ML20153D482
| ML20153D482 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/23/1985 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0988K, 988K, NUDOCS 8602240158 | |
| Download: ML20153D482 (33) | |
Text
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/mN Commonwealth Edison
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) one First Nitional Plaza.. Ch cago. Ittinois
.e (O 7 Address fleply to: Post Office Box 767 (j Chicago, Illinois 60690 December 23, 1985 gg Wp v
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Mr. James G. Keppler pp Regional Administrator p OL U.S. Nuclear Regulatory Commission E
Region III pit 799 Roosevelt Road Glen Ellyn, IL. 60137
Subject:
LaSalle County Station Unite 1 and 2 Request for Information Under 10 CFR50.54(f)
NRC Docket Nos. 50-373 and 50-374 References (a):
NRC letter from J.G.
Keppler to C. Reed dated November 22, 1985 (b):
CECO letter from D.L.
Farrar to J.G. Keppler dated December 5, 1985 (Attachment 3)
(c):
CECO letter from C.
Reed to J.M. Taylor dated November 26, 1985 (Attachment 2)
Dear Mr. Keppler:
This letter is Commonwealth Edison Company's (" Edison")
response to the Nuclear Regulatory Commission's ("NRC" or
" Commission") request for information under 10 CFR50.54(f),
Reference (a).
Edison shares your concern that efforts to improve the regulatory performance of the LaSalle County Nuclear Station.
Units 1 and 2 ("LaSalle") have not been completely effective in preventing recent operational events.
Edison recognizes that the regulatory performance at LaSalle requires additional improvement to prevent the type of recent events that have occurred and to ensure we meet the Company's goal of safe and error-free nuclear operation.
Therefore, Edison has committed to perform the extensive actions discussed below.
A key element in this program is the Management Plan already provided on December 5, 1985 (Attachment 3).
Other elements of this program are discussed below in relation to specific regulatory concerns raised in your letter.
Edison believes that the implementation of this program will substantially upgrade LaSa11e's regulatory performance, g22gOM f 3-SY.CEO l
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s Edison's program will work as follows to address the'five concerns you identified-0 1.
ADEOUACY OF MANAGEMENT. MANAGEMENT-STRUCTURES AND l
MANAGEMENT PRACTICES Both upper and operating management at LaSalle! have-substantial experience with operating nuclear power plants.' See Table 1.
However, to further strengthen the management team. Edison has made some changes in personnel, especially in the maintenance area.
t At the station level, new positions include a Production Superintendent, Services Superintendent,. Assistant Superintendent for. Technical Services, an Assistant: Superintendent for Work Planning, an Assistant Fire Marshall responsible'for housekeeping, and a part-time, on-site representative from corporate Station 3
Nuclear Engineering Department, ("SNED").
The Production Superintcndant position is especially noteworthy because both operations and maintenance personnel report to him.
The Assistant Superintendent for Work Planning is a Senior Reactor Operator with several years of experience at LaSalle.
He and his staff will coordinate outage work and ensure the proper day-to-day scheduling of work.
At the corporate level, the position of Manager.of Production, Nuclear Stations Division has been replaced by two new Division'Vice-Presidents, one for older plants (Dresden, Quad' Cities and Zion) and one for newer plants (LaSalle, Byron and Braidwood).
These positions were created in recognition of'the complexity of the newer stations and the substantial increase in the number of Technical Specification requirements for them.
Ken Graesser, the new Division Vice President for LaSalle, was one of our most effective plant managers, and brings leadership and many proven management systems to the position to help improve LaSalle's performance.
Several new management practices also have or are being instituted to deal with specific issues. - These include: (1) the integration.of control room work requests which require-interdepartmental interfaces into the daily schedule and the
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establishment of a weekly; quota lfor completing control room work requests,'(2) the assignment.offan expediter of work requests, (3) the formalization of the use--of the-degraded' equipment log, (4).
monitoring of the backlog of procedural changes, (5) implementation of a feedback program for lessons-learned from' deficient modification packages, and (6) increased communications.between Rad Chem and other departments.
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Other, more general management practicesEinclude the development of a performance' tracking system:to' monitor adequacy of work planning, the~ computerization of~ planning programs and 2
increased interactions.with NRC personnel.
f The general and specific-management changesfenumerated-above and in the Management Plan are expected to significantly improve' regulatory performance at LaSalle. 'In addition, a further:
review of the station's organization will be completed in the Spring of 1986.
4 2.
ADEOUACY OF MAINTENANCE AND MODIFICATION PROGRAMS Edison has previously described,-in
Attachment:
2, some of the changes it has instituted to. improve the LaSalle maintenance and 1
modification program.
These changes include elements of the design control program described in the Management Plan.
In addition, the Management Plan includes an eleven point 5-Year Modification Plan i
for ensuring.the timely completion of modifications in accordance j
with their safety significance.
This. program should also improve coordination with SNED.
The details of this plan are described in.
l l
The Management Plan also describes a program which is i
expected to reduce the backlog of work requests, ensure that
. requests with the greatest safety impact are done first and' prevent repetitive equipment problems.
The details of the program are also
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discussed in Attachment 3.
A recent NRC review of modificationsfcompleted during the LaSalle Unit 2 outage has already noted~the positive effects of some j
of the improvements described herein.
i 3.
ADEOUACY OF CONTROL OF WORK ACTIVITIES i
We understand that this item refers in part to work activities which have led to SCRAMS or ESF actuations.
Section G.6
.of the attached response to your report (" Response") describes the station's improving record in this area.
As for other work 4
i activities, such as the control of lifted leads and jumpers, the taking of chemistry samples,. control of~ locked valves, control'over-high radiation areas and personnel errors, Sections A, D, E and F of i
the attached response describe the station's improving record.in these areas.
Moreover, the Management' Plan includes additional actions which.are' expected to further improve station performance in these areas.
The details of implementing these actions-are also
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included in the Management Plan.
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ADEOUACY OF THE' IMPLEMENTATION OF THE REGULATORY' IMPROVEMENT-PLAN Edison believes that the Regulatory Performance Improvement Plan (" Improvement. Plan") instituted in February, 1984 already has improved performance at LaSalle even though that improved
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performance was not as great as'had been anticipated.
and the attached-graphs to this letter show that significant improvements have already been achieved in those areas identified by your Task Force Review.
In particular, implementation of the Improvement Plan has resulted in:
(1) more aggressive resolution of equipment problems; (2) more effective planning and control of site activities; and (3) reduction in the frequency of personnel errors 5.
ADEOUACY OF THE RESOURCES COMMITTED TO LASALLE Our 1986 and 1987 budgets for personnel, expenses, and investments for operations, maintenance and modifications have'been reviewed in a systematic manner.
The preliminary budgets.were established by department heads at LaSalle and General Office' Nuclear Support Departments.
The budgets were further reviewed by' the Station Manager and Executive Management.
We have provided adequate resources to ensure the safety of our plants and to make the additional improvements outlined in our Management Plan.
We will monitor our performance objectives as outlined to see that we are meeting our program dates.
If during this review, we find that additional resources are needed, necessary action will be taken.
We believe that the measures and actions described in this letter and its attachments demonstrate Edison's continuing commitment to the operational safety of LaSalle County Station.
The periodic meetings which we plan to have with your staff to review our progress in meeting the goals and milestones in the Management Plan provide the NRC and Edison the opportunity to agree to any mid-term corrections to these programs that may be required.-
Since several.of the programs will not be completed prior to the end of the LaSalle Unit 1 refueling outage, we'will conduct an On-Site Review prior to returning the unit to operation which will review the status of the: programs at that time and determine if any additional special reviews need to be performed prior to startup.
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. As is our normal practice at.our otherJstations,Rthis J On-Site Review prior to_startup will specifically provide assurance that unit startup can proceed safely by'a:
1.
Review of outstanding work requests to identify the ones having safety impacts and completion of those requests.
2.
Review outstanding procedure revisions,-especially those resulting from modifications and Tech Spec changes implemented in support-of the-Unit 1 refueling outage, prior to startup to ensure that required procedure revisions have been completed.
3.
Review outstanding modifications for safety impact prior to Unit 1 startup.
Edison believes that the implementation of these 4
commitments and of the corrective actions described in our response to your Task Force report provide assurance that LaSalle will continue to operate in a manner which ensures adequate protection of the public's health and safety.
To the best of my knowledge and belief the statements contained herein are true and correct.
In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Very truly yours, CedRstd Cordell Reed Vice President SUBS IBED and y O to befo me thfsN day of 011LLW
, 1985 044 1
Notary'Public j
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TABLE 1 4
j IABATJE STATION
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.i MANAGDutNT EIPERIENCE IRVEL IN YEARS COM4ERCIAL MILITARY TOTAL LICENSE JOB TITTE NAME NUCIEAR NUCIRAR OrlfER EXPERIENCE HEIA 24 0
0*
2%
IBRODresden1-2-3) 8tation Mgr 890' Im8a11e Services Supt 16 0
0 16
.( B0 Dresden 2-3) j
- Production'Bupt 20 0
0 20 (800 Dresden 1-2-3)
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880 IaSalle i
9.5 0
2 11 5-880
- Asat Supt Tech Services l
Asst Supt Operating i
10 10 0
20 880 3
E
- As t Supt Maintenance T
0 8
- 15. k I
i i Security Administrator 8
0 23 31 Operating Eng 8
6 18 890
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' Operating Eng 10 6
0 16 880
.f 16 0
16 32 890
- Operating Eng e-
! Master IM
.95
'O 2
11 5 (BRO).
