ML20135D958

Responds to NRC Re Violations Noted in Insp Repts 50-373/96-09 & 50-374/96-09.Corrective Actions:Reviewed Backlog of Action Requests (Ar),Reclassified ARs & Revised LAP-1300-01, Action/Work Request Processing

ML20135D958
Person / Time
Site:	LaSalle
Issue date:	02/24/1997
From:	Subalusky W COMMONWEALTH EDISON CO.
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE)
References
NUDOCS 9703060149
Download: ML20135D958 (21)

Text

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, tealle Generating Station 2601 North 21st Road Marseilles, !!,613 4 !-9757

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j j February 24,1997

! Mr. James Lieberman, Director  !

l Office of Enforcement

U. S. Nuclear Regulatory Commission 4

One White Flint North

11555 Rockville Pike Rockville, MD 20852-2738

Subject:

Notice of Violation and Proposed imposition of Civil l 9enalties; LaSalle County Units 1 and 2; Docket Nos. 50-373 and 50-374

References:

1. NRC Letter dated January 24,1997, from A. B. Beach to T. J. Maiman; Notice of Violation j and Proposed imposition of Civil Penalties - '

$650,000 (NRC Special Inspection Report

{ No(s). 50-373/96009; 50-374/96009)

2. Comed Letter dated January 13,1997, from W. T. Subalusky to A. B. Beach.

3. Comed Letter dated February 6,1997, from

, T. J. Maiman to U. S. Nuclear Regulatory l

Commission Document Control Desk; Response to Request for Information Pursuant to  :

10 CFR 50.54(f) Regarding Adequacy and  ;

Availability of Design Bases Information

4. Comed Letter dated February 18,1997, from T. J. Maiman to U. S. Nuclear Regulatory  ;

! Commission Document Control Desk; Transmittal i of Independent Self Assessment Team Report

Dear Sir:

.I e jy '

In Reference 1, the NRC transmitted to Commonwealth Edition Company 3 (Comed) a Notice of Violation and Proposed imposition of Civil Penalties. -

06001O That correspondence concemed the service water event that occurred in June 1996. Comed discussed these issues with NRC representatives at a  :

predecisional enforcement conference held on September 27,1996. j i EDR ADO K O 373 .

O PDR

The purpose of this letter is to provide our response to the Notice of Violation and Proposed Imposition of Civil Penalties, pursuant to 10 CFR 2.201. Comed admits to the violations. Attachment 1 contains our detailed response to each violation cited in the Notice of Violation, pursuant to the provisions of 10 CFR 2.201. Our responses include reasons for the violations, corrective steps taken and results achieved, as well as corrective steps to avoid recurrence and date(s) when full compliance will be achieved.

Enclosed is a check in payment of the Proposed Civil F'analties.

Comed is concerned with the seriousness of the issues and concurs with the NRC's  !

concems expressed in the transmittal letter accompanying Reference 1. These include  !

lack of appropriate safety focus and questioning attitude by management and NRC's i substantial involvement to focus management attention on factors significant to resolution  ;

l of these problems at LaSalle County Station. Underscoring the depth of our concern with these issues, LaSalle County Station management has undertaken a series of important

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initiatives since the service water event in June,1996. These initiatives were developed to l address the violations identified in Reference 1, as well as to promote necessary improvements in several other areas. These initiatives are briefly described below. {

! SpecialInvestination Team

- In response to the service water event, a special investigation team was formed under the direction of the Vice President for Nuclear Support. This team conducted an extensive i investigation of the causal factors, significance, consequences, corrective actions and j lessons to be learned. The team identified inadequacies in the way that work was  ;

! reviewed and assigned and the oversight of the contractor's work activities. Once the l sealant was injected, LaSa!Ie failed to recognize several precursors which provided  !

indication of foreign material intrusion. Operability assessments were performed that did not correctly identify the potential safety significance of the condition.

The investigation team developed a series of thirty-seven specific recommendations, which, for implementation purposes, are divided into four categories:- processes and programs, problem identification, plant management; and, self-assessment and oversight.

LaSalle County Station is in the process of implementing these recommendations. (As appropriate, the findings of the special investigation team related to causal factors and corrective action of the violations noted in Reference 1 are described in Attachment 1 hereto.) .More generally, the recommendations of the special investigation team are being formally tracked in our Nuclear Tracking System and are available for NRC's review.

As we complete these actions, effectiveness reviews will be performed as appropriate. j i

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Independent Self Assessment Team (ISAT)

In order to ensure a thorough understanding of performance issues at the LaSalle County Station, Comed commissioned an Independent Self Assessment Team. A similar assessment was performed for the Zion Station. These intensive assessments were performed by teams of experienced consultants and industry peers who reviewed the functional areas of Operations, Maintenance, Engineering, and Plant Support against the standard of best-performing plants in the industry. The ISA team also developed an ,

assessment of the fundamental causes of performance declines at Zion and LaSalle,  ;

including the Nuclear Operations Division and Corporate organizations in that assessment.  :

, LaSalle County Station and Nuclear Operations Division management briefed Mr. Bill  !

l Beach, NRC Region ill Regional Administrator, on December 23,1996. The ISAT Report has been transmitted to the NRC (Reference 4). On its own initiative, Comed conducted public meetings on February 20,1997, to present the ISAT results for LaSalle County Station and Zion Station. NRC personnel attended these public meetings.

