ML20151R646
| ML20151R646 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/04/1986 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0988K, 988K, NUDOCS 8602060170 | |
| Download: ML20151R646 (39) | |
Text
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. Commonwealth Edison
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/ Chicago. Usinois 60690 b
February 4, 1986 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 Request for Information Under 10 CFR50.54(f)
NRC Docket Nos. 50-373 and 50-374 References (a):
NRC letter from J.G.
Keppler to C.
Reed dated November 22, 1985 (b):
CECO letter from D.L.
Farrar to J.G. Keppler dated December 5, 1985 (Attachment 3)
(c):
CECO letter from C.
Reed to J.M.
Taylor dated November 26, 1985 (Attachment 2)
(d):
CECO letter from C. Reed to J.G.
Keppler dated December 23, 1985
Dear Mr. Keppler:
This letter is Commonwealth Edison Company's (" Edison")
revised response to the Nuclear Regulatory Commission's ("NRC" or
" Commission") request for information under 10 CFR50.54(f),
Reference (a).
An initial response was transmitted on December 23, 1985, as Reference (d).
At a subsequent meeting with your staff on January 17, 1985, ceveral items of clarification were discussed including (1) a need to provide cross-referencing between the NRC areas of concern and related Edison Management Plan sections; (2) a request for additional information regarding management, management structures and practices that have attributed to station performance and changes made to improve that performance, and (3) a need for more definitive information regarding the number of outstanding work requests, modifications and procedure changes that will remain open at the end of the LaSalle Unit 1 refueling outage now in progress and justification for plant restart if these items are not current.
This transmittal will address these three items and supersede the earlier response, Reference (d), in its entirety.
Edison shares your concern that efforts to improve the regulatory performance of the LaSalle County Nuclear Station Units 1 and 2 ("LaSalle") have not been completely effective in preventing I
8602060170ggh00373 gO PDR ADOCK PDR G
t recent operational events.
Edison recognizes that the regulatory performance at LaSalle requires additional improvement to prevent the type of recent events that have occurred and to ensure we meet the Company's goal of safe and error-free nuclear operation.
Therefore, Edison has committed to perform the extensive actions discussed below.
A key element in this program is the Management Plan already provided on December 5, 1985 (Attachment 3).
Other elements of this program are discussed below in relation to specific regulatory concerns raised in your letter.
Edison believes that the implementation of this program will substantially upgrade LaSalle's regulatory performa,nce.
Edison's program will work as follows to address the five concerns you identified:
1.
ADEOUACY OF MANAGEMENT. MANAGEMENT STRUCTURES AND MANAGEMENT PRACTICES Both senior and operating management at LaSalle have substantial experience with operating nuclear power plants.
See Table 1.
However, to further strengthen the management team, Edison has made some changes in personnel.
At the station level, in March of 1985, new positions were added which included a Production Superintendent and a Services Superintendent to assist the Station Manager with day-to-day activities; an Assistant Superintendent for Technical Services to better coordinate support from off-site departments and the management of the interfaces with various regulatory agencies; and an Assistant Fire Marshall responsible for housekeeping.
The Production Superintendent position is especially noteworthy because both Operations and Maintenance personnel report to him, which permits him to better control plant activities.
At the corporate level in September, 1985, the position of Manager of Production, Nuclear Stations Division, was replaced by two new Division Vice Presidents--one for the older plants (Dresden, Quad Cities and Zion) and one for the newer Plants (LaSalle, Byron and Braidwood).
These positions were created in recognition of the complexity of the newcr stations and the substantial increase in the number of Technical Specification requirements for them, and to provide additional corporate attention to and support for the stations.
Ken Graesser, the new Division Vice President for LaSalle, was one of our most effective Plant Managers, and brings leadership and many proven management systems to the position to help improve LaSalle's performance.
Edison and Station Management have also responded to some of the problems identified by the NRC's review of LaSalle Station.
1 e
-, In October, 1985, changes were made at the Department Head level in the Mechanical Maintenance and Instrument Maintenance areas: new masters were appointed in both departments.
Both of the new masters are qualified to sit for a Senior Reactor Operator's license.
Thus, they bring a level of experience, that, at this point in LaSalle's operation is important to increase the sensitivity and recognition of the complexity of the station.
The new masters will provide new leadership by proposing new management systems: (1) to reduce the backlog of work requests; (2) to implement trending systems to identify potential maintenance problems; and (3) to implement corrective measures for the identified problems.
Another change in personnel at LaSalle was the addition of an on-site representative from the corporate Station Nuclear Engineering Department (SNED).
We believe that this person can help with the planning and coordination of modifications and repairs and will more quickly involve Engineering and the Architect Engineers.
The presence of this person on-site is expected to result in the improvement of quality and content of modification design packages.
Finally, by working with the station we will implement a feedback program which will utilize lessons learned from deficient modifications to improve the products by the Engineering Department and the Architect Engineers.
Changes have also been made in the Radiation Chemistry Department as a result of inspections by the NRC and reviews by the station and our Corporate Health Physics group.
A new Radiation Chemistry Supervisor was appointed in early October.
To fill that person's existing position, a new Health Physicist, who was formerly attached to the Corporate Health Physics group, was appointed as a lead Health Physicist.
Also appointed was an Assistant to the Radiation Chemistry Supervisor and a Radiation Contamination Control Supervisor.
The Assistant to the Radiation Chemistry Supervisor has a Senior Reactor Operator's license and has had operating experience.
Prior to that, he had been a Radiation Chemistry Technician at another of our facilities.
We believe that his background will enable him to promote an atmosphere of increased sensitivity to problems in the Radiation Chemistry area.
The other changes will help us to increase in-plant supervision and to correct some of the problems that have been found in the plant on tours.
These changes will also allow Radiation Protection Supervisors to work with people in the plant to avoid errors.
Early in 1985, Edison established a task force to recommend improvements in work planning at all of its nuclear plants.
LaSalle has been selected as the pilot station for implementing the tank force recommendations.
Accordingly, a new position of Assistant Superintendent for Work Planning was established.
He reports to the Production Superintendent.
The person appointed has ten years of experience at LaSalle Station and formerly held a Senior Reactor
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Additional people were also appointed to the work planning group; three of them'have Eenior Reactor Operator licenses at LaSalle Station.
This group will increase the coordination work in a very complex station and place increased emphasis on work requests that
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potentially could affect day-to-day operations.
1
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Several new management practices also have or are being i
instituted to deal with specific issues.
These include: (1) the integration of control room work requests which require 4
j interdepartmental interfaces into the daily schedule and the establishment of a weekly quota for completing control room work
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requests, (2) the assignment of an expediter of work requests, (3) the formalization of the use of the degraded equipment log, (4) formally monitoring the backlog of procedural changes, (5) implementation of.a feedback program for lessons learned from deficient modification packages, and (6) increased communications i
between the Radiation Chemistry and other departments.
Other, more general management practices include the i
development of a performance tracking system to monitor the adequacy of work planning, the computerization of planning programs, and increased interactions with NRC personnel.
The general and specific management changes enumerated above and in the Management Plan are expected to significantly 4
improve regulatory performance at LaSalle.
In addition, a further j
review of the station's organization will be completed in the Spring of 1986.
f I
i j
2.
ADEOUACY OF MAINTENANCE AND MODIFICATION PROGRAMS l
Edison has previously described, in Attachment 2, some of j
the changes it has instituted to improve the LaSalle maintenance and modification program.
These changes include elements of the design 3
control program dorcribed in the Management Plan.
In addition, the Management Plan includes an eleven point 5-Year Modification Plan
~
i for ensuring the timely completion of modifications in accordance i
with their safety significance.
This program should also improve coordination with SNED.
The details of this plan are described in J
i l
The Management Plan also describes a program which is expected to reduce the backlog of work requests, ensure that requests with the greatest safety impact are done first and prevent repetitive equipment; problems.
The detailsLof the program are also discussed in Attachment 3.'
A recent NRC review of modifications completed during the LaSalle Unit 2 outage has already noted the positive effects of some of the improvements described herein.
3.
ADEOUACY OF CONTROL OF WORK ACTIVITIES We understand that this item refers in part to work activities which have led to SCRAMS or ESF actuations.
Section G.6 of the attached response to your report (" Response") describes the station's improving record in this area.
As for other work activities, such as the control of lifted leads and jumpers, the taking of chemistry samples, control of locked valves, control over high radiation areas and personnel errors, Sections A, D, E and F of the attached response describe the station's improving record in these areas.
Moreover, the Management Plan includes additional actions which are expected to further improve station performance in these areas.
The details of implementing these actions are also included in the Management Plan.
4.
ADEOUACY OF THE IMPLEMENTATION OF THE REGULATORY IMPROVEMENT PLAN Edison believes that the Regulatory Performance Improvement Plan
(" Improvement Plan") instituted in February, 1984 already has improved performance at LaSalle even though that improved performance was not as great as had been anticipated.
and the attached graphs to this letter show that significant improvements have already been achieved in those areas identified by your Task Force Review.
In particular, implementation of the Improvement Plan has resulted in:
(1) more aggressive resolution of equipment problems; (2) more effective planning and control of site activities; and (3) reduction in the frequency of personnel errors
,- 5.
ADEOUACY OF THE RESOURCES COMMITTED TO LASALLE Our 1986 and 1987 budgets for personnel, expenses, and investments for operations, maintenance and modifications have been reviewed in a systematic manner.
The preliminary budgets were established by department hoads at LaSalle and General Office Nuclear Support Departments.
The budgets were further reviewed by the Station Manager and Executive Management.
We have provided adequate resources to ensure the safety of our plants and to make the additional improvembnts outlined in our Management Plan.
We will monitor our performance objectives as outlined to see that we are meeting our program dates.
If during this review, we find that ar itional resources are needed, neceseary action will be taken.
6.
PLANS FOR LASALLE COUNTY UNIT 1 STARTUP AFTER REFUELING In light of concerns about the total station work load, we have evaluated the existing backlog of Work Requests, Work Requests affecting Control Room indications and annunicato s, Station Modifications, and Procedure Revisions.
We have paid particular attention in our evaluation to those categories that could affect the safe return of LaSalle Unit 1 to service following the current refueling outage.
As requested by your letter, the following paragraphs describe measurable criteria which we presently believe should give Edison and the NRC assurance that LaSalle Unit 1 can be safely returned to service.
While the criteria below now seem reasonable, additional reviews during the next few months may reveal that changes should be made to them.
Any substantive changas will be reviewed with your inspectors for acceptability.
Work Requests The existing LaSalle total station backlog of Work Requests numbers approximately 2300, excluding modifications.
The significance of these Work Requests varies widely, ranging from replacing Safety Relief Valves to repairing leaking drinking fountains.
The total backlog number fluctuates significantly and can be misleading, since it is influenced strongly by the accumulation of refueling outage work requests that are prepared well in advance of the outage.
Work requests in this category can number between 600 and 800, e
.-.--~~
- We have concluded, based on our review of the total backlog at our Zion, Dresden, and Quad Cities Stations, that an average of 1400-1500 non-outage work requests outstanding is nominally acceptable.