Ma ter EM
'10 0
12 22 i
\\
- Master M 9
0 0
9 880
! Rad Chen Supervisor T
0 0
7 Tech Staff St.pervisor l
10 0
2 12 8R0 j
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N TABLE 1 (Con't)
IASAIJR STATION MANAGFJGENT EIPERIENG IEVEL IN YEARS (00NTINtED) i COMRCIAL MILITARY TOTAIS LICENSE JOB TITIR NAME NUCIEAR NUCIEAR OTHER EXPERIENCE HEID Training Supervisor 8
8 0
16 BRO ~
Personnel Admin 2
0 15 17 '
Financial Coord 3
0 26 29 l
Office Supervisor 8
0 9
17 1
QC Supervisor 9
6 0
15 Storeroca Supervisor 2
6 8'
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t ATTACHMENT 1 Response to the Final Report 4
on the Task Force' Review of Operational History'
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for LaSalle County Station, Units 1=and 2
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Fire Protection A review of fire protection Deviation Reports (DVRs) and Licensee Event Reports (LERs) shows substantial improvement in all areas over the past five years.
The attached graphs show that both.
personnel errors and DVRs/LERs involving equipment failures have decreased dramatically.
See Graphs 1 and 2.
However, to ensure continuing improvement and to provide added assurance that fire protection reqdirements will be met, LaSalle initiated in early 1984 an extensive fire protection review program which includes significant corporate support.
Under this program, LaSalle has either conducted or has had conducted several major studies and reviews to ensure compliance with the fire protection requirements in the Technical Specifications.
In addition, Edison has budgeted three and one-half million dollars for fire protection improvements at LaSalle over the next three years.
At the corporate level, support is provided through ensuring the availability of adequate technical services and inter-station coordination.
A.2 Vent Stack Monitor The station has and continues actively to pursue solutions to problems with the vent stack monitors.
For example, heat tracing installed in January 1984 has resulted in the successful prevention of sample line freezing.
Other actions initiated by the station to improve monitor performance include:
1.
completion of two modifications to deal with electrical noise problems and plans to install one more modification:
2.
completion of two modifications regarding detector damage:
3.
completion of one modification regarding pump damage:
4.
improvements in operability by changing procedures-and setpoints:
5.
changes to Technical Specifications and 6.
purchase of a $40,000 back-up system These actions have already led to the significant reduction in failures shown in Graph 3 and are expected to continue that improvement.
A solution to the problem of spurious spiking by these monitors is also being actively pursued.
A.3 Ammonia / Chlorine Detectors One aspect of control room habitability is the ability to seal off the control room ventilation system from external sources of ammonia and chlorine.
To implement this protective action, the station has installed ammonia and chlorine detectors in the control room ventilation system.
Because the detectors have not functioned as expected, the station has taken significant actions starting in the summer, 1985, to deal with the problem in'the interim while actively pursuing several options for correcting the situation permanently.
. In the interim, the station undertakes full preventive maintenance every six days instead of monthly as required by the Technical Specifications.
Also, the station has posted warnings about radio frequency interference with the chlorine detectors.
The longer term actions included use of INPO's Nuclear Network for an industry-wide search for more reliable detectors and a consideration of design changes which would result in a logic that would increase system reliability and reduce the effects of spurious signals from these detectors.
In the alternative, the station is considering requesting a change to the Tech Specs based on the circumstances that the nearest source of chlorine would be a barge on the Illinois River, which is 4.8 miles downhill f rom the plant at its point of closest approach, only 0.2 miles closer than the 5 miles limit beyond which no detectors would be required.
If this i
Tech spec change is not obtained, the station will modify the chlorine detectors to eliminate the identified problems.
These modifications are presently estimated to cost $324,000.
A.4 Reactor Water Cleanup System A review of Reactor Water Cleanup System isolations shows a marked decrease in reportable events in 1985 as compared with 1984, 5 versus 47.
See Graph 4.
As you noted, some of this improvement resulted from system changes which reduced the problem.
- Moreover, the station is actively reviewing the calibration of the reactor clean up system's differential flow instrumentation to determine whether that calibration can be changed to better compensate for density changes during reactor startup.
Furthermore, the problem of spurious isolations caused by leaks in the Reactor Water Cleanup Demineralizer Inlet and Outlet Valves will be eliminated by repairing them with spare parts from a recently identified supplier.
The station believes that these steps should result in continued improvements in this area.
A.5 Residual Heat Removal Service Water Pumps The station has been having problems with residual heat removal service water pumps and motors and is having similar problems with diesel generator cooling pump motors in the same general area in the plant.
Some of these problems were caused by isolated incidents.
One problem due to thrust bearing failure led to an investigation which resulted in the correction of the same problem for another motor.
Causes of some of the problems are suspected to be either cement dust in the windings or problems with insulation.
Edi' son's System Material Analysis Department is currently testing motor winding samples to try to determine the cause of motor failure.
Once the root cause is determined, appropriate corrective actions will be pursued.
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.A.6-~RHR Shutdown Coolina Isolation Valve On occasion,_the RHR shutdown cooling isolation valve ~has failed to open.. Edison has expended considerable resources since August, 1983, in trying to determine the cause of this failure.- In i
October, 1984, a consulting fira (MOVATS) diagnosed the valve.and i
. motor' operators and found that no equipment limitations were being exceeded.
SNED and the architect-engineer, Sargent and Lundy, have assistcd the station's investigation of causes of valve inoperability.
The station's technical staff will evaluate the need 1
for additional help when the valve is disassembled during the
' current LaSalle Unit 1 outage.
This problem has not yet been resolved completely, in'part because the valve is operated so i
seldomly.
However, the station has instituted procedures which have j'
resulted in the valve's consistent successful operation.
There have been no failures since February 1985 in approximately 4 operations.
i B.
Electrical Jumper and Lifted Lead Controls
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LaSalle's design requires the use of jumpers and lifted leads to perform routine surveillance of electrical instrumentation and equipment.
Over 1,000 jumpers and lifted loads are used monthly in the course of performing surveillances required by the Technical l
Specifications.
Of the thousands'of jumpers and lifted leads used yearly, approximately seven jumpers or lifted lead tags were lost in j
1985.
Also, problems with lost jumpers and lifted lead tags j
resulted in two DVRs for each of the years 1984 and 1985.
As you a
noted'in your report, the number of DVRs in this areas has been
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decreasing.
See Graph 5.
We believe that this improvement in
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performance has been due in significant part to the procedures which i
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the station already has implemented to better control jumpers and j
lifted leads and to improved personnel performance.
These changes in procedures include:
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1.
Nine revisions, the last in October, 1985, to the administrative procedure for Temporary System Changes to i
require more information in the log book for jumpers and lifted leads and to incorporate lessons learned on an ongoing basis.
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2.
Implementation in August, 1984, of a procedure for the i
documentation of the independent verification of the proper use of lifted. leads and jumpers in~ troubleshooting.
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j 3.
Modification in the Spring, 1985, of the maintenance j
department's troubleshooting worksheet to provide for documentation of the independent verification of the_use of l
leads and jumpers.
LAP 1300-1 I-3 1
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- 4.
Purchase of new jumpers having'different colors 1so that the presence of old : jumpers :can _ be identified readily and trigger an. investigation as to whether those jumpers were properly controlled.
This was' accomplished in the Fall, 1984.
The station believes that the procedures in place have improved LaSalle's_ control over jumpers and-lifted lead tags.
C.
Modification / Installation Procrans LaSalle has had problems with modifications to the. plant.
The station has recognized these problems and has taken extensive actions to prevent their recurrence.
For example, the short and long term corrective actions in response to items C.l.and C.3 of your Task Force Report are described in detail in the attached copy of Reference-(c).
Appropriate corrective actions also have been initiated in response to the other specific events in items C.2 and C.4 through C.7.
Moreover, it should be noted--that some of these items received accelerated, intensive attention because they were Picked up by the potentially significant event system established by our Regulatory Performance Improvement Plan.
As part of the LaSalle County Management Plan, LaSalle has initiated an eleven point, 5 year modification plan and a~ twelve point design control plan.
Five of the actions _in the modification plan either have been completed or are ongoing, with three items completed on or before schedule'.
These actions include the establishment of a modification review committee, the development of a scheme for categorizing modifications'and assigning priorities ~to them, the development of a new mechanism for handling new modification requests and the holding of all responsible organizations accountable for completing activities on time.
Ongoing activities include the categorization of modifications, the assignment of priorities to them and a review of their impact on the startup of Unit 1.
Eight of the activities in the design control program have been completed.
These include the assignment of a " cognizant" engineer to each modification to assure accountability for its nuccessful completion, reports to the Station Manager on audits by site QA and Station QC on implementation of the environmental qualification program and the establishment of a committee to review all safety-related post-modification tests.
Ongoing activities include changes in the method of handling Drawing Change Requests (DCRs) to ensure their timely and correct completion.
In addition, Edison is revising the Quality program to include inspection for conformance to design documentation for future safety-related modifications.
This program will ensure that critical components in~their as-built configuration meet tolerances in the design documents.
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. i As for the particulars of the actions during the Unit I refueling outage, station emphasis understandably has been placed on meeting its commitments to the NRC.
Other safety-related and reliability-related modifications'which could impact safety will be completed during the refueling outage.
Of the 89 modifications currently scheduled before startup, 57 respond to NRC commitments.
The remaining 32 were identified after careful review of the relative importance of outstanding modifications.
Moreover, prior to startup, outstanding modifications will be reviewed again for safety significance for restart.
Therefore, Edison believes that the deferral of remaining modifications.will not adversely impact i
the reliability of safety, equipment during the period that the[ plant.
t will operate until the remaining modifications are completed.
D.
Radiation Chemistry Samples The station is required to devote substantial resources to the-daily taking of chemistry samples.
Sixteen person hours are H
used daily to take approximately 90 daily samples.
Routine sampling has not, in general, been a problem.
