ML20248A227

Notice of Violation from Insp on 890725-0911.Violations Noted:Licensee Attempted to Lineup Common Reactor Bldg Closed Cooling Water HX from Unit 2 to 1 W/O Approved Procedure

ML20248A227
Person / Time
Site:	LaSalle
Issue date:	09/22/1989
From:	Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248A224	List: IR 05000373/1989019 ML20248A219 ML20248A227
References
50-374-89-19, NUDOCS 8910020163
Download: ML20248A227 (2)

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U NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-374 As a result of the inspection conducted on July 25 through September 11, 1989, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the following v blations were identified:

A. 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by procedures of a type appropriate to the circumstances and be accomplished in accordance with those procedures.

LOP-WR-02, Startup and Operation of the Reactor Building Closed Cooling Water System, provides instructions for aligning the common Reactor Buf1 ding Closed Cooling Vater (RBCCW) heat exchanger in a Unit 2 lineup but did not provide instructions for swapping it from a Unit 2 lineup to a Unit 1 lineup.

LAP-820-2, Station Procedure Preparation and Revisions, provides the steps by which station procedures are to be revised.

LAP-820-1, Station Procedures, provides guidelines for the limited circumstances in which procedural deviations are permissible such as when an obvious typographical error can be corrected by the use of an Addendum Deficiency Sheet (ADS). It also requires the ADS to be completed and signed by the supervisor of the individual making the l change, ard to be forwarded to the Procedure Manager, prior to continuing performance of the procedure.

l l Contrary to the above, on August 13, 1989, the licensee attempted to lineup the common RBCCW heat exchanger from a Unit 2 lineup to a Unit 1 lineup without having an approved procedure. The procedure that was used was recognized to not have the necessary instructions to perform the evolution and it was not revised in accordance with LAP-820-2.

The individuals involved did intend to use the guidelines of LAP-820-1 to allow the evolution to proceed, however, this was contrary to the written intent of that procedure and the individuals also failed to document the l

changes being made on an ADS signed by their supervisor and forwarded to l the Procedure Manager prior to the continuance of the work as required by LAP-820-1.

This is a Severity Level IV violation (Supplement I).

l B. Technical Specification 6.2.A requires that the detailed written j

procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be adhered to. Appendix A of Regulatory Guide 1.33 includes administrative procedures.

Bi10020163 890921 PDR ADOCK 05000373 O PNU

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+ Notice of' Violation- 2 l

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LaSalle administrative procedure LAP-240-6, Temporary System Changes,

= defines temporary system changes as temporary connections such as hoses, tubing or piping that join two systems together, thus alterir:g the system design or configuration.

LaSalle administrate u procedure LAP-240-6, steps F.2 and F.3 provide instructions for initiating a Temporary System Change, and steps F.4 and F.5 pertain to onsite review cod approval, and Shift Engineers review of the Temporary System Change authorization.

LaSalle administrative procedure LAP-100-4, Control of Non-Station Personnel, which includas sub-station construction, step F.8 requires that all non-station Commonwealth Edison superivors, who perform or control work, be familiar with the work control process with particular attention to a certain-group of procedures which includes LAP-240-6.

Contrary to the above, on August 28, 1989, sub-station construction, while attempting to clean the cooling fans on the 2 East and 2 West main transformers, cross connected the station air system and.the clean condensate water system together without using a temporary system change.

Sub-station construction did not adhere to procedure LAP-240-6, Temporary System Change, and the licensee'did not adhere to procedure LAP-100-4, Control of Non-Station Personnel.

This is a Severity Level V violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Consideration may be given to extending your response time for good cause shown.

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Dated lt)D u-W. D. Shafer/ Chief Reactor Projbets Branch I

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