ML20140B663
| ML20140B663 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/20/1997 |
| From: | Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Subalusky W COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20140B670 | List: |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-1.033 50-373-97-03, 50-373-97-3, 50-374-97-03, 50-374-97-3, EA-97-214, NUDOCS 9706060287 | |
| Download: ML20140B663 (4) | |
See also: IR 05000373/1997003
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May 20, 1997
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EA 97-214
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Mr. W. T. Subalusky, Jr.
Site Vice President
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LaSalle County Station
Commonwealth Edison Company
2601 North 21st Road
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Marseilles, IL 61341
SUBJECT:
NRC INSPECTION REPORT NOS. 50-373/97-03 & 50-374/97-03,
NOTICE OF VIOLATION, AND EXERCISE OF DISCRETION
Dear Mr. Subalusky:
On March 21,1997, the NRC completed an inspection at your LaSalle facility. The
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enclosed report presents the results of that inspection.
During this six-week inspection period, your staff's continuing performance was
characterized by instances of procedural and Technical Specification non-compliance, the
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use of inadequate procedures, and continuing problems with the work control process.
Your staff also identified examples of inadequate implementation of the design control
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process. These performance deficiencies indicate that corrective actions have not been
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effective to date.
During this inspection period, seven violations and two apparent violations of NRC
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requirements were identified. The first violation involves the failure to notify the NRC that
the license for a senior reactor operator was no longer required. This violation was the
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result of weaknesses in the administrative controls for licensed operator staffing which
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could have resulted in non-licensed personnel working in a licensed position. Because this
violation was based upon activities of the licenr.ee prior to the events leading to the
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extended plant shutdown and satisfies the other criteria in Section Vll.B.2, " Violations
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identified During Extended Shutdowns or Work Stoppages," of the " General Statement of
Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600,
a Notice of Violation (NOV) is not being issued.
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The second violation involves two NRC-identified examples of the failure to follow
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procedures during diesel generator testing. These particular violations stem from
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continuing human performance weaknesses. The inspectors also identified a third example
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of failing to follow procedures involving administrative procedures. However, an NOV is
not being issued for this third example since it is considered another example of the
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violation cited in NRC Inspection Report 50-373/96018; 50-374/96018 for the failure to
follow administrative procedures. The vio!ation indicates that additional management
attention is warranted in the area of procedure use.
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W. T. Subalusky, Jr.
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The third violation relates to three examples of inadequate procedures identified by the
inspectors. The first r,xample involves a procedure used by operators to record cooling
lake level. This procedure prescribed an upper limit on lake level that was greater than the
level specified in the Updated Final Safety Analysis Report for preventing adverse
consequences from internal flooding. This procedural inadequacy contributed to the high
level condition of the cooling lake which resulted in the declaration of an Unusual Event.
The second example involves work instructions for inspecting the steam tunnel check
dampers that did not contain appropriate qualitative or quantitative acceptance criteria.
This example is not included in the NOV for inadequate procedures because it satisfies the
criteria in Section Vll.B.2 of NUREG-1600 (Enforcement Policy). The third example
pertains to performing calibrations of the cooling lake blowdown flow instrumentation
without using instructions or procedures appropriate for the activity. These last two
violation examples stem from problems with the work control process.
Three violations were identified regarding the failure to complete Technical Specification
surveillances within the required frequency. However, an NOV is not being issued for the
violation involving a missed surveillance test for the residual heat removal system
containment spray isolation valves because it satisfies the criteria in Section Vll.B.2 of
A seventh violation was identified pertaining to the inappropriate use of a maintenance
repair activity to implement a design change. This issue is similar to previously
identified design control problems described in NRC Inspection Report 50-373/96011:
50-374/96011. An NOV is not being issued for this violation because it satisfies the
criteria in Section Vll.B.2 of NUREG 1600.
The apparent violations pertain to an inadequate modification that resulted in the potential
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for a single failure of the control room ventilation intake radiation monitoring system. The
single failure could result in the control room and auxiliary electric equipment room
ventilation systems being unable to automatically perform their design function during
accident conditions. The modification also introduced an unreviewed safety question.
