ML20031F155
| ML20031F155 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/21/1981 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20031F151 | List: |
| References | |
| NUDOCS 8110190271 | |
| Download: ML20031F155 (8) | |
Text
-
Commonwealth Edison f '
)7 one First Nati:nal Plan, Chicago, Ilknois (C
Address Reply to: Post Office Box 767
,/ Chicago. Illinois 60G90 September 21, 1981 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 NRC Inspection Report No. 50-373/81-20 NRC Docket No. 50-373 c Reference (a):
C. E. Norelius letter to Cordell Reed dated August 21, 1981.
Dear Mr. Keppler:
The following is in response to the inspection by Messrs.
F.
- Maura, M.
Ri.ig and J. Hopkins on May 19-22, 29, June 2-5, 11, 12, 16, 17, 23, 24 and 30, and July 1 and 2, 1981, of activities on LaSalle County Station.
Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
To the best of my knowledge and belief, the statements contained herein and in the enclosure 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 to to be reliable.
If you have any questions in this regard, please direct them to this office.
Very truly yours, L. O. DelGeorge Director of Nuclear Licensing Enclosure SUBSCRIBED.AND SWORN to befo7e me this of/4 day o f VAzff&nt/ub, 1981.
W wd -
/M Notary Public 2555N Oh{0 gp22
ENCLOSURE Response to Notice of Violation The response to the items of apparent noncompliance in Appendix A of the Reference (a) is provided in the following paragraphs.
ITEM 1 10 CFR 50, Appendix B, Criterion III, requires that measures be established to assure that applicable regulatory requirements and the design basis, as defined in Paragraph 50.2 and as specified in the licensee application, for those structures, systems and components to which Appendix B is applicable, are correctly translated into specifications, drawings, procedures and instructions.
The Q.A. Manual, Quality Requirement 3.0, Section 3.1, states that "The extent of the design review and evaluation of the original design and modifications will be determined by the complexity of the system and safety-related function to be performed by that system.
Design evaluation of modifications will be commensurate with those applied to the original design.
Review and evaluation by the Architect Engineer, and Nuclear Steam Supply System vendor, and/or the Project Engineering or the Station Nuclear Engineering Department, as well as by other CECO organizations, and specially qualified people, such as Level III's for NDE and for concrete inspection and tests, will assure that designs, specifications and procedures will conform to the ASME and other applicable codes, standards, regulatory requirements, SAR commitments and appropriate quality standards, as applicable."
Contrary to the above:
a.
The de.gn of the diesel generators does not guarantee ~that the capability to supply reliable emergency power, within the required time, is not impaired during periodic testing of the diesel generators.
As a result, the preoperational-tests of diesel generators lA and 0 did not include a demonstration of this capability as required by Table 14.2-38 o f the FSAR.
b.
The fuel day tanks for each fire diesel pump were designed with a capacity for only 550 gallon instead of the 750 gallon capacity stated in Section 9.5.4.3 of the FSAR.
c.
The design of the load sequencing for several safety-related loads is not in accordance with FSAR Table 8.3-1,
" Loading of 4160 volt ESF Busses."
. A.
Corrective Action and Results Achieved A change will be made to the diesel generator 0,-1A and 2A logic circuitries to trip the diesel generator bus feeder breakers one time upon receipt of a LOCA initiation signal.
This design change will ensure that the diesel generators are not connected to their respective bus until load shedding has occurred, even if the LOCA occurs which a diesel generator surveil-lance test is in progress.
A Special Test will be conducted to demonstrate this capability.
Deficiency Reports PT-DG-101A-613 and PT-DG-201A-227 were written to ensure this is accomplished prior to fuel load.
Section 9.5.4.3 of the FSAR will be revised to reflect the correct capacity of the diesel fire pump day tanks.
Deficiency Report DT-D0-101-629 was written to ensure this is accomplished prior to fuel load.
An FSAR revision will be submitted to correct the errors in FSAR Table 8.3-1.
Deficiency Report PT-DG-101A-614 was written to ensure this is accom-plished prior to fuel load.
The preoperational test was performed using the correct loads.
