ML20134N126
| ML20134N126 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/14/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20134N116 | List: |
| References | |
| 50-373-96-19, 50-374-97-19, NUDOCS 9702210212 | |
| Download: ML20134N126 (6) | |
See also: IR 05000373/1996019
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U.S. NUCLEAR REGULATORY COMMISSION
REGION lli
Docket Nos.:
50-373, 50-374
License Nos:
Report Nos.:
50-373/96019(DRS), 50-374/96019(D RS)
Licensee:
Commonwealth Edison Company
Facility:
LaSalle County Station, Units 1 and 2
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Location:
2601 N. 21st Road
Marseilles, IL 61341
Dates:
November 6,7, December 4,1996,
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January 3,1997, and February 3,1997
Inspectors:
D. Jones, Reactor Engineer
Approved by:
W. J. Kropp, Chief
Engineering Specialists Branch 1
Division of Reactor Safety
9702210212 970214
ADOCK 05000373
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Report Details
Ill. Enaineerina
E3
Engineering Procedures and Documentation
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E3.1
Desian Chanaes and Modifications Proaram (37702)
a.
Insoection Scooe
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This inspection pertained to inspection Followup item 50-373/374/96016-04 which
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identified an issue with the use of Nuclear Design Information Transmittals (NDIT)
as design change documents. The inspector reviewed the licensee's procedure
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pertaining to NDITs and reviewed completed NDITs for any significant minor or
major rnodifications that were performed outside the site established design control
process.
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b.
Observations and Findinas
NRC inspection report, 50-373/374/96016(DRP), identified that NDIT LS-0252
modified RCIC air operated valve actuators and, based on the use of the NDIT,
inspection Followup Item 50-373/374/96016-04 was issued in this report to assess
the use of the NDIT as a possible design change document.
1.
Review of NDITs
The inspector reviewed the NDIT iog and selected approximately 35 NDITs to
review. The review identified the following NDITS where the NDIT was used to
effect modifications to equipment:
DATE
NDIT
DESCRIPTION
01/23/96
LS-0108
Safety-related modification of the HVAC Damper
OVC15YA actuator tie-back plate
01/30/96
LS-0134
Safety-related modification to enlarge the mounting hole
on the control rod drive pumps
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02/02/96
LS-0144
Safety-related modification changing the size of the
flange bolts for the ODG exhaust expansion joint from
1 1/4 inch Dia. to 1 inch Dia.
03/20/96
LS-0238
Safety-related modification of flange for actuator seal
drain to HPU flow switch so that a special drain tube
could be tightened
04/02/96
LS-0253
Safety-related approval of RF air operated valve actuator
changes
05/22/96
LS-0268
Bailey instruments within the Unit 2 remote shutdown
panel were found missing rear support brackets
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DATE
NDIT
DESCRIPTION
06/24/96
LS-0324
Safety-related modification of mounting tie-back plate
for replacement actuator for HVAC damper OVC30YB
iO'25/96I
[LSM)43' :
To provide seslingidbtails anisealirig materials fort
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penetrations and: openings in ordef to minimize air
leakage.so that the: control roorn an' auxiliary electric'~
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equipment room csn maintain pressure.
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From late 1995 until October 1996, the licensee performed minor modifications
using the NDIT process rather than the process defined in a station approved
procedure. This matter is further discussed in section E3.2 b (2) of this report.
2.
History of the NDIT Process
The NDIT process was defined in corporate procedure NEP-12 03, Revision 0,
" Nuclear Design Information Transmittal" and LaSalle's site Appendix, NEP-12-
03LA, "Lasalle Nuclear Design Information Transmittal," Revision 1. The inspector
determined the procedure and Appendix stated that the purpose of the NDIT was to
formally transmit design document, vendor, walkdown, and engineering judgment
information in a controlled manner. The procedure and Appendix further stated that
the transmittal of engineering judgement shall be verified by a qualified independent
reviewer, who shall sign the NDIT to document concurrence that the engineering
judgement was technically sound. Appendix NEP-12-03LA, Revision 1, did not
describe the use of the NDIT process as a modification process. The station had a
minor and major modification process already delineated in station procedures LAP
1300-14, " Minor Plant Change Procedure," and LAP 1300-2, " Modification
Program," respectively. The failure to perform modifications from late 1995 until
October 1996 in accordance with an approved procedure is considered a violation
to 10 CFR 50, Appendix B, Criterion V (50-373/374/96019-01).
