ML20236D060
| ML20236D060 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/03/1989 |
| From: | Bliss H COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8903220440 | |
| Download: ML20236D060 (3) | |
Text
{{#Wiki_filter:' w 'A +e.. sM., Eg, "' ;, yN bommonwicith Edison: @O i ^ 0;- )(One First National Plaza, Chicago, Illinois -
- , O ?J - Adoress Peply to: Post Office Box 767 i;
-1 - Q, Chicago, Illinois 60690 ,= . March 3, 1989- 'Mr. A./BertiD'avla Regional Administrator i 1 j U.S. Nuclear Regulatory Commission: 1 Region;III' j 799 Roosevelt Ro'ad Glen Ellyn,~IL '60137 .- 1
Subject:
. LaSalle County Station-Units'l and 2 i Response to Inspection-Report Nos. l 50-37A/88022 and 50-374/88021 q . HRC Doq)tel_Hos. 50-373 and__50-374 lJ l References (a): E.G. Greenman letter to Cordell Reed-dated.Octobo: 28,'1988.- '(b): B'. Clayton letter to Cordell Reed dated February 8, 1989.
Dear Mr. Davis:
1 This letter is in response to tile inspection conduct'ed by Messrs.LR. l Lanksbury,.R. Kopriva, P.L. Eng, and J.F., Smith 'on August 9f through October.21,: 1988, of_certain, activities conducted at LaSa11e' County Station.' Reference; (a) indicated that certain activities appeared to.be in noncompliance with NRC ~ 1 requirements. Reference (b) described this violation. The following-attachment provides Commonwealth Edison Company's response to the Level V Notice of Violation. '3 [ t If you have any further questions regarding'this matter, please direct them to this office. very truly~yours, s h32jDOCK05000373 0440 990303 O PNU H. E. liss Nuclear, Licensing Manager 1 Im - t, Attachment ./
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- Senior' Resident Inspector - LaSalle I k' l'
'5573K u 1 _
6' i ) AITACIRiENT I l VIOLATIO.tJ: 10 CFR 50, Appendix B, Criterion V, requiresthatactivkties affecting quality be accomplished in accordance with apptoved procedures. LAP-850-3, Revision 9, " Service Information Letters (SILs)," Step E.2, states in part: "The following time limits apply to SIL implementation: Category 1 - no latar than three months after issue date.") Step Ft.3 l states in parts l "The General Electric representative onesite will make any comments o (or indicate none if that is the case)..."; Step F.4 states in part: " File the original in the SIL notebook"; Step F.5.b states in part: " Central file will..., file the guideline and a copy of both Status Response Form, and letter of rejection to DMNS with original SIL." j j 4 Contrary to the above, the following example of activities affecting j quality not being accomplished in accordance with an approved procedure were identified: SIL 380, Revision 1, had an issue date of February 10, 1984, and j was determined to be a Category I SIL. Therefore, implementation would have l l to be complete by May 10, 1984. Implementation was completed on April 29, 1985, with the issuance of LOS-RR-SRI. In addition, the SIL notebook did not I contain copies of the letter to DMNS, GE comments, and the S7.L guideline as ) s required. I I l CQRRILCIIVE ACTI01LTAl<EN AliR_REETE_ ACHIEVED: l Commonwealth Edison Company admits this violation. LaSalle Station recognized the problem with time limits imposed by Step E.2 of LAP-850-3, 1 Service Information Letters (SIL's), Revision 9, in April, 1985. LAP-850-3, Rev'elon 10, changed the time limits for SIL implementation into recommended guidelines, an was or4.ginally intended by General Electric (GE) SIL 001. This revision simplified the review process and filing instructions by eliminating the GE Site Representative comments and the SIL Guideline (LAP-850-3, Rev. 9, Attachment A). It also incorporated the use of Action Item Records (AIR's) to track the review of SIL's. In order to simplify the paper flow, LAP-850-3, Revision 11, was initiated in November 1985. This revision instructed the completed SIL Status L Response forms (Attachment A) to be placed in the corresponding AIR folder, rather than being filed in the SIL Notebook. LaSalle Station has performed a review of its SIL Notebook to ensure that the notebook is up-to-date and to determine if a proper review of applicable SIL's has.taken place. To ensure that all applicable.SI' s have been received by LaSalle Station, GE was contacted to provide a list f SIL's that have been sent to the station, which required a response te GE. This list also identified SIL's that GE had already received a response from LaSalle Station. Thic list was received and compared against LaSa11e's records including the SIL Notebook. The SIL Notebcok was updated, and the following categories were identified and acted upon. s h
m 7 ; c ' '- 4 I i . A. SIL's that the station has reviewed and a response sent to GE. This category required no further action. 'B. SIL's that the station is in the process of reviewing and which a ) response has not yet been sent to GE. These SIL's,are being tracked via AIR's on the Nuclear Tracking System (NTS) and will be processed 'i in accordance with LAP-850-3. No additional action is required for this category. C. SIL's that the station has reviewed, but no response was sent to GE. For these SIL's, documentation of the review for each SIL was -located' and collected. New'SIL Status Response forms were written, or in i some cases, the old response forms were reproduced and submitted with l l l the supporting documentation for review before being sent to GE. j These SIL's were routed through the Technical Staff Supervisor, l Assistant Superintendent of Technical Services, and the Services Superintendent to review for adequacy. The SIL Status Response forms l were then sent to GE in accordance with LAP-850-3. No additional -{ action is required for this category. D. SIL's that the station has not reviewed. For these SIL's, copies of each SIL have been obtained, logged appropriately, and processed in accordance with LAP-850-3. Each SIL has had a preliminary review performed to identify possible significant safety issues. This 1 I initial review confirmed that none of the SIL's posed an immediate threat to plant operation or safety. Each SIL is being reviewed in I detail, for applicability at LaSalle and is being tracked by an AIR. I Upon completion of each review, the SIL will be handled in accordance with the procedure. e l CORERCTLVJLACIION_.IAKEN TO AVOID _1.URTHER_Y10LAIl0Rt { l LAP-850-3 was rereviewed and revised again to simplify and clarity l the procedure's instructions for processing, filing, and responding to GE SIL's sont to LaSalle Station. l l-All station personnel involved in the processing of SIL's were trained on LAP-850-3, emphasizing the correct method and time frame for processing SIL's. In addition,.the same personnel were counselled on the importance of adhering to procedures. PATE_QL_filLL._CQtiELIANCEL Full compliance has been achieved. ?. 5573K _ _ - -}}