison Company Facility:

LaSalle County Station, Units 1 and 2 Location:

2601 N. 21st Road

'

Marseilles,IL 61341 Dates:

January 6 through February 16,1999 Inspectors:

M. Huber, Senior Resident inspector J. Hansen, Resident inspector R. Crane, Resident inspector Approved by:

Melvyn N. Leach, Chief Reactor Projects Branch 2 9903160431 990310 PDR ADOCK 05000373 O

PDR

_ _ _ _ _ _ _

_ _____._. _

_._

..

'

'

-

.

.

'

EXECUTIVE SUMMARY LaSalle County Station, Units 1 and 2 inspection Report 50 373/99001(DRP); 50-374/99001(DRP)

This inspection report included aspects of licensee operations, maintenance, engineering and

plant support. The report covers a 6-week period of inspection conducted by the resident staff.

Mant Operations In general, the inspectors observed that operations personnel were knowledgeable of

plant and equipment status, maintained accurate records, effectively communicated operational information, and operated equipment in accordance with approved procedures. In two instances, which included a loss of the heater drain pump supply to the reactor feedwater pumps and a decrease in the main condenser vacuum while realigning the off-gas system, operators appropriately responded to the unplanned plant transients which resulted from equipment problems. _ The operators took appropriate actions in accordance with plant abnormal operating procedures. (Section 01.1)

The lack of attention to detail and failure to physically verify equipment status resulted in

several configuration management events. The safety significance of these events was determined to be minimal and the licensee took appropriate corrective action.

(Section 01.2)

Several main and radwaste control room instrument displays did not indicate within the

-

respective normal operating band or " green" band, although the actual measured parameters were within the design operating range. Operators were knowledgeable of the correct operating bands and the potential design changes; however, the issues were not identified as control room distractions. Operations personnel did not take action to ensure the discrepancies were appropriately resolved in a timely manner.

(Section O2.1)

The control room operators' response to the unexpected closure of the heater drL ank

pump forward valves and resultant reduction in condensate flow to the reactor feed pumps was appropriate. The licensee's technical support staff responded to the transient in an expeditious manner. (Section 04.1)

Operators responded to a decrease in main condenser vacuum which occurred as a

result of leaking isolation valves in an off-gas (OG) train being removed from service.

Control room operators operated the plant in accordance with the appropriate plant procedures and maintained the plant in a safe condition throughout the transient.

However, a more timely implementation of the procedure change to address the leaking valves would have precluded the transient. The licensee safely restored the plant to full

. power. (Section O4.2)

The operators conservatively declared the applicable train of the control room and

auxiliary electric equipment room ventilation system inoperable when a radiation detector was declared inoperable. When the sysScr. was inoperable, the availability of safety related ventilation systems decreased and the licensee accurately recorded the system unavailability for mairJenance rde ourposes. The licensee had implemented

2

)

r

!

'

.

'

this process in response to historical poor personnel performance and planned to discontinue declaring equipment inoperable unnecessarily. (Section 04.3)

l Maintenance The licensee did not maintain adequate foreign material exclusion boundaries during a

maintenance activities in some instances. In addition, contract personnel identified a condition potentially adverse to quality, but did not document the issue or notify licensee management of the concern. Specifically, contract personnel noted potentially eroded concrete in the drywell but did not forward the concern to the licensee's corrective action program. The licensee's corrective actions fer +he issues were appropriate.

(Section M1.1)

An equipment problem with the controller for the heater drain pump forward valves

.

resulted in the simultaneous closure of the three valves and subsequent reduction in condensate flow to the reactor feed pumps. Overall, plant equipment operated as designed during the transient. Maintenance department personnel effectively developed and implemented a comprehensive troubleshooting plan and returned the valves to service in a timely manner. In addition, the 1B heater drain pump was found by the licensee to have degraded performance. The licensee's plans to address the performance of the 1B pump was adequate. (Section M2.1)

The licensee completed the planned standby liquid control (SLC) system maintenance

activities and began testing the SLC system in accordance with the established schedule. The action requests which the licensee had not scheduled for completion prior to the system being returned to service would not impact system operability.

(Section M2.2)

,

The licensee performed a thorough investigation of repeated radiation monitor failures

-

and developed appropriate corrective actions. (Section M2.3)

The licensee identified two errors where contract construction personnel did not meet

programmatic requirements and management expectations for the out-of-service (OOS)

program. The consequences were minimal but the events warranted continued station management attention in reinforcing strict compliance with OOS program requirements to ensure that personnel safety was maintained and configuration control problems did not result in more significant problems. The licensee's completed and planned corrective actions were adequate. (Section M4.1)

The licensee established a plan to address the Unit 2 material condition as a part of

+

their Restart Action Plan item 3.3 and determined what work would be performed before restart of Unit 2. The licensee reviewed the outstanding work request backlog, i

determined the corrective tasks which would be completed prior to Unit 2 startup, and incorporated the work in the Unit 2 outage plan. Also, the licensee's implementation of the process for reviewing potential work for the Unit 2 outage appeared adequate.

(Section M8.1)

l

'

.

-. -

..- --

..

-.

. -

-

- --

.

'

.

.

.

.

~

Enoineerino Engineering personnel adequately completed an operability determination relaied to

.

piping welds in a timely manner using appropriate assumptions. Operations personnel were cognizant of the issue and corrective actions identified in the evaluation.

