ML20236V709

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-373/98-05 & 50-374/98-05 on 980605

ML20236V709
Person / Time
Site:	LaSalle
Issue date:	07/28/1998
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O COMMONWEALTH EDISON CO.
References
50-373-98-05, 50-373-98-5, 50-374-98-05, 50-374-98-5, NUDOCS 9808040153
Download: ML20236V709 (1)

See also: IR 05000373/1998005

Text

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July 28, 1998 l

Mr. Oliver D. Kingsley

President, Nuclear Generation Group

Commonwealth Edison Company

ATTN: Regulatory Services

Executive Towers West 111

1400 Opus Place, Suite 500

Downers Grove, IL 60515

l Dear Mr. Kingsley:

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-373/98005(DRS);

50-374/98005(DRS))

This will acknowledge receipt of your letter dated July 3,1998 in response to our letter

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dated June 5,1998, transmitting a Notice of Violation associated with Inspection Report No.

50-373/98005(DRS); 50-374/98005(DRS). These reports summarized the results of an

Engineering and Technical Support inspection at your LaSalle County Station. We have

reviewed your corrective actions and have no further questions at this time. These corrective

actions will be examined during future inspections.

Sincerely,

s/Geoffrey E. Grant

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Geoffrey E. Grant, Director

Division of Reactor Projects

! Docket Nos.: 50-373;50-374

License Nos.: NPF-11; NPF-18

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Enclosure: Ltr dated 7/3/98

F. Dacimo to USNRC

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See Attached Distribution

DOCUMENT NAME: G:\LAS98005.TY

To receive a copf of this document, Indicate in the box 'C" = Copy w/o attach /enci "E" = Copy w/ attach / encl "N" = No copy

OFFICE Rill:DRs / Rill:DRs Rill:DRP Rill:EICs i Rill:DRs

NAME Duncan/lc Jacobson Hills ) Clayton N Grant @

DATE: 7M/98 7/2JP98 7/bh 7d98 7t@/98

OFF CIAL RECORD COPY

9900040153 980728  ?

PDR ADOCK 05000373 i

G PDR

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O. Kingsley 2

cc w/o enct: M. Wallace, Senior Vice President

D. Helwig, Senior Vice President

G. Stanley, PWR Vice President

J. Perry, BWR.Vice President

D. Farrar, Regulatory

Services Manager -

1. Johnson, Licensing Director

DCD - Licensing

T. O'Connor, Station Manager

P. Barnes, Regulatory Assurance

Supervisor

cc w/ encl: R. Hubbard

N. Schloss, Economist

Office of the Attorney General i

State Liaison Officer J

Chairman, Illinois Commerce

Commission

Distribution:

SAR (E-Mail)

Project Mgr., NRR w/enci i

C. Paperiello, Rill w/enci

! J. Caldwell, Rlli w/enct

B. Clayton, Rlli w/ encl

SRI LaSalle w/ enc!

DRP.w/ encl

TSS w/ enc!

DRS (2) w/enci 4

Rlli PRR w/enct

PUBLIC IE-01 w/enci

Docket File w/enci

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GREENS 4

IEO (E-Mail)-

DOCDESK (E-Mail)

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/* 125alle Generating 5tation

2601 North 21st Road

hMidg

', Marseilles. IL 61341-9757

Tel 815-3574761

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July 3,1998

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l United States Nu'cleaf Regulatory Commission

Attention: Document Control Desk

Washington, D. C. 20555

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Subject: Notlce of Violation, NRC Inspection Report

50-373/374-98005

LaSalle County Station, Units 1 and 2 i

Facility Operating License NPF-11 and NPF-18 I

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NRC Docket Nos. 50-373 and 50-374

Reference: G. E. Grant letter to O. D. Kingsley, dated June 5,1998,

Transmitting NRC Inspection Report 50-373/374-98005

The enclosed Attachment A containt ' :alle County Station's response to

the Notice of Violation that was transmittoc' the Reference I.etter.

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

If there are any questions or comments conceming this letter, please refer

them to Harold D. Pontious, Jr., Regulatory Assurance Manager, at

(815) 357-6761, extension 2383.

