ML20138H802
| ML20138H802 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/23/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0801K, 801K, NUDOCS 8512170327 | |
| Download: ML20138H802 (6) | |
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N Commonwealth Edison
) One First Nationit Pitza Chic"go, Illinois (g-t,1
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i 7 Address Reply to: Post Office Box 767
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,/ Chicago, Illinois 60690 -
October 23, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle. County Station Units 1 and 2 Response to Inspection Report Nos. 50-373/85-024 and 50-374/85-025 NRC Docket Nos.'50-373 and 50-374 Reference (a):
C. E. Norelius letter to-Cordell Reed dated September 27, 1985.
Dear Mr. Keppler:
Tnis letter is in response to the inspection conducted by Messrs.
M. Jordan, J. Bjorgen, A. Morrangiello and R.-Kopriva on July 25 through of activities at LaSalle County Station. Reference (a)
September 6' 1985,tain activities appeared to be in noncompliance with NRC indicatedtliatcer requirements. The Commonwealth Edison Company response to the Section 11 open item and the Notice of Vio'lation is provided in the enclosure.
If you have any further questions on this matter, please direct them to this office.
Very tr y yours, Aew Of L. Farrar Director of Nuclear Licensing
'lm Attachment cc: NRC Resident Inspector - LSCS OCT 241985 0801K-8512170327'B51023 PDR ADOCX 05000373 G
PDR 250/ l\\I
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.t ATTACHMENT RESPONSE TO SECTION-11 OPEN-ITEM (374/85-25-02 DRP)
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STATEMENT'0F PROBLEM ECN M-625-LS was issued to install support plates around piping penetrations on the air conditioning units of RHR pump room coolers..The ECN included reference sketches showing the location of the plates. The drawings which incorporated the ECN did not incorporate the reference sketches to show the location of the plates.
RESPONSE
The design change.information including reference. sketches, included in ECN M-625-LS pertained to vendor drawings. These drawings were
-listed on the ECN as affected drawings. When the ECN was incorporated, Sargent & Lundy revised the vendor drawings to show the design detail's and the location of the plates. The location of the plates was called out on l
l each _ vendor drawing using either ? typical detail" or descriptive notes and symbols. If only one design detail applied to all plate locations on a
'particular drawing, that detail was called out as a typical detail with the usual understanding that the same design detail applied to all the piping connections on the drawing. The necessary design information in the reference sketch.was incorporated on the design. drawings. This same basic procedure would be used now, except the drawing revisions would be controlled by Drawing Change Requests' (DCR's).
Based on the above, we believe that information contained.in reference sketches was and is _being adequately incorporated into the plant
' design documents.
It should be noted, however, that the use of reference sketches in ECN's is an infrequent practice.
Our further review of these drawings, however, revealed a problem relating to the handling of the subsequent revisions on these drawings'by the vendor. At the time ECN M-625-LS was incorporated, we revised the affected vendor drawings called out in the ECN. - A set of revised drawings
.was sent.to the vendor for their record. Four out of the eight of these drawings were subsequently revised or retransmitted by the vendor for a
-different reason (to include some additional as built information). The subsequent vendor information on.these four drawings did not include design.
changes per the ECN. incorporated by us on their earlier revisions.
The
. drawings were released by the vendor to us for information only. Sargent &
Lundy-did not review these drawings (because they were labelled for infomation only) and distributed these drawings to Commonwealth Edison and Sargent & Lundy personnel for information, resulting in the loss of the record design information relating to ECN M-625-LS on these drawings.
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r Based on.the above findings, it is our conclusion that this situation represents an isolated occurrence and is not indicative of a wide-spread weakness.
In order to. provide further assurance that pre-fuel load ECN's in general were processed correctly and that the as-built configuration is properly represented in design drawings, an additional
. review will be completed over the next 3-4 months. This review will involve approximately 100 randomly selected ECN's ano will verify proper completion of work in' the field and accuracy of as-built drawings.
Because this review is not limited to drawings closed via an FCR, it represents an expanded scope over the initial review.
CORRECTIVE ACTION-TAKEN TO AVOID FURTHER NONCOW LIANCE As stated previously, the issuance.of construction series ECN's directly
.to the' construction personnel was terminated as of fuel load for each
~ unit. Subsequent design changes are authorized under the modification program which includes a provision for updating drawings via a Drawing Change Request (DCR). DCR's are initiated by plant personnel only after the physical installation is complete.
