IR 05000373/1996013
| ML20134G503 | |
| Person / Time | |
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| Site: | LaSalle  |
| Issue date: | 01/29/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20134G470 | List: |
| References | |
| 50-373-96-13, 50-374-96-13, NUDOCS 9702100433 | |
| Download: ML20134G503 (28) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III i i l l Docket Nos: 50-373. 50-374
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License Nos: NPF-11. NPF-18 4 -.
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i j Report Nos: 50-373/96-13. 50-374/96-13
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l Licensee: Commonwealth Edison Company i j
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Facility: LaSalle County Station. Units 1 and 2
l Location: 2601 N. 21st Road
Marseilles. IL 61341 '
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3 Dates: September 13 - October 25. 1996 and December 13. 1996
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l Inspectors: M. Huber. Senior Resident Inspector K. Ihnen. Resident Inspector H. Simons. Resident Inspector i D. Roth. Resident Inspector. Dresden Station
Approved by: Marc Dapas. Chief. Projects Branch 2
- Division of Reactor Projects i
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9702100433 970129 FDR ADOCK 05000373
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EXECUTIVE SUMMARY J
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LaSalle County Station. Units 1 and 2
{ NRC Inspection Report 50-373/96-13(DRP); 50-374/96-13(DRP)
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This inspection included aspects of licensee operations, maintenance, engineering, and plant su3 port. and covered a six-week period from i- September 13 through Octo3er 25, 1996.
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- The inspectors identified several examples of poor worker practices involving
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radiological controls and housekeeping. fire protection controls for weldin and procedural adherence. The inspectors were concerned with instances o operating and maintenance department first line supervisors conveying non-conservative procedural adherence expectations to worker The issues with poor worker practices along with an ineffective overview of engineering
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requests and the failure to adequately address reactor core isolation cooling rupture disk problems, reflect continuing problems with effective resolutioh of long-term performance issue Plant Operatjons
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The inspectors identified a violation involving the failure of a Unit Supervisor and other control room operators to follow the general procedure for shutdown and to initiate a procedure change reflecting the actual shutdown process used. (Section 04.1)
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. Equi 3 ment operators did not follow out-of-service instructions resulting in tie wrong battery charger being de-energized. This was considered a violatio (Section 04.2)
Several self-assessment initiatives were considered goo (Sections 07.1 through 07.3)
Maintenance
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The inspectors identified several plant housekeeping conditions that had the potential to adversely impact plant operations, such as the use of duct tape where it could interfere with valve operation. These conditions were also indicative of poor worker practice (Section M2.1)
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The licensee's initiative to inspect the drywell to suppression pool downcomers was goo (Section M2.2)
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The inspectors identified a violation involving an inadequate freeze seal maintenance procedure. Workers establishing a' freeze seal on an emergency diesel generator (EDG) cooling water line demonstrated a good questioning attitude in identifying that the subject procedure did not ;
contain the required information. However, a maintenance department first line supervisor attempted to resolve the problem by explaining th _ _ . . _ _
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-'o intent of the procedure rather than seeking a formal work package clarification or procedure revisio (Section M3.1) i l
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The inspectors identified a violation involving the failure of maintenance workers to follow a procedure during reassembly of the 0 EDG :
service water strainer which resulted in excessive leakage of a strainer j backwash valve, necessitating rework. Documentation in the rework
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package was not thorough, representing an impediment to good root cause '
analysis. (Section M4.1)
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A violation was identified involving the failure to follow work request ,
instructions which resulted in installation-of jet pump plugs in the 1
' wrong reactor recirculation 100). A fuel handling supervisor demonstrated poor proceduraY ad1erence practices by continuing with jet pump plug installation even though he was aware that a required drawing was missing from the work package. (Section M4.2)
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The inspectors identified a violation involving the failure to follow work practices required by fire protection procedures for ensuring a safe welding environmen (Section M4.3)
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Enaineerinq
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The inspectors' identified a violation involving inadequate i administrative procedures for control of engineering work. The licensee did not have a formal, proceduralized process for handling engineering requests and existing informal processes were inef#ective in prioritizing and ensuring timely completion bf engineering wor (Section El.1)
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The inspectors identified an apparent violation for the failure to implement corrective actions following a 1994 reactor core isolation cooling system rupture disc event. A second rupture disc event, apparently due to the same root cause as the 1994 event. occurred on August 28. 1996. The ineffective engineering request contributing factor to the corrective action problem. process was (Section also a E2.2)
Plant Sucoort
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The inspectors identified a violation involving several examples of the failure to adhere to required radworker practices. The ins)ectors were concerned that actions taken by the licensee to address pro)lems with radworker practices and radiological housekeeping conditions, were not sufficient to ensure long-term and consistently good performance in i these area (Section R1.1) I i
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- I Report Details Summary of Plant Status
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Unit 1 began this inspection period at 100 percent power. On September 2 the unit was shut down to repair a servo valve failure on a turbine control valve. The unit remained in cold shutdown for the remainder of the inspection perio Unit 2 was operating at a reduced power level of 82 percent at the beginning !
of this inspection period to maintain the core power distribution within allowable limits. On September 19, Unit 2 was shut down for a refueling outag Major work activities performed during the . outage included suppression pool cleaning, core shroud inspections, motor-operated valve testing, and reactor recirculation manual isolation valve modification i Ooerations
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l 01 Conduct of Operations
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01.1 General Comments (71707)
The inspectors conducted frequent reviews of ongoing plant operations using Inspection Procedure 71707. Walkdowns were performed in the main control room; emergency diesel generator rooms; the auxiliary electrical equipment rooms; safety-related puma rooms; the reactor building, including the drywell; the turbine Juilding; and the radwaste facilit The inspectors also observed and discussed plant status and pending evolutions with shift personnel in the control roo .2 Sourious Reactor Water Cleanuo (RWCU) Isolations Inspection Scone (93702. 71707)
On September 17. a high differential flow condition occurred in the Unit 2 RWCU system when the 2A filter demineralizer was placed into service. The high differential flow resulted in a Group 5 containment isolation actuation, an engineered safety features system actuatio The inspectors responded to the control room and observed the operator response, reviewed RWCU logs, interviewed the auxiliary operators involved with placing the 2A filter demineralizer in service, and reviewed the following procedures:
LaSalle Operating Abnormal LOA-2H13-P601 C411. " Division 1 RWCU
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Flow High," Revision 7
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LaSalle Operating Procedure (LOP)-RT-06, "RWCU System
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Filter /Demineralizer Precoat." Revision 23 LaSalle Operating Procedure LOP-RT-07, "RWCU - Placing a Filter /Demineralizer in Service," Revision 15
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- Observations and Findings
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The RWCU system Group 5 containment isolation occurred when operators
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were placing the 2A filter demineralizer in service. The inspectors
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observed operator actions subsequent to the isolation, which included ,
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verification that the RWCU system was isolated, and system inspections to thedetermine if an actual high differential flowleak existed or some other failure had caused condition.
