ML20214L158

Documents Review of Util Response to BNL Rept on Mod Program.Recommends NRC Inspect Identified Procedure Revs to Determine Adequacy & Future Mods to Verify That Corrective Actions Effective

ML20214L158
Person / Time
Site:	LaSalle
Issue date:	08/26/1986
From:	Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20214L144	List: ML20214L141 ML20214L158
References
NUDOCS 8609090454
Download: ML20214L158 (2)

Text

'

t hee UNITE 3 STATES - - - -

' NUCLEAR REGULATORY COMMISSION REGloN lli

, 7ee moosEVELT ROAD eLEN ELLYM. ILUNOIS 64137 AUG 2 610.,86 a...*

MEMORANDUM FOR: Charles E. Norelius, Director, Division of Reactor Projects THRU: . G. Guldemond, Chief, Reactor Projects Branch 2e FROM: Geoffrey C. Wright, Chief, Reactor Projects Section 2C

SUBJECT:

BROOKHAVEN NATIONAL LABORATORY (BNL) REPORT ON LASALLE MODIFICATION PROGRAM

References:

(a) Letter dated April 9, 1986, from C. E. Norelius to C. Reed (b) Letter dated June 30, 1986, from D. L. Farrar to J. G. Keppler This memo documents our review of the Commonwealth Edison Company response (Reference (b)) to the BNL Report on the LaSalle Modification Program which was transmitted to Commonwealth Edison Company by Reference (a).

Reference (b) listed responses to the eight concerns identified to Section 2 of the BNL report. Our evaluation and recommendations are as follows:

Item 1 - The response is to vague to determine if corrective action is adequate.

Recommendation: The NRC sheuld inspect: (1) the identified procedure revisions to determine adequacy, and (2) future modifications to cetermine if corrective actions were

! effective.

Item 2 - The response is adequate.

Recommendation: No additional NRC action necessary.

Item 3 - The response indicates a calibration setpoint of 1157 psig is being used to meet a design setpoint of 1157 psig.

Recommendations: The NRC should inspect to determine if the calibration setpoint is adequate to meet the design setpoint when the inaccuracies of the calibration method and instruments are taken into consideration.

Item 4 - The response appears to only address actions for the upcoming Unit 2 refueling outage.

Recem.endation: The NRC sh 9 d imrect to insure that the generic l issue is z W " c.

8609090454 860903 PDR ADOCK 05000373 o PDR i

s Charles E. Norelius 2 AUG 2 61986 Item 5 - The response does not set a goal for acceptable turnaround time, as a result the adequacy of the corrective action cannot be determined.

Recommendation: The NRC should inspect to: (1)determineifthe Proactive Management Plan establishes such a goal, and (2) evaluate progress in reaching the goal.

Item 6 - The response does not indicate how conduct of future audits /surveillances will be assured.

Recommendation: The NRC should inspect to determine if these audits are performed or verify that requirements are established to perform these audits.

Item 7 - Same as Item 1.

Item 8 - Response appears to meet recommendation of Brookhaven. However the licensee should consider increasing the frequency of the audit instead of adding additional management review since the problem appears to be the large usage of the drawings and not inadequate corrective action.

Recommendation: The NRC should discuss this with the licensee.

1 Item 3 should be performed by a DRS specialist during a future scheduled inspection. A letter is being drafted to request such an inspection.

The other items can be performed by the Resident Inspectors when performing a future inspection to fulfill the requirements of the Inspection program.

By receipt of a copy of this memo, the Resident Inspectors are requested te perform the recommended inspections. The result of the inspections cay result in a letter to the licensee or be included in a future inspection report.

f jGeoffey . Wright, bief Reactor Projects Section 2C cc: Resident Inspector -

LaSalle Attachments:

1. Reference (a)

2. Reference (b)

ee # #44 _ , _ _ . . _ _ __ UNITO BTATES .

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• NUCLEAR REGULATORY COMMIS$10N RE0lON lli 7ee moostytLT nonc eLEN ELLYN. ILLINOIS 49137

...,* APR 9 1986 Docket No. 50-373 Connonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

Enclosed for your infomation and consideration is the final report fron Mr. William Gunther of Brookhaven National Laboratory (BNL), a contractor for NRC Region III, who recently performed a technical review of the LaSalle County Nuclear Station-modification program. Although Mr. Gunther concluded that controls have been established and are being properly implemented, he identified several concerns in Section 2 and amplified on the concerns in Section 5 of the report. In some cases these concerns are similar to those which we identified in the special task force report in September,1985, and in the November 22,1985,10 CFR 50.54(f) letter. We request that you respond to the concerns including your assessment of the concerns and your proposed actions to address the concerns.

The NRC will be evaluating the concerns and your corrective action during

! future inspections.

If you have any questions please call me.

Sincerely, f k -

^^

f Charles E. Norelius, Director Division Reactor Projects

(

Enclosure:

As stated cc w/ enclosure:

D. L. Farrar, Director l

of Nuclear Licensing _.

