ML20116B301
| ML20116B301 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/19/1985 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| 0001K, 1K, NUDOCS 8504250203 | |
| Download: ML20116B301 (10) | |
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Dcs Commonwealth Edison I
one First National Plazi, Chicago, Illinois Address Reply to: Post Office Box 767 Chicago. tilinois 60690 April 19, 1985 James M. Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
LaSalle County Station Units 1 and 2 Proposed Imposition of Civil Penalty NRC Docket Nos. 50-373 and 50-374 References (a):
J. G. Keppler letter to J. J. O'Connor dated March 21, 1985.
(b):
1.E. Inspection Report Nos. 50-373/84-28 and 50-374/84-36.
Dear Mr. Taylor:
In response to the letter of Reference (a) and in accordance with the requirements of 10 CFR 2.205, Commonwealth Edison hereby provides a remittance in the amount of $25,000 for the civil penalty imposed in connection with circumstances surrounding the inoperative Standby Gas Treatment Systems at LaSalle County Station. Our response to the NRC's Inspection Report regarding this incident is attached.
Commonwealth Edison is also concerned about reducing personnel errors and improving Control Room operations at LaSalle County Station. We have taken prompt and extensive corrective action to accomplish these improvements as described in the enclosure. Control Room operations and personnel errors have been the subject of increased scrutiny by NRC Region III personnel at LaSalle County Station throughout 1984.
Inspectors have provided positive feedback recently as to the apparent effectiveness of these corrective actions. We will continue our efforts in these areas and executive management will monitor the progress.
It should be noted that while the alleged event did occur, it in no way compromised the ability of the Standby Gas Treatment (SBGT) System to perform its design function. The "A" SBGT train was fully capable of satisfying its design function at the reduced flow rate observed during this event. The "B" SBGT train was also available with Operator action to remove the control switch in PTL; Station management is confident that the operator would have responded correctly had the SBGT system been needed to mitigate the consequences of an accident.
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J. M. Taylor April 19, 1985
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To the best of my knowledge end belief the statements contained
.herein and in.the attachment are true and correct. In some respects these
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statements artinot based on my personal knowledge but upon information furnished by other Commonwealth Edison employees. -Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
>3, Please address any questions regarding this matter to this office.
p Very truly yours, Cordell Reed Vice President im cc: Resident Inspector - LaSalle
~J. G. Keppler
_ Region III Attachment
~.1 SLESCRIBED and SWORN to before me,this t Q +/ day of /2b4_ L
,, 1985
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Notary Public
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ATTACHENT -
s CO N LTH EDISON COWANY
. RESPONSE-TO NOTICE OF VIOLATION
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W C DOCKET NOS. 50-373-and 50-374 A.
Noncompliance Technical Specification 3.6.5.3 requires two independent stancby gas treatment-subsystems to be operable in operational conditions 1, 2 and
'3.
Action statement a. states that with one standby gas treatment subsystem inoperable, restore' the inoperable subsystem to OPERA 8LE status within 7 days, or be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.=
3 Contrary to the above, the "A" Standby Gas Treatment (S8GT) train was inoperable from October 16 to October 30, 1984, in violation of the 7 day limiting condition for operation with Unit 2 in operational condition 1.
Three of seven doors on the S8GT train were not closed properly, which resulted in the system not being able to meet the minimum air flow requirements for operability as established by
' Technical Specification 4.5.5.3.b.3.
A'dmission or Denial of Alleged Violation-j.
iCommonwealth Edison admits to the alleged violation. Although it could not be_ conclusively _ determined when the "A" S8GT train became inoperable, the most probable cause would have rendered the train inoperable in-excess of the seven day limiting condition for operation.
. Reason for the Violation l'
i.
. This violation was the. result of inadequate post maintenance test
, requirements to demonstrate operability of "A" S8GT train upon return to L
services.
Corrective Action Taken and the Results Achieved Upon identification of the low flow condition, the."A" S8GT train was
~immediately returned to operable status by adjustment of the flow controller. Subsequently, upon discovery of the inadequately secured access doors, the doors were properly secured and the flow controller was returned to its original setting.
' Other immediate actions included inspection of the "B" SBGT train to -
l ensure that the. access doors were properly secured and conduct of the
- operability surveillance for both trains immediately following completion of surveillance activities in progress (LES-PC-2, " Groups 2 and 4 Isolation Actuation Logic System Functional Test").
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2-1 Corrective Action-Taken to Avoid Further Noncompliance The Operating Engineer _specified a post maintenance test for the work in question. However, the. test specified was to check for proper differen-
.tial pressure indication and did not verify SBGT system operability..
The Operating Engineer believed that closing the S8GT train access doors-upon completion of work was craft capability and he ascertained that the work would have no' impact on system operability if the access doors were
-properly closed.