These apparent violations are being considered for escalated enforcement action in
accordance with NUREG-1600. Therefore, NOVs are presently not being issued for the
apparent violations. A pre-decisional enforcement conference is not necessary to enable
the NRC to make an enforcement decision regarding these apparent violations and the
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other apparent violations identified in NRC Inspection Report Nos. 50-373/96011:
50-374/96011,50-373/96013: 50-374/96013, and 50-373/96018: 50-373/96018. In a
discussion between Mr. M. N. Leach, Chief, Operator Licensing Branch, and
Mr. W. T. Subalusky, Jr., LaSalle County Station Site Vice-President, on May 7,1997, the
licensee declined the opportunity for a pre-decisional enforcement conference. Please
contact Mr. Leach at 630-829-9705 within 7 days of the date of this letter if you wish to
request a pre-decisional enforcement conference for any of these apparent violations. You
also have the option to correct or enhance the information previously docketed for the
apparent violations within 30 days of the date of this letter. If a request for a
pre-decisional enforcement conference is not made or additional information is not
provided within the time specified or an extension of time has not been granted by the
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W. T. Subalusky, Jr.
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NRC, the NRC will proceed with its enforcement decision. The characterization of the
apparent violations described in the enclosed inspection report may change as a result of
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further NRC review. You will be advised by separate correspondence of the results of our
deliberations on this matter.
The violations cited in the enclosed Notice of Violation (Notice) and the circumstances
surrounding the violations are described in detailin the enclosed inspection report. You
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are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. In your response, you should document
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the specific actions taken and any additional actions you plan to prevent recurrence. Your
response may reference or include previous docketed correspondence, if the
correspondence adequately addresses the required response. After reviewing your
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response to this Notice, including your proposed corrective actions and the results of
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future inspections, the NRC will determine whether further NRC enforcement action is
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necessary to ensure compliance with NRC regulatory requirements.
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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practices," a copy of this letter,
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its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
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Sincerely,
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/s/ G. E. Grant
Geoffrey E. Grant, Director
Division of Reactor Projects
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Docket Nos:
50-373; 50-374
License Nos:
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Enclosures:
2. Inspection Report 50-373/97-03; 50-374/97-03
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DOCUhENT hA&E: R:\\lNSPRPTS\\ POWERS)LASA\\LAS97003.DRP
To recevo e copy of this document, endicate in the box *C" = Copy without attachlenct "E" = Copy wrth attach /enci "N" = No copy
OFFICE
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DAPAS N D $ ' N
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NAME
CLAYTON
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DATE
5/ li197
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OFFIC4AL RECORD LOPY
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W. T. Subalusky, Jr.
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cc w/ encl:
T. J. Maiman, Senior Vice President
Nuclear Operations Division
D. A. Sager, Vice President,
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Generation Support
H. W. Keiser, Chief Nuclear
Operating Officer
F. Dacimo, Plant General Manager
P. Barnes, Regulatory Assurance
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Supervisor
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1. Johnson, Acting Nuclear
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Regulatory Services Manager
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Richard Hubbard
Nathan Schloss, Economist
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Office of the Attorney General
State Liaison Officer
Chairman, Illinois Commerce
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Commission
Document Control Desk Licensing
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Distribution:
Docket File w/ encl
DRP w/enci
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PUBLIC IE-01 w/ encl
Rlli PRR w/enci
OC!LFDCB w/enci
SRI LaSalle, Dresden,
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CAA1 w/ encl (E-mail)
Quad Cities w/enci
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Project Manager, NRR w/ encl
A. B. Beach, w/enci
RAC1 (E-Mail)
Deputy RA, w/enci
Rlll Enf. Coordinator, w/enci
DRS (2) w/enci
TSS w/enci
J. Lieberman, OE w/enci
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J. Goldberg, OGC w/enct
R. Zimmerman, NRR w/enci
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