I G. J. Diederich, Plant Manager DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, Rill Phyllis Danton, Attorney l General's Office, Er,vir:r c 161 l Ccrtrol Division

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s, ' - - - - - - - - - - - - - - - - - - - - - - - -

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) i BROOKHAVEN NATIONAL LABORATORY

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ASSOCIATED UNIVERSITIES. INC.

Upton,Long Island. New York 11973 l

.(516)282s 7005 Department of Nuclear Energy FTS 666' Building 130 February 28, 1986 PRIO'tITY COUTItG Mr. Nicholas J. Chrissotimos-W U.S. Nuclear Regulatory Commission [ , l$r., -

u3s if Region III Eity_ _re ,.

799 Rooseve1t Road Glen Ellyn, IL 60137 U* l c bj FILE R E

Dear Nick:

RE: FIN A3552 The Brookhaven National Laboratory (BNL) report for the technical review of the LaSalle County Nuclear Station Modification Program is enclosed. This review was conducted during the period February 10- 14, 1986 by Mr. W. Gunther.

If you have any questions or comments, please do not hesitate to call me, or Bill Gunther (FTS 666-7961).

Very truly yours, l /[4 9l-3}ohn H. Taylor, Group '_eader Plant Systems and Eculpter.: Analysis l JHT/slf Enclosure cc: J. Bjorgen, LaSalle (w/ "enclosure)

W. Cunther, Bf'L ( )

R. Hall, BNL ( " "

)

M. Jordan, LaSalle (

)

M. Kerlin, NRC ( )

(

l R. Bari, BNL (w/o" enclosure)

W. Kato, BNL ( )

l File

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O BROOKEAVEN ETIONAL 1ABORATORY TECHNICAL REVIEW EEPORT M)DIFICATION PROGRAM CONTROLS FIN A-3552. TASK CEDER 004 MTE OF REVIEW: February 10-14, 19 86 LICENSEE: Commonwealth Edison Company FLANI: LaSalle County Nuclear Station BNL TECHNICAL SPECIALIST: Mb$

W. E. Gunther

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CONTENTS Page i

I  !

1. BACKGROUND AND 0BJECTIVE.......................................... 1 1

2.

SUMMARY

OF RESULTS................................................

2

3. PERSONNEL CONTACTED...............................................

3

4. INFORMATION REVIEWED..............................................

3 4.1 Procedures.................................................. 4 4.2 Documents...................................................

5

5. DESCRIPTION OF REVIEWED AREAS.....................................

Modification Package Review. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 5.1 5

5.1.1 Setpoint Discrepancy Mod. Package 82-305. . . . . . . . . . . . .

5.1.2 FCRs/ECNs Subsequent to Mod. Approva1................ 5 6

5.2 T r a i n in g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7 5.3 D r awin g Con t r o l s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . : . . . . .

8 5.3.1 Drawing Revision De1ay...............................

8 5.3.2 Drawing Status Review................................

9 5.4 Quality Assurance..........................................

Procedure / Tech Spec Changes Due to Mods.................... 9 5.5 10

6. C O N C LU S I ON S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

11 APPENDEK A Audit Outline..............................................

o .

b

1

1. BACKGROUND AND OBJECTIVES

'The LaSalle County Nuclear Station is a two unit RWR owned and operated by the Commonwealth Edison Company (Ceco). Under the direction of NRC Region III, BNL was contracted to review the modification program controls being employed by CECO during the first Unit I refueling outage.

On February 10, 1986, W. Gunther of BNL arrived at the LaSalle County Nuclear Station to conduct this review with the following objectives in mind:

1. Determine by review if 10CFR50.59 design change evaluations were properly performed, including a written safety evaluation to insure that the change does not affect safety margin or involve an un-reviewed safety question.

2. Determine whether quality assurance and quality control were ap-plied toward the approval and implementation of the modification.

3. Determine that complete testing is planned or has been performed to insure proper design and implementation of the modification pack-age.

4. Review the as-built modifications to determine if the changes were made consistent with NRC and licensee commitments.

5. Determine that system changes have been properly documented in plant drawings and procedures, including licensed operator train-ing.

In order to achieve these objectives, a comprehensive review of selected modification packages was conducted with specific attention given to the 50.59 safety evaluations, identified procedure changes and licensed operator training

! requirements, modification package technical content, completeness and organiza-tion, and post modification testing instructions. The packages were selected with input from the NRC resident inspection group who provided a listing of licensee commitments for the outage along with various outage installation in-formation. An engineering synopsis of selected modifications was provided by the licensee prior to the on-site inspection which permitted the compilation of an audit outline (Appendix A) using various source documents such as LaSalle up-l dated FSAR and the appropriate NRC Inspection and Enforcement Manual Inspection Procedures. The licensee's co-operative attitude, particularly the engineers in the technical staff engineering group responsible for modification package co-ordination, enhanced the inspection effort and permitted the objectives to be met.

2.

