ML20236J109
| ML20236J109 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/03/1998 |
| From: | Dacimo F COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-373-98-05, 50-373-98-5, 50-374-98-05, 50-374-98-5, NUDOCS 9807080051 | |
| Download: ML20236J109 (11) | |
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Commonwealth lihu,n Campany la%alle Generating Mation 2N)! North 21st Road Marwilles 11. 61341-9757 Tel 815-3574,761 July 3,1998 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555
Subject:
Notice of Violation, NRC Inspection Report 50-373/374-93005 LaSalle County Station, Units 1 and 2 Facility Operating License NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374
Reference:
G. E. Grant letter to O. D. Kingsley, dated June 5,1998, Transmitting NRC Inspection Report 50-373/374-98005 The enclosed Attachment A contains LaSalle County Station's response to the Notice of Violation that was transmitted in the Reference letter.
Attachment B provides the commitment (s) for this submittal.
If there are any questions or comments conceming this letter, please refer them to Harold D. Pontious, Jr., Regulatory Assurance Manager, at (815) 357-6761, extension 2383.
Respectfully, a
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Fred R. Dacimo 3
Site Vice President o
n LaSal'e County Station f
Enclosures cc:
C. A. Paperiello, Acting NRC Region 111 Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle l
D. M. Skay, Project Manager - NRR - LaSalle l
F. Niziolek, IDNS Senior Reactor Analyst i
9hb7080051900703 PDR ADOCK 05000373 i
G PDR i
_ A Unicom company
ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98005 VIOLATION: 373/374-98005-03 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, as of April 21,1998, th's licensee failed to adequately perform combustible loading calculations required by LaSalle Administrative Procedure LAP 240-6, " Temporary Alterations," Revision 36, dated August 21,1997, associated with temporary alterations 2-0030-97 and 1-0122-97 on August 12,1997, and September 26,1997, respectively. As a result, the licensee failed to identify that the approved fire protection program may have been adversely impacted.
REASON FOR VIOLATION:
Commonwealth Edison Company (Comed) agrees that for temporary alterations (TALTs) 2-0030.-97 and 1-0122-97 the combustible loading calculations, required by LaSalle Administrative Procedure LAP 240-6,
" Temporary Alterations," were not adequately performed.
An investigation identified that TALTs 2-0030-97 and 1-0122-97 were duplicated from TALT 1-012197. The engineer who prepared the Fire Protection Screening for TALT 1-0121-97 failed to determine an accurate value of combustible material per unit length of hose and then compounded
- the error by performing an inaccurate multiplication function. Additionally, the supervisor who reviewed the data failed to notice the error in the calculation. These errors are broadly characterized as inattention to detail and inadequate self-checking.
.The per unit combustible material value used for TALT 1-0121-97 was then used without additional review for the Fire Protection Screening in TALTs 2-0029-97,1-0122-97, and 2-0030-97. This caused the " Change in
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. Combustible Loading" calculation in Nuclear Engineering Procedure (NEP) 04-07 Exhibit A, Table 1, for each of the four noted TALTs, to be erroneously calculated at less than 1000 BTU per square foot. Because the calculated value was less than 1000 BTU per square foot that is procedurally required, the additional evaluation was not performed. Therefore, the actual increase in combustible loading of 1257 BTU per square foot of fire zone
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- area (actual value when calculation was performed correctly) was not evaluated.
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I ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION l
NRC INSPECTION REPORT 373/374-98005 The consequences of this incident were minimal. Comparison of combustible loading limits for the applicable fire zones to the total combustible loading in each zone, plus the incremental increase in the zone due to the hose, demonstrated that significant margin (approximately 95%)
was still available before the combustible limit would be reached. Therefore, the combustible loading limits were not challenged.
. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
An evaluation of this issue identified two additional related TALTs (1-0121-97 and 2-0029-97) with the same type combustible loading calculation error. These TALTs performed similar plant modifications for the
.1E12-F068A and 2E12-F068A residual heat removal service water isolation valves, respectively.~ These TALTs were the predecessors of
.TALTs 1-0122-97 and 2-0030-97 identified in the violation.
When the combustible loading calculation in the Fire Protection Screening for TALT 2-0030-97 was found to be in error, the calculation was corrected (which also addressed the three other TALTs) and the Fire Protection Screening revised. The revised screening was evaluated and accepted by the Fire Protection Program Coordinator. It concluded that there was no -
adverse impact to the LaSalle Station Fire Protection commitments. It was-also noted that no extended conditions existed since the four TALTs affected by the error had been removed.
Additionally, a review of all active installed TALTs was performed to determine if any had similar Fire Protection Screening issues. No active
. TALTs with Fire Protection Screenings were identified as having similar errors in the combustible loading calculation.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:
The supervisor involved in the event has been counseled and now understands the importance of reviewing calculations to ensure they are complete and accurate.
