ML20247E213
| ML20247E213 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/24/1989 |
| From: | Morgan W COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0013K, 13K, 9416N, NUDOCS 8905260171 | |
| Download: ML20247E213 (5) | |
Text
_-
,~x Comm:nwrith Edison N
f 72 West Adams Street, Chicago, Illinois QL Address RepTy foTPosIDffice Box 767~
N.s/ Chicago, Illinois 60690 0767 April 24, 1989 i
Mr. A. Bert' Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Units 1 and 2 Response to Inspection Report Nos.
50-373/89003 and 50-374/89003 Routine Safety Inspection NRC Docket Hon 50-373 and 50-374 Reference (a):
E. McKenna letter to Cordell Reed dated March 23, 1989
)
Dear Mr. Davist This letter is in response to the inspection conducted by Messrs. R.
Lanksbury and R. Kopriva on January 30 through March 13, 1989 of certain l
activities at LaSalle County Station.
Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company's response to the two Level IV Notice of Violations is provided in the Attachment.
If you have any further questions regarding this matter, please direct them to this office.
Very truly yours, V
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W. E. Mdrgan Nuclear Licensing Administrator 1m Attachment
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cc NRC Resident Inspector - LSCS I\\
8905260171 890424 PDR ADOCK 05000373 0013k i
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ATTACitiERI
. YIOLATION:
IR 50-374/89003-01 Technical Specification 6.2.A states, in part:
Detailed written procedures including applicable checkoff lists covering items listed shall be prepared, approved and adhered tot 1.
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 which includes-administrative-procedures.
Administrative Procedure LAP-1300-5, Revision 10, Field Change
]
Requests (FCR), Steps F.22, F.23 and F.24 states, in part, the following F.22 Verifies that the work was completed by FCR and that the revised documents are updated acceptably.
.F.23 Reviews and approves final disposition disposition of FCR.
F.24 Verifies completion of FCR Contrary to the above, on July 13, 1987, which was the completion of modification M-1-2-84-136, Replacement of the Barton. Differential Pressure (dp) Switches with Static-O-Ring (SOR) dp switches, the licensee failed to
- review and verify completion of FCR L85-87 which required the installation of a pulsation dampener on SOR switch 2E31-N012AA. The dampener was not installed but the drawing was changed and approved reflecting the installation of the dampener. This-also made the drawing incorrect, not reflecting the actual plant configuration.
CQEECTIVE ACTION IMER_MUESULIS_ACUJRED LaSalle Station Work Request L87143 was written to install the required pulsation dampener. This work request also installed a pulsation dmnpener on Instrument 2E31-N012AB. This work request 'vas completed on February 19, 1989. The proper installation of the pulsation dampener was verified with the work request. The proper operation of the associated instruments will be checked when RHR Shutdown Cooling can be initiated during a unit shutdown. Action Item Record (AIR) 374-200-89-00901 was written to track performance of this verification.
The cause of the inadequate verification of the FCR installation was determined to be a mis-interpretation of the results of the FCR walkdown due to the physical similarity between the pulsation dampener and a normal instrument tubing fitting.
Although the pulsation dampener body is longer
{
than a normal fitting, its outward appearance is very similar in all other respects. Because of this, the walkdown of the pulsation dampener installation 9416N
v]y;-.
was mis-interpreted..Specifically, the modification engineer.took photoptaphs
.of the. instrument arrangement for Instruments 2E31-N012AA and 2E31-N012AB, af ter. the apparent pulsation dampener installation, believing that the -
photographs. documented the presence of the pulsation' dampener. Upon inspection of the photographs for Instruments 2E31-N012AA and 2E31-N012AB.during the in"estigation of this event, the~ photographs proved that the pulsation dampener was not present.
CQREECTIVE ACTION TAKEN -TO AVOIJLIURT11ER VIOLATION' The error in the FCR installation was determined to be related to the pulsation dampener's physical similarity to normal instrument tubing fittings, and not generic to the FCR p:ocess. Therefore, a list of plant applications containing pulsation dampeners was generated, and an additional walkdown was conducted to ensure that similar errors were not in existence. This was done by personnel f amiliar with the pulsation dampeners and the f act that the previous walkdown he.d mis-interpreted the appearance of normal instrument tubing fittings.
The walkdown determined that the two instruments on Unit 1 (the same instruments as Un3 t 2) also did not have the pulsation dampeners required by the drawings.
Station Work Request L87697 was written to install the needed pulsation dampeners.
Instrument Maintenance and Technical Staff personnel will be ta11 gated on this response.
No further corrective actions are required to avoid further violation.
~ DATE_HHEN FULL COMPLIM{CE_ MILL _D] LAC 1111LV_E.Q LaSalle Unit 2 is presently in full compliance with regards to the instrument identified in the Notice of Violation, in that the associated instrument lines have the pulsation dampeners installed.
LaSalle will complete installation of the pulsation dampeners on Unit 1 prior to startup after the Unit 1 third refuel outage currently scheduled for November, 1989.
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.r VIOLATION:
IR 50-373/89003-02 l
Title 10, Code of Federal Regulations (CFR), Part 50.72, Immediate notification, Section 2(11) states, in part "...the licensee shall notify the NRC as soon as practical and, in all cases, within four hours of any event or condition that results in manual or automatic actuation of an Engineered Safety Feature (ESF)
Contrary to the above, on February 4, 1989, and again on February 6, 1989, there had been an ESF actuation in that the Residual Heat Removal (RHR) shutdown cooling pump suction valve 2E12-F008 isolated on a high flow signal and the licensee had not reported the actuation via the Emergency Not3fication System (ENS).
CQRRICTIVE ACTION TAKEIL]diD._RES%IS_AClllEER A letter was issued on February 10, 1989 from the Production Superinter. dent to all SROs to establish the requirement to report all actuations of EST equipment in all modes, unless a specific interpretation exists in writing exempting a given cirewnstance.
l CORRECTIVE ACT1Q. N_TAKEILIORIP FURTHER VIOLATLON a.
The Notification Procedure (LZP-1310-1) and the Deviation Report Procedure (LAP-1500-5), which provide guidance for 10 CFR 50.72 deportability, will be revised to include additional guidelines. These guidelines will be as follows:
1.
If a system is being started up or shutdown and the procedure does not indicate that there is a reason to expect an ESF actuation and one occurs, it is reportable.
An unplanned half scram and half isolation s3 nal is not reportable.
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2.
If a procedure states that during the evolution an ESF actuation will occur and the Shift Supervisor elects not to defeat the actuation, I
(i.e., the automatic startup of the Standby Gas Treatment System) the actuation is not reportable.
3.
Any unplanned isolation of RHR Shutdown Cooling will be reportable.
4.
If an approved procedure states that during the evolution a cpecific ESF actuation will occur and does but additional components isolate that were not identified, it will be reportable.
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,g 5.
The Shift Supervisor will always contact the Duty Officer and/or Assistant Superintendent of Operations (ASOP) to obtain concurrence on the deportability of-an event. When there.is any doubt, the Duty Officer and/or AS.' will contact the Station Manager or one of the Station Superintendents for additional guidance.
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b.
Additional examples of specific ESF actuation cases may be included in this procedure to ensure consistency in reporting of ESF actuations.
DATE WHEN FUL.L COMPLIANCE WILL BE ACHIIVED LaSalle is presently in full compliance.
LZP-1310-1 and LAP-1500-5 will be revised by June 1, 1989.
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