ML19321A393

Responds to NRC 800509 Ltr Re Violations Noted in IE Insp Rept 50-373/80-15.Corrective Actions:Battery Chargers Have Been Cleaned.Units 1 & 2 Steam Dryers Require Extensive Mod

ML19321A393
Person / Time
Site:	LaSalle
Issue date:	06/06/1980
From:	Peoples D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19321A388	List: ML19321A393
References
NUDOCS 8007230281
Download: ML19321A393 (8)

Text

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. /%--one Commonwealth First Edison National Plata. Chicago. Ilknas

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',l 7 /J Addr2ss R; ply 12: Post Offics Box 767 Ng;$r ChiCIgo, llhnois 60690 l W

June 6, 1980 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission, 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

'LaSalle County Station Unit 1 Response to IE Inspection Report No. 50-373/80-15 NRC Docket No. 50-373 Reference (a): R. F. Heishman letter to C. Reed dated May 9, 1980

Dear Mr. Keppler:

The following is in response to the inspection conducted by Messrs. F. Maura, F. Reimann and J. Streeter on February 19-22, 26-29, March 4-7 and 19-22, 1980, of activities on LaSalle County Station Unit 1. Reference (a) indicated that certain activities appeared to be in non-compliance with NRC requirements. These activities are addressed in the enclosurc to this letter. Each of these items and the Commonwealth Edison respanse has been discussed at length with Mr. J. Streeter of your staff.

You should also be aware what appears to be a departure from past practice with regard to the content of the subject inspection report. Specifically, it should be noted that item 4.a of the Notice of Violation was not discussed at the exit interview held on March 21, 1980. It is acknowledged, however, that these matters were reviewed in subsequent telephone conversations with members of your staf f.

In the case of Item 1.e, the foreign material in the reactor vessel to which reference is made was not discovered until March 22, 1980, and as such could not be relied upon to support the findings discussed at the exit interview on March 21. This matter is under intensive review by Commonwealth Edison, and our final evaluation will be available at the site f'r review by your staff.

Preliminary evaluation by the Commonwealt Edison Operational Analysis Department (OAD) has been comp.',v.ed and the Nuclear Steam Supply System vendor (General Electric) aas been requested to perform an evaluation which is expected to be completed shortly.

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800723028'l.

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.Mr. James G. Keppler June 6, 1980 Page 2 Because of the extensive review both by your staf f and our own of this response, the date for submitta] of the formal response was extended to June 6, 1980. This extension was communicated in a telecon from Mr. R. Walker of your staff.

Please refer any additional questions you may have on these matters to this office.

Very truly yours, K7%2c D. L. Peop2'es

[ Director of Nuclear g/

Licensing Enclosure l

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l 4387A

. Enclosure Response to Notice of Violation The items of apparent non-compliance identified in Appendix A of the NRC letter dated May 1, 1980, are responded to in the following paragraphs.  !

1. 10 CFR 50, Appendix B, Criterion II requires, in part, that activities affecting quality be accomplished under suitable controlled condition, such as adequate cleanliness. Criterion XIII requires, in part, that meaSJres be establisned to contro) the storage and preservation of material and equipment in

! accordance with work and inspection instructions to prevent damage or deterioration.

The Quality Assurance Program, Quality Requirement QR2.0, contains a Commonwealth Edison Company commitment to the regulatory positions of Regulatory Guide 1.38, Rev. 2, and Regulatory Guide 1.39, Rev. 2. The regulatory positions of Regulatory Guides 1.38, Rev. 2 and 1.39, Rev. 2 endorses the requirements of ANSI N45.2.2-1972 and N45.2.3-1973 respectively.

ANSI N45.2.2.-1972, Section 6.2, states, in part, that,

" Cleanliness and good housekeeping practices shall be enforced ,

at all times in the storage areas. The storage areas shall be 4

cleaned as required to avoid the accumulations of trash, discarded packaging materials and other detrimental soil . . .

The use of storage of food, drinks . . . in any storage area shall not be permitted . . . Periodic inspections shall be performed to assure that storage areas are being maintained."

Section 6.5 states, in part, that, " Items released from storage and placed in their final locations within the power plant, shall be.. . . cared for in accordance with the requirements of Section 6 of this standard." ANSI N45.2.3-1973 requires, in 1

part, that control of all tools, equipment, materials and supplies be maintained to prevent the inadvertent inclusion of deleterious materials or objects in critical systems.

