ML20199E748
| ML20199E748 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/29/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1716K, NUDOCS 8606240044 | |
| Download: ML20199E748 (8) | |
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[h Commonwealth Edison V{ 7 Address Reply to: Post Office Box 767
) One First National Plaza. Chicaoo. Ilunois Chicago lilinois 60690 May 29, 1986 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.
50-373/86-007 and 50-374/86-008 NRC Docket Nos. 50-373 and 50-374 Reference (a):
C. E. Norelius letter to Cordell Reed dated April 28, 1986.
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Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs.
M. Jordan, J. Bjorgen, R. Kopriva, S. Stasek, A. Morrongiello and Ms. E. Hare of your office conducted February 13 through March 12, 1986, of activities at LaSalle County Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. The Commonwealth Edison Company's response to the Notice of Violation is provided in the enclosure.
LaSalle Station recognizes the concern over recognition of inoperable systems. This issue has been widely discussed among management and supervisory personnel, as well as among licensed operators. A new station procedure was issued on March 7,1986 which includes guidance to assist shift personnel in evaluating operability questions. We believe that the guidance provided in this procedure is adequate to ensure that shift personnel can evaluate operability or identify the need for promptly obtaining additional assistance.
l In addition a task force has been established to further develop criteria for determining when equipment is either operable or inoperable.
This task force will analyze one technical specification system thoroughly.
This is expected to lead to a more refined set of generic criteria which can be applied by shift personnel to determine system operability when faced with component failure within a system.
MAY 3 01986 8606240044 860529 PDR ADOCK 05000373 G
PDR i
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Mr. J. G. Keppler May 29, 1986 An extension of one day for the submittal of this response was granted per telecon with W. G. Guldemond of your staff on May 28, 1986.
If you have any further questions on this matter, please direct them to this office.
Very tr y yours, D. L. Farrar Director of Nuclear Licensing Im Attachment cc: NRC Resident Inspector - LSCS 1716K l
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ATTACHIENT
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NOTICE OF VIOLATION (IR 374/86008-01) 1.
Technical Specification 6.2.A requires detailed written procedures including applicable checkoff lists covering various operations of the facility to be prepared, approved and adhered to:
(a) ' Item 6.2.A.1 requires the applicable procedures recommended in Appendix A of Regulatory guide 1.33, Revision 2, February 1978.
Section 4 of this guide requires procedures for startup, opiration, and shutdown of safety related BWR systems including the Reactor Water Cleanup System.
(b) Item 6.2.A.6 requires procedures for preventive and corrective maintenance operations which could have an effect on the operation of the facility.
10 CFR 50 Appendix B Criterion V states that activities affecting quality shall be. prescribed by... procedures...of a type appropriate to the circumstances...
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Contrary to the above, on March 2, 1986, the licensee failed to adhere to procedure, LGP-RT-05, for the Unit 2 Reactor Water-Cleanup System which caused the system to isolate.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED After the isolation was completed, the manual valves were returned to the correct positi.on and the isolation signal reset.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION As a result of this event, the operators involved were counseled on the importance of ensuring proper configuration. In this event because of operational problems experienced, the operator should have realized the relevance of the NOTE in the procedure.
In addition the procedures for operating the Reactor Water Clean Up System have been revised to identify i
critical steps requiring local verification. Also, the remote mechanical indicators have been repaired. It is anticipated that, after a period of time to demonstrate the reliability of the mechanical indicators, the requirement for local observation will be deleted."
During the time frame of the investigation of th'is event, another apparent example of failure to follow instructions occurred, which also caused an ESF actuation. In this instance a nuclear station operator was assigned responsibility for clearing an outage on Unit 1 containment i
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l 2-pressure switches. This outage had been reviewed by a Shift Foreman who had provided written instructions on the sequence of operations necessary to avoid spurious actuations. The NSO made a diligent effort to review the affected drawings, but overlooked a relay contact. Because of this error he felt that the specified sequence of operations was unnecessary, and did not direct the Equipment Attendant in the proper sequence of operations.
In this event the NSO was counseled on the need for attention to detail when reviewing drawings.
In addition, the importance of notifying his supervisors prior to deviating from instructions was emphasized.
These lessons learned were identified to all licensed operators via the License Requalification reading program.
DATE OF FULL COMPLIANCE Full compliance has been achieved.
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. NOTICE OF VIOLATION (IR 373/86007-03) 1.
Technical Specification 6.2.A requires detailed written procedures including applicable checkoff lists covering various operations of the facility to be prepared, approved and adhered to:
(a) Item 6.2.A.1 requires the applicable procedures recommended in Appendix A of Regulatory guide 1.33, Revision 2, February 1978.
Section 4 cf this guide requires procedures for startup, operation, and shutdown of safety related BWR systems including the Reactor Water Cleanup System.
(b) Item 6.2.A.6 requires procedures for preventive and corrective maintenance operations which could have an effect on the operation of the facility.
10 CFR 50 Appendix B Criterion V states that activities affecting quality shall be prescribed by... procedures...of a type appropriate to the circumstances....
Contrary to the above, the licensee's corrective maintenance procedure for replacing the Unit 1 Standby Liquid control System explosive valves was inappropriate in that it failed to assure the system piping was properly filled and vented which resulted in the unnecessary fast start of the "lB" Emergency Diesel Generator on February 26, 1986.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The affected diesel generator was secured and returned to standby.
Sensing lines which could have been subjected to a hydraulic transient were inspected; no damage was found.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION The root cause of this event was a misunderstanding by personnel reviewing the maintenance procedure. The operating procedure entitled
" Filling, Venting and Draining the Standby Liquid Control System" was not written to fill the piping on the reactor side of the explosive valves. The maintenance procedure directed the fill of the system per the operating procedure without noting that this would not fill one section of piping, personnel involved in reviewing the maintenance procedure were counseled on the need for attention to detail. The maintenance procedure, LMP-SC-01, is i
being revised to clarify the filling and venting instructions. The
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operating procedure, LOP-SC-01 is being revised to include instruction on how to fill the injection line.
. DATE OF FULL COMPLIANCE Pull Compliance will be achieved when the above mentioned procedure changes are completed. This will be by September 30, 1986, prior to the next anticipated usage.
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' NOTICE OF VIOLATION (IR 373/86007-04) 2.
Technical Specification 4.4.4.C requires the reactor coolant conductivity to be determined at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with the i
continuous conductivity monitor inoperable when not in operational Conditions 1, 2, or 3.
Contrary to the above, the 24 hcur sample was missed for Unit 1 on February 18, 1986, when the continuous conductivity monitor was inoperable.
CORRECTIVE ACTION TAPEN AND RESULTS ACHIEVED (a) Reactor coolant samples have been obtained and analyzed for conductivity within the specified sample frequency since 1400 on February 19, 1986.
(b) The Laboratory Foreman was reprimanded, upon his return to the Station, on March 3, 1986.
(c) The Shift Foreman was counseled upon his return to the Station Purch 5,1986.
(d) Tailgate on this event were held with the Operating Department on April 24, 1986 and Radiation Chemistry Department on March 11, 1986.
(e) This event was discussed at a March 5, 1986, meeting with all Station Department Heads.
I CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION:
(a) The Radiation Chemistry Technicians will be retrained to understand the sampling requirements of the Technical Specifications and the proper completion of the Attachments to LAP-1800-4, " Rad Chem surveillance." This training will be completed by June 6, 1986.
(b) The Radiation Protection Foremen have been retrained to understand the sampling requirements of the Technical Specifications and the requirements for review of the Attachments to LAP-1800-4. The radiation protection Foremen have initiated review of these attachments (sampling requirements) shiftly.
(c) Chemistry Management has been retrained to understand the sampling requirements of the Technical Specifications, verify that they have j
been met and provide a detailed turnover of non-routine sampling requirements to the offshift radiation protection Foreman should unusual conditions exist.
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. (d)
LOP-RT-03, " Reactor Water Cleanup System (RWCU) - Shutdown," was revised to include a note to inform the Radiation Chemistry Department when the Reactor Water Cleanup System is shutdown.
(e)
LOS-AA-DI, " Daily Surveillance," was revised to accurately indicate that the surveillance for an inoperable continuous conductivity monitor is applicable at all times.
(f)
LAP-1800-4, " Rad Chem Surveillance," has been revised to accurately indicate that the surveillance for an inoperable continuous conductivity nonitor is applicable at all times.
(g) Monday through Friday when chemists are on-site a chemist will review the surveillance schedule daily along with the Laboratory Foreman.
(h) LAP-1800-6, " Rad Chem Foreman Shift turnover" has been revised to require the Rad Chem Shift Foreman to review the Technical Specification sample sheet in the laboratory area on a shiftly basis.
DATE OF FULL COMPLIANCE Full compliance will be completed June 6, 1986.
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