ML20214E127

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Forwards Addl Info Re Plans & Programs to Upgrade Station Activities in Response to 860218 Request.Planned Actions Stated Are Formal Commitments,Not Goals & Expectations
ML20214E127
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 02/28/1986
From: Reed C
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1350K, NUDOCS 8603070132
Download: ML20214E127 (8)


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/^N Commonwealth Edison

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Address Reply to. Post Office Box 767

. Chicago. Illinois 60690 February 28, 1986 ?RIORITYRouTIigg

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Mr. James G. Keppler 01'NS h,r.h mr -

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Regional Administrator '-

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U.S. Nuclear Regulatory Commission MM 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

LaSalle County Station Units 1 & 2 Additional Information Regarding Plans and Programs to Upgrade Station Activities NRC Docket Nos. 50-373 and 50-374 Reference (a): C. Reed letter to J.G. Keppler dated February 4, 1986 (b): J. G. Keppler letter to C. Reed dated November 22, 1985

Dear Mr. Keppler:

Pclerence (a) transmitted Commonwealth Edison's response to your request for information, Reference (b), pursuant to 10CFR50.54(f), regarding Region III concerns involving the control of station activities at LaSalle County Station. Our response contained numerous commitments regarding station activities including many plans and programs to improve the station's control of work both prior to Unit 1 start-up and long term.

In a meeting with you and your staff on February 18, 1986 a number of questions were raised regarding our response. The purpose of this letter is to answer those questions. The Attachment to this letter addresses your concerns and should provide the necessary information to resolve the issues.

We believe this transmittal will satisfactorily answer all your questions regarding our 10 CFR50.54(f) response.

Very truly yours, M 9 $Lo,-J Cordell Reed Vice President

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S ATTACHMENT ISSUE: The olanned actions stated in our letter appear to be aoals/ expectations instead of formal commitments.

The planned actions stated in our letter are formal commitments. We believe the measures and actions make-up an aggressive, comprehensive program to improve station performance. We assure you that the described actions are being aggressively pursued. We would like to restate, however, that future reviews of these comunitments may reveal the necessity to make changes. If such-changes do become necessary, they will be reviewed with you or your staff for acceptability. To ensure a clear understanding of the commitments made to reduce the backlog of existing work, we have provided a list below:

Area of Concern Commitment Date

1. Non-outage Work Request Reduce backlog to 1400 Prior to Unit 2 Backlog Fall Refuel
2. SR, ASME, reliability- Reduce backlog to 300 Prior to Unit I related Work Request Backlog restart
3. Control Room Annuniciators Establish "blackpanel" One month after Unit 1 attaining full power
4. Control Room Work Request Reduce backlog to 20 Prior to Unit 1 restart Begin work next working day Completed No backlog relating to Prior to indicators / alarms used as: Unit 1

- degradation of reactor coolant press. boundary,

- initial condition in DRA anal.,

- pri indication of ECCS avail.

5. Modifications complete 82 Unit 1 outage Prior to Unit I related mods, startup.

Complete 22 high priority December 1986 non-outage related mods.

cont'd.

Area of Concern Commitment Date

6. Procedure changes Reduce backlog to 450 Prior to Unit 1 startup
7. On-site review Complete review to Prior to Unit 1 justify safe unit stkatup p'.artup ISSUE: Role of the Nuclear Safety Department Offsite Review function as related to the LaSalle County Unit I startup.

Offsite Review's normal duties require approval of safety evaluations for safety-related modifications, procedures, special tests and experiments and changes to technical specifications. LaSalle County Station also has a technical specification required Onsite Nuclear Safety Group (ONSG) of four personnel that perform the independent assessment of operational safety as required by NUREG-0731. Due to the problems experienced with the modification program in early 1985 at LaSalle County Station the ONSG has focused more effort on in-plant inspection of work in progress. This effort was implemented at both LaSalle and Byron in the summer of 1985. Since the present LaSalle Unit 1 outage represents the first major refueling outage at the Station, the Nuclear Safety Department will participate in the Onsite Review meeting concerning the readiness of the unit to return to service. In addition to this Nuclear Safety Department personnel including members of the ONSG will review the safety-related modifications performed during the outage and more importantly, verify that the existing management controls for modifications are adequate. The specific controls to be reviewed include the first and second level review programs implemented to provide reasonable assurance that modifications are installed, tested, documented and placed in service according to station procedures. In addition Nuclear Safety Department personnel will verify that the personnel assigned to perform modification work clearly understand the program and their responsibilities.

ISSUE: Rationale for not having procedure changes. associated with modifications.

completed prior to declaring the equipment operable.

