ML20079G925
| ML20079G925 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/06/1983 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 7227N, NUDOCS 8401230233 | |
| Download: ML20079G925 (14) | |
Text
- 1 L.,
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['N Commonwsalth Edison
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) one First Nationit Pfar:. Chicteo, Illinois
's C 7 Addr;ss R; ply to: Post Offica Box 767 (j Chicago, Illinois 60690 September 6, 1983 Mr. James G. Keppler, Regional Administrator
- Region.III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Unit 1 Responce tn Notice of Violation and Proposed Civil Peralty NRC Docket No. 50-373
Dear Mr. Keppler:
By this letter, Commonwealth Edison Company responds to the Notice of Violation and Proposed Imposition of Civil Penalties of the NRC,_the Special Inspection Report, and its accompanying letter regarding the occurrence that resulted in a Suppression Pool to Drywell Vacuum Breaker Isolation Valve being mispositioned during facility operation.
In accordance with 10 CFR 2.201, this response is submitted within 30 days as specified.
In addition, upon completion of your review of this response, we are requesting that you consider mitigating or remitting the pgggggedcivilpenaltyasallowedforin10CFR-2.205.
This request is ted separately Commonwealth Edison understands the significance of the viola-tions cited in the Notice.
We rely heavily on a well trained and highly motivated staff ~of operators, engineers, technicians, and managers to safely and efficiently operate LaSalle County Station.
Strict adherence to procedure is required and compliance is emphasized by all levels of supervision.
We recognize that the events in question which gave rise to this enforcement action demonstrate deficiencies in administrative control as well as actions that were less than expected from this group of professionals.
As described in Attachment A to this letter, the LaSalle County Station has instituted a full range of measures to address the concerns which'were identified by these violations.
These actions are directed at correction of the procedural as well as the performance problems.
Tt.ey have been. researched and implemented with the ultimate goal of removing the possibility of future generic type deviations.
They have the full support.and backing of both station and company management.
Management recognizes the importance of good administrative control in fostering awareness and compliance with good operating practice.
In answer to the three questions in your letter addressed to such measures, Commonwealth Edison affirms the following actions:
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'4-p li G. Keppler' September 6, 1983 4
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Ensure double verification of equipment line-up is ' performed on return -to service of all safety related equipment after maintenance and test activities:
h 1;. I.E..InspectionLReport 50-373/83-05 identified a discrepancy
.betweenfLAP 240-1, Locked Valve Procedure, and Individual System Checklists.
a)-
A. total of 36 procedures were revised to bring all procedures into compliance..In addition,.as procedures are reviewed as required by LAP 820-1 every two-years, an audit is being conducted to verify locked valve manipulations are documented and verified.
This is done in accordance with the
. appropriate Mechanical Checklist on LOS-LV-SR1, Locked Valve Surveillance.
b)
LAP 900-4, Equipment Outage Procedure has been revised to add
- the requirements that the supervisor in charge of the equipment must determine and fill in the "af ter" position on outage checklists.from an approved Mechanical or Electrical Checklist.-
By'doing this, the last full checklist' remains effectively current.
The supervisor must also audit the checklist ~for proper completion and sign and date the checklist.
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c)
The position of Operating Department Outage Co-ordinator has been established and will be manned at the request of the l~
Unit Operating Engineer, to co-ordinate the planning and conduct of maintenance from the Operations viewpoint.
One of his duties involves co-ordinating with the Unit Operating Engineer and Shift Supervisors to accomplish required Mechanical and~ Electrical checklists in a timely manner after completion of~all maintenance and surveillances on a p
particular-system.-
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d)
LAP.240-1, Attachments A(B), C(D), Locked Valve Checklist,-
has.been revised and divided such that locked valves associated with safety systems will be verified current prior to start-up.
This is directed as a final step by LGP l-S1, u
H Master Start-up Checklist.
o 8.
' Establish a feedback mechanism from personnel utilizing procedures to L
ensure.that procedural deficiencies identified during work are l.
resolved prior to completion of the work:
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Procedures are established and in effect that provide for timely correction of procedural deficiencies.
