ML20010A759
| ML20010A759 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/23/1981 |
| From: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20010A756 | List: |
| References | |
| NUDOCS 8108120182 | |
| Download: ML20010A759 (1) | |
Text
g<&** * *'4jo UNITED STATES g,
NUCLEAR REGULATORY COMMISSION
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GLEN ELLYN, ILLINOIS 60137 June 23,1981 MEMORANDUM FOR:
E. L. Jordan, Deputy Director, DRRI, IE:HQ FROM:
R. F. Heishman, Acting Director, DRPI, RIII
SUBJECT:
R'EQUEST FOR GUIDANCE IN REGARD TO PERSONNEL QUALIFICATIONS AT LASALLE COUNTY NUCLEAR STATION (AITSF03031781)
The enclosed memorandum from Roger Walker, the LaSalle Station, Senior Resident -Inspector, identifies what appears to be a ccaflict between the licensee requirements identified in the FSAR which commits tc ANSI-18.1-1971 and inspection requirements outlined in the NTOL Management Inspec tion for licensee compliance in the area of personnel qualifications which requires the licensee to comply with ANSI /ANS 3.1.
Several concerns surrounding requirements for establishing adequate personnel qualifica-tions to support fuel load and subsequent operations of the site have been identified by various regional inspectors since the' writing of th'e memoran-dum, particularly in the area of Radiation Control Technicians for normal operations and emergency response.
The licensee has been reluctant to implement the training or qualifications required by ANSI /ANS-3.1-1979.
In a June 18, 1981 Region III staff meeting on the licensing readiness '
of the LaSalle County Station it was decided that obtaining a regulatory
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position which requires the licensee to conform to the requirements of ANSI /ANS 3.1 would allow us to reconcile the outstanding open items identified in the attached memorandum in addition to providing a mech-anism for correcting observed deficiencies in the licensee's training and qualification, program.
Your assistance in resolving this problem in conjunction with NRR would be greatly appreciated. T: Bournia, the NRR LPM for LaSalle has been appraised of this situation.
Please call Roger Walker or Frank Reimann if yo~u need any further information.
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. F. Heishman, Acting ~ Director Division of Resident and Project Inspection
Enclosure:
As Stated 8108120182 810803 PDR ADOCK 05000373' A
PDR CONTACT:
Frank W. Reimann FTS 384-2542
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May 27,1981 Frank W. Reimann, Acting Chief Reactor Proj ects Section IC, Projects Branch 1, Division of Resident MEMORANDUM FOR:
and Project Inspection, USNRC, RIII Roger D. Walker, Senior Resident Inspector, USNRC FROM:
LaSalle County Nuclear Station 373/80-41-01 REQUEST FOR GUIDANCE TO RESOLVE OPEN ITEM
" QUALIFICATION OF PERSONNEL THA
SUBJECT:
documented a special inspection conducted jointly Inspection report 50-373/80-41 The by a team consisting of Of fice of I and E and Of fice of i
0694/0737.
The inspection per Task Action Item T.B.1.2 of NUREG qquirements'for this inspection were defined in (Draf t) " Criteria for Utility and Manage =ent 1980. The (Draft) " Criteria Mansg'ement and Technical Guidance", ilated July 17,and Technical Guidanc for Utility Management l
ff as the acceptance criteria for training and qualifications of p ant stastated that from the personnel.
Inspection Report Open Item 373/80-41 -01 qualification ~ records reviewed, the inspectorsi were unable to determine that a number of individuals' that would fill positions in the Onsite Emergency 3.1-1979. During Organization met the education requirement.s of draf t ANSI /ANS the exit interview on September 11*, 1980, the licensee stated t at they would h
h Onsite address the qualifications of personnel that would fill positions in t e Emergency Organization in the response to NUREG 0694.
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.54, which includes Appendit L.
The inspector ha's reviewed FSAR, Amendment "Ihe inspector does not Appendix L is the licensee's response to NUREG 0694.
f eel that this submittal adequately addresses Onsite. Staff Orga Management with respect the licensee's previous commitment with respect to The inspector is aware that and the licensee meets qualification and training of personnel is ANSI N18.1,1971The differences in the this commitment in most respects.