(Section E1.1)

Plant Support The inspectors ident;fied an access path to an area being controlled as a high radiation

-

area which the licensee did not properly identify as specified by plant procedures.

Furthermore, the licensee identified that a construction maintenance technician inappropriately entered the area under the Unit 2 reactor vessel. The worker's RWP associated with his maintenance activity did not authorize entry to the area. Although the problems appeared to be isolated and the licensee's response was appropriate, the events indicated the need for continued licensee oversight of construction activities.

(Section R1.1)

-,

. -.-.

-

.. - -, -. -.-

. -.. -.

-. --

-.

... -

f t

i

,"

.

.,

"

ReportOetails Summary of Plant Status During this inspection penod, the licensee maintained Unit 1 at or near full power except during two short duration reductions in reactor power to approximately 60 percent in response to i

secondary plant equipment failures. Unit 2 remained shut down for a refueling outage with all

' fuel removed from the reactor.

l. Operations

' Conduct of Operations 01.1. General Comments (71707. 61726)

The inspectors conducted frequent reviews of ongoing plant operations. These reviews included observations of control room shift turnovers and operator performance during plant evolutions. Also, the inspectors reviewed daily logs and interviewed operations personnel regarding plant status and events.

'

The inspectors observed discussions regarding the status of plant equipment, planned testing, and maintenance in general, the inspectors observed that operations personnel were knowledgermble of plant and equipment status, maintained accurate records, effectively communicated operational information, and operated equipment in accordance with approved procedures.- In two instances, operators responded to unplanned plant transients which resulted from equipment problems. The operators i

took appropriate actions in accordance with plant abnormal operating procedures.

These instances, which included a loss of the heater drain pump supply to the reactor feedwater pumps and a decrease in the main condenser vacuum while realigning the off-gas system, are discussed in Sections O4.1 and 04.2 of this report. Other observations are detailed in the sections below.

01.2 Confiauration Control Issues a.

Inspection Scooe (71707)

{

i The inspectors reviewed several issue:; related to configuration control deficiencies.

'

b.

Observations and Findinas Motor Control Center (MCC) Deeneraized With Temoorary Modification (TMOD)

Installed i

On January 1,1999, operators deenergized 480 volt switchgear (SWGR) 231X and 231Y to support scheduled Unit 2 outage work. As a result of the deenergization, an

,

- MCC providing temporary electrical power to security perimeter lighting and switchyard l-

- lighting was unexpectedly deenergized. The licensee evaluated the problem and l

determined that the operators failed to recognize that the switchgear was being used as I

a temporary power source for the MCC. When developing, the out-of-service (OOS)

checklist and preparing to remove the switchgear from service, the operators were

'

,

expected to identify the that the switchgear was the temporary power source for the

,

l l

1

-

.

_.

-

.

-.-__

_.. _. -. _ _ _. _ - - _. _. -. _ _. _, _ _. _. _.. _. _ _ _ _ _ _

.

.

.

.

'

security lighting. The licensee d' etermined that the operator assigned to review the OOS checklist for temporary power connections did not physically evaluate the SWGR for temporary connections. Instead, the operator completed the review using incorrect verbal information from the TMOD coordinator, who indicated that no TMODs were in place which would be affected when the SWGR was deenergized. The licensee initiated appropriate corrective actions for the errors and compensatory measures to address the loss of the security lighting.

'

Operator Deeneraized incorrect Breaker On January 8,1999, a licensed operator incorrectly opened an offsite breaker for an incoming power line. The operator was responding to an control room alarm for the trip of the 138 kilovolt power line number 6102. The operator announced the alarm to the his supervisor and referenced the appropriate alarm response procedure.

Subsequently, the operator determined that manually tripping the breaker for line 6102 was necessary and received concurrence from his supervisor to trip the line. Although

the operator requested a peer-check on opening the breaker, he inadvertently opened the breaker for line 0108 prior to the peer-check. The operator immediately recognized his error and informed his supervisor, who implemented actions to restore the breaker.

The licensee reviewed the issue and determined that the operator did not perform an

,

adequate self-check and peer-check due to perceived time pressure. Also, the supervisor did not perform a control board check prior to concurring with the operator that opening the breaker was the appropriate action.

Fuel Handlina Supervisor incorrectiv Sioned Prereauisite as Complete On February 10,1999, instrument maintenance (IM) techniciant dentified that a shuttle tube had not been installed inside of the source range neutron monitoring instrumentation dry tube. The IM technicians were under the Unit 2 reactor vessel preparing to install the dry tube. The technicians removed the nose piece from the bottom of the dry tube and discovered that the shuttle tube was not installed.

Prerequisite C.9 of LaSalle Fuel Procedure (LFP)-600-02, " Replacement of LPRM [ local power range monitor) and SRM [ source range monitor]/lRM [ intermediate range monitor)

Dry Tube Assemblies," Revision 7, required the shuttle tube to be installed in the dry tube by the IMs prior to installation of the dry tube in the vessel. The fuel handling supervisor discussed the step with IM personnel and was informed that the shuttle tube J

was installed in the new dry tube by the manufacturer. However, neither the fuel handling supervisor nor the IM technician physically verified the installation. The technicians and radiation support personnel unnecessarily received radiation exposure j

as the dry tube had to be removed and the shuttle tube installed.

'Mispositioned Breaker Licensee electrical maintenance personnel found a 125-volt attemating current breaker

?

in the "ON" position, instead of off as specified by the OOS documentation, during a walkdown of an OOS boundary prior to performing a maintenance activity. The licensee

'

initiated an investigation to determine why the OOS breaker was in the incorrect position. A temporary modification tag which specified that the breaker was to be in the

"ON" position was hanging on the breaker in a manner which covered the OOS card.

The temporary modification tag may have contributed to the problem in some manner.

- - - -..

-

- -

-

.

_ _ _ _.. _ _..

.

(

,

-

.

-

^

However, the licensee did not identify a cause for the mispositioned breaker. The licensee's response to the discovery of the mispositioned switch was adequate, inadvertent Transfer of Cycled Condensate to Unit 2 Suppression Pool

'On February 7,1999, operators inadvertently transferred approximately 25,000 gallons of water from the cycled condensate tank to the Unit 2 suppression pool'while fdiing a portion of the Unit 2 high pressure core spray (HPCS) system. The licensee identife' d the condition when a supervisor informed the main control room that the filling of the HPCS piping was taking longer than expected. The control room operators identified an increase in suppression pool water level and the Unit Supervisor directed operators to stop filling the HPCS system. The licensee review'ea the valve positions for the boundary of the portion of the HPCS system being filled and found a drain valve open.

Subsequent investigation by the licensee revealed that the procedure used to drain the piping in support of maintenance and testing did not have specific steps directing the restoration of all valves manipulated to the original configuration. The licensee also determined that the surveillance procedure used to fill the system in support of a leak rate test did not include steps to verify the position of the test boundary valves. As part of the corrective actions, the licensee performed a complete mechanical checklist verification of the Unit 2 HPCS system.' Furthermore, the licensee initiated an investigation and indicated their intent to revise the HPCS draining procedure to include restoration of the system configuration. The licensee's actions were appropriate.

- c.

Conclusions The lack of attention to detail and failure to physically verify equipment status resulted in several configuration management events. The safety significance of these events was determined to be minimal and the licensee took appropriate corrective action.

Operational Status of Facilities and Equipment 02.1 Review of Control Room Distractions a.

Insoection Scope (71707)

The inspectors reviewed aspects of the licensee's main control room distractions program and performed observations of main and radwaste control room conditions which could impact operator performance.

b.

Observations and Findinas The inspectors identified that the measured parameter values indicated on several J

instrument displays in the main and radweste control rooms were outside the normal operating band. The normal operating band, or " green" band was an operator aid intended to identify the range of acceptable values of an instrument's measured parameter. Discussions with the licensee's cognizant system engineers revealed that each of the parameters displayed was operating within its design range and in i

accordance with approved procedures. Also, the licensee planned to review potential design changes to revise the green band for some of the affected instruments, although

,

j

' the design changes were not scheduled for completion. Although cognizant of the j

problems with the displays and potential design changes, the operators were not aware

'

.

..

-

--

-.

,.-

. -..

-.. - -

__

. _ _ __ _..._ _.. _ _ _ _ _ _ _.._. _.. _. _._. _ _ _._ ___

.

'

-

.

.

that the design changes were not scheduled. The operators were knowledgeable of the corrent operating bands. Specific panel displays indicating outside the respective green band included turt>ine the lube oil header pressure computer point, the control rod drive cooling water flow differential pressure (Unit 1 and 2), the reactor building closed cooling nier temperature (Unit 1 and 2), the reactor ca isolation cooling steam inlet pressure, the radwasM W" ding differential pressure, and the OB waste concentrator tank level.

The OB waste concentrator tank was permanently removed from service. However,

,

there was no label on the radweste control panel to indicate that the licensee no longer I

used the instrument. In addition, the inspectors noted that the licensee had initiated

'

action requests for two tank level instrument displays in the radwaste control room where the full range of the indicated green band could not be used without receiving a level alarm.

None of the instances noted by the inspectors were considered by the licensee as control room distractions. However, the licensee was reviewing the issue and indicated to the inspectors their intention to perform a review of all plant panels for similar j

occurrences.

c.

Conclusions

.

.

I Several main and radwaste control room instrument displays did not indicate within the respective normal operating band or " green" band, although the actual measured parameters were within the design operating range. Although operators were knowledgeable of the correct operating bands and the potential design changes, the

,

issues were not identified as control room distractions. Operations personnel did not

,

take action to ensure the discrepancies were appropriately resolved in a timely manner.

Operator Knowledge and Performance 04.1 FeedwaterTransient a.

Inspection Scope (71707. 92901)

The inspectors observed the main control room operaitors' response to the loss of the

'

feedwater heater drain pump forward capability. In addition, the inspectors reviewed the overall plant response to the transient.

b.

Observations and Findinas, On January 5,1999, the heater drain pump forward valves unexpectedly closed. The operators' response to the unexpected reduction of condencate flow to the reactor feedwater pumps, which resulted from the unexpected closure of the heater drain tank pump forward valves, was timely and in accordance with plant abnormal operating procedures. A qualified nuclear engineer and the shift technical advisor reported to the control room in an expeditious manner and assisted the operating crew in evaluating the nuclear parameters impacted by the reduction in power. The operators reduced reactor j.

power to compensate for the reduced condensate flow to the reactor feedwater pumps.

