ML20024H773
| ML20024H773 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/07/1991 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9106100458 | |
| Download: ML20024H773 (9) | |
Text
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1400 Opus Place Downm Grove, minois costs June 7,1991 U.S. Nuclear Regulatory Commission ATTN: NRR Document Control Desk Washington, DC 20555
Subject:
LaSalle County Station Units 1 and 2 Response to Notice of Violation Inspection 50 373/91005; 50 374/91004 NBC_DockeLNosc50:3Z3_and_50 374_
Reference:
W.D. Shafer letter to Cordell Reed dated May 8,1991 transmitting NRC Inspection Report 50 373/91005; 50 374/91004 Enclosed is Commonwealth Edison Company's (CECO) response to the subject Notice of Violation (NOV) which was transmitted with the referenced letter and Inspection Report The NOV cited two Severity LevelIV violations. The first violation was the result of an excessive delay in correcting a fire protection issue. The second violation cited six (6) examples of proceduralInad6quacies or lack of adherence to procedures.
CECO understands the significance of these events as well as the need for effective corrective actions to prevent recurrence. These have been considered in developing actions in response to the cited violations. LaSalle Station has performed a review of all Deviation Reports and Licensee Event Reports since 1990 which were procedure related events. This review was conducted to determine the collective root cause of events such as those identified in this NOV and also in previous inspection reports. The results of this review are being evaluated to determine the appropr! ate form of corrective action. CECO's response to the cited violations is provided in the following attachment.
i If your staff has any questions or comments concerning this letter, please refer them to Annette Denenberg, Compliance Engineer at (708) 515 7352.
Very truly yours, 1
d
? T.J. Kovach N clear Licensing Manager GAD /TJK/CAH Enclosure cc:
A.B. Davis, Regional Administrator Rlli B. Siegel, Project Manager NRR T. Tongue, Senior Resident inspector ZNLD989/1
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f VIOLATION: IR 374/91004 01 10 CFR 50, Appendix B, Criterion XVI, states, in part, measures shall be established to ensure that conditions adverse to quality, such as f ailures, malf unctions, deficiencies, deviations, defective material and equipment and nonconformances are promptly identified and corrected.
Contrary to the above, from 1987 to April 16,1991, a condition adverse to quality, a fire hazard, was not promptly corrected. A work request dated in 1987 Identified oil leakage from the 2A Turbine Driven Reactor Feed Pump (TDRFP) which had saturated fire retardant materials in the Unit 2 Auxiliary Building. This condition and a similar condition of unknown duration regarding the 1 A TDRFP identified by the NRC had not been corrected as of April 16,1991. (374/91004 01)
RESPONSE
Commonwealth Edisor, acknowledges the violation. The violation involved CECO's f ailure to replace oil saturaled fire retardant insulation in a timely manner.
Commonwealth Erlison reviewed the condition when it was found in 1987. At that time, the Stativ Fire Marshall and the insulation vendor determined that the oil soaked insulation was an acceptable fire retardant because it was not wet. The replacement of the insulation was therefore deferred until the feedpump oil leaks could be adequately repcited to prevent recurrence of oilleaking onto the insulation. However, after the olileaks were repaired, there was no feedback to initiate the work request 'o have the insulation replaced.
The Station considers the length of time that the identitled condition existed to be unacceptable. The oli soaked insulation should have been replaced following the repairs for the oil looks since a unit outage was not required to perform the insulation work.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
The oilleaks were repaired and the insulation was replaced for the identified TDRFPs Additionally, the remaining TDRFPs were examined to ensure that similar conditions did not exist.
CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOlD FURTHER VIOLATIONS:
Drainage trc ys were installed on the 1 A and 2A TDRFPs to help catch oil and channelit away from areas where it could drip on insulation and other components.
Additionally, closer attention will be given to completion of work requests dealing with fire protection issues. The Station Fire Marshall or Assistant will review fire protection designated Work Requests for urgency and scheduling input.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The corrective actions in response to the violation have been completed for both units. Full compliance has been achicved.
