ML20236F090
| ML20236F090 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/26/1998 |
| From: | Dacimo F COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9807020021 | |
| Download: ML20236F090 (9) | |
Text
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Onumonwcalth Edmn G,m[uny LAalle Generating Station
~
2601 North list Road )
Marwilles. lL 613 41-937 Tel 8143574761 l
June 26,1998 United States Nuclear Regulatory Commission )
Attention: Document Control Desk Washington, D.C. 20555 l
Subject:
Supplemental Response to NRC's Request for Information Pursuant to 10 CFR 50.54(f) Regarding Adequacy and Availability of Design Bases Information LaSalle County Nuclear Power Station, Units 1 and 2 Facility Operating License NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374
References:
(1) J M. Taylor (NRC) letter to J.J. O'Connor (Comed) dated October 9,1996, " Request for Infom1ation Pursuant to 10 CFR 50.54(f)
Regarding Adequacy and Availability of Design Bases Information" (2) T.J. Maiman, W.T. Subalusky (Corned) letter to J.M. Taylor (NRC) dated February 6,1997, Response to " Request for Information Pursuant to 10 CFR 50.54(f) Regarding Adequacy and Availability of Design Bases Information" Reference (1) requested that information be provided regarding the adequacy and availability of design basis information. Reference (2) provided LaSalle County Station's response. Reference (2) concluded with the following statement:
"We currently conclude that the existing design and configuration control processes are adequate if implemented effectively. Our 1 confidence in the effectiveness of past management and k implementation of these processes has been reduced by the
( . ,i deficiencies we have encountered through continuing \
self-assessment, and the potential extent of condition referred to above. We continue to aggressively pursue identification and correction of deficiencies. The results of these efforts are ,
available for your review. We will be submitting a follow-up letter O M, .
to Region Ill to report the results of our continuing p\h self-assessments and associated corrective actions."
9807020021 980626 PDR ADOCK 05000373. ,
P PDR w
1 1 . .
i The purpose of this letter is to communicate those actions taken at LaSalle County Station that provided Comed a basis for concluding we have confidence in the adequacy and availability of design bases information and configuration control processes, such that the plant will be operational consistent with the design basis at LaSalle.
To address deficiencies identified following the June 1996 service water event and the shutdown of Unit 1 for material condition issues and Unit 2 for a scheduled refueling outage, LaSalle Management developed a Restart Plan to prepare the station for startup and continued safe, reliable operation i thereafter.~ The Plan includes seven Restart Strategies calling for reviews, l assessments, corrective actions, and program improvements in the foliowing areas:
- 1. Safe Plant Operation
- 2. Human Performance
- 3. Plant Material Condition
- 4. Effective Engineering Support
- 5. Corrective Action and Self-Assessment i
- 6. Training
- 7. Process improvement !
1 The assessments and corrective actions performed as part of these I strategies have been routinely discussed in the monthly NRC Public Meetings regarding LaSalle Restart. l Although all seven strategies play an important role in safe operation of the facility, Effective Engineering Support Strategy (4) and Corrective Action and Self Assessment Strategy (5) directly tie to providing the basis for determination that the plant will be operated consistent with the design basis. Documentation for each of the seven strategies is available onsite for review.
Effective Engineering Support Strategy - Restart Strategy 4 Effective Engineering Support is comprised of severalimprovement l initiatives. These initiatives and the specific actions taken at LaSalle to implement them are fully described in the closure documentation supporting Strategy 4 that is available onsite for your review. The more significant programs, which contain actions needed to re establish reasonable assurance that LaSalle County Station is in conformance with its design basis, are:
- 1. System Functional Performance Reviews
- 2. Design Reviews
- 3. Configuration Control Evaluations
- 4. System Readiness Reviews
- 5. Engineering Capability
The comerstone of LaSalle's review of the potential consequence of lapses in design and configuration control is the System Functional Performance Review (SFPR). The SFPR compared the design functions of 42 key plant i systems to the as-found and previously tested configuration. The risk importance of the 42 systems reviewed in the SFPR covered approximately 98% of the contributors to Core Damage Frequency as defined in the LaSalle Probabilistic Risk Analysis. Completion of necessary actions identified during the SFPR provides reasonable assurance that these systems will perform their intended design functions. In addition to required surveillance, post-maintenance and modification testing, system testing to resolve SFPR issues is also being performed.' Reviews of Technical Specification surveillance procedures were performed to verify testing of the appropriate function and revised as necessary. Based on findings from SFPR, the surveillance procedure review was expanded to non-SFPR Technical Specification systems. These functional reviews and system tests provide Comed with reasonable assurance that the systems and components relied upon for safe operation will function to meet their design bases requirements.
