IR 05000373/1993016
| ML20045B512 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/10/1993 |
| From: | Burgess B, Nejfelt G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20045B508 | List: |
| References | |
| 50-373-93-16-EC, 50-374-93-16, NUDOCS 9306180028 | |
| Preceding documents: |
|
| Download: ML20045B512 (30) | |
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L U. S. NUCLEAR REGULATORY COMMISSION
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REGION III
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Reports No. 50-373/93016(DRS); 50-374/93016(DRS)
Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee: Commonwealth Edison Company Opus West III 1400 Opus Place, 6th Floor Downers Grove, IL 60515 Facility Name:
LaSalle County Nuclear Station, Units 1 and 2 Enforcement Conference At: Glen Ellyn Holiday Inn, Glen Ellyn, IL
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Enforcement Conference Conducted: May 26, 1993 Inspector:
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Approved By:
<ud/b5em a,,4dMS B. L. Burgess, Chief Date Operational Programs Section
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Enforcement Conference Summary Enforcement Conference on May 26. 1993 (Reports No. 50-373/93016(DRS) and
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No. 50-374/93016(DRS))
Areas Discussed: The enforcement. conference addressed the lack of adequate
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management oversight of. the LaSalle Emergency Operating Procedure (EOP)
Program, and discussed three related and apparent violations delineated in NRC Inspection Reports No. 50-373/93009(DRS) and No. 50-374/93009(DRS)..These apparent violations were for (1) two. inadequate E0P support procedures, (2)
inadequate E0P corrective actions, and-(3) E0P conflicts with human factors
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principles. Based upon the information presented at the enforcement
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conference, two violations and one open item were written.
In this report, j
the NRC cited two E0P support procedures that were inappropriate to the
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circumstances (Paragraph 4); and inadequate corrective actions for identified
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E0P discrepancies as violations (Paragraph 4). The open item addressed the lack of action taken to address human factors concerns (Paragraph 5) and the
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lack of management controls regarding items entered into the Nuclear Tracking
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Systems. A meeting to address particular concerns of this inspection report was held on June 7, 1993 (Paragraph 6).
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PDR ADOCK 05000373 r
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REPORT DETAILS
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Persons Present at the Enforcement Conference Commonwealth Edison Company (Ceco)
W. P. Murphy, Site Vice President, LaSalle
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G. Spedl, Plant Manager, LaSalle J. V. Schmeltz, Operations Manager, LaSalle J. Mossman, Public Affairs Director R. Ward, Nuclear Oversight Analysis Director W. F. Naughton, Director of Strategic Licensing & Regulatory Performance T. Shaffer, Executive Assistant
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G. Wald, Nuclear Communications Administrator M. B. Depuydt, Nuclear Licensing Administrator, LaSalle
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J. E. Lockwood, Regulatory Assurance Supervisor J. H. Atchley, Senior Operations Supervisor T. A. Hammerich, Assistant System Engineering Supervisor S. Reece Koenig, Regulatory Performance, Downers Grove S. L. Trubatch, Counselor, Winston & Strawn Members of the Public
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J. Mustis, Staff Writer, The Daily Time, Ottawa, IL J. Spencer, WCMY/WRKX Radio, Ottawa, IL
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Illinois Department of Nuclear Safety (IDNS)
J. Roman, Resident Engineer U.S. Nuclear Reaulatory Commission (USNRC)
H. Miller, Deputy Regional Administrator T. O. Martin, Acting Director, Division of Reactor Safety (DRS)
M. Ring, Chief, Operations Branch, DRS
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R. DeFayette, Director, Enforcement B. L. Burgess, Chief, Operational Programs Section, DRS R. L. Hague, Chief, Section 10, Division of Reactor Projects (DRP)
G. M. Nejfelt, Inspector, DRS R. L. Doornbos, Inspector, DRS P. R. Pelke, Enforcement Specialist P. Alloway, Public Affairs D. Roth, Operator Licensing, DRS 2.
Enforcement Conference A public enforcement conference was held at the Holiday Inn, Glen Ellyn, IL, on May 26, 1993.
The conference was conducted as a result of the preliminary findings of the E0P followup inspection conducted from April 12, 1993, to April 30, 1993, in which apparent violations of NRC regulations were identified.
Inspection findings were documented in
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w Inspection Report No. 50-373/93009(DRS) and 50-374/93009(DRS),
transmitted to the licensee by letter dated May 20, 1993.
The purpose of this conference was to (1) discuss the apparent violations, their causes, and the licensee's corrective actions; (2)
determine if there were any escalating or mitigating circumstances; and (3) obtain any information which would help determine the appropriate enforcement action. The conference was open to the public as part of the NRC's trial program on open enforcement conferences.
Following an introduction by the Deputy Regional Administrator, and a discussion of the enforcement policy, the specific inspection concerns and apparent violations were presented. The licensee's representatives provided additional information concerning the apparent violations. The licensee's representatives described the events which lead to the apparent violations, including root causes and corrective actions taken.
At the conclusion of the meeting, the licensee was informed that they would be notified in the near future of the final enforcement action.
3.
Licensee's Response to 1993 E0P Inspection The licensee's efforts to assess E0P Program concerns in Inspection Report No. 50-373/93009(DRS) and 50-374/93009(DRS) were thorough. A task force was formed to investigate NRC E0P Inspection concerns and identified similar concerns for the control and tracking of information.
Regarding the control of information, a problem was identified with inadvertent omissions of setpoints, such as that observed in the E0P-setpoint document. Corrective actions discussed included a better
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mechanism to control setpoints. With regard to the tracking of E0P information, it was recognized that approximately 15% of the commitments in the nuclear tracking system (NTS) were not closed.
Finally, the licensee acknowledged the need to address human factors considerations in the E0P Support Procedure Writer's Guide and the E0Ps.
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Disposition of Apparent Violations l
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26, 1993, the NRC concurred with the licensee that a management breakdown in the area of E0Ps did not occur. This conclusion was based on the overall adequacy of the E0Ps. Consideration of the apparent violations resulted in a decision to issue two severity level IV violations and one open item.
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Severity Level IV Violations:
The two E0P support procedures that were considered inappropriate to the circumstances were the " Alternate Rod Insertion" and
" Alternate Boron Injection" procedures.
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In the Alternate Rod Insertion Procedure, replacement fuses were not contained in the E0P locker and the fittings on the hose used for venting the control rod overpiston area would not have allowed venting to occur. With regard to the Alternate Boron Injection Procedure, two additional drums of sodium pentaborate (B-10) were needed to achieve cold boron shutdown weight and the operator had no method to accurately measure the B-10.
Additionally, a caution statement to inform the operators about the chemical toxicity of B-10 was not included, nor was sufficient protection provided from the B-10 powder (i.e., face shield).
Finally, the contingency provided in the procedure to obtain additional B-10 from others sources (e.g., Dresden or Quad Cities) did not identify the quantity needed nor the method by which it was to be obtained.
The inappropriateness of these two E0P support procedures for the circumstances is considered a violation of 10 CFR 50, Appendix B, Criterion V (No. 50-373/93016-01 and 50-374/93016-01).
The corrective actions taken for E0P concerns placed into the nuclear tracking system (NTS) for Action Item Requests (AIRS) No.
373-100-91-00302 and 373-251-91-00001 were either not performed or partially completed. These AIRS addressed 1991 E0P Inspection deficiencies for E0P support procedures and for human factors respectively.
AIR deficiencies for E0P Support Procedures (AIR 373-100-91-00302)
included:
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Labeling concerns involving numerous examples of the procedure noun name disagreeing with the equipment noun name.
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E0P support equipment stored or located in the plant was not identified by the red E0P support label. An example is the lack of a label for the sodium pentaborate maintained in storage.
(3)
Operator aids were not corrected after revising the tables in LGA-02, " Secondary Containment Control."
(4)
Multiple examples were found where the attachments to E0P support procedures did not follow the Support Procedures Writer's Guide (LAP-820-11TF, Revision 0) requirements.
For example, the alternate rod insertion attachments were unclear with respect to fuse control.
(5)
The sequence of lifted leads and jumpers were not specified in the procedures, however, the writers guide specified the procedural step as an indication of installation sequence.
(6)
The E0P Support Procedure books were not tabbed.
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The second AIR (AIR 373-251-91-00001) addressed either no action or a failure to justify the action specified in responding to t
concerns regarding the E0P Writer's Guide.
For example, procedural emphasizing techniques (underlining or capitalization)
were inconsistent. Other examples included not specifying that
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cautions and notes should be kept to one topic; and not providing guidance on how tables or figures were to be referenced.
i Additionally, the scheduled completion date for this AIR was
changed approximately eight times without management concurrence.
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Also, rather than responding to concern that the previous E0P Writer's Guide was non-restrictive, the licensee added language to the Writer's Guide that specifically allowed greater latitude.
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These allowances contradicted the guidance provided in NUREG-0899.
l The failure to take or complete corrective actions for the E0P Writer's Guide and support procedure deficiencies is considered a violation of 10 CFR 50, Appendix B, Criterion XVI.
(No. 50-373/93016-02 and 50-374/93016-02).
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Human Factors Concerns
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E0P flowcharts and support procedures were reviewed for consistency with LaSalle's Emergency Procedure Writer's Guideline, E0P Support Procedure Writer's Guide, and accepted human factors principles described in NUREG-0899 and NUREG-1358.
I The licensee did not address many of the human factors concerns identified in the 1991 E0P Inspection.
For example, comments supplied by the licensee's corporate human factors engineer (HFE) in November
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1991 either went unheeded or were placed in the AIR tracking system as discussed previously.
Examples of these concerns were: E0P flowchart format notes and cautions were allowed after the action step, cautions did not provide information relating to hazardous conditions that may cause personnel injury, no guidance for distinguishing between control room and in-plant operator actions, and no specified acceptable emphasis techniques (i.e., use of underlining or capitalization).
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Additionally, cautions and notes, were removed from numerous support procedures and placed into the discussion section of the procedure.
In some cases, cautions, notes, conditional steps, and action steps necessary to the performance of the procedure were also found in the discussion section. The level of detail in the body of the procedure was occasionally inadequate.
For example, the procedure for LGA-CY-01,
" Alternate Vessel Injection using Cycled Condensate System," buried vital cycled condensate system information in the discussion section.
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Pending completion of a human factors review of the E0Ps, this item will be tracked as an open item (No. 50-373/93016-03 and 50-374/93016-03).
For administrative purposes, the apparent violations identified in NRC Inspection Report No. 50-373/93009(DRS) and 50-374/93009(DRS) are closed by the two violations and the open item cited above, i
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Open Item An open item is a matter which has been discussed with the licensee which will be reviewed further by the NRC and which involves some action on the part of the NRC or licensee or both.
An open item disclosed during this inspection is described in Paragraph 5.
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Meetina at Corocrate Office on June 7. 1993 A meeting was held on June 7,1993, at the licensee's Downers Grove Office. At this meeting, the NRC acknowledged that five items were presented incorrectly in Inspection Reports No. 50-373/93009 and No. 50-374/93009. The corrected information with its 93009 report reference in brackets were:
(1) the reactor core isolation cooling (RCIC) referenced in LGA-01 was not an action step and therefore was allowable after the step to which it applied [Page 9, Paragraph b],
(2) Flowcharts LGA-05 and LGA-06 were consistent with LGA-04
[ Appendix A, Page 2, Bullet 5], (3) LAP 820-11TG Attachment A, page 6, listed two flashlights and six lanterns [ Appendix A, Page 3, Bullet 7],
(4) LAP 820-llTF provided guidance on page 22, paragraph Sa for parentheses [ Appendix A, Page 4, Bullet 7], and (5) reference to VB system was deleted [ Appendix A, Page 12, Bullet 6]. These corrections did not invalidate the NRC findings.
8.
NRC Response to Boron " White Paper" The licensee forwarded to the NRC after the enforcement conference a
" White Paper" discussing the assumptions used in the alternate boron shutdown weight calculations. With the information provided by the licensee, the NRC agreed that the appropriate conservative assumptions for mixing and dilution were incorporated into the boron injection values. The Final Safety Analysis Report (FSAR) assumptions for boron mixing and dilution were additional conservative factors that only applied for the standby liquid control (SLC) system.
Attachments:
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NRC Presentation Slides 2.
CECO Presentation Slides
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U.S. NUCLEAR REGULATORY
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t COMMONWEALTH EDISON COMPANY LASALLE COUNTY NUCLEAR STATION l
i ENFORCEMENT CONFERENCE j
MAY 26,1993 l
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EA 93-117
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REPORTS NO. 50-373; 374/93009
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GLEN ELLYN-HOLIDAY INN
Roosevelt Rd.
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COMMONWEALTHL EDISON' COMPANY
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LASALLE COUNTY NUCLEAR STATION
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AGENDA-May 26,1993 INTRODUCTION:
Hubert Miller, Deputy Regional Administrator-l
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DISCUSSI'ON OF ENFORCEMENT POLICY:
Robert W. DeFayette, Director, Enforcement and-i investigation Coordination Staff
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PURPOSE OF THE ENFORCEMENT l
CONFERENCE:
Bruce L. Burgess, Chief, Operational Programs Sections
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Branch, Division of Reactor Safety. (DRS)
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i DISCUSSION OF CONCERNS:
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Bruce L. Burgess SUMMARY OF APPARENT VIOLATIONS:
j Gregory M. Nejfelt, Reactor inspector, DRS-
_ LICENSEE PRESENTATION AND
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DISCUSSION:
CLOSING REMARKS:
Hubert Miller (Slide // 2)
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PURPOSE OF THE ENFORCEMENT
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CONFERENCE i
to discuss the apparent violations
to discuss the root cause and safety significance
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licensee to point out any errors in the
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inspection report
to discuss corrective actions taken or planned
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to discuss other information that will help in determining the appropriate enforcement action
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SUMMARY
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Two inadequate procedures.
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l Numerous procedure deficiencies.
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Lack of corrective action for 1991
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Inspection.
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Apparent lack of management
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attention to EOP Program.
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l INADEQUATE i
EOP SUPPORT PROCEDURES
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i inspection found two inadequate procedures:
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ALTERNATE BORON INJECTION (LGA-RT-03, Revision 1)
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ALTERNATE ROD INSERTION, (LGA-l NB-01, Revision 1)
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FIRST INADEQUATE PROCEDURE
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ALTERNATE BORON INJECTION (LGA-RT-03, Revision 1):
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On-site supply of sodium pentaborate i
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was inadequate to achieve cold shutdown as the procedure directed.
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O B-10 not located where it would be
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UFSAR assumptions for B-10 mixing and dilution were omitted.
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No method provided to measure a 30-
pound boron (B-10) batch.
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No method provided to protect the operator from chemical toxicity (i.e., face
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shield);
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Insufficient quantity for emergency depressurization.
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i SECOND INADEQUATE PROCEDURE
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LGA-NB-01, ALTERNATE ROD INSERTION,
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incompatible hose fitting prevented venting the hydraulic control unit
overpiston area.
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Replacement fuses needed were not provided.
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PROCEDURE DEFICIENCIES S
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Human factor weaknesses
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Writer's Guide
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Labelling
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Setpoint Document
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i CORRECTIVE ACTIONS
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i SIMILAR DEFICIENCIES WERE CITED IN i
1991 EOP INSPECTION
Human factor weaknesses
support procedure writer's guide
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inconsistent procedure / equipment
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setpoint document
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MANAGEMENT ATTENTION
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Management attention to EOP Program was
ineffective...
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continued weaknesses in procedures
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continued weaknesses in the verification and validation process
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poor resolution of weaknesses identified by NRC, Quality Assurance, and corporate.
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inadequate oversight of the EOP
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i SUMMARY
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Numerous procedure deficiencies.-
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Lack of corrective action for 1991-j
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Inspect. ion.
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attention to EOP Program.
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e APPARENT VIOLATIONS There are three apparent violations regarding management inattention to the EOP Program.
The particular violations address:
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TWO inadequate EOP support procedures
(10 CFR Part 50, Appendix B, Criterion V).
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inadequate corrective actions for
previously identified EOP problems (10 CFR Part 50. Appendix. B, Criterion XVI).
inability to maintain quality of EOPs (TS l
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1ST APPARENT VIOLATION
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Q 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that licensed
activities affecting quality be prescribed by documented instructions or procedures of the type appropriate to the circumstances, and accomplished
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according to these instructions or procedures.
i Contrary to the above, the procedures adverse to quality existed at the l
LaSalle County Nuclear Station for the following circumstances:
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Procedure LGA-RT-03, ALTERNATE BORON INJECTION, Revision 1 (July 2,1992), was inadequate in that the on-site
supply of sodium pentaborate was insufficient to achieve cold shutdown as the procedure directed.
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Procedure LGA-NB-01, ALTERNATE ROD INSERTION,
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Revision 1 (May 12,1992), was inadequate in that an
incompatible hose fittings prevented venting the hydraulic control unit overpiston area as the procedure directed.
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This is an apparent violation which is subiect
to further review, and may be subiect to
_ chance orior to any resultina enforcement i
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2ND APPARENT VIOLATION I
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10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures
shall be established to assure that conditions adverse to quality, such as failures, deficiencies and deviations, are promptly identified and corrected.
Contrary to the above, between February 8,1991, and April 30,1993, conditions adverse to quality existed at the LaSalle County Nuclear Station, and the conditions were not promptly corrected, in that:
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The licensee did not adequately correct procedural EOP errors that were tracked as Action item Request (AIR) No. 373-100-91-00302 dated March 22,1991.
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The licensee did not act upon the original human factors concerns from the 1991 EOP inspection to clarify procedural actions, AIR 373-251-91-00001 dated Decernber 31,1991.
i This is an apparent violation which is subject i
_t_o further review, and may be subject to change prior to any resulting enforcement action.
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3RD APPARENT VIOLATION
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LaSalle Technical Specification 6.2.A.c (Amendment No. 86 for Unit-1 and i
Amendment No. 70 for Unit-2) requires establishing, maintaining, and controlling emergency procedures as specified in NUREG-0737 and i
Supplement 1 to NUREG-0737 by Generic Letter No. 82-33, Section 7.1, as a licensed activity.
Generic Letter No. 82-33, Section 7.1, items b and c respectively required:
(1) upgrading the EOPs using NUREG-0737, item I.C.1, and (2) upgrading
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EOPs consistently with Technical Guidelines and an appropriate procedure
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Writer's Guide.
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NUREG-0737, item I.C.1, required considering human factors engineering, j
such as, clarity of procedural actions.
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Contrary to the above, between February 8,1991 and April 30,1993, the
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writer's guide for the EOP support procedures aid not adequately consider Generic Letter No. 82-33 and NUREG-0737 requirements for controlling and
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maintaining the EOPs.
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This is an apparent violation which is subject to further review, and may be subject to
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COMMONWEALTH EDISON LASALLE COUNTY STATION EMERGENCY OPERATING PROCEDURES ENFORCEMENT CONFERENCE MAY 26,1993 A
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INTRODUCTION Warren P. Murphy LaSalle Site Vice President o
APRIL 30,1993 NRC EXIT MEETING o
IMMEDIATE FOLLOW UP ACTION o
TASK FORCE FINDINGS o
TODAY'S AGENDA J
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AGENDA
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INTRODUCTION W. P. MURPHY
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EOP PROGRAM HISTORY J.H.ATCHLEY 1991 NRC INSPECTION OPEN ITEMS J. V. SCHMELTZ
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SAFETY SIGNIFICANCE / BROAD ISSUES G. F. SPEDL i
CONCLUSION W. P. MURPHY
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LASALLE EOP PERFORMANCE HISTORY-r January 1991
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We implemented Rev. 4 of the EOP's, following 6 months of Operator Training for, Licensed, non-licensed operators and
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Classroom and Simulator Instructors.
INPO evaluated EOP performance in mid January,1991 and had some concems relating to EOP Flow Charts:
INPO realized that we had just implemented Rev. 4. and decided to give us 3 months to become more proficient with the EOP's and come back to
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m-evaluate the perfomiance training program at LaSalle.
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LAS ALLE EOP PERFORM ANCE IIISTORY
Febmary 1991
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The NRC conducted an EOP Team Inspection at LaSalle in early February,1991. They identified some of the same pmblems that INPO had observed. Other deficiencies wem identified, but none of them would have prevented the accomplishment of a Safety Action because the procedums were:
i Technically adequate, Understandable and Useable.
In response to these observations an EOP Committee was forme.d to assist
the EOP Coordinator with the specific purpose of having an interdisciplinary team to address the concems of INPO. The NRC
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concems wem not yet transmitted.
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The EOP Coordinator, t
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The Administrative Opemting Engineer, j
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The Tmining Supervisor, and i
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The LaSalle Simulator Training Supervisor.
i The ownership of the progmm remained with the EOP Coordinator.
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'r LASALLE EOP PERFORMANCE IIISTORY Late April 1991 INPO conducted a second simulator observation of the EOP usage at LaSalle. The msults were an INPO 1 rating. Due to this success, the EOP committee decided to stay together to assist in completing the items from the NRC evaluation of the EOP progmm.
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NTS items wem assigned to the 1991 NRC inspection mport deficiencies.
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Due to the weaknesses observed in the EOP Support Procedures (then called " LOA's"):
A Contractor was hired to write the EOP Support Procedure Writers Guide and upgmde the support procedums from " LOA's" to
"LGA's" to have consistent step stmeture.
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O The EOP Coordinator requested Commonwealth Edison's Human Factors Department to provide Human Factors mview for the Support Procedums.
O Validation was performed on the revised procedures by Operating Department personnel.
May 1991
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NRC conducted the annual license mqualification examination and gmded it satisfactory.
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November 1991 The LaSalle annual GSEP exercise was performed satisfactorily, exercising some of the LGA support procedures in the plant.
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l LAS ALLE EOP PERFORMANCE HISTORY May 1992 The NRC conducted the annual License Requalification examination, and graded it satisfactory. Strengths were noted:
Reactor Operator control panel operations, O
Senior Reactor Opemtor place-keeping on the EOP flow charts,
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O Training Personnel.
June 1992
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LaSalle annual GSEP pre-exercise was performed satisfactorily, exercising some of the LGA suppon procedures in the plant.
l During the 1991 NRC License Requalification evaluation, the NRC observed that the Job Perfomiance Measures (JPM's) for the EOP suppon procedures were adequate, met the guidelines of NUREG 1021, but wem limited in quantity.
During the 1992 NRC License Requalification evaluation, the NRC acknowledged that several JPM's wem added to the bank that requim an
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attemate path for accomplishment, and this increased the realism associated with
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this method of training.
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DESK TOP REVIEW
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1991 NRC EOP Inspection OPEN ITEM CORRECTIVE ACTION Inadequate control and documentation In August 1991 LaSalle developed and
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of basis / justification for setpoints, implemented progmm control document, plant specific data and input data to LGA-820-1ITE Setpoint Document calculations.
1993 NRC EOP Inspection Specific deficiencies identified
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DEFICIENCIES ROOT CAUSE CORRECTIVE ACTIONS
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Omission of conservative Reliance on BWROG Document use of BWROG l
boron dilution definition and position.
assumption assumptions appmved by NRC without
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documentation within our l
program.
Missing value and/or Inadvertent omission Document review and
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refeience programmatic changes
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Lack of justification for Inadequate Development justification l
differences between EOP documentation of document under preparation
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and PSTG (conservative deviation.
rounding)
Fonnatting Failure to cross-reference LGA's will be reviewed for l
inconsistencies in procedures completeness of cross Writer's Guide entry reference and pmgrammatic
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conditions changes
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t Retrievability of Calculations were Documents will be
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I information (calculations maintained in the EOP transferred to central file in-not in central files)
Coordinators desk accordance with approved administrative procedures.
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WALKDOWNS 1991 NRC EOP Inspection OPEN ITEM CORRECTIVE ACTION
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Local actions probably could be In late 1991 LaSalle revised validation
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perfomied, but some might be procedure to incorporate identified Human -
accomplished after confusion or delay Factors concems.
due to deficiencies in the support
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procedures.
A contractor was himd to develop EOP Support Procedures Writer's Guide and EOP Support Procedums.
Support Procedums wem validated by operators and concluded procedures were adequate.
r 1993 NRC EOP Inspection Specific deficiencies identified
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OPEN ITEMS RESPONSE / CORRECTIVE ACTION t
Two procedures inadequate -
LaSalle CONCLUDED both procedums LGA-NB-01 and LGA-RT-03 would work as written.
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All other procedures performable, but Corrective actions will be taken to enhance I
level of detail and consistency could level of detail and consistency.
be enhanced to reduce reliance on i
operator training and memory.
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CONCERN ANALYSIS RESPONSE / CORRECTIVE ACTIONS
Adequate amount of No requirement to As an enhancement LaSalle boron on-site to achieve maintain cold shutdown will strive to maintain the cold shutdown weight of boron on site.
required amount of boron for Procedure provides for cold shutdown on-site.
obtaining additional Additionally, it will be stored'
boron from Dresden at 820' elevation and/or Quad Cities as needed.
Methods to measure Scale not on hand, face Procedures will be enhanced, boron or to protect shield not noted, both QV and Human Factors operators am readily obtainable performed walkdown, weaknesses identified will be addressed Definition of tenn Commonly understood Will add definition
"Cmcked Open" Failure to specify Amount of required Appropriate details will be replacement details of boron can be calculated, added to the procedure boron to be obtained method to be from altemate location detennined appropriate to circumstances
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1.G A NH-01, ALTERN ATE ROD INSERTION
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CONCERN ANALYSIS CORRECTIVE ACTIONS t
Wrong fitting on hose Root cause for the Locker inventoried and (Tool control issue)
wrong fitting on the sealed._ Proper hose was
hose is not known. This pmvided.
did not preclude the i
ability to vent. The Developing locker inventory fitting could be cut off control process.
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and venting achieved.
Wmng fitting on hose Experience shows that No corrective actions
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(Personnel safety issue)
flow and pmssure can requimd.
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be controlled during the'
venting process.
Replacement fuses not Not intended to be in Spam fuses in locker and on in locker or on check locker. Supply known inventory check list.
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list to be madily available-in control room.
QV has identified other I
readily available items which will be controlled.
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Potential for fuse Agree Writer's Guide Specific inconsistency will be confusion due to failure was not followed -
mviewed and either corrected to follow Writer's Guide Walkdown by SQV or justified.
showed fuses could be
changed without Failure to follow Writer's confusion.
Guide will be addmssed in l
JPMs are administemd progranunatic review.
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I training is performed.
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r 1991 EOP Inspection OPEN ITEM CORRECTIVE ACTIONS Verification and validation of EOPs An expen was himd to write the EOP r
and support procedums was a Support Procedun=s Writers Guide and l
programmatic weakness support procedures. The support procedures were re-written and re-validated to address the EOP inspection concems.
1993 NRC EOP Inspection
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Specific deficiencies identified DEFICIENCIES ROOT CAUSE CORRECTIVE ACTIONS
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Failure to effectively Specific instances of V&V procedures will be control elements of the inadequate management revised to ensure procedure V&V process.
oversight such as failure format consistencies.
to mquire of verification EOPs and Support Procedums of the support will then be verified and procedures.
validated to the revised procedures.
Human Factors will be involved in all revisions of the WG.
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Deviations from the WG will be justified and documented.
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DEFICIENCY CONCLUSION CORRECTIVE ACTION
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EOP Howchart - found CECO does not consider No change required note / caution after action an itemized list of
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step systems to constitute an action step. (except words)
No specine acceptable Capitalszation is clearly Ensum that documentation emphasis techniques the preferred emphasis justifying underlining is
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(underlining).
technique, underlining is available permitted only under very limited circumstances Writer's Guide made A mview of the NUREG less mstrictive 0899 was completed. The
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(underlining for information obtained will be
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emphasis, lack of clarity used to revise the WG. Any in action steps and deviations from the NUREG cautions before action will be properly documented.
steps.
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l MANAGEMENT OVERVIEW j
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MANAGEMENT CONTROL OF EOP PROGRAM
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o Inadequacies existed in the management of the EOP program.
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However, there is evidence of management control present.
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o Therefore, we have conclude that there was not a programmatic breakdown of management controls in the EOP Program.
i Corrective Actions Responsibilities of EOP program maintenance has been assigned to the plant Operations Department.
Assignment of EOP program maintenance as the primary responsibility of
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a qualified individual.
Specific detailed job description for the EOP program coordinator which clearly delineates responsibilities and authorities.
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Independent detailed audit of the EOP Program when the corrective action is complete to ensure that adequate management control has been obtained.
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Perform periodic EOP Program audit.
i To ensure success of corrective actions, we will review our corrective actions against other Commonwealth Edison Station EOP programs.
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.. v o M ANAGEMENT OVERVIEW
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Safety Significance All EOPs and Support Procedures are capable of being performed NRC acknowledged all but two EOPs are performable as written.
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LaSalle has explained why these two EOPs am perfonnable.
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EOP Suppon Procedures walked down successfully, Completed May 19,1993 Other independent indications of safety adequacy Successful initial and requalification license exams (five sepamte occasions)
Annual GSEP Exercises successfully completed Independent QV team statused all items identified in 1991 inspection repon and concluded no specific safety concems were identified.
i NUREG 0899 line item review perfomled against LaSalle procedures and
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no significant safety issues were identified.
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MANAGEMENT OVERVIEW SIX SPECIFIC AREAS OF CONCERN:
Inadequacies in the VeriDeation and Validation of EOP Suppon Procedures Previously discussed Acknowledged de0ciencies
Perfonnance problems for EOP Suppon Procedums - Two Procedures
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Previously discussed Procedures are capable of being performed
Inconsistencies between support procedures and writers guide Previously discussed Acknowledged deficiencies Untimely and incomplete msolution of concems placed into NTS
All items identiDed in 1991 wem mviewed Acknowledged deficiencies Root Cause Evaluation identined NTS progammatic issues s
Corrective Actions include:
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Revising program to provide expectations in the areas of documentation, completion dates, mviews, and closure.
Completion by July 15,1993 Implementation of post closum review of.NRC items on a sampling
basis Completion by September 1,1993
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Revision of Writers Guide contrary to consistent EOPs
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Previously discussed i
EOP diffemnces from NUREG 0899 will be evaluated for consistency
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Overall Management of EOP Program Previously discussed Additional action to be taken to ensure more effective management control
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