IR 05000373/1997016: Difference between revisions

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U.S. NUCLEAR REGUt.ATORY COMMISSION REGION 111    ,
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Docket Nos:  5 4 373;50-374
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Ucense Nos:  NF?-11, NPF-18 Repo:t No:  50 373/97016(DRP); 50 374/97016(DRP)
Ucensee:  Commonwealth Edison Company Facility:  LaSalle County Station, Units 1 and 2 1.ocation:  2601 N. 21st Road Marseilles,IL 61341
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Dates:  September 20 - October 31,1997 inspectors:  M. Huber, Senior Resident inspector J. Hansen, Resident inspector R. Crane, Resident inspector C. Mathews, lilinois Department of Nuclear Safety (  Approved by: . Anton Vogel, Acting Chief, Projects Branch 2
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Division of Reactor Projects I
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9712060189 971128 PDR ADOCK 05000373 G  PDR  ,
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EXECUTIVE SUMMARY LaSalle County Station, Units 1 and 2 NRC Inspection Report No. 50-373/07016(DRP); 50-374/g7010(DRP)
This inspection report included aspects of licensee operations, maintenance, engineering and plant support. The report covers a 6-week period of inspecuon conducted by the resident staf Ooerations
. Based on routine inspector observctions of control room acuvitiss, operators were attentive to the main control room panels, knowledgeable of various system configurations, and arware of actMiles in the plant. Shift pre-briefs were of high quality and effective in communicating plant conditions. (Secuon 01.1)
. The licensee initiated appropriate immediate correcuve actions to address equipment failures involving an emergency diesel generator failure to start and two breaker failure Plant personnel used the corrective action process at LaSalle to address the equipment failures. (Section 01.2)
. The licensee's completed and planned actions for protecung emergency sources of cooling water and critical plant systems imm cold weather were adequate. The inspectors considered the licensee's use of previous plant experience in formulating its cold weather plare to bs a good initiative. (Section 02.2)
Maintenance
* The inspectors observed several surveillance activities and the surveillance tests were performed by plant personnel in an acceptable manner. The inspectors did not identify concems with personnel perfo.mance. (Section M1.1)
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The licensee incorporated lessons leamed from previous maintenance activities into work planning. In addition, the licensee decontaminated the Division ll residual heat removal (RHR) pump rocm. These improvements increased the licensee's ability to perform maintenance more efficiently. (Secuon M2.1)
Enaineerina
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An engineer performing a review of survelliance testing for the emergesy diesel generators during the System Functional Performanco Review (SFPR) incorrectif determined that a technical specification test procedure was acceptable. The engineer's error appeared to be an isolated instance where problems were not appropriately classlfied for resolution. The licensee's plan to review the SFPR documentation to ensure that identified problems were documented for resolution was appropriat (Section E2.1)
 
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. Plant Suooort
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The inspectors identified that the licensee did not have a procedure to ensure prescription eyewear was available for use with emergency breathing apparatus by licensed operators with a license condition requiring the use of correctivt eyewear when performing licensed duties. The licensee had identified the issue and was implementing corrective action to prevent recurrence. (Section P5.1)
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Report Details
' Summary of Plant Status During this inspection pedod, the hoensee maintained Unit 1 in cold shutdown (Operational Condition 4) for a forced outage and Unit 2 remained shut down for a refueling outage with all fuel removed from the reacto L Operations 01 Conduct of Operations 01.1 General Comments Inspection Scope (7170'A The inspectors conducted frequent reviews of ongoing plant operations by performing control room panel walkdowns and observing operator performanc Observation and Findinos Overall, the licensee operated the plant safely and performed activities in accordance with procedures. The inspectors observed routine control room activities such as operator tumovers, operators' response to annuretors, and surveillance activities (discussed in Section Mt.1). The operators were attentive to the main control room panels, knowledgeable of various system configurations, and aware of activities in the plant. The shift manager conducted pre-shift briefings for oncoming shift personnel which were thorough and effective in communicating plant operational and work achvity status, in one instance, the bdefing included presentations by engineering personnel and personnel from the outage management organization to the oncoming operating crew that had not been on shift for seven days. The presentations consisted of detailed updates of ongoing maintenance activities and were requested by the shift manager to ensure that the crew was well informed. Thro aghout the inspection period, the pre-shift briefings were conducte3 in a professional manner, both licensed and non-licensed operators discussted issues, and a good questioning attitude was displayed by operations personne Conclusions The inspectors observed that the operators were attentive to the main control room panels, knowledgeable of various system configurations, and aware of activities in the picnt. The licensee generally conducted plant operations in accordance with procedures and in a safe manner. The pre-shift briefings have consistectly been of high quality over
,; the entire inspection period. The shift manage /s request for de'. ailed discussions of plant -
maintenance activities for his operating crew to help ensure that the operators were informed of the plant status was goo _ _ _ - _ _ - _ - _ _
 
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01.2 Correcuv's Actions for Eautoment Failures Inspection Scope (71707. 40500)
The inspectors reviewed the licensee's correcGye scuons for the following equipment fauures:
  * O emergency diesel generator (EDG) supply breaker to Unit 2 failed to energize on September 27,1997, during surveulance testin * O EDG failed to start or '. september 29,1997, during surveulance testin * Unit 1 Division ill safety-related bus supply breaker from the station auxiliary transformer (SAT) failed to energize on October 7,1997, during surveillance testin Observations and Findinos For each of the equipmmt failures listed e5ove, the licensee generated a problem identification form (PlF), which is the beginning of the correcove action proces Appropriate management attention was placed on reviewing the failures and appropriate ,
personnel from various departments performed the root cause investigations for the failures. The licensee assessed the impact of the failures on the operabluty of other components, and determined the correcuve actions in a timely manne For the failure of the Unit 2 supply breaker from the 0 EDG, on September 27,1997, the licensee determined that the root cause for the failure was binding of the cubicle mounted breaker position switch linkage. The switch monitored the breaker position as part of the breaker control logic. The switch contacts must be open or the breaker would not energize. In this particular event, the switch never opened when the operator retumed the breaker to service (racked in the breaker) following maintenance. When the licensee was performing post-maintenance testing (PMT) of the breaker, it failed to actuate. The engineering department recommended correcuve actions which included additional switch inspections and revision to maintenance procedures to include the linkage configuration inspection. The licensee's root cause and corrective actions appeared appropriat On September 29,1997, during a surveillance test of the O EDG output breaker the O EDG failed to start. The operators were using a procedure which required that the operat; ' take manual control of the fuel system and slowly increase the EDG speed after it started. From the investigation, the licensee concluded that the procedure was adequate and the operators followed the procedure, in addition, the licensee did not ident g any equipment deficiencies. However, the licensea enhanced the EDG starting procedure by adding an operator to improve communications when the operators were performing the procedure and other steps to ensure that the EDG was running before operators could take manual control of the fuel system. The inspector reviewed the procedure, LaSalle Operating Procedure (LOP)-DG-02, " Diesel Generator Startup and Operation," Revision 25, and did not identify any problems with the procedure that was used by the operators. The inspectors reviewed the training that had previously been given to the operators. The inspectors determined that the operators had received
 