i Before the event, the RWCU system was operating normally with the
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2B filter demineralizer in service. Operators completed routine resin
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replacement before placing the 2A filter demineralizer in service during
the next shift. Following shift turnover, operators pre)ared to return
the 2A filter demineralizer to service, by unisolating t1e demineralizer J
with the local control switch. When the local control switch was placed in the unisolate position, the demineralizer inlet and outlet valves
, automatically opened. Alarms annunciated in the control roo ; indicating RWCU system high differential flow. Operators attempted to
isolate the filter demineralizer to prevent the Group 5 isolation. but j, were unsuccessful.
i During control room observations, the inspectors noted that operators i
were using a procedure to restore the RWCU system to service following the isolation. While no problems were observed with the restoration f
procedure, the troubleshooting procedure used for recovery from a Group _
5 isolation, which should be performed before returning the RWCU system
{ to service, was not referenced in the alarm response procedure.
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Based on a review of procedures for placing the filter demineralizer in !
) service and discussions with o)erators. the inspectors were not able to
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licensee did not identify any leaks during a walkdown of the RWCU '
syste The inspectors noted that similar events have occurred
involving isolation of the RWCU system when the 2A filter demineralizer l was ) laced in service. However, the licensee did not identify the cause
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of t1e high differential flow condition for these earlier events. The licensee plans to conduct further testing to determine the cause for the
! most recent isolation event.
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The inspectors will review the results of additional licensee testing to
- determine the root cause for this event, and will also review operating procedures to determine if they provide sufficient guidance for recovery from a Group 5 containment isolation. This issue is considered an i unresolved item (50-374/96013-01) pending the completion of these 4 review l
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i Conclusions The control room and auxiliary operators appeared knowledgeable and used-appropriate procedures to respond to the RWCU system isolation. The inspectors will conduct additional followup inspection to evaluate i
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'- l control room procedural adequacy and licensee corrective actions for i this event and previous similar event l l 04 Operator Knowledge and Performance
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04.1 Failure to Follow Procedures When Shifting Reactor Recirculation (RR)
Pumos to Slow Speed
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a. Insoection Scope (71707) 1 The inspectors observed the normal shutdown of Unit 2 on September 19 in preparation for a refueling outage. Specifically the inspectors -
observed,the power reduction and the evolution involying transfer of the RR pumps from fast to slow spee b. Observations and Findings
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' The inspectors noted that the licensee's plan for shifting the RR pumps from fast to slow speed differed from the normal shutdown procedur Step 7 of LaSalle General Procedure LGP-2-1. " Normal Unit Shutdown."
Revision 48. recuired the operators to downshift the RR pumps to slow speed per procecure LOP-RR-08. " Changing Reactor Recirc Speed from Fast to Slow Speed." Instead of shifting the RR pumps per LOP-RR-08, the licensee planned to perform LaSalle Instrument Surveillance LIS-RR-205 " Unit Recirculation Pump Tri) System A Breaker Arc Suppression Response Time Test." Revision 2. whici would result in shifting the pumps to slow speed. The intent of this surveillance procedure is to determine recirculation pump breaker arc suppression response time The Unit 2 Supervisor conducted an infrequent evolution briefing with involved instrument mechanics, operators, and nuclear engineers before conducting the surveillance test. Personnel conducting the brief did not mention that LGP-2-1 s)ecified the use of LOP-RR-08 for shifting the pumps to slow speed and tlat use of LIS-RR-205A to perform the pump shift required a procedure change to LGP-2-1. The inspectors questioned
the Unit Supervisor about the discrepancy between the normal shutdown prccedure and the planned evolution. After discussing the issue amongst themselves, the operators marked Step 7 of LGP-2-1 "N/A." added a note that instrument surveillance LIS-RR-205A was to be used, and continued with the evolutio Technical Specification 6.2.A.a requires that applicable procedures
, recommended in Appendix A of Regulatory Guide 1.33. Revision February 1978, be implemented. Regulatory Guide 1.33 specifies procedures 'or plant shutdown and for procedure adherence and temporary change mett is. LaSalle Administrative Procedure LAP-100-40 " Procedure Use and Ac ence Expectations." Revision 6, required that a temporary
procedure change be completed and procedure LGP-2-1 be revised for the planned RR pump shifting evolution. The failure to either follow LGP-2-1 or initiate a procedure change as required by LAP-100-40 is considered an example of a violation of Technical Specification 6.2. (50-373/96013-02a; 50-374/96013-02a).
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04.2 Operator De-enercized Wrona Eouioment Durina Out-of-Service (00S)
a. Insoection Stone (93702. 71707)
i On October 12 equipment operators were removing the Unit 2. Division 2 ;
battery charger from service when they shut down the Unit 1 battery !
charger instead. The inspectors reviewed the 00S procedure. 00S
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checklist, the applicable operating procedure, and statements written by !
