ML20236W662
| ML20236W662 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/31/1998 |
| From: | Dacimo F COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-373-98-10, 50-374-98-10, NUDOCS 9808060135 | |
| Download: ML20236W662 (5) | |
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C(mimonwcalth fdnon Company lasalle Generating Station
_g 2601 North 21st Road Marwilles, 11.61341 9757 lel HI 4357K61 July 31,1998 I
United States Nuclear Regulatory Commission i
Attention: Document Control Desk Washington, D. C. 20555 l
Subject:
Reply to a Notice of Violation, NRC Inspection Report j
50-373/374-98010 l
LaSalle County Station, Units 1 and 2
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Facility Operating License NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 l
Reference:
G. E. Grant letter to O. D. Kingsley, dated July 2,1998, f
Transmitting NRC Inspection Report 50-373/374-98010 1
The enclosed Attachment A contains LaSalle County Station's response to the Notice of Violation t'lat was transmitted in the Reference letter.
Attachment B provides the commitment (s) for this submittal.
If there are any questions or comments concerning this letter, please refer them to Harold D. Pontious, Jr., Regulatory Assurance Manager, at (815) 357-6761, extension 2383.
Respectfully, Y\\
Fred R. Dacimo Site Vice President i
LaSalle County Station pk Enclosures cc:
C. A. Paperiello, Acting NRC Region 111 Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle j' ~ 1Z D. M. Skay, Project Manager - NRR - LaSalle F. Niziolek, IDNS Senior Reactor Analyst l
9800060135 900731 DR ADOCK 05000373
ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98010 VIOLATION: 373/374-98010-01 Technical Specification 6.2.A.a requ'res 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 equipment control (e.g., locking and tagging).
Step B.2.3 of LaSallo Administrative Procedure (LAP) 100-30," Independent Verification," Revision 16, an equipment control procedure, requires an apart-in-time independent verification when installing or removing out-of-service (OOS) tags.
Contrary to the above, on April 23,1998, two operators, performing OOS tag removal and positioning of control room ventilation system dampers, did not perform an apart-in-time independent verification, required by LAP-100-30.
REASON FOR VIOLATION:
Operations department personnel were to clear OOS #980001699 and hang another OOS. OOS # 980001699 required them to remove tags and open manual dampers that supply the Main Security Control Center (MSCC).
They were expected to open dampers OVC29YA and OVC29YB. Instead, they pulled the OOS cards and opened dampers OVC26YA and OVC26YB that are physically adjacent but on different vent ducts that supply the main control room and were controlled by a different OOS.
The Unit Supervisor briefed the two operaters on the assignment emphasizing the sequence to clear OOS #980001699 prior to hanging the other OOS since this sequence was necessary to maintain ventilation flow to the MSCC.
The Unit supervisor did not specifically discuss the methods to be used for performing the independent verifications required for both out-of-services.
This was an inappropriate action, since 1) this instruction or guidance would have enabled the second operator to identify that the wrong component had been located, and 2) the operators had limited experience in current independent verification requirements.
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1 ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98010 When the first damper (0\\lC26YB) was located on the "B" train of ventilation, and was the only damper noticed by the operators to have an OOS card attached, they assumed it was the correct damper. The actual case was that the correct damper, with the correct OOS card, was covered by a foraign material exclusion cover. The first operator removed the card and caecked f
only that the verbiage on the card agreed with the label information, not with the OOS checklist. The second operator also only checked that the verbiage on the card agreed with the label information. These were inappropriate actions in not adhering to procedural requirements for l
independent verification and poor work practices in removing OOS tags j
without use of the checklist.
Next, when the OVC26YA damper was located, another opportunity was I
available to recognize that an error had been made in clearing this out of service. Again the operators assumed that their first actions were correct and repeated the same inappropriate actions on the "A" train damper in the same manner.
l The Root Cause determination identified that two human performance errors involving failure to follow administrative procedures were made:
1.
Removing OCS cards from components without comparing card i
information to the OOS checklist.
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2.