SUMMARY

OF RESULTS During the present LaSalle Unit I refueling outage, a large number of mod-ifications are being performed, many resulting from changes required by the A number of specific Facility Operating License, known as license conditions.

rodification packages relating to these license conditions were reviewed in depth to verify that the LaSalle Station modification prograr co=mitments are 1

2 being followed, including proper interf aces between the engineering group, con-struction group, operations, training, and administrative groups involved with procedure and drawing controls.

The LaSalle Modification Program satisf actorily meets NRC requirements and CECO commitments with the following exceptions * )

1. The training of personnel, especially licensed operators, on the system changes resulting from a modification, should be accom-plished prior to declaring the modification operable (see Section 5.2).

2. Modification 83-018 regarding the upgrade of the de system instru-mentation and annunciation should specify that procedures be changed and operator training be conducted prior to returning the modified system to service (see Section 5.5).

3. Conflicting setpoint information provided in the CRD Auto Scram modification package (82-305) should be resolved by approved docu-mentation within the package (see Section 5.1.1).

4. Complete engineering and design of the modification, including a physical walkdown of the proposed installation, should be conducted prior to submittal of the package to the plant (see Section 5.1.2).

5. An excessive turnaround time for drawing changes resulting from modifications exists which could increase the potential for operat-ing errors (see Section 5.3.1).

6. Quality Assurance (OA) involvement in the station modification pro-gram should address the operationally significant aspects of the program (see Section 5.4).

Licensed operstOrc Eh0uld be Cade aVare of procedure and technical 7.

specification changes resulting froc certain saf ety related codifi-f cation activities prior to system operability (see Section 5.5).

i l

8. An inventory of " critical control room drawing" status is performed l

on a quarterly basis. The results of the inventory should be re-viewed by technical staf f canagement to insure appropriate action is taken to correct discovered discrepancies (see Section 5.3.2).

I

3. PERSONNEL CONTACTED The following CECO personnel provided information for this inspection:..

Station Manager *

1. G. J. Diederich Production Superintendent *

2. C. E. Sargent Services Superintendent *

3. R. D. Bishop Shift Engineer

4. H. Hentschel

5. W. Jakielshi Shift Foreman R. D. Crerfor d Training Supervisor

• 6.

P. F. Manning Tech. Staff Supervisor *

7. Station Nuclear Engineering Dept (SNED)*

8. B. K. Wong S. R. Harmon Training Operations Supervisor *

9. Tech. Staff Engineering Group Supvr.*

10. W. C. Kirchhoff Tech. Staff - Mechanical Group Leader

11. C. Ford Tech. Staff Mechanical Engineer

12. K. Keller Tech. Staff Compliance Group Supervisor *

13. T. A. Hammerich T. Bozan Drawings Control Clerk

14. Station QA Supervisor *

15. M. Jeisy Additionally, NRC Senior Resident Inspector Mike Jordan and NRC Resident Inspectors John Bjorgen and Ron Kopriva participated in various phases of this technical review.

• Attended entrance and/or exit meeting.

4. INFORMATION REVIEWED 4.1 Procedures

1. Plant Modifications, LAP-1300-2, REv.19,1/6/86.

2. Guidelines for Development of Tests for Modifications LTP-800-9, Rev. 1, 8/26/85.

, 3. Initial Review of Modification Work Request, LTP-800-7, Rev. 2, 1/19/82.

4. Final Review of Modification Work Request, LTP-800-8, Rev. 1, 1/19/82.

5. Procedure Chance Centrol, LAP-820-2, Rev. 26, 11/1/85.

6. Receipt and Dis t ribution of Drawings , LAP-810-8, Rev. 9, 9/11/85.

7. Control of Drawing Modification, LAP-810-9, Rev. 10, 12/11/85.

8. Field Change Requests , LAP-1300-S, Rev. 6, 1/9 /86.

9. Calibration of 4kV Emergency Bus Loss of Voltage Relays by 0.A.D., LES-GM-119, Rev. 4, 9/20/85.

10. Unit 2 Control Rod Drive Scram Discharge Level Sensing Line -

Check, LIP-RD-603, Rev. 1, 11/21/85.

11. Conduct of Operations, LAP-1600-3, Rev. 27,1/13/86.

12. 250V DC Battery Trouble Annunciator Response Procedure, LOA 2PM01JA108, Rcs. 1, 8/84.

. _. q,

13. 250V DC Battery Charger Trouble Annunciator Response Procedure, 14A 1(2)PM01JA109, Rev. 3, 5/83.

14. Desigm Control for Operations - Plant Modifications, Q.P. 3-51, 11/20/85.

Note: Modification Packages contain multiple station drawings, Pield Change Re-questa (PCR), Engineering Change Notices (ECNs), correspondence, work requests, safety evaluations, proposed tech spec changes, and various check lists included in LAP-1300-2 attachments.