'

The inspectors noted that the feedwater level control system responded as designed and maintained reactor vessel water level within the normal control band as operators lowered reactor power by reducing reactor recirculation flow. The reactor recirculation

.

and control rod drive systems also responded as designed. Two feedwater heaters 8-l*

e-w a=w--

-

w y

w

~n.,.4-.--i t-s-

- - - - -

=a e

~.-- - + + - -

w-

-

's+

e-

e-

. _. _.. _ _ _ _ _. _. _ _ -

. _... _ _. - _ _._.._.. _._. _ _ __ _.

.

.

.

J

,

'

isolated as expected due to a high level in the heater drain tank. Following the troubleshooting and maintenance discussed in Section M2.1, the operators restored the

,

l plant to full power.

!

l c.

Conclusions

'

The control room operators' response to the unexpected closure of the heater drain tank

~

pump forward valves and resultant reduction in condensate flow to the reactor feed i

pumps was appropriate. The. licensee's technical support staff responded to the transient in an expeditious manner.

-

l 04.2 Operator Resoonse to Decreasina Condenser Vacuum i

a.

Insoection Scope (71707. 92901)

The inspectors reviewed the operators response to the decrease of the main condenser vacuum which occurred when operators changed the operating train of the Unit 1

- off-gas (OG) system.

b.

Observations and Findinas -

On January 24,1999, with Unit 1 at 100 percent power, operators were placing a redundant OG train in service to remove the operating train from service for maintenance. After the operators isolated the previously operating train, the main

,

condenser vacuum decreased by approximately 3" mercury (Hg). Concurrently, control i

room operators identified that the total OG flow dropped significantly and other operators near the OG system identified abnormal flow noises in the oncoming OG train.

Operetors reduced the reactor power level by reducing reactor recirculation flow to restore the condenser vacuum, in addition, the operators restored the previously operating OG train to service.

Both the OG trains were in operation until the licensee evaluated the problem. From the evaluation, the licensee determined that the manual isolation valves for the train being removed from service leaked. Therefore, when operators isolated steam from the air ejector, a bypass flow path to the train being placed in service existed. The licensee changed the operating procedure to allow the operators to isolate the leakage path between the OG trains. Operators then completed the transfer in order to perform the maintenance on the train scheduled to be removed from service.

The operators maintained the plant in a safe condition throughout the transient and operated the plant in accordance with the appropriate normal and abnormal operating procedures. The licensee identified the leaking valves, formulated recovery plans and subsequently completed the restoration to full power safely and effectively. When the licensee reviewed the maintenance history of the leaking valves, the results of the review indicated that an engineer previously identified that the valves were leaking. A procedure change request to isolate the leaking valves was in process and a more timely implementation of the procedure would have precluded the transient.

.

, _..

,

'

.

.

.

c.

Conclusions Operators responded to a decrease in main condenser vacuum which occurred as a result of leaking isolation valves in an OG train being removed from service. Control room operators operated the plant in accordance with the appropriate plant procedures and maintained the plant in a safe condition throughout the transient. However, a more timely implementation of the procedure change to address the leaking valves would have precluded the transient. The licensee safely restored the plant to full power.

04.3 Control Room (CR) and Auxiliary Electric Room (AEER) Ventilation Systems Declared Inoperable Durina Radiation Monitor Detector Maintenance and Testina a.

Insoection Scone (71707)

The inspectors reviewed control room ventilation radiation monitor failures which occurred during the inspection period. The inspectors reviewed the Technical Specifications (TS), the Updated Final Safety Analysis Report (UFSAR), the control room logs, the degraded equipment log, and interviewed operations personnel, b.

Observations and Findinas On January 25,1999, a radiation monitor for the CR and AEER ventilation system failed and would not reset. The operators declared the equipment inoperable, implemented actions required by TS Limiting Condition of Operation (LCO) 3.3.7.1for the radiation detector, and initiated a problem identification form (PIF). In addition, the operators initiated work documents to repair the detector (see Section M2.3).

While reviewing the operator's actions to the specific detector failure, the inspectors identified that the operators took action to prevent the CR and AEER ventilation train from automatically starting when technicians performed maintenance or testing of the radiation detectors in that train. Specifically, the operators declared the B CR/AEER train inoperable and placed the emergency makeup unit and supply fan switches in the pull-to-lock position when instrument maintenance technicians were repairing or testing the B train radiation monitors. Section 7.3.4.1 of the UFSAR indicated that maintenance and testing of a single radiation monitor would not result in an inoperable ventilation system. In addition, the TSs did not require that the CR/AEER system be made inoperable for testing or maintenance on the radiation detectors. In the late 1980s, the licensee implemented the practice of simultaneously declaring the CR/AEER train inoperable to prevent inadvertent automatic equipment actuations when a corresponding radiation detector was inoperable for testing or maintenance.

The licensee recorded the equipment unavailability when the detector or the CR/AEER ventilation system was inoperable as required by the maintenance rule. However, the licensee indicated that operations personnel would no longer unnecessarily declare equipment inoperable during maintenance and testing.

j c.

Conclusions

!

The operators conservatively declared the applicable train of the CR/AEER ventilation system inoperable when a radiation detector was declared inoperable. When the

-

system was inoperable, the availability of safety related ventilation systems decreased and the licensee accurately recorded the system unavailability for maintenance rule purposes. The licensee had implemented this process in response to historical poor

personnel performance and planned to discontinue declaring equipment inoperable l

unnecessarily, ll. Maintenance M1 Conduct of Maintenance M1.1 Unit 2 Drywell inse?ction a.

Insoection Scope (62707)

The inspectors observed a maintenance pre-job briefing, evaluated the housekeeping and material condition of the Unit 2 drywell, and observed the following drywell work activities in progress.

