ML20057B876
| ML20057B876 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/16/1993 |
| From: | Hague R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20057B870 | List: |
| References | |
| 50-373-93-19, 50-374-93-19, NUDOCS 9309240099 | |
| Download: ML20057B876 (10) | |
See also: IR 05000373/1993019
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U.S. fiUCLEAR REGULATORY COMMISS10f4
REGION III
Report Nos.
50-373/93019(DRP); 50-374/93019(DRP)
Docket Nos.
50-373; 50-374
License Nos. NPF-ll; NPF-18
Licensee:
Commonwealth Edison Company
Executive Towers West III
1400 Opus Place Suite 300
Downers Grove, IL 60515
Facility Name:
LaSalle County Station, Units 1 and 2
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Inspection At:
LaSalle Site, 11arseilles, Illinois
inspection Conducted:
July 13 through August 27, 1993
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Inspectors:
D. Hills
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C. Phillips
11. Simons
P. Louden
J. Roman, Illinois Department of Nuclear Safety
Approved By:
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R. L/ ifa e Chief
Date
Reackor>roj,ectsSection1C
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Inspection Summary
Inspection from July 13 through Auqust 27. 1993 (Reports No. 50-373/93019
1DRP): 50-374/93019(DRP)).
Areas Inspected: A routine, unannounced safety inspection was conducted by
the resident inspectors, regional inspectors, and an Illinois Department of
Nuclear Safety inspector.
The inspection included followup on previously
identified items and licensee event reports; review of operational safety,
monthly maintenance, and surveillance activities; a review of safety
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assessment and quality verification activities; an emergency preparedness
review and a report review.
Results:
Of the eight areas inspected, no violations were identified in
six.
In the remaining areas, two violations were identified regarding
failure to perform effective corrective actions (paragraph 5) and failure to
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follow procedure (paragraph 4).
There was one unresolved item regarding the
adequacy of an engineering review (paragraph 7). There was one open item
regarding a licensee proposal to submit a technical specification change to
clarify how the independent safety engineering group function is to be carried
out (paragraph 2).
There was a second open item regarding upgrade of
operational readiness of the Operational Support Center (OSC) and update of
emergency plans and training (paragraph 8).
9309240099 930917
ADOCK 05000373
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Onerations
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Operating crew performance during a feedwater heater transient was excellent.
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An alert operator identified problems with a Unit 2 containment isolation
valve and actions to test- and repair the valve were excellent.
Radiolooical Protection
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Radiological housekeeping was poor. This has been a recurring concern.
Maintenance
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The failure of two quality control inspectors to perform adequate inspections
and the failure to perform effective corrective actions resulted in the
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miswiring of two separate modifications. Attitudes toward performing in depth
root cause analysis appeared to be improving although it was too early to
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evaluate effectiveness. Maintenance training was effective.
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Safety Assessment /0uality Verification
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Recent initiatives indicated some improvement in self assessment capability.
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An inadequate review was performed in 1987 when evaluating the applicability
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of NRC Information Notice 87-10, " Potential For Water Hammer During Restart of
Residual Heat Removal Pumps."
Emergency Prenaredness
The condition of the Operations Support Center reflected poor pre-planning and
coordination between operations and emergency planning personnel on the dual
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use of this facility.
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DETAILS
1.
Persons Contacted
- W. Murphy, Site Vice President
- J. Schmeltz, Station Manager
J. Gieseker, Site Engineering and Construction Manager
C. Sargent, Support Services Director
- M. Reed, Technical Services Superintendent
- J. Lockwood, Regulatory Assurance Supervisor
- M. Santic, Maintenance Superintendent
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- R. Crawford, Work Planning Assistant Superintendent
- Denotes those attending the exit interview conducted on
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August 27, 1993.
The inspectors also talked with and interviewed several other licensee
employees during the course of the inspection.
2.