Procedure revisions associated with modifications are classified by the cognizant sngineer as required or not required, prior to declaring the equipment operable in secordance with LAP 1300-2, " Plant Modifications". This designation is reviewed by 1 the Technical Staff Supervisor and an Operating Engineer during the modification l cpproval process. Any procedure revision which impacts on the operation of the squipment or which has reasonable potential for confusing or misleading personnel -

using the procedure is required prior to declaring the equipment operable.

Procedure revisions not required prior to declaring the equipment operable are ccheduled for completion within 30 days of modification completion.  !

Examples of procedure revisions not required prior to declaring the equipment operable are as follows:

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1. Surveillance procedures for surveillances that will not be performed within 30 days.
2. Revisions to Hathaway Alarm Typer Point numbers which do not change the print-out message.
3. Removal of a precaution that is no longer necessary but which has no potential for causing an incorrect action.

ISSUE: If the Majority of Safety-Related. ASME Code-related and reliability-related work requests are typified as repair / return to storeroom, weld repairs on non-safety systems and other work not impacting safety, how are the remainder of the work requests typified.

Typical examples of work requests included in the 300 Code, Safety and reliability work requests which will not be completed prior to Unit 1 startup are as follows:

Circuit board repairs which will be returned to stores; welding jobs on plant cquipment, reactor water cleanap valve repair work requests awaiting parts delivery, spare control rod drive rebuild work requests, rebuild work requests for various ITT damper actuators throughout the plant, rebuild work requests for valve motors and limitorques being returned to Stores, various work requests for fire protection in out building warehouses and solenoid valve repairs for return to Stores. All 300 outstanding work requested are typified above. There is not a remaining number of work requests in other categories. The statement in our letter used the term " majority". It could have said "all". In summary, 45 percent of the cubject work requests are repairs for return to Stores, 40 percent are welding jobs cnd 15 percent are Safety related or Code work requests which are not critical to plant operation, i.e.

1) ASCO valve repair for spares,
2) Fuel pool clean up valve packing and actuator repairs,
3) Water tight door improvement / awaiting parts,
4) Control Rod Drive rebuilds (spares).
5) RHR vent valve local indication,
6) Rebuild ventilation damper actuators.

ISSUE: Completion of High Priority Hodifications extend through end of 1986.

The "high" priority classification was assigned to these modifications to indicate that they should be scheduled for completion before those modifications classified in the " medium" or " low" priority classifications. The following list summarizes the scope and the expected installation schedule for the twenty-two "high" priority modifications. Eight of the twenty-two modifications are classified as

cafety-related because at least a portion of the modification pertains to cafety-related structures or components. None of these modifications represents a cafety concern.

1. 1-0-81-025; This modification installs a time delay relay in the pump auto start circuitry for the Security Diesel Generator Day Tank Makeup Pump. This modification is non-safety related. It will provide an alarm only when the makeup pump fails to start or restore day tank level in lieu of the current arrangement which causes an alarm every time the pump starts.

Scheduled Installation: October 1986

2. 1-0-82-121; This modification provides in place backwash capability for Condensate Polisher strainer OCP01M. It is non-safety related and eliminates a repetitive maintenance problem.

Scheduled Installation: October 1986

3. 1-0-83-019; This modification provides a method for draining water that accumulates inside the curbing surrounding the Electrode Boilers. It is non-safety related and eliminates a recurring housekeeping problem. INPO concern.

Scheduled Installation: May 1986 (75% complete)

4. 1-0-83-022; This modification moves the Radwaste Discharge Process Radiation Monitor Skid from the Valve House to the Turbine Building. This modification is safety related. It will eliminate past problems with freezing of the sample lines and a potential contamination problem in the Valve House (Offsite Area).

Scheduled Installation: May 1986 (95% complete).

5. 1-0-84-005; This modification provides permanent heat tracing for the stack i isokinetic probe. It is non-safety related and is intended to replace the current temporary heat tracing. The current temporary arrangement works well and has eliminated the freezing problems experienced with this line in past winters.

Scheduled Installation: May 1986 4

6. 1-0-84-058; This modification revises the water /cludge interface r instrumentation on several Radwaste vessels. It is non-safety related. The current instrumentation has performed very poorly and has resulted in tank overflows and large area contaminations.

Scheduled Installation: December 1986 (tentative)

This is a major job. An exact date for completion cannot be determined at this time.

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7. 1-0-84-060, 1-0-85-011, 1-0-85-014; These modifications concern ... j installation of the Interim Radwaste Storage' Facility (IRSF). i They are all non-safety related. l Scheduled Installation: August 1986
8. 1-0-85-019, 1-0-85-020; These modifications provide for installation of

-additional Chlorine detectors, replacement of existing Chlorine detectors with a more reliable model and modification of the '

trip logic for initiation of the Control Room Ventilation System Emergency pressurization Mode to tolerate a single failure or spurious signal. They are safety related. These modifications represent a backup contingency plan in the event the Technical Specification change to remove these detectors is not approved.