This event has been discussed in the design engineering weekly communications meeting with emphasis placed on the importance of accuracy in performing and reviewing calculations.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full' compliance'was achieved on April 15,1998, with the evaluation of the correctly calculated combustible loading.
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I ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98005 VIOLATION: 373/374-98005-04 10 CFR 50, Appendix B, Criterion XVI," Corrective Actions," requires that I
measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, on March 27,1998, the NRC identified that an unauthorized plant design change to the Unit 0,1 A and 2A diesel generator air box drains that had been previously identified by the NRC on June 19,1997, had not been corrected.
REASON FOR VIOLATION:
Comed agrees that the unauthorized plant design change to the Unit 0,1 A and 2A diesel generator air box drains was not corrected in a timely manner.
A review of this incident indicates a human performance error and a lack of follow through on the part of the system engineerin that the administrative procedure was not followed which resulted in the issue not being resolved in a timely manner.
A Problem identification Form (PIF) was written to bring this issue to management's attention on June 16,1997. This PlF was closed to an existing Engineering Request (ER) which asked for an evaluation to hard pipe the Air Box drains to floor drains or justify the use of tygon tubing in this application. This was coded as a Plant Design Change Request (PDCR) which was assigned a "B" priority under the ER process with a due date of June 24,1998. This required presentation to a technical review committee within six months of the initiation of the ER.
The system engineer " approved" the ER on August 5,1997, forwarding it to Design Engineering without completing the required technical evaluation in accordance with LaSalle Administrative Procedure (LAP) 1300-16,
" Engineering Request." The system engineer who forwarded the ER did not provide comments or complete required actions when he approved the ER, 1
therefore, no fr>llow-up action was taken and the issue remained in the ER process and was not presented to a technical review committee.
A second PIF was written on March 31,1998, identifying the lack of follow-up on the initial discrepancy. The ER was then evaluated and received final I
approval on May 5,1998, with the decision to "as-build the current configuration.
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ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98005 A contributing factor in this failure was the high turnover of personnel involved in the resolution of this discrepancy. The Temporary Alteration Coordinator who originated the action left in late 1997. The system engineer responsible for the evaluation also left at the same time. The combination of these discreet events directly contributed to the lack of emphasis being placed on this corrective action.
CORRECTIVE STEPS.TAKEN AND.RESULTS ACHIEVED:
The current configuration was evaluated as an "as-built" change, which has received a technical evaluation and a safety evaluation under 10 CFR 50.59.
The results of the initial technical evaluation confirmed that there was no adverse impact on the diesels in this configuration. This configuration complies with the manufacturer's recommendation to keep the drains open to preclude moisture build-up in the air boxes.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATION:
The engineer involved in this event is no longer employed by Comed.
System Readiness Reviews (SRR) have been conducted in preparation for Unit 1 start-up. This required a review of all outstanding work (including ERs) against a given system and the identification of issues which require action for restart or an affirmation that the work is appropriately classified and can be worked to its current schedule date following restart. A board of management personnel from multiple departments reviews the results of the SSR. On the board's recommendation the system is classified as ready.
This review will ensure systems have no unauthorized design changes.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on June 19,1998, with completion of the "as built" evaluation for the tygon tubing.
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RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98005
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VIOLATION: 373/374-98005-12 10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions," requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, on March 27,1998, the NRC identified that the licensee had failed to update the station fuse list since April 1994. As a result, several hundred deficiency reports regarding safety-related and non-safety-related fuse discrepancies had not been evaluated.
REASON FOR VIOLATION:
Comed agrees that the fuse discrepancies identified in 1994 were not properly addressed. Numerous fuse discrepancies associated with safety related and non-safety-related equipment were identified, but were not reviewed or evaluated. LaSalle A.Jministrative Procedure (LAP) 400-11,
" Fuse Replacement Program" failed to provide adequate guidance to ensure timely resolution of fuse issues. In additior there was complacency and a e
lack of attention regarding the fuse control piogram on the part of management personnel that also contributed to the violation. Historically, fuse discrepancies rarely resulted in operability issues or unacceptable fuses. This led personnel to focus on the fact that the fuse size discrepancies were identified rather than focusing on evaluating the discrepancies.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVn3:
Upon identifying that the fuse discrepancies were not evaluated, the discrepancies were separated into two categories. The first category contained actual fuse discrepancies, for example, the installed fuse was a different size or type than that which was stated on the fuse list. The second category are not actual discrepancies and can be characterized as missing information on the fuse list (e.g., design size, fuse type, etc.).
A preliminary assessment of each fuse discrepancy in the first category was performed. This assessment was based on a review of the affected schematic diagram and engineering Judgment. The main criteria for the assessments were to determine if the installed fuse is able to handle the continuous circuit load. This assessment determined that all of the fuses were acceptable.