ZNLD989/2
VJOLATION: IR 373/91005 01a to 373/91005 01f 10 CFR 50, Appendix D, Oritoria V, statos, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a typo appropriate to the circumstances, and shall be accomplished in accordance with those instructions, procedures or drawings.
Contrary to the above, the following are examples of improper procedure adequacy and adhorenco:
EXAMPLE A:
On March 21,1991, Work Rec uest L99799 was inadequate for proventivo maintenance on the Unit i hyc rogen r9 combiner when it failed to requiro replacement of the blower cover which resulted in a loss of Unit 2 primary containment to the secondary containment. The work procedure allowed the hydrogen recombiner to be lined up to the drywell of the operating unit with the blower cover removed. The blower cover is an integral part of the primary containment. Th9 nood to have the blower cover installed had boon previously identiflod during the last performance of this preventative maintenance on Unit 2 in 1988 Work Request L75487. (373/91005 01a)
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The blower was staried at 11:10 on March 21,1991 and remained running for ten minutes. Operations discovered the breach of Unit 2 primary containment at 11:50, with subsequent corrective actions as follows:
Immediately entered a one hour time clock pursuant to Technical Specification 3.6.1.1.
Immediately closed the Unit 2 hydrogen recombiner (HG) primary containment isolation valves.
At 13:45, started post LOCA sampling equipment to analyze Unit 2 suppression chamber oxygen content which was found to be greater than 4%
At 14:05, entered twenty four hour timoclock pursuant to Technical Specification 3.6.6.2.
At 14:20, secured post LOCA sampling equipment with suppression chamber oxygen content at 4.8%
At 19:15, started inerting Unit 2 suppression chamber.
At 20:40, secured inerting with suppression chamber oxygen content within acceptable limits at 2.6%
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CORRECTIVE ACTIONS THAT WILL DE TAKEN TO AVOID FURTHER VIOLATIONS:
The LaSailo Station Technical Staff has determined that the work proceduto should only be podormed while the unit is In condition 4 or 5, and that the HG out of y containment valvos on the opposito unit should be takon administratively primar service. When the system is in this configuration, the blower can run with the cover removod.
A revision to LES.HG 103 (Rev.1, entitled " Hydrogen Recombinor Olower Motor Lubrication *) has boon submittod as recommended by the cognizant Technical Staff system enginoor. The following changos and additions to LES HG 103 will bo incorporated:
A prerequisite will be added to take the affected HG primary (containment 1.
j lsolation valves for both units administratively out of sorvice closed) during maintenanco noting that the Out of Service for the SA and GA valvos of the outago unit will nood to be temporarily littod for the ton minuto run.
t 2.
A precaution will be added to specify that the blower will be operated with its cover removed, and that this arrangement will cause the blower to tako suction from the reactor building atmosphere and thus shall not be allowed to dischargo to primary containment in reactor conditions 1,2, or 3.
3.
A limitation statement will be added noting that the primary containment as defined by the existing hydrogon recombinor loop will be broachod with the removal of the blower cover.
4.
A limitation statement will be added noting that the hydrogen recombiner will be considered inoperable and remain isolaled from requirod Primary Containment until a successful local leak rate test (LLRT) is completod.
5.
A proceduto step will be added after the section for the ten minuto run to notify the Technical Staff to perform a local leak rate test following completion of all work. Additionally, it will be noted that an integrated loak rato test (ILRT) is not an acceptable substituto for an LLRT.
DATE WHEN FULL COMPLIANCE WILL DE ACHIEVED:
Compilance via the immediato corrective action was achloved by 20:40 on March 21,1991. At that time, the Unit 2 3rimary containment was secured with suppression chamber oxygen conuent within acceptable limits.
Revision 1 of LES HG 103 is scheduled for completion by December 1,1991.