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training on the manual starting procedure and recently performed the LOP-DG-02 procedure without incident. The licensee's corrective actions appeared appropriat Concoming the failure of the Unit i Division lli supply breaker from the SAT on October 7, 1997, the licensee replaced the breaker and transported the failed breaker to the vendor for further inspection. The breaker that failed was manufactured by General P.'d (GE). While reviewing failure histories for GE breakers, the licensee idoufied two additionalinstances where GE breakers had failed to energize durin9 testing within the
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past year. The licensee evaluated the three GE breaker failures that occurred over the last year and concluded that no single common mode problem existed. However, the b  root cause for the Unit 1 Division ill supply breaker from the SAT was still being evaluated by engineering personne The licensee's immediate corrective actions for the Division ill breaker failure appeared adequate. However, the licensee's investigation of the Unit 1 Division til supply from the SAT was ongoing to determine the root cause of the October 7,1997, failure and the potential for related failures of other GE breakers in service in the plant. This was considered an inspection followup item pending NRC review of the results of the breaker failure investigation (50-373/97016-01). Conclusions a
Ucensee personnel implemented corrective actions for the equipment failures listed i
above. The corrective action process was used by personnel involved with reviewing the failures and the inspectors observed that appropriate management attention was given to the equipment failures and the corrective action process was property utilize Operational Status of Facilities and Equipment
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O2.1 Out-of-Service (OOS) Error Performance Indicator Evaluation Insoection Scoce (71707)
The licensee's response, dated March 28,1997, to the 10 CFR Part 50.54(f) letter delineated performance indicators that would be used to trend and monitor plant performance. During this inspection period, the inspectors reviewed the performance indicator data reported by the licensee through September 1997 and assessed the performance indicator for OOS errors. The inspectors interviewed plant personnel and reviewed the following documents:
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Nuclear Operating Division (NOD)-OA.39, " Performance indicators for Nuclear Operations Branch," Revision 1
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Commonwealth Edison (Comed) Critical Performance Indicator 50.54(f) Variance Reports for August 1997 and September 1997
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PlFs completed during June through September 1997 for OOS issues
 
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. Qhservations and Findinas The OOS error performance indicator accuratey reflected the OOS errors documented by plant personnel between June 1997 and September 1997 on PIFs. In addition, the data used to evaluate LaSalle's performance in the area of OOS orrors was consistent with the definition of the data used to support the performance measure. Comed defined the OOS error performance indicator in NODCA.39 as the total number of OOS PIFs over the period of a month designated as a significant condition adverse to qualit For more than three months prior to October 1997, LaSalle station OOS errors had exceeded the site established threshold of greater than five t .CS errors and the NOD threshold of greater than one OOS error per month. In response to the performance indicator threshold being exceeded, the licensee increased corporate and site managemer't oversight of the OOS program and initiated correcuve actio u to address the OOS errors occurring in the plan Licenses personne: responsible for the oversight of the OOS error performance indicator were knowledgeable of the performance indicator criteria and corrective actions initiated to address the number of OOS errors. The licensee correctly determined that, while the number of OOS errors has remained relatively constant when compared to enriy 1997, the causes of the OOS errors changed from human performance problems in the plant to poor performance in the areas of scheduling and planning of OOS activities. The additional corrective actions initiated by the licensee to resolve the scheduling and planning issues appeared appropriat @clusions The OOS error performance indicator accurately reflected the status of significant OOS errors and personnel responsible for the indicator were knowledgeable of the OOS program problems. Also, corporate and site management responded as directed by procedure to address the OOS errors at LaSall .2  Cold Weather Preparations Inspection Scope (71714)
The inspectors reviewed the licensee's program for protecting safety-related systems against the effects of cold weather. The inspectors reviewed applicable licensee documentation, interviewed operations staff, and conducted plant system walkdown Observations and Findinas Operations personnel were performing LaSalle Opersting Surveillance (LOS)-ZZ-A2,
  " Preparation for Winter Operation," Revision 14, and making progress toward completing station preparations for the onset of cold weathe Due to the fact that both units were not operating, the licensee was installing equipment to supplement the existing plant heating systems. For example, the licensee planned to install a submerged air sparger which was designed to prevent the buildup of ice on submerged portions of the intake structure, primarily the trash racks, in addition, the
 
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licensee planned to stage other portable heating equipment in critical areas to proverd frening of sensitive equipment during extreme cold weathe The inspectors evaluated the stored emergency sources of cooling water, extemal to plant buildsngs, and found that they were heated and supplied with heat tracing on piping exposed dirocuy to the environment. In addition, operators were required by LOS-ZZ-A2 to verify the proper operation of heaters and heat tracin The licensee incorporated lessons loamed from last year into the planning for the -
forthcoming cold weather season. To address problems previously experienood, the licensee was installing additional heating equipmerd throughout the plant. No deficiencies were noted by the inspectors in the licensee's preparations for cold weather,      4 Conclusions The licensee's completed and planned actions for cold weather protection appeared adequate to protect emergency sources of cooling water and critical plant systems from cold weather. The inspectors considered the licensee's use of previous plard experience in formulating cold weather plans to be a good initiativ Miscelleneous Operations issues I
08 i. 10 CFR 50.54m Letter Commitment Review Inspection Scope (71707)
The inspectors reviewed licensee commitments, Numbers 1, 54. 75,100, 271, 316, and 322, pertaining to Commonwealth Edison Company's March 28,1997, response to NRC's request for information pursuant to 10 CFR 50.54(f) and observed two Management Review Meetings (MRM). Observatioris and Findinos On September 22,1997, the inspectors observed a portion of a MRM where 008 errors were discussed by the operations manager. Corporate managemord attended the meeting and the discussion addressed the licensee's corrective actions planned and completed for OOS errors, in the March 28,1997, response, the licensee had committed to review performance indicators that exceeded their corresponding thresholds. The OOS performance indicator exceeded the established threshold (as discussed in Section 02.1) and was reviewed during the meetin During the MRM held on October 23,1997, the licensee discussed the status of the implementation of the maintenance rule and the status of human performance improvements at LaSalle Station. During the human performance presentation, station management discussed the current status and trends, the status of the strategies identified in the restart plan for improving human performance, and potential changes to the human performance improvement initiatives necessary to address adverse
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. Conclusions The licensee made progress toward addressing 10 CFR 50.54(f) commdments discussed in the March 28,1997, letter to the NRC. The discussions in the MRM met commitments made by the licensee in the March 28,1997, letter to the NRC and management attention remaine1 focused on the improvement initiatives established at the statio IL Maintenance M1 Conduct of Maintenance M1.1 General Comments Inspection Scoce (61726)
The inspectors observed portions of the following surveillance tests:
  * LOS-HP-Q1, "HPCS [High Pressure Core Spray) System inservice Test,"
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Revision 35
  . LaSalle Technical Surveillance (LTS)-800-103, " Unit i 1 B Diesel Generator 1E22-S001 Start and Load Acceptance Surveillance," Revision 2
  . LOS-500-111, " Unit 1 integrated Division til ECCS [ Emergency Core Ccoling System) Respor.se Time Surveillance," Revision 4 Observations and Findinas Operations, maintenance, and engineering personnel followed procedures, were knowledgeable of the purpose of the overall test and the individual steps in the test, and prachced good three-way communications during the performance of surveillance test Engineering personnel conducted a thorough heightened level of awareness briefing prior to performing LTS-800103. Equipment failures which occurred during the tests were discussed in Section 01.2 and a surveillance procedure problem was discussed in Section E Conclusion The surveillance tests were performed in an acceptable manner and no concoms with personnel perfom1ance were identified by the inspector M2 Maintenance and Material Condition of Facilities and Equipment M2.1 General Comments Inspection Ccope (6270'A The inspectors obi erved portions of maintenance activities associated with the repair of the residual heat removal (RHR) heat exchanger discharge valves, repair of the EDG 1 A
 
