ML20247H964
| ML20247H964 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/09/1998 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kingsley O COMMONWEALTH EDISON CO. |
| References | |
| EA-98-217, NUDOCS 9805210299 | |
| Download: ML20247H964 (5) | |
Text
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l May 9, 199C l
EA 98-217 l
Mr. Oliver D. Kingsley President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West 111 1400 Opus Place, Suite 500 Downers Grove, IL 60515
SUBJECT:
NRC REVIEW OF LICENSEE EVENT REPORTS DOCUMENTING ENGINEERING DEFICIENCIES AT LASALLE AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Kingsley:
This refers to the NRC's review of Licensee Event Reports (LERc) that documented engineering design deficiencies at Commonwealth Edison's (Comed's) LaSalle County Station. The results of the NRC's review were discussed with several members of the LaSalle staff at a meeting on April 14,1998.
The NRC has determined that six violations of NRC requirements occurred. This determination was based on the information documented in the LERs, and discussed at the meeting. These violations included unanalyzed conditions and conditions that were outside the design basis of LaSalle Units 1 and 2, and were caused by noncompliance in design control, procedural inadequacies, and inadequate corrective actions. Examples included: (1) hot shorts that could result in damage to motor-operated valves required for safe hot shutdown; (2) American Society c,f Mechanical Engineers Boiler and Pressure Vessel Code,Section XI inservice test program anomalies due to personnel errors; (3) potentialloss of both trains of the standby gas treatment system and containment pressure suppression during a loss of coolant accident because the system design was not adequately understood when developing system operation procedures; (4) leak detection temperature calculation errors; (5) reactor building high energy line break (HELB) bounding temperature was potentially nonconservative; and (6) potential pressurization of the turbine building ventilation exhaust tunnel resulting from a main steam HELB due to calculation errors. Each of these violations had existed for an extended period of time without being identified by either the facility's or Comed's assessment programs. A list of the corresponding LERs is enclosed with this letter.
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I O. Kingsley 2
l The six violations represent a significant regulatory concern because they demonstrated that the LaSalle Nuclear Plant staff was not sufficiently rigorous in ensuring that the facility's design basis was adequately incorporated in the design, installation, testing, and operation of some systems and components affecting quality. Normally, such violations would be considered for escalated enforcement in accordance with NUREG-1600, " General Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement Policy). However, as discussed in Section Vil.B.2 of the Enforcement Policy," Violations identified During Extended Shutdowns or Work Stoppages,"
the NRC may refrain from issuing a Notice of Violation or propose a civil penalty for violations that were identified after: (1) the NRC has taken significant enforcement action based upon a major safety event contributing to an extended shutdown of an operating reactor; or (2) the licensee entered an extended shutdown related to generally poor performance over a long period of time.
Accordingly, after consultation with the Director, Office of Enforcement, I have been authorized to exercise enforcement discretion in accordance with Section Vll.B.2 of the Enforcement Policy and not issue a Notice of Violation or propose a civil penalty in this case. Discretion was warranted because: (1) the violations were licensee-identified as a result of a comprehensive program for problem identification and correction that was developed in response to the shutdown; (2) the violations were based upon activities which took place prior to the events leading to the shutdown of LaSalle County Station; (3) the violations would not be categorized at a Severity Level higher than Severity Level ll; (4) the violations were not willful; (5) the LaSalle facility is shut down for performance reasons including engineering and design issues, such as the ones identified in these LERs, and in enforcement actions (EAs) issued on September 29, 1997 (EAs96-392 and 97-021) which involved a Severity Level 111 problem for the failure to adequately control design changes to the residual heat removal service water system and the control room radiation monitoring system; (6) Comed's decision to restart LaSalle Units 1 and 2 requires NRC concurrence in accordance with Confirmatory Action Letter Rlll-96-008B; (7)
Comed has demonstrated that remedial action is being taken to ensure re-establishment of design margins for plant systems prior to plant restart; (8) Comed has made substantial progress in addressing and resolving the issues identified in the LERs described in the enclosure and the bases for closure of each LER will be documented in NRC inspection reports; and (9) the NRC issued a $650,000 civil penalty on January 24,1997 (EA 96-325), which included sanctions for engineering violations related to the failure to understand the design functions and performance characteristics of safety-related systems.
