ML20059A837

Suppls Response to Violations in Insp Repts 50-373/91-19 & 50-374/91-19.Completion Date for safety-related Contact Testing Assurance Program Revised from 940531 to 950531

ML20059A837
Person / Time
Site:	LaSalle
Issue date:	12/20/1993
From:	Benes G COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 9401030159
Download: ML20059A837 (7)

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Comm:nwntth Edison

- y 1400 Opus Place V ' Downers Grove, Illinois 60515 December 20,- 1993 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk

SUBJECT:

LaSalle County Nuclear Power Station Units 1 and 2 Supplemental Response to EDSFI Violation 373/91019-07 and 374/91019-07 Safety Related Contact Testing Adequacy Program NRC Docket Nos. 50-373 and 50-374

REFERENCES:

1. T.J. Kovach letter to USNRC dated January 16,1992, transmitting response to EDSFI report.

2. T.O. Martin letter from USNRC to L.O. DelGeorge' dated March 12,1993, transmitting Inspection Report Nos. 50-373/93002 and 50-374/93002.

3. J.L. Schrage letter to NRC dated March 15,1993, regarding the Quad Cities SRCTA program.

Dr. Murley:

In our original response to the subject violation (Reference 1), LaSalle County.  ;

Station committed to complete a safety-related contact testing assurance program by May 31,1994, to prevent reoccurrence of this violation. In Reference 2 the NRC closed this issue based on the progress performed to date and this commitment.

LaSalle County Station is revising the original date for completion of this '

commmitment from May 31,1994 to May 31,1995. ' Attachment A provides the justification for this schedule change and the current status of this project.

I To the best of my knowledge and belief, the statements contained above are {

true and correct. In some respect these statements are not based on my personal knowledge, but obtained information furnished by other Commonwealth Edison employees, contractor employees, and consultants. Such informatio'n has been reviewed in accordance with company practice, and I believe it to be reliable.

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,i Please direct any questions you may have concerning this submittal to this  ;

office.

Very truly yours,- ,

% Bed Gary G. Benes -

Nuclear Licensing Administrator-  ;

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Attachments:

a A. Supplemental Information cc: J. B. Martin, Regional Administrator - RIII-D. L. Hills, Senior Resident Inspector - LSCS.

A. T. Gody, Jr., Project Manager, NRR -  :!

Office of Nuclear Facility' Safety - IDNS i

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ATTACHMENT A Supplemental Response To Inspection Report 50-373/91019; 50-374/91019-Violation 373/91019-07; 374/91019-07 Safety Related Contact Testine Adequacy (SRCTA) Project JNTRODUCTION LaSalle County Station is revising the completion date for the Safety Related Contact Testing Adequacy (SRCTA) project from May 31,1994,- to May 31,1995. The scope of.

work fbr this project includes the review of the electrical drawings and station procedures for more than 40 systems, and this extension will provide additional time

. for reviewing these systems, evaluating the results of this project, and implementing any required corrective actions.

BACKGROUND During the Electrical Distribution System Functional Inspection (EDSFI) of October 7 -

through November 8,1991, a Level IV Violation was issued for failing to adequately test the offsite power undervoltage relay logic circuitry. In our response to this item, LaSalle County Station committed to implement the SRCTA project to prevent reoccurrence of this violation. The station also committed to complete this project by May 31,1994.

Prior to EDSFI the station was already in the process ofimplementing the SRCTA project because of similar contact testing concerns which were identified earlier at Quad Cities, Zion, and LaSalle. At the time of the inspection,-the station was reviewing vendor proposals for performing this work.

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1 PURPOSE The purpose of.the SRCTA project is to ensure that all safety-related contacts which_

perform a function identified in the Technical Specifications, Updated Final Safety'  ;

. Analysis Report (UFSAR), or Nuclear Steam Supply System (NSSS) vendor (GE) . '

design specifications are properly tested by station procedures. A secondary purpose of this project is to develop a database which relates Technical Specification and UFSAR functional requirements, testing procedures, and schematic diagrams to the. devices and associated contacts.  :

SCOPE OF WORK The scope of work for the SRCTA project consists of the following four phases:

1. Review of the Technical Specifications, UFSAR, and GE design specifications to identify the system functions.  ;

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2. Review of the schematic diagrams to identify miscellaneous functions and the . l contacts which perform a function identified in item 1 or the schematic diagrams.

3. Review of the station procedures to determine if these contacts are' adequately--

tested.

4. Implement corrective actions as necessary. .

All safety-related systems and non-safety related systems.with safety-related components are included in the scope of work. Any concerns or issues that are:

identified by the SRCTA program will be resolved as described in Reference 3.

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.l PROJECT STATUS -)

The evaluati- of the Technical Specifications, UFSAR, and.GE design specifications ~

has been co.. ed.