ANSI /ANS training requirements in some respect's are significant and in most cases,A 3.1 (Draf t '.979) is more limiting.
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i Frank W. Reimann 2
5/27/81 operators. ANSI N18.1 requires a high school education aor equivalent and a high degree of manual dexterity; while ANSI /ANS 3.1 (Draf t-1979) requires a high school diploma, one year of power plant experience, j
and training as required by Sectio,n 5 of the standard for persons i
assigned to these positions.
The licensee'would not meet the latter standard for exp erience for these personnel, nor would it meet the training requiremeats which include evaluation by written examinations (the licensee administers writt'en examinationsi but does not require the employee to pass them)', on-the-job training under the guidance of
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a qualified individual, and a supervisor or qualified operator's
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certification of satisf'actory performance capability.,
Since the licensee has not resolved this, issue with his FSAR submittal as requested, I am requesting' guidance and clarification as to the applicability of the inspection requirements for this inspection.
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i Roger D. Walker Senior Resident Inspector, ESNRC LaSalle C.oonty Nuclear Station
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s NUCLE AR REGULATORY COMMISSION
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- GLEN ELLYN. ILLINo So137 s
NGy03 50 Docket No. 50-373 Commonwealth Edison Company ATTN:
Mr. Cordell Reed Vice President post Office Box 767 Chicago, IL 60690 Gentlemen:
This. refers to the special inspection conducted by Messrs. R. L. Spessard, I. N. Jackiv 'and R. D. Walker of this office and Messrs. A. Bournia and G. W. Rivenbark of the Office of Nuclear Reactor Regulation on September,8 through Septe=ber 11, 1980 of activities at the LaSalle County Nuclear Station, Unit 1, authorized by NRC Construction Permit No. CPPR-99 and to the discussion of our findings with Mr. R. H. Holyoak at the conclusion of the inspection.
This inspection involved an evaluation of the LaSalle Cnunty Station
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organization and =ana gement " capabilities in accordance with NUREG-0694, "DI - Related Requirements for New-Operating Licenses." The enclosed copy of our inspection report identifies areas examined during the in-spection which consisted of a ' selective examination of procedures and representative records, observations, and interviews with personnel.
No items of noncompliance with NRC requirements were identified during the course of this inspection; however, numerous areas in which your staffing and management controls need to be finalized and/or upgraded to meet current NRC requirements and guidelines are discussed in the attached report, and these areas will be reexamined prior to-issuance of an Operating License.
Additionally, two items of safety concern were identified during the inspection, and these items will receive further review by the NRC prior to the issuau;: of an Operating License.
One item relates to the com-position of the shift crews, where the members of the crew are not a per=anent group, and the other relates to the boundary of the control room, where the Shift Supervisor's office which does not have visible access to the control room is considered as part of the control room.
These items are discussed in sections 7 and 10 of this enclosed report.
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Cc.monwealth Edison Company N0'i031350 In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Rone, except as follows.
If this report contains informatica that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this letter, to withhold such information from public disclosure.
The applicati'on must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, James G. Keppler Director
Enclosure:
IE Inspection
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Report No. 50-373/80-41 cc w/ enc 1:
Mr. J. S. Abel, Director of Nuclear Licensing Mr. L. J. Burke, Site Construction SuperintenJ mt Mr. T. E. Quaka, Quality Assurance Supervisor Mr. R. H. Holyoak, Station Superintendent Mr. B. B. Stephenson Project Manager Central Files Reproduction Unit NRC 29b AE0D Resident Inspector, RIII PDR Local PDR NSIC TIC Mr. Dean Hansell, Office of Assistant Attorney General RIII RI I RII
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II RII J.jll ekiv/jp Sp sard Het haan Nore ius K pler 10/17/80 g go
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'd U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND EN7ORCE.ENT
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REGION III Report No. 50-373/80-41 Docket No. 50-373 License No. CPPR-99 Licensee: Commonwealth Edison Company
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Post Office Box 767 Chicago, IL 60690 Facility Name: LaSalle County Nuclear Station, Unit 1 Inspection At: LaSalle Site, Marseilles, IL Inspection Conducted:
September 8 -11, 1930
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Inspectors:
R. D. Walker Q n - 2 /
.4 k'LLs 7 N.-)Jackiv
/O-J/ ~ /d R. L. Spessard
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l A. Bournia X,
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'2 -'* Spessard, Chief.Av.u.>-~ c..
