ML20211H057

Discusses Insp Repts 50-373/96-11,50-374/96-11,50-373/96-13, 50-374/96-13,50-373/96-18,50-374/96-18,50-373/97-03 & 50-374/97-03 from September 1996 - March 1997.Violations Noted.Licensee Required to Submit Written Statement

ML20211H057
Person / Time
Site:	LaSalle
Issue date:	09/29/1997
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Subalusky W COMMONWEALTH EDISON CO.
References
50-373-96-11, 50-373-96-13, 50-373-96-18, 50-373-97-03, 50-373-97-3, 50-374-96-11, 50-374-96-13, 50-374-96-18, 50-374-97-03, 50-374-97-3, EA-96-392, EA-97-021, EA-97-21, NUDOCS 9710060180
Download: ML20211H057 (6)

See also: IR 05000373/1996011

Text

___ -

.

- -

- _ - - -

_

,

.*

9

. p # "*%

UNITED STATES

.p

g

NUCLEAR RE2ULATORY COMMISSION

g

o

REGloN lli

E

' "~

801 WARRENVILLE RoAo

USLE, ILUNolS 60532-4351

September 29, 1997

EA 96 392, and 97-021

Mr. W. T. Subalusky, Jr.

Site Vice President

LaSalle County Station

Commonwealth Edison Company

2601 North 21st Road

Marseilles, Illinois 61341

SUBJECT:

EXERCISE OF ENFORCEMENT DISCRETION

(NRC Inspection Reports: 50-373/374/96011, 50-373/374/96013,

50-373/374/96018, and 50 373/374/97003)

Dear Mr. Subalusky:

This refers to four inspections conducted from September 1996 to March 1997 at the LaSalle

facility. The inspectione ',ncluded a review of the repair activities associated with the

replacement of the Unit 2 "A" residual heat removal service water (RHRSW) pump impeller,

review of several problems that indicate weaknesses in your corrective action system, and

control room habitability problems. We discussed the significance of the issues and the need

for lasting and effective corrective action with members of your staff at the inspection exit

meetings conducted on September 24,1996, December 13,1996, February 13,1997, and

March 21,1997. Since you were still developing and implementing corrective actions for a prior

enforcement action (EA 96-325)' that encompassed the apparent violations, our inspection

reports dated November 15,1996, January 29,1997, February 13,1997, and May 20,1997,

offered you the option to request a predecisional enforcement conference or respond to the

apparent violations. You elected to respond to the apparent violations and did not request a

predecisional enforcement conference,

,

Based on the information identified during the inspections and the information provided in your

responses, the NRC has concluded that violations of NRC requirements did occur. The

violations have been grouped into three areas. The first grouping pertained to repair activities

associated with replacement of the Unit 2 "A" RHRSW pump impeller. The second grouping

n

pertained to inadequate corrective actions to resolve precursors that led to a rupture disk failure

y@

. for the reactor core isolation cooling system, suppression pool foreign material problems,

/

ggS

breaker alignment problems, and control switches that prematurely degraded. The third

g

oo,

grouping pertained to control room and auxiliary electric equipment room habitability problems.

o.o

The grouping of issues was based on the information developed during the inspections and

gg

' your January 10,1997, and March 14,1997, responses to the apparent violations discussed in

- 5.,8

the inspection reports; the information that you provided during the exit meetings; and your

i

.

Se

8

T.b

1

EA 96-325 issued a $650,000 civil penalty on January 24.1997. for issues identified during inspections conducted frorn July

0'40

through August 1996: The issues were failure to understand the design functions and performance characteristics of safety-related

structures, inadequate planning and control over safety-related maintenance, non-conservative operability evaluations, and the

failure to identify and correct significant conditions adverse to quality.

• "

48/8/818#R5#

Ni!C BLE CEMER C8PY

- . , - - - - . - . - - - . _ . - . . - . _ - - - . - - . - - . _ -

_

.,

} -y

i>

'

l Commonwealth Edison Company

-2-

h

h

Licensee Event Reports 374/97009,373/96012,373/96012-01,373/96014,373/96017,

'

[

373/96017-01, 373/96021,373/96021 01.

- The first grouping of violations pertained to the failure to control and manage the Unit 2 "A"

i

RHRSW pump impeller replacement. The inadequate control of this safety-related

i-

maintenance activity resulted in the installation of a different size impeller because maintenance

- ;:arsonnel failed to machine the impellers to the size specified on the work request plan. This

.}

resulted in altering the hydraulic characteristics of the system and constituted an unauthorized

4

- system modificatione in addition, post maintenance testing failed to determine if the altered

i

system hydraulic characteristics affected system design performance. A properly implemented.

i.

.and evaluated post maintenance test would have identified the installation error. Lastly, there

!=

was a lack of engineering rigor and questioning attitude when your staff failed to question,

,

j

- evaluate, and resolve system performance problems that were the direct result of the increased

system flow because of the new impeller. The problems included the failure of a discharge

I

isolation valve and the off scale reading (pegged high) of a flow meter installed in the pump's

discharge flow path,

'

i

-

.

The second grouping of violations pertained to the inability of the licensee's corrective action ~

program to implement timely and effective corrective actions to prevent several 1996 events

.

. that were either known industry problems or had previously occurred at the plant. The

>

!

ineffective corrective actions resulted in the following deficiencies: (1) failure of a rupture disk

i

for the reactor core isolation cooling system, (2) misaligned 480-volt breakers that could have

-

caused the loss of the normal and emergency power supply for the control room and

emergency diesel generator room ventilation systems during a seismic even, (3) suppression

_

_ ool foreign material control problems that could have resulted in inadequate net positive

=

p

' suction head to the emergency core cooling system pumps, and (4) control switch degradation

.[

problems due to exposure to hydrocarbons during the manufacturing process and/or the use of

i-

cleaning agents containing hydrocarbons.

L

?The third grouping of violations pertained to your staff's identification that the surveillance

[

testing program and design change program were inadequate to demonstrate and maintain

- post accident operability of the control room (CR) and auxiliary electric equipment room (AEER)

.

t-

. ventilation systems. . The AEER and CR ventilation systems had not been verified orarable

.

_

since initial plant operation in that your program failed to verify routinely that the miems h6d

L

the capability to maintain a positive pressure of 1/8 inch water column and sim tarly,

~

preoperational and post modikation testing failed io verify this design parameter. Positive

7"

pressure ensures that dose rates ao operators are within the federal limits during a design basis

.

accident. In addition, an inadequa'e safety evaluation for a 1993 modification, which changed

the initiation logic for the CR and AEER radiation monitoring system, introduced a single failure

vulnerability and resulted in an unroviewed safety question.

I

xThe corrective actions for the violations mainly stemmed from EA'96-325 and consisted of

-- establishing a new site management team, a special inspection team, an independent self

j-

assessment team, and a corrective action plan. The corrective action plan was divided into four

p

--phases. These included definition of the physical plant work and other activities to be

,

]

l-

i

!

i

e

.

, ,. a

_.,.... .

_

. .

.

-. -

,

- _ . , . ,-

.-

m

,. ,

-

,.:c-

,

_ _. _

. _ _ _ - _ . ~ _ _ _ . _ _ _ _

_ _.

. _ _ _ . _ _ . . _ . _ _ _

n

-

j.

1

^

. ..

.

Commonwealth Edison Company

-3-

E

,

.

.

-

completed before unit restart, work completion, restart and readiness evaluations, and unit

restart and power ascension. The corrective action strategy focused on safe plant operation,

j

improved plant material condition, effective outage management, effective work control,

p

improved human performance, effective engineering support, and improved corrective action

programs.

individually, these groups of violations would be designated as Severity Level lit problems in

j

accordance with the NRC's NUREG 1600, " General statement of Policy and Procedures for

_ NRC Enforcement Actions,"(Enforcement Policy). These problems are of significant regulatory

n

!

concem because they demonstrated that Commonwealth Edison Company did not manage the

!

modification or corrective maintenance processes; that post maintenance testing did not always

[

confirm component operability; that inservice tests did not always verify continued operability of

F

tested equipment; and that the management control systems, barriers, and processes in place

at the time of the inspection were not always effective in ensuring the early detection and timely

resolution of conditions adverse to safe plant operation. Normally, such problems would be

j.

subject to civil penalties.

8

However, I have been authorized after consultation with the Director, Office of Enforcement to

4

F

exercise enforcement discretion in accordance with Section Vll.B 6, " Violations involving

i

Special Circumstances," of the Enforcement Policy and not issue Notices of Violation or

[

propose civil penalties in this case. The decision to apply enforcement discretion was based on

[

consideration of the following: (1) significant NRC enforcement action (EA 96-325) was

!

imposed against the LaSalle County Station for a service water sealant intrusion event for

[

which the licensee's corrective actions encompass the root causes for these apparent

j.

= violations, (2) the licensee voluntarily shut down both units to address wide ranging

L

performance problems that encompass the causes for the apparent violations, (3) the apparent

,

p

violations were not willful,- (4) the apparent violations were related to activities before the

shutdown, (5) the apparent violations would not be classified at a severity level higher than

. Severity Level ll, (6) actions specified in Confirmatory Action Letter (CAL) Rlll-96-008B

>

. effectively prevent your staff from starting LaSalle County Station without NRC approval, and

t

i

(7) although the NRC identified a number of these issues because of its inspections, the NRC-

.has determined, based on continuing NRC inspection effort, that Commonwealth Edison

i

- Company has dedicated significant resources to address the performance issues and improve

,

'

LaSalle County Station conduct of operations. Nonetheless, the NRC must emphasize that

. failure to achieve effective performance improvement could lead to more significant regulatory

-i

,

i

sanctions.

LI

'As stated above, the NRC has concluded that information regarding the reasons for the

-1

}.

apparent violations, the corrective actions taken, the corrective actions planned to prevent

l

recurrence, and the date when full compliance will be achieved is already adequately

' -

addressed on the docket. However, you are required to submit a written statement or

' -

explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your

corrective actions or your position. In that case, or if you choose to respond, clearly mark your

,

j

response as a " Reply to Exercise of Enforcement Discretion; NRC Inspection Reports -

l

50-373/374/96011; 50-373/374/96013; 50-373/374/96018; and 50-373/374/97003" and send it

i

i

!

i

i

l~

.

.

~.

_

_-

J

-

- - .

. - . - - - - -

. - -

-._ _

. - .

- ~.

- - - - -

..o

.

,

.

Commonwealth' Edison Company -

4-

-

.

to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk Washington, D.C.

V

20555, with a copy to the Regional Administrator, Region lil, and a copy to the NRC Resident

'

inspector, within 30 days of the date of the letter transmitting this Notice. Under the authority of

".

Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or

,

affirmation. : Because the response will be placed in the NRC Public Document Room (PDR), to -

.

l 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, if personal privacy or

'

proprietary information is necessarf 'n provide'an acceptable response, then please provide a

,

bracketed copy of your response that i Jentifies the information that should be protected and a

redacted copy of your response that de.stes such information. If you request withholding of

'

-

such material, you must specifically identify the portions of your response that you seek to have

.

withheld and provide in detail the bases for your claim of withholding (e.g., explain why the

,

,

disclosure of information would create an unwarranted invasion of personal privacy or provide .

[

- the information required by 10 CFR 2.790(b) to support a request for withholding confidential

i

commercial or financial information). If safeguard's information is necessary to provide an

acceptable respcnse, please provide the level of protection described in 10 CFR 73.21.

't

in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice, a copy of this letter will be

i

placed in the NRC Public Document Room (PDR).

i

Sincerely,

4

l

w

i

-

,

A.. Bill Beach --

Regional Administrator -

.

Docket Nos. . 50-373,50-374

[

License Nos. NPF-11, NPF-18

.

, . _ _ .

I

'

.

i-.

j .'-

i

4

[

.

$

.

J

w

---em-

,

.,

,

, , - - -

,-,,..a,

--

--.w<~

- + , - + - ~ - - ,

,. - ,

n-,

,

-

-

v.-

-

-

-- _

.

_

.

.

. . . . __.

. _ . . . . .

_

. _ . _ . _

.

-

. . .

. .

1

Commonwealth Edison Company

-5-

. cc:

R. J. Manning, Executive

Vice President, Generation

M. Wallace, Senior Vice

President, Corporate Services

E. Kraft, Vice President -

BWR Operations

Liaison Officer, NOC-BOD

,

D. A. Sager, Vice President.

Generation Support

D. Farrar, Nuclear Regulatory

_ Services Manager

-

1. Johnson, Licensing

Operations Manager

Document Control Desk-Licensing

F. Dacimo, Plant General Manager

P. Bames, Regulatory Assurance

. Supervisor

Richard Hubbard

Nathan Schloss, Economist

-

Office of the Attomey General

State Liaison Officer

Chairman, Illinois Commerce

Commission

.

4

-

. .

-

-

-

-

.

-.=

=

. Commonwealth Edison Company,-

-6-

DISTRIBUTION

. PUBLIC IE-01

SECY

CA

LCallan, EDO

- AThadani, DEDE

LChandler, OGC

_

JGoldberg, OGC

' SCollins, NRR

RZimmerman, NRR

Enforcement Coordinators

Rl, Ril and RIV

Resident inspector, LaSalle-

'

- RCapra, NRR-

DSkay, NRR

JGilliland, OPA

HBell, OlG .

GCaputo,01

TMartin,'AEOD -

TReis, OE

JLieberman, OE :

OE:EA (2)(also by E-Mail) -

' RAO: Rill

SLO: Rill

' PAO: Rill

.OC/LFDCB -

DRP

Docket File:

1

. . . . . .

. . . . . . . . . . .

.

..

.

..

. . . .

. . -.

.

. . - -

..

-

-

--

. _ . -