ML20248D579
| ML20248D579 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/28/1989 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8908110081 | |
| Download: ML20248D579 (9) | |
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Address Reply to: Post DfficiiEIONI
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July 28, 1989-1 a
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Mr. A. Bert Davis Regional' Administrator 9
U.S. Nuclear Regulatory Commission
. Region'III
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l799 Roosevelt Road b
Gle'n Ellyn,.IL-601371 Subjects: LaSalle County Station Units 1 and 2 Response to Inspection Report Nos.
50-373/89010 and 50-374/89010 Special Maintenance Team Inspection NRC Docket Nos. 50-373 and 50-374-
- Reference (a).
H.J'.' Miller letter to Corde11' Reed dated June 28, 1989.
Dear Mr.. Davis This letter in-in response to the special maintenance teamil'spection n
conducted by Mr. S. Eick and'others on May 1-5, 15-19 and 25, 1989,-of certain activ3 ties at LaSalle. County Station. Reference'(a). indicated that certain
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activities appeared to be in non-compliance with'NRC requirements. The f
Conrionwealth Edison Company responses to the three Level IV Notice of 1
. Violations and additional concerns are provided in Attachments'l through 4 of'
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this lett.er.
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. Commonwealth Edison appreciates the extensive effort by the Region Staff and the many_useful observations and recommendations which resulted from
,"h this inspection.
.n If you have any questions regarding this matter, please contact this office.
Very truly yours,
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T. J.gRovach Nuclear Licensing Manager im Attachment
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P.C. Shemanski - Project Manager, NRR
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8908110081 890728 7
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C 1EESPONSE TO LASALLE COUNTY STATION LEYEL IV VIOLATION 373/89010-01 374/89010-01
. VIOLATION:
10 CFR 50,; Appendix B, Criterion VI, as described in Topical' Report CE-1-A, Revision 55, and as implemented by Quality Assurance Manual Section 6, requires that measures be established to control the issuance of documents, such as procedures, including changes thereto.
Further, changes to procedures p
are required to be reviewed for accuracy and approved for release by authorized personnel.
Contrary to the'above, emergency diesel generator semi-annual operability test Procedures GA-1, Revision 4; SA-2, Revision 6; andLSA-3, Revision 7, for all.five emergency diesel generators were not reviewed for adequacy and conformance to the requirements of Technical Specification 4.8.1.1.2a.4, and a.5.
Revisions to the procedures incorrectly retained steps that required pre-warming and shutdown of the engines prior to conducting the 184. day semi-annual surveillance.
As a result, none of the five emergency diesel generators were started from ambient temperature conditions since February 6, 1989, for, Diesel "0";
since June 11,.1986, for Diesels "1A" and "2A"; and since January 15, 1987'for Diesels "1B" and "2B".
Subsequent testing by the licensee on May 2, 1989, ludicated that all five emergency diesel generators were operable.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The immediate corrective action was to perform fast starts from ambient. conditions on all five (5) diesel generators (DG).
No significant difference in response time was noted.
CORRECTIYS ACTION TAKEN TO AVOID FURTHER VIOLATION To prevent a further occurrence, LOS-DG-SA1, LOS-DG-SA2 and i
'LOS-DG-SA3 were revised to delete the slow start and warm-up prior to the fast start, and a statement was added requiring a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> wait after the last time a DG.is run to be able to take surveillance credit for a fast start from ambient conditions. These revisions are all approved and in the procedure manuals.
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i This occurrence is believed to be a unique case of an incorrect interpretation of the ambie.it start criteria specified in a Technical Specification footnote. The procedure originally met all Technical Specification requirements.
In the course of revising the procedure to reflect Technical Specification changes and plant modifications, an error was introduced by the reviser, and not detected during the review process. The present procedure change process provides for a System Engineer review of i
substantive procedure revisions.
DATE OF FULL CpliPLIANCE Operability of DGs was essured on May 2, 1989.
Full compliance was achieved with issuance of the procedure revisions on June 12, 1989.
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A2TACIMtatT_2 CECO RESEQHSE TO LASALLE' COUNTY STATION LEVEL IV VIOLATION 373/89010-02, 374/89010-02 VIOLATIDH:
LaSalle Unit 1 and 2 Technical Specification Surveillance require-ments 4.8.1.1.2d.7 and 13 require that diesel generators be demonstrated operable at least once per 18 months during a shutdown by verifying that all diesel generator trips except the engine overspeed trip (an overcurrent trip.
for Division 3 only) and an emergency manual trip, are automatically bypassed by an Emergency Core Cooling System (ECCS) signal.