Our goal at LaSalle, however, is to maintain a backlog of only 1400 total non-outage-related Work Requests.
This goal will be achieved prior to the LaSalle Unit 2 fall refuellos outage.
We will monitor our progress toward this goal monthly and review it with Region III NRC inspectors during periodic meetings.
If our progress toward the goal appears insufficient over a two month interval, we will take appropriate action, such as authorized overtime or assigning additional contract personnel to the work, as appropriate.
However, as specifically applicable to the LaSalle Unit i refueling outage startup, we have determined that presently only 700 Work Requests applicable to Unit 1 are either safety-related, ASME code-related, or considered reliability-related in accordance with our QA program.
Out of that number of 700 important Work Requests, we will assure there will remain less than 300 outstanding in these categories prior to Unit 1 restart, the majority of which are typified as " repair and return to Storeroom", weld repairs on non-safety-related systems, and other work having no impact on safe plant operation.
This reduction of more than 57% in these important categories of Unit 1 Work Requests should provide ample assurance that LaSalle Unit 1 can be safely returned to service.
Outstanding important Unit 1 Work Requests will be reviewed before start-up as described later.
Control Room Ascociated Work Requests For outstanding Control Room associated Work Requests, page 11 of the Management Plan reflects our commitment of a backlog of less than 20 prior to Unit 1 startup.
As we have discussed with your inspectors, we will achieve the "blackpanel" goal of having no routinely lighted annunciator alarms on LaSalle Unit 1 within one month of reaching full power operations following the completion of the refueling outage.
a '
Additionally, we have established a station practice of beginning work on any valid Control Room associated Work Request by the next working day.
This assigns a high priority to these Work Requests, and promotes their timely completion.
For those outstanding Unit 1 Control Room associated Work Requests, we have established the goal that there will be none relating to indicators or alarms used as the primary indication of a significant abnormal degradation of the reactor coolant system pressure boundary, the primary indication of any process variable used as an initial condition in a Design Basis Accident analysis, or the primary indication of the availability of an ECCS system.
This limitation provides appropriate assurance that LaSalle Unit 1 can be safely restarted.
The outstanding Control Room associated Work Requests for Unit 1 will be reviewed as described below prior to startup.
Modifications There are presently 333 modifications outstanding (excluding modifications that are physically installed but which have some paperwork details outstanding and modifications expected to be cancelled).
82 of these are scheduled for completion during the current Unit I refueling outage.
51 are scheduled for the 1st refueling outage for Unit 2 in the fall of 1986.
The remaining 200 modifications have been categorized and prioritized and a schedule for their completion is being developed in accordance with the Fivs Year Modification Plan under development as described on pace 17 of the Management Plan.
Only 22 of the 200 modifications are considered to have a high priority, and all 22 are expected to be completed in 1986.
We expect the Five Year Plan to significantly improve the manageability of our modification program, especially in conjunction with the creation of the new station Work Planning Group, and to i
provide for the timely completion of design changes consistent with their importance to safe and efficient plant operation.
The schedule being developed is based on their relative importance and the availability of resources.
Since the large majority of this category of modifications are medium or low priority, a great deal of flexibility is available in their schedule.
Our preliminary determination is that none of the outstanding work will impact Unit 1 operations, but an additional review will be made as described below prior to Unit restart.
Procedure Chances As of January 24, 1986, the number of outstanding procedure changes has been reduced to 684.
Total outstanding procedure changes at Unit 1 startup will be reduced to less than 450, of which none will be in the priority one class described below.
In accordance with LaSa11e's new procedure tracking program, each procedure revision is assigned a due date for completion based on a priority system as follows:
1.
-Procedure revisions associated with Modifications that affect operations are completed prior to declaring the equipment operational (approximately 24 of the current total).
2.
Procedure revisions associated with Modifications that do not affect operations are scheduled for completion within 30 days of Modification completion (approximately 150 of the current total).
3.
Procedure revisions associated with commitments are assigned due dates commensurate with the applicable commitment (approximately 32 of the current total).
4.
Other procedure revisions are scheduled for completion within 3 months.
Typically, these changes consist of typographical errors and clarifications.
Each procedure revision is reviewed by an experienced SRO and may be assigned a shorter completion date based on its importance
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to plant operation.
We are confident that this priority scheme as well as our recently developed tracking and followup program will ensure that procedure revisions are completed in a timely fashion and will not impact plant operation.
The pre-startup on-site review will include a review of outstanding procedure changes to ensure that those required for safe l
plant operation have been completed.
f
e e We will conduct an On-Site Review prior to returning the unit to operation which will review the status of all of the programs at that time and our progress towards the above criteria to determine if any additional special reviews need to be performed prior to startup.
As is our normal practice at our other. stations, this On-Site Review prior to startup will specifically provide assurance that unit startup can proceed safely by a:
1.
Review of outstanding work requests to identify the ones having safety impacta and the completion of those requests.
2.
Review of outstanding procedure r evi;il o ns, especially those resulting from modifications and Tech Spec changes implemented in support of the Unit 1 refueling outage, prior to startup to ensure that required procedure revisions have been completed.
3.
Review of outstanding modifications for safety impact prior to Unit 1 startup.
We believe that the measures and actions described in this letter and its attachments demonstrate Edison's continuing commitment to the operational safety of LaSalle County Station.
The periodic meetings which we plan to have with your staff to review our progress in meeting the goals and milestones in the Management Plan provide the NRC and Edison the opportunity to agree to any mid-term corrections to these programs that may be required.
To the best of my knowledge and belief the statements contained herein are true and correct.
In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Very truly yours, Cordell Reed Vice President SUBSCR BED and "
RN to befor rJe this_.l day (> '
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.- CROSS REFERENCE BETWEEN LASALLE 10CFR 50.54f LETTER AND CECO MANAG9 TENT PLAN SECTIONS Cross-Reference to NRC Concern CECO Management Plan (1) Adequacy of Management Scheduling / Planning Section Radiation Protection Performance Section Management Structures Scheduling / Planning Section Organization Section Management Practices Scram Reduction Section ESF Actuation Section Scheduling / Planning Section Work Request Backlog Section Time Clock / DEL Section (2) Adequacy of Maintenance Scheduling / Planning Section and Modification Control Room Information Deficiencies Section Program Work Request Backlog Section Time Clock / DEL Section Modification Section Design Control Section (3) Adequacy of Control of Scram Reduction Section Work Activities ESF Actuation Section Scheduling / Planning Section Design Control Section 4
Personnel Performance Section (Additional information in Attachment 1 to letter, Section G.6)
(4) Adequacy of Regulatory The whole Plan, specifically Personnel Improvement Plan Performance and Rad Protection Performance Sections (5) Adequacy of Resources Addresset in letter only i
1 i
i N.
/.
-s TABLE 1 IABAIJE STATION MANAGE 3ENT IIPERIRNCE IRVEL IN TEARS Cup 0EllCIAL MILITARY TUFAL LICENSE JOB TITIR NADE NUCIEAR NUCIEAR Uf1tER EIPERIENCE HEIR 2%
0 24 IBRODresden1-2-3)
Station Mgr BRO IaBalle Services Supt 16 0
0 16
( B0 Dresden 2-3)
Production Supt 20 0
0 20 (Ello Dresden 1-2-3) 8HO IaBelle i
Asst Sept Tech Servlees 9.5 0
2 n.5-SRO I
Asst Supt Operating 10 10 0
20 BRO Asst Supt Maintenance T
0 8
- 15. "
3 Security Administrator 8
0 23 31 Operating Eng 8
6 18 8R0 Operating Eng 10 6
0 16 8110 Operating Eng 16 0
16 32 BRD Master IM
. 9.5 0
2 11.5
( 880)
~
Master EM
- 10 0
12 22 i
's Master M 9
0 0
9 BRO Red Chen Superviser T
0 0
7 Tech Staff Supervisor l
10 0
2 12 BRD l
r i
t b-
I
/
TABLE 1 (Con't)
IASAIJE STATICE DIANAGENINT EIPE:tIENCE 1ETEL IN YEAIER l
(G)RTINtNED) 1 C0ftetRCIAL MILITARY TOTAT.
LICElt8E JOB TITf2 NADEC NUCIEAR NUCLEAR OFNER EXPERIENCE HEID Training Supervisor 8
8 0
16 BRO i
Personnel Admin 2
0 15 17
- Financial Coord 3
0 M
d i
^
0 9
17 Offlee Supervisor 8
QC Supervisor 9
6 0
15 I
Storeroom Supervisor 2
0 6
8' o
6 9
I O
O 9
0 e
O
F ATTACHMENT 1 Response to the Final Report on the Task Force Review of Operational History for LaSalle County Station Units 1 and 2 A cross-reference between portions of this response and relevant sections of our Management Plan is provided by superscripts in the following text and the cross-reference listing on Page 11 of this Attachment.
f 4
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A.1 Fire Prvtection A review of fire protection Deviation Reports (DVRs) and Licensee Event Reports (LERs) shows substantial improvement in all areas over the past five years.
The attached graphs show that both personnel errors and DVRs/LERs involving equipment failures have decreased dramatically.
See Graphs 1 and 2.
However, to ensure continuing improvement and to provide added assutance that fire protection requirements will be met, LaSalle initiated in early 1984 an extensive fire protection review program which includes significant corporate support.
Under this program, LaSalle has either conducted or has had conducted several major studies and reviews to ensure compliance with the fire protection requirements in the Technical Specifications.
In addition, Edison has budgeted three and one-half million dollars for fire protection improvements at LaSalle over the next three years.
At the corporate level, support is provided through ensuring the availability of adequate technical services and inter-station coordination.
A.2 Vent Stack Monitor The station has and continues actively to pursue solutions to problems with the vent stack monitors.
For example, heat tracing installed in January 1984 has resulted in the successful prevention of sample line freezing.
Other actions initiated by the station to improve monitor performance include:
1.
completion of two modifications to deal with electrical noise problems; 2.
completion of two modifications regarding detector damage:
3.
completion of one modification regarding pump damage; 4.
improvements in operability by changing procedures and setpoints:
5.
changes to Technical Specifications..nd 6.
purchase of a $40,000 back-up system These actions have already led to the significant reduction in failures shown in Graph 3 and are expected to continue that improvement.
A solution to the problem of spuricus spiking by these monitors is also being actively pursued with the vendor as well as other utilities having similar design.
Additional actions include replacement of the power supply for the high and mid range detectors in conjunction with the periodic calibration scheduled for February, 1986.
At that time an outstanding modification to improve noise suppression will also be completed.
A.3 Ammonia / Chlorine Detectorsl One aspect of control room habitability is the ability to seal off the control room ventilation system from external sources of ammonia and chlorine.
To implement this protective action, the station has installed ammonia and chlorine detectors in the control room ventilation system.
Because the detectors have not functioned as expected, the station has taken significant actions starting in the summer, 1985, to deal with the problem in the interim while actively pursuing several options for correcting the situation permanently.
