IR 05000373/1980041
| ML19347C616 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/21/1980 |
| From: | Bournia A, Jackiw I, Rivenbark G, Spessard R, Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19347C615 | List: |
| References | |
| 50-373-80-41, NUDOCS 8012310470 | |
| Download: ML19347C616 (12) | |
Text
.
D
'
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-373/80-41 Docket No. 50-373 License No. CPPR-99 Licensee: Commonwealth Edison Company Post Office Box 767
,
Chicago, IL 60690 Facility Name:
LaSalle County Nuclear Station, Unit 1 Inspection At:
LaSalle Site, Marseilles, IL Inspection Conducted:
September 8 -11, 1980
'E', Ai, < za,.,-i Inspectors:
R. D. Walker ;,,.
/c - 2 / -M whr 7-
. c-
~1.N.'$cackiw 8 W~/d b
R. L. Spessard
'* R l A a a + e.. +._
f G. W. Ridenbark f,
/ c' - 3 / - D
"R,( A v -6a A.
A. Bouriiia L s c
.4 - /7
' ?if*.knu >+.--/.
.
Approved By:
R.~L. Spessard, Chief
~ * F2 Projects Section 1 Inspection Summary Inspection on September 8-11, 1980 (Report No. 50-373/80-41)
Areas Inspected: This special, announced inspection involved 164 inspector-hours onsite in the areas of Onsite Staff Organization and Management.;
Independent Safety' Engineering Group; Shift Technical Advisor; Shift Manning and Overtime Restrictions; Shift Supervisor Duties and Responsibility; Shift Relief and Turnover Procedures, Control Room Access, and Operating Experience Feedback.
Results: No items of noncompliance were identified.
!
,
8012310 4 70
.
. -.
._
. _.
..
.
_
.
.
.-
_
.
_ __
.
.
.
DETAILS
1.
Persons Contacted
- F.
A. Palmer, Division Vice President Nuclear. Stations
- R. E. Jortberg, Director of Nuclear Safety
- R. D. Bishop, Technical Staff Supervisor
- C. W. Schroeder, Assistant Technical Supervisor
- R. H. Holyoak, Superintendent LaSalle County Station
- G.
J. Diederich, Assirtant Superintendent
- L. O. DelGeorge, Licensing Administrator
- J.
R. Kodrick, Staff Engineer Maintenance
- P.
F. Manning, Quality Control Supervisor
- P. G. Kuhel, Offsite Review /LaSalle County Station B. B. Stephenson, LaSalle County Station Project Manager J. Mcdonald, Training Supervisor The inspectors also interviewed other licensee employees including members of the technical, operating, maintenance, and personnel staffs.
- Denotes persons present at management interview onsite.
2.
Purpose of Inspection
The purpose of this inspection was to evaluate the LaSalle County Station organization and management capabilities preceding license issuance in accordance with NUREG-0694, THI-Related Requirements for New Operating Licenses." The review was based on an NRC document entitled " Draft Criteria for Utility Management and Technical Compe-tence," dated July 17, 1980.
These draft criteria address the organization, resources, training, and qualifications of plant staff, and management both onsite and offsite for routine operations and the resources and activities both onsite and offsite for accident conditions.
The licensee's offsite management resources and capabilities had been inspected on May 13-14, 1980, during a special inspection conducted at the Commonwealth Edison Company Corporate Office in Chicago, Illinois and, therefore, were not included in the scope of this inspection. Refer to IE Inspection Report No. 50-295/80-10 and 50-304/80-10.
3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Onsite Staff Organization and Management The objective of this part of the inspection was to review the manage-ment and technical capability of the LaSalle County Station Staff.
,
-2-
.
_
_
..
__
._
...
,_
. _ -
.
.
.
.
In performing this task, a review was conducted of the plant staff
.
organizational arrangement, responsibility, authority, and qualifica-tions of plant staff principal personnel.
In evaluating the adequacy of the LSCS staff, NRC members met and held discussions with members of the plant and members of the corporate office. The information presented here is based on record reviews, oral discussions, and information that has been formally submitted to the NRC by CECO.
a.
Documents Reviewed (1) " Draft Criteria for Utility Management and Technical Com-petence," dated July 17, 1980.
(2) Qualification records of plant personnel.
(3) ANS 3.1, " Standard for Qualification and Training of Personnel for Nuclear Power Plants" (Draft - 1979).
b.
