ML20207L561

Responds to NRC Re Violations & Deviations Noted in Insp Repts 50-373/85-26 & 50-374/85-27.Corrective Actions:Special Rept Issued to Document All Temp Excursions Which Occurred During Jan 1984 - Aug 1985

ML20207L561
Person / Time
Site:	LaSalle
Issue date:	01/07/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1087K, NUDOCS 8701120231
Download: ML20207L561 (11)

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.,, . Commonwealth Edison C One First N:tionti Plaza, Chicrgo, lihnos G

• Address RIply to: Post Office Box 767 Chicago, Illinois 60690 January 7, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Cotanission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

LaSalle Cetnty Station Units 1 and 2 Response in Inspection Report Nos.

50-373/85-026 and 50-374/85-027 NRC Docket Mos. 50-373 and 50-374 Reference (a): C. J. Paperiello letter to Cordell Reed dated December 6, 1985.

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Mr. Z.

Falevits on August 12-14, 26-28, and September 3, 1985, of activities at LaSalle County Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. The Cotunonwealth Edison Company's response to the Notice of Violation is provided in Attachment A. Certain other activities appeared to be deviations from previous commitments made to the Nuclear Regulatory Conunission. The Commonwealth Edison Company's response to the Notice of Deviation is provided in Attachment B.

Commonwealth Edison disagrees with the basis for the Notice of Violation on items numbered IR 373/85-027-02 and IR 373/85-026-04; 374/85-027-04. We request you review your conclusions in light of the information provided in this report.

If you have any further questions regarding this matter, please direct them to this office.

Very t y yours, i .

I D. L. Farrar Director of Nuclear Licensing la i Attachment cc: NRC Resident Inspector - LSCS 1087K 8701120231 860107 PDR ll G

ADOCK 05000373 PDR ..

JAN 8W lf S 4 2'0l

y ATTACHMENT A ITEM OF NONCOMPLIANCE (373/85-026-01)

Technical Specification 3.7.7 (Area Temperature Monitoring) states that "The temperature of each area of Unit 1 and Unit 2 shown in Table 3.7.7-1 shall be maintained within the limits indicated in Table 3.7.7-1".

Action item for 3.7.7.a requires that with one or more areas exceeding the temperature limit (s) shown in Table 3.7.7-1 for more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, the licensee shall prepare and submit a Special Report to the Commission within the next 30 days and including an analysis to demonstrate the continued operability of the affected equipment.

Contrary to the above, the temperature limits of Table 3.7.7-1 were exceeded in the Unit 1 drywell during numerous and extended periods during 1984 and 1985 and a Special Report for these events were not submitted in a timely manner to the Commission to demonstrate the continued operability of the affected equipment.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED This violation occurred due to a misunderstanding of the reporting requirements committed to in the December 22, 1983 letter for the first fuel cycle. As soon as the misunderstanding became apparent, a special report was forwarded (DVR 1-1-85-166) to document all temperature excursions which occurred during the period January 1984 to August 1985.

The significance of this occurrence was discussed with those personnel involved with gathering and transmitting drywell temperature data to ensure that they were aware that all temperatures above 150*F in the vicinity of safety related electrical equipment were reportable occurrences.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE To prevent any further misunderstanding of reporting requirements, a formal, permanent station procedure (LTP-300-17) has been written to clearly define data gathering, handling, and reporting requirements. This procedure is approved for use and will be used for routine monitoring of drywell temperatures.

DATE OF FULL COMPLIANCE Full compliance has been achieved.

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ITEM OF WONCOMPLIANCE (374/85-027-02) 10 CFR 50, Appendix B, Criterion XIV, as implemented by

, Conunonwealth Edison company Quality Assurance Manual, Nuclear Generating I

Stations, Section 14, requires that measures be established for indicating the operating status of structures, systems, and components, such as by tagging.

