ML20024F632
| ML20024F632 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/24/1983 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20024F626 | List: |
| References | |
| 7184N, NUDOCS 8309090539 | |
| Download: ML20024F632 (4) | |
Text
.
[D Commonwealth E:~ son
^
) One First N. tion:1 Pitza, Chicigo, Ilknois s
O' Address Reply to: Post Offica Box 767 Chicago. Illinois 60690 i
N August 24, 1983 Mr. James G. Keppler, Regional Administrator
- Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Units 1 and 2 Response to Inspection Report Nos.
50-373/83-28 and 50-374/83-23 NRC Docket Nos. 50-373 and 50-374 Reference (a):
J. F. Streeter letter to Cordell Reed dated July 28, 1983.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs. S.
G. DuPont, L. A. Reyes, R. D. Lanksbury, and G. C. Wright on June 20 through July 22, 1983, of activities at LaSalle County Station.
Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Communwealth Edison Company response to the Notice of Violation is provided in the enclosure.
To the best of my knowledge and belief the statements contained herein and in the attachment are true and correct.
In some respects these statements are not based upon my personal knowledge but upon information furnished by other Commonwealth Edison employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, Cid slul83 h#* D.
L. Farrar Director of Nuclear Licensing CWS/1m Attachment cc:
NRC Resident Inspector - LSCS AllG 2 91983 7184N 8309090539 830902 PDR ADOCK 050003fg a
J
~
RESPONSE TO INSPECTION REPORT 50-373/83-28 and 50-374/83-23 1.
NONCOMPLIANCE 10 CFR 50, Appendix B, Criterion XI, states, in part, " Test proce-dures shall include provisions for assuring that all prerequisites for the given test have been met...".
Startup Manual Procedure LSU 400-1, Appendix A, Section 5.0, states, in part, " Test conditions which are different than those expected during normal or accident operation should be justified and documented in the system initial conditions and prerequisites section."
Startup Manual Procedure, LSU 500-1, Section F.5, states, in part, "The System Test Engineer shall be responsible for verifying the prerequisites are satisfied prior to commencing a test."
Contrary to the above, a test condition existed that was different than those expected during normal or accident 7peration without being documented in the system initial conditions and prerequisites section of the Low Pressure Coolant Injection test portion of the Residual Heat Removal System Preoperational Test Procedure, PT-RH-201, in that the automatic initiation made of the "B" and "C" loops of RHR were defeated by the Unit Separation Criteria.
Additionally, the System Test Engineer failed to verify that the prerequisites of PT-RH-201, specifically those that were impacted by the Unit Separation Criteria were satisfied prior to commencing the test.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED A deficiency report (PT-RH-201 - 224) was written to document the failure of the system to respond as anticipated.
Inspection of the panels and a review of the Unit 2 Jumper and Lif ted Lead Log revealed several temporary circuit changes in effect.
These changes were returned.
Subsequently, the logic testing was satisfactorily performed.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE This noncompliance has been reviewed with all System Test Engineers.
A listing of all temporary circuit changes for unit separation was obtained and specifically reviewed by System Test Engineers assigned to affected systems to ensure that no additional " surprises" would occur.
In addition, a review was done of all outstanding temporary circuit changes which had been originated by operations personnel to prevent inadvertent actuations of any equipment during testing.
As a result of this review, a consolidated set of jumpers and lifted leads t
has been put into effect.
This consolidation has greatly reduced the number of outstanding circuit changes and simplified the task of determining whether the changes affect planned testing.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
7184N J
\\
l 1 I 2.
NONCOMPLIANCE 10 CFR 50, Appendix B, Criterion V, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, the following instances were noted during the performance of the Containment Integrated Leak Rate Test (CILRT) where an activity affecting quality was not accomplished in accordance with an approved procedure:
a)
Contrary the station test procedure LTS 300-4, the air supply header was vented and the spool-piece connecting the charging line to the containment spray line was removed prior to the completion of temperature stabilization.
b)
Contrary to station test procedure LTS 300-4, no entries were made in the CILRT events log between 2120 hours0.0245 days <br />0.589 hours <br />0.00351 weeks <br />8.0666e-4 months <br /> on June 28, 1983, and 0730 hours0.00845 days <br />0.203 hours <br />0.00121 weeks <br />2.77765e-4 months <br /> on June 29, 1983, even though actions were taken such as those noted in item a above, that should have been logged.
CORRECTIVC ACTION TAKEN AND RESULTS ACHIEVED These incidents were discussed at length with the System Test Engineer, emphasizing the importance of complying with both the intent and the words when using station procedures.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER COMPLIANCE This noncompliance was discussed in meetings with all System Test Engineers, emphasizing _the need to follow approved procedures.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
7184N
. 3.
NONCOMPLIANCE 10 CFR 50, Appendix B, Criterion XIV, states, in part, " Measures shall be also be established for indicating the operating status of structures, systems, and components of the nuclear power plant...,
such as by tagging valves and switches, to prevent inadvertent operation."
Contrary to the above following completion of the licensee's valve lineup for the CILRT, the inspectors found that the Jet Pump Instru-mentation Stop Valves in the TIP room had not been tagged to prevent inadvertent operation.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The valves in question were properly tagged and verified to be in the proper position after the problem was identified.
r CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE t
This event has been discussed with all System Test Engineers.
Emphasis is being placed on ensuring that tags and labels identifying equipment undergoing preoperational testing are properly installed.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED All corrective actions have been completed.
l I
t L
7184N
.