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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:INCOMING CORRESPONDENCE
MONTHYEARML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl 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 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 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 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 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 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 ML20211Q9911999-09-10010 September 1999 Informs That License SOP-4048-4,for Wp Sly May Be Terminated Due to Individual Retiring 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) 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 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 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 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 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 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 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 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 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 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 ML20195B2301999-05-19019 May 1999 Requests Approval of Proposed Changes to QA Topical Rept CE-1-A,rev 66a.Attachment a Describes Changes,Reason for Change & Basis for Concluding That Revised QAP Incorporating Proposed Changes Continues to Satisfy 10CFR50AppB ML20206R4561999-05-12012 May 1999 Provides Notification That Ws Jakielski,License SOP-30168-3, Is Being Reassigned & No Longer Requires Use of NRC License, IAW 10CFR50.74 ML20206K7081999-05-0707 May 1999 Forwards 10CFR50.46(a)(3) Rept Re Significant Change in Calculated Pct.Loca Analyses for Both GE Fuel & Siemens Power Corp Fuel Demonstrates Results within All of Acceptance Criteria Set Forth in 10CFR50.46 05000373/LER-1999-001, Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(ii).Attachment a Provides Commitments for Submittal1999-05-0707 May 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(ii).Attachment a Provides Commitments for Submittal ML20206K1861999-04-30030 April 1999 Informs That in Comed Submitted Annual Exposure Rept for Personnel Receiving Greater than 0 Mrem/Yr Rather than 100 Mrem/Yr.Updated Rept Limiting Data to Personnel Receiving Greater than 100 Mrem/Yr,Attached ML20206F0931999-04-30030 April 1999 Forwards LaSalle County Nuclear Power Station,Units 1 & 2 Effluent & Waste Disposal Semi-Annual Rept for 1998. LaSalle County Station Tech Specs Recently Revised to Reduce Periodicity of 10CFR50.36a ML20206R0751999-04-30030 April 1999 Forwards License Renewal Applications & Certification of Medical Examinations for LaSalle County Station Personnel Whose Licenses Expire in Nov.Personnel Listed.Without Encls ML20206D5921999-04-28028 April 1999 Forwards Annual Environ Operating Rept for 1998 for Environ Protection Plan, for LaSalle County Station,Units 1 & 2. Rept Includes Info Required by Listed Subsections of App B to Licenses NPF-11 & NPF-18 ML20206B2471999-04-20020 April 1999 Informs That SE Kuczynski Has Been Transferred to Position No Longer Requiring SRO License.Cancel License SOP-31030-1, Effective 990412 ML20205L8161999-04-0808 April 1999 Advises NRC of Util Review & Approval of Cycle 8 Reload Under Provisions of 10CFR50.59 & Transmit COLR for Upcoming Cycle Consistent with GL 88-16.Reload Licensing Analyses Performed for Cycle 8 Utilize NRC-approved Methodologies ML20205J9451999-04-0505 April 1999 Submits Petition Per 10CFR2.206 Requesting That LaSalle County Nuclear Plant Be Immediately Shut Down & OL Suspended or Modified Until Such Time That Facility Design & Licensing Bases Are Properly Updated ML20205K5841999-03-31031 March 1999 Submits Rept on Status of Decommissioning Funding for Reactors Owned by Comm Ed.Attachment 1 Contains Amount of Decommissioning Funds Estimated to Be Required Pursuant to 10CFR50.75(b) & (C) ML20205B4241999-03-23023 March 1999 Provides Results of drive-in Drill Conducted on 990208,as Well as Augmentation Phone Drills Conducted Since 981015,as Committed to in Util ML20207J9841999-03-0505 March 1999 Informs That Effective 990212,KC Dorwick Has Resigned & No Longer Requires Use of NRC License for LaSalle County Station ML20207C7251999-03-0101 March 1999 Forwards Annual Rept for LaSalle County Station, for Period of 980101-981231.App E to Rept Provides Info on All Personnel Receiving Exposures of More than 0 Mrem/Yr Rather than 100 Mrem/Yr Requirement of TS 6.6.A.2 ML20207F9581999-03-0101 March 1999 Requests