These procedures include:
a)- LAP 820-4, Temp rary Procedures Changes, provides a mechanism for immediate procedure revision and is applied in cases where.the change does not change the procedure intent.
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Keppler. September 6, 1983
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b)
LAP-820-2, Station _ Procedure Preparation and Revision,
'provides for an accelerated ~ approval of a necessary procedure 1 change.for timely approval.
Once' approved, the. procedure is copied and authorized for use prior to final typing and distribution to controlled plant procedure manuals.
This
-copyris;used and. maintained in the. Temporary Procedure Change Log when not being performed until the final typed revision is distributed. ~This effort is directed at completion within one working day.-
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LAP 820-7, Special Procedures, provides for procedure prepar-stion which is required for one time or limited time use, and which is not, in itself, a test and is not a temporary change to existing station procedures.- This provision is used to provide approved procedures for use in problem analysis and identification of suspect equipment or system performance.
- d ).
LTP'100-2, Special Operation Tests, provides for procedure preparation and conduct of tests of systems or components performed.by LaSalle County Station personnel and/or by vendor representatives.
Use of these approved procedures will be emphasized in the training sessions planned and committed to in Attachment A.
C.
Ensure that short term corrective actions following future events include determination and resolution of causal factors that resulted in personnel performance deficiencies:
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The=LaSalle County Station maintains close supervision and docu-mentati.on of all incidents.
This is accomplished by independent investigations of all deviations to determine cause and appropriate corrective actionc.
The report is then forwarded for approval by On-Site review.
2.
In addition, for occurrences of a significant nature involving personnel and performance, Station Management evaluates the event to determine if it is reportable to the Division Vice President per Production Instruction 1-3-F/N-7.
The Division Vice-President then designates the level of investigation (on-site, informal, or l formal) to-be performed.
When the event is non-reportable per this~ program, the Superintendent or Assistant Superintendent shall determine if an on-site investigation is required, and F
initiate as-appropriate.
As soon as possible after identifica-tion of an event, a debriefing meeting is scheduled with all involved personnel to provide a basis for evaluation of the causal factors.
In the future, LaSalle County Station will ensure that corrective' actions as described above will be directed at determining and correcting both the causes of the event and attempting to recognize generic associated problems co prevent recurrences of a similar nature.
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J. G. Keppler September 6, 1983-In summary, Commonwealth Edison reaffirms its commitment to proper administrative control of all equipment under all circumstances in accordance with Technical Specifications.
We recognize the importance of a thorough investigation of events being promptly completed to ensure that' problems are effectively resolved.
Through the measures we have described in this letter and the attachment to it, we believe that the recurrence of this incident and similar incidents can be prevented.
The operation of LaSalle County Station can continue with full assurance of plant safety.
If there are any questions regarding this matter, please contact this office.
Very truly yours, AO Cordell Reed Vice-President lm Attachment cc:
Director, Office of I&E NRC Resident Inspector - LSCS G. Benson, Regulatory Affairs i~
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ATTACHMENT-A 4:
c RESPONSE T0 NOTICE OF VIOLATION p
e COMMONWEALTH EDISON COMPANY.
Doc!<et No.1 50-373 e'
LASALLE COUNTY NUCLEAR POWER STATION License No. NPF-11 UNIT 1 This is Commonwealth Ediscn Company's response, pursuant to 10
~ CFR 2.201, to the Nuclear Regulatory Commission's Notice of Violation and Proposed Imposition of Civil Penalties (EA 83-59) issued on August 9,
- 1983.
VIOLATION A - (373/83-26-02 (DPRP))
LaSalle County-Technical Specifications Section 6.2.A requires that
' written procedures shall be adhered to for equipment control-(e.g.
locking and tagging /out-of-service procedures).
