ML20215B707
| ML20215B707 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/25/1986 |
| From: | Turbak M COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 2437K, NUDOCS 8612120290 | |
| Download: ML20215B707 (4) | |
Text
!
<), One First Natonal Plaza, CNcago, Illinois pgg COmffMN1WGaith Edloort e
/ Address Reply to: Post Omce Sox 767 w/ CNcago, tuinois 60690 - 0767 November 25, 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 Unit 2 1 and 2 Response to Inspection Report Nos. 50-373/86035 and 50-374/86036 NRC Docket Nos. 50-373 and 50-374 i
Rcference (a): W. G. Guldemond letter to Cordell Reed dated October 29, 1986.
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs. M.
Jordan, J. Bjorgen, R. Kopriva, J. Mueller and J. Ulle on September 3 through October 7, 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 response to the three level IV violations identified in the Notice of Violation is provided in the enclosure.
If you have any further questions on this matter, please direct them to this office.
4 Very truly yours, M. S. Turbak Operating Plant Licensing Director bc Attachment ec: NRC Resident Inspector - LSCS 2437K
/
8612120290 861125 PDR ADOCK 05000373 PDR 1 1986 I \\
DEC IEo/
ATTACHMENT A VIOLATION:
IR 374/86036-01 (AIR 374-100-86-03601)
Technical Specification 3.3.7.4 requires remote shutdown instrumentation to be operable with readouts displayed in the remote shutdown panel external to the control room. The required Instrumentation included the Residual Heat Removal (RHR) service water temperature. With any of the required monitoring instrumentation inoperable, the instrumentation shall
+
be restored to operable status within seven days or the plant shall be in at least hot shutdown within the next twelve hours.
Contrary to the above, on September 16, 1986, the reactor was not in at least hot shutdown nor was the RHR service water temperature indicator on the remote shutdown panel operable, seven days after the indicator had been made inoperable on September 9, 1986.
j CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Upon discovery of the Technical Specification violation, the work was promptly completed.
The instrument was retucned to an operable status fifteen and one-half hours after it was discovered that a Technical Specification 7 day time clock applied to the equipment.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION A review of all Safety Related Work Requests in progress was conducted to identify any additional problems of this nature. None were identified.
The Work Request procedure was revised to amplify the Shift Engineer review for Technical Specification concerns, and to add a new attachment to aid the Shift Engineer and Work Analyst in categorizing Work Requests correctly and ensuring all Technical Specification concerns are addressed prior to starting the work.
A program is in progress to generate a cross reference list between Instruments and appropriate Technical Specifications. AIR 374-200-86-0541 will track the completion of this work. This will assist the Shift l
Engineer in identifying work requests which affect technical specification instrumentation.
DATE OF FULL COMPLIANCE i
Full compliance has been achieved.
I I
ev--
y
-m-4
,e,,
,ev-,
,-+.---,.r ev-~c=.-
e
VI"LATION: IR 374/86036-02 (AIR 374-100-86-03602) 10 CFR 50 Appendix B, Criteria V Instructions, Procedures, and Drawings requires that acitivities affecting quality shall be prescribed by.
procedures.
appropriate to the circumstances.
Contrary to the above, on September 17, 1986, the control room annunciator alarm procedure LOA 1(2)H13-P601 C301, " Residual Heat Removal Heat Exchanger Discharge Cooling Water Heat Exchanger A/B Temperature Hi," was found not to be appropriate in that, it did not include a reference to Technical Specification 3.3.7.4. Limiting Condition for Operation for remote shutdown monitoring instrumentation, of which the RHR Hx service water discharge temperature indication is a part.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The procedure LOA 1(2)H13-P601 C301 was revised and now includes the proper reference to the appropriate Technical Specification.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Control Room Annunciator procedures for other indications at the remote shutdown panel were reviewed for similar pitiills. No additional deficiencies of this natrre were found.
DATE OF FULL COMPLIANCE Full compliance has been achieved.
l i
l l
0=,
.s VIOLATION: IR 374/86036-03 (AIR 374-100-86-03603)
+
Technical Specification 6.2.A.1 states, " Detailed written procedures shall be prepared, approved and adhered to for applicable procedures recommended in Appendix A of Regulatory Guide 1.33. Revision 2. February 1978."
Regulatory Guide 1.33, Appendix A, includes procedures for the control of equipment.
4 LaSalles's administrative procedures for the control of equipment includes procedure lap-1300-1, " Work Request," which states, "The Shift Engineer shall review Technical Specification requirements and verify that equipment can be removed from service and is not required to be operable."
Contrary to the above, on September 9, 1986, the Shift Engineer failed to review the Technical Specification requirements section of the work request before removing the equipment from service.
The related Technical Specification, section 3.3.7.4, had a seven day Limiting Condition for Operation time clock which was exceeded CORRECTIVE ACTION TAKEN AND'RESULTS ACHIEVED The Work Request procedure was revised to amplify the Shift Engineer review for Technical Specification concerns, and to add a new attachment to aid the Shift Eng!..eer and Work Analyst in categorizing Work Requests correctly and ensuring all Technical Specification concerns are addressed prior to starting the work.
l CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION A program is in progress to generate a cross reference list between Instruments and appropriate Technical Specifications. AIR 374-200-86-0541 will track the completion of this work. This will assist the Shift Engineer in identifying work requests which affect technical specification instrumentation.
DATE OF FULL COMPLIANCE Full compliance has been achieved.
2437K l
.