ML20129D572

From kanterella
Jump to navigation Jump to search
Insp Repts 50-373/96-07 & 50-374/96-07 on 960623-0802. Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support
ML20129D572
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 09/23/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20129D556 List:
References
50-373-96-07, 50-373-96-7, 50-374-96-07, 50-374-96-7, NUDOCS 9609300129
Download: ML20129D572 (17)


See also: IR 05000373/1996007

Text

.

. .

.

l U.S. NUCLEAR REGULATORY COMMISSION

l

REGION 111

-

.

l

4

Docket Nos: 50-373, 50-374

! License Nos: NPF-11, NPF-18 ,

l '

'

Report Nos: 50-373/96007, 50-374/96007

i

Licensee: Commonwealth Edison Company

Facility: LaSalle County Station, Units 1 and 2

Location: 2601 North 21st Road

Marseilles, IL 61341 {

Dates: June 23 - August , 1996

> Inspectors: K. Ihnen, Resident Inspector  !

H. Simons, Resident Inspector i

J. Adams, Reactor Engineer l

N. Shah, Radiation Specialist

D. Hart, Radiation Specialist

G. Pirtle, Security Specialist

J. Roman, Illinois Department of Nuclear Safety

Approved by: Bru r nsen, Acting Chief, Projects Branch 5

Divis1% of Reactor Projects

l

l

l

9609300129 960923

PDR ADOCK 05000373

PDR

l $( G

... . - -. . - - - . . .---. . - . . - - - _ - - - - - _

.

. .

.

! EXECUTIVE SUMMARY

l

l LaSalle County Station, Units 1 and 2

NRC Inspection Report 50-373/96007(DRP); 50-374/96007(DRP)

This integrated inspection report included aspects of licensee operations,

maintenance, engineering and plant support. The report covers a 6 week period

by the resident inspectors plus several announced inspections by regional

specialist inspectors.

Plant Operations

. A maintenance work practice deficiency and a procedural weakness resulted

in a significant plant transient during an Instrument Maintenance (IM)

l surveillance. Corrective actions for a previous event and a problem

identification form (PIF) were not fully effective in preventing the main

,

steam isolation valve (MSIV) isolation and reactor scram which occurred on

l

June 26, 1996. This is considered a violation of 10 CFR 50, Appendix B,

l Criterion XVI (Section 01.2).

!

I

. Materiel condition of the containment air particulate and noble gas

monitors was considered poor. In addition, an operator work-around was

identified by the inspector (Section 01.3).

Maintenance

. A Technical Specification (TS) surveillance to verify the proper position

of four manual primary containment isolation valves in each unit had not

been conducted monthly as required because the surveillance procedure did

not include these valves. The valves had been verified locked closed once

per 18 months per an administrative procedure. Although Comed had

initiated a review of TSs required surveillances to ensure they were being

properly accomplished, this problem was outside the scope of the review and

was not previously identified (Section M1.1).

. Four human performance errors which occurred while performing 00Ss were not

significant when reviewed individually. However, the number of errors in a

short time period indicated a continuing need for improvement in human

performance (Section M1.2).

Enaineerina

. No significant engineering issues were documented in this inspection

report. Significant engineering issues which occurred during this

inspection period were documented in inspection reports 50-373/374-96008

and -96009. Both of these reports discussed details of the events related

to the inadvertent injection of foam sealant into the core standby cooling

system (CSCS) water tunnel.

i

1

. . __ . -

- -.. -. -. . - - - . _ _ - - - - . - - _

.

.

. .

i

8

, Plant Suncort

. The inspectors reviewed a recent failure in the radwaste evaporator system

which caused a large spill. The inspectors concluded that there was no

i formal maintenance and operational trending program for the floor drain and

chemical waste processing systems. This could affect long-term evaporator

,

operations. No problems were observed with the licensee's initial response

i

'

to the evaporator spill event or with the radiological planning for the

,

,

evaporator room cleanup (Section RI.1).

. Human performance errors in the area of fire protection continued to occur.

Corrective actions for previous missed fire watches had not been fully

'

.

l effective. The failure to perform a Technical Specification fire watch is

considered a violation (Section F1.1).

i  !

. Implementation of the Vehicle Barrier System was reviewed and determined to
be adequate. The need for some administrative actions, barrier

l modifications, and additional analyses were noted (Section S1.1).

l

!

.

f

1

'

I

w

4

i

!

