ML20202B153
| ML20202B153 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/30/1986 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CON-FIN-A-3552 1823K, NUDOCS 8607100220 | |
| Download: ML20202B153 (5) | |
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Commonwealth Edison
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) 72 West Adams Street, Chicfgo, Illinois (s) Address Reply to: Post Office Box 767
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g Chicago.Jilinois 60690-0767 fRIORITypogryg June 30, 1986 f.ipt c
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'i Mr. James G. Keppler*
Regional Administrator
' FILM U.S. Nuclear Regulatory Commission Region III q
799 Roosevelt Road Glen Ellyn, IL 60137 4
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Subject:
LaSalle,C6uhty Station Units 1 and 2 Response'to Brookhaven National Laboratory Report on W ification Report program Controls' FIN A-3552 NRC Docket Nos. 50-373'and 50-374
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Refer.ence (g):
C. E. Morelius letter to Cordell Reed dated April 9, 1986
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Dear 19.'Keppler:
This letter.is in response to the concerns ide'ntified in the enclosure.to reference (a). Commonwealth Edison has carefulJy assessed each.
of the concerns and our response is. included in the attachment. We appreci-ate the positive comments as well as identification of specific areas' which can be improved, our response discusses each of these in some detail..
Considering t'he extent of the audit, we take some pride'in the -
report conclusion "...it is apparent that controls have been established and are properly implemented at.LaSalle...".
If you have any further questions regarding this matter, please e
. refer them to th.is office.
Very truly yours, a
W.
I D nnis L. Farrat Director of Nuclear Licensing m.
s Im Attachment J
l cc: NRC Resident Inspector - L5CS i
Dr. A. Bournia M. C. parker - IDNS
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i B607100220 860630 1823(
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- 1..The training of personnel, especially licensed opdratorsm on the system changes resulting from a modification', should Ife accomplished pribr to -
declaring 'the modification operable (See Section 5.2).
Adminstrat,1ve Training documents and" procedures are undEr revision to' implement more effective methods of informing operators of significant'modificatifns'priortoretdrningtheaffectedsystem,to operable statup.
Summaries'of selected modifications are being posted in the control room for review by onshift licensed. operators. shift turnover
- procedures for licensed. operators will require onco (aing watchstanders to review and initial the summaries of recent significant modifications. This addit'ional measure augments the existing training system which updates operators on plant design changes through individually issued reading packages and regularl'y scheduled classroom sessions.
Contr.ol' documents under revision to address this concern include LAP 1300-2, Modifications, LAP 200-3, shift change, and the training'ACMI for License Requalification. These revisions will'be completed prior to unit restart.
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2.
Modification 83-018 regarding the upgrade of the de system instrumentation and. annunciation shod 1d specify that procedures be changed and operator training be conducted prior to returning the modified system to service (see Section 5.5).
Modification 1-1-83-018 upgraded some of Unit one Control Room DC 4
Instrumentation and an annunciator. to be consistent. with that already installed on Unit Two. The' modification provided remote
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information to the Unit one control room operator, previously only av,ailable from a local codtrol panel. The' change is' easily discernible by the control room operdtor and requires no additional-knowledge or ski 181s to effectively' utilize the information provided.
The new annunciator and response procedures being provided on Unit one are identical to those already in use on Unit Two. Operators ar( already familiar with the use of the annunciator and
. procedure. Based on the above infor'mation, a review of this I
= modification by the operating Engineer and Training Supervisor l
r'esulted in a' decision not to require training prior to modification. installation but rather to train operators f%11owing i
installation. Considering that no significant deviation from normal conservative plant operating' practice would result from an operator unaware of this change, the decision not to. train prior,.to j
mod installation.is considered appropriate.
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The determination of.the procedure changes rdquired prior to the
' modification operability is based on the operators' needs for operating the' system after the modification is placed in service.
In the case of modification package M-1-1-83-018, arnunciator alarm
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procedures were being added for 250v DC sattery Trouble due to changes in the DC instrum*entation for control room Jpdication. The additional alarm aids the operator in identifyirg a problem. The.
anr.unciator procedure response informs the operator to investigate the cause and notify the Shif,t' Supervisor of the problem'. These.
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.are responses which ar'e typically expected of-a trained licensed operator. Annunciator response procedure LOA-LPM 01J-A108 was revised to reflect the changes in the modification prior to the 250V DC instrumentation mod work approval for opetration.
p Con [lictingse~tpoint.informa,tionprovidedintheCRDAutoScram
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modification package (82-305) should bh resolved 'by approved
.. documentation wit,hin the package (se.e Section,5.1.1)..,
Modification Package M-1-1-82-305 inc'luded the calculations for the' low pressure setpoint for CRP charging heade'r. pressure.- The Genera 1' Electric (GE) calculations determined a required setpoint of 1157,psig was needed to' meet.the design conditions. The GE 1etter recommended assetpoint of 1170 psig on the basis that the 20 PSI increment scale on the Rosemount' Trip Units would be'used for*
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calibr,at' ins the instrumentation. The Station Nuclear Engineering.
Department (SNEQ) has authorized a low pressure setpoint of 1157, psig based on the fact the Station uses more accurate test instrumentation when performing the required calibrations.
Additional documentation from SliED has been obtained to clarify the Msetpointspecified.intheModification. Package.