In the interim, the station undcrtakes full preventive maintenance every six days instead of monthly as required by the Technical Specifications.
Also, the station has posted warnings about radio frequency interference with the chlorine detectors.
The longer term actions included use of INPO's Nuclear Network for an industry-wide search for more reliable detectors and a consideration of design changes which would result in a logic that would increase system reliability and reduce the effects of spurious signals from these detectors.
In the alternative, the station is considering requesting a change-to the Tech Specs based on the circumstances that the nearest source of chlorine would be a barge on the 3111nois River, which is 4.8 miles downhill from the plant at its point of closest approach, only 0.2 miles clocer than the 5 miles limit beyond which no detectors would be required.
Submittal of the change is scheduled for early March, 1986.
A.4 Reactor Water Cleanup System 2 A review of Reactor Water Cleanup System isolations shows a marked decrease in reportable events in 1985 as compared with 1984, 5 versus 47.
See Graph 4.
As you noted, some of this improvement resulted from system changes which reduced the problem.
- Moreover, the station is actively reviewing the calibration of the reactor clean up system's differential flow instrumentation to determine whether that calibration can be changed to better compensate for density changes during reactor startup.
Furthermore, the problem of spurious isolations caused by leaks in the Reactor Water Cleanup Demineralizer Inlet and Gutlet Valves will be eliminated by repairing them with spare parts from a recently identified supplier.
The station believes that these steps should result in continued improvements in this area.
A.5 Residual Heat Removal Service Water Pumps The station has been having problems with residual heat removal service water pumps and motors and is having similar problems with diesel generator cooling pump motors in the same general area in the plant.
The cause of the motor failure has been N!eIk$own du0 k$ a$$a0$oNUSndf 0r h$e$kE!k"Skta0k3 bEkeb"moESEd8kn "
the area subject to similar failure have been or will be rewound.
This work is expected to be completed by December, 1986.
_ A.6 RHR Shutdown Coolina Isolation Valve On occasion, the RHR shutdown cooling isolation valve has failed to open.
Edison has expended considerable resources since August, 1983, in trying to determine the cause of this failure.
In October, 1984, a consulting firm (MOVATS) diagnosed the valve and motor operators and found that no equipment limitations were being exceeded.
SNED and the architect-engineer, Sargent and Lundy, have assisted the station's investigation of causes of valve inoperability.
The station's technical staff will evaluate the need for additional help when the valve is disassembled during the current LaSalle Unit 1 outage.
This problem has not yet been resolved completely, in part because the valve is operated so seldomly.
However, the station has instituted procedures which have resulted in the valve's consistent successful' operation.
There have been no failures since February 1985 in approximately 4 operations.
B.
Electrical Jumoer and Lifted Lead Controls LaSalle's design requires the use of jumpers and lifted leads to perform routine surveillance of electrical instrumentation and equipment.
Over 1,000 jumpers and lifted leads are used monthly in the course of performing surveillances required by the Technical Specifications.
Of the thousands of jumpers and lifted leads used yearly, approximately seven jumpers or lifted lead tage were lost in 1985.
Also, problems with lost jumpers and lifted lead tags resulted in two DVRs for each of the years 1984 and 1985.
As you noted in your report, the number of DVRs in this areas has been decreasing.
See Graph 5.
We believe that this improvement in performance has been due in significant part to the procedures which the station already has implemented to better control jumpers and lifted leads and to improved personnel performance.
These changes in procedures include:
1.
Nine revisions, the last in October, 1985, to the administrative procedure for Temporary System Changes to require more information in the log book for jumpers and lifted leads and to incorporate lessons learned on an ongoing basis.
LAP 240-6 2.
Implementation in August, 1984, of a procedure for the documentation of the independent verification of the proper use of lifted leads and jumpers in troubleshooting.
LIP GM 938.
3.
Modification in the Spring, 1985, of the maintenance department's troubleshooting worksheet to provide for documentation of the independent verification of the use of leads and jumpers.
LAP 1300-1 4.
Purchase of new jumpers having different colors so that the presence of old jumpers can be identified readily and trigger an investigation as to whether those jumpers were properly controlled.
This was accomplished in the Fall, 1984.
The station believes that the procedures in place have
' improved LaSalle's control over jumpers and lifted lead tags.
C.
Modification / Installation Programs LaSall'e has had problems with modifications to the plant.
The station has recognized these problems and has taken extensive actions to prevent their recurrence.
For example, the short and long term corrective actions in response to items C.1 and C.3 of your Task Force Report are described in detail in the attached copy of Reference (c).
Appropriate corrective actions also have been initiated in response to the other specific events in items C.2 and C.4 through C.7.
Moreover, it should be noted that some of these items received accelerated, intensive attention because they were picked up by the potentially significant event system established by our Regulatory Performance Improvement Plan.
As part of the LaSalle County Management Plan, LaSalle has initiated an eleven point, 5 year modification plan 3 and a twelve point design control plan 4 Five of the actions in the modification plan either have been completed or are ongoing, with three items completed on or before schedule.
Tnese actions include the establishment of a modification review committee, the development of a scheme for categorizing modifications and assigning priorities to them, the development of a new mechanism for handling new modification requests and the holding of all responsible organizations accountable for completing activities on time.
Ongoing activities include the categorization of modifications, the assignment of prioritics to them and a review of their impact on the startup of' Unit 1.
Eight of the activities in the design control program have been completed.
These include the assignment of a " cognizant" engineer to each modification to assure accountability for its successful completion, reports to the Station Manager on audits by site QA and Station QC on implementation of the environmental qualification program and the establishment of a committee to review all safety-related post-modification tests.
Ongoing activities include changes in the method of handling Drawing Change Requests (DCRs) to ensure their timely and correct completion.
In addition, Edison is revising the Quality program to include inspection for conformance to design documentation for future safety-related modifications.
This program will ensure that critical components in their as-built configuration meet tolerances in the design documents.
As for the particulars of the actions during the Unit i refueling outage, station emphasis understandably has been placed on meeting its commitments to the NRC.
Other safety-related and reliability-related modifications which could impact safety will be completed during the refueling outage.
Of the 89 modifications currently schet!!ed before startup, 57 respond to NRC commitments.
The remaining 32 were identified after careful review of the relative importance of outstanding modifications.
Moreover, prior
'to startup, outstanding modifications will be reviewed again for safety significance for restart 5 Therefore, Edison believes that the deferral of remaining modifications will not adversely impact the rollability of safety equipment during the period that the plant will operate until the remaining modifications are completed.,
D.
Radiation Chemistry Samples The station is required to devote substantial resources to the daily taking of chemistry samples.
Sixteen person hours are used daily to take approximately 90 daily samples.
Routine sampling has not, in general, been a problem.
Rather, missed.or late samples are usually associated with instrument failure or other unusual events which trigger non-routine sampling periods.
While there have been some failures to take such chemical samples on time, the number has been decreasing.
See Graph 6.
Station performance in this area has improved as the result of better communications between plant operators, plant management and the radiation chemistry department regarding the observance of non-routine sampling periods.
These improvements in communication are enumerated in Item J of the Radiation Protection Performance section of the Management Plan 6 The improvements include daily interface with the Operating Shift Supervisor'and periodic meetings with various department heads.
In addition, LaSalle will conduct the activities enumerated in Item D of the Personnel Performance section of the Management Plan 7 Missed radiation chemistry surveillances will be analyzed for root causes and, once those causes are identified, corrective actions will be instituted.
The station believes that the procedures in place or under development will continue to improve LaSalle's record for the timely taking of chemical samples.
E.
Improperly Locked Valves On occasion a valve is improperly locked.
As noted, these are isolated events with no common cause.
This circumstance makes a corrective action program difficult to formulate.
However, Graph 7 shows that the number of DVRs attributable to such occurrences has decreased dramatically since 1983 due to the following actions.
1.
All locks were changed on valves to improve control over keys.
]
- 2.
The administrative procedure for controlling changes in the positions of locked valves was revised to increase control over those valves.
LOS-LV-SRI.
3.
Break away locks were replaced with non-breakable locks for all valves other than fire protection valves.
4.
The locked valve checklist was reviewed to eliminate unneeded valves.
We believe that these actions will continue to reduce the number of DVRs issued for improperly unlocked valves.
P.
Doors in High Radiation Areas The station has undertaken a vigorous program to ensure that doors are closed when they should be.
Of the fifteen actions enumerated in Item G of the Radiation Protection Performance section of the Management Plan,8 ten have already been completed.
These actions included additional training, a new surveillance procedure, assignment of responsibility for ensuring prompt repairs to doors in high radiation areas, the attachment of security guidelines to key cards and the development of a preventive maintenance program for doors in high radiation areas.
Other actions still underway include the consideration of installing local alarms on some doors, disciplinary action when appropriate, implementation of additional restrictions on key cards and the provision of pocket-sized folders designed to increase awareness of radiation protection requirements.
In addition, open doors are included in the Procedural Compliance actions listed in Item A of the Radiation Protection Performance Section of the Management Plan.9 Finally, the stat 16n has submitted a proposed change to its Technical Specifications 10 which would eliminate about half of the high-radiation doors by adopting the recently approved Standardized Technical Specification guidance for defining high-radiation areas.
Edison believes that these completed and ongoing actions will effectively control doors in high radiation areas.
G.1 Control Room Work Requests The station has undertaken several steps to deal with control room work requests.
Their priority has been increased by daily reviews by the shift engineer.
A significant contributor to these work requests, chronic alarmed annunciators, has been the subject of a concerted corrective effort.
This effort has been successful in reducing the number of repeat occurrences for specific pieces of equipment.
._ In addition to these steps, the problem has been addressed in the Management Plan under the items Work Request Backlogll and Control Room Information Deficiencies 12 Those items detail a plan for accurately assessing the actual backlog in work requests, for expediting the processing of work roquests and for reducing the backlog to an optimum level.
Graph 8 presents the station's commitment for reducing the number of work requests.
That Graph shows that current actions have already begun to decrease the number of outstanding work requests at the targeted rate.
For the long term, a Permanent Fix Program 13 will be initiated for repetitive equipment problems.
These actions should bring the work request backlog under control and prevent its becoming an issue again.
G.2 Time Clocks / Degraded Equipment Loq LaSalle has been operating with several time clocks running on Limiting Conditions for Operation due to abnormal conditions allowed by the Technical Specifications.
Although such operation is clearly permitted under LaSalle's license, Edison shares the Region's concern with this situation.
Accordingly, the Management Plan includes a seven point program to reduce both the number of LCO time clocks running during plant operation and any abnormal conditionsl4 The station has already implemented a priority system for LCO time-clock-related work requests.
Edison believes that once this program has been implemented fully this issue will be resolved.
The Management Plan also includes a six point program for reducing the number of items on the degraded equipment log and for formalizing its use15 This formalization of the log should addreas the concerns identified.
As for the log availability to the Shift Engineer and status boards, they are not required because all relevant information is now provided on shift turnover sheets.