Modifications are expected to significantly reduce unnecessary ESF actuations.

Scheduled Installation: July 1986 or as soon thereafter as possible if the modification proves necessary.

9. 1-0-86-001; This modification provides for replacement of the low oil pressure switches on the Auxiliary Electric Equipment Room Ventilation System compressors. It is safety related. The current model switch is no longer manufactured.

Scheduled Installation: July 1986

10. 1-0-86-002; This modification provides for installation of local audible alarms on High Radiation Doors. It is non-safety related. It is expected to assist in resolving LaSalle's problem with respect to High Radiation Doors being inadvertently left open or unlocked.

Scheduled Installation: June 1986

11. 1-1-82-249; This modification adds a time delay for the alarm on the-watertight door to the Unit 1 Residual Heat Removal Service Water pump room. It is non-safety related and provides for elimination of a nuisance alarm.

Schedule Installation: March 1986

12. 1-1-83-088; This modification provides for revision to the Control Room Breathing Air System. It is non-safety related. The current isolation valves are prone to leakage and isolation valves are not provided for individual bottles. The modified arrangement will make the system much easier to maintain.

Scheduled Installation: September 1986

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13. 1-1-84-108; This modification provides for installation of a larger strut assembly on a Service Water line that is experiencing vibration problems. It is non-safety related.

Scheduled Installation: June 1986

14. 1-1-85-027, 1-2-85-034; These modifications replace the Standby Gas Treatment high flow alarm switches with dual setpoint switches.

The current low flow alarm is provided for heater protection and is set too low to warn of a potential Technical Specification violation. These modifications are safety related.

Scheduled Installation: August 1986

15. 1-1-85-049; This modification revises the probe data processor so that the control rod full in light works off either the 00 or Full In reed switch. Aids the operator in determining that all rods are in following a scram. This modification is safety related.

Schedule Installation: March 1986

16. 1-2-84-078; This modification puts an instrument snubber in the sensing line for the Fuel Pool Cooling pump low suction pressure switch.

Currently the pump trips when started due to pressure surges.

This modification is non-safety related.

Scheduled Installation: June 1986 17 1-2-84-187; This modification changes the Vent and Purge System flow transmitter from a Hays Republic Model 252A to a Validyne Model P232A. The current model has proven to be unreliable. This modification is non-safety related.

Scheduled Installation: June 1986

18. 1-2-86-002; This modification installs High Density Fuel Racks in the Unit 2 Fuel Pool to increase storage capaci6y. This modification is safety related.

Schedule Installation: August 1986 This date is extremely tight. If the modification cannot be installed prior to the Unit 2 refuel outage, it will be postponed to a later date. The additional storage capacity will not be required for several years.

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ISSUE: Residual Heat Removal Service Water Pumps There are fifteen (15) pump motors in the subject areas which could be subject to failures similar to those experienced with the Residual Heat Memoval (RHR) Service Water pump motors. There are eight (8) RHR Service Water pumps, five (5) Diesel Generator (DG) Cooling Water pumps, and four (4) Fuel Pool Emergency Makeup pumps located in this area. The two (2) Diesel Generator Cooling Water pump motors for i

the HPCS Diesel Generators, although located in the subject areas, are sealed j motors manufactured by General Electric and are not believed to be susceptible to j this type of failure. All motors believed to be subject to failure were

manufactured by Reliance.

1 The majority of problems experienced have been with the RHR Service Water pump motors. All eight (8) of these motors have been rewound since the construction 2

period when the potential for cement dust intrusion existed. This problem is considered resolved for these particular motors.

l With regard to the Diesel Generator Cooling Water pump motors, two of the motors susceptible to this problem have been rewound. The motor for the 2A Diesel Generator (2DG0lP) has not been rewound. This motor will be replaced with a rewound motor prior to December 1986. The long time frame for this motor is based on a 26 week delivery time for obtaining a spare motor.

I The 2A diesel generator, including the 2A diesel cooling water pump, is tested at least every 31 days in accordance with the Technical Specifications. To date, i there have been no failures of the 2A diesel cooling water pump motor (original I

motor installed).

1 i Four diesel generators are required by Tech Spec 3.8.1.1 for Unit 2 operation (0, 2A, 2B and 1A). A failure of the 2A D/G Cooling Water pump would pose no

! oignificant threat to our ability to safely shutdown Unit 1 or 2, based on:

! 1) The favorable operating history of the offsite power system and the diesel

generator, j 2) The number of available paths to the onsite power buses from the offsite sources and, i

j 3) The fact that one ESF division can safely shutdown the unit for a loss of offsite power.

We believe the probability of failure of this motor during the remainder of 1986 is 4

relatively low. Should a failure occur, the requirements of the Technical Specification action statement for an inoperable Diesel Generator will be implemented.

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