Contrary to the above, since January 1984, the licensee did not demonstrate that the diesel generator automatic trips (except those noted) were. automatically bypassed by actuation of the specified relay contact. The licensee's surveillance procedures and test methodology were inadequate to prove that the generator trip interlocks would actually prevent the diesel I
generator trip during an ECCS actuation. The procedures incorrectly required that an electrical lead wire be disconnected ahead of the lockout relay.
Subsequent tests by the licensee on May 2 and 3, 1989, indicated that the l
relay correctly operated.
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CREEEf71YI_ACTIDM_TAKEN AND RESULTS_ACHIIVED Immediate corrective action was taken for the logic test procedure i
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- deficiencies.,LaSalle Special Test (LST). procedures to demonstrate and
' document operability of the subject relays were writ +en and performed for each
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diesel generator by May 3, 1989.
An evaluation of the adequacy of a sampling of similar logic testing procedures was conducted to identify any additional testing concerns. No additional concerns were identified.
L CQREEET1YE ACTION TAKEN TO AVOID FUETHER VIOLATIOl]
l The applicable logic testing procedures will be revised to include functional testing of all the relays. A CECO corporate task force to review logic testing practices and determine what additional actions should be taken had been established prior to May 1989. This task force will initiate a Safety Related Contact Testing Program and Surveillance Adequacy Review for LaSalle County.
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DATE OF FULL COMPLJ] dice i
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Full compliance was achieved on May 3, 1989 when the above mentioned 1
LST's were performed and test results were approved. Applicable surveillance procedures will be revised to fully test the. relays in question for future Surveil).ance s. This will be completed by November 1, 1989. The Safety Related Contact Testing Program and Surveillance Adequacy Review is expected to be completed in 1990.
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j ATTACIIME!!T_3 1
CECO RESEOliSE TO LASALLE_CQllti.TY STATION l
LKyEL IV VIOLATION IR 373/89010-03, 374/89010-01 VIOLATIOli2 10 CFR 50, Appendix B, Criterion XVI, as described in Topical Report CE-1.A, Revision 55 and as implemented by Quality Assurance Manual, Section 10, requires that measures be established to assure conditions adverse to quality, such as failurec and deficiencies are promptly identified and corrected.
Contrary to the above, as of May 20, 1989, the licensee failed to promptly inspect, correct, or justify continued operation of more than 50 Unit 1 and 2 motor operated valves (MOVs) that were subject to common mode failures of torque switches made of melamine material as described in the 10 CFR 21 report issued by Limitorque Corporation on November 23, 1988.
By May 20, 1989, the licensee completed a Justification for Continued Operation of the MOVs.
CQERECUVE ACURtLIAKE!LANRJiESETSJLCllIEYED An evaluation was performed on May 19, 1989 during Onsite Review 89-031 for the operability of Limitorque MOVs which m3y utilize white melamine torque switches. A Justification for Continued Operation (JCO) was also completed and in place on May 20, 1989. As part of the evaluation, an action plan was developed for replacement of any melamine torque switches in SMB-000 and SB/SMB-00 Limitorque MOV's.
The MOV's were placed into three categories based on specific criteria specified in the Onsite Review.
A records review hed been completed prior to the Onsite Review for both units. All SMB-000 and SB/SMB-00 operators that fell into the serial number category identified by Limitorque in the Part 21 notification (i.e.
affected MOV's) were reviewed for type of torque switch material. A review of the MOV's motor current traces for Unit 2 affected MOV's was completed prior to startup after the Unit's second refuel outage.
A review of current traces has also been completed for the Unit 1 affected MOV's.
All Unit 2 inside containment affected MOV's were inspected and torque switches replaced as necessary prior to startup after its second refueling outage.
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n Work requests have been initiated on all affected motor operated valves and those which haven't been completed to date will be inspected per the developed action plan. All Priority 1 MOV's identified by Onsite Review l
89-031 were completed by June 8, 1989 for both units. All torque switches on the identified _ Priority 1 MOV's which were replaced due to the melamine material were found to be operational.
Priority 2 and 3 MOV's will be verified not to have melamine torque switches prior to startup after the next unit outage or a current trace may be completed to extend this inspection until the next refueling outage.
