ML20132E805
| ML20132E805 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/27/1985 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Oconner J COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20132E810 | List: |
| References | |
| EA-85-095, EA-85-95, NUDOCS 8510010175 | |
| Download: ML20132E805 (5) | |
See also: IR 05000373/1985023
Text
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September 27, 1985
Docket Nos. 50-373 and 50-374
License Nos. NPF-11 and NPF-18
EA 85-95
Commonwealth Edison Company
ATTN: Mr. James J. O'Connor
President
Post Office Box 767
Chicago, IL 60690
Gentlemen:
Subject:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES
(NRC INSPECTION REPORT N05. 50-373/85023 and 50-374/85018)
This refers to the inspections conducted during the period June 10 - July 24,
1985 of activities authorized by NRC Operating License Nos. NPF-11 and NPF-18
for the LaSalle County Nuclear Power Station, Units 1 and 2.
The inspections
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were conducted after the NRC Resident Inspector was informed on June 10, 1985
that your staff identified that Unit 2 was without Emergency Core Cooling
capability for approximately five days and that the plant had been without
secondary containment integrity for approximately three days during this
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same period.
This matter was discussed on June 24, 1985 during an
Enforcement Conference held at the LaSalle County Nuclear Power Station
between Mr. 8. L. Thomas and other members of your staff and myself and other
members of the NRC staff.
Item I described in the enclosed Notice of Violation and Proposed Imposition
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of Civil Penalty involves loss of the automatic initiation capability of the
Emergency Core Cooling System (ECCS) in response to a low-low-low reactor
vessel water level signal between June 5-10, 1985 while Unit 2 was in cold
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shutdown.
The violation resulted from the failure of your staff to ensure
that modifications performed on safety-related systems were adequately
controlled so that system operability was not jeopardized.
In addition, from
3:30 a.m. on June 5 until 5:30 p.m. on June 8, 1985, secondary containment was
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neither established nor maintained as required by the Technical Specifications
when Emergency Core Cooling capability is lost.
The circumstances leading to
the violations are described below.
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Division III of the ECCS was removed from service in March 1985 for normal
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maintenance.
Between April and June 1985, due to inadequate controls in the
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design, inspection, and testing areas, the piping to two reactor vessel water
level actuation switches in Division I of the Unit 2 Emergency Core Cooling
System (ECCS) was installed backwards and, as a result, the Division I ECCS
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
,
0510010175 050927
ADOCK 05000373
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Commonwealth Edison Company
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September 27, 1985
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pumps would not have initiated as required on a low-low-low reactor vessel
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water level trip signal.
At 3:30 a.m. on June 5, 1985, while unaware that
Division I was inoperable, you removed Division II of the ECCS from service
Since'you had removed Division III from service in March 1985, the three ECCS
divisions were inoperable and automatic initiation capability of the ECCS in
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response to a low-low-low reactor vessel water level signal was lost until
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the problem was discovered and corrected on June 10, 1985.
The cause of this
event was the lack of adequate design document, inspection, and testing
controls in your modification program.
While we recognize that when these violations occurred LaSalle Unit 2 was in
cold shutdown, we consider this violation particularly significant because of
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its similarity to a violation identified in April and for which you were
cited in July and to several other recent events for which violations are
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cited in the enclosed Notice. On April 17, 1985, while performing monthly
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functional tests on LaSalle Unit 1, your staff determined that two switches
for the Unit 1 Automatic Depressurization System (ADS) were miswired, making
the trip system "B" for ADS initiation inoperable.
This matter was discussed
with you during a May 28, 1985 Enforcement Conference, and a Notice of Violation
was sent to you on July 18, 1985 for inadequacies in your design and test
controls (Reference NRC Inspection Reports 50-373/85017 and 50-374/85017).
The causes of the ADS problem were almost identical to the causes of the
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Unit 2 ECCS problem, even though the trip system "A" for ADS initiation was
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wired correctly and would have been able to initiate if required.
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Item II involves your discovery on July 17, 1985 that the piping to your
Unit 1 Regenerative Heat Removal (RHR) shutdown cooling pump high suction flow
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alarm and isolation switches was installed backwards.
A verification walkdown
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failed to identify this improper installation.