4.2 Documents

1. Task Force Review of Operational History for LaSalle County Station, Units 1 and 2 US NRC Final Report, 9/24/85.

2. LaSalle County Station Units 1 and 2 Request for Information p Under 10CFR50.54(f), Commonwealth Edison Co., 2/4/86.

3. Prompt Change Request (PCR) Approval Form, PCR Log #86-6, PDM

1. L-LOP-85-68, 2/13/86.

4. Modification Package M-1-1-82-305, Control Rod Drive Low Charg-ing Water Headers Scram.

5. Modification Package NF1-1-82-284, Degraded Voltage Protection.

6. Modification Package M-1-1-82-319 Emergency Diesel Generator IB Pre-lubrication.

7. Modifications Package M-1-1-82-310, Relocation of Emergency Diesel Generator 1A Control.

8. Modifica:ica Package M-1-1-82-290, Electrical Penetration Re-dundant Fault Protection.

9. Modification Package M-1-1-83-018, DC Instrumentation and Annunciation Upgrade.

I

10. . CECO Quality Assurance Program Manual for Nuclear Generating

)

' Stations, Rev. 12, 6/5/85.

11. Drawing Change Request (DCR) log of open DCRs.

12. NRC IE Inspection Modules 37700, Design, Design Changes, and Modifications; 37701, Facility Modifications; 37702, Design Changes and Modifications Program; 37828B, Modifications and Changes to Facility and Systems.

4____.__._.

t

5. DESCRIPTION OF REVIEWED AREAS To determine the adequacy of the LaSalle modification program, an audit plan was developed based on the NRC IliE Inspection Modules and on specific The unit in-1 information obtained from the licensee and NRC resident inspectors.

spection as outlined in the audit plan (attachment 1), consisted of a review of specific modification packages to determine the engineering and design technical attributes, and the proper identification of procedure changes, drawing revi-sions, and training requirements. In addition, the completeness of post modifi-cation testing, the application of quality assurance during the entire modification process, and the physical inspection of modification work in prog-ress were reviewed and are discussed in this report.

5.1 Modification Package Review Six Unit I modification packages were reviewed in detail to determine com-pliance with various administrative controls identified in station procedures, and to determine the technical adequacy of the enclosed material. Each package contains the modification approval sheet, work requests, marked up drawings, Engineering Change Notices (ECNs), Field Change Requests (FCRs), a post modifi-cation test procedure, proposed tech spec changes, a 10CFR50.59 Safety Evalua-tion, and an engineering synopsis of the change. Forms which list the affected procedures and drawings as we.11 as the required training and when it is to be accomplished are also included. Installation details and documentation demon-strating quality control and quality assurance reviews are contained in the package as well.

These voluminous packages were found to be technically accurate and com-plete, providing a traceable history of modification design, review, approval, installation, and testing. Adherence to the controls established by station procedure LAP-1300-2, Plant Modifications, was evident as was the knowledge Concerns and/or of recom-l the responsible engineers assigned to each modification.

mondatiens resulting from this aspect of the inspection are as follows:

5.1.1 Setpoint Discrepancy - Modification Package M-1-1-82-305 l

l The Control Rod Drive (CRD) Automatic Scram on Low Discharge Pressure i

l modification package contains conflicting information regarding the instrument setpoint. A detailed calculation was transmitted to the Station (G. Crane to R. Bishop - 8/9/84) which recommended a nominal trip point of 1170 psig and an allowable value of 1140 psig. Other information within the modification package, including a proposed tech spec submittal and a drawing change request, stated that the trip setpoint should be 1157 psig. While it appears that the 1157 psig set point is correct, approved documentation should be included within the modification package which justifies the deviation from the original calcu -

lation.

/

5.1.2 FCRs/ECNs Subsequent to Modification Approval To permit minor changes and/or corrections to be made to a modification subsequent to authorized release of the package for installation, a Field Change

T ray be processed. Of concern in the packages reviewed were the T.t r

= '--~~.~-e . n_ ___ __ _ _

type and number of errors or omissions in the submitted design package which required FCRs or ECNs to resolve the problem. These errors indicated a lack of Several examples are knowledge and awareness of plant physical configuration.

given below:

• In modification package M-1-1-82-305 for the CRD discharge pressure automatic scram addition, ECNs were required to relocate proposed cable terminations in the Rector Protection System (RPS) panels "due to existing cables presently terminated," correct cable separ-ation problems, supply mounting details for the time delay relays and terminal blocks, and to relocate pressure transmitters. In addition, a number of FCRs had to be written to change the instru-ment stand heights to permit proper instrument tube sloping, and to change wire codes, terminal block numbers and labels including an incorrect annunciator label (Righ Pressure instead of Low Pres-sure). An error in the setpoint specified (1267 vs 1157), and re-routing of hangers and conduits due to interferences were also cor-rected through FCRs in this package.

• In modification package M-1-1-82-284 for installation of backup re-lays for monitoring safety system bus voltage, ten FCRs were re-quired to obtain relay mounting requirements, correct relay wiring diagrams, and to resolve wiring discrepancies.

+ For the EDG 1B pre-lubrication modification, M-1-1-82-319, which involves installation of a new 3 gym pump to continuously supply lube oil to both the turbo-charger bearings and engine accessories, eighteen FCRs were required to resolve problems associated with pump relocation due to interferences, incorrect thermal overload settings, and hanger and piping rerouting.

