ML20236U409
| ML20236U409 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/24/1998 |
| From: | Dacimo F COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CAL-RIII-96-08, CAL-RIII-96-8, NUDOCS 9807300123 | |
| Download: ML20236U409 (6) | |
Text
Commonw r.ilth 1:dnon Compan) lxbile Generating Nation 2G)1 North 21st Road a
M.trxilles,11. 613 i19757 Tel HI5 3574>T61 July 24,1998 i
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United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Information Regarding NRC's Supplement to Confirmatory Action Letter Rlll-96-008 LaSalle County Nuclear Power Station, Units 1 and 2 Facility Operating License NPF-11 and NPF-18 j
NRC Docket Nos. 50-373 and 50-374
References:
(1)
H.J. Miller (NRC) letter to R.E.Querio (Comed) dated July 2,1996, " Confirmatory Action Letter."
(2)
H.J. Miller (NRC) letter to R.E. Querio (Comed) dated July 5,1996, " Supplement to Confirmatory Action Letter Rill 96-008."
(3)
A.B. Beach (NRC) letter to W.T. Subalusky, Jr.
I (Comed) dated April 14,1997, " Supplement to l
Confirmatory Action Letter Rlll-96-008."
g (4)
G.E. Grant (NRC) letter re NRC Inspection Report No. 373/98004; and Exercise of Enforcement Discretion, dated April 10,1998.
(5)
W.T. Subalusky (Comed) letter to NRC, dated August 27,1997, as supplemented by F.R.
Dacimo letter to NRC dated April 30,1998.
f d,3 (6)
NRC Inspection Report No. 373/97014, dated October 17,1997.
(7)
C.J. Paperiello (NRC) letter to O.D. Kingsley (Comed), dated June 15,1998, " Closure of LaSalle County Station Confirmatory Action Letter Nos. Rlll-96-008 and Rill-96-008A.
Since July 1996, the Nuclear Regulatory Commission (NRC) has issued one Confirmatory Action Letter (CAL), and two supplements thereto, to Commonwealth Edison Company's (Comed) LaSalle County Station.
I 9807300123 983724 PDR ADOCK 05000373 p
PDR A i:nicom company O
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(References 1 through 3) The purpose of this letter is twofold. First, it
, sumrnarizes the actions taken by Comed and the NRC Staff in closing out the CAL and its first supplement -- both of which focused narrowly on the clogging of non-essential service water strainers.
Second, the letter describes the comprehensive corrective actions implemented at LaSalle in response to the more general human performance, material condition, corrective action and engineering support and design issues underlying the original service water system events leading to Comed's decision to shutdown of both LaSalle Units. This summary supports close-out of the remaining supplemental CAL issues.
Backaround On July 2,1996, the NRC issued a CAL regarding potential blockage on non-essential service water strainers. (Reference 1) It directed Comed to complete three actions related to the clogging of non-essential service water strainers and to make available documentation regarding these actions to an NRC Augmented inspection Team. The NRC issued a supplemental CAL on July 5,1996, expanding the scope of corrective actions in response to l
newly discovered potential blockage in a residual heat removal cooling l
water system suction strainer. (Reference 2) After implementation of the
. extensive corrective actions, the NRC conducted inspections and closed these CAL issues. (References 4 and 7) l l
In reviewing the events underlying the CALs, Comed discovered several deficiencies regarding the material condition of the LaSalle Units that extended beyond the condition of the service water system. On l
September 20,1996, Comed shut down LaSalle Station Unit 2 for planned refueling outage L2R07. Furthermore, on September 22,1996, Comed shut down LaSalle Unit 1 to repair the Number 4 Turbine Control Valve 4TCV i
(forced outage L1F35).