4 Contrary to the above, on August 12 and 28, 1985, operator yellow i caution tags attached in September 1984 to the control room containment j monitoring recorders 2TR-CM037 and 2TR-CM038 indicated that the recorder

alarms were set at 150*F whereas calibration records indicated that these

alarms had been set at 140*F and 141*F respectively since January 26, 1984.

t l CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED

, A thorough review of calibration records on the above equipment j does not substantiate this violation. The initial calibration of the drywell high temperature alarms (LIS-CM-204) was completed on 31 January 1982 with the alarms set at 140*F and 141*F.

On March 13, 1984, Onsite Review 84-22 was initiated to approve raising the alarm set points to 150*F if necessary (Unit 2 had not yet i entered the heat up phase of start up testing). The basis for.this Onsite l Review was Unit 1 experience which nad demonstrated that the temperature i

sensors are located in a locally hot area of the drywell and would exceed o ~their alarm points well before any high temperature limits were exceeded.

l The Onsite Review was approved on March 22, 1984.

l In September of 1984 Unit 2 had proceeded through startup testing to full power. When the unit reached full power, temperature in the vicinity of these sensors was found to be 135'F to 145'F, causing the alarms to be annunciated at least'50% of the time. In order to allow the alans to

! annunciate only when temperatures higher than normal were encountered, the

alarms were raised to 150*F, in accordance with Onsite Review 84-22, under l Nuclear Work Requests as L35938 and L35939.

r During the inspection period of August 12 and 28, 1985, instrument calibration records indicate that the recorder alarm set points were 149'F

and 148.8'F. The Commonwealth Edison individual assisting the inspector was apparently in error when he stated that the current setpoints were 140*F and 141*F.

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The calibration procedure indicates that the alarms were calibrated on October 15, 1985 (18 month calibration frequency). The calibration proce-dure indicates that the alarm set points were "found" at 149'F and 148.8*F and "left" at 138.9'F and 140.5*F. When (in August) the caution cards were found by the inspector, they were properly placed to indicate that the alarms were set higher than their calibration procedure specified in accordance with LaSalle Onsite Review 84-22.

Commonwealth Edison requests that this violation be reevaluated in light of the above information.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE None required.

DATE OF FULL COMPLIANCE Not required.

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ITEN OF NONCOMPLIANC5 (373/85-026-03) 10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company (CBCo) Quality Assurance Manual, Nuclear Generating Station, Section 5, requires that activities affecting quality be performed in accordance with documented instructions and procedures of a type appropriate to the circumstances.

Contrary to the above, the following examples of failure to follow

. procedures or lack of documented procedures were identified:

a. Ceco procedure LLp 84-21: (1) Did not contain a specific time table for monitoring drywell temperatures, (2) The " checking" and

" reviewer" signatures were missing from the available drywell temperature monitoring data, (3) The drywell temperature monitoring data was submitted to S&L in a noncontrolled manner contrary to Ceco Quality procedure Q.p. No. 6-1 titled " Distribution of Design Documents," (4) Acceptance criteria for Equipment Qualification (EQ) threshold temperatures used to assure component qualified life was erroneous in that ambient rather than housing temperatures were used, and (5) Attachments A and D lacked documented evidence of site engineering review as required by the QA program, Section 6.

b. Documented procedures were not available to address corrective actions to be taken by power plant operational personnel when temperatures exceed the TS 3.7.7 limits.

c. A documented survelliance procedure requiring inspections and surveillance of piping or equipment insulation and other potential sources of increased sensible heat load, prior to closure of the drywell and return to power was not available.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The immediate corrective action, as listed below were initiated and performed until both units were shutdown. A review of temperature data taken at the station was performed with off-site engineering to verify that all required data had been transmitted.

During an exit meeting on September 3, 1985, the licensee presented a temporary temperature monitoring program. The program included (1) Weekly monitoring of all Unit 1 drywell permanent and temporary thermocouples.

(2) Daily monitoring on Unit 2 of permanent and temporary thermocouples.

