ML20141M507
| ML20141M507 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/27/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9208310320 | |
| Download: ML20141M507 (8) | |
Text
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Commonwsaltr' Edison E
1400 Opus Place l
v' Downers Grove, Illinois 60515 1
August 27,1992 1
1 U.S. Nuclear Regult. tory Commission Washington, DC 20555 Attention: Document Control Desk 4
Subject:
LaSalle County Nuclear F,wer Station Units 1 and 2 Peply to Notice of Violation Inspection Report Nos. 50-373/92013; 50-374/92013 NRC Docket Nos. 50-373 and 50-374 i
Reference:
B. Clayton letter to Cordell Read dated Ju.y 29,1992 transmitting NRC Inspection Report 50-373/92013; 50-374/92013 Enclosed is the Commonwealth Edison Company (CECO) resr anse to the Notice of Violation (NOV) which was transmitted with the reference letter and Inspection Report.
The NOV concemed a lack of plant worker emphasis on fire protection program implementation. CECO's response is provided in the attachment.
If your staff has any questions or comments concerning this letter, please refer them to Jim Watson, Compliance Engineer at (708) 515-7205.
Sincerely,
((. /kw/dv u
l T.J. Kovach Nuclear Licensing Manager
)_
Attachment cc:
A.B. Davis, Regional Administrator - Region lil B.L. Siegel, Pro'ect Manager, NRR D. Hills, Senior hesident inspector 4
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RESPONSE TO NOTICE OF VIOLATION j
NRC INSPECTION REPORT 50-373/92013;50-374/92013 s
VIOLATION;(IR 373(374)/92013-01)
Technical Specification 6.2.A.11, requires, in part, that detailed written procedures shall be prepared, approved, and adhered to for fire protection program implementation.
i LaSalle Administrative Procedure (LAP) 900-18,"Use of Lumber and Other Combustibles in the Plant," Revision 7, requires, in part, the followi.1g:
Step F.1 - Prior to moving combustible material that will be left unattended in the plant from normal storane areas, the responsible person shall obtain af, proval from the fire marshall by comp'eting LAP-f 900-18, Attachment Transient Combustible Permit.
Step F.5 - Excess combustible materials are to be removed following completion of the activity in safety related areas.
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Step F.7 - Combustible materials such as air filters shall not be stored l
in the plant except as allowed by the fire marshall.
Step F.8 - Wh 2n combustible materials are moved into an area and l
the quantity ex. ds the allowable limits, compensatory measures will be taken, as ;;t the fire marshall.
Contrary to the above:
A.
As of March 16,1992, approximately 200 bags of trash,
[
exceeding the allowable limits had accumulated in the dry active waste storage area located in fire zone 5B4 and the required j
compensatory measure set by the fire me.rshall had not been taken.
B.
Combustible materials were left unattended in the plant without obtaining a transient combustible permit in the following cases:
June 24,1992, a large pile of electrical cables in fire zone S94 i
June 23,1992, a 55 gallon drum of grease (approximately 1/2 full) in fire zone 311 (694' level o. the Unit 2 reactor l
building).
June 30,1992, one 30 gallon drum of waste oil l
(approximately 1/3 full) in fire area 1 (refueling floor).
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RESPONSE TO NOTICE OF VIOL ATION r
NRC INSPECTION REPORT l
50-373/92013;50-374/92013
(
)
July 1,1992, a 30 gallon drum of waste oil and a large l
quantity of air hoses in fire zone 5011 (710' level of the turbine building).
1 C.
As of June 26,1992, combustible materials consisting of approximately 60 large bags of used ventilation filters, were l
stored on the 815' level of the auxiliary building, a safety related area without an exception allowed by the fire marshall ant had not been removed following completion of the activity.