Rather, missed or late samples are usually associated with instrument failure or other unusual r
events which trigger non-routine sampling periods.
While there have been some' failures to take such chemical sanples on time, the number has been decreasing.
See Graph 6.
Station performance in this area has improved as the result of better communications between plant operators, plant management and the radiation chemistry department regarding the obaervance of non-routine sampling periods.
These improvements in communication are enumerated in Iten J of the Radiation Protection Performance section of the Management Plan.
The improvements include daily interface with'the Operating Shift Supervisor and periodic meetings with various department heads.
In addition, LaSalle will conduct the activitius enumerated in Item D of the Personnel Performance section of the Management-Plan.
Missed radiation chemistry surveillances will be analyzed for root causes and, once those causes are identified, corrective actions will be instituted.
The station believes that the procedures in place or under development will continue to improve LaSalle's record for the timely taking of chemical samples.
E.
Improperly Locked Valves On occasion a valve is improperly locked.
As noted, these are isolated events-with no common cause.
This circumstance makes a corrective action program difficult to formulate.
However, Graph 7 shows that the number of DVRs attributable to such occurrences has decreased dramatically since 1983 due to the following actions.
1.
All locks were changed on valves to improve control over keys.
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, 2.
The administrative procedure for controlling changes in the positions of locked valves was revised to increase control over those valves.
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3.
Break away locks were replaced with non-breakable locksffor all valves other than fire protection valves.
4.
The locked valve checklist was reviewed to eliminate unneeded valves.
We believe that these actions will continue to reduce the number of DVRs issued for improperly unlocked valves.
F.
Doors in Hioh Radiation Areas The station has undertaken a vigorous program to ensure that doors are closed when they should be.
Of the fifteen actions enumerated in Item G of the Radiation Protection Performance section of the Management Plan, ten have already been completed.
These actions included additional training, a new surveillance procedure, assignment of responsibility for ensuring prompt repairs to doors in high radiation areas, the attachment of security guidelines to key cards and the development of a preventive maintenance program for doors in high radiation areas.
Other actions still underway include the consideration of
. installing local alarms on some doors, disciplinary action when appropriate, implementation of additional restrictions on key cards and the provision of pocket-sized folders designed to increase awareness of radiation protection requirements.
In addition, open doors are included in the Procedural Complience actions listed in Item A of the Radiation Protection Performance Section of the i
Management Plan.
Finally, the station has submitted a proposed change to its Technical Specifications which would eliminate about half of the high-radiation doors by adopting the recently approved' Standardized Technical Specification guidance for defining high-radiation areas.
Edison believes that these completed and ongoing actions will effectively control doors in high radiation areas.
G.1 Control Room Work Recuests The station has undertaken several steps to deal with control room work requests.
Their priority has been increased by daily reviews by the shift engineer.
A significant contributor to these work requests, chronic alarmed annunciators, has been the subject of a concerted corrective effort.
This. effort has been successful in reducing the number of repeat occurrences for specific pieces of equipment.
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. In addition to these steps,'the problem has been addressed in'the Management Plan under the items Work Request Backlog and Control Room Information Deficiencies.
Those items detail a plan for accurately assessing the actual backlog in work requests, for expediting the processing of work requests and for reducing the backlog to an optimum level.
Graph 8 presents the station's commitment for reducing the number of work requests.
That Graph shows that current actions have begun already to decrease the number of' outstanding work requests at the targeted rate.
For the long term, a Permanent Fix Program will be initiated for repetitive equipment' problems.
These actions should bring the work request backlog under control and prevent its becoming an issue again.
G.2 Time Clocks /Dearaded Eculoment Loa LaSalle has been operating with several time clocks running on Limiting Conditions for Operation due to abnormal conditions allowed by the Technical Specifications.
Although such operation is clearly permitted under LaSa11e's license, Edison shares the Region's concern with this situation.
Accordingly, the Management Plan includes a seven point program to reduce both the number of LCO time clocks running during plant operation and any abnormal conditions.
The station has already implemented a priority system for LCO time-clock-related work requests.
Edison believes that once this program has been implemented fully this issue will be resolved.
The Management Plan also includes a six point program for reducing the number of items on the degraded equipment log and for formalizing its use.
This formalization of the log should address the concerns identified.
As for the log availability to the Shift Engineer and status boards, they are not required because all relevant information is now provided on shift turnover sheets.
The log is principally for the use of the Shift control Room Engineer (SCRE).
The SCRE is the Control Room SRO/STA who is responsible for control room operations.
gb,3 SCRAM /ESF Actuations An extensive SCRAM reduction program is described in the Management Plan.
Several items on that program have been completed.
These include the establishment of a SCRAM reduction committee, a historical review of SCRAMS ard a determination of their root causes and a review of the conduct of station operations.
Graph 9 shows a significant reduction in the number of SCRAMS as a function of time.
Moreoever, two of the significant causes of SCRAMS have been identified.
For these two causes of scrams, alternative methods of implementing the same functions also have been identified.
The Management Plan includes an extensive program for reducing ESF actuations.
A task force has been formed, it has I
reviewed all actuations since January 1, 1984 to identify problem areas, and a tracking and trending system has been implemented.
6 This information is used to identify root causes of excessive ESF actuations and to recommend corrective-actions to prevent their recurrence.
So far, three sources of repetitive false actuations have been identified; two are being evaluated, the third one will be acted on.
Graph 10 shows that the number of actuations has l'
decreased significantly in 1985.
Implementation of this program should further reduce the number of ESF actuations to an acceptable level.
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G.4 Outstandina Procedure Chances Of the 1260 outstanding procedure change requests in
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process, a review shows that approximately 70% are minor items-such l
as the correction of typographical errors and changes in format.
Efforts to reduce the number of outstanding change reauests are j
significantly aheed of schedule.
By early December, the number was
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reduced to 943, an approximately 25% reduction.
See Graph 11.
Moreover, none of the DVRs written in 1984 for defective procedures implicated the number of open procedure changes as a problem.
However, as indicated in the Management Plan, the station is j
revising its program for controlling changes in procedures.
These revisions include:
j 1.
The collection of minor changes in a biennial review of procedures.
]
2.
The provision of a schedule for completing each change once it is initiated.
3.
The procedure manager's use of a computer to track changes to a procedure.
I These changes should further improve the station's timely 1
j completion of procedure' changes.
G.5 Personnel Errors / Missed Surveillances The number of personnel errors reported by the station is based on its assessment of the cause of an event.
Every effort is made to determine accurately the root cause of an event and to i
characterize properly any contributing factors.
To further ensure i
j that DVRs/LERs are properly characterized as to cause codes,Han l
Edison off-site review group is independently reviewing the i
station's assignment of causation codes.
An NRC letter to Edison dated December 2, 1985 transmitted a copy of the Office for Analysis and Evaluation of Operational Data (AROD) assessment of LaSalle i
LERs.
That report stated that the quality of LaSalle LERs was above average when compared to other facilities that'have been evaluated using the same methodology.
Moreover, Graph 12 shows that the number of personnel errors is ooing down Finally the Management Plan includes additional efforf on improv.ing person,nel performance.
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' As for missed surveillances, Graph 13 shows a significant decrease in missed surveillances.
Here, again, the station is I
sensitive to the need to conduct surveillances in a timely manner and believes that its improving record in this area demonstrates that sensitivity.
G.6 Control Over Work Activities on Site i
We understand that this item refers to work activities which led to SCRAMS or ESP actuations.
Actions have been taken which have dr.smatically improved this situation.
See Graphs 9 and 10.
These include: the establishment of a daily work schedule which is distributed to cognizant station personnel; the conduct of a daily station meeting to plan and discuss the day's activities, advance scheduling of work and support requirements and limitations on the work which can be performed at any time on reactor protection systems.
In addition, the effects of work activities are included in the general programs for sensitizing supervisors and managers to the need for close attention to detail.
These activities are expected to continue to reduce the number of SCRAMS or ESF actuations due to work activities.
V.1-7 Perceptions Edison is concerned that the significant improvements already realized and demonstrated by the attached graphs have not been fully considered in deriving your perceptions and conclusions j
regarding plant performance.
Edison hopes that the information l
provided here will lead you to re-evaluate your perceptions and i
conclusions to reflect this substantial progress.
V.8 Technical Specification Edison agrees that the LaSalle technical specifications are in need of review and simplification.
The importance of the key information contained in them is diluted by their large volume of less important requirements.
Some of the requirenents may be i
actually adverse to safety, while others are simply ambiguous.
l Furthermore, complete and meaningful bases do not exist for most of I
the LaSalle technical specifications A jointly funded program by Edison and the Electric Power Research Institute to study the application of probabilistic techniques to the identification and l
justification of technical specification changes, began in June, i
1985, has identified numerous potential problems with the existing specification.
l
(
. Improvements in both safety and resource requirements can be realized through a focused effort to correct human factor and other technical weaknesses in the technical specifications.
A program has been undertaken by both the nuclear industry and NRC to improve technical specifications.
Criteria for objectively defining the scope of the technical specifications have been developed and applied successfully, on a trial basis.
Each of the Owners Groups, the Atomic Industrial Forum, and the NRC have major efforts in progress to improve the glearing human factor deficiencies in the Standardized Technical Specifications.
An industry standard writer's guide for technical specifications is being prepared as a revision to the existing ANSI /ANS 58.4 standard.
This standard will incorporate the new selection criteria for technical specifications as well as guidance on the style and format for writing them.
When these efforts are completed, Edison expects to propose major revisions to the LaSalle County technical specifications based on them.
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Conunonwealth Edison ATTACHMENT 2
'D, One First Natenal Mars. Cheago, libres d
e.