B.
Corrective Action to Avoid Further Noncomoliance The LaSalle Project Engineering Department reviewed ten (10) completed presperational tests to determine whether the applicable plant systems and components were built in accordance with the description given in the FSAR.
This review also included a repeat review of the applicable test results to ensure they met-the design requirements as ststed in the FSAR.
The results of this review were discussed with members of the NRC Region III staff on August 14, 1981, and again on August 20, 1981.
The review concluded that the ten (10) systems reviewed were built and testec in accordance with the FSAR, with the exception of minor editorial conflicts with no safety significance.
In addition, a checklist was developed by the LaSalle Project Engineering Department to ensure that all applicaole sections of the FSAR are reviewed when evaluating test results for conformance with the design requirements stated in the FSAR.
The example cited in Item a of this noncompliance was thought to be adequately addressed by our commitment to install a second level of undervoltage protection in accordance with our discussions with NRR.
This
. conclusion is also supported by the fact that an eighteen month surveillance test of this feature was deleted from the Technical Specifications.
In addition, Mr.
R. Walker, LaSalle Senior Resident Inspector, was tracking resoletion of this issue with open item numbers 373/81-06-13 and the station was tracking resolution of this issue with Action Item Records 01-80-485 and 01-81-277.
We respectfully request NRC Region III to provide clarification as to why items previously identified as open items should be examples of noncompliance.
C.
Date of Full Compliance Full compliance has been achieved.
ITEM 2 10 CFR 50, Appendix B, Criterion V, requires that procedures include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
10 CFR 50, Appendix B, Criterion XI, requires that test results be evaluated to assure that test requirements have been satisfied.
The Q.A. Manual, Quality Requirement 10.0, Section 11.3, requires that test results be evaluated following each test to assure conformance with design and performance requirements.
Contrary to the above:
a.
The licensee wrote an acceptance criteria, approved it, performed the test, and reviewed and approved the test results for PT-DO-101 and 201, regarding the low level alarm for the diesel generators fuel storage tanks, all of which allow the amount of stored fuel to fall below the minimum requirements-specified in the FSAR.
b.
The licensee wrote an acceptance criteria, approved it, performed the test, and reviewed and approved the results of.PT-DO-101 and 201, regarding the low level alarms and high level pump cutoff for the diesel fire pump day tanks, all of which allow the amount of. stored fuel oil to be less than that required to fight a fire and ignore the fuel consumption in the determination of the minimum 7-day fuel storage requirements _for the HPCS system, as stated in the FSAR.
. A.
Corrective Action and Results Achieved The diesel generator fuel storage tank's low level alarms will be recalibrated to revised setpoints to ensure that the amount of stored fuel does not fel) below the minimum requirements specified in the FSAR.
Deficiency Report PT-DO-101-628 was written to ensure this action is accomplished prior to fuel load.
The low level alarms and high level pump cutoff for the diesel fire pump day tanks will be 1ccalibrated to revised setpoints to ensure that the amount of stored fuel oil is adequate to fight a fire and ignore the fuel consumption in the determination of the minimum 7-day fuel storage requirements for the HPCS system, as stated in the FSAR.
An FSAR revision will be submitted to insert the correct requirements for the amount of stored fuel oil to satisfy the above criteria.
Deficiency Report PT-DO-101-627 was written to ensure the above actions are accomplished prior to fuel load.
The example cited in Item a of this noncompliance was discovered by Commonwealth Edison personnel and evaluation of appropriate action was in progress prior to this inspection.
B.
Corrective Action to Avoid Further Noncompliance Refer to Item 1.B of this letter C.
Date of Full Compliance Full compliance has been achieved.
ITEM 3 10 CFR 50, Appendix B, Criterion XI, requires that a test program be established to assure that all testing required to demonstrate that systems and components will perform satisfac-torily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
The Q.A. Manual, Quality Requirement 10.0, Section 11.2, requires that written test procedures be developed to demonstrate design and performance characteristics as specified in design and operating requirements.
