ML20133E691

Responds to NRC Re Violations Noted in Insp Repts 50-373/96-16 & 50-374/96-16.Corrective Actions:Pif Was Promptly Generated & Valve Assemblies Were Declared Inoperable

ML20133E691
Person / Time
Site:	LaSalle
Issue date:	01/08/1997
From:	Subalusky W COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9701130113
Download: ML20133E691 (5)

Text

, 0)mmonot etti! f& vin Company

, 12$alle Generating Station

, 26fil Nortti 21st Road Marseilles !!. 613 i19757 Tcl H I 435~%'61 1

1 January 8,1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

NRC INSPECTION REPORT 50-373/96016(DRP);

50-374/96016(DRP) AND NOTICE OF VIOLATION l

Reference:

J. L. Caldwell letter to W. T. Subalusky, dated December 9,1996, Transmitting NRC Inspection Report 373/374-96016 l

The enclosed attachment contains LaSalle County Station's response to the Notice of Violation, that was transmitted in the Reference letter.  !

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 Enclosure cc: A. B. Beach, NRC Region 111 Administrator h

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M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle DCD - Licensing (Hardcopy: Electronic: )

Central File 9701130113 970108 PDR G

ADOCK 05000373 PDR A rn.com compan3

ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-96016 VIOLATION: 373/374-96016-02 10 CFR 50, Appendix B, Criterion V states, in part, that activities affecting quality shall be prescribed by documented instructions and shall be i

accomplished in accordance with these instructions.

a. LAP-1500-8A, " Initiating A Problem Identification Form,"

Revision 0, Attachment B, Paragraph 4 states, in part, that a material which fails to meet drawing or written specifications or a material with faulty manufacturing warrants the initiation of a PlF.

b. LAP-220-5, " Equipment Operability Determination," Revision 3, Paragraphs 2.a,2.b,2.c, and 2.d state, in part: that if any on-  !

site personnel know of a possible operability issue then they must notify the Shift Engineer (SE) and promptly forward any documentation; that the SE shall review the information and i ensure that a PIF is initiated; and that the SE shall make a determination of the issue's effect on SSC operability and  ;

document such determination on the PlF. l Contrary to the above,

a. On March 17,1996, licensee staff performed bench tests and determined that air operated valve (AOV) actuators in the Reactor Core Isolation Cooling System (RCIC) and Primary Containment Isolation System (PCIS) did not exhibit the preloaded spring closing forces specified in their written specifications when adjusted using the vendor's procedures, but no PIF was generated.

b. On April 1 and 2,1996, instructions were issued to rebuild RCIC and PCIS AOV actuators to bring them into compliance with their written specifications. Other PCIS AOVs were known to be equipped with similar actuators. Despite the acknowledgment of a non conformance, documentation of the identified need for corrective actions was not forwarded to the SE; no PlF was generated; and no documented operability determination was made for the effected SSCs.

This is a Severity Level IV Violation (Supplement I).

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ATTACHMENT l

.' RESPONSE TO NOTICE OF VIOLATION 1 NRC INSPECTION REPORT 373/374-96016 REASON FOR VIOLATION 37?/374-96016-02 l LaSalle County Station acknowledges that in March 1996, personnel failed l

to document the non-conformance and perform an operability determination '

l as required by plant procedures. The failure to prepare formal documentation of the non-conformance issue in accordance with LAP- 1500-8A, initiating A Problem Identification Form (PIF), and operability determination LAP 220-5, Equipment Operability Determination, was a human performance error. As an organization there were multiple opportunities to comply with Station procedures to document a non-conforming condition and conduct an operability determination. The component engineer was the first line of defense and carried the majority of

, the responsibility to act in accordance with Station procedures. He was too focused on resolving the pneumatic actuator concems within the outage time constraints and did not initiate a PIF. Additionally, the engineer's

understanding of the Operability Determination Procedure, LAP-220-5 was deficient. The engineer discussed the problem with other Engineering,

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Outage Organization and Operating personnel. Specifically, the safety related function of the valves was discussed with these other personnel.

The conclusion was that the valves were acceptable based upon satisfactory results of local leak rate testing and inservice test stroke timing, and no further action was taken. None of the personnel contacted by the component engineer including Engineering supervisors, Outage supervisors and licensed operators, questioned whether a PlF had been submitted or if an operability determination was in progress. All of these personnel were insensitive to the problem identification and reporting process.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:

On September 28,1996, preliminary calculations indicated that some of the pneumatic primary containment isolation valves (PCIS) potentially would not close under design conditions. A PIF was promptly generated and the valve assemblies were declared inoperable. Licensee Event Report (LER) 373-96-011-01 was completed November 26,1996, documenting the safety consequences. Based on the subsequent analysis performed, LaSalle County Station concluded that the valves had sufficient margin to perform their design basis function.

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, .. ATTACHMENT

, RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-96016 The Engineering Department in the past has been negligent in submitting Problem identification Forms upon identifying discrepancies. The Station's threshold for PIF submittal has been lowered along with increased senior Engineering supervision reinforcement. The Engineering staff has received specialized training regarding procedures LAP-1500-8A and LAP-220-5.

These training seminars included " Regulatory Fundamentals" (Safety and Operability Evaluations), in addition to discussing the recent industry events related to Generic Letter 91-18.

Subsequent to this event, on October 14,1996, the Station held a work standdown. During this time, management communicated expectations .

stressing procedural awareness and adherence as well as the need to place I

operational safety over production. PIF generation within the Engineering department, as well as the entire station, has increased significantly since l the March,1996, time frame, indicating a greater sensitivity level to '

document the non-conformance issues.

CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS:

Station managers will continue to raise the standards and expectations for LaSallo Station to emohasize the importance of operational safety. These standards and expectations will be reinforced through consistent communication, training, and monitoring to ensure procedure compliance.

To provide reasonable assurance that any other non-conformance issues that may not have been properly documented, before the recent increased emphasis on problem identification are identified and resolved, specific actions are being required before either unit will be restarted. These actions include:

System Functional Performance and Design Reviews of selected safety related systems and systems important to safety will be conducted. It is expected that non-conformance issues will be identified during these reviews. Issues important to safe plant operation will be resolved before restart.

. A review of open and new PIFs and related corrective actions to ensure that issues important to safe plant operation are resolved prior to restart.

e A review of open and new root cause investigations to ensure that issues important to safe plant operation are resolved before restart.

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. ATTACHMENT

, RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-96016

. A review of open and new Engineering Requests (ER) to ensure that issue important to safe plant operation are resolved prior to restart.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was achieved on September 28,1996, upon documenting the non-conformance issue in accordance with station procedures.

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