As a complement to SFPR, a Design Review was performed on selected systems or portions of systems to investigate and characterize potential, substantive design problems. The Design Reviews looked at the original design basis development and the control of the design basis over time using the NRC's Safety System Functional Inspection (SSFI) methodology.
Design reviews were conducted on four systems (Control Room Ventilation, Auxiliary Electric Equipment Room Ventilation,125 Volt Direct Current System, Core Standby Cooling). These systems were selected based on historical problems identified as part of ongoing design control self-assessment activities, as well as, those problems related to design control, NRC inspection findings and industry experience. The SFPR identified substantive design issues on two other systems (Standby Gas Treatment and Primary Containment Purge and Vent). Design reviews were also completed on these two additional systems.
In summary, the SFPR and Design Reviews concluded that analytical and design control processes were, in general, appropriately applied to the designs. Ineffective implementation of design requirements during ,
construction, pre-operational testing, and operational maintenance activities, j however, contributed to inadequate configuration control for certain systems.
With the exception of ventilation systems, nearly all of the issues found were related to the implementation of design control processes and implementation of appropriate surveillance testing to confirm functionality rather than to the designs themselves. Corrective actions were taken for specific issues and for past design control implementation problems. j 1
i Program and procedural control revisions were made to preclude l
. recurrence. Issues identified by SFPR were screened using the restart issue review criteria. Based on this screening, issues which (1) impact operability as defined in the Technical Specifications or (2) are in non-conformance to ,
the licensing and design basis will be resolved prior to restart. Other issues ;
not meeting the restart criteria will be corrected during the next operating cycle or during the next refuel outage.
The SFPR identified three " generic issues" that require resolution prior to restart. These three generic issues (instrument setpoint control, the lack of an integrated test program for SBM switch replacement and inadequacies in Technical Specification surveillance testing) were addressed for all applicable systems rather than only the 42 SFPR systems. For example, all Technical Specification surveillance were reviewed and revised, as required. Additional actions were taken that applied to both SFPR and non-SFPR systems. Testing programs were to provide assurance that proper I testing will be performed and will reveal non-conformance with design through analysis of test results. Discrepancies between the UFSAR and existing plant configurations and procedures that had been identified were collected and reviewed for significance. Those UFSAR discrepancies screened as restart will be completed prior to Unit 1 startup. Over the long term, it is anticipated that the on-going LaSalle Design Basis initiative (presently scheduled for completion in 1999) and its line-by-line review of the UFSAR, will provide comprehensive, documented assurance that the design ,
basis is accurate. I l
The SFPR, design reviews and assessments identified a number of design l control process issues. Configuration control assessments were performed l in areas of design change control, design drawing conformance to field j configurations, and operational configuration consistency with the UFSAR. I Also assessed was the potential use of non-approved methods to make design changes to the plant, possible unauthorized design changes implemented by maintenance activities, and the effectiveness of testing programs' abilities to detect non-conformances through test results.
Individual design documents were corrected and program and process changes were implemented to improve the control of the design basis.
These actions provide station management with reasonable assurance that the configuration control at LaSalle will be adequate to maintain the plant configuration in conformance with the plant design bases.
l System Readiness Reviews (SRR) are being conducted to ensure that systems important to safe startup and reliable operation are in satisfactory operating condition prior to startup. The System Readiness Review provides a forma! process to systematically screen open items to the restart criteria to ensure that issues deferred do not, individually or collectively, impact the system's ability to perform its intended function. For each system, the System Readiness Review and Tumover to Operations process will be C_______________.._____.__ . _ - _ _ . _ - - _ - _ -
accomplished in two phases. The first phase is the System Engineering review and affirmation that the system is in a condition to support safe and reliable operation. The second phase is the tumover of each system to Operations following completion of required work, system line-ups and testing resulting in an operable system.