ZNLD989/4
EXAMPLEB:
On January 2,1991, work performed was not in accordance with procedure LEP EO 1; 5,"Klocknor Mooller Circuit Breakers and Related MCC Equipment,"
which requires that a functional test of the overload bypass circuitry be performed after maintenance in order to moet Technical Specification 4.8.3.3.1.b. This resulted in an inadequate work request which allowed the Unit 1 drywell nitro 0en mako up valvo 1VOO47 to be placed back in service without a lost of the overload bypass circuitry)after replacing the forward / reversing motor starter contacto (373/91005 01 a CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The IVOO47 valve was immediately closed and declared Inoperable. The applicable action required by Technical Specification 3.6.3. was taken to close and deactivate valve 1VOO47 within the required four hours. An Out Of Servico 4
on the valve was logged as completed at 08:40 on January 3,1991. The 1VOO47 l
valve was tested for overload bypass and performed satisfactorily per procedure i
LST 91002. This test occurred durin0 the afternoon shift on January 3,1991 4
l under the applicable timeclocks of Technical Specifications 3.6.3. and 3.8.3.3.
The IVOO47 valve was then returned to operable status.
The Electrical Maintenance personnelinvolved with this event have been counseled, emphasizing strict adherence to procedures.
This event was revlewed with all Electrical Maintenance Departmont personnel to clarify the Technical Specification requirements of procedure LEP EO 115.
CORRECTIVE ACTIONS THA1 WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Froceduro enhancements are being made to clarify the Technical Specification reaulrements of procedure LEP EO 115 steps E.3 through E.5.
DATE WHEN FULL COMPLlANCE WILL BE ACHIEVED:
Full compliance was achieved with the return of the 1VOO47 valve to an operable status.
The revision to LEP EO 115 is scheduled for completion by November 1,1991.
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J EXAMPLEC On ikech 16,1991, a proceduto was not appropriate such that instrument surveillance LIS NR 103BA,
- Unit 1 Averago Power Ran00 Monitor (APRM)
Channels B, D, F Rod Block and Scram Semi Annual C1libration for Normal Conditions," failed to provide a step to reposition a metut scale switch which was necessary to proceed. The surveillance was completed under verbal authorization from the Instrument Maintenance Supervisor. (373/91005 01c)
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
A brocedure steflS NR 103BA and Lkhopriate sections of LIS NR 103AA, was inseriod in the Li NR 103AB, R 103BB. This additional procedure sie 3 addressos the APRM's panel meter scale switch position which the tecinician must use in order to perform the calibration. Prior to this change, this switch oosition was indeterminato. Additional clarifications and typographical correct ons were made based upon feedback from workers and supervisors. With the addition of the sie a and other minor corrections, the procedures used to perform the APRM ca lbrations are now effective and consistent.
CORRECTIVE ACTIONS THAT WILL BE LKEN TO AVOID FURTHER VIOLATIONS:
LaSalle Station cautiously approached revising the procedures for the APRM calibrations and functional tests. A temporary procedure was written for functional testing in order to preclude any serious problems, prior to the permanent procedure being approved. This type of action is used when deemed appropriate by the Station based upon the extent of change to a procedure.
Once the permanent proceduros are approved, feedback from the field, via addendum deficiency sheets, :>rovido the Input needed to make the Instrument Maintenance procedures as e'fective as possible.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved upon addin0 the procedure step which addresses meter scalo switch positioning. Proceduto enhancements resulting from field input are a continuing process, i
l ZNLD989/6 l
.. EXAMPLE D:
On March 19,1991, a procedure was not appropriate when an inadvertent engineered safety feature (ESF) actuation occurred. While performing diesel generator protective relay calibrations in accordance with procedure ES GM 129," Unit 1 Southern Division OAD Periodic Protective Relay Calibration Procedure at LaSalle County Station for Relays Not Mentioned in Technical Specifications" the auto start signal to diesel generator 1B occurred when the feeder breaker to bus 143 opened. Although LES GM 129 provides for disabling trips that could occur during testing, the procedure did not g ve specific direction as to what items were required to be disabled. The o aening of the feeder breaker was a direct result of not disabilng the proper tr ps during the performance of LES GM-129. The diesel generator did not auto start because it was inoperable due to preventive maintenance. (373/91005 01d)
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Once the cause of the feed breaker trip was determined, ESF bus 143 was reenergized.