Priority 3 MOV's will be verified not to have melamine torque switches prior to startup after each units next refueling I
outage.
LaSa11e's procedures for Motor Operated valve inspection had been previously revised to allow the use of only Brown Fiberite torque switches for SMB-000 and only new style torque switches (i.e., not subject to the Part 21) for SB/SMB-00.
This will ensure that all future replacement torque switches will be of a type not subject to the Part 21.
CQRRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION When the station receives notice of a Part 21 report which could affect LaSalle County equipment or operation, an Action Item Record (AIR) will be issued to investigate and develop an action plan to address the concern.
Other appropriate CECO departments will be involved as necessary to assist the station in time 17 resolution of the concerns.
LAP-1500-4, Action Item Record (AIR), will be revised to implement this requirement.
DATE OF FULL COMPL1AHfE The station is presently in full compliance.
LAP-1500-4 will be revised by September 30, 1989.
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l CECp_REEPRISE TO FQQE_jiEAERESSES IN THE LSCE_ EAR {IENANCE TEAM INSPECTLON REPOEI IIAMSMITTAL LETIIE The management of LaSalle Cot ty Station is comn.itted to improvements in the maintenance process and will continue to be invo3ved in monitoring those areas where improvements are needed.
Recent initiatives such as the formal System Engineer program and organizational changes in the technical support area to enhance the development and guidance of the System Engineers should provide the basis for future performance improvements.
LaSalle County acknowledges the problems associated with the technical support area and is closely monitoring the performance in that area to ensure strengthened support of all aspects of Station Performance.
The weaknesses identified in the Reference (a) Inspection Report transmittal letter are specifically addressed below:
CONCERN 1:
Instances of poor communication between corporate and site that resulted in inadequate corrective action on a 10CFR21 report regerding potential common mode failure of more than 50 motor-operated valves.
RESPONSE
Corporate 10 CFR 21 procedures are being reviewed to assure required actions are communicated to the site and are tracked end followed-up. This review and associated changes are expected to be completed by September 29, 1989.
CONCERN 2:
Instances of ineffective direction of maintenance activities that resulted, for example, in lack of QC involvement in surveillance testing, and inadequate controls to monitor the performance of degraded solenoie operated discharge valves of the fuel oil transfer pumps for Unit 2 emergency diesel generators.
RESPONSE
A program will be developed such that Quality Control (OC) will per.forn e.n overview of selected maintenance surveillance.
This program will involve QC personnel in observing a sample of surveillance or portions of surveillance on a periodic basis.
The monitoring of plant equipment status and performance, and the timely resolution of equipment problems will be enhanced by the formal System Engineer program.
The System Engineer will also be involved with station surveillance performance.
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Y CONCERN 3:
Instances of.Inadequi s engineering support that resulted in' poor
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~ Technical Staff review of procedures used to' verify operability I
of the five emergency' diesel generators, and limited involvement
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with cause/ failure' analysis associated with Program Analysis Data'~
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sheets.
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RESPONSE
The technical review of station procedures is believed to be
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.l performed in a manner consistent'with overall plant safety and I
reliability. The specifics of.the procedures for the emergency diesel generators are addressed in the responses to the notice of violations. ' CECO believes that these are isolated cases and that l
overall the station procedures are technically adequate.
The procedure change process has been revised to assure that the j
System Engineers are.involvedLin. procedure' revisions which effect the operation,0f their systems. This was only done informally in l
the past.
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.The Technical. Staff will be involved in all Problem Analysis Data Sheets (PADS) in'the future.
Several Technical Staff Engineers l
. have received Manag= ment Oversight and Risk Tree (MORT) root cause l
training in-July 1989,. Additional personnel in maintenance
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departments and the Technical Staff will' receive root cause training in the future to improve the cause/ failure analysis of equipment problems and to ensure appropriate corrective actions are taken to reduce repetitive failures.
CONCERN 4:
In many instances there was an overall low level of. system awareness and technical knowledge of System Engineers.
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RESPONSE
Prior to the inspection, the Technical Staff had initiated a formal System Engineer Qualification program. This program includes additional special training on specific systems as well as training on general topics. The program also has specific responsibilities and expectations for System Engineers. These measures will ensure that each System Engineer is knowledgeable of both the technical details of the assigned system (s) as well as day-to-day condition of the system. This program will enhance the overall technical support of the station operations and maintenance.
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