ML20211Q025
| ML20211Q025 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/29/1997 |
| From: | Subalusky W COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-373-97-07, 50-373-97-7, 50-374-97-07, 50-374-97-7, NUDOCS 9710220063 | |
| Download: ML20211Q025 (7) | |
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Tri H i %.4%74'61 September 29,1997 Up!ted States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Notice of Violation; NRC Inspection Report 50 373/374 97007 LaSalle County Station, Units 1 and 2 Facility Operating License NPF 11 and NPF 18 NRC Docket Nos. 50 373 and 50 374
Reference:
M. N. Leach letter to W. T. Subalusky, dated August 29,1997 Transmitting NRC Inspection Report 50 373/374 97007 The enclosed attachment contains LaSalle County Station's response to the Notice of Violation, that was transmitted in the Reference letter, if there are any questions or comments conceming this letter, please refer them to me at (815) 357-6761, extension 3600.
Respectfully, n
W. T. Subalusky Site Vice President I
LaSalle County Station h,D f Enclosure cc:
A. B. Beach, NRC Region Ill Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle
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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374 97007 VIOLATION: 373-97007-01 10 CFR Part 50, Appendix B, Criteria V, " Instructions, Procedures, and Drawings," requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstance and be accomplished in accordance with these instructions, procedures, or drawings.
LTS-600-4 "American Society of Mcchanical Engineers (ASME)Section XI Inservice Testing of Pumps and Valves," Revision 14, Step F.6.b requires that the pump be declared inoperable and appropriate actions be taken as specified in the Limiting Conditiona for Operation in the Technical Specifications when the pump is confirmed to be in the Required Action range.
Contrary to the above, inspectors ident:fied that on June 13,1997, after surveillance test results indicated tha'. tha 1B residual heat removal pump parameters were in the Required Action ronge, the licensee did not immediately declare the pump inoperable for the low pressure coolant injection and shutdown cooling modes of operation until approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later, respectively.
This is a Severity Level IV violation (Supplement l} (50 373/97007 01).
REASON FOR VIOLATION: 373 97007-01 This event was the subject of Licensee Event Report (LER) 97-025-00, submitted July 9,1997. The response to this violation duplicates the information docketed under the LER.
The cause of the delay in the operability determination was personnel error in that the Shift Manager, Unit Supervisor and Nuclear Station Operator failed to make an appropriate operability determination based on installed Control Panel Indication, but instead decided to call the 1B RHR Pump operable based on Process Computer indications of the pump flow and pressure parameters. The personnel error was cognitive in that the operators failed to recognize the action they should take in spite of careful
- analysis, t
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ATTACHMENT RESPONSE TO N3TICE OF V12LATION NRC INSPECTION REPORT 373/374 97007 CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The indicators for 1B RHR Pump discharge pressure (1E12 R612B) and flow (1E12 R603B) were verified to be operating properly. During fudher troubleshooting and verification of the previous day's results on June 14,1997, one out of tolerance indicating point was noted and corrected during calibration of the flow indicator in accordance with LIP RH 502B.
Based on completion of surveillance LOS RH 01, following recalibration of the instruments, an engineering evaluation of 1B RHR Pump performance was satisfactorily performed, and the pump was declared operable on June 15,1997. Engineering's review of 1B RHR Pump performance determined that it met applicable pump specifications and was not degrading.
The Shift Manager was counseled exiensively by LaSalle Senior Management and reminded of the expectations for conservative decision making that continue to be vigorously communicated throughout the station by the Plant General Manager and other senior management personnel.
Other control room personnel involved in this event were also counseled it was stressed by senior management that there is a clear expectation to declare equipment inoperable as soon as conditions specified by the Technical Specifications cannot be met and to take required actions promptly.
Appropriate disciplinary measures were taken in regard to those individuals responsible for this event.
CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS:
No actions beyond those identified above are necessary.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on June 15,1997, when the 1B RHR pump was declared operable after successful completion of surveillance LOS-RH-Q1.
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ATTACHMENT RESPONSE T@ NOTICE OF VIOLATIEN NRC INSPECTION REPORT 373/374-97007 VIOLATION: 373/374 97007-02 10 CFR Part 50, Appendix B, Criterion V, "Instructioni. Procedures, and Drawinns," requires that activities affecting quality be prescribed by documenad procedures or instructions of a type appropriate to the circumstances, and be accomplished in accordance with those procedures or instructions.