(3) All data collected to be transmitted to S&L through SNED for review and evaluation of qualified life of components.

c (4) Formalization of the surveillance program to include procedures addressing: frequency of data collection; action required upon loss of a thermocouple; requirements of site review of data; method of transmittal of data to SNED and S&L; time limit for data evaluation; interface with EQ program; calibration requirements; inspection of drywell thermocouples; and other applicable requirements.

The licensee agreed to contact Region III prior to the next Unit 1 and Unit 2 shutdown and drywell entry to allow for a visual inspection of electrical components and cables by the inspector.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE

a. A permanent station procedure LTP 300-17 has beer written and approved to govern data taking, handling, and temp 0rature limits.

1) Routine performance of the procedure is scheduled as part of the station general surveillance program. The procedure includes guidelines for accelerated data gathering after startup and when higher than normal temperatures are encountered.

2) Acceptance criteria for temperature data in LTP 300-12 are based upon Technical Specification 3.7.7 and 3.6.1.7 and Environmental Qualification (E.Q.) limits as specified by off-site engineering (SNED). The acceptance criteria were reviewed and approved as part of the permanent procedure. The procedure incudos a mechanism for review and approval of changes to the acceptance criteria.

3) The procedure includes a mechanism for formal transmittal of temperature data to off-site engineering (SNgD).

4) Procedure LLP 84-21 has been allowed to expire. All data gathering is covered under procedure LIP 300-17.

5) Data taken using LTP 300-17 will be reviewed and approved as part of the general station survelliance program.

b. LTP 300-17 specifically states the actions required by Technical Specification 3.7.7 in the event a temperature in excess of 150*F or 180*F is encountered. In addition the procedure specifies required notifications and engineering evaluations to be performed if E.Q.

limits are exceeded.

c. The drywell close out procedure (LOP-DW-01) has been changed to require the Technical Staff Supervisor to sign-off that an insulation inspection either has been performed or is not required as appropriate.

DATE OF FULL COMPLTANCE Full Compliance has been achieved.

r ITEM OF WONCOMPLIANCE (373/85-026-04; 374/85-027-04) 10 CFR 50, Appendix B, Celterion IVI, as implemented by Commonwealth Edison Company Quality Assurance Manual, Nuclear Generating Stations, Section 16, requires that measures be established to assure that conditions adverse to quality such as deviations, nonconformances . . . are promptly identified and corrected.

Contrary to the above, the licensee's Station Nuclear Engineering Department (SNED) failed to respond in a prompt and responsible manner regarding their evaluation and recommendations for containment monitoring (temperature) alarm set points as recalculated and supplied by S&L. S&L submitted this data through the LaSalle plant management for SNED review and evaluation in December 1984 for Unit 1 and January 1985 for Unit 2.

Requested response dates were designated as January and February 1985; however, as of August 14, 1985, no effective action had been taken by SNED engineers to disposition this issue.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED In order to clarify the above Item of Noncompliance, we believe the second sentence of the second paragraph should read, "LaSalle plant personnel submitted modifications via Action Item Records (AIRS) for SNED review and evaluation in December 1984 for Unit 1 and January 1985 for Unit 2".

Action Item Record (AIR) dated December 3, 1984 requested SNED assistance for a modification revising the setpoints of 2 points on recorders 1TR-CM037 and ITR-CM038. This Unit 1 AIR had a requested completion date of January 2, 1985. Another AIR dated January 28, 1985 requested SNED assistance for modification revising the setpoints of 2 points of recorders 2TR-CM037 and 2TR-CN038. This Unit 2 AIR had a requested completion date of February 18, 1985.

The Unit i drywell temperature data evaluated by S&L was dated 1/2/84, 1/9/84, 1/13/84, 2/1/84, 3/22/84 and 3/27/84. The S&L analysis and recommendation was contained in a September 28, 1984 letter to the LaSalle project engineer. The S&L recommendation to SNED was to establish new alarm setpoints for recorder ITR-CN037 at 155'F and for recorder 1TR-CM038 at 145*F. SNED evaluated the recommended changes and determined that the present 140*F alarm setpoints were conservative, as compared to raising them to 145*F and 155'F and did not approve raising the Unit 1 CM alarm setpoints.

