ML20237D216

Responds to NRC Re Violations Noted in Insp Repts 50-373/98-15 & 50-374/98-15.Corrective Actions:Testing Methodology Was Developed to Cycle Valves Associated W/ Modified Deluge Sys

ML20237D216
Person / Time
Site:	LaSalle
Issue date:	08/21/1998
From:	Dacimo F COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-373-98-15, 50-374-98-15, NUDOCS 9808250153
Download: ML20237D216 (7)

Text

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, Gammonu calth litiv>n Gimpany

• 1.aSalle Generating Station

_j MI Nonh 21st fload Marseilles, IL 613 619757 Tel H I 5-357#'61 August 21,1998 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555

Subject:

Reply to Notice of Violation, NRC Inspection Report 50-373/374-98015 LaSalle County Nuclear Power 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 July 24,1998, '

Transmitting NRC Inspection Report 50-373/374-98015 and Notice of Violation The enclosed Attachment A contains LaSalle County Station's response to the Notice of Violation that was transmitted in the Reference letter.

Attachment 8 provides the commitment (s) for this submittal.

A conference phone call was held on July 29,1998 between members of my staff and NRC Region til personnel to clarify the Notice of Violation. It was agreed that one of the valves listed in the Notice of Violation, specifically ,

valve 1FP-160A, is not part of a system that contains a second isolation l valve in series and therefore, is still considered not testable. The other J valves mentioned in the Notice of Violation are testable and should have been tested as stated in the Notice of Violation.

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I If there are any questions or comments concerning this letter, please refer .

' them to Harold D. Pontious, Jr., Regulatory Assurance Manager, at 4 (815) 357-6761, extension 2383.

Respectfully,

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Fred R. Dacimo Site Vice President LaSalle County Station Enclosure cc: J. L. Caldwell, Acting NRC Region ill Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle J. Roman, IDNS Inspector - LaSalle F. Niziolek, Office of Nuclear Facility Safety - lDNS 4

ATTACHMENT A l

RESPONSE TO NOTICE OF VIOLATION l NRC INSPECTION REPORT 373/374-98015 l VIOLATION: 373/374-98015-02 l Technical Specification 4.7.5.2.b requires for each deluge and sprinkler system in Table 3.7.5.2-1, that operability be demonstrated at least once per 12 months by cycling each testable valve in the flow path through at least one complete cycle of full travel.

l Technical Specification Table 3.7.5.2-1 listed the deluge and sprinkler .

system that supply water for fire suppression to the control room and auxiliary electric equipment room ventilation systems as systems that must be tested for operability at least once per 12 months.

Contrary to the above, as of July 17,1998, testable valves 1FP-160A, 1FP-160B,1FP-161,1FP-236, and 1FP-234 in the fire protection system lines that supply fire suppression water to the control room and auxiliary electric equipment room ventilation systems had not been cycled in the preceding 12 months.

1 REASON FOR VIOLATION:

On July 20,1998, it was determined that Fire Protection manual isolation valves associated with the following Control Room and Standby Gas Treatment charcoal filter bed deluge systems were not cycled as required by Technical Specification Surveillance Requirement 4.7.5.2.b:

. OVC01FA, Control Room HVAC Supply Air Filter Unit.

. OVC01 FB, Control Room HVAC Supply Air Filter Unit.

. OVC01SA, Control Room Emergency Makeup Filter Unit.

. OVC01SB, Control Room Emergency Makeup Filter Unit.

e 01VG01S, Standby Gas Treatment System Equipment Train.

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ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98015 The deluge system installed to protect the charcoal filter beds originally consisted of a single isolation stop valve that was maintained in the "normally open" position. The deluge system was pressurized up to the soleroid operated deluge valves (two total per charcoal filter train) which are installed in the system downstream of the normally open isolation stop valve.

The solenoid operated deluge valves are located adjacent to the associated charcoal filter unit before the piping entered the charcoal filter train.

The normally open single isolation valves were closed in 1986 in response to industry events involving fire suppression systems causing inoperability of safety related systems (refer to I.E. Information Notices 85-85 and 87-14).

.Specifically, water from the non-safety related fire protection system had the potential for rendering safety-related ventilation systems inoperable.

The intent of closing the single isolation valve in 1986 was to minimize the potential for a non-safety fire protection system adversely impacting a safety related system, thereby ensuring that safety systems are available given a valid demand for their operation. Cycling the single isolation valves for testing purposes was considered challenging to the charcoal train because vf past experience in wetting the charcoal within the charcoal train due to leakage past the solenoid operated deluge valves. Therefore, the single isolation valves were not considered testable because the risk associated with cycling the valves was too severe, in 1996, after experiencing continuing leakage of fire protection systems into the charcoal trains, the deluge systems associated with the five charcoal filter beds discussed earlier were modified to add a second "normally closed" isolation valve in series with the existing "normally closed" isolation valve. In addition, an open drain line was installed between the valves; to completely eliminate the potential of rendering the ventilation trains inoperable during a non-fire event. The failure to perform a rigorous review of the associated design change package resulted in the valves not being cycled as required by Technical Specification 4.7.5.2.b upon completion of the modification.