Onsite OAD personnel were tailgated on this event, emphasizing that care must be taken when using general procedures to ensure all isolation points are identified prior to performing required actions.
CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
LES-GM 129 and LES GM 229 are being replaced with per system / equipment basis (LES GM 300/400 series). procedures written These new arocedures will specify equipment isolation points required to perform the survelilance, and will no longer rely solely on test personnel review. The procedure writing and submittal for the LES GM 300/400 series was begun in early 1990 as part of a response to concerns identified in an evaluation of 4 kV preventive maintenance.
Additional revisions of the new procedure LES GM 309 (" Unit 1 Southern Division OAD inspections and Calibrations for the DG 1B System") which relate specificially to this event have been written and submitted for approval.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved upon reenergizing ESF bus 143. The revision to LES GM 309 is scheduled for completion by July 31,1991. Completion of the remaining LES GM-300/400 series of procedures for other systems and equipment is expected by Fall 1991.
ZNLD989/7 i
EXAMPLE E:
On March 28,1991, activities affecting quality were not accomplished in accordance with documented procedures when failure to follow LOP-RP 03, "RPS Bus A Transfer," resulted in a Group IV Primary Containment Isolation.
The Nuclear Station Operator responsible for the evolution made an error while copying instructions from the procedures which were given to equipment
- operators. Use of the incorrect instructions caused the Group IV isolation.
(373/91005 01e)
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Unit recovery from the isolation was performed in accordance with LOA VR 01,
" Recovery from a Group IV lsolation or Spurious Trip of Reactor Building Vent."
The individuals involved In the event were counselled and reprimanded for falling i
to adhere to procedures. The counselling reiterated procedural adherence -
requirements and the need to employ correct and approved documents in performing evolutions.
CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
The operators involved in this event have tallgated the Op9 rating crews on the importance of procedural adherence This review stressed the significant consequences involved with transpctng information from procedures onto note paper.
DATE WHEN FULL COMPLlANCE WILL BE ACHIEVED:
Full compliance has been achieved.
r ZNLD989/8 6
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.. EKAMPLE F:
On April 5,1991, activity affecting quality was not prescribed by procedure when Residual Heat Removal (RHR) vents were apparently opened by an unauthorized individual (s). While returning the B RHR loop to service, approximately 100 gallons of water from the suppression pool was spilled onto the floor from the suction line vents. (373/91005 01f)
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Upon noticing water coming from the high point vont valves, the equipment attendant present at the pump, closed the vent valves and installed the pipe cap.
This action stopped the flow of water. The area where the water spilled was cleaned up.
A HPES investigation was performed to determine why the vent valves were open. The investigation was unable to determine how the valves came to be opened. Intentional mispositioning of the valves was considered and determined during the investigation not to be the cause of the event.
CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
The following corrective actions were initiated as a result of the HPES investigation:
LOP RH 03," Draining the Residual Heat Removal System," will be revised to properly identify the valves that should be closed by Step F.6.h.2.
An evaluation is being performed to determine whether or not the high point vent valves should be locked valves.
To eliminate filling a system that has vent or drain valves mispositioned when returning the system to service, a mechanical checklist lineup of vents and drains will be employed prior to clearing outages that admit a liquid back into the system. This requirernent is being added to LAP 900 4, Equipment Out-Of-Service Procedute.*
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved with the closure of the vent valves. The revision to LAP-900 4 is scheduled for completion by June 23,1991. The evaluation of locking the high point vent or drain valves is scheduled for com 31stion by July 2, 1991. The revis on to LOP RH-03 is scheduled for completion ay September 2, 1991.
ZNLD989/9
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