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Complete engineering and. design of the modification, including a physical walkdcIwn of.the proposed installation, should be conducted prior to' submittal of the package to the plant (see Section 5.1.2)'.
The concern expressed o've'r the'FCR' changes made on Modification package's during the Unit 1 Outage has been noted during*the planning gnd preparation of Modifications for the upcoming first refuel outage of Unit 2.
In particular, the Station Nuclear Engineering Department (SNED) is compiltng instalt&ation tolerances in one document (Master Tolerance document). Engineering has also' directed that' Unit 2 outage modifications previously sent to LaSalle I
be reviewed for similar design problems, irncluding conflicts reviewed with the current Station equipment configuratiori, that,,
were experienced'during the Unit I refyel outage. Additionally,,
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selected mod'ifications to be implemented.at Unit 2, that had a large number'6f FCR's when installed.at Unit I during the current -
, Unit 1 outage, have been or will be revised to. attempt to, pick up these FCR's in the Unit 2 designs before the Unit 2 outage starts.
Finally, a field verification.walkdown for constructabflity df major modffications.is schedul,e,d to be perforined.
n These actions shou}d res g in fewer design changes of the type identif.ied as concerns in'the Technical Review Report, during the installation phase of Unit 2 'first refueling. outage meitlifications.
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An excessive turnaround t'ime~for drawing changes resulting from modifications exists which could increase the potential for operating '
errors (see Sectio.n 5.3.1)'.
As part of the Proactive Management Plan which was developeil in the 5
..lasit quar.ter'of 1985, Station Nuc&r Engineering-Department has directed the A/E to reduce the turnaround time for the processing of Drawing Changes, espec,ially Jn the case where critical control
.r,oom drawings are involved. Progress has already[been noted in decreasing the A/E drawing review time and. issuance of drawings.
Provisions are.in place to' indicate the prints which have
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plant conditions.
_ 6.' Quality Assurance (QA) involvement in the' station modi ~fication program should address the operationally significant aspects of the program (see Section 5.4).
In response to the,. concerns relative to Quality Assuran'cs Department in this Section, the secqnd statement in the-ftrat paragraph comes from the, Procedure LAP 1300-f and points out the = -
. fact the Step 3,8 of that Procedure is not correct and that'it does
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not follow the requirements of.the Quality. Assurance Procedgre 3-51.
Accordingly, this Procedure will be' required to be corrected.
c Quality. Assurance is not involved at this point but'rather af ter -
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the item.is declared operational.
Instead, in rgference to QP "3-91, Steps C.28 through C.33, Quality control has respoiisibilith, for verifying satisfactory cpapletion of work, inspection, construc-
, tion steps, quality control requirements, required sign-offs and other requirements prior to operational testing by the operating Engineer or Shift Engineer; The negt step is for Quality control to review the modification tests, to assure all steps are properly signed off, test' data was recorded and meets acceptance criteria, etc.; followed by the Technical Staff Supervisor and Training Superyisor verification dhd"khen authorizai. ion of ope,r,ation to the modified equipment by the operating Engineer or, Shift Engineer.
After authorized for operation, the package is sent to Sta, tion
" Quality Assurance to verify Yequirements have b,een satisfactorily completed.
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In reference to the last' par 9 graph,'a Quality. Assurance audit,was performed on a selection of modifications to verify compliance to
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thi Commonwealth Edison Company Qtrality Assurance Manual requirements.and procedures and included coverage of training
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. personnel, updating procedures and updated critical control room drawings prior.to modification. operability. 'In addition, future'"
audits and/or surveillances will be conducted to ensure compliance of the requirements.
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.Also,'the QP 3-51. Step Q.34 was revised recently to clarify that
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e,ach modification requires field verification, either by in-proqess
- witness / hold' points, surveillances, or by specific checking of the@ -
completed work that the work package has been satisfactorily completed prior to signing the Ptodification Approval Sheet.
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14 censed 'osferators should' be made aware of procedure and technical, specification changes resulting from certain saf.ety related modifications activitieis prior,to system operability (see Section 5.5).
The station administrative procedure for controlling modification (1.AP QOO-2) is under revision to include an additional review and determination of. appropriate training for modification related Technical Specification and procedure changes.
Operators performing "on shift" license duties will be notified of significant Technical Specificgtion and proced'ure changes relating to critical modifications pr'ior to rbturning the affected system to operable status. These reviews will be accomplished in conjunction with shif t turnovers as described undler step 1) of this document.
Ag'ain, this additional measure augments the existing training system which updates operators on Technical Specification and
' procedure changes through individually issued reading packages and regularly scheduled classroom. sessions.
Revisions to 1.AP 1300-2 will be completed prior to unit startup.
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_An inventory of " critical control room drawing" status is performed on a 8.
quarterly basis. The res'ults of the inv'entory sho'uld be reviewed by technical staff management'to insure. appropriate hetion is taken to correct, discovered discrepancies (s,ee Section 5.3.2).
.The intent of the inventory check of.critital ' control' room drawings is to ensure that the' Operating Department is supplied with,'the
. current revisions pertuining to these drawings. Due to the large
. usage of the drawings during plant operation, cards and drawings could be misplaced.
1.AP 810-V will be revised to include a review by Tech St&ff Management to ensure that major problems do not
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continue uncorrected.
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