The capabilities of engineering personnel were upgraded through the addition of experienced personnel, additional training of existing personnel and organizational and programmatic changes to ensure that work products meet acceptable standards. The System Engineen.ag qualification program was strengthened to upgrade the technical capabnity and judgment of System Engineering personnel. The SFPR and System Readiness Reviews were used to mentor engineering personnel in desired engineering standards. The Engineering Assurance Group function was implemented to address deficiencies in the technical content and quality of engineering products. Through these efforts, overall engineering product rework has decreased from about 27% to 9% over the past year.
As indicated above, the results of the Effective Engineering Support Strategy are available onsite for review. A significant portion cf this strategy was reviewed during the April 1998 NRC Engineering and Technical Support (E&TS) Inspection at LaSalle County Station. Overall, the E&TS concluded that the engineering and technical support provided by the design and system engineering groups was adequate. In particular, the inspection Team noted that implementation of the modification and 10 CFR 50.59 processes, as well as the system engineering support of the surveillance and testing program appeared effective.
Corrective Action and Self Assessment - Restart Strategy 5 The Corrective Action Program (CAP) has undergone significant improvements since our initial response to the Section 50.54(f) request in February 1997. In particular, a new CAP, developed by a CemEd six-station peer group, was implemented in May 1997. The existing CAP is described in the Strategy 5 closure documentation available onsite for review.
In general, Corrective Action progrartmatic improvements at LaSalle include a new integrated problem reporting system, an improved nuclear commitment tracking process, an interim dedicated team of root cause investigators, a new Operating Experience (OPEX) program, a new format for event screening, and a revised formal Corrective Actions Review Board (CARB). The scope of improvement initiatives in each of these areas at LaSalle is extensive. For example, eight corporate-wide Nuclear Station Work Procedures (NSWPs) and numerous changes to station directives have been issued. Approximately 900 station personnel have received Corrective Action Program-related training since May 1997. Approximately 240 personnel have attended Human Error Reduction Training. These l changes are indicative of LaSalle's commitment to this initiative.
E_____ _ __
i 1
The "new" LaSalle Correction Action Program and assessment activities tepresent a significant improvement above what existed at LaSalle prior to the current shutdown. Based on recent intemal audit results, and performance indicator results, the CAP process is being effectively implemented to ide;ntify problems and implement corrective actions, including actions to determine the extent of problems and actions to prevent recurrence.
The program and process changes implemented at LaSalle have resulted in i
improvements in prob lem identification, root cause determination and the implementation of corrective' actions;' Continued attention is required for closure documentation and corrective action effectiveness reviews. Overall, the CAP is adequate to support unit restart and continued power operations.
The results of implementing the Corrective Action and Self-Assessment Strategy are available onsite for review. The effectiveness of LaSalle's CAP was reviewed during the recent NRC 40500 Inspection. At the inspection exit meeting on June 5,1998, the Team Leader indicated that the CAP was
' working and adequately addressing weaknesses and problems that were i self-identified in 1996 and 1997. No potential violations were identified.
Conclusion i
Based on the programs, reviews, and correctiva actions that have been performed on site, Comed has reasonable assurance that the plant configuration is consistent with the design basis. Additionally, program and process changes have been implemented to address past implementation problems to prcvide assurance that LaSalle will maintain the plant consistent with the design basis. These actions have provided the rationale for concluding that the design bases are translated into appropriate operating, maintenance, and testing procedures. The improved Corrective Action Program will provide assurance that degraded or non-conforming conditions are identified and corrected in a time frame consistent with the ' safety significance of the item and that processes and programs to control plant configuration co7tinue to be effective.
l As a result of the reviews, assessments, and corrective actions taken since j our initial response in February 6,1997, some of the specific actions !
discussed in our response of February 6,1997 were revised. Attachment 1 to this letter provides a summary of these revised actions.
I l
i i
i
If there are any questions or comments conceming this letter, please refer
. : them to Harold D. Pontious, Jr., Regulatory Assurance Manager, (815) 357-6761, extension 2383.
Respe ,
f
/ r mi Fred R. Dacimo Site Vice President ~ - - -
LaSallo County Station Attachment cc: NRC Region 111 Administrator NRC Senior Resident inspector - LaSalle Project Manager - NRR - LaSalle Office of Nuclear Facility Safety - IDNS I
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