I Personnel Channes/ Human Performance Over the past several months, new personnel have been moved into a number of positions at LaSalle, including: Plant General Manager; Unit 1 Plant Manager; Site Engineering i Manager; Outage Manager; Units 1 and 2 Maintenance Superintendents; Saf9ty Assessment Manager; Corrective Action Manager; and SQV Director. These individuals '

bring proven industry records to help us meet our immediate and long term challenges as well as sustain strong performance. "

Near term, we must stay focused on the fundamentals of conservative decision making, leadership, accountability and ownership, self-assessment, and materiel condition. ,

Emphasis will be on steady, solid improvement and not on quick fixes. At a recent "all l hands" briefing, management conveyed their expectation for LaSalle's improvement and the necessary elements of each individual's contribution to this effort: Strict procedural adherence, strong use of the self-checking program, a questioning attitude and a demand for resolution of issues.

Manaaement Action Plan for Restart As noted above, neither unit at LaSalle County Station will be restarted until certain key issues are resolved. The key management tool being used to achieve specific goals is the LaSalle County Nuclear Station Unit 1/ Unit 2 Restart Plan. The Plan integrates site activities and describes our near term performance improvement strategy. The Plan consists of an integrated set of complementary programs and activities that willimprove our confidence that power operations will be safely initiated and the units returned to reliable full power operation in a controlled manner.

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s The Plan is divided into four pht.ses:

• Definition of physical plant work and other activities to be completed prior to unit restart l . Work completion.

l . Restart and operational readiness evaluation. j j . Unit restart and power ascension.

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The Specific Action Plans are organized into five strategies that continue the site performance improvement focus established in the 1996 Operational Plan and extend to additional items that are required to achieve a safe and event-free restart. i t

. Safe Plant Operation  !

. Plant Materiel Condition and Effective Outage Completion l

. Effective Engineering Support and Corrective Action implementation j

. Effective Work Control  :

. Human Interaction and Performance We will continue to keep the NRC informed concerning our activities in this regard (a copy of the plan has been provided to the NRC Senior Resident inspector at LaSalle County Station).  !

Summarv l In summary, these initiatives are designed to provide confidence that events such as the service water event in June,1996, will not be repeated. LaSalle County Station will be operated in a safe and conservative manner and we recognize Gat the implementation of these initiatives is crucial to success. I am committed to that succes_s and we recognize i the need to improve our implementation. This need was most recently illustrated in Reference 3, in which we concluded that the existing design and configuration control processes are adequate if implemented effectively; however, our confidence in the effectiveness of past management and implementation of these processes was reduced by the deficiencies we have encountered through continuing self-assessment, and the potential extent of condition discovered therein.

We are committed to the success of our improvement initiatives. In this regard, Reference 2 noted that LaSalle County Station and Comed management have determined that neither unit will be restarted (Unit 1 is in a forced outage to resolve equipment problems and Unit 2 is in a refueling outage), until specific actions are taken to resolve problems in the areas of system design and testing, material condition, operator performance and engineering support of the plant.

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If there are any questions or comments conceming this letter, please refer them to me at

(815) 357-6761, extension 3600.

Respectfully, W. T. Subalusky Site Vice Pres,ident LaSalle County Station ,

i Enclosure 1 4

cc

A. B. Beach, NRC Region ill Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle l D. M. Skay, Project Manager - NRR - LaSalle i NRC Document Centrol Desk l 1

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1 l STATE OF ILLINOIS ) l j )  ;

i COUNTY OF LASALLE ) Docket Nos. 50-373 '

! ) 50-374 j COM ED COMPANY )  ;

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{ LASALLE COUNTY STATION - UNITS 1 & 2 )

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2 AFFIDAVIT I i

a 1 affirm that the content of this transmittal Comed letter dated February 24,1997, to l i J. Lieberman from W. T. Subalusky is true and correct to the best of my knowledge, l

! information and belief. I

. S I-AM du William T. Subalusky' \

Site Vice President C ) '

LaSalle County Station I i

l Subscribed and sworn to before me, i a Notary Public in a

. lilinois, this - 2Y*day ndoffor the State of February,1997.

i My commission expires on l  % x gg .2000, ,

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OFFICIAL :. . :=::=:::::,N SEAL

! {l RUTH A DILLON h j l'>

NOT ARY PUSUC. STATE OF ILLINOtS h

, MY COMMIS860N EXPfRf S:03/25M)0 < '

NOTARY PUBLIC l j

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t l ATTACHMENT I RESPONSE TO NOTICE OF VIOLATION i

NRC INSPECTION REPORT l 373/374-96009 VIOLATION - 373/374-96009-1.A.1.a-b 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

requires, in part, that activities affecting quality be prescribed by and accomplished in  !

, accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.

LaSalle Administrative Procedure (LAP) 300-37," Minor Maintenance Action Request Procedure," Revisions 3 (dated October 2,1995) and 4 (dated May 13,1996), step F.1, require, in part, that the Lead Unit Planner with the assistance of the Lead Maintenance i

Planner screen Action Requests to determine if the Action Request is minor. Step F.1.a defines an Action Request on safety-related equipment as minor when the work activity is

] limited to packing adjustments, valve handle replacement, tightening of threaded i

connections, walkdown inspections and troubleshooting which will not effect the safety- l related function for any systems or components.  !

a. Contrary to the above, on December 12,1995, an activity affecting quality  !

was not accomplished in accordance with LAP 300-37 in that the screening of I the Action Request AR950063168 for the sealing of cracks in the safety-related Lake Screen House, pedormed by the Lead Unit Planner and the {

Lead Maintenance Planner, failed to determine that the work was not " minor maintenance." (01012)

b. Contrary to the above, between May 21,1996, and June 20,1996, an activity affecting quality involving safety related work performed by a Comed contractor, repair of cracks in the Lake Screen House, was performed without documented instructions, procedures, and drawings appropriate for the l activity. (01022)

ADMISSION OF THE ALLEGED VIOLATION LaSalle County acknowledges that the screening of the A.ction Request (AR) failed to determine that the work was not " minor maintenance" and that repair of cracks in the Lake i Screen House was performed without documented instructions or procedures. I REASON FOR VIOLATION - 373/374-96009-1.A.1.a-b The crack repair was initiated as an AR. The AR paperwork did not provide adequate control and the process of screening lacked the engineering involvement to assure that structures were assigned the correct safety classification and appropriate repair technique.

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I The sealant work being performed was considered "F :llity" repairs and inappropriately assumed to be non-intrusive. The contractor worker ore using " craft capability" to perform the sealant work, no work package was generated for the work. There was no formal control on the contractor, their process, or repair implementation. This resulted from '

not placing limits on the work and an inadequate review and approval of the contractor's injection procedure.

3 CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The backlog of Action Requests (AR) was reviewed by Engineering for safety significance.

Approximately 47 ARs were placed on hold and then reclassified. Engineering reviewed work performed by Consolidated Facilities Maintenance (CFM) under ARs and concluded I g that no work compromised safety.

The Site process for Action Request screening, LAP-1300-1, " Action / Work Request Processing," was revised in July,1996, to require a multi-discipline review team and engineering review of structural repairs.

Specific guidance was established on what work was appropriate for assignment to CFM.

Maintenance Memo No. 200-14, Control of Consolidated Facilities Maintenance Work Activities" was issued on July 12,1996, which delineates the work to be performed by CFM l

. and methods by which that work is to be controlled. This Memo has been deleted and ,

3 incorporated into two common Comed procedures NSWP-WM-06," Minor Maintenance  !

Process" and NSWP-WM-07, " Facilities Maintenance". These procedures are described i

more fully below. i We also identified that routine work in the power block, performed under Blanket Work Requests, could result in work being performed that had not been adequately screened.

We have discontinued use of Blanket Work Requests for performing routine work. These activities are now performed under procedure LAP-300-41 " Pre-Reviewed Work Requests".

The pre-reviewed Work Requests are screened and contain specific work instructions for each activity. l An Engineering Policy on Sealant Work was instituted. This policy is the basis for revisions to LAP-240-6, " Temporary Alterations", LAP-1300-1, " Action / Work Request Processing" and Maintenance Memo No. 600-04," Guide to Dealing With Furmanite". The revisions l

outline specific requirements for structural and sealant repairs to plant buildings and equipment.

As part of AR screening, any proposed structural repair will require engineering review. To help in structure identification, we have updated design drawings to clearly identify safety-related/ seismic structures and have developed a Q-List for safety-related/ seismic structures.

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l CORRECTIVE ACTONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS A common procedere for screening Action Requests, NSWP-WM-08," Action Request Screening Process", has been approved by the six Comed Sites and has been implemented at LaSalle. This procedure in conjunction with an upgraded site work control procedure provide consistent formal criteria for classification, and accurate assignment of work. Post implementation assessments have been conducted to verify the effective implementation of this screening process.

To assure that work is adequately controlled, the six Comed Sites have developed two common procedures NSWP-WM-06," Minor Maintenance Process" and NSWP-WM-07,

" Facilities Maintenance". These procedures, in conjunction with the new Action Request screening process will help to ensure that work is accurately assigned and that work instructions appropriate to the activity are provided to the worker (s). LaSalle has implemented these procedures and conducted an initial implementation assessment on February 7,1997.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved in July 1996 with revision to LAP-1300-1, and the issuance of Maintenance Meme 200-14. We recognize that we continue to encounter unacceptable performance in effectively correcting our problems. We will be performing ongoing effectiveness reviews of the implementation of our corrective actions during 1997.