Administrative control of equipment is implemented through LAP 900-4, Equipment Out-of-Service Procedure", and. LAP 240-1, "Use of Locks on Valves" The NRC finds that contrary.to this requirement, the licensee did not auhere to these
- precedures as indicated below:
- 1. - LAP'900-4, " Equipment Out-of-Service Procedure", Step F.2.J requires that_the supervisor in charge of the equ1pment or his designee, will-i audit the equipment outage checklist to verify proper completion.
Step F.2.K requires, for safety.related outages, that the shift l
supervisor will designate a second person to make an inspection and verify'that'the physical isolation points have been properly L
positioned for return to service.
2.
LAP 240-1, "Use of Locks on Valves", Step F.6 requires that, if plant 7
conditions require a locked valve to be positioned in a manner other l
than'that indicated in Attachment A(B), the valve may be unlocked and L
repositioned either by an approved procedure or an outage checklist.
When the procedure or outage is completed, the valve shall be placed in the position indicated in Attachment A(8) and locked, n
Contrary to the above, the Suppression Pool Side Isolation Valve
}'
(1PC003D) for the "D" Suppression Pool to Drywell Vacuum Breaker was left closed upon clearance of 005 1-541-83 on May 26, 1983.
This resulted in the "0" Vacuum Breaker being inoperable.
- DISCUSSION A.
. Commonwealth Edison admits Violation A.
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. B.
The reasons for the violation are summarized as follows:
1.
Failure of the' administrative control of equipment.
a)
LAP 900-4 stated "The position "after" should De the same as positico "before" unless plant conditions prohibit".
The several outages used to accomplish modification package 1-1-83-230, and temporary lifts of the outages to accomplish necessary Local Leak Rate Tests, allowed the situation to arise where the "before" position was listed as closed.
The persons clearing and verifying clearance of the final outage used this provision to determine the "after" position.
The supervisor in charge of the equipment recognized this discre-pancy but believed additional testing was required and thus returned the equipment to service per the outage checklist.
b)
Failure to perform a line-up in accordance with LGP l-S3, Pre-Start Line-Up Check Off List.
This final system valve line-up was not conducted due to an oversight by the Unit Operating Engineer and Shift Supervisors.
This was a failure to implement an existing procedure.
LAP 240-1, Attachment A, Locked Valve Checklist was performed satisfactorily on May 17, 1983, and was felt to be adequate.
However, significant work continued on the Vacuum Breaker subsequent to this effort.
c)
Failure of Test Procedure LTS 500-1, "Drywell/ Suppression Pool Vacuum Breaker Valve Force Check", to require locking, verification, and documentation of the final position of the vacuum breaker isolation valves.
C.
Corrective Actions Taken and the Results Achieved:
1.
Upon discovery on June 21, 1983 at 11:30 a.m.,
the valve was immediately locked open and all other vacuum breaker isolution valves were checked and verified to be in the correct locked i
position.
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2.
A DVR (Deviation Report) was submitted and a Shift Engineer and Shift Control Room Supervisor were assigned to conduct a Professionalism Program On-Site Investigation.
3.
The Senior Resident NRC Inspector was notified.
4.
A re-verification of flow path " Locked Closed" valves per LAP 240-1, Attachment A, Locked Valve Checklist, was initiated.
This action was completed on June 25, 1983 at 6:00 a.m.
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. D.
Corrective Steps Taken to Avoid.Further Violations:
1.-
The Professionalism Investigation was completed on June 24, 1983 and the following corrective actions were taken:
a)
A sequence of events for the-violation was developed, documented and prepared for review by all operating crews.
The violation was reviewed with all shifts as they reported to work, to ensure all were aware of the importance of repositioning valses properly, following the 0.0.S.
procedure, and the Locked Valve Checklist.
This was accomplished for cach crew by the Shift Engineer with the Operating Assistar.t Superintendent present.
This action was completed on July 1, 1983.
b)
Equipment 0.0.S. Procedure, LAP 900-4, was revised as follows:
Step F.2.e The " Supervisor in Charge of the Equipment" then enters the position required by the Normal Start-up Mechanical or Electrical Checklist for the component in the " Position After" column of the Equipment Outage Checklist.
