ML20134M986

Notice of Violation from Insp on 960903-24.Violations Noted: on 960331,for Unit 1 & on 960531,for Unit 2,fuel Pool Emergency Makeup Pumps Removed from Svc to Be Modified by Adding SS Weld Overlay to CS Pump Casing

ML20134M986
Person / Time
Site:	LaSalle
Issue date:	11/15/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20134M955	List: ML20134M953 ML20134M986 ML20134N017
References
50-373-96-11, 50-374-96-11, NUDOCS 9611260113
Download: ML20134M986 (4)

Text

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NOTICE OF VIOLATION l Commonwealth Edison Company Dockets No. 50-373, 50-374 l LaSalle County Station Licenses No. NPF-11, NPF-18 'I Units 1 and 2 i

During an NRC inspection conducted on September 3 through 24,1996, five violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. 10 CFR Part 50, Appendix B, Criterion Ill, " Design Control," requires, in part, that measures be established to ensure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions, it further requires that design changes be subject to design controls commensurate to those applied to the original design and that the changes be approved by the responsible design organization.

Contrary to the above:

1. On March 31,1996, for Unit 1 and on May 31,1996, for Unit 2, the fuel pool emergency makeup pumps were removed from service in order to be modified by adding a stainless steel weld overlay to the carbon steel pump casing and this design change was not subject to design controls

) commensurate to those applied to the original design. Furthermore, the design change was not approved by the responsible design organization because it was performed as a maintenance activity.

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2. As of September 24,1996, the design basis temperature of the high pressure coolant system was incorrectly translated into calculations VY-004,

" Unit 1, Division i ECCS Equipment Cooling Water System," Revision 0, ATD-0375, "ECCS Pump Room Temperature During Shutdown With Area Coolers inoperable," Revision 0, and 3C7-089-001, "ECCS Room Temperature Transient Following LOCA Concurrent With Loss of Area Cooler," Revision 1, Revision O. This was due to a 1985 design change which modified the suction of the HPCS system from the condensate storage tank to the suppression pool and increased the design basis temperature.

This is a Severity Level IV violation (Supplement I).

1 B. 10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires, in part, that tests be performed in accordance with written test procedures which incorporate  ;

the requirements and acceptance limits contained in applicable design documents. '

DO 73 G PD?1  !

a Notice of Violation It further requires that test results be evaluated to ensure that tes, requirements have been satisfied.

Contrary to the above:

1.

As of September 24,1996, surveillance test procedure LTS-200-3, "RHR Heat Exchanger Tubeside DP Test," Revision 3, did not contain acceptance limits contained in the design equipment specification for the residual heat removal heat exchanger differential pressure.

2. As of September 24,1996, the results of tests on the 28 residual heat removal heat exchanger had not been adequately evaluated in that an increase in differential pressure within the tubes by approximately 22 percent over a three year period from 1992 to 1995 was not detected or evaluated to ensure test requirements had been satisfied.

This is a Severity Leve'.1V violation (Supplement I).

C.

Technical Specification surveillance 4.7.1.3.c requires, at least once per 18 months, determination that sediment deposition anywhere within the lake screen house behind the bar grill is not greater than one foot in thickness.

4 Contrary to the above, the following portions of the circulating water bays, within the lake screen house behind the bar grill, were not determined to have sediment l

depositions of no greater than one foot in thickness at least once in an 18 month l period:

1. Between November 12,1992, and February 9,1996, the northwest and southeast corners of the three Unit 1 circulating water bays were not inspected.

2. Between January 8,1992, and February 28,1996, the northwest and southeast corners of the Unit 2A circulating water bay were not inspected.

3. Between December 6,1991, and February 28,1996, the northwest and southeast corners of the Unit 2B circulating water bay were not inspected.

4. Between February 18,1992, and March 15,1995, the northeast and southwest corners of the Unit 2C circulating water bay were not inspected.

5. Between September 27,1993, and February 28,1996, the northwest and southeast corners of the Unit 2C circulating water bay were not inspected.

This is a Severity Level IV violation (Supplement 1).

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Notice of Violation ,

1 D.

10 CFR Part 50, Appendix B, Criterion V, " Instructions, Pracedures, and Drawings,"

requires, in part, that activities affecting quality be perform ?d using documented j

instructions or procedures of a type appropriate to the circumstances. \ l Commonwealth Edison Quality Assurance Manual, Revisior'. 65a, dated April 17, 1995, Section 5, " Instructions, Procedures, and Drawings," requires, in part, that activities governed by the quality assurance program be performed using documented instructions, procedures, and drawings appropriate for the activity.

Contrary to the above, in February 1996, the licensee first leveled the sedimentation such that it would comply with technical specifications and then removed the sediment from the Unit 1 circulating water bays without any documented instructions or procedures.

I This is a Severity LevelIV violation.

1 E.

10 CFR 50.71(e) requires, in part, that licensees update the Final Safety Analysis Report periodically to reflect modifications to the plant. Subsection (4) requires such updates to be no more than 24 months apart and to reflect all changes made up to a maximum of six months prior to the update.

Contrary to the above, as of September 24,1996, the LaSalle Updated Final Safety 3-Analysis Report had not been updated to reflect the change in initial and maximum suppression pool temperatures approved by License Amendments 67 (Unit 1) and 49 (Unit 2), issued in July 1989. This period exceeds 24 months.

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company is hereby required to submit a written statement of explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region lil, and a copy to the NRC Resident inspector at the LaSalle facility, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and '

should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should  !

not be taken. Where good cause is shown, consideration will be given to extending the  !

response time.

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Notice of Violation - Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Lisle, Illinois this 15th day of November 1996