ML20054D243

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IE Insp Rept 50-373/82-10 on 820213-14,18-19,23-26 & 0302-06 & 10-12.Noncompliance Noted:Failure to Calibr & Control Timing Device Used in Activities Affecting QA & Failure to Follow Procedures
ML20054D243
Person / Time
Site: LaSalle Constellation icon.png
Issue date: 03/31/1982
From: Jackiw I, Lanksbury R, Maura F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20054D237 List:
References
50-373-82-10, NUDOCS 8204220472
Download: ML20054D243 (6)


See also: IR 05000373/1982010

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-373/82-10(DETP)

Docket No. 50-373

License No. CPPR-99

Licensee: Commonwealth Edison Company

Post Office Box 767

Chicago, IL 60690

Facility Name: LaSalle County Station, Unit 1

Inspection At: LaSalle Site, Marsellies, IL

Inspection Conducted: February 13, 14, 18, 19, 23-26, March 2-6 and

10-12, 1982

Inspectors:

ackiw

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R.

anksbury

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F. Maura

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Approved By

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Inspection Summary

Inspection on February 13, 14, 18, 19, 23-26, March 2-6, and 10-12, 1982

(Report No. 50-373/82-10(DETP))

Areas Inspected: Routine, announced inspection to witness preoperational

testing; review preoperational test results, previous items of noncompliance

and open items. The inspection invoved 267 inspector-hours onsite by three

NRC inspectors including 79 inspector-hours during offshifts.

Results: Of the three areas inspected no items of noncompliance were iden-

tified in one area. Within the two remaining areas three apparent items of

noncompliance were identified (failure to calibrate and control timing device

used in activities affecting quality, Paragraph 4.c.; failure to assure that

deficiencies are corrected properly, Paragraph 3.b.; failure to follow

procedures, Paragraph 3.c. and 5).

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8904220472 820331

PDR ADOCK 05000373

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DETAILS

1.

Persons Contacted

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  • B. Stephenson, Project Manager
  • R.

Holyoak, Station Superintendent

  • R.

Bishop, Assistant Station Superintendent

  • J. Renwick, Technical Staff Supervisor
  • R. Kyrovac, Operations QA Supervisor

The inspectors also interviewed other licensee employees including

members of the construction, quality assurance, technical and

operating staff.

  • Denotes those attending the exit interviews of March 12, 1982.

2.

Licensee Action on Previous Inspection Findings

(Closed) Open Item (373/80-36-05):

Preoperational test procedure

PT-AP-103, Emergency Power Redundancy, does not meet all regulatory

and FSAR requirements. The inspector reviewed Revisions 2 through 11

and determined the procedure appears to conform to Chapter 8 and

Table 14.2-6 of the FSAR; and that the acceptance criteria in the SER

was incorporated into the test procedure.

(Closed) Open Item (373/81-07-04):

Scram testing by filling instru-

ment volume, and auto operation of scram timing recorder. The

inspector reviewed the results of LST 81-141, performed on March 5,

1982, and determined that a satisfactory full core scram was performed

by slowly filling the instrument volume. Automatic operation of the

timing recorder was accomplished satisfactorily.

(Closed) Noncompliance (373/82-02-01): Failure to take adequate cor-

rective action as stated in response to an item of noncompliance. The

inspector reviewed the licensee's response (L. O. De1 George letter to

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J. G. Keppler dated February 2,1981) to this item and reviewed the

licensee's procedure, LAP-1500-4, for tracking NRC commitments. The

inspector agrees with the licensee's response that the problem appears

to have occurred due to not using the available tracking system rather

than due to a flaw in the system.

3.

Review of Preoperational Test Procedures and Test Results

The inspector reviewed test Procedures PT-AP-101 and 201, and the

test results against the FSAR, the SER (NUREG-0519) and Regulatory

Guide 1.6.8.

The following problems were noted:

a.

Some of the tests required by FSAR Table 14.2-4, such as voltage

being within design specifications, were apparently performed as

part of PT-AP-103.

This is an Open Item (373/82-10-01) pending

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the review of PT-AP-103 test results by the inspector.

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b.

Several Deviation Reports (DR's) had been generated due to over-

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load settings (magnetic and/or thermal) not being in accordance

with design values. A review of the deficiencies showed all had

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'been closed indicating that the settings were verified correct

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or had been reset to design values. The inspector reviewed some

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of the closed DR's against the findings of Report No. 50-373/82-11,

where overload (OL) settings were found to disagree with the

Sargent and Lundy (S&L) Electric Service Order (ES0) data sheets,

and determined that either the DR's were closed without actually

correcting the deficient condition, or the OL settings had been

tampered with since the DR's were closed.