While the number of FCRs is a concern, it is the basic nature of the The chancer required that is a concern that should be tracked in the future.

licenece etcted that a co=mittent has been made to require Formalengineers to physi-incorporation of this cally valkdcen the design prior to site submittal.

commiteent into the Modification Program should improve the quality of the pack-ages and decrease the potential for a design or installation error.

5.2 Training Prior to the return to service of operationally significant systems that have been modified in a manner that affects the system operation, it is impera- Simi-tive that operating personnel be completely knowledgeable of the change.

larly, certain modifications may require instrument technician, electrician, or maintenance mechanic training, but generally their training on a modification is based upon f amiliarization with the resulting procedural changes-and may be accomplished subsequent to modification completion.

LaSalle Station management acknowledges the importance of training person-nel on modifications, and has incorporated into the Modification Program several r.echanisms for evaluating and implementing training requirements during the mod-

!c, review and apornval process. These include:

- -- . . _ . ..y. .__ . _ _ _ _

• Sign off by the Training Supervisor on the Modification Approval Sheet indicating that the Training Department is notified of the modification. This notification includes an Engineering Synopsis describing the change.

• Approval by the Operating Engineer and the Training Supervasor of a Training Summary Sheet (attachment J of LAP-1300-2) which notes if

" Training required prior to Mod Operation," and what the training emphasis is. This same form is also used by the Tech. Staff Super-visor to notify the Training Supervisor when the modification is completed.

• Sign off by the Training Supervisor on Form 3-51-1, the modifica-tion approval sheet, that training is complete. The procedural

- wording explaining this sign off (step 34) states that the Training Supervisor " Assures that training required prior to operation is performed."

The method most of ten used by the Training Department to train operating This is backed up by personnel on modifications is through required reading.

classroom training if questions arise or additional information becomes availa-ble. Several of the required reading write-ups for the modification packages reviewed were read and were found to accurately reflect the operating signifi-cance of those modifications. In general, modification training is properly addressed with the significant exception discussed in the following paragraphs.

Through discussions with Training and Operating Department personnel, it was learned that sign off by the Training Supervisor on the modification appro-val sheet of " Training Complete" indicated that the material had been prepared It and, for the case of required reading, had been distributed to Operations.

was not indicative, as the procedure LAP-1300-2 states, that the training was performed. An operator responsible for unit operation with a modified system (s) could therefore potentially not receive training on the modification for up to (D days following the return of the modified system to service. The 60 days ccrresponds to the CECO cocpletion consitment for this mode of notification.

This is unsatisfactory and does not meet the intent of the Modification Progran.

The licensee concurred with this potential problem and took action through the use of a Prompt Change Request (PCR #86-6) to provide an alternate method of notifying operators of important modifications prior to the operator assuming responsibility for the shift. While the action taken does not meet the full in-tent of the procedure, as a temporary measure it does provide reasonable assur-ance that operators taking the watch are aware of the modifications and how they affect system operation. A permanent change should be accomplished in the very pear future - certainly prior to Unit I start-up. __

5.3 Drawing Controls Control of drawing changes resulting from a station modification is criti-cal to assuring that an accurate record of station equipment design and opera-tion is maintained throughout the plant life. Drawing controls are imposed in the LaSalle Modification Program through the following means:

- ~ - - _ _ . _ _ _ _ _

• Two copies of drawings are submitted with any Desi'gn Change Request (DCR) sesociated with a modification, one of which is maintained at Central files in an "Open DCR File" and which any be accessed by station personnel.

• For certain special drawings, known as " critical control room draw-ings" the hard copy is marked up by the responsible engineers to reflect the as built condition. The mark up of those drawings is accomplished prior to system operation, sad is reviewed and ap-proved by the Tech. Staff Supervisor.

• Aperture cards in the Control Room, Tech. Support Center, and Cen-tral Files are marked with the modification number or the outstand-ing DCR number indicating that the drawing is not current.

+ A quarterly inventory is performed to verify that the Critical Con-trol Room Drawings are accurate.

These controls along with several other informal tracking mechanisms pro- the vide a satisf actory means for assuring that drawings exist which represent current plant configuration. A review of the implementation of these controls 1 modification packages revealed that these controls for several of the Unit were being properly applied with the following exceptions.

5.3.1 Drawing Revision Delay An excessive amount of time (6 to 8 months) exists from the initiation Followingof a drawing change request to the time a revised drawing is received.

' the present refueling outage of Unit I where numerous modifications are being implemented, it is conceivable that marked up or outdated drawings and aperture This cards will exist in the control room for 6-8 months of power operation.

increases the probability of an error occurring in routine or emergency condi-tions where drawings may be used in the decision making process, While suchthe as mark-up during i

valve lineups, equipment tagouts, or systen trouble-shooting.

l of certain drawings declared by Operations to be special prior to cod. operabil-

! ity alleviates part of this concern, it should be noted that the critical con-j trol room drawings do not include drawings associated with the electrical dis-tribution system, emergency diesel generator controls, Reactor Core Isolation i

i Cooling (RCIC), and normal feedwater and reactor water level controls.