the operators to evaluate the circumstances surrounding the personnel erro l t
b. Observations and Findinas Equipment operators (EO) were using procedures to remove the Unit 2 battery charger from service. Out-of-service 960012473 checklist special instructions required shutdown of the Unit 2 battery charger - 1 using LOP-DC-01. " Energizing. Startup, and Shutdown of a Battery 1 Charger." Revision 8. Step F.3. The E0s de-energized the Unit ~1 battery charger using LOP-DC-01 instead of the Unit 2 battery charger. A control room operator, responding to a control room alarm. contacted the EOs to determine if the Unit 1 charger was de-energized by mistake. The control room operator directed the EOs to re-energize the Unit 1 battery I charger and continue as planned with removing the Unit 2 battery charger i from service. The inspectors reviewed the DOS checklist and associated '
procedures and determined that they were adequat c. Conclusions j
This personnel error apparently resulted from lack of self-checking and inattention to detail. The failure to follow instructions specified in 00S 960012473 is considered an example of a violation of 10 CFR Part 5 Appendix B. Criterion V (50-373/96013-03a; 50-374/96013-03a). as described in the attached Notice of Violatio Quality Assurance in Operations 07.1- Site Ouality Verification (SOV) Performance a. Insoection Scope (40500. 71707)
The inspectors reviewed quality assurance activities related to a licensee integrated assessment of LaSalle station performanc b. Observations and Findinos The licensee's SOV department performed an integrated review of- station performance early in the inspection period. The SOV organization conducted a historical review of identified perfccmance weaknesses and, based on the aggregate of findings, concluded thw management needed to evaluate the ability to operate the plant safely in consideration of the many challenges posed to plant operations. Human performance weaknesses in the engineering and mechanical maintenance departments as well as
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process and program weaknesses, were identified by the SOV organization as problems that continued to challenge plant operations. In additio continuing material condition problems and the lack of a self-assessment culture at the station also posed a challenge to plant operation The SOV organization developed a list of areas for focused assessments to further validate identified performance concern The SOV organization also established criteria for initiating actions such as a stop work order and unit shutdown, based on the significance of findings. The inspectors concluded that the subject criteria were general in nature and equivalent to what a cuality assurance organization would use to. determine the neec for action on a day-to-day basi _,
In response to the concerns raised by the S0V department, the licensee formed two teams: one team to review the identified areas of concern for safety significance, and the second team to identify corrective -
actions to resolve the problem Conclusions
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The inspectors considered the integrated review of LaSalle station performance by the SOV organization to be a good initiative. The response of plant management to the concerns identified by the SOV organization was timely. However, additional time is needed to evaluate the effectiveness of licensee initiatives in resolving the broad performance probloms identifie .2 Event Screening Committee (ESC) Meetina Chances Inspection Scope (40500. 71707)
The inspectors reviewed the licensee's process for identifying and reporting problems and observed several ESC meetings which included discussion of problem identification forms (PIF). Observations and Findinas The licensee uses the PIF process to document problems and conditions adverse to qualit Problem identification forms initiated during the preceding day are discussed at the daily ESC meeting. The inspectors documented weaknesses in the ESC function in NRC Inspection Re) ort 50-373/96004: 50-374/96004. Subsequently, the licensee revised t1e format of the ESC meetings. The licensee identified additional weaknesses in the ESC 3rocess following the service water event in July 1996, and as a result t1e licensee initiated further changes to the ES During this inspection period, the inspectors observed several ESC meetings and noted that the most recent changes to the ESC involved both the membership and conduct of the meeting. The meeting membership is comprised of senior managers, with representatives from operations, engineering, maintenance and work control. The inspectors noted that
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PIFs were no longer pre-screened before the meeting. with all PIFs receiving the same level of review. Licensee management reiterated to the staff their expectations for problem identification and as a result, the number of PIFs generated by plant personnel increased dramaticall The increased 41 umber of PIFs resulted in a backlog such that the ESC was not able to review all of the PIFs written the previous da Conclusions t The inspectors concluded that the changes to the structure and format of the ESC produced mixed results. The elevation of problems to the senior management level and the membership of the committee appeared more stable. However, more resources were required to review the increased .
number of PIFs and the timeliness of PIF evaluations was impacted as a result. The licensee attempted to eliminate the PIF backlog. Howeve '
continued licensee management attention is necessary to ensure quality and timely reviews of PIFs in order to properly identify and classify- :
trend t 07.3 Denartmental Self-Assessments (40500. 71707) ,
The licensee instituted a departmental self-assessment program as part of the continuing effort to develop a self-assessment culture among plant personnel. Periodically, a given departnent presents self-assessment results to the Site Vict.-President snd Plant Manager. The inspectors attended a mechanical maintenance department self-assessment presentation. Maintenance personnel were self-critical the discussion was open and no defensive posture was apparent. The inspecto considered the department self-assessment review to be a good initiativ Miscellaneous Operations Issues 08.1 NRC Review of Institute for Nuclear Power (INPO) Evaluations The inspectors reviewed the INP0 Evaluation Report dated August 199 No new safety issues were identifie II. Maintenance M1 Conduct of Maintenance M1.1 General Comments a. -Insoection Scoce (62703 and 61726)
The inspectors observed the following maintenance and surveillance activities during this inspection period in accordance with inspection procedures 62703 and 61726:
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Work Request (WR) 960085699-01. " Disassemble and Repair Valve
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Internals (2B EDG Cooling Water Strainer Backwash Outlet Valve)"
WR 960085699-02. " Freeze Seal on the 2B EDG Cooling Water Strainer Backwash Valve"
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WR 950055465-01. "Open and Repair 0 EDG Cooling Water Pump -
Strainer"
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WR 950055645-02. " Weld Repair of the 0 EDG Covers"
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WR 950099971-01. " Valve 2E13F332A Repairs"
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WR 940060460-01. " Unit 2 High Pressure Core Spray EDG Cooling Water Pump Repair"
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WR 940061754-01. " Install / Remove 2B RR Loop Jet Pump Plugs to !
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b. Observations and Findinas The inspectors determined that licensee personnel performed work in accordance with the work instructions specified in the various work -
rec uest Involved workers appeared knowledge of the maintenance tasks, anc operations and engineering personnel were appropriately involved in the work activities. However, the inspectors did identify a procedural weakness and examples of the failure to follow procedures and work instructions while observing licensee work activities. The inspectors findings are discussed in detail in Section M3 " Maintenance Procedures and Documentation." and Section M4. " Maintenance Staff Knowledge and Performance."
M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Plant Material Condition a. Insoection Scooe (62703)
fhe inspectors assessed plant material condition and cleanliness during plant tours of accessible areas of the reactor and turbine building b. Observations and Findings During the tours. the inspectors noted several examples of poor '
housekeeping including the following:
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A small leak (2-3 drops / minute) on the Unit 1 motor-driven reactor feedwater pump (MDRFP) seal cooler line with no catch basi No placard identifying parts staged or stored outside of the MDRFP roo Use of a valve-chain for valve 2CD009A. "A GLAND STEAM CONDENSER I OUTLET VALVE." to tie'open a doo The gear box that connected valve 2CD0118. "B 0FFGAS CONDENSER ;
INLET." to its reach rod was wrap 3ed with duct tape, and '
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A black fluid was dripping down tie outside of containment below the Unit 1 main steam isolation valve roo _
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- Conclusions The inspectors concluded that the use of duct tape where it could interfere with valve operation. leaving parts unattended and unmarked'in
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the field, and using a valve chain to hold open a door, were poor worker practices. Workers were not sensitive to conditions that could adversely impact plant o)erations. The inspectors discussed the identified practices wit 1 the appropriate Unit Supervisor M2.2 Suporession Pool Insoection and Cleanina Scooe (62703) -
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The inspectors reviewed licensee act'ivities pertaining to the Unit 2 l suppression 3001 cleaning, desludging, and inspection conducted in '
response to 4RC Bulletin 95-02, " Unexpected Clogging of a Residual Heat Removal Pump Strainer While Operating in Suppression Pool Cooling Mode." Observations and Findingji In response to NRC bulletin 95-02, the licensee committed to clean the !
