ML20246D622
| ML20246D622 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/30/1989 |
| From: | Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20246D619 | List: |
| References | |
| 50-373-89-14, 50-374-89-14, NUDOCS 8907110377 | |
| Download: ML20246D622 (2) | |
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NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50-373; 50-374 LaSalle County Nuclear Station As a result of the inspection conducted on May 23 through June 16, 1989, and~in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Proccuure for NRC Enforcement Actions (1988), the following violation was identified:
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings and be accomplished in accordance with these instructions, procedures, or drawings and that instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Technical Specification Surveillance Requirements 4.6.5.3.b.2 and 4.6.5.3.c for the Standby Gas Treatment System and 4.7.2.b.2 and 4.7.2.c for the Control Room and Auxiliary Electric Equipment Room Emergency Filtration System specify that the charcoal adsorbers meet the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.
This regulatory position specifies that charcoal adsorbers of two-inch bed depth with assigned decontamination efficiencies of 95% be tested with methyl iodide with a penetration acceptance criterion of less than 1% and that charcoal adsorbers of four-inch or greater bed depth with assigned decontamination efficiencies of 99% be tested with methyl iodide with a penetration acceptance criterion of less than 0.175%.
Nuclear Regulatory Commission (NRC) Generic Letter No. 83-13, Clarification of Surveillance Requirements for HEPA Filters and Charcoal Adsorber Units in Standard Technical Specifications on ESF Cleanup Systems, issued to all applicants for operating licenses and holders of construction permits for power reactors on March 2, 1983, specifies a methyl iodide penetration test acceptance criterion of less than 0.175% when a charcoal adsorber efficiency of 99% is assumed or less than 1% when a charcoal adsorber efficiency of 95%
is assumed in the NRC staff's safety evaluation.
The NRC staff's Safety Evaluation Report for LaSalle County Station Units 1 and 2, NUREG-0519, March 1981, states that the Standby Gas Treatment System charcoal bed depths are eight inches with an assigned efficiency of 99% (Subsections 6.5.2.2 and 15.3.2.1 and Table 15.1) and that the Control Room and Auxiliary Electric Equipment Room Emergency Filtration System charcoal bed depths are two inches with an assigned efficiency of 95% (Subsection 6.5.2.1).
Contrary to the above, the licensee failed to include the appropriate quantitative and qualitati.e acceptance criteria specified by Technical Specifications for the aforementioned ventilation systems into the implementing procedure in that Station Procedure No. LTS-400-16, Removal of Carbon Test Canisters from Filtration System Trains for Analysis, establishes an acceptance 8907110377 890630 PDR ADOCK 05000373 O
FDC
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"'t Notice'of Violation 2
criterion for. methyl iodide penetration of less than or equal to 10% rather than the Technical Specification Surveillance Requirement acceptance criteria for methyl iodide penetration of less than 0.175% er the Standby Gas Treatment System and 1% for the Control Room and Auxiliary Electric Equipment Room Emergency Filtration System.
As a result of the er:oneous procedural acceptance criteria there were five apparent failures to meet Technical Specification Surveillance Requirements (April 4, 1985; May 31, 1985 (two adsorber beds); and June 5, 1985 (two adsorber beds)) and four periods of time during at least part of which the licensee was in apparent violation of Technical Specification Limiting Condition of Operation Action Requirements which specified restoration of the inoperable ventilation systcms or reactor shutdown within specified periods of time (April 4 through July 1, 1985; May 31, 1985 through November 25, 1986; June 5, 1985 through July 8, 1986; and June 5, 1985 through December 3, 1986).
This is a Severity Level IV violation (supplement I).
Pursuant to the provisions of 10 CFR 2.201, you are required to subm1= 'o this office within thirty days of the date of this Notice a written statemc or explanation in. reply, including for each violation:
(1) the corrective actions that have been taken and the results achieved; (2) the corrective actions that will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
hlSobY9 Y
UAW Dated
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L. Robert Greger, Chief Reactor Programs Branch l
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