O Address holy c: Post Ottc3 Box 767 i
Chcago, minois 60690 November 26, 1985 i
Mr. James M. Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
. LaSalle County Station Units 1 and 2 Response to Notice of Violation and Proposed Imposition of Civil Penalty Inspection Report Nos. 50-373/85-023 and 50-374/85-018 (EA 85-95)
Reference:
J. G. Xeppler letter to J.-J. O'Connor i
+
dated September 27, 1985.
i
Dear Mr. Taylor:
l This is Carmonwealth Edison Company"s (Edison) response to the above referenced Nuclear Regulatory Commission's (NRC) Notice of Violation, Proposed Imposition of Civil Penalties and accorrpanying inspection report.
As we agreed, this response has been submitted within 60 days of the Notice rather than within the 30 days originally provided. We appreciate the
- opportunity that this extension of time has given us to explain in detail Edison's comprehensive program for addressing the matters at issue here.
1 Because Edison does not protest the fine, this letter is accompanied by a check as payment in full of the $125,000.00 penalty.
4 Edison appreciates the significance of the deficiencies identified i
in the Notice.
Our program to ensure the safe operation of our nuclear j
facilities depends in part on ensuring the correct implementation of plant ~
modifications. Edison acknowleoges that the events which gave rise to these deficiencies were unacceptable. -To ensure that similar incidents will not recur, Edison has initiated the extensive corrective action discussed below 3
for both the Station and the General Office.
The attachment to this letter describes the wide range of measures, both immediate and long term, which have been instituted by the Is h11e County Nuclear Power Station and General Office management. The imediate (1) ensured that the violations were corrected; (2) determined measures:
that no similar violations had gone undetected; and (3) instituted new procedures to prevent a recurrence of similar events. Among the significant
. longer term measures are the establishment of a committee which, for a trial period, will review post-modification tests for their ability to determine the operability of the modified equipment and the development of a checklist for helping to choose appropriate tests for modified equipment.
9
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s 2-November 26, 1985 J. M. Taylor These measures demonstrate Edison's continuing commitment to the operational safety of its nuclear stations. Edison believes that such safety will be enhanced by the corrective actions described in this letter and its attachment and, therefore, that the LaSalle County Nuclear Power Station will continue to operate in a manner that fully ensures public health and safety.
-Very truly yours, C bN b Cordell Reed Vice-Presiden't im Attachment cc:
J. G. Keppler - Region III LaSalle Resident Inspector SUBSCRIEED APO SORN to before me this M day OW}Mamla.o 1985
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4 ATTACHENT.
RESPONSE TO-NOTICE OF VIOLATION 1A.
Technical Specification 3.3.3.b requires that with one or more Emergency Core Cooling System (ECCS)-actuation instrumentation channels _ inoperable take the action required by Table 3.3.3.1.-
Table 3.3.3.1_in Action 30 requires that when the nunber of operable channels is less than the required minimum of two, place the inoperable channel in the tripped condition within one_ hour or declare the associated system inoperable.
Contrary to the above, from 3:30 a.m. on June 5, -1985 until 12:10 -
p.m. on June 10,'1985 when the number of operable chamels was less than the required minimum-of two, the inoperable ECCS actuation instrumentation channel was not placed in the tripped condition within one_ hour and the associated system was not declared inoperable.
ADMISSION OR DENIAL OF TW ALLEED VIOLATION
' Commonwealth Edison admits the violation.
REASON FOR THE VIOLATION This violation resulted from our reliance on post-modification tests which did not accurately determine the operability of the modified Division 1 Low Reactor Water Level Switches, t
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED 1.
Initial Responses As soon as-it was discovered that the instruments were inoperable, one of the switches was placed in the tripped condition as required
- by Action 30 of Table 3.3.3.1 of Technical-Specification 3.3.3.b.
Appropriate Station Persomel and General.0ffice Management were also informed of the event.. Shortly thereafter, the errors were
. corrected and an investigation was initiated into the causes of the, events. The results of these investigations provided bases for additional actions intended to prevent recurrence of similar events.-
9
i
. 2.
Further Actions To ensure that no other problems of this type had been missed, several broader actions were taken.
All safety-related modifications made during the Unit 2 outage were reviewed by either the Commonwealth Edison Station Nuclear Engineering Department (SED) or the architect-engineer. No serious discrepancies requiring further physical changes were discovered. Also, either SE D, the station or the architect-engineer walked down all accessible safety-related modifications made during the Unit-2 outage. The architect-engineer also reviewed for completeness the results of our walkdowns. As a result of these walkdowns, only minor discrepancies between the design documents and as-built configurations were discovered. Only one, a labeling deficiency, required correction in the field. For the others, we have corrected the appropriate documents.
Moreover, a Quality Control Inspector independently walked down one hundred twenty-four of the instruments modified during the outage.
All of the test requirements specified in the safety-related work requests and modifications performed during the outage were reviewed completely. Also, it was verified, prior to restart, that all modified instruments would perform as designed.
3.
Training All departments involved conducted informal documented training sessions to discuss the event, its causes, and the corrective actions being taken to prevent its recurrence. This training was accomplished in two steps. First, prior to startup, appropriate personnel in the instrument maintenance, electrical maintenance, and operating departments were trained. After startup, relevant personnel in construction, maintenance, technical staff, and quality control, as well as contractor personnel were also trained. At each of these sessions the significance of the events and their unacceptability were emphasized.
We believe that these training sessions have strengthened post-modification testing procedures by increasing awareness of the need to ensure that testing accomplishes its intended function.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION 1.
Revised Modification Procedures Our analysis of these events led us to change significantly the station's procedures governing the types of actions involved here.
These changes in procedure substantially strengthen the process for ensuring that post-modification tests are adequate.
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.The Station's administrative procedure for pla'nt modifications, LAP 1300-2, has been revised as follows:-
'a'. ' The procedure now explicitly requires the preparation of post-modification tests in accordance.with.the newly established
" Guidelines -for~ Development of Tests for Modifications"lLTP -
800-9. These guidelines provide methods for developing tests to ensure!that system and component operability are adequately:
L demonstrated after modification..Our confidence 'in these guidelines is based, in part, on the following new approach ~
incorporated in them.. Instead of focusing. testing on only modified equipment, testing,'where warranted,=will'now be' 4
extended to unmodified parts of a system. By varying input' signals at those. points in the system.and observing the.
i corresponding responses'in the modified part of the system we-will be better able to' verify the operability of the.
modification. In particular, this procedure would have helped to ensure the proper installation of instrument piping to-p pressure differential DP type instrumentation.
b.
These incidents have also led us to realize the importance of I
developing in one person an attitude of responsibility. for all aspects of a modification. Accordingly,.the procedures now i
require the cognizant modification engineer to be more involved l
with the installation and testing of modifications. This greater involvement includes maintaining overall knowledge of a-l modification's design and status, assuring that design intent is implemented in the modification as installed and monitoring progress on the design, installation.and testing of a modification.
f 2.
Checklists These incidents have also demonstrated the' limited effectiveness of checklists used to determine system operability. Such checklists were developed after April,1985 in response to an incident j
involving inoperability of a train of the, Standby Gas Treatment..
l System. Although itwas believed that such checklists would be l
adequate, there was only a limited period of time in.which to assess i
the-adequacy of those checklists before the June,-1985 events i
occurred. Because experience has now shown that checklists limited to system inoperability are not always adequate, the maintenance and i
operating departments have developed additional checklists which go i
beyond previous lists by now requiring some testing at the component.
level.. This consideration of finer levels of: detail should aid in the selection of testing requirements adequate to demonstrate operability after either maintenance or modification.- Accordingly, it is believed that these new lists-will help to prevent recurrence.
of these types of events.
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Review Committee To further ensure the adequacy of tests of safety-related modifications, an additional level of review of post-modification tests for their ability to determine the operability of. modified equipment has been established. This review will be conducted by a committee which will include the Technical Staff Supervisor, an Operating Engineer or an Assistant Superintendent, and the cognizant Modification Engineer. This committee will review the adequacy of any modified equipment before it is declared operable.
~
DATE WHEN FlLL COWLIAICE WILL BE ACHIEVED Full Compliance has been achieved.- The effectiveness of the Review Committee will be evaluated by March, 1986 to determine whether the committee should become a permanent part of the post-modification review process.
4 18.
Technical Specification 3.5.2 requires at least two Emergmcy Core Cooling Systems (ECCS) to be operable in the shutdown condition.
With both of the required subsystems / systems inoperable, one subsystem must be restored to operable status within four hours or secondary containment integrity be established within the next eight hours.
Contrary to the above, with the three ECCS Divisions inoperable on June 5,1985, secondary containment integrity was not established within eight hours.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Commonwealth Edison admits the violation.
REASON FOR THE VIOLATION Same as in Item 1A.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Secondary Containment integrity had been reestablished before it was discovered that the Division I ECCS Systems were inoperable. - No further corrective action was necessary.
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CORRECTIVE ACTION TAKEN TO AVOID FURTER VIOLATION p
Refer to Item 1A.
l DATE WHEN FtLL COWLIANCE WILL-BE ACHIEVED I
Full Compliance has been achieved.
i i
IC.
10 CFR Part 50, Appendix B, Criterion VI, as implemented by the i
Commonwealth Edison Company's Quality Assurance Manual,' Quality Requirement 6.1, requires that a document control system be used to assure that documents such as drawings be distributed to and used at q
the locations where the prescribed activity is performed.
Contrary to the above, Field Change Request 85-123 dated April 4, 1985 was issued to correct an error in Modification M-1-2-84-136; I
however, it was not distributed to and used at the location where the prescribed activity was performed. _ As a result, piping for-two switches was installed backwards rendering Division I of the Unit 2 Emergency Core Cooling Systems inoperable.
j ADMISSION OR DENIAL OF T E ALLE E D VIOLATION Commonwealth Edison admits the violation.
i REASON FOR TE VIOLATION i
i This violation resulted from an inadequate document control' procedure.