Findings LaSalle County Station is managed by Mr. R. H. Holyoak, Station Superintendent, who is responsible for direct management of the station including compliance with the NRC operating license, government regulations, ASME Code requirements and the Company Quality Assurance Program. He also supervises the stations on-site review function as specified in the Technical Specifications.
Reporting to the Station Superintendent are the Maintenance Assistant Superintendent, Administrative and Support Services Assistant Superintendent, Operating Assistant Superintendent and the Personnel Administrator. They are responsible for the day-to-day operating, maintenance, and refueling activities of the station.
The LSCS-FSAR and the Technical Specifications state that the qualifications of the plant staff will meet the requirents of ANSI N18.1, 1971.
In conducting this portion of the inspection, the inspectors reviewed a number of qualification records of plant personnel to verify that they meet the requirements of ANSI N18.1 - 1971 and also the requirements of draft ANSI /ANS 3.1 4979 provided in the NRC document " Criteria for Utility Management and Technical Competence" dated July 17, 1980. Of the individuals reviewed, the inspectors noted that one individual did not meet the experience requirements of ANSI N18.1, 1971 for the position - Supervisors Not Requiring NRC License-Radiochemistry.
Also, from the qualification records reviewed, the inspectors were unable 'to determine that a number of individuals that would fill positions in the onsite emergency organization (i.e. main-tenance manager, operations manager, etc.) met the education requirements of draft ANSI /ANS 3.1 - 1979.
,
-3-
..
.
-_ _
_,-
--,
.
During the exit interview on September 11, 1980, the licensee stated
-
that they would address the qualificati;ns of personnel that would fill positions in the onsite emerge % y organization in the response to NUREG-0694. This item will bc reviewed during a NRC followup inspection (373/80-41-01). W h regard to the individual that does not meet the requirements of ANSI N18.1 - 1971, the licensee stated that the individual would be qualified or the licensee would select another in'dividual to fill that position. This item will also be reviewed during a NRC followup inspection (373/80-41-02).
With regard to the Radiolcgical Protection Organization and the review of the Emergency Plan Implementing Procedures, these items will be inspected during routine NRC inspections prior to fuel load (373/80-41-03).
The licensee informed the inspectors that a number of significant organizational changes had taken place both at the LSCS and in the CECO Corporate Office since Ceco's last submitted organizational information. The inspectors requested that CECO document these changes in a submittal to the NRC.
No items of noncompliance were identified in this area.
5.
Independent Safety Engineering Group (ISEG)
The objective of this portion of the inspection was to determine that the licensee has established or plans to establish an onsite safety engineering group independent of the plant staff to perform independent reviews of plant operational activities, evaluate the technical adequacy of procedures and changes important to safe operation of the facility, and evaluate and assess the plant's operating experience and performance.
a.
Document Reviewed (1) " Draft Criteria for Utility Management and Technical Competence,"
dated July 17, 1980.
(2) SECY-80-242, " Independent Safety Engineering Group (ISEG)."
b.
Findings On September 11, 1980, discussions were held with Commonwealth Edison corporate personnel to discuss their plans regarding the establishment of an independent onsite safety engineering group.
CECO intends to establish this group in their corporate office.
This group would be composed of two sections, a BWR section and a PWR section, and would be a part of a new offsite organization callcd the Nuclear Safety Organization.
This organization is headed by Mr. R. Jortberg who will report to the Ceco President.
,
-4-
_
.
CECO is considering assigning two or more engineers onsite at
-
each plant with possibly five additional engineers located at the corporate office. The five corporate office engineers will represent several different disciplines and would spend a few days at each plant.
The inspectors were informed that CECO management had arranged a meeting with Mr. H. Denton, NRR Director, on September 23, 1980, to discuss their plan for the Safety Engineering Group.
CECO intends to submit a description of its plan for establishing the ISEG after their discussions with Mr. H. Denton. This item will remain open pending further review by the NRC (373/80-41-04).
No items of noncompliance were identified in this area.
6.
The objective of this portion of the inspection was to determine whether the licensee was prepared to implement the Shift Technical Advisor (STA) staffing requirement / commitment by time of issuance of an operating lirense.
a.
Documents Reviewed The following reference and licensee documents were reviewed and discussed:
(1) NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendations" dated July, 1979.
(2) Clarifying documents for NUREG-0578 dated September 27 and November 9, 1979.
