ML20137B307

Responds to NRC Re Violations Noted in Insp Repts 50-373/96-18 & 50-374/96-18.Corrective Actions:Procedure Use & Adherence Expectations procedure,LAP-100-40 Was Clarified

ML20137B307
Person / Time
Site:	LaSalle
Issue date:	03/13/1997
From:	Subalusky W COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9703210273
Download: ML20137B307 (3)

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March 13,1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

NOTICE OF VIOLATION; NRC INSPECTION REPORT 50-373/96018

Reference:

M. N. Leach letter to W. T. Subalusky, dated February 13,1997, Transmitting NRC Inspection Report 373/374 96018 .

The enclosed attachment contains LaSalle County Station's response to the Notice of Violation, that was transmitted in the Reference letter. .

I If there are any questions or comments conceming this letter, please refer them to me at (815) 357-6761, extension 3600.

Respectfully, f ..

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W. T. Subalusky Site Vice President LaSalle County Station Enclosure l cc: A. B. Beach, NRC Region lli Administrator l M. P. Huber, NRC Senior Resident inspector - LaSalle l D. M. Skay, Project Manager - NRR - LaSalle i i e * ~ ". * ~ ,

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s ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-96018 1

VIOLATION: 373/96018-02 During an NRC inspection conducted on October 26 through December 13,1996, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 6.2.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 procedure adherence, use, and temporary change methods.

LaSalle Administrative Procedure 100-40," Procedure Use and Adherence Expectations,"

Revision 6, requires that procedures identified as " Reference Use" be available at the work location for periodic reference to confirm that all procedure steps have been performed and to document steps as required.

Contrary to the above, on November 26,1996, the operator performing LaSalle Operating Surveillance DG-02, "1 A DG [ diesel generator] Auxiliaries," at the emergency diesel generator cooling water pump, did not have a copy of the surveillance procedure, which was identified as " Reference Use," at the work location.

This is a Severity L evel IV violation (Supplement I) (50-373/96018-02).

REASON FOR VIOLATION: 373/96018-02 Our review of this activity identified that the operators performed the surveillance within the requirements of LAP-100-40, Rev. 6, Procedure Use and Adherence Expectations, however, we identified a deficiency in LAP-100-40. The deficiency is that the procedure did not clearly specify the responsibility of a remote worker as to whether the procedure was to be at the work location for reference use when steps were communicated to the worker by the procedure user.

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The operator performing local operations did not have a copy of the procedure and, per l LAP-100-40, was not required to have a copy. The Control Room operator communicated actions to the local operator worker via the telephone system. The Control Room operator  !

had a copy of the surveillance. Other actions were communicated to the local operator by  ;

another operator located in a room above the diesel generator cooling water pump room. l The operator in the room above the diesel generator cooling water pump room had the i procedure and used it to direct the actions of the surveillance. During the performance of the surveillance, no steps were missed and all data required to complete the surveillance was obtained.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:

On January 14,1997, the Procedure Use and Adherence Expectations procedure, LAP-100-40 was clarified. Step B.3.7 was revised to state that when procedure steps are communicated to the performer by the procedure user, the performer is not required to have the procedure at the work location. This is consistent with previous expectations of procedure use.

CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS:

i Shift Manager's and other manager's plant walkdowns include observations for procedural l adherence. Plant activities are reviewed to verify that procedures are in-hand or at the work location as appropriate.

In reviewing this issue, we identified a need to review again, procedures for their level of use. We have established a criteria for assigning the level of use for procedures.

Operating procedures will be reviewed against the criteria to verify or change the level of use as appropriate. This review will be completed by May 1,1997.

Other site procedures will be reviewed against the criteria to verify or change the level of use as appropriate. This review will be completed by August 28,1997.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Compliance was achieved on January 14,1997, when LAP-100-40 was revised.

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