VIOLATION - 373/374-96009-1.A.2.a-b-c 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected, in the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, on June 19,1996, and continuing until July 5,1996, Comed failed to promptly identify and evaluate a significant condition adverse to quality, specifically the injection of foam sealant materialinto the service water tunnel. The injection of the sealant material was a significant condition adverse to quality because the activity introduced debris into the senrice water tunnel that challenged the functionality of the non-essential and safety-related service water systems because both systems took suction from the service water tunnel. The licensee failed to identify and correct the condition, as evidenced by the following examples:

a. On June 19,1996, following the determination that all three non-essential service water strainers were fouled, the licensee incorrectly determined that the fouling was caused by corn cob material used in sandblasting the exterior of the lake screen house when, in fact, the fouling occurred from foam sealant material.

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b. On Juna 24,1996, following a second occurrence of fouling of the non-essential service water strainers and fouling of the diesel-driven fire pump strainers and having recognized that the source of the fouling was foam sealant material, the licensee inconectly determined that the physical  ;

properties of the foam sealant material would not continue to place the service water systems in jeopardy, (i.e., the foam sealant material was aEached to the ceiling of the service water tunnel or was buoyant). _ In fact, L the sealant material, was not buoyant and was later identified on the bottom of the service water tunnel in close proximity to the safety-related service l

water intake resulting in a significant condition adverse to quality created by j the material presenting the potential for uptake into and fouling of the t l safety-related service water system.

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c. On June 28,1996, following the discovery by divers that a significant quantity l of foam sealant material was near the bottom of the service water intake tunnel, in close proximity to safety-related service water systems, the licensee ,

incorrectly determined that foam sealant material would not challenge the functionality of the service water systems. (01032)

ADMISSION OF THE ALLEGED VIOLATION LaSaile County acknowledges that our identification, evaluation and resolution of the issues surrounding the injection of foam sealant material into the :,ervice water tunnel was neither timely nor adequate.

REASON FOR VIOLATION - 373/374-96009-1.A.2.a-b-c The site response to the event revealed weak management safety focus, both in the failure to identify and evaluate significant conditions adverse to quality and in the Site management of the event once identified.

Once the sealant was injected, LaSalle Station failed to recognize several precursors which provided indication of the foreign material intrusion. An Instrument Maintenance technician discovered foreign material in a radiation monitor associated with the service water system,-

but the Station did not evaluate the source and potential impact. An engineer incorrectly diagnosed a temperature control valve on the service water system that was blocked by foreign material. Operations and engineering personnel did not correctly determine the

. cause of service water strainer plugging. After a second service water strainer plugging event, the Station correctly identified the source of the foreign material intrusion.

i Our Problem Identification process, or PlF process, was ineffective. Our PlFs were " pre-screened" to improve the efficiency of the screening meetings. We found that this screening forum diminished the active discussion on the event and limited the opportunity l to link it to previous or similar events. This event also demonstrated that Senior Plant Managers were not always directly involved in the daily discussion of plant events.

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.- i I .* l LaSalle management failed to proactively control the event response. We initially misjudged the event's significance and permitted the event to evolve rather than  ;

- aggressively establishing the facts, evaluating response options, and taking effective action l

to contain the event. Compounding this event, management's focus was on keeping the units online.

The Station performed operability assessments that did not correctly identify the potential i significance of the condition. The Station did not critically challenge the assumptions made

to justify continued operability of the essential service water systems, or the potential l impact of the event on non-essential service water.

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Engineering was not effectively involved in the work planning and review, or in the event

- response. Initially there was an error in the safety classification of the lake screen house and service water tunnel; this resulted from a lack of knowledge with respect to safety-

[ related and seismic category 1 structures on the part of the engineering staff. The j investigation into the extent of the problem by operations and engineering was weak and i untimely. Initial corrective actions were not adequate, leading to untimely problem correction.

l l CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED

! 1. For Site Response to events: ,

I Senior Management has communicated with the organization, through I

[ various forums, the nature of the Service Water event, the significance of the j event and behavior changes required by each of us. We also placed great l j emphasis on safety as our priority over production. 1 Since then, extensive changes in management personnel have been made.

l LaSalle has brought in a number of industry proven personnel to lead the j LaSalle improvement effort including: Plant General Manager; Unit 1 Plant i j Manager; Site Engineering Manager; Outage Manager; Units 1 and 2 '

i-Maintenance Superintendents; Safety Assessment Manager; Corrective Action Manager and SOV Director. ,

! LAP-100-54 " Event Response Guideline," was developed and implemented

! to ensure appropriate Senior Management focus to significant plant events i and help to ensure proper resources are dedicated to the recovery efforts

! and to the root cause determination.