A
'In order. to preclude this type of-problem in the future, LaSalle Station will require that a test be conducted to demonstrate operability anytime-a safety-related s'ystem is returned to service. A Post Maintenance
' Operational Test Checklist has been developed to ensure that the post maintenance' test specified adequately demonstrates system operability in light of the. work _actually performed. Nuclear Station Division has directed that each CECO Nuclear Station review this checklist for
-applicability.
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In addition,Lthe station has implemented administrative controls for the
~S8GT trains and Control Room Ventilation System trains to ensure that
-the access doors are properly closed following any entry. These controls include installation of lockwires, pointed arrows on the access
~ doors to indicate the proper position of the door handles, and posting
~ f signs on each train requiring notification of the Shift Engineer L
o prior-to opening the access doors. Nuclear Stations Division has directed that each CECO Nuclear Station review these controls for applicability.
Date of Full Compliance Full compliance has been achieved.
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- 2 z e-B.: Noncompliance Technical ~ Specification 6.2.A.1 requires that detailed written procedures be prepared, approved and adhered to. This includes the applicable procedures recommended in Appendix "A" of Regulatory Guide l.33, Revision 2, February 1978. Applicable procedures include those governing the activities associated with the Standby Gas Treatment System.
Activities associated with the "A" S8GT train conducted during the period October 16-30, 1984 were not accomplished according to documented procedures as indicated by the examples set out below:
1.
Procedure LAP-1600-2, " Conduct of Operations", Paragraph F.1.z states, " Operations personnel shall be attentive to the conditicns.
of the plant at all times. They must be alert to ensure that the e
_ plant is operating safely and take action to prevent any progress toward a condition that might be unsafe."
Contrary to the above, on October 30, 1984, the center desk control room operator was aware of the low flow condition in the "A" S8GT, but did not inform operations management or take any other actions to correct the low flow.
I 2.
Procedure LAP-200-3, Revision 9, " Shift Change", Paragraph 6.d.2 requires that the Nuclear Station Operator (NS0) " inspect his unit control room panels, and particularly annunciator panels-with the off-going NSO,_ verifying important operating parameters, especially those relating to safety systems."
Contrary to the above, on October 30, 1984, during a shift change, the NSO did not adequately check or inspect the low flow recorder indication of the "A" SBGT train, a safety system, to verify important operating parameters, although the recorder was reading in the abnormal area.
3.
Procedure LAP-220-3, Revision 6, " center desk operator's Log",
Section F.2.g states', "The log will include a-descriptive.
chronology for the main events of the shift and their time in the sequence of occurrence, such as: Starting and stopping of major Common Plant equipment."
Contrary to the above, on October 30, 1984, the center desk operator failed to log either of the main events of stopping the i
B" S8GT train by placing it in the Pull-to-Look position or the starting of the "A" S8GT train.
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Admission or Denial of Alleged Violations Commonwealth Edison admits to the alleged violations.
1.
Reason for the Violations A review of this event indicated that the Center Desk Nuclear Station Operator (CONS 0) was alert and attentive to control room instrumentation and that he did identify the low flow condition.
However, he failed to recognize the significance of the low flow condition and therefore did not take appropriate corrective action.
Corrective-Action Taken and the Results Achieved Tallgates were conducted on the specifics of this event as subsequent shifts reported for duty prior to allowing assumption of W11ft responsibility.
Corrective Action-to Avoid Further Noncompliance Due to the similarity of this event to previous events, it was
' determined that extraordinary corrective action was required to improve performance. To this end, a consultant behavioral scientist was contracted to conduct diagnostic sessions with operating personnel in order to facilitate their identification of barriers to improved performance and methods of removing the barriers.
Additionally, a human factors review of this event was performed by representatives from the corporate office and a consultant with expertise in this area. This review resulted in improvements to LaSalle Procedure LES-PC-02, " Groups 2 and 4 Isolation Actuation Logic System Functional Test" and initiated a modification to change the low flow alarm setpoint to 3600 SCFM.
Station Superintendent tailgates were also conducted with operating personnel that strongly emphasized station management's expectations in all areas found deficient in this event.
Date of Full Compliance Full compliance has been achieved.
2.
Reason for the Violation Shift turnovers at LaSalle Station include a comprehensive review of plant status and are generally rated very good by outside observers (i.e., corporate overview and INP0). This problem occurred because the CDNSO failed to walkdown the SBGT panel due to test activity in progress at the panel during turnover. Otherwise, a detailed review of the CDNSO turnover activities found Ulem adequate.
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- - Corrective Action-Taken and Results Achieved
~Not applicable.
Corrective Action Taken to Avoid Further Noncompliance Bypassing the SBGT panel during turnover, although understandable, was a violation of LaSalle Procedure LAP-200-3, " Shift Change", and is unacceptable. The Station Superintendent has conducted tailgates with operating personnel to emphasize the importance of thorough panel walkdowns and a&erence to procedures. In addition, a review of LaSalle Procedure LAP-200-3, " Shift Change", identified some areas that were in need of clarification. The necessary procedural clarifications have been completed.