I The 1FP-160A valve stated in the violation was not part of the systems l modified and is still considered a single stop valve and is not considered 4 testable. _ This valve will become testable when the system is modified.

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l ATTACHMENT A i

RESPONSE TO NOTICE OF VIOLATION i NRC INSPECTION REPORT 373/374-98015 This event is believed to be isolated to the fire protection system and considered a singular incident because:

. A formal Technical Specification Surveillance Review was conducted in 1995 to ensure all Technical Specification Surveillance Requirements were adequately addressed by plant procedures and surveillance. The review identified one fire protection valve that was not cycled as required by plant Technical Specifications. No other fire protection valve deficiencies were identified. This review was conducted prior to the mortification being installed. As a result, the applicability of Technical Specification Surveillance Requirement 4.7.5.2.b was not challenged.

No additional valve modifications (besides those discussed earlier) have been made to the fire protection system (since the Technical Specification review was conducted in 1995) that have affected Technical Specifications or compliance with Technical Specification s surveillance requirements. 1

. Reviews of other systems outside of fire protection were conducted as part of the System Functional Performance Review (SFPR) program in 1997. The objective of the program was to establish a level of confidence that selected systems important to safe and reliable operation could demonstrate functional performance consistent with the design basis. The program was expanded to include a review of the surveillance associated with non-SFPR systems (excluding Fire Protection and the Off-site Dose Calculation l

Manual). Identified deficiencies were corrected. 1 The cause of this event was a management deficiency in not identifying that the installation of a second normally closed manualleolation valve in series rendered each normally closed valve to be testable. Technical Specification 4.7.5.2.b was reviewed as part of the modification process, but the valves were not corisidered testable because the risk of wetting the charcoal within the associated charcoal filter bed was considered too severe (i.e., safety related plant equipment could be damaged or disrupted by non-safety related equipment). Therefore, the systems were not considered testable l after the modifications were installed and the valves were not cycled as discussed in Technical Specification 4.7.5.2.b.

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ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT .

. 373/374-98015 f I

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

The five charcoal filter bed deluge systems containing two normally closed manual isolation valves in series (with an open drain line between the  !

valves) were declared inoperable when it was determined that the valves t were testable and compensatory measures (i.e. fire watches) were established as required by Technical Specification 3.7.5.2 Action a.

4 A testing methodology was developed to cycle the valves associated with the modified deluge system. An annual surveillance procedure (LOS-FP-A7,

" Fire Protection Filter Unit Deluge Flow Path Valve Cycling Test") was ,

developed to cycle and lubricate the isolation valves for each charcoal filter '

bed containing two (2) normally closed valves in series. The surveillance 3 was performed with satisfactory results prior to Unit 1 startup. As a result, Technical Specification Surveillance Requirement 4.7.5.2b has been satisfied and the valves and the associated deluge syotems were declared OPERABLE.

CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:

The LaSalle Engineering Organization has undergone significant changes resulting in standards of heightened awareness and development of a '

rigorous questioning attitude by preparers and evaluators of engineering products. Performance measures, developed by independent review l groups, are in place to monitor and ensure the effectiveness of these changes. Continuous improvement is evident. The current engineering personnel training and qualification program reinforce the above standards.

A Training Needs Analysis of this event will be conducted. The results of the analysis will be inputted into the Engineering Continuing Training

Program. Completion of this item is being tracked by Nuclear Tracking System (NTS) # 373-180-98 SCAQ00008.01.

Outstanding modifications to other charcoal filter bed deluge systems are being reviewed to ensure a similar event does not occur. This action is l being tracked by NTS # 373-180-98-SCAQ00008.02.

l DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was achieved on July 29,1998 when valves 1FP-160B, 1 FP-161,1 FP-236, and 1 FP-234 were successfully cycled.

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ATTACHMENT B REGULATORY COMMITP.:ENT(S)

The following identifies those actions committed to by Comed in this document. Any other actions discussed in this submittal represent intended or planned actions by Comed. They are described to the NRC for the NRC's information and are not regulatory commitments.

Regulatory Commitment (s) Tracking Number A Training Needs Analysis of this NTS# 373-180-98-SCAQ00008.01 event will be conducted. The results of the analysis will be inputted into the Engineering Continuing Training Program.

Outstanding modifications to other NTS # 373-180-98 SCAQ00008.02 charcoal filter bed deluge systems l

are being reviewed to ensure a l similar event does not occur.

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