ML20140B673

Notice of Violation from Insp on 970207-0321.Violation Noted:Applicable Procedures Recommended in App a of RG 1.33,Rev 2,Feb 1978,were Not Correctly Implemented

ML20140B673
Person / Time
Site:	LaSalle
Issue date:	05/20/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20140B670	List: ML20140B663 ML20140B673 ML20140B685
References
RTR-REGGD-01.033, RTR-REGGD-1.033 50-373-97-03, 50-373-97-3, 50-374-97-03, 50-374-97-3, NUDOCS 9706060288
Download: ML20140B673 (4)

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l NOTICE OF VIOLATION Commonwealth Edison Company Dockets No. 50-373; 50-374 LaSalle County Station Licenses No. NPF-11, NPF-18 j Units 1 and 2 During an NRC inspection conducted on February 7 through March 21,1997, violations of NRC requirements were identified, in accordance with the " General

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Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

1. Technical Specification 6.2.A.a requires that applicable procedures recommended in ,

Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be established,  ;

implemented, and maintained.

Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, specifies 3 procedures for the operation and testing of the onsite emergency power sources.

Step E.13.12 of LaSalle Operating Procedure (LOP) DG-02, " Diesel Generator Startup and Operation," Revision 22, requires that the Nuclear Station Operator (NSO) make appropriate entries in Attachment E to LOP-DG-02, " Diesel Generator  !

Start and Run Log." Section 3 of Attachment E to LOP-DG-02 requires the operator to record the time that the diesel generator output breaker is closed during the test.

Step 3.12 of LaSalle Operating Surveillance (LOS) DG-M1, "O Diesel Generator

. Operability Test," Attachment A, Revision 32, requires the operator to record engine data on Attachment C2 to LOS-DG-M1 after the emergency diesel generator (EDG) has been loaded for at least one hour .QB reached thermal equilibrium (which ever time is greater). Also, the stated purpose of the procedure was to demonstrate that the O DG could be started and operated at rated load for at least 60 minutes.

Contrary to the above, the applicable procedures recommended in Appendix A of i Regulatory Guide 1.33, Revision 2, February 1978, were not correctly implemented in the following instances:

a. On March 3,1997, during testing of the 2A EDG, the NSO recorded the time that the EDG reached rated load of 2400 kw instead of the time that the EDG output breaker was closed.

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b. On February 27,1997, the 0 emergency diesel generator was tested at rated load for 56 minutes, four minutes less than the 60 minute operating time required by the procedure.

This is a Severity Level IV violation (Supplement I) (50-373/97003-01; 50-374/97003-01).

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2. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," [

requires that activities affecting quality be prescribed by deurnented procedures or instructions and that these procedures or instructions include oppropriate  :

quantitative or qualitative acceptanco criteria for determining tmt important i

activities have been satisfactorily accomplished.

.. t Contrary to the above:

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a. Step 2.c of LOS-AA-S1,."Shiftly Logs," Revision 56, Attachinent C1, dated l November 23,1996, did not include adequate acceptanu:. criteria for cooling -  :

lake level. The shiftly log procedure inappropriately lirted 701.7 feet as the '

maximum allowable lake level while the Updated Final Saf ety Analysis Report, Section 3.11.1.4.2, specified the maximum lake level as 701 feet.

b. On September 1,1995, and December 20,1996, calibration of the lake t blowdown flow instrument OFE-WL-001, an activity affecting quality, was {

performed without the use of documented instructions, procedures, or acceptance criteria appropriate for the activity. [

This is a Severity Level IV violation (Supplement 1) (50-373/97003-02; 50-  !

374/97003-02). j 1

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3. Technical Specification Surveillance Requirement 4.0.5 requires, in part, that -[

inservice testing be performed in accordance with Section XI of the American  !

l i Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code and j j applicable addenda as required by 10 CFR Part 50, Section 50.55a(g).  !

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!- 6 l The LaSalle County Station Pump and Valve Inservice Testing Program, dated [

l October ~10,1995, required that the residual heat removal (RHR) pump shutdown  !

cooling suction valve,1E12-F006A, be tested in the open direction on a quarterly [

frequency. [

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Technical Specification Surveillance Requirement 4.0.2 requires that each i surveillance requirement be performed within the specified surveillance interval with i a maximum allowable extension not to exceed 25 percent of the specified interval. (

Technical Specification Surveillance Requirement 4.0.5.c states,in part, the  !

provisions of Specification 4.0.2 are applicable to the required frequencies for performing inservice testing activities." {

t Contrary to the above, on February 28,1997, the licensee identified that testing of  ;

the HHR pump shutdown cooling suction valve,1E12-FOO6A, was previously i performed on October 10,1996, and was not performed again until March 29,  !

1997, which exceeded the required quarterly test interval plus 25 percent maximum allowable extension.

This is a Severity Level IV violation (Supplement 1) (50-373/97003-03).

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a Notice of Violation  !

4. Technical Specification Surveillance Requirements 4.5.2.1 and 4.5.1.a.2.a require, in part, that low pressure coolant injection (LPCI), Division 1, be demonstrated -  !

operable at least once per 31 days by performing a channel functional test of the i LPCI discharge line " keep filled" pressure alarm instrumentation. i i

Technical Specification Surveillance Requirement 4.0.2 requires that each  ;

surveillance requirement be performed within the specified surveillance interval with j a maximum allowable extension not to exceed 25 percent of the specified interval.

l Contrary to the above, the licensee did not test the keep filled pressure alarm ,

instrumentation within the required monthly test interval and maximum allowable extension. LaSalle Instrument Surveillance (LIS) RH-316A, " Unit 1 Residual Heat i Removal (RHR) Pump 1 A Discharge High/ Low Pressure Functional Test,"

Revision 3, which tests the keep filled alarm instrumentation, was performed on December 28,1996, and 59 days later on February 25,1997, which was not within the required monthly test interval plus 25 percent maximum allowable extension.

This is a Severity Level IV violation (Supplement 1)(50-373/97003-04).

Pursuant to the prcvisions of 10 CFR Part 2.201, Commonwealth Edison Company is hereby required to submit a written statement of explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region 111, and a copy to the NRC Resident inspector ,

at the LaSalle facility, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for violation Nos. 2,3, and 4: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that -

have been taken and the results achieved, (3) the corrective steps that will be taken to ,

avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. if an adequate reply is not received within the time specified in this Notice, an order or a Demand for information may L be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

i The NRC has concluded that information ragarding the reason for violation No.1, the f corrective actions taken and/or planned to prevent recurrence, and the date when full j

> compliance will be achieved is adequately addressed within the body of this report.

j However, you are required to submit a written statement or explanation pursuant to

10 CFR 2.201 if the description herein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as

a " Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission,

ATTN

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional a Administrator, Region lil, and a copy to the NRC Resident Inspector at the facility that is l

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Notice of Violation the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction However, if you find it necessary to include such information, you shc,uld clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal besis to support your request for withholding the information from the public.

Dated at Lisle, Illinois this 20th day of May l

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