ML20113D279
| ML20113D279 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/27/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 9929N, NUDOCS 8504150184 | |
| Download: ML20113D279 (5) | |
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Commonwealth Edison One First National Plaz 1 Chicago. tilinois Address Reply to: Post Othee Box 767 Chicago. Illinois 60690 March 27,1985 Mr. James G. Keppler Regional Administrator U.S. tbclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Units 1 and 2 Response to Inspection Report Nos.
50-373/84-33 and 50-374/84-40 FEC Docket Nos. 50-373 and 50-374 Reference (a): Letter dated February 26,1985 from W. D. Shafer to Cordell Reed.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs.
M. Jordan and J. Bjorgen on December 18, 1984 through February 13, 1985, of activities at LaSalle County Station. Reference (a) indicated that certain activities appeared to be in noncompliance with tEC requirements.
The Commonwealth Edison Ccmpany response to the Notice of Violation is provided in the enclosure.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, h%
V"" D. L. Farrar Director of tbclear Licensing im Attachment cc: NRC Resident Inspector - LSCS MAR 291986 0504150104 850327 9929N PDR ADOCK 05000373 0
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ATTACHMENT COMONWEALTH EDISON CO WANY LASALLE COUNTY STATION UNITS 1 and 2 RESPONSE TO NOTICE OF VIOLATION ITEM OF NONCOMPLIANCE:
1.
Technical Specifications, Paragraph 6.2, invokes Regulatory Guide 1.33, Revision 2, including ANSI N18.7 (1976) which requires the licensee to have procedures for control of documents and changes thereto to preclude the possibility or use of outdated or inappropriate documents.
Contrary to the above, the inspector noted two examples of system modifications being installed without timely issue of updated operating procedures or drawings:
a.
The Reactor Core Isolation Cooling System was modified in November 1984 to autostart on low water level after shutdown.
The licensee failed to issue revised system operating procedures until January 1985.
b.
The Reactor Feedwater System was modified during the fall 1984 outage to separate the power supplies and add a three second time delay for the low suction pressure trip of the feedwater pumps. The licensee failed to issue revised wiring drawings for the trip circuit which resulted in the incorrect installation of a jumper on February 8, 1985, which resulted in a reactor trip on loss of feedwater.
CORRECTIVE ACTION TAKEN Ato RESULTS ACHIEVED As a result of the reactor trip and subsequent investigation, all modifications which were in a similiar state of processing, that is the modification installed but the final review not complete, were reviewed. As a result of this review fifty-six modifications were identified as potentially requiring drawing changes. All outstanding drawings changes which affected wiring and schmatic diagrams were processed by February 18, 1985.
A review of all outstanding procedure changes was conducted by the Procedure Manager to identify procedure revisions resulting from modifications. There were ten procedure changes identified as a result of this review but the modifications for all these changes were still in progress.
F.
... CORRECTIVE ACTION TAKEN TO AVOID FlRTER NONCOWLIANCE At the time of the reactor trip the station modification procedure LAP-1300-2 required the updated drawings to be submitted for revision after the modification received final closecut review. On February 8, 1985, LAP 1300-2 was revised to require the submittal of as built prints upon declaring the modification operational. The modification procedure is currently again under revision to specify that procedure revisions which result from the installation of a modification, and are not specified by the on site review to be required before
-declaring the modification operable, will be revised within thirty days of completing the modification.
DATE OF FULL COWLIATE Review of all outstanding modifications has been completed, and all drawing change requests which were requi.ted have been processed. The outstanding procedure revisions have been reviewed and no procedure revision resulting from a modification which has been installed was identified.
The procedure change for the processing of drawing changes was complete February 8, 1985. The change to the procedure specifing the thirty day processing time for procedure revisions will be complete by April 12, 1985.
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ITEM OF NONCO WLIANCE:
- 2. -Facility Operating Licenses NPF-ll and NPF-18 require the licensee to maintain a fire protection program set forth in Appendix R to 10 CFR 50 as supplemented and amended by changes to the license and the Safety Evaluation Report. Licensee procedure LAP 900-22, which implements portions of the requirements of Appendix R to 10 CFR 50 and-Regulatcry Guide 1.120, requires that heat generating or heat source equipment must not be left unattended while it is warm enough to cause ignition of any surrounding combustible materials.
Contrary to the above, on January 24, 1985, the inspector found unattended pcrtable electric space heaters in use in the "O" and "1B" diesel generator rooms.
CORRECTIVE ACTION TAKEN Ato RESULTS ACHIEVED The portable eletric heaters were immediately removed from the diesel generator roams.
CORRECTIVE ACTION TAKEN TO AVOID FURTFER NONCOWLIANCE The placement of the portable electric heaters in the diesel generator rooms was the: result of an attempt to avoid a violation of Technical Specificatica section 3.7.7 using methods that were based on prior operating experience during severe cold weather conditions.
Although LAP-900-22, Use of Heat Generating Equipment and Heat Sources, required that heat source equipment be attended, the procedure did not specifically address portable electric heaters and the requirements were not clear to the personnel involved.
LAP-900-22 has been revised to clearly' identify the requirements for all types of heat generating equipment including portable heaters.
The revision also requires that several key persons are notified prior to the use of heat generating equipment.
DATE OF FULL CO W LIANCE Full compliance has been achieved.
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- ITEM OF NONCO WLIANCE 3.
. Technical specification 4.4.3.2.2 specifies the alarm ~setpoint with-functional and calibration test frequency-requirements for Reactor
- Coolant System leakage detection instrumentation. A channel-functional test is required every 31 days and a channel calibration' is required at least once per 18 months for the Residual Heat Removal-(RW); Shutdown Cooling High Pressure Monitor and the High Pressure Core Spray (WCS) System alarm setpoints. Technical specification 6.2.A.7-requires procedures to be written for surveillance and testing requirements.
Contrary to the above, the high pressure leak detection monitoring switches for the RHR shutdown cooling piping were not functional tested every 31 days and no procedure to perform the function or calibration tests were issued. In addition, the procedure for the HPCS alarm setpoint (LIS-W-03) specified a tolerance above the-technical specification limit.
CORRECTIVE-ACTION TAKEN AND RESULTS ACHIEVED The instruments in question were imediately recalibrated and functionally tested. Procedure changes were initiated to correct the problems identified. Because of'a delay in getting the procedure revision approved,.the monthly functional test which should have been performed on March 1, 1985 was overlooked a second time. All procedure revisions required have been completed, in the surveillance requirements have been added to the instrument maintenance surveillance schedule.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIANCE The surveillance requirement for Technical Specification 4.4.3.2.2 was reviewed to assure that the other instruments monitoring the high/ low pressure interfaces were tested at the proper intervals and the setpoints satisfied Tech Spec.
DATE OF FULL COWLIANCE March 14, 1985 9929N