ML20138G753

Responds to NRC Re Violations Noted in Insp Repts 50-373/96-10 & 50-374/96-10.Corrective Actions:Procedure Changes Will Be Issued for Following Affected DG Procedures to Add Caution Statement Directing Use of LTP-500-1

ML20138G753
Person / Time
Site:	LaSalle
Issue date:	12/26/1996
From:	Subalusky W COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9701020243
Download: ML20138G753 (4)

Text

. _ .. - _ -

O>mmonw calth 1.dm m Comjuny 12$alle Generating Station

- } 2601 North 21st Road  !

Marseilles. II. 6I .4 s 1-9757 Tcl HI 5 .45Ni?61 ,

i December 26,1996 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

NRC Inspection Report No. 50-373/96010;

) 50 374/96010 (DRP) and Notice Of Violation

Reference:

J. L. Caldwell Letter to W. T. Subalusky, dated November 26,1996, Transmitting NRC Inspection Report 373/374-96010 The enclosed attachment contains LaSalle County Station's response to the 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 these violations.

1 If there are any questions or comments conceming this letter, please refer d

them to me at (815) 357-6761, extension 3600.

Respectfully, CQ s

k. W. T.' Subalusky

, Site Vice President LaSalle County Station Enclosure cc: A. B. Beach, NRC Region 111 Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle

,10033 a DCD - Licensing (Hardcopy: Electronic: )

Central File 9701020243 961226 PDR ADOCK 05000373 G PDR r Unicom company

l

\

ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT

! 373/374-96010 i

VIOLATION: 373/374-96010-01 10 CFR 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type i appropriate to the ci:cumstances and shall be accomplished with these instructions, ,

procedures, or drawings.  !

LaSalle Technical Procedure (LTP)-500-1, " Diesel Generator Output Breaker  !

4 Troubleshooting Procedure," Revision 6, stated, in part, that the purpose of the procedure is to determine the failure mode in the event that a diesel generator (DG) output breaker fails to close during its monthly operability surveillance.

Contrary to the above, on August 14,1996, the output breaker for the "O" DG failed, but

, LTP-500-1 was not used to troubleshoot and determine the failure mechanism.

4 This is a Severity Level IV Violation (Supplement 1). j REASON FOR VIOLATION: 373/374-96010-01 l l Procedure LTP-500-1 was not used to troubleshoot the "0" Diesel Generator output breaker to Unit 1 as required. The cause of the violation was human performance error in that personnel did not follow station procedures. Electrical Maintenance and System l Engineering personnel were not aware of Procedure LTP-500-1. Procedure i LOS DG-M1 called out troubleshooting procedure LTP-500-1 but this was not j adequately communicated to personnel conducting the troubleshooting. The human performance error resulted from less than adequate communications between the Operating Department and the troubleshooting personnel.

4 Procedure LTP-500-1, " Diesel Generator Output Breaker Troubleshooting Procedure",

Revision 6, states:

"The purpose of this procedure is to determine the failure mode in the event that a diesel generator output breaker fails to close during its monthly operability surveillance."

4 r

1

c .

s -

4 ATTACHMENT RESPONSE TO NOTICE OF VIOLATION j NRC INSPECTION REPORT

! 373/374-96010 4

Procedure LOS-DG-M1, "O Diesel Generator Operability Test", Revision 31, was in -

progress at the time of the breaker failure. Limitation D.17 of this procedure states: <

i  !

j "I,f Output Breaker fails to close on first attempt, do NOT make any further attempts.  :

.DG must be allowed to continua to run at 900 RPM with the voltage regulator in AUTO.

]

System Engineer and Electrical Maintenance must be immediately contacted to 4

' troubleshoot per LTP-500-1." On August 14,1996, (at approximately 20:52) during the

performance of LOS-DG-M1,"O Diesel Generator Operability Test", a problem was

discovered when the "0" DG output breaker to Unit 1 (ACB 1413) would not close remotely from the control room while attempting to parallel the DG to Bus 141Y.

! Breaker maintenance had been completed per LES-GM-103A, "4.16KV & 6.9KV l.T.E.

Breaker and TSC Switch Operational Test", and the performance of LOS-DG-M1 was j the final action required to declare the "0" DG operable. At this point the "0" DG was approximately halfway into the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> timeclock for restoring the DG or commencing

[ shutdown of the Unit 1 reactor.

! A visual inspection of the breaker was performed, but no obvious problems were noted.

Electrical Maintenance and System Engineering were called to troubleshoot the breaker. The assigned DG System Engineer was unavailable, so the Auxiliary Power t (AP) System E'1gineer was called to provide support in troubleshooting the breaker, j

The initial troubleshooting efforts consisted of taking voltage readings across contacts

in the breaker closing circuit to try to identify the failed component. These actions were I the same as those specified in LTP-500-1, but the Electrician and System Engineer i

performing the troubleshooting did not follow Procedure LTP-500-1 because they were not aware of the procedure nor of Limitation D.17 in LOS-DG-M1 requiring the use

! Procedure LTP-500-1. In addition, Operations personnel did not initially direct these personnel to use procedure LTP-500-1.

i Some time later, after troubleshooting had begun, the System Engineer was made

! aware of the requirement to use Procedure LTP-500-1. He reviewed Procedure LTP 500-1 and determined that the actions already taken or planned were the same as

! those specified in the procedure. However, the procedure steps were not signed off as being performed. The initial troubleshooting actions failed to locate the failed components, so a Work Request was generated to troubleshoot and repair the breaker. ,

! This failure to follow the procedure vlas a human performance error.  !

A contributing factor to this event was that Procedure LOS-DG-M1 contains a statement

! in the Limitations Section to troubleshoot the diesel generator output breaker per j LTP 5001 if the breaker fails to close; however, it would be more effective to include i this statement immediately preceding the step to close the breaker. Previous revisions of this procedure contained this statement within the step that directs closure of the i breaker, but the statement was moved to the Limitations Section during the most recent revision to the procedure.

[

./

• ATTACHMENT  !

RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-96010 CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:

The System Engineer who was called in to investigate the "0" Diesel Generator Output  !

Breaker problem has been made aware of the specific troubleshooting procedure on .

Diesel Generator Output Breakers. Subsequent to this event, on October 14,1996, the Station held a work standdown. During this time, management communicated expectations for procedural awareness and adherence.

l CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS:

l Procedure changes will be issued for the following affected diesel generator procedures ,

to add a caution statement directing the use of procedure LTP-500-1 for {

troubleshooting the diesel generator output breaker immediately preceding the step (s) d

! to close the breaker: LOP-DG-02, Diesel Generator Startup and Operation; LOS-DG-M1, O Diesel Generator Operability Test; LOS-DG-M2,1 A(2A) Diesel

, Generator Operability Test; LOS-DG-M3,1B(2B) Diesel Generator Operability Test.

These procedures will be revised by January 31,1997.

System Engineers will be trained on procedure LTP-500-1, which is specifically written to troubleshoot Diesel Generator output breaker problems. This training will be  !

completed by March 26,1997. d 4

Instrument Maintenance personnel have had annual retraining on troubleshooting.

4 Electrical and Mechanical Maintenance personnel will have troubleshooting training in 1997.

l DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 1

Full compliance was achieved when management reinforced procedural adherence expectations during the October 14,1996, Station work standdown.

i 1 i

(

3

.