ML20128D379
| ML20128D379 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/02/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9302100128 | |
| Download: ML20128D379 (5) | |
Text
m Commonwealth Edison 1<
1400 Opus Plics -.
j -
1
. Downers Grove, Illinois 60515 -
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i February 2, 1993-4 i
U.S. Nuclear Regulatory Commission 4
j Washington, DC-20555-Attention:-Document-Control Desk-
Subject:
LaSalle. County Nuclear Power Station Units 1-and 2-Reply-to Notice of Violations 50-374/92028 Inspectton Report'Nos.-50-373/92028:
NRC Docket-Nos. 50-373'and.50-374-l
=;
Reference:
H. B. Clayton letter to L. De1 George: dated lanuary 5, 1993:
. transmitting NRC Inspection Report 50-373/92028; 50-374/92028
-Enclosed is the Commonwealth Edison Company (CEC'o) response to~the-Notice of Violations (NOVs) which were transmitted with the'-referenced inspection report.
The violation concerns inadequate work instructions _.
If your staff has:any. questions or' comments concerning-this letter,.
please refer them to Sara Reece-Koenig, Compliance: Engineer at (708)- 515-7250.:
r Sin'cerely,1 D.'Farrar: 4 Nuclear' Regulatory Services. Manager-Attachment cc: ;A.B.: Davis,: Regional Administrator --Region _III
,B.,Stansky, Project Manager, NRR-D;' Hills.--Senior Resident Inspector ZNLD/2490/1
-080008 a
c9302100128 930202 I
PDR :ADOCK 05000373
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4-s ATTACHMENT REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/92028; 374/92028 i
VIOLATION: 374/92028-02 10 CFR 50, Appendix B, Section V requires, in part, that activities affecting quality shall be prescribed by documented. instructions of a-type appropriate to the circumstances.
Contrary to the above, during February 1992, the work package (HR L13363) to reassemble the low pressure core injection "A" full flow test valve (2E12-F024A) did not include instructions to ensure the gear box was full of grease as required by laSalle Maintenance Procedure (LMP)-GM-37, Lim 1 orque Operator Maintenance (SMB-3), step F.33.3.
This is a Severity Level IV violation (Supplement 1).
REASON FOR THE VIOLATION:
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Commonwealth Edison acknowledges the violation, which relates to the Low Pressure Coolant Injection (LPCI) "A" Full Flow Test-Valve (2E12-F024A).
The Notice of Violation misidentifies LMP-GM-37,-Limitorque Operator Maintenance (SMB-3), Step F.33.3 as-the step which does not include F
instructions to ensure the gear box is full of grease, the correct step is F.32.1.
LMP-GM-37 was developed with the assumption that filling the actuator with grease and verifying the amount of grease put in _the actuator, was within craft capability.
The individuals who performed the actuator rebuilds 4
were trained on LaSalle's Limitorque procedures.
The training did not i
include methodologies for putting grease in the horizontally mounted actuators or verifying an appropriate amount of grease had been added.
The following conditions contributed to the failure of-the_ actuator:
High dose rates at the valve and time pressure ~to get the job.done, i
required that a.large number of_. individuals work on the actuator.
The numerous turnovers between work crews and management supervision, resulted in inadequate communication.
Work package-instructions allowed the option to reuse the old grease er use:new grease.
Allowing reuse.of the old grease was based on_ the actuator having been refurbished approximately one week earlier. Using the old grease causedithe worker to deviate from the normal methods for putting grease in the actuator, resulting in the grease accumulating on-top of the worm gear.
ZNLD/2490/2
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d ATTACHMENT REPLY TO NOTICE Of VIOLATION NRC INSPECTION REPORT 373/92028; 374/92028 VIOLATION: 374/92028-02 4
10 CFR 50, Appendix B, Section V requires, in part, that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances.
Contrary to the above, during February 1992, the work package (HR L13363) to reassemble the low pressure core injection "A" full flow test valve (2E12-F024A) did not include instructions-to ensure the_ gear box was full of grease as required by LaSalle Maintenance Procedure.
(LMP)-GM-37, limitorque Operator Maintenance (SMB-3), step F.33,3.-
This is a Severity Level IV violation (Supplement 1).
4 REASON FOR THE VIOLATION:
f Commonwealth Edison acknowledges the violation.-which relates to the Low Pressure. Coolant Injection (LPC.U "A" Full Flow. Test Valve-(2E12-F024A).