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Approved Isy:
Projects Section 1 Inspection Summary Insoection on September'- 8-11, 1980 (Report No. 50-373/80-41)
Areas Inspected:
This special, announced inspection involved 164 inspector-hours onsite in the areas of Onsite Staff Organization and Management; Independent Safety Engineering Group; Shift Technical Advisor; Shift Manning and Overtime Restr'ictions; Shift Supervisor Duties and Responsibility; Shift Relief and Turnover Procedures, Control Room Access, and Operating Experience Feedback.
Results: No items of noncompliance were identified.
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Persons Contacted
- F. A. Palmer, Division Vice President Nuclear Stations
- R. E. Jottberg, Director of Nuclear Safety
- R. D. Bishop, Technical Staff Supervisor
- C. V. Schroeder, Assistant Technical Supervisor
- R. H. Holyoak, Superintendent LaSalle County Station
- G. J. Diederich, Assistant Superintendent
- L. O. DelGeorge, Licensing Administrator
- J. R. Kodrick, Staff Engineer Maintenance
- P. F. Manning, Quality Control Supervisor
- P. G. Kuhel, Offsite Review /LaSalle County Station B. 3. Stephenson, LaSalle County Station Project Manager J. Mcdonald, Training Supervisor The inspectors also interviewed other licensee e=ployees including
=cmbers of the technical, operating, maintenance, and personnel staffs.
- Denotes persons present at management interview onsite.
2.
Purtose of Insoection The purpose of this inspection was to evaluate the LaSalle County Station organization and management capabilities preceding license.
issuance in accordance with NUREG-0694, TMI-Related Requirements for New Operating Licenses." The review was based on an NRC document entitled " Draft Criteria for Utility Management and Technical Compe-tence," dated July 17, 1980. These draft criteria address the organization, resources, training, and qualifications of plant staff, and management both onsite and offsite for routine operations and the resources and activities both onsite and offsite for accident conditions.
The licensee's offsite management resources and capabilities had been inspected on May 13-14, 1980, during a special inspection conducted at the Commonwealth Edison Company Corporate Office in Chicago, Illinois and, therefore, were not included in the scope of this inspection. Refer to IE Inspe,ction Report No. 50-295/80-10 and 50-304/80-10.
3.
Licen;ee Action oad Previous Insoection Findings Not inspected.
4.
Onsite Staff Organization and Management The objective of this part of the inspection was to review the manage-ment and technical capability of the LaSalle County Station Staff.
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In performing this task, a raview was conducted of tha plant staff organizational arrange =ent, responsibility, authority, and qualifica-tions of plant staff principal personnel.
In evaluating the adequacy
- c. the LSCS staff, NRC members met and held discussions with members of the plant and me=bers of the corporate office.
The information presented here is based on record reviews, oral discussions, and inforsation that has been for= ally submitted to the NRC by CICo.
a.
Documents Reviewed (1) " Draft Criteria for Utility Management and Technical Com-petence," dated July 17, 1980.
(2) Qualification records of plant personnel.
(3) ANS 3.1, " Standard for Qualification and Training of Personnel for Nuclear Power Plants" (Draft - 1979).
b.
Findings LaSalle County Station is mana'ged by Mr. R. H. Holyoak, Station Superintendent, who is responsible for direct management of the station including compliancc with the NRC operating license, government regulations, ASME Code requirements and the Company Quality Assurance Program. He also supervises the stations on-site review function as specified in the Technical Specifications.
Reporting to the Station Superintendent are the Maintenance
- Assistant Superintendent,-Administrative and Support Services-Assistant Superintendent, Operating Assistant Superintendent and the Personnel Ad=inistrator.
They are responsible for the day-to-day operating, maintenance, and refueling activities of the station.
The'LSCS-FSAR and the Technical Specifications state that the qualifications of the plant staff will meet the requirents of ANSI N18.1, 1971.
In conducting this portion of the inspection, the inspectors reviewed number of qualification records of plant personnel to verify that they meet the requirements of ANSI N18.1 - 1971 and also the require =ents of draft ANSI /ANS 3.1 -4979 provided in the NRC document " Criteria for Utility.
