ML20147F091

Responds to NRC Re Violations Noted in Insp Repts 50-373/87-35 & 50-374/87-34.Corrective Actions:Procedure LOS-RI-Q3 Revised to Separate Slow & Quick Start Evolutions Into Two Separate Procedures

ML20147F091
Person / Time
Site:	LaSalle
Issue date:	02/22/1988
From:	Butterfield L COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
4209K, NUDOCS 8803070233
Download: ML20147F091 (4)

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.(j) Address Reply to: Poet0767 CNeago,liknois60690 Of5ce Box 757

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February 22, 1988 Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Comunission Region'III 799 Roosevelt Road Glen Ellyn, IL- 60137-

Subject:

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

50-373/87035 and 50-374/87034 NRC Docket Nos. 50-373 and 50-374 Reference (a): W.L. Forney letter to Cordell Reed dated January 26, 1988.

Dear Mr. Davis:

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

M. Jordan and R. Kopriva on December 1, 1987 through January 6, 1988, of '

certain activities at LaSalle County Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. The Ceaumonwealth Edison Company's response to the Level IV Notice of Violation with two examples, is provided in the Attachment.

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

Very truly yours, l -

. k L.D.Butterfielk Nuclear Licensing Manager im Attachment cc: NRC Resident Inspector - LSCS o\

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IR 374/87034-01 (AIR 374-100-87-03401)-

-IR'373/87035-08 (AIR 373-100-87-03508) y VIOLATION:

i- Technical specification 6.2.A requires that detailed written

. procedures including applicable' checkoff lists shall be prepared, approved .

and adhered to for the following:

-1. The epplicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulaatory Guide 1.S3' includes surveillance and testing procedures.

2. Emergency conditions involving potential or actual release of

-radioactivity "Generating Station Emergency Plan" and station emergency and abnormal procedure?.

10 CFR 50.72, b.2.iii D, "Four Hour Reports," requires the licensee r to notify the NRC within four hours of.tne occurrence of "Any event or condition.that alone could have prevented the fulfillment of the safety function of structures or system that are needed to .... mitigate the consequences of'an accident."

Emergency Procedure LZP-1310-1, "Notifications," step F.2.b.3)c),

states, in part, "Non emergency events Four Hour Reports .... any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to .... (4) mitigate the consequences of an accident".

Surveillance Procedure LOS-RI-93, "Reactor Core Isolation Cooling (RCIC) System Pump Operability and Velve Inservice Tests," step F.11.b, states, "Open both RCIC full flow test return to CST valves 2E51-F022 and 2E51-F059".-

Contrary to the above, the licensee failed to follow a surveillar.ce procedure and an emergency procedure in the following instances.

A. On December 1, 1987, during the testing of the RCIC turbine and system, the operator failed to open the RCIC full flow test return to CST valve 2E51-F022 per the procedure LOS-RI-Q3. This resulted in a RCIC turbine trip on overspeed while performing the test.

B. On December 16, 1987, the RCIC keep fill pump seized up causing the RCIC system to bow ingerable. This is a non-emergency reportable event with a four hour notification to the NRC.- The licensee did not report the event in accordance with Emergency Procedure LZP-1310-1 within four hours. The event was not reported until approximately 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> after its occurrence.

. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (374/87034-01)

The individuals involved in this event were interviewed. It was determined through the interviews that the procedure was difficult to use because it provided guidelines for both the quick start of RCIC and the slow start. The procedure also had several steps that required the operator to open multiple valves simultaneously. -These factors resulted in the Operator and Station Control Room Engineer (SCRE) attempting to determine a better way of performing the required test.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION

1) LOS-RI-Q3 is being revised. (AIR 373-251-88-00020) The revision will  :

separate the slow and the quick start evolutions into two separate procedures. The steps involving multiple valve manipulations are being re-written to eliminate identified problems.

2) All station first line supervisors will be counseled regarding their responsibility for enforcing procedural adherence. This will be accomplished prior to March 14, 1988, via a station prepared audio presentation. l DATE OF FULL COMPLIANCE March 14, 1988 L

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mePitCTIVE ACTION TAKEN AND RESULTS ACHIEVED (373/87035-08)

The individuals involved with this incident were interviewed. The results of the discussicn indicated that the notification requirements were overlooked by everyone involved. The unit was going from Hot shutdown to Cold '

shutdown when the failure occurred. The Main Condenser was being used for the heat sink and the condensate / Condensate Booster System was the source for maintaining reactor vessel water inventory.

CORRBCTIVE ACTION TAKEN TO AVOID FURTHER VIO!ATION

1. All personnel involved have been interviewed and instructed on the proper notification frequency.

2. The Station control Room Engineer copies of the Unit 1 and 2 Technical Specifications have been clearly .aarked, in the RCIC Specification to identify the notification requirements.

DATE OF FULL COMPLTANCE Full compliance has been achieved.

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