ML20207E995
| ML20207E995 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/03/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20207E980 | List: |
| References | |
| 1836K, NUDOCS 8607220458 | |
| Download: ML20207E995 (6) | |
Text
, - - ~
j Commonwealth Edison
..f
__ 4 72 West Adams Street, Chicigo, Illinois l
\\
< Address Reply to: Post Office Box 767 w,/ Chicago, Illinois 60690 -0767 July 3, 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.
50-373/86015 and 50-374/86016 NRC Docket Nos. 50-373 and 50-374 Reference (a):
C. J. Paperiello letter to Cordell Reed dated June 6, 1966
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs.
R. Hasse, R. Lanksbury, S. Hare and M. Jordan conducted on April 14-21, 1986. The special inspection was a result of our report of personnel error involved in the hanging of an out-of-Service tag on Unit 1 High pressure Core Spray Suppression Pool Full Flow Test Valve. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company's response to the Level IV Notice of Violation is provided in the attachment. Each example is discussed as an individual event with detailed explanation to give some indication of the high concern we have in this area.
If you have any further questions on this matter, please direct them to this office.
Very tr y yours, Av p D. L. Farrar Director of Nuclear Licensing Im Attachment cc: NRC Residant Inspector - LSCS 1836K f
f OUL 8 1986 G
SCol
ATTAct9WNT VIOLATION:
IR 373/86015-01A (AIR 373-100-86-01501)
A.
Item 1.c of Appendix A to Regulatory Guide 1.33 identifies " Equipment control (e.g., locking and tagging)." Procedure LAP 900-4, Revision 24, entitled Equipment Out of Service Procedure, requires all necessary Out-of-Service Cards be placed on safety-related equipment removed from service in accordance with the Checklist.
Contary to the above, on March 19, 1986, the day shift EA hung the OOS card and de-enorgized a breaker that was not specified on the Temporary Lift Checklist.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Upon discovery, the OOS Card was rehung on the correct breaker and the mispositioned breaker was returned to the proper configuration.
CORRECTIVE ACTION TAKEN TO AVOID PURTHER VIOLATION The EA was counseled on the importance of double checking before operating equipment to prevent mistakes. A letter documenting this counseling was placed in the EA's personnel file, and the potential for advanced discipline in the future was discussed. The EA has a good work record and the lapse is believed to be an isolated event.
The labels for the individual MCC breakers have been remade to include the Unit designation.
The floor in the Unit 2 Switchgear room has been painted a tan color, to be consistent with other Unit 2 floors.
Training has been conducted on the importance of clearly communicating all aspects of a job, (expected breaker position, etc.) and the need to repeat back the instructions. This training was completed by June 5, 1986.
DATE OF PULL COMPLIANCE Pull compliance has been achieved.
)
. VIOLATION: IR 373/86015-01B (AIR 373-100-86-01502)
B.
Item 1.c of Appendix A to Regulatory Guide 1.33 identified procedures for Equipment Control (e.g., locking and tagging). Both Procedure LAP 1600-2, " Conduct of Operators Procedure," and LAP 900-4 require that a second independent verification shall be made when placing safety-related equipment into or out of service.
Contrary to the above, on March 19, 1986, a second verification of the 005 Card placement was not performed after placing the High Pressure Core Spray Suppression Pool Full Flow Test Valve motor operator breaker out of service, tw earrIyg ACTION TAKEN AND RESULTS ACHIEVED Upon discovery, the 00S card was rehung on the correct breaker and a proper second verification was performed.
'MDECTIVE ACTION TAKEN TO AVOID FURTHER VIO'.ATION The NSO involved was given five days of f without pay. Additionally he was assigned a special task of preparing a summary of licensed operator responsibilities. This summary was generated off shift by the NSO, and will be presented to all licensed operators. These actions were taken after review of the event with Commonwealth Edison corporate management. That review also considered the individual's reactor operator license, 10CFR Part 55, I.E. Information Notice No. 85-69, and an NRC internal memo on " Guidance for Enforcement Actions Regarding Individuals".