!

I

ii

_ ___ __ _ ..._._ _ ._. - . _ . ._ _ _ _ _ _ _ _ . _ . ._

,

l *

. .

.

Report Details

Summary of Plant Status

Unit 1 operated at or near full power until June 19, 1996, when power was

reduced to about 77% due to low service water header pressure. Full power was

achieved again on June 20. On June 24, power was again reduced to about 77%

due to low service water header pressure. On June 26, at 2056 hours0.0238 days <br />0.571 hours <br />0.0034 weeks <br />7.82308e-4 months <br />, an

automatic reactor scram occurred due to the closing of the main steam

isolation valves (MSIV) during a surveillance. On June 28, a reactor startup

! commenced; however, later that day, Unit I was manually scrammed due to the

core standby cooling system (CSCS) being declared inoperable. Unit I returned

to service on July 14 and remained at or near full power for the remainder of

the inspection period.

Unit 2 operated at or near full power until June 19, 1996, when power was

, reduced to about 77% due to low service water header pressure. Full power was

! achieved again on June 20. On June 24, power was again reduced to about 77%

due to the low service water deader pressure. At midnight on June 29, a

l shutdown of Unit 2 began after the CSCS system was declared inoperable. Unit

2 was returned to service on July 16, and remained at or near full power for

the rest of the inspection period.

I. Operations

01 Conduct of Operations

01.1 General Comments (71707)

l

The inspectors conducted frequent reviews of ongoing plant operations.

In general, operations in the control room were conducted in a

professional manner with good decorum and communication practices.

The inspectors observed portions of both units' shutdowns and startups,

and control room response to abnormal conditions. No problems were

identified in control room operations during this inspection period.

01.2 Automatic Reactor Scram Durina Surveillance Testina

a. Insoection Scope (71707)

The inspectors reviewed the circumstances surrounding the Unit I

automatic reactor scram on June 26, 1996. The inspectors observed the

initial root cause investigation effort and the Plant Operations Review

Committee (PORC) startup review meeting.

b. Observations and Findinas

On June 26, 1996 at approximately 8:56 p.m., a MSIV isolation was

received on Unit 1 while instrument maintenance (IM) department

1

l

--- - . -

.

. .

,

'

l

l personnel were performing LaSalle Instrument Surveillance (LIS)-MS-102,

" Unit 1 Main Steam Line High Flow MSIV Isolation Calibration." The MSIV
isolation resulted in an automatic reactor scram. All systems

i functioned as expected during the shutdown and no anomalies were

observed.

) There are four instrument racks associated with the main steam line hi

i flow detection instrumentation. Each instrument rack contains one

'

primary containment isolation system (PCIS) subchannel. Each PCIS

subchannel consists of four Static 0-Ring (SOR) differential pressure hi

flow switches, one from each main steam line. These subchannels are A1

1 (A switches), B1 (B switches), A2 (C switches), and B2 (D switches).

l The switches are configured in a one-out-of-two twice logic. To trip a

j PCIS subchannel from the high flow switches, at least one switch in a

!

channel must trip on high flow. To receive a full MSIV isolation, one

of the A or C channels must trip along with one of the B or D channels.

l A half isolation trip was in place on the A2 channel during the

calibration of the C switch. An IM technician had just completed

actions for propressurizing the_ switch to near reactor pressure, and was

in the process of throttling open the switch's high side isolation valve

when a trip was received from the PCIS Channel B2. The combination of

these trips caused the MSIV isolation.

The root cause of the event was an IM work practice deficiency in the

technique for prepressurizing instruments. A contributing factor was a

procedural weakness. The procedure did not include steps to reset the

main steam high flow isolation trip channel prior to returning the

instrument to service. This action would have reduced the probability

of receiving a MSIV isolation from a pressure spike induced while

valving in the instrument.

A previous MSIV isolation and reactor scram occurred on Decmber 12,

1994, during the same surveillance procedure. The root cause of this

previous event was an equipment failure; specifically, a SOR switch had

failed. The root cause report and corrective actions for this event

focused on. ne failed switch. The instrument maintenance calibration

procedure was not identified as a possible contributing cause. In

retrospect, the corrective actions for the December 12, 1994, were

appropriate for the failed switch, but too narrowly focused.