Flexibility is provided to accommodate special plant conditions as required.
Step F.2.g Deletes reference to "before" position for determining proper "after" position.
Step F.2.j The " Supervisor in Charge of the Equipment" or l
his designee will audit the Equipment Outage Checklist to verify prcper completion, and sign and date the Equipment Outage Checklist.
This procedure was revised, approved and entered I
into control documents on June 27, 1983.
Crew tailgate training sessions on the Revision were l
conducted by the Shift Engineers.
This action was completed on September 1, 1983.
c)
A complete review of the following items was conducted to identify and implement improvement of administrative control of equipment:
1.
LAP 240-1 has been revised to divide the locked valve checklist into four f.ections a)
Attachment A(B).ncludes Type 1, 2, and 3 valves.
l b)
Attachment C(D) includes Type 4 valves.
4 2>
- LGP l-S1, Master Start-Up Checklist,-has been revised to require.that as.a-final check, LAP 240-1 Attachment A(B) will be verified current prior to start-up.
This action was completed on September 5, 1983.
This action provides assurance that any. locked valves.that may have been manipulated by maintenance actions.or-surveillance are properly positioned prior to a mode change.
12.1 Equipment Out-of-Service-Procedure,. LAP 900-4, was reviewed to identify further generic problems.
With the enhancement.of' administrative control as provided by the Supervisor in Charge of the Equipment assigning "af ter" positions to the Equipment Outage Checklists and signing verification of proper completion, no futher changes were found necessary.
A Quality Control Surveillance of the Equipment Out-of-Service Procedure i.o identify chronic, recurring problems was conducted on June 27, 1983.
No further. problems were identified and the Out-of-Service System was deemed adequate.
The Operating Assistant Superintendent'has requested that further audits by Quality ~ Control be conducted on the Equipment Out-of-Service Procedure in October and December, 1983, to verify full compliance with the procedure change, and to identify any further procedural inadequacies.
3.
Locked Valve. Position Verification, LOS-LV-SR1, was reviewed for adequacy.
This procedure allows for changing a Locked Valve position when the operation is not covered by an approved procedure or Out-of-Service Checklist.
A revision was made to limit the use of this procedure to occasions when the operator is in continuous attendance.
Any other situations not covered by a proce-i dure will require use of the Equipment Out-of-Service l~
procedure.
This item was completed on September 5, 1983.
4.
Drywell/ Suppression Pool Vacuum Breaker Valve Force Check i.
Surveillance, LTS 500-2, as well as all LaSalle Technical Procedures and LaSalle Technical Surveillances have been reviewed to verify the requirement for locking, verifica-tion, and documentation of the final position of any j
locked valves associated'with their performance.
This item was completed on September 5, 1983.
4 5.
.The completion time-frame for checklists after an outage was also reviewed.
In accordance with LGP 1-S3, Pre-Start-Up Line-Up Check Off List, the Unit Operating Engineer provides a list with the Master Outage Checklist of Mechanical and Electrical checklists requested prior to startup.
Due to the varying work load and number of systems that may be affected and the delays that can occur in any outage, application of a specific time frame is not considered prudent.
. In August,--the position of Outage Co-ordinator for the Operating Department was established.
When required, this position will function to assure a timely flow of maintenance throughout an outage.
Among his tasks, the co-ordinator will interface with the Unit Operating Engineer and Shift Supervisors to ensure necessary mechanical and electrical checklists are completed as system maintenance ano surveillance is completed.
Specific checklists are required to be performed prior to
-Unit Start-up following each Refueling Outage or extended maintenance (greater than two months).
Satisfactory completion of LGP l-S3 is noted as a sign-off in the final checks of the Master Start-up Checklist, LGP 1-S1.
6.
Classroom Training has been rescheduled for the period of September 9, 1983 through October 18, 1983.