2. For Event Screening:

The Event Screenir;g Committee was upgraded to include the Station

Manager and the Operations, Maintenance, Work Control, and Engineering i managers. Each event is examined for significance and determination of

. immediate actions required. This provides senior management a direct 5

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l. connection to the events occurring at LaSalle. Benefits include (1) senior i management actively participate in discussions of issues and greater

- involvement with our staff who are dealing with those issues, (2) teamwork is j demonstrated and practiced, and (3) it is the initiating step for escalation of j- an issue and how management will work toward resolution of the problem.

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3. For Engineering involvement:

The Action Request (AR) screening process has been upgraded for work l classification and assignment. A Senior Reactor Operator (SRO) now leads .,

l a collegial review meeting which includes operations, maintenance, and i engineering. This review verifies that ARs contain adequate information, address facility impact, properly classify work, indicate task priority, and are appropriately assigned. As part of this screening, proposed structural repair now requires engineering review. To help in structure identification, we have updated design drawings to identify safety-related/ seismic structures and j have developed a Q-List for safety-related/ seismic structures.

. Roles and responsibilities were clarified. Operations Department has overall responsibility to determine Operability. Engineering advises Operations and

). performs the engineering analyses that support the operability decision.

f Engineering formed an independent review group to review the Engineering analyses that provide input to operability determinations. This team reviewed i- operability assessments performed since May 1996 and found no other l

significant discrepancies. Continuing review of operability determinations has l been made a part of the Engineering Assurance Group activities.  !

In ' July and September 1996, training was provided by Corporate En~gineering on the regulatory fundamentals of 10 CFR 50.59 Safety Reviews and  ;

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Operability Assessments. The training, attended by 114 people primarily from the engineering area, provided an overview of how these documents are used to ensure compliance with the licensing basis.

On November 27,1996, eighteen members of the Plant Operations Review Committee (PORC) received similar training with additional focus on their role as PORC members.

During the fourth quarter 1996, engineering support personnel and licensed operators received additional training on LAP-220-5 " Equipment Operability Determination."

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CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS

1. For Site Response to events:

LAP-100-54, " Event Response Guideline," is currently in effect. The six

, Comed Sites have developed a common procedure NSWP-A-07 " Event j Response Guidelines". The procedure provides guidance on an event

response process which strengthens and formalizes recovery, repair, and

root cause activities in response to significant plant events. This procedure

will be implemented at LaSalle by May 10,1997 and will replace LAP-100-54 l " Event Response Guideline."

2. For Event Screening:

The six Comed Sites have developed a common procedure NSWP-A-15

" Comed Nuclear Division Integrated Reporting Program." The procedure requires the Event Screening Committee to include Operations, Maintenance /Ouality Control, Engineering, and Committee Leader designated by the Station Manager. This procedure will be implemented at

! LaSalle by May 10,1997.

j 3. For Engineering involvement:

An Engineering Assurance Group (EAG) has been established and is  ;

comprised of senior industry-experienced and plant-experienced personnel.

l The EAG provides line review of important engineering products including safety evaluations, operability assessments and others. The EAG also uses

, these reviews as a method of mentoring engineers and the engineering j j organization with the objective of improving technical capabilities and the l l quality of engineering products. l i- As part of the LaSalle Upgraded 1996 Operational Plan, Engineering

implemented improvements in communication interfaces between i Engineering and Operations, Maintenance, and Work Control. Improved Engineering management tools were also developed. Engineering I- management continues to upgrade engineering department capability as reflected in action plans to restart the LaSalle units.

a For Operability Evaluations:

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The Independent Safety Review Overview Group was formalized in LAP-220-5 " Equipment Operability Determination" (Rev. 4,9/96). A member j of this Group reviews all operability assessments for concurrence.

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, DATE WHEN FULL COMPLIANCE WiLL BE ACHIEVED Corrective actions taken address specific examples for this violation. We are currently in compliance. We recognize that we continue to encounter unacceptable performance in effectively correcting our problems. We will be performing ongoing effectiveness reviews of the implementation of our corrective actions during 1997.

VIOLATION - 373/374-96009-l.B.1.a-e 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

requires, in part, that activities affecting quality be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Technical Specification 6.2 requires that the written procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be established, implemented, and maintained. Regulatory Guide 1.33, Appendix A, recommends procedures be established for the Authorities and Responsibilities for Safe Operation and Shutdown and for the operation of the Service Water System.

Contrary to the above:

a. On July 9,1996, an activity affecting quality, safety-related testing on the diesel generator cooling water strainer backwash lines to determinc system flow rates, was performed without the use of dxamented instructions, i prxadures and drawings appropriate for the activity,

b. As of August 20,1995, an activity affecting quality, inspecting and cleaning of both 10 and 40 basket Emergency Core Cooling Water System (ECCS) service water strainers, was inappropriate to the circumstances in that LaSalle Maintenance Procedure LMP-GM-25, "ECCS Service Water Strainer Maintenance," Revision 2, did not address the differences between the two strainers, including the differences in the length of the drive shafts. (This resulted in the discovery on July 14,1996, of a drive shaft for a 10 basket strainer installed in a 40 basket strainer in a Unit 2 Residual Heat Removal service water system strainer D300B.)

c. As of August 20,1996, Normal Operating Procedure LOP-DG-04, Revision 18, " Diesel Generator Special Operations," w activity affecting quality, was found inappropriate to the circumstances in that it did not contain ,

the necessary instructions for manual backwashing of the diesel generator service water system strainers.

c. As of August 20,1996, Normal Operating Procedure LOP-RH-14, Revision 4,

" Backwash of the Residual Heat Removal Service Water Strainers," an activity affecting quality, was found inappropriate to the circumstances in that it did not contain the necessary instructions for manual backwashing of the Residual Heat Removal system strainers.