It was determined that the facts in this case did not warrant removal of the individual from licensed duties. This determination was based upon the following factors:
- 1) The initial action did not indicate an intent to falsify the verification but only a mistaken belief that a signature had been erroneously omitted, 2) the NSO had nothing to gain personally by signing the checklist for the verifier, 3) after recognizing the seriousness of his failure to fully inform his supervisor and reflecting on his personal integrity he came forward with all of the facts, 4) he had been evaluated by his superiors to be a good operator and the Company believes he has a satisfactory work record, 5) the disciplinary action taken is consistent with the way the Nuclear Stations Division has administered disciplinary suspension in Personnel Error cases and is considered in this case to be a maximum discipline prior to termination.
g
. In addition, all Operating Shift personnel were provided with guidance.concerning signature responsibility and the station and corporate position on infractions of this nature. Training was also provided on this specific event with an emphasis on the importance of adherence to company procedures and guidelines. All of these training items were completed by June 5, 1986.
This event has been widely discussed with operators at all Comunonwealth Edison nuclear plants. A letter has been issued by Nuclear Stations Division to all nuclear stations identifying the need for valid, signatures and initials on all plant records, and identifying acceptable',
uses of initials for verifications. This policy on initials and signatures has been issued to all station personnel, and is being incorporated into e permanent station procedure.
4 DATE OF PULL COMPLIANCE 1
Full compliance has been achieved.
N 4
i
(
q 1836K b
i
.^
' 6 [.'
VIOLATION: IR 374/86016-014 (AIR 374-100-86-01601) v.
' \\
C.
Item 1.g of Appendix A to Regulatory Guide 1.33 identifies " Shift and Relief Turnover" as required procedures. Procedure LAP 200-3 requires that the oncoming Shift Engineer, oncoming Station Control Room Engineer (SCRE)/ plant SRO, oncoming Shift Foreman, and offgoing Nuclear Station Operator (NSO) with the oncoming NSO shall perform a visual control room panel check which shall include the status of safety-related systems (green board concept).
l contrary to the above, on the afternoon of March 19, 1986, the oncoming Shift Engineer, Shift Control Room Engineer, Shift Foreman, Nuclear Station Operator, and offgoing Nuclear Station Operator failed to determine the status of a safety-related system in that they failed to identify that the High Pressure Core Spray Suppression Pool Full Flow Test Valve was inoperable, i
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED 1
Upon discovery by the SCRE, the outage was rehung correctly and the mispositioned U-2 breaker was returned to its normal position. This action restored the subject valve to fully operable status.
l i
N RECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION i
l The individuals involved in the inadequate panel inspections have been specifically counseled on the need for attention to detail. Operator training programs have been updated to include better guidance in recognizing off-normal panel conditions. SCRE's have been retrained on their specific responsibilities for ensuring proper shift turnover practices are employed effectively. shift Engineers have been instructed to strengthen their questioning of operators to ensure operators are aware of and understand off-normal conditions.
I Shift surveillance procedures have been revised to require that, if an ESF alarm exists, for a system considered operable, an BSF status summary will be obtained and reviewed to ensure all faults are understood.
Directions have been provided to assist operators in ensuring that i
appropriate computer points are taken out of scan when the computer is restarted.
j DATE OF FULL COMPLIANCE Full compliance has been achieved.
4
!i.
VIOLATION: IR 374/86016-OlB (AIR 374-100-86-01602)
D.
Step F.33.f of Shift Surveillance procedure LOS-AA-S1 requires that the HPCS Full Flow Test to Suppression Pool valve, 1(2)E22-F023, be checked to indicate closed.
Contrary to the above, on March 19, 1986, the afternoon shift NSO failed to perform Step F.33.f of the procedure.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Upon discovery the breaker was returned to the proper position and a proper HPCS lineup could be observed.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION LOS-AA-S1 has been revised to contain: 1) A precaution about burned out bulbs causing false panel indication - step D.3, and 2) a step to make the operators more aware of ESF system status - step F.82.
In addition, all shift personnel were trained on this specific event with an emphasis on attention to detail. Further guidance on recognizing off-normal panel conditions has been included in Operator Training programs.
DATE OF FULL COMPLIANCE Full compliance has been achieved.
t I
l l
1836K l
l l
. - _ _ _