The NRC has concluded that information documented in the LERs already adequately addressed on the docket the reasons for the violations, the corrective actions taken, the corrective actions planned to prevent recurrence, and the date when full compliance will be achieved. No response to this letter is required.
The exercise of enforcement discretion in this case is identified as escalated enforcement item (EEI) 50-373/98013-01; 50-374/98013-01, " Examples of Noncompliance in Design Control, Procedure Adequacy, and Corrective Actions." This eel will be used to track the exercise of enforcement discretion.
O. Kingsley 3
in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room (PDR).
Sincerely, original /s/ by A. B. Beach A. Bill Beach Regional Administrator Docket Nos: 50-373;50-374 License Nos: NPF-11; NPF-18
Enclosure:
List of Licensee Event Reports (LERs) included in NCV 50-373/98013-01; 50-374/98013-01 cc w/ encl:
M. Wallace, Senior Vice President D. Helwig, Senior Vice President G. Stanley, PWR Vice President J. Perry, BWR Vice President D. Farrar. Regulatory Services Manager
- 1. Johnson, Licensing Director DCD - Licensing F. Dacimo, Site Vice President T. O'Connor, Station Manager P. Barnes, Regulatory Assurance Supervisor Richard Hubbard Nathan Schloss, Economist Office of the Attomey General State Liaison Officer Chairman. Illinois Commerce Commia.on See Attached Distribution G:D Rpthe bou! 'C' = Copy wthout attachmenvenclosure 'E's Co y Wih attachment / enclosure 'N's No copy LAS04278.DRS DOCUMENT NAME:
To receive a copy of this document. Indicate OFFICE Rlll A, f-OE l
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Distribution:
J. Lieberman, OE w/enci J. Goldberg, OGC w/ encl B. Boger, NRR w/ encl SAR (E-Mail)
Project Mgr., NRR w/ encl A. Beach w/enci J. Caldwell w/ encl B. Clayton w/ encl SRI LaSalle w/enci DRP w/enci TSS w/ encl DRS w/enci Rlli PRR w/enci PUBLIC IE-01 w/ encl Docket File w/ encl GREENS LEO (E-Mail)
DOCDESK (E-Mail)
t LIST OF LICENSEE EVENT REPORTS (LERs)
INCLUDED IN eel 50-373/98013-01; 50-374/98013-01 LER NUMBER '
EVENT DATE TITLE REPORT DATE 50-373/96016-00 Hot Short Could Result in Damage to Motor-Operated Valves 11/06/96 Required for Safe Hot Shutdown.
12/03/96 50-373/96019-01 American Society of Mechanical Engineers (ASME)Section XI 50-373/96019-02 Inservice Test Program Anomalies Due to Personnel Error.
50-373/96019-03 12/10/96 04/04/97 50-373/97005-00 Potential Loss of Both Trains of the Standby Gas Treatment l
50-373/97005-01 System and Containment Pressure Suppression During the Firsi i
50-373/97005-02 10 Seconds of a LOCA Due to Deficiencies in Original Design 02/20/97 Analysis and Procedures.
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l 03/24/97 50-373/97031-00 Leak Detection Area Temperature Calculation Error.
50-373/97031-01 50-373/97031-02 08/22/97 09/19/97 50-373/97033-00 Reactor Bui: Jing High Energy Line Break (HELB) Bounding 50-373/97033-01 Temperature Potentially Unconservative.
09/11/97 10/10/97 50-373/97046-00 Potential Pressurization of the Turbine Buil ding Ventilation 12/16/97 Exhaust Tunnel Resulting From a Main Steam HELB Due to a 01/15/98 Calculation Error.