ML20132E805

Discusses Insp Repts 50-373/85-23 & 50-374/85-19 on 850610- 0724 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $125,000

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: ML20132E805 ML20132E851
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 ')I

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 ,

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 ,

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 '

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 t

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

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. I

Division III of the ECCS was removed from service in March 1985 for normal r

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

PDR ADOCK 05000373 '

G PDR

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. Commonwealth Edison Company 2 September 27, 1985

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pumps would not have initiated as required on a low-low-low reactor vessel

I 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

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

j 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

, cited in the enclosed Notice. On April 17, 1985, while performing monthly

! 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

Unit 2 ECCS problem, even though the trip system "A" for ADS initiation was

i wired correctly and would have been able to initiate if required.

'

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

i alarm and isolation switches was installed backwards. A verification walkdown

l failed to identify this improper installation. This installation resulted in

! these switches being inoperable during power operation,'and a Technical

Specification Limiting Condition for Operation was exceeded. Although there

i 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

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, 3 September 27, 1985

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 4 September 27, 1985

The responses directed by this letter.and the enclosed Notice are not subject 3

to the clearance procedures of the Office of Management and Budget as required

by'the Paperwork Reduction Act of 1980, PL 96-511.

'

Sincerely,

,.

'

Orlainal sic:ed by

d::c5 G. I'.cppler (;

-James G. Keppler '( ,'

Regional Administrator

^

' Enclosures:

1. Notice of Violation '

and Proposed Imposition '

,

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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. Commonwealth Edison Company 5 September 27, 1985

Distribution

PDR

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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

DCS

Resident Inspector, RIII

Phyllis Dunton, Attorney

General's Office Environmental

Control' Division

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