Specifically, five DR's

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were compared to the findings of Inspection Report No. 50-373/82-11

with the following results:

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(1) MCC 135X-1, compartment B-1: design calls for a thermal OL

setting of 1.68.

During the preoperational test it was found

at 2.1 and DR No. 585 was written to correct the problem. The

closed DR states the setting had been " reset."

The inspector

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found the setting at 2.0.

(2) MCC 135X-2, compartment B-3: design calls for a thermal OL

setting of 12.

During preoperational testing it was found at

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16 and DR No. 401 was written. The closed DR states the

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setting had been " reset."

The inspector found the setting at

14.

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LSU 200-2, Revision 10, Step F.3.K requires the Test Engineer to

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verify that the deficient condition has been resolved by either-

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visual inspection of the work done to correct the deficient

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condition or by satisfactory completion of the required retesting-

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specified on:

(1) temporary turnover agreement, (2) as described

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in LSU 500-3, or (3) the preoperational steps relating to the'

deficient condition.

In this particular case the only applicable

option available was the visual inspection of the work done since

the OL settings were not- actually tested. The fact that the OL

settings are being found to disagree with the corrective action

stated in their specific DR is considered to be a violation of

10 CFR 50, Appendix B, Criterion XVI, and Procedure LSU 200-2 of

the LaSalle Startup Manual and is an example of an item of

noncompliance (373/82-10-02).

The inspector stated that based on his findings there appears to

exist a problem with the accuracy of the corrective act. ions docu-

mented in the DRs', and the present status of the overload settings

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for all MCC's.

As a result he expects the licensee to:

(1) Perform a reinspection of all MCC's covered by PT-AP-101,

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and those MCC's covered by PT-AP-201 which are required for

Unit 1 operation, to determine whether the magnetic and

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thermal overloads have been set in accordance with the design

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specifications,

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(2) Identify all closed DR's on the subject of overloads which

during the reinspection show to have been erroneously closed,

(3) Functionally test for operability the motors supplied by any

breakers requiring lower thermal overload settings than those

found during the reinspection, unless by design the overload

is bypassed when the motor is required to function.

The licensee objected to be required to reinspect MCC's supplying

non-safety related leads. The inspector stated all breakers

supplying systems important to safety as defined by 10 CFR 50,

Appendix A and Regulatory Guide 1.68 must be the subject of this

reinspection. The reinspection is an open item (373/82-10-03)

pending the inspector's review of the results.

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During the review of PT-AP-201 Data Sheets 12.2H, 12.2I, 12.2T,

c.

and 12.2V the inspector noted five instances in which the recorded

overload settings were higher than the required design values,

however, no DR's had been generated to correct the problem. As a

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result of the findings the licensee generated DR's No. 420 through

424 and the settings were checked and reset to agree with design

values. Failure-to write the required DR's is considered to be a

violation of 10 CFR 50, Appendix B, Criterion V, and Startup Manual

Procedures LSU 200-2 and 500-3, and is an example of an item of

noncompliance (373/82-10-04A).

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d.

Final review of resolved and unresolved deficiencies, Open Item

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(373/82-10-05).

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4.

Preoperational Test Results Review

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a.

PT-VY-101, CSCS Equipment Cooling, Unit 1, Preoperational Test.

Unresolved deficiencies, Open Item (373/82-10-06).

b.

PT-MS-101A, MSIV-LCS Preoperational Test. Unresolved deficiencies,

Open Item (373/82-10-07).

c.

PT-MS-101B, MSIV and MS Instruments Preoperational Test and

SD-RT-101, Reactor Water Cleanup System Demonstration.

(1) During performance of the above two preoperational tests

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the closure times of the systems primary containment isola-

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tion valves were measured with " general usage" stopwatches.

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General usage equipment is not a part of the measuring and

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test equipment (M and TE) calibration program and have no

specific controls imposed on them. The licensee contends

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that no specific requirement exists to calibrate stopwatches

and points out that stopwatches, or any other type of timing

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device, are not listed in the QA Manual in the list of types

of equipment requiring periodic calibration. The above shows

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ties affecting quality in the M and TE calibration program.

a failure to include a piece of test equipment used in activi-

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This is considered to be a violation of 10 CFR 50, Appendix B,

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Criterion XII and is an example of an item of noncompliance

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(373/82-10-08).

Based upon an informal survey of other operating Commonwealth

Edison Company nuclear generating sites and upon discussion

with LaSalle operating personnel, the abova noted problem would

appear to be generic company wide.