The log is principally for the use of the Shift Control Room Engineer (SCRE).
The SCRE is the Control Room SRO/STA who is responsible for control room operations.
G.3 SCRAM /ESF Actuations An extensive SCRAM reduction program is described in the Management Plan 16 Several items on that program have been completed.
These include the establishment of a SCRAM reduction committee, a historical review of SCRAMS and a determination of their root causes and a review of the conduct of station operations.
Graph 9 shows a significant reduction in the number of SCRAMS as a function of time.
Moreoever, two of the significant causes of SCRAMS have been identifiedl7 For these two causes of scrams, alternative methods of implementing the same functions also have been identified.
, The Management Plan includes an extensive program for reducing ESF actuations18 A task. force has been formed, it has reviewed all actuations since January 1, 1984 to identify problem areas, and a tracking and trending system has been implemented.
This information is used to identify root causes of excessive ESP actuations and to recommend corrective actions to prevent their recurrence.
So far, three sources of repetitive false actuations have been identified; two are being evaluated, the third one will be acted on.
Graph 10 shows that the number of actuations has decreased significantly in 1985.
Implementation of this program should further reduce the number of ESF actuations to an acceptable level.
G.4 Outstandino Procedure Changes Of the 1260 outstanding procedure change requests in process, a review shows that approximately 70% are minor items such as the correction of typographical errors and changes in format.
Efforts to reduce the number of outstanding change requests are significantly ahead of schedule.
By early December, the number was reduced to 943, an approximately 25% reduction.
See Graph 11.
Moreover, none of the DVRs written in 198a for defective procedures implicated the number of open procedure changes as a problem.
However, as indicated in the Management Plan 19, the station is revising its program for controlling changes in procedures, These revisions include:
1.
The collection of minor changes in a biennial review of procedures.
2.
The provision of a schedule for completing each change once it is initiated.
3.
The procedure manager's use of a computer to track changes to a procedure.
I These changes should further improve the station's timely completion of procedure changes.
G.5 Personnel Errors / Missed Surveillances The number of personnel errors reported by the station is based on its assessment of the cause of an event.
Every effort is made to determine accurately the root cause of an event and to characterize properly any contributing factors.
To further ensure that DVRs/LERs are properly characterized as to cause codes, an Edison off-site review group is independently reviewing the station's assignment of causation codes 20 An NRC letter to Edison dated December 2, 1985 transmitted a copy of the Office for Analysis and Evaluation of Operational Data (AEOD) assessment of LaSalle LERs.
That report stated that the quality of LaSalle LERs l
was above average when compared to other facilities that have been evaluated using the same methodology.
Moreover, Graph 12 shows that the number of personnel errors is goinq down, Finally the ManagementPggnincludesadditional effort on improving, personnel performance.
=.
- As for missed surveillances, Graph 13 shows a significant j
decrease in missed surveillances.
Here, again, the station is sensitive to the need to conduct surveillances in a timely manner i
and believes that its improving record in this area demonstrates that sensitivity.
l G.6 Control Over Work Activities on Site We understand that this item refers to work activities which led to SCRAMS or ESF actuations.
Actions have been taken which have dramatically improved this situation.
See Graphs 9 and 10.
These include: the establishment of a daily work schedule 22 i
which is distributed to cognizant station personnel; the conduct of a daily station meeting to plan and discuss the day's activities, advance scheduling of work and support requirements and limitations i
on the work which can be performed at any time on reactor protection 4
i systems.
In addition, the effects of work activities are included I
in the general programs for sensitizing supervisors and managers to the need for close attention to detail.
These activities are i
expected to continue to reduce the number of SCRAMS or ESF actuations due to work activities.
V.1-7 Perceptions i
Edison is concerned that the significant improvements already realized and demonstrated by the attached graphs have not been fully considered in deriving your perceptions and conclusions regarding plant performance.
Edison hopes that the information provided here will lead you to re-evaluate your perceptions and conclusions to reflect this substantial progress.
V.8 Technical Specification Edison agrees that'the LaSalle technical specifications are in need of review and simplification.
The importance of the key information contained in them is diluted by their large volume of less important requirements.
Some of the requirements may be actually adverse to safety, while others are simply ambiguous.
Furthermore, complete and meaningful bases do not exist for.most of the LaSalle technical specifications A jointly funded program by Edison and the Electric Power Research Institute to study the application of probabilistic techniques to the identification and justification of technical specification changes, began in June, i
1985, has identified numerous potential problems with the existing specification.
4
,, _. _. - -. -, -. _ _, -. _ _ -. _. - _ _ _ _ _ ~, _ -. _ _ _, _.. - _. _,. _.,
1
! Improvements in both safety and resource requirements can be realized through a focused effort to correct human factor and other technical weaknesses in the technical specifications.
A program has been undertaken by both the nuclear industry and NRC to improve technical specifications.
Criteria for objectively. defining the scope of the technical specifications have been developed and applied successfully, on a trial basis.
Each of the Owners Groups, the Atomic Industrial Forum, and the NRC have major efforts in progress to improve the glaring human factor deficiencies in the Standardized Technical Specifications.
An industry standard writer's guide for technical specifications is being prepared as a revision to the existing ANSI /ANS 58.4 standard.
This standard will incorporate the new selection criteria for technical specifications as well as guidance on the style and format for writing them.
When these efforts are completed, Edison expects to propose major revisions to the LaSalle County technical specifications based on them.
j CROSS-REFERENCE BETWEEN CECO RESPONSE TO THE LASALLE OPERATIONAL HISTORY REVIEW TASK FORCE FINAL REPORT AND THE CECO MANAGEMENT PLAN Footnote CECO Management Plan Page Item 1
4 A.6 2
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4
Commonwealth Edison ATTACHMENT 2 f] F One F.est Notensi mars. Chicago. mino s v.
Accress Repry c: Post Ottca Box 767 Crucago. luvos 60690 November 26, 1985 Mr. James M. Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Comntission Washington, D.C.
20555
Subject:
. LaSalle County Station Units 1 and 2 Response to Notice of Violation and Proposed Imposition of Civi Penalty Inspection Report Nos. 50-373/85-023 and 50-374/85-018 (EA 85-95)
Reference:
J. G. Keppler letter to J. J. O'Connor cated Septenter 27, 1985.
Dear Mr. Taylor:
This is Comonwealth Edison Ccmpany's (Edison) response to the above referenced Nuclear Regulatory Conmission's (NRC) Notice of Violation, Proposed Imposition of Civil Penalties and acconpanying inspection report.
As we agreed, this response has been si.bmitted within 60 days of the Notica rather than within the 3C cays originally provided. We appreciate the ~
upportunity that this extension of time has given us to explain in detail Edison's comprehensive program for addressing the matters at issue here.
Becaust Edison does not protest the fine, this letter is accompanied by a check as payment in full of the $125,000.00 penalty.
E.11 son appreciates the significance of the deficiencies identified in the Notice. Our progra= to ensure the safe operation of our nuclear facilities depenas in part on ensuring the correct implementation of plant '
ecdificaticns. Edison acknowleoges that the events which gave rise to these deficiencies were unacceptable. To ensure that similar incicents will not I
recur, Edison has initiated the extensive corrective action eff===ed below for both the Station and the General Office.
The attachment to this letter describes the wide range of measures, both immediate and long term, which have been instituted by the i sulle County Nuclear Power Station and General Office management. The usnediate seasures: (1) ensured that the violations were corrected; (2) determined c
that no similar violations had gone undetected; and (3) instituted new procedures to prevent a recurrence of similar events. Among the significant
. longer term measures are the establishment of a committee which, for a trial perioc, will review post-modification tests for their ability to determine the operability of the modified equipment and the development of a checklist for helping to choose appropriate tests for modified equipment.
f 9
j_s L) va J y
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J. M. Taylor 2-November 26, 1985 These measures demonstrate Edison's continuing commitment to the operational safety of its nuclear stations. Edison believes that such safety will be ennanced by the corrective actions described in this letter and its attachment and, therefore, that the LaSalle County Nuclear Power Station will continue ta operate in a manner that fully ensures public health and safety.
Very truly yours, b-b b
Cordell Reed Vice-President im ss Attachment cc:
J. G. Keppler - Region III LaSalle Resident Inspector SUBSCRIEED A2 FwCRN to before me this M day OG}1.Mamlao, PB5
& ! ? G & l t < b c_.,
j Notary Puolic l
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ATTACHENT RESPONSE TO NOTICE OF VIOLATION 1A.
Technical Specification 3.3.3.b requires that with one or more Emergency Core Cooling System (ECCS) actuation instrumentation channels inoperable take the action required by Table 3.3.3.1.
Table 3.3.3.1 in Action 30 requires that when the nunter of operable channels is less than the required minimum of two, place the inoperable chamel in the tripped condition within one hour or declare the associated system inoperable.
Contrary to the above, from 3:30 a.m. on June 5,1985 until 12:10 s'
p.m. on June 10, 1985 when the nunter of operable chamels was less than the required minimum of two, the inoperable ECCS actuation instrumentation channel was not placed in the tripped condition within one hour and the associated system was not declared inoperable.
ADMISSION OR DENIAL OF T K ALLE E D VIOLATION Commonwealth Edison admits the violation.
REASON FOR T E VIOLATION This violation resulted from our reliance on post-modification tests which did not accurately determine the operability of the modified Division 1 Low Reactor Water Level kitches.
CORRECTIVE ACTION TAKEN AND RESULTS A'.HIEVED 1.
Initial Responses As soon as it was discovered that the instruments were inoperable, e
one of the switches was placed in the tripped condition as required by Action 30 of Table 3.3.3.1 of Technical Specification 3.3.3.b.
i l
Appropriate Station Persomel and General Office Management were also informed of the event. Shortly thereafter, the errors were corrected and an investigation was 149tiated into the causes of the j
events. The results of these investigations provided bases for aoditional actions intended to prevent recurrence of similar events.
i i
I
. 2.
Further Actions To ensure that no other problerns of this type had been missed, several broader actions were taken.
All safety-related modifications made during the Unit 2 outage were reviewed by either the Comonwealth Edison Station Nuclear Engineering Department (SED) or the architect-engineer. No serious discrepancies requiring further physical changes were discovered. Also, either SED, the station or the architect-engineer walked down all accessible safety-related modifications made during the Unit 2 outage. The architect-engineer also reviewed for congleteness the results of our walkdowns. As a result of these walkdowns, only minor discrepancies between the design documents and as-built configurations were disccvered. Only one,_a labeling deficiency, required correction in the field. For the others, we have corrected the appropriate docun.ents.
Moreover, a Quality Control Inspector independently walked down one hundred twenty-four of the instruments modified during the outage.
All of the test requirements specified in the safety-related work requests and modifications performed during the outage were reviewed completely. Also, it was verified, prior to restart, that all modified instruments would perform as designed.
3.
