ML19345D998
| ML19345D998 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/08/1980 |
| From: | Bournia A Office of Nuclear Reactor Regulation |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8012220350 | |
| Download: ML19345D998 (33) | |
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UNITED STATES f
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NUCLEAR REGULATCRY COT.l?.1tS3lCN s
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y DEC 8 1980 Docket Nos.: 50-373 and 50-374 MEMORANDbM FOR:
- 3. J. Youngblood, Chief, Licensing Branch No.1, DL FROM:
A. Bournia, Project Manager, Licensing Branch No.1, DL SU3 JECT:
FORTHCOMING MEETING WITH COMMONWEE TH EDISON CCMPANY DATE AND TD'E:
December 17, 1980 3:30 AM LOCATION:
G. E. Office, Landow Building Bethesda, Maryland PURPOSE:
To discuss all open items with respect to LaSalle's SER, both TMI and non-TMI, see Enclosures PARTICIPANTS:
CECO Staff L. DelGeorge, et al.
NRC Staff P. S. Check, J. P. Knight, V. S. Noonan, L. S. Rubenstein, R. L. Tedesco, W. E. Kreger, J. Kramer and S. Schwartz O 0A A. Bournia, Project Manager Licensing Branch No. 1 Division of Licensing 122VD Q
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r. J. S. 'bei f rec ce of Nuclear Licensing Commonwealtn Edison Ccmaany
- ost Office Box 767 Chicago, Illinois 60690 cc: Philio P. Steptee, Esq.
Suite d200 One First 'istional Dia a Chicago, Illinois EC503 Dean Hansell, Esquire Assistant Attorney General ISS West Randolph Street Suite 1315 Chicago, Illinois 60601 Mr. Roger Wal'<er, Resident Insaector U. S. Nuclear Regulatory Ccmmission Post Office Box 224 Marseilles, Illinois 61364
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- 0. Ziemann Branch File T. Purley
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- n. Denten R. Schroeder o
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1 Casetisennut D. Skovnolt O
R. ?u role G. Knighton-Z T. Novak M. Ernst S. Varga R. Baer
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R. A. Clark A. Thacani B o
R. Reid ACRS (16)
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'f R. Tedesco atterney, CEL3 J. Youngolocd OIE (3)
A. Scnwencer CSD (7)
F. Miraglia Project."anager A. Sournia J. R. Miller Licensing Assistant M. Rusnorock G. Lainas Receptionist D. Crutchfield TERA W. Russell J. LeDoux, I&E J. 01shinki V. Moore R. Vollmer I&E Headquarters R. Sosnak I&E Region I F. Senauer I&E Region II R. E. Jackson I&E Regicn III G. Lear I&E Regicn IV V. Nconan
!&E Region V l
S. Pawlicki V. Senarcya NRC
Participants:
Z. Ros:toczy P. Check, v. P. Knight, V. Noonan, W. Haass L. Rubenstein, R. Tedesco, W. Kreger, D. Muller J. Kramer, S. Schwartz R. Ballard W. Regan J. D. Saltzman D. Ross P. Check R. Satterfield
- 0. Parr bec: Applicant & Service List F. Rosa W. Butler W. Kreger R. W. Houston T. Murphy W. Gare.ill L. Rubenstein T. Soeis W. Johnston
- 3. Grimes H. Collins F. Pagano S. Ramos J. Kramer N. Hughes
ENCLOSURE 1 STATUS OF LASALLE NON-TMI ISSUES 1.
Ficod Potential - (2.2.2, 2.2.5)
The revised gradation for the riorao submitted in Amendment 41 to tne FSAR is acceotacle. F wever. tne as-built spill..y ripra; does not conform to either tne stated desig't in tne FSAR or to good riarac erosion protection practices. The acclicant is taking remedial action. When this action is ccmpleteo, we will inspect tne as-built riprap.
2.
Low Shear Modulus - (2.6.1, 2.5.6)
The aoplicant has committed to provide field testing data for verifying the shear modulus at low strain levels.
3.
Internally Generated Missiles - (3.5.1)
The acclicant must clarify the criteria used to determine "significant" damage to structure, systems and ccmoonents (SSC) and show how these 53C are crotected against missiles inside containment.
2 Mark II Containment (a) Dynamic System Analysis Under Faulted Conditions - (3.9.2, 3.9.5)
We recuire documentation of the applicant's reevaluation of the reactor vessel, its internals, supports, and attached piping for combined loss-of-coolant accident and safety shutdown earthcuake loads, inciuding tne annulus pressuri:ation effects.
(b) Leading Combinations, Design Transients and Stress Limits - (3.9.3, 3.9.5)
We requir? documentation of the applicant's reevaluation of the safety-related systems and components based upon the load combinations, response combination metnodology, and acceptance criteria required by us.
(c) Pool Dynamic LOCA and SRV Loads - (6.2.1.1)
We need additional information to comolete our review in the following areas:
a.
T-quencher air clearing load specification, and b.
Pool temcerature responses to safety relief valve transients.
5.
Comoonent Succorts - (3.9.3)
The applicant has not submitted its resolution of observed cracking of the jet pumo holddown beams.
6.
Preservice and Inservice Testing of Pumos and Yalves - 3.9.6)
The applicant has not submitted its proposed program for the preservice and inservice testing of pumos and valves.
. 7.
Seismic Oualification (a) The toplicant nas not suomitted tne information describing tne metheds and criteria usea to 3.oress the vibration fatigue cycle er acts on tne arrected equipment due to the requireo loaoing conditions, has not submitted the results of the in-situ impedance tests and has not completed the cualification program.
(b) We have not comoleted our seismic oualification review team review.
3.
Environmental Cualification - (3.11)
We are currently reviewing the aoolicant's NUREG-0588 environmental submittal, and we anticipate a site audit in December 1980.
9.
Ballooning and Rupture - (4.2.3)
We have not completed our generic review and implemented new acceptance criteria for cladding models. Therefore, we require that ECCS analyses in the FSAR be supolemented and be performed with tne materials models of NUREG-0630.
- 10. Comoined Seismic and LOCA Loads on Fuel Assembly - (4.2.3)
The applicant must perform analyses with GE approved analytical methods as reported in GE Recort NECE-21175-P to show comoliance with our acceptance criteria.
- 11. Channel Box Deflection - (4.2.3)
The acclicant has not referenced NEDO-21354 and as a result has not committed to perform the recommended te:ts or the time interval for performing these tests.
- 12. MCpR - (4.4.1, 4.4.2, 15.1)
The applicant must modify the operating limit MCPR based on the generator load rejection without bypass event satisfying the MCPR l
safety limit of 1.06.
- 13. ODYN Reanalysis l
The applicant must analyze the following transients: (a) generator load l
rejection without bypass, (b) turbire trip without bypass and main steam isolation valve closure, and (c) for ASME Overpressure Protection - main steam isolation valve closure with flux scram.
14.
Control Rod System Modification - (4.6.2)
The applicant must show operability of the control rod drive system in order to justify elimination of the return line to the reactor vessel.
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- 15. Scram Discharge Volume - (4.6.2) i We require the applicant to satisfy the requirements resulting from the i
generic study on scram discharge volure design.
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. 16. Safety / Relief Valves - (5.2.2, 6.3.2)
We require tnat the applicant perform tests to show that flow :nrougn the safety relief valves is adequate to orovide the necessary fluid relief for alternate shutdown ccolicg.
- n addition, the acclicant must submit drawing's indicating modification to the Croscy valves and the results of review performed by the SWR Owner's Grouo on tests of :nese valves.
- 17. ATWS - (5. 2.2, 7. 2.3, 15.2.1)
(a) We require that the aoplicant agrees to implement plant modifications on a schedular basis in conformance with the Commission's final resolution of ATWS.
In the event that LaSalle starts oceration before necessary olant modifications are implemented, we require scme interim actions be taken by LaSalle in order to reduce, further, the risk from ATWS events. The applicant will be required to:
(i)
Develop emergency procedures to train operators to recognize an ATWS event, including consideration of scram indicators, rod cosition indicators, flux nonitors, vessel level and oressure indicators, relief valve and isolation valve indicators, and containment temperature, cressure, and radiation indica tors.
(ii) Train operators to take-actions in the event of an ATWS including consideration of immediately manual scramming the reactor by using the manual scram buttons followed by changing rod scram switches to the scram position, stripping the feeder breakers on the reactor protection system power distribution buses, opening the scram discharge volume drain valve, prompt actuation of the standby liquid control system, and prompt placement of the RHR in the pool cooling mode to reduce the severity of the containment conditions.
- 18. Preservice and Inservice Inspection Program - (5.2.4)
The applicant has not submitted its revised program of preservice and inservice inspection of Class 1, 2, and 3 components in accordance to 50.55 a(g).
- 19. Detection of Intersystem Leakace - (5.2.5)
The applicant must address leakage criteria for check valves at' the RCS/RCIC, RCS/RHR, RCS/LPCS, RCS/LPCI interfaces and show how leakage into the LPCS and LPCI system is detected.
- 20. Comoliance with Accendices G & H - (5.3.1, 5.3.2, 5.3.3) l For Unit 1, additional information for exemption for paragraphs IV.A.2.a and IV.B of Appendix G must be submitted by the applicant.
For Unit 2, insufficient information are presented for use to comolete our review.
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4 21.
low Caoscity of Safety / Relief Valves in %R (5.d.2)
See item 16 above.
- 22. Classification af R'A ! sol ation '!alves - (5.4.2)
We require that the valves which serve to isolate the residual heat removal system from de reactor coolant system be classified category A/C in accordance with the provisions of Section X: of the ASME code.
- 23. Steam Byoass of tne Suoeression Pool - (6.2.1.1)
The acclicant accroach to suceression pool bypass is not consistent with Branch Technical Position CSB 6-5.
The acolicant must comit to perform a low ;:cwer surveillan, r leakage test of the containment at each refueling outage. Applicant plans to acceal the staff's cos i tion.
24 Containment Leskage Testing - (6.2.6)
With respect to applying with Appendix J, the following comitment and additional infor.ation is required:
(a) Leak test of RHR shutdown return isolation valve be performed as Type C test utilizing air.
(c) Additional information is required for isolation valves in lines for LPCS injection, HPCS injection, RER/LPCI injection, and the RHR shutdown cooling return and the arrangements of the vacuum breaker valves.
- 25. Assurance of Filled ECCS Line - (6.3.2)
The applicar t must specify the test interval for the periodic venting of the ECCS 'njection lines to reduce the likelihood of air pocket presence.
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- 26. Perodic Testing of Valves Used to Isolate Reactor Coolant System - (6.3.2)
See item 19 above.
- 27. Post-LOCA ECCS Leakage - (6.3.4)
We require the applicant to address the consequences and means of containing t
l leakage from the first isolation valve outside the suppression pool.
- 28. Physical Separation and Electrical Isolation - (7.1.4, 7.2.3, 7.3.3, 7.6.3)
Based on information supplied by the applicant, there is still concern regarding LaSalle's definition and/or treatment of associated circuits. We are reviewing the adequacy of the present design. For the instrument cabinets where non-Class IE wiring is bundled with Class IE wiring, we require that the applicant demonstrate (by test or analysis) that the Class IE circuits and equipment are not degraded below an acceptance level by challenges by non-Class IE circuits.
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- 29. Tes: Tecnnicues - (7.1.2)
In order to perform some surveillance testing, it is necessary for the applicant to pull fuses. We consider that this design does not satisfy the requirerents o' IEEE Std 27?-!:71 Paragraohs 4.11 and 2.20.
We consider this item closed. The applicant will only utilize this method at refueling. The aoplicant must document its comnitment.
2C. Safety System Setooints - (7.1.4)
We have not comoleted our review of the Tecnnical Specifications. We intend to review the information on setpoints in the Technical Specifications.
If any concerns are noted, we will require some clarification.
- 31. Drawings - (7.1.4, 7.3.3, 7.6.3)
Based on our audit of certain drawings during our site visit, we consider this item closed except for confirming documentation (drawings) to be supplied on the low-Icw set relief logic and documentation of the function of this system.
- 32. RCIC Classification - (7.4.3)
The aoplicant has proviced the information on their prooosed design change for switchover. We consider this item closed except for their submittal of the final design.
- 33. Safety - Related Disolay - (7.5)
We are reviewing this item as a result of the applicant's inout.
34 Rod Block Monitor - (7.6.3)
We are reviewing this item. The apolicant has documented that the rod block monitor is not required for any of the analyses in Chapter 15.
- 35. Low or Degraded Grid Voltage - (8.2.2)
The applicant committed to implement-the second levet undervoltage protection.
l We require the design implementation information prior to our approval. This j
information has not been provided.
- 36. Shared Diesel - Generator (8.3.2) l (a) The applicant has informally connitted to transferring automatically a number of vital supoort system loads for the shared diesel genera-to r.
This has been found acceptable pending verification of the design imolementation. Drawing showing the implementation have not been provided.
l (b) The applicant did not commit to transferring automatically the AC source of power to the 250 DC and 125 DC battery chargers. The apolicant indicated that the battery had sufficient capacity for the time required to manually reconnect the AC power. We require manual procedures be provided for our review.
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. 37. Reactor Containment Electrical Denetracians - ;3.a.1)
The reactor containment electrical cenetrations do nct conform to Regulatory Guice 1.53.
The apolicant was informed tnat we. vill not accept self-fusing characteristics of cable to orovide crotection against ructure of primary containment. Applicant plans to acpeal tne staff's cosition.
- 23. Adecuacy of the 120-Yolt Alternating Current Reactor Protection System Power Sucoly - (5.4.7)
The applicant has committed to comply with the generic resolution. This was found acceptable pending verification of the design imolementation.
Drawings showing design implementation have not been provided.
- 39. _ Thermal Overload Protection Bypass - (2.4.9)
The applicant has inoicated that provisions for cycassing thermal overload protection would meet position C1 of Regulatory Gu,ide 1.106. This was found acceptable pending documenting. The documentation has not been provided.
40.
Physical Secaration Setween Class IE and Non-Class IE Cables A site visit by the staff (ISE and ICSS) identified a number of locations where inadequate separation exists between Class IE and non-Class IE cables.
Secaration criteria in the FSAR specifies that non-Class IE cables are separated by an acceptable distance or barriers from Class IE cables.
al. Fire Protection - (9.5)
With respect to fire protection, the following additional information is required:
(a) For the alternate shutdown panel, it was determined that simultaneous loss of several circuits and/or cabinets would jeopardize safe clant shutdown. The applicant has not provided details of the design to alleviate this condition.
(b) The applicant agreed to evaluate the physical separation between cables for the control room redundant HVAC systems and identify areas where separation does not meet fire protection guidelines.
The results of this evaluation has not been provided.
l (c) The applicant has not documented that all primary shutdown cables are not located in the same room with the alternate shutdown panel.
(d) Control cables for two series RHR valves are not separated by the required distance at two locations. The apolicant has stated though that these RHR valves are the only primary reactor boundary interface protected by two series motor operated valves. This needs to be documenteo to resolve this issue.
(e) Seoaration of associated cables is a requirement resulting from Appendix R.
Additional questions are being prepared to address this item.
. (fl Yhlation of containment isolation due to a cesign basis fire is a rewirement resulting from Accendix R.
Additional cuestions are be;ng crecareu to address this iten.
22.
Radiation Protection Nianagement (12.5)
(a) The Radiation Protection '4anager should have a clear line of authority to the Diant Manager as indicated in NUREG-0731 and Degulatory Guide 3.3.
Figure 1.7 of the Topical Recort CE-1A, Rev.14, does not delineate Onis line of autnority between tne Rad / Chem Suoervisor and tne Plant Superintendent.
(b)
It is our position that tne Rad / Chem Supervisor meet the minimum requirement of Regulatory Guide 1.3 which references ANS/19.1.
Your Rad / Chem Supervisor resume indicates that he has a majority of his training and ex erience as a chemist and does not meet the requirements of Regulatory Guide 1.3.
43.
Industrial Security (13.4)
As a resuit of our site visit and cur review, there are 32 itens of concern.
44 Use of Nonreliable Ecuioment in Anticioated Ooerational Transients - (15.1)
(a) The aoplicant must analyze the generator load rejection without bypass and turbine trip without bypass transients without relying upon the use of the level 8 trip.
(b) In analyzing anticipated operational transients, the applicant took credit for equipment which has not been shown to be reliaole. Our position is that this equipment be identified in the technical specifications with regard to availability, setpoints and surveillance testing. The applicant must submit its plan for implementing this requirement along with any system modification that may be required to fulfill the requirement.
i 45.
Use of Non-Safety Grade Ecuicment in Shaft Seizure - Accident - (15.2)
The applicant included the use of non-safety grade equipment in his analyses for shaft seizure and shaft break accidents. We require that these accidents be reanalyzed without allowance for the use of non-safety grade equipment.
j 46.
Technical Soecifications - (16)
We have not completed our review of Technical Specifications.
47.
Quality Assurance - (17.0)
The applicant must address deficiencies of those systems, structures and components wnich should be under the control of the operational quality assurance program (Q-list).
18.
Financial Qualifications - (20)
We have not comoleted our financial qualifications review.
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ENCLOSURE 2 STATUS OF ' ?SALLE'S MI IS30ES
- .A.1.1 shi#t 'e:nn' ai Acviser 1.
We are unable to ascertain if the STAS meet the recuirements for technical ecucation and training as cescribed in our October 31, 1979 letter to licensees. CECO should reovide a state ent that it eets the recuirs >>1ts of this October 31, 1979 letter and orovide detailed information substan-tiating this fact for each of its STA candidates.
2.
Ceco written submittals have not been clear as to the number of SR0s that it will provide on eacn minimum shif t crew in acdition to the SCRE/STA.
Based on our discussions with CECO, we believe that it crocoses to a) orovide two SR0s in addition to the SCRE/STA and b) to have the shift foreman /SRO reolace the SCRE/STA as the control room SRO in an emercency situation where the SCRE/STA must assume the STA function. We made no determination thus far as to the acceotability of such a crocosal. CECO should Mr. ament its oracosal on this subject with sufficiently detailed information to provide a basis for discussion and resolution of the issues with accroariate PPC management.
I.A.1.2 Shift Suoervisor Administrative Outies 1.
CECO should orovide a management directive that emahasizes the crimary management responsibility of the shift supervisor (shift engineer) for safe ooeration of the plant under all conditions of his shift and clearly establishes his command duties.
2.
CECO should orovide a statement indicating that the senior corocrate manager resoonsible for nuclear coerations has reviewed the administrative duties of the shift sucervisor and delegated those that detract frcm or i
2 are sutcrdinate to t"e arage"ent #esect.sibilities for assurirg safe crer3-tion of the clant to c:rer ocerations uarsonnel not on duty in t.,e contr71 room.
3.
Procedures snould ce rodified to snow :nat in case of an ernrge.cy wnere the snift sucervisor is recuired to establish himself in the r antrol rocm and remain in command authority until procerly relieved, the :hift sucer-visor's office is not considered to be cart of the control room for this purpose and that the shif t supervisor must physically establish himself in the immediate control console area of the control recm.
4 P v.cJures should be modified to soecify.that a senior reactor ocerator 9.ill be assigned to and physically stationed inside the immediate control a
console area of the control room at all times and to indicate that, for this ourcose, tne shift sucervisor's office is not considered to be cart of the control room.
5.
Procedures should be modified to clearly cescribe the control room cornand authority as residing with the SR0 assigned to the control roon any time the shift supervisor is not physically present inside the control room.
I.A.1.3 Shift Manning 1.
CECO should submit information soecifying for SR0s and R0s (excluding management oersonel) a) how many personnel it excects to have cualified for each shift crew position at fuel load and at other specific dates out to one year following fue' t and b) the number of emoloyees in each position that it excects to lose versus time-(i.e.', through exam failure and attr131on). This information will provide a basis for our conclusions regarding the adecuacy of the staffing plan #or LaSalle. Ceco should also describe its contingency plan for filling positions in the event
. trat the #ive indi,iduals i-One sni#t er.;ineer training cr ; rim :r the five in tne STA training crogram are not licensed or available to serve in tnese positions.
I 2.
It is our view that shift crews should work and train together on an essentially permanent basis. CECO has informed us that it cannot recuire this because of its agreement with the Bargaining Unit. We intend to imcose this as a recuirement. However, this is a proposed new staff position which we must get approved before imposing it.
3.
CECO should submit a commitment to orov1de three licensed reactor ocerators (R0s) on the minimum shift crews for two unit oceration. The October 20, 1930 CECO submittal committed to only two R0s for two unit oceration.
I.3.1.2 Evaluation of Organization and Management 1UREG-0731 states that the Radiation protection Section and the Chemistry Section be secarate. LaSalle's organizational chart (Fioure 12.1 Ji shows these two groucs as one.
I.C.1 Short-Term Accident and Procedure Review The staff has not received responses from the BWR Owner's Group to the issues raised in the letter from D. Eisenhut to S. T. Rogers dated October 21, 1980.
These resconses will provide the background and bases for several recuired actions in the LaSalle emergency procedures.
I.C.2 Shift and Relief Turnover Procedures 1.
Ceco's shift relief turnover procedures must be modified prior to fuel load to include:
a.
check lists for critical plant carameters b.
check lists for proper system alignment c.
check lists for equipment under maintenance and test for non-licensed operator shif t relief.
2.
CECO must describe its system #ce evaluating the adecuacy of its shi#t turnover croceoures.
!.C.a Centrol Room Access CECO control rocm access crocedures must be modified erfor to fuel load tc eliminate portions of draft procedures that seem to undermine the responsibility of the s'<.tt engineer (shift suoervisor) and SR0 for c:eration and contrcl room command.
I.C.5 Feedback of Oceratina Excerience The crocedures in place at LaSalle during our Sectemoer 9-12, 1930 site visit did not describe the system for disseminating operatina exoerience information to plant operating personnel and support staff in sufficient detail to assure that operating personnel are informed of all accropriate coerating experience information both from LaSalle and from other nuclear stations. CECO must provide aporooriate crocedures to assure adequate dissemination of ooerating exoerie"ce information to the LaSalle coerating and suoport staff prior to fuel load.
I.C.6 Verifv Correct Performance of Operational procedures We require a letter from the applicant connitting to implement a program for verifying correct performance of operational phase activities crior to fuel loading. The letter should state the program wil' comoly with the description provided in NUREG-0737. Our I&E will audit the implementation.
I.C.7 NSSS Vendor Review of Procedures The applicant stated that General Electric will review the low power tests, I
l power ascension tests and emergency procedures, but did not indicate when they would conclete the review. After the review is completed, we need verifica-tion from the applicant that General Electric has completed their review.
] In acci: ion, we neec to ' now General Electric's conclusion, and now any of General Electric's recommencations were nancied.
I.C.S Pilot-Monitoring of Selected Emercency Procedures for NTOLs We require that the apolicant orovide a revised cooy of the LaSalle General Aonormal procecures, tne ATWS orocedure and tne Reactor Trio orocedure revised to reflect the contitments made during out orocedure review. We also require that the apolicant provides a descriotion of tne training to be conducted on :ne emergency orocedures crior to fuel load.
I.D.1 Control Room Design Review We have performed our site review and our review of the acolicant's oreliminary assessment. Design imorovements have been soecified to the applicant to be completed erfor to fuel loadin; and an item before full cower, see attachment. The acclicant nas committed to perform these tasks. In addition, long range imorovements have also been indicated which must ce addressed in the long term analysis as recuired by this task action. Subject to the c?ification by the residence insoector of the improvements required prior to fuel load ano full' power, we consider this item closed.
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ATTACHMENT A.
Ceficiencies :o be corrected crice to fuel loadina a nunciators and Alarms 1.
n a.
.accroximately 92 individual annunciater tiles will be rearranged to improve organi:ation of annunciator panels. A.1.(b)(2)
- b.
Annunciator tiles with legends using small character si:e and neignt will be replaced. A.1.(b)(4) c.
Audible alarm signal intensities will be adjusted to provide ecual detection levels for all audible alarms. A.1.(b)(8) d.
Reactor control panel audio alarm frequency will be lowered to a level well below 5000 Hz. A.1.(b)(9) e.
Annunciater tile reflash capability will be demonstrated. A.1.(b)(10) 2.
Controls a.
Cecarcation will be applied to control panels to prcmote visual re-cognition of closely-spaced J-handle controls. A.2.(b)(1) b.
G :ardrails will be installed on all benchboards and censoles. A.2.(b)(2) c.
Cemonstrate clockwise direction of Feedwater Turbine control to in-crease turbine speed. A.2.(b)(4) d.
J-handIes for pumps, open-close valves ?nd throttleable valves will be differentiated by color, shape and texture coding. A.2.(b)(6) e.
Institute administrative procedures to control removal and replacement of interchangeable control indicator light covers. A.2.(b)(7) f.
Denonstrate availability of tools for replacement of indicator lamps. A.2.(b)(8)
References are to the staff's Control Room Design Review Report trans-
_. _._.. mi_tted to.the applicant en October _.23._1980.
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De. mens: rate availaoilit, and use of administrative crecedures to assess incicatcr lignt status, failure or cegradatien. A.2.(b)(9)
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Provide positive visual indication of armec/d:sarmed status of pushbutten trip switches. A.2.(b)(10) 3.
Oisplays a.
Provide 'ncreal range' banding on vertical inaicators located just belcw annunciater panels. Sanding shall be permanent (i.e., en meter face) whereever possible. A.3.(b)(1) b.
Relabel meter ' strings' of 5 or more meters to aid in meter iden-tification. A.3.(b)(2) c.
Identify those meters which have a 'ncrmal' coerating range, and pro-vide temporary range bancs. Range bands shall be made permanent where possible, and all applicable meters shall have permanent ' normal' range bands by 18 months after full pcwer operation. A.3.(b)(3) d.
Provide demarcatien to crgani:e and identify related meters on electrical panel 1PM01J. A.3.(b)(5) e.
Replace all hand-made meter scales with permanent scales. A.3.(b)(6) f.
Provide demarcation lines to improve the visual asscciation of legend /
indicator lights with their associated esntrols. A.3.(b)(7) l g.
Replace blue indicator lamp covers for those indicators where lu-minance contrast is too low.
A.3. ('. )(9) 4 Control / Display Relationships a.
Demonstrate that valve position indications are based on positive indication of valve status. A.4.(b)(1) b.
Identify isolation valve pressure displays as inboard or outboard.
A.A.(b)(3) l 9
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c.
Relacel hPCS cumo displays. A.4.(b)(4) d.
Provide demarcation lines and possible color coding to associate tne FPCS current ceter with tne MPCS pump centrols. A.A.(b):5) e.
Provide identical Peretration Pressure S/C Duct and S/C Rocm tem-perature meters. A.4.(b)(6)(b) f.
Relocate labels that are partially obscured by indicator light covers at base of panel 1H13P601. A.4.(b)(6)(c) g.
Provide RHR system white indicator lights with labels / legends that indicate system status. A.4.(b)(:)(d) h.
Provide label for LPCS pump cooler valve. A.4.(b)(7) 1.
Demonstrate human factors ennancement and appropriate control / display relationships for Containment Isolation and Leak Detection panel /
console IPM13J and IPH16J. A.4.(b)(9) 1
- j. Provide the following Standby Gas Treatment panel corrections: A.4.(b)(10) l Provice Unit 1/ Unit 2 demarcation.
Label strip chart recorders and install correct enart pacer Provide missing indicator light covers Complete panel mimics Correct inconsistent annunciator legend.
k.
Provide Feedwater and Condensate Panel 1PM03J demarcation and colcr coding to enhance system / subsystem discrimination, visually segregate unrelated control / display components, improve control / display relation-l ships, and improve the visual relationship between valve controls and valve position indicators. A.4.(b)(11)(a)(b)(c)(d)
I 1.
Relabel motor-driven feedwater pump. A.4.(b)(11)(e) m.
Provide demarcation and color coding to enhance control / display relations and discriminatien for Auxiliary Systems Panel / Console IPM09J and IPM10J. A.4.(b)(12)(b)(c)
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5.
Recorders a.
Der.onstrate recorder operability / maintenance. A.S.(b)(1) b.
Establish censistant systems for dual-recorder uoper/ lower pen colors, and provide approcriate " 5els for eacn recorder that will be censistent with pen locaticn and color coding. A.5.(b)(2)(3)(4)(5) c.
Demonstrate that recorder scales and chart paper scales correspond.
A.5(b)(5) d.
tiodify SRV temperature recorder (Panel IH13P512) to eliminate am-biguity as to wnich channel is being displayed. A.5.(b)(8) 7.
Workspace, Layout and Environment a.
Relocate general procedures, annunciator procedures and emergency procedures at the Unit 1 operating desk. Provide color coding to identify procedures. Demonstrate rapid and uninhibited selection of appropriate procedures by the operators. A.7.(b)(1)(d) b.
Genenstrate computer capability to printout historical meteorological data on demand. A.7.(b)(1)(1) c.
Replace white indicator.'1 hts with white backlignt legend lights.
A.7.(b)(2)(a) i d.
Replace black emergency trip pushbuttons with red pushbuttons.
A.7.(b)(2)(b)
I e.
Demonstrate installation and accuracy of new mimics and demarcations as described in the Preliminary Assessment Report. A.7.(b)(3)(4) f.
Install additional control room lighting to increase lighting levels on panels anc consoles. A.7.(b)(5)(a) g.
Install new covers for blue status lights where luminance contrast is too low. A.7.(b)(5)(b) n....
e
a.
Install mcdified ceiling grids to reduce glare en parels and cen-soles. Noce: time period for cccoletion of this item may be ex-tended to accommodate vender delivery senedules. A.7.(b)(5)(c) 1.
Reduce sound levels of audible alarms to a maximum 65dbA level.
A.7.(b)(6)
- j. Imorove visual recognition of phone jacks on control room back panels. A.7.(b)(8)(a) k.
Provide index and location labels for the scund powered phene patch panel. A.7.(b)(8)(b) 1.
Organize ccmmunications equipment located at the center desk.
A7.(b)(8)(c) m.
Previde accessible, designated storage for cperator protective equip-ment, and demonstrate that ecuipment is installed and available fer use by c;erators. Cenonstrate availability of adequate cennunicatien systems for use with cperator protective equipment. Demonstrate availability and adequate storage of individual operator corrective lenses for use with protective equipment. A.7.(b)(9)(b)(c) 8.
Remote shutdown panel a.
Provide panel mimics and demarcation. A.8.(b)(1) b.
Demonstrate emergency lighting provistens in the remote shutdown panel area. A.8.(b)(3) 9.
Computers a.
Cemonstrate trending capability of computer printouts and CRT dis-j plays. Install labeling system for stripchart trend recorders.
l A.9.(b)(1) b.
Demonstrate resolution of the problem of glare on CRT displays.
A.9.(b)(2) c.
Modify CRT displays to improve CRT readability. A.9.(b)(3) 9
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d.
Ca enstrate availability of Ocerational crececures covering ocerator acticns in the event of tctai loss of the process ccm: uter systam.
A.9.(b)(4) e.
Relabel point ID display to be censistent with thumowneel control.
A.3.(b)(5) f.
Reorganize point ID index by ccaponent number and by system.
A.9.(b)(7)
~~
B.
Deficiencies to be ccrrected before full ccwer oceration
]
1.
Annunciators and alarms a.
Improve visual access to annunciator centrols by color and shape coding. A.1.(b)(5)
C.
Deficiencies to te addressed in the Cetailed Control Room Desien Review TFie~rTicwing items do not represent the entire scoce of the detailed control rocm design re::crt called fcr in Task I.D.1 of NUREG-0660, but are those de-ficiencies which have been identified at this time as requiring additional analysis to arrive at an appropriate solutten, or which are scheduled for corr e tien after initial full power operation.
1.
Annunciators and Alarms a.
Provide a plan for annunciator tile relocation that locates annun-f ciator tiles above their related systems or controls /dispisys, and complete the analysis of annunciator tile organization within in-dividual annunciator panels. A.1.(b)(1)(2) b.
Provide a detailed analysis of annunciator panel arrangement that l
provides unambiguous distinction between alarms with direct plant l
safety implication and alanns not having a direct effect on plant safety. A.1.(b)(3) c.
Provide a detailed analysis of the use of acditicnal audible alarms (and associated tone / frequency coding) t: imprese directional cueing l
i and operator location of alamed panels, and to avoid the possibility l
of failure to recognize individual alams during multiple alam events. A.I.(b)(7)
2.
2ntrols a.
Provide a detailed analysis Of tne ;otentiai :erater error tna-could be caused by the clese spacing of adjacent J-handle c:ntrols (e.g., panel IPM03J). !mprove cperat:r visaal accass to controls by relocating control indicator lights.
Indicator lignt relocation to be acccmplished Orier to second startup cycle. A.2.(b)(1) b.
Analy:e all J-handle controls to ensure that visual access to legend /
identification material obscured by the J-handle is not material that wculd be recuired during emergency situations. A.2.(b)(3) c.
Identify and evaluate pcsitive means of detemining indicator lignt failure er degradaticn. A.2.(b)(9) 3.
Displays a.
Review all indicators with eitner temocrary or permanent ' normal' range bands, and ensure that all applicable meters have been identified and that pemanent 'nomal' range bands have been installed prior to the second star Jp cycle. Identify all indicators where the provisicn of additional range bands (e.g., abnomal operation) wculd improve cperator perf:mance, and provide schedules for installing these range bands. A.3.(b)(3) 6.
Provide plans and schedules for reorganization of electrical panel IPM01J meters. A.3.(b)(5) c.
Provide detailed analyses of means to improve the positive association of legend / indicator lights with their associated controls. A.3.(b)(7) 4 Control / display relationships a.
Develop improved Div. I Outboard Isolation valve labeling to minimize the potential confusion resulting from the A-B-C-0/A-E-J-N relation-ship as it now exists.
4.(b)(2) b.
Provide a detailed analysis of the RHR system Loop B Div. II mirror-imaging between Pump A and Pumb B meters. Justify the arrangement as it now exists, or provide plans and schedules for meter relo-cation. A.4.(b)(6)(a) v
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c.
Provide detailac analyses f:r the relccaticn of Feetaater and Sn-densate canel IPMC3J c ntrols anc cisclays to enhance subsysten dis-crimination and imorove control / display relationsnips. Provide olans anc scnecules f:r acc molishing ralocati:ns. A.t.(b)(11)(a,'(b)(c)(d) d.
Analyze Auxiliary Systems panel / console iPM09J and IPM10J and identify display relocations to imorove centrol/disolay relationsnios. Com-plete relocations prior to second startuo. A.4.(b)(12)(a)
Analyze Electrical Control panel IPM.0lJ and relocate selected meters e.
to improve control / display relationships. Complete relocations crior to seccnd startuo. A.4.(b)(13)(a)(c) f.
Provide an analysis of the Reactor Control Panel 1H13P603 status indicator mirror imaging. Justify this arrangement or provide plans and schedules for revised sequencing of these indicators.
A.4.(b)(16)(a) 5.
Lacels No recuirennts 6.
Recorders a.
Provide an analysis of the potential problems associated with use of dual-scale chart paper. A.6.(b)(7) 7.
Workspace, layout and environment t
l a.
Provide a detailed analysis of the duties and functions of the cen-ter desk operator, acting as a communications comand center con-troller, during the course of an emergency requiring comunications f
to-and-from the control room. A.7.(b)(1)(f) b.
Provide an analysis and operational plans for Unit 1 or Unit 2 operator interfaces with the mirror-imaged Unit 1/ Unit 2 consoles i
and panels. A.7.(b)(1)(h)
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c.
In conjunction with the detailed analysis of annunciator panel rearrangement to d'stinguish between safety and non-safety alarns,
rovide an analysis investigating tne use of color (over and acove
'first-cut' red) to cs:ageri:e the cegree of severity or potential safety c:nsequences of individual alarms. A.7.(b)(2)(c) 8.
Remote shutdown panel
'io requirements 9.
Computer a.
Provide an analysis of the apparent violation of design convention with rescect to location of the number thumbwheel switch and the function thumbwheel switch. A.9.(b)(7) l I
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. :.3.1 Training During Low cower Testinc This item recuires a scecial low ocwer test that crovides eaninoful technical information Oeyonc tnat obtained in the normal start-uo program, and also orovides succlemental ocerator training. The acclicant's crocosal only res:cnded to succlemental :erator training during their :: art-co orogram.
We require additional low power tests from which useful information could be derived.
In a telechone conversation with the acclicant, we crocosed a test that would meet these objectives. The aoplicant indicated that it would review our crocosed test with General Eier tric and get back with us. We informed the acclicant that to maintain our current schedule, we need agreement on the crocosed test and a commitment from the applicant to cerform the test, or one of similar scoce, as soon as cossible. We further noted that we need tho details of the test and a safety analysis for our review four weeks crior to the scheduled test date.
II.3.1 Reactor Coolant System Vents We require the following to comolete our review:
a.
Procedures and suoporting analysis for operator use of the vents.
b.
Verification that a positive indication of valve cosition is orovided in the control room.
c.
Descriotion and drawings of the soecific design features of the LaSalle vent system. A comoarison of the venting cacability should be made with the generic venting capability orocosed by the SWR owners grouo.
II.B.2 Plant Shielding This item states that the location of all vital areas be identified and the aoplicant orovide for adequate access to vital areas and orotection of safety equioment by design changes, increased permanent or temocrary shielding.
Accordingly, the acolicant must provide layout drawings to indicate the
location of :ne vital areas, cost-accident access routes to ncse areas, and shielcing modificaticns made as a result of imolementing.NUREG-0737 recuirements.
!!.3.3 Post-Accident Samolino Ine acolicant nas not orov'cea tne oicina anc instrument arawings locating the cost-accident samoling and analysis systems, and also estimates for sacoling and analysis times.
II.D.1 Delief and Safety Valve Test Recuirements The applicant has not provided a comnitment for resciution of this item.
'de recuire a commitment to recuf rements of NUREG-0737 as acolied to I!.D.1 and our generic resolution of SWR Owner's Grouc testing crogran:.
II.3.7 3nalysis of Hvdrocen Control and II.S.S Decraded Core To meet II.B.7 & II.3.8 action items, the acolicant committed to inert the containment with certain contingencies. Further discussions with the applicant are needed before we can conclude our review on this matter.
II.D.3 -
Valve Position Indication The apolicant has submitted sufficient information to start our review.
II.F.1 Additional Accident Monitoring Instrumentation
- 1.
The applicant does not comely with the low energy gamma sensitivity recuirements of Table II.F.1-3 of October 30, 1979 clarification letter for the high-range containment monitor. LaSalle's containment nonitors are located in steel sleeves which will result in the inability of the monitors to detect 60 KEV ohotons.
2.
The applicant has not provided a summary of the interim crocedures for quantifying the high-level accident radioactivity releases of noble gases
- Additional requirements may be defined later.
3 I
and iodines. Mcwever, if the acciicant :cmoletes installation and calibration of high-rance noole gas effluent monitors and iodine and carticulate effluent sanoles crior to fuel loading, then interim :rocedures are act necessary.
II.F.2 Inadequate Core Ccoling !nstruments The acolicant states that this item is not acclicable to LaSalle. However, NUREG-0737 requires by fuel load that a descriotion of other instrumentation be submitted by all clants and installation of additional instrumentation by 1/1/82.
II.K.1 IE Sulletins
- 10. Ocerability Status The October 20, 1980 resconse is incomolete. The acclicant must review and modify, as recuired, administrative crocedures to be used to verify redundant systems coeracility when safety-related systems are re.oved from service. The acclicant must also review and modify, as required, orocedures for restoring equioment to service and to assure coerability status is known. Furthermore, the applicant must review crocedures to assure operator awareness of system status.
- 23. Reactor Vessel Level Instrumentation The applicant must provide a descriotion of alternate instrumentation that might give the coerator the same information on plant status as the primary level indicators.
II.K.3 Final Recommendations of B&O Task Force 3.
Reoorting SV & RV failures & challences This item has not been addressed by the aoolicant. However, the applicant ccmmitted to perform this item.
- 13. H:C: L R:!C :nitiation Levels The aoolicant has crovided its bases for not frolementing this item, out we recuire tne acclicant to orovide analyses wnicn succorts its cosition.
In additien, the acclicant must address ;rovisions for auto 9atic restart of 0.C:C.
15.
Isolation of HPCI and RCIC The apolicant has indicated to incarcorate time delay relays to overcome cressure spike, however the installation date will not ce till June 1, 1982. NUREG-0737 recuires by 4 months before ocerating license.
- 16. Challenges to and Failure of Relief Valves The aoolicant must orovide the results of the SWR Owner's Grouc in this area.
- 17. ECCS Outages This is not acclicable to LaSalle.
- 18. ADS Actuation This item was not addressed by the applicant.
- 21. Restart of LPCS & LPCI The acclicant must provide the results of the BWR Owner's Grouo in this area.
- 22. RCIC Suction The applicant has provided the information on their proposed design change to meet this requirement. We consider this item closed except for their submittal of the final design. In addition the acolicant indicates that the modification will be comoleted by 6/82 as compared to NUREG-0737 requirement 1/1/82.
24
_Soace Cooline for mPCD3CIC l
The aoplicant cust orovide veri'ication tnat the HPCI/RCIC systems are designed to.d thstano the cocolete loss of alternating current cower to their succort systems, including coolers for at least two nours.
It is not clear that the FSAR analysis referenced in :ne October 20, 1980 resconse address a two-hour loss of all alternating current cower nor that the analyses acoly to RCIC which is not cart of the ECC system.
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- 30. Small Break LOCA Methods This item was not addressed by the aoplicant.
44 Evaluate Transients with Single Failure The October 20, 1980 response references FSAR transient analyses; however, these analyses do not include worst single failure. The acolicant must provide an evaluation of anticioated transients with j
single failure to verify no fuel failure.
i
- 45. Manual Deoressurization The aoolicant cust provide the results of the BWR Owner's Group Study l
of this topic.
- 46. Michelson Concerns This item was not addressed by the applicant.
III.A.2 Emergency Preoaredness - Long Term Based on our review, we conclude that uoon satisfactory resolution of the items listed below the olanning objectives of NUREG-0654 will be met:
11 -
1.
Provide a description of and ce=pletion schedule for =eeting the
=ini=us shift staffing require =ent as indicated in Table 3-1.
The Plan =ust describe the on-shift staffing levels and describe the capability to aug=ent the on-shift functional aress within a shgre period after declaration.
~he i=ple=entation schedule for licensed operators, auxiliary cperators, and the shift technical advisor shall be as specified in the July 31, 1980, letter to all pcwer reactor licensees.
2.
Provide for predetermined EALS for the high range effluent monitors.
EALS shall be based on offsite dose rates in accordance with Appendix 1 of NUREG-0654 and with the reco=nendations set forth in Table 5.1 of the Manual of Protective Action Guides.
3.
Provide a description of andec=pletion schedule for a pro =pt alerting and notification system which =eets the design objectives of Appendix 3 of NUREG-0654, Revision 1.
4.
Provide an actual sample of the public educational program in the Plar for NRC review.
i 5.
Provide a description of and completion schedule for an upgraded meteorological program which meets the criteria stated in Appendix 2 of NUREG-0654, Revision 1.
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6.
Provide a summary of the evacuation time study and a description of i
their use for recommending protective actions.
l 7.
Provide a description of the expected dose reduction factors offered l
in residential units near the facility.
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l S.
Fulfill the following co==it=ents:
a.
Clearly indicate in the Plan that the local e=ergency organi-zations will be invited to participate in annual exercises 8knd that S' ate emergency organi:ations will be invited once every three years.
~
b.
Clearly indicate in the Plan that Eealth Physics drills vill be conducted se=i-annually which involve response to, and analysis of, si=ulated elevated airborne and liquid samples and direct radiation measurements in the environment. These drills shall include an actual test of the post-accident sa=pling systens.
c.
The Plan must indicate that independent audits of E=ergency Pre-paredness will be conducted annually.
9.
Conduct an exercise
- that tests the integrated capability and a major portion of basic ele =ents within e=ergency preparedness plans and organizations (i.e. licensee, State and county groups).
l I
An exercise has recently been conducted with the if censee, State of Illinois, and LaSalle and Grundy Counties on December 4,1980. This was a major l
l full-scale exercise with all organizations and was observed by the NRC.
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- .J.:.1 Orf ary Ceciant Sources Outside 0:ntain ent The aoolicant has not provided: (1) a list of the systems to be initially teste: crior to fuli Ocwer oceration, (2) a descriction of the method for obtaining actual leak rates, and (3) 'recuency of ceriodic leak testing in the continuing leak reduction crocram.
Also, the acolicant nas not discussed the acolicability of l4ortn Anna and related ircidents (discussed in twREG-0737, item III.D.1.1 clarification, subsection 3) to LaSalle. We require this information to resolve our concern relating to this item.
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. Items Recuired to be Addressed by a Cate Other Than Fuel Load or Full ?cwer I.3.2 Plant Safety Parameter Disciay Console The acclicant has not addressed this item. Mcwever, in NUREG-0727 for l
this item, the soecific imolementation schedule and specific recuirements were soeci'ied to be cresented in 1UREG-0696. We anticioate that NUREG-0696 will be issued in Decemoer 1980, and tnat we will require tnat aoplicants shall submit to us by Acril 1,1981 or orior to issuance of an ocerating license, whichever is later, a descrip*.on of the design of the safety carameter display system and their schedule of installation of this sys tem. We will perform a pre-installation audit. A safety parameter disolay system shall be ocerational, but not necessarily reet all the design criteria of fiUREG-0656 cy July 1,1982, or orior to issuance of an operating license, whichever is later. Compliance with all desian f
require ents of NUREG-0696 is recuired oy Acril 1,1983.
II.K.3
- 25. Power on Pueo Seals 7/1/81 i
This item was not addressed by the applicant.
- 27. Common Reference Level 7/1/81 The technical specification water-level nomenclature described in the October 20, 1980 response is ur. acceptable as a substitute for a cormon reference point for level instrumentation. The applicant must orovide documentation of modifications to level instrumentation to reference a common point.
- 28. Qualification of ADS Accumulators 1/1/82 The fact that only 2 of 7 valves are needed in the short term and 1 of 7 valves is needed in the long term is not sufficient justification of design acceptability. The acplicant must verify that the accumulators on the ADS valves are designed to withstand a hostile environment and l
still perform their function 100 days after an accident.
- 31. Plant-Scecific Analysis 1/1/33 This ite9 aas not addressed :y the acclicant.
i III.A.1.2 Uograde Emergency Succort Facilities Additional clarification. vill be provided in the near future.
No Additional Information Recuired I.A.2.1 I.A.2.3 I.A.3.1 I.C.3 II.3.4 II.E.4.1 II.E.4.2 I!.K.1 item 5 and item 22 III.A.1.1 III.D.3.3 III.D.3.4 I
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