This installation resulted in
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these switches being inoperable during power operation,'and a Technical
Specification Limiting Condition for Operation was exceeded.
Although there
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are several redundant signals that may provide this same system isolation
function, this violation demonstrates other examples of the lack of adequate
design document and testing controls in your program.
Item III involves another instance where the piping to the two Unit 2 RHR
Shutdown Cooling pump suction high flow isolation switches was installed
backwards.
Your staff failed to recognize this improper installation during a
verification walkdown, but after a review of data associated with an alternate
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test, identified the problem with the installation of the lines to the
switches. Although we recognize the Technical Specification does not require
these switches to be operable in cold shutdown, this violation demonstrates
further design and testing failures'in your modification program.
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Commonwealth Edison Compary,
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September 27, 1985
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These violations also demonstrate a need for you to re examine your commitments
made to the NRC with regard to operability testing. On October 30, 1984, the
LaSalle plant failed to perform adequate tests on the Standby Gas Treatment
System (SBGT) after maintenance work was performed.
As a result, plant
personnel were not aware that the SBCT.was inoperable until the problem was
brought to their attention by the NRC"Residant Inspector.
That event resulted
in a recent $25,000 civil penalty.
In the April 19, 1985 response to this
civil penalty action, Commonwealth Edison Company stated, "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 system 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 work performed." The violations
cited in this Notice indicate that more effective controls must be implemented
to ensure that operability tests will be performed on safety-related systems
after maintenance or modification and before these systems are returned to
service.
To emphasize the need for you to ensure that modifications performed on safety-
related systems have adequate controls so that system operability is not
jeopardized, and to ensure that an effective program for performing operability
tests is implemented, I have been authorized, after consultation with the
Director, Office of Inspection and Enforcement, to issue the enclosed Notice
of Violation and Proposed Imposition of Civil Penalties in the cumulative amount
of One Hundred and Twenty-five Thousand Dollars ($125,000) for the violations
described in the enclosed Notice.
In accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C
(1985), the violations described in the enclosed Notice have been categorized
collectively as a Severity Level III problem.
The base civil penalty for a
Severity Level III problem is $50,000.
However, after considering the
escalation and mitigation factors in the Enforcement Policy, the base civil
penalty has been increased by 150 percent because of the multiple examples of
the particular violations and your prior poor performance in the area of concern.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
action you plan to prevent recurrence.
After reviewing your response to this
Notice, including your corrective actions, the NRC will determine whether
further NRC enforcement action is necessary to ensure compliance with NRC
regulatory requi'rements.
In accordance with 2.790 of the NRC's " Rules of Practice," Part 2, Title 10,
Code of Federal Regulations, a copy of this letter and its enclosure will be
placed in the HRC Public Document Room.
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. Commonwealth Edison Company
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September 27, 1985
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The responses directed by this letter.and the enclosed Notice are not subject
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to the clearance procedures of the Office of Management and Budget as required
by'the Paperwork Reduction Act of 1980, PL 96-511.
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Sincerely,
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Orlainal sic:ed by
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d::c5 G. I'.cppler
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-James G. Keppler
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Regional Administrator
^
' Enclosures:
1.
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and Proposed Imposition
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of Civil Penalties
2.
Inspection Reports
No. 50-373/85023(DRP)
No. 50-374/85018(DRP)
cc w/ enclosures:
D. L Farrar, Director
of Nuclear Licensing
G. J. Diederick, Station
Superintendent
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September 27, 1985
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Distribution
SECY
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CA
JMTaylor, IE
RVollmer, IE
JCollins, IE
JKeppler, RIII
. JAAxelrad, IE
ABBeach, IE
APuglise, RM
EJordan, IE
BGrimes,.IE
JPartlow, IE
JLieber: nan, ELD
Enforcement Coordinators
RI, RII, RIII, RIV, RV
FIngram, PA
- VStello,'DED/ROGR.
JCrooks, AE0D
SConnelly, 0IA
BHayes, OI
. HDenten, NRR
RStark, NRR
IE:ES File
IE:EA File-
EDO Rdg File
Resident Inspector, RIII
Phyllis Dunton, Attorney
General's Office Environmental
Control' Division
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