ML19353A905
| ML19353A905 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/23/1989 |
| From: | Morgan W COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0340T, 340T, NUDOCS 8912080064 | |
| Download: ML19353A905 (5) | |
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i Nd Chicago, Ilknois 60690 0767 October 23, 1989 Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Units 1 and 2 Response to Inspection Report t
Nos. 50-373/89019 and 50-374/89019 NRC Docket Nos. 50-373 and 50-374 Reference (a):
W.D. Shafer letter to Cordell Reed dated September 21, 1989.
Dear Mr. Davis:
This letter is in response to the inspection conducted by Messrs. R.
Lanksbury, R. Kopriva, S. DuPont and D. Butler on July 25 through September 11 1989, of certain activities at LaSalle County Station.
Reference (a) indicated l
that certain activities appeared to be in noncompliance with NRC requirements, i
The Commonwealth Edison Company response to the one Level IV and one Level V Notice of Violation is provided in the Attachment.
If you have any further questions regarding this matter, please contact this office.
Very truly yours, P de Wayne E. Morgan Nuclear Licensing Administrator 1m Attachment cc:
NRC Resident Inspector - LSCS l
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Technical Specification 6.2.A requires that the detailed written procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be adhered to.
Appendix A of Regulatory Guide 1.33 includes
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administrative procedures.
LaSalle Administrativo Procedure LAP-240-6, Temporary System Changes, defines temporary system changes as temporary connections such as hoses, tubing or piping that join two systems together, thus altering the system design or configuration.
LaSalle Administrative Procedure LAP-240-6, Steps F.2 and F.3 provide instructions for initiating a Temporary System Change, and steps F.4 and F.5 pertain to onsite review and approval, and Shift Engineers review of the Temporary System Change authorintion.
LaSalle Administrative Procedure LAP-100-4, Control of Non-Station Personnel, which includes sub-station construction, step F.8 requires that all non-station Commonwealth Edison supervisors, who perform or control work, be familiar with the work control process with particular attention to a certain group of procedures which includes LAP-240-6.
Contrary to the above, on August 28, 1989, sub-station construction, while attempting to clean the cooling fans on the 2 East and 2 West main transformers, cross connected the station air system and the clean condensate water system together without using a temporary system change. Sub-station construction did not adhere to procedure LAP-240-6, Temporary System Change, and the licensee did not adhere to procedure LAP-100-4, Control of Non-Station Personnel.
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COBBECIIVE_ ACTION TAKEN AND RESULTS ACHIEVEQ i
The hose connection that cross-connected the Service Air (SA) system with the Clean Condensate (MC) system was immediately uncoupled and secured.
The air purge of the Unit 2 Main Generator was secured and the Turbine Lube 011 (TO) system was shutdown to prevent further water intrusion into the system.
System air hose connection tap points in the area were drained and the Turbine Lube 011 has been checked for water.
Representative samples of system air hose connection tap points were blown down to determine the extent of water intrusion into the SA system.
All water was blown out of the system.
Dew point measurements, taken at the system air hose connections where water was observed, have confirmed moisture removal.
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n CORRECTIVE ACTION TAKEN TOE 0ID FUR 1HER VIOLATJDN l
This event has been reviewed with all personnel involved, emphasizing the concern with cross-connection of systems.
Station generated General Information Notice 89-067 was issued on August 30, 1989 to review this event with all on-site personnel.
A Sub-Station Construction representative now attends the daily morning plant status meeting, which includes representatives from all station work groups, to discuss their planned work activities for the day.
Sub-Station Construction will use a Station Hork Permit to obtain authorization from'the Operating Department for work involving use of station systems such as Service Air, Clean Condensate, etc.
A letter was issued to all site personnel prohibiting the cross connection of plant systems, such as air and water, unless specifically
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authorized by Station Operating Department Supervision.
This letter was
' issued from D. Galle (VP BNR Operations) and T. J. Malman (VP PHR Operations).
A corporate task force has been initiated to review this event and its potential for impact on the other Commonwealth Edison nuclear stations and to determine any addittorial recommendations and corrective actions.
DATE OF FULL COMPLIANCE Full compliance was achieved on August ;'8,1989 following the removal of the hose which cross-connected Service Air and Clean Condensate systems and the counseling of the personnel involved.
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IR 374/89019-03 10 CFR 50, Appendix B, Criterton V, requires that activities affecting quality be prescribed by procedures of a type appropriate to the circumstances and be accomplished in accordance with those procedures.
LOP-HR-02, Startup and Operation of the Reactor Building Closed Cooling Hater System, provides instructions for aligning the common Reactor Building Closed Cooling Hater (RBCCH) heat exchanger in a Unit 2 lineup but did not provide instructions for swapping it from a Unit 2 lineup to a thilt I lineup.
LAP-820-2, Station Procedure Preparation and Revisions, provides the steps by which station procedures are to be revised.
LAP-820-1, Station Procedures, provides guidelines for the limited circumstances in which procedural deviations are permissible such_as when an obvious typographical error can be corrected by the use of an Addendum Deficiency Sheet (ADS).
It also requires the ADS to be completed and signed by the supervisor of the individual making the change, and to be forwarded to the Procedure Manager, prior to continuing performance of the procedure.
Contrary to the above, on August 13, 1989, the licensee attempted to lineup the common RBCCH heat exchanger from a Unit 2 lineup to a Unit I lineup without having an approved procedure.
The procedure that was used was recog-nized to not have the necessary instructions to perform the evolution and it was not revised in accordance with LAP-820-2.
The individuals involved did intend to use the guidelines of LAP-820-1 to allow the evolution to proceed, however, this was contrary to the written intent of that procedure and the l
Individuals also failed to document the changes being made on an ADS signed by l
their supervisor and forwarded to the Procedure Manager prior to the continuance of the work as required by LAP-820-1.
CORBECI1YE_ACI1ON TAKEN AND RESULTS ACRLEVEQ L
The event was reviewed with the Operating Department personnel l
involved emphasizing adhercnce to procedures including LAP-820-1 and LAP-820-2.
b CORBECIIVE ACTION TAKEN TO AVOID FURTHER V1QLalLQN LOP-WR-02 has been revised and now provides adequate guidance for i
swapping RBCCW pumps and heat exchangers for all configurations.
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Strict procedural compliance is required per LAP-1600-2, except s.s
.provided by LAP-820-1.
The Assistant Superintendent of Operations is in the process of reviewing the station philosophy and policy concerning procedural compliance with all Operating Department personnel.
These meetings are held in small groups and include-emphasis.on the requirements' of LAP-820-1 and LAP-820-2. Attendance will be documented on training completion forms.
This event has been included in Licensed Operator and Non-Licensed Operator required reading packages and in requal training modules, i
DAILDE FULL COMPLIANCE Full compliance has been achieved.
The Assistant Superintendent of.
Operations completed his review with Operating personnel on October 20, 1989.
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