ML20097D268

Responds to NRC Re Violations Noted in Insp Rept 50-373/92-08 & 50-374/92-08.Corrective Actions:Operators Counseled Re Unsatisfactory Performance in Failing to Follow Procedures

ML20097D268
Person / Time
Site:	LaSalle
Issue date:	06/05/1992
From:	Kovach T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9206100042
Download: ML20097D268 (4)

Text

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s C:mm:nnealth Edisin

> 1400 Opus Place

. ,. O J Down:ta Grove, Illinois 60$15 U

June 5,1992 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk

Subject:

LaSalle County Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos. 50 373/92008; 50 374/92008 NB030cke1NoL50 313_and_50 3Z4

Reference:

B. Clayton letter to Cordell Reed dated May 6,1992 transmitting NRC Inspection Report 50-373/92008; 50-374/92003 Enclosed is the Commonwealth Edison Com 3any (CECO) response to the Notice of Violation (NOV) which was transmitted with she reference letter and inspection Report. The NOV cited one Severity Level IV violation related to procedural adherence de"iciencies. CECO acknowledges the violation and the NRC's concern of this violation due to its recurring nature. CECO's response is provided in Attachment A.

If your staff has any questions or comments concerning inis transmittal, please refer them to Jim Watson, Cor, (lance Engineer at (708) 515 7205.

Sincerely, Ad. L '&

T.J. Kovach Nuclear Licensing Manager Attachments cc: A.B. Davis, Regional Administrator - Region 111 B.L. Siegel, Pro ect Manager, NRR D. Hills, Senior Resident inspector I*n0004 9206100042 920605

.hDR ADOCK 05000373 #O PDR ZNLD/1845/1 / l' ,

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ATTACHMENT A RESECNSE_TO. NOTICE _OEVIOLATION NRC Inspection Report 50 373/92008;50 374/92008 VIOLATION (373/92008-018,01b, and 01c) i.aSalle Technical Specification 6.2.A.1 requires, in part, that detalled written procedures covering items in Regulatory Guide 1.33, Appendix A, Revision 2, be prepared, approvec , and adhered to. Regulatory Guide 1.33 lists proceuures for the control rod drive and liquid radioactive waste systems.

Contrary to the above, procedures for the control rod drive and liquid radioactl re waste systems were not adhered to in the following examples:

a. Non licensed operators did not leave open the accumulator waterside drain valves in accordance with LaSalle Operatin(I Proceduro LOP RD-10, " Control Charging," Revision 9, steps D.4 and F.10.b(, during accumulator precharging on February 10,1992, Rod Drive i

b. Non licensed operators did not verify that a hose was in place between the discharge and the chemical waste sump in accordance with LOP WF-29,

" Transfer of Floor Drain Concentrator Feed Tank 1 A to Chemical Waste System, " Revision 2, steps C.6 and F.1.a on February 16,1992.

c. Non licensed o >erators did not complete Attachment B,"CRD Accumulator Charging Chec dist "in accordance with LOS RD 10, "CRD System Accumulator Initial Charging," Revision 9, sie a F.26, or LOP RD 20, ' Control Rod Accumulator Recharging / Water Remova ," Ravlsion 1, step F.9, for the majority of accumulator a arm responses bE, tween January 1 through March 19,1992.

This is a Severity Level IV violation (Supplement I).

BEASOfiEORRIE_YlOLAllON:

Concerning the issue relative to LOP RD-10, steps D.4 and F.10.b, Commonwealth Edison acknowledges the violation. This event involved the failure -

to open the waterside drain valves during accumulator charging on 2/10/92.

Non licensed operators and a technical staff engineer were working on returning the CRD system to service follo, vin jor repairs on the system during a refuel

. outage. The operators were cha accumulators in a manner not part of the approved procedure. The techni taff engineer concurrently was testing the.

scram valves. As a result of thi operators not properly performing the charging procedure and a lack of specific communication between the technical staff engineer.and the o >erators, concerning the status of accumulator charging, a single rod was inac vertently scrammed.