. Contrary to the above, PT-DG-101A did not include testing of the diesel generators lA and 0 to ensure that each starting air subsystem (two air start motors) has enough air storage capacity for a minimum of five normal cranking cycles in rapid sucession withoug the use of the air compressors, assuming the redundant subsystems failed to operate, as stated in FSAR Section 9.5.6.1.1.
A.
Corrective Action and Results Achieved A revision to the F SAR will be submitted to clarify the criteria applicable to the diesel generator air storage capacity.
The content of this submittal was discussed with the NRR reviewer and he has given his tentative approval.
A test will be performed to ensure that the LaSalle Diesel Generators meet this criteria.
Deficiency Reports PT-DG-101A-612 and PT-DG-201A-226 were written to track completion of these items.
These deficiencies will be resolved prior to fuel load.
B.
Corrective Action to Avoid Further Noncompliance Refer to Item 1.B of this letter.
C.
Date of Full Compliance Full compliance has been achieved.
ITEM 4 10 CFR 50, Appendix B, Criterion XII, requires that measures be established to assure that instruments used in activities affecting quality be properly controlled, calibrated and adjusted at specified periods to maintain accuracy within the necessary limits.
Commonwealth Edison Company Q.A. Manual, Quality Requirement l
12.0, Paragraph 12.1 requires that measuring and test equipment which is used to perform the preoperational testing and to ascertain the proper indications in the operation of generating station equipment will be periodically calibrated or adjusted to assure that accuracy is maintained within necessary limits in order to verify design requirements.
Paragraph 12.3 requires that history records for measuring and test equipment be used to indicate calibration status, condition, correction to be applied and repair events.
LSU 300-4, Revision 3, Step F.2.b(3), requires the Test Engineer to " ensure that required test equipment is calibrated and will be available and that any required calibration data is available."
+
. Contrary to the above, wattmeter No. 2JI-DG069 used at the local control panel for diesel generator 2A was not properly calibrated on March 12-13, 1981, nor was its calibration assured by the Test Engineer; and records of its calibration, including required correction to be applied, were not maintained.
As a result, the diesel generator was inadvertently overloaded up to 126% of rated power during subsequent testing.
A.
Corrective Action and Results Achieved The wattmeter in question has been recalibrated and documentation of calibratica verified to be available.
A sign has been posted near the wattmeter to provide a correction factor which must be applied to any readings taken from the wattmeter.
B.
Corrective Action to Avoid Further Noncompliance The individual involved has been informed of his error and instructed that he must document calibrations including any required corrections to be applied.
This is believed to be an isolated occurrence and no forther corrective action is necessary.
C.
Date of Full Compliance Full compliance has been achieved.
ITEM 5 10 CFR 50, Appendix 8, Criterion XV, requires that measures be established to control materials, parts, or components which do not ccnform to requirements in order to prevent their inadver-tent use or installation.
The Q.A. Manual, Quality Requirement No. 15.0, Section 15.3 states, in part, that " items which are found to be nonconforming to design and specification require-ments ox workmanship standards will be positively identified and uniquely segregated or handled as nonconforming to prevent their inadvertent use."
LSU 100-2, Revision 10, Step F.1.e, states that, "After the release boundaries are agreed upon, Station Construction and Site Q.A. shall make a detailed verification of all items in the System and Equipment List for completeness, conformance to specification, and receipt of required documentation.
Defici-ency Reports shall be prepared for all deficient conditions in accordance with LSU 200-1, " Pre-Turnover De ficiencies."
. Contrary to the above, during 1980 the licensee failed to identify in a nonconformance or deficiency report either at the time of installation or at the time of system turnover, the installation of a wattmeter with the incorrect calibration units on the local. panel of diesel generator 2A.
A.
Corrective Action and Results Achieved Deficiency Report PT-DG-201A-214 was written to document installation of the incorrect wattmeter.
The correct wattmeter will be installed prior to fuel load.
i B.
Corrective Action to Avoid-Further Noncompliance A memo has been issued by the Project Manager to applicable site personnel to reinforce their responsibility to generate deficiency reports to document all known deficient conditions.
C.
Date of Full Compliance Full compliance has been achieved.
2547N 4
m..
.