suppression pool during the current Unit 2 refueling outage. The licensee inspected the emergency core cooling system (ECCS) suction strainers to determine the as-found condition of the strainers before commencing cleaning activities. The inspection was performed by a diver and recorded on videotape. The inspectors viewed the videotape and noted that the ECCS strainers appeared to be free of debris with the exce) tion of a small amount of foreign material (less than one percent of t1e surface area). The foreign material, which consisted of short (less that six inches) strings that may have been _ remnants of duct tape, was easily removed by the divers. In the videotape, the diver pointed _
out the silt layer on the bottom of the pool and identified small pieces of foreign material in the silt, such as silicon caulk. wire tie wraps, and a beverage can lid. More debris, such as a three foot by three foot rubber mat and a three foot by three foot sheet of gasket material, were discovered under the silt layer during cleaning and desludging activitie The licensee also inspected the downcomers in the suppression pool for the presence of debris and found a six foot by four foot nylon ba The licensee concluded that under design basis accident conditions involving a blowdown of the drywell into the suppression pool, the foreign material could have migrated to the ECCS suction strainers resulting in blockage of greater than 50 percent of the surface area causing a Jotential loss of net positive suction head to the ECCS pumps; Based on t11s determination, the licensee initiated a 10 CFR Part 50.72 notification on October 16, 1996, for a condition discovered while .
shutdown that could have resulted in the plant being outside the design '
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Conclusions The inspectors concluded that the suppression pool cleaning and ,
desludging efforts were thorough and the initiative to inspect the downcomers was good. The licensee plans to perform further engineering analysis to determine the full impact of the foreign material on ECCS operability. This issue is considered an unresolved item (50-374/96013-04) pending NRC review of the licensee's analysis and the adequacy of the licensee's previous actions to ensure suppression pool cleanlines M3 Maintenance Procedures and Documentation M Inadeauate Procedure Caused Confusion Durina Freeze S'eal a. Insoection Scoce (62703)
The inspectors observed workers establishing a freeze seal for valve .
actuator maintenance and reviewed LaSalle Maintenance :
Procedure LMP-GM-14. "Use of Freeze Jackets," Revision 4. dated July i 1992. The inspectors also discussed the work activity and the with the involved Maintenance Department first line supervisor, procedure b. Observations and Findinas On October 10, the inspectors observed maintenance workers using LMP-GM-14 to establish a freeze seal on the Unit 2. Division 3 EDG cooling water strainer backwash line. The evolution involved the use of a freeze jacket which circulated liquid nitrogen to freeze the water in the pipe. Workers used two thermocouples at different locations (one upstream and one downstream of the freeze seal) to measure the temperature of the pip One of the thermocouples was not functioning 3roperly which caused a large difference in thermocouple readings. T1e workers reviewed the procedure to determine the minimum allowable freeze seal temperature limit such that the material properties of the piping would not be challenge Procedure LMP-GM-14 did not provide any guidance on freeze seal temperature limits to protect the piping integrity. The licensee delayed the work evolution to pursue adding a clarification to the work-package. The inspectors determined that procedure LMP-GM-14 was inadequate for the circumstances in that it did not specify a lower temperature limit for the freeze seal. This is considered an example of '
a violation of 10 CFR Part 50. Ap)endix B, Criterion V (50-373/96013-05a: 50-374/96013-05a), as descr13ed in the attached Notice of Violatio The inspectors were also concerned that a maintenance supervisor was communicating incorrect procedural adherence expectations to workers. A first line maintenance su3ervisor walked by while the workers were reviewing procedure LMP-Gi-14. The supervisor attempted to resolve the workers' questions by walking the workers through the procedure and
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explaining the basis and intent of the procedure, rather than a encouraging them to initiate a ]rocedure change. This issue was j discussed extensively between t1e involved workers and their supervisor.
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The inspectors also noted that the first line supervisor asked them how to interpret the procedure. The inspectors explained to the supervisor
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j that becoming involved in licensee activities was not appro)riate unless there was an immediate safety concern. The maintenance worcer agreed to
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proceed if acceptable to the NRC inspectors. Again, the inspectors j
explained the need for NRC inspectors to remain independent of licensee
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4 Conclusions The workers establishing a freeze seal on an EDG cooling water line l j
demonstrated a good cuestioning attitude in identifying that the >
} governing procedure cid not contain the required information. Howeve the maintenance first line su)ervisor attempted to resolve the problem
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- work package clarification or procedure revision. Eventually, a work i i
package clarification was obtained after maintenance management became
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I M3.2 Post-Maintenance Testina (PMT) Review (62703)
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The inspectors reviewed completed containment isolation valve work
' packages to determine the scope of work and the adequacy of post-maintenance testing (PMT) as it related to the American Society of ,
I Mechanical Engineers in-service testing requirement The inspectors reviewed the completed work packages for the following valves:
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2RE024. Drywell equipment-drain inboard isolation valve
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2RE025. Drywell equipment drain outboard isolation valve
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2RF012. Drywell floor drain sump isolation valve
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2RF013. Drywell floor drain sump isolation valve The ins)ectors did not identify any problems with the PMT requirements prescri)ed in the work package M4 Maintenance Staff Knowledge and Performance M4.1 Failure to Follow a Procedure Resulted in Maintenance Rework a. Insoection Scoce (62703. 61726)
The inspectors. observed maintenance activities on the 0 EDG cooling water pump strainer and PMT which included a hydrostatic pressure tes The inspectors discussed the repair work and rework due to failed PMT with various maintenance personnel, including the Lead Work Analyst and Construction Superintenden . . .
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. Observations and Findings On October 2. tne inspectors observed the operators returning the 0 EDG cooling water strainer to service so that a hydrostatic pressure test could be performed When the essential service water system was started, licensee personnel observed excessive leakage from the shaft of the strainer backwash valve. The licensee aborted the pressure test and l directed the work analyst'to provide instructions in the work package i
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for troubleshooting the cause of the leak. Using the revised work Jackage the licensee determined that a spacer was'not installed on the l Jackwash valve shaft during reassembl .
