ML20031B852
| ML20031B852 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/15/1981 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20031B833 | List: |
| References | |
| NUDOCS 8110060151 | |
| Download: ML20031B852 (9) | |
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[^n N Commonwealth Edison
) On3 First N; tion:t Pina, Chic 7go, lilinois
('O'7 Address Reply to: Post Office Box 767
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/ Chicage, Illinois 60690 April 15, 1981 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Unit 1 Response to Inspection Report 50-373/81-06 NRC Docket No. 50-373 Reference (a):
R. F. Heishman letter to C. Reed dated March 18, 1981
Dear Mr. Keppler:
The following is in response to the inspection conducted by Messrs. R. D. Walker and S. E. Shepley on January 5 through February 6,
1981 of activities on LaSalle County Station Unit 1.
Reference (a) indicated that certain activities appeared to be in noncompliance wi'.h NRC requirements.
The Commonwealth Edison response to this notice of violation is provided in the enclosure.
Commonwealth Edison acknawledges that the discrepant activities identified did in fact violate the cited provisions of the Commonwealth Edison Quality Assurance Program.
Although the nature of the violation is of itself relatively minor, we also acknowledge the need to improve the program of implementation of the "out-of-service" procedure.
Without intending to minimize the significance of the event cited, it is important to note that the extensive activities on LaSalle County Unit 1 to complete construction, demands f ar more frequent exercize of the out-of-service procedure than is expected after LaSalle County Unit 1.is placed into operation.
Furthermore, of the approximately 4450 outages taken_in 1980, the only known violations-are those referenced in Reference (a).
However, our attention will be directed at improving the out-of-service procedure implementation to eliminate to the extent possible, any future violations.
The corrective action identified to accomplish this objective is discussed in the enclosure.
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If you have any questions in this regard, please direct-l them to this office.
i Very truly yours, b-o C. Reed Vice President 1
i Enclosure i
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NRC. Resident Inspector - LSCS SUBSCRIBED and SJ g to 3
i before th.i BAL/s day of 1981 K f (1 Dl l (lo0 ( /OLO NoJary Public p
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r Enclosure Response to Notice of Violation The response to the item of apparent noncompliance identified in Appendix A of the NRC letter dated March 18, 1981, is provided in the followirg paragraphs.
10 CFR 50 Appendix B, Criterion XIV, requires measures to be-established to indicate the operating status of systeas and components, such as by tagging valves, to prevent inadvertent operation.
Commonwealth Edison Company Assurance Manual,14-518, item 3C, states in part:
"... attach out of servie cards at all isolation points, as required by station procedures, to item (or items) taken out of service."
LaSalle County Station Equipment out of service procedure, LAP-900-4, F.1.f. and Construction Instruction No. 1-2-G-1 states the supervisor in charge of the work "has the responsibility to assure that... out of service cards have been placed correctly and that the equipment is safe to work on."
Contrary to the above, on December 23, 1980, line 1DG22A was cut into when that section of the system was not properly tagged out.
This resulted in the shutdown of the Emergency Diesel 0, which was being run as part of a preoperational test, and the paritial flooding of the 573' elevation of the Reactor Building with diesel cooling water.
Corrective Action Taken and Results Achieved The error resulted from an incorrect outage boundary being set up by the Commonwealth Edison startup engineer.
The error was the result of a failure of the Edison supervisor responsible for the work to assure that the outage location was properly identified, as is required by Construction Instruction 1-2-G-1.
Ine water discharged by cutting into lina 1DG22A did not result in any personal injury or equipment tamage and was subsequenty cleaned up.
No corrective action was required other than the repair of the line mistakenly cut.
Lorre,gtive Action Taken to Avoid Further Noncompliance Out of approximately 4450 uutages taken in 1980 which required the use of the LaSalle County "out-of-service" procedure, no other case is known for which the boundary specified for the outage was not adequate to protect the men working on the outage and adjacent plant equipment.
The other occurrence cited in the subject inspection report, though similar in nature, did not occur in 1980.
s-
-2 Because this error appears to be an isolated occurrence when viewed in the light of the number of outages taken, no procedural changes are judged to be necessary.
However, in order to clearly indicate the responsibility of all Commonwealth Edisca personnel respcnsible for such work, a directive was issued to all Station Construction Engineers, all Startup Engineers, and all Operatioral Analysis Department (0AD) Engineers which was co-signed by the Assistant Site Construction Superintendant, the Startup Coordinator and the Lead OAD Engineer.
This directive reiter~ted the Edison supervisor's responsibility to:
1.
Identify work determined to be required, and determine the outage boundaries.
2.
Review the outage with the contractor with emphasis en protection of contractor personnel.
3.
Verify that the outage as specified in the field is in fact adequate to protect the contractor prior to start of work.
This directive, along with the recognition by site management of the importance of minimizing future errors of this type, will minimize the potential for recurrer.ce of such errors.