ZNLD/1845/2 .j i

o ATTACHMENT A BESEONSE_IO.NOIlCEOF_Y)OLATION NRC Inspection Report 50 373/92008; 50 374/92008 (continued)

Conceming the issue relative to 1.OP WF 29, Commonwealth Edison acknowledges the violation. T*11s event involved not verifying that a transfer hose was properly installed in a sump during the transfer of the 1 A Floor Drain Concentrator Feed Tank. The operator believed, from previous information, that t the hose was in place and did not reverify its placement. However, this hose had been removed to accommodate cleaning of the floor and was not reinstalled. This cleaning had been accomplished between the previous visual observation of proper hose installation and the actual tank transfer.

Concerning the issue relative to LOP RD 20, Commonwealth Edison acknowledges the violation. This event involves not pro 3erly documenting on the Attachment B of this procedure the response to acct au ator trouble alarms. This lineup documentation required double verification of valving. Although original l valve position was documented, requirements for second verification which is i performed on the same document, caused some of the paperwork to become lost.

Commonwealth Edison considers these ovents concerning procedure adherence -

to be serioun situations and has taken ste's a to continually reinforce the imaortance of 3roperly adhering to 3rocedures with al operating personnel. Additiona'ly, due to lhe recurring events nvolving procedure adherence, upper station management has created a task force to seek resolution of this issue as well as procedure adequacy. The task force Initially consists of all station depa'iments with bargaining unit, first line supervisors, and senior station management representation.

I GOBBECRVE_SIEES_TAKEMANDlHEBESULISACHIEVED; Each event was thoroughly investigated by upper station management, in addition 1- to evaluating the facts of each event, the 3ersonal perforrnance history of each Individual was also reviewed. Based on 11e review, the following corrective actions were taken.

Concerning the issue relative to LOP RD 10, steps D.4 and F.10 b, the operators -

involved were counseled concerning their unsatisfactory performance in falling to follow the procedure. Also, the operators and technical staff engineer were apprised of the importance of clear concise communications.

l Concer.ning the issue relative to LOP-WF 29, the non-licensed operator involved was counseled and a letter placed in his file relative to this event. In addition, members of this crew made a presentation to all six crews concerning the need

! and importance of following procedures.

ZNLD/1845/1 -

l ATTACHMENT A BESEONSEIO_NOIlCE_OF_VKXA110N NRC Inspection Report 50 373/92008;50-374/92003 (continued)

Concerning the issue relative to LOP RD 20, a arocedure change was made to the annunciator response procedure LOA 1(2)H13 #603 A503, *CRD HYD ACCUM TROUBLE". This change directs the NSO to ensure that the proper attachment is filled out by the non licensed operator when responding to the accumulator alarms, in addition to the above actions directed at the specific events, a daily order was issued to operations regarding the need to 3roperly follow procedures. Also a meeting was held with upper station operat ng management and the shift engineers; at this meeting, the need for properly following station procedures was reinforced.

COBHECTIVE.SIERS_TAKEN_TO. AVOID _EURTHER_VKXATIONS:

The Station Manager is conducting meetings with station personnel which includes a discussion on procedure adequacy and the importance of properly adhering to procedures. This will be completed on September 1,1992.

Also, the shift engineers have stressed to their respective crews the imporiance of proaerly adhering to procedures and dist,ussed the results of the shift engineer ano upper station operating management meeting.

A task force has been created and will meet periodically throughout the SALP 11 period to review, propose, and implement >ossible solutions to the procedure adherence issue at LaSalle Station. The f rst formal meeting was held June 4, 1992.

DATE_WHEN EULLCOMELIANCE_WilABEACHIEVED:

Based on corrective steps taken and the results achieved, full compliance has been acnteved.

ZNLD/1845/2