ML20006E742
| ML20006E742 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/09/1990 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9002260303 | |
| Download: ML20006E742 (10) | |
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1 February 9, 1990
-.pg Mr; A. Bert Davis
' Regional' Administrator, U.S. Nuclear Regulatory Conunission p
Region.III
-799 Roosevelt Road-h' Glen Ellyn, IL: 60137
Subject:
. LaSalle. County Station Units 1 and 2 Response to Inspection Report Nos.
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i-50-373/89023 and 50-374/89022 Routine. Safety Inspection
'NRC Docket Nos. 50-373'and 50-374 o
Reference:
(a) E.G. Greenman letter to C. Reed
- dated January 10, 1990.
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Dear Mr. Davis:
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lThis letter'is in response to.the routine safety inspection-conducted.
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by R Lanksbury and R.1Kopriva of your staff on October.24.through December 7, 1989. Reference (a) indicated that certain' activities appeared to be in noncompliance with the NRC. requirements.
j The Commonwealth Edison (CECO) response to the Level IV Notice of Violation is'provided in the attachment. CECO's response as requested, f
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addresses the individual' concerns as well'as the programmatic corrective'
-i actionalin' response to the violation concerning<Procadural Adherence.
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~ If there are any questions or consnents-regarding this matter, please
- contact-this office.
Very truly yours, 9
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' ova ch -
Nuclear Licensing Manager Attachment a
cc: Senior Resident Inspector - LSCS
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ATTACIBtENT C0ffl0NWEALTH EDISON RESPONSE TO NOTICE OF VIDIATION 50-373/89023-l 30-374/89022 i
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As a-result of the inspection conducted from October 24 through December 7, 1989, and in accordance with 10 CFR Part 2, Appendix C - General Statement of : Policy and Procedure' for NRC Enforcement Actions (1989), the following-violation was identified:
Technical Specification 6.2.A states, in part:
Detailed written procedures including applicable checkoff' lists covering items listed below shall be prepared, approved and adhered to:
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The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February.1978 which includes j
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- administrative, surveillance and operational procedures.
Preventative and corrective maintenance operations.
a.
Contrary to the above, on October 20, 1989 - while. searching for a-
' ground in the 125V DC System on Unit 1, the Shif t Engineer f ailed -
0 to follow procedure LOP-DC-05 which caused a primary containment C
isolation system isolation and standby gas treatment automatic start (No. 373/89023-01a; No. 374/89022-01a).
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b.
Contrary to the above, on November 7, 1989, while preparing to
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perform the local leak rate-test on valve 1G33-F004, the Unit 1 l
operator opened _ valve 1G33-F001 prior to valve 1G33-F103 being.
L closed. This is a violation of procedure LTS-100-19, step F.2.b (No. 373/89023-01b).
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c.
Contrary-to the above, during the inspection period, several l
scaffolds in the control room and the drywell (in the vicinity of E
safety-related equipment) were noted as not containing adequate toeboards, not having plumb vertical support members, lack of l
crossbracing, and not adequately braced / tied off.
This is a violation of Administrative Procedure LAP-900-28, (No.
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373/89023-01c; No. 374/89022-Olb).
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Contrary to the above, on July 18, 1989, the surveillance coordinator had failed to verify that all of the data that had been entered was correct and an incorrect code resulted in a i
This is in violation of Administrative 1
l Procedure LAP-100-11, step F.1.e (No. 373/89023-01d; No.
374/89022-01c).
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Notice of. Violation-,
. Contrary.to the above, on December'4, 1989, while performing the-Is...
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high-reactor pressure' isolation' calibration for shutdown cooling j
F-the Unit:1' operator through poor communications with the instrument mechanic, energized-the breaker controlling 1E12-F008-instead of deenergizing it.
This is a violation of Surveillance Procedure LIS-NB-111, step F.3.A (No. 373/89023-01e).
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Contrary.to the above, on November 2, 1989, after removing a safety relief valve on Unit 1 the maintenance mechanics failed to insta11'the correct number of bolts on a blind flange cover for an opening in'the main steam line, resulting in a significant primary water.~1eak-in the drywell when the reactor water level was flooded-c
-up to the steam lines. This is a violation of Maintenance Procedure INP-MS-06, step F.2.13.1 (Np. ' 373/89023-01f).
Together these examples of failure to adhere to procedures are considered a Severity' Level IV violation-.