These sessions, with each operating crew, will cover:
a)
The sequences of events for this event, b)
The professionalism investigation and findings.
c)
The Inspection and Enforcement Conference Summary.
d)
The Station Response.
e)
Review of corrective actions and procedure changes.
f)
Discussion i
This training will be conducted by the Shift Engineer with an Operating Engineer or the Operating Assistant i-Superintendent in attendance.
This action will be l
completed on October 18, 1983.
l E.
Date When Full Compliance Will Be Achieved:
In our effort to ensure a full understanding by all operating staff of this incident and corrective actions, and to identify any further generic procedural inadequacies, training sessions will be conducted as described in item D.l.c.2 and D.l.c.6.
Full compliance will be completed as described in these sections.
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. VIOLATION ~B
'(373/83-26-01.(DPRP))
LaSallejCounty Technical Specification 3.0.4 prohibits entry into an
. operational; condition:(including-hot shutdown, start-up or power
' operation) unless.the Limiting Conditions-for Operation are met without reliance on provi'sions contained in the Action Statement.
Technical Specification ~ Limiting Conditions.for Operation 3.5.4 requires that, s
whenever the reactor is in. hot shutdown, start-up, or power operation, allisuppression' pool to drywell. vacuum breakers be operable or closed.
1The NRC. finds:that' contrary to this, the reactor entered the operational conditions'of hot shut down, start up and/or power operation with the "D" Suppression _ Pool to Drywell Vacuum Breaker isolated and inoperable on May 28, June 2,' June 7, June 8, and June 14, 1983.
DISCUSSION
.A.
Commonwealth Edison Admits Viol $ tion B.
.B.
_The reasons for this violation are summarized as follows:
1.
Failure of administrative control of equipment.
a)- An extensive maintenance outage was completed on 5/28/83.
Included in this maintenance outage was Modification l-1-83-230 on "D" Suppression Pool to Drywell Vacuum Breaker.
A total of three different Equipment Outages were used to control-the various aspects of the job.
The last
' outage.to be cleared listed the "before" position of the l'
1PC0030 "D" Vacuum Breaker Suppression Pool Isolation Valve as closed.
This was used as the "after" position by the L
operator clearing the outage as was permitted by the Equipment l
Out-of-Service Procedure, LAP 900-4.
The clearance of the l
outage was safety verified as required and the checklist was audited by the supervisor.
The Supervisor recognized the position discrepancy but believed additional testing was required, and thus returned the equipment to service per the outage checklist.
Outage completion test LOS-PC-M2, Drywell-Suppression Pool Vacuum Breaker Operability Test for Conditions 1, 2, and 3, was performed satisfactorily.
This test cycles the vacuum breakers and checks proper indication.
-b)
Locked Valve Checklist, LAP 240-1, Attachment A(B), was performed on May 17, 1983 and the valve IPC003D verified locked open.
Successful completion of this checklist was signed on LGP l-S3, Pre-Startup Line-up Check-Off List.
This was eleven days prior to the start-up.
Maintenance and Surveillance Testing continued after this date.
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. c)
The Unit Operating Engineer and' Shift Supervisors overlooked
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the need to perform LOS-PC-OlM or LOS-PC-ole prior to start-up.
A total of seventy checklists were performed in accordance with LGP l-S3 prior to the start-up on May 28, 1983.
2.
No'further manipulations of the Isolation Valve or Vacuum Breaker occurred prior to the Reactor Start-Up on May 28, 1983 and no further checks were required by the start-ups conducted on June 2,
June 7, June 8, and June 14, 1983.
On June 21, 1983 at 11:30 a.m.,
a Technical Staff Engineer found 1PC003D unlocked and closed.
C Through E The Corrective actions taken to prevent a recurrence of this event, the corrective actions taken to avoid further violations, and the date when full compliance will be achieved, have been addressed in the broad scope response to Violation A of this document.
It should be noted that at no time following the May 28, 1983 Reactor Start-up was there a requirement or necessity to check the valve line-up on the Vacuum Breakers.
