ML20062H706

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Responds to NRC Re Violations Noted in IE Insp Rept 50-373/82-25.Corrective Actions:Control Switch for Drywell Sump Discharge Isolation Valve 1RE 025 Placed in Auto/Close Position Preventing Sump Valves from Actuating
ML20062H706
Person / Time
Site: LaSalle Constellation icon.png
Issue date: 07/28/1982
From: Schroeder C
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20062H702 List:
References
4610N, NUDOCS 8208160140
Download: ML20062H706 (4)


Text

.

x Commonwealth Edison

/ one First E;tional PLua, Crucspo. Ilhnois g

Addr ss Reply to: Post Othee Box 767 w

Chicago, Ilhnois 60690 July 28, 1982 Mr. James 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 Revised Response to NRC l

Inspection Report No. 50-373/82-25 NRC Docke t No. 50-373 Reference (a):

W. S.

Little letter to Cordell Reed dated June 9, 1982.

(b):

C. W. Schroeder letter to J.

G.

Keppler dated July 7, 1982, " Response to NRC Inspection Report No. 50-373/82-25.

Dear Mr. Keppler:

On July 28, 1982, Mr. F. Maura o f your o f fice discussed Reference (b) with C. W. Schroeder.

Mr. Maura pointed out an apparent omission in the table in Item 3 of Attachment 8.

Startup Test #10 should be required to be reviewed and approved by Project Engineering prior to Test Condition 2.

The remainder o f this letter contains the information provided in Reference (b), upcated with this change.

This letter is in response to the inspection conducted by Messrs. R. Lanksbury, F. Maura, and D. Robinson on April 19-23, 27-30, May 6, 7, 11, 13-18, and 21, 1982 o f activities at LaSalle County Station Unit 1.

Referenc+2 (a) indicated that certain activities appeared to be in non.-compliance with NRC requirements.

The Commonwealth Edison Company response to the notice of violation is provided in Attachment "A".

Reference (a) also stated:

"It is our understanding that your Station Nuclear Engineering Department will review and approve all completed Startup Test Procedures at the completion of each Test Condition, as defined in the FSAR, and prior to proceeding with testing at the next Test Condition."

Attachment "B" to this letter provides confirmation, clarification, and amplification of this statement.

8208160140 820810 PDR ADOCK 05000373 G

PDR AUG 2 IS82

~

0 J.

G. Keppler July 27, 1982 To the best of my knowledge and belief the statements con-tained herein and in the attachments are true and correct.

In some respects, these statements are not' based on my personal knowledge but upon information furnished by other Commonwealth Edison personnel.

Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

If you have any further questions on this matter, please contact this office.

Very truly yours, bw 7/1Bf %2.

C. W. Schroeder Nuclear Licensing Administrator 1m cc:

NRC Resident Inspector - LSCS 4610N

ATTACHMENT "A" Response to Inspection Report 50-373/82-25 Item of Apparent Noncompliance Technical Specification, Section 6.2.A.7 requires that written procedures including applicable checkoff lists for surveillance and testing be prepared, approved and adhered to.

Preoperational test procedure PT-PC-101, Revision 24, required the primary containment integrated leak rate test be conducted in accordance with surveil-lance procedure LTS 300-4.

LTS 300-4 requires that drywell equipment sump discharge isolation valves 1RE 024 and 025 be closed during the performance of the CILRT.

t' Contrary to the above, the control switches were left in the auto position causing the valves to open and approximately 83 gallons were pumped out of the primary containment during the performance of the CILRT on May 17, 1982.

Corrective Action and Results Achieved Commonwealth Edison personnel in the control room discovered that the control switches for the drywell equipment sump discharge isolation valve were in the auto position when the sump discharge isolation valves opened and the sump pump actuated to pump water out of the pri-mary containment.

The control switch for the drywell sump discharge isolation valve 1RE 025 was then placed in the auto /close position, as was required by the procedure.

This action prevented the sump valves from opening and the pumps from actuating.

The effect of the loss of 83 gallons from the during the test was evaluated and determined not to adversely affect the test results.

LaSalle Station personnel initiated deviation report DVR-1-1-82-48 on this item and submitted Licensee Event Report LER #82-025/03L-0 to Region III as documentation.

Corrective Action to Avoid Further Noncompliance To prevent the recurrence of a valve lineup violation, LTS 300-4, will be revised to required that any change in the valve lineup, for any reason, will require the signatures of the Test Engineer, Shi f t Engineer, and Reactor Operator.

The valve number and valve position will also be noted along with justification for the valve change, and verification that the valve is returned to its required position.

Date of Full Compliance Full compliance will be achieved prior to the next CILRT on either Uni t 1 o r Uni t 2.

The revision to LTS 300-4 will be tracked by AIR l-82-371.

4610N

ATTACHMENT 8 Clarification of Agreement for Review and Approval.

of Startup Test Results at LaSalle Reference (a):

W. S.

Little letter to Cordell Reed dated June 9, 1982.

Reference (a) stated:

"It is our understanding that your Station Nuclear Engineering Department will review and approve all completed Startup Test Procedures at the completion of each Test Condition, as defined in-the FSAR, and prior to proceeding with testing at the next Test Condition."

Commonwealth Edison agrees with this statement and provides the following information to assure there is no misunderstanding in its interpretation:

1.

Project Engineering will be performfag the review and approval of Startup Test Procedures and test results.

Upon successful completion of the Startup Test Program, Project Engineering reverts back to the Station Nuclear Engineering Department for ongoing operational support of the Station.

2.

The above statement pertains to the review and approval of the startup test procedures and test results for the initial Cycle 1 plant startup program for Units 1 and 2.

3.

Only those Startup Tests that are completed will be required to be reveiwed and approved at the completion of a test condition, and prior to proceeding with testing at the next test condition.

Certain tests are conducted at more than one 1'

test condition.

These tests are not required to be reviewed and approved until all testing at all required test conditions is completed.

Specifically, only the following tests are required to be review and approved by Project Engineering PRIOR TO proceeding to the next Test Condition (TC):

Test #

To Be Approved Prior To 3

TC heatup (Done) 4 TC heatup (Done) 6 TC2 8

TC6 10 TC2 l

14 TC3 21 TC6 28 TC2 31 TC3 70 TCl 4610N

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