ML20028G697

Responds to NRC 830106 Ltr Re Violations Noted in IE Insp Repts 50-373/82-50 & 50-374/82-17.Corrective Actions: Deficiency Rept Initiated on 821004 to Record Missing Flow Orifice & Ensure That Orifice Will Be Installed

ML20028G697
Person / Time
Site:	LaSalle
Issue date:	02/03/1983
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20028G696	List: ML20028G697
References
5928N, NUDOCS 8302170315
Download: ML20028G697 (3)

Text

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• S N Commonwealth Edison

) One First National Plaza, Chicago, Ilknois O 7 Address Reply to: Post Oce Box 767

/ Chicago, Illinois 60690 February 3, 1983 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 i

Subject:

LaSalle County Station Units 1 and 2 Response to Inspection Report Nos.

50-373/82-50 and 50-374/82-17 NRC-Docket Nos. 373- and- 50-374 -

Reference (a): C. E. Norelius letter to Cordell Reed dated January 6, 1983.

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs. R. D. Lanksbury, P. R. Wohld, and D. L. Robinson on October 4-28, 1982, of activities at LaSalle County Station. Reference (a) indicated that certain activities appeared to be in non-compliance with NRC requirements. The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.

To the best of my knowledge and belief the statements con-tained 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 uly yours, 8302170315 830209 a PDR ADOCK 05000373 0 --1->

PDR D. L. Farrar Director of Nuclear Licensing b

8CWS/lm Attachment cc: NRC Resident Inspector - LSCS FEB 4 083 5928N

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ATTACHMENT-A Response to Inspection-Report-50-373/82-50 and-50-374/82-17 Item of-Noncompliance

1. Technical Specification 6.2, Plant Operating Procedures and

, Programs, states, " Detailed written procedures including l applicable checkoff lists covering items listed below shall be l prepared, approved and adhered to:" specifically including, i " Actions to be taken to correct specific and foreseen potential l malfunctions of systems or components malfunctions of systems or components including responses to alarms...."

! Contrary to the above, procedures LOA-1(2)PM06J A209.R3, and LOA 1(2)PM06J B102.R1, written to provide the appropriate response to " door open" alarms for the Reactor Building watertight doors at elevation 673'4", failed to adequately specify the actions to be taken for a door alarm. The actions specified did not indicate or reflect the importance of the doors in assuring the operability of safe shutdown equipment at this elevation'in the event of plant flooding due to internal water sources. This contributed to the lack of appropriate corrective action to alarm conditions during the period evaluated (September 8, 1982 to October 5, 1982). During this period, the alarm printout records indicated that one or more watertight doors in Unit 1 were not closed for over fifty percent of this time..

No response required i

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Item - o f- Noncompliance

2. 10 CFR 50, Appendix B, Criterion XI states, " Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, .... "

l LaSalle County Station Startup Manual, LSU 100-2, Revision 12, dated February 23, 1982, " Construction - Operating Turnovers and l Releases," requires that, "After the release boundaries are l agreeed upun, Project Construction and Site Q.A. shall make a l detailed verification of all items in the System and Equipment

List for completeness, conformance to specification, and receipt of required documentation. Deficiency Reports shall be prepared for all deficient conditions in accordance with LSU 200-1, Pre-Turnover Deficiencies."

• Contrary to the above, the Unit 2 High Pressure Core-Spray (HPCS) system was transferred for testing without the HPCS flow measuring orifice installed and without this being identified by Project Construction or Site Q.A. as a deficient condition. The deficiency was only recognized when the associated flow instru-ment channel failed to respond when called on to take HPCS flow test data during a preoperational test.

Corrective Action-Taken-and-Results Achieved Deficiency report PT-HP-201-47 was initiated October 4, 1982 to record the missing flow orifice and ensure that it is eventually installed upon delivery. The circumstances which led to the Field Engineer signing the orifice installation complete were immediately reviewed with the individual. The individual fully

( understood how his actions led to signing off a non-installed.

l component.

Corrective Action Taken to Prevent Recurrence Letter DSL #164 -

Subject:

Adherence to Procedures was sent to all Project Construction Department personnel as a measure to learn from the instances where procedures had not been strictly followed and to preclude future instances of procedure non-adherence. Additionally, the above subject letter was reviewed during a Project Construction Department staff meeting on January 6, 1983.

Date of Full Compliance Full compliance has been achieved as of January 6, 1983.

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