It is therefore necessary to insure a faster turnaround of drawing changes that are icportant to plant operation. Consideration should be given to review-ing and revising the critical control room drawing list to insure that complete and accurate drawings are available to the operator for the "P& ids" and "Elec-tricals" associated with those systems required for safe plant operation. _

5.3.2 Drawing Status Review An inventory of critical control room drawings and the aperture cards Io-cated in the control room, tech. support centers, and central files has been conducted on a quarterly basis since February 1985, to verify that drawings have been redd: ' and aperture cards have been marked as appropriate with any and

1

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The most recent inventory conducted during the week of all outstanding 10, 1986 DCRs.found that two critical control room drawings were missing and February Of concern is that the cog-one aperture card was not the latest revision.

misant engineers' action was simply to replace the missing drawings and update the obsolete aperture card rather than determine the cause for the discrepancy.

The quarterly inventory performed as per LAP-810-9 should be reviewed /acknow ledged by plant asnagement to insure that proper long term cause of the problem.

5.4 Ouality Assurance (QA)

The Station Quality Assurance (OA) Department is involved with the modi-fication approval procecs as specified in the Modification Program procedure The OA Supervisor's signature on the modification approval sheet LAP-1300-2.

indicates that he has reviewed the A modification second review installation by the QAand approves Supervisor is per-declaring the mod. operational.

formed to verify that the modification documentation is complete (Reference steps "U" and "AA" of LAP-1300-2) .

Direction is provided to the QA Supervisor via the CECO Quality Assurance Program Manual which contains Q.P. #3-51, Design Control for Operations - Plan i

Modifications, and an audit check list, Evaluation Area No. 3 - Design Drawings The documents adequately address the Modification Program and Document Control.

controls that should exist, and the OA responsibilities to verify that these controls are in place, with the exception that insufficient QA commitment to Modification Progran implementation verification exists.

The recommendation to expand QA involvement beyond a cursory documenta-tion / administrative verification is based on a review of several audits per-These audits did not address the important require-formed by QA in the past.

ments of the Modification Program stated in LAP-1300-2, including the commit-cents for training personnel, updating procedures, These andattributes updatingarecritical important control room drawings prior to modification operability. and are part of the responsibility components of the modification installation, Veri-accepted when the QA sign off on the modification approval s regularly to provide the quality assurance committed to in the Modification Pro-gram.

5.5 Procedure / Technical Specification Changes Due to Modification The Modification Program provides a satisfactory mechanism for identifying Proce-procedural and/or tech spec changes that may result from a The modification able to station personnel via a computerized tracking program.

packages reviewed were found to properly document the procedures which w fected by the modification and, in some cases, the revised procedures were al-ready approved. Similarly, for those modifications that resulted in a tech spec l change,the change. In addition, a computerized tracking mechanism was available final ap-to statu of netr in the modification review process provider a second check that;:cposed i ne tech

- ' the modification be enedftt,ned on NRC seceptance

" r re .

l l

i For those modifications which the operating and training supervisors decide must have procedures revised prior to declaring the mod. operable, it is apparent that a potential for personnel unfamiliarity with the change could exist at the time the modified system is returned to service. In procedure LAP-820-2 regarding station procedure control and distribution, it is noted in step 16 that "Af ter Station Manager authorisation... the Procedure Change Synopsis

[is] promptly routed to the Training Supervisor for training as necessary."

During the time that it takes to prepare and distribute training material to all of the licensed operators and for them to read and understand it, the modified system could be returned to service. While the station decision not to train personnel on unappoved procedures is reasonable, licensed operator cognizance of procedural changes resulting from a modification should exist at the time the mod. is declared operational. Likewise, the operator must be aware and know-ledgeable of the implication of any tech spec changes resulting from the modifi-cation prior to the declaration of operability.

A second concern arose from a review of modification package M-1-1-83-018 involving the addition of de system instrumentation and annunciation in the con-trol room. The determination by the Responsible Engineer, and approved by the Operating and Training Supervisors, was that procedure changes and training could be conducted af ter modification operability. Because this mod. involves changes to annunciator response procedures (ARP) including one significant ARP for 250V DC Battery Trouble, it is recommended that at least a portion of the procedures and training be accomplished prior to mod. operation. The licensee agreed to have ARP IPM01JA108 approved prior to declaring the modification oper-able.

l 6. CONCLUSIONS i

' Based on a detailed review of several modification packages being proces-sed during the current LaSalle Unit I refueling outage, coupled with an examina-tion of the LaSalle Modification Program procedures, and discussions with LaSalle personnel, it is apparent that controls have been established and are being properly implemented at LaSalle, with the exceptior. of the items described within this report.

