ML20134N126

Insp Repts 50-373/96-19 & 50-374/96-19 on 961106-07,1204, 970103 & 0203.Violations Noted.Major Areas Inspected: Inspector Reviewed Ndit Log & Selected Approx 25 Ndits to Review

ML20134N126
Person / Time
Site:	LaSalle
Issue date:	02/14/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20134N116	List: ML20134N113 ML20134N117 ML20134N126
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: NPF-11, NPF-18

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, 3

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

PDR 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)

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a. Insoection Scooe

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This inspection pertained to inspection Followup item 50-373/374/96016-04 which

identified an issue with the use of Nuclear Design Information Transmittals (NDIT)

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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.

l b. Observations and Findinas

NRC inspection report, 50-373/374/96016(DRP), identified that NDIT LS-0252 l

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.

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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 l

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

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iO'25/96I [LSM)43'8 : To provide seslingidbtails anisealirig materials fort

penetrations and: openings in ordef to minimize air

leakage.so that the: control roorn an'd auxiliary electric'~

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equipment room csn maintain pressure.

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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e non power block plant change packages

e minor safety-related design changes

e 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- j

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, I

was not followed prior to issuing Revision 2 of NEP 12-03LA.  !

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Further review of the issuance of NEP 12-03LA determined that the site quality i

organization had also identified in a Corrective Action Record (CAR) 96 01-96-049 l

that site appendixes to NEPs were not reviewed in accordance with the LAP 820

process. The quality organization accepted site engineering's response which

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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

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address the issue of utilizing the NDIT process as a modification: l

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Revision 2 of NEP 12-03LA that described the use of the NDIT as a vehicle

for processing modifications and was issued in October 1996 has been

superseded.

e Revision 3 to NEP 12-03LA will be issued that clearly states that the NDIT

cannot be used to issue a design change or to circumvent the temporary

modification process.

e Until the issue of Revision 3 to NEP 12-03LA and required training, NDITs

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

desi0n information; not to initiate minor modifications.

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:

e Identify the NDIT process was being used to process plant modifications

without always performing safety evaluations, and

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• Identify that the review and approval process for the site appendix NEP-12-

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03LA was not in accordance with the station's technical specifications was i

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-

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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,

4 documented in Paragraph E3.1 of this report, identified two violations. This item is

3 closed.

V. Manaaement Meetinos

X1 Exit Meeting Summary

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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,

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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

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"D. Egan, Design Engineering Supervisor

• L. Guthrie, Operations Manager i

l "D. Ray, Station Manager I

• 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:

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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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