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e. As of August 20,1996, Normal Operating Procedure LOP-WS-05, l Revision 3, " Service Water Strainer Operations," a Technical Specification required procedure, was not appropriately maintained in that it did not contain the necessary instructions to allow for backwashing of the non-essential l service water strainers. (02013) l ADMISSION OF THE ALLEGED VIOLATION LaSalle Station acknowledges the failure to perform work without use of appropriate or complete inst .:tions, procedures and/or drawings to implement backwashing and 2

maintenance of cooling systems.

REASON FOR THE VIOLATION l

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in example a, a procedure did not exist to determine the flowrates on the diesel generator 1

cooling water strainer backwash lines. Additionally, the test was not documented.

in examples b, c, d, and e, procedures did exist but were not adequate to support the needed backwashing efforts ( manual backwashing for diesel generator cooling water, residual heat removal service watsr, and the non-essential service water strainers) .  !

j CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Specific to the event, procedures, LOP-DG-04 and LOP-WS-05 were replaced with temporary procedures in July 1996. These temporary procedures provided the necessary

instructions to perform a manual backwash on the DG cooling water strainers and the non-essential service water strainers. Since then, permanent revisions have been completed for procedures LOP-DG-04, " Diesel Generator Special Operations", LOP-RH-14,

" Backwash of the Residual Heat Removal Service Water Strainers", and LOP-WS-05, l

" Service Water Strainer Operations". These procedures now includs necessary instructions needed to perform manual backwashing.

The non-essential service water procedure, LOP-WS-05, was revised to include diagnostic steps to assist the operator to evaluate strainer operation and to provide instructions for manual backwash. The previous procedure was deficient because it did not provide adequate information to detect the failure of automatic backwash nor did it provide instructions for the proper backwash methodology based on the strainer condition, especially the dP across the strainer. The current revision corrects those deficiencies.

The procedures for DG cooling water and RHR service water strainers, LOP-DG-04 and LOP-RH-14, did not contain specific instructions for the proper placement of the manual backwash handle nor diu they provide adequate instructions for manual operation of the backwash outlet valve. LOP-DG-04 also did not provide adequate instructions for manual positioning of the outlet valve to maintain adequate flow to ECCS area coolers during manual backwash. The current revisions correct those deficiencies.

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CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS l

Three testing procedures have been developed and subsequently implemented to determine system flow rates for the diesel generator cooling water strainer backwash lines:

LST 96-042, " Determining Division 1 Cooling Water Strainer Backwash Valve Position,"

LST 96-043, " Determining Division 2 Cooling Water Strainer Backwash Valve Position,"

and LST 96-044, " Determining Division 3 Cooling Water Strainer Backwash Valve Position" which were issued on July 10-12,1996.

An intemal assessment of the event determined that the alarm response procedures and phnormal procedure utilized during the event also required improvement. The abnormal icedure, LOA-WS-01," Loss of Service of Water", was already being improved as part of  !

tne Operating Procedure Upgrade project. The old procedure only provided directions for a 1 total loss of non-essential service water whereas the new, unit specific abnormal  !

procedures provide directions for response to degraded non-essential service water events as well as for a total loss of non-essential service water. Similar improvements have been made to most abnormal procedures as a result of this Upgrade Project. The Operating Procedure Upgrade Project is ongoing. Currently there are fifteen dedicated procedure writers supporting this Project. The project is now focusing on alarm response, normal operating, and surveillance procedures.

The alarm response procedures were deficient because they did not provide adequate l diagnostic information to the operator to evaluate the operation of the non-essential service water strainer nor did they direct the operator to the abnormal procedure. The current revisions have corrected these deficiencies. i l

Maintenance procedures for electrical, mechanical, and instrument maintenance '

disciplines are being upgraded. Currently, there are 9 dedicated procedure writers supporting the Upgrade project.

LaSalle Management has been aggressive in communicating and reinforcing expectations  ;

for procedural adherence. A significant part of this effort was the station work stand down that took place on October 14,1996. Also, as ment 5ned ea;1ier, procedural adherence is one of the fundamentals of each individual's contribution to LaSalle improvement. Our l efforts have seen some success in that work has slowed as personnel work strictly to the i procedure and the number of procedures that have been referred to the procedure writers for correction or enhancement has increased. But we must be diligent in our implementation of procedures. We realize that we have significant work ahead of us. '

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l Corrective actions taken address specific examples for this violation.