The process described in station procedures LAP 1300-2 and LAP 1300-14 were
reviewed and approved in accordance with the station administrative procedure,
LAP 820-2, " Station Procedure Preparation." An attachment to this procedure
LAP 820-2T required that part of the review and approval process for LAPS 1300-
14 and 1300-2 was an on-site review (OSR). As stated above, the inspector
determined that the NDIT process has been used to effect modifications to
components and systems since late 1995. However, not until October 1996 did
the licensee issue a revised Site Appendix (NEP-12-03LA, Revision 2). This
Appendix, in addition to describing the use of the NDIT as means to transmittal
information, also described the use of the NDIT for the following:
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non power block plant change packages
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minor safety-related design changes
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minor non-safety-related design changes
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Revision 2 of NEP-12-03LA, which was written and approved by site engineering,
was not reviewed and approved in accordance with station requirements defined in
LAP 820-2. The failure to review and approve NEP-12-03LA, Revision 2, in
accordance with station requirements is considered a violation (50-373/374/96019-
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02) of Technical Specification 6.2, " Plant Operating Procedures and Programs," in
that the procedure for the review and approval of station procedures, LAP 820-2,
was not followed prior to issuing Revision 2 of NEP 12-03LA.
Further review of the issuance of NEP 12-03LA determined that the site quality
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organization had also identified in a Corrective Action Record (CAR) 96 01-96-049
that site appendixes to NEPs were not reviewed in accordance with the LAP 820
process. The quality organization accepted site engineering's response which
stated that the applicable station procedure would be revised to exempt site
appendixes to corporate NEPs from the station review and approval process.
The licensee has or willimplement the following immediate corrective actions to
address the issue of utilizing the NDIT process as a modification:
Revision 2 of NEP 12-03LA that described the use of the NDIT as a vehicle
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for processing modifications and was issued in October 1996 has been
superseded.
Revision 3 to NEP 12-03LA will be issued that clearly states that the NDIT
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cannot be used to issue a design change or to circumvent the temporary
modification process.
Until the issue of Revision 3 to NEP 12-03LA and required training, NDITs
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will require department head approval prior to issuance to ensure there are
no modifications ceing processed using the NDIT.
3.
Review of NDITS at Other Licensee Facilities
To determine if the NDIT process was being used in a similar manner at other
Commonwealth Edison facilities, the inspectors reviewed the NDIT Logs and
approximately 20 NDITs generated at the Zion and Braidwood Nuclear Stations.
The review of the these NDITs and the NDIT procedure at each station determined
the NDIT process was being used as originally intended, which was to transmit
desi n information; not to initiate minor modifications.
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c.
Conclusions
Even though Lasalle station had existing procedures to process plant modifications,
since late 1995 the licensee had used the NDIT process to effect minor
modifications to safety-related equipment without always performing a written
safety evaluation to support these changes. Establishing an additional modification
process was indicative of poor management oversight of plant activities. Also, the
failure of the Site Ouality Verification (SOV) organization to:
Identify the NDIT process was being used to process plant modifications
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without always performing safety evaluations, and
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Identify that the review and approval process for the site appendix NEP-12-
03LA was not in accordance with the station's technical specifications was
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indicative of less than adequate self-assessment capabilities.
E8
M!:cellaneous Engineering issues (92902)
E8.1
(Closed) Insoection Follow-Uo item 50-373/374-96016-04: Site procedure NEP-12-
03LA, "LaSalle Nuclear Design Information Transmittals (NDIT) Site Appendix,"
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Revision 2, appeared to change the intent of the NDIT process defined in corporate
procedure NEP-12-03. The site appendix expanded the NDIT scope to include
minor changes to safety-related documents. Follow-up inspection activities,
documented in Paragraph E3.1 of this report, identified two violations. This item is
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closed.
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V. Manaaement Meetinos
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Exit Meeting Summary
The inspectors presented the results of these inspections to Commonwealth Edison
management listed below at an exit meeting on January 3,1997 and on February 3,
1997. The licensee acknowledged the findings presented.
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The inspectors asked the licensee if any materials examined during the inspection should
be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
@ *P. Barnes, Regulatory Assurance Supervisor
"D. Egan, Design Engineering Supervisor
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- L. Guthrie, Operations Manager
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"D. Ray, Station Manager
- W. Subalusky, Site Vica President
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- At exit meeting on January 3,1997
@lndicates those present at the phone exit on February 3,1997
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INSPECTION PROCEDURES USED
IP 37702:
Design Changes and Modifications Program
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ITEMS OPENED, CLOSED, AND DISCUSSED
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Opened
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373/374/96019-01 VIO
Failure to follow procedures
373/374/96019-02 VIO
Failure to review and approve NEP-12-03LA, Revision 2 in
accordance with station requirements
Closed
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373/374/96016-04 IFl
Use of NEP-12-03LA for design changes
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