ML20135D775

Suppls Response to Violations Noted in Insp Repts 50-373/96-11 & 50-374/96-11.Corrective Actions:On 970104, NEP-12-03LA,Rev 2,LaSalle Nuclear Design Info Transmittal (Ndit) Site,App Voided

ML20135D775
Person / Time
Site:	LaSalle
Issue date:	02/24/1997
From:	Subalusky W COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9703050494
Download: ML20135D775 (3)

Text

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Commonu calth FAhson Company l#alle Generating Station 1/dll North 214 Riud Marseilles! 11.61.441 9757 j Tel 814357C61 I

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February 24,1997

United States Nuclear Regulatory Commission Attention

Document Control Desk i j Washington, D.C. 20555 I

Subject:

NRC INSPECTION REPORT NO. 50-373/96011; 2

50-374/96011 (DRS) AND NOTICE OF VIOLATION

References:

1. G. E. Grant Letter to W. T. Subalusky, dated

November 15,1996, Transmitting NRC Inspection Report 373/374-96011

2. W. T. Subalusky Letter to U.S. NRC, dated December 20,1996, Transmitting Response to '

, NRC Inspection Report 373/374-96011 and

, Notice of Violation Reference 1 transmitted US NRC Inspection Report 373/374-96011 and ,

j reference 2 transmitted LaSalle County Station's response. The enclosed '

] attachment supplements LaSalle County Station's response to the Notice of Violation item 1. If there are any questions or comments concerning this letter,

, please refer them to me at (815) 337-6761, extension 3600.

J Respectfully, W. T. Subalusky Site Vice President LaSalle County Station .

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9703050494 970224 Enclosure PDR ADOCK 05000373 G PDR , , ,

cc: A. B. Beach, NRC Region 111 Administrator

/f~Ol M. P. Huber, NRC Senior Resident inspector - LaSalle y  :

D. M. Skay, Project Manager - NRR - LaSalle F. Niziolek, Office of Nuclear Facility Safety - IDNS DCD - Licensing (Hardcopy: Electronic: ).

Central File

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4 ATTACHMENT 1 i LASALLE COUNTY GENERATING STATION SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION IN INSPECTION REPORT NO. 50-373/96011 (DRS); 50-374/96011 (DRS) I Violation A (96011-01 & 96011-17):

i Subsequent to the exit for NRC Inspection Report 96019 on January  !

3,1997, at LaSalle County Station, Comed helc' discussions with the NRC l regarding additional corrective actions being taken in response to the subject  !

Notice of Violation in Inspection Report 96011. The following corrective l actions regarding the Nuclear Design Information Transmittal (NDIT) process i have been or will be taken.

The corrective steps that have been taken and the results achieved

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1. On January 4,1997, NEP-12-03LA, Revision 2, LaSalle Nuclear Design Information Transmittal (NDIT) Site Appendix, was voided.

This revision was voided because the procedure contained instructions which were misinterpreted as allowing minor modifications to be authorized by the NDIT procedure.  ;

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2. All NDITs issued under NEP-12-03LA, Revision 2 have been reviewed to determine if other NDITs had been inappropriate!y used )

to make design changes. Three occurrences of inappropriate use of {

the NDIT procedure were identified. The first provided generic approval to modify valve packing. This NDlT was voided. A design drawing was issued to control the use of valve packing. The second involved a material substitution for an unavailable original material for non-safety related damaged soil drain piping. A safety evaluation screening has been performed and the material specification for the piping has been updated. The third NDIT, involving a material type change in valve guides, was supplemented with a parts evaluation, a safety evaluation and update of the valve drawings in accordance with applicable station procedures.

3. On January 3,1997, the Site Engineering Manager required that all NDITs be approved by an Engineering Department Head prior to issue. On February 6,1997, for other reasons, a stop work order was issued by Site Quality Verification on use of NEPs subject to completion of independent technical reviews, Onsite Review and Station Manager approval in accordance with the station Technical Specifications. NEP-12-03 and a new revision to NEP 12-03LA, which resolves tha deficiencies with Revision 2, are currently scheduled for this review process. Use of NDITs is suspended until the full review and approval process is completed for these two procedures.

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w The corrective steps that will be taken to avoid further violations:

1. Revision 3 of NEP-12-03LA was written to (1) clarify the scope of use of this procedure, (2) specifically prohibit the use of an NDIT for transmittal of a design change, (3) specifically prohibit the use of an NDIT to circumvent the temporary alteration procedure and (4) require a 10CFR50.59 screening for repairs or upgrades of an NDIT dealing with the same repair. As noted above, an independent technical review and Onsite Review will be performed for this revision of the site appendix along with NEP-12-03, prior to their implementation. This process will be complete before March 14,1997. Training on these procedures will be conducted by March 28,1997,

2. All NDITs issued by Engineering to all revisions of NEP-12-03LA will be reviewed to determine if additional NDITs had been inappropriately used to make design changes. If an inappropriate use of an NDIT is identified, immediate corrective action will be taken. This effort will be complete by Apri! 4,1997.

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