The inspectors reviewed the original work package in detail to. determine potential causes for the leak. The workers used procedure LMP-GM-25,
" Emergency Core Cooling System Service Water Strainer Maintenance."
l Revision 4. to perform maintenance on the strainer. Step F.4.25 of this 3rocedure recuired that the workers ensure that various interfaces
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l l Jetween the crive shaft and thrust bearings in the backwash valve were i flush with each other. If these faces were not flush, the procedure directed the worker to install a spacer. The procedure did not require a sign-off for step F.4.25. The inspectors concluded that the worker either missed this step in LMP-GM-25 or made an error in performing the ste The inspectors also ident ified that the reason for the rewor specifically. the faibre to install the necessary spacer during reassembly of the strainer and backwash valve, was not well documented l in the ? work Jackage. The description of.tre work that was performed to fix the leac was vague and the rework phage did not document the as-found conditions of the strainer upon disassembl The failure tc assemble the 0 EDG cooling water strainer backwash valve in accordance with LMP-GM-25 is considered an example c. a violation of Technical Specification 6.2.A.a (50-373/96013-02b: 50-374/96013-02b). as described in the attached Notice of Violation.
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, Conclusions
The inspectors concluded that maintenance workers failed to follow a procedure in the work package when reassembling the 0 EDG cooling water strainer and backwash valve. As a result, the strainer leaked
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excessively necessitating rework. In addition, documentation in the rework package was not thorough, representing an impediment to good root cause analysi M4.2 Failure to Obtain Aoorooriate Information for Work Package Insoection Scooe (62703. 71707)
The inspectors reviewed the circumstances surrounding an error during the installation of jet ) ump plugs on Unit 2. The inspectors discussed the error with the fuel landling supervisor directly involved in the
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evolution, reviewed the associated work package, and directly observed !
the removal of the incorrectly installed jet pump plug Observations and Findinos '
. . i On October 9. fuel handlers and General Electric (GE) personnel began installing jet pump plugs on the B reactor recirculation (RR) loo Work request 940061754-01 " Install / Remove 2B Reactor Recirculation Loop !
Jet Pump Plugs to Support 678 Work " specified that jet pump plugs be installed in jet pumps 11 through 20 in accordance with the applicable drawing contained in the work package. n uring the pre-job briefing for this evolution, the fuel nandling supervnor identified that the required drawing was missing from the work packag This drawing
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identified the location of the jet pumps for each recirculation loop, The fuel handling supervisor contacted GE personnel to determine which jet Jumps were associated with the B RR 100). He also requested a copy of t1e missing drawing. However, the fuel landling supervisor decided I l
to start the work activity and install jet pump plugs without first obtaining the necessary drawing.
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The encoming crew of fuel handlers brought the required drawing to the refuel floor and noticed that jet alugs had been installed on the
l A RR loop rather than the B loop. pump At t1e time of discovery, two jet pump plugs had been installed in the A RR loop. The Shift Manager sto] ped work on the refuel floor to investigate the incident. The work paccage was also remed to facilitate removal of the two plugs installed on the A a loo The failure to install jet pump plugs in the jet pumps specified in WR 940061754-01 instructions is considered an example of a violation of 10 CFR Part 50 Ap 50-374/96013-03b),pendix B, Criterion V (50-373/96013-03b:
as described in the attached Notice of Violatio The inspectors disct.ssed this event with the involved. fuel handling supervisor, In retrospect the fuel handling supervisor agreed that he had made a poor decision to continue work without all of the required documentation available in the work packag The insSectors observed the removal of the jet ) ump plugs installed in the A R1 loop. No problems were identified wit 1 procedural adherence during this work activity. The inspectors also reviewed the work package and concluded that it was adequate. The inspectors observed
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that foreign material exclusion controls on the refuel floor were
! strictly enforced. In addition, the ins)ectors nnted that the radiation -
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! protection technician assigned to the jo) provided good support.
l Contamination was properly controlled by wiping down the refueling
- bridge after each plug had been remove .
c. Conclusions
'. The fuel handling supervisor demonstrated Joor judgement by continuing !
with the jet pump plug installation even t1ough he was aware that a '
' required dr, wing was missing from the work package.
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O M4.'3 Failure to Follow Procedure for Cutting and Weldinq j Insoection Scone (62703)
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On September 28. the licensee stop]ed all work due to a problem with an 00S and a misinterpretation of Tec1nical Specifications. These events resulted in a special NRC inspection which was documented in Inspection Report 50-373/96016; 50-374/96016. The inspectors responded to the site to ensure that the work was stopped in an orderly, safe fashion. In addi * n, the ins)ectors toured the plant and observed activities asst aed with t1e few jobs that were allowed to continue on systems important to shutdown ris j The ins)ectors observ5d welding activities on the flanges and covers of the 0 E % cooling water strainer and reviewed LAP-900-10. " Fire j J
Protection Procedure for Welding and Cutting." The inspectors discussed j their findings with the Fire Protection Group Leader Construction -
i Superintendent. and the Quality Assurance Superviso l Observations and Findinas
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On September 29, the inspectors observed a weld re) air en the 0 EDG cooling water strainer end flange and noted that t1e control of combustibles in'the vicinity of the welding activity was poo When the inspectors entered the area, the workers began picking up the obvious flammable material, including cloth rags and unnecessary electrical cords. The inspectors noted that a nylon foreign material exclusion bag and a nylon garbage bag were hung on scaffolding around the strainer and that these items were being used as a flash shield at the work site. The inspectors discussed their observations with the Fire Protection Group Leader and he agreed that the workers were not in compliance with the applicable fire protection procedure and were not i meeting the licensee's expectation for control of combustibles during welding activitie i
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LaSalle Administrative Prou Jure LAP-900-10. " Fire Protection Procedure for Welding and Cutting." Revision 16, requires that areas where cutting and welding are in 3rogress be ke3t clean and that all accumulation of trash, rags, etc. 3e removed. T1e failure of workers to keep the 0 EDG cooling water strainer area clean and to remove unnecessary material in the vicinity of the welding site, is considered a violation of Technical Specification 6.2.A.g (50-373/96013-06: 50-374/96013-06), as described in the attached Notice of Violatio The inspectors observed approximately twelve other welding activities during the ins)ection period and did not identify any problems with the
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control of comaustibles at the work site ;
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The inspectors identified that workers were not consistently adhering to required safe work practices for welding. This event also reflected l insufficient supervisorj focus considering that the welding activity was
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' one of the few jobs in progress at the time due to a plant-wide work stoppag t l III. Enaineerina l
El Conduct of Engineering El.1 Weaknesses in the Enaineerino Reau3st (ER) Process .
a. Insoection Scoce (37551)
The inspectors reviewed the engineering backlog with emphasis on the-reactor core isolation cooling (RCIC) system. .Specifically, the inspectors reviewed the status of ERs in the licensee's electronic work l
control system _(EWCS). The process for writing, prioritizing, and following up on ERs was discussed with engineering managen1en The
inspectors also discussed the ER process with several system engineers to assess.their knowledge and understanding of the process.