(2) The inspectors consider that the methodology utilized in

the MSIV closure time tests is deficient not only in that

the timing devices were not calibrated but that the

methodology allowed other factors, such as human error, to

contribute to the data taken.

It is considered that for

tests that measure times utilized in the verification of

safety-related parameters and that are of relatively short

duration, such as MSIV closure times, that a methodology be

used that eliminates any extraneous error, such as using a

calibrated mutichannel recorder. Recognizing that the

question of short time measurement methodology is generic in

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nature, and applies not only to LaSalle but to other nuclear

generating stations, this open item (373/82-10-09) is being

forwarded to NRC headquarters for resolution.

(3) PT-MS-101B, Unresolved deficiencies, Open Item (373/82-10-10).

(4)

SD-RT-101, Unresolved deficiencies, Open Item (373/82-10-11).

d.

PT-VP-103, Primary Containment HVAC Preoperational Test.

Unresolved deficiencies, Open Item (373/82-10-12).

e.

FT-VR-101, Reactor Building HVAC Precperation Test.

Unresolved

deficiencies, Open Item (373/82-10-13).

f.

PT-VW-101, Radwaste Area HVAC Preoperation Test. Unresolved

deficiencies, Open Item (373/82-10-14).

5.

Preoperational Test Witnessing

The inspector witnessed the following portions of PT-AP-103, Emergency

Power Redundancy:

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a.

Unit 1, Division 1, Test 3, Simulation of LOCA with a simultaneous

loss of offsite power.

b.

Unit 1, Division 2, Test 4, Simulation of LOCA with Unit Cross Tie

Capability.

c.

Unit 1, Division 2, Test 1, Loss of Offsite Power.

The tests were performed in accordance with approved test procedures

using calibrated instrumentation. A preliminary review of the test

results showed that the "0" diesel generator did not meet the voltage

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and frequency requirements of Regulatory Guide 1.9 during the simulation

of LOCA with loss of offsite power. Specifically, during the initial

starting of the LPCS pump the voltage dropped to approximately 64% of

rated versus the 75% minimum stated in the guide. Frequency dropped

below the 95% minimum. Open Item 373/81-20-17 generated as a result

of the inspector's review of the diesel generators prototype test

results remains open pending satisfactory resolution of this problem.

A review of the test log indicated that during the performance of

earlier Division 2 tests:

a.

The licensee could not control voltage on the 1A diesel generator

because fuses in the voltage regulator circuits were missing. The

inspector was later informed that the fuses had been removed by a

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test engineer days before during trouble shooting and he had for-

gotten to replace the fuses. The licensee does not control the

rcmoval of fuses the way jumpers, lifted leads and relay blocks are

controlled by LAP 240-3.

Failure to control the removal of fuses is

considered to be a violation of 10 CFR 50, Appendix B, Criterion V

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and the QA Manual Quality Requirement 5, and is an example of an

item of noncompliance (373/82-10-04B).

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b.

The 1A diesel generator would not start due to a lifted lead on

terminal block 89 on 1H13-P618. The investigation revealed that

the lifted lead had been logged in accordance with LAP 240-3,

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however the Jumper and Block Master Log is maintained chronologic-

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ally and is not segregated by plant systems. Therefore, during

heavy use of the Log, such as during the plant's preoperational

phase, it is extremely difficult to locate all possible existing

jumpers, lifted leads, etc.

The licensee planned to maintain a

combined log for Units 1 and 2 which would greatly increase the

volume of entries once Unit 2 entered its preoperational phase.

The licensee was informed that a separate log must be maintained

for each unit, and a better system must be developed to improve

the identification of existing jumpers, lifted leads, etc.

This

item was partially addressed in Inspection Report No. 50-373/82-11

where it is identified as open item 373/82-11-16.

c.

High vibration was experienced during the operation of the

"B" RHR

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pump. The inspector was informed by the Test Engineer that addi-

tional vibration data has been taken and is being analized by the

General Electric Company. This is an Open Item (373/82-10-15)

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pending licensee resolution and review by the inspector.

6.

Exit Interview

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The inspectors met with licensee representatives (denoted in Paragraph 1)

.on March 12, 1982. The inspectors summarized the scope and findings of

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the inspection. A telephone conversation regarding the inspection-

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findings was conducted with Mr. Bishop on March 22, 1982.

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The licensee acknowledged the statements by the inspectors with respect

to the items of noncompliance.

(Paragraphs 3.b.,

3.c.,

4.c., and 5.)

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