After the shutdown, Comed determined that neither Unit should restart prior to resolution of material condition, human performance, corrective action process, and engineering support and design deficiency issues identified by Comed and the NRC. On April 14,1997, the NRC issued a second supplement to the original CAL that acknowledged Comed's decision to not restart its Units. (Reference 3) The second supplemental CAL directed Comed to: (1) formally docket a restart plan for the LaSalle Units; (2) keep the NRC staff informed of the projected startup date for the lead Unit; (3) meet with the NRC staff on approximately a monthly basis to discuss startup plan implementation and the extent to which the evaluation criteria for corrective action effectiveness have been met; and (4) meet with the NRC 2
once Comed's high intensity training program for LaSalle operators was complete to discuss training results and indicators used to evaluate the ability of licensed operators to startup and operate the LaSalle Units.
Comed has met its obligations relative to these requirements. (See, in part, l
References 5 and 6)
The second supplemental CAL also directed Comed to meet with the NRC, i
once it concludes that one of its Units at LaSalle County Station is ready for restart, in order to discuss the basis for that conclusion. A public meeting satisfying this CAL item is scheduled for July 24,1998. Finally, this letter documents the bases for Comed's conclusion that it has resolved the specific issues raised in the second supplemental CAL relative to I
deficiencies in material condition, human performance, corrective action processe.s, and Engineering support and design deficiencies.
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Summarv of CAL issue Closure 1
A summary of key corrective actions and results in each issue area is set forth below. These summaries are derived from the LaSalle County Restart Action Plans which are available onsite for review.
Human Performance l
Several actions have been taken at LaSalle County Station to improve this area of performance. LaSalle management took initial actions that resulted in a step change in human performance. Short-term actions included publicizing events, such as Station or Department event clock resets, and increasing individual accountability when events take place. These actions were focused on establishing clear management expectations, ensuring workers understood and applied these expectations, and establishing clear accountability for resolving human performance weaknesses and eliminating repeat human performance errors.
Despite these short-term improvement initiatives, human performance continued to be cyclic in nature. Thus, additional actions have been implemented to ensure lasting improvement, including educating the work force in human error reduction techniques, use of human error reduction tools, and introducing leading indicators for human performance so that each department head can take preemptive actions to correct behaviors, based on observations, prior to significant events. As a result of both the short-and long-term initiatives, human performance is on an improving trend, as reflected in the Station's Event Free Clock and Error Rate indicators. in addition, LaSalle County Station personnel are committed to achieving long-term human performance improvement. The combination of l
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1 improvement initiatives, results achieved to date, and personnel commitment to I,opg-terrn human performance improvement, support the conclusion that LaSalle Unit 1 is ready for restart and operation.
Material Condition I
Extensive reviews have been undertaken to identify material condition deficiencies at LaSalle County Station. The primary effort -- the System Functienal Performance Review -- resulted in an inspection of 42 systems (those with the greatest contribution to core damage frequency risk) to ensure that problems such as configuration discrepancies and degraded components were identified and captured in the Station's corrective actions process. Station management established stringent criteria to screen these issues to ensure that problems with the potential to adversely impact safe i
Unit 1 restart or operation were scheduled for resolution during the Unit 1 outage. A Unit 1 outage plan was established and implemented in which each of these work items was resource loaded, resolved, and subsequently tested.
This effort resulted in resolution of eight major programmatic material j
condition challenges, including SBM switch and Klockner-Moeller relay l
replacement, and hundreds of component-or system level material I
condition problems. The final step of the process, to check the adequacy of plant material condition on a system-by-system basis, was the System l
Readiness Review. The System Readiness Review included a review cf
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work and testing completed, as well as remaining unresolved issues
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(individually and in the aggregate), to ensure systems are prepared to l
support restart and continued reliable plant operation thereafter. For l
example, the reactor water cleanup system, a source of significant operational problems in the past, has undergone a major overhaul, and the System Readiness Review has been completed and this system is prepared to support restart and power operation. Collectively, the issue identification, screening, resolution and review process gives Comed confidence that, upon completion of final physical work and testing, LaSalle Unit 1 is ready to restart.