The Station's procedure for controlling Field Change Requests (FCR) did.
}
-not require the FCR's to list contractor drawings. Therefore, FCR 85-123 did not list all of the drawings for revisions to the instal-
]
lation details for 22 instruments. For 20 of those instruments, the -
installation details had been revised on the contractor's drawings. For the remaining two instruments, the contractor's production drawings i
I reflected only the original designs because the drawings had not been modified in accordance with the FCR. The FCR had not indicated that
]
those drawings would be affected.
i q.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The installat' ion of the two instruments was corrected and tested'to i
demonstrate the proper reinstallation. To ensure that similar problems l
.had not been missed, all'other FCR's generated during_the outage were reviewed, and found not to contain any further errors.
1-4
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. CORRECTIVE ACTION TAKEN TO AVOID FURTE R VIOLATION To prevent a recurrence of this type of error, we have added mandatory cross-references to the Stations' procedures. Station Administrative Procedure LAP 1300-5 " Field Change Requests" has been revisec to require an FCR to include a list of all affected documents / drawings,. including contractor production drawings. In addition, both the mechanical and the electrical contractors have prepared and implemented procedures to i
formalize the control of FCR's and requirements for Quality Coltrol field inspection. These procedures require checks to ensure tt at FCRs are properly posted to all affected drawings.
i DATE WEN FULL COWLIANCE WILL BE ACHIEVED Full compliance has been achieved.
10.
10 CFR Part 50, Appendix B, Criterion X, as implemented by the Commonwealth Edison Company Quality Assurance Manual, Quality Requirement 10.1, requires that Quality Assurance inspections be conducted at the site during modification activities to verify conformance to applicable drawings.
Contrary to the above, Quality Assurance inspections were not conducted at the site during Modification M-1-2-84-136 to verify conformance to the applicable drawing (FCR 85-123).
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Commonwealth Edison admits the violation.
REASON FOR THE VIOLATION This violation resulted from a failure to specify adequate hold points in the instructions for installing modifications.
CORRECTIVE ACTION TAKEN APO RESULTS ACHIEVED All accessible elements of the modifications performed during the outage were completely walked down. To ensure an independent review, this i
walkdown was conducted by persons who had not been involved with the installations. Moreover, the results of these walkdowns were documented.
It was found that all final installations were in accord with the approved final designs.
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CORRECTIVE ACTION TAKEN TO AVOID FURTER VIOLATION 1
Station proceduresIhave been substan'tially modified to ensure that.
inspections will_ be conducted during' modification activities. LaSalle has developed and. implemented an administrative procedure LAP 1700-3,'
" Guidelines for Quality Control Hold Points". This procedure provides guidance to Station Quality Control and Contractor Quality ~ Control
_ personnel in establishing hold points._ That guidance requires mandatory
' hold points for field inspections to verify that safety related modifications have been installed in accordance with approved drawings and specifications.
DATE WHEN FLLL COWLIANCE WILL BE ACHIEVED Full Compliance has been achieved.
lE.
10 CFR Part 50, Appendix B, Criterion XI, as implemented by the
. Commonwealth Edison Company Quality Assurance Manual, Quality Requirement 11.1, requires that the test program include those tests necessary to demonstrate that systems will perform satisfactorily in service following plant maintenance or modifications.
Contrary to the above, Operational. Test LIS-NB-204 performed following the completion of Modification M-1-2-84-136 did not L
adequately demonstrate system operability in that the test only_
verified the instrument and electrical connections. - The piping configuration of the reactor pressure vessel water level reference l
and variable legs was not verified.
1 ADMISSION OR DENIAL OF TE ALLEGED VIOLATION -
Commonwealth Edison admits the violation.
REASON FOR THE VIOLATION 7
I This violation resulted from an inadequate post modification test which.
was-improperly limited to testing the instrument and its electrical connections.
CORECTIVE ACTION TAKEN AIO RESILTS ACHIEVED To ensure that similar problems in other equipment had not been overlooked, all safety-related_ instrumentation modified during the outage was retested. The retests verified correct instrument response to varying process parameters..All installation errors identified were.
corrected and retested to verify that the final "as_ installed" plant-condition reflected the "as desigrud" condition. -
. CORRECTIVE ACTION TAKEN TO AVOID FURTER VIOLATION '
We believe that the new procedures discussed above in Item I.0 will prevent a recurrence of this event. Those procedures, especially the new guidelines for~ identifying adequate post-modification tests and, in the interim, the committee review of those tests for adequacy,'should ensure that all relevant parameters are tested and. verified.
DATE WEN FlLL COWLIANCE WILL BE ACHIEVED Full Compliance has been achieved.
8 5
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Technical Specification 3.3.2 requires the isolation. actuation'.
- instrumentation channels shown in. Table 3.3.2-1 to be operable with i '
their trip setpoints set consistent with the values shown in Table 3.3.2-2.
The Residual Heat Removal-(RHR) shutdown cooling pump t-suction high flow instrumentation is included for Operating.
Conditions 1, 2, and 3.. Technical: Specification 3.3.2.c. requires j
that with the number of operable channels less than the minimum L
operable channels per trip system required for both trip systems,'
place at_least one trip system.in the tripped condition within one houriand take the action required by Table 3.3.2-1.
Action Item 25 of Table 3.3.2-1 requires the isolation valves to be closed and~
locked for the RHR shutdown cooling mode and the system to be declared inoperable.
j, Contrary to the above, from' April 7, 1985 until July 12, 1985, while i
the plant was in Operating Conditions 1, 2, and 3, the Unit 1 RHR
}
shutdown cooling pump suction high flow sensors would not have met the designated isolation setpoint in that the isolation actuation instrumentation channels were inoperable. With the channels inoperable, the actions required by Action Item 25 of Table 3.3.2.1 j
were not taken. The isolation valves were not closed and locked for the RHR shutdown cooling mode and the system was not declared f
ADMISSION OR DENIAL OF THE ALLEED VIOLATION Commonwealth Edison admits the violation.
REASON FOR TE VIOLATION i
This violation resulted from our reliance on post-modification tests l
which did not securately determine the operability of the RHR Shutdown i
. Cooling High Flow isolation switches.
[
CORFECTIVE ACTION TAKEN AND FESULTS ACHIEVED r
l The discovery of the inoperabl'e switches was made when the plant was in l
an Operational Condition which did not require those switches to be operaole. Accordingly, no immediate action was required. Before entering an Operational Condition in which those switches were required-to be operational, the piping errors were corrected, and it was verified 1
that the switches could perform their isolation functions.
l l
I CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION j:
Refer to Item 1A.
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28.
10 CFR Part 50, Appendix B, Criterion VI, as implemented by the Comonwealth Edison Company's Quality Assurance Manual, Quality Requirement 6.1, requires that a document control system be used to assure that documents such as drawings, be distributed to and used at the locations where the prescribed activity is performed.
Contrary to the above, Drawing Change Request 7383, issued to document a piping change to Modification M-1-1-82-054, was not distributed to and used in the development of Modification M-1-1-84-091. As a result, the Unit 1 Regenerative Heat Removal shutdown (RHR) pump cooling suction flow isolation channels were inoperable during power operations from April 7, 1985 until the unit was shutdown on July 12, 1985.
ADMISSION OR DENIAL OF TE ALLEED VIOLATION Commonwealth Edison adnits the violation.
REASON FOR TE VIOLATION This violation resulted from the failure to ensure that changes to the plant were reflected on current plant drawings. The violation occurred as described below.
On May 10, 1982 it had been discovered that the original flow switches 1E31-N012A and lE31-N0128 were piped backwards due to the High and Low Process Lines being reversed inside the Suppression Pool. Accordingly, WR #L15576 and modification #M-1-1-82-054 were issued to correct the piping and (in addition) install pressure snubbers. Snubbers were added and the repiping was performed by reversing the tubing locally at the instrument rack. Upon satisfactory resolution of M-1-1-82-054, Drawing Change Request #73-83 was submitted to reflect: (1) The inclusion of pressure snubbers, and (2) the changes to the process line, root valve, and Excess Flow Check Valve numbers associated with lE31-N012A and B (with the Drywell Penetration Numbers remaining the same). Based on their request for more information with regard to the snubber installa-tion, the Architect Engineer (A/E) rejected DCR 73-83. DCR 73-83 (which included the revised drawing #M-2096-5) was inadvertently closed out' without the appropriate changes being made. Therefore, when lE31-t012A and B were removed and later replaced by lE31-N012AA/A8/BA/BB, their process inputs (High vs Low) became crossed, due to drawing #M-2096-5 having never been revised.
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. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Our investigation of the situation revealed that it had resulted from a failure to properly complete action on a Orawing Change Request (DCR).
To ensure that similar problems had not been overlooked, the Station's, tne Architect Engineer's (A/E), and the Station Nuclear Engineering Department's (SED), Drawing Change Request logs were reviewed to identify DCRs which had been rejected or cancelled. Allrejected,open or cancelled DCR's were verified to reflect properly on the critical drawings and/or the appropriate drawing aperture cards. No further discrepancies were found. The DCR for Modification M-1-1-84-91 reflected the previously rejected drawing change request.
CORRECTIVE ACTION TAKEN TO AVOID FURTER VIOLATION This incident alerted us to a procedural deficiency in our handling of DCR's. On that basis, SED initiated a review of its procedure for control of DCR's. This review indicated that SED had revised its DCR procedure in August 1984 to provide a specific procedure for handling DCRs rejected or cancelled by the A/E. This procedure was not in effect at the time this incident occurred. It is believed that the current procedure will prevent the recurrence of a similar problem.