Contrary to the above, the licensee does not have a program to maintain adequate cleanliness as evidenced by the following:

a. On February 19 and 20, welding and grinding of overhead HVAC equipment was being conducted in the control Room without adequate protection for the instruments below.

. b. During an inspection of the Control Room control panels on February 28 and March 6, 1980,_ dust, grit, and other debris was found inside the cabinets containing electronic equipment for such systems as the Building Unit Exhaust Monitor, Off-Gas Monitor, Radiation Recorders, Division 1 and 2 Leak Detection, Division 1 Diesel Generators, and TlP Machine Controls.

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c. Durjng plant tours on February 28 and March 6, 1980, i combustible material, discarded food, concrete block chips and grit, dust and other detrimental soll was found on 24V battery chargers 10C38E and 37E, 130V battery charger 2DC09E, control and relay cabinets for Diesel Generators 1A, 18, and 0, and High Pressure Core Spray instrument rack H-22-P024.

d. On March 4-5, 1980, difficulty was encountered in starting the 1A and IB recirculation pumps due to dirt in the incomplete sequence trip relay contacts, i e. On March 22, 1980, a foreign substance high in chlorides, sulfur, copper, and tin was found inside the Unit I reactor vessel adhering to sections of the vessel wall, head, core support plate, and feedwater sparger inlet box. The material was apparently left inside the recirculation system or vessel internals prior to the performance of an integrated recirculation system-vessel internals testing at elevated temperature and pressure.

Response

1. Corrective Action Trken and Results Achieved The cleaning of the control panels will begin as soon as a jurisdictional dispute between the craft electricians and CECO maintenance personnel is resolved. The battery chargers noted >

in the report have been cleaned. The Unit I and II steam dryers have extensive modifications to be made. After the modifications are complete, the dryers will be washed down with demin water. The steam separators will be washed down with demin water prior to installation in the vessel.

Inspection of the Unit I Rx vessel identified the following areas which require cleaning. These areas are the core plate, fuel support castings, control rods and guide tubes, the vessel walls above the main steam nozzles, vessel head, and the steam separator. These areas are being steam cleaned and locally cleaned using approved solvent. CECO NCR #415 and GE FDOR

1. HAl-300 have been written and forwarded to CECO Engineering Department for evaluation' . This review will determine any short term and long term affects this foreign material may have.

Corrective Action to Avoid Future Noncompliance Site Quality Procedure SQP-13-3 has been written. This procedure describes the cleanliness requirements for the various I areas of the plant. A Ceco Station Construction field engineer has been given the responsibility to implement this procedure.

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Date of Full Compliance Site Procedure SQP-13-3 will be implemented June 9, 1980.

2. 10 CFR 50, Appendix B, Criterion V, states that, " Activities af fecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to

) the circumstances . . . Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." Quality Requirement 11.0, Section 4

11.2, states that, " Written test procedures will be developed to demonstrate design and performance characteristics as specified in design and operating requirements. The procedure will ,

include . . . the data to be obtained and requirements and acceptance limits to be fulfilled." Startup Manua. procedure LSU 400-1, Section F.1, requires that preoperational test procedures include precautions needed for safety of equipment and that it contain acceptance criteria against which the success or failure of the test will be judged. It also requires that these items be clearly described, highlighted, or identified. Contrary to the above:

a. Revision 29 to test procedure PT-RR-101, dated February 18,

< 1980, which was issued to provide for the measurement of the time from turbine control valve fast closure signal to complete suppression of the electronic arc between the open contact of the recirculation pump motor circuit breaker, did not include acceptance criteria listed in design or i

licensing documents,

b. Procedure PT-RR-101 did not contain any precautions, limitations or steps designed to protect the reactor vessel against thermal transients. i

Response

2. Regarding item 2.a. and 2.b., steps were taken during the inspection to correct the identified noncompliance.

Consequently, no reply to these items of noncompliance is

. required.

3. 10 CFR Part 50, Appendix B, Criterion XII, requires, in part, that " Measures shall be established to assure that tools, gauges, instruments and other measuring and testing devices used in activities affecting quality are properly . . . calibrated

. . . at specified periods to maintain accuracy within necessary limits." Quality Assurance Program Quality Requirement 12.0, Section 12.1, states that Measuring and test equipment which is

used.. . to perform the preoperational testing . . . will be periodictlly calibrated or adjusted to assure that accuracy is maintained within necessary limits in order to verify design requirements."

