ML20058D837
| ML20058D837 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/24/1993 |
| From: | Murphy W COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9312060054 | |
| Download: ML20058D837 (6) | |
Text
.
P O ' LaSalle County Nuclear Station Commonw2alth Edison
?
2G01 N. 21st. Rd.
Marseilies, lHinois 61M1 Telephone 815/357-6701 November 24, 1993 M
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Document Control Desk
Subject:
LaSalle ccunty Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos. 50-373/r'"28; 50-374/93028 NRC Docket Numbers 50-373 an' 374
Reference:
E.
G.
Greenman letter to M.
J. Wallace, Dated October 26, 1993, Transmitting NRC Inspection Report 50-373/93028; 50-374/93028 i
Enclosed is Commonwealth Edison Company's response to the Notice of Violations (NOV) which was transmitted with the referenced letter and NRC Inspection Report.
The violations regarded a failure to follow procedures with regard to mispositioning a spent fuel assembly in the Unit 2 spent fuel pool (paragraph 3).
The second involved inadequate corrective actions to l
prevent recurrence for a similar event in May, 1993.
If there are any questions or comments concerning this letter, please refer them to JoEllen Burns, Regulatory Performance Administrator at (708) 663-7285.
i Respectfully, 0 /jf.-1' ?
W P. Mur l sf e Vic e dent LaSalle County Nuclear Station ec:
J.
B. Martin, Regional Administrator, RIII A. T. Gody Jr., Project Manager, NRR v
D. Hills, Senior Resident Inspector, LaSalle y
7 t
i
-3 ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT ~
I 50-373/93028; 50-374/93028
.j VIOLATIONS: 374/93028-01 and 374/93028-02
~
During an NRC inspection conducted o~ September 23.through September 25, 1993, violations of HRC requirements were identified.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,".10 CFR Part 2, Appendix C, the violations are listed below:
1.
LaSalle TechnAcal Specification 6.2.A.a requires written procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February l
1978, be established, implemented, and maintained.
Regulatory Guide l
1.33 includes procedures for preparation for refueling and refueling j
equipment operation.
i LaSalle Fuel Procedure (LFP)-100-2, " Administrative control of Transfer.
I l
of Fuel or special Nuclear Material Between or Within the Spent Fuel l
Pool (s) or Vaults", requires, in part, that all steps in the Nuclear Component Transfer List be completed and verified by the Fuel Handling 4
l Supervisor.
j l
1 Contrary to the above, on September 13, 1993, during defueling of the i
Unit 2 reactor, fuel handlers placed and verified a spent fuel bundle designated by t!
clear Component Transfer List to be placed in spent fuel pool positio. FFF-38 into position GGG-38.
t i
1 This is a Severity Level IV violation (Supplement I).
)
}
2 10 CFR 50, Appendix B, Section XVI, states, in part, " Measures shall be established to assure that conditions adverse'to quality... are promptly identified and corrected... the measures shall assure that the cause of the condition is determined and corrective action taken to 3
preclude repetition."
Contrary to the above, corrective actions for a similar event in May j
1993, did not prevent fuel handlers from placing spent fuel in an i
incorrect location in the Unit 2 spent fuel pool on Septenber 13, 1993.
j This is a Severity Level IV violation (Supplement I).
LaSalle 1 I
o
__m I
1 1
s ATTACHMENT (Continued)
.l RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-373/93028; 50-374/93028 REASON FOR VIOLATION: 374/93028-01 i
On September 16, 1993 during a nuclear fuel piece count in the Unit 2 Spent
. Fuel Pool, LaSalle identified that fuel bundle YJ0483 was in fuel pool cell location GGG-38, instead af its designated location, FFF-38.
LaSalle Fuel l
Procedure (LFP)-100-2, " Administrative Control of Transfer of Fuel or Special Nuclear Material Between or Within the Spent Fuel Pool (s) or Vaults", was being used and followed by the fuel handling personnel.
3 The reason for the bundle being placed in the wrong cell location is that proper self-checking techniques were not applied by the personnel involved.
I Additionally, an operator aid nap that had been developed was not used. The map had some minor errors that led the fuel handling supervisor to believe that it should not be used.
The supervisor failed to inform Operations
'l management of the concern and elected to proceed without compliance to previous direction on using the map.
The development and use of this map were corrective actions from a previous event in May 3993.
The alignment problem in the fuel racks that had been
~
previously identified did not appear to contribute to the problem since the alignment error was minimal in this area of the spent fuel pool. The need for improved indexing of the cells was previously identified and is expected to be completed prior to the Unit 1 refuel outage scheduled to start in March, 1994.
I An improved indexing system would have increased the probability of su'ccess,-
but proper verification of bundle placement was still necessary to ensure that the bundle was in the right location.
1 The t'ait 2 Spent Fuel Pool consists of high density fuel racks which are i
designed tc maintain a subcritical fuel array of any combination in the fully
.j loaded racks. The safety aspect of margin to criticality has been acceptably encompassed by the rack design, and the proper documentation of the location of the nuclear fuel is addressed in the LFP through verification audits.
Therefore, the safety consequences of this event and the previous event were minimal.
]
t i
i l
i I
1 i
i 1
j>.i LaSalle 2 3
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
- Puel movement was suspended until an investigation was conducted and corrective actions were taken. The following are corrective actions that were-taken to further minimize the likelihood of a similar occurrence through the completion of the core unload.