Management and Technical Competence" dated July 17, 1980.
Of the individuals reviewed, the inspectors noted that one individual did not meet.the experience requirements of ANSI N18.1, 1971 for the position'- Supervisors Not Requiring NRC License-Radiochemistry.
Also, from the qualification records reviewed, the inspectors were unable to determine that a number of individuals that could fill positions in the onsite emergency organization (i.e. nain-tenance manager, operations manager, etc.) met the education requirements of draft ANSI /ANS 3.1 - 1979.
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During the exit interview on September 11, 1980, the licensee stated that they would address the qualifications of perscanel that would fill positions in the onsite energency organization in the response to NUREG-0694.
This item will be reviewed during a NRC followup inspection (373/80-41-01). With regard to the individual that does not meet the requirements of ANSI N18.1 - 1971, the licensee stated that the individual would be qualified or the licensee' would select another iddividual to fill that position.
This item will also be reviewed during a NRC followup inspection (373/80-41-02).
With regard to the Radiological Protection Organization and the review of the Emergency Plan Implementing Procedures, these items will be inspected during routine NRC inspections prior to fuel load (373/80-41-03).
The licensee informed the inspectors that a number of significant organizational changes had taken place both at the LSCS and in the CECO Corporate Office since CECO's last submitted organizationat info r=ation.
The inspectors requested that CECO document these changes in a submittal to the NRC.
No ite=s of noncompliance were identified in this area.
5.
Independent Safet? Engineering Group (ISEG)
The objective of this portion of the inspection was to determine that the licensee has established or-plans to establish an onsite safety engineering group independent of the plant staff, to perform independent reviews of plant operational activities, evaluate the technical adequacy of procedures and changes important to safe operation of the facility, and evaluate and assess the plant's operating experience and perfor=ance.
a.
Document Reviewed (1) " Draft Criteria for Utility Management and Technical Coepetence,"
dated July 17, 1980.
(2) SECY-80-242, " Independent Safety Engineering Group (ISEG)."
b.
Findings On September,11,1980, discussions were held with Co=monwealth Edison corporate personnel to discuss their plans regarding the establishment of an independent onsite safety engineering group.
CECO intends to establish this group in their corporate office.
This gro'up would be composed of two sections, a BWR section and a PWR section, and would.be a part of a new offsite organization called the Nuclear Safety Organization. This organization is headed by Mr. R. Jortberg who will report to the CECO President.
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CECO is considering assigning two or more engineers onsite at each plant with possibly five additional engineers locaced at the corporate office.
The five corporate office angineers will represent several different disciplines and would spend a few days at each plant.
The inspectors were informed that CICo management had arranged a meeting with Mr. H. Denton, NRR Director, on September 23, 1980, to discuss their plan for the Safety Engineering Group.
Ceco intends to submit a description of its plan for establishing the ISEG after their discussions with Mr. H. Denton. This item will remain open pending further review by the NRC (373/80-41-04).
No items of noncompliance were identified in this area.
6.
The objective of this portion of the inspection was to determine whether the licensee was prepared to implement the Shift Technical Advisor (STA) staffing requirement /co=mitment by time of issuance of an operating license.
a.
Documents Reviewed The following reference and licensee documents w(re reviewed and discussed:
(1) NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short.Te2m Recommendations" dated July, 1979.
(2)
Clarifying documents for NUREG-0578 dated September 27 and November 9, 1979.
(3) American National Standards (ANS) draft revision 3.1 of December. 6,1979, entitled " Standard for Qualification and Training of Personnel for Nuclear Power Plants."
b.
Findings The licensee explained that he plans to designate the person assigned to perform the STA function as Shift Control Room Engineer (SCRE). The licensee plans to train the SCRE's in special technical areas as required by the NRC staff position on training far STA's.
However, he has not co=mitted to meet the staff req'uirement that he provide fully trained STA's by l
January,1981 or by fuel loading, whichever is later.
- Instead, the licensee proposes that its special STA training will be completed by June, 1981.
At the present time, it appears that the plant will not be completed and ready for full load before the end of February,1981.- The licensee management was informed that the June,1981 date for completing STA training does.not meet the staff position.