That Initial License Examination Currently Scheduled for Weeks of May 15 & 22,2000 Be Changed to Weeks of Nov 13 & 20,2000.Class Size Is Projected to Be Twelve RO & SRO Candidates ML20207D6831999-03-0101 March 1999 Forwards fitness-for-duty Program Performance Data for Each Comed Nuclear Power Station & Corporate Support Employees for Six Month Period Ending 981231,per 10CFR26.71(d) ML20207C8401999-02-25025 February 1999 Forwards Rev 60 of Comed LSCS Security Plan,Iaw 10CFR50.4(b) (4).Rev Eliminates Requirement for Annual change-out of Vital & PA Keys & Locks & re-configuration of PA Fence Around North Access Facility.Rev Withheld ML20207A9361999-02-24024 February 1999 Forwards Rev 4 to Restart Plan,To Reflect Review,Oversight & Approval Process Necessary to Restart Unit 2.Review & Affirmation Process Will Focus on Station Capability to Support Safe Dual Unit Operations 1999-09-30
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Osmmonwcatth Edison O)mpany
, l#ialle Generating, Station
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, Marseilles. IL 6134 l#757 TcI HI 43574,76i November 27,1996 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Response to Systematic Assessment of Licensee Performance (SALP) 13 Report LaSalle County Nuclear Generating Station Units 1 and 2 NRC Docket Numbers 50-373/50-374 I
Reference:
A. B. Beach letter to W. T. Subalusky dated October 17,1996, transmitting the NRC SALP 13 Report for LaSalle County l Station !
Commonwealth Edison Company (Comed) appreciates the NRC staff ,
meeting with us and presenting the SALP 13 report on October 29,1996, as l well as affording us the opportunity to provide our views on the SALP results.
We agree with your assessment of overall Station performance and we are disappointed in the decline in those areas you have indicated. The reference letter requested that we respond to the SALP Report addressing our actions for performance improvements in the areas of plant operations, maintenance, and engineering. This letter provides LaSalle's comments to the SALP 13 Report.
Our method for improvement at LaSalle consists of a basic three step approach. The first step is to establish the basic fundamentals of effective management, such as follow up, accountability, high standards, and critical self-assessment to effect near term improvement in human performance.
The next step is to implement effective improvement planning by starting with short-term results oriented plans, and using the fundamentals referred
! to above, progressing to long-term plans. The third step is to put in place
! the processes and actions needed to maintain improvements achieved.
These include on-going self-assessments, worker involvement, and Significantly improved training.
D f 9612030200 961127 PDR ADOCK 05000373 1'b L\D PDR
- .G. v 9 A l'ntcom Con) pan)
. .' 4 I j . !
Based on a number of human performance errors, a work standdown was initiated on October 12,1996. During this time, I met with all site departments to discuss LaSalle's performance and to communicate my expectations for both supervisors and workers. Special emphasis was '
placed on the first line supervisor in implementing their oversight of ongoing
! work and the need to coach and correct worker performance. Four key s l points were emphasized: (1) self-checking is expected, (2) follow procedures or stop work and correct the deficient procedure, (3) report low level J problems via Problem Identification Forms (PlFs), and (4) apply peer 1 l checking and peer pressure to improve LaSalle's human performance. The !
subsequent slowdown of work as our staff paid greater attention to following procedures and the increase in procedure changes and self-identified 3 procedure related problems indicate some degree of success. However, use i of and adherence to procedures is still at an unacceptable level, our human J performance error rate remains unacceptably high, and additional effort is ;
required.-
l
, One important result of this standdown was the establishment of weekly l
departmental human performance meetings. A group of station personnel meet to determine the human performance topics to be discussed at these meetings based on the previous week's performance.
L Managers have been directed to observe activities in the field, take ;
appropriate corrective action, and provide written reports of these 1 j observations to the Station Manager and Site Vice President. The quality of )
l these reports varies widely but is generally unacceptable and indicates our managers have a considerable amount to learn in conducting observations.