Respectfully, '

a -

Fred R. Dacimo

Site Vice President

LaSalle County Station

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Enclosures ,.

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cc: ./C. A. Paperiello, Acting NRC Region 111 Administrator -

M. P. Huber, NRC Senior Resident inspector - LaSalle

D. M. Skay, Project Manager - NRR - LaSalle

F. Niziolek, IDNS Senior Reactor Analyst

A th1icom Company

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' ATTACHMENT A

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RESPONSE TO NOTICE @F VIOLATION l

NRC INSPECTION REPORT

373/374-98005

VIOLATION: 373/374-98005-03

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10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and

Drawings," requires that activities affecting quality shall be prescribed by ,

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documented instructions, procedures, or drawings, of a type appropriate to l

the circumstances and shall be accomplished in accordance with these - !

( instructions, procedures, or drawings.

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, Contrary to ibe above, as of April 21,1998, the licensee failed to adequately

l perform combustible loading calculations required by LaSalle Administrative

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Procedure LAP 240-6, " Temporary Alterations," Revision 36, dated

l August 21,1997, associated with temporary alterations 2-0030-97 and

l 1-0122-97 on August 12,1997, and September 26,1997, respectively. As a

result, the licensee failed to identify that the approved fire protection program  !

may have been adversely impacted.

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REASON FOR VIOLATION:

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Commonwealth Edison Company (Comed) agrees that for temporary

alterations (TALTs) 2-0030 97 and 1-0122-97 the combustible loading

calculations, required by LaSalle Administrative Procedure LAP 240-6,

" Temporary Alterations," were not adequately performed.

An investigation identified that TALTs 2-0030-97 and 1-0122 97 were -

duplicated from TALT 1-0121-97. The engineer who prepared the Fire

Protection Screening for TALT 1-0121-97 failed to determine an accurate

value of combustible material per unit length of hose and then compounded '

l the error by performing an inaccurate multiplication function. Additionally,

, the supervisor who reviewed the data failed to notice the error in the

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calculation. These errors are broadly characterized as inattention to detail

and inadequate self-checking.

The p.er unit combustible material value used for TALT 1-0121-97 was then

used without additional review for the Fire Protection Screening in

TALTs 2-0029-97,1-0122-97, and 2-0030-97. This caused the " Change in

Combustible Loading" calculation in Nuclear Engineering Procedure

(NEP) 04-07 Exhibit A, Table 1, for each of the four noted TALTs, to be

erroneously calculated at less than 1000 BTU per square foot. Because the

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calculated value was less than 1000 BTU per square foot that is procedurally

required, the additional evaluation was not performed. Therefore, the actual

increase in combustible loading of 1257 BTU per square foot of fire zone '

area (actual value when calculation was performed correctly) was not

[~ evaluated.

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ATTACHMENT A

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RESPONSE TO NOTICE OF VIOLATION

NRC INSPECTION REPORT

373/374-98005

The consequences of this incident were minimal. Comparison of

combustible loading limits for the applicable fire zones to the total

combustible loading in each zone, plus the incremental increase in the zone

due to the hose, demonstrated that significant margin (approximately 95%)

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was still available before the combustible limit would be reached. Therefore,

the combustible loading limits were not challenged.

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L CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

An evaluation of this issue identified two additional related TALTs

l (1-0121-97 and 2-0029-97) with the same type combustible loading

i calculation error. These TALTs performed similar plant modifications for the

1 E12-F068A and 2E12-F068A residual heat removal service water isolation

valves, respectively. These TALTs were the predecessors of

l TALTs 1-0122-97 and 2'-0030 97 identified in the violation.

When the combustible loading calculation in the Fire Protection Screening

L for TALT 2-0030-97 was found to be in error, the calculation was corrected ,

l (which also addressed the three other TALTs) and the Fire Protection 4

! Screening revised. The revised screening was evaluated and accepted by i

the Fire Protection Program Coordinator. It concluded that there was no I

i adverse impact to the LaSalle Station Fire Protection commitments. It was

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' also noted that no extended conditions existed since the four TALTs affected l

by the error had been removed. '

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Additionally, a review of all active installed TALTs was performed to 1

determine if any had similar Fire Protection Screening issues. No active l

TALTs with Fire Protection Screenings were identified as having similar

errors in the combustible loading calculation.

CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:

The supervisor involved in the event has been counseled and now

understands the importance of reviewing calculations to ensure they are

complete and accurate.

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This event has been discussed in the design engineering weekly

l communications meeting with emphasis placed on the importance of

accuracy in performing and reviewing calculations.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was achieved on April 15,1998, with the evaluation of the

correctly calculated combustible loading.

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. ATTACHMENT A

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RESPONSE TO NOTICE OF VIOLATION

NRC INSPECTION REPORT

373/374-98005

VIOLATION: 373/374-9800504

10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions," requires that

measures shall be established to assure that conditions adverse to quality,

such as failures, malfunctions, deficiencies, and nonconformances are

promptly identified and corrected. In the case of significant conditions

adverse to quality, the measures shall assure that the cause of the condition

is determined and corrective action taken to preclude repetition.

Contrary to the above, on March 27,1998, the NRC identified that an

unauthorized plant design change to the Unit 0,1 A and 2A diesel generator

air box drains that had been previously identified by the NRC on

June 19,1997, had not been corrected.

REASON FOR VIOLATION:

Comed agrees that the unauthorized plant design change to the Unit 0,1 A

and 2A diesel generator er box drains was not corrected in a timely manner.

A review of this incident indicates a human performance error and a lack of

follow through on the part of the system engineer in that the administrative

procedure was not followed which resulted in the issue not being resolved in

a timely manner.

A Problem identification Form (PIF) was written to bring this issue to

management's attention on June 16,1997. This PIF was closed to an

existing Engineering Request (ER) which asked for an evaluation to hard

pipe the Air Box drains to floor drains or justify the use of tygon tubing in this

application. This was coded as a Plant Design Change Request (PDCR)

which was assigned a "B" priority under the ER process with a due date of

June 24,1998. This required presentation to a technical review committee

within six months of the initiation of the ER.

The system engineer " approved" the ER on August 5,1997, forwarding it to

Design Engineering without completing the required technical evaluation in

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accordance with LaSalle Administrative Procedure (LAP) 130016,

" Engineering Request." The system engineer who forwarded the ER did'not '

' provide comments or complete required actions when he approved the ER,

therefore, no follow-up action was taken and the issue remained in the ER

orocess and was not presented to a technical review committee.

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A second PIF was written on March 31,1998, identifying the lack of follow-

up on the initial discrepancy. The ER'was then evaluated and received final

approval on May 5,1998, with the decision to "as-build" the current

configuration.

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ATTACHMENT A

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RESPONSE TO NOTICE OF VIOLATION

NRC INSPECTION REPORT

373/374-98005

A contributing factor in this failure was the high tumover of personnel

involved in the resolution of this discrepancy. The Temporary Alteration

Coordinator who originated the action left in late 1997. The system engineer

responsible for the evaluation also left at the same time. The combination

of these discreet events directly contributed to the lack of emphasis being

placed on this corrective action.

CORRECTIVE STEPS.TAKEN.AND RESULTS ACHIEVED:

The current configuration was evaluated as an "as-built" change, which has

received a technical evaluation and a safety evaluation under 10 CFR 50.59.

The results of the initial technical evaluation confirmed that there was no

adverse impact on the diesels in this configuration. This configuration

complies with the manufacturer's recommendation to keep the drains open

to preclude moisture build-up in the air boxes.

CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATION:

The engineer involved in this event is no longer employed by Comed.

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System Readiness Reviews (SRR) have been conducted in preparation for

Unit 1 start-up. This required a review of all outstanding work (including

ERs) against a given system and the identification of issues which require

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action for restart or an affirmation that the work is appropriately classified

and can be worked to its current schedule date following restart. A board of

management personnel from multiple departments reviews the results of the

SSR. On the board's recommendation the system is classified as ready.

This review will ensure systems have no unauthorized design changes.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was achieved on June 19,1998, with completion of the "as

built" evaluation for the tygon tubing.