Licensee Action on Previously Identified Items (92701 and 92702)
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(Closed) Unresolved Item (373/93007-04(DRP)): Determine acceptability
of combining the independent safety engineering group (ISEG) with the
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quality verification organization. Although this arrangement was not
preferred by NUREG-0737, it was not specifically forbidden.
It was
recognized that the potential for ISEG functions to be compromised was
increased. The inspectors will continue to evaluate the effectiveness
of the new quality verification organization during routine inspections
and consider this concern closed.
The licensee agreed to submit a
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revision to technical specifications stating unambiguously, how the ISEG
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function is to be carried out.
Completion of this revision is
considered an open item (373/93019-03(DRP)).
(0 pen) Unresolved Item (373/93013-01(DRP)):
Evaluate acceptability of
Operations Manager not possessing a senior reactor operator (SRO)
license. The licensee proposed to resolve this matter with a technical
specification change submittal to delete the assistant superintendent of
operations title and require the SR0 license be held by other specific
positions.
This item will remain open pending resolution through that
submittal.
(Closed) Open Item (373/93007-03(DRP)):
Review of seismic qualification
test records.
The inspectors reviewed the test records and
documentation of the Unit I scram relay modification and have no further
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concerns. This item is closed.
No violations or deviations were identified in this area.
3.
Licensee Event Reports Followup (92700)
The following licensee event reports were reviewed to ensure that
reportability requirements were met, and that corrective actions, both
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immediate and to prevent recurrence, were accomplished or planned in
accordance with the technical specifications:
(Closed) LER 374/93004-00 Reactor Scram Due to' Low Charging Header
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Pressure
(Closed) LER 373/93012-00 Reactor Core Isolation Cooling System
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Declared Inoperable Due to Associated Bus Voltage Dropping Below
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Technical Specification Limits
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(Closed) LER 373/93013-00 Primary Containment Isolation System Relay
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Failure
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No violations or deviations were identified in this area,
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4.
Operational Safety Verification (71707)
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The inspectors reviewed the facility for conformance with the license-
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and regulatory requirements.
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a.
On a sampling basis the inspectors observed control room
activities for proper control room staffing; coordination of plant
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activities; adherence to procedures or technical specifications;
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operator cognizance of plant parameters and alarms; electrical
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power configuration; and the frequency of plant and control room
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visits by station managers.
Various logs and surveillance records
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were reviewed for accuracy and completeness.
Significant observations were:
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1.)
Operating crew performance during a feedwater heater
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transient was excellent. On July 12, 1993, while the
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inspector was-in the control room the 14A low pressure
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feedwater heater emergency drain level controller failed
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resulting in the loss of the 14A and the 15A low pressure
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heaters. The operating crew response to the transient was
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excellent.
Communications'during the event in the control
room were excellent. The crew was able to return the 14A
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heater to service and stabilize the unit while working on
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returning the 15A to service.
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2.)
Alert operator observations and a conservative operating
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approtch by management resulted in identifying and
correcting problems with a containment isolation valve. On
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August 19, 1903, during valve lineups to cool the Unit 2
suppression pool the control room operator noticed that flow
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and pressure were not responding as expected. An equipment
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operator was sent to the low pressure core spray full flow
test valve but noticed no problem at that time. Management
put the valve out-of-service in the closed position and
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declared the valve inoperable.
Later testing showed that
the motor-operator clutch mechanism had failed.
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b.
On a routine basis the inspectors toured accessible areas of the
facility to assess worker adherence to radiation controls and the
site security plan, housekeeping or cleanliness, and control of
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field activities in progress.
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Significant observations were:
Radiological housekeeping in the turbine building was poor. On
July 24, 1993, the inspector toured the lower two levels of the
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turbine building with the radiological waste foreman. The
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majority of contaminated areas had boots. gloves, and bags lying
on the floor in, around, and across the boundaries. Oil was found
on the floor in two places which presented a trip hazard.
During a tour of the station on August 19, 1993, the general
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radiological housekeeping of the turbine building was poor.