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coohng water pump, and installation of a temporary modification to support safet t related electncal bus maintenance. The inspectors also interviewed engineering and maintenance personnel and reviewed associated work packages which included:
. Work Request (WR) g70070gg6-01, Perform Ultrasonic Test of RHR Piping
* WR g70039772-01, Replace Valve Discs and Guides of 1E12F0688
* WR g60085704-01, Pump [EDG 1A Cooling Water Pump) Outboard Seal Leak Qbservations and Findton The inspectors determined that, overall, the maintenance work was performed satisfactorily and in accordance with the appropriate work procedures. Also, the inspectors observed good coordination among departments involved with the maintenance activities. Outace department personnel incorporated lessons loamed from past maintenance activities into the work schedule which resulted in work progressing in a raore efficient manner. Personnelinvolved in work actMties were knowledgeable of the equipment operation, desig7, and work documents, The inspectors noted that the Division 11 RHR pump room had recently been decontaminated, in a+hion, mechanics could access the room and perform maintenance without constraints of anti contamination clothing. The supervisor with oversight of the 1B RHR service water heat exchanger discharge valve work commented that decontamination of the Division ll RHR comer room resulted in maintenance activities in the area being performed more efficiently and effectively than previously when the area was contaminate The inspectors identified one minor foreign material concem in the Division il core standby cooling system pump room. The inspectors informed the licensee and the items were properiy dispositioned. A sump cover plate was not installed, which created a situation where foreign material could be introduced into the sump. However, the sumps did not perform a safety-related function, Conclusions The licensee incorporated lessons leamed from previous maintenance activities into work planning and decontaminated the Division 11 RHR pump room. These improvements increased the licensee's ability to perform maintenance more efficientl M8 Miscellaneous Maintenance issues M8.1 (Clostd) Inspector Follow-up item 50-373/94005-02: Inoperable EDG penthouse heaters resulted in a differential temperature causing reverse rotation of the ventilation fans. The inspectors vesified that the licensee had completed an ana'ysis which ensured reverse rotation would not preclude the fans from performing as required on an automatic star This item was close _ -_-___-__-__ _
 
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M8.2 (Closed) Violation 50-373/9400210: Ten safety-related excess flow check valves were found to be improperly stored and no inspection or test program was found to be in place to anure quality of the poppet assemblies. The inspectors performed a walkdown of the warehouse and determined that equipment was stored as required by the licensee's material control program. Also, the inspectors reviewed documentation and determined that adequate receipt instructions were provided for warehouse personnel to verify proper quality of poppet assemolies. This item was close Ill. Ei.31neerina E2  Engineering Support of Facilities and Equipment E Failure to Perform Adeouate Emeroency Diessi Generator Surveillance Test Inspection Scope (37551)
The inspectors reviewed the licensee's actions to address technical specification testing that was not performed on all five EDGs at LaSalle Station. The inspectors evaluated the licensee's corrective actions, which included the performance of a special procedure, and reviewed documentation of the System Functional Performance Review (SFPR)
previously completed by the licensee for the EDGs.
 
! Observations and Findinos
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On October 8,1997, the licensee identified that a surveillance test procedure, LTS-500-111, " Unit 1 integrated Division 111 ECCS Response Time Surveillance,"
Revision 5, performed to meet technical specification surveillance requirement 4.8.1.1.2.d.9, was inndequat The surveillance test was performed with the EDG running and all dhe automatically connected loads being powered by the EDG under normal conditions instead of accident
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conditions, in the LTS-500-111 procedure, many of the loads were operated at a lower
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load than the postulated load conditions which would exist when the equipment was operating during an accident. Therefore, the test did not evaluate the worst-case accident load conditions of the EDGs to ensure that 2860 kW would not be exceede Technical Specification Surveillance Requirement 4.8.1.1.2.d.9 required that the licensee verify that all loarls that would be automatically connected to the EDG during an accident would not exceed the 2000-hour EDG rating of 2860 kW. However, the licensee had never documented that the required surveillance testing, using worst case loading conditions, was adequately completed for both LaSa!!e Unit 1 and Unit When the issue was identified by the licensee staff, the Shift Manager was notified and he declared all five EDGs at LaSalle inoperable. Subsequently, engineering personnel developed and completed a new surveillance procedure to document the verification required by technical specifications. The it'spectors reviewed the completed procedure 5  and did not identify any problems. The licensee documented the issue on a PIF and initiated a root cause investigatio _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _
 
