ML19330B395
| ML19330B395 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/07/1980 |
| From: | Peoples D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19330B393 | List: |
| References | |
| NUDOCS 8007310533 | |
| Download: ML19330B395 (5) | |
Text
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July 7, 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 Supplemental Response to IE Inspect'.on Report No. 50-373/80-15 NRC Docket No. 50-373 Reference (a):
D. L.
Peoples letter to J.
G. Keppler dated June 6, 1980
Dear Mr. Keppler:
The enclosed information supplements the response prcvided in Reference (a) to the items of noncompliance discussed in IE Inspection Report 50-373/80-15.
This supplemental response was discussed with Messrs. Streeter and F. Maura of your Staf f on June 25, 1980.
The enclosed information documents the results of that discussion.
If there are any further questions in this regard, please direct them to this office.
Very truly yours,
/-
D. L. Peoples Director of Nuclear Licensing Enclosure 4992A JUL 111980 80 07310533
Enclosure Supplemental Response to Notice of Violation The items of apparent noncompliance identified in Appendix A of the NRC letter dated May 9, 1980 and addressed in the response contained in Reference (a) are discussed further in the following supplemental response.
Item 1 A.
The NRC requested that a physical inspection be performed of the dryer and separator, in addition to the cleaning discussed in Reference (a).
Commonwealth Edison will perform a visual inspection of both the dryer and separator prior to final installation in the reactor vessel.
In addition, the dryer will be submerged prior to final installation to flush any trapped materials.
Due to the large circular cross-sections within the separator and the ease of visual examination, submerging this component will not be required.
B.
The NRC requested that a visual examination of the control rod guide tubes be conducted.
Commonwealth Edison has conducted a visual examination of the outer row of guide tubes which are accessible without dissassembly.
Although the NRC suggested that a visual examination of a few internal guide tubes should also be performed, this additional inspection is judged to be impractical at this time.
Such an inspection would require draining the vessel and removing the installed construction work platform which would seriously effect the current plant schedule.
Because the contamination in question has been reviewed by General Electric with no additional inspection or cleaning recommended; the certain delay in schedule imposed by the additional guide tube inspection is judged not be justified.
C.
The NRC requested that a record be provided of the remedial work completed to address the contamination observed in the' Unit I reactor vessel.
Commonwealth Edison will document the cleaning work performed in
- a. report being prepared by Reactor Controls, Inc.
In addition, l
the LaSalle County operating staff will document inspections performed and observations made.
These documents will be available at the plant site for inspection.
D.
The NRC requested that the potential short and long term effects of the Unit 1 contamination be evaluated.
~~
O Commonwealth Edison has performed through its Operational Analysis Department (OAD) a chemical analysis of the contaminant.
This information was provided to the Nuclear Steam Supply System vendor, General Electric (GE), for review.
Although a final report has not been received as yet, GE has indicated that the contamination is not expected to have any deleterious effects on the surfaces exposed and that further cleaning beyond that now completed would not be required.
These reports will be available at the plant site for inspection.
E.
The NRC requested clarification of the program, implemented at LaSalle County to address cleanliness deficiencies.
Commonwealth Edison reiterated that an engineer has been assigned as staff assistant to the LaSalle site construction superintendent whose only job is to review and resolve cleanliness deficiencies.
This engineer will have the authority to assign construction labor as required to resolve clecoliness deficiencies ex'peditiously and to prevent future noncompliance.
To promote an understanding of the role of this individual, both the site construction superintendent (L. Burke) and the station superintendent (R. Holyoak) will issue a memorandum advising their respective staff to notify the staff engineer of all cleanliness concerns.
This program was recently implemented, and will be assessed over the next 2 to 3 months for its effectiveness.
If further corrective action is considered to be nr.stsary at the end of this time, Region III will be informed.
Item 2 - No clarification required Item 3 A.
The NRC requested clarification of the term "significant
. limitations" as applied to the corrective action to be implemented after June 16, 1980.
l The apparent limitation contained in this phrase represents a aualification not in the scope of the limitations delineated in a preoperational test procedure, but in the degree to which non-essential parameters which could be, but are in fact not, required to provide for the physical protection of equipment are covered by the corrective action to be taken.
Specifically, all limitations explicitly identified in the test procedure will be covered by the corrective action defined.
However, only the primary source of data will be required to meet the revised criteria, e.g. control room instruments will typically.be used rather than Iraal instruments and only one of a class of instruments FJst meet the criteria 1.e. pump suction pressure l
l
only where both suction and discharge pressu13 are available.
Simply stated, the corrective action discussed in Refere'nce (a) will be applied to all instruments providing essential information necessary to the completion of a test.
B.
The NRC requested that the basis for the 18 month surveillance criteria committed in Reference (a) be clarified.
Specifically, it was requested that the 18 month interval be assessed against ANSI 18.7 section 5.2.16.
In arriving at the 18 month surveillance interval, Commonwealth Edison considered all applicable regulatory and industry standards.
It is judged that this interval is adequate for the purpose it is intended to serve.
The 18 month interval is equivalent to the current practice at recently licensed LWR facilities and is consistent with the practice at operating nuclear facilities on the Commonwealth Edison system.
It should be understood that this program applies to all equipment essential to a test as discussed in Item 3.A above, and in that regard is a broader requirement than the mandatory surveillance under the technical specifications.
The parameters addressed in ANSI 18.7 section 5.2.16 were also reviewed, and it is judged that the program defined for LaSalle County Station is compatible with the guidance offered.
Although no clearly defined surveillance standards have been established, the criteria to be imposed at LaSalle County provide the necessary assurance that essential instrumentation will provide appropriate data to evaluate a system test.
C.
The NRC requested that additional information be provided relative to the adequacy of data accumulated on tests performed prior to June 16, 1980.
Commonwealth Edison agrees to review against the revised criteria the calibration and loop check status of all instruments relied upon for per-operational tests performed prior to June 16, 1980.
Justification will be provided for the use of data acquired from instruments not meeting the new criteria.
This process will include the following steps:
1.
determination of surveillance status prior to the test 2.
recalibration if new criteria is not satsified.
3.
if upon recalibration the instrument is found to have been out of calibratin:
(a) accept results if deviation is conservative, (b) justify use of results if deviation is not conservative l
o.
_4 This program is representative of the review that will be conducted for all inctruments relied upon in tests. performed prior to June 16, 1980.
1 Item 4 - No clarification required.
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