Work Request (WR) No. 960013327, Reactor Recirculation Suction isolation

.

Valve Refurbishment Work Request No. 970105797-01, Low Pressure Core Spray (LPCS) Testable

.

Check Valve Repairs OOS No. 980011337, Safety Relief Valve (SRV) Accumulator Venting

.

b.

Observations and Findinas The pre-job briefing for the replacement of the internals of the Unit 2 reactor recirculation suction isolation valve was well coordinated and comprehensive.

Maintenance personnel performed the work activities in the Unit 2 drywellin accordance with the requirements of the work package and the pre-job briefing. The vicinity of the worksite was free of debris, workers generally used appropriate procedures for foreign material exclusion (FME), and workers and supervisors demonstrated a detailed knowledge of the work.

While inspecting the Unit 2 drywell, the inspectors identified that the bonnet was not installed on the LPCS testable check va!ve, which was disassembled for maintenance.

However, no FME barrier was in place and no maintenance personnel were performing maintenance on the valve. The inspectors found an FME cover in the vicinity of the valve but not attached. The licensee's FME procedure required that FME covers be adequately secured to equipment. In addition, the inspectors also found that air lines to a residual heat removal (RHR) testable check valve were disassembled and no FME covers were installed. The inspectors informed the licensee's drywell coordinator and mechanical maintenance superintendent of the conditions and the licensee initiated actions to inspect the exposed piping with a boroscope and establish appropriate FME protection. The licensee took additional actions to prevent recurrence including discussing this event, and the results of an effectiveness evaluation of the

,

l implementation of the licensee's new FME procedure, at a communication meeting with mechanical maintenance personnel.

_ _ _ _ _. _ _. _. _ _. _ _. _ _. _. _ _. _ _.. _. _ _ _ _ _ _ _. _ _... _

>.

-

-

.

,

,

.-

l During the drywell inspection, the inspectors also identified that caps were removed

'

,

from the steam relief valve accumulator vent pipes. Although operators removed the l

!

caps as directed by an OOS procedure, the operators did not establish an FME boundary to preclude dirt or small pieces of debris from falling into the piping, and

!

potentially the accumulators, as a result of maintenance activities in the area. The licensee's FME procedure required all open process piping to have specific controls in place to prevent the introduction of foreign material. Therefore, the lack of FME i

protection for the vent lines did not meet the licensee's procedural requirements. The

inspectors informed the licensee of the conditions observed and the licensee took

'

actions to establish appropriate FME protection.

The licensee identified an additional instance of inadequate FME protection when a maintenance technician fell into a sump opening which was covered by plastic. As a result of the fall, the technician did not become contaminated but received a laceration on his leg. Although a rope barrier identified the area surrounding the sump as a foreign material exclusion area, a "NO STEP" sign was not placed on the sump cover as required by Nuclear Station Procedure (NSP)-WC-3008, " Foreign Material Exclusion,"

Revision 1. The licensee subsequently placed the required sign on the sump cover.

The licensee's failure to follow the FME procedure in the three instances above is a violation of TS 6.2.A.a. which requires the licensee to implement and follow the applicable procedures specified in Regulatory Guide 1.33. Regulatory Guide 1.33

specifies that procedures be implemented for the general control of maintenance on

'

. safety related equipment. The licensee did not identify any foreign material insida any

,

of the areas with inadequate foreign material protection. In addition, the corrective

actions were also appropriate. This failure constitutes a violation of minor significance and is not subject to formal enforcement action (Minor Violation (MV) 50-374/99001-01),

Also during the drywell inspection, the inspectors noted that portions of the concrete drywell floor above the pressure suppression chamber appeared to be eroded. A contract iupervisor stated that the condition had been noted by contract personnel, however, neither the contract supervisor nor the contract personnel initiated a PlF or notified the licensee's drywell coordinator. The inspectors informed the drywell coordinator of the conditions and the licensee initiated an engineering request to evaluate the deteriorated concrete. The licensee's initial determination of the extent of the condition revealed that *.he degradation appeared limited to the area identified by the inspectors and that the erosion was limited to the concrete surfacing compound. The licensee planned to comp!ete the evaluation prior to Unit 2 startup.-

c.

Conclusions The licensee did not maintain adequate FME boundanes during maintenance activities in some instances. In addition, contract personnelidentified a condition potentially adverse to quality, but did not document the issue or notify licensee management of the concem. Specifically, contract personnel noted potentially eroded concrete in the

. drywell but did not forward the concem to the licensee's corrective action program. The licensee's corrective actions for the issues were appropriate.

{

.

.

-

.-

-

-.

-. - -

---. -

-.

-.

p

,

.

.

.

,

,

d M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Loss of Pumo Forward C=ammv a.

Insoection Scone (62707. 92902)

The inspectors reviewed the graphs of the plant response and interviewed operators

' and maintenance personnel following the unexpected closure of the heater drain tank pump forward valves. The inspectors assessed the material condition of the equipment involved, the aggregate impact of the noted deficiencies on the operation of the plant,

. and the licensee's corrective actions.

b.