On March 6,1995, a Problem Identification Form (PIF) was written by a

reactor operator identifying a potential problem with the methodology of

performing LIS-MS-102. The PIF outlined the basic scenario which caused

the MSIV closure and the reactor scram of June 26, 1996. Specifically,

the potential for a MSIV isolation due to a pressure spike while valving

in a hi flow switch. In the PIF, the operator also presented a solution

to prevent the event from occurring. The event screening committee  :

which reviewed this PIF forwarded it to the " Scram Reduction Committee"

for appropriate review and action. However, no action was taken to

revise the procedure.

2

, . _ _ . . _ . _ _ _ _ _ _ -. _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ . _ _ _ _ _

~

{ * *

! +

1 .

The failure to take adequate corrective actions on these two previous

issues described above, resulted in a significant condition adverse to

quality on June 26, 1996; specifically, a MSIV isolation and reactor

scram. This is a violation of 10 CFR 50, Appendix B, Criterion XVI (VIO

373/374-96007-01).

c. Conclusion

i

A maintenance work practice deficiency and. a procedural weakness ,

resulted in a MSIV isolation and reactor scram during an IM

surveillance. Corrective actions for a previous event and a PIF were

i not fully effective in preventing the MSIV isolation and reactor scram

which occurred on June 26, 1996.

01.3 Unolanned Entry Into Technical Specification (TS) 3.0.3

,

a. Insoection Scone (71707. 62703)

The inspector reviewed the circumstances surrounding the entry into TS 3.0.3 following the loss of containment air particulate and noble gas ,

monitor 2PL75J, while monitor 2PL15J was inoperable for calibration.

The inspector interviewed personnel involved in the event and reviewed  !

licensee documentation of the event.

b. Observations and Findinas

On July 22, 1996, the licensee entered TS 3.0.3 due to insufficient

operable instruments to monitor Unit 2 containment leakage as required

by TS 3.4.3.1. This event was initiated by the loss of the containment

air particulate and noble gas monitor 2PL75J due to the tripping of the

sample pump. At the time, containment air particulate and noble gas

monitor 2PL15J was removed from service for the performance of LIS-PC-

206, " Containment Air Particulate and Noble Gas Monitor Calibration."

IMO technicians were able to restart the monitor 2PL75J after it

tripped, which returned it to an operable status. TS 3.0.3 was exited

24 minutes after its entry.

Materiel condition problems and work control weaknesses were

contributing factors to this event. The inspector conducted a review of

twelve PIFs written over the previous eleven months that were associated

with the 2PL15J and 2PL75J containment air particulate and noble gas

monitors. Several examples of material condition problems were noted.

In recent examples, the 2PL75J monitor control room indication failed

downscale, the 2PL75J indication was observed to be spiking, the 2PL15J

indication was observed to be spiking, and the 2PL15J or 2PL75J sample

pumps were routinely tripping following particulate filter change out.

The inspector also noted a materiel condition problem with the

containment cooler condensate flow rate monitoring system. This system

was inoperable at the time of the event. If operable, it would have

provided sufficient instrumentation such that entry into TS 3.0.3 would

not have been necessary. The inspector later learned that the

l

'

3

-

. .

I

!

containment cooler condensate flow rate monitoring system had been

inoperable for a significant period of time and had been referred to

engineering for determination of corrective action.

4

{ The inspector concluded that weaknesses in the work control process

contributed to the event. The 2PL15J monitor calibration work was

l approved and started without considetetion of maintenance personnel

j availability to complete the work. This oversight resulted in the

i inoperable condition of the 2PL15J monitor at the time of the event and

-

lead to the TS 3.0.3 entry.

I Problems similar to the event of July 22, 1996 recurred on July 31,

1996, and again on August 1, 1996. The licensee removed the 2PL15J
monitor from service to allow for the operation of the post accident )

,

sampling system for testing. In these cases, the licensee considered  !

! the 2PL15J monitor operable and available for use. The 2PL75J monitor l

l subsequently tripped, leaving the unit without any containment

. particulate or gaseous activity monitors in operation. The control room

] operator promptly started the 2PL15J monitor each time.

The inspector identified two operator workarounds. First, the operator

is required to remove one of the containment air particulate and noble

gas monitors from service, prior to operating the post accident sampling  !

system. Failure to do this results in the tripping of the associated

containment air particulate and noble gas monitoring system. Second,

the containment air particulate and noble gas monitors routinely trip

following particulate filter paper replacement. The inspector was

informed by the licensee that the first workaround was on the workaround

list but the second was not. The licensee informed the inspector that >

the second workaround would be placed on the list, and so would the

containment cooler condensate flow rate monitoring system.

c. Conclusion

Materiel condition of the containment air particulate and noble gas

monitors was considered poor based on the problems discussed above and  ;

the historical performance. In addition, an operator work-around was '

identified by the inspector.

