IR 05000373/1986042
| ML20214D560 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/14/1986 |
| From: | Darrin Butler, Hasse R, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214D558 | List: |
| References | |
| 50-373-86-42, 50-374-86-42, NUDOCS 8611240139 | |
| Download: ML20214D560 (5) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-373/86042(DRS);50-374/86042(DRS)
Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee: Consr.onwealth Edison Company P.O. Box 767 Chicago, Illinois 60690 Facility Narre: LaSalle County Station, Units 1 & 2 Inspection At: LaSalle Site, Marseilles, Illinois Inspection Conducted: November 5-7, 1986
_\\\\~l+7)b Inspectors:
a e Date 61&s D. Butler
// /h7[p Date Approved By:
M. Phi lips, Chief
// V[#[
Operational Programs Section D~ ale Accompanying Personnel:
J. Bongarra, NRR I. Schoenfeld, NRR Inspection Summary 50-373/~8604_(2(DRS)iise Tf uVg~rYde
- 50-374/86042_(DRS A_rea_s InspecisdT~~SiecTcTasn~oiinc_e(_ Reports No.
Inspection _on November 3-/, 1986 d sifely Tn'siec1 Ton is eter
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errergency operating procedures were prepared and validated in accordance with the approved Procedured Generation Package. The inspection was conducted in accordance with TI 2515/IP.
Results: No violations cc deviations were identified.
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8611240139 861117 gDR ADOCK 05000373 PDR i
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DETAILS 1.
Persons Contacted Corr 4ronweal_th _Ed_ison, Compapy*
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R. Bishop, Services Superintendent J. Klika, Procedures Manager T. Harrserich, Technical Staff Supervisor R. Stobert, Station QA Superintendent D. Enright, QA Engineer P. Manning, Assistant Superintendent, Technical Services U.S. NRC*
h. Jordan, Senior Resident Inspector J. Bongarra, NRR I. Schoenfeld, NRR Other personnel were contacted as a matter of routine during the inspection.
- All personnel listed attended the exit interview on November 7, 1986.
EptergescLperatip1 focedures
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Emergency Operating Procedures (EOPs) have undergone significant changes as a result of the 1979 accident at the Three Mile Island facility.
The new E0Ps are required to be symptom oriented rather than event oriented.
Generic Letter 82-33, " Requirements For En.argency Response Capability" (Supplement I to NUREG-0737) required all licensees and applicants to submit to the NRC for approval a Procedures Generation Package (PGP)
describing their plan for developing the upgraded E0Ps. The PGP consists of four paits:
Plant-specific Technical Guideline (P-STG) - the technical basis for
the new E0Ps Pk-nt-Specific Writers Guide - the details of the specific methods to
be used by the licensee in preparing the E0Ps A description of the program for verification and validation of the
E0PS A description of the program for training operators on the E0Ps
The purpose of this inspection was to determine if the licensee's upgraded E0Ps had been prepared and validated in accordance with their NRC approved PGP. This was accomplished by a detailed comparison of a sample of E0Ps and their validation documentation against the approved PGP. Operator Training on the new E0Ps will be covered in a future inspectio __
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Documents Reviewed The following documents were reviewed during this inspection:
(1) Procedures Generation Package.
(2) LAP 820-1, Attachment F-2, " Writers Guide For LaSalle General Abnormal (LGA) Symptom-Based Emergency Procedures," Revision 23.
t (3) LAP-820-2, " Station Procedure Preparation and Revision,"
Revision 26.
(4) LGA-01, " Level / Pressure Control."
(5) LGA-04, " Level Restoration."
(6) LGA-05, "RPV Flooding."
(7) LGA-ATWS-02, " Secondary Containment Control."
(8) LGA-ATWS-05, "ATWS RPV Flooding, b.
_Inspe_ction Resul ts
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The inspectors determined that the licensee's E0Ps (licensee
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designated as LGAs) were prepared and validated in accordance with
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their approved PGP. However, the inspectors did have several concerns as discussed in the following paragraphs:
(1) Plant-Specific Technical Guideline
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The inspectors had two concerns related to the P-STG:
(a) All portions of the PGP had been placed under the licensee's document control program with the exception of the P-STG. While the P-STG was being informally controlled by the Procedures flanager, the inspectors were concerned that control might be lost when the incumbent left that position. The inspectors stated, and the licensee concurred, that the P-STG should be controlled in a manner similar to a design reference document. This is considered an open item (373/86042-01; 374/86042-01).
(b)
If a licensee based his P-STG on the Generic Technical Guidelines (GTG) previously approved by the NRC, they were required to identify in the PGP any potentially safety significant deviations from the GTG and provide a justification for each deviation. Daviations made subsequent to PGP approval were to be subject to 10 CFR 50.59 requirements. While the licensee did identify and justify deviations from the GfG in their approved PGP, the term
" deviation" was not well defined at that time.
Subsequently, the NRC issued Appendix A, (Review Procedures for the evaluation of PGPs) to Section 13.5.2 of fiUREG-0800(SRP).
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This Appendix provides a more definitive characterization of the term " deviation" to be used by the NRC in reviewing PGPs. The inspectors reconcended that the licensee consider incorporating this guidance into their program for controlling their P-STG. The licensee agreed to do this. This is considered an open item (373/86042-02; 374/86042-02).
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(2) _EOP Validation The inspectors had two concerns related to the validation o.
E0Ps:
(a) As noted earlier, the licensee had validated their E0Ps in accordance with their PGP. However, the documentation of this validation is relatively informal and has no controlled status. Subsequent to the initial validation, the licensee had formalizeu the validation process under procedure LAP-820-1, Attachment F-2.
The formalized validation program had not been exercised against the existing E0Ps since no changes had been made to them since initial validation that required revalidation. The inspectors recommended that the existing E0Ps be revalidated under the formalized validation program.
The licensee agreed that this was appropriate.
This will be tracked as an open item (373/86042-03; 374/86042-03).
(b) The validation program involves " proof-in-use" exercises at the simulator and when necessary, walk-throughs at the plant. The simulator esaluations are conducted as part of the operator requalification program. The inspectors were concer.ied that the validation program was not sufficiently specific in defining validation criteria (e.g., a require-ment for multi-event scenarios). The inspectors also emphasized that when the requalification training program was used for procedure validation, the same emphasis should be placed cn evaluating the technical adec,uacy of the procedure as procedure useability and operator proficiency.
The licensee agreed to evaluate the need for more specific validation criteria in their validation program. This will be tracked as an open item (373/86042-04; 374/86042-04).
(3) Control Room Walkthrough The inspectors performed a control room walkthrough to assess E0P accessibility, useability of procedure format, and consistency of nomenclature between procedures and control panel labelling.
During the walkthrough the inspector identified an operator aid on a control room back panel that was not under the control of the operator aid program. The aid was a label identifying the location of a jumper installation to be made when implementing procedure LOA-MS-01, "Mainsteam Isolation Bypass For Emergency Depressurization." Failure to control this operator aid could lead to confusion if the procedure or terminal locations were changed without changing the aid.
The licensee acknowledged this oversight and agreed to correct it. This will be tracked as an open item (373/86042-05; 374/86042-05).
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Open Items Open items are matters which have been discussed with the licensee which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both.
Open items disclosed during the inspection are discussed in Paragraphs 2.b.(1).(a), 2.b.(1).(b),
2.b.(2).(a), 2.b.(2).(b), and 2.b.(3).
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on November 7, 1986, and summarized
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the purpose, scope, and findings of the inspection.
The licensee stated that the inspectors had no access to proprietary information.
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