DATE WHEN FULL-COWLIANCE WILL BE ACHIEVED Full compliance has been achieved.
The expanded review which encompasses a wider scope than that suggested'by this ' noncompliance is scheduled for completion by March 1,1986.
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RESPONSE TO NOTICE OF VIOLATION ITEM OF NONC0f4)LIANCE 1.
Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion VI, Document Control, states, in part:
" Measures shall be established for issuance of documents... procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes are reviewed for adequacy and approved for release by authorizeo personnel and are distributed to and used at the location where the prescribed activity is performed."
Commonwealth Edison Company Quality Assurance Manual, Quality Requirement 6.0, Document Control, states, in part:
... provision to assure as-built drawings are kept updated, properly maintained, and controlled. Such documents will be distributed to and used at the location where the prescribed activity is performed. Changes to these doucments will be handled similarly..."
Contrary to the above, ECN No. M-586LS and subsequent FCRs were not incorporated into permanent drawings or distributed resulting in the Unit 2 leak detection monitors not being properly located in the RHR equipment room.
CORRECTIVE-ACTION TAKEN AND RESULTS ACHIEVED Engineering ^ Change Notice (ECN) No. M-586-LS was issued during the construction of LaSalle Unit 2 to locate leak detection thernocouples in the RHR cubicle. This ECN was closed by reference to a Field Change Request (FCR). Because the FCR did not fully duplicate the physical work authorized by the ECN, the work was not completed although design
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documents were revised as if it had been. Consequently, the design drawings did not accurately reflect the as-built configuration.
Note that ECN No. M-586-LS is a construction series ECN transferred directly from the Architect-Engineer to the site' construction personnel. This mechanism was replaced by the modification program once fuel loading was initiated.
Upon discovery of this situation, the following corrective actions were taken:
1.
Modification M-1-2-85-053 was implemented to relocate the thermocouples within the RHR cubicle. This work was completed prior to returning the unit to service.
2.
Approximately 150 construction series ECN's, which had been released in the same time frame as ECN No. M-586-LS, were reviewed to see if any had been closed similarly by reference to an FCR and, therefore, had the capacity for a similar error. No additional ECN's were found to have been closed in this manner.
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. ~ CORRECTIVE ACTION TAKEN AND RESULTS-ACHIEVEb A.
The four drawings.that were subsequently revised by the vendor will be revised again to reincorporate the ECN information..These drawings will be' redistributed for record per our project distribution list.
This action will be completed by October 31, 1985.
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B.
Approximately 100 pre-fuel load ECN's prepared approximately in the same time period will be reviewed to determine if this sort of problem occurred on any other ECN's. Affected drawings, 'if any, will be revised in the same. manner as "A" above. This action will be completed by December 31, 1935.
CORRECTIVE ACTION-TAKEN TO AVOID FURTHER NONCONPLIANCE A.
All' post-fuel load ECN's are closed out using Commonwealth Edison generated DCR's. The DCR form lists all the affected drawings including vendor drawings. Sargent & Lundy revises the vendor drawings and releases the drawings for record to the vendor, Commonwealth Edison and
,Sargent & l. undy personnel.
B.
Sargent & Lundy-currently reviews all new revisions on vendor drawings transmitted to us by vendors to ensure that any design changes that Sargent & Lundy may.have made on the earlier revisions of these drawings are not lost in the subsequent revisions by the vendors. 'Blis practice will be formalized by a revision to the Project Instructions which will be made by October 31, 1985.
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ITEM OF NONCOWLIANCE
- 2. LTechnical Specifications Section 6.2 requires the licensee to adhere to detailed written procedures for instrument operations.that can have an effect on the safety of the facility.
4 Contrary to the above, the licensee failed to follow procedure LIP-GM-09 when returning instrument 1B21NO370B to service which caused Unit 1 to trip.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The Unit 1 trip resulted from a personnel error. All plant systems' responded as designed. A post trip review was completed and the Unit was returned to service. This error has been discussed with Instrument Maintenance Department personnel.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER-NONCOMPLIANCE
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Disciplinary action was taken with respect to the ~ individual involved.
The' individual has been reassigned to 'less-sensitive duties.
DATE WHEN' FLLL COWLIANCE WILL BE' ACHIEVED Full compliance has been achieved.
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