This is a Severity Level IV violation (Supplement I),
BEASON_EQELTHEVIOLATION; (Example A) i LaSaile County Station management acknowledges the violation. The cauce of this violation was an informal arrangement between fire protection i
supen'ision m' station laborer aemonnel concerning trash removal from ti e area and a lack of knov' Jge o" the admin!strative limits and necessarv compensatory measures for the area. LaSalle County Station had sei 4
administrative limits on the quantity of trash staged in this fire zono. The limits provided for an hourly fire watch when 75 trash bags had accumulated, and continuous fire watch at 125 bags, This area was designated for trash to be brought and held until it could be surveyed for removal from the Radiological Controlled Area (RCA). The Station Fire Marshal was notified by the NRC of the concern on the me ning of March 4
18,1992. The area was immediately verified to contain less than 125 bags l
at that time, but when re-checked that afternoon as a follow-up, the count exceeded 200 bags and a continuous watch had not been set. Prior to tho j
morning of March 18,'1992, the trash sorting (surveying) table had become disabled, and with the refuel outage ending, trash accumulated faster than anticipated. A!though the survey equipment repairs were started soon after l
the table became disabled, repairs were not completed until March 19, 1992. Station Security Personnel patrolled this zone hourly for both security-l and fire prevention purposes. This patrol had not been made aware of the administrative limits, only that it was in fact a designated trash staging area.
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RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-373/92013;50-374/92013-COBBEGIlVERIEES_ TEEN AND THE RESULTRACMEYEQ; A continuous fire watch was established in accordance with LAP 900-18 c.
the afternoon of March 18,1992, until bag count was reduced to less than 125 bags.
The trash sorting table repairs were completed and bag count was reduced to Mss than 125 bags by 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> on March 19,1992.
The trash staging area, formerly ene large area bounded by enclosure unitc, has been replaced with 6 lidded, steel bins. Maximum content of the 6 bins
- s 120 bags, with lids shut. This provides for easier com >llance with the administrative limits and a safer fire condition.
Security post order, LPO 105, was revised on July 16,1992, to formally establish and document an hourly fire watch for this trash area. This revision also delineates the administrative limits and necessary action. No trash is allowed outside of the bins and when the bins are full, the Station Fire Marshal or Shift Supervision will be notified that fire watch requirements must be evaluated. Also a sign has been placed in the trash aren giving equivalent instruction.
LAP-900-18, Fire Prevention for Transient Fire Loads, was revised July 23, 1992, to include the administrative limits, and document de!Iy checks of the area for compliance, Monday through Friday except Holidays, by the Station Laborer Supervisor, and weekly checks by the Station Fire Marshal.
Security and Station Laborer groups, workers and supervision, were trained on the requirements and expectations relating to trash and fire protection control for this area on July 161992 and July 17,1992, respectively. A follow-up expectations meeting with the Station Laborer group was conducted August 24,1992, by the Station Laborer Supervisor.
Thus far, the above ac;.cns have resulted in a cleaner, better controlled area.
CQBBECT1VE ACTIONS TAK_EN TO AVOID FURTHER VIOLATIONS; No further corrective steps remain to be taken.
DATE_WHEN EULLCRMP_LIANCE WILLBE ACHIEV_ED:
Full compliance was achieved March 18,1992, upon establishing the continuous fire watch.
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-RESPONSE TO NOTICE OF VK)LATION NRC INSPECTION REPORT 50-373/92013;50-374/92013
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BEASONf0fLTHEXIOLAIlON: (Example B)
LaSailo Courify Station management acknowledg9s the violation.
1 The electrical cables found in fire zone 5B4 were taken into the plant by an employee who was not adequately familiar with LAP 900-18, Fire Prevention for Transient Fire Loads, and did not realize that a permii was required as cables are considered a combustible mrterial.
The 55 gallon drum of grease was apparently left in the tendon tunnel prior to the requirement of nermits, and later removed from the tunnel. The j
individual could not be identified that may have moved it from the tenoon tunnel to the Unit 2 Reactor Building fire zone 311.
The 30 gallon drum of wat.!e oil on the refuel floor was empty when taken to the floor, and as such the work group thought that a permit was not required. This was a case of poor judgment since the intent was to collect t
oil in it which would then neec a permit.
The waste oil drum in fire zone 5C11 was being staged to take out of tFo RCA. It did have a pemet for the area in which it had been used. The physical relocation of the barrel without an accompanying transfer permit to i
another area created'an administrative trap with respect to the use of permits.