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Inconsistencies were noted in the way hoses, crossing from
contaminated areas to clean areas, were being secured. Two
particular observations were in an area around the 2D heater drain
room, and the IB turbine driven reactor feed pump (TDRFP) room.
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Both rooms contained contaminated areas which had hoses exiting
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the established controlled area without being secured to avoid the
potential spread of contamination. A similar problem with a hose
and an electrical cord in the 2A TDRFP room was observed on August
26, 1993. The failure to secure hoses, electrical cords, etc..,
which breach a contaminated boundary is contrary to procedure LRP-
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1490-1, " Construction of Radiological Control Areas and Step Off
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Pads", step F.2.d, and is a violation of Technical Specification
6.2.B that requires that radiological protection procedures be
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adhered to (50-373/93019-02; 50-374/93019-02(DRP)).
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c.
Walkdowns of select engineered safety features (ESF) were
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performed. The ESFs were reviewed for proper valve and electrical
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alignments.
Components were inspected for leakage, lubrication,
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abnormal corrosion, 'entilation and cooling water supply
availability. Tagouts and jumper records were reviewed for
accuracy where appropriate.
One violation was identified in this area.
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5.
Monthly Maintenance Observation (62703)
Station maintenance activities affecting the safety-related and
important to safety systems und components listed below were observed or
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reviewed to ascertain that they were conducted in accordance with
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approved procedures, regulatory guides and industry codes or standards,
and did not conflict with technical specifications.
The following maintenance activities were observed and reviewed:
L23738
Diesel Generator Cooling Water Pump "lA" Reassembly
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L23339
Disassemble and Inspect Unit 2 Reactor Core Isolation
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Cooling Steam Trap
L22415
Unit "2A" Reactor Recirculation Pump Seal Rebuild
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L23707
Troubleshoot and Repair "2A" Diesel Generator Cooling Water
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Pump
L23740-
Disassemble and Inspect "0" Diesel Generator Cooling Water
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Pump
L24117
Troubleshoot Unit 2 "0" Diesel Generator Cooling Water Pump
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Breaker
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Significant observations included:
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a.
Inattention to detail and ineffective corrective actions lead to
miswiring in two separate modification installations. On July 7,
1993, a relay was miswired while performing a modification on the
28 diesel generator cooling water pump because of a personnel
error.
Prior to installation of the relay, one electrician
checked to determine which were the "a" contacts and which were
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the "b".
After checking, the relay was handed to the electrician
who would perform the wiring.
The checking electrician
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communicated wrong information to the wiring electrician.
The QC
inspector saw that the electrician checked the relay but did not
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verify the information himself.
The mistake was caught during
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post modification testing. The work package showed that the step
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was signed by both the electrician and the quality control (QC)
inspector.
The QC inspector admitted that the way in which he
performed his inspection was incorrect and not within management
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expectations. The corrective action in this case was to give
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further training to the QC inspectors in management expectations
of inspection performance.
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On August 5,1993, during installation of a separate modification
on the Unit I high pressure core spray room cooling fan, a- relay
was miswired because of a personnel error. Again, the problem was
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detected during post maintenance testing. The step in question on
the procedure was signed by the electrician and a QC inspector
(different individuals from the first case) . This was a
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violation of 10 CFR 50 Appendix B'Section XVI, representing a
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failure to take effective corrective actions (373/93039-01(DRP)).
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During the second miswiring, the electricians and the QC inspector
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focused on ensuring that the "a"
and "b" contacts were properly
wired.
The QC inspector failed to apply independent verification
to the entire job.
Primary concerns in this case were that QC
inspectors were not adequately performing independent reviews
necessary to catch wiring errors and management was unable to
permanently correct this problem.
The licensee's corrective actions after the second event were
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extensive.
Nuclear Station Work Procedures (NSWP), which are
corporate documents, were changed to include a second
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verification by another electrician before lifting and after
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landing a lead. Training was conducted on August 20, 1993, for
electricians, on how to properly complete-and sign for steps of
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the NSWPs.