(3) American National Standards (ANS) draft revision 3.1 of December 6, 1979, entitled " Standard for Qualification and Training of Personnel for Nuclear Power Plants."
b.
Findings The licensee explained that he plans to designate the person assigned to perform the STA function as Shift Control Room Engineer (SCRE). The licensee plans to train the SCRE's in special technical areas as required by the NRC staff position on training for STA's.
However, he has not committed to meet the staff requirement that he provide fully trained STA's by January, 1981 or by fuel loading, whichever is later.
Instead, the licensee proposes that its special STA training will be completed by June, 1981. At the present time, it appears that j
the plant will.not be completed and ready for full load before l
the end of February, 1981. The licensee management was informed that the June, 1981 date for completing STA training does not
meet the staff position. This' item remains open pending further review by the NRC (373/80-41-05).
-5-
'
.
.
.
...
.
.-
,
.-
-
. __
.
The licensee proposes that its SCRE (STA) will be a licensed
.
senior reactor operator (SRO) who will be stationed in the control room at all times and will serve as the control room SRO required by the NRC's July 31, 1980 letter from Mr. D. Eisenhut to all licensees and applicants providing the staffs interim staffing criteria. The licensee plans that this SCRE will exercise a command and supervisory function in the control room.
The l'icensee informed us that similar plans had already been approved by the NRC for several of its operating plants (Dresden, Quad-Cities and Zion). The licensee was informed that their proposal does not meet the requirements of the NRC staff position for the STA and that a similar proposal by Duke Power Company for its McGuire Plant was recently found to be unacceptable by the NRC staff. The licensee was requested to document their proposed plan providing all of their arguments and a detailed description so that the staff could be sure that it was evaluating the complete proposal. The licensee indicated that he had made arrangements to discuss this plan for using a SCRE to replace both the STA and the control room SRO with Mr. H. Denton, NRR Director on September 23, 1980.
This item will remain open pending further review by the NRC (373/80-41-06).
No items of noncompliance were identified in this area.
7.
Shift Manning and Overtime Restrictions The objective of this portion of the inspection was to determine whether the licensee was prepared to implement the proposed shift manning compliment and overtime restrictions.
a.
Documents Reviewed Letter of July 31, 1980; to: All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits; from: Darrell G. Eisenhut, Director Division of Licensing; Subject:
Interim Criteria for Shift Manning.
I b.
Findings The licenaee indicated that he planned to operate the LaSalle plant using five or six operating shift crews. A substantial number of LaSalle personnel have taken the NRC license examina-tions fer SRO and R0 licensees and it appears reasonable that they will have sufficient number of these licensed by fuel loading to man at least five shift crews. However, the licensee was advised that shift manning had been an item of much concern in recent reviews of other plants and that he should fully document
his plans in a submittal to the NRC to provide a basis for the j
NRC's evaluation and findings with respect to the adequacy of (
LaSa11e's shift manning plans.
,
l l-6-
- -
-
.
-
-
- -
.
_
_
_
.
.
The licensee was advised that he should provide detailed shift
-
staffing plans that include discrete times starting with fuel load and extending for a period of a year or two:
(1) The number of licensed SR0's and RO's that will have completed the license examination.
(2) The number of those that have completed the examination
"that the licensee expects will be actually licensed.
(3) The number of licensee personnel in training for SRO and RO.
(4) A narrative discussion explaining the plan in detail and including the assumptions made with respect to:
(a) Dates for completing training and the NRC license examinations, (b) The number of license applicants passing the exams, (c) The number of licensed personnel the licensee expects to lose due to attrition, and (d) How the licensee expects to handle and accommodate time away from shift work due to sickness, vacation and training.
It was suggested to the licensee that this information be sub-mitted using tables and charts in a format similar to that for which the licensee has been provided an example of.
This item will remain open pending further review by the NRC (373/80-41-07).
The licensee explained that the bargaining Unit (Union) members of its operating staff [ reactor operators (RO's) and auxiliary operators (A0's)] are allowed (as a result of the licensee's contract with the Union) to select which shifts they wish to work on with the result that they do not stay with any one shift As a result, the operating shift crews (SR0's, RO's and crew.
A0's) are not fixed groups of people who are always assigned to work together and to train together as a team.
It was pointed out to the licensee that, while no known specific NRC requirement has been identified to assure that shift crews stay together permanently and receive training together both on routine and emergency response matters, that it seemed to be desirable from a safety point of view. The licensee was informed that the NRC plans to consider this subject further (373/80-41-08).