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. VIOLATION ~C' (373/83-26-03-(DPRP))
LaSalle County Technical Specification 6.6.B.l.b requires that the
. director of the appropriate regional office or his designee be notified as expeditiously as possible but'within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and confirmed by telegraph, mailgram,,or facsimile transmission, no later than.the first working day following any event involving operation of the unit or
- affected system when any parameteraor operation subject to a limiting condition is'less conservative than the least conservative aspect of the limiting condition for operation established in the Technical Specifica-
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.tions.
The NRC finds.that contrary to this commitment, the licensee discovered that the unit was operated in a condition less conservative than the least conservative aspect of the Limiting Condition for Operation established-in Technical Specification 3.4.4 on June 21, 1983.
Technical'Specificaion 3.6.4 requires that all suppression pool to drywell vacuum breakers be1 operable during hot shutdown, start-up and power operation.
The Unit was operated with the "D" suppression pool to drywell vacuum breaker isolated and inoperable and this condition was not reported.to the NRC Region III until June 24, 1983.
DISCUSSION g
A.
Commonwealth Edison Admits Violation C.
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- B.
The reasons for the violation are summarized as follows:
1.
On June 21, at 11:30 A.M.
the IPC003D, "O" Suppression Pool
-Vacuum Breaker Suppression Pool Side Isolation Valve was l'
discovered unlocked closed.
This rendered the "C" Suppression
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Pool.to Drywell Vacuum Breaker inoperable.
The valve was Limmediately repositioned and locked open.
I The. Licensee referred to Technical Specification 6.6.B.1.f.
This L
item.then referenced Technical Specification 6.6.B.2.c.
As a result of this, a 30 day reportable occurrence was classified and t
the Senior Resident Inspector was informed.
L While it was recognized that the "0" Vacuum Breaker had been inoperable for a period of time exceeding the limit in the L
Technical Specification.3.6.4, immediate action had been taken to realior the system to a safe operating condition.
Since the F
principal'cause of the event was determined to be procedural L
inadequacy, the event was initially classified in accordance with Technical Specification 6.6.B.2.c.
L On the morning of June 24, 1983, following discussions with the I
Senior Resident Inspector, the event was reclassified per Technical Specification Section 6.6.B.l.b.
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. C.
Corrective Actions Taken and the Results Achieved:
1.
On June 24, 1983 at 1315,.the NRC Red Phone notification was made.
2.
On June 24, 1983 at 1449, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> NRC Region III telephone notification was made.
3.
On June 24, 1983 at 1535, the NRC Region III Regional Director was telecopied the confirmation.
4.
On July 5, 1983 the completed Licensee Event Report was distributed.
D.
Corrective Actions Taken to Avoid Further Violations:
1.
Standard practice for classification of events at LaSalle includes the discussion and agreement by at least two Senior Reactor Operators as to the proper classification.
The Administrative Controls section of Technical Specifications as well as LZP-1310-1, Notifications, are used as references.
Notifications as deemed necessary are then initiated.
For all notifications, a courtesy call is made to the NRC Resident Inspector.
After reviewing this event, the response by LaSalle Station is that the present practice is satisfactory for the timely and proper classification of events.
This incident, which was difficult to categorize, resulted in a violation of reporting requirements.
Once recognized, all notifications were made in an expeditious and proper manner.
The-problem in classifying this event is considered another example cf how the complexity and difficulty in interpreting the Technical Specifications can result in the differences of opinion.
It should be noted that this is the first occurrence of an incorrect classification of a License Event Report at LaSalle Station.
4 2.
Classification of occurrences and interpretation of Technical Specifications are a continuous item of emphasis in the station.
Problems encountered at LaSalle and throughout the industry are brought to the attention of those concerned in the following manner:
a)
"For Your Information" items are transmitted to all cognizant individuals by the Operating Engineer, Operating Assistant Superintendent, or Station Superintendent.
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Assorted Experience Items are-' covered in the regular training modules-for all licensed individuals.
c). Experience in classification is also provided in the Annual Generating Station Emergency Training.
E.
Date When Full Compliance Will Be Achieved:
Full Compliance _.with corrective actions is complete at this time.
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