l b. Observations and Findinas The inspectors reviewed LAP 1300-iS. " Engineering Request " Revision which prescribes how to geaerate an ER using the EWCS. A separate procedure. LAP-1300-18, "Roadmap to Plant Design Changes," Revision defines the process after an ER has been reviewed and approve However, neither of these procedures defined the process by which ERs were reviewed, approved, and prioritize l The inspectors noted that there are 14 types of ERs defined in the subject procedures. These range from plant design change requests ,
l (PDCRs) which reauire extensive engineering work and are presented to l the licensee's Technical Review Committee (TRC) for approval, to system
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engineering assistance requests and site support engineering requests which are typically less involved and can be completed in a short time perio The licensee has an informal process for reviewing and prieritizing ERs on a weekly basis. Licensee efforts to prioritize ERs were not effective in facilitating engineering work. The licensee had 1380 ERs in d review status awaiting approval, 297 of which were PDCRs. N ny of the outstanding ERs were generated in 1994 and 1995 and had not yet been
, reviewed. During interviews, several system engineers stated that the
ER process was vague and that it was not clear who had responsibility L for processing design changes such that a presentation could be made to
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the TRC. Based on the large number and age of ERs in a review status and the results of interviews with various system engineers, the i inspectors concluded that the ER process was ineffectiv '
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The ineffectiveness of the ER process was evident in the licensee's followup to the 1994 RCIC rupture disc event. The team that investigated the event recommended the following three actions:
(1) Consider installation of a RCIC turbine remote trip device near the RCIC room exit. (2) Relocate the RCIC exhaust pressure trip sensors, and (3) Upgrade the RCIC drain line piping to stainless steel. On July 3, 1995, the responsible system engineer wrote an ER for installation of a remote RCIC turbine trip device at the RCIC room exits. The ER was reviewed by site engineering personnel who subsequently requested that the system engineer submit the request to the TRC, However, before the ER could be presented to the TRC, a design had to be specified.-cost
" estimates generated, and alternative solutions developed. Design engineering support for this additional work was not 3rovided and consequently, no action has been initiated for this El which remained in a review statu .
Regarding the recommendation to relocate the RCIC exhaust pressure trip sensors, the responsible system engineer wrote an ER which was presented to the TRC and subsequently approved. However, implementation of the design change package was not scheduled. The inspectors considered this an example of the lack of prioritization for pending design change Regarding the recommendation to upgrade the drain line piping to stainless steel, the responsible system engineer wrote an ER for a plant design change. Although this was a plant design change, this ER was approved without +he involvement of the TRC. The ins 3ectors noted that some ERs were app oved "on the spot." indicative of t1e informality of the ER proces Other deficiencies in im]lementing corrective actions from the 1994 RCIC rupture disk event, whic1 contributed to a similar event in August 199 are discussed in Section E2.2 of this repor c. Conclusions The inspectors concluded that the licensee did not have a formal, proceduralized )rocess for the review, approval, and prioritization of ERs. and that t1e informal processes being used were inconsistent and ineffective in ensuring the timely completion of engineering work. The failure of LAP-1300-16 and LAP-1300-18 to provide adequate controls for engineering work is considered an example of a violation of 10 CFR 5 Appendix B, Criterion V (50-373/96013-5b: 50-374-96013-05b), as described in the attached Notice of Violatio . - ~- . .. . - _ .. .. ._- -
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0 E2 Engineering Support of Facilities and Equipment '
l E2.1 Auxiliary Electrical Eauioment Room (AEER) Habitability Not Evaluated for Plant Modification i
a. 'Insnection ScoDe (37551. 92903) l
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On October 10 the licensee discovered a condition while shutdown that ;
could have resulted in Unit 1 being in an unanalyzed condition while at '
]ower. The licensee did not evaluate the dose consequences in the AEER Jefore modifying the plant by removing the main steam isolation valve ,
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.(MSIV) leakage control system. The inspectors reviewed this licensee finding to determine if the licensee had properly bounded the scope of 4 the conditio I Observations and Findinas The licensee identified the unanalyzed condition while preparing evaluations for removal of the MSIV leakage control system from Unit 2 during the current refueling outage. The licensee determined that dose consequences to operators-in the AEER following an accident had not been addressed for the same design change already completed on Unit As specified in Section 6,4 of the Final Safety Analysis Re) ort (FSAR),
the AEER has a ventilation system designed to ensure that t1e room is habitable during all normal and abnormal conditions including accident conditions. The system is designed to filter incoming air to reduce !
radioactive material and other contaminants and to maintain a positive '
pressure in the AEER of 1/8 inch H 0 column relative to the pressure in surrounding areas. TheUnit1.MSiVleakagecontrolsystemwasremoved ,
from service in March 1996. This modification affected the l post-accident dose rates to personnel in the AEER. The licensee had not determined the magnitude of the dose increase and therefore concluded that Unit 1 was in an unanalyzed condition during power operations subsequent to the modificatio Based on a review of Technical Specification requirements, the licensee concluded that there was no requirement to periodically test the capability of the AEER ventilation systen, to maintain the FSAR specified positive pressure of 1/8 inch H O 2 column. However, the licensee was not able to provide the inspectors with the results of a test that confirmed that the AEER ventilation system could establish the pressure specified in the FSA The licensee conducted a walkdown of the AEER and discovered two doorways where air flowed into the room. In this condition, the AEER was not at a pressure greater than the surrounding area. The flow of air into the room did not pose an immediate safety concern because both units were in cold shutdow The inspectors cuestioned the licensee about the lack of testing and operating procecures to ensure that the AEER was being maintained within
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I the design basis. The licensee planned to calculate the dose consequences resulting from the removal of the MSIV leakage control system and perform testing to determine if the AEER could be pressurized to the appropriate design level specified in the FSA . . Conclusions lhe inspectors concluded that the licensee may have operated both Unit 1 and Unit 2 outside of the original design basis since the plant was initially licensed, due to the potential inability of the respective AEERs to remain habitable following a design basis accident. This issue is considered an unresolved item (50-373/96013-07: 50-374-96013-07)
pending further NRC review of the licensee's dose calculations and.the results of additional AEER ventilation system testin E2.2 Inadeouate Corrective Action for RCIC Ruoture Disc Event Inspection Scone (37551)
Following the August 19, 1996, RCIC rupture disk event, which is described in NRC Inspection Report 50-373/96010; 50-374/96010, the '
inspectore m oleted a comprehensive review of licensee activities associatw with operation of this system. The inspectors reviewed several licensee evaluations of the RCIC system. ERs, and corrective action items tracked via the licensee's nuclear tracking system. Many of these actions had been initiated following a similar 1994 RCIC rupture disc even The inspectors reviewed the following RCIC system evaluations performed by the licensee:
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" Recommendations Report for LaSalle RCIC Systems." dated December 16, 1992, performed by GE
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" Report of RCIC Rupture Disc Investigation Team," dated March 17, 1994
" Independent Safety Engineering Group Review of RCIC Systems,"
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(OVL 01-94-087). dated September 30, 1994 Observations and Findings Although RCIC system im)rovements and actions were identified in licensee assessments, t1e licensee did not consistently implement recommended corrective actions. While some corrective actions were implemented. several were no Lack of Comorehensive Imarovement Plan One of the corrective actions recommended by the licensee following the 1994 RCIC rupture disk event was to:
" Prepare a comprehensive RCIC improvement program which encompasses the findings from this investigation, the Quad Cities
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6/9/93 event. INP0 assist visit of January 1994, and the December 1992 GE repor This overall program for both units should mandate specific due dates that shall be met. Assure appropriate resources are provided to ensure the end result is a RCIC system that meets the standards of the Site Vice President anJ Station Manager."
