ML20133D163

Responds to NRC Re Violations Noted in Insp Repts 50-373/85-19 & 50-374/85-21.Corrective Actions:Temporary Sys Change Installed to Defeat Isolation Signal.Rhr Sys Restarted

ML20133D163
Person / Time
Site:	LaSalle
Issue date:	09/10/1985
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
0589K, 589K, NUDOCS 8510080222
Download: ML20133D163 (4)

Text

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Commonwealth Eclison bMO

' One First N1tional P:aza. Chicago. Ilknois O Address Reply to: Post Office Box 767

,\. Chicago, Illinois 60690 a

September 10, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

LaSalle County Station Units 1 and 2 Response to Inspection Report Nos.

50-373/85-019 and 50-374/85-021 NRC Docket Nos. 50-373 and'50-374 Reference (a): N. Chrissotimos letter to Cordell Reed dated August 13, 1985.

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs.

M. Jordan, J. Bjorgen, R. Kopriva and P. Wohld on June 20 through July 24, 1985, of activities at LaSalle County Station. Reference (a) indicated that certain Gctivities appeared to be in noncompliance with NRC requirements.

' The Commonwealth Edison Company's response to the Notice of Violation is provided in the attachment.

If you have any further questions regarding this matter, please direct them to .this office.

Very truly yours, w#_ _

+ D. L. Farrar Director of Nuclear Licensing Im Attachment cc: NRC Resident Inspector - LSCS SEP 121985 0589K 8510000222 850910 PDR ADOCK 05000373 G PDR  ; g T}E O/ _ _

i ATTACHMENT RESPONSE TO NOTICE OF VIOLATION 4

i ITEM OF NONCOMPLIANCE

1. 10 CFR 50, Appendix B, Criterion XIV, as implemented by CECO's Quality Assurance Program, Quality Procedure No.14-51, requires, in part, that

measures be established to indicate the operating status of systems or i components to prevent inadvertent operation.

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! Contrary to the above, the inspector noted two examples of inadequate

! procedures causing inadvertent equipment or system operations:

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a. Due to a procedure (equipment outage) not specifying the installation of a jumper to remove the RHR system high suction flow isolation switches from service, the shutdown cooling portion of j the Unit 2 Residual Heat Removal System isolated on July 1,-1985.

) b. Due to a test procedure (LTS 300-10) failure to take all the 1

appropriate equipment out of service, the Unit 2 Reactor Building Closed Cooling Water and Primary Containment Ventilation Systems isolated on June 26, 1985.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED

a. A temporary System Change was initiated, reviewed, approved, and installed to defeat the isolation signal, which was not required while in cold shutdown. The residual heat removal system was restarted.

b. The testing continued ana was completed with the valves which

.! isolated remaining isolated. The isolation of these valves had no

! impact on the operation of the unit at the time of the event.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE

a. This event description has been included in the requalification

, training material for licaised operators, emphasizing the importance of thorough and complete outages on equipment.

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b. The surveillance procedure LTS-300-10 will be revised to prevent the isolation of these valves during the drywell pressurization required by this test. LTS-300-4 which also pressurizes the

, drywell will also be reviewed to determine if a similar change is

! required.

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e The. personnel which review and approve procedures are currently more sensitive of the concern over inadvertent operation of equipment.

DATE WHEN FULL C0hPLIANCE WILL BE ACHIEVED

! a. Full compliance will be achieved by November 6, 1985 when the i licensed operators will have completed their requalification j training regarding this event.

b. Full compliance will be achieved when the procedures are revised, as appropriate, which is currently scheduled for January 1, 1986 or prior to the next use of the procedures, whichever occurs first.

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ITEM OF NONCOMPLIANCE I

2. ' Technical Specification 6.2.A.3 requires written procedures to be

" prepared, approved, and adhered to ... for actions to be taken to correct specific and foreseen potential malfunctions of systems or components Contrary to the above the licensee failed to prepare and issue a procedure for shutting down one Control Rod Drive pump and starting '

4 another while operating the unit at full power which possibly could have j.

prevented a reactor scram on June 29, 1985.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED A new procedure, LOP-RD-03, has been written, approved, and issued to provide detailed instructions on how to shift Control Rod Drive pumps.

1 CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOW LIANCE

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This lack of procedure is believed to be an isolated occurrence.  :

DATE WW N FULL COW LIANCE-WILL BE ACHIEVED Full compliance has been achievea.

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