ML20054G481

Responds to NRC Re Violations Noted in IE Insp Rept 50-373/82-10.Disputes Violation.Isolation Valves Closed within Required Time Frame.Use of Noncalibr Stopwatches Is Widespread Industry Practice

ML20054G481
Person / Time
Site:	LaSalle
Issue date:	04/28/1982
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20054G468	List: IR 05000373/1982010 ML20054G481
References
4008N, NUDOCS 8206210596
Download: ML20054G481 (5)

Text

.

'N Commonwealth Edison O- ) Oro First Nation 11 Plua, Chictgo. lilinois O "7 Addr:ss R ply tz Post Offics Box 767 v' Chicago Illinois 60690 April 28, 1982 Mr. Jame s G. Keppler, Regional Administrator 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. 50-373/82-10 NRC Docke t No . 50-373 Reference (a): W. S. Little letter to Cordell Reed dated March 31, 1982.

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs. I. Jackiw , R . Lanksbury , and F. Maura on February 13, 14, 18, 19, 23-26, and March 2-6, a nd 10-12, 1982 o f activities at LaSalle County Station Unit 1. Reference (a) indicated that certain activities appeared to be in non-compliance with NRC requirements.

The Commonwealth Edison Company response to the notice o f violation is provided in the enclosure.

It is noted that Reference (a) concluded that no response was required for Item 3b since the inspection showed that action had been taken to correct the identifed non-compliance and to prevent recurrence.

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 cased upon my personal knowledge but upon information furnished by other Commonwealth Edison and con-tractor employees. Such info. lation has been reviewed in accordance with Company practice and I believe it to be reliable.

- APR 3 0 082 8206210596 820616 PDR ADOCK 05000373 G pon

)

J. G. Keppler April 28,'1982 If you have any further_ questions on this matter, please direct them to this office.

Very truly yours, L. O . DelGeo rge Director of Nuclear Licensing im Enclosure cc: NRC Resident Inspector - LSCS SUBSCRIBED and SWQRN po before me .this MR+A day of (L4wG , 1982 44 Il k L Notary PuDlic i 4008N i

l l

4 f  ?

I

I l

l 1. Item o f Apparent Noncompliance 10 CFR 50, Appendix B, Criterion XII, requires that measures be established to assure that tools, gauges, instruments, and other measuring and testing devices used in activities af fecting

quality are properly controlled, calibrated and adjusted at l specified periods to maintain accuracy within necessary limits.

{

i Contrary to the above , the licensee failed to include timing .

i devices used to measure primary containment isolation valve closure times in their measuring and test equipment calibration program.

Corrective Action Taken and Results Achieved i

j Upon investigation, no immediate corrective action was considereo necessary. The valves in question were the Reactor i Water Cleanup and Main Steam isolation valves. Nine out of ten o f these valves were timed with stopwatches that had been found accurate in a check performed December 30, 1981, in response to another inspector's concerns. The remaining valve was timed I using a stopwatch that has not been checked for accuracy.

4 However, review of the closure times obtained reveals that the

! stopwatch used would have had to be inaccurate by greater than 4

25 percent for the valve time to have been out of tolerance. It is concluded that all ten isolation valves close within the 1 required time frame.

Corrective Acton Taken to Avoid Further Noncompliance Selection of time measurement devices is based on the time ,

intervals involved and the required accuracy. In the case o f j the valves in question, the required accuracy is established by

, Technical Specification 4.0.5 which requires inservice testing j of valves in accordance with Section XI o f the 1974 ASME Boiler and Pressure Vessel Code with Summer 1975 Addenda. Sub-article IWV 3410(c)(2) o f the Code states that "The stroke time o f all power-operated valves shall be measured to the nearest second or

10% of the maximum allowable stroke time, whichever is less, whenever such a valve is full-stroke tested." Commonweal th

! Edison believes that this requirement is readily satisfied by an I uncalibrated stopwatch. Any problems with the valves or with

the time measurement devices would be identified by the trending i o f the valve times, also required by the Code. Calibration and

certification of time measurement devices for such applications

! is unnecessary and does not improve safety. Use o f uncalibrated

! stopwatches for such applications is widespread industry j practice.

i Where the application warrants additional accuracy, e.g. RPS l Response Time Testing , Commonwealth Edison utilizes more

sophisticated instrumentation and includes such equipment in our l Measuring and Test Equipment Certification Program.

i l Date o f Full Compliance i

Full compliance has been achieved.