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ATTACHMENT A

• RESPONSE TO NOTICE OF VIOLATION

NRC INSPECTION REPORT

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373/374-98005

VIOLATION: 373/374-98005-12

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10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions," requires that

measures shall be established to assure that conditions adverse to quality,

such as failures, malfunctions, deficiencies, and nonconformances are '

promptly identified and corrected. In the case of significant conditions

adverse to quality, the measures shall assure that the cause of the condition I

l Is determined and corrective action taken to preclude repetition.

Contrary to the above, on March 27,1998, the NRC identified that the

licensee had failed to update the station fuse list since April 1994. As a

result, several hundred deficiency reports regarding safety-related and f

non-safety-related fuse discrepancies had not been evaluated.

REASON FOR VIOLATION:

Comed agrees that the fuse discrepancies identified in 1994 were not

properly addressed. Numerous fuse discrepancies associated with safety

, related and non-safety-related equipment were identified, but were not

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reviewed or evaluated. LaSalle Administrative Procedure (LAP) 400-11,

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" Fuse Replacement Program" failed to provide adequate guidance to ensure

l timely resolution of fuse issues. In addition, there was complacency and a

i lack of attention regarding the fuse control program on the part of

management personnel that also contributed to the violation. Historically,

I fuse discrepancies rarely resulted in operability issues or unacceptable

fuses. This led personnel to focus on the fact that the fuse size

discrepancies were identified rather than focusing on evaluating the

discrepancies.

l CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

Upon identifying that the fuse discrepancies were not evaluated, the

discrepancies were separated into two categories. The first category

contained actual fuse discrepancies, for example, the installed fuse was a

different size or type than that which was stated on the fuse list. The second

category are not actual discrepancies and can be characterized as missing

information on the fuse list (e.g., design size, fuse type, etc.).

A preliminary assessment of each fuse discrepancy in the first category was

performed. This assessment was based on a review of the affected

schematic diagram and engineering judgment. The main criteria for the

assessments were to determine if the installed fuse is able to handle the

continuous circuit load. This assessment determined that all of the fuses

were acceptable.

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ATTACHMENT A

, RESPONSE TO NOTICE OF VIOLATION

NRC INSPECTION REPORT

373/374-98005

A detailed analysis in accordance with procedure LAP-400-11 " Fuse

Replacement Program" was subsequently performed for each Unit 1, Unit 2,

and Unit 0 safety-related fuse discrepancy in the first category. These

evaluations determined that no fuses required replacement prior to Unit 1

start up. A detailed analysis was also performed for 79 of the 83

non-safety-related fuse discrepancies in the first category for Units 1 and O. .

These evaluations determined that no fuses required replacement prior to

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Unit 1 start-up. The four remaining Unit 1 and Unit 0 discrepancies will be

completed prior to Unit 1 restart (NTS # 373-100-98-00512.02). The other

fuse discrepancies (i.e., the Unit 2 non-safety-related discrepancies in the

first category and the entire second category) are not required for Unit 1 '

start-up. However, they will be evaluated by August 31,1998

(NTS # 373-100-98-00512.01).

CORRECT 3VE STEPS TAKEN TO AVOID FURTHER VIOLATION:

LAP-400-11, " Fuse Replacement Program" was revised to include the

requirement to track all fuse discrepancies by initiating an Engineering

Request (ER) for each fuse discrepancy. This will ensure evaluation

because ERs are routinely reviewed and prioritized in accordance with

station procedures.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED- . i

Full compliance will be met for Unit 1 on July 28,1998, when the fuses

essential for Unit 1 start-up are evaluated. The remaining fuse

discrepancies, not required for Unit 1 start-up, will be evaluated by

August 31,1998.

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ATTACHMENT A

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RESPONSE TO NOTICE OF VIOLATION i

NRC INSPECTION REPORT I

373/374-98005

VIOLATION: 373/374-98005-15

10 CFR 50, Appendix B, Criterion XVI," Corrective Actions," requires that ,

measures shall be established to assure that conditions adverse to quality,

such as failures, malfunctions, deficiencies, and nonconformances are ]

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promptly identified and corrected. In the case of significant conditions

adverse to quality, the measures shall assure that the cause of the condition

is determined and corrective action taken.to preclude repetition.