Recent Modification Program changes initiated by the licensee, along with the actions necessary to address the concerns expressed in this report, should result in achievement of the desired controls.

i AUDIT OUTLINE FIN A-3552 - TASK ORDER 4 LA SALLE OUTAGE MODIFICATION WORK CONTROLS 2/10-14/86

1. Review modifications for 10CFR50.59 evaluations including sample of non-safety related mods.

2. Selected safety related modifications reviewed for the following:

- control room drawings reflect changes

- procedures are revised as necessary

- testing is planned or has been performed to verify o'perability

- licensed operator training completed prior to system operation

- review and approval process for modification implementation and testing is assured

3. Application of quality assurance and controls during design, implementation, and testing process.

4. Physical inspection of work in progress:

- personnel qualifications QA/QC involvement

- impact on plant considered - backup systems maintained operable

- impact on adjacent systems including instrumentation and cabling

- appropriate controls such as fire watches are maintained Partial List of Modifications to be Reviewed

- scram discharge volume vents and drains and level monitoring instrumentation; modification nunber M-1-1-82-263

- control rod drive low discharge pressure automatic scram during startup and refueling; modification number 1-1-82-305

- second level of undervoltage relaying protection for safety bus; License Condition #20

- emergency diesel generator upgrade including pre lube system; modification number 1-1-83-129

- addition of control room instrumentation for de parameters; nodification number 1-1-83-018

. 2 .- - - . - . .- - ._ _ . _ _ _

- installation of redundant. fault current devices for high voltage reactor containment electrical penetrations; modification number 1-1-82-290

- RCIC steam line break logic modification; modification number 1-1-81-8. l l

1 i

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I

Q Commonwealth Edison

, n wee asems si t.chiceno.eimoi.

m py w poet on.c. een ter Q-i Aser Chicago,timone 90690 0767 PRIORITY ROU12"3 Ii m is . .. . , ;

June 30.1986

• -g:A N' - i? --v:

d <bi b ,!

Mr. James G. Keppler FIL%

Regional Administrator U.S. Nuclear Regulatory Commission Region III

'l99 Roosevelt Road Glen Ellyn, IL 60137 subject: LaSalle County Station Units 1 and 2 Response to Brookhaven National Laboratory Report on Modification Report Program Controls FIN A-3552 NRC Docket Nos. 50-373 and 50-374 Reference (a): C. E. Norelius letter to Cordell Reed dated April 9, 1986

Dear Mr. Keppler:

This letter is in response to the concerns identified in the enclosure to reference (a). tv==nnwealth Edison has carefully 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 the extent of the audit, we take soce pride in the report conclusion "...it is apparent that controls have been established and are properly implecented at LaSalle...*.

If you have any Tui ther questions regarding this matter, please refer thee to this c H i e.

Very truly yours, nnis L. Farrar Director of Nuclear Licensing i la Attachment cc: NRC Fesident Inspector - LSCS Dr . F. , r.ournia r.. C. Parker - R."

\

t 7&oL .2ao - - _ - . . __ _

t.

RTTAGBENT .

1. The training of personnel, especially licensed operators, on the system changes resulting from a modification, should be accomplished prior to declaring the modification operable (See Section 5.2).

nominstrative Training dociaments and procedures are under revision to implement more effective methods of informing operators of significant modifications prior to returning the affected system to operable status, summaries of selected modifications are being posted shift in the control turnover room for review by onshift licensed operators.

procedures for licensed operators will require encoming watchstanders to reviewThis andadditional initial the measure summaries augments ofthe recent significant modifications. existing training system which updates ope changes through individually issued reading packages and regularly scheduled classroom sessions.

Control documents under revision to address this concern inclu 1AP 1300-2, Modifications, IAP 200-3, shift change, and theThese revisions training ACHI for License Requalification.

- completed prior to unit restart.

2. Modification 83-018 regarding the upgrade of the de syste changed and operator training be conducted prior to returning the codified system to service (see section 5.5).

Modification 1-1-83-ole upgraded some of Unit One Control Room DC Instrumentation and an annunciator The modification to be consistent provided remotewith that already installed on Unit Two.

information to the Unit One control room The operator, previously only change is easily available from a local control panel.

discernible by the control room operator and requires no additional knowledge or skills to ef fectively utilize the information provided.

The new annunciator and response procedures being provided on Unit Operators One are identical to those already in use on Unit Two.

are already familiar with the use of the annunciator and Based on the above information, a review of this procedure. modification by the Operating Engineer and Training Supervisor resulted in a decision not to require training prior to modification installation but rather to train operators following Considering that no significant deviation from installation.

normal conservative r!rn+ operating practice would result from an user.gc, the decision not to train prior to operator unaware c' tna ' cppropriate.

r ad ins t r.11t.t i e-

a l

The determination of the procedure changes required prior to the modification operability is based on the operators' needs for operating the system after the modification is placed in service.

annunciator alarm In the case of modification package M-1-1-83-018, procedures were being added for 250V Dc Battery Trouble due Theto f changes in the DC instrumentation for cont ol room indication.The additional alarm aids the operator in identifying a problem.

annunciator procedure response informs the operator to investigate These the cause and notify the shift supervisor of the problem.

are responses which are typically expected of a trained licensed  ;

Annunciator response procedure LOh-1PM013-A108 was '

operator.

revised to reflect the changes in the modification prior to the l 250V DC instrumentation mod work approval for operation.