Observations and Findinag On January 5,1999, the three heater drain pump forward valves received an erroneous signal to close. The valves directed flow from the heater drain tank pumps to the suction of the reactor feed pumps. The valves closed and resulted in less condensate flow to the reactor feedwater pumps and an automatic start of an additional condensate pump and condensate booster pump. Also, operators reduced reactor power to maintain the appropriate reactor vessel water level. The inspectors noted that the feedwater level control system responded as designed and maintained reactor vessel water level within the normal control band as operators lowered reactor power by reducing reactor recirculation flow. The reactor recirculation and control rod drive systems responded as designed. Two feedwater heaters isolated as expected due to a high levelin the heater drain tsnk.

Instrument maintenance personnel developed and implemented a comprehensive troubleshooting plan to determine the reason that the valves closed. From the review, maintenance personnel identified that the general initiating event of the transient was a spurious change in the heater drain tank level setpoint from 7 feet to 10 feet. However, maintenance personnel were unable to identify the specific failure which caused the

.

level setpoint change. The licensee's troubleshooting plan anticipated that it would be difficult to identify the specific component failure and contained a step to replace a controller circuitry card and components of the heater drain tank level control circuitry.

The licensee replaced the components and satisfactorily tested the operation of the heater drain pump forward valves prior to retuming the valves to service. The valves operated normally throughout the remaining 6 weeks of the inspection period.

During the investigation, the licensee also identified that there was no flow indicated from the 1B heater drain pump when the heater drain system load decreased after the pump forward valves closed. The licensee concluded that the 1B pump performance j

had degraded below the performance of the other two heater drain pump which were running in parallel. The other running pumps provided sufficient pressure to close the discharge check valve of the 1B pump during the low load condition. Although no equipment problems resulted, the licensee planned to overhaul the 1B heater drain pump during the next refueling outage and was evaluating performing the pump maintenance on-line prior to the outage.

The licensee's management conducted a critique of the event and identified several

- - - -

opportunities in which the recovery from the transient could have been performed in a

_ _ _ _. - _ _. _ _ _ _ _ _ -. _... _ _. _ ~ _.. _ _

.

-

'

.

,

more efficient manner. Operators and maintenance technicians actions were appropriate and no additional material condition problems were noted.

c.

Conclusions An equipment problem with the controller for the heater drain pump forward valves resulted in the simultaneous closure of the three valves and subsequent' reduction in condensate flow to the reactor feed pumps. Overall, plant equipment operated as designed during the transient. Maintenance department personnel effectively developed and implemented a comprehensive troubleshooting plan to retum the valves to service in a timely manner, in addition, the 1B heater drain pump was found by the licensee to have degraded performance. The licensee's plans to address the performance of the 1B pump was adequate.

M2.2 Review of Unit 2 Standby Liouid Control System Maintenance and Modifications a.

Insoection Scope (62707)

The inspectors reviewed the status of Unit 2 outage maintenance activities scheduled for the standby liquid control (SLC) system including the status of all work requests,

'

action requests, and engineering requests related to the system. In addition, the inspectors performed a system walkdown to assess the material condition of the SLC system.

b.

Observations and Findinas

During the inspection period, the licensee stated that all maintenance activities were completed on the SLC system. However, the inspectors found that a few action

,

requests remained on the system after the licensee indicated that all maintenance work was complete. These action requests included items such as the repair of a pump gearbox grease leak, replacement of a copper tube vent line from the pump gearbox, and repair of loose sheathing on pipe insulation. These items either had not been through the planning process or were not prioritized to be completed during the outage after going through the licensee's work control process. The remaining maintenance activities were consistent with the licensee's outage scope criteria and did not impact the system operability. The inspectors found that the licensee had scheduled the remaining items such as testing, procedure revisions, and design change documentation closure prior to system turnover to operations.

c.

Conclusions The licensee completed the planned SLC system maintenance activities and began i

testing the SLC system in accordance with the established schedule, The action j

requests which the licensee had not scheduled for completion prior to the system being returned to service would not impact system operability.

i

'

.

-

-.

-

,

-

i

-

-

-

.

.

I

,

-

.

..

.

.

)

M2.3 - Response to Rana =+ad CR and AFFR Radi= Hon Monitor Failures

a.

Insoection Scope (62707)

The inspectors reviewed the licensee's troubleshooting, repair, and testing of the control room ventilation radiation monitors following several failures during the inspection period.

b.

Observations and Findinas On January 25,1999, a radiation monitor for the CR and AEER ventilation system failed and would not reset. The operators declared the equipment inoperable, implemented actions required by TS LCO 3.3.71, and documented the problem on a PIF. Also, the operators initiated work documents to repair the detector.

_

While reviewing the PIF, the licensee identified that two radiation monitors in the B CR/AEER ventilation train had failed several times in the previous 30 days and developed a comprehensive troubleshooting plan to determine the root cause of the j

radiation detector failures. The licensee implemented the troubleshooting to identify the cause of the failures so that maintenance personnel could develop appropriate repairs.

During the review, maintenance and engineering personnel determined the various failure modes of the monitor, evaluated each failure mode, and developed

!

recommendations. The licensee concluded that the January 25,1999, monitor failure was due to a premature electrical component failure of a newly installed detector. To address the premature failures, the licensee planned to enhance the maintenance program by operating the detectors for a period of time to identify defective detectors i

. prior to placing them in service. Also, the licensee planned to evaluate'a program for i

energizing other electrical components prior to installation as a preventative maintenance activity.

c.

Conclusions The licensee performed a thorough investigation of repeated radiation monitor failures and developed appropriate corrective actions.

M4 Maintenance Staff Knowledge and Performance M4.1 Construction Personnel Errors in Imolementina OOS

.

a.