Expectations were communicated that the
"B"
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assisting the job has responsibility for the correct completion of
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each step.
Electrical maintenance formed a personnel error
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committee to review errors and solicit ideas from the department
on how to prevent them. The QC inspector involved in the second
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case retook a qualification exam to inspect terminations and
passed with a 100 percent score. Training was held with the QC
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department to stress line by line verification and use of wiring
diagrams in work packages.
This training communicated the
expectation of independent review of the entire modification not
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simply the wiring of the
"a"
and "b" contacts on relays.
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also stressed that with the change to the NSWP, the QC inspector
is not the second verifier but an independent check of the
completion of the step.
Finally, the station met with the
corporate preparers of the NSWPs to discuss reduction of the
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number of QC hold points in the procedures.
With a QC hold point
for each step in the procedure, the potential existed for the QC
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inspector to become one of the workers, losing an objective point
of view.
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b.
Observations and discussions indicated maintenance training
effectiveness was improving. During the period the inspector
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interviewed mechanical maintenance "A"
and "B" men, the lead
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electrical foreman, and several instrument maintenance technicians
while attending an instrument maintenance training class.
Through
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these discussions and observations it was determined that
classroom topics were pertinent, due to good communications
between workers and supervisors and maintenance and training
departments.
The training was useful and applicable on the job
sites.
Training materials were good. Instructors were
knowledgeable and were able to make good use of the differing
levels of experience in the classrooms.
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c.
LaSalle performed an extensive screening of all plant valves to
determine which ones were susceptible to pressure locking and
In a separate discussion with Dr. Earl Brown of
the NRC, he stated that after meeting with over 30 licensee's,
LaSalle was the only one that had a clear understanding of these
problems and how the screening and prioritization should be
performed. This initiative has management support with corrective
actions to start as early as the Unit I refueling outage in the
spring.
d.
Management attitudes toward root cause determination appeared to
improve.
On August 18, 1993, the Unit 2 oreaker for the "0"
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diesel generator cooling water pump failed to close as required
when starting the Unit 2 low pressure core spray pump.
A team was
put together to investigate the root cause. A specific individual
was assigned as the lead to the investigation.
Previously, this
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level of effort did not occur until a series of problems surfaced.
On August 26, 1993, after replacement of the Unit I reactor core
isolation cooling system water leg pump, an oil leak developed
prior to returning the system to operability. A strong effort was
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made to determine all possible problem sources with a
determination to investigate them prior.to committing to a course
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of action. This kind of effort was not observed in the past.
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These two examples appear to be a positive change.
It was still
too early to determine if the change will be permanent and
effective.
One violation was identified in this area.
6.
Monthly Surveillance Observation (61726)
Surveillance testing required by technical specifications, the safety
analysis report, maintenance activities, or modification activities were
observed or reviewed. Areas of consideration while performing
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observations were procedure adherence, calibration of test equipment,
identification of test deficiencies, and personnel qualification. Areas
of consideration while reviewing surveillance records were completeness,
proper authorization and review signatures, test results properly
dispositioned, and independent verification documented.
The following
activities were observed or reviewed:
LaSalle Operating Surveillance (LOS)-RH-Q1
Low Pressure Core Injection
and Residual Heat Removal Service Water Pump and Valve Inservice Test
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for Operating Conditions 1,2,3,4, and 5.
LaSalle Instrument Surveillance (LIS)-PC-203B Unit 2 Drywell Hi
Pressure Emergency Core Cooling Division 2 Instrument Channels B and D
Quarterly Calibration.
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LaSalle Instrument Procedure (LIP)-RR-605 Unit 2 Calibrated J: ' Pump
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flow Indication Calibration.
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No violations or deviations were identified in this area.
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7.
Safety Assessment and Quality Verification (40500)
a.
The inspectors noted two recent initiatives indicating some
improvement in the licensee's self assessment capability. The
first was an independent review of procedure adequacy and
commitment management. This offsite review was requested by the
site vice-president in response to NRC findings from an emergency
operating procedures inspection.