Temperature dets was being recorded for the Unit 2 drywell temperature profile with the first data taken December 26, 1984. Additional temperature data was collected for Unit 2 on January 10, 1985 and January 24, 1985.

r S&L evaluated the Unit 2 temperature data and based on their letter dated March 25, 1985, recommended the Unit 2 CM alarm setpoints be revised to 1460F and 1340F, At this time, Unit 2 had already begun an outage Which started February 27, 1985. Since the unit was in cold shutdown, SNED did not consider processing of the setpoint changes to be urgent. In addition, it was SNED's opinion that no CM alarm setpoint changes should be implemented during this time period, because of the drywell work and its effect on the resulting drywell temperature profile. The readings on which these setpoints are based would likely be affected by changes in air distribution, condition of pipe insulation and the addition of equipment.

In addition, any future changes made in the drywell would require new sets of temperature data for comparison and validation of the recommended setpoints. I Following the conclusion of the Unit 2 outage on July 21, 1985, new temperature readings were taken on 8/5/85, 8/6/85, 8/14/85, 8/23/85 and 8/28/85. Additional temperature readings were taken in the Unit 1 drywell, approximately at the same time, 8/8/85, 8/23/85 and 8/28/85, updating each unit's equipment qualification calculations for an SRV equipment area ambient temperature of 1700F, S&L's recommendation was not to revise the Unit 1 or Unit 2 CM setpoints, but to leave them unchanged at 1400F. This recommendation was addressed in S&L's October 11, 1985 letter to SNED. SNED addressed this S&L evaluation in a November 6, 1985 letter to LaSalle Station, recommending the CM alarm setpoints for both Units 1 & 2 remain unchanged at 1400F. Additionally, SNED requested that AIR's and modifications on this topic be closed.

The Unit 1 modification was cancelled November 11, 1985 and AIR was cancelled December 5,1985. The Unit 2 modification was cancelled November 11, 1985 and AIR was cancelled December 5, 1985.

CORRECTIVE ACTION TO AVOID FURTHER NONCOMPLIANCE Based on the above findings we do not feel that this item is a I

violation. It is our conclusion that SNED utilized conservative engineering judgment and the extended unit outage time to address fully the CM alarm setpoint issue, concluding and recommending to LaSalle Station that no changes were necessary, and that the associated modifications and AIR's should be cancelled.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l

1 Full compliance has been achieved.

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. o ATTACHMENT B DgVIATION (373/85-026-05)

(a) As a result of the inspection conducted August 12-14, 26-28, and September 3, 1985, the following deviation in four parts to NRC commitments contained in your LaSalle Unit 1 letter dated December 22, 1983, were identified:

1. Commitment - Page 11. Paragraph 5. " Augmented temperature monitoring will be performed...to monitor actual temperatures to assure safety-related equipment does not degrade beyond pre-defined thresholds..."

Attachment A of LAP-820-7 for procedure LLP 84-25 dated July 9, 1984, states that the reason for the special Unit 1 drywell temperature monitoring program procedure is to " provide a time table for collecting data regarding temperatures in the Unit 1 drywell thru first refuel."

Contrary to the above, monitoring of drywell temperatures using the temporary thermocouples stopped in December 1984.

2. Commitment - Page 10, Paragraph 3, "A temperature monitoring program has been defined to evaluate the results from the short term fixes."

Contrary to the above, adequate documented evaluation of the results was not available for review.

3. Commitment - Page 14. Paragraph 1.c., "Should the temperature in an area where safety related equipment is located exceed the limiting temperature on which the 18-month life is based for that equipment, for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, an analysis for continued operation will be completed within seven days or the unit will be temporarily shut down for a visual inspection and correction of the anomalous condition (s)".

Contrary to the above, such an analysis was not available for review for various periods of time when the limiting terperature was exceeded for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

4. Commitment - Annex A, Technical Specification, "The temperature monitoring program will verify that these temperature limits are correlated to Control Room CM Monitors (4).