)

l

2. Item o f Apparent Noncompliance 10 CFR 50, Appendix B, Criterion XVI, _ requires that measures be established to assure that conditions adverse to quality, such as deficiencies, deviations and nonconformances be promptly identified and corrected. The LaSalle Station Startup Manual procedure LSU 200-2, Revision 10, Step E.3.k requires the Test Engineer to verify that the deficient condition has been resolved either by visual inspection of the work done to corrent the deficiency or by satisfactory completion of the required retesting.

Contrary to the above, deficiency reports Nos. 401 and 585 generated during the performance o f PT-AP-101, to indicate incorrect overload settings in compartment B-3 o f MCC 135X-2 and compartment B-1 o f MCC 135X-1, respectively, were closed with the notation that the overload settings had been reset to the design value. A recent inspection of the settings showed they were not at the value specified by the designer.

Corrective Action and Results Achieved In response to the inspection of overload settings referenceo above, an inspection o f all Unit 1 MCC overload settings and Unit 2 FCC overload settings required for Unit 1 fuel load, was made by LaSalle Uperational Analysis and Quality Assurance departments. MCC overload settings which were found not set in accordance with the required setting were corrected by either physically adjusting the setting or by revising the required setting. Inspection Report 50-373/82-18 documented these actions and the inspector closed Open Item 373/82-10-03 in that report. The results of the inspection were compared with overload setting deficiencies identified during preoperational testing to determine whether proper corrective action had been taken on these deficiencies. It was determined that the problem of incorrect overload settings was related to the administrative control o f the settings as opposed to that o f inadequate resolution o f oeficiencies.

Corrective Action to Avoid Further Noncompliance To ensure that adequate administrative control is maintained over MCC overload settings, procedures have been implemented at LaSalle specifying the guidelines to be used in setting the overload settings for 480V MCC breakers, and for revising the required settings.

Da te of Full Compliance Full compliance has been achieved.

4008N

3. Item o f Apparent Noncompliance 10 CFR 50, Appendix B, Criterion V, requires that activit19s affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and be accomplished in accordance with 'these instructions, procedures or drawings,

a. Fuses in the voltage regulator circuit for the 1A diesel generator were removed and not replaced prior to the performance of PT-AP-103 test and as a result, the voltage could not be adjusted as required. The fuses were forgot-ten because administrative procedures do not require that the removal and reinstallation of fuses be controlled in the manner that lifted leads, jumpers, and relay blocks are controlled.

b) Deficiency reports were nut generated during the perfor-mance o f PT-AP-201 for five cases in which overload settings were found to be higher than the required setting.

The timely generation o f the Deficiency Reports is a requirement of startup manual procedures LSU 200-2 and LSU 500-3. (NO RESPONSE REQUIRED)

Corrective Action Taken and Results Achieved a) The fuses that were missing from the voltage regulator control circuit did not af fect the capability of Diesel Generator lA (DG-1A) to perform its intended function.

DG-1 A automatically started and carried the required ECCS loads while maintaining voltage and frequency within the required limits. The removed fuses were discovered when manual control was taken in preparation for paralleling to off-site power. The DG-1A was shutdown, the fuses were replaced and the DG-1A was tested satisfactorily.

Corrective Action to Avoid Further Noncompliance a) The Administrative Procedure for control o f Electric Jumpers, Relay Blocks, and Lifted Electrical Leads, has been revised to include the control o f fuse removal for the purpose o f disabling a circuit, except when part of an Out-o f-Se rvice . Fuses that are removed as part o f an Out-o f-Service are administratively controlled under the Out-of-Service Procedure.

Inspection Report 50-373/82-18 documented that this procedure has been revised and the inspector closed Open Item 373/82-10-04B in that report.

Date o f Full Compliance a) Full compliance has been achieved.

4008N