Full ccmpliance was achieved when the testing procedures were issued in July 1996. For the remaining maintenance and operations procedures, compliance was achieved in l

September 1996.

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VIOLATION - 373/374-96009-l.B.2.a-b 10 CFR 50.59, " Changes, Tests and Experiments," paragraph (a), requires, in part, that a licensee may make changes in the facility as described in the safety analysis report, without prior Commission approval, unless the proposed change involves a change in the i

technical specification incorporated in the licence or an unreviewed safety question.

Records of changes must include a written safety evaluation which provides the bases for the determination that the change does not involve a unreviewed safety question.

, The Core Standby Cooling System (CSCS) is described in Section 9.2.1 of the UFSAR.

Section 9.2.1.2 states that the backwash cycle requires 250 gpm at 20 psid.

Section 9.2.2.2 states that a 1/16" mesh is installed in the non-essential service water strainers.

Contrary to the above:

a. As of August 20,1996, a written safety evaluation to provide the bases for a determination that a change to the facility did not involve an unreviewed safety question was not performed for a change to the facility involving the discovery on July 13,1996, that the backwash flow of the 0,1 A and 2A diesel generator cooling water strainers, a part of the CSCS Equipment Cooling Water System, was determined to be approximately 22 gpm, significantly less than the 250 gpm described in Section 9.2.1.2 of the UFSAR.  ;

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b. As of August 20,1996, a written safety evaluation to provide the bases for a j determination that a change to the facility did not involve an unreviewed safety question was not performed for a change to the facility involving the discovery, on June 27,1996, that the non-essential service water strainers were installed with a 1/8" mesh instead of the 1/16" mesh described in Section 9.2.2.2 of the UFSAR. (02023)

ADMISSION OF THE ALLEGED VIOLATION LaSalle acknowledges that, at the time of the event, safety evaluations had not been performed to address the changes. As a note of clarification, prior to August 20,1996, both items had been resolved. Specifically, the backwash flow through tne diesel generator cooling system was increased and verified to be 250 gpm prior to July 11.1996.

Likewise, on July 5,1996, a safety evaluation was performed to change the UFSAR and justify the non-essential service water strainers being installed with a 1/8" mesh instead of the 1/16" mesh. Thus both items were resolved prior to August 20,1996.

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r REASON FOR THE VIOLATION Violation 373/374-96009-l.B.2.a - In July 1996, the Site identified that the backwash flow in the 0,1 A and 2A diesel generator cooling water strainers had been reduced to less than i the 250 gpm required by Section 9.2.1.2 of the UFSAR. There was no evidence that a 10 CFR 50.59 safety evaluation or screening was performed during the period of time that the plant was operated with this change from the description in the FSAR. The backwash i flow was not required to be tested as part of startup testing. As such, we did not recognize degraded system performance and the need to perform an evaluation. j Violation 373/374-96009-l.B.2.b - The NRC noted that the UFSAR specified the size of the non-essential service water strainers as 1/16". Discussions with LaSalle personnel indicated that the strainer size was 1/8". No safety evaluation or screening had been j performed on this change. The plant had operated out of compliance with the UFSAR in l this area since the start of plant operations.

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The original specification for purchasing service water strainers called for strainer elements with openings equivalent to no greater than 3/16" diameter. The actual strainer supplied has 1/8" slotted openings, which are typical for this type of strainer application. During the l original bid evaluation, this size was assessed, judged to be acceptable, and a bid award made for the installed design. However, the UFSAR was never updated to reflect the purchased and installed mesh.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED l i

Violation 373/374-96009-l.B.2.a - Since the backwash strainer piping does not have flow elements installed, Test Procedures were developed and implemented to measure backwash flow and balance the system. The backwash MOV's were reset to the open travel established by the tests on or before July 11,1996. The MOV Setpoint Binder has been updated in accordance with LAP 300-35, " Motor Operated Valve Setpoint Binder Administrative Control Procedure". Additionally, a note in the binder requires that the flow test be repeated as part of any post-maintenance testing for internal valve work. Also, a note on the electrical schematics will be added stating that the valves should not be opened to 100% and that the MOV setpoint binder should be referenced to determine tho  !

proper setpoint.

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Violation 373/374-96009-l.B.2.b - A review of all system components in the flow path was initiated. This included heat exchangers, int,trument lines and control valves. The only item found which had a smaller opening than the strainer is one control valve on the Unit 2 Turbine Building Closed Cooling Work System. This valve is provided with a full flow capacity bypass line which can be opened by the operators if needed. The control valve plugging phenomenon is typically slow to develop, thus operators have a long period of time in which to open this bypass line. Engineering is currently evaluating modifying or replacing this valve to eliminate the potential plugging concern. The conclusion of the review was that the existing strainer mesh size of 1/8" is acceptable and the service water  ;

system has the capability to handle the size of material which will pass through it.

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s .