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Contrary to the above, on March 27,1998, the NRC identified that an

important to safety designated Klockner-Moeller (K-M) relay located in Motor

Control Center 132Y-2, cubicle B1, had been identified by the licensee as

containing crystal deposits that met the K-M PM program relay replacement

criteria on August 23,1997, but had not been replaced as required.

REASON FOR VIOLATION:

Comed agrees that based upon the K-M Preventive Maintenance (PM)

program relay replacement criteria presented during the inspection the K-M

relay should have been replaced. The replacement criteria presented stated

that any safety-related (SR) or important to safety (ITS) relay found to exhibit

crystal growth was to be replaced, and the relay in question exhibited crystal

growth.

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However, subsequent to the inspection it was discovered that the l

acceptance criteria for the K-M relays stated that K-M relays used as 74

devices (alarm relays) in non-safety, ITS applications only required

replacement if the relays were found to be nonfunctional. This is true of ITS,

74, K-M relays even if crystal deposits are present on the relay. The relay

identified during the inspection (MCC 132Y-2 cubicle B1) is a spare

(contacts not used), non safety but ITS,74 relay that had been shown to be

functional using LaSalle Electrical Surveillance (LES) GM-109, " Inspection of

480V Klockner-Moeller Motor Control Center" and, as such, did not require

replacement.

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ATTACHMENT A i

RESPONSE TO NOTICE OF VIOLATION l

NRC INSPECTION REPORT

373/374-98005

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The confusion in the acceptance criteria presented to the inspectors was

created by the fact that there are four separate categories for classifying the l

K-M relays. Two categories are not part of the inspection project and two

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are part of the inspection project. The K-M relays that are not part of the

inspection project are the SR/EQ relays, which are being replaced this

outage regardless of condition. The normal replacement frequency for these

relays is included in the EQ Binders. The other is non-safety and not

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important to safety related, which are replaced when they become .

nonfunctional.

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The two categories of K-M relays that are par' of the inspection project i

are:

1) All SR relays and ITS non-74 relays. The acceptance criteria

for these relays is no crystallization, or no discoloration and

cracking, or failure of their surveillance test (LES-GM-109). If

any of these criteria are not met, then the relays are replaced.

2) ITS 74 relays, which have an acceptance criteria of

replacement if they become non-functional or failure of their

surveillance test (LES-GM-109).

The relay in question was an ITS 74 relay. As a result of a lack of attention

to detail by the cognizant engineer, this distinction was not recognized at the

time the information was provided.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

A review was performed of all relays being addressed by the K-M

replacement program, no other incidents of SR or ITS identified as having

crystals and .bsequently not replaced were identified.

The relay identified during the inspection has been replaced, even though it

was not required.

After it was recognized that incorrect acceptance criteria had been presented

during the inspection, NRC Region 111 personnel were informed of the correct

acceptance criteria.

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ATTACHMENT A

RESPONSE TO NOTICE OF VIOLATION

NRC INSPECTION REPORT

373/374-98005

CORRECTIVE STEPS TAKEN TO AVOlD FURTHER VIOLATION:

The individual involved in this incident has been counseled by his supervisor

regarding the I:nportance of providing complete and accurate information to

inspectors.

Additionally this incident was discussed in a departmental meeting in

, May 1998 to heighten the awareness of others to errors of this nature.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

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Full compliance has been maintained,

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ATTACHMENTS j

REGULATORY COMMITMENT (S) l

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The following identifies those actions committed to by Comed in this

document. Any other actions discussed in this submittal represent intended '

or planned actions by Comed. They are described to the NRC for the NRC's

information and are not regulatory commitments.

Regulatory Commitment (s) Tracking Number

The four remaining Unit 1 and NTS # 373-100-98-00512.02

Unit 0 discrepancies will be l

completed prior to Unit 1 restart.

The other fuse discrepancies (i.e., - - NTS # 373-100-98-00512.01 -

the Unit 2 non . safety-related i

discrepancies in the first category

and the entire second category) are

not required for Unit 1 start-up.

However, they will be evaluated by

August 31,1998.

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