The licensee never developed or im31emented this pla An Action Item Record (AIR) was issued to track tlis corrective action item with an original assigned completion date of October 3. 1994. The followin series of due date extensions were granted by Regulatory Assurance:g
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Extension to December 31, 1994 - SQV personnel were performing an audit'and the cognizant individuals wanted to include the audit findings in the RCIC improvement progra .
Extension to June 15. 1995 - The system engineer responded to the AIR on December 21, 1994, and stated that improvement items from many sources, including the SQV report, were being tracked for RCIC system im)rovements. The system engineer requested the
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extension on t1e AIR to continue to track the RCIC improvement .
Extension to January 2.1996 - The status of the item was reviewed on May 31, 1995, and another extension grante The licensee closed the AIR on January 5, 1996, although the licensee had not taken the action originally s3ecified in the subject AIR. While the responsible system engineer was a]le to track and facilitate some improvements to the RCIC system, a formalized plan with buy in from all departments was not develope Due to the implementation of some system improvements and increased system availability, the RCIC system did not receive licensee management's attention. The system engineer lacked the management support needed to complete additional system improvement Failure to Install Drain Line Tao and Procedurally Check for Water An AIR had been generated following the 1994 RCIC rupture disk event to evaluate the need for either a modification such as adding a sight glass to the drain line, or developing another suitable method for verifying that water was not present in the RCIC drain pot. In the AIR response dated August 17. 1994, the licensee proposed that flanges be installed in the connecting drain line and that a tap with isolation valves be installed in the line between the flanges for flushing the exhaust line drain pot. In the AIR response, the licensee also proposed implementing i
a periodic surveillance requirement to ins 3ect and flush the drain lines l every outage. A note was included at the 30ttom of the AIR response stating that drain pot taps would be available for water checks. In !
September 1994. SOV personnel performed an audit. OVL 01-94-087, and
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reviewed the proposed corrective actions included in the subject AIR l response. In addition to these corrective actions. SOV personnel recommended that the licensee generate a procedure that required
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'. monitoring of the system for water accumulation before each run of the RCIC pump The licensee's failure to implement corrective actions to address the accumulation of water in the RCIC exhaust line drain pot following the 1994 rupture disc event, was a contributing cause for the August 1996 event. The modification involving the installation of drain line taps was completed on Unit 2 during the February 1995 refueling outage. The modification was scheduled to be installed in the Unit 1 RCIC system during the January 1996 refueling outage, however, the modification was not initiated. The RCIC system engineer did not know why this modification had been deferred. The recommendation from the SQV audit to implement a procedure for monitoring water accumulation before RCIC.,
pump runs was also never acted on. If the licensee had implemented these recommendations, the accumulation of water in the drain pot may ;
have been identified and consequently the August 1996 rupture disc event prevente l The failure to take appropriate corrective action to preclude recurrence of a rupture disc event is considered an apparent violation of 10 CFR l i
Part 50. Appendix B, Criterion XVI (50-373/96013-08). !
Lack of Timely Corrective Actions and Root Cause Evaluation for the 1996 Ruoture Disc Event Licensee implementation of corrective actions to address RCIC ru ture disk failures following the 1996 event continued to be slow and acked management involvemen l l
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During discussion of the August 28, 1996, event at the Plant '
Operations Review Committee meeting, the root cause evaluation team committed to issue their final report within two weeks of the meeting. As of the end of this inspection period, the subject report had not been issue .
As with the 1994 event one of the recommended corrective actions follow ~ng the 1996 event was to periodically check for water accumuiation in the drain pot. The licensee wrote a procedure to accomplish this, however, engineering personnel made an error in calculating how much water should be expected to accumulate in the drain pot. In an ER written on September 2, 1995, engineering personnel were asked to perform another calculation by September 15, 1995. However, this calculation had not been completed as of the end of this inspection perio .
The licensee also determined that over-torquing of the rupture discs during periodic replacement may have been a contributing cause of the event. Maintenance personnel noted that the discs were " wrinkling" during the torquing evolution and questioned whether the work )rocedure contained the correct torque values:
After reviewing t1e specified torque values and contacting the vendor, the licensee concluded that the torque values were too
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high and may have caused damage to the rupture disc The licensee decided to send the Unit 2 rupture discs offsite for testing to quantify the affect of over-torquing. The inspectors noted that this action was also progressing slowl ;
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. . l Conclusions '
The inspectors concluded that the licensee failed to implement adequate
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corrective actions following the 1994 RCIC system rupture disc event, and as a result, a similar event occurred on August 28, 1996. The licensee also did not implement other corrective actions in a timely manner, although these were not directly related to the RCIC rupture
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disc event. Recommended corrective actions following the 1996 event were also not being implemented in a timely manner. Weaknesses in the
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l licensee's ER process, as described in Section E1.1 of this repor ;
along with insufficient licersee management attention for continued i
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system improvements, also contributed to inadequate implementation of corrective action E8 Miscellaneous Engineering Issues l
E (Closed) Unresolved Item 50-374/96010-02(DRP): This item is discussed in Section E2.2 of this report. The inspectors determined that the I licensee did not take adequate corrective action for a previously '
identified problem. This item is close E8.2 (Closed) Inspector Followuo Item 50-373/374-96005-02(DRP): Lack of preventive maintenance for full core display air filter ;
This followup item involved review of the preventive maintenance activity intended to prevent heat-related problems with the full core display due to clogged air filters. The licensee discussed the condition with the vendor and determined that an annual replacement of the air filters was appropriat The inspectors verified that the licensee had developed a preventive maintenance procedure and schedul This item is close IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Decline in Radworker Performance Insoection Scone (71750)
The inspectors evaluated radworker practices while observing maintenance, engineering, and operations personnel in tne radiological protected area. The inspectors discussed their observations with radiation protection managemen !