4 DATE MEN FlLL COWLIANCE WILL BE ACHIEVED Full compliance has been achieved.
2C.
10 CFR Part 50, Appendix B, Criterion XI, as implemented by the Commonwealth Edison Company Quality Assurance Manual, Quality Requirement 11.1, requires that the test program include those tests necessary to demonstrate that systems will perform satisfactorily in service following plant maintenance or modifications.
Contrary to the above, the post-installation testing performed following the completion of Modification M-1-1-84-091 did not adequately demonstrate system operability in that the test did not detect that the Regenerative Heat Removal pump suction high flow isolation switches were piped backwards prior to returning the instruments to service.
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. ADMISSION OR DENIAL OF THE ALLEED VIOLATION Commonwealth Edison admits the violation.
REASON FOR THE VIOLATION See Item 2A.
CORRECTIVE ACTION TAKEN A 2 RESULTS ACHIEVED See Item 2A.
CORRECTIVE ACTION TAKEN TO AVOID FURTE R VIOLATION Refer to Item lA.
DATE diEN FULL CO WLIANCE WILL BE ACHIEVED Full Compliance has been achieved.
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10 CFR Part 50, Appendix B, Criterion XI, as implemented by the Commonwealth Edison Company Quality Assurance Manual, Quality Requirement 11.1, requires that the test program include those tests necessary to demonstrate that systems will perform satisfactorily in service following plant maintenance or modifications.
Contrary to the above, during this inspection period, the operability test for two Unit 2 shutdown cooling high flow isolation switches was not performed correctly. Specifically, walkdown of the p.cing to these switches identified no problems although the piping to the switches was installed backwards. This error was discovered by an alternate test that was not specified for proof of operability testing.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Commonwealth Edison admits the violation.
REASON FOR THE VIOLATION As a result of previously identified installation errors a system walkdown was designated in June,1985 as corrective action to verify that all piping was installed in accoroance with design drawings modified during the outage. A Technical Staff Engineer was assigned to perform a walkdown of the RHR Shutdown Cooling pump suction high flow isolation switches. The Engineer who performed the walkdown had traced the piping to a wall penetration and when he went to the other side of the wall he reoriented himself with informal markings on the piping which were reversed. The remainder of the inspection was performed utilizing the reversed reference.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Our investigation to determine tne cause of the walkdown error identified the problems that could have contributed to it. As a result, a second walkdown of all process instrumentation piping which penetrated walls was conducted by two Technical Staff personnel, one on either side of the wall. Moreover, all differential pressure instrumentation was verified by performing a second test by varying the process which the instrumentation measured. The piping was corrected and it was verified that the installation was correct by conducting a retest which measured flow in the system.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Refer to Item 1A.
DATE WHEN FULL C0hPLIANCE WILL BE ACHIEVED Full Compliance has been achieved.
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[O iN) o.w r.monwealth Edison Com ATTACHMENT 3 3
T; rs: National M'n. Chcago, minois -
$. - ):( O ) Addr:ss Reply to: Post Offica Box 767 1:
~ Q Chic gs. Illinois 60690
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December 5, 1985
.Mr. James G. Keppler j
. Regional Administrator l
U.S. Nuclear Regulatory Commission Region III j
799 Roosevelt Road Glen Ellyn, IL,60137 l
subject: Lasalle County station I? nits 1 and 2 Management Plan ERC Docket Bos. 50-373 and 50-374 i
}
Dear Mr. Keppler:
Rnclosed is the Action Plan that Lasalle has been developing over-the past few months to address areas that are of matual concern. This is
]
being submitted for your information and is in response to verbal commitments
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that have been made during recent meetings with you or your staff.-
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. A response to the 10 CFR 50.54(f) letter, dated November 22, 1985 to 1
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Cordell Reed, will be transmitted in accordance with the schedule specified in that letter.
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If you have any further questions re'sarding this matter, please direct them to this office.
Very y yours, y
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1 D. L. Farrar f
Director of Buclear Licensing h
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ec: Dr. A. Bournia - ERE ERC Resident Inspector i
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i PROACTIVE MANAGEE NT PLAN O
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TAME OF CONTENTS i
PAGE 2
l SCRAM REDUCTION k
ESF ACTUATIONS SCHEDULING /PIANNING T
CONTROL ROOM INIORMATION DEFICIENCIES 9
12-i WORK REQUEST BACKIDG TIME CLOCKS / DEGRADED EQUIPMENT LOG (DEL)
Ik' PROCEDURES BACKIOG-
.15 MODIFICATIONS 17 DESIGN CONTROL 19 C000 G ICATION WITH RESIDENT INSPECTOR 21 RADIATION PROTECTION PERFORMANCE 22 PERSONNEL PERFORMANCE 2h REGUIATORY PERFORMANCE
-27 ORGANIZATION 28 GRAPHS MANAGEMEN2 PIAN IMPLEMENTATION 1
t SCRAMS 3
EST ACTUATIONS 6
CONTROL ROOM INFORMATION DEFICIENCIES 11 WORK REQUEST BACKI4G 13 PROCEDURES BACKIDG 16 l
CATEGORIZATION /PRIORITIZATION OF MODIFICATIONS 18 I
HI RADIATION DOOR VIDIATIONS 23 l
PERSONNEL ERROR IZRS 25 CUMULATIVE IZR HISTORY (NUMBER) 26 e
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l i-l INTRODUCTION The objective of this plan is to realize a significar.t improve-ment in the performance of IaSalle Station. Although, the primry focus is on improved Regulatory Performance, benefits in Station l
j availability as well as other areas are expected to result.
l The plan is divided into major areas with a detailed action plan I
for each area. Where appropriate, measurement standards such as trend graphs and projected completion dates are provided.
j The plan is intended to be a living document subject to change as conditions dictate. Although some variation in meeting pro-jected goals should be expected due to unforeseen circumstances, the Station considers itself accountable for rigorous adherence to this plan.
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j LASALLE COUNTY STATION ACTION PLAN STATUS 1
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SCRABI REDUCTI(N 1
l PROJECTED ACTUAL l
g COMPIETION COMPIETION RESP.
DATE DATE COM4ENTS
. A. Establish Corsnittee CES/ACS 8/6/85
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B.ScramHistoryReview,includinglistofscramssh CES/ACS 9/3/85 root causes l
C. Review Station Conduct of Operations CES/ACS 9/26/85 D. Review RPS Sury. testing CES/ACS 9/26/85 E. Turbine trip channel redundancy l
- 1. Identify alternatives CES/ACS Complete Complete
- 2. Feasibility / Cost study-CES/ACS 2/28/86
- 3. Establish schedule for improvement CES/ACS 6/01/86-Schedule Depend-ent Upon Results l
or Feasibility-l Study l
F. Inst. line hydraulic transient RPS trips l
l
- 1. Ident!ry alternatives.
CES/ACS Complete _
Complete
- 2. Feasibility / Cost Study CES/ACS Complete Complete
- 3. Establish schedule for improvement CES/ACS 5/01/86 l
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REACTOR SCRAMS
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9 ESF ACIUATIONS PROJECTED ACTUAL COMPIJ: TION COMPIEPION HESP.
DATE DATE COM4ENTS' A. Task Force DSB
- 1. Form Task Force Complete Complete i
- 2. Initiate' ongoing tracking / trending Complete Complete
- 3. Review all actuations since 1/1/84 to identify Complete Complete problem areas
- b. Review actuations for root cause as they occur On Going On Going.
and recosamend corrective actions to prevent recurrence -
.5. RWCU delta-flow cal-data Modification
- a. SNED letter RFJ 12/02/85
- b. MOD to OSR 1/08/86
- d. MOD installed (both units) 2/15/86
- a. Review SNED Scoping analysis DSB 11/08/85 11/13/85
- b. Decision on MOD /fbnding C=ID/KG 11/15/85-11/15/85 Estimated ~ cost
$324,000.
Will do.
- c. Modification Package engineered RFJ.
1/15/85
- d. Modification Package installed PFH/
3/09/85 Y
- e. Submit Tech Spec Change Request DSB/TAH 3/03/85 g.
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3 ESF ACHIATIONS (Continued)
PROJECTED ACTUAL COMPIETION COMPIETION RESP.
DATE DATE C0044ENTS
options
/DG Options include.- downgrade system from code
- reduce number of valves installed
- welded instead of flanged installation Decision on funding KG/GJD 1/31/86' Modification schedule' DGB/PFM 2/28/86 b
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SCHEDULINC/PIANNIRI PROJECTED
-ACTUAL COMPLETION COMPIETION RESP.
DATE DATE COP 94ENTS A. Establish a task force to evaluate implementation CES Complete Complete or a Planning Deprtment consisting or major Station departments B. Develop technique for planning:
CES/JEL
- 1. Hefuel Outage Complete Complete
- 2. Forced Outage Complete Complete
- 3. Daily Work (jobs which interface)
Complete Complete C. Develop a Performance Trdeking Scheme
- 1. Starts / Completions / Cancels /% Compliance CES/JEL 12/09/85
- 2. Reports to Production Superintendent CES/JEL 12/09/85 Start Date
-3. Publish Teriodic status reports around Station CES/JEL 12/09/85 Start Date D. Implement a Planning Group
- 1. Establish an Assistant Superintendent level position GJD 1/31/85'
- 2. Organization, authority, responsibility, size, CES'/JEL 12/30/85 composition (preliminary)
- 3. Assign Operating personnel (5 Operators)
Complete Complete
- k. Assign additional department personnel CES/wES 12/30/85
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SCMDULIM/PIABIM (Continued)
PROJECTED ACTUAL COMPIETION COMPIETION
- RESP, DATE DATE C0604ENTG E. Computerize the Planning Programs
- 1. Refuel Outage Complete Complete
- 2. Forced Outage Complete Complete
- 3. Daily Work CES/JEL -
3/01/86 Need Computer-
'lype Person By -
by 1/1/86 F. Inform Station personnel of Planning Department's CES/JEL 1/31/86 functions e
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CONHIOL B0(31 IBF01BIATION DEFICIENCIES
- PROJECTED ACTUAL COMPIETION COMPIETION RESP.
