ML20052E691

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Responds to NRC Re Violations Noted in IE Insp Rept 50-373/82-06.Corrective Actions:Procedures Changed for Verification of Physical Isolation Points for safety-related Equipment Outages
ML20052E691
Person / Time
Site: LaSalle Constellation icon.png
Issue date: 04/07/1982
From: Stiede W
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20052E689 List:
References
3798N, NUDOCS 8205110355
Download: ML20052E691 (4)


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"N Commonwealth Edison

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) oni First N',tiorni Piara, ChicIgo, fihnois O 7 Address Reply to: Post Office Box 767

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/ Chicago, Illinois 60690 April 7, 1982 Mr. James G. Keppler, Regional Administrator Directorate o f 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 Item o f Noncompliance Inspection Report 50-373/82-06 NRC Docke t No. 50-373 Reference (a):

R. L. Spessard letter to Cordell Reed dated March 9, 1982.

Dear Mr. Keppler:

Attached please find Comnionwealth Edison Company's response to the item of non-compliance transmitted by Reference (a).

4 To the best of my knowledge and belief the statements contained in the attachment are true and correct.

In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees.

Such information has been reviewed in accordance with Company practice i

and I believe it to be reliable.

If there are any further questions on this matter, please contact the Nuclear Licensing Department.

Very truly yours, W.

L. Stiede Assistant Vice President im Attachment cc:

NRC Resident Inspector - LSCS SUBSCRIBE 0 and SWORN to before me this f d day o f _h lL 1982 00

' Notaryg()ublic Ap0 28 B205110355 820503 PDR ADOCK 05000373 3798i G PDR

ATTACHMENT Item o f Non-Compliance 10 CFR Part 50, Appendix-B, Criterion V, s tates, 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."

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.

Quality Procedure 11-2 states in Section 5.4 that " Station staff unoer the direction of the Station Superintendent will operate equipment and systems in accordance with approved operating procedures and as required by the Preoperational or Startup test procedures."

Quality Requirement 14.0 states in Section 14.3 " STATUS CONTROL" that " methods of control will be provided through construction and Station Operating Procedures which describe the use of

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forms, tags, and logging methods."

Station procedure L AP 240-3, Electrical Jumper and Relay Block 1

and Lif ted Electrical Leads, establishes the administrative con-trols necessary for the installation and removal of electrical leads and jumpers.

The Shif t Engineer has the daily responsibi-lity to verify the installation or removal and document these actions with appropriate master log entries.

Station procedure L AP 820-5 states that the status o f system valves shall be verified using mechanical checklists.

Contrary to the above:

a.

On December 5, 1981, during a instrument line hydrostatic test, valve 1821 F371, which was tagged out-o f-service in the closed position, was in fact not closed. (373/82-06-OlA)

'b.

On December.6, 1981, valve 1DG032, which is in the cooling water line to the Low Pressure Core Spray (LPCS) pump, was found closed.

The mechanical checklist, LOP-DG-08M, requires the valve to be open (listed as " locked open").

This resulted in the LPCS pump running without cooling water, which contributed to the running of the LPCS pump while temperatures were above the alarm limits.

(373/82-06-018)

_.2-c.

On December 6, 1981, LPCS pump temperature thermocouple leads were found to have been determinated without any authorizing documentation and without operations depart-ment knowledge.

This contributed to the LPCS pump being run while temperatures were above alarm limits.

(373/82-06/01C)

Corrective Action and Results-Achieved r

(373/82-06-01A)

Valve 1821-F371 was found cracked open, a f ter the inadvertant spraying of water on some workers in the reactor vessel.

The valve was subsequently closed and an investigation into the cause of the apparent violation o f the Out-o f-Service procedure was made.

It is thought that the reason for the valve not being fully closed was due to the stiffness of the valve on closure combined with an insufficient check o f valve tightness of closure.

This is believed to be an isolated incident.

(373/82-06-018)

Valve 1DG032 was found valved out.

The valve was unable to be operated due to a broken keyway in the valve handle.

The valve appeared to be partially open.

The valve tag described it as the Diesel Cooling Water outlet valve and-there

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had been no problem with Diesel Generator Cooling.

Manual valve IDG032 was repaired immediately upon discovery, with parts from the Unit 2 counterpart.

The valve was opened as ' required by procedure prior to subsequent pump runs.

The LPCS Pump Motor was determined to have not been damaged by satisfactory test results -o f motor vibration and oil' sample tests.

(373/82-06-01C)

Investigation revealed that the loss of temper-ature indication for the LPCS Pump Motor bearings was due to leads having been determinated at the computer and a broken thermocouple lead.

The broken lead was repaired,.and the computer leads were reterminated after it could not be determined for what reason the leads had been disconnected.

Corrective Action to Avoid Further Noncompliance (373/82-06-01A)

Administrative corrective action has been taken l

to prevent future recurrences.. A procedure change has been maoe to the L AP 900-4, Equipment Out-of-Service Procedure, which requires verification by a second person of physical isolation points for Safety Related equipment outages.

l (373/82-06-018)

Administrative corrective action is being taken to prevent future recurrences.

It was noted during a review of the incident that the mechanical checklist, LOP-DG-08M, listed the valve name of IDG032 in a manner that was unclear for describing the valve's purpose for providing cooling water to the LPCS Pump Motor.

A procedure revision will be made to clarify the valve name o f 10G032 on LOP-DG-08M.

b

~~. ;.(373/82-06-01C)

Administrative corrective action is being taken to prevent future recurrences.

An Operating. Standing Order will be issued to use the process. computer to monitor equipment para-meters when appropriate' In addition, a visual inspection of safety related electrical panels in the plant is to be performed-checking for unassigned jumpers and lif ted leads prior. to fuel load.

Date of Full Compliance (373/82-06-OlA)

Double verification of physical isolation points has been approved by procedure revision 13 o f LAP' 900-4 for present station usage.

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(373/82-06-018)

The procedure revision to LOP-DG-08M shall be completed by 4-15-82.

(373/82-06-01C)

The Standing Order for monitoring equipment parameters will be issued by April 15, 1982.

The visual inspection of electrical panels shall be completed prior to fuel load.

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