ML20137D844

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-373/96-19 & 50-374/96-19.Corrective Actions:Site Engineering Manager Required That All Ndits Be Approved by Engineering Dept Head Prior to Issue on 970103

ML20137D844
Person / Time
Site:	LaSalle
Issue date:	03/21/1997
From:	Subalusky W COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9703260325
Download: ML20137D844 (7)

Text

, 4 hmmonw ralth I'4 hum Qnnpany 12 Nile Generating Station 1(ol North 21st Roati Starvilks il 613 il 9757

, , Tel H 15-357W61 March 21,1997 United States Nuclear Regulatory Commission i

Attention: Document Control Desk Washington, D.C. 20555

Subject:

NOTICE OF VIOLATION; NRC INSPECTION REPORT 50-373/374-96019

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Reference:

M. N. Leach letter to W. T. Subalu sky, dated

February 14,1997, Transmitting NRC Inspection

Report 373/374-96019 4

The enclosed attachment contains LaSalle County Station's response to the Notice of Violation, that was transmitted in the Reference letter.

If there are any questions or comments concerning this letter, please refer them to me at (815) 357-6761, extension 3600.

l Respectfully, W. T. Subalusky Site Vice Preside LaSalle County Station Enclosure hI .I cc: A. B. Beach, NRC Region Ill Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skt.y, Project Manager - NRR - LaSalle 9703260325 970321 ~

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VIOLATION: 373/374-96019-01a i

10 CFR 50, Appendix B, Criterion V states, in part, that activities affecting quality shall be prescribed by documented instructions and shall be accomplished in accordance with these instructions.

LAP-1300-14, "fAinor Plant Change Procedure" and LAP-1300-2, " Modification Program,"  !

described the station process for performing modifications including the necessary safety i screening evaluations.

i Contrary to the above, the inspector determined that from late 1995 until October 1996  !

station minor modifications were performed on components and systems using Nuclear j Design Information Transmittal (NDIT) forms rather than the process defined in LAP-1300-14. Some of these minor modifications did not have written safety screening evaluations which would have been required by LAP-1300-14 (NDITs LS-0144,0 DG flange bolts; LS-0268, shutdown panel brackets; and LS-0438, control room sealing).

This is a Severity Levei IV Violation (Supplement 1).

REASON FOR VIOLATION: 373/374-96019-01a Comed agrees that the LaSalle site appendix to the NDIT procedure 12-03LA was used inappropriately to transmit and perform design changes.

The original purpose of the Site Appendix to the NDIT Procedure is stated to provide "the requirements for the preparation and control of safety-related, regulatory-related and non-safety related nuclear design information transmittals." The scope of the original revision and the first revision stated that the appendix applies to LaSalle County Station.

. Revision 2 of the Site Appendix expanded the scope of the NDIT process at LaSalle  !

County Station to include (1) non-power b%ck plant changes, (2) minor safety-related design changes to a controlled design document with Design Engineering Supervisor 3 approval, and (3) non safety related changes to a controlled design document. l This revision of the procedure required independent review and 10 CFR 50.59 safety .

evaluation screening of the proposed changes and submittal of a DCR for the changes. l However, the procedure failed to provide written guidelines or screening for definition of minor changes which could be made under this procedure. Instead the use of this procedure for minor changes was administratively controlled by requiring approval of the Design Engineering Supervisor. This permitted the use of this procedure for minor j changes at the discretion of the Design Engineering Supervisor only. ,

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The Design Engineering Supervisor was the authorized approver of the NDIT procedure.

His approval of the provisions to make minor safety-related design changes via this procedure indicated a lack of understanding of the need for complete written instructions for these changes and was accordingly inappropriate.

Additionally, in October 1996, when the Design Engineering Supervisor was directed to cease making such design changes under the NDIT Procedure, he did so by verbally instructing his personnel to not use this provision rather than voiding and appropriately revising the procedure.

A contributing factor to the incomplete revision to the procedure was the failure to submit the procedure revision for safety evaluation screening, technical review and Onsite Review required by the plant Technical Specifications as discussed in response to Violation 373/374/96019-01b.

This revision led to use of this procedure in lieu of the appropriate procedure (LAP-1300-14, " Minor Plant Change Procedure) for certain minor modifications.

The safety significance of this violation is being evaluated on a case by case basis for each change performed under the NDIT procedure, and the extent of condition is being determined by review of all modifications performed under the NDIT procedure, as described in the corrective actions, below.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED: )

1. On January 3,1997, the Site Engineering Manager required that all NDITs be I approved by an Engineering Department Head prior to issue.