II. Maintenance ,

M1 Conduct of Maintenance

M1.1 Failure to Conduct a Technical Soecification Reauired Surveillance

a. Inspection Scope (61726)

The inspectors reviewed the circumstances surrounding a missed TS

surveillance, including the reason it was missed and how it was

identified.

4

- .. - - _- .

- - - - - --_

- _

.

. .

.

l

b. Observations and Findinas ,

On August 2, 1996, an issue was identified by Comed personnel concerning l

which valves must be checked to verify primary containment integrity in

accordance with TSs. As a result, a review was conducted and it was  ;

identified that eight manual primary containment isolation valves (four J

on each unit) were not verified to be in the correct position once per

31 days as required.

These eight valves were not included in the monthly surveillance

l procedure that is conducted to satisfy TS Surveillance Requirement

! 4.6.1.1.a. These eight manual valves isolate one of the two narrow

range suppression pool sightglasses. Although these valves had not been

checked monthly, they had been verified locked closed once each 18

months per an administrative surveillance.

l

The failure to conduct the required surveillance in accordance with TS 4.6.1.la is a violation (VIO.373/374-96007-02). The root cause and

corrective actions will be followed up during the review of the response

to the violation and the LER.

Comed had done a complete review of TS surveillances in November 1995

because several surveillances had been missed. The review was directed

at verifying that a procedure existed for conducting all required

surveillances, and verifying the frequency for conducting these

procedures was correct and was being appropriately tracked. The review

did not include reviewing the content of the surveillance procedures to

L ensure they completely satisfied the TS surveillance requirements; thus,

the problem discussed above was not discovered.

c. Conclusion

A TS surveillance to verify the proper position of eight manual primary

containment isolation valves had not been conducted monthly as required

because the surveillance procedure did not include these valves.

However, these valves were verified locked closed once per 18 months per

an administrative procedure. Although Comed had performed a review of

TS-required surveillances to ensure they were being properly

accomplished, this problem was outside the scope of the review and was

not previously identified.

M1.2 Several Human Performance Errors in Performina Out-of-Services (00S)

a. Insoection Scope (62703)

The inspectors reviewed several 00S problems which occurred during the

inspection period.

5

._. -_ .

- . - - . _ _ - - . - - - - - . . - . - - ._- -.-- - - - - - - ._.

.

. .

.

b. Observations and Findinas

The Operations Manager initiated an Out-of-Service (005) standdown due

to several human performance errors that occurred. The following is a

summary of the events.

On July 18, an operator incorrectly hung an DOS on the wrong control

switches in the radwaste control room. This was identified by another

operator during a walkdown before performing a radwaste water transfer.

On July 22, while hanging an DOS on a fire protection circuit, the

operators in the control room received several alarms that were

unexpected, indicating that more fire detection circuits than planned

had lost power. This event is described further in Section F1.1 of this

I report.

On July 22, while clearing an DOS on plant service water to the stator

cooling system, an error resulted in a transient which challenged

temperature limits on the Unit I main turbine bearings.

Also on July 22, during the preparation of an 00S on the 08 control room

ventilation system, an instrument related to the U2 standby gas

treatment system was also taken DOS. This was not a planned evolution

and resulted in a potential challenge to the operability of an ,

i

engineered safety feature.

During the standdown, all operating crews were briefed on these events

and performance expectations were reiterated.

I c. Conclusion

Individually, the four human performance errors which occurred while

l performing 00Ss were not safety significant. However, the number of

errors in a short time period indicated a continuing need for

improvement in human performance.

III. Enaineerina

Engineering issues were the focus of separate special inspection during this

inspection period. An NRC Augmented Inspection Team performed a review of the l

circumstances surrounding the injection of foam sealant into the CSCS system. l

This review is documented in inspection report 50-373/374-96008. Engineering i

performance related to the foreign materiel in the essential service water l

,

tunnel is also documented in inspection report 50-373/374-96009. l

4

,

! 6

l

_

__ _. _ __ _- _ _ ___ _ __- _ .___ ___ _ _ _ __ _ _ - . _

.