This ites remains open pending further review by the NRC (373/80-41-05).
The licensee propo'ses that its SCRE (STA) will be a licensed senior reactor operator (SRO) who will be stationed in the control room at all times and will serve as the control room SRO required by the NRC's July 31, 1980 letter from Mr. D. Eisenhut j
to all licensees and applicants providing the staffs interim staffing criteria. The licensee plans that this SCRE will exercise a command and supervisory function in the control room.
The 1icensee informed us that similar plans had already been approved by the NRC for several of its operating plants (Dresden, Quad-Cities and Zion). The licensee was informed that their proposal does not meet the requirements of the NRC staff position for the STA and that a similar proposal by Duke Power Company for its McGuire Plant was recently found to be unacceptable by the NRC staff. The licensee was requested to document their proposed plan providing all of their arguments and a detailed description so that the staff could be sure that it was evaluating the complete proposal.
The licensee indicated that he had made arrangements to discuss this plan for using a SCRE to replace both the STA and the control room SRO with Mr. H. Denton, NRR Director on September 23, 1980. This item will remain open pending further review by the NRC (373/80-41-06).
No items of noncompliance were identified in this area.
7.
Shift Manning and Overtime Restrictions The objective'of this portion of the inspection was to determine
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whether the licensee was prepared to implement the proposed shift manning compliment and overtime restrictions.
a.
Documents Reviewed, Letter of July 31, 1980; to: All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits; from: Darrell G. Eisenhut, Director Division of Licensing; Subj ect:
Interim Criteria for Shift Manning.
b.
Findings The licensee indicated that he planned to operate the LaSalle plant' using five or six operating shift crews. A substantial number of LaSalle personnel have taken the NRC license,examina-
.tions for SRO and RO licensees and it appears reasonable that they will have sufficient number of these licensed by fuel loading to man at least five shift crews. However, the licensee was advised that shift manning had been an item of much concern in recent reviews of other plants and that he should fully document his plans in a submittal to the NRC to provide a basis for the NRC's evaluation and findings with respect to the adequacy of LaSalle's shift manning plans.
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The licensee was advised that he should provide detailed shift staffing plans that include discrete times starting with fuel load and extending for a period of a year or two:
.i (1) The number of licensed SRO's and RO's that will have completed the license examination..
(2),The number of those that have completed the examination that the licensee expects.will be actually licensed.
(3) The number of licensee personnel in training for SRO and RO.
(4) A narrative discussion explaining the plan in detail and including the assumptions made with respect to:
(a)^ Dates for completing training and the NRC license examinations, (b) The number of license applicants passing the exams, (c) The number of licensed personnel the licensee expects to lose due to attrition, and (d) How the licensee expects to handle and accommodate time away from shift work due to sickness, vacation and training.
It was suggested to the licensee that this information be sub-mitted using. tables and charts in a format similar to that for which the licensee has been provided an example of.
This item will remain open pending further review by the NRC (373/80-41-07).
The licensee explained that the bargaining Unit (Union) members of its operating staff [ reactor operators (RO's) and auxiliary operators (A0's)] are allowed (as a result of the licensee's contract with the Union) to select which shifts they wish to work on with the result that they do not stay with any one shift As a result, the operating shift crews (SRO's, RO's and crew.
AO's') are not fixed groups of people who are always assigned to work together and to train together as a team.
It was pointed out to the licensee that, while no known specific NRC requirement -
has been identified to assure that shift crews stay together per=anently and receive training together both on routine and emergency response matters, that it seemed to be desirable from a safety point of v.ew.
The licensee was informed that the NRC plans to consider this subject further (373/80-41-08).
The iicensee explained that he was considering the possible use of twelve hour shifts. as nor=al working shifts for its shift crews for special extended occasions. Under these conditions the crews would work three days and be off approximately four days, then work four days and be off three days so that the normal v.ork week would average 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> or less.
The licensee explained that he was planning to work such shifts, using super-isory personnel only, on a trial period for four weeks in October, 1980. The licensee expressed the view that this typ'e of shift
=annia; was not in conflict with the specific wording of tha NRC's July 31, 1980 letter en i=teria criteria for shift manning.
