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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217H6341999-10-15015 October 1999 Requests Renewal of Operator Licenses for Listed Personnel. Current Licenses for Kh Curran,Lm Gerlach,Rc Weber & Bt Rhodes Will Expire in Nov 1999.Proprietary NRC Form 398 & NRC Form 396 Encl.Proprietary Info Withheld ML20217H6251999-10-15015 October 1999 Requests Renewal of Operator Licenses for Listed Personnel. Current Licenses for MR Kahn,Aj Mclaughlin,De Montgomery & Kr Murphy Will Expire in Nov 1999.Proprietary NRC Form 398 & NRC from 396 Encl.Proprietary Info Withheld ML20217F4301999-10-14014 October 1999 Responds to 991012 Rai,Based on 991001 Telcon Re Suppl to Request for TS Change to Revise MCPR Safety Limit & Add Approved Siemens Topical Rept for LaSalle County Station, Unit 1 ML20217D3191999-10-12012 October 1999 Submits Request for Addl Info Re Licensee 990707 Proposed License Amend to Revise Min Critical Power Ratio.Listed Questions Were Discussed with Util in 991001 Telcon ML20217C1671999-10-0808 October 1999 Provides Suppl to RAI for Approval of Unreviewed Safety Question Re Assessment of Certain safety-related Concrete Block Walls at LaSalle County Station,Units 1 & 2 ML20217A7601999-10-0606 October 1999 Forwards Insp Repts 50-373/99-15 & 50-374/99-15 on 990729-0916.One Violation of NRC Requirements Occurred & Being Treated as Ncv,Consistent with App C of Enforcement Policy ML20212M0931999-10-0404 October 1999 Refers to 990922-23 Meeting Conducted by Region II at LaSalle Nuclear Power Station.Purpose of Visit,To Meet with Licensee Risk Mgt Staff to Discuss Util Initiatives in Risk Area & to Establish Dialog Between SRAs & Risk Mgt Staff 05000373/LER-1999-003, Forwards LER 99-003-00 IAW 10CFR50.73(a)(2)(iv).Commitments for Submittal Also Encl1999-10-0404 October 1999 Forwards LER 99-003-00 IAW 10CFR50.73(a)(2)(iv).Commitments for Submittal Also Encl ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr ML20217A6201999-09-30030 September 1999 Advises of NRC Plans for Future Insp Activities at Facility for Licensee to Have Opportunity to Prepare for Insps & to Provide NRC Feedback on Any Planned Insps Which May Conflict with Plant Activities.Plant Issue Matrix & Insp Plan Encl ML20212E7171999-09-22022 September 1999 Forwards RAI Re Requesting Approval of License Amend to Use Different Methodology & Acceptance Criteria for Reassessment of Certain Masonry Walls Subjected to Transient HELB Pressurization Loads 05000374/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Encl1999-09-20020 September 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Encl ML20212C0591999-09-17017 September 1999 Informs That NRC Reviewed Licensee Justifications for Deviations from NEDO-31558 & Determined That Justifications acceptable.Post-accident Neutron Flux Monitoring Instrumentation Acceptable Alternative to Reg Guide 1.97 ML20212A3581999-09-13013 September 1999 Confirms That Fuel MCPR Data for LaSalle County Station,Unit 1,Cyle 9,sent by Ltr Meets Condition 2,as Stated in 970509 NRC Ltr ML20211Q9911999-09-10010 September 1999 Informs That License SOP-4048-4,for Wp Sly May Be Terminated Due to Individual Retiring ML20212A1141999-09-10010 September 1999 Forwards RAI Re Licensee 990519 Amend Request,Which Proposed to Relocate Chemistry TSs from TS to licensee-controlled Documents.Response Requested by 990930,so That Amend May Be Issued to Support Upcoming Unit 1 Refueling Outage ML20211P2211999-09-0808 September 1999 Forwards Insp Repts 50-373/99-14 & 50-374/99-14 on 990809- 13.No Violations Noted.Insp Concluded That Emergency Preparedness Program Maintained in Good State of Operational Readiness ML20212A8571999-09-0707 September 1999 Informs That Proprietary Document, Power Uprate SAR for LaSalle County Station,Units 1 & 2, Rev 2,Class III, NEDC-32701P,submitted in ,Marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) ML20211Q6861999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Plant License Applicants During Wks of 001113 & 20. Validation of Exam Will Occur at Station During Wk of 001023 05000374/LER-1999-001, Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Encl1999-09-0303 September 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Encl ML20211M1151999-08-31031 August 1999 Requests That Following Eleven Individuals Take BWR Gfes of Written Operator Licensing Exam to Be Administered on 991006 ML20211G1831999-08-27027 August 1999 Provides Addl Clarification of Proposed Refueling Practices Under Proposed Core Alterations Definition Re 990813 Application for Amend to TS ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) ML20211F8731999-08-25025 