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- GENERAL DISCUSSION OF PROCEDURAL ADRERENCE Corporate and Station Policy requires strict adherence to procedures and E
this policy has been stressed.. The root cause of the failure to adhere to procedures, however, is often varied.
LaSalle County Station, therefore,.
evaluates each event and strives to implement appropriate corrective actions based on investigation results. The' corrective. actions include the actions
. focusing on the individual, based on consideration for past performance, as well as removing human factor barriers which may discourage the strict adherence'to j
procedures._ When appropriate, the nature of the error and relevant casual
.j factors are further disseminated. This process also looks at previov similar 4
events where appropriate to determine additional corrective actions wnich may be
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necessary. Root cause techniques are used. The goal of Commonwealth Edison and l
LaSalle Station is to eliminate such events and continue to strive for
. performance excellence.
EROGRAMMATIC CORRECTIVE ACTIONS TO PREVENT FURTHER NONCOMPLIANCE LaSalle Station will continue to investigate events in which procedures were not followed and implement appropriate corrective actions based on the investigation results.
LaSalle Station does recognize that the administration
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of policy on procedure compliance can be further emphasized at the Station.
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A letter f rom the Station Manager to all Department Heads was ' sued on i
December 18, 1989. The subject of this letter was Personnel Performance Issues. All departments have discussed the issues of this letter within their j
departments. One of the issues discussed was failure to follow procedures.
Five of the events discussed in the Notice of Violction were specifically summarized in this letter. Currently, the Commonwealth Edison policy on I
procedure adherence is communicated through company policy N0D-0A.1, Nuclear l
' Operations Policy of Directives, Controlled Memoranda and Procedure. This policy is reflected in Station procedures.
LaSalle Station has developed an Action Plan to further enhance the expectations of all Station personnel with respect to procedural adherence. The Action Plan contains elements such as the establishment of a communications task force and the conducting of half day departmental meetings.
These departmental meetings will include topics on-procedural adherence and communications, and are expected to be coinpleted by.
April 1, 1990.
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Yl01AIID]ii IR 373/89023-01A
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IR 374/89022-01A 4
Technical Specification 6.2.A' states, in part:
' Detailed written procedures including applicable. checkoff lists covering items listed below shall be prepared, approved and adhered to:
The applicable procedures recommended in Appendix A'of Regulatory Guide 4
1.33, Revision 2,' February 1978 which includes administrative, 1
surveillance and operational procedures.
Preventive and corrective maintenance operations.
a.
Operating Procedure LOP-DC-05,125V DC System, Division 2 Ground Location and Isolation, provides for a specific sequence to be followed when attempting to locate a ground.
Contrary to the above, on October 20, 1989, while searching.for a ground in the 125V DC System on Unit 1, the Shift Engineer. failed to follow-1 procedure LOP-DC-05 which caused a primary containment isolation system isolation and standby gas treatment automatic start.(No. 373/89023-01a; j
No. 374/89022-01a).
.i CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED i
Unit 1 Division 2.125 Volt DC Bus Circuit Breakers 8 and 20 were reclosed.
4 The PCIS isolation logic was reset. The AC Distribution Bus 142Y was re-energized causing the negative 125 volt DC ground to clear.
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.CDRRECIIVEJiCIION TAKEN TO AVOID _IURIHER VIOLATION The individuals involved in the event were counseled on the importance of.
adhering'to procedures. A General Information Notification (GIN) was issued to the appropriate operating department personnel to tailgate the event.
LOP-DC-05 was revised to incorporate guidance for ground isolation when crosstied between units.
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- DAIE_0F FULL COMPLIAliCE i
The station is presently in full compliance.
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VIOLATION:
IR 373/89023-01B:
- b.. Procedure LTS-100-19, Reactor Water Clean Up Suction Local Leak Rate Test-
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1(2)G33-F001 and 1(2)G33-F004, step F.2.b requires that valve 1G33-F103, RWCU Suction-from Reactor Vessel Bottom Bypass Stop, be closed. Step F.4
' directs the opening of'1G33-F001.
Contrary to the above, on November 7,1989, while preparing to perform the local leak rate test on valve 1G33-F004, the Unit 1 operator opened valve 1G33-F001 prior to valve 1G33-F103 being closed. This is a violation of~
procedure LTS-100-19, step F.2.b (No. 373/89023-Olb).
. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED L
'The Reactor Water Cleanup Suction Valves IG33-F001 and 1G33-F004 were immediately closed when leakage was reported.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION The individuals involved in this event were counseled on the importance of adhering to procedures.
DATE OF FULL COMPLIANCE
-The. station is presently in full compliance.
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~ VIOLkT10Hi,IR 373/89023-010 IR 374/89023-01B
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Administrative. Procedure LAP-900-28, Erection Inspection and Use of Scaf folding and Ladders provides numerous requirements for the erection of scaffolding.,
~ Contrary to the above, during the inspection period, several scaffolds in
~the control room and the drywell (in the vicinity of safety-related.
equipn.ent) were noted as not containing adequate toeboards, not having plumb vertical support members, lack of crossbracing, and not adequately braced / tied off. This is a violation of Administrative Procedure LAP-900-28, (No. 373/89023-01c; No. 374/89022-Olb).
QQRRECTIVE ACTIONS TAKEN AND RESULTS ACllIEVED On November 9, 1989.all plant scaffolding was inspected for compliance to R
LAP-900-28, Revision 5.
During the period of time from November.9, 1989, through November 15, 1989, all plant scaffolding was either removed if it could not meet the procedure or upgraded to fully meet the procedure.
Scaffolds that did not have adequate toeboards, were not plumb, did not have 4!
locked crossbracing or were not adequately braced or tied off were corrected
.during.this inspection.
Mechancial Maintenance Department (MMD) on November 9,1989, revised procedure LAP-900-28, Revision 5 to provide clarification of issues addressed during the
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inspection.
LAP-900-28, Revision 6 was approved by November 15, 1989.
I-All of the Maintenance / Modification contractor staff and craft personnel E
involved with scaffold eraction were trained to the requirements of c
LAP-900-28, Revision 6 by November 26, 1989.
QQRRECTIVE ACTION TAKEN TO PREVENT FURTHER VIOLATION Contractor personnel who are currently onsite involved with scaffold erection r
have been trained to the latest revision of LAP-900-28 and new contractor personnel involved with scaffold erection arriving onsite will be trained
.during inprocessing training.
The Contractor Safety Coordinator will perform random scaffolding inspections during periods when scaffolding is being used.
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Mechanical Maintenance has tailgated on this issue in November 1989.
4 Electrical, Mechanical and Instrument Maintenance and Substation Construction will' train personnel by March 15, 1990.
DATE OF FULL COMPLIANCE The Station is presently in full compliance. Mechanical, Electrical, and Instrument Maintenance Departments will be trained by March 15, 1990.
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. VIOLATION :
=IR 373/89023-01D-IR 374/89023-010 d.
Administrative. Procedure LAP-100-11, LaSalle County Station General Surveillance Program, step F.1.e requires that the surveillance coordinator verify thatLthe data has been entered correctly.
Contrary to'the above, on July 18, 1989, the surveillance coordinator had failed to verify'that-all of the data that had been entered was correct and an incorrect code resulted in a missed surveillance. This is in
-violation of Administrative Procedure LAP-100-11, step F.1.e (No.
1 373/89023-01d; No.'374/89022-01c).-
r CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The subject surveillance was immediately performed and evaluated as satisfactory. The surveillance databank (GSRV) was searched for additional incorrect codes in the'" Increased Frequency" field. One error was found in the _ corresponding Unit 1 surveillance record..Since Unit I was defueled, the surveillance was not required and the only corrective action required was to delete the zero (0).
.The Scope Operators'end surveillance coordinator-were counseled on the need for accuracy. The GSRV Coordinator routinely checks the data bank following.
all' data-entry and verifies the accuracy of all data fields in any record altered, as' identified in the resultant Transaction Report, and makes all needed corrections.
- CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATION The Management'Information Systems (MIS) Depattment will revise the GSRV Users I
Manual to address the use and effect of zero (0) in the " Increased Frequency" field.
I The " Overdue Surveillance" lists have been revised to be user friendly.
The administrative procedure for GSRV (LAP-100-11) will be revised to. provide more guidance for reviews by departmental survelliance schedulers and to
. caution against-the use of a zero (0) in-the " Increased Frequency" field.
DATE OF' FULL COMPLIANCE The Station is presently in full compliance.
LAP-100-11 will be revised by April 30, 1990.