The hosec in fire zors SC11 were breathing air hoses and had been in the area prior to the use of the transient permit system. The affected i
department did not realize that hoses were considered a combustible material and needed a permit, These examples of the violation occurred due to poor training on the L
procedures relating to the handling of combustible materials.
i COBB.EClLVE STEPE_TEATE&YEREENTAKEMNDRESULTS ACHIEVED; L
The following corrective actions were taken to address the above examples i
of the violation, in part or in total.
In each case, the item was promptly removed from the plant or a permit was Issued.
LAP-900-18, " Fire Prevention for Transient Fire Loads", was revised on July 23; 1992, to give better guidance to the work groups. The procedure now allows for staging materials in a designated location, while they await survey prior to being removed from the RCA. The procedure also now includes periodic plant inspections by the Station Fire Marshal.
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RESPONSE TO NOTlCE OF VIOLATION NRC INSPECTION REPORT 50-373/92013;50-0/4/92013 The Station Fire Marshal has conducted tailgates with all major work groups impacted by the Fire Protection procedures and reviewed the procedures in the meetings.
The major work aroups affected = y the Fire Protection procedures usage have o
also received a General Information Notification (GIN) which summarizes the procedure changes.
LAP-900-15, " Station Housekeeping / Materiel Condition Program", was reviewed -
and determined to adequately address the fire protection issues that an inspector should consider. A memo was sent to all housekeeping inspectors to increase their sensitivity in this area, particularly to increase the comme i; cation to the Station Fire Marshal.
COBBEGILVfLSIEP_S THAT_WILLBE_TAKENIOROlD FURTHER VIOLKilONS; No further corrective steps remain to be taken.
DATE_WHENIULkCOMELI ANCE3 VILL BEACHIEVED; Full compliance was achieved by July 1,1992, when the last item in these examples was identified and removed or received a permit, as appropriate.
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1 RESPONSE TO NOTICE OF VIOLATION j
' NRC INSPECTION REPORT f 373/92013;50-374/92013 BEASON FOR THE_YLOLAllON: (Example C) l-LaSalle County Station management acknowledges the violation.
At the time of the event, new filters were taken into the area and had the l-proper permit. After installing the new filters, the permit was transferred to the used filters. The Station Laborer group was notified to remove the i
filters. The Station Laborer group had not been made aware of the filter change job arior to the start of work, and were unable to provide the 4
j necessary cisposal arrangements upon job completion. Subsequently, filter l-removal was then overlooked.
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This violation occurred due to a lack of participation by the Station Laborer group in the Station work planning meetings.
COBBEGIlVE STEPS THAT HAVEEEEN TAKENR4D_BESULTS ACHIEVED; The filters were removed from the area on June 26,1992, i
Effective August 24,1992, a Station Laborer group representative began -
regularly attending the Station work plannin0 meetings to provide input on the need for planning disposal arrangements as jobs are scheduled.
LAP-900-18, " Fire Prevention for Transient Fire Loads", was revised on July 23,1992, to give better guidance to the work groups. The procedure now -
allows for staging matenals in a designated location, while they await survey prior to being removed from the RCA. The procedure also now includes.
periodic plant inspections by the Station Fire Marshal and provides direction that the Station Fire Marshal will review the outstanding permits and disposition them es necessary.
The Station Fire Marshal has conducted tallgatas with all major work groups impacted by the Fire Protection procedures and reviewed the procedures in F
the meetings.
i The major work groups affected by the Fire Protection proceduros usage
-have also received a General Information Notification (GIN) which -
y summarizes the procedure changes.
LAP-900-15, " Station Housekeeping / Materiel Condition Program", was-reviewed and determined to adequately address the fire protection issues j
- that an inspector should consider. A~ memo was sent to all housekeeping' Inspectors to increase their sensitivity in this area, particularly to increase the communication to the Station Fire Marshal.
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RESPONSE TO NOBCE OF VIOLATION NRO INSPECTION REPORT 4
50-373/92013;50-374/92013 COBBEDTIVE STEL S THAT WILL BE TAKEN TO AVOID FURTHEB YJOLAI!QNS;-
No further corrective steps remain to be taken.
DATE WHEN FUI,LCOMPLIANCE WILLEEACHIEVEDj Full compliance was achieved when the f;!ters were removed on June 26, 1992.
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