Insoection Scope (62707. 92902)

,

'

The inspectors reviewed two instances in which the licensee identified maintenance personnel errors while performing OOS activities. Specifically, the inspectors reviewed j

the licensee's initial actions following the discovery of the errors and assessed the adequacy of the licensee's subsequent corrective actions.

b.

Observations and Findinas

)

On February 2,1999, a contract sheet metal foreman reviewed work request

"-

No. 960017462-04 and identified that work was in progress on the Unit 2 primary containment ventilation (VP) ductwork without an OOS. The licensee took immediate

'

__

-.i.--a

-,.

48\\.

p-4

<

A K

J-

w--+k a

-

-

.

'

-

.

.

l

.

action to stop work on the Unit 2 VP ductwork in the drywell and initiated an investigation. The licensee's investigation concluded that the cause of the failure to have an OOS for the work was human performance errors by the personnel assigned to complete the work, the supervisor, and the work analyst. The licensee discussed the

'

details of the event with the sheet metal work group and lessons leamed were discussed at a weekly maintenance communication meeting. Furthermore, the licensee intended to document the lessons learned from this event. In addition, the licensee I

developed a new seminar for maintenance supervisors and foremen which stressed the importance of correctly reading work packages and ensuring that an OOS was correct.

The licensee's completed and planned actions wure adequate and there were no nuclear safety consequences of this event. The personnel safety consequences were

'

minimal since the VP fans were OOS for a separate maintenance activity.

On February 8,1999, contract maintenance personnel, assigned to connect electrical wiring in accordance with work request No. 980114430-01, discovered that the wires had OOS tags affixed to them specifying that the wires remain disconnected. The maintenance personnel discussed their findings with their supervision and were directed to proceed with the work. Licensee operations personnel assigned to remove the OOS tags discovered the wires connected with the OOS tags in place. The licensee stopped all work related to connecting and disconnecting electrical wiring associated with temporary modifications and initiated a prompt investigation. The licensee planned to complete an apparent cause investigation by February 20,1999, and train electrical maintenance personnel (including supervisors) on the OOS standards and expectations.

The licensee's response appeared appropriate and there were no nuclear safety consequences of this event. The personnel safety consequences on this specific incident were minimal since both the wiring and the breaker to which the wires were connected were deenergized and OOS. In both instancss, configuration control was not maintained.

  • c.

Conclusions The licensee identified two errors where contract construction personnel did not meet programmatic requirements and management expectations for the OOS program. The consequences were minimal but the events warranted continued station management attention in reinforcing strict compliance with OOS program requirements to ensure that personnel safety was maintained and configuration control problems did not result in more significant problems. The licensee's completed and planned corrective actions were adequate.

M8 Miscellaneous Maintenance issues M8.1 Unit 2 Maintenance Backloa Review Plan a.

Insoection Scope (62707)

The inspectors reviewed licensee actions to address the corrective maintenance backlog for Unit 2. In addition, the inspectors reviewed the implementation of the licensee's implementation of Restart Plan Strategy 3, Action Plan 3.3 related to the maintenance backlog review plan for Unit 2.

l

_

._ _ _ _. _

-

_ _. _ _. _. _.

.._.______.___.__.._m

_ _.

-

'

'

.

.

.

L b. -

' Observations and Findinas The inspectors verified that the licensee implemented the Restart Action Plan to evaluate the maintenanoe backlog and determine which corrective tasks would be included in the Unit 2 outage plan. Also, the licensee reviewed corrective tasks on an ongoing basis during the outage to ensure that plant material condition was acceptable for Unit 2 restart.

)

The licensee implemented the action plan to ensure that plant personnel appropriately addressed the backlog of both outage and non-outage corrective maintenance activities.

The licensee also used three different sources to identify corrective tasks on a daily basis that might need to be added to the Unit 2 outage work scope. The three sources included action requests, tasks added to work requests, and outage scope change request forms. The licensee's action request (AR) screening committee reviewed the -

ARs and tasks added to work requests to determine the work priority (outage or non-outage). The screening committee then submitted any items recommended for completion during the Unit 2 outage to the scope screening committee. The scope screening committee reviewed the work using the restart scope criteria specified in the

,

LaSalle Station Outage Scope Control Guideline, WC 302. The licensee's process for reviewing and approving changes to the outage work scope, as well as the criteria used i

to define the work, was appropriate and the screening of items for completion within the outage was accurate.

c.

Conclusion The licensee established a plan to address the Unit 2 material condition as a part of L

their Restart Action Plan item 3.3 and determined what work would be performed before i

restart of Unit 2. The licensee reviewed the outstanding work request backlog, determined the corrective tasks which would be completed prior to Unit 2 startup, and incorporated the work in the Unit 2 outage plan. Also, the licensee's implementation of the process for reviewing potential work for the Unit 2 outage appeared adequate.

Ill. Enaineerina E1 Conduct of Engineering E1.1 Operability Determination Reviews I

a.

Insoection Scone (37551)

The inspectors reviewed the UFSAR and an Operability Evaluation (OE) 98033 regarding possible problems with piping welds on American Society of Mechanical Engineers (ASME) Section 111 Class 3 piping.

b.

Observations and Findinas The inspectors verified that the documentation of the operability evaluation met the licensee's administrative requirements and that the assumptions used to develop the operability determination were valid. The licensee was in compliance with the TS

>

requirements and engineering personnel supported operations by completing the operability evaluation in a timely manner.

