ML20247F216
| ML20247F216 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/08/1998 |
| From: | Dacimo F COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-373-97-23, 50-374-97-23, NUDOCS 9805190210 | |
| Download: ML20247F216 (3) | |
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Commonu ralth lilium Company laSalle Generating Station i
a 2601 horth 21st Road Marwilles, !!. 61341-9757 Tel 815d574,761 i
May 8,1998 United States Nuclear Regulatory Commission i
Attention: Document Control Desk Washington, D.C. 20555
Subject:
Notice of Violation, NRC Inspection Report 50-373/374-97023 LaSalle County Station, Units 1 and 2 Facility Operating License NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374
Reference:
G. E. Grant letter to O. D. Kingsley, dated March 23,1998, Transmitting NRC Inspection Report 50-373/374-97023 The enclosed attachment contains LaSalle County Station's response to the Notice of Violation, that was transmitted in the Reference letter.
If there are any questions or comments concerning this letter, please refer l
them to Harold D. Pontious, Jr., Regulatory Assurance Manager, at (815) 357-6761, extension 2383.
Respectfully, 1
Fred R. Dacimo Site Vice President LaSalle County Station Enclosure cc:
A. B. Beach, NRC Region Ill Administrator M. P. Huber, NRC Senior Resident Inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle y
9005190210 900500
/
PDR ADOCK 05000373 g
PM t
A Unicom Company L_-_______
ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-97023
. VIOLATION: 373/374-97023-03 During an NRC inspection conducted on December 22,1997, through March 6,1998, a violation of NRC requirements was ident!fied.
10CFR50, Appendix B, Criterion lil, " Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated l
into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.
l Contrary to the above, on March 20,1997, design change package 9500087 to install permanent screens in the Unit 2 floor drain and equipment sumps to prevent foreign material intrusion into sump piping and containment isolation valves was canceled because the design change package and associated work request could not be located after physical work was completed. As a result, the iicensee failed to ensure, through documentation of completed post-modification inspection and other activities such as drawing revisions, that the applicable design basis and regulatory requirements were correctly translated into specifications, drawings, procedures, and.: instructions.
REASON FOR VIOLATION:
The violation resulted from a programmatic breakdown between the modification and work control processes. Specifically, the work request (WR) packages associated with Design Change Package (DCP) 9500087 were physically misplaced, and not linked to the DCP in the Electronic Work Control System (EWCS). However, a WR to install foreign material exclusion (FME) plugs in the Unit 2 floor drain and equipment sump drain lines during outages was linked to the DCP, and subsequently canceled after l
the screens were installed. Since the only WR linked to the DCP was canceled, the modification coordinator incorrectly assumed that the DCP -
should also be canceled.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The WR packages were located and electronically linked to DCP 9500087.
The DCP status in EWCS was reset from canceled to active, and the DCP is being tracked as a " partially installed" design change. The DCP will be completed prior to restart of Unit 1 (NTS 373-100-97-02303.01).
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A review of canceled DCPs to identify similar problems is currently 75%
complete, and no other problems have been identified. This review will be complete prior to restart of Unit 1 (NTS 373-100-97-02303.02).
The DCP cancellation process requirements have been re-enforced with the Modification Coordinators.
l CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS:
1 To prevent misplacement, original design change packages will be retained j
by Design Engineering. Only copies of the packages will be issued to the field. This policy has been in effect since November 1997 (NTS 373-100-97-02303.03).
To prevent disconnection of work requests from their associated design change packages, the Modification Coordinator will create the initial WRs associated with DCPs. This policy has been in effect since the fall of 1995 (The linkage error occurred in April of 1995) (NTS 373-100-97-02303.04).
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
1 Full compliance was achieved on February 28,1998, when DCP 9500087 was reset to active status.
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