The elearicai .,s and procedures for the following four systems have been )

reviewed:

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1. Residual Heat Removal (RHR) System 1

2. High Pressure Core Spray (HPCS) System i

3. Low Pressure Core Spray (LPCS) System

4. Automatic Depressurization System (ADS) ,

The Reactor Core Isolation Cooling (RCIC) system and Primary Containment Isolation j System (PCIS) are currently being reviewed. The next two systems to be reviewed are  :

the Reactor Protection System (RPS) and Diesel Generator (DG) system. I t

SUMMARY

OF FINDINGS l The review of the schematic diagrams for the above four systems identified l approximately 1600 contacts which perform a Technical Specification function,500  !

contacts which perform a function only described in the UFSAR or GE design '  ;

specifications, and 1400 contacts which perform miscellaneous functions per unit.  ;

The review of the applicable surveillance and test procedures did not identify any I untested functions described in the Technical Specifications or UFSAR for these systems. In addition, all contacts in the circuits important to safety are verified by. ,

testing to perform their safety function. The only testing problems found to date concern untested functions identified only in the GE design specifications or on the >

schemntic diagrams and minor contact testing deficiencies. These problems are - ,

described below:  ;

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1. A total of six (6) relay contacts per unit in the ADS and RHR initiation logic  :

circuits were not individually verified to open on reset. The contacts were verified to perform their safety function and actuate the logic channel, and reset of the logic-  !

circuit was verified. l

2. A total of 42 relay contacts per unit in the low-low set logic of ADS were not individually verified to open on reset. The contacts were verified to close a'nd perform their design function, and the reset of the logic circuit was verified. The low-low set function is not classified as safety-related.

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3. The control switch contacts in the auto-start circuit of RHR cubicle cooler fans 1(2)VYO50 and 1(2)VYOGC were not demonstrated to stop these fans if placed in the " pull-to-lock" position. These switch contacts are normally closed, and contact continuity was tested since the fans were demonstrated to automatically start and' stop when the associated RHR pump was started and stopped.

4. The close position indicating lights for the following manual isolation . valves were .

not verified to be energized by the associated valvo limit switches:

a. 1(2)E12-F020 - RHR shutdown cooling suction line

b. 1(2)E12-F090A,B - RHR shutdown cooling return line

c. 1(2)E12-F092A,B,C - RHR injection hne L;

d. 1(2)E21-F051 - LPCS injection line

e. 1(2)E22-F038 - HPCS injection line . l q

These valves are required to be open for system operability, and the valve position 1 indicating lights are verified to function properly in this position. Except for RHR . j valve 1(2)E12-F020, these valves were also found to be cycled during a surveillance R test, but the energization of the close indicating lights was not documented. In addition, these limit switch contacts are classified as non-safety related. o

5. The seven (7) ADS valve open alarms on each unit were not verified to be actuated.

by the associated relay contacts. The valves are cycled during surveillance tests, but the activation of these alarms is not documented. However, proper operation of the valve indicating lights is required to be verified. These alarms are not safety-related.

6. The fourteen (14) contacts in the logic circuit which automatically trip a RHR pump on isolation ofits associated suction lines are not tested for this function in -

either unit. This function is not specified in the Technical Specifications, UFSAR, or GE design specifications, and the contacts in this circuit are verified not to trip the pumps with proper valve lineup.

7. The control switch and limit switch contacts of RHR A and B Heat Exchanger Outlet sample valves 1(2)E12-F411A and B are not. tested. These valves ~do not: ,

l perform a function described in the Technical Specifications and are not normally used for taking a sample from RHR A or B. RHR valves 1(2)E12-F412A 'and B.'

.'which are periodically tested are normally used for taking a sample from this system.

These deficiencies will be resolved, such as enhancing existing procedures, where appropriate, as described in Reference 3, and AIRS will be issued to track the

,. completion of the corrective actions.

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.. JUSTIFICATION FOR SCHEDULE CHANGE Extending the schedule from May 31,'1994, to May 31,1995, will not decrease the  ;

reliability or safety of the facility because the system reviews completed to date indicate that a very high percentage of safety-related contacts are being adequately tested. In addition,;nost of the safety-related systems including all the Emergency Core Cooling Systents (ECCS) will.be reviewed by May 31,1994. .

The scope of' work for the SRCTA project is larger than that indica' ted in our response to the subject violation (Reference' 1). In Reference 1 we indicated that only those i contacts which perform a function identified in the Technical. Specifications would be - r reviewed. As indicated above, the scop.3 of work for the-SRCTA project also includes- r the review of contacts which perform a function identified in the UFSAR or GE. system - l design specifications. In addition, eliminating those systems which do not perfo:m any  !

Technical Specification function from the project would not significantly reduce the- i scope'of work because over 90% of the systems under review perform at least one Technical Specification ftmetion.

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