ML19332D599
| ML19332D599 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/20/1989 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML19332D600 | List: |
| References | |
| NUDOCS 8912050007 | |
| Download: ML19332D599 (3) | |
See also: IR 05000373/1989018
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Docket No. 50-373 .
NOV 29 19 9
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Docket No. S0-374
Commonwealth Edison Company
ATTN:: Mr. Cordell Reed
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Senior-Vice President
Post Office Box 767
Chicago,.IL 60690
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Gentlemen:
SUBJECT: SAFETY SYSTEM FUNCTIONAL INSPECTION
This letter forwards the results and conclusions of the Safety System Functional
Inspection-(SSFI) of the high pressure core spray system (HPCS) at the LaSalle
County Nuclear Generating Station. The inspection was conducted from July 24
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through August 25, 1989 by NRC personnel and consultants, and an exit meeting
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was conducted at the site on August 25, 1989, with Mr. G. Diederich and others
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of your staff. Additional information was subsequently forwarded to the
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inspection team for evaluation, and a' management exit meeting was held on
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. October 10, 1989, with Mr. L. De1 George and others of your staff to review
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followup inspection findings and potential enforcement items.
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~The objectives of thic SSFI were to assess the operational readiness and
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functionality of HPCS and to evaluate the effectiveness of your efforts in
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performing a similar inspection of the same system. Particular attention was
. paid to the details of system design and modification, maintenance, testing,
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and operations applicable to this system and other systems required to support
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HPCS operations. As a result of concerns which arose during the inspection,
the scope was also expanded to incorporate the Division I and II batteries,
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and the 250 Volt batteries.
The-inspection team determined that HPCS was operable; however, there were
several examples where the actual design margins were less than stated in the
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Updated Final Safety Analysis Report or in conflict with the Technical
Specification requirements. The most significant example of a design deficiency
affecting' functionality concerned the Division I batteries. The station
batteries were designed to operate at a minimum temperature of 65'F; however,
the Technical Specifications allowed the batteries to be considered acceptable
at battery cell temperatures as low as 60*F.
The inspection team determined
that based on the current loads, the Division I batteries would not be capable
of performing their design function at temperatures below the design value of
65'F.
Other significant findings include:
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' Uncertainty that installed equipment would operate at the minimum voltage
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the equipment may experience during'an event. Your staff was still
evaluating this issue at the conclusion of the inspection.
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Lack.of complete follow-through on a modification (M-1-1-84-019, adding a
relay to prevent.the. Division 3 diesel from loading onto a faulted bus)
such that an annuciator. response procedure was not changed and
erroneously directed the operator to ensure that the diesel generator had
loaded onto the bus, which was what the modification prevented from
occurring. This modification also may have createri an unreviewed safety
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Program plans for check valve maintenance and temporary modifications
were considered strengths.
The SSFI conducted by Commonwealth Edison in 1987 on this same system did an.
excellent. job of finding and correcting labeling problems and most drawing
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concerns. The effort was conducted by a multi-disciplinary team composed of
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individuals experienced in electrical and mechanical design. However, this
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SSFI was heavily oriented toward walkdowns of the system and review of completed
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modifications and maintenance performed on the system. Your evaluation
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contained two major lie.itations that contributed to not identifying the items
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found by our inspection. .These limitations were (1) the assumption that the
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existing surveillance procedures covered all applicable Technical Specification
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surveillance-requirements and (2) the assumption that all activities associated
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with-the original design and installation were acceptable.
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Notwithstanding the limitations of your program, as identified during this
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inspection, we believe your initiative to conduct SSFIs is a positive one. We
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understand that an internal Commonwealth Edison Task Force evaluation of the
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effectiveness of:your SSFIs also identified the limitation' associated with
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-design verification and recommended expanding the scope of future SSFIs to
incorporate more design verification activities. We encourage your efforts in
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performing additional SSFIs-and given the benefit of identifying issues'such
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as those produced by your inspection and ours at LaSalle commend your initiative
to evaluate and improve the process. Also, we recognize your Task Force
' recommended steps be taken to improve the accuracy and availability of design
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basis information. These design basis reconstitution efforts are very important
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and we, therefore, expect to monitor these efforts closely.
Some of our concerns appear to be in violation of NRC requirements as specified
.in the enclosed Notice. A written response is required.
In addition, the
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report also addresses other violations, unresolved, or open items as well
as observations and conclusions made by the inspection team. The other
violations are not included in the enclosed Notice because your efforts met the
criteria specified in the NRC's Enforcement Policy (10 CFR Part 2, Appendix C)
for non-cited violations. We request that you also address each of the
unresolved and open items along with your reply to the identified violations in
the enclosed Hotico.
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NOV 2 01999
Commonwealth Edison Company
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In accordance with 10 CFR 2.790 of the Commission's regulations, a' copy of
this letter, the enclosure, and your response to this letter will be p' laced in
the NRC Public Document Room.
The responses directed by this letter and the accompanying Notice of Violation
are not subject to the clearance procedures of the Office of Management and
' Budget as required by the Paperwork Reduction Act of 1980 PL 96-511.
We will gladly discuss any' questions you have concerning this inspection.
Sincerely,
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ORIGINAL SfGNED Bf HUBERT J. MILLER
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Hubert J. Miller, Director
Division of Reactor Safety
Enclosures:
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1.
-2.
Inspection Report
No. 50-373/89018(DRS); and
No. 50-374/89018(DRS)
cc w/ enclosures:-
T. Kovach, Nuclear
Licensing Manager
G.'J. Diederich, Station
~ Manager
DCD/DCB (RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
Richard Hubbard
J. W. McCaffrey, Chief, Public
Utilities Division
David Rosenblatt, Governor's
Office of Consumer Services
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