! Further direction and guidance is being provided.
l-The second step is our short-term focused planning effort intended to l achieve measurable improvement in station performance, while at the same time, training our management team on how to implement improvement planning that uses accountability and focuses on results rather than actions.
This effort initially involved the review of existing action plans for LaSalle and selecting those items that are essential to long-term success, yet achievable l in the short-term. The results of this effort are reflected in our Upgraded 1996 Operational Plan.
1 i The difference between this and past plans is that this plan does not try to !
i be all encompassing. We have specifically limited plan activities to a set that are important and can be accomplished to show results by the end of December 1996. Our Upgraded 1996 Operational Plan, which has been i discussed with the N9C Resident inspectors, includes the following I j elements:
L i
i 2
l
l 9
?
Safe Plant Operation - Key elements of the plans in this area are directed at achieving measurable improvement in safe plant operation and include:
. reduce operator challenges (work-arounds, temporary j
, alterations, main control room distractions) l
. improve operator performance through increased observation j and coaching
. correct processes that challenge safe operation (out-of-service -
activities and plant labeling)
Effective Work Manacement - Key elements of the plans in this area focus I on improving maintenance and work control including.
l . reduce maintenance rework
. improve work execution
. Improve work package and procedure quality Effective Plant Support - The plans in this area differ from those in the ;
above areas because of the need to establish fundamental management ;
activities in the engineering area. These plans, therefore, have fewer '
measurable results, but focus on achieving short term improvements in l technical support of the plant and the operating organization. The plans include: ,
i e improve root cause determination and identification of
- necessary immediate and long term corrective actions L . take short term actions to assess and improve conformance to the design basis '
. improve Engineering communication and interfaces with l Operations, Maintenance and Work Control e implement fundamental Engineering management tools l . implement short term actions of System Engineering improvement plan
. improve the quality of safety and operability evaluations -
A weekly accountability meeting is being held where Action Plan Sponsors and Action Plan Team Leaders discuss assigned actions and progress i towards achieving plan results. Support of other groups is requested at this
, meeting to ensure that any barriers to success are removed. Managers are l accountable to ensure success of these near term plans. We are focused on achieving results, not just on performing activities. All members of the .
LaSalle staff are encouraged to understand the focus areas and objectives !
and be knowledgeable of the progress and results achieved.
3
. .. _ . _ . - _ . - .__u .m .. . .-__ _ m _
l 1 .
l Following is a discussion of improvement efforts in operations, maintenance, and engineering, including some examples from the Upgraded 1996 Operational Plan.
ODerationS i We have placed special emphasis on the fact that " Operations is in charge." ;
I met with each shift manager to reinforce this expectation and solicited input :
as to what we could do to accelerate that change. Shift managers "in !
charge" has been communicated to all site personnel. The shift manager is now part of the LaSalle Management Team. This Team has a daily meeting i in the shift manager's office to discuss plant issues and allow the shift ;
manager to solicit any help needed to ensuru safe plant operation. We understand the need for an immediate safety focus culture change. The LaSalle Management Team is working with all site personnel to support l operations and to understand and remove barriers in this regard. l l
Operations management continues to stress key human performance attributes for safe, effective work including the need for a questioning i' attitude, self-check, peer-check, and procedural adherence. These are reinforced by management observations, weekly simulator evaluations, and debriefs of crew performance. This supervisory observation effort is focused on the most important areas and the results are used in regular discussions between Operations Supervisors and Operators.
Examples of operations involvement in the LaSalle Upgraded 1996 Operational Plan include the following elements directed at short-term operationalimprovements:
Reduce Operator Challences: Several actions are underway to improve !
plant material condition. One is by reducing operator work-arounds. I Seventy-six work-arounds currently exist. Operations, Maintenance, and l Engineering have worked together and identified nineteen work arounds to 1 be eliminated by the end of the year. The remaining fifty-seven will each have an individual action plan and schedule for resolution developed by December 31,1996. Beginning in 1997, as workarounds are identified, they will be prioritized and a resolution plan developed per the priority (i.e.,
Priority A is 30 days and Priority B 60 days).