DATE DATE CO M NTS A. New Control Room Work Request's (CHWR) B-1 priority.
WHil On Going On Going (B-1 = Start work next work day and work normal hours l
to completion) 1 B. Control Room Work Requests integrated into daily WES On coing On Going
. schedule (Interface WR's only)
C. Complete U-2 CRWR's requiring outage WES 12/08/85 End of current' outage-D. Black panel in effect on Unit 1 at startup WES 3/01/86 End of 1st Refuel Outage i
E. Complete U-l CRWR's requiring outage WES 3/1/86 End of 1st Refuel Outage F - Schedule and complete 25 CRWR's. per week WES 11/19/85 11/19/85 Start Date
- 0. Daily Status Report (Planned & Completed)
WES 11/25/85
.11/20/85-Start:Date H. Weekly plot of CRWR's WRH 12/03/85 12/03/85 Start Date I. Permanent Fix Program for repetitive equip. problems
- 1. Identify 5 repetitive problems needing long-term solutions WES/MS 1/01/86
- 2. Identiry alternatives PFM Schedule depend-pnt on problem definition.
O That:.Directly affect the controls used by operators during emergency situations, off-normal situations or routine operations.
Results in inforuution, relied on by operators to take action, being inaccurate or indeterminate.
Results in an annunciated Control Room alarm that reflects an off-normal condition.
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OtWFRDL ROGG INFOIGIATION IINFICIENCIES' PROJECTED
-ACTUAL COMPIETION COMPIETION RESP.
DATE DATE COD 94EN'ITI
- 3. Perform reasibility/ cost study PFN Schedule depend-ent on problem.
definition.
- k. Establis'h schedule for resolution
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ent on problem definition t
O That: Directly arrect the controls used by operr. tors during emergency situations, off-normal situations or routine operations.
Results in information, relied on by operators to take action, being inaccurate or indeterminate.
Results in an annunicated Control' Room alarm that reflecta an off normal condition.
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LASALLE COUNTY STATION CONTROL ROOM WORK REQUESTS
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MNK REGEST EMXIDG PROJECTED ACTUAL COMPlfrION COMPlfflON RESP.
DATE DATE CODMENTS A. Refine accountability of actual backlog
- 1. Review of current backlog CES/WES 1/31/86
- 2. Maintenance of backlog record via improved CES/WES 2/28/86 reporting system
- 3. Assign an individual to expedite Work Request processing GJD 1/01/86 D. Review of outstanding Work Requests on U-l CES/Wmf 1/31/86 Intent is to cleanup prior to identify those with safety impact which to restart should te done prior to'U-l startup C. Define an optinnan backlog level and assess resource level CES/WES 1/31/86 vs. workload, actual backlog, and optimum backlog D. Reduce backlog to optimum level CES/WES 9/01/86 E. Optimize parts /saterials procurement CES/WES 2/28/86 i
F. Permanent Fix Program for repetitive equipment problems
- 1. Identify five repetitive problems needing long-term CES/WES 1/31/86 solution PFM Schedule depend-
- 2. Identify alternatives ent on problem definition 3.- Perform feasibility / cost study PFM
' Schedule depend-ent on problem definition
- b. Establish schedule for improvement PFM Schedule depend-ent on problem definition.y s
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LASALLE COUNTY STATION
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WORK REQUEST BACKLOG 4000-3500-3000-2500 2 0 0 0--
1500-1000-500-OJ F M AM J J A S O N D J F M AM J J A S O N D J F M A M J J A S O N D y
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PROJECTED' ACTUAL-COMPIKPION COMPIETION -.
RESP.
DATE DATE CO694ENTS A. Reduce i of time clocks in effect to a reasonable level
- 1. Conduct overall assessment or time clocks, i.e.,
WRH/DMP 12/20/85.
causes, regetitive problems, etc. This may require a record system or log on time clocks to collect data.
- 2. Review results and make recommendations to reduce WRH/DMP 1/06/86
- of. time clocks in errect.
- 3. Formally define priority requirements for time WRii 12/02/85
-12/02/85 clock related Work Requests
%. Implement priority system WRH/OE's 12/02/85 12/03/85-
- 5. Establish a preliminary target number prior to Unit WRH 3/01/86 I startup and monitor
- 6. Reevaluate with both units in power operation CES/WRH h/15/86 T. Establish a target number
-WRH 5/01/86 I
B. Reduce # of DEL's in effect
- 1. Review history and comunitments '
WRH/JAA 12/02/85
- 2. Conduct overall assessment of DEI. to identify WRH/DMP 12/20/85 causes for==har of entries
- 3. Make recomumendations to reduce the number during WRH/DMP 1/06/86 normal. operation j
- k. Formalize use of DEL. What ' goes in log, what does WRH/JAA 2/01/86 l
degraded mean, etc.
/SCRE's l
. 5. Establish a preliminary target number prior to Unit WRil 3/01/86 l
1 startup and monitor -
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- 6. Reevaluate status with both units in operation CES/WRif 5/01/86 g.
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ymnmmmen mamgag PROJECTED ACTUAL COMPIATION COMPILTION RESP.
DATE DATE C000FNTS RDB/JCK 10/21/85 10/21/85 A. Improve procedures process to make it more errective RDB/JCK 10/21/85 10/21/85 D. Establish target backlog RDB/JCK Ongoing Ongoing C. Monitor tacklog RDB/JCK 2/28/86 Prior to Unit 1 D. Review procedures outstanding, especially those Startup resulting from U-1 Modifications during Refuel Outage, prior to Unit 1 Startup s
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OUTSTANDING PROCEDURE CHANGES i
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PROJECTED ACTUAL COMP 1RTION COMPLETION RESP.
DATE DATE CODMENTS'
' A. 5 Year Modification Plan l
- 1. Establish a Modification Review Committee RDB Complete Complete RDB 10/25/85 10/25/85
- 2. Develop a yriority/ category scheme RDB 11/11/85 10/25/85
- 3. Develop mechanism to handle new modification requests RDB 1/05/86
- 4. Redefine scope of Modification Program (i.e. - setpoint changes, etc. )
RDB 1/05/86
- 5. Categorize existing modifications
- 6. Prioritize modifications within categories RDB 1/20/86 T. Deview outstanding modirications for safety RDB 2/28/86 Impact prior to Unit I startup RDB 3/1k/86
- 8. Schedule spectric modifications for completion commensurate with established rate and publish schedule (preliminary schedule)
- 9. Deview preliminary schedule with all responsible CJD/RDB 4/25/86 organizations and establish final schedule consis-tent with the comunitment of the responsible
. organizations.
- 10. Issu. monthly status reports - Include RDB 12/05/85-11/20/85 start Date l
exM*Jtive suBEEkry
- 11. No'd all responsible organizations accountabla KC/CJD On Going On Going
'or performing activitits within the commited schedule i7 4
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MODIFICATIONS C ATEGORIZED TARGET s eeeeee P R IO RITI Z E D T A R G ET..............
ACTU AL FOR BOTH
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MIMGWNDL PROJECTED ACTUAL COMPLETION COMPIEfION RESP.
DATE DATE COM4ENTS l
A. Improve Design Schedule & Quality l
- 1. Assign Cognizant Engineer to all Modificat*ons
- a. Define Cognizant Engineer responsibility /
RDB/PFM Complete Complete accountability fer successful completion of i
l Modification from initial design to declar-ation of operability 1
- b. Training / Expectations Program for cognizant RDB/PFM 11/18/85 11/15/85 l
Engineers
- c. Assign Modifications RDB/PFM Complete Complete
- 2. Improve quality / content of modification design l
packages I
- a. Implement feedback program which utilizes RDB/PFM h/25/86 l
lessons learned from deficient modification packages to improve the Modification Program i
- 3. Environmental Qualtrication Program implementation review and corrective action as required
- a. Conduct " Big Picture" status meeting to review GID Complete Complete total program and compliance with intent as well I
as letter of the law i
- c. Conduct QC audit and prepare report RDB Complete Complete
- d. Conduct QA audit and prepare report RDB.
Complete Complete E
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PfM11ECTED AC'li.lAL COMPIETION COMPIEPION RESP.
DATE DATE C000ElrFS li. Identify backlogs in the design process (other than design) such as DCR's. FCR's, etc. that are potentials;ror future mistakes and develop trending / tracking measures to reduce to a
====geable level.
- a. DCR's (1) Establish a reasonable turnaround time for RDB/i?M 1/31/86 DCR's and target for cleanup of backlog (2) Obtain SNED concurrence KG/GJD 1/31/86 (3) Moottoring method and suimmary report RDB/PFM
-1/31/86
- b. Other RDB/PFM 3/31/86
- 5. Post Modification / Maintenance Testing
- a. Assign / define a required commaittee to CJD Complete Complete.
+
review all safety related most maintenance /
Modificatica tests for adequacy. High level
- Master & T.S.S.?
O.E.7
- b. Review checklists in effect to assess adequacy IANt(NSG) 1/31/86 By Nuclear Safety Croup l
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i GEBESICATIM VITE MIM IMPECTURI PfKkIECTED ACTUAL C00FIEFION C00FIEFIOlt l
RESP.