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The licensee's failure to perform surveulance testing to vert'y that au M:I :^ " ;  ,
connected loads Jid not exceed the 2000 hour EDG reting of 2860 kW is a violation of  i Technical SpoolSostion Surveilleos Requirement 4.8.1.1.2.d.g (50 373/g7016 02;  j 60 374/g7016 02). However, the NRC is not citing this vioistion because it satis 6er, the  ;
nrtteria delineated in Section Vll.8.2 of the WRC's eniorcement policy (NUREG 1600).  !
Spool 6capy, the licensee has entered an extended shutdown; enforcement action was not considered necessary to achieve remedial action; the violation was based upon activities
,    of the licensee prior to the events leading to the shutdown; the violation would not be  >
r":;;:4E+1 at Severity Level 11; the viola 3an was not willful; the licenses's decision to
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  - restart the plant requires implicit NRC conoummos; and the violation was identined by the licensee,        i I
!  The inspootors reviewed documentation of the SFPR ooinpleted by the lloonses for the  f EDGs. The SFPR was performed by tha licensee to review the matettal condition W the
. EDGs and assess the adequacy of EDO survelRanoe tests. in this case, the engineer reviewing the EDG surveillance tems identined that the survedlance procedure used to d
satisfy the requiremente of Technical Specinostion SurvelNanos Requirement    i 4.8.1.1.2.d.g was irM+g:':. However, the engineer further reviewed the issue and subsorsently determined that the surveillance procedure was adequate, but did not doomneat his rationale for concieding that the procedure was socsplabl ,
The licensee initiated a PlF to document the engineer's error, in addition, the licensee  ;
reviswed the SFPR documentation for the standby gas treatment system, the primary  _
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oo:etainment vent and purge system, the etHR system, the EDGs, and the EDO diesel fuel  !
oil systems, to determine if additional errors similar to the one made by the engineer  '
dudng the SFPR of the ED3s existed. The licensee's review of the SFPR documentation for the five systems did not identify errors similar to the error made by the engineer performing the review of the EDG testing, Conclusions The licensee's corrective action for the inadequate surveillare:m testing was appropriate
  'and the licensee's review of the EDO loading was adequate. However, the licensee's failure to perform the required toot.nical specification testing was a non-cited violatio The licensee's review of sc SFPR documentation to ensure that identified problems were doc.:monted for resolution was appropriate. The inspectors concluded that the engineer performing the review of the EDG surveillance testing during time SFPR identified the
:  inadequate test but incorrectly determined that the test procedure, LTS-500111, was acceptable.
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l      IV. Plant Support P5 Sta. ' Training and Quallfloation in EP (82701)
P Emeroency_Biagt20dtLQuah6G800GE    !
J          i i Insoection Scoce f82205)      !
1    The inspectors used inspection Procedure 82205 to review the T r":sfr.s of the
;    licensee's shift personnel required to respond to plant emergencies, Observations and Findinas    ;
;    The inspectors determined that, overall, the licensee had implemented a program for providing breathing apparatus and appropriate training for opostors to meet the requirements of 10 CFR 50, Appendix R, Section H. However, of the 34 control room operators with a corredive lens restriction in their individual license, only 8 had eyewear t suitable for use with a breathing apparatus. The inspectors identified that there weio no
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Inst;uctions or procedures to ensure that all licensed operators, who were required to wear corredive lenses as a condition of their individual NRC licenses, had corrective t
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lenses of the appropriate type available should these individuals be required to wear self-
;-    contained breathing apparatus while performing licensed dutie The inspectors identified that LaSalle Operating Ab,wrmal (LOA)-FX-101, " Unit 1 Safe Shutdown with a Loss of Offsite Power and a Fire in the Control kaom or AEER [ Auxiliary ,
Electric Equipment Room)," Revialon 1, and LOA-RX-101, " Unit 1 Control Room
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Evacuation Abnormal," Revision 1, required operators to use control room enstgency breathing apparatus when the control room was uninhabitable concurrent with a loss of coolant accident (LOCA) or loss of offsite power (LOOP). Operators were required by the
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procedures to evaluate the control room environment during a loss of coolard concurrent
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with a fire in the control room and use the apparatus if necessary. However, as previously stated, the licensee's failure to have procedural or programmatic controls to ensure that corrective eyewear was available to operators which require it, is a violation ,
of 10 CFR 50, Appendix B, criterio1 V. However, this non repetitive, licennee-identified
!    and corrected violation is being trsated as a Non-C:ted Violation, consistent with Section Vll B.1 of the Niic Enforcement Policy (50-37'W97016-03; 50-374/97016 03).
 
The licensee had initiated corrective action to procure appropriate eyewsar inserts for the l breathing apparatus and to ensure that licensed operators have the necessary corrective lenses as specified as a corWition in their respective licenses. This action was scheduled to be complete 9 on December 15,1997. Furthermore, the licensee was evaluating NRC  .
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. Information Nohce 97 46, " Failure to Provide Special Lenses for Operators Using Respirator or Self-Contained Breathing Appamtus During Emergency Operations," which
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was scheduled to be completed by January 18,16:08. Operations persoi,r,elindicated  '
that a quarterty surveillance revision was in progress to add a review to verify that all licensed control room operators hav6 oprops'.ste eyewear for use with breathing apparatu .
An additional licensee initiative had been undertaken to qualify all mechanical maintenance mechanics in the use of respirators. This action exceeds the requirements
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I for emergency responders as specified in the station emergency pla The inspectors considered the mechanical maintenance department initiative to be good, Conclusions The licensee's failure to have procedures to ensure respirator eyewear was available for control room personnel was a non-cited violation. However, the licensee had initiated action to procure appropriate eyewear for current control room personnel. The license 6's permanent corrective action, which involved a surveillance revision to ensure operator eyewear was available, was in progress. The licensee's initiative to qualif/ au mechanical maintenanos department personnel was good and no other deficiencies were noted in the qualificutions of emergency responder VL Mananoment Meetinas X1 Exit Meeting Summary The inspectors presented the results of these inspections to licensee management listed below at an exit meeting on October 31,1997. The lloonsee Wc;d:$; +    1 the f6ndings presente ;
The inspectors asked the licensee if any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
 
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PARTIAL LIST OF PERSONS CONTACTED      j
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Comed          I
  *W. Subalusky, Site Wm President F. Dacimo. Plant General Manager        !
  *S. Smith. Plant Manager        !
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J. Mcdonald, Safety Quality Vertecetion/ Safety Assessment Manager
  *R. Holsterman, Maintenance Manager
  *R. Palmieri, System Engineering Supervisor      .
  *N. Hightower, Health Physics Supervisor        l
  *P. Bames, Regulatory Assurance Supervisor      !
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  * Present at exit meeting on October 31,199 l
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INSPECTION PROCEDURES USED i
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IP 37551 Onsite Engineering IP 40500 Effectiveness of Licensee Controis in identifying, ResoMng, and Preventing
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Problems lP 61726 Gurveillance Observation        >
IP 62703 Maintenance Observation IP 71707 Plant operations IP 71750 Plant Support Activities
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50 373/374-97016-02 NCV FC ve to perform M+j;": technical spoolAcetion test -
i 50 373/374-97016 43 NCV No procedurel or programmatic guidance for ensuring  -
prescription eyewearwas avalable    ;
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50 373/374-97016-02 NCV Failure to perform M+g::t- technical specincation test  >
50 373/374 97016-03 NCV No procedural or programmatic guidance for ensuring prescription eyewearwas available 50 373/94005 02 IFl inoperable EDG penthouse heaters resulted in a differential temperature cocaing reverse rotation of the ventilation fans 50 373/94002-10 VIO Ten safety felsted excess flow check vahm were found to  '
be impioperty stored and no inspection or test program was found to be in place to assure quality of the poppet assemblies i
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UST OF ACRONYMS USED AEER AuxAary Electric Equipment Room DRP  ')ivision of Reactor Projects COMED Commonwealth Edison ECCS Emerponcy Core Coolmg System EDG  Emergency Diesel Generator GE  General Electric HPC8 High Pressure Core Spray LOA  LaSalle Operating Abnormal LOCA Loss of Coolard Accident LOOP Loss o'Offsite Power LOP  LaSalle Ope:ation Procedure LOS  LaSalle Operating Surveillance LTS  LaS:lle Teenical Survemance MRM Management Review Meeting NOD  Nuclear Operating Division NRC Nuclear Regulatory Commission NCV Non-Cited Violation
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OOS Out-Of Servios PDR NRC Public Document Room PlF Problem identification Form RHR Residual Heat Removal SAT Station AuxiliaryTransformer SFPR System FuncGonal Performance Review WR  Work Reepost
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Latest revision as of 20:57, 1 January 2021