2. On January 4,1997, NEP-12-03LA, Revision 2, LaSalle Nuclear Design Information Transmittal (NDIT) Site Appendix, was voided. 4

3. The Design Engineering Supervisor was counseled by the Site Engineering Manager on the inappropriate actions taken.

4. All NDITS issued under NEP-12-03LA, Revision 2 have been reviewed to determine if NDITs had been inappropriately used to transmit design changes under this revision. Three occurrences of inappropriate use of the NDIT procedure were identified.

. The first provided generic approval to modify valve packing. This NDIT had not been used and was voided. A assign drawing was issued to control the use of valve packing.

. The second involved a material substitution for an unavailable original material for damaged soil drain piping. A safety evaluation screening has been performed to validate the material change and the material specification for the piping has been appropriately updated.

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3 I -* The third NDIT, involving a material type change in valve guides, was

! supplemented with a parts evaluation, a safety evaluation and update of the j valve drawings in accordance with applicable station procedures.

l l No changes to plant hardware were necessary as a result of this investigation.  !

J l 5. On February 6,1997, a stop work order was issued by Site Quality Verification on

! use of NEPs for reasons cited in Violation 373/374/96019-01b. This stop work order i applied to all NEPs and site appendices to the NEPs subject to completion of safety i I

i evaluation screenings, independent technical reviews, Onsite Review and Station j Manager approval in accordance with the station Technical Specifications. Use of l- NDITs was suspended until the full review and approval process was completed for NEP-12-03 and NEP-12-03LA.

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6. Revision 3 of NEP-12-03LA was written to (1) clarify the scope of use of this l ]

procedure, (2) specifically prohibit the use of an NDIT for transmittal of a design l change, and (3) specifically prohibit the use of an NDIT to circumvent the temporary j alteration procedure. j i

l 7. The 50.59 safety evaluation screening, independent technical review and Onsite t

Review was completed for Revision 3 of the site appendix, along with NEP-12-03.

CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS:

1. Training on these procedures will be conducted by March 28,1997.

2. All NDITs issued by Engineering to all revisions of NEP-12-03LA will be reviewed to determine if additional NDITs had been inappropriately used to make design changes and, where they were, establish if safety evaluation screenings and design verification had been perfomied. Where inappropriate use of an NDIT is identified or the safety evaluation screening and/or design verification were not completed or not completed correctly, action will be taken to address the significance and consequence of the inappropriate use and implement any reqcired corrective action.

This will be completed by April 4,1997.

- DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance will be achieved when training is completed and after all NDITs have been reviewed and any necessary corrective actions implemented prior to unit restart.

VIOLATION: 373/374-96019-01b Technical Specification 6.2, Plant Operating Procedures and Programs, states in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, 3 Revision 2, February 1978. I i

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l Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations), j j Appendix A, states that administrative procedures for procedure review and approval i

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t activities should be covered by written procedures.

! Procedure LAP 820-2, " Station Procedure Preparation and Revision," Revision 39,-

Section B.1.3, states that all new procedures or revisions receive either a technical review i or on-site review as specified in attachment LAP 820-2T. LAP 820-2T identifies that

! LAP-1300-14, " Minor Plant Change Procedure," requires an on-site review. )

o j Contrary to the above, the LaSalle station site engineering department issued site i appendix, NEP-12-03LA, "LaSalle Nuclear Design Information Transmittals (NDIT) Site i Appendix," Revision 2, in October 1996 without the Appendix being processed in  !

l accordance with procedure LAP 820-2. NEP-12-03LA defined a different minor j modification process than the one described in station procedure LAP-1300-14. <

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.I This is a Severity Level IV Violation (Supplement I). l REASON FOR VIOLATION: 373/374-96019-01b l

Comed agrees that the LaSalle station Engineering Department issued site appendix

NEP-12-03LA without the appendix being processed in accordance with procedure

LAP-820-2," Station Procedure Preparation and Revision". The appendix was reviewed to 4

LaSalle Administrative Procedure 850-4, " Review of Technical Document Updates". At i j . LaSalle County Station, LAP 850-4 is the only Administrative procedure which controls the

required review of NEPs, LaSalle County Station site appendices to the NEPs and LaSalle 1 Nuclear Engineering Procedures (LNEP). LAP 850-4 does not include, however, the' safety evaluation screening, independent technical review and Onsite Review provisions of j Section 6.2.0. " Technical Review and Control" (a subsection of 6.2 Plant Operating l Procedures and Programs) of the Technical Specifications. The significance of this is that

NEPs, in general, have not been reviewed in accordance with these requirements.