Contrary to the above, the analysis that was provided to correlate local temperatures in the drywell to alarm setpoints on control room containment monitoring (CM) recorders was found erroneous.

n' CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED

1. Weekly monitoring of Unit 1 Drywell temperatures was initiated inunediately. The purpose of the augmented drywell temperature monitoring program stated in the 22 December 1983 letter, was four fold. When the augmented temperature monitoring program (LLP-84-25) was stopped on December 1984, Commonwealth Edison believed that all four purposes had been accomplished and that daily monitoring of six temperatures on routine surveillances was adequate to assure continued equipment operability.

In retrospect, continued performance of this program would have provided better assurance that the drywell temperature was adequately monitored.

The inspection made in August 1985 revealed that a local " hot-spot" had developed in the Unit 1 drywell which was not discovered by routine monitoring. Had the augmented program been performed, this local high temperature would have been discovered earlier.

Environmental Qualification (EQ) calculations performed based upon the temperatures (December 1984 to September 1985) encountered in the Unit 1 drywell have demonstrated that no abnormal degradation of safety related components has occurred. These calculations have been substantiated by physical inspections performed during the current refueling outage. The affects of the temperature problem have been considered in calculating the remaining qualified-life of these components.

2. A formal written evaluation of the results of "short term fixes" as described in the December 22, 1983 war not performed. The intent of this statement in the letter was to use the temperature data itself as an evaluation.

The temperatures that were recorded were compared against previous data and regulatory limits to determine if changes in air flow were required. At each available unit shutdown, adjustments were made to air flows in an attempt to shift cooling from areas with larger cooling margin to those areas needing more margin. Upon subsequent return to power, the temperature data colected would clearly show the success or failure of the changes.

4 While not all changes made were successful, this iterative approach was as a whole extremely successful. A review of the temperature data clearly shows the affect of these changes and a general leveling of the margin to tempersture limits.

3. This alleged deviation resulted from two factors:

(1) The inadequate specification of temperature limits in the December 22, 1983 letter in that the limiting temperature for the SRV solenoids was not specified as a metal temperature.

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(2) The uncertain status of the SRV solenoids as to their NUREG-0588 category. The limit specified in the December 22 letter was based upon Category I criteria.

Immediate corrective action for (1) was to contact off site engineering to insure that no confusion existed as to the source of data used to calculate current Environmental Qualification lifetimes. No confusion existed and calculated lifetimes were based upon proper data. No component was at any time exposed to conditions which would have caused the component to exceed its qualified life prior to the first refueling outage. As documented in Inspection Report 50-373/85026, 50-374/85027 the SRV solenoids have in excess of 13 years qualified life remaining at a housing

' temperature of 187'F. During 1984, clarification was received from off-site engineering (SNED) which classified the SRV solenoids as NUREG 0588 Category II.

4. The intent of this commitment was to generate on overall drywell temperature profile. This profile would then serve as a basis for selecting alarm set points for the four. safety-related drywell temperature sensors such that no safety related component could exceed a temperature limit without an alarm being received.

From the experience gained from multiple data taking and evaluation of the drywell temperatures it is apparent that the generation of an overall temperature profile is not feasible. The temperature profile changes after every outage due to changes in air distribution condition of pipe insulation and the addition of equipment. These changes are done every outage to " fine tune" the air flow distribution to achieve the maximum usage of available capacity. The station will continue to perform the temperature monitoring program as defined in LTP 300-17.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE A new procedure (LTP-300-17) is currently in use. This procedure removes all judgement and interpretation concerning when and how to monitor drywell temperature. This procedure monitors and records data from all

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permanent and temporary sensors. The procedure is scheduled to be performed i weekly by the station general surveillance program. In addition, multipoint recorders have been rented and installed to facillitate monitoring of all temporary sensors. The utilization of this procedure addresses all four parts of the deviation.

j DATE OF FULL COMPLTANCE l Full compliance of all four parts has been achieved.

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