The Quality Assurance Manual introduction contains a licensee commitment to comply with applicable Regulatory Guides as listed in the FSAR. Furthermore, the FSAR, page B.1-37, states that testing of instrumentation and electrical equipment is in accordance with ANSI N45.2.4 (1972) and IEEE 336-1971.

IEEE 336-1971, Section 2.5.2, states, in part, that " Measuring and test equipment used to determine compliance with specifications shall be adjusted and calibrated at prescribed intervals against certified equipment having known valid relationships to nationally recognized standards." Section 6.2.1 states, in part, that " Tests shall be performed to verify that the quality of installed equipment has not deteriorated during the construction phase" and that " Tests shall be mar to assure that instrumentation and control channels are propc~ly .

calibrated." IEEE Standard Dictionary of Electrical and Electronic Terms defines " calibrate" for nuclear stations as

" Adjustment of the system and the determination of system accuracy using one or more sources traceable to the NBS."

" System" is defined as "The entire assembled equipment excluding only the sample collecting pipe."

Contrary to the above:

a. Calibrations of the entire instrument loop are not always performed prior to preoperational testing, as was the case for the recirculation loop suction temperature instrumentation,

b. The licensee has no program for conducting periodic calibrations during the construction phase of the plant prior to the acceptance of a system for operation.

Response

It should be noted that all of the references cited to justify this item of non-compliance apply only to Measuring and Test Equipment.

Commonwealth Edison, in accordance with what we believe is a valid interpretation of the applicable standards, does not include permanently installed plant instrumentation within the scope of Measuring and Test Equipment. Recognizing that Commonwealth Edison's program for periodic calibration of Measuring and Test Equipment meets the regulatory requirements and that the NRC's real concern addressed in this inspection is with permanently installed plant instrumentation, the following action will be implemented:

For.preoperational testing performed on or after June 16, 1980, the licensee commits that instrumentation utilized to provide data for demonstration of Acceptance Criteria and to satisfy sinnificant limitations in Preoperational Tests (PT's) shall meet the following:

1. Such instrumentation shall have calibrations of the entire loop (i.e. be loop checked) prior to the collection of data from that instrument which is to be used for demonstration of Acceptance Criteria. These " loop checks" may be done prior to or daring

. the course of a Preoperational Test (PT). It is noted that in special instances where the physical design of an instrument does not allow complete loop checks, as much of the instrument loop will be checked sa is possible.

j 2. Such instrumentation shall be "in calibration". For the purpose of this commitment, "In calibration" shall be interpreted that calibration of such instrumentation has been done within the preceeding 18 months.

Implementation of these additional measures will be achieved on June 16, 1980.

4. 10 CFR 50, Appendix B, Criterion XVII, requires, in part, that

. . . test records . . . identify . . . action taken in

- connection with any deficiencies noted." Appendix B of the FSAR, page B.1-33, and the Quality Assurance Manual include a licensee commitment to' comply with the requirements and guidelines of Regulatory Guide 1.28, which endorses ANSI N45.2.

Paragraph 18, " Quality Assurance Records," of ANSI N45.2.

j requires that sufficient records be prepared as work is performed to furnish documentary evidence of the quality of l Items -and of activities af fecting quality.

Contrary to the above:

a. The reactor vessel bottom head drain temperature

thermocouple was known to be damaged as early as December

5, 1979, but sufficient records were not generated until a Deficiency Report was written on December 19, 1979.

b. The recirculation loops suction temperature instruments were known to be giving inaccurate readings as early as February 4, 1980, but sufficient records were not generated j until a Deficiency Report was written on March 3, 1980.

Response

4. Corrective Action Taken and Results Achieved

, 'As noted above, sufficient records have been generated to document the subject deficiencies.

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Corrective Action to Avoid Further Non-compliance Commonwealth Edison's interpretation of the referenced statement from ANSI N45.2. is that the records referred to are the preoperational test records. These records are prepared as work is performed. However, in response to the inspector's concerns, the System Test Engineers will be notified that anomalous conditions encountered during testing must be promptly noted (e.g., a note in the margin of the test, an entry in Section 13.2 o f the test, generation of a deficiency report, etc.) to document that the problem was noted and its impact on the test evaluated prior to continuing the test.

Date of Full Compliance Full Compliance will be achieved on June 16, 1980.

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