With both units shutdown, management with operations input has identified a number a material condition items which will be corrected prior to start-up.
This, along with the extensive work being completed during Unit 1 and Unit 2 outages, and the change of standards will result in improvement in plant material condition.
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l Correct Processes That Challence Safe Plant Operation: To minimize '
l human performance errors, plant labeling is being upgraded to support !
( operators and other station personnelin the safe completion of operations ,
l and maintenance activities. At a recent action plan progress meeting, the L labeling plan Team Leader indicated that three milestone dates had not ;
l been met.- This was in part due to a failure to schedule and obtain suppod from other departments and is indicative of the need for continued emphasis .
on enforcing management expectations. Senior management is taking '
these opportunities to reinforce accountability and to modify individual l- behaviors to ensure expectations are being met. In this case, Maintenance -
- and Stores committed the needed resources to assist in bringing the labeling .
l plan back on schedule. !
Maintenance L Several initiatives are ongoing in the maintenance area to address worker ,
l- performance. Using specific criteria, weekly field observations of workers l
- l. are being performed by First Line Supervisors to ensure expectations are known and accountability is pushed down tc the worker level. Pre-job ,
briefings and job turnovers have been standardized to reduce the risk of r human performance errors in these processes. A review of the maintenance training programs is in progress to address current skill and knowledge-based deficiencies in the maintenance arms.
l Examples of maintenance involvement in the LaSalle Upgraded 1906 Operational Plan include the following elements directed at short-term l improvements.
Reduce Maintenance Rework: Reducing maintenance rework will help i LaSalle Station achieve more effective work management. We have reviewed data bases for rework, identified the major contributors and i analyzed those to reveal the underlying causes of rework at LaSalle. The ;
c analysis showed both skill-based errors (e.g. ineffective implementation of i self-check and procedure adherence) and knowledge-based errors (e.g., }
i knowledge weaknesses in pumps for mechanics, motors for electricians, and l l
the EHC system for instrument techs). Corrective actions have been l
determined to address these and include enhanced training and additional management monitoring of activities associated with pumps, motors and EHC during L2R07 and L1F35. Increased worker involvement through !
meetings and informal discussions is underway to improve identification of j maintenance issues, such as rework, through the PlF process. Maintenance l initiated PlFs have increased (43 in August,79 in September,354 in l October, and 118 through November 18). !
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Imorove Work Execution: The work priorities of the Fix-It-Now (FIN) Team have been realigned to focus on emergent equipment problems, such as
, Main Control Room distractions, which challenge the operators. Twenty-one l
ARs/WRs have been identified that are within FIN Team capability. Six have been resolved and the other fifteen are scheduled for completion by December 31,1996. We are also increasing FIN work that is classified l
emergent priority work. By this, we will gain quicker tum around on minor ,
maintenance and provide a level of protection for scheduled work. We are on schedule to achieve a goal of having the percentage of FIN Team work that is higher priority increased from 20% to 40%
Enaineerina As discussed during our SALP meeting, the new engineering management team has observed deficiencies in engineering consistent with those cited in the SALP 13 report. We have put in place several stop gap measures to immediately improve the technical quality and content of selected Engineering products. :
For example, we have implemented formal Department Head review and approval of engineering work products including Problem Identification Form issues, significant safety evaluations and operability evaluations, technical specification clarifications, significant root cause determinations and formal regulatory responses. This action willimprove work product quality.
An Independent Review Group for Safety Evaluations and Operability Evaluations was established. This function will transition to be part of an ;
Engineering Assurance Group which has a broader in-line and overview function. The Engineering Assurance Group is led by an industry leader in engineering assurance and will include personnel with long term, broad experience in engineering and engineering processes.