-

.

__

-..

_

_

_

-_

.

'

'

.

.

\\

.

The inspectors discussed the OE with operations and system engineering personnel.

Operators were cognizant of the issues and corrective actions resulting from the j

evaluations.

'

c.

Conclusions Engineering personnel adequately completed the operability determination related to piping welds in a timely manner using appropriate assumptions. Operations personnel were cognizant of the issue and corrective actions identified in the evaluation.

IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Inaooropriate Radiation Area Access Control a.

Inspection Scope (71750)

The inspectors performed a walkdown of the radiological area controls in the Unit 2 reactor building. Specifically, the inspectors reviewed access signs to areas being controlled as high radiation areas, and radiation survey information located on ladders and scaffolding.

b.

Observations and Findinas On February 6,1999, the inspectors discovered that an extension ladder in the Unit 2 reactor building was positioned to allow an alternate personnel access path to a scaffold platform which was in an area which the licensee controlled as a high radiation area.

'

The normal access was by a scaffold ladder which the licensee appropriately controlled with high radiation signs. However, the extension ladder did not have any signs but did have an equipment-in-use tag affixed to it. The inspectors informed the licensee's radiological protection management of the posting discrepancy. The licensee promptly removed the ladder. In addition, the licensee initiated an investigation in accordance with their corrective action program. Radiation protection personnel surveyed the area in the vicinity of the scaffold and found that all radiation levels were below the station definition of a high radiation area (<100 millirem per hcur). The inspectors considered the licensee's response adequate.

The inspectors did not identify any additional instances of inadequate radiological postings. However, the licensee identified that an instrument maintenance technician passed through a radiation area barrier to the area under the Unit 2 reactor vessel.

However, the technician's radiation work permit (RWP) did not permit entry into the area under the reactor vessel. The licensee performed an investigation of the event and determined that the issues was an isolated problem. The licensee counseled the worker who was not familiar with LaSalle station and did not maintain appropriate attention to detail while in the plant. The licensee's response to the problem was adequate.

c.

Conclusions The inspectors identified an access path to an area being controlled as a high radiation area which was not properly identified in accordance with plant radiation protection

..

.

.

_ - -

_ - _ _..

.

.

.

.

procedures. Furthermore, the licensee identified that a construction maintenance technician inappropriately entered the area under the Unit 2 reactor vessel. The worker's RWP associated with his maintenance activity did not authorize entry to the area. Although the problems appeared to be isolated and the licensee's response was appropriate, the events indicated the need to continue to provide radiation protection i

oversight of construction activities.

l V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the results of these inspections to licensee management listed below at an exit meeting on February 16,1999. 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.

'

l l

l

~

.

. -.-

.- --

-..

-.

.-.

.

.

-

..

-.

-

i O

.

.

.

.

.

,

.

PARTIAL LIST OF PERSONS CONTACTED I

i

'

Comed l

l

  • J. Benjamin, Site Vice President
  • C. Berry, Chief of Staff D. Bowman, Chemistry Supervisor
  • R. Brady, Jr., Regulatory Assurance Manager

,

  • E. Connell, Design Engineering Supervisor C. Crane, Vice President, BWR Operations D. Farr, Operations Msnager i
  • G. Heisterman, Maintenance Manager G. Kaegi, Site Training Manager R. McConnaughay, Shift Operations Superintendent
  • J. Meister, Engineering Manager T. O'Connor, Plant Manager
  • R. Palmieri, System Engineering Manager J. Place, Health Physics Supervisor
  • K. Poling, Work Control Manager J. Pollock, Support Engineering Superv;sor
  • W. Riffer, O & SA Manager
  • E Shankle, Support Services Manager R. Stachniak, Nuclear Oversight Assessment Manager
  • Present at exit meeting on February 16,1999.

INSPECTION PROCEDURES USED IP 37551:

Onsite Engineering IP 61726:

Surveillance Observation IP 62707:

Maintenance Observation IP 71707:

Plant Operations IP 71750:

Plant Support Activities IP 92901:

Followup - Plant Operations IP 92902:

Followup - Maintenance ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-374/99001-01 MV Failure to follow FME procedure Closed 50-374/99001-01 MV Failure to follow FME procedure DiMW119d None

-

-

.-

_

.-.

_

.

O l

.

'

,

,

,

,

.

,

LIST OF ACRONYMS USED AEER Auxiliary Electric Room AR Action Request ASME American Society of Mechanical Engineers

,

BWR Boiling Water Reactor

-

CR Control Room DRP Division of Reactor Projects FME Foreign Material Exclusion HPCS High Pressure Core Spray IM Instrument MJchanic IP Inspection Procedure IRM Intermediate Range Monitor j

LCO Limiting Condition of Operation

!

LFP LaSalle Fuel Procedure LPCS Low Pressure Core Spray LPRM Local Power Range Monitor MCC Motor Control Center MV Minor Violation NRC Nuclear Reg.:atory Commission NSP Nuclear Station Procedure

OE Operability Evaluation

.

OG Off-Gas

]

OOS Out-Of-Service

-

PlF Problem Identification Form

.

RHR Residual Heat Removal RWP Radiation Work Permit i

SLC Standby Liquid Control SRM Source Range Monitor SRV Safety Relief Valve SWGR Switchgear TMOD Temporary Modification UFSAR Updated Final Safety Analysis Report VP Primary Containment Ventilation WR Work Request i

.