A 10 CFR 50.59 evaluation was performed which concluded that there was no unreviewod  ;

safety question associated with the 1/8" strainer size. An update to the UFSAR was  !

approved on July 5,1996, to change the identified strainer size to 1/8" slotted type. The I change is currently pending incorporation in the next UFSAR revision.

i CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATION 3 i

The UFSAR is currently undergoing a comprehensive review. We have reviewed UFSAR chapters 6,7,8,9 and 10 from an operational perspective. Concerns have been identified and are in various stages of evaluation and resolution. Based on this review, we recognized that to better identify potential unreviewed issues, we would expand our UFSAR review to include the perspective of design, maintenance, accident analysis, and technical programs. The January 30,1997 letter from T. Maiman to A. Beach, " Comed Plan for Upgrading the Quality and Access to Design Information at all Six Nuclear i Stations", describes Comed's (and LaSalle's) planned actions. The actions address three {

broad categories of design information: Design Basis Document Manuals, Critical Calculation Information, and UFSAR Validation.  !

We are performing functional performance reviews of systems important to safe and reliable operations to identify any deficiencies that may need correction prior to startup. 1 These reviews include comparing functional performance to the Design Basis. We have i essentially completed five of these reviews and are expanding the scope of the reviews as l needed, depending on conditions found. The final scope may include as many as 28 reviews encompassing selected portions of about 41 systems on each unit. Risk significance is a key factor in selecting these systems. This effort will also include selected functional testing of these systems to confirm performance capabilities. As issues are identified in the Safety System Functional Inspections, the UFSAR will be updated as necessary.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED e

Violation 373/374-96009-l.B.2.a_ - Full compliance was achieved when the backwash flows were verified to be 250 gpm on July 11,1996.

Violation 373/374-96009-l.B.2.b - Full compliance was achieved on July 5,1996, when a safety evaluation was performed to change the UFSAR and justify the non-essential service water strainers being installed with a 1/8' mesh instead of the 1/16" mesh.

VIOLATION - 373/374-96009-II.A (Violation Not Assessed a Civil Penalty) 10 CFR Part 50, Appendix B, Criterion XVil, " Quality Assurance Records," requires, in part, that sufficient records be maintained to fumish evidence of activities affecting quality.

Inspection and test records shall, as a minimum, identify the inspector, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.

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Contrary to the abeve, records were not maintained to furnish evidence of activities affecting quality for the work performed on the Unit 2 residual heat removal service water i strainer D300A on July 6 and 12, and on Unit 2 residual heat removal service water strainer D3008 on July 12,1996, in that the records did not identify the inspector, the results, or the action taken in connection with the deficiencies noted. (03014)

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

REASON FOR THE VIOLATION LaSalle Station acknowledges the failure to furnish evidence of activities affecting quality which included inspection and test records based on 10 CFR 50, Appendix B, Criterion XVil.

4 Work package administrative controls were not properly implemented which resulted in work packages being signed-off as completed when they were not. The work packages did not contain the information (e.g. inspector, results, or action taken) required in order to ensure proper quality records. ,

l Contributing factors include improper procedure adherence, implementation of quality {

records process, work control process, poor pre-job briefing, quality control, and  !

inappropriate supervision of work package implementation. l CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED On August 20,1996, the applicable work packages (960064167 01,960064400 01, and 960064357 01), which involved the cleaning and inspection of RHR service water strainers '

2E12-D300A and 2E12-D3008, were updated to reflect the appropriate methods and results of the inspections performed. Additionally, other work packages were also reviewed to ensure complete documentation.

CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS l aSalle Station Procedure, LAP 1300-1, " Action / Work Request Processing", has been revised to state the documentation requirements which include the "as found" conditlon,

" work performed", and the "as left" condition within work packages. Work control, engineering and quality control supervision have reviewed the expectations of package completion to prevent this from recurring.

Procedure LMP-GM-25 has been revised to require that supporting inspection criteria be include as a part of the completed work package documentation.

Pre-job briefings are routinely used as a forum to communicate to workers and supervisors the need to provide quality documentation of work and to comply with applicable procedures.

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LaSalle Station initiated the LaSalle Maintenance Procedure Upgrade Project during 1996.

This project is planned to be completed by January 1999 with the intent of the upgrade focusing on the improvement of maintenance procedures and processes. To date, many process related procedures, such as the Nuclear Work Request (NWR) procedure, has been developed and implemented which includes a multidisciplinary review to evaluate work packages.

Engineering and maintenance personnel are now participating in the Action Request screening process to ensure that work is rigorously reviewed, accurately assigned and that work instructions appropriate to the activity are provided to the worker (s).

Quality Control (OC) has established criteria and performed training on the role of QC to ensure independent and thorough evaluation of work processes as well as ensuring that quality assurance records are retained which meet or exceed the minimum requirements of Appendix B, Criteria XVil. A Problem Identification Form (PIF) and Deviation Report (DR) hsve been issued based on this evolution.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED i i

Full compliance was achieved on August 20,1996, with the update of the applicable work packages.

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