August 1999 Forwards Insp Repts 50-373/99-13 & 50-374/99-13 on 990804-06 & 09-11.No Violations Noted.Fire Protection Program Strengths Includes Low Number of Fire Protection Impairments & Excellent Control of Transient Combustibles ML20210U3201999-08-17017 August 1999 Forwards Insp Repts 50-373/99-12 & 50-374/99-12 on 990623-0728.No Violations Noted ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed 05000373/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Listed1999-07-23023 July 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i).Commitments Made by Util Are Listed ML20210E0501999-07-22022 July 1999 Submits Summary of 990630 Management Meeting Re Licensee Performance Activities Since Start Up of Unit 2.List of Attendees & Matl Used in Presentation Enclosed ML20210B7071999-07-16016 July 1999 Responds to Requesting Review & Approval of Three Proposed Changes to Ceco QA TR,CE-1A Per 10CFR50.54(a)(3) & 10CFR50.4(b)(7) ML20209H5171999-07-15015 July 1999 Discusses 990701 Telcon Re Arrangements for NRC to Inspect Licensed Operator Requalification Program at LaSalle County Nuclear Generating Station for Weeks of 990913,1018 & 1129 ML20209G4031999-07-14014 July 1999 Forwards Insp Repts 50-373/99-11 & 50-374/99-11 on 990614-18.No Violations Noted ML20209E1211999-07-14014 July 1999 Submits mid-cycle Rev of COLR IAW LaSalle County Tech Spec 6.6.A.6.d.Rev to COLR Was Necessary Due to Implementation of TS Change Approved by Ltr Dtd 990212,which Changed Turbine Stop Valve & Turbine Control Valve Scram ML20209F6931999-07-13013 July 1999 Forwards Insp Repts 50-373/99-04 & 50-374/99-04 on 990513-0622.No Violations Noted.Determined That Multiple Challenges to Main Control Room Operators Occurred During Insp Period Due to Human Performance Weaknesses ML20210C1521999-07-0909 July 1999 Forwards Post-Outage (90 Day) Summary Rept for ISI Examinations & Repair/Replacement Activities Conducted from Beginning of First Insp Period of Second ten-yr Insp Interval Through L2R07 Refueling Outage ML20209G3901999-07-0909 July 1999 Informs NRC of Status of Commitments & Requests NRC Concurrence for Use of ASME Section III App F Acceptance Criteria to Permanently Qualify Units 1 & 2 Penetrations M-49 & M-50 ML20209E0341999-07-0909 July 1999 Provides NRC with Siemens Power Corp (SPC) Fuel & GE Fuel MCPR Data for LaSalle Unit 1 Cycle 9.LaSalle Unit 1 Is Currently Scheduled to Start Cycle 9 in 991101 ML20209E0361999-07-0808 July 1999 Forwards LaSalle County Station Unit 2 Cycle 8 Startup Test Rept Summary,Iaw TS NPF-18,Section 6.6.A.1.Startup Test Program Was Satisfactorily Completed on 990501 ML20196J9131999-07-0101 July 1999 Submits Status of Nuclear Property Insurance Currently Maintained for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR50.54(w)(3) ML20196J9061999-07-0101 July 1999 Provides Evidence That Util Maintains Guarantee of Payment of Deferred Premiums in Amount of $10 Million for Each of Thirteen Reactors,Per 10CFR140.21 ML20209B8241999-06-30030 June 1999 Forwards Five 3.5 Inch Computer Diskettes Containing Revised Annual Dose Repts for 1994 Through 1998 for Individuals Receiving Neutron Dose Not Previously Included in Reported Total Effective Dose Equivalent Values.Without Diskettes ML20196J4711999-06-30030 June 1999 Discusses Closure of GL 92-01,Rev 1,Suppl 1, Rv Structural Integrity, Issued on 950519 to Plant,Units 1 & 2 ML20212J0311999-06-21021 June 1999 Informs of Actions Taken to Close Remaining Open Items in .Attachment Provides Detailed Justification for Closure of Open Items in Sections 5.2.2 & 5.2.8 ML20196B1951999-06-18018 June 1999 Informs NRC That Do Werts,License OP-30373-2,no Longer Requires Use of NRC License for LaSalle County Station. License May Be Terminated ML20195J7761999-06-15015 June 1999 Submits Request Relief CR-23,requesting Relief from Code Required Selection & Examinations of Noted Integral Attachments & Proposes to Utilize Alternative Selection & Examination Requirements Similar to Code Case N-509 ML20196G8021999-06-15015 June 1999 Requests Renewal of SRO License for Vv Masterson.Current License for Vv Masterson Will Expire Jul 1999.NRC Forms 398 & 396,encl.Without Encls ML20195G7101999-06-11011 June 1999 Informs That Effective 990514,GH Mccallum,License SOP-31412, No Longer Requires Use of NRC License for LaSalle Station. License Should Be Terminated ML20195D6351999-06-0404 June 1999 Notifies NRC of Actions That Has Been Taken in Accordance with 10CFR26, Fitness for Duty Programs ML20207D2821999-05-27027 May 1999 Requests That Implementation Date for Unit 1 Be Changed Prior to Startup for L1C10 to Allow Best Allocation of Resources to Implement Unit 1 Amend Prior to Startup for Either L1C9 or L1C10.Unit 2 Will Implement Mod IAW Request 1999-09-08
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217D3191999-10-12012 October 1999 Submits Request for Addl Info Re Licensee 990707 Proposed License Amend to Revise Min Critical Power Ratio.Listed Questions Were Discussed with Util in 991001 Telcon ML20217A7601999-10-0606 October 1999 Forwards Insp Repts 50-373/99-15 & 50-374/99-15 on 990729-0916.One Violation of NRC Requirements Occurred & Being Treated as Ncv,Consistent with App C of Enforcement Policy ML20212M0931999-10-0404 October 1999 Refers to 990922-23 Meeting Conducted by Region II at LaSalle Nuclear Power Station.Purpose of Visit,To Meet with Licensee Risk Mgt Staff to Discuss Util Initiatives in Risk Area & to Establish Dialog Between SRAs & Risk Mgt Staff ML20217A6201999-09-30030 September 1999 Advises of NRC Plans for Future Insp Activities at Facility for Licensee to Have Opportunity to Prepare for Insps & to Provide NRC Feedback on Any Planned Insps Which May Conflict with Plant Activities.Plant Issue Matrix & Insp Plan Encl ML20212E7171999-09-22022 September 1999 Forwards RAI Re Requesting Approval of License Amend to Use Different Methodology & Acceptance Criteria for Reassessment of Certain Masonry Walls Subjected to Transient HELB Pressurization Loads ML20212C0591999-09-17017 September 1999 Informs That NRC Reviewed Licensee Justifications for Deviations from NEDO-31558 & Determined That Justifications acceptable.Post-accident Neutron Flux Monitoring Instrumentation Acceptable Alternative to Reg Guide 1.97 ML20212A3581999-09-13013 September 1999 Confirms That Fuel MCPR Data for LaSalle County Station,Unit 1,Cyle 9,sent by Ltr Meets Condition 2,as Stated in 970509 NRC Ltr ML20212A1141999-09-10010 September 1999 Forwards RAI Re Licensee 990519 Amend Request,Which Proposed to Relocate Chemistry TSs from TS to licensee-controlled Documents.Response Requested by 990930,so That Amend May Be Issued to Support Upcoming Unit 1 Refueling Outage ML20211P2211999-09-0808 September 1999 Forwards Insp Repts 50-373/99-14 & 50-374/99-14 on 990809- 13.No Violations Noted.Insp Concluded That Emergency Preparedness Program Maintained in Good State of Operational Readiness ML20212A8571999-09-0707 September 1999 Informs That Proprietary Document, Power Uprate SAR for LaSalle County Station,Units 1 & 2, Rev 2,Class III, NEDC-32701P,submitted in ,Marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) ML20211Q6861999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Plant License Applicants During Wks of 001113 & 20. Validation of Exam Will Occur at Station During Wk of 001023 ML20211F8731999-08-25025 August 1999 Forwards Insp Repts 50-373/99-13 & 50-374/99-13 on 990804-06 & 09-11.No Violations Noted.Fire Protection Program Strengths Includes Low Number of Fire Protection Impairments & Excellent Control of Transient Combustibles ML20210U3201999-08-17017 August 1999 Forwards Insp Repts 50-373/99-12 & 50-374/99-12 on 990623-0728.No Violations Noted ML20210E0501999-07-22022 July 1999 Submits Summary of 990630 Management Meeting Re Licensee Performance Activities Since Start Up of Unit 2.List of Attendees & Matl Used in Presentation Enclosed ML20210B7071999-07-16016 July 1999 Responds to Requesting Review & Approval of Three Proposed Changes to Ceco QA TR,CE-1A Per 10CFR50.54(a)(3) & 10CFR50.4(b)(7) ML20209H5171999-07-15015 July 1999 Discusses 990701 Telcon Re Arrangements for NRC to Inspect Licensed Operator Requalification Program at LaSalle County Nuclear Generating Station for Weeks of 990913,1018 & 1129 ML20209G4031999-07-14014 July 1999 Forwards Insp Repts 50-373/99-11 & 50-374/99-11 on 990614-18.No Violations Noted ML20209F6931999-07-13013 July 1999 Forwards Insp Repts 50-373/99-04 & 50-374/99-04 on 990513-0622.No Violations Noted.Determined That Multiple Challenges to Main Control Room Operators Occurred During Insp Period Due to Human Performance Weaknesses ML20196J4711999-06-30030 June 1999 Discusses Closure of GL 92-01,Rev 1,Suppl 1, Rv Structural Integrity, Issued on 950519 to Plant,Units 1 & 2 ML20195B6031999-05-24024 May 1999 Ack Receipt of Which Transmitted Changes Identified as Rev 60 to LaSalle Nuclear Station Security Plan,Submitted Per Provisions of 10CFR50.54(p) ML20206U3641999-05-19019 May 1999 Confirms Plans to Conduct Routine Mgt Meeting on 990630 in Lisle,Il Re Recent Plant Performance & Lessons Learned from Unit 2 Restart ML20206T0081999-05-19019 May 1999 Forwards Insp Repts 50-373/99-03 & 50-374/99-03 on 990401-0512.Two Violations of NRC Requirements Occurred & Being Treated as non-cited Violations.One Violation Re Two Operators Failure to Log Suppression Pool Temp as Required ML20206S5291999-05-14014 May 1999 Forwards Insp Repts 50-373/99-10 & 50-374/99-10 on 990419-23.Violation Noted:Nrc Determined That Previously Unresolved Item Involving Failure to Adequately Implement fitness-for-duty program,non-cited Violation ML20206K7401999-05-0303 May 1999 Informs That as Result of April 1999 Senior Mgt Meeting, LaSalle Identified as Routine Oversight Plant.Summary of NRC Discussion Related to LaSalle Listed.Meeting Scheduled for 990506 to Discuss Latest Meeting of NRC Senior Managers ML20206G6631999-05-0303 May 1999 Forwards Insp Repts 50-373/99-07 & 50-374/99-07 on 990329- 0402.NRC Determined That Two Violations of NRC Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20206G7511999-05-0303 May 1999 Forwards Insp Repts 50-373/99-09 & 50-374/99-09 on 990406-09.No Violations Were Identified.Insp Focused on Actions Recently Taken to Identify Common Causes for Previously Identified Programmatic Radiation Staff Problems ML20205S8101999-04-20020 April 1999 Forwards Insp Repts 50-373/99-08 & 50-374/99-08 on 990311- 26.No Violations Noted.Overall,Insp Results Indicated That Unit 2 Mods Properly Installed & That Plant Matl Condition of Unit 2 Acceptable ML20205R5461999-04-16016 April 1999 Forwards Insp Repts 50-373/99-02 & 50-374/99-02 on 990217- 0331.Non-cited Violation Re Failure of Operator to Follow Procedure Which Resulted in Surveillance Procedure Acceptance Criteria Being Evaluated ML20205R4171999-04-16016 April 1999 Forwards Summary of 990406 Meeting Re Readiness for Restart of Plant,Unit 2 & Dual Unit Operation & Recent Plant Performance Review Issued by NRC ML20205J2381999-04-0505 April 1999 Submits Summary of 990322 Meeting with Util to Discuss Experiences & Performance of Plant Since Startup of Unit 1 Status of Matl Condition & Unit 2 Outage.Associated Meeting Summary & Handouts Provided by Util Encl ML20205D5801999-03-29029 March 1999 Refers to Insps 50-373/98-17 & 50-374/98-17 & Subsequent OI Investigation 3-98-032 Into Info Reported to NRC by Comed on 980518,that Deliberate Violation of NRC-required FFD Program May Have Occurred at LaSalle & Forwards NOV ML20205D6971999-03-29029 March 1999 Discusses Insp Repts 50-373/98-17 & 50-374/98-17 & OI Rept 3-98-015 Completed on 981119 & Forwards Nov.Apparent Deliberate Violation of NRC-required Comed Fitness for Duty Program Noted ML20205G5411999-03-26026 March 1999 Advises of Completion of Plant Performance Review on 990204 to Develop Integrated Understanding of Safety Performance. Overall Performance at Plant Improved as Discussed.Insp Plan & Plant Issues Matrix Encl ML20205A6411999-03-25025 March 1999 Refers to Investigation Conducted by OI (Investigations Rept 3-1998-028) to Determine If Employment Discrimination Occurred After Contract Worker Raised Radiation Safety Concerns Re Plant.Synopsis from Subj Rept Encl ML20204J8411999-03-24024 March 1999 Submits Summary of 990226 Meeting Re Performance of LaSalle Since Startup of Unit 1,status of Matl Condition of LaSalle & Status of Unit 2 Outage.List of Attendees & Matl Used Encl ML20205A6211999-03-24024 March 1999 Discusses 990226 Mgt Meeting with Util Re Performance of LaSalle Since Startup of Unit 1,status of Matl Condition of LaSalle & Status of Unit 2 Outage.Associated Meeting Summary & Handout Provided to NRC by Util Encl ML20204J7021999-03-22022 March 1999 Confirms Plans to Conduct Mgt Meeting on 990406 at Mazon Emergency Operations Facility to Discuss Readiness for Restart of Unit 2 ML20204E0751999-03-18018 March 1999 Discusses Review of Rev 6M to Portions of Plant Emergency Plan Site Annex ML20207J8901999-03-10010 March 1999 Forwards Insp Repts 50-373/99-01 & 50-374/99-01 on 990106- 0216.No Violations Identified.Personnel Errors Occurred During Insp Period.Overall Performance of Plant Personnel Acceptable ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function ML20203C9811999-02-0808 February 1999 Ack Receipt of ,Which Transmitted Changes Identified as Rev 59 to Security Plan.No NRC Approval Required ML20203A1981999-02-0202 February 1999 Forwards Insp Repts 50-373/98-23 & 50-374/98-23 on 981121-990105.No Cited Violations Identified.Two Equipment Problems Identified During Shutdown for Planned Outage Were Not Effectively Addressed to Preclude Problem Recurrence ML20198N4531998-12-18018 December 1998 Confirms Plans to Conduct Routine Mgt Meeting on 990119 at Mazon Emergency Operations Facility to Discuss Lasalle,Unit 1 Performance & Status of Lasalle,Unit 2 Restart Activities ML20198E9281998-12-17017 December 1998 Forwards Insp Repts 50-373/98-22 & 50-374/98-22 on 981010- 1120.No Violations Noted.Overall Performance of Plant Personnel Was Acceptable ML20198F2891998-12-16016 December 1998 Forwards Insp Repts 50-373/98-25 & 50-374/98-25 on 981102-06.No Violations Noted.Insp Was Evaluation of Operator Workaround Program ML20198B3741998-12-14014 December 1998 Forwards SE Accepting one-time Request for Relief from Certain Provisions of Section XI of ASME Boiler & Pressure Vessel Code,Per 10CFR50.55a for Certain Plant Safety/Relief Valves ML20197H3561998-12-0404 December 1998 Final Response to FOIA Request for Docments.Records in App a Encl & Will Be Available in PDR ML20198B1531998-12-0202 December 1998 Forwards Insp Plan for Next 6 Months & Plant Issues Matrix. Info Provided to Minimize Resource Impact on Staff & to Allow for Scheduling Conflicts & Personnel Availability to Be Resolved in Advance of Inspector Arrival Onsite ML20196F7361998-12-0202 December 1998 Informs That Document GE-NEDC-31531P,Suppl 1, ARTS Improvement Analysis for Lscs,Units 1 & 2,Removal of Direct Scram Bypassed Limits, Marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) ML20196G4601998-11-27027 November 1998 Forwards FEMA Correspondence, Transmitting FEMA Final Evaluation Rept for 980318 Emergency Preparedness Exercise at LaSalle Nuclear Generating Station 1999-09-08
[Table view] |
See also: IR 05000373/1996014
Text
l
l
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1
January 8, 1997
Mr. W. T. Subalusky, Jr
Site Vice President
LaSalle County Station
Commonwealth Edison Company
2601 North 21st Road
Marseilles, IL 61341
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS
NO. 50-373/96014(DRS); 50-374/96014(DRS))
Dear Mr. Subalusky:
This will acknowledge receipt of your letter dated December 20,1996,in response to our
letter dated November 20,1996, transmitting a Notice of Violation associated with the
failure to adequately consider the effects of incore irradiation of intermediate range
monitors (IRMs) during the preparation for removal of IRMs on May 22 and July 1-2,
1996, and the failure to follow the requirements of the radiation work permit (RWP) during
radwaste pump aisle work on August 20,1996. In your response to the violations, you
indicated that the replacement of the IRMs was performed during two separate forced
outages and that the replacement required two entries into the drywell in a Hot Shutdown
condition and not at power as stated in the subject report. We acknowledge that the IRMs
were removed during Hot Shutdown conditions and not at power. We have reviewed your
corrective actions for the violations and have no further questions at this time. These
corrective actions will be examined during future inspections.
Sincerely,
/s/ M. Icach (for)
Geoffrey E. Grant, Director
Division of Reactor Safety 1
i
Docket Nos. 50-373; 50-374 l
Licenses No. NPF-11; NPF-18
Enclosure: Ltr 12/20/96 W. T. Subalusky,
Comed to US NRC, w/ enc!
See Attached Distribution
1
1
'
SEE ATTACHED CONCURRENCES
I
DOCUMENT NAME: G:DRS/LAS010_7.DRS
1. .e. .. . con ' o'i. d-e - a'. * 'ica'- 4a c - corr -/ " i. ci r . c. ,, .f. u f. ,i n - n. .,,
OFFICE Rill l Rill l Rlll l#
NAME NShah:jp TKozak MLeach/GGrantM
DATE 01/ /97 01/ /97 01/ 8 /97
0FFICIAL RECORD COPY
9701130078 970108
PDR ADOCK 05000373
O PDR
. _ _ _ . . . _-.-. - -
_ . .- - _ . - _ - - - .--- .- _ - .-
.
l
i *
.
Mr. W. T. Subalusky, Jr
Site \nce President
LaSalle County Station
Commonwealth Edison Company .
2601 North 21st Road
Marseilles, IL 61341
Dear Mr. Subalusky:
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS NO. 50-373/96014
(DRS); 50-374/96014(DRS)
r
l This will acknowledge receipt of your letter dated December 20,1996,in response to our
!
letter dated November 20,1996, transmitting a Notice of Violation associated with the
l failure to adequately consider the effects of incore irradiation of intermediate range
'
monitors (lRMs) during the preparation for removal of IRMs on May 22 and July 1-2,
l 1996, and the failure to follow the requirements of the radiation work permit (RWP) during
radwaste pump aisle work on August 20,1996. In your response to the violations, you
! indicated that the replacement of the IRMs was performed during two separate forced
outages and that the replacement required two entries into the drywellin a Hot Shutdown
condition and not at power as stated in the subject report. We acknowledge that the IRMs
were removed during Hot Shutdown conditions and not at power. We have reviewed your
corrective actions for the violations and have no further questions at this time. These
corrective actions will be examined during future inspections.
l
Sincerely,
Geoffrey E. Grant, Director
Division of Reactor Safety .
Docket Nos. 50-373; 50-374
Licenses No. NPF-11; NPF-18
Enclosure: Ltr dtd 12/20/96
See Attached Distribution
DOCUMENT NAME: G:DRS/LAS010_7.DRS
g g .i..
, . .,, ., ini. . . . ..... . i in. n . c c.,, iin.. .ti.cnt..ci r - c.,, iin .ti.cnf...i n-
0FFICE RIII C RIII /] RIII
NAME NShah:jp @ TKozakY MLeach/GGrant
DATE 01/7 /97 01/ 1 /97 01/ /97
'
l OFFICIAL RECORD COPY
.. - - - _ -- -
__ _ __ ____ _
4
.
W. T. Subalusky -2- January 8 1997
cc w/o encl: T. J. Maiman, Senior Vice President
Nuclear Operations Division
D. A. Sager, Vice President,
Generation Support
H. W. Keiser, Chief Nuclear
Operating Officer
D. J. Ray, Station Manager
J. Burns, Regulatory Assurance
i
Supervisor
1. Johnson, Acting Nuclear
Regulatory Services Manager
f cc w/ encl: Document Control Desk - Licensing
i Richard Hubbard i
! Nathan Schloss, Economist, i
Office of the Attorney General
l State Liaison Officer
Chairman, Illinois Commerce Commission
Distribution:
Docket File w/enci Rlli PRR w/enci W. L. Axelson, Rlll w/enci
PUBLIC IE-01' w/ encl SRis, LaSalle, Dresden, RAC1 w/ encl (E-mail)
OC/LFDCB w/enci Quad Cities w/enct Enf. ' Coordinator, Rlli w/enci
DRP w/enct LPM, NRR w/enci
DRS w/enct A. B. Beach, Rlli w/enci
1
130037
.o
-
1
. . O mnu,nucahh tihmin Compan3 '
<
ie inc c.cocraiinoiainin
2(d i %,rth 21 i Hii.iti
. Wrs illev 11.(if 4 e i4'i' )
l
wi xn <s .<, ,.
!
s
i
December 20,1996
^
i
United States Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, D.C. 20555 I
s
Subject: REVIEW OF AUGUST 20,1996, ADMINISTRATIVE
-
i
OVEREXPOSURE AND RESULTS OF THE
OCTOBER 15-18,1996, RADIATION PROTECTION
(RP) INSPECTION
Reference: l
G. E. Grant letter to W. T. Subalusky, dated l
November 20,1996, Transmitting NRC Inspection
Report 373/374-96014 f 1
The enclosed attachment contains LaSalle County Station's response to the
Notice of Violation, that was transmitted in the Reference letter.
The letter transmitting the referenced Notice of Violation contained a
statement that needs clarification. The replacement of the Intermediate
Range Monitors was performed during two separate forced outages.
Replacement required two entries into the drywell in a Hot Shutdown
condition and not at power as stated in the report.
If therq.are any questions or comments conceming this letter, please Tdfer
them to me at (815) 357-6761, extension 3600.
Respectfully,
h ^
W. T. Subalusky
Site Vice President
LaSalle County Station
Enclosure
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cc: /B. Beach, NRC Region 111 Administrator
M. P. Huber, NRC Senior Resident inspector - LaSalle
p. M. Skay, Project Manager - NRR - LaSalle
DCD - Ucensing (Hardcopy: Electronic: )
Central File
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ATTACHMENT
RESPONSE TO NOTICE OF VIOLATION
NRC INSPECTION REPORT
373/374-96-014
VIOLATION: 373/374-96-014-01
10 CFR 20.1501 requires that each licensee make or cause to be made surveys that !
may be necessary for the licensee to comply with the regulations in Part 20 and that are
reasonable under the circumstances to evaluate the extent of radiation levels,
concentrations or quantities of radioactive materials, and the potential radiological
hazards that could be present.
Pursuant to 10 CFR 20.1003, surveymeans an evaluation of the radiological conditions
and potential hazards incident to the production, use, transfer, release, disposal, or
presence of radioactive material or other sources of radiation.
Contrary to the above, on May 22,1996, and July 1-2,1996, the licensee did not make
surveys to assure compliance with 10 CFR 20.1201(a), which limits radiation exposure
to 5 rem total effective dose equivalent (TEDE). Specifically, the licensee did not
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adequately consider the effects of incore irradiation of intermediate range monitors
(IRMs), as disseminated in NRC Information Notice 88-63, during the preparation for
removal of IRMs on May 22,1996, and July 1-2,1996.
This is a Severity Level IV violation (Supplement IV). *
REASON FOR VIOLATION: 373/374/96-014-01
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On May 22,1996, an entry was made into the Unit Two Drywell with the reactor in a Hot l
Shutdown condition. The purpose of this entry was to replace the 'D' IRM , Normal
station practice is to allow a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> decay time after reactor shutdown prior to
removing in-core detectors. Due to the scheduled short duration of the forceioutage,
the 'D' IRM was replaced within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of reactor shuidown. The ALARA analyst
considered the short time after reactor shutdown as he was preparing the ALARA plan '
for tne activity. Lessons learned from an event at Quad Cities Station involving a
detector that was stuck in the core and read approximately 200 R/Hr was included in
the ALARA review. Due to inadequate communications between the ALARA analyst,
Operations and the Nuclear Engineering group, the ALARA analyst calculated an
expected dose rate using the assumption that the detector had been placed out of
service for over a month, thereby precluding exposure to neutron flux. In fact, the
detector had been declared inoperable due to high noise, but had not been tagged out
of service, and had been inserteo into the core during the reactor shutdown.
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ATTACHMENT
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RESPONSE TO NOTICE OF VIOLATION !
NRC INSPECTION REPORT
373/374-96-014 I
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The ALARA plan for the work required a continuous survey by a Radiation Protection
Technician (RPT) during detector removal. The RPT was to stop work if a 10R/Hr
contact dose rate was observed on the detector. The RPT actually stopped work after ,
identifying a dose rate of 7 R/Hr. The radiological conditions were assessed and
additional controls were put in place before the work was resumed. The detector t
replacement continued without any additional radiological concems. The estimated
exposure for the work was 270 mrem. The actual exposure for the detector
replacement was 199 mrem. The ALARA Analyst documented the unexpected dose :
rate on a Problem Identification Form (PlF). This PlF was reviewed by the Event
Screening Committee and assigned to the Work Control Department with a non-
significant status._ ;
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' On July 1 another replacement of the 'D' IRM was performed on Unit 2. The same
ALARA Analyst prepared the ALARA plan for this activity. He verified that this IRM had
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been removed from the core and taken out of service in late May. Additionally, in
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accordance with normal station practices the reactor was shutdown greater than j
l 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before the detector was removed. Based on this information, dose rates were
! expected to be minimal. This detector replacement was completed with no radiological
concems. :
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The primary cause of the May 22,1996, event was inadequate communications
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between Operations, Radiation Protection, and System Engineering. This resulted in a
l lack of clear understanding of when the Intermediate Range Monitor (IRM) detector had
last been exposed to neutron flux. A contributing cause of this violation was that station
procedures and the travelers used to generate work packages did not contain
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adequate controls to ensure irradiation of detectors was properly evaluated prior to
detector removal. This was identified in May and documented on a Problem l
identification Form (PlF). This PlF was given a low priority and assigned incorrectly to
the Work Control Department. Untimely corrective actions allowed a seconoTncore -
detector to be removed without addressing the concems identified in the PIF.
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ATTACHMENT
RESPONSE TO NOTICE OF VIOLATION
NRC INSPECTION REPORT
373/374-96-014 !
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CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED: '
The PIF generated as a result of these higher than anticipated dose rates was
reclassified as significant and reassigned to the Radiation Protection Department for
resolution. The Radiation Protection Manager now reviews all PIF's generated to
identify any that involve the RP Department or Rad Worker practices. The RPM then
ensures that the proper level of attention is given to resolving the identified issues. A
review of the procedure, LFP-600-3, "lRM and SRM Handling" was performed and the
procedure was found to be inadequate in several areas including no reference to incore 1
exposure history at the detector and, in addition, there were extensive references to l
equipment / tools rto longer in use. )
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CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS
LFP-600-3 "lRM and SRM Handling" and LFP-600-4 "TIP Removal" have been revised
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to include references to IN 88-63. A requirement was added for Operating to provide
detector exposure history to Radiation Protection for determination of anticipated dose q
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rates. An exposure history and dose calculation was included in the ALARA plan for !
each detector removal. This information will be reviewed by the ALARA Planner prior to
the commencement of work. The procedures were revised to include the requirement :
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that an RPT be in continuous attendance during detector removal to perform surveys.
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The travelers that are used to develop the work packages for removal of SRM's, IRM's,
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and TIP's were revised to include a sign-off for the Operating Engineer and Radiation
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Protection Supervision before work is begun. This signature is to ensure that irradiation
of the detectors is taken into consideration when developing the ALARA plan
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED: .,_
Full compliance was achieved with the revision of procedures LFP-600-3 and
LFP-600 4.
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!" ATTACHMENT '
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RESPONSE TO NOTICE OF VIOLATION
NRC INSPECTION REPORT
373/374-96-014
VIOLATION: 373/374-96-014-03
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Technical Specification 6.2(B) states that radiation control procedures shall be
maintained, made available to all station personnel, and adhered to.
Station procedure LAP-100-22 (Revision No.18), " Radiation Work Permit (RWP)
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Program," Step e(4), requires that workers comply with the requirements of the RWP
and all associated documents.
RWP No. 960027Jequired that the radiation protection (RP) department be notified i
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Contrary to the above, on August 20,1996, a radwaste operator performed work in the
radwaste pump aisle, without contacting the RP department as required by
RWP No. 960027
This is a Severity Level IV violation (Supplement IV).
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REASON FOR VIOLATION: 373/374/96-01443
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A Radwaste Supervisor was tasked to determine if the waste collector and waste surge i
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tanks needed to be cleaned of solids / sludge as a part of a larger project to replace the I
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' radwaste filter elements. This task involved removing all water and performing a visual
irispection of those tanks. The tanks are in a high radiation area; not frequently
accessed.
While assisting the removal of water operation from the Equipment Drains (WE) Surge
Tank, an opwator received a total whole body exposure of 52.7 mrem as determined by
his electronic dosimeter (ED). He was authorized to receive 50 mrem in accordance
with the Radiation Work Permit (RWP) he was using. Following the event, a survey
determined the working dose rates were 200 to 400 mrem /hr. This exceeded the
j expected 20 to 35 mrem /hr dose rate.
Although the Radwaste Group, Radiation Protection (RP), and the ALARA Group were
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aware of the work that was to be performed, the potential for elevated dose rates in the
Radwaste Pump Aisle was not identified. This was a result of inadequate supervisory
methods and failure to communicate expectations. Neither the Radwaste Shift
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Supervisor leading the job briefing, nor the Radiation Protection Technician (RPT) l
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ATTACHMENT
RESPONSE TO NOTICE OF VIOLATION
NRC INSPECTION REPORT
373/374-96-014
attending the briefing, specifically reminded the operator entering the Radwaste Pump
Aisle to frequerstly check his digidose readings while in the Radwaste Pump Aisle. The
writers and reviewers of the special procedures did not identify the potential for
changing dose rates, even though the purpose of the special procedures was to allow
the water level to drop down lower than normal to observe the sludge layer in the tanks.
The general RWP used by the operator entering the Radwaste Pump ' Aisle did not
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allow draining of'any system that could result in changing the radiological conditions of
an area without RP approval. Inadequate communication between the Operator and
the RPT resulted in a " key" being issued for entry into the Radwaste Pump Aisle without
the RPT having a clear understanding of the scope of work planned in the Radwaste i
Pump Aisle.
The operator did not periodically review his ED status to verify his accumulated dose.
The RPT attending the pre-job briefing did not question the duties of the individualin
the Radwasto Pump Aisle.
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The ALARA review performed the day of the work did not include review of the special
procedures portion because the focus was on the non routine entry of the tank room
and because the Radwaste Pump Aisle operator work was thought to be routine. The
ALARA review did not include all personnel involved in the work since the inspection of
the tank was handled as a separate RWP and separate task from the pump down of
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the tanks. There was no separate job specific RWP for the Radwaste Pump Aisle work i
to perform the special procedures to pump down the tanks because Operating believed
the work to be routine.
A RWP request submitted by the supervisor of the work did not relate the full scope of
the work being performed. Per the RWP request, only a tank inspection was to be
completed. During the planning process, RP was informed of the entire projecTscope
of the tank inspection. No discussion was held regarding the potential for changing
area dose rates in the Radwaste Pump Aisle.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
A chain and lock were installed to secure the door until the investigation was
completed.
An investigation survey was conducted, identifying the hot lines. A flush was completed
to reduce the general area dose rates back to normallevels.
The individual's TLD was pulled for processing and the individual was denied access to
the RPA pending a review of the event.
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ATTACHMENT
RESPONSE TO NOTICE OF VIOLATIO:J
NRC INSPECTION REPORT
373/374-96-014
The operating department individual and his supervisor were counseled regarding the
responsibility of the individuals when in a High Radiation Area.' The non licensed
operator and the Radwaste Supervisor received appropriate discipline. To help the
individuals involved to fully understand the event, the Radwaste Supervisor was
assigned to lead the Root Cause Evaluation Team.
An article was placed in the plant newsletter describing the event, highlighting several
areas needing improvements, which may have prevented this event. This event was
communicated in two successive Plan of the Day Meetings to statien departments. This
event is also currently communicated in NGET Training classes.
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The details of this event were reviewed with the entire Radwaste Staff and the
Radiation Protection Department.
Communications within the Radwaste Department has been improved. The Radwaste
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Shift Supervisor now meets each weekday prior to day shift, with the Radwaste
Operators. During this m5eting, the supervisor discusses all work to be performed C
throughout the day. His discussions include related Radiation protection information
and status and Radiation Standards and Expectations.
CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS:
All 1997 RWPs have been written to. require an electronic dosimeter with ear piece
when accessing the Radwaste Pump Aisle or other High Rad /High Noise area.
The Radiation Protection Department will perform a review of the time keeping
functionality of the electronic dosimeter in high noise areas of the plant. Areas
exceeding the recommended ambient noise level as set forth by the manufacturer will
be evaluated for further controls. This will completed by April 1,1997. -
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on October 21,1996, when Radwaste Operations began
meeting with the shift personnel prior'o any work beginning in an RPA.
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