Training All departments involved conducted informal documented training sessions to discuss the event, its causes, and the corrective actions being taken to prevent its recurrence. This training was accomplished in two steps. First, prior to startup, appropriate personnel in the instrunent maintenance, electrical maintenance, and operating departments were trained. After startup, relevant personnel in construction, maintenance, technical staff, and quality control, as well as contractor personnel were also trained. At each of these sessions the significance of the events and their unacceptability were emphasized.
We believe that these training sessions have strengthened post-C modification testing procedures by increasing awareness of the need to ensure that testing secomplishes its intended function.
CORRECTIVE ACTION TAKEN TO AVOID FURTER VIOLATION l
1.
Revised Modification Procedures Our analysis of these events led us to change significantly the station's procedures governing the types of actions involved here.
These changes in procedure substantially strengthen the process for ensuring that post-modification tests are adequate.
. The Station's adninistrative procedere for plant modifications, LAP 1300-2, has been revised.as follows:
The procedure now explicitly requires the preparation of post-a.
modification tests in accordance with the newly established
" Guidelines for Development of Tests for Modifications" LTP 800-9. These guidelines provide methods for developing tests to ensure that system and conponent operability are adequately demonstrated after modification. Our confidence in these guidelines is based, in part, on the following new approach incorporated in them. Instead of focusing testing on only modified equipment, testing, where warranted, will now be extended to unmodified parts of a system. By varying input signals at those points in the system and observing the corresponding responses in the modified part of the system we will be better able to verify the operability of the modification. In particular, this procedJre would have helped to ensure the proper installation of instrument piping to pressure differential DP type instrumentation, b.
These incidents have also led us to realize the importance of developing in one person an attitude of responsibility for all aspects of a modification. Accordingly, the procedures now require the cognizant modification engineer to be more in.olved with the installation and testing of modifications. This greater involvement includes maintaining overall knowledge of a modification's design and status, assuring that design intent is implemented in the modification as installed and monitoring progress on the design, installation and testing of a modification.
2.
Checklists These incidents have also demonstrated the limited effectiveness of checklists used to determine system operability. Such checklists j
were developed after April,1985 in response to an incident involving inoperability of a train of the Standby Cas Treatment Systen. Although it was believed that such checklists would be adequate, there was only a limited period of time in which to assess the adequacy of those checklists before the June,1985 events occurred. Because experience has now shown that checklists limited to system inoperability are not always adequate, the maintenance and operating departments have developed additional checklists which go beyond previous lists by now requiring some testing at the cunponent level. This consideration of finer levels of detail should aid in the selection of testing requirements adequate to demonstrate operability after either maintenance or modification. Accordingly, it is believed that these new lists will help to prevent recurrence of these types of events.
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3.
Review Committee To further ensure the adequacy of tests of safety-related modifications, an additional level of review of post-modification tests for their ability to determine the operability of modified equipment has been established. This review will be conducted by a committee which will include the Technical Staff Supervisor, an Operating Engineer or an Assistant Superintendent, and the cognizant Modification Engineer. This committee will review the adequacy of any modified equipment before it is declared operable.
DATE WHEN FLLL COWLIAtCE WILL E ACHIEVED Full Compliance has been achieved. The effectiveness of the Review Comittee will be evaluated by March,1986 to determine whether the committee should become a permanent part of the post-modification review process.
18.
Technical Specification 3.5.2 requires at least two Emergency Core Cooling Systems (ECCS) to be operable in the shutdown condition.
With both of the required subsystems / systems inoperable, one subsystem must be restored to operable status within four hours or secondary containment integrity be established within the next eight hours.
Contrary to the above, with the three ECCS Divisions inoperable on Me 5,1985, secondary containment integrity was not established within eight hours.
f.DMISSION OR ENIAL OF TE ALLEED VIOLATION Comonwealth Edison admits the violation.
l REASON FOR THE VIOLATION Same as in Item 1A.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED j
l Secondary Containn. ant integrity had been reestablished before it was discovered that the Division I ECCS Systems were inoperable. No further corrective action was necessary.
I l
l I
- 2 CORRECTIVE ACTION TAKEN TO AVOID gjRTER VIOLATION Refer to Item 1A.
DATE WEN FtLL COWLIANCE WILL EE ACHIEVED Full Compliance has been achieved.
1C.
10 CFR Part 50, Appendix B, Criterion VI, as implemented by the Commonwealth Edison Company's Quality Assurance Manual, Quality Requirement 6.1, recuires that a document control system be used to
.o assure that documents such as drawings be distributed to and used at the locations where the prescribed activity is performed.
Contrary to the above, Field Change Request 85-123 dated April 4, 1985 was issued to correct an error in Modification H-1-2-84-136; however, it was not distributed to and used at the location where the prescribed activity was performed. As a result, piping for two switches was installed backwards rendering Division I of the Unit 2 Emergency Core Cooling Systems inoperable.
ADMISSION OR DENIAL OF TE ALLEED VIOLATION Commonwealth Edison adnits the violation.
EASON FOR TK VIOLATION This violation resulted from an inadequate document control procedure.
The Station's procedure for controlling Field Change Requests (FCR) did not require the FCR's to list contractor drawings. Therefore, FCR 85-123 did not list all of the drawings for revisions to the instal-l lation details for 22 instruments. Fcr 20 of those instruments, the l
Installation details had been revised on the contractor's drawings. For the remaining two instruments, the contractor's prockJction drawings reflected only the original designs because the drawings had not been modified in accordance with the FCR. The FCR had not indicated that those drawings would be affected.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The installation of the two instruments was corrected and tested to demonstrate the proper reinstallation. To ensure that similar problems had not been missed, all other FCR's generated during the outage were reviewed, and found not to contain any further errors.
. O CORRECTIVE ACTION TAKEN TO AVOID FURTE R VIOLATION To prevent a recurrence of this type of error, we have added mandatory cross-references to the Stations' procedures. Station Administrative Procedure LAP 1300-5 " Field Change Requests" has been revised to require an FCR to include a list of all affected docunents/ drawings, including contractor production drawings. In addition, both"the mechanical and the electrical contractors have prepared and inplemented procedures to formalize the control of FCR's and requirements for Quality Control field inspection. These procedures require checks to ensure that FCRs are properly posted to all affected drawings.
DATE WEN FULL COWLIANCE WILL BE ACHIEVED Full compliance has been achieved.
10.
10 CFR Part 50, Appendix B, Criterion X, as implemented by the Commonwealth Edison Company Quality Assurance Manual, Quality Requirement 10.1, requires that Quality Assurance inspections be conducted at the site during modification activities to verify conformance to applicable drawings.
Contrary to the above, Quality Assurance inspections were not conducted at the site during Modification M-1-2-84-136 to verify conformance to the applicable drawing (FCR 85-123).
ADMISSION OR DENIAL OF THE ALLEGED VIQ.ATION Commonwealth Edison admits the violation.
REASON FOR THE VIOLATION This violation resulted from a failure to specify adequate hold points c
in the instructions for installing modifications.
CORRECTIVE ACTION TAKEN APO RESULTS ACHIEVED All accessible elements of the modifications performed during the outage were completely walked down. To ensure an independent review, this walkoown was conducted by persons who had not been involved with the installations. Moreover, the results of these walkdowns were,docu1ented.
It was fot 1d that all final installations were in accord with the approved final designs.
~_
CORRECTIVE ACTION TAKEN TO AVOID FURTE R VIOLATION Station procedures have been substantially modified to ensure that inspections will be conducted during modification activities. LaSalle has developed and implemented an administrative procedure LAP 1700-3, "Guiuelines for Quality Control Hold Points". This procedure provides guidance to Station Quality Control and Contractor Quality Control personnel in establishing hold points. That guidance requires mandatory hold points for field inspections to verify that safety related modifications have been installed in accordance with approved drawings and specifications.
DATE WEN FIA.L COWLIANCE WILL BE ACHIEVED ss Full Compliance has been achieveo.
1E.
10 CFR Part 50, Appendix B, Criterion XI, as implemented by the Commonwealth Edison Company Quality Assurance Manual, Quality
' Requirement 11.1,, requires that the test program include those tests necessary to demonstrate that systems will perform satisfactorily in service following plant maintenance or modifications.
Contrary to the above, Operational Test LIS-f6-204 performed following the congletion of. Modification M-1-2-84-136 did not adequately demonstrate system operability in that the test only varified the instrument and electrical connections. The piping configuration of the reactor pressure vessel water level reference j
end variable legs was not verified.
ADMISSION OR DENIAL OF TFE ALLEGED VIOLATION Conmonwealth Edison acknits the violation.
T REASON FOR THE VIOLATION This violation resulted from an inadequate post modification test which was improperly limited to testing the instrument and its electrical
' ~ connections.
CORRECTIVE ACTION TAKEN Ato RESULTS ACHIEVED To ensure that similar problems in other equipment had not been l
l overlooked, all safety-related instrumentation modified during the I
outage was retested. The retests verified correct instrument response l
to varying process parameters. All installation errors identifico were corrected and retested to verify that the final "as installed" olant condition reflected the "as desicped" condition.
CORRECTIVE ACTION TAKEN TO AVOIO FURTER VIOLATION We believe that the new procedures discussed above in Item I.D will prevent a recurrence of this event. Those procedures, especially the new guidelines for identifying adequate post-modification tests and, in the interim, the committee review of those tests for adequacy, should ensure that all relevant parameters are tested and verified.
DATE WEN Ft1L COWLIAICE WILL BE ACHIEVED Full Compliance has been achieved.
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. 2A.
Technical Specification 3.3.2 requires the isolation actuation instrumentation channels shown in Table 3.3.2-1 to be operable with their trip setpoints set consistent with the values shown in Table 3.3.2-2.
The Residual Heat Removal (RHR) shutdown cooling pump suction high flow instrumentation is included for Operating Conditions 1, 2, and 3.
Technical Specification 3.3.2.c. requires that with the ntnber of operable channels less than the minimum operable channels per trip system required for both trip systems, place at least one trip system in the tripped condition witnin one hour and take the action required by Table 3.3.2-1.
Action Item 25 of Table 3.3.2-1 requires the isolation valves to be closed and locked for the Rm shutdown cooling mode and the system to be declared inoperable.
Contrary to the above, from April 7,1985 until 11y 12,1985, while the plant was in Operating Conditions 1, 2, and 3, the Unit 1 RHR shutdown cooling purrp suction high flow sensors would not have met the designated isolation setpoint in that the isolation actuation instrumentation channels were inoperable. With the channels inoperable, the actions required by Action Item 25 of Table 3.3.2.1 were not taken. The isolation valves were not closed and locked for the RHR shutdown cooling mode and the system was not declared inoperable.
ADMISSION OR DENIAL OF THE ALLEED VIOLATION Commonwealth Edison ac2 nits the violation.
l REASON FOR TE VIOLATION 1
l This violation resulted from our reliance on post-modification tests which did not accurately determine the operability of the R$ Shutdown l
Cooling High Flow isolation switches.
