ML20248M122

Forwards Engineering & Technical Support Insp Repts 50-373/98-05 & 50-374/98-05 on 980319-0421,NOV & Exercise of Enforcement Discretion.Number of Deficiencies Attributed to Lack of Thoroughness During Performance of Work

ML20248M122
Person / Time
Site:	LaSalle
Issue date:	06/05/1998
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O COMMONWEALTH EDISON CO.
Shared Package
ML20248M123	List: ML20248M122 ML20248M127
References
50-373-98-05, 50-373-98-5, 50-374-98-05, 50-374-98-5, EA-98-286, EA-98-297, GL-89-13, NUDOCS 9806150035
Download: ML20248M122 (4)

See also: IR 05000373/1998005

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June 5, 1998

EA 98-286

EA 98-297

Mr. Oliver D. Kingsley

President, Nuclear Generation Group

Commonwealth Edison Company

ATTN: Regulatory Services

Executive Towers West lli

1400 Opus Place, Suite 500

Downers Grove,IL 60515

SUBJECT:

NRC ENGINEERING AND TECHNICAL SUPPORT (E&TS) INSPECTION

REPORT NOS. 50-373/98005(DRS) & 50-374/98005(DRS), NOTICE OF

VIOLATION, AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Kingsley:

On April 21,1998, the NRC completed an inspection at your LaSalle facility. The focus of this

inspection was to review the engineering and technical support provided to the station. The

inspection also included a review of the status of the LaSalle Restart Action Plan actions related

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to engineering. The enclosed repod presents the results of that inspection.

Overall, the NRC concluded that the engineering and technical support provided by the design

and system engineering groups was adequate. In particular, implementation of the modification

and the 10 CFR 50.59 processes, as well as the system engineering support of the surveillance

and testing program appeared to be effective. The NRC also concluded that good progress has

been made in the implementation of the engineering action plan items discussed in the LaSalle

Restart Action Plan.

This inspection also identified a number of concems. These concems are generally

categorized into three different areas: (1) examples of work which at times lacked sufficient

attention-todetail, (2) material condition issues, and (3) the status of various regulatory

. programs. Regarding the first concem, the NRC identified a number of deficiencies which were

attributed to a lack of thoroughness during the performance of work. For example, during the

review of a relay replacement issue, the fJRC identified that although a relay had been

identified for replacement, the relay was overlooked and not replaced. Regarding material

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condition, although the overall material condition of the station has improved, the NRC identified

a number of material condition deficiencies despite extensive walkdowns prior to the inspection.

For example, the NRC identified that diesel generator rollup door curbs were in poor material

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condition and failed to fulfill their intended function. The NRC reviewed a number of your

programs including the inservice testing program, setpoint control program, Generic Letter 89-13 heat exchanger inspection program, and the fuse control program. We noted that

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Comed identified a number of significant deficiencies with these and other important programs,

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and are in the process of taking corrective actions to improve these programs. However, given

the scope of problems identified to date, and given the number of additional programs to be

reviewed, it is apparent that a significant amount of work remains to be accomplished prior to

Unit 1 restart.

Based on the results of this inspection, the NRC has determined that violations of NRC

requirements occurred. These violations are cited in the enclosed Notice of Violation (Notice)

and the circumstances surrounding them are described in detail in the subject inspection report.

The violation regarding the fuse control program demonstrated a lack of thoroughness because

the quality and safety assessment organization had previously reviewed the program and failed

to identify the large backlog of fuse discrepancies which had not been evaluated. The

violations regarding unauthorized changes to the diesel generator air box drains and the failure

to replace a degraded relay identified by the preventative maintenance program, demonstrated

. a failure to correct known deficiencies. In addition, errors identified by the NRC during the

review of temporary alterations were of concem since this was due to a lack of attention-to-

detail during the performance of work. Finally, the failure to provide the NRC with all completed

10 CFR 50.59 evaluations as required by 10 CFR 50.59(b)(2) was of concem since a corporate

procedure was inadequate despite extensive reviews prior to issuance to all six nuclear sites.

The NRC has concluded that information regarding the reason for the violation associated with

10 CFR 50.59 reporting, and the corrective actions taken and planned to correct the violation

and prevent recurrence, is already adequately addressed in this inspection report. Therefore,

- you are not required to respond to this violation unless the description therein does not

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accurately reflect your corrective actions or your position. In that case, or if you choose to -

provide additional information, you should follow the instructions specified in the enclosed

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Notice.

in addition, during this inspection, the team reviewed a number of violations which were self-

identified. These violations will not be subject to enforcement action because your efforts meet

the criteria specified in Section Vll.B.1 of the " General Statement of Policy and Procedures for

NRC Enforcement Actions,"(Enforcement Policy), NUREG-1600.

Finally, the NRC identified two violations; one related to design control and the other to

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corrective actions. However, after reviewing these violations and following consultation with the

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Director, Office of Enforcement, because these violations satisