ML20140B663

Forwards Insp Repts 50-373/97-03 & 50-374/97-03 on 970207-0321 & NOV

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: ML20140B663 ML20140B673 ML20140B685
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 i

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EA 97-214

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Mr. W. T. Subalusky, Jr.

Site Vice President  !

LaSalle County Station

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Commonwealth Edison Company

2601 North 21st Road ,

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:

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On March 21,1997, the NRC completed an inspection at your LaSalle facility. The j

enclosed report presents the results of that inspection.

During this six-week inspection period, your staff's continuing performance was l

characterized by instances of procedural and Technical Specification non-compliance, the l

use of inadequate procedures, and continuing problems with the work control process.

Your staff also identified examples of inadequate implementation of the design control i

process. These performance deficiencies indicate that corrective actions have not been l

effective to date.

During this inspection period, seven violations and two apparent violations of NRC

requirements were identified. The first violation involves the failure to notify the NRC that

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the license for a senior reactor operator was no longer required. This violation was the ,/

result of weaknesses in the administrative controls for licensed operator staffing which

i. 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 j

extended plant shutdown and satisfies the other criteria in Section Vll.B.2, " Violations '

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. l

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l The second violation involves two NRC-identified examples of the failure to follow

! procedures during diesel generator testing. These particular violations stem from i

l continuing human performance weaknesses. The inspectors also identified a third example l

l 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

violation cited in NRC Inspection Report 50-373/96018; 50-374/96018 for the failure to

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follow administrative procedures. The vio!ation indicates that additional management

attention is warranted in the area of procedure use.

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9706060?87 970520

PDR ADOCK 05000373

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. W. T. Subalusky, Jr. 2-

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

NUREG-1600.

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

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the NRC to make an enforcement decision regarding these apparent violations and the

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. -3-

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NRC, the NRC will proceed with its enforcement decision. The characterization of the I

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apparent violations described in the enclosed inspection report may change as a result of ,

further NRC review. You will be advised by separate correspondence of the results of our I

deliberations on this matter.

The violations cited in the enclosed Notice of Violation (Notice) and the circumstances

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surrounding the violations are described in detailin the enclosed inspection report. You

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

i 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 I

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response to this Notice, including your proposed corrective actions and the results of

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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j Sincerely,

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/s/ G. E. Grant

Geoffrey E. Grant, Director

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Division of Reactor Projects

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Docket Nos: 50-373; 50-374

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License Nos: NPF-11; NPF-18

Enclosures: 1. Notice of Violation

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 Rill M HH1 fH

NAME DAPAS N D $ ' N CLAYTON GRANT I

DATE 5/ li197 5// / 19 7 5f 7

OFFIC4AL RECORD LOPY

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- W. T. Subalusky, Jr. -4-

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cc w/ encl: T. J. Maiman, Senior Vice President

Nuclear Operations Division

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D. A. Sager, Vice President,

Generation Support

H. W. Keiser, Chief Nuclear

Operating Officer

F. Dacimo, Plant General Manager

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P. Barnes, Regulatory Assurance

Supervisor . .

1. Johnson, Acting Nuclear

Regulatory Services Manager

i Richard Hubbard

Nathan Schloss, Economist i

Office of the Attorney General

State Liaison Officer

Chairman, Illinois Commerce

l Commission

Document Control Desk Licensing

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Distribution:

Docket File w/ encl DRP w/enci

j PUBLIC IE-01 w/ encl Rlli PRR w/enci  ;

. OC!LFDCB w/enci SRI LaSalle, Dresden, l

CAA1 w/ encl (E-mail) Quad Cities w/enci

l 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 '

J. Goldberg, OGC w/enct R. Zimmerman, NRR w/enci

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