Date of Full Compliance Full compliance has been achieved.
'_3._
RysUn for the Violation
. The CONSO failed to satisfy the logging requirements of LaSalle Administrative Procedure LAP-220-3, " Center Desk Operator's Log".
Corrective Action Taken and the Results Achieved Not applicable.
Corrective Action Taken to Avoid Further Noncompliance The importance of proper log entries and rigorous aterence to procedures was stressed in Superintendent tailgates with operating personnel. 'In addition, the logging procedures are being revised to provide additional clarity as to logging requirements.
.It~should be noted that CDNSO did make log entries with regard to
. starting and stopping the S8GT trains, although they did not satisfy the' literal. requirements of LAP-220-3, " Center Desk Operator's Log".
The CDNSO also recorded the SBGT flow on the Shiftly Surveillance sheets for his shift.
The oncoming CDNSO also made log entries with regard to starting and stopping the S8GT trains but did not specifically log the fact
=that the "B" S8GT train was in Pull-to-Lock (PTL) at the beginning of his shift. He also did not log the low flow condition on "A" S8GT train..Both of these logging deficiencies can be attributed to the fact that he bypassed the SBGT panel in his panel walkdowns.
In reality, these deficiencies resulted from an inadequate turnover-and are the subject of a separate item.
~Date of Full Compliance Full compliance has been achieved.
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,. C.
Noncompliance 10 CFR Part 50, Appendix B, Criterion V, as implemented by the licensee's Quality. Assurance (QA) Topical Report (CE-1-A), requires that activities affecting quality be accomplished in accordance with documented procedures.
i
- QA Manual Procedure QP No. 3-52, " Design Control for Operations-Plant Maintenance", states under definition for routine maintenance, in part,
... work, if not performed correctly, that could have impact on safety or plant reliability, shall not be designed as routine."
Contrary to the above, the work request for the "A" SBGT train mainten-
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ance of October 15-16, 1984, work that could have impact on safety or plant reliability, was incorrectly designed as " routine"; consequently there were no detailed installation instructions or cautions on how to
-properly return the system to service.
Admission or Denial of Alleged Violation Commonwealth Edison admits the alleged violation. It is believed that the problem was caused by inadequate post maintenance test requirements and lack of administrative controls rather than inadequate work instruc-tions. The designation of this work as " routine" had little impact on
-the content of the work instructions.
-Reason for the Violation This problem was caused by inadequate post maintenance testing and lack of administrative controls to ensure that the S8GT train access doors
'were properly secured upon completion of work rather than inadequate work instructions.
Corrective Action-Taken and the Results Achieved Not applicable.
Corrective Action Taken to Avoid Further Noncompliance Corrective actions described in conjuction with Item A adequately address this problem.
Date of Full Compliance Full compliance has been achieved.
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.... D.
Noncompliance 10.CFR 50.72(b)(2)(iii) requires that the licensee notify the NRC Operations Center within four hours 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 radioactive material.
~ Contrary to the above, on October 30, 1984, the licensee was aware that one Stan&y Gas Treatment train was inoperable due to low flow and that the other train was inoperable due to the fan switch being in a pull-to-lock position; thus, the S8GT system could not fulfill the safety function of controlling the release of radioactive material, but the licensee did not report this condition to the NRC until 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> later.
Admission or Denial of Alleged-Violation Commonwealth Edison admits that the NRC Operations Center was not notified within four hours of the event's occurrence as required by 10 CFR 50.72(b)(2)(lii).
The initial investigation focused on the circumstances leading to the inoperability of the "A" S8GT train and therefore did not identify the
. fact that both S8GT trains had been concurrently inoperable. This fact
-was not identified until November 2, 1984, during a subsequent investi-
-gation. The NRC Operations Center was notified via the Emergency
. Notifica-tion System (ENS) phone within one hour of identification.
Reason for the Violation The information necessary to conclude that both S8GT trains had been inoperable on October 30, 1984, did not come to management's attention until November 2,1984, due to the fact that the personnel involved in
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'this event did not consider the "B" S8GT train inoperable with its control switch in Pull-to-Lock (PTL).
Corrective Action Taken and Results Achieved The NRC Operations Center was notified that both SBGT trains had been inoperable on October 30, 1984, via the Emergency Notification system
-(ENS)= phone within one hour of identification.
Corrective Action Taken to Avoid Further Noncompliance
. Nuclear Stations Division Directive, NSDD-A09, " Conduct of Operations",
and LaSalle Administrative Procedure, LAP-1600-2, " Conduct of Operations",
have been revised to clearly indicate that PTL shall be considered
= inoperable.
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w-Due to antiguities associated with interpreting portions of 10 CFR 50.72,
-a meeting was held with NRC Region III management on November 28, 1984, at' the request of the licensee, to clarify reporting requirements.
1Information obtained at this meeting has been incorporated in Station reporting guidelines.
Date of Full Compliance Full compliance has been achieved.
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