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CORRECTIVE ACTION TAKEN Af0 ESULTS ACHIEVED The discovery of the inoperable switches was made when the plant was in an Operational Condition which did not require those switches to be operable. Accordingly, no immediate action was required. Before entering an Operational Condition in which those switches were required to be operational, the piping errors were corrected, and it was verified that the switches could perform their isolation functiors.
CORRECTIVE ACTION TAKEN TO AVOID FlRTHER VIOLATION Refer to Item 1A.
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DATE MEN FtLL COWLIAPCE WILL BE ACHIEVED Full Compliance has been achieved.
28.
10 CFR Part 50, Appendix B, Criterion VI, as implemented by the Commonwealth Edison Company's Quality Assurance Manual, Quality Requirement 6.1, requires that a docm ent control system be used to assure that docments such as drawings, be distributed to and used at the locations whera the prescribed activity is performed.
Contrary to the above, Drawing Change Request 7383, issued to
,, s document a piping change to Modification M-1-1-82-054, was not distributed to and used in the development of Modification M-1-1-84-091. As a result, the Unit 1 Regenerative Heat Removal shutdown (RM ) pump cooling suction flow isolation channels were inoperable during power operations from April 7,1985 until the unit was shutdown on July 12, 1985.
ADMISSION OR DENIAL OF TE ALLEED VIOLATION Commonwealth Edison admits the violation.
REASON FOR TE VICLATION This violatiun resulted from the failure to ensure that changes to the plant were reflected on current plant drawings. The violation occurred as described below.
On May 10, 1982 it had been discovered that the original flow switches 1E31-PO12A and lE31-N0128 were piped backwards due to the High and Low Process Lines being reversed inside the Suppression Pool. Accordingly, WR #L15576 and modification #M-1-1-82-054 were issued to correct the piping and (in addition) install pressure snuboers. Snubbers were aoded and the repiping was performed by reversing the tubing locally at the c
instrument rack. Uoon satisfactory resolution of M-1-1-82-05A, Drawing Change Request #73-83 was submitted to reflect: (1) The inclusion of pressure snubbers, and (2) the changes to the process line, root valve, and Excess Flow Check Valve numbers associated with IE31-PO12A and B (with the Drywell Penetration Numbers remaining the same). Based on their request for more information with regard to the snubber installa-tion, the Architect Engineer (A/E) rejected DCR 73-83. DCR 73-83 (which included the revised drawing #M-2096-5) was inadvertently closed out without the appropriate changes being made. Therefore, when lE31-t012A and B were removed and later replaced by lE31-N012AA/AB/BA/BB, their process inputs (High vs Low) became crossed, due to drawing #M-2096-5 having never been revised.
, CORRECTIVE ACTION TAKEN AND RESLLTS ACHIEVED Our investigation of the situation revealed that it had resulted from a failure to properly complete action on a Drawing Cnange Request (DCR).
To ensure that similar problems had not been overlooked, the Station's, tne Architect Engineer's (A/E), and the Station Nuclear Engineering Department's (SED), Drawirq Change Request logs were reviewed to identify DCRs which had been rejected or cancelled. Allrejected,open or cancelled DCR's were verified to reflect properly on the critical drawings and/or the appropriate drawing aperture cards. No further discrepancies were found. The DCR for Modification M-1-1-84-91 reflected the previously rejected drawing change request.
CORRECTIVE ACTION TAKEN TO AVOID FURTER VIOLATION This incident alerted us to a procedural deficiency in our handling of DCR's. On that basis, SED initiated a review of its procedure for control of DCR's. This review indicated that SED had revised its DCR procecure in August 1984 to provide a specific procedure for handling DCRs rejected or cancelled by the A/E. This procedure was not in effect at the time this incident occurred. It is believed that the current procedure will prevent the recurrence of a similar problem.
DATE #EN FLLL COWLIANCE WILL BE ACHIEVED Full compliance has been achieved.
l 2C.
10 CFR Part 50, Appendix B, Criterion XI, as implemented by the Commonwealth Edison Company Quality Assurance Manual, Quality Requirement 11.1, requires that the test program include those tests necessary to demonstrate that systems will perform satisfactorily in service following plant maintenance or modifications.
Contrary to the above, the post-installation testing performed following the completion of Modification M-1-1-84-091 did not adequately demonstrate system operability in that the test did not detect that the Regenerative Heat Removal pump suction high flow isolation switches were piped backwards prior to returning the instruments to service.
L
, ADMISSION OR DENIAL OF TE ALLEED VIOLATION Commonwealth Edison admits the violation.
REASON FOR THE VIOLATION See Item 2A.
CORRECTIVE ACTION TAKEN Ato RESULTS ACHIEVED See Item 2A.
.s CORRECTIVE ACTION TAKEN TQ AVOID FURTER VIOLATION Refer to Item 1A.
DATE WHEN FLLL COWLIAPCE WILL BE ACHIEVED Full Compliance has been achieved.
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10 CFR Part 50, Appendix B, Criterion XI, as implemented by the Commonwealth Edison Company Quality Assurance Manual, Quality Requirement 11.1, requires that the test program include those tests necessary to demonstrate that systems will perform satisfactorily in service following plant maintenance or modifications.
Contrary to the above, during this inspection period, the operability test for two Unit 2 shutdown cooling high flow isolation switches was not performed correctly. Specifically, walkdown of the piping to these switches identified no problems although the piping to the switches was installed backwards. This error was discovered by an alternate test that was not specified for proof of operability testing.
ADMISSION OR DENIAL OF TE ALLEGED VIOLATION Comonwealth Edison adnits the violation.
REASON FOR THE VIOLATION As a result of previously identified installation errors a system walkdown was designated in June, 1985 as corrective action to verify that all piping was installed in accoroance with design drawings modified during the outage. A Technical Staff Engineer was assigned to perform a walkdown of the RHR Shutdown Cooling pump suction high flow isolation switches. The Engineer who performed the walkdown had traced the piping to a wall penetration and when he went to the other side of the wall he reoriented himself with informal markings on the piping which were reversed. The remainder of the inspection was performed utilizing the reversed reference.
CORRECTIVE ACTION TAKEN Ato RESULTS ACHIEVED Our investigation to determine the cause of the walkdown error identified the problems that could have contributed to it. As a result, a second walkdown of all process instrumentation piping which penetrated walls was conducted by two Technical Staff personnel, one on either side g
of the wall. Moreover, all differential pressure instrumentation was verified by performing a second test by varying the process which the instrumentation measured. The piping was corrected and it was verified that the installation was correct by conducting a retest which measured flow in the system.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Refer.to Item 1A.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full Compliance has been achieved.
0764K
-Q Commonwe:lth Edison O '# - One First N:tenal Ptera Cheeq7 ATTACHMENT 3 Ittino.s j.*
C y' Acoress Reply to Post Office Box 767 j
Crucago. Illinois 60690 s
December 5. 1985 Mr. James C. Esppler Regional Administrator U.S. Buclear Regulatory Commission Region III 799 Roosevelt Road Glen Illyn, IL,60137
Subject:
LaSalle County station Units 1 and 2 Management Plan IRC Docket Bos. 50-373 and 50-374
Dear Mr. Esppler:
ss l
Enclosed is the Action Plan that LaSalle has been developing over the past few months to address areas that are of mutusi concern.
This is being submitted for your information and is in response to verbal coenitrents that have been made during recent meetings with you or your staff.
A response to the 10 CFR 50.54(f) letter, dated Rovember 22, 1985 to
~
Cordell Reed, will be transmitted in accordance with the schedule specified in that letter.
If you have any further questions regarding this matter, please direct them to this office.
Very y yours,
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D. L. Farrar Director of Buelear Licensing Im z
cc:
Dr. A. Bournia - ERR ERC Resident Inspector pr W,lua>-
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REVISION 0 11/22/85 0
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37
TABIZ OF CONTENTS PAGE 2
SCFAM PIDUCTION h
ESF ACTUATIONS SCREDULING/PININING 7
CONTROL 300M IN MR.vaTION IEFICIENCIES 9
12 WORK REQUEST BACKIDG TIME CIDCKS/ DEGRADED EQUIPMENT LOG (DEL)
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PROCEDURES BACKIDG 15 17 MDDIFICATIONS DESIGN CONTROL 19 ss COMMUNICATION WITH RESIDENT I?!SPECTOR 21 RADIATION PROTECTION PER70FFANCE 22 PEFSONNEL PEPJORMANCE 30 33 Organization 34 Regulatory Performance GFAPHS 1
MANAGDENT PIAN IMPIIMENTATION 3
SCRAMS 6
ESF ACTUATIONS 11 CONTROL ROOM INEFFATION DEFICIENCIES 13 WORK REQUEST BACKIDG 16 PROCEDUFIS BAC)10G CATEGORIZATION /PRICRITIZATION 0F MODIFICATIONS 16 EI RADIATION DOOR VIDIATIONS 29 31 PEFSONNEL ERROR IIPS 32.
CLWJIATIVE LER HISTORY (NU)GER)
IT"RCDUC !CN The objective of this plan is to realize a significant improve-ment in the performance of IaSalle Station. Although, the primry focus is on improved Regulatory Performance, benefits in Station availability as well as other areas are expected to result.
s, The plan is divided into major areas with a detailed action plan for each area. Where appropriate, measurement standards such as trend gra;ts and projected completion dates are provided.
The plan is intended to be a living document subject to change as conditions dictate. Although some variation in meeting pro-jected goals should be expected due to unforeseen circumstances, the Station considers itself accountable for rigorous adherence to this plan.
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PROJECTED AC1tJAL C00@lfrION COMPIETION RESP.
DATE DATE C000ENTS A. Establish Comunittee CES/ACS 8/6/85 B. Scram History Review, including list of scrsus and CES/ACS 9/3/85 root causes C. Review Station Conduct of Operations CES/ACS 9/26/85 D. Review RPS Sury. testing CES/ACS 9/26/85 l
E. Turbine trip channel redundancy 1 - n tiry alternatives CES/ACS Complete Complete
- 2. Feasibility / Cost study' CES/ACS 2/28/86 '
i
- 3. Establish schedule for improvement CES/ACS 6/01/86 Schedule Depend-ent Upon Results or Feasibility Study F. Inst. line hydraulle transient RPS trips
- 1. Identify alternatives CES/ACS Complete Complete
- 2. Feasibility / Cost Study CES/ACS Complete Complete
- 3. Establish schedule for improvement CES/ACS 5/01/86 1:
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i REACTOR SCRAMS l
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12 10 8
6 4
2 J F M AM J J A S O N D J F M AM J J A S O N D J F M A M J J A S O N D 1983 1984 1985 M
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1 EBF ACTURTIONS PfGIECTED AC1tJAL COMPIETION COMPIPTION RESP.
