ML20057B876

Insp Repts 50-373/93-19 & 50-374/93-19 on 930713-0827. Violations Noted.Major Areas Inspected:Followup on Previously Identified Items & Ler,Review of Operational Safety,Monthly Maint & Emergency Preparedness

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: ML20057B869 ML20057B874 ML20057B876
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 i

C. Phillips

11. Simons

P. Louden

J. Roman, Illinois Department of Nuclear Safety

Approved By: /// [//f/' f7

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R. L/ ifa e Chief Date

Reackor>roj,ectsSection1C

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Inspection Summary

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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 J

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 >

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

PDR ADOCK 05000373

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Onerations ,

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Operating crew performance during a feedwater heater transient was excellent.

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 i

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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 i

miswiring of two separate modifications. Attitudes toward performing in depth  ;

root cause analysis appeared to be improving although it was too early to  !

evaluate effectiveness. Maintenance training was effective.  !

Safety Assessment /0uality Verification i

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Recent initiatives indicated some improvement in self assessment capability. ,

An inadequate review was performed in 1987 when evaluating the applicability '

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 ,

use of this facility. l

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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 '

• R. Crawford, Work Planning Assistant Superintendent

• Denotes those attending the exit interview conducted on '

August 27, 1993.

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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 ,

quality verification organization. Although this arrangement was not l

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 .;

revision to technical specifications stating unambiguously, how the ISEG ]

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 i

concerns. This item is closed. 1

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 {

Pressure

(Closed) LER 373/93012-00 Reactor Core Isolation Cooling System

Declared Inoperable Due to Associated Bus Voltage Dropping Below .

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Technical Specification Limits

(Closed) LER 373/93013-00 Primary Containment Isolation System Relay  !

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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- i

and regulatory requirements. j

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a. On a sampling basis the inspectors observed control room

activities for proper control room staffing; coordination of plant ,

activities; adherence to procedures or technical specifications; l

operator cognizance of plant parameters and alarms; electrical 5

power configuration; and the frequency of plant and control room  !

visits by station managers. Various logs and surveillance records l'

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

inspector was-in the control room the 14A low pressure i

feedwater heater emergency drain level controller failed l

resulting in the loss of the 14A and the 15A low pressure j

heaters. The operating crew response to the transient was '

excellent. Communications'during the event in the control  ;

room were excellent. The crew was able to return the 14A t

heater to service and stabilize the unit while working on ,

returning the 15A to service. l

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 [

August 19, 1903, during valve lineups to cool the Unit 2

suppression pool the control room operator noticed that flow l

and pressure were not responding as expected. An equipment ,

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 l

declared the valve inoperable. Later testing showed that  :

the motor-operator clutch mechanism had failed. l

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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 -

field activities in progress. ,

Significant observations were:

Radiological housekeeping in the turbine building was poor. On  !

July 24, 1993, the inspector toured the lower two levels of the ,

turbine building with the radiological waste foreman. The  !

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 +

radiological housekeeping of the turbine building was poor. l

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. .

Both rooms contained contaminated areas which had hoses exiting i

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- 1

1490-1, " Construction of Radiological Control Areas and Step Off ,

Pads", step F.2.d, and is a violation of Technical Specification  :

6.2.B that requires that radiological protection procedures be  !

adhered to (50-373/93019-02; 50-374/93019-02(DRP)). l

c. Walkdowns of select engineered safety features (ESF) were e

performed. The ESFs were reviewed for proper valve and electrical ,

alignments. Components were inspected for leakage, lubrication, '

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.

5. Monthly Maintenance Observation (62703)

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Station maintenance activities affecting the safety-related and

important to safety systems und components listed below were observed or

! 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 l

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L23339 Disassemble and Inspect Unit 2 Reactor Core Isolation '

Cooling Steam Trap

L22415 Unit "2A" Reactor Recirculation Pump Seal Rebuild ,

L23707 Troubleshoot and Repair "2A" Diesel Generator Cooling Water .

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Pump '

L23740- Disassemble and Inspect "0" Diesel Generator Cooling Water

Pump

Troubleshoot Unit 2 "0" Diesel Generator Cooling Water Pump

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L24117

Breaker j

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

After checking, the relay was handed to the electrician

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the "b".

who would perform the wiring. The checking electrician ,

communicated wrong information to the wiring electrician. The QC

inspector saw that the electrician checked the relay but did not '

verify the information himself. The mistake was caught during ,

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 i

expectations. The corrective action in this case was to give <

further training to the QC inspectors in management expectations  ;

of inspection performance. ,

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 "

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 i

violation of 10 CFR 50 Appendix B'Section XVI, representing a i

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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  !

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  !

extensive. Nuclear Station Work Procedures (NSWP), which are  ;

corporate documents, were changed to include a second l

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 '

the NSWPs. Expectations were communicated that the "B" man

assisting the job has responsibility for the correct completion of i

each step. Electrical maintenance formed a personnel error i

committee to review errors and solicit ideas from the department l

on how to prevent them. The QC inspector involved in the second .'

case retook a qualification exam to inspect terminations and

passed with a 100 percent score. Training was held with the QC j

department to stress line by line verification and use of wiring I

diagrams in work packages. This training communicated the  ;

expectation of independent review of the entire modification not i

simply the wiring of the "a" and "b" contacts on relays. It was i

also stressed that with the change to the NSWP, the QC inspector i

is not the second verifier but an independent check of the

completion of the step. Finally, the station met with the i

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corporate preparers of the NSWPs to discuss reduction of the

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  !

inspector to become one of the workers, losing an objective point

of view. ,

b. Observations and discussions indicated maintenance training

effectiveness was improving. During the period the inspector ,

interviewed mechanical maintenance "A" and "B" men, the lead j

electrical foreman, and several instrument maintenance technicians

while attending an instrument maintenance training class. Through '

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 I

determine which ones were susceptible to pressure locking and

thermal binding. 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" l

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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  !

made to determine all possible problem sources with a

determination to investigate them prior.to committing to a course ,

of action. This kind of effort was not observed in the past. .j

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

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 '

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. ,

LaSalle Instrument Procedure (LIP)-RR-605 Unit 2 Calibrated J: ' Pump '

flow Indication Calibration.

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 .:

emergency plans and training are considered an open item (373/93019- l

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. ,

No violations or deviations were identified in this area.

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10. Unresolved items -

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, I

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 ,

disclosed during the inspection is discussed in Paragraphs 2 and 8. )

12. Exit' Interview

The inspectors met with licensee representatives (denoted in Paragraph ,

1) during the inspection period and at the conclusion of the inspection  :

period on August 27, 1993. The inspectors summarized the scope and- ,

results of the inspection and discussed the likely content of this ,

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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