ML20029B262

Responds to NRC 910124 Ltr Re Violations Noted in Insp Repts 50-373/90-26 & 50-374/90-27.Corrective Actions:Instrument Maint Procedures Reformated to Incorporate Signoff & Isolation Signal Reset

ML20029B262
Person / Time
Site:	LaSalle
Issue date:	02/25/1991
From:	Kovach T COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9103060327
Download: ML20029B262 (4)

Text

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., [ [ ccmmenwealth Edison

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7 February 25,1991 Mr; A. Bert Davis i 1

Regional Administrator. .

U.S. Nuclear Regulatory Commission 1 Region Ill' 799 Roosevelt Road Glen Ellyn,IL 60137

Subject:

LaSalle County Station Units 1 and 2 Response to inspection Report Nos.

.50-373/90026;50 374/90027 i t1R0_D.odetJfoad0-323_and_S0-314__

Reference:

. (a) W.D, Shafer letter to C. Reed dated January 24,1991.

Dear Mr. Davis:

This letter is in response to the inspection conducted by Messrs. T. Tongue, C, Phillias, T. Laughton and H. Simons of your staff and assisted by J. Roman of the Illino s Department of Nuclear Safety pertaining to certain activities at the LaSalle  ;

County Station. Reference (a indicated that certain activities appeared to be in

' noncompliance with NRO requ)irements. The Commonwealth Edison response to t Level IV Notice of Violation is provided in the following attachment. -

If there are any questions or comments regarding this matter, please contact this Very truly yours, L

T.-J ovach Nuclear Licensing Manager  ;

. cc:' Senior. Resident inspector - LSCS ZNLD745/10 :

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L AUACHMENT Commonw.ealttLEdison.LaSale_ County _StatLon c Besponse_to. Notice _oLViolation LaSalle County Station continues to place emphasis on Corporate and Station policies which require strict adherence to procedures, in both instances of the cited failures to follow procedures, the individuals and departments were counselled to ensure that Station awareness la re-heightened concerning this issue. LSCS is <

committed to safe operation and recognizes the importance of eliminating mistakes which result from failure to follow procedures as a vital component in achieving this goal. Review of the applicable procedures revealed them to be adequate, and both violations were specific to personnel failure to follow approved procedural steps. The review however, provided insight which is resulting in re examination of some practices, which will help minimize the risk of future events. Attached are responses to the individual examples identified within the inspection report.

in addition, the inspection report noted a potential concern about the adequacy of the station's procedures. The station currently has in excess of 10,000 preedures,

. all of which are periodically reviewed for possible improvements, Major rewrite / reformat efforts are in progress for mechanical, electrical, and instrument procedures, and are

- being considered for operating procedures. These ongoing enhancements represent-more than five percent of the station's total workload,- The station believes that the

- enhancements being made willimprove usability and reduce the number of procedure related errors.

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.- 2-VIOLAIJON: 1R 5.0-324l00D27-01A 10 CFR 50, Appendix B, Criteria V, states,in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be '

accomplished in accordance with these instructions, procedures, or drawings.

a. On December 17,1990, while performing LIS MS-406, Condenser Low Vacuum Main Steam isolation Functional Test on Unit 2, an Instrument Maintenance Technician performed steps of the procedure out of sequence resulting in an unplanned Primary Containment isolation System Group I isciation.

CORRECTIVE. ACTIONS TAKEtiAND_ BES1)LISACHIEVED The isolation signal was recet immedietely and the surveillance for that channe! was completed satisfactorily, ,

GORRECTIVE ACIJONS_TAKEN TO AVQlp FURTHEELYlOLATIONS The Instrument Maintenance technician involved was counselled on the importance of following a procedure as it is written in sequential order and to centact his supervisor for clarification concerning unsure procedural sie as.

He was also reminded that there were no exceptions in deviating from t1e arocedure sequence without an approved procedure change. Additionally, le was reminded to take the procedure with him to perform work, and that it is unacceptable to work from the attachment.

This event was tallgated with the Instrument Maintenance Department at the next in theweekly sequential communication order and ensuring meeting, t hat one channelis reset beforewith emphasis on following proceeding to the next.

A long term action, which was already in progress, is the reformatting of the Instrument Maintenance procedures to incorporate most of the signoff into the body of the arocedure eliminating most of the attachments currently used. This is scleduled for completion in late 1995.

r IBE DATE OEEllLLSOMELIANCE Full compilance has been achieved.

ZNLD745/12

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3 l VIOLATIDilt IR 50-374/9002LQ1B 10 CFR 50, Appendix B,' Criteria V, states,in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or dravngs, of a type appropriate to the circumstances and shall be eccoo plished in accordance with these instructions, procedures, or drawings,

b. Aq December 19,1990, it was discovered that a clerk had failed to

. ' ace copies of the procedure LGd 1 1, Unit Startup, In a file drawer c a new rev!sion, as required and identified by station administrative p xedure LAP-820 3, Procedure Distribution. This resulted in the commencement of a reactor startup using the wrong procedure revision.

DDRBECl1VEACIlORSIAKENANDllESullSACHlEVER A review of the newer revision showed that none of the changes made o affected steps which had been performed. The proper procedure revision E

was obtained and the_startup was continued as planned. All operating forms files have been verified to have the most current revisions.

QORRECT'lVE ACTIONS TAKEN T_QlVDID FURTBEBllRLAIl011S LAP-100-40, Procedure Use and Adhorence Expectations, was issued to describe how to. verify that one has the most up to date revision of a 7 articular procedure. A General Information Notification (GIN 90-101) was ssued for all plant personnel to review the portions of LAP 100 40, which.

- pertain to the proper handling of all procedures, whether obtained from a controlled file, or a form file.

.The clerical guidelines for procedure updates includes direction that the form

file will be reviewed and out-dated forms destroyed prior to updating the procedure set. '

IllE_DATE_OF_El).LktOMP.LIANGE Full compliance has been achieved.

ZNLD745/imw.

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