ML20094H987
| ML20094H987 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/14/1984 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20094H908 | List: |
| References | |
| 8796N, NUDOCS 8408140180 | |
| Download: ML20094H987 (4) | |
Text
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's Commonwealth Edison
[
) Ont First Nttional Plaza. Chic:go, Illinois
(
'/ Address Reply to: Post Offica Box 767
'(j/ Chicago, Illinois 60690 June 14, 1984 Mr. James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road - Region III Glen Ellyn, IL 60137
Subject:
LaSalle County Station linit 2 Response to Inspection Report No. 50-374/84-04 NRC Docket No. 50-374 Reference (a):
W.
S. Little letter to Cordell Reed dated April 24, 1984.
(b):
D.L. Farrar letter to J. G. Keppler dated May 22, 1984.
Dear Mr. Keppler:
This letter supplements the response to the inspection conducted
,by Mr. Z.
Falevits on January 31 through February 13, 1984, of activities at LaSalle County Station transmitted by reference (a).
The timing for submittal of this supplement was discussed with Mr. Cordell Williams of your staff on June 14, 1984.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, h
D.L. Farrar Director Nuclear Licensing Im Attachment cc:
NRC Resident Inspector - LSCS M
8796N j@ N 9408140100 840009 DRADOCK05000g
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ATTACHMENT A COMMONWEALTH EDISON COMPANY LASALLE COUNTY STATION UNIT 2 SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION NONCOMPLI ANCE 10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company Corporat? Quality Assurance Manual, Nuclear Generating Stations, Section 5, requires that activities affecting quality be performed in accordance with documented instructions and procedures of a type appropriate to the circumstances.
Contrary to the above, the following examples of inadequate implementation of procedures were identified.
1.
Procedure LAP-810-5 Revision 9, requires that drawings be checked against Sargent and Lundy status list quarterly to assure that up-to
~
date drawings are being maintained in the central file.
Na documented evidence could be found to indicate that any checks have been performed in the last two years.
One aperture hard copy print (No. M-5444, Sh. 2) made from central file records, did not contain any engineering approval signatures and did not identify the current' revision status of the drawing.
2.c. Indicating control light arrangements on drawings do not agree with the arrangements on the panel.
(Drawing series /E-1-4497 AA-AD and IE-2-4498 AA-AD.)
ITEM 1 CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED On February 23 & 24, 1984 a drawing audit was performed on Sargent &
Lundy Electrical, Mechanical, Structural and Architechtural drawings.
Of
.the 29,348 drawings audited, 252 were missing from the file and 133 had
.the wrong revision.
The 133 drawings with the wrong revision were pulled from the file. The drawings identified as missing / wrong revision during the audit were requested from Drawing Management Services and a committment was made for Sargent & Lundy to have all the drawings to Drawing Management Services by June 15, 1984.
l
_2_
The aperture card (M-5444, Sheet 2) identified as not containing engineering approval signatures and_not identifing the current. revision
- status was corrected prior to the exit.
The revision now in central. File
.issthe A revision-dated June 15, 1977 and contained the required
' engineering _ approvals, this revision is the current revision per the
- Sargent and Lundy print index.
CORRECTIVE' ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE To assure quarterly auditing of the drawing' files, the item has been put on the General Survie11ance Program.
Documentation will be maintained on all future audits.
Station procedure LAP-810-5 has_also been revised to clarify the quarterly sample audit requirements for the drawing files.
DATE OF FULL COMPLI ANCE
' June 15, 1984.
L 1
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ATTACHMENT B Additional Information Regarding Item 2.C Of the~ Notice of Violation-dated April 24,-1984 The indicating control light arrangements shown on LaSalle County' Station drawings reflect standard drawing conventions developed by
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Sargent & Lundy and Commonwealth Edison.
These specify red lights to indicate-full open valves, green lights to indicate full closed vlaves, etc.
Subsequent to development of these drawing standards and issuance of the majority of station drawings, LaSalle implemented a " green board" program.1 This program is aimed at reducing operator errors by creating
-control room panel indications which are more meaningful to the operator.
Under this' concept, a valve in its normal position will be-shown in green regardless of its position.
An off-normal valve will be Jshown.in red, calling the attention of the, operator to the abnormal line-up.
Implementation of the " green board" concept has been a -
significant improvement from a human factors standpoint.
Operator training and participation in the actual setup of control panels for green board has served to familiarize them with this concept.
Thus Commonwealth Edison believes this minor discrepancy between the drawings and panels is not likely to result in confusion.
We also believe that revisich of these drawings to reflect green board would contribute little to-plant safety or reliability. -We believe the large effort in manpower both at-the site and at our A.E.,
plus the significant cost associated with revising these drawings is not justified.
8796N
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