.

.

J

IV. Plant Sunnort i

R1 Radiological Protection and Chemistry Controls

l

R1.1 OWZ Evanorator Event (83750)

a. Scone - (0 pen) Followun on IFI 373/374-96006-05fDRS)

i

The inspectors reviewed the licensee's maintenance of the liquid

radwaste evaporators and a June 15, 1996 event involving the licensee's

OWZ evaporator. Items specifically reviewed included:

. The evaporators' maintenance histories;

. Licensee procedures concerning evaporator operation; l

. The licensee's problem identification form (PIF No. 96-1715)

documenting the June 15, 1996 event; and

l . A Deviation Report (DVR No.88-085) documenting a similar event in

i 1988.

I The inspectors also interviewed selected members of the licensee's

radwaste operations, system engineering and radiation protection groups.

b. Observations and Findinas

. System Operation and Maintenance

l The licensee has three evaporators (IWF, 2WF and OWZ) for cleanup of

i liquid radwaste from the floor drain and chemical waste systems. Only

one of the evaporators is normally needed to handle liquid radwaste

processing. The station evaporators were to be replaced with a vendor

system, which was to be installed in 1995. Several problems identified

l during preoperational testing delayed installation, which is now

l scheduled for the end of 1996. Until installation of the vendor system,

,

'

the station evaporators remained the primary system for processing

liquid radwaste.

l The station evaporators were maintained under an informal program

developed by the radwaste coordinator. Under this program, each

evaporator was sequentially removed from service to perform necessary

maintenance and component inspection. However, operational parameters

l (i.e. evaporator temperature, pressure, flow rates, etc) were not

'

trended and therefore, not used to measure system performancs. The

radwaste coordinator and system engineer take corrective actions for

deviations from normal operation based on their familiarity with the

l evaporators.

The inspectors were concerned that the lack of a formal maintenance and

operational trending program could impact long-term evaporator

operation, if the vendor problems were not resolved. The existing

informal program appeared adequate, but relied on personal knowledge

rather than a formal process.

,

l

'

.

.

.

The Updated Final Safety Analysis Report (UFSAR) accurately described

radwaste processing activities as they were being performed at the

facility. The licensee was performing a 10 CFR 50.59 analysis for the

specific vendor process to be used and indicated that the UFSAR would be

revised after the analysis was completed.

. Evaoorator Soill Event

On June 15, 1996, a spill of about 3600 gallons of contaminated water

and sludge occurred in the OWZ evaporator room and an adjacent hallway.

Radiation levels in the evaporator room increased to 5 rea/hr (normally

0.05 rem /hr) and contamination levels.in the hallway exceeded 1 million I

dpm (seearable). An NRC inspection performed June 16-18, 1996, reviewed j

the licensee's immediate response to the event and the cleanup of the

hallway outside the evaporator room; no problems were identified.

Although the licensee was still investigating the root cause, a

preliminary inspection of the evaporator (via remote camera) indicated  ;

apparer.t damage to a gasket located on the evaporator heating element.

In 1988, similar damage (caused by overpressurization of the evaporator

system) also resulted in leakage from the 0WZ evaporator. The

inspectors verified that corrective actions for the 1988 event were in

place and that no overpressurization had occurred.

During the 1988 event, cracks in the evaporator room wall allowed water

to leak through and flow down the exterior of the radwaste building.

Although the cracks were repaired, the licensee again observed leakage

on the exterior wall during the current event. A radiological survey of

the affected area did not identify any contamination, but the survey did

find several other areas of the wall where residual contamination from

the 1988 event had apparently leached onto the exterior surface. This

contamination ranged from 3,000 to 5,000 dpa (seearable). The affected

areas were decontaminated and coated with a sealant to prevent further

leaching.

The licensee was decontaminating the evaporator room to allow for

subsequent disassembly of the evaporator to identify the source of the

leakage. The inspectors reviewed the ALARA plans for the cleanup; no

problems were identified. These plans included positioning workers

outside the radwaste building to verify that no water leakage occurred

during the cleanup,

c. Conclusions

The inspectors concluded that there was no formal maintenance and

operational trending program for the floor drain and chemical waste

processing systems. This could affect long-term evaporator operations.

No problems were observed with the licensee's initial response to the

evaporator spill event or with the radiological planning for the

evaporator room cleanup. The licensee was still investigating the root

cause of the event.