The licensee was advised that the subject NRC letter was written with an eight hour shift in mind as a normal work day and that its plans for 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> normal shifts were outside the scope of this letter and did not meet the intent of the letter. The licensee was advised that he should document, in a submittal to the NRC, a commitment to meet the overtime requirements, as specified in the interim criteria provided in the NRC's July 31, 1980 letter. This item will remain open pending further review by the NRC (373/80-41-09).
8.
Shift Suu.-rvisor Duties and Responsibilities The objective of this portion of the inspection was to determine whether the licensee had reviewed the administrative duties of the shift supervisor and delegated functions that detract from or are subordinate to the management responsibility for assuring safe operation of the plant to other personnel not on duty in the control
- room, a.
Documents Reviewed (1) NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report-and Short Term Recommendations" dated July, 1979.
(2) Clarifying documents for NUREG-0578 dated Septe=ber 29 and November 9, 1979.
(3) Procedure LAP 200-1, Revision 6, dated September 10, 1980,
" Operating Department Organization".
(4) Procedure LAP 1600-2, Revision 12, dated June 13, 1980,
" Conduct cf Operations."
b.
Findings The review showed that the licensee's responses and planned responses to these items are likely to be resolved without any significant problems. The licensee has already committed in its April 15, 1980 submittal to the NRC that it will conform with the TMI Action Items 1.A.I.2 and 1.C'.3 = ~. with the NRC's clarification of these items.
In reviewing.these Action Items, the items were discussed with licensee representatives and draf ts - of procedures that had been prepared to i=plement them were reviewed.
A number of suggestions were made to the LaSalle plant management as to changes that should be made to bring these procedures into line with the NRC staff po'sitions. The licensee expressed a concern.on these items that the NRC position related to requiring that the shift supervisor remain in the control room until properly relieved is in conflict with the NRC's July 31, 1980 Interim Shift'
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Criteria which requires that an SRO who is not thc. shift super-visor remain in the control room at all timas.
It was agr:ed that clarification will be provided on this matter. It is expacted that based on discussions with the licensee, the licensee will modify its_ procedures for LaSalle to fully implement the TMI Action Item requirements.
IE will inspect these procedures when they are finalized to assure that they fully i=ple=ent the TMI Actio'n Items and the clarified NRC positions on them prior to fuel loading (373/80-41-10).
No items of noncompliance were identified in this area.
9.
Shift Relief and Turnover Procedures The objective of this portion of the inspection was to determine if the licensee had implemented shift relief and turnover procedures to ensure adequate knowledge of plant status.
a.
Documents Reviewed (1) NUREG-0578, THI-2 Lessons Learned Task Force Status Report and Short Term Recommendation" dated July,1979.
(2) Procedure LAP 200-3, Revision 3, dated June 19,1980, Shift Change."
b.
Findings The review showed that the licensee's respon.ses and planned responses to this item are likely to be resolved without any -
significant problems. The licensee has already committed in its April 15, 1980 submittal to the NRC that it will conform with the TMI Action Item 1.C.2 and with the NRC's clarification of this item.
In reviewing ~this Action Item, the item was discussed with licensee representatives and drafts of procedures that have been prepared to implement this item were reviewed. A number of suggestions were made to bring these procedures into line with the NRC staff positions on them.
It is expected that based on d* sc2ssions with the licensee, the licensee will modify his proceoures for LaSalle to fully i=ple-ment the TMI Action Item requirements.
II will inspect these procedures when they are finalized to assure that they fully i=plement the TMI Action Items and the clarified NRC positions prior to fuel loading (373/80-41-11).
l No items of noncompliance were identified in this area.
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10.
Cocerol Room Accest
' The ' objective of this portion of the inspection was to determine that the licensee has established methods to control access to the Control Room.
a.
Documents Reviewed (1) Draft Procedure LAP 1100-12, Revision 0, dated September 10, 1980, " Control Room Access."
(2)
NUREG-0578 "TMI-2 Lesson Learned Task Force Status Report and Short Tern Recommendation" dated July, 1979.
b.
Findings The review showed that the licensee's responses and planned responses to this ites are likely to be resolved without any significant problems.
The licensee has already committed in its April 15, 1980 submittal to the NRC that it will conform with the ThI Action Item 1.C.4 and with the NRC's clarification of this item.