The licensee explained that he was considering the possible use of twelve hour shifts as normal working shifts for its shift crews for special extended occasions. Under these conditions the crews would work three days and be off approximately four days, then work four days and be off three days so that the normal work week would average 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> or less. The licen explained that he was planning to work such shifts, using ss isory personnel only, on a trial period for four weeks in Octo
.,
1980. The licensee expressed the view that this type of shift-7-
-
-
-
-
- - -
-
-
manning was not in conflict with the specific wording of the
-
NRC's July 31, 1980 letter on interim criteria for shift manning.
The licensee was advised that the subject NRC letter was written with an eight hour shift in mind as a normal work day and that its plans for 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> normal shifts were outside the scope of this letter and did not meet the intent of the letter. The licensee was advised that he should document, in a submittal to the NRC, a commitment to meet the overtime requirements, as specified in the interim criteria provided in the NRC's July 31, 1980 letter. This item will remain open pending further review by the NRC (373/80-41-09).
8.
Shift Supervisor Duties and Responsibilities The objective of this portion of the inspection was to determine whether the licensee had reviewed the administrative duties of the shift supervisor and delegated functions that detract from or are subordinate to the management responsibility for assuring safe operation of the plant to other personnel not on duty in the control room.
a.
Documents Reviewed (1) NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendations" dated July, 1979.
(2) Clarifying documents for NUREG-0578 dated September 29 and November 9, 1979.
(3) Procedure LAP 200-1, Revision 6, dated September 10, 1980,
" Operating Department Organization".
(4) Procedure LAP 1600-2, Revision 12, dated June 13, 1980,
" Conduct of Operations."
b.
Findings The review showed that the licensee's responses and planned responses to these items are likely to be resolved without any significant problems. The licensee has already committed in its April 15, 1980 submittal to the NRC that it will conform with the TMI Action Items 1.A.1.2 and 1.C.3 and with the NRC's clarification of these items.
In reviewing these Action Items, the items were discussed with licensee representatives and drafts of procedures that had been prepared to implement them were reviewed. A number of suggestions were made to the LaSalle plant management as to changes that should be made to bring these procedures into line with the NRC
staff positions. The licensee expressed a concern on these
'
items that the NRC position related to requiring that the shift supervisor remain in the control room until properly relieved is in conflict with the NRC's July 31, 1980 Interim Shift-8-
-
-
- -
~
,
.
.
Criteria which requires that an SRO who is not the shift super-
visor remain in the control room at all times.
It was agreed that clarification will be provided on this matter. It is expected
,
that based on discussions with the licensee, the licensee will modify its procedures for LaSalle to fully implement the TMI Action Item requirements.
IE will inspect these procedures when they,are finalized to assure that they fully implement the TMI Action Items and the clarified NRC positions on them prior to fuel loading (373/80-41-10).
'
No items of noncompliance were identified in this area.
9.
Shift Relief and Turnover Procedures
'
The objective of this portion of the inspection was to determine if the licensee had implemented shift relief and turnover procedures to ensure adequate knowledge of plant status.
a.
Documents Reviewed (1) NUREG-0578, TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendation" dated July, 1979.
(2) Procedure LAP 200-3, Revision 3, dated June 19, 1980, Shift Change."
b.
Findings The review showed that the licensee's responses and planned responses to this item are likely to be resolved without any significant problems. The licensee has already committed in11ts April 15, 1980 submittal to the NRC that it will conform with the TMI Action Item 1.C.2 and with the NRC's clarification of
- his item.
In reviewing this Action Item, the item was discussed with licensee representatives and drafts of procedures that have been prepared to implement this item were reviewed.
A number of suggestions were made to bring these procedures into line with the NRC staff positions on them.
It is expected that based on discussions with the licensee, the licensee will modify his procedures for LaSalle to fully imple-i ment the TMI Action Item requirements.
IE will inspect these I
procedures when they are finalized to assure that they fully implement the TMI Action Items and the clarified NRC positions
'
!
prior to fuel loading (373/80-41-11).
No items of noncompliance were identified in this area.
!
i
!
-9-
-
-
-
-
-
-
-
-
-
- - - -
-
.
10.
Control Room Access The objective of this portion of the inspection was to determine that the licensee has established methods to control access to the Control Room.
a.
Documents Reviewed (1) Draft Procedure LAP 1100-12, Revision 0, dated September 10, 1980, " Control Room Access."