Insp Repts 50-373/97-16 & 50-374/97-16 on 970920-1031.One Violation Noted.Major Areas Inspected:Licensee Operations, Maint,Engineering & Plant Support
ML20202E953
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 11/28/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20202E936 List:
References
50-373-97-16, 50-374-97-16, NUDOCS 9712080189
Download: ML20202E953 (17)


Text

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U.S. NUCLEAR REGUt.ATORY COMMISSION REGION 111 ,

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Docket Nos: 5 4 373;50-374

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Ucense Nos: NF?-11, NPF-18 Repo:t No: 50 373/97016(DRP); 50 374/97016(DRP)

Ucensee: Commonwealth Edison Company Facility: LaSalle County Station, Units 1 and 2 1.ocation: 2601 N. 21st Road Marseilles,IL 61341

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Dates: September 20 - October 31,1997 inspectors: M. Huber, Senior Resident inspector J. Hansen, Resident inspector R. Crane, Resident inspector C. Mathews, lilinois Department of Nuclear Safety ( Approved by: . Anton Vogel, Acting Chief, Projects Branch 2

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Division of Reactor Projects I

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9712060189 971128 PDR ADOCK 05000373 G PDR ,

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EXECUTIVE SUMMARY LaSalle County Station, Units 1 and 2 NRC Inspection Report No. 50-373/07016(DRP); 50-374/g7010(DRP)

This inspection report included aspects of licensee operations, maintenance, engineering and plant support. The report covers a 6-week period of inspecuon conducted by the resident staf Ooerations

. Based on routine inspector observctions of control room acuvitiss, operators were attentive to the main control room panels, knowledgeable of various system configurations, and arware of actMiles in the plant. Shift pre-briefs were of high quality and effective in communicating plant conditions. (Secuon 01.1)

. The licensee initiated appropriate immediate correcuve actions to address equipment failures involving an emergency diesel generator failure to start and two breaker failure Plant personnel used the corrective action process at LaSalle to address the equipment failures. (Section 01.2)

. The licensee's completed and planned actions for protecung emergency sources of cooling water and critical plant systems imm cold weather were adequate. The inspectors considered the licensee's use of previous plant experience in formulating its cold weather plare to bs a good initiative. (Section 02.2)

Maintenance

  • The inspectors observed several surveillance activities and the surveillance tests were performed by plant personnel in an acceptable manner. The inspectors did not identify concems with personnel perfo.mance. (Section M1.1)

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The licensee incorporated lessons leamed from previous maintenance activities into work planning. In addition, the licensee decontaminated the Division ll residual heat removal (RHR) pump rocm. These improvements increased the licensee's ability to perform maintenance more efficiently. (Secuon M2.1)

Enaineerina

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An engineer performing a review of survelliance testing for the emergesy diesel generators during the System Functional Performanco Review (SFPR) incorrectif determined that a technical specification test procedure was acceptable. The engineer's error appeared to be an isolated instance where problems were not appropriately classlfied for resolution. The licensee's plan to review the SFPR documentation to ensure that identified problems were documented for resolution was appropriat (Section E2.1)

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. Plant Suooort

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The inspectors identified that the licensee did not have a procedure to ensure prescription eyewear was available for use with emergency breathing apparatus by licensed operators with a license condition requiring the use of correctivt eyewear when performing licensed duties. The licensee had identified the issue and was implementing corrective action to prevent recurrence. (Section P5.1)

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Report Details

' Summary of Plant Status During this inspection pedod, the hoensee maintained Unit 1 in cold shutdown (Operational Condition 4) for a forced outage and Unit 2 remained shut down for a refueling outage with all fuel removed from the reacto L Operations 01 Conduct of Operations 01.1 General Comments Inspection Scope (7170'A The inspectors conducted frequent reviews of ongoing plant operations by performing control room panel walkdowns and observing operator performanc Observation and Findinos Overall, the licensee operated the plant safely and performed activities in accordance with procedures. The inspectors observed routine control room activities such as operator tumovers, operators' response to annuretors, and surveillance activities (discussed in Section Mt.1). The operators were attentive to the main control room panels, knowledgeable of various system configurations, and aware of activities in the plant. The shift manager conducted pre-shift briefings for oncoming shift personnel which were thorough and effective in communicating plant operational and work achvity status, in one instance, the bdefing included presentations by engineering personnel and personnel from the outage management organization to the oncoming operating crew that had not been on shift for seven days. The presentations consisted of detailed updates of ongoing maintenance activities and were requested by the shift manager to ensure that the crew was well informed. Thro aghout the inspection period, the pre-shift briefings were conducte3 in a professional manner, both licensed and non-licensed operators discussted issues, and a good questioning attitude was displayed by operations personne Conclusions The inspectors observed that the operators were attentive to the main control room panels, knowledgeable of various system configurations, and aware of activities in the picnt. The licensee generally conducted plant operations in accordance with procedures and in a safe manner. The pre-shift briefings have consistectly been of high quality over

,; the entire inspection period. The shift manage /s request for de'. ailed discussions of plant -

maintenance activities for his operating crew to help ensure that the operators were informed of the plant status was goo _ _ _ - _ _ - _ - _ _

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01.2 Correcuv's Actions for Eautoment Failures Inspection Scope (71707. 40500)

The inspectors reviewed the licensee's correcGye scuons for the following equipment fauures:

  • O emergency diesel generator (EDG) supply breaker to Unit 2 failed to energize on September 27,1997, during surveulance testin * O EDG failed to start or '. september 29,1997, during surveulance testin * Unit 1 Division ill safety-related bus supply breaker from the station auxiliary transformer (SAT) failed to energize on October 7,1997, during surveillance testin Observations and Findinos For each of the equipmmt failures listed e5ove, the licensee generated a problem identification form (PlF), which is the beginning of the correcove action proces Appropriate management attention was placed on reviewing the failures and appropriate ,

personnel from various departments performed the root cause investigations for the failures. The licensee assessed the impact of the failures on the operabluty of other components, and determined the correcuve actions in a timely manne For the failure of the Unit 2 supply breaker from the 0 EDG, on September 27,1997, the licensee determined that the root cause for the failure was binding of the cubicle mounted breaker position switch linkage. The switch monitored the breaker position as part of the breaker control logic. The switch contacts must be open or the breaker would not energize. In this particular event, the switch never opened when the operator retumed the breaker to service (racked in the breaker) following maintenance. When the licensee was performing post-maintenance testing (PMT) of the breaker, it failed to actuate. The engineering department recommended correcuve actions which included additional switch inspections and revision to maintenance procedures to include the linkage configuration inspection. The licensee's root cause and corrective actions appeared appropriat On September 29,1997, during a surveillance test of the O EDG output breaker the O EDG failed to start. The operators were using a procedure which required that the operat; ' take manual control of the fuel system and slowly increase the EDG speed after it started. From the investigation, the licensee concluded that the procedure was adequate and the operators followed the procedure, in addition, the licensee did not ident g any equipment deficiencies. However, the licensea enhanced the EDG starting procedure by adding an operator to improve communications when the operators were performing the procedure and other steps to ensure that the EDG was running before operators could take manual control of the fuel system. The inspector reviewed the procedure, LaSalle Operating Procedure (LOP)-DG-02, " Diesel Generator Startup and Operation," Revision 25, and did not identify any problems with the procedure that was used by the operators. The inspectors reviewed the training that had previously been given to the operators. The inspectors determined that the operators had received