3. Conflicting setpoint information provided in the CRD Auto Scram modification package (82-305) should be resolved by approved documentation within the package (see section 5.1.1).

Modification Package M-1-1-82-305 included the calculations The for the J low pressure setpoint for CRD charging header pressure.

General Electric (GE) calculations determined a required Thesetpoint GE of 1157 psig was needed to meet the design conditions.

letter reconnended a setpoint of 1170 psig on the basis that the 20 j PSI increment scale on the Rosemount TripNuclear The station Units would be used for Engineering l calibrating the instrumentation.

Department (SNED) 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 froc SNED has been obtained to clarify the setpoint specified in the Modification Package.

4.

Complete engineering and design of the modification, including a physical walkdown of the proposed installation, should be conducted prior to submittal of the package to the plant (see Section 5.1.2).

The concern expressed over the PCR changes made on Modification Packages during the Unit 1 Outage has been noted during the planning and preparationInofparticular, Modifications for theNuclear the Station upcoming first refuel outage of Unit 2.

Engineering Department (SNED) is compiling installation tolerancesEngi in one document directed that Unit (Master 2 outageTolerance document).

modifications previously sent to 1.aSalle be reviewed for similar design problems, including conflicts reviewed with the current Station equipment configuration, Additionally,that were experienced during the Unit I refuel outage.

,e . _ . _ _

6 selected modifications to be implemented at Unit 2, that had a large nimber of PCR's when installed at Unit I during the current Unit 1 outage, have been or will be revised to attempt to pick g these FCR's in the Unit 2 designs before the Unit 2 outage starts.

Finally, a field verification walkdown for constructability of major modifications is scheduled to be performed.

These actions sho.Od result in fewer design changes of the type identified as concerns in the Technical Review Report, during the installation phase of Unit 2 first refueling outage modifications.

5. An excessive turnaround time for drawing changes resulting from modifications exists which could increase the potential for operating errors (see section 5.3.1).

As part of the Proactive Management Plan which was developed in the last quarter of 1985, Station Nuclear Engineering Department has directed the A/E to reduce the turnaround time for the processing of Drawing Changes, especially in the case where critical control room 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 outstanding changes to ensure the operators are aware of present plant conditions.

6. Quality Assurance (QA) involvement in the station modification section 5.4).

In response to the concerns relative to Quality Assurance Department in this section, the second statement in the first paragraph coces from the Procedure LAP 1300-2 and points out the fact the Step 38 of that Procedure is not correct and that it does not follow the requirements of the Quality Assurance Procedure 3-51. Accordingly, this Procedure will be required to be corrected. '

Quality Assurance is not involved at this point but rather after the item is declared operational. Instead, in reference to QP 3-51, Steps C.28 through C.33, Quality Control has responsibility for verifying satisfactory completion 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 next step is for Quality Control to review the modification tests, to assure all steps are properly i

signed off, test data was recorded and meets acceptance criteria, etc.; fo11 cued by the Technical Staff Supervisor and Training Supervirer ve rification and then authorization of operation to the trMifice eqty ent by the Operating L g nect or Shift toEngineer.

Station M operation, the ---Ne is sent Afte

, w verify requiru h m t- m retirf m r$1v

(

cc  !.

E

,e = \l In reference to the last paragraph, a quality Assurance audit was

, performed on a selection of modifications to verify compliance to the commonwealth Edison Company guality Assurance Manual requirements and procedures and included coverage of training 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.

Also, the DP 3-51 step C.34 was revised recently to clarify that each modification requires field verification, either by in-process witness / hold points, surveillances, or by specific checking of the completed work that the work package has been satisfactorily completed prior to signing the Modification Approval Sheet.

• 1. Licensed operators should be made aware of procedure and technical specification changes resulting from certain safety related modifications activities prior to system operability (see section 5.5).

The station administrative procedure for controlling modification (LAP 1300-2) 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 Specification and procedure changes relating to critical modifications prior to returning the affected system to operable status. These reviews will be accomplished in conjunction with shift turnovers as described under step 1) of this document.

l l

Again, this additional measure aug:ents the existing training l

system which updates operators on Technical specification and procedure changes through individually issued reading packages and regularly scheduled classroom sessions.

Revisions to LAP 1300-2 will be cocpleted prior to unit startup.

i

8. An inventory of " critical control room drawing" status is performed on a quarterly basis. The results of the inventory should be reviewed by technical staff management to insure appropriate action is taken to correct discovered discrepancies (see Section 5.3.2).

The intent of the inventory check of critical control room drawings is to ensure that the Operating Department is supplied with the current revisions pertaining to these drawings. Due to the large

( usage of the drawings during plant operation, cards and drawings i

cou!6 ?t rirplaced. LAP 810-9 vill be revised to include a review by k e rietf Management to ensuu. that major problems do not rrected.

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