(2) NUREG-0578 "TMI-2 Lesson Learned Task Force Status Report and Short Term Recommendation" dated July, 1979.
b.
Findings The review showed that the licensee's responses and planned responses to this item are likely to be resolved without any significant problems. The licensee has already committed in its April 15, 1980 submittal to the NRC that it will conform with the TMI Action Item 1.C.4 and with the NRC's clarification of this item.
In reviewing this Action Item, the item was discussed with licensee representatives and drafts of procedures that have been prepared to implement it were reviewed. A number of sugges-tions were made to bring these procedures into line with the NRC staff positions on them.
It is expected that based on discussions with the licensee, the licensee will modify his procedures for LaSalle to fully implement the TMI Action Item requirements.
IE will inspect these procedures when they are finalized to assure that they fully implement the TMI Action Items and the clarified NRC positions on them prior to fuel loading (373/80-41-12).
c.
Concerns Shift Engineer's Office The shift engineer's (Shift Supervisors) office at the LaSalle plant is separated from the control room by a solid reinforced concrete wall. There are no windows in this wall between the control room and the Shift Engineer's office. Access from the Shift Engineer's office to the control room is through a door in the Shift Engineer's office that is located in the wall that is on the opposite side of the office from the reinforced concrete wall, then through an "L" shaped hall outside the office and through another door (vital area door) in the reinforced concrete wall of the control room. The licensee was informed that not-withstanding earlier guidance from the NRC that Shift Supervisor's offices adjacent to control rooms could be considered as part of the control room, we did not believe that a Shift Engineer's office that does not have direct visible access to the control room should be considered a part of the control room. That is,
- 10 -
-
O the Shift Engineer or SRO should not be considered to be inside
the control room, whenever they are inside the Shift Engineer's office. The licensee was asked to specifically define the boundary of the control room in his response to this item. (373/80-41-13)
No items of noncompliance were identified in this area.
11.
Operating Experience Feedback to Operating Staff The objective of this portion of the inspection was to determine that the licensee has procedures to provide feedback on plant operations to the operating staff.
a.
Documents Reviewed (1) Procedure LAP 850-4, Revision 6, dated July 9, 1980, " Review of Technical Document Updates."
(2) NUREG-0660-TMI-2 Task Action Plan.
(3) Offsite Review Plan, Revision 10.
b.
Findings The review showed that the licensee's planned response to this item is likely to be resolved without any significant problems.
The licensee has not previously committed to the NRC that he will conform with the TMI Action Item 1.C.5 and with the NRC's clarification of this item. The licensee was advised that he should make such a commitment along the lines of his commitment to Action Items 1.A.I.a, 1.C.2, 1.C.3, and 1.C.4 which was made in the licensee's submittal to the NRC on April 15, 1980.
In reviewing this Action Item, the item was discussed with licensee representatives and drafts of procedures that have been prepared to implement it were reviewed. A number of suggestions were made to bring these procedures into line with the NRC staff positions on them.
It is expected that based on discussions with the licensee, the licensee will modify his procedures for LaSalle to fully implement the TMI Action Item requirements.
IE will inspect these procedures when they are finalized to assure that they fully implement the THI Action Items and the clarified NRC position on them prior to fuel loading (373/80-41-14).
No items of noncompliance were identified in this area.
12.
Item of Special Interest In discussions with the LaSalle Training Supervisor, it was learned that the licensee's corporate management had visited each of the Commonwealth Edison Company (CECO) nuclear plants including LaSalle to make a special presentation to the plant staff concerning the
- 11 -
l
O importance of safe operation of plants. The presentation at the
,
LaSalle Plant had been video taped and the inspectors reviewed the tape presentation.
In the presentation, Ceco ccrporate managers emphasized the importance of plant operator taking conservative action whenever there is any question in the minds of the operators as to what to do.
Emphasis was placed on operating within the Technical Specification limits. The presentation was forceful and indicates that CECO corporate management is concerned with safety.
No items of noncompliance were identified in this area.
13.
Management Interview The inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection period on September 11, 1980.
The inspectors summarized the scope and findings of the inspection activities. The licensee was advised that this inspection identified numerous areas in which formal documentation had not been established and/or licensee procedure had not been finalizedand, therefore, the NRC interoffice team was unable to reach conclusions in these areas.
These areas will be reinspected during a followup NRC inspection.
l l
l
,
,
'
- 12 -
l
!
l l
h