ML20059N123
| ML20059N123 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/24/1990 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9010100134 | |
| Download: ML20059N123 (3) | |
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c 1400 Opus Pitc3 Downtra Grova, Illinois 60515 September 24,1990 L
U.S. Nuclear Regulatory Commission Attn: Document Control Desk -
L Washington, D.C. 20555-
Subject:
LaSalle County Station' Units 1 and 2 Response to Notice of Violation I.R. No. 50-373/90009 and 50-374/90012 NBC_Dmhet Nos. 50-373 and_50-374 a
Reference:
- (a)
'A.B. Davis letter lto C. Reed dated August 23,1990.
1
Dear Sir:
This letter is in response to the NRC inspection conducted during the' period of i!
December 30,'1986 through January 27,1987, and to the closeout inspection conducted by Mr.R.D. Lanksbury of your office on May 3-4,1990 conceming certain activities at' 0
LaSalla County Station. : Reference (a) Ind'cated that the activities regarding a test engine er who falsified another individual's initials in January 1987 vio ated NRC
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require,ments and has been categorized as a Level ill violation.- Although a civil penalty is consideed for a severity Level lli violation, the NRC has decided that a civil penalty =
will not be prooosed in this case because of the prompt identification of the violation, and the prompt ana extensive corrective actions taken by the licensee.
Subsequently, Commonwealth Edison (CECO) was requested h provide a i
response providing the basis for concluding why CECO currently has confidence in the -
1 Individual's activities. The following attachment provides that response.
1 If you have any further questions on this matter, please direct them to this office.
l Very.truly yours,.
/
ovach-Nuclear Licensing Manager i
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'i Attachment cc:
A.B. Davis - Region lil Senior Resident inspector - LaSalle j
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9010100134 900924 2
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ATTACHMENTJ e
LASALLE COUt#Y STATION'S RooponBe1D NRC No6ce of Violadkm in NRC InspecDon Report 50473/90009: 374/90012 i
VIOLATION:
--Technical Specification 6.2.A requires the licensee to adhere to detailed -
surveillance and testing procedures, including ~ check-off lists.
4 Surveillance Procedure LTS-900-4,'" Low Pressure Coolant injection (LPCl)
Pressure Isolation Valve Water Leak Test", requires.an instrument stop valve:
(2E12-F350A) to be closed and verified closed by,two people and documented in -
Attachment A," Procedure Verification".
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' Contrary to the above, on January 17,1987, during the performance of LTS 900-4, Instrument Stop Valve 2E12-F350A was not closed and not verified to be in the closed position by two people.
RESPONSE
In response to the event of January 17,1987,' Commonwealth Edison Compani,
- (CECO) reviewed the test engineer's overall work record, and the event itself, to determine if the incident was an isolated event and whether a program of remediation could lead to his restoration to a position of confidence. A review of.
the test engineer's activities in the priod prior to the ~ event, which included tests and other quality documentation, slowed no abnormalities.; Also, the individual accepted the need fori and appropriateness ~of, the disciplinary action. As a result, CECO concluded that although the test engineer used poor judgerr9nt, he could be J
retumed to a condition where confidence in his work could be estRlished.
Accordingly, a six month monitoring and assessment program was established to ensure that the negative work performance was an isolated incident and would not continue. Under this program, a sampling of all activities was performed by Technical Staff supervision and the results reported periodically to the Station Manager. This monitoring program was completed successfully. In addition, the follow ng corrective actions were taken:
The leakage rate test (LLRT) in question was su~ccessfully re-performed.
The event was discussed at a tailgate session with the Technical Staff and other station departments.
Procedure LAP-100-30. " Independent Verification," was approved to provide specific guidance for second verification.
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With the exception of this event, the individual's behavior has been good; there.
i have been no examples of negative performance and no concerns identified with
'i his current work status. He has demonstrated in his work a disciplined approach to ?
his responsibilities, and a sound technical basis for his actions. His continued -
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understanding of management expectations demonstrates the effectiveness of the j
six month monitoring plan.
- 1 The individual's good performance since the incident is consistent with his overall-work rscord. Before the incident, the test engineer's record did not contain any,
actions which would suggest that he would act contrary to CECO procedures and expectations. The test engineer worked at LaSalle for 4-1/2 years prior to the event. His record of trustworthiness and integrity validates that the incident was an -
isolated event.' His subsequent good performance corroborates his work record.
The event itself, the disciplinary action, and the subsequent remediation program 3rovided powerful learning experiences, and an appreciation for management's nsistence on strict accountability. The effectiveness of those experiences is t
evident from his recent performance. The test engineer has been involved with -
several important projects, including DCRDR commitmer,t coordination and -
tracking at the station and 10CFR50 Appendix J testing coordination (including
- lLRT performance). These projects were monitored through norma! management -
practices and were success"ully completed by the individual.: Management reviews of his performance of these activ' as show that they have been carned out with the same meticulous attention to reg. iatory compilance which has characterized his =
other work.
For all of these reasons, CECO has confidence that this individual will continue to perform his activities consistent with an awareness of management's insistence on safety and quality in all work activities.
I ZNLD145-30 i -
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