8

._

.

. .

.

F1 Control of Fire Protection Activities

F1.1 Failure to Perform a Tech Spec Reauired Firewatch

a. Inspection Scone (71750)

The inspectors reviewed the circumstances surrounding a missed firewatch

event and discussed the event with the fire protection group.

b. Observations and Findinas

At 6:00 a.m. on July 31, 1996, a fire protection inverter was taken 00S

for scheduled maintenance. The 00S and associated fire impairment were )

prepared and reviewed prior to taking the inverter 00S. The individuals

that prepared and reviewed the 00S and associated fire impairment failed

to recognize that the 00S would cause all power to be lost to the Unit 2

main fire detection control panel and the control room remote  !

annunciator panel. Fire suppression capability was not affected. j

When the 00S was implemented, the appropriate fire watches were not j

established as required by the action statement of Technical

Specification 3.3.7.9. This is considered a violation (VIO 374-96007-

03).

At 9:00 a.m. an operator recognized that power to the main fire

detection control panel had been lost and immediately notified the fire

marshal. The fire marshal immediately established the fire watches.

The power to the main fire detection control panel was restored at

approximately 7 p.m. that day when the scheduled maintenance was

completed.

Comed's investigation determined this incident resulted due to a human

performance error on the part of the personnel writing and reviewing the

00S and the fire impairment.

This event was not isolated in that several fire watches had been missed

in 1996. Two of these missed fire watches were required by TSs and

therefore documented in LERs. Other missed fire watches were not

required by TSs and were not reportable. However, they were still

significant in that human performance with regards to conducting fire

watches was weak. Corrective actions for the previously missed fire l

watches appeared to be too narrow in scope to have prevented this

current event.

c. Conclusions

Human performance errors in the area of fire protection continued to

occur. Corrective actions for previous missed fire watch had not been

fully effective. The failure to perform a TS fire watch is considered a

violation.

9

__ _ _ _

. - . -.- -- ..- - - - - - -.. - - - - _ -.

.

' '

,

,

51 Conduct of Security and Safeguards Activities

!- S1.1 Temocrary Instruction 2515/132. " Malevolent Use of Vehicles at Nuclear

Power Plants"

l

i

a. Inspection Scone (TI 2515/132) I

l

j Areas examined included the licensee's provisions for land vehicle l

control measures to protect against the malevolent use of a land vehicle '

l and to determine compliance with regulatory and licensee commitments.

!

b. Observations and Findinas

j (1) Vehicle Barrier System

The inspector found that the features and structures that form the

Vehicle Barrier System (VBS) met the design characteristics established

by the NRC. The vehicle barrier components and the location of the

barrier were as described in the revised summary description of the VBS

which the licensee submitted to the NRC in February 1996.

A visual walkdown performed by the inspector confirmed that the general

type of vehicle barrier described in the VBS summary description had

been installed and that the barrier was continuous.

Some observations were noted that require analysis or actions by the

licensee's staff. The observations are noted below and will be tracked

as an inspection followup item (IFI 50-373/374-96007-04). The specific

VBS locations for the below noted observations are considered Safeguards

Information and exempt from public disclosure.

(a) Spacing between some barriers exceeded recommendations.

(b) Some barrier connectors at some locations were not secured to

prevent manipulation with hand held tools.

(c) A separate engineering analysis had not been completed to confirm

that structural features for a small portion of the VBS was

adequate to act as an effective vehicle barrier.

(2) Bomb Blast Analysis

Inspector field observations of standoff distances were consistent with

those documented in the summary description. The licensee confirmed

that the calculation of minimum standoff distance was based on NUREG/CR-

6190 or an independent engineering analysis. Six actual measurements

were completed to confirm that the minimum standoff distances, as

documented in the summary description, were the actual distances

provided by the as-built VBS.

The licensee identified standoff distance for one location within the

VBS required additional analysis based upon the inspector's

10

. _ _ _ _ _ _ . _ . . . _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ . . . _ _

.

. .

.

i

determination that a land vehicle could approach closer to the building

containing vital equipment than the licensee's initial analysis

indicated. This issue will be monitored as an Inspection Followup Item

(IFI 50-373/374-96007-05).