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rL k Observations and Findinas
The inspectors noted several instances of poor radworker performance:
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On October 7. the inspectors identified that various hoses crossing a contaminated area boundary in the 2D heater drain (HD) l
pump room were not secured. The licensee corrected the condition.
however, on October 11. the inspectors again identified hoses breaching a contaminated area boundary in the 2A HD pump room that were not taped or secured, t
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On October 10. the inspectors observed that a maintenance worker was not wearing required protective clothing while in a I
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contaminated area. The worker was wearing rubber gloves and rubber shoe covers but did have on cloth gloves or cloth shoc p covers.
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The inspectors observed personnel loitering in relatively high dose rate areas and a worker kneeling in a contaminated area while wearing only minimal protection clothing.
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The inspectors identified several instances of poor contaminated
- area boundary control. For example, the contaminated area outside
! the outboard MSlv room in the reactor building was disorganized and contained a large amount of contaminated material in a small contaminated area. As a result, contaminated equipment was crossing the contaminated area boundary.
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The licensee also identified additional examples of poor radworker performance practices similar to those identified by the
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' LaSalle Radiation Procedure LRP-1490-1. " Construction of Radiologically Posted Areas and Step Off Pad Areas," Revision 13. dated ,
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l January 12. ,1996. Step F.2.d. recuires that hoses, electrical cord etc. , which breach a contaminatec area boundary, be taped or tied
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securely, or otherwise be secured where they exit the area. The
! condition of unsecured hoses crossing the contaminated area boundary in i the 2A and 2D HD pump rooms is considered an example of a violation of i~
Technical Specification 6.2.B (50-373/96013-09a; 50-374/96013-09a), as described in the attached Notice of Violatio ;
i LaSalle Radiation Procedure LRP-1410-2. " Minimal Protective Clothing."
Revision 7. dated June 23. 1994. Step F.2. requires that minimal i protective clothing requirements include cloth and rubber shoe covers i
and cloth and rubber gloves. The failure of a maintenance worker to
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wear the required minimal protective clothing in a contaminated area is
! considered an example of a violation of Technical Specification 6. (50-373/96013-09b; 50-374/96013-09b) as described in the attached Notice of Violatio . . .--. - --~.--.- -._-.-.._-.-.--..-.-.- -, . . . . - .-
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f , Conclusions
The inspectors concluded that radworker performance and radiological i
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housekeeping standards had declined. Historically, radworker performance has been mixed with impr.oved per.formance being a function of
the degree of management involvement. The inspectors were concerned L that actions taken by the licensee to address problems with radworker practices and radiological housekeeping conditions, were not sufficient l
to ensure long-term and consistently good performance in these area '
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V. Manaoement Meetinas Exit Meeting Summary
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The inspectors presented the results of their inspection activities to licensee management at an exit meeting on October 25, 1996. The
inspectors further discussed the results of their inspection related to
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the August 28. 1996. RCIC system ~ rupture disc event at an inspection l
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exit meeting on December 13. 1996. The licensee acknowledged the findings presente ~
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The inspectors asked the licensee if any materials examined during the j inspection period should be considered proprietary. No proprietary L information was identified.
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[ PARTIAL LIST OF PERSONS CONTACTED p Comed
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j * Subalusky, Site.Vice President
- *0. Ray. Station Manager '
- *L. Guthrie, Operations Manager
- A. Magnafici. Acting Maintenance Superintendent
! *A. Javorik. System Engineering Supervisor
- D. Boone. Health Physics Supervisor
, *R. Crawford Work Control Superintendent
[ *J. Burns. Regulatory Assurance Supervisor
- Pr'esent at exit meeting on October 25. 1996.
4 INSPECTION PROCEDURES 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 93702 Prompt Onsite Response to Events at Operating Power Reactors' ;
IP-92903- Followup - Engineering i l
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ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-374/96013.01 URI Review of spurious RWCU isolations 50-373/374-96013-02a VIO Failure to follow shutdown procedure 50-373/374-96013-02b VIO Failure to follow maintenance procedure 50-373/374-96013-03a VIO Failure to follow out-of-service instructions 50-373/374-96013-02 VIO Failure to follow work request instructions 50-374/96013-04 URI Review of ECCS operability in response to strainer clogging 50-373/374-96013-05a VIO Inadequate freeze seal 3rocedure -
50-373/374-96013-05b VIO Inadequate Engineering Request process 50-373/374-96013-06 VIO Failure to follow fire protection pr'ocedure 50-373/374-96013-07 URI Review AEER dose calculations and ventilation testing 50-373/96013-08 EEI Failure to take corrective action for 1994 RCIC rupture disc event 50-373/374-96013-09a VIO Failure to follow RP 3rocedures for taping hoses across contamination Joundary 50-373/374-96013-09b VIO Failure to follow RP procedures by not wearing appropriate protective clothing Closed 50-373/374-96005-02 IFI Lack of preventive maintenance of ' full core display air filters 50-374/96010-02 URI Followup of RCIC rupture disc event corrective actions
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a I LIST OF ACRONYMS USED AEER Auxiliary Electric Equipment Room AIR . Action Item Record ALAPA As Low As Reasonably Achievable - -
DRP Division of Reactor Projects-ECCS Emergency Core Cooling System-EDG Emergency Diesel Generator E0 Equipment Operator i ER Engineering Request l ESC Events Screening Committee EWCS Electronic Work Control System FSAR Final Safety Analysis Report 4 FME Foreign Material. Exclusion I GE General Electric HD Heater Drain IDNS Illinois Department of Nuclear Safety INP0 -Institute for Nuclear Power Operations IR Inspection Report IFI Inspection Follow-up Item LAP LaSalle Administrative Procedure LCO Limiting Condition for Operation LER Licensee Event Report LGP LaSalle General Procedure LIS LaSalle Instrument Surveillance l LMP LaSalle Maintenance Procedure LOP LaSalle Operating Procedure LRP LaSalle Radiation Procedure MSIV Main Steam Isolation Valve-MDRFP Motor-Driven Reactor Feedwater Pump NRC Nuclear Regulatory Commission 00S Out-of-service PDCR Plant Design Change Request'
PIF Problem Identification Form PMT Post-Maintenance Testing PDR NRC Public Document Room RCIC Reactor Core Isolation Cooling RP Radiation Protection
'RR- Reactor Recirculation RWCU Reactor Water Cleanup SOV Site Quality Verification TRC Technical Review Committee i URI Unresolved Item '
VIO - Violation WR- Work Request
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