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i ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98005 A detailed analysis in accordance with procedure LAP-400-11 " Fuse Replacement Program" was subsequently performed for each Unit 1, Unit 2, and Unit 0 safety-related fuse discrepancy in the first category. These l
evaluations determined that no fuses required replacement prior to Unit 1 i
start-up. A detailed analysis was also performed for 79 of the 83 non safety related fuse discrepancies in the first category for Units 1 and O.
These evaluations determined that no fuses required replacement prior to Unit 1 start-up. The four remaining Unit 1 and Unit 0 discrepancies will be completed prior to Unit 1 restart (NTS # 373-100-98-00512.02). The other fuse discrepancies (i.e., the Unit 2 non safety-related discre,nancies in the 4
first category and the entire second category) are not required for Unit 1 start-up. However, they will be evaluated by August 31,1998 (NTS # 373-100-98-00512.01).
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:
LAP-400-11, " Fuse Replacement Program" was revised to include the re' uirement to track all fuse discrepancies by initiating an Engineering q
Request (ER) for each fuse discrepancy. This will snsure evaluation because ERs are routinely reviewed and prioritized in accordance with station procedures.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be met for Unit 1 on July 28,1998, when the fuses essential for Unit 1 start-up are evaluated. The remaining fuse discrepancies, not required for Unit 1 start-up, will be evaluated by August 31,1998.
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ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98005 VIOLATION: 373/374-98005-15 10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions," requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, on March 27,1998, the NRC identified that an important to safety designated Klockner-Moeller (K-M) relay located in Motor Control Center 132Y-2, cubicle B1, had been identified by the licensee as containing crystal deposits that met the K-M PM program relay replacement criteria on August 23,1997, but had not been replaced as required.
REASON FOR VIOLATION:
Comed agrees that based upon the K-M Preventive Maintenance (PM) program relay replacement criteria presented during the inspection the K-M relay should have been replaced. The replacement criteria presented stated that any safety-related (SR) or important to safety (ITS) relay found to exhibit crystal growth was to be replaced, and the relay in question exhibited crystal.
j growth.
However, subsequent to the inspection it was discovered that the I
acceptance criteria for the K-M relays stated that K-M relays used as 74 devices (alarm relays) in non-safety, ITS applications only required replacement if the relays were found to be nonfunctional. This is true of ITS, 74, K-M relays even if crystal deposits are present on the relay. The relay identified during the inspection (MCC 132Y-2 cubicle B1) is a spare (contacts not used), non-safety but ITS,74 relay that had been shown to be functional using LaSalle Electrical Surveillance (LES) GM-109, " Inspection of 480V Klockner-Moeller Motor Control Center" and, as such, did not require replacement.
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HESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98005 The confusion in the acceptance criteria presented to the inspectors was created by the fact that there are four separate categories for classifying the K-M relays. Two categories are not part of the inspection project and two 4
are part of the inspection project. The K-M relays that are not part of the inspection project are the SR/EO relays, which are being replaced this outage regardless of condition. The normal replacement frequency for these relays is included in the EO Binders. The other is non-safety and not important to safety related, which are replaced when they become
.I nonfunctional.
The two categories of K-M relays that are part of the inspection project are:
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All SR relays and ITS non-74 relays. The acceptance criteria i
for these relays is no crystallization, or no discoloration and cracking, or failure of their surveillance test (LES-GM-109). If any of these criteria are not met, then the relays are replaced.
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ITS 74 relays, which have an acceptance criteria of replacement if they become non-functional or failure of their surveillance test (LES-GM-109).
j The relay in question was an ITS 74-relay. As a result of a lack of attention to detail by the cognizant engineer, this distinction was not recognized at the time the information was provided.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
A review was performed of all relays being addressed by the K-M replacement program, no other incidents of SR or ITS identified as having crystals and subsequently not replaced were identified.
The relay identified during the inspection has been replaced, even though it was not required.
After it was recognized that incorrect acceptance criteria had been presented during the inspection, NRC Region ill personnel were informed of the correct acceptance criteria.
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i ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98005 CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:
The individual involved in this incident has been counse' led by his supervisor 4
regarding the importance of providing complete and accurate information to inspectors.
Additionally this incident was discussed in a departmental meeting in May 1998 to heighten the awareness of others to errors of this nature.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been maintained.
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ATTACHMENT B l
REGULATORY COMMITMENT (S) l Ihe following identifies those actions committed to by Comed in this l
document. Any other actions discussed in this submittal represent intended l
or planned actions by Comed. They are described to the NRC for the NRC's information and are not regulatory commitments.
Tracking Number The four remaining Unit 1 and NTS # 373-100-98-00512.02 Unit 0 discrepancies will be completed prior to Unit 1 restart.
The other fuse discrepancies (i.e., -
NTS # 373-100 98-00512.01 the Unit 2 non-safety-related discrepancies in the first category l
and the entire second category) are not required for Unit 1 start-up.
However, they will be evaluated by August 31,1998.
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