Failing to verify that the correct cards had been removed by performing independent verification.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The following actions were taken after the errors were identified or as part of the prompt investigation.
1.
Verified the correct clearing of OOS #980001699. Tags were removed from 0VC29YA and OVC29YB and the dampers opened.
2.
Verified the correct placement of OOS #980000532. Cards were added to OVC26YA and OVC26YB and the dampers returned to the l
closed position.
3.
Other work, including OOS work, performed by the two operators was reviewed to determine if problems with the quality of their work were present. No discrepancies were identified.
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ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-98010 l
4.
The two operators were suspended from normal operating duties and given a temporary assignment to develop lessons learned from this event. They were subsequently reassigned to work supporting restart testing until they are re-qualified by training and evaluated by Operations Managernent. Additionally, appropriate disciplinary action was taken.
5.
The Pre-Job Brief Checklist in LAP-200-3 was revised to include a reference to LAP-100-30, Independent Verification. It is Management's expectation that shift supervisors use the checklist during pre-job briefings. During subsequent communication meetings with the shift crews independent verification requirements l
were emphasized.
6.
The shift supervisor was counseled on management expectations:
- 1) regarding the need for thorough pre-job briefings and 2) to require that independent verification be performed through an apart-in-time method excect when apart-in-action is necessary. Additionally, appropriate disciplinary action was taken.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:
I The Operations Department has completed a human performance review session, focusing on Operations Department documented events. This review included lessons learned, why the events occurred, and how they could have been prevented. This session covered operating events from 1997 and 1998.
General Information Notification 98-61, " Clarification of Independent Verification when Performing Out-Of-Services and Changes to LAP-100-30,"
was issued to Operations Department Personnel.
1 LAP-100-30 has been revised to require that the apart in-time method of l
independent verification be used for all safety related out of services, except i
for the following cases:
installation of temporary alterations.
installation of jumpers and lifted leads.
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l DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
l Full compliance was achieved on April 23,1998 when OOS #980001699 was successfully cleared.
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ATTACHMENT B REGULATORY COMMITMENT (S)
The,following identifies those actions committed to by Comed in this document. Any other actions discussed in this submittal represent intended or planned actions by Comed. They are described to the NRC for the NRC's information and are not regulatory commitments.
Tracking Number None t
4
i CWmGURY 1
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) d ACCESSION NBR 9808060060 DOC.DATE: 98/07/30 NOTARIZED: NO DOCKET #
FACIL:STN-50-454 Byron Station, Unit 1, Commonwealth Edison Co.
05000454 STN-50-455 Byron Station, Unit 2, Commonwealth Edison Co.
05000455 AUTH.NAME AUTHOR AFFILIATION GRAESSER,K.L.
Commonwealth Edison Co.
RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)
SUBJECT:
Informs 1. hat application of Okonite tape splices at Byron
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Station is same as at Braidwood Station. Comed proposes application of ltra dtd 950126 & 950725 & SE dtd 951113 as resolution of Unresolved Item for Byron Station.
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:
l TITLE: General (50 Dkt)-Insp Rept/ Notice of Violation Response j
NOTES: Standardized Plant.
05000454(
Standardized Plant.
05000455
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RECIPIENT COPIES RECIPIENT COPIES l
ID CODE /NAME LTTR ENCL ID CODE /NAME LTTR ENCL PD3-2 PD 1
HICKMAN,J 1
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INTERNAL: ACRS 2
AEOD/SPD/RAB 1
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DEDRO 1
L FILE CENTER 1
NRR/DRCH/HOHB 1
1 NRR/DRPM/PECB 1
NRR/DRPM/PERB 1
1 NUDOCS-ABSTRACT 1
OE DIR 1
L OGC/HDS2 1
RGN3 FILE 01 1
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EXTERNAL: LITCO BRYCE,J H 1
NOAC 1
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NRC PDR 1
NUDOCS FULLTEXT 1
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NOTE TO ALL " RIDS" RECIPIENTS:
l PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FPOM DISTRIBUTION LIS1 i
OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CO!"~ACT THE DOCUMENT CONTRC l
DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL