IR 05000373/1998004
| ML20216G584 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/10/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20216G542 | List: |
| References | |
| 50-373-98-04, 50-373-98-4, 50-374-98-04, 50-374-98-4, NUDOCS 9804200397 | |
| Download: ML20216G584 (40) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION i
REGIONlli J
Docket Nos:
50-373; 50-374 License Nos:
Report Nos:
50-373/98004(DRP); 50-374/98004(DRP)
Licensee:
Commonwealth Edison Company -
Facility:
LaSalle County Station, Units 1 and 2 Location:
2601 N. 21st Road Marseilles,IL 61341 Dates:
January 24 - March 10,1998
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inspectors:
M. Huber, Senior Resident inspector J. Hansen, Resident inspector R. Crane, Resident inspector C. Brown, Reactor Irispector Approved by:
Kenneth G. O'Brien, Acting Chief Reactor Projects Branch 2
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9004200397 900410 PDR ADOCK 05000373
O PDR
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EXECUTIVE SUMMARY LaSalle County Station, Units 1 and 2 NRC inspection Report No. 50-373/98004(DRP); 50-374/98004(DRP)
This inspection report included aspects of licensee operations, maintenance, engineering and plant support. The report covers a six-week period of inspection conducted by the resident inspectors.
I Plant Operations Inspectors observed operations personnel following plant procedures and being attentive l
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to plant conditions and equipment status during routine activities. The licensee's response to the partialloss of offsite power was good and operators performed well during the event. However, the deletion of several Technical Specification (TS)
clarifications was not communicated to operations personnelin a timely manner.
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The licensee took appropriate actions to identify the root cause of SBM [ switch board,
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miniature) control switch failures and to develop corrective actions. (Section O2.1)
The inspectors identifwi cominued problems with plant housekeeping, including left over
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materials from maintenance activities, damaged lagging, and poorlighting.
(Section O2.2)
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l The licensee's actions to address an improperly engaged locking device on a valve were j
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thorough and appropriate. However, the licensee's corrective actions to previously
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identified locked valve program implementation problems were not complete, and resulted in a non-cited violation example. Specifically, the licensee had decided to no longer implement program requirements for an 18-month locked valve checklist j
verification, but had not made the corresponding revision to the program. (Section O3.1)
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The inspectors reviewed several aspects of the LaSalle Station Restart Plan and
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confirmed related plan actions had been implemented. However, the effectiveness of these actions regarding two of the reviewed areas was not yet sufficient to achieve the plan's restart goals. In particular, although licensee actions regarding personnel performance had been implemented, inspectors noted a recent decline in this area, necessitating several resets of the licensee's station event free clock in a relatively short
time period. Severalissues described in this report also relate to personnel performance problems. Likewise, concerns involving repeat events due to inadequate corrective action implementation were exemplified by two violation examples, also described in this report, and confirmed by additional examples in the licensee's performance tracking.
Work scheduling deficiencies continued to impede tirnely completion of outage activities such as reactor water cleanup system modifications. (Section 08.1)
The inspectors identified that, due to a personnel error, the liconsee had not properly
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addressed an existing station procedure governing operational experience reviews while instituting a conflicting corporate Nuclear Station Work.'rocedure. This issue was indicative of a recent adverse trend in personnel performance, described in this report, and constituted an NRC-identified non-cited vblation. (Section 08.2)
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The licensee implemented the actions described in LaSalle Station Confirmatory Action
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l Letters (CAL) Rlll-96-008 and Rlil-96-008A related to the June 1996 service water event.
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(Section 08.3)
The inspectors reviewed selected 50.54(f) performance indicators, and concluded that
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the percent of rework has been consistently declining, and accurately reflected the improving quality of maintenance activities at LaSalle. In addition, the temporary l
modification performance indicator accurately reflected the status of temporary modification resolution. Adequate processes were in place to ensure goals would be achieved. (Section 08.4)
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Maintenance l
Overall, maintenance activities observed by the inspectors were acceptable and in
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conformance with work package requirements, and supervisors were present at the work locations. However, minor foreign material exclusion control problems, such as missing plugs on a drain collecting pot and poorly secured covers on a pipe during a valve replacement, were identified and subsequently addressed by the licensee.
(Section M1.1)
Enoineerina The licensee identified through a departmental self-assessment that the engineering
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request screening process did not include a methodology to ident fy and evaluate potential operability issues associated with engineering requests. As a result of this concern, the licensee generated at least one additional formal operability evaluation.
Corrective actions for this concern were appropriate. Engineering personnel have continued to identify engineering issues during system and program reviews.
(Section E2.1)
The licensee did not implement adequate corrective actions for the failure to test the
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manual backwash function of the residual heat removal service water strainers. On February 3,1998, the licensee identified that, due to a personnel error involving a lack of understanding of inservice testing requirements, procedure changes requiring performance of manual testing of the strainer backwash function had not been implemented. The failure to incorporate testing into the plant surveillance program resulted in a non-cited violation example. (Section E2.2)
Program reviews in the engineering area, performed by Quality and Safety Assessment
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Department personnel, were thorough and identified many pertinent issues. Findings resulting from the reviews were documented for resolution by station personnel. Specific examples of these findings are discussed below with respect to Section F4.1 of this report. (Section E7.1)
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Plant Support The licensee identified potential problems during a review of the fire protection program
at LaSalle. These issues included missed firewatches, the lack of coordination calculations, and a potentially non-conservative fire stop justification. The licensee took appropriate correct:ve actions for the missed firewatches, which were considered a non-cited tiolation. The other two issues remained under review by the licensee and inspectors. (Section F4.1)
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l Report Details Summary of Plent Status During this inspection period, the licensee maintained Unit 1 in cold shutdown (Operational Condition 4) for a forced outage. Unit 2 remained shut down for a refueling outage with all fuel removed from the reactor.
I. Operations
Conduct of Operations 01.1 Communication of OperationalInformati.o.n a.
Inspection Scope (71707)
The inspectors evaluated operations personnel performance while attending operations department shift briefings, monitoring control room activities, reviewing daily logs, and interviewing operations personnel regarding plant status. In addition, the inspectors observed the licensee's performance on March 6,1998, when two offsite power lines were lost. The inspectors also reviewed LaSalle Administrative Procedure (LAP)-1200-17, " Operating License /TS Clarifications," Revision 4.
b.
Observations and Findinas
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In general, the inspectors observed that operations personnel were knowledgeable of plant and equipment status, maintained accurate records, effectively communicated operational information, and operated equipment in accordance with approved procedures.
Response to Partial Loss of Offsite Power On March 6,1998, two of five offsite power lines de-energized due to adverse weather conditions. The licensee responded well to the loss of the two offsite power lines. The licensee took conservative action which included:
Stopping plant maintenance activaies to prevent potentialloss of important
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equipment (e.g. emergency diesel generators),
Staffing the Technical Support Center; and
l Increasing control room (CR) oversight by adding an additional CR supervisor.
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The inspectors observed operator performance during the event. Operators followed procedures and conducted CR briefings to address changes in plant status as the changes occurred.
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Technical Specification (TS) Clarifications On February 13,1998, during a routine main control board walkdown, the inspectors identified that 23 TS clarifications were in the Control Room Supervisor's and Shift Manager's controlled TS clarification sets. Operations shift personnel believed that the clarifications were in effect. On February 12,1998, the Regulatory Assurance Manager had approved deletion of 19 of the 23 TS clarifications.
The inspectors determined that, during the deletion process, the regulatory assurance staff and operations management had reviewed the deleted clarifications and determined that none were applicable to current plant conditions. Although deletion of the clarifications was delayed for two weeks to allow p%nt management time to inform plant personnel, operations management failed to inform operations shift personnel of the decision to delete the clarifications until questioned by the inspectors. Also, the inspectors identified that LAP-1200-17 provided no guidance regarding the timeliness of the removal of the deleted clarifications from the controlled manuals, even if the deleted clarifications were determined to be non-conservative. Regulatory Assurance personnel removed the deleted clarifications from the controlled TS clarification sets once identified by the inspector.
c.
Conclusions The inspectors concluded that operations personnel followed plant procedures and were attentive to plant equipment. The licensee responded well to the partialloss of offsite power. Regarding the TS clarifications, the inspectors determined that communication of operational information to shift personnel was not timely. However, the safety significance was minimal as none of the deleted clarifications were applicable at the time of the inspection.
O2 Operational Status of Facilities and Equipment O2.1 Operability of SBM ISwitch Board. Miniaturel Control Switches a.
Inspection Scope (71707)
The inspectors reviewed the licensee's action to address control switch failures identified by the operators. Documents reviewed by the inspectors included problem identification forms (PlF), an operability 7 valuation, the vendor manual for the SBM switches, and the Updated Final Safety Analysis Report (UFSAR).
b.
Observations and Findinos On January 3,1998, licensed operators identified that a control switch for the 18 outboard main steam isolation drain valve failed to spring retum (automatically) to the normal position. Since that time, the licensee identified similar problems on other switches. To determine the root cause of the switch failure, the licensee sent the switch to General Electric (GE) for a failure analysis. On January 14,1998, GE notified LaSalle that the torque on the tie bolts on the switch was not within specification, which potentially impacted the seismic qualification of the switch, however the switch was not binding.
Subsequently, GE completed an evaluation of the less-than-required tie bolt torque and
concluded that the switches would remain operable vath larque values as low as 3.3 inch-pounds. LaSalle engineers reviewed the GE data and conclusions and verified j
that the SBM switches installed at LaSalle were operable, maintaining seismic
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qualification with reduced torque on the tie bolts.
Following the initial failure analysis performed by GE, the licensee sent an additional switch for failure analysis that failed to spring return to the normal position. The licensee also performed testing at their C-Team facilities. Both analyses determined that the
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switches failed to spring return to the normal position because of inadequate clearances I
on the bearing surface of the assembly. The inadequate clearar,ces were the result of post-mold shrinkage of the bearing assembly, aggregated when the tie bolts on the
assembly were torqued. On January 23,1998, GE issued a 10 CFR 21 notification to provide the information concerning the failure of certain SBM switches with the spring retum function to reset (spring return to normal) following operation.
To address the issue at LaSalle, the licensee implemented corrective actions which included the following:
Implementation of an interim Daily Order to have operators verify smooth
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opnration of switches, observe correct switch response, and verify that the switches spring return to the normal position.
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Document deficiencies for disposition.
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Suspension of SBM switch replacements.
- Preparation of an operability evaluation and repair plan to address the defective
switches.
The inspectors reviewed the licensee's evaluation and corrective action for the switch failures. Overall, the licensee took appropriate action for the switch failures and the corrective actions appeared appropriate. However, the inspectors identified the following
problem:
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incorrect PlFs Operators initiated PlFs when SBM switch prob' ems were observed during routine plant operations. On several PIFs, the Shift Manager did not make a conclusion with respect to the operability of some of tLa switches, although the switches were on operable systems. Instead, the PlF indicated that equipment operability was "not applicable" to the switch. When the inspector questioned the conclusion and the operability status, the licensee indicated that the switches were operable, but degraded. The inspector identified that the PIF has a default that identified the operability status of equipment as
"not applicable"if the Shift Manager does not specifically identify the operability status (i.e., "yes" for operable, "no" for not operable). No adverse consequences resulted from failing to evaluate operability on the PlFs since action requests (AR) were generated to replace the defective switches and operability of the switches was evaluated as part cf the AR process. In addition, the licensee addressed the switch operability on a generic basis in Operability Evaluation No. OE 98001. The licensee made corrections to the data
base program which was used to generate the PlFs to remove the "not applicable" default condition when determining the operability status of equipment.
c.
Conclusions The licensee took appropriate action to identify the root cause for the SBM failures and developed corrective actions. The licensee's final resolution of the SBM issues was not complete at the end of the inspection period. The licensee was still evaluating the scope of SBM switches that will need rep!acement prior to plant restart.
O2.2 Enaineered Safety Feature (ESP) System Walkdowns (71707)
a.
Inspection Scope (71707)
Throughout the inspection period the inspectors walked down accessible portions of the following Unit 1 ESF systems:
residual heat removal (RHR) Unit 1
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high pressure core spray (HPCS)
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b.
Observations and Findinas Overall, the inspectors did not find any problems which would render the equipment inoperable and material condition appeared acceptable. However, the inspectors noted the general conditions in reactor building high radiation areas were indicative of continued problems with housekeeping practices. Specifically, the inspectors identified left over materials from maintenance activities, damaged lagging, and poor lighting. In addition, inspectors found two instances of temporary shielding in which the plastic restraints holding the shielding to the pipe had stretched, allowing the shielding to hang approximately one foot below the horizontal section of pipe to which it was affixed. The inspectors noted that many of the conditions were of the same nature as those described in the previous inspection report (50-73/97022(DRP); 50-374/97022(DRP)). The inspectors verified that operations personnel subsequently entered all noted conditions into the licensee's corrective action program and that the corrective actions from the previously identified housekeeping conditions were stillin the process of being implemented.
c.
Conclusions Overall, the inspectors did not find any potential problems which would render the inspected ESF equipment inoperable and material condition appeared acceptable. The inspectors noted continued problems with housekeeping practices in the plant as exemplified by materials remaining following maintenance activities, damaged lagging, and poor lighting. However, the licensee's corrective actions for previously identified housekeeping issues were still being implemented.
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Operations Procedures and Documentation (71707)
03.1 Deficiencies Related to the Locked Valve Proaram i
a.
Inspection Scope (71707)
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The inspectors evaluated the licensee's actions to address a valve that was not adequately locked to prevent opening. The inspectors interviewed operations and engineering personnel, and reviewed documentation which included the licensee's prompt investigation and LAP-200-3, " Conduct of Operations - Shift Operations,"
Revision 30, Section 26, " Locked Valves."
b.
Observations and Findinas
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On February 10,1998, the licensee performed a configuration control walkdown in preparation for an upcoming NRC inspection. Operations personnelidentified that the locking mechanism for a suppression pool side test tap upstream isolation valve was not secure. The valve was in the required closed position with a lock and chain installed.
However, the chain was not appropriately attached which allowed the valve handle to be turned. The safety-significance was minimal as the valve was in the correct position, the downstream isolation valve was closed and locked, and the test tap outlet was capped.
Operations personnel implemented immediate corrective actions which included correctly j
locking the valve closed and verifying the position of all locked valves on all operable i
systems (emergency core cooling systems, emergency diesel generator and support systems, primary containment valves, and the shutdown cooling system). All valves inspected by the licent.ee were found locked in the required positions. The licensee determined in their prompt investigation that the valve had last been repositioned on August 27,1997, following local leak rate testing, and had been independently verified to be locked in the closed position. Operators had incorrectly fastened the lock at a position which still allowed the valve handle to be operated because the chain used in conjunction with the locking device was excessively long.
During a review of the licensee's locked valve program, on February 11,1998, the inspectors identified that LaSalle Operating Procedure (LOP)-LV-01(2)M, " Unit 1(2)
Locked Valve Position Checklists," had not been cornpleted within the last 18 months as required by Step B.2.10 of LAP-200-3, Section 26. The licensee previously identified that the locked valve program had not been implemented as procedurally required and on July 8,1997, initiated PIFs L1997-04307 and 04337. The licensee concluded the failure to verify locked valve positions every 18 months as required was an administrative issue requiring a procedure revision to remove the requirement. However, operations personnel did not initiate corrective actions to change the procedure. Instead, the licensee subsequently initiated a degraded equipment log entry on December 12,1997, which indicated that alllocked valves were in a degraded status due to failure to complete the 18 month position verification. The licer ne determined that equipment operability was not affected. The degraded equipment,ug entry was to remain in effect until a procedure change, which was initiated on December 23,1997, removed the 18 month position verification requirement. The inspectors identified that the procedure change request had been given a low priority for completion and had not been assigned a specific due date for completion. Failure of operations department personnel to identify and
j implement corrective actions to revise the locked valve program is a violation of
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10 CFR Part 50, Appendix B, Criterion XVI. However, because this violation satisfies the criteria in Section Vll.B.2, " Violations identified During Extended Shutdowns or Work Stoppages," of the " General Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement Policy), a Notice of Violation (NOV)is not being issued.
Specifically, the violations were related to problems which were present prior to the events leading to the shutdown, the violations would not be classified at a severity level higher than Severity Level 11, the violations were not willful, and enforcement action was not considered necessary to achieve remedial action, in addition, actions specified in Confirmatory Action Letter Rill-96-0088 effectively prevent the licensee from restarting LaSalle County Station without implicit NRC approval.
c.
Conclusions
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The inspectors concluded that the prompt investigation and immediate corrective actions implemented by operations department personnel following the recent identification of an improperly engaged locking device were appropriate. Also, the licensee's actions which verified the correct locked status of valves in operable systems minimized the significance of the event. However, the licensee's corrective actions for the previous locked valve program problems were neither thorough nor effective which resulted in the continued failure to properly implement the locked valve program.
Miscellaneous Operations issues O8.1 LaSalle Station Restart Action Plan Review a.
Inspection Scope (71707)
The inspectors reviewed the implementation status of various restart action plans specified in the NRC Restart Plan for LaSalle Station, dated December 16,1997.
b.
Observations and Findinas (Open) C.2.2.a. - Goals and Expectations Communicated and Understood by the Staff The inspectors verified the implementation of the LaSalle Station Restart Action Plan 2.1, Step 1, " Expectations - Establish Clear Expectations for Human Performance and Interaction," established to improve human performance for support of safe plant operation. The objective of the strategy was to provide a near-term siep-change in the human performance and teamwork of site workers. The performance standard defined in the plan to evaluate the effectiveness of the licensee's actions to achieve the objective was an improving trend in the average days between resets of the station event free clock.
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To accomplish this action step, the licensee held various meetings for all station employees, communicated station goals, and provided the overall performance expectations for plant management and plant staff. At various All-Station Meetings, licensee management discussed the station goals and management expectations of the plant staff. The station goals included a safe, uneventful startup; a safe,long uneventful run; and finally, world-class performance. Management expectations of each individual's
contribution were strict procedural adherence, the strong use of the self-check program (STAR - stop, think, act, review), have a questioning attitude, and to demand resolution of issues. Additional actions implemented by the licensee in this area specific to maintenance personnel are discussed in Section M8.1.
Although the licensee implemented the actions in the Restart Plan for this area, errors attributed to personnel performance deficiencies continued to occur at the plant and the licensee had reset the station event free clock four times during this inspection period.
Two instances are discussed in Sections E2.2 and F4.1. In addition, violations involving personnel error are discussed in Sections 08.2 and E2.2. As a result, at the time of the inspection, the licensee was not meeting the plan's restart goal which necessitated an improving trend in this area. This item will remain open pending further NRC review in this area.
l (Open) C.2.2.h. - Ms.naaement's Ability to Coordinate Effective Corrective Actions The inspectors verifiec~ the implementation of the licensee's Restart Action
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Plan 5.1, Step 8, which consisted of the implementation of the Commonwealth Edison (Comed) Nuclear Station Work Procedures (NSWPs) related to the corrective action process. The procedures, Nos. NSWP-A-10 through NSWP-A<17, were implerrented on May 12,1997, and training on the new procedures was provided to site personnel. The implementation of the action plan steps related to improving the corrective action process at LaSalle was completed on September 17,1997. The station demonstrated improvement in the corrective action process by implementing the NSWPs. However, ineffective corrective nictions were identified by the inspectors during this inspection period as described in Sections 03.1 and E2.2. In addition, at the time of the inspection, the licensee was not meeting the plan's restart goal which necessitated less than or equal to two significant repeat events per month. This item will remain open pending review of the licensee's implementation of Action Plan 1.1.A, Step 15.
(Open) C.2.1.a. - Effectiveness of the Quality Assurance Proaram The inspectors reviewed the implementation of the licensee's Restart Action Plan 5.2, which was established to improve the Quality and Safety Assessment organization's ability to diagnose nuclear safety and quality concems. An evaluation of recent performance with respect to Quality and Safety Assessment audits in the engineering area is described in Section E7.1. This item will remain open pending further review during a planned safety assessment / quality verification inspection.
(Open) C.2.2.e. - Manaaement's Demonstrated Awareness of Dav-to-Day Operational Concems The inspectors reviewed the implementation of the licensee's Restart Action Plan 1.28, Step 9, which was establish d to ensure that a monthly prioritization review of the status of temporary modifications (TMODs) would be accomplished by the applicable groups and that management would be informed of issues impacting the ability to achieve the TMOD removal performance standard. The performance standards defined in the plan were no significant TMODs installed at startup as determined by station management and no TMODs greater than 30 days old without an action plan.
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The licensee identified areas for discussion during the daily staff meeting addressing
areas which included corrective actions, operator work arounds, and TMODs. The TMOD l
coordinator informed management of temporary alteration resolution status and issues which required management attention for resolution. Operations and engineering department personnel were monitoring installation and removal of temporary alterations which were identified in the restart plan for removal during L1F35 and had incorporated
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these temporary alterations into the plant work schedule. The TMOD coordinator
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informed the inspectors that the number of temporary alterations scheduled to be removed prior to completion of the L1F35 outage might not be sufficient to satisfy the restart readiness measure of less than or equal to ten temporary alterations that had been installed for greater than one refuel outage. Engineering and operations personnel performed a review of the modification removal schedule and determined the restart readiness measure would be satisfied. The inspectors determined that meetings to review TMOD removal status were effective and licensee management was being adequately informed of the TMOD removal status and any barriers to schedule implementation. This item will remain open pending review of the licensee's i
implementation of Restart Action Plan 1.2.A, Step 16 and 1.2.C, Step 6.
(. pen) C.2.2.a. - Manaaement's Ability to Coordinate Resolution of Sionificant issues O
The inspectors reviewed the implementation of LaSalle County Station Restart Action Plan 1.28, Steps 10 and 11, established to reduce operator challenges from TMODs by ensuring that the TMOD closure plans would be reviewed against restart criteria with justifications approved by management for those TMODs which would be deferred from the L1F35 outage.
The inspectors reviewed the station work schedule, several TMOD packages, and one justification for removal and determined that licensee management had evaluated temporary alteration closure plans for restart applicability and had provided written justification which defined the safety impact and impact on operations department personnel for those temporary alterations that had been removed from the L1F35 outage j
scope. This item will remain open pending review of the licensee's implementation of Restart Action Plan 1.2.A, Steps 12 and 15; 1.2.C, Step 5; and 5.1, Step 8.
(Open) C.3.3.a. - Operator Loa Keepina Practices The inspectors verified the implementation of LaSalle County Station Restart Action Plan 1.1 A, Step 4, which was initiated to improve operator performance. The licensee's plan was to monitor operator logs for completeness, legibility, and conformance with expectations and initiate corrective actions where standards were not achieved. The inspectors reviewed the shift manager's, control room unit, radioactive waste, and outside operator logs on many occasions during the inspection period. While actions implemented by the licensee had improved operations department log keeping, the licensee identified one instance where significant information was not included in the shift logs.
On February 26,1998, operations personnel responsible for the radioactive waste treatment initiated a PIF which documented a spill of approximately 10 gallons of contaminated water which occurred when operators were preparing the 1B fuel pool cooling filter for service. The licensee's initialinvestigation and corrective actions for the
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spill were appropriate. However, the radioactive waste operators failed to document the spillin the shift logs. On February 27,1998, during the operations department pre-shift brief, the shift manager discussed the expectation that all significant activities would be documented in the logs to allow circumstances surrounding events to be reconstructed.
The inspectors determined that a late entry had been made by the licensee to update the radioactive waste log once the deficiency had been identified. Also, operations personnel initiated a PlF identifying the log keeping deficiency, determined the cause of the deficiency to be human performance, and implemented corrective actions, The inspectors determined the actions taken to be appropriate and in accordance with the action plan. This item will remain open pending further observation and review during a planned NRC restart readiness inspection.
(Open) C.4.h. - Effectiveness of the Plant Maintenance Proaram includina Schedulina and Work Control
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The inspectors reviewed the implementation of Strategy 3 of LaSalle County Nuclear Station Restart Acticn Plan 3.1, Step 3, for improving schedule adherence. The inspectors verified implementation of the three specified action items. The three action items involved implementing daily department head and outage management meetings and ensuring all departments were represented in schedule preparation. Although the action steps had been implemented prior to the installation of modifications to the reactor water cleanup (RWCU) system, the inspectors noted that the scheduling period for this I
modification was completed 21 days over the scheduled 54 days.
The inspectors reviewed a root cause investigation report completed by 'he licensee to determine the causes for the RWCU system modification project delays. The report concluded that the root causes of the project delays centered around poor project management practices. In addition, the licensee Quality and Safety Assessment (Q&SA)
personnel identified 24 inappropriate actions reflective of poor work scheduling in the month of January 1998. The inspectors did not find any instances of scheduling errors affecting nuclear safety. However, scheduling errors continued to cause delays in outage l
work activities. This item will remain open pending additional NRC review in this area.
l (Open) C.4.k. - Enaineerina Backloa Manaaed and Impact on Operations Assessed i
The inspectors reviewed the implementation of LaSalle County Station Restart Action i
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Plan 4.2, Step 8.2, established to ensure the open engineering requests (ERs) were reviewed and resolved as necessary to support restart. The licensee identified that ERs were not consistently being screened for operability issues during the review process. As a result, engineering personnel completed an operability screening for ERs on operable systems and planned to review ERs for operability issues prior to inoperable systems being declared operable. The inspectors determined that the action plan was not fully implemented and the impact of ERs on operations not adequately assessed (see Section E2.1).
The inspectors reviewed the implementation of LaSalle County Station Restart Action Plan 4.2, Step 8.6, to reduce the number of TS clarifications to the minimum required for restart. The licensee reduced the number of open TS clarifications to four and planned to review all active TS clarifications for restart applicability prior to restart. The inspectors reviewed the open TS clarifications and identified no technical concerns. This item will
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remain open pending additional NRC review during a planned engineering and technical support inspection.
c.
Conclusions The inspectors concluded that the licensee was making progress in completing the LaSalle Station Restart Plan. Hcwever, the plan had not yet been fully effective at achieving two of the restart goals established in the plan. In particular, problems were noted in personnel performance and corrective action implementation. In addition, work scheduling deficiencies impeded timely completion of outage activities.
08.2 Implementation of Nuclear Station Work Procedures (NSWP)
a.
Inspection Scope The inspectors reviewed the licensee's implementation of the Comed Nuclear Station Work Procedures.
b.
Observations and Findinas The licensee implemented LAP-850-6, " Processing of Operating Experience (OPEX)
Information," Revision 8, on March 25,1995, to address the internal distribution requirements for the routing, review, and actions to be taken regarding external operating experience information. Subsequently, the licensee implemented a procedure developed by all the Comed nuclear stations, NSWP-A-06, Revision 0, " Operating Experience (OPEX)," for evaluating and initiating action for operating experience information at all nuclear stations. The procedure's primary objective was to ensure that lessons learned from operating experiences were used to prevent occurrences of such events and improve plant safety and reliability. The licensee implemented the procedure on February 27,1997.
The inspectors discussed the OPEX program with the OPEX coordinator, who stated that he was using NSWP-A-06 to perform his duties as part of the operating experience program at LaSalle. However, LAP-850-6 was an active procedure at LaSalle and was required to be used when performing activities related to the OPEX program, but had not yet been revised to ensure consistency between the LAP and the NSWP.
When implementing NSWPs, the licensee had a procedure in place to ensure that the appropriate reviews and approvals were conducted by station personnel before the implementation of an NSWP. The process, defined in NSWP-A-01," Generation and Processing of NSWPs," Revision 3, was implemented at the time when the NSWP for the OPEX program was implemented and required the site to perform the following:
Safety Evaluation of the new NSWP.
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Technical Review of the new NSWP.
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Review and address training requirements.
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Schedule implementation dates.
- Conduct an On-Site Review.
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Initiate changes or deletions to current station procedures.
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The NSWP review for the OPEX procedure was performed and documented by the licensee and required a change to the LAP. The change was necessary to ensure that the process described in the NSWP was used for evaluating new OPEX information, which was an enhancement to the OPEX program at the station. However, due to personnel error on the part of the OPEX coordinator, the changes to the LAP for the OPEX program had not yet been completed. Some station personnel used the LAP process for reference to route and evaluate OPEX information, althou0h the NSWP was being implemented by the OPEX coordinator at LaSalle.
The inspectors reviewed the other NSWPs to evaluate the extent to which NSWPs or Nuclear Station Procedures (NSPs) were implemented without adequate review or without required revisions or deletions to applicable station procedures. Since July 1996, 21 NSWPs and NSPs were implemented. Revisions to pre-existing plant procedures were required for five of the NSWPs. However, only LAP-850-6 was not revised contrary j
to the requirements of NSWP-A-01. In addition, the licensee subsequently revised the LAP-850-6 and reviewed all NSWPs and NSPs to ensure all existing plant procedure i
requiring revisions were completed. The licensee's failure to revise LAP-850-6 is a violation of 10 CFR 50, Appendix B, Criterion V. However, because this violation satisfies the criteria in Section Vll.B.2, " Violations identified During Extended Shutdowns or Work Stoppages," of the " General Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement Policy), an NOV is not being issued. Specifically, the violations
.
were related to problems which were present prior to the events leading to the shutdown, the violations would not be classified at a severity level higher than Severity Level 11, the violations were not willful, and enforcement action was not considered necessary to achieve remedial action. In addition, actions specified in Confirmatory Action Letter Rlll-96-008B effectively prevent the licensee from restarting LaSalle County Station without implicit NRC approval.
c.
Conclusions
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The majority of the NSWPs and NSPs were implemented by the licensee with required reviews completed to ensure conflicts did not exist between the new procedures and plant procedures already implemented. However, the failure to address an existing procedure in one instance wb's implementing an NSWP is an example of continuing problems regarding personnel performance. A recent adverse trend in this area is discussed in Section 08.1.
08.3 Confirmatory Action Letter (CAL) Review The licensee implemented all the actions described in CALs Rlll-96-008 and Rill-96-008A. The NRC's reviews of the licensee's actions to the circumstances surrounding the CALs were documented in inspection Reports 50-373/374-96008 and 50-373/374-96009.
08.4 50.54(f) Performance Indicators a.
Inspection Scope (71707)
The inspectors reviewed the development of selected 50.54(f) performance indicators, and interviewed operations, maintenance and plant management personnel.
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b.
Observations and Findinas The inspectors reviewed the following performance indicators:
99. Percent Rework Performance indicator C9, percent rework, was developed by the licensee to assess the quality of maintenance activities. Overall, the consistent decline in the rework percentage from 3.9 percent to 1.6 percent indicated that the quality of the maintenance activities was improving. The inspectors reviewed Nuclear Operations Division (NOD)-OA.39,
" Performance Indicators for Nuclear Generation Group (NGG)," Revision 3, and discussed the definition of rework with maintenance personnel. Based on the discussions, the inspectors identified that one aspect of the current definition of rework was not understood by several maintenance personnel responsible for identifying rework activities. Specifically, the inspectors found one instance of damage to equipment from an unrelated maintenance activity which the licensee did not identify as rework. The failure to classify the activity as rework was a direct result of not understanding the current definition of rework. The inspectors noted that the definition of the rework performance indicator was revised three times since the initial definition in NOD-OA.39, Revision 0, in April 1997. The current definition included damage to other equipment due to an unrelated maintenance activity.
The inspectors observed a rework committee meeting in which senior maintenance department and maintenance training department personnel determined which maintenance activities were classified as rework.' The inspectors noted that a thorough discussion of each rework item occurred with an emphasis on root cause determination and future prevention. The inspectors also considered the participation by maintenance training department personnel to be valuable, in addition, the committee members were conservative when classifying potential rework items.
C4. Temocrary Plant Modifications The inspectors reviewed open TMODs and the station work schedule. Also, the inspectors interviewed engineering and operations personnel. Operations and engineering personnel responsible for oversight of the temporary modification performance indicator were knowledgeable of performance indicator criteria and actions taken to reduce the number of temporary modifications in the plant. The licensee had incorporated the installation and removal of temporary alterations into the plant work schedule including the removal of TMODs not implemented to support the outage. In one instance, the TMOD coordinator updated management of TMOD status during a daily staff meeting and appropriate action was taken by plant management to resolve a deviation from an established workdown curve. The inspectors concluded the TMOD
- performance indicator accurately reflected the status of temporary modification resolution in the plant.
c.
ponclusions The percent of rework has been consistently declining and accurately reflected the improving quality of maintenance activities at LaSalle. The TMOD performance indicator i
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accurately reflected the status of temporary modification resolution and adequate processes were in place to ensure the TMOD goals would be achieved.
08.5 10 CFR 50.54(f) Letter Commitment Review I
a.
Inspection Scope (71707)
The inspectors reviewed licensee commitments, Nos. 68 and 69, pertaining to Comed's j
March 28,1997, response to NRC's request for information pursuant to 10 CFR 50.54(f).
b.
Observations and Findinos (Closed) Commitment Nos. 68 & 69: Development and implementation of safe, effective, simple, efficient, and fair processes and practices at each site by peer groups.
The licensee was participating in Nuclear Operations Division (NOD) (now Nuclear Generation Group (NGG)) Peer Teams such as Management and Administration, Operations, Outage, Work Control, Configuration Control, and others. The teams or groups were formed to improve processes and replicate improvements across the NGG.
For example, the Operations Peer Group drafted operations standards which were incorporated into procedures at LaSalle Station. Although the peer groups had been implemented, some activities initiated by the peer groups had not been implemented. For example, the five-week work scheduling process was implemented at other plants within Comed, but not at LaSalle. The LaSalle Station was in an extended outage for both Units and attempted to implement the schedule previously. However, problems with the work control process at the station delayed the implementation of the five-week schedule and the plan for its implementation was being evaluated by the licensee. The licensee was planning the final scope of work prior to restart of Unit 1 and the outage activities were not yet fully developed at the end of the inspection. In addition, the licensee was planning to implement a 12-week work scheduling process at the end of the outage. These items are closed.
c.
Conclusions The licensee made progress toward addressing 10 CFR 50.54(f) commitments discussed in the March 28,1997, letter to the NRC. The licensee implemented NOD Peer Teams in accordance with the commitments in the 50.54(f) letter.
08.6 Followup of Inspection items
.
(Closed) Violation 50-373/374-97006-01: Several examples of plant personnel failing to follow procedure.
The inspectors verified completion of the following corrective actions:
The licensee revised LAP-820-2, " Procedure Preparation and Revision,"
Revision 41, and LAP-820-2T, " Review and Approval Requirement Matrix for Procedures," Revision 7, and developed LAP-1200-23, " Procedure Technical Review and Control Process," Revision 0, to provide more specific requirements
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regarding verification and validation and end-user involvement in procedure development.
Through review of departmentalletters indicating completion and resulting
procedure change requests, the inspectors determined that the licensee had implemented a re-categorization of procedures as "Information,"" Reference," or
" Continuous Use."
The licensee changed the radiation protection technician training requirements to
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include LaSalle Radiation Protection Procedure 5271-6, " Construction of Radiologically Posted Areas and Step Off Pads Areas."
The licensee implemented extensive actions to improve plant personnel
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performance in accordance with their Restart Plan. The effectiveness of these actions will be evaluated in accordance with the NRC Manual Chapter (MC) 0350 Restart Plan for LaSalle Station.
This item is closed.
(Closed) Violation 50-373/374-97011-01: Inadequate corrective actions for inadequate instructions for performing a manual backwash of diesel generator service water strainers.
The inspectors visually verified that the 1 A diesel generator strainer hand crank had been shortened to eliminate the interference which prevented manual backwash. The inspectors also verified that LaSalle Operating Procedure (LOP) DG-04, " Diesel Generator Special Operations," Revision 23, and LOP-RH-14. " Backwash of the Residual Heat Removal Service Water Strainers," Revision 8, were revised to provide instructions for use of a special handle for manual backwash if the permanent handle was not present on the strainer. The licensee also implemented extensive actions to improve the corrective action program in accordance with their Restart Plan. The effectiveness of these actions will be evaluated and tracked in accordance with the NRC MC 0350 Restart Plan for LaSalle Station. This item is closed.
(Closed) Violation 50-373/96018-02: Operator did not have LaSalle Operating Surveillance (LOS) DG-Q2, "1 A Diesel Generator Auxiliaries," a " Reference Use" procedure, at the work location.
The inspectors verified that LAP 100-40, " Procedure Use and Adherence Expectations,"
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Revision 13, had been revised to provide more specific guidance to clarify expectations l
for having procedures at the work location. Through review of departmentalletters indicating completion and resulting procedure change requests, the inspectors determined that the licensee had implemented a re-categorization of procedures as
"Information,"" Reference," or " Continuous Use." This item is closed.
l (Closed) Violation 50-373/374-97011-04: Failure to source check the residual heat removal service water effluent monitor within the required interval due to personnel error.
j The inspectors verified that the licensee had revised LAP-100-11, "LaSalle County Station Surveillance Program," Revision 15, to better define an incomplete test and to ensure that i
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no performance credit would be given to incomplete surveillance tests. The licensee also implemented extensive actions to improve plant personnel performance in accordance with their Restart Plan. The effectiveness of these actions will be evaluated and tracked
!
in accordance with the NRC MC 0350 Restart Plan for LaSalle Station. This item is closed.
(Closed) Violation 50-373/374 96020-03: Inadequate out-of-service instruction for Unit 2, Division 2, battery charger circuit breaker.
The inspectors reviewed Operations Department Memorandum No.19, "Out-of-Service Expectations," Revision 2, dated January 13,1997. Attachment B to this document discussed the program in progress to make plant labels match the electronic work control system database and station procedures. It also provided interim guidelines to prevent hanging out-of-service cards on the wrong components. The inspectors reviewed LOP-DC-01, Revision 9, which had been revised through the addition of attachments to more specifically identify and locate associated breakers. The most current revis!on of this procedure, Revision 11, no longer contained the attachments, but corresponding information had been incorporated into individual sections for each battery charger. The inspectors also reviewed LAP-100-30, Revision 15, which had been revised to provide
" apart in time" independent verifications of out-of-services. This item is closed.
(Closed) Violation 50-373/97007-01: Failure to declare the 18 residual heat removal pump inoperable in a timely manner after it was found in the required action range during surveillance testing.
The inspectors reviewed a memorandum-to-file dated August 12,1997, which documented discussions held with the Shift Managers regarding this event. The memorsndum described management expectations for conservative decision making that were emphasized during these discussions. This item is closed.
(Closed) Licensee Event Report (LER) 50-373/95016: Unit 1 manual reactor scram due to emergency governor lockout valve sticking. The licensee determined that the valve sticking was caused by foreign material within the turbine lube oil system becoming l
lodged in the internals of the lockout valve. The licensee's corrective actions included an extensive flush of the turbine lube oil system. In addition, the licensee planned to install duplex filters in the lube oil supply lines and re-route the supply lines for all of the turbine driven recctor feed pumps prior to startup to prevent further foreign material entrapment.
This item is closed.
l 08.7 Previous Examples of Performance issues l
The following items occurred before the current LaSalle Station extended shutdown and are specif c examples of fundamental performance issues. During the extended shutdown, the licensee has been taking corrective actions to address these fundamental issues in accordance with their LaSalle Station Restart Plan and the NRC was evaluating the adequacy of these initiatives through the NRC MC 0350 Restart Plan for LaSalle Station. These issues include problems involving personnel performance; material condition; procedural adequacy; and the design, work control, safety evaluation, equipment operability evaluation, and corrective action processes. Therefore, the following items are closed with regard to further NRC tracking because:
the items were essentially superseded by the current LaSalle Station status and actions and do not necessarily represent current plant performance, the licensee was addressing the related fundamental performance issues through
+
actions described in the LaSalle Station Restart Plan, and the NRC staff was evaluating current indications of licensee performance and the
licensee's effectiveness in addressing these fundamental performance issues in accordance with the NRC MC 0350 Restart Plan for LaSalle Station.
Ensuring that appropriate actions were implemented to address these specific items remains the responsibility of the licensee.
(Closed) Violation 50-373/95004-01: Several examples of failures to follow procedure or inadequate procedures.
(Closed) Violation 50-373/96004-01: Failure to prevent recurrence of diesel generator
]
and emergency core cooling system pump start.
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(Closed) Violation 50-373/374-96006-01: Failure to perform safety evaluation of
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operating drywell monitors.
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(Closed) Violation 50-373/374-96007-01: Failure to take adequate corrective actions to prevent recurrence of a main steam isolation valve isolation and reactor scram.
(Closed) Violation 50-373/374-96007-02: Failure to perform TS surveillance to verify position of manual containment valves.
,
(Closed) Violation 50-373/374-96007-03: Failure to perform a TS required fire watch.
(Closed) Violation 50-373/374-96010-01: Failure to follow troubleshooting procedure.
(Closed) Violation 50-373/374-96013-02: Failures to follow shutdown and rnaintenance procedures.
(Closed) Violation 50-373/374-96013-03: Failure to follow out-of-service and work request instructions.
(Closed) Violation 50-373/374-96013-06: Failure to follow fire protection procedures.
'
(Closed) Inspection Followup Item (IFI) 50-373/95004-02: Incorrectly tagged valve resulted in personnel injury.
(Closed) IFl 50-374/95006-01: Operator response to steam leak hindered due to material condition.
(Closed) IFl 50-373/374-95006-02: Ineffective corrective actions for missed surveillance.
(Closed) IFl 50-373/374-96005-03: Resin intrusion due to reactor water cleanup system problems.
,
(Closed) LER 50-374/94008. Revision 0: Reactor scram due to electrohydraulic control line failure.
(Closed) LER 50-374/95009. Revision 0: High pressure core spray diesel generator and pump initiation due to procedural deficier :y.
(Closed) LER 50-374/95011. Revision 0: Inadvertent engineered safety features actuation and reactor core isolation cooling system isolation due to personnel error.
(Closed) LER 50-373/95018. Revision 0: Trip of reactor protection system bus resulting j
in half scram due to relay failure.
(Closed) LER 50-374/96002. Revision 0: Manual reactor scram due to 2E main power l
transformer.
(Closed) LER 50-373/96003. Revision 0: Reactor scram due to spurious spike of intermediate range monitor.
)
(Closed) LER 50-374/96003. Revision 0: Inadequate corrective action for design deficiency involving drywell cooler condensate flow rate monitoring system.
(Closed) LER 50-373/06004 Revision 0: Reactor protection system motor generator set electrical protection assembly breaker inadvertently tripped due to personnel error.
(Closed) LER 50-374/96004. Revision 0: Missed TS fire watch due to incomplete fire impairment permit.
(Closed) LER 50-373/96006. Revision 0: Manual scram due to high vibration on main turbine generator exciter caused by oil deflector on the vibration probe assembly at the exciter bearings rubbing the rotor shaft (Insufficient bore of the r'il deflector).
(Closed) LER 50-373/96007. Revision 0: Reactor scram on main steam flow high trip isolation during surveillance due to instrument technician work practice deficiency.
(Closed) LER 50-374/96007. Revision 0: Reactor water cleanup isolation on high differential flow.
(Closed) LER 50-374/96008. Revision 0: Inadequate review of out-of-service checklist results in TS violation.
(Closed) LER 50-373/96009. Revision 0: Missed TS surveillance on primary containment manual valve positions as a result of an inadequate Final Safety Analysis Report review.
(Closed) LER 50-374/96009. Revision 0: Potential degradation of post loss of coolant emergency core cooling system recirculation capability as a result of the discovery of foreign materialin the pressure suppression pool.
(Closed) LER 50-373/96010. Revision 0: Inadequate standards for TS clarifications.
(Closed) LER 50-373/96010. Revision 1: Inadequate standards for TS clarifications.
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(Closed) LER 50-373/96010. Revision 2: Inadequate standards for TS clarifications.
(Closed) LER 50-373/96010. Revision 3: Inadequate standards for TS clarifications.
(Closed) LER 50-373/96013. Revision 0: Emergency diesel generator fuel oil not analyzed in accordance with TS surveillance requirements due to procedural deficiencies.
(Closed) LER 50-373/96015. Revision 0: Misinterpretation of TS surveillance results in inoperable diesel driven fire suppression pumps.
(Closed) LER 50-373/96015. Revision 1: Misinterpretation of TS surveillance results in inoperable diesel driven fire suppression pumps.
08.8 Licensee Event Reports Previousiv Addressed issues associated with the following LERs were dispositioned in previous inspection reports. Therefore, these LERs are considered closed.
(Closed) LER 50-373/96008. Revision 0: Foreign material injected into service water tunnel due to inadequate work control causing dual unit shutdown. Licensee actions are being tracked in violations associated with escalated enforcement items in NRC inspection report 50-373/374-96009 (NRC Inspection Followup System numbers 373/374-96-325-01012,01022,01032,02013,02023, and 03014).
(Closed) LER 50-373/96008. Revision 1: Foreign material injected into service water
' tunnel due to inadequate work control causing dual unit shutdown. Licensee actions are being tracked in violations associated with escalated enforcement items in NRC inspection report 50-373/374-96009 (NRC Inspection Followup System numbers 373/374-96-325-01012,01022,01032,02013,02023, and 03014).
(Closed) LER 50-373/97009. Revision 0: Inadequate understanding of lake design basis.
Licensee actions are being tracked in Violation 50-373/374-97003-02a.
(Closed) LER 50-373/97025. Revision 0: Erroneous determination of residual heat removal system pump operability requirements. Licensee actions are being tracked in Violation 50-373/97007-01.
t (Closed) LER 50-373/97027. Revision 0: Equipment not seismically constrained to meet seismic category 1 areas. Licensee actions are being tracked in Violation 50-373/374-97011-05.
(Closed) LER 50-373/97027. Revision 1: Equipment not seismically constrained to meet seismic category 1 areas. Licensee actions are being tracked in Violation 50-373/374-97011-05.
(Closed) LER 50-373/97028. Revision 0: Residual heat removal increased frequency surveillance missed. Licensee actions were tracked in Non-cited Violation 50-373/97011-03.
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(Closed) LER 50-374/97001. Revision 0: Potential for missing fuel due to discovery of broken fuel pin. Licensee actions are being tracked in Violation 50-373/374-97011-07 and Inspection Followup Item 50-373/374-97011-08.
(Closed) LER 50-373/97032. Revision 0: Failure to comply with TSs due to nonconservative maintenance planning. Licensee actions are being tracked in Violation 50-373/374-97015-01, 11. Maintenance M1 Conduct of Maintenance M1.1 General Comments a.
Inspection Scope l
The inspectors observed all or portions of the following work activities:
WR960069045 02:
1FC03PB pump needs to have weld repair
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WR960069045 01:
1FC03PB pump vibrations trending upward
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WR970085110:
reinstall relief valve 2WR151 A
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WR970046800:
reactor core isolation cooling (RCIC) exhaust steam drain
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pot drain pipe replacement WR960042799 06:
B return fan suction damper; fabricate and install damper
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mounting bracket b.
Observations and Findinas The inspectors found the work package in active use at all in progress work activities.
Technicians were interviewed by the inspectors and demonstrated a detailed knowledge of assigned activities. The inspectors observed supervisors at the work locations including the mechanical maintenance shop.
The inspectors noted that activities for the 2A reactor building closed cooling water (RBCCW) heat exchanger relief valve, and the RCIC exhaust steam drain collecting pot were not being effectively controlled. Specifically, the foreign material boundaries established on each side of the RBCCW relief valve were not adequately secured. Also, the inspectors found two openings to the RCIC exhaust steam drain collecting pot open with no foreign material exclusion (FME) plugs installed and no workers present at the work site. Neither condition represented a safety-significant condition; however, both indicated communication and implementation of management standards was not fully effective. The inspectors discussed the FME issues with maintenance personnel, who subsequently took action to address the minor FME control problems.
c.
Conclusions
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f Maintenance activities were generally performed in an acceptable manner in conformance with work package requirements. Active supervision of work activities was observed. However, two instances of FME problems were noted by the inspectors, and were being addressed by the licensee.
M8 Miscellaneous Maintenance issues M8.1 Maintenance Leadershio Standards a.
Inspection Scope The inspectors reviewed a method the licenses used to communicate management expectations to the plant maintenance staff.
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b.
Observations and Findinas l
The maintenance department management implemented maintenance leadership l
standards to provide craft personnel, maintenance planners, and maintenance l
supervisory personnel with the maintenance managers expectations for performing l
maintenance work at LaSalle. Maintenance department management defined the role of the maintenance department and provided standards to ensure that the maintenance department could perform effectively and fulfill their role.
The maintenance management expectations were outlined in nine standards:
Standard 1:
General Maintenance Practices Standard 2:
Procedure Adherence Standard 3:
Self Checking and Additional Verification Standard 4:
Plant Materiel Condition Standard 5:
Safety
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l Standard 6:
Radiological Protection Standard 7:
Training and Qualification Standard 8:
Tool Use Standard 9:
Professionalism in Maintenance The standards were consistent with the expectations established by the Station Management. In addition, the inspectors discussed the standards with maintenance department personnel who were cognizant of the standards.
c.
Conclusions Maintenance department management communicated expectations to employees through
' the Maintenance Leadership Standards. The standards appeared adequate and the maintenance personnel were cognizant of managements expectations.
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M8.2 10 CFR 50.54(0 Letter Commitment Review i
a.
Inspection Scope (62707)
The inspectors reviewed licensee commitments, Nos. 48,49, 50,52,181,182, and 183 pertaining to Comed's March 28,1997, response to NRC's request for information pursuant to 10 CFR 50.54(f).
l b.
Observations and Findinos l
(Closed) Commitment No. 48: A standard screening process has been put in place at all six sites to ensure maintenance work is properly classified and prioritized.
l The screening committee knowledge base was a collection of disciplines representing l
different areas of the nuclear work process. The minimum of five members were required l
for a meeting. The minimum disciplines present to convene a Screening Committee Meeting were as follows:
Ucensed - has a current SRO license.
- l Engineering - is knowledgeable in engineering design and plant design and
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license basis.
Maintenance (IM, EM, MM)- is knowledgeable in the division and scope of work
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among the three maintenance departments.
Work Analyst -is knowledgeable in work requirements and package preparation.
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l Work Control (Scheduling) - is knowledgeable in work scheduling.
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Fix-It-Now (FIN) - is knowledgeable in FIN team capabilities.
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During the course of the screening process, the screening team members must assign a
priority to each of the reviewed action requests (ARs) and work requests (WRs). The
'
breakdown of the priority levels and criteria used to determine the priority category of each AR and WR was as follows:
"A" priority Emeroency work having an immediate and direct impact on the
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health and safety of the general public or plant personnel, poses a significant
,
l industrial hazard, or require immediate attention to prevent the deterioration of
plant condition to a possible unsafe or unstable level.
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"B1" priority Uraent work that should be scheduled and started within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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"B2" priority Emeroent work that should be scheduled and started within two
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weeks.
"B3" priority Emeroent work that should be scheduled and started within five
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weeks.
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C" priority Routina work that follows the normal scheduling process.
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The licensee stated that the screening committee was meeting five days a week and reviewed 50 to 80 AR's each meeting. The inspector reviewed PlFs for the previous eight months from a search on " maintenance-priority". None of the PlFs were noted to have been written for mis-prioritizing the work request. The screening committee may send the AR/WR to the FIN team for processing within the team. This item is closed.
(Closed) Commitment No. 49: Work planning is being evaluated to identify inefficiencies in the planning process that prevent work from being performed.
The licensee stated that the evaluation for inefficiencies in the process was ongoing and the interim report was scheduled for May 1,1998. The inspector's review of recent PlFs indicated problems in the planning and scheduling maintenance work were still present.
Additional reviews in this area will be tracked through evaluations performed in conjunction with the NRC's Manual Chapter 0350 LaSalle Station Restart Plan item C.4.h, " Effectiveness of the plant maintenance program including scheduling and work control." Therefore, this item is closed.
LClosed) Commitment No. 50: All sites are currently implementing a minimal work request process which enhances job planning for minor work.
The Station has approved the minimal work request process per the Minor Maintenance Process NSWP-WM-06. The screening process defined in NSWP-WM-08 defined how the screening committee would address minor maintenance as "Toolpouch" maintenance or" Minimal Work Request". The Station has been using the minimal work process for 100 to 150 tasks a month.
Additional reviews in this area will be tracked through evaluations performed in conjuction with the NRC's Manual Chapter 0350 LaSalle Station Restart Plan item C.4.h,
" Effectiveness of the plant maintenance program including scheduling and work control."
Therefore, this item is closed.
(Closed) Commitment No. 52: The amount of emergent work completed by the Fix-It-Now (FIN) teams was measured to determine the effectiveness of the initiatives.
The FIN team was established as a self-contained team that could perform work with limited dependence on external resources per procedure NSWP WM-05, Revision 0.
With the team performing short duration emergent work, the scheduled work would be protected from disruption by rescheduling to allow priority emergent work to be performed. The FIN team was limited to the day shift work, work that was not involved in areas covered by Operational Analysis Division (OAD) and substation construction departments, and work with a duration of eight hours or less. The goal was the performance of 50% of the emergent A, B1 and 82 priority work.
l The inspectors reviewed the monthly performance data which showed that the FIN team was performing about 50 percent of the emergent priority A, B1 and B2 maintenance
'
work, by the number of jobs completed. The Station was also training more personnel as FIN team members to replace team members, and to provide for a larger team, as the
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team has commenced to work the non-outage maintenance 83 and C priority work requests. This item is closed.
(Closed) Commitment No.181: Implementing work control processes improvements to allow work to be efficiently completed in the field and to minimize the occurrence of inadequate work packages.
The licensee implemented the following processes improvements:
wo t package quality improvements.
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work package quantity.
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FIN team implementation.
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AR pre-screening.
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work request backlog reduction.
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Additional reviews in this area will be tracked through evaluations performed in conjuction with the NRC's Manual Chapter 0350 LaSalle Station Restart Plan item C 4.h,
" Effectiveness of the plant maintenance program including scheduling and work control."
Therefore, this item is closed.
(Closed) Commitment No.182: Including critical work processes and programs in the scope of department self-assessment activities and implementing self-assessments focused on specific programs.
The inspectors verified that the Station had implemented LAP-1500-9, "Self-Assessment,"
Revision O. Attachment A to the procedure contains suggested topics for self-assessment activities. This item is closed.
(Closed) Commitment No.183: Developing performance measures for critical work
/
processes.
The licensee had developed a set of performance iridicators to measure work processes that were placed in the monthly NOD indicator report. The October 1997 report contained 25 process indicators and the November 20,1997, and the weekly report contained 12 process indicators.
Additional reviews in this area will be tracked through evaluations performed in conjuction with the NRC's Manual Chapter 0350 LaSalle Station Restart Plan item C.4.h,
"Eifectiveness of the plant maintenance program including scheduling aM work control."
Therefore, this item is closed.
c.
Conclusions The seven action items were found to be in place and generally functioning at the LaSalle station. The introduction of the FIN team process appears to have provided assistance in all phases of the maintenance and planning proces ses.
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111. Enaineerina E2 Engineering Support of Facilities and Equipment E2.1 Enaineerina Requests (ER) Not Screened for Operability Issues a.
Inspection Scope (37551)
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The inspectors evaluated the licensee's actions to address open ERs that may not have been screened for potential operability issues. The inspectors interviewed operations and engineering personnel and reviewed LAP-1300-16, " Engineering Request," Revision 2.
b.
Observations and Findinas I
On February 19,1998, during an engineering self-assessment of the ER program, engineering personnelidentified that the ER screening process did not include a process for identifying and evaluating potential operability issues associated with an ER. The engineering self-assessment group celected 24 of 3800 open ERs to evaluate and identified potential operability concems. The assessment group determined that, while management's expectation was that the corrective action process would be used to h
identify operability concems, the ER procedure did not specifically require a problem identification form (PIF) be generated by individuals that identified an operability concem.
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Thus, licensee personnelinitiated some ERs without the cor esponding PlFs being generated to ensure operability issues were evaluated.
Licensee management implemented several corrective actions which included:
Resolving the potential operability concerns from the 24 ERs reviewed by
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engineering. The limsee determined that no operability evaluations were
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necessary.
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Performing an initial assessment of 701 open ERs on operable systems which
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resulted in one operability evaluation and no inoperable systems or components.
Placing operations personnelin the review cycle for newly generated ERs.
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Developing a plan to review all ERs for impact on TS systems not currently
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required to be operable. The lic*nsee planned to complete the ER reviews on
_
systems prior to declaring the systems operable.
c.
@_nclusions Engineering personnel have continued to identify engineering issues during system and program reviews, some potentially affecting equipment operability. The inspectors
determined the immediate and long-term corrective actions regarding the ER associated operability issues identified during the self-assessment were apfropriate.
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E2.2 Inadeauste Corrective Action Forinadeauste Inservice Test a.
Inspection Scope (92700. 37551)
The inspectors reviewed circumstances surrounding an inadequate test of the manual I
backwash function of the residual heat removal service water (RHRSW) strainers. The
inspectors reviewed Pifs and LOP-RH-14. " Backwash of the Residual Heat Removal I
Service Water Strainers," Revision 9.
I b.
Observations and Findinas On February 3,1998, the licensee identified that manual testing of the RHRSW strainer backwash function was not performed as required by TSs and the inservice testing (IST)
z program. Specifically, the RHRSW strainer backwash va!ves,1E12-F336A and B, were
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required to be manually exercised as part of the IST program because the manual operation of the valves was a safety-related function. When the issue was identified, operators declared the RHRSW system inoperable and performed testing of the manual backwash valves using procedure LOP-RH-14. The; inspectors reviewed the test procedure and did not identify any problems. In addition, the procedure was revised to ensure required testing was performed in the future.
During the NRC service water system inspection conducted in SeptemJer 1996, the NRC identified that the backwash valves were not being tested as required. The licensee initiated corrective actions during the service water inspection to verify that the manual backwash function was performed and a procedure change request (PCR) was initiated to manually exercise the valves quarterly. However, the PCR was not scheduled to be
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completed until September 1997, one year after the issue was identified by the NRC and when the licensee initiated the corrective actions. In addition, the PCR was deferred two times, with the latest due date for completion of the PCR being March 3,1998. The inspectors questioned the rational for deferring the PCR and the licensee indicated that it was an error which occurred due to a lack of a complete understanding of system operability requirements related to the IST program requirements.
The licensee's corrective actions for the inadequate testing of the RHRSW backwash j
valves identified in September 1996 were not effective to ensure that the PCR would be
completed and the appropriate testing of the manual backwash function of the valves would be incorporated into the plant surveillance program. The inadequate corrective action is a violation of 10 CFR Part 50, Appendix B, Criterion XVI. However, because this violation satisfies the criteria in Section Vll.B.2, " Violations identified During Extended Shutdowns or Werk Stoppages," of the " General Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement Policy), an NOV is not being issued.
Specifically, the violations were related to problems which were present prior to the events leading to the shutdown, the violations would not be classified at a severity level higher than Severity Level 11, the violations were not willful, and enforcement action was not considered necessary to achieve rems Aial action. In addition, actions specified in Confirmatory Action Letter Rill-96-008B effectively prevent the licensee from restarting j
LaSalle County Station without implicit NRC approval (50-373/98004-01b).
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c.
. Conclusions The licensee's corrective action program improvements were implemented in May 1997, following the initial identification of the issue, but prior to deferral of the PCR on two occasions. In this case, the corrective actions ident;fied in September 1996 for the failure
~ to test the manual backwash valves for the RHRSW strainers were ineffective to ensure that the deficiency was promptly corrected. The failure to incorporate testing into the plant surveillance program resulted from a personnel performance error.
E7 Quality Assurance in Engineering Activities
. E7.1 Quality and Safety Assessment (Q&SA) Proaram Reviews a.
Inspection Scope (40500)
The inspectors reviewed the audit results of various engineering programs performed by the Q&SA organization at LaSalle.
b.
Observations and Findinas The licensee's Q&SA organization performed reviews of several station programs to t
evaluate program implementation. Programs reviewed by Q&SA included:
Fire Protection
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Equipment Qualification
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Generic Letter 89-13, " Service Water System Problems Affc.cting Safety-Related
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Equipment" Vendor Technical Information Program (VETIP)
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l American Society of Mechanical Engineers (ASME) Code Activities (Inservice
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inspection and Inservice Testing)
- Preventive Maintenance (PM)
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Appendix J
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The Q&SA auditors reviewed (where applicable) the program administration, system design, equipment maintenance, testing and surveillance, lessons leamed, and corrective actions. The licensee documented the findings of the reviews and issued PIFs for identified problems. The audits were performed by the licensee partly to review the programs to ensure that they were adequate for restart and potential issues that could affect plant restart were identified ar.d corrected.
The inspectors reviewed the issues identified by the licensee and the resolution of the issues by station personnel. The inspectors determined through this review that the program reviews performed by Q&SA personnel were through and a good initiative.
Examples of issues identified by the licensee in the fire protection area are discussed in Section F4.1 of this report.
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c.
Conclusions The inspectors concluded that the program reviews performed by the Q&SA personnel were thorough and a good initiative. Station personnel documented for resolution findings resulting from the reviews.
jy. Plant Support F2 Control of Fire Protection Activities F4.1 Fire Protection Proaram Issues a.
Inspection Scope (62704)
Th inspectors reviewed the results of an evaluation of the fire protection program performed by the licensee's Q&SA organization. In addition, the inspectors reviewed fire watch logs, the UFSAR, Comed Nuclear Design Information Transmittal (NDIT)
No. LAS-ENDIT-0712, " Fuse and Breaker Coordination for the 125 Vdc Safe Shutdown Control Circuits for the RHR Service Water Pump 1C," and Concem Screening Form for operability Evaluation No. OE 98006.
b.
Observat!ons and Findinas During the review of the Fire Protection Program conducted by the Q&SA organization (see Section E7.1), the licensee identified missed hourly fire watch inspections, issues associated with the 125 volt DC and 120 volt AC safe shutdown c( nt.ol circuits, and a potentially non-conservative fire stop analysis for various plant fire prc4ection materials.
The three issues reviewed by the inspectors are detailed below.
Missed TS Fire Watch Inspections On January 31,1998, the licensee identified that two contract fire watch inspectors each j
failed to perform two hourly fire watch inspections although they had documented the inspections as complete. The licensee immediately terminated the employment of both contractors from all Comed facilities and implemented corrective actions. The corrective actions included briefings on the events and the expactations for procedure adherence.
in addition, the licensee revised the guidelines govei.nng the fire watch inspections to
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more clearly define expectations and was increasing supervisory oversight of the fire i
watch inspectors.
The licensee identified another example of a missed fire watch inspection on February 27,1998. The fire watch inspector had left the station after completing his shift without any fire watch inspector available for the next hourly fire watch duties. The licensee determined that the root causes involved inadequate communications between the supervisor and the fire watch inspector who left the station and the lack of adequate process controls. The licensee subsequently established controls which required the fire watch inspectors to report to the work control center (WCC) senior reactor operator (SRO) before and after scheduled inspections to ensure that fire watch inspectors were available for all required inspections. The licensee also established training to discuss i
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the event with all fire watch personnel. In addition, the licensee revised the procedural guidelines for fire watch inspectors to incorporate the expectations for both the fire watch inspectors and their supervision. Corrective actions also included increased supervision arid other process controls that were identified in LaSalle System Engineering Action Plan 98-06.
The inspectors considered the root causes of these missed fire watches to be sufficiently different as to not constitute a repetitive problem. The licensee's failure to perform hourly fire watch inspections is a violation of TS 3.3.7,9. However, this non-repetitive licensee identified and corrected violation is being treated as a non-cited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-373/374-98004-03).
Lack of Calculations for the 125 Volt DC and 120 Volt AC Safe Sht.tdown Control Circuits The inspector reviewed the licensee's action plan to address the lack of calculations demonstrating electrical breaker and fuse coordination for the 125 volt DC and 120 volt AC safe shutdown control circuits. The Q&SA auditors identified that the control circuits for the 1C RHR service water pump did not fully isolate the remote portion of the local / remote transfer switch. The lack of coordination could disable the local portio:) of the switch in the event of a fire induced short, rendering the 1C RHR service water pump unavailable to support safe shutdown until fuses are replaced. The licensee completed a coordination calculation, documented in LAS-ENDIT-0712, of the 125 volt DC safe shutdown control circuits and demonstrated that adequate coordination existed.
Generically, the licensee evaluated the potential for the lack of coordination and concluded that the design provide reasonable assurance that clectrical coordination between control fuses and breakers would not result in the loss of common power fuses.
However, the licensee planned to perform calculations to document the coordination during the ongoing design basis reconstitution effort. In addition, the NRC is to review portions of the electrical system during a planned engineering and technical support inspection.
Potentially Ncn-Conservative Fire Analysis The inspector reviewed the Operability Screening Form for operability evaluation No. OE 98006 which was completed by the licensee to address the use of polyethylene /pulyvinyl chloride (PVC) as material in electrical fire stop penetrations (i.e.,
cable tray penetrations), the use of which may have been non-conservative. Electrical fire stop justification No. SCM-32-68 dated August 19,1993, used a material that was less flammable than the polyethylene /PVC that was used in some penetrations.
However, the UFSAR indicated other material types which were used and were not considered in the fire stop justification. The licensee conducted fire tests in accordance with fire test standards using the polyethylene /PVC material which passed the qualification tests. Therefore, the results of the operability evaluation indicated that the penetration fire stops were operable and the fire stop analysis was acceptable. The conclusion reached in the operability evaluation was based on the evaluation of the polyethylene /PVC as the worst case with respect to fire resistance. Because the polyethylene /PVC was worst case for the fires stop penetrations, and the actual cable routed in the cable trays was IEEE-383 qualified, the licensee concluded that the justification was adequate. The inspectors had not yet reviewed the analysis to determine the adequacy of the polyethylene /PVC test and how it compared to the
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penetration seal configurations in the plant, which would impact the acceptability of the fire stop analysis for the cable tray penetration seals. This is an unresolved item pending furtt.er NRC review (50-373/374-98004-04),
c.
Conclusions -
The licensee performed an in-depth review of the fire protection program and identified potential issues requiring resolution by the licensee. The inspector concluded that the licensee resolved the issues in a timely manner and planned additional actions to improve the program overall.
F8 Miscellaneous Fire Protection ($wues F8.1 (Closed) LER 50-373/98001: IA sed TS Fire Watch Due To Personnel Error. The issues related to this LER were discussed in Section F4.1 of this report. This LER is closed.
V. Manaaement Meetinos X1 Exit Meeting Summary The inspectors presented the results of these inspections to licensee management listed below at an exit meeting on March 10, i998. The licensee acknowledged the findings presented. The inspectors asked the licensee if any materials examined during the inspection should be considered proprietary. The licensee identified none.
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PARTIAL LIST OF PERSONS CONTACTED Comed
- F. Dacimo, Site Vice President
- T. O'Connor, Plant Manager
- S. Smith, Restart Manager
- G. Poletto, Engineering Manager
- W. Riffer, Quality and Safety Assessment Manager
- G. Heisterman, Maintenance Manager D. Sanchez, Site Training Manager D. Boone, Site Support Manager D. Enright, Operations Manager
- R. Palmieri, System Engineering Supervisor
- N. Hightower, Health Physics Supervisor D. Rhoades, Chemistry Supervisor
- P. Barnes, Regulatory Assurance Supervisor
- Present at exit meeting on March 10,1998.
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INSPECTION PROCEDURES USED IP 37551 Onsite Engineering IP 40500 Effectiveness of Licensee Controls in identifying, Resolving, and Preventing Problems IP 61726 Surveillance Observation IP 62707 Maintenance Observation IP 71707 Plant Operations IP 62704 Plant Support Activities IP 92700 Onsite Follow-up of Written Raports on Nonroutine Events at Power Reactor Facilities ITEMS OPENED, CLOSED, AND DISCUSSED Open 50-373/374-98004-01a NCV Ineffective corrective action for locked valve program update 50-373/374-98004-01b NCV Ineffective corrective action for RHRSW manual test procedures 50-373/374-98004-02 NCV Failure to follow procedure when LAP was not updated 50-373/374-98004-03 NCV Failure to perform T.S. firewatches 50-373/374-98004-04 UNR NRC review of fire stop analysis Discussed or Closed Rill-96-0C6 CAL Confirmatory Action Letter from the Service Water Event Rlli-96-008A CAL Supplemental Confirmatory Action Letter from the Service Water Event 50-373/374-98004-01a NCV Ineffective corrective action for locked valve program update 50-373/374-98004-01b NCV Ineffective corrective action for RHRSW manual test procedures 50-373/374-98004-02 NCV Failure to follow procedure when LAP was not updated 50-373/374-98004-03 NCV Failure to perform T.S. firewatches i
50-373/374-97006-01 VIO Several examples of plant personnel failing to follow procedure
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J 50-373/374-97011-01 VIO Inadequate corrective actions for inadequate instructions for performing a manual backwash of diesel generator service water strainers 50-373/96018-02 VIO Operator did not have LaSalle Operating Surveillance (LOS) DG-Q2, "1 A Diesel Generator Auxiliaries," a
" Reference Use" procedure, at the work location 50-373/374-97011-04 VIO Failure to source :: heck the residual heat removal service water effluent monitor within the required inteNal due to personnel error 50-373/374-96020-03 VIO Inadequate out-of-service instruction for Unit 2, Division 2, battery charger circuit breaker 50-373/97007-01 VIO Failure to declare the 1B residual heat removal pump inoperable in a timely manner after it was found in the required action range during surveillance testing 50-373/95016 LER Unit 1 manual reactor scram due to emergency governor lockout valve sticking 50-373/95004-01 VIO Several examples of failures to follow procedure or inadequate procedures 50-373/96004-01 VIO Failure to prevent recurrence of diesel generator and i
emergency core cooling system pump start 50-373/374-96006-01 VIO Failure to perform safety evaluation of operating drywell monitors i
50-373/374-96007-01 VIO Failure to take adequate corrective actions to prevent recurrence of a main steam isolation valve isolation and reactor scram 50-373/374-96007-02 VIO Failure to perform TS surveillance to verify position of manual containment valves 50-373/374-96007-03 VIO Failure to perform a TS required fire watch 50-373/374-96010-01 VIO Failure to follow troubleshooting procedure 50-373/374-96013-02 VIO Failures to follow shutdown and maintenance procedures 50-373/374-96013-03 VIO Failure to follow out-of-service and work request instructions 50-373/374-96013-06 VIO Failure to follow fire protection procedures 50-373/95004-02 IFl incorrectly tagged valve resulted in personnel injury
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50-374/95006-01 IFl Operator response to steam leak hindered due to material condition 50-373/374 95006-02 IFl Ineffective corrective actions for missed surveillance 50-373/374-96005-03 IFl Resin intrusion due to reactor water cleanup system problems 50-374/94008 LER Reactor scram due to electrohydraulic control line failure 50-374/95009 LER High pressure core spray diesel generator and pump initiation due to procedural deficiency 50-374/95011 LER Inadvertent engineered safety features actuation and
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reactor core isolation cooling system isolation due to personnel error 50-373/95016 LER Manual reactor scram due to emergency governor / lockout
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valve problem-(
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50-373/95018 LER Trip of reactor protection system bus resulting in half scram due to relay failure l
50-374/96002 LER Manual reactor scram due to 2E main power transformer
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50-373/96003 LER Reactor scram due to spurious spike of intermediate range l
monitor l
50-374/96003 LER inadequate corrective action for design deficiency involving
drywell cooler condensate flow rate monitoring system l
50-373/96004 LER Reactor protection system motor generator set electrical
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protection assembly breaker inadvertently tripped due to personnel error 50-374/96004 LER Missed TS fire watch due to incomplete fire impairment permit j
50-373/96006 LER Manual scram due to high vibration on main turbine generator exciter caused by oil deflector on the vibration
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probe assembly at the exciter becrings rubbing the rotor shaft (insufficient bore of the cil deflector)
50-373/96007 LER Reactor scram on main steam flow high trip isolation during surveillance due to iristrument technician work practice deficiency i
50-374/96007 LER Reactor water cleanup isolation on high differential flow
50-373/96008 LER Foreign material injected into service water tunnel due to inadequate work control causing dual unit shutdown 50-373/96008, Revision 1 LER Foreign material injected into service water tunnel due to inadequate work control causing dual unit shutdown 50-374/96008 LER Inadequate review of out of-service checklist results in TS violation 50-373/96009 LER Missed TS surveillance on primary containment manual valve positions as a result of an inadequate Final Safety Analysis Report review 50-374/96009 LER Potential degradation of post loss of coolant emergency core cooling system recirculation capability as a result of the discovery of foreign materialin the pressure suppression pool 50-373/96010 LER Inadequate standards for TS clarifications 50-373/96010, Revision 1 LER inadequate standards for TS clarifications 50-373/96010, Revision 2 LER Inadequate standards for TS clarifications 50-373/96010, Revision 3 LER inadequate standards for TS clarifications 50-373/96013 LER Emergency diesel generator fuel oil not analyzed in i
accordance with TS surveillance requirements due to procedural deficiencies 50-373/96015 LER Misinterpretation of TS surveillance results in inoperable diesel driven fire suppression pumps 50-373/96015, Revision 1 LER Misinterpretation of TS surveillance results in inoperable diesel driven fire suppression pumps 50-373/97009 LER Inadequate understanding of lake design basis 50-373/97025 LER Erroneous determination of residual heat removal system pump operability requirements 50-373/97027 LER Equipment not seismically constrained to meet seismic category 1 areas 50-373/97027, Revision 1 LER Equipment not seismically constrained to meet seismic category 1 areas 50-373/97028 LER Residual heat removal increased frequency surve.illance missed
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50-374/97001 LER Potential for missing fuel due to discovery of broken fuel pin 50-373/97032 LER Failure to comply with TSs due to nonconservative -
l maintenance planning i.
t 50-373/98001 LER Missed TS fire watch due to personnel error l
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LIST OF ACRONYMS USED AR Action Request
ASME American Society of Mechanical Engineers l
CAL Confirmatory Action Letter COMED Commonwealth Edison CR Control Room DRP Division of Reactor Projects ER Engineering Request ESF Engineered Safety Feature i
FIN Fix-It-Now FME Foreign Material Exclusion GE General Electric HIT High Intensity Training
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HPCS High Pressure Core Spray l
IST inservice Testing LAP LaSalle Administrative Procedure l
LER Licensee Event Report LOP LaSalle Operating Procedure LOS LaSalle Operating Surveillance MC Manual Chapter MR Minimal Work NDIT Nuclear Design Information Transmittal
NGG Nuclear Generating Group
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NRC Nuclear Regulatory Commission l
NOD Nuclear Operations Division NOV Notice of Violation NSP Nuclear Station Procedures L
NSWP Nuclear Station Work Procedures l
OAD Operational Analysis Division (
OPEX Operating Experience l
PCR Procedure Change Request
PDR NRC Public Document Room PlF Problem Identification Form PM Preventive Maintenance PVC Polyvinyl Chloride Q&SA Quality and Safety Assessment RBCCW Reactor Building Closed Cooling Water
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l RCIC Reactor Core Isolation Cooling i
RHR Residual Heat Removal RHRSW Residual Heat Removal Service Water
{
RWCU Reactor Water Cleanup SBM Switch Board, Miniature SRO Senior Reactor Operator SVP Eite Vice President f
TIP Traversing in-Core Probe
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TMOD Temporary Plant Modification TS TS c:
UFSAR Updated Final Safety Analysis Report WR Work Request WCC Work Control Center 40