DATE DATE CONo A. Task Pbree DSB
- 1. Fbra hak Pbree Complete Co-plete
- 2. Initiate' ongoing tracktr.g/ trending Complete Complete
- 3. Review all actuations since 1/1/8% to identify Complete Complete problem areas
%. Review actuations for root cause as they occur On Colng On Colng and recommend corrective actions to prevent recurrence
- 5. RWCU delta-flow cal-data Modification
- a. SNED letter RFJ 12/02/85
- b. MOD to OSR 1/08/86
- c. MDD to IMD 2/01/86
- d. MOD f r. stalled (both units) 2/15/86
- a. Review BREP Scoping analysis DSB 11/08/85 11/13/85
- b. Decision on MOD / funding CJD/KG 11/15/85 11/15/85 Estimated cost
$324,000 Will do.
- c. Modification Package engineered RPJ 1/15/85
- d. Modification Package installed PFN/
3/0')/85 E
- e. Submit Tech Spec Change Request DGB/TAH 3/03/85 g
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t EBF ACIWTIORB (Oostinued)
PIMAIECTED ACTUAL COMPIETION COMPIETION RFSP.
DATM DATE CfMIF1tTS
- 7. Schedule RWCU valve replacement Review MOD to decrease cost / increase Station DSB/PFM 12/22/5 options
/DG Options include - downgrade system from code
- reduce number or valves installed
- welded instead of rianged installation Decision on ibnding KC/CJD 1/31/86 Modification schedule DGB/ PPM 2/28/86 v.
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LASALLE COUNTY STATION ESF ACTUATIONS
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1994 1985
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SCMBULING/PIANNIEC PIMUECTED AC1UAL Cope'!ErION COMPlfrION RESP.
DATE
_ DATE CDP 94ENTS A. Establish,a task force to evaluate implementation CES Complete Complete of a Planning Department consisting of anjor Station departments B. Ihvelop technique for planning:
CES/JEL
- 1. Rettael Outage Complete Complete
- 2. Porced Outage Complete Complete
- 3. Daily Work (jobs which interface)
Complete Complete C. Develop a Performance Tracking Scheme
- 1. Starts / Completions / Cancels /5 Compliance CES/JEL 12/09/85
- 2. Reports to Production Superintendent CES/JEL 12/09/85 Start thte
- 3. Publish periodic statts reports around Station CES/JEL 12/09/85 Start Inte D. Implement a Planning Group
- 1. Establish an Assistant Superintendent level position GJD 1/31/85
- 2. Organisation, authority, responelbility, size, CE0i/JEL 12/30/85 composition (preliminary)
- 3. Assign Operating perst.nnel (5 Operators)
Complete Complete
%. Assign additional department personnel CES/WES 12/30/85 N
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PiNMECTED ACTUAL CODFIETION C00fPIETION RESP.
DATE DATE C000FFfS E. Computerize the Planning Programs
- 1. Refuel Outage Complete Complete
- 2. Pbreed Outage Complete Complete
- 3. Daily Work CES/JEL 3/01/86 Need Computer Type Person By by 1/1/86 F. Inform Station personnel of Planning Degartment's CES/JEL 1/31/86 fbnctions 1:
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G)WTROL lEMBI IEPUIntTICII DEFICIlWCIRS' PROJECTED AC'111AL COMPIEPION COMPIJ. TION RESP.
DATE DATE C0004ENTS A. New Control Room Work Request's (CRWR) B-1 priority.
WRil on Coing On Going (B-1 = Start work next work day and work normeni hours to cosspletion)
B. Control Room Work Requests integrated into daily WES On coing on Colng schedule (Interface WR's only)
C. Complete U-2 CRWR's requiring outage WES 12/08/85 End of current outage D. Black panel in errect on Unit I at startup WES 3/01/86 End of 1st Refuel Outage E. Complete U-1 CRWR's requiring outage WES 3/1/86 End or ist Refuel Outage F. Schedule and complete 25 CRWH's per week WES 11/19/85 11/19/85 Start Date G. Daily Status Report (Planned & Conspleted)
WES 11/25/85 11/20/85 Start Date H. Weekly plot of CRWR's WRH 12/03/85 12/03/85 Start Date I. Personent Fix Program for repetitive equip. problems
- 1. Identify $ repetitive problems needing long-tern solutions WES/PC 1/01/86
- 2. Identify alternatives PPM Schedule depend-ent on groblem definition
- That: Directly arrect the controls used by operators during emergency situations, orf-nocauti situations or routine operations.
Results in inforuuttion, relied on by operators to take action, being inaccurate or indeterminate.
Results in an annunciated Control Room alarm that reflects an off-normal condition.
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PROJECTED AC'I1JAL COWlETION COMPlfr10N RESP.
DATE DATE COMFlf1S 4
- 3. Perform reasibility/ cot,t study PPM Schedule depend-l ent on problem definition i
%. Establish schedule for resolution PPM Schedule depend-ent on problem definition i
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- That: Directly arrect the controls used by operators during emergency situations, off-normal situations or routine operations.
j Results in inforsuition, relled on by operators to take action, being inaccurate or Indeterminate.
Results in an annunicated Control Room alarm that reflects an off-normal condition.
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CONTROL ROOM WORK REQUESTS CONTROL ROOM ALARMS WORK REQUEST A L A R M S '""""'"
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s-WNE RBERST MCEla0 PfMAIECTED AC1UAL COMPIETION COMPIETION RESP.
DATE -
DATE COD 9FNTS A. Refine accountability of actual backlog
- 1. Review of current backlog CES/WES 1/31/86
- 2. Maintenance of backlog record via improved CES/WES 2/28/86 reporting system
- 3. Assign an individual to expedite Work Request processing CJD 1/01/86 B. Review of outstanding Work Requests on U-1 CES/WRH 1/31/86 Intent is to to identify those with safety impact which cleanup prior should be done prior to'U-1 startup to restart C. Define an optismse backlog level and assess resource level CES/WES 1/31/86 vs. workload, actual backleg, and optlamme backlog D. Reduce backlog to optimum level CES/WES 9/01/86 E. Optimize parts /saterials procurement CES/WES 2/28/86 F. Permanent Fix Program for repetitive equl sment problems l
- 1. Identify five repetitive problems needing long-tern CES/WES 1/31/86 solution
- 2. Identify alternatives PFM Sefwdule depend-ent on problem definition
- 3. Perform feasibility / cost study PFM Schedule depend-ent on groblem definition
- b. Estahlish schedule for improvement PFM Schedule depend-ent on problem defini tion y
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500
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PROJECTED AC'IUA L COMP!Pr!ON COMPIJTION RfliP.
DATE DATE CopeqElrrs A. Redwe # of time clocks in errect to a reasonable level
- 1. Conduct overall assessment of time clocks, i.e.,
WRH/DMP 12/20/85 causes, repetitive problems, etc. 'Ihis seiy require a record system or log on time clocks to collect data.
- 2. Review results and make recommendations to reduce WRH/DMP 1/06/86
- of time clocks in errect
- 3. Pornmally define priority requirements for time WRll 12/02/85 12/02/85 clock related Work Requests
- b. Implement priority system WRil/0E's 12/02/85 12/03/85
- 5. Establish a preliminary target number prior to tinit WRH 3/01/86 1 startup and monitor
- 6. Reevaluate with both units in power operntion CES/WRH is/15/86
- 7. Establish a target number WRH
$/01/86 B. Reduce i of DEL's in errect
- 1. Review history and conseltments WRH/JAA 12/CP/85
- 2. Conduct overall assessment of DEL to identify WRH/DBF 12/20/85 causes for number or entrles
- 3. Make recosamendations to reduce the number during WRH/006' 1/06/86 normal. operation
- 4. Formalize use of DEL. What goes in Iog, what does WRH/JAA 2/01/86 degraded mean, etc.
/SCRE's
- 5. Establish a preliminary target number prior to Unit WRif 3/01/86 1 startup and monitor 7
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- 6. Reevaluate status with both units in operation CTli/WRH 5/01/86
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FWomiltNWB RAMIDO PROJECTED AC11JAL COMPIETION COMPIJTION RF11P.
DATE DATE CON.,
A. Improve procedures process to make it more errective RDB/JCK 10/21/85 10/21/85 B. Establish target backlog RDB/JCK 10/21/85 10/21/85 C. Monitor backlog RDB/JCK Ongoing Ongoing D. Review grocedures outstanding, especially those RDB/JCK 2/28/86 Prior to Unit 1 resulting from U-1 Modifications during Heruel Outage.
Startup prior to Unit 1 Startup
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MODIFICATIONS PROJECTED
- ACTilAI, COMPIETION COMPLETION RESP.
DATE DATE CfM ENTS A. 5 Year Modification Plan 4
- 1. Establish a Modirleation Review Committee RDB Complete Complete
- 2. Develop a priority /catego y scheme RDB 10/25/85 10/25/85
- 3. Develop mechanism to handle new modification RDB 11/11/85 10/25/85 requests
- 4. Redefine scope of Modification Program RDB 1/05/86 (1.e. - setpoint changes, etc.)
- 5. categorize existing modifications RDB 1/05/86
- 6. Prioritize modifications within categories RDB 1/20/86 T. Review outstanding modirications for sarety RDB 2/28/86 impact yrior to Unit I startup
- 8. Schedule spectric modifications for completion RDB 3/lb/86 commensurate with established rate and publish schedule (preliminary schedule)
- 9. Review greliminary schedule with all responsible GID/RDB h/25/86 organizations and establish final schedule consis-tent with the coassitment of the responsible organizations.
- 10. Issue monthly status reports - Include RDB 12/05/85 11/20/85 Start Ihte executive summary
- 11. Hold all responsible organizations accountable Kr;/CfD on Colng On Colng for performing activities within the convolted schedule 5
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l DERIM GWI1EDL PRGIECTED ACTUAL COMPiPrION COMPIJ: TION RESP.
DATE DATE C0099ENTS A. Improve Design Schedule & Quality
- 1. Assign Cognizant Engineer to all Modifications
- a. Define Cognizant Engineer responsibility /
RDB/ PPM Complete Complete accountability for successib1 completion of Modification from initial design to declar-at ton or operability
- b. Training / Expectations Program for cognizant RDB/ PPM 11/18/85 11/15/85 Engineers
- c. Assign Modifications RDB/PFM Complete Complete
- 2. Improve quality / content or modification design pckages
- a. Implement feedback program which utilizes RDB/ PPM b/25/86 lessons learned from defielent modification packages to ingrove the Modification Program
- 3. Environmental Qualification Program implementation review and corrective action as required
- a. Conduct " Big Picture" status meeting to review GJD Complete Complete total program and compliance with intent as well as letter of the law
- c. Conduct QC audit and pregare report RDR Complete Complete e
- d. Conduct QA audit and pregare report RDB Complete Complete U
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IMISIM COWIWOL (Onettuned)
PROJECTED AC'ItJAI, COMPIFTION COMPIETION RESP.
DATE DATE C00091WJ
- k. Ident1ry backlogs in the destan process (other than design) such as DCR's, FCR's, etc. that are potentials for future mistakes and develop trending / tracking sensures to reduce to a manageable level.