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VIOLATION '
-IR: 373/89023-01E-e.
Instrument' surveillance procedure LIS-NB-111, Unit 1 Reactor High Pressure Shutdown Cooling Isolation Calibration, step F.3.A requires that if the shutdown cooling mode is required to be in operation the operator is required to de-energize the breakers for the RHR Shutdown Cooling Outboard Suction' Isolation Valve 1E12-F008.
-Contrary to the above, on December 4, 1989, while performing the high reactor pressure isolation calibration for shutdown cooling, the Unit'l I
operator-through poor communications with ~ the instrument mechanic, energized the breaker controlling 1E12-F008_instead of deenergizing it.
j This is_a violation of Surveillance Procedure LIS-NB-111, step F.3.A (No.
373/89023-01e).
5 CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED Following the closure of-1E12-F008, " Residual Heat Removal Shutdown Cooling-suction header outboard isolation valve," it was determined that the valve should remain closed and the surveillance test completed.
Once LIS-NB-111 was completed, the-PCIS group 6 isolation (135 psig reactor high pressure) logic was reset and the 1E12-F008 valve was reopened. This was completed within 1
' hour of the event.
CORRECTIVE _ ACTION TAKEN TO AVOID FURTHER VIOLATION A' communication task force was developed to review the current station communication practices and develop recommendations to improve communication practices. -Recommendations have been developed and are currently being reviewed by~theitask force members prior to presenting them to upper station management for approval.
Tne Instrument Maintenance (IM) department is reviewing LIS-NB-111 and similar procedures to determine the need for requiring a signoff when log entries are required or components such as breakers or valves are manipulated.
The Instrument Maintenance department is developing a work practice to notify the NSO prior to any 1/2 scram or 1/2 isolation signal by issuing a new maintenance memo.
By providing the NSO with the warning that a trip signal will be generated, the NSO may be abic to better evaluate the consequences of receiving a trip signal knowing the status'of the' plant and provide another mechanism for preventing an error.
DAIE OF FULL COMPLIMCE Full compliance has been achieved.
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.IR 373/89023-01F
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=f.[MaintenanceprocedureLMP-MS-06, Installation /RemovalofMainSteamSafety Valves, step F.2.13.1,. requires that four bolts and nuts be installed and -
evenly tightened at 90 degree intervals around a blind flange that is-installed when an SRV is removed.
Contrary to the above, on November 2, 1989,'after removing a~ safety relief valve on Unit 1 the maintenance mechanics failed to install the correct J
. number of bolts' en a blind' flange cover for an opening in the main steam line,.resulting in a significant primary water leak in the drywell when R
the reactor water level was_ flooded up to the steam lines. This is a violation of Maintenance Procedure LMP-MS-06, step F.2.13.1 (No.
373/89023-01f).
CDERECTIVE ACTIONS TAKEN AND RESULTS A0llIEVED-
'Immediately after the leaking blind flange was identified a Mechanical Maintenance Department (MMD) crew was sent in the drywell to install all twelve of the flange cover bolts. Within forty-five minutes from the notification of the leak, the leak was stopped.
Strong backs were installed on all the flanges and all the' flange bolts were installed.
The flanges were l
, inspected and' determined to be leak tight.
CORRECTIVE ACTION TAKEN TO AVOID FURTILER VIO14Il0N
- 1. - LOP-FC-17, Filling the Reactor Well and Dryer / Separator Pit from the Suppression Pool through the RHR or LPCS System, is being revised to require verifying the main steam line integrity prior to raising reactor level above the steam lines.- This is a verification by Operating and Mechanical Maintenance Departments.
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UMP-MS-06, is being revised to include additional details as to the-purpose of the flange covers as well as how the covers are to be secured.
The procedure requires MMD Management-to verify that this action is L
_ completed.
LMP-MS-06 will also require MMD Management to verify no/ minimal water leakage through the steam line drains to ensure the main steam line is drained prior to removing a valve or flange cover.
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The entire Mechanical Maintenance Department has been tailgated on this l
event and its significance, with emphasis on procedure adherence. Also pointed out were acceptable means on how to make procedure changes when y
problems arise.
DAIE OF FULL COMPLIANCE L
I The Station is presently in full compliance. The procedure revisions will be completed by March 15, 1990, prior to the start of Unit 2 third refuel.
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