The NEPs are prepared, revised and issued by Comed Corporate Engineering. They were used originally only by the Design Engineering Department, and this department was originally an off-site centralized Comed organization. The Design Engineering function has been transferred to the LaSalle County Station. Even so, the NEPs have traditionally not been considered as site procedures. Accordingly, LAP 820-02, the procedure for

. preparation and revision of site procedures, does not include the NEPs in its scope. This was a mis-interpretation of the status of NEPs as they apply to controlling the design processes for the systems, structures and components at LaSalle.

The safety impact of this violation is considered to be of low significance. These procedures have been technically reviewed, as they were developed and revised by Comed Corporate Engineering, and have been used extensively to control the Comed design engineering processes. In addition, these procedures were reviewed under the direction of the Site Engineering Manager for impact on the station under LAP 850-4.

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. , , j Finally, as part of the corrective actions described below, these procedures are undergoing  :

reviews consistent with the Technical Specification requirements, and the extent of condition of any deficiencies discovered as part of the reviews of these procedures will be investigated and the safety significance of the deficiencies on the design and configuration j of the plant will be evaluated usirig the LaSalle County Station Corrective Action Program.  !

Comed also agrees that NEP-12-03LA defined a different minor modification process than the one described in station procedure LAP-1300-14, " Minor Plant Change Procedure".

This issue is discussed in response to Violation 373/374/96019-01a.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:

1. On February 6,1997, Site Quality Verification issued a Stop Work Order on use of all Nuclear Engineering Procedures subject to completion of the reviews required by Section 6.2.C of the Technical Specifications.

2. On February 14,1997, the Engineering Department initiated the following process to comply with these requirements for each NEP requiring review:

. A written 10 CFR 50.59 safety evaluation of the procedure is prepared and independently reviewed and approved.

. An independent technical review and, where required, a cross-discipline review, is conducted of the procedure using a specially prepared precedure, i LaSalle Limited Procedure (LLP)-97-010, " Review and Approval of l Engineering Procedures". The.LLP was written because of the deficiencies I cited above on the site and NEP procedures on procedure review, approval j and control. I e PlFs are written to document reviewer comments. When required site appendices are written or revised to correct deficiencies in the NEPs and/or to conform the NEP to LaSalle specific requirements or site practices. 'PIFs and appendices are forwarded to Corporate for coordination of needed NEP revisions.

• The safety significance of each PIF is evaluated and the impact of significant deficiencies on prior work performed to the affected procedure is evaluated. l If necessary , appropriate corrective action is taken to resolve the impact of i the deficiency.

. The approved safety evaluation, the results of the technical review and, if required, cross-discipline review of the procedures m presented to Onsite Review.  !

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4 . .Upon approval by Onsite Review and signature of the Station Manager or

' designee, Quality Control reviews the Onsite Review paperwork and l i

applicable 50.59s and then contacts an SQV supervisor to receive j concurrerice on release of the Stop Work Order for that procedure f 3. Additional extent of condition reviews by SOV have indicated the potential for similar  ;

' deficiencies in the process for review of other Comed Corporate Procedures. - A root 1 cause team has been assembled and a root cause evaluation of the failure to j conduct appropriate reviews prior to implementation of Comed Corporate procedures, in general, has been initiated. ' As a result of this action, other LaSalle County Station organizations have stopped work to these procedures until applicable reviews have been completed except in cases where such a stop work would affect plant safety or security.

CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS:

1. About 70 NEPs have been identified as requiring these reviews. The process described above is being followed for each NEP prior to its release for use. ' All required reviews will be complete prior to further use of each procedure and all procedures requiring reviews will be reviewed prior to restart of the plant.

2. The special LLP written on February 7,1997, to implement the NEP review process has a maximum lifetime of six months. A permanent LAP covering the appropriate reviews of non-station procedures will be prepared by August 7,1997.

3. The appropriate reviews of other Comed Corporate procedures requiring reviews to re-initiate use of the procedure, will be completed prior to plant restart.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Reviews of all Comed Corporate procedures requiring review and the preparation c' a permanent LAP to require and implement future reviews of these procedures in accordance with the Technical Specifications will be completed prior to unit redart.

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