(3) Procedural Controls

The licensee appropriately defined criteria for maintenance,

surveillance, and compensating for the VBS in Corporate Nuclear Security

Guideline No. 4, " Operational Planning and Maintaining Integrity of

Vehicle Barrier Systems (VBS), Revision 0, dated February 1996. Some

administrative issues required further action by the licensee and are

described below. Resolution of these administrative matters will be

tracked as an Inspection Followup Item (IFI 50-373/374-96007-06).

(a) Some building barriers that act as part of the VBS were not

included within the VBS description.

(b) A surveillance procedure for testing and inspection of the VBS was

required.

(c) The need to advise the NRC Region III office concerning barriers

! that have to be compensated for, in excess of 30 days, was not

l included in the procedure for VBS compensatory measures.

(d) NRC review comments, dated June 26, 1996, pertaining to the VBS

addressed in Revision 54 of the security plan, need to be

resolved.

Discussions with the Site Security Administrator, security staff, and a

Senior Reactor Operator confirmed that procedures necessary to safely

shutdown the units after a bomb blast were reviewed and found to be

adequate.

c. Conclusion

The licensee's provisions for land vehicle control measures met

regulatory requirements and licensee commitments. The VBS program was

consistent with the summary description submitted to the NRC; installed

components were identified in NUREG/CR-6190 or the licensee's

engineering analyses, and appropriate procedures had been developed and

implemented. The need for some additional administrative actions,

analysis, and barrier modifications were noted and will be tracked as

Inspection Followup Items.

l

II

- -

. i

.

l

l

i

, V. Manacement Meetinas

f

l X1 Exit Neeting Summary

The inspectors presented the results of these inspections to Comed

management listed below at an exit meeting on August 7, 1996. Comed

acknowledged the findings presented.

The inspectors asked the licensee if any materials examined during the

inspection should be considered proprietary. No proprietary information

was identified.

!

l

4

$

l

4

I

i

i

I

i

c

!

i

12

- . . - .. . . _ .--

,

l

l .

l

l

PARTIAL LIST OF PERSONS CONTACTED

!

Comed

  • J. Brons, Acting Site Vice President
  • D. Ray, Station Manager
  • L. Guthrie, Operations Manager

P. Smith, Maintenance Superintendent

  • R. Fairbank, System Engineering Supervisor

P. Antonopoulos, Site Engineering Manager

  • D. Boone, Health Physics Supervisor
  • R. Crawford, Work Control Superintendent
  • J. Burns, Regulatory Assurance Supervisor
  • Present at exit meeting on August 7, 1996.

INSPECTION PROCEDUkES USED

IP 37551 Onsite Engineering

IP 40500 Effectiveness of Licensee Controls in Identifying, Resolving, and

Preventing Problems

IP 61726 Surveillance Observation

IP 62703 Maintenance Observation

IP 71707 Plant Operations

IP 71750 Plant Support Activities

IP 83750 Occupational Exposure

TI 2515/132: Malevolent Use of Vehicles at Nuclear Power Plants

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

373/374-96007-01 VIO Failure to take corrective actions on a significant

condition adverse to quality (MSIV isolation and

reactor scram)

373/374-96007-02 VIO Failure to perform a Tech Spec surveillance to verify I

the position of manual containment isolation valves

373/374-96007-03 VIO Failure to perform a Tech spec required fire watch

VBS Barrier Modifications and Analysis

.

373/374-96007-04 IFI l

373/374-96007-05 IFI Analysis of VBS Standoff Distance  !

373/374-96007-06 IFI Administrative Requirements Pertaining to the VBS

Items Discussed

373/374-96006-05 IFI Root Cause of the Radwaste Evaporator Failure

13

. . _ . . _ . . _ _ . _ - . _ _ _ _ _

-

.

.

LIST OF ACRONYMS USED

ALARA As low As Reasonably Achievable

CSCS Core Standby Cooling System

DRP Division of Reactor Projects

DRS Division of Reactor Safety

IDNS Illinois Department of Nuclear Safety

IM Instrument Maintenance

IR Inspection Report

IFI Inspection Follow-up Item

LER Licensee Event Report

LIS LaSalle Instrument Surveillance

MSIV Main Steam Line Isolation

NRC Nuclear Regulatory Commission

DOS Out of Service

PCIS Primary Containment Isolation System

PIF Problem Identification Form

PORC Plant Operations Review Committee

PDR NRC Public Document Room

SOR Static 0-Ring

TI Temporary Instruction

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

VBS Vehicle Barrier System

14

l

.