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training on the manual starting procedure and recently performed the LOP-DG-02 procedure without incident. The licensee's corrective actions appeared appropriat Concoming the failure of the Unit i Division lli supply breaker from the SAT on October 7, 1997, the licensee replaced the breaker and transported the failed breaker to the vendor for further inspection. The breaker that failed was manufactured by General P.'d (GE). While reviewing failure histories for GE breakers, the licensee idoufied two additionalinstances where GE breakers had failed to energize durin9 testing within the

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past year. The licensee evaluated the three GE breaker failures that occurred over the last year and concluded that no single common mode problem existed. However, the b root cause for the Unit 1 Division ill supply breaker from the SAT was still being evaluated by engineering personne The licensee's immediate corrective actions for the Division ill breaker failure appeared adequate. However, the licensee's investigation of the Unit 1 Division til supply from the SAT was ongoing to determine the root cause of the October 7,1997, failure and the potential for related failures of other GE breakers in service in the plant. This was considered an inspection followup item pending NRC review of the results of the breaker failure investigation (50-373/97016-01). Conclusions a

Ucensee personnel implemented corrective actions for the equipment failures listed i

above. The corrective action process was used by personnel involved with reviewing the failures and the inspectors observed that appropriate management attention was given to the equipment failures and the corrective action process was property utilize Operational Status of Facilities and Equipment

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O2.1 Out-of-Service (OOS) Error Performance Indicator Evaluation Insoection Scoce (71707)

The licensee's response, dated March 28,1997, to the 10 CFR Part 50.54(f) letter delineated performance indicators that would be used to trend and monitor plant performance. During this inspection period, the inspectors reviewed the performance indicator data reported by the licensee through September 1997 and assessed the performance indicator for OOS errors. The inspectors interviewed plant personnel and reviewed the following documents:

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Nuclear Operating Division (NOD)-OA.39, " Performance indicators for Nuclear Operations Branch," Revision 1

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Commonwealth Edison (Comed) Critical Performance Indicator 50.54(f) Variance Reports for August 1997 and September 1997

PlFs completed during June through September 1997 for OOS issues

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. Qhservations and Findinas The OOS error performance indicator accuratey reflected the OOS errors documented by plant personnel between June 1997 and September 1997 on PIFs. In addition, the data used to evaluate LaSalle's performance in the area of OOS orrors was consistent with the definition of the data used to support the performance measure. Comed defined the OOS error performance indicator in NODCA.39 as the total number of OOS PIFs over the period of a month designated as a significant condition adverse to qualit For more than three months prior to October 1997, LaSalle station OOS errors had exceeded the site established threshold of greater than five t .CS errors and the NOD threshold of greater than one OOS error per month. In response to the performance indicator threshold being exceeded, the licensee increased corporate and site managemer't oversight of the OOS program and initiated correcuve actio u to address the OOS errors occurring in the plan Licenses personne: responsible for the oversight of the OOS error performance indicator were knowledgeable of the performance indicator criteria and corrective actions initiated to address the number of OOS errors. The licensee correctly determined that, while the number of OOS errors has remained relatively constant when compared to enriy 1997, the causes of the OOS errors changed from human performance problems in the plant to poor performance in the areas of scheduling and planning of OOS activities. The additional corrective actions initiated by the licensee to resolve the scheduling and planning issues appeared appropriat @clusions The OOS error performance indicator accurately reflected the status of significant OOS errors and personnel responsible for the indicator were knowledgeable of the OOS program problems. Also, corporate and site management responded as directed by procedure to address the OOS errors at LaSall .2 Cold Weather Preparations Inspection Scope (71714)

The inspectors reviewed the licensee's program for protecting safety-related systems against the effects of cold weather. The inspectors reviewed applicable licensee documentation, interviewed operations staff, and conducted plant system walkdown Observations and Findinas Operations personnel were performing LaSalle Opersting Surveillance (LOS)-ZZ-A2,

" Preparation for Winter Operation," Revision 14, and making progress toward completing station preparations for the onset of cold weathe Due to the fact that both units were not operating, the licensee was installing equipment to supplement the existing plant heating systems. For example, the licensee planned to install a submerged air sparger which was designed to prevent the buildup of ice on submerged portions of the intake structure, primarily the trash racks, in addition, the

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licensee planned to stage other portable heating equipment in critical areas to proverd frening of sensitive equipment during extreme cold weathe The inspectors evaluated the stored emergency sources of cooling water, extemal to plant buildsngs, and found that they were heated and supplied with heat tracing on piping exposed dirocuy to the environment. In addition, operators were required by LOS-ZZ-A2 to verify the proper operation of heaters and heat tracin The licensee incorporated lessons loamed from last year into the planning for the -

forthcoming cold weather season. To address problems previously experienood, the licensee was installing additional heating equipmerd throughout the plant. No deficiencies were noted by the inspectors in the licensee's preparations for cold weather, 4 Conclusions The licensee's completed and planned actions for cold weather protection appeared adequate to protect emergency sources of cooling water and critical plant systems from cold weather. The inspectors considered the licensee's use of previous plard experience in formulating cold weather plans to be a good initiativ Miscelleneous Operations issues I

08 i. 10 CFR 50.54m Letter Commitment Review Inspection Scope (71707)

The inspectors reviewed licensee commitments, Numbers 1, 54. 75,100, 271, 316, and 322, pertaining to Commonwealth Edison Company's March 28,1997, response to NRC's request for information pursuant to 10 CFR 50.54(f) and observed two Management Review Meetings (MRM). Observatioris and Findinos On September 22,1997, the inspectors observed a portion of a MRM where 008 errors were discussed by the operations manager. Corporate managemord attended the meeting and the discussion addressed the licensee's corrective actions planned and completed for OOS errors, in the March 28,1997, response, the licensee had committed to review performance indicators that exceeded their corresponding thresholds. The OOS performance indicator exceeded the established threshold (as discussed in Section 02.1) and was reviewed during the meetin During the MRM held on October 23,1997, the licensee discussed the status of the implementation of the maintenance rule and the status of human performance improvements at LaSalle Station. During the human performance presentation, station management discussed the current status and trends, the status of the strategies identified in the restart plan for improving human performance, and potential changes to the human performance improvement initiatives necessary to address adverse

. performance trend =

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. Conclusions The licensee made progress toward addressing 10 CFR 50.54(f) commdments discussed in the March 28,1997, letter to the NRC. The discussions in the MRM met commitments made by the licensee in the March 28,1997, letter to the NRC and management attention remaine1 focused on the improvement initiatives established at the statio IL Maintenance M1 Conduct of Maintenance M1.1 General Comments Inspection Scoce (61726)

The inspectors observed portions of the following surveillance tests:

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Revision 35

. LaSalle Technical Surveillance (LTS)-800-103, " Unit i 1 B Diesel Generator 1E22-S001 Start and Load Acceptance Surveillance," Revision 2

. LOS-500-111, " Unit 1 integrated Division til ECCS [ Emergency Core Ccoling System) Respor.se Time Surveillance," Revision 4 Observations and Findinas Operations, maintenance, and engineering personnel followed procedures, were knowledgeable of the purpose of the overall test and the individual steps in the test, and prachced good three-way communications during the performance of surveillance test Engineering personnel conducted a thorough heightened level of awareness briefing prior to performing LTS-800103. Equipment failures which occurred during the tests were discussed in Section 01.2 and a surveillance procedure problem was discussed in Section E Conclusion The surveillance tests were performed in an acceptable manner and no concoms with personnel perfom1ance were identified by the inspector M2 Maintenance and Material Condition of Facilities and Equipment M2.1 General Comments Inspection Ccope (6270'A The inspectors obi erved portions of maintenance activities associated with the repair of the residual heat removal (RHR) heat exchanger discharge valves, repair of the EDG 1 A

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coohng water pump, and installation of a temporary modification to support safet t related electncal bus maintenance. The inspectors also interviewed engineering and maintenance personnel and reviewed associated work packages which included:

. Work Request (WR) g70070gg6-01, Perform Ultrasonic Test of RHR Piping

  • WR g70039772-01, Replace Valve Discs and Guides of 1E12F0688
  • WR g60085704-01, Pump [EDG 1A Cooling Water Pump) Outboard Seal Leak Qbservations and Findton The inspectors determined that, overall, the maintenance work was performed satisfactorily and in accordance with the appropriate work procedures. Also, the inspectors observed good coordination among departments involved with the maintenance activities. Outace department personnel incorporated lessons loamed from past maintenance activities into the work schedule which resulted in work progressing in a raore efficient manner. Personnelinvolved in work actMties were knowledgeable of the equipment operation, desig7, and work documents, The inspectors noted that the Division 11 RHR pump room had recently been decontaminated, in a+hion, mechanics could access the room and perform maintenance without constraints of anti contamination clothing. The supervisor with oversight of the 1B RHR service water heat exchanger discharge valve work commented that decontamination of the Division ll RHR comer room resulted in maintenance activities in the area being performed more efficiently and effectively than previously when the area was contaminate The inspectors identified one minor foreign material concem in the Division il core standby cooling system pump room. The inspectors informed the licensee and the items were properiy dispositioned. A sump cover plate was not installed, which created a situation where foreign material could be introduced into the sump. However, the sumps did not perform a safety-related function, Conclusions The licensee incorporated lessons leamed from previous maintenance activities into work planning and decontaminated the Division 11 RHR pump room. These improvements increased the licensee's ability to perform maintenance more efficientl M8 Miscellaneous Maintenance issues M8.1 (Clostd) Inspector Follow-up item 50-373/94005-02: Inoperable EDG penthouse heaters resulted in a differential temperature causing reverse rotation of the ventilation fans. The inspectors vesified that the licensee had completed an ana'ysis which ensured reverse rotation would not preclude the fans from performing as required on an automatic star This item was close _ -_-___-__-__ _

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M8.2 (Closed) Violation 50-373/9400210: Ten safety-related excess flow check valves were found to be improperly stored and no inspection or test program was found to be in place to anure quality of the poppet assemblies. The inspectors performed a walkdown of the warehouse and determined that equipment was stored as required by the licensee's material control program. Also, the inspectors reviewed documentation and determined that adequate receipt instructions were provided for warehouse personnel to verify proper quality of poppet assemolies. This item was close Ill. Ei.31neerina E2 Engineering Support of Facilities and Equipment E Failure to Perform Adeouate Emeroency Diessi Generator Surveillance Test Inspection Scope (37551)

The inspectors reviewed the licensee's actions to address technical specification testing that was not performed on all five EDGs at LaSalle Station. The inspectors evaluated the licensee's corrective actions, which included the performance of a special procedure, and reviewed documentation of the System Functional Performance Review (SFPR)

previously completed by the licensee for the EDGs.

! Observations and Findinos

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On October 8,1997, the licensee identified that a surveillance test procedure, LTS-500-111, " Unit 1 integrated Division 111 ECCS Response Time Surveillance,"

Revision 5, performed to meet technical specification surveillance requirement 4.8.1.1.2.d.9, was inndequat The surveillance test was performed with the EDG running and all dhe automatically connected loads being powered by the EDG under normal conditions instead of accident

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conditions, in the LTS-500-111 procedure, many of the loads were operated at a lower

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load than the postulated load conditions which would exist when the equipment was operating during an accident. Therefore, the test did not evaluate the worst-case accident load conditions of the EDGs to ensure that 2860 kW would not be exceede Technical Specification Surveillance Requirement 4.8.1.1.2.d.9 required that the licensee verify that all loarls that would be automatically connected to the EDG during an accident would not exceed the 2000-hour EDG rating of 2860 kW. However, the licensee had never documented that the required surveillance testing, using worst case loading conditions, was adequately completed for both LaSa!!e Unit 1 and Unit When the issue was identified by the licensee staff, the Shift Manager was notified and he declared all five EDGs at LaSalle inoperable. Subsequently, engineering personnel developed and completed a new surveillance procedure to document the verification required by technical specifications. The it'spectors reviewed the completed procedure 5 and did not identify any problems. The licensee documented the issue on a PIF and initiated a root cause investigatio _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _

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The licensee's failure to perform surveulance testing to vert'y that au M:I :^ " ; ,

connected loads Jid not exceed the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> EDG reting of 2860 kW is a violation of i Technical SpoolSostion Surveilleos Requirement 4.8.1.1.2.d.g (50 373/g7016 02; j 60 374/g7016 02). However, the NRC is not citing this vioistion because it satis 6er, the  ;

nrtteria delineated in Section Vll.8.2 of the WRC's eniorcement policy (NUREG 1600).  !

Spool 6capy, the licensee has entered an extended shutdown; enforcement action was not considered necessary to achieve remedial action; the violation was based upon activities

, of the licensee prior to the events leading to the shutdown; the violation would not be >

r":;;:4E+1 at Severity Level 11; the viola 3an was not willful; the licenses's decision to

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- restart the plant requires implicit NRC conoummos; and the violation was identined by the licensee, i I

! The inspootors reviewed documentation of the SFPR ooinpleted by the lloonses for the f EDGs. The SFPR was performed by tha licensee to review the matettal condition W the

. EDGs and assess the adequacy of EDO survelRanoe tests. in this case, the engineer reviewing the EDG surveillance tems identined that the survedlance procedure used to d

satisfy the requiremente of Technical Specinostion SurvelNanos Requirement i 4.8.1.1.2.d.g was irM+g:':. However, the engineer further reviewed the issue and subsorsently determined that the surveillance procedure was adequate, but did not doomneat his rationale for concieding that the procedure was socsplabl ,

The licensee initiated a PlF to document the engineer's error, in addition, the licensee  ;

reviswed the SFPR documentation for the standby gas treatment system, the primary _

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oo:etainment vent and purge system, the etHR system, the EDGs, and the EDO diesel fuel  !

oil systems, to determine if additional errors similar to the one made by the engineer '

dudng the SFPR of the ED3s existed. The licensee's review of the SFPR documentation for the five systems did not identify errors similar to the error made by the engineer performing the review of the EDG testing, Conclusions The licensee's corrective action for the inadequate surveillare:m testing was appropriate

'and the licensee's review of the EDO loading was adequate. However, the licensee's failure to perform the required toot.nical specification testing was a non-cited violatio The licensee's review of sc SFPR documentation to ensure that identified problems were doc.:monted for resolution was appropriate. The inspectors concluded that the engineer performing the review of the EDG surveillance testing during time SFPR identified the

inadequate test but incorrectly determined that the test procedure, LTS-500111, was acceptable.