- m. DCR's (1) Establish a reasonable turnaround time for RDB/PFM 1/31/86 DCR's and target for cleanup of tacklog (2) Obtain SNED concurrence KC/GJD 1/31/86 (3) Monitoring sethod and susuunry report RDB/PFM 1/31/86
- b. Other RDB/PFM 3/31/86
- 5. Post Modification / Maintenance Testing
- a. Assign / define a required committee to CJD Complete Complete review all safety related post amintenance/
Modification tests for adequacy. Illgh level
- Nster & T.S.S.?
O.E.7
- b. Review checklists in errect to assess adequacy IMR(NSC) 1/31/86 By Nuclear Safety Group 8
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l C[30EMICATIM VITE REBI M IMIFECTORS PROJECTED AC'IUAL COMPIETION COMPIJ. TION RESP.
DATE DATE C000FFIS A. Aggressive interaction with Resident Inspector to GJD/RDB On Going On Going better understand concerns and address, as well as
/CES/
unrket the good things Depart-ment Heads B. Weekly meeting with Resident GJD On Going On Colng
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RADIATION PROFkCTim PIERFDIBIANCE PfMATECTED ACWAL CODFIETION COMPlfrION RESP.
DATE DATE C000FNTS A. Procedural Compliance
- 1. Doctamented ta11 gates conducted with all personnel Complete Complete
- n. laSalle problem areas
- b. Byron Enforcement Action
- 2. All 1st line supervisors reminded of their responsi-Complete Complete bility for procedural compliance at Expectation
-Meetings held with Station's upper management
- 3. On going program to upgrade procedures and training Ongoing Ongoing B. Prisking (See Also Item 'A - Procedural
- Compliance)
- 1. Seti p af nine (9) frisker booths in progress.
IRA Reruel Complete Five additional booths awaiting setup.
- 2. Fbur (b) state-of-the-art whole body friskers on order IRA Refuel 505 Complete.
2 have tad boards.
Pro-Jeet: 12/13/85 Five (5) are are proposed for 1966 budget IRA 1966
- 3. Pbrty elsht (48) additional 196-14 friskers (handheld)
IRA Reruel All 48 ree'd.
are on order
,18 in service.
Meaninder in service.
12/9/85 3'
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RADIATIM PRDtWCTIM PEHp015tANCE (Conttamed)
PfMMECTED ACTUA!,
COMPirrIOff COMPIETION RESP.
DATE DATE C0009'NTS
- 5. New stepmff pads on order to remind personnel of IRA Refbel Complete requirement for whole toly rrisk
- 6. Permnent cement block frisker stations proposed IRA 1986 for 1986 budget.
C. Starring
- 1. Add an Assistant to Rad Chen Supervisor (SRO License)
RDR Refuel Complete IRA 1966
- 2. Add a lead Fbre e n
- 3. Add a Timekeeper / Scheduler (should allow a IRA 1966 Complete Forean to be in the plant 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> / day)
- h. Contract 10-15 quellfled techs for Unit 1 1st IRA Refuel Complete Refuel including supervision
IRA /'11C As Avall-On Colng Dresden/ General Orrice as available able IRA As Avall-On Colng
- 6. Encourage Nealth Physicist exchange program able D. Sgace
- 1. Convert apgroximtely 1000 ft' of lunchroom to JL Refbel Complete tudge issue and INP grocessing area, etc.
- 2. Addition of approximtely 500 ft' In traller IRA Refbel Complet e gark for HP of fice to ellrinate c ovded conditions 3
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9 RADIATim PNUfBCFtm PHHfGDIANCE (Continued)
PRWECTED AC'111AL COWIJ"rION COMP!J*rION
__ RFliP.
DATE DATE Cr$9ENTS E. Personnel Contamination (See also Item A - Procedural Compliance.)
- 1. Each event is investigated by Department with Rad Ongoing Ongoing Chem representation to determine root cause and propose corrective action
- 2. Daily report of contamination events provided to Ongoing Ongoing Department Heads and Station upper annagement (monthly trending).
- 3. Reviewing contamination survey techniques and frequency JL Refbel Comple te or contamination surveys for areas or known problens
- k. Developing a system to assign priority to Work Requests JL Reruel Complete Informally related to contamination control and grovide rollovup implemented.
Procedure in OGH
- 5. Continued tallantes by individual departments Ongoing Ongoing
- 6. RCT's stationed at high trarrie areas for contamination Complete Complete control and proper frisking technique F. Area Contamination (See also Item A - Proce=%ral Compilance.)
- 1. Establish a Contamination Control Coordiretor RDB Refuel Complete
- a. Ares contamination cleanup RDB/JL On Going On reing
- b. Event investigation RDB/JL On Colng On Colng
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MADIAff05 PROTWCTIS PERfDIONCE (Oostimmed)
PROJEC'ITD AC'f"JAL COOS'iRTION COOFIJN' ION RFliP.
DATE DATE C000EWPS
- c. Review contamination history to identify methods RDR/JL 2/17/85 for minimizing contaminating events
- d. Reclaim long-term contaminated areas RDR/JL 1986
- 2. Technical Start to evaluate ventilation as a possible PFM 1/05/86 contributor to spread of contamination
- 3. Equipment designed to aid in contamination control DH Rehael Complete
- a. Tents
- b. Drip pans
- c. Filtered air movers
- b. More extensive use nr Kelley closures to prevent Ongoing Ongoing g
spread of contamination
- 5. Contamination earts Icv sted at frisker locations IRA Reruel Complete
- 6. Major contamination event investigations to determine Ongoing Ongoing root cause and propose corrective action to preclude repetition C. High Radiation Door Violations (See also Iten A -
Procedural Compliance.)
- 1. All personnel instructed to challenge high rad doors Complete Complete to assure closure.
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f RADIAT105 PROTECTIM PERRNOIANCE (Continued)
IMIECTED
- ACitfAI, COMPirrION COMP! prion RESP.
DATE DATE COW 9ENTS
- 2. All personnel instructed on responsibilities and Complete Complete expectations regarding high radiation door security
- 3. Retnrorcement or sunnagement expectations and personnel Dept.
10/lb/85 Complete lleads responsibilities provided to all personnel
- b. Guidance provided in N-CET training has been curanded RDC 10/08/85 Complete to include more emphasis on responsibility or com-pliance with high radiation door security
- 5. Responsibility assigned for assuring high rad doors Complete Complete are repaired expedit16usly
- 6. Dorough investigation (DVR & ROR) conducted for each Ongoing Ongoing high radiation door violation with consideration or disciplinary action for identified violators / supervisors T. Surveillance or high rad doors implemented (IAP-1100-13)
IRA Refuel Complete
- 8. Continue evaluation or installation or local alarms WL 3/86 on selected doors m
10/15/85 11/15/85
- 9. High Rad Door Thsk Force (Corporate)
RDB/TAH 1/05/86 12/03/85
- 10. Subsmit p % d Tech Spee revision IRA 12/15/85
- 11. Evaluate implementation or recosamendations from Corporate High Radiation Door Task Force IRA 1/17/85
- 12. Implement additional restrictions on issue or high radiation keys / key cards IRA 10/lb/85 Cow lete e
- 11. Attach high radiation aren door security guidelines y
to high radiation keys / hey cards for issuance M
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MADIATION PRDIWCTIW PERFOIWWDC (Coatimued)
PfnJECTED AC'! VAL COMPIhTION COMPII. TION RESP.
DATE DATE CO M iffS 1%. Evaluate / implement issuance of pocket-sized Radiation MAP 12/20/85 Folders on Protection Awareness rolder which includes high radia-order tion door security guidelines
- 15. Consider periodic preventative saintenance prqrram MAP 11/01/85 Complete Will do.
for high radiation door hardware H. Noble Cas Contamination
- 1. A1 ARA review required when opening Orr Ons process lines DH 10/85 Complete
- 2. Showering utilized for decontamination rather than Complete Complete decay method untti guidance provided by Correrate
- 3. ScaA utilized for areas or noble nas contamination Complete Complete ir air sample is impractical or untimely
%. Additional training w!11 be provided to RCT's and HP's Complete Complete on noble gas contamination I. Unconditional Releases
- 1. Security Cuard instructed to ensure unconditional Complete Complete release pass for a broader range or items
- 2. Program drastically tightened rollowing contaminated Complete Complete solvent problem
- 3. Secure dumpsters JL 12/31/85
%. Designate a trash holding aren prior to survey JL 12/31/85
- 5. Designate an enclosed area for survey or trash JL 12/31/85
- 6. Evaluate gurchase or a trash cominctor Complete Complete 7
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IRADIAT105 PRDTWCTION PRRFUfMWCR (Continued) l PfMMECTED
- ACTUM, COMPirrl0N COMPIf."rION RPJIP.
DATE DNTE COP 9ENTS J. Interthee with Other Derartments (Communications)
- 1. Twice weekly meetings with Services Department Heads RDB On Colng on Colng
- 2. Rad Chem participates in Contamination Investigations IRA On Colng On Colng
- 3. Red Chem participates in Scheduling Program IRA On Colng On Going
%. Daily interrace with Shift IRA On Coing On CoIng
- 5. Had Chem participates in ta11 gates or other departments IRA On Coinc On Colpg
- 6. Weekly Department Heads. Meeting IRA On Colng on Colng;
- 7. Outage Planning Meeting IRA On Colng On Colng
- 8. Had Chem representative is Chairman of Dellan Task 1RA Cowplete Complete Force Maintenance Scheduling
- 9. Rad Chem participates in Daily Planning Meeting IRA On Colng On Coing
- 10. AIARA lines DH On Coing On Colng
- 11. Delian Team Building IRA 1/01/86
- 12. Restructuring of badging area (See Item D - Sgnee.)
IRA Complete Complete K. Miscellaneous
- 1. Remote enrrel monitor operational Dil Refbel Complete
- 2. Issue contractor fllm indges with security indge IRA 12/09/85
- 1. Issue CECO flim indges with security indge IRA Refuel Complet e 2
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LASALLE COUNTY STATION HIGH RAD AREA DOORS LEFT OPEN 19 8 5 '"""'""'"
1986 TARGET 30-25-
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O JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 5
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j NN 1.e.. Teanneork. Effectiveness, Compilance with Requirements, etc.
PfMAIECTED ACTUAL COBFIETIOM COMP!ErION i
RESP.
DATE DATE COBO4ElfrS l
i A. Expectations Meetings
- 1. lat Line, Supervisors GJD Complete Complete i
- 2. Convey espectations to senior manayment with CJD Cong,lete Complete emphasis on team work B. Dellan Efforts CJD 1/01/86 f
C. Communication on R.P. procedure compilance CJD 9/01/85 Complete l
D. Missed Rnd Chen Surveillances
- 1. Conduct detailed root cause review DGB/PRL 1/31/86 1
i
- 2. Identify effective corrective action (s) to DGB/PRL 2/14/86 l
minimize recurrence.
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i LASALLE COUNTY STATION PERSONNEL ERROR LERS 1984<<<<<<<
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NUMBER OF LERS 1984sss--so 19 8 5 nnenanna 200<
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