In reviewing this Action Item, the item was discussed with licensee representatives and drafts of procedures that have been prepared to implement it were reviewed.
A number of sugges-tions were.made to bring these procedures into line with the NRC staff positions on them.
It is expected that based on discussions with the licensee, the licensee will modify his procedures for LaSalle to fully i=plement the TMI Action Item requirements.
IE will inspect these procedures when they are finalized to assure that they fully imple=ent the TMI Action items and the clarified NRC positions on them prior to fuel loading (373/80-41-12).
c.
Conce rns Shif t Engineer's Office The shift engineer's (Shift Supervisor.;) office at the LaSall'e plant is separated from the control room by a solid reinforced concrete wall.
There are no windows in this wall between che control room and the Shift Engineer's office.
Access from the Shift Engine ^r's office to,the control room is through a door in the Shift Engineer's office that is located in the wall that is on the opposite side of th2 office frem the reinforced concrete wall, then through an "L" shaped hall outside the office and through another door (vital area door) in the reinforced concrete wall of the control' room.
The licensee was informed that not-withstanding earlier guidance from the NRC that Shift Supervisor's offices, adjacent o control roues could be considered as part of the control room, we did not believe that a Shift Engineer's office that does not have direct visible access to the control room should be considered a part of the contro.1 room.
That is,
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the Shift Engineer or SRO should not be considtred to be insid the control room, whenever they are inside the Shi*ft Engineer's office.
The licensee was asked to specifically define the boundary of the control room in his response to this item. (373/80-41-13)
No items of noncompliance were identified in this area.
11.
Operating ' Experience Feedback to Operating Staff The objective of this portion of th'e inspection was to determine that the licensee has procedures to provide feedback on plant operations to the operating staff.
a.
Documents Reviewed (1) Procedure LAP &50-4, Revision 6, dated July 9,1980, " Review of Technical Document Updates."
(2) NUREG-0660-TMI-2 Task Action Plan.
(3) Offsite Review Plan, Revision 10.
b.
Findings The review showed that the licensee's planned response to this item is like,1y to be resolved without any significant problems.
Tht. licensee has not previously committed to the NRC that he will conform with the TMI Action Item 1.C.5 and with the NRC's
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clarification of this item.
The licenser was advised that he should make such a commitment along the a lines of his cocmitment to Action Items 1. A.I.a,1.C.2,1.C.3, and.1.C.4 which was made in the licensee's submittal to the NRC on April 15, 1980.
In reviewing this Action Item, the item was discussed with licensee representatives and drafts of procedures that have been prepared to implement it were reviewed.
A number of suggestions were made to bring these procedures into line with the NRC staff positions on them.
It is expected that based on discussions with the licensee, the licensee will modify his procedurer frs.
LaSalle to fully implement the TM7 Action Item requirements. II will inspect these procedures whe. they are finalized to assure that they fully implement the TM7 Action Items and the clarified NRC position on them prior to fuel loading (373/80-41-14).
No items of noncompliance were identified in this area.
12.
Item of Special Interest-In discussions with the LaSalle Training Supervisor, it was learned that the licensee's corporate management had visited each of the Commonwealth' Edison Company (CECO) nuclear plants including LaSalle to make a special presentation to the plant staff concerning the
.y 7
i pertance of safe ope-otion of plants. The presentati:n at the LaSalle. Plant had been video taped and the inspectors reviewed tbc
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tape presentation.
In the presentation, CECO corporate managers e=phasized the importance of plant operator taking conservative action whenever there is any question in the minds of the operators as to what to do.
Emphasis was placed on operating within the Technical Specification limits.
The presentation was forceful and indicates that CECO corporate management is concerned with safety.
No itens of noncompliance were identified in this area.
- 13..Managenent Interview The inspectors met with licensee representatives (denoted in Paragraph
- 1) at the conclusion of the inspection period on September 11, 1980.
The inspectors su=marized the scope and findings of the inspection activities.
The licensee was advised that this inspection identified su=erous areas in which formal documentation had not been established and/or licensee procedure had not been finalizedand, therefore, the NRC interoffice team was unable to reach conclusions in these areas.
These areas will be reinspected during a follewup NRC inspection.
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