Examples of engineering involvement in the LaSalle Upgraded 1996 Operational Plan includes the following elements directed at short-term improvements in the area of Effective Plant Support:
Imorove Root Cause Identification and Corrective Action Determination:
A Corrective Action Review Board (CARB) has been implemented to review root cause reports for adequacy and appropriatenus of corrective actions.
CARB has raised the standards for rigorous root cause analyses as indicated by numerous requests for supplemental information and/or
- analysis prior to acceptance. Actions are also in place to push the accountability for root cause analysis quality down from the CARB to the r responsible line manager. These actions are expected to increase l management involvement and thus improve the capability of the staff to conduct root cause analyses and will reduce the frequency of repeat events.
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4 l Implement Short-Term Actions to Assess and improve Conformance to the
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! Desian Basis: These activities include performing System Functional !
. Performance Reviews for selected systems, as part of longer term reviews l for all systems important to safe and reliable operation. ' This will better !
establish the detailed functional requirements, prioritize known and latent l
system problems, and confirm the adequacy of periodic testing for '
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l monitoring functional performance. Five systems have been selected for L
completing these reviews prior to statup of LaSalle Units 1 and 2 (Main J Control Room Ventilation / Auxiliary Electric Equipment Room Ventilation; l
Core Standby Cooling (essential service water); 125 VDC (Div i and 11); i Reactor Core isolation Cooling; Electrohydraulic Control). Additionally, detailed design reviews are being conducted for the first three'of these systems, which will confirm the design adequacy compared to the design basis requirements via detailed review of design and analytical information. I Industry personnel with extensive experience in nuclear facilities are leading the reviews and are coaching and tutoring LaSalle engineers in these l processes. ;
As I mentioned earlier, the third step in our approach to improvement is to put in place the processes to maintain improvements achieved. Extensive j l effort has been exerted to upgrade LaSalle Station's ability to identify its own i
problems. Each Department Head is required to conduct a self-assessment )
of their area and meet with the Station Manager and Site Vice President to i
- discuss problems and corrective actions being taken. Specific areas .
required to be discussed include personnel performance and training.
Follow up in subsequent sessions is being used to hold Department Heads accountable for making improvements. Also, the Management Review l Board is being reconstituted and refocused to provide move effective assessment. Groups outside of LaSalle Station are also being used more i frequently to provide objective assessments of site activities. Assessments of this nature include one on inservice testing activities and two related to
. SQV activities.
1 L Finally, we appreciate your acknowledgment of improvement in Radiation Protection; however, we are not satisfied with our performance in this area.
Management field observations have been increased as part of the effort to
! improve this area. We are also working to effect improvements in Security, L which declined, and Fire Protection where performance continued at only an acceptable level. ;
Although I believe we know the full range of performance issues that face LaSalle, an Independent Self Assessment (ISA) has been initiated for
- LaSalle Station. The purpose of the ISA is to revalidate known performance l weaknesses at LaSalle, identify new issues and identify why past efforts to I
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INPO assessors has been assembled to perform the assessment and will be on-site at LaSalle from December 3 to December 13. I will share the results t of this Independent Self Assessment with you.
We will update our Operational Plan for the first part of 1997. As we complete this effort, we will continue to share this plan with the NRC Resident inspectors. I hope to meet with you early in 1997 to discuss LaSalle's performance and will contact your office to set up a meeting. :
1 It is critical through our efforts that we achieve improved human performance ,
and plant material condition. As indicated above, our focus is on results ;
l rather than activities. In closing, we believe that we understand our performance issues and have the determination to improve through the (
efforts described above. if you have questions regarding the infomiation provided, please contact me at 815-357-6761 Ext. 3600.
1 Respectfully, )
l W. T. Subalusky Site Vice President LaSalle County Station i cc: A. B. Beach, NRC Region ill Administrator M. P. Huber, NRC Senior Resident inspector - LaSrile l D. M. Skay, Project Manager - NRR - LaSalle F. Niziolek, Office of Nuclear Facility Safety - IDNS l DCD - Licensing (Hardcopy: Electronic: ) l Central File l l
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