The Notice of Violation misidentifies LMP-GM-37, Limitorque Operator Maintenance (SMB-3), Step F.33.3 as the step.which does not include instructions to ensure the gear box--is full of grease, the correct step is F.32.1.
LMP-GM-37 was developed with the assumption that-filling the actuator with grease and verifying the amount of grease put in the: actuator, was within craft capability. The individuals who performed the actuator rebuilds-were trained -by-the-M@alac-insal mPOWeEtttt;to"*aining on LaSalle's Limitorque procedures; The-training did not: include methodologies for putting-grease in the horizontally mounted actuators or verifying an appropriate amount of grease had been added.
The following conditions contributed to the failure of the actuator:
High dose rates at the valve and time pressure-to get the job'done, required _that a large number of. individuals work-on the actuator; The-numerous-turnovers between work crews and management superv.ision, resulted in inadequate communication.
Work package instructions allowed the option.to: reuse ~the old grease or use new grease. Allowing reuse of the old grease was based on-the actuator having been refurbished approximately one week ear _ lier.
Using the old grease caused the worker.to_ deviate from_the normal methods for-putting grease in the actuator, resulting.in.the grease accumulating on top of the worm gear.
ZNLD/2490/2
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ATTACHMENT REPLY TO NOTICE OF VIOLATION
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NRC INSPECTION REPORT 373/92028; 374/92028 REASON FOR THE VIOLATION: (continued)
There were no instructions available to the workers regarding the_use of old grease and the method for putting the grease into the actuator.
After the work started, the decision was made, to use new grease.
This information was not conveyed to the individual performing the work.
The quantity of new grease used and disposal of the old grease resulted in the inability-to determine the amount of grease in the actuator.
The Inspection Report description states that a' contributing factor was that the workers were rushed to meet a four hour LCO with the valve operator disassembled.
There was no 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />'LC0 related to this job because the unit'was in a: refuelling outags.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED:
The actuator for valve 2E12-F024A was disassembled, inspected, reassembled-and properly repacked with grease.
Valve 2E12-F024A'was satisfactorily tested in accordance with Station procedures.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS:
All horizontally mounted actuators.which were refurbished during Unit 2's fourth refueling outage-were inspected and verified to be properly lubricated.
The crews involved-in Limitorque actuator-rebuilds in the Unit 1 refuel 4
outage, which was in progress during this event, were trained on this event'to ensure that a similar problem would not occur on the Unit _1 valve rebuilds.
The following procedures are being revised to provide acceptable methodologies.to insert grease-into the actuators and to verify.
lubrication levels'are adequate:
LMP-GH-32, Lim 1 torque Operator Maintenance (SMB-000).
LMP-GM-33,-Limitorque Operator Maintenance (SMB-00).
LMP-GH-34, Limitorque Operator Maintenance (SMB-0).-
LMP-GM-35, Limitorque Operator Maintenance (SMB-1).-
LMP-GM-36, Limitorque Operator Maintenance (SMB-2).
LMP-GM-37,.Limitorque Operator Maintenance (SMB-3).
LMP-GM ?8, Limitorque Operator Maintenance._(SMB-4).
LMP-GM-42, Limitorque Operator Maintenance (SMB-4T).
LMP-GM-54', Limitorque Operator Maintenance (SB-0)'.
LMP-GM-55, Limitorque Operator Maintenance (SB-3).
LMP-GM-56, Limitorque Operator Maintenance (SB-00).
LMP-GM-57, Limitorque Operator Maintenance (SMC-2).
LMS-GM-01, limitorque Grease Inspection and Lubrication Application.
a ATTACHMENT REPLY TO NOTICE Of VIOLATION-NRC INSPECTION REPORT 373/92028; 374/92028 CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS: (continued)
A General Information Notification (GIN) will'be distributed-to appropriate station personnel.
The GIN will discuss this event and-emphasize the need for effective-communication on jobs with unusual conditions.
The lesson plans for the training of personnel _who perform work on Limitorque actuators will be evaluated to determine the need to incorporate the methodology for installing. grease in horizontally mounted motor operated valves.
Distribution and review of the GIN is expected to be completed by March 25, 1993.
Evaluation of training lesson plans is expected to be completed by August 1, 1993.
Revisions to the Limitorque maintenance procedures-is expected to be completed by August 1, 1993.
DATE HHEN FULL COMPLIANCE MILL BE ACHIEVED:
LaSalle Station was in full compliance upon satisfactory completion of the valve test in accordance with station-procedures.
4 ZNLD/2490/4
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