This initiative was very
insightful, identifying a number of deficiencies that were key to
improving the problem identification and resolution process. The
other was a routine onsite quality verification corrective actions
audit, following the offsite review, that.resulted in a number of
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repeat findings. These multiple repeat findings were treated as
an issue with p_lant management.
Both initiatives represented an
effort by licensee overview organizations to identify underlying
causes.
The inspectors will evaluate plant management response to
these audits and hence overall effectiveness.
Further inspector
observance of licensee overview activities will ascertain whether
the licensee can extend these efforts into areas that were not
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first identified as concerns by others.
b.
The review for station applicability of Information Notice 87-10,
" Potential For Water Hammer During Rastart of Residual Heat
Removal Pumps" was inadequately performed. An evaluation was
performed to determine the possibility of a water hammer if,
during use of a residual heat removal (RHR) pump for suppression.
pool cooling, a loss of offsite power in conjunction with a loss
of coolant accident injection signal were to occur. The
evaluation performed was subjective with unsubstantiated
assumptions. This is an unresolved item pending a reevaluation
(373/93019-04(DRP)).
No violations or deviations were identified in this area.
8.
Emeroency Preparedness (IP 82701)
During the management meeting presentation of the previous Systematic
Assessment of Licensee Performance (SALP) on August.20,_1993,
differences were noted between the licensee and the NRC regarding the
overall assessment of emergency preparedness. An inspection tour.was
conducted through the Operational Support Center (OSC) on August 23,
1993 to resolve these differences. The condition of the- 0SC reflected
poor planning and coordination between operations and emergency planning
personnel in the dual use of this facility. The facility was found in a
marginal state of operational readiness. The licensee was in the
process of converting the dedicated OSC into a dual use facility to be
used as both an OSC and an operator lunchroom. The dedicated telephones
were found tangled under a table. The two telephones required per the.
emergency plan were plugged in and operable.
However, three other
telephones to be used by the OSC maintenance supervisors were not
plugged in and the telephone jacks were inaccessible.
The OSC was relocated in February 1993; however, the emergency plan
implementing procedure, LZP-1430-1, " Role and Staffing of the OSC", had
not been revised to accurately reflect the new location of the OSC. The
LaSalle Annex to the Generating Station Emergency Plan had not been
revised to reflect the new location. No training had been provided to
OSC responders regarding the change in locations, the intended set up'of
the facility, or the change in assembly and accountability card readers.
A potential OSC Director was interviewed regarding the activation of the
OSC. This OSC Director was familiar with the overall purpose and
operation of the OSC.
However, he was not familiar with the specific
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set up of the facility.
It was also unclear to this OSC Director which'
card reader would be used for assembly and accountability.
Upgrade of operational readiness of the OSC facility'and update of
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emergency plans and training are considered an open item (373/93019-
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04(DRSS)).
9.
Report Review (90713)
During the inspection, the inspector reviewed selected licensee reports
and determined that the information was technically adequate, and that.
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it satisfied the reporting requirements of the license, technical
specifications, and 10 CFR as appropriate.
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No violations or deviations were identified in this area.
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10.
Unresolved items
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Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, violations, or
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deviations. An unresolved item disclosed during the inspection is
discussed in Paragraph 7.
11.
Open items
Open items are matters which have been discussed with the licensee,
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which will be reviewed further by the inspector, and which involve some
action on the part of the NRC or licensee or both.
Open items
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disclosed during the inspection is discussed in Paragraphs 2 and 8.
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12.
Exit' Interview
The inspectors met with licensee representatives (denoted in Paragraph
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1) during the inspection period and at the conclusion of the inspection
period on August 27, 1993. The inspectors summarized the scope and-
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results of the inspection and discussed the likely content of this
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inspection report.
The licensee acknowledged the information and did
not indicate that any of the information disclosed during the inspection
could be considered proprietary in nature.
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