ML20087D383

Responds to NRC Re Violation in Insp Rept 50-373/91-20.Corrective Actions:Event Discussed Among Mgt & Regulatory Assurance Personnel to Ensure Missed Surveillances Dispositioned Properly

ML20087D383
Person / Time
Site:	LaSalle
Issue date:	01/10/1992
From:	Kovach T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9201160143
Download: ML20087D383 (2)

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\ Down2rs Grova, Illinois 60515 January 10,1992 U.S. Nuclear Regulatory Commicslon Attn: Decument Control Desk WashintJto ., DC 20555

Subject:

LaSalle County Nuclear Station Units 1 and 2 Response to Notice of Violation :

Inspection Repori Nos. 50-373/91020; 50-374/91020 '

NRC Docket Nos. 50-373 and 50-374

Reference:

Brent Clayton letter to Cordell Reod dated -

December 13,1991 transmitting NRC Inspection Report 50-373/91020; 50 374/91020 Enclosed is Commonwealth Edison Company's (CECO) response to the subject - .e Notice of Violation (NOV) which was transmitted with the referenced letter and Inspection Report. Tne NOV cited one Severity Level IV violation. The violation - -.

ca.icerned the failure to notify the NRC within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after determining that the testing-for certain undervoltage relays was inadequate. CECO's response is provided in the '

following attachment.

, if your staff has any questions or comments concernin them to Annette Der.anberg, Compliance Engineer at7352, 515 (708) g this letter, please refer 1

Very truly youra.

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T.J. vach Nuclear Lic sing Manager <

Attachment cc: A. Bert Davis, NRC Regional Administrator - Rlli--

B. Siegel, Project Manager - NRR T. Tongue, Senior Resident inspector

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RESPONSE TO LEVEL IV VIOLATION INSPECTION REPORT 50 373/91020;50-374/91020 L ATTACHMENT A L

VK)LATICN: IR 50-373/91020-01 l 10 CFR 50.72 l

practical andallin(b)(2)(lii)(D) cases within fourrequires theoccurrence hours of the licenseeoftoanv notify eventthe or NRC as so condition that alone could have prevented the fulfillment of the safety function-of structures or systems that are needed to mitigate the consequences of an- l accident.

Contrary to the above, on November 7,1991, notification of the NRC was not made within fout hours when it was dotermined that inadequate testing of the undervoltaga relays for the cafety divisions 1,2, and 3 electrical bt ses on both units 1 and 2 could have prevented any or all Emergency diesel Generators from performing their safety functions during an accidsnt condition.

REASON FOR THE VIOLATION:

Station management believed that NRC guidance similar to that in Generic Letter 87-09 existed and was app!! cable to the specific situation. It was -

believed that this guidance '.llowed a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provision' period during which L

the surveillances could be ,erformed without declaring the equipment inoperable. On November'e 1991 at approximately 7:30 a.m., Regulatory Assurance revicwed tne event, cluestioned the potential of having missed an ENS notification, and initiated ac ditional review. Furtt.er investigation by

! senior station management led to a decision that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provision period was inappropriately applied to Technical Specification 4.0.3. This action led to not declaring the Diesel Generators inoperable and not entering Technical l Specification 3.0.3. As a result, the need for a 10CFR50.72 notification was not recognized.

l CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED:

ENS notification was initiated on November 8,1991.

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

This svent has bean discussed .:.mong LaSalle County Station, Senior Management and Regulatory Assurance personnel to ensure m:ssed surveillances are dispositioned properly.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was achieved November 8,1991.

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