ML20086J079
| ML20086J079 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/06/1983 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 7226N, NUDOCS 8401230149 | |
| Download: ML20086J079 (2) | |
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Comrconwealth Edison
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/ One First National Phr. Chic;g], Ilknois
' Address R; ply to: Post Offico Box 767 Chicago, Illinois 60690 4
September 6, 1983 Mr. James G. Keppler, Regional Administrator
- Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 c
Subject:
LaSalle County Station Unit 1 Request for Mitigating and Remitting The Proposed Civil Penalty of the Notice of Violation and Propored Civil Penalty NRC Docket No. 50-373 6
Dear Mr. Kcppler:
By this letter, Commonwealth Edison Company is requesting your consideration to the matter of mitigating the Proposed Civil Penalty as allowed for in 10 CFR 2.205.
This request is initiated separately as directed by the Notice of Violation dated August 9, 1983.
While Commonwealth Edison admits to the violations described in the Notice of Violation and recognizes the severity of the incidents, we believe the Civil Penalty proposed is excessive and merits your review for reduction for the following reasons:
1.
After discovery of the event on June 21, 1983, LaSalle County Station undertook an exhaustive review to identify and promptly correct the violation, verify no further violations had occurred, and implement supplemental actions to verify generic deficiencies did not exist or were positively addressed.
The full scope of this task is described in the LaSalle County Station Response to the Notice of Violation.
In addition, all Commonwealth Edison Operating Nuclear Stations have been contacted and where a similar problem as experienced at LaSalle was identified, corrective actions are being implemented.
We believe the full range of corrective action, the promptness of implementation, the extensive retraining conducted and planned, and our audits to verify compliance represent a complete and outstanding effort in problem analysis and correction.
2.
While this event revealed shortcomings in the areas of administrative control and the conduct of operations, we believe these problems have been properly remedied.
The assertion that the lack of effective preventative actions taken in response to issues on NRC Inspection Reports Nos. 50-373/63-01 (DPRP) and 50-373/83-05 (OPRP) does not appear correct.
A review of these reports and LaSalle County Station's responses indicates that corrective action was properly taken and implemented.
While both of these issues indicated inconsistencies among different procedures that manipulated common 8401230149 830906 IS
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.o J. G. Keppler September 6, 1983 equipment, our corrective actions reflect an effort to identify, address and correct the deficiencies identified.
Only in the broadest retrospective analysis could this occurrence be similarly categorized when both reports are taken as a whole.
After several years of operation in accordance with the Equipment Out-of-Service Procedure, an option that allowed the "before" position to be used as the "after" position when returning equipment to service resulted in an event that revealed the inadequacy of this provision.
A signifi-cant shortcoming was identified and remedied.
Operator response was in accordance with procedure and did not reveal any specific personnel error, except that despite proper identifica-tion and completion of some 70 checklists prior to start-up, an important checklist was overlooked.
Our revision to LAP 900-4, Equipment Out-of-Service Procedure, has provided that as equipment is returned to service, the "after" position will be provided by a supervisor in charge of the equipment from an approved mechanical or electrical checklist and proper completion will be verified by a supervisor.
This will effectively ensure all mechanical and electrical checklists are current at all times.
In conclusion, Commonwealth Edison understands the signi'icance of the violations involved.
We also feel that our investigation and prompt corrective actions merit consideration.
The contention that 0revious non-compliance items shculd have identified this potential for 1olation appears tc be in error.
Our review of these items fails to establish a link to any recognizable indications for the prevention of this violation.
Because of the redundsncy of the vacuum breakers as described in the FSAR, the Safety consquences of thf.s event were minimal and the health and safety of the public were maintained.
On these bases, we request your consideration for mitigating the Civil Penalties involved.
Very truly yours, Cordell Reed Vice-President CWS/lm cc:
Director, Office of I&E NRC Resident Inspector - LSCS G. R. Benson, Regulatory Affairs 7226N