ML20129C788
| ML20129C788 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/17/1996 |
| From: | Subalusky W COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9610240117 | |
| Download: ML20129C788 (3) | |
Text
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Commonwealth litison Com[uny 1.asalic Generating $tation 26(11 North 2Ist Hoad Marseilles, IL 61311 >>757 3
Tel 815-357F61 j
October 17,1996 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
LaSalle County Station Units 1 and 2 Response to NRC to Notice of Violation
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Inspection Report Nos. 373/374-96006 NRC Docket Numbers 50-373 and 50-374
Reference:
J. L. Caldweil letter to Mr. W. T. Subalusky, dated September 17,1996, Transmitting NRC Inspection Report 373/374-96006 I
The enclosed attachment contains LaSalle County Station's response to the i
Notice of Violation, that was transmitted in the Reference letter. The attachment to this letter contains the immediate corrective actions taken as well as long term corrective actions to preclude recurrence of this violation.
If there are any questions or comments conceming this letter, please refer them to me at (815) 357-6761, extension 3600.
Respectfully, W. T. Subalusky Site Vice President LaSalle County Station i
Enclosure cc:
A. B. Beach, NRC Region lil Administrator (L/) () \\
M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle DCD - Licensing (Hardcopy:
Electronic:
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Central File 9610240117 961017 1
DR ADOCK 05000373 I
PDP A i'nwom compa,o
ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-96006
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VIOLATION: 373/374-96006-01 Title 10 to the Code of Federal Regulations, Part 50.59(b)(1), requires, in part, that licensees maintain records of changes in the facility "to the extent that these changes constitute changes in the facility as described in the safety analysis report." These records must include a written safety evaluation which provides the bases that the change does not involve an unreviewed safety question.
LaSalle Updated Final Safety Analysis Report Section 7.5.2.2.2.1, "Drywell Hydrogen and Oxygen Monitoring Subsystem," subsection Operational Considerations, Revision 5, stated, in part, "During normal operation, the system is maintained in a j
standby mode."
Contrary to the above, on June 13,1996, and routinely for more than a year prior to that date, the drywell hydrogen and oxygen monitoring systems for Units 1 and 2 were being operated in a continuous mode, not meintained in a standby mode, and a written safety evaluation to support this change in operation had not been performed.
This is a Severity Level IV Violation (Supolement I).
REASON FOR VIOLATION: 373/374 96006-01 The Drywell H2/02 Monitoring systerr provides the means to determine the weekly Technical Specification (TS) surveillance in accordance with TS 4.6.6.2, for the suppression chamber oxygen concentration. The Post-LOCA panels are the only practical instruments the station has for monitoring the oxygen concentration. H2/02 l
Monitors were operated continuously due to repeated weekly occurrences of being greater than the allowable oxygen concentration in the supprossion chamber of 4%,
during the weekly surveillance. During the period the monitors were operated in this fashion, the increasing oxygen level was detected and the appropriate corrective action was taken prior to exceeding the 4% limit. This was done at the direction of the Unit Operating Engineer via the Daily Orders to the Shift crew. This is an operator work-around that has not received adequate support for timely resolution.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
Some sources of oxygen have been identified. Efforts are underway in L2R07 and planned for L1R08 to eliminate some of these sources.
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sTTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-96006 System Engineering has performed an evaluation for the impact of continuous operation of the H2/02 system and has submitted a change to the UFSAR to allow continuous operation. System design has been evaluated and it was determined that it can be operated continuously.
4 The continuous use of the H2/02 Monitor by Operations was terminated. It is now operated weekly in performance of the required TS 4.6.6.2 surveillance and is retumed to the standby mode of operation following surveillance completion. Operation of the H2/02 Monitor is and will continue to be in accordance with LOP CM-02, "Startup, Operation and Shutdown of the Post LOCA Primary Containment Atmosphere Hydrogen and Oxygen Monitoring System." A temporary procedure change was issued that lowers the required reinerting level from 3.5% to 2.5% oxygen concentration. This lower setting provides added assurance that weekly monitoring results will be within the technical specification limit of 4%
The use of Daily Orders to convey system operations instructions in lieu of procedural guidance was also terminated. The function of the Daily Orders is to provide near-term direction to the crew on upcoming events and to share inforrnation. Daily orders are not intended to be used in lieu of procedures.
CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS:
System Engineering is pursuing an alternate system to continuously monitor oxygen concentrations in the drywell using a new O2 Monitor.
This new system for performing the required TS 4.6.6.2 surveillance will be installed on both units in conjunction with Unit 1 Refueling outage, L1R08, and Unit 2 Refueling outage, L2R07.
Should continuous operation of the H2/02 Monitor be necessary in the future, pump run time will be checked and additional maintenance performed, as needed, prior to continuous operation. This will be added as a prerequisite to LOP CM-02. This procedure will be revised by November 15,1996.
The Operating Engineers have been counseled on the purpose of the Daily Orders and have reviewed the Operation Department Memo. This action is complete. This review will be included in the nomial training cycle as a required annual review task, to be completed on October 15,1996.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full Compliance was achieved on June 14,1996, when the H2/02 monitor was returned to standby mode of operation.
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