Corrective Action Process As part of its restart efforts, LaSalle management implemented a new corrective action process at the Station and took steps to ensure line management ownership of that process. Through the corrective action restart action plan, steps were taken: to bolster the root cause determination process; improve turnaround time and report quality; to ensure corrective actions are effective; and to improve the use and usefulness of the problem I
identification and resolution process.
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Subsequent evaluations of program effectiveness demonstrated that additional improvements were needed. As a result, additional screening of Engineering issues has been performed to ensure they are appropriately prioritized for resolution and to institutionalize screening of Engineering issues going forward. Site databases have been reviewed to ensure that all issues are receiving appropriate treatment via the Station's corrective action process. Several actions also were taken to increase Senior Management involvement in the corrective action process.
As a result of these actions, improving trends have been observed in corrective action performance indicators, such as a reduction in overdue corrective actions and repeat events, and an increase in the number of Problem identification Forms workers are writing. These actions and data demonstrate that worker and management support for the corrective action program has resulted in improvements that ensure the corrective action process at LaSalle County Station is prepared to support Unit i restart and reliable operation.
Enaineerina Support and Desian Finally, LaSalle County Station has taken extensive actions to ensure that processes and procedures used to maintain the plant's design basis and produce Engineering products result in systems and components that are capable of fulfilling their intended functions. Accordingly, improvement actions have been undertaken to upgrade the capability of Engineering personnel and to ensure Lafane Engineering is ready to support Unit 1 restart and continued, reliat,% operatios.
Engineering capability has been improved by creating a qualification process for Engineering personnel that emphasizes the importance of l
maintaining system design basis information. While training and other improvements were ongoing, interim measures were implemented to maintain the quality of Engineering products, including the use of an Engineering Assurance Group and experienced contract Engineers to mentor less experienced engineers and Engineering managers.
Organizational changes also have been made, including creation of a Design Engineering Group that has sole responsibility to act as the design l
authority for LaSalle County Station. Additionally, there has been increased emphasis on maintenance of design basis in other areas within Engineering, such as in System Engineering.
Steps taken to ensure plant operational readiness include extensive reviews of the design and material condition of plant systems to gain confidence in the adequacy of engineering and design to support plant restart and continued, reliable operation. These reviews included the System 5
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Functional Performance Review, design reviews, and configuration control reyiews. The reviews conducted were of sufficient depth that LaSalle l
management is confident issues with significant safety impact w,re j
identified for resolution. As described in the Material Condition section I
above, these issues have been screened and significant issues have been resolved during the Unit 1 outage. In response to identified weaknesses, Engineering processes have been improved to ensure the prompt and l
effective resolution of any emerging Engineering issues. The System l
Readiness Review process ensured that any remaining unresolved issues, individually and in the aggregate, do not adversely impact Unit 1 restart or operation.
Conclusion It is Comed's determination, based on the actions summarized above, that the issues identified in the CALs have been resolved and no longer preclude safe restart and operation of LaSalle County Station Unit 1. Additionally, 1
programs necessary to ensure continued improvement in material condition, i
human performance, corrective action processes, and engineering support and design, have been institutionalized at LaSalle County Station.
With respect to Unit 2 restart, an approach similar to Unit 1 will be used.
Significant improvements to the material condition of the Unit will be made to j
ensure that systems will function and be operated consistent with their design basis. Other aspects to be applied to Unit 2 include improvements in 1
l labeling, area decontamination, hot spot reduction, detailed look-backs at Unit 2 issues and a thorough test program. To enhance the overall program,
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l we will add the lessons leamed from Unit 1 restart on Unit 2. This will result in a safe Unit 2 startup and long, uneventful run.
j If there are any questions or comments concerning this letter, please refer l
them to Harold D. Pontious, Jr., Regulatory Assurance Manager.
(815) 357-6761, extension 2383.
t Respectfully, 7
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Fred R. Dacimo Site Vice President LaSalle County Station cc:
C. A. Paperiello, Acting NRC Region lil Administrator M. P. Huber, Nf1C Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle F. P"'iolek, Office of Nuclear Facility Safety - IDNS 6
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