1 An operator aid for determining Unit 2. Spent Fuel Pool cell
+
locations was revised to provide benchmarks _to allow-verifiers to
]
more easily determine the correct cell locations. Additional f
details were added to show rack sections as an added reference point for location verification. The operator aid was also marked whenever a bundle was added to the pool, giving the verifier other l
bundle locations in the pool as a reference.
]
Fuel handlers were instructed on management's expectations for verification of prope: bundle placement.
Cell' verification was required prior to lowering the bundle into the fuel pool cell.
After lowering the bundle into the cell, but prior to disengaging the grapple from the bundle, fuel handlers were required to
. l reverify proper bundle placement, this time utilizing multiple i
methods of proper cell location.
l Fuel Handling Supervisors no longer received short reliefs from SRos during core unload. To assure the most highly experienced personnel were present supervising the remainder of core unload, I
only personnel trained on this pool configuration. directed bundle placement.
Bundles located next to the indexing on the west side of the fuel pool were removed prior to r'suming core alterations. This removed obstructions that obscured north-south location references 1
in the pool.
The crew was counselled on the fuel pool aligmment issue, the need to use self-checking practices, doing the job right, and on i
management's expectations of performance.
1
)
The bundle of concern was placed in the required cell location in accordance with the Nuclear Component Transfer List (UCTL).
The core unload was completed with no other fuel handling errors.
i i
1
- I I
i LaSalle 3 i
- i g
yy y-g y
y-y y
2--9
4_ _ _ _
t i
l I
CORRECTIVE ACTIf*"
- TO BE TAKEN TO AVOID FURTHER VIOLATIONS:
Procedure e-100-2, " Administrative Control of Transfer of Puel or
+
Special Nuclear Material Between or Within the Spent Puel Pool (s) or Vaults", will be evaluated and revised, as necessary, to more clearly l
define the responsibilities of the fuel handlers and ensure tools are f!
available to the fuel handlers for making accurate verifications-of fuel
~
'i location. This procedure will be revised prior to the start of the next refuel outage.
A new procedure, LFP-100-6, " Verification of Fuel Movements Within the
+
Reactor and Spent Fuel Storage Pools,"_was written. This procedure l
provides a standardized method of verifying proper placement cf fuel assemblies within the reactor and spent fuel pool.
1 Corrective actions described in the previous section will be evaluated l
+
for incorporation into other plant procedures as necessary. Any required procedure revisions will be completed prior to the start of the next refuel outage.
i Additional actions, addressed in the May 1993 event will continue:
+
A movable indexing system for use in the Spent Puel Pool is being
+
sought to help localize the indexes to the area in the pool of i
handling activity.
A human factors review of the core unloading and loading process l
will be conducted prior to the start of the next refuel outage.
T LaSalle completed the core reload from November 4 to 13, 1993 with no
+
fuel handling errors.
DATE WHEN TULL COMPLIANCE WILL BE ACHIEVED:
Pu:
compliance was achieved on September 17, 1993 when fuel bundle YJ0483 was
). aced in cell location FFF-38.
LaSalle 4
-....u i
1 ATTACHMENT (Continued)
RESPONSE TO NOTICE OF VIOLATION URC INSPECTION REPORT i
50-373/93028; 50-374/93028 j
VIOLATION: 374/93028-02 10 CFR 50, Appendix B, Section XVI, states, in part, " Measures shall be l
established to assure that conditions adverse to quality... are promptly
-)
identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is i
determined and corrective action taken to preclude repetition."
l LaSalle does not agree that the May 1993 and September 1993 events involve l
"significant" conditions adverse to quality.
Plant procedures are in place to ensure that conditions adverse to quality are promptly identified and
.j corrected. The procedures require periodic independent verification of proper bundle placement within the spent fuel pool.
This ensures that bundles are in the proper locations for core reload and meets requirements for inventory of r
LaSalle fully understands the importance of all aspects of fuel handling including bundle location in the fuel pool. Management expectations of the fuel handlers is that they be diligent in their work and that a mispositioned fuel bundle, even in the spent fuel pool, is unacceptable performance. On the i
other hand, it would be irresponsible of us to suggest that we have put mechenisms in place such that we can guarantee that there will never be a fuel bundle mispositioned in the spent fuel pool again.
The control mechanisnm that we have put in place, however, are designed to minimize such occurrences and to provide for sn additional verification after fuel moves have been l
a completed.
It was this provision of the procedure which caused us to identify and correct the mispositioned bundle. Therefore, plant procedures, as a i
whole, worked and there were no adverse consequences to the plant, personnel
- l or public safety.
}
l I
FROGRAM ENHANCENENTS:
Procedure LFP-100-2, " Administrative Control of Transfer of Puel or Special Nuclear Material Between or Within the Spent Fuel Pool (s) or Vaults", will be evaluated and revised, as necessary, to more clearly define the responsibilities of the fuel handlers and ensure tools are available to the fuel handlers for making accurate verifications of fuel location.
This procedure will be revised prior to the start of the next refuel outage.
A new procedure, LFP-100-6, " Verification of Fuel Movements Within the
+
Reactor and Spent Puel Storage Pools," was written. This procedure provides a standardized method of verifying proper placement of fuel assenblies within the reactor and spent fuel pool and will reduce the likelihood of placing a fuel bundle in an incorrect location.
a LaSalle 5
>