ML20091D771
| ML20091D771 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/18/1991 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9110290052 | |
| Download: ML20091D771 (4) | |
Text
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- e' 7.cs\\ Commonwealth Edison 2/
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Down1rs Grova, Illinois 60515 54 3
October 18,1991 P
n U.S. Nuclear Regulatory Commission
' Attn: Document Control Desk-Washington, DC 20555
,1
Subject:
- LaSalle County Nuclear Station Units 1 and 2 Response to Notice of Violation
- Inspection Report Nos. 50-373/91015; 50-374/91015 NRC Doiet Nos. 50-373 and 50-374
Reference:
W.D. Shafer letter to Cordell Reed dated September 19,1991 transmitting NRC Inspection C
Report 50-373/91015; 50-374/91015 Enclosed is Commonwealth Edison Company's (CECO) response to the subject Notee of Violation (NOV) which was transmitted with the referenced letter and L inspection Roport. The NOV c!!ed two Severity Level IV violations. The first violation
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- concerned the use of an inadequate procedure during testing. The secor d violation was regarding the failure to properly report an event. CECO s response is provided in the following attachment.
If your staff has any questions or comments concerning this
'~ olease roter them to Annette Denenberg, Compliance Engineer at (708) 515-7 Very truly yours,
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T.J. Kovach Nuclear Licensing Manager Attachment c
cc:
A.' Bert Davis, NRC Regional Administrator - Rlli B. Siegel, Project Manager - NRR T. Tongue, Senior Resident inspector f
9110290052 911o18 ADOCK0300$3
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s RESPONSE TO LEVEL IV VIOLATIONS INSPECTION REPORT 50-373/91015;50-374/91015 ATTACHMENT A VIOLATION: (50-373/91015-01) 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed and accomplished by documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Contrary to the above, on July 30,1991, the test procedure for the Unit 1 reactor core isolation cooling (RCIC) system was inappropriate to the circumstances in that the arocedure did not require shutting the discharge valve to the lubricating oil cooler and 3arometric condenser to prevent draining the pump dischargo line upon shutdown and did not provide for venting the pump discharge line upon restart.
REASON FOR THE VIOLATION:
On July 31,1991 at 1655 hours0.0192 days <br />0.46 hours <br />0.00274 weeks <br />6.297275e-4 months <br />, Operating and Tech Staff were performing special proceduie LLP-91-083, " Reactor Core Isolation Cooling (RCIC) System Start in Conditions 1,2, and 3". This procedure was being performed to roubleshoot the RCIC
. system in response to a u y 29,1991 overspeed inp that occurred during the system Jl cold quick start.
During the portion of the procedure where RCIC had been runnir.g and was subsequently shutdown, t was determined that a procedure stop to close 1E51-F046, RCIC Lube Oil Cooler Stop, was not included in the procedure.
In preparing this special procedure, the step to close 1E51 F046 was inadvertently omitted. Had the step been properly incorporated, the Lube Oil Cooler Stop (1 E51-F046) would have been closed at the appropriate point in the evolution and there would have been no need to loclude a requirement to fill and vent the RCIC system.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED:
s The RCIC Lube Oil Cooler Stop 1E51-F046, was closed and, as a conservative measure prior to resta-ting the system, the fill and vent procedure was performed.
Execution of the procedure was continued following a conference between the Nuclear Station O aerator and the Station Control Room Engineer. Appropriate notations were made to tie LLP-91-083 procedure package documenting justification for continuing the evolution.
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s CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOt.ATK)NS:
LLP-91-083, " Reactor Core isolation Cooling (RCIC) System Start in Conditions 1,2, and 3", was a s:>ecial px,cedure which was specifically written to duplicate certain plant -
conditions that had occurred previously, it was written as a " single use" procedure and -
was not used again after July 31,1991. The special procedure formally expired on -
August 31,1991.
LaSalle is currently performing a study to ascertain the effectiveness of the methods used during the preparation and approval of special tests and special procedures.
Completion of the study is expected by February 29,1992.
in order to natify aporoarlate personnel of tho details of this event, General Information Notice GIN 91-74 was ssued informing the appropriate departments of the situation and increasing their awareness during Special Procedure and/or Test preparation and review. Completion of this GIN is expected by December 11,1091-.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved upon identification and correction of the condition caused by the procedural deficiency, 4
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>O RESPONSE TO LEVEL IV VIOLATIONS i-INSPECTION REPORT I
50-373/91015;50-374/91015 i
ATTACHMENT A VIOLATION: (50-374/91015-02) 10 CFR 50.72 (b)(2)(ill)(c) requires the licensee to notify the NRC as soon as practical and in all cases, within four hours of the occurrence of any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to control the release of radioactir material.
Contrary to the above, on March 21,1991, notification of the NRC was not made within four houts when LaSalle Unit 2 experienced an unplanned breech of containment resulting in the loss of control over the release of radioactive material.
REASON FOR THE VIOLATION:
The cause of the failure to re aort this event in a timely manner was due to a cognitive error by personnel responsib e for event classification. They clearly recognized that, had the duration of the event exceeded one hour, it would have been reportable as a violation of the Technical Specifications. Because the duration was less than one hour, it was believed the event was not reportable. The need to report the event as a condition that could have prevented the fulfillment of a safety function was not properly assessed.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED:
Once the failuie to notify and report was brought to the attention of the station, the issue was reviewed and discussed. LaSalle Station concluded that this event required notification under 10CFR50.72 and is reportable as an LER in accordance with 10CFR50.73. An ENS notification was made at 1010 hours0.0117 days <br />0.281 hours <br />0.00167 weeks <br />3.84305e-4 months <br /> on July 3,1991 and a LER was submitted on July 26,1991.
CORRECllVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS:
The Operating Department was tailgated to emphasize the need to closely review the reporting requirements for loss of a safety function even if Technical Specification LCO's are met. Regulatory Assurance personnel who review classifications were also tailgated on these requirements. Additionally, LaSalle Emergency Procedure LZP-1310-1, " Notifications", was revised on July 24,1991 to include more specific examplet of notification requirements for events including those affecting primary containment integrity. This revision reorganized the procedure to help facilitate proper identlilcation of reporting requirements.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was attained on July 26,1991 upon submission of the LER.
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