DATE DATE CODGE3lTS
- 0. Aggressive interaction with Resident Inspector to CJD/RDB On Coing On Going l
better understand concerns and address, as well as
/CE3/
market the good things Depart-ment Heads B. Weekly meeting with Resident GJD On Going On Coing 9
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l MDIATIM FEFFM! TIM FWRMIANCE PROJECTED AC'lVAL COMPIETION COMPIETION RESP.
DATE DATE COMElrFo C. Procedural Compliance
- 1. Documented tailgates conducted with all personnel Complete Complete
- a. IaSalle problem areas
- b. Byron Enforcement Action
- 2. All 1st line supervisors reminded of their responsi-Complete Complete bility for procedural compliance at Expectation
-Meetings held with Station's upper management
- 3. On going program to upgrade procedures and training ongoing ongoing B. Frisking (See Also Item'A - Procedural Compliance)
- 1. Setup of nine (9) frisker booths in progress.
IRA Refuel Complete Five additional booths awaiting setup.
- 2. Pbur (%) stnte-of-the-art whole body friskers on order IRA Refuel 50% Complete.
2 have bad boards. Pro-ject: 12/13/85 Five (5) more are proposed for 1986 budget IRA 1986
- 3. Pbrty-eight (48) additional IM-Ik friskers (handheld)
IRA Refuel All 48 ree'd.
18 in service.
are on order Remainder in service.
12/9/85 3'
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PROLTECTED AC1tlAL COWIEFION COWIEFION RESP.
DATE DATE COf955fTS IRA 12/30/85
%. Five (5) IRT monitors from CAF to replace Eberline hand and foot monitors IRA Refuel Complete
- 5. New stenfr pads on order to remind personnel of requirement for whole body frisk IRA 1986
- 6. Perunnent cement block frisker stations 3roposed for 1986 beadset.
I C. Starring
- 1. Add an Assistant to Rad Chen Supervisor (SHO License)
RDB Refuel Complete IRA 1986
- 2. Add a Imad Foreann IRA 1966 Complete
- 3. Add a Timekeeper / Scheduler (should allow a Foreman to be in the plant 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> / day)
IRA Refuel Complete
- 4. Contract 10-15 qualified techs for Unit 1 1st Refuel including supervision IRA /TK As Avail-On Coing
- 5. Supplement existing NP's and RCT's with Braidwood/
able Dresden/ General Office as available IRA As Avail-On Going
- 6. Encourage Nealth Physicist exchange program able D. Space JL Refbel Complete
- 1. Convert approximately 1000 ft* of lunchroom to badge issue and INP processing area, etc.
IRA Refuel Complete
- 2. Addition of approximately 500 ft' in trailer park for MP office to eliminate crowded conditions N
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RADIATION PRDITCTICE PERP05 STANCE (Continued)
PROJECTED ACTUAL COMPI17 ION COMPIETION RFliP.
DATE DATE COMMENTS E. Personnel Contamination (See also Item A - Procedural Compliance. )
- 1. Each event is investigated by DeInrtment with Rad Ongoing Ongoing Chem representation to determine root cause and propose corrective action
- 2. Daily report of contsmination events provided to Ongoing Ongoing Department Heads and Station upper mnagement (monthly trending).
- 3. Reviewing contamination survey techniques and frequency JL Refuel Complete of contamination surveys for areas of known problems
%. Developing a system to assign priority to Work Requests JL Refbel Complete Informally related to contamination control and provide follovup implemented.
Procedure in OCR
- 5. Continued ta11 gates by individual departments Ongoing Ongoing
- 6. RCT's stationed at high traffic areas for c:;ntamination Complete Complete control and groper frisking *echnique F. Area Contamination (See also Item A - Procedural Compliance.)
- 1. Establish a Contamination Control Coordinator RDB Refbel Complete
~
- a. Ares contamination cleanup RDB/JL On Coing On Going
- b. Event Investigation RDB/JL On Coing On Colng 5
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anautTICE PEDfECTIGE PRIBUIBIRES (Castimmed) l l
PROJECTED ACTUAL COMPIETION COMPIETION RESP.
DATE DATE C000 TENTS
- c. Re'lew contamination history to identify methods RDB/JL 2/17/85 for minimizing contaminating events l
- d. Reclaim long-term contaminated areas RDB/JL 1986
- 2. Technical Staff to evaluate ventilation as a possible PFM 1/05/86 i
contributor to spread of contamination 1
- 3. Equipment designed to aid in contamination control DR Refuel Complete
- a. Tents
- b. Drip pans
- c. Filtered air movers l
%. More extensive use of Kelley closures to prevent Ongoing Ongoing g
spread of contamination
- 5. contamination earts located at frisker locations IRA Refuel Complete
- 6. Major contamination event investigations to determine Ongoing Ongoing root cause and prcpose corrective action to preclude repetition C. High Radiation Door Violations (See also Item A -
Procedtral Compliamee.)
- 1. All personnel lastructed to challenge high rad doors Cowplete Complete to assure closure.
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v RADIATICE PRO 11tCTION PERF0050ARCE (Continued)
PRGIECTED AC'I1JAL COMPIETION COMPIETION RESP.
DATE DATE COMMENTS
- 2. All personnel instructed on responsibilities and Complete Complete expectations regarding high radiation door security
- 3. Reinforcement of management expectations and personnel Dept.
10/1h/85 Complete Heads responsibilities provided to all personnel
- 4. Cuidance provided in N-CET training has been expnded RDC 10/08/85 Complete to incitxle more emphasis on responsibility of com-pliance with high radiation door security
- 5. Responsibility assigned for assuring high rad doors Complete Complete are repired expeditiously
- 6. Thorough investigation (DVR & ROR) conducted for each Ongoing Ongoing high radiation door violation with consideration of disciplinary action for identified violators / supervisors T. Surveillance of high rad doors Implemented (IAP-1100-13)
IRA Refuel Complete
- 8. Continue evaluation of installation or local alaras WL 3/86 on selected doors
- 9. High Rad Door Task Fcree (Corporate)
CM 10/15/85 11/15/85 RDB/ Tall 1/05/86 12/03/85
- 10. Sutsalt proposed Tech Spec revision
- 11. Evaluate implementation of reccaunendations from IRA 12/15/85 Corporate High Radiation Door Task Force IRA 1/17/85
- 12. Implement additional restrictions on issue of high radiation keys / key cards
- 13. Attach high radiation area door security guidelines IRA 10/1h/85 Complete to high radiation keys / key cards for issuance Os a
W*
BASEATIM PWfBCTIM PN (Contimmed)
PfEMECTED ACTUAL COff!ET10N C00FIETI0lt RESP.
DATE DATE C000FHTS 1%. Evaluate / implement issuance of pocket-sized Radiation MF 12/20/85 Folders on Protection Awareness folder which includes high radia-order tion door security guidelines
- 15. Consider periodic preventative maintenance program MF 11/01/85 Complete Will do, for high radiation door hardware E. Noble Gas Contamination
- 1. AIARA review required when opening Off Cas Focess IInes Dif 10/85 Complete
- 2. Shouering utilized for decontamination rather than Complete Complete decay method untti guidance provided by Corporate 3.- SCBA utilfred for areas or noble gas contamination Complete Complete ir air sample is impractical or untimely
%. Additional trataing will be provided to RCT's and HP's Complete -
Complete on noble gas contamination I. tinconditiemal Deleases
- 1. Security Guard instructed to esaure unconditional Complete Complete release pass for a broader range of items
- 2. Program drastically tightened following contaminated Complete Complete solvent problem
- 3. Secure dumpsters JL 12/31/85
%. Designate a trash holding area prior to survey JL 12/31/85
- 5. Designate an emelosed area for survey or trash JL 12/31/85
- 6. Evaluate parchase or a trash comppetor Complete Complete g
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..o MBEATIM pMNMTIM N (CastlW)
PROJECTED ACTUAL CODFIETION COMPIEf!ON RESP.
DATE DATE C000ENTS I
J. Interfhee with Other Departments (P-witcaticns )
- 1. Twice weekly meetings with Services Department Heads RDB On Coing On Colng j
- 2. Red Chem participates in Contamination Investigations IRA On Colng On Colng I
- 3. And Chem participates in Scheduling Progrr.m IRA On Going On Going l
15 Daily Interflace with Shift IRA On Coing On Colng j
l
- 5. Red Chen participates in tailsates of other departments IRA On Going On Colng i
- 6. Weekly Department Heads, Meeting IRA On Colng On Going
-j i
T. Outage Planning Meeting IRA On Colng On Going
- 8. Bad Chen representative is Chairson of Dellan Task IRA Complete Complete Force Maintenmace Scheduling l
- 9. Bad Chem participates in Daily Planning Meeting I3tA On Colng On Coing 1
- 10. AIARA 11aes DH On Colng On Coing
- 11. Delian Team Ihallding IRA 1/01/86
- 12. Restructurlag of badging area (See Item D - Space.)
IRA Complete Complete K. Miscellammous
- 1. Remote barrel amaitor operational DH Refuel Complete
- 2. Issue contractor film todges with security todge IRA 12/09/85
- 3. Issue CECO film todges with security tadge IRA Refuel Complete L
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PROJECTED ACTUAL COpFIETION COMPIrrION RESP.
DATE DATE COBGFNTS O. Expectations Meetings CJD Complete Complete
- 1. 1st Line, Supervisors CJD Complete Complete
- 2. Convey expectations to senior management with emphasis on team work GID 1/01/86 B. Delian Efforts GJD 9/01/85 Complete C. Comumaication on R.P. procedure compliance D. Missed Rnd Chen Surveillances DSB/PRL 1/31/86
- 1. Conduct detailed root cause review DSB/PRL 2/14/86
- 2. Identify effective corrective action (s) to mialmize recurrence.
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