Given the extremely low frequency of occurrence of such errors, it is judged that the existing procedures are currently adequate for use after the initiation of operation of the LaSalle County units.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
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ij Note:
The attached letter was previously transmitted unsworn on April 13 -.1981.- No substantive change.has been made to the-original submittal.
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<O Commonwealth Edison
[ C/ '= ) One First Nttional Pitta, chictgo lilinois
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Address Reply to: Post Office Box 767
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Chicago, Illinois 60690 April 13, 1981 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Unit 1 Response to Inspection Report 50-373/81-06 NRC Docket No. 50-373-Reference (a):
R. F. Heishman letter to C. Reed dated March 18, 1981
Dear Mr. Keppler:
The following is in response to the inspection conducted by Messrs. R. D. Walker and S. E. Shepley on January 5 through February 6, 1981 of activities on LaSalle County Station Unit 1.
Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison response to this notice of violation it provided in the enclosure.
Commonwealth Edison acknowledges that the discrepant activities identified did in fact violate the cited provisions of the Commonwealth Edison Quality Assurance Program.
Although the nature of the violation is of itself relatively minor, we also acknowledge the need to improve the program of implementation of the "out-of-service" procedure.
Without intending to minimize the significance of the event cited, it is important to note that the extensive activities on LaSalle County Unit 1 to complete construction, demands far more frequent exercize of the out-of-service procedure than is expected after LaSalle County Unit 1 is placed into operation.
Furthermore, of the approximately 4450 outages taken in 1980, the only known violations are those referenced in Reference (a).
However, our attention will be directed at improving the out-of-service procedure implementation to eliminate to the extent possibie, any future violations.
The corrective action identified to accomplish this objective is
. discussed in the enclosure.
'APR 15 gggy
.. If you have any questions in this regard, please direct them to this office.
Very truly yours, C. Reed Vice President Enclosure cc:
NRC Resident Inspector - LSCS 22598 i
f
Enclosure Response to Notice'of Violation The response to the item of apparent noncompliance identified in Appendix A of the NRC letter dated March 18, 1981, is provided in the following paragraphs.
10 CFR 50 Appendix B, Criterion XIV, requires measures to be established to indicate the operating status of systems and components, such as by tagging valves, to prevent inadvertent operation.
Commonwealth Edison Company Assurance Manual,14-518, item 3C, states in part:
... attach out of servie cards at all isolation points, as required by station procedures, to item (or items) taken out of service."
LaSalle County Station Equipment out of service procedure, LAP-900-4, F.1.f. and Construction Instruction No. 1-2-G-1 states the supervisor in charge of the work "has the responsibility to assure that... out of service cards have been placed correctly and that the equipment is safe to work on."
Contrary to the above, on December 23, 1980, line IDG22A was cut into when that section of the system was not properly tagged out.
This resulted in the shutdown of the Emergency Diesel 0, which was being run as part of a preoperational test, and the paritial flooding of the 673' elevation of the Reactor Building with diesel cooling water.
Corrective Action Taken and Results Achieved The error resulted from an incorrect outage boundary being set up by the Commonwealth Edison startup engineer.
The error was the result of a failure of the Edison supervisor responsible for the work to assure that the outage location was properly identified, as is required by Construction Instruction 1-2-G-1.
The water discharged by cutting into line 1DG22A did not result in any personal injury or equipment damage and was subsequenty cleaned up.
No corrective action was required other than the repair of the line mistakenly cut.
Corrective Action Taken to Avoid Further Noncompliance Out of approximately 4450 outages taken in 1980 which required the use of the LaSalle County "out-of-service" procedure, no other case is known for which the boundary Specified for the outage was not adequate to protect the men wn. king on the outage and adjacent plant equipment.
The other occur. ace cited in the subject inspection report, though similar in nature, did not occur in 1980.
2 Because this' error appears to be an isolated occurrence when viewed in the light of the number of outages taken, no procedural changes are judged to be necessary.
However, in order to clearly indicate the responsibility-of all Commonwealth Edison personnel responsible for such work, a directive was issued to all Station Construction Engineers, all Startup Engineers, and all Operational Analysis Department (0AD) Engineers which was co-signed by the Assistant Site Construction Superintendant, the Startup Coordinator and the Lead 0AD Engineer.
This directive reiterated the Edison supervisor's responsibility to:
1.
Identify work determined to be required, and determine the outage boundaries.
2.
Review the outage with the contractor with emphasis on protection of contractor personnel.
3.
Verify that the outage as specified in the field is in fact adequate to protect the contractor prior to start of work.
This directive, along with the recognition by site management of the importance of minimizing future errors of this type, will minimize the potential for recurrence of such errors.
Given the extremely low frequency of occurrence of such errors, it is judged that the existing procedures are currently adequate for use after the initiation of operation of the LaSalle County units.
l Date When Full Compliance Will Be Achieved Full compliance has been achieved.
l J