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l IV. Plant Support P5 Sta. ' Training and Quallfloation in EP (82701)

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J i i Insoection Scoce f82205)  !

1 The inspectors used inspection Procedure 82205 to review the T r":sfr.s of the

licensee's shift personnel required to respond to plant emergencies, Observations and Findinas  ;
The inspectors determined that, overall, the licensee had implemented a program for providing breathing apparatus and appropriate training for opostors to meet the requirements of 10 CFR 50, Appendix R, Section H. However, of the 34 control room operators with a corredive lens restriction in their individual license, only 8 had eyewear t suitable for use with a breathing apparatus. The inspectors identified that there weio no

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Inst;uctions or procedures to ensure that all licensed operators, who were required to wear corredive lenses as a condition of their individual NRC licenses, had corrective t

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lenses of the appropriate type available should these individuals be required to wear self-

- contained breathing apparatus while performing licensed dutie The inspectors identified that LaSalle Operating Ab,wrmal (LOA)-FX-101, " Unit 1 Safe Shutdown with a Loss of Offsite Power and a Fire in the Control kaom or AEER [ Auxiliary ,

Electric Equipment Room)," Revialon 1, and LOA-RX-101, " Unit 1 Control Room

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Evacuation Abnormal," Revision 1, required operators to use control room enstgency breathing apparatus when the control room was uninhabitable concurrent with a loss of coolant accident (LOCA) or loss of offsite power (LOOP). Operators were required by the

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procedures to evaluate the control room environment during a loss of coolard concurrent

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with a fire in the control room and use the apparatus if necessary. However, as previously stated, the licensee's failure to have procedural or programmatic controls to ensure that corrective eyewear was available to operators which require it, is a violation ,

of 10 CFR 50, Appendix B, criterio1 V. However, this non repetitive, licennee-identified

! and corrected violation is being trsated as a Non-C:ted Violation, consistent with Section Vll B.1 of the Niic Enforcement Policy (50-37'W97016-03; 50-374/97016 03).

The licensee had initiated corrective action to procure appropriate eyewsar inserts for the l breathing apparatus and to ensure that licensed operators have the necessary corrective lenses as specified as a corWition in their respective licenses. This action was scheduled to be complete 9 on December 15,1997. Furthermore, the licensee was evaluating NRC .

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. Information Nohce 97 46, " Failure to Provide Special Lenses for Operators Using Respirator or Self-Contained Breathing Appamtus During Emergency Operations," which

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was scheduled to be completed by January 18,16:08. Operations persoi,r,elindicated '

that a quarterty surveillance revision was in progress to add a review to verify that all licensed control room operators hav6 oprops'.ste eyewear for use with breathing apparatu .

An additional licensee initiative had been undertaken to qualify all mechanical maintenance mechanics in the use of respirators. This action exceeds the requirements

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I for emergency responders as specified in the station emergency pla The inspectors considered the mechanical maintenance department initiative to be good, Conclusions The licensee's failure to have procedures to ensure respirator eyewear was available for control room personnel was a non-cited violation. However, the licensee had initiated action to procure appropriate eyewear for current control room personnel. The license 6's permanent corrective action, which involved a surveillance revision to ensure operator eyewear was available, was in progress. The licensee's initiative to qualif/ au mechanical maintenanos department personnel was good and no other deficiencies were noted in the qualificutions of emergency responder VL Mananoment Meetinas X1 Exit Meeting Summary The inspectors presented the results of these inspections to licensee management listed below at an exit meeting on October 31,1997. The lloonsee Wc;d:$; + 1 the f6ndings presente ;

The inspectors asked the licensee if any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED j

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Comed I

  • W. Subalusky, Site Wm President F. Dacimo. Plant General Manager  !
  • S. Smith. Plant Manager  !

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J. Mcdonald, Safety Quality Vertecetion/ Safety Assessment Manager

  • R. Holsterman, Maintenance Manager
  • R. Palmieri, System Engineering Supervisor .
  • N. Hightower, Health Physics Supervisor l
  • P. Bames, Regulatory Assurance Supervisor  !

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  • Present at exit meeting on October 31,199 l

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INSPECTION PROCEDURES USED i

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IP 37551 Onsite Engineering IP 40500 Effectiveness of Licensee Controis in identifying, ResoMng, and Preventing

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Problems lP 61726 Gurveillance Observation >

IP 62703 Maintenance Observation IP 71707 Plant operations IP 71750 Plant Support Activities

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C048 OPEN, CLOSED, OR DISCUSSED (

Qlt80 50 373-97016-01 IFl Reviu of GE breaker failure investigation ,

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50 373/374-97016-02 NCV FC ve to perform M+j;": technical spoolAcetion test -

i 50 373/374-97016 43 NCV No procedurel or programmatic guidance for ensuring -

prescription eyewearwas avalable  ;

Closed ,

50 373/374-97016-02 NCV Failure to perform M+g::t- technical specincation test >

50 373/374 97016-03 NCV No procedural or programmatic guidance for ensuring prescription eyewearwas available 50 373/94005 02 IFl inoperable EDG penthouse heaters resulted in a differential temperature cocaing reverse rotation of the ventilation fans 50 373/94002-10 VIO Ten safety felsted excess flow check vahm were found to '

be impioperty stored and no inspection or test program was found to be in place to assure quality of the poppet assemblies i

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UST OF ACRONYMS USED AEER AuxAary Electric Equipment Room DRP ')ivision of Reactor Projects COMED Commonwealth Edison ECCS Emerponcy Core Coolmg System EDG Emergency Diesel Generator GE General Electric HPC8 High Pressure Core Spray LOA LaSalle Operating Abnormal LOCA Loss of Coolard Accident LOOP Loss o'Offsite Power LOP LaSalle Ope:ation Procedure LOS LaSalle Operating Surveillance LTS LaS:lle Teenical Survemance MRM Management Review Meeting NOD Nuclear Operating Division NRC Nuclear Regulatory Commission NCV Non-Cited Violation

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OOS Out-Of Servios PDR NRC Public Document Room PlF Problem identification Form RHR Residual Heat Removal SAT Station AuxiliaryTransformer SFPR System FuncGonal Performance Review WR Work Reepost

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