Contrary to tha abcve, on June 26,1997, the inspectors identified that Work Request No. 970049757, ' Replace / Rebuild Air Start Motors," did not provide ir,structions of a type appropriate to the circumstances in that it provided inappropriate post maintenance test guidance. Specifically,it did not require a timed start of the emergency diesel generator following air start motor replacement although such replacement could affect the Technical Specification required start time.
This is a Severity Level IV violation (Supplement I) (50 373/97007-02; 50 374/97007-02).
REASON FOG VIOLATION: 373/374-97007-02 The cause for the inadequate post maintenance is sting of the replacement air start motors for the diesel generators was inadequate technical review.
The station had determined, by engineering judgment, that performing an idle start following like-for like replacement of the air start motors adequately demonstrated the functionality of the diesel generator and a fast start was not required. Bench testing of air start motors which had been assembled to original state followed by an idle start was deemed to be adequate to verify proper operation of the air start motors on the diesel generators. This engineering judgment was promulgated through Technical Specification Clarificction 02 90. This Technical Specification Clarification was the basis for the work instructions in the subject work request. The investigation determined that the technical basis for this engineering judgment had not been adequately documented.
CCRRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The "O' diesel generator was satisfactorily fast started on June 26,1997.
Technical Specification Clarification 02 90 Rev 1 has been canceled. Fast stai. tests will be performed on emergency diesel generators that have had their air start motors replaced prior to declaring them operable (NTS# 373-100-97-00702.01).
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ATTACHMENT RESPONSE TO NOTICE CF VIOLATION NRC INSPECTION REPORT 373/374 97007 CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS:
Fast start testing will be required when an air start motor has been replaced until technical justification for the use of idle start testing has been established and documented. Applicable procedures will be identified and revised by November 30,1997, to require f ast start testing when air start motors are replaced (NTS# 373 100-97-00702.02).
Existing Technical Specification Clarifications were reviewed in June 1997 as part of the Station's Restart Action Plan (Strategy No. 6), which is intended to minimize the number of Clarifications to the extent possible prior to start up. An annual Technical Specification Clarification review, in accordance with LAP 1200-17, will use the June 1997 review to evaluate the content of each Clarification to determine whether it should be eliminated, revised, incorporated into other programs, or be maintained as is. The annual review will be completed by October 30,1997. Any required actions resulting from this review will be completed prior to startup of either unit (NTS# 373-100 97 00702.03).
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on June 26,1997, when the "0" Diesel Generator was successfully fast start tested.
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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-97007 VIOLATION: 373/374 97007-05 Technical Specificailon 0.2.A.a requires that applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be established, implemented, and maintained.
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, specifies procedures for contamination control.
Step F.9.a.1 of LaSalle Administrative Procedure LAP 900 8," Hose Identification and Control," Revision 17, requires that all tygon tubing used on contaminated systems be identified with " Internal Contamination" stickers.
Contrary to the above, on June 6,1997, the inspectors identified that tygon tubing installed to support leakage testing on contaminated components (Iow and high pressure feedwater heaters) was not identified with " Internal Contamination" stickers.
This is a Severity Level IV violation (Supplement IV) (50-373/97007 06, 50 374/97007 06).
REASON FOR VIOLATION: 373/374 97007-05 Inadequate training of Radiation Protection (RP) and other plant personnel on the requirements of LAP-900 8 resulted in a generallack of knowledge of the labeling requirements associated with tygon tubing.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The tubing identified during the inspection was properly labeled per LAP-900 8. RP personnel performed a walkdown of the Units 1 and 2 Reactor and Turbine buildings and identified several additional instances of unmarked tygon hose or tubing, which were then properly labeled.
RP personnel were briefed on this event during their department communications meeting on June 9,1997, c
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ATTACHMENT RESPONSE TG NOTICE OF VIOLATisN NRC INSPECTION REPORT 373/374-97007 CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS:
Hose control training for Nuclear Generating Employee Training (NGET) and Advanced Rad Worker Training will be enhanced to include labeling requirements for tygon hoses and tubing by January 15,1998, (NTS# 373100 97 00705.01 and 00705.02).
In March 1997, the Station conducted a Root Cause Analysis on Procedure Adherence and Adequacy (NTS# 373 200 97 00040.00). This analysis identified a programmatic weakness regarding tralning on administrative procedures, and an action item was created to develop a training program by June 1,1998, (NTS# 373100 97 00705.03).
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compilance was achieved on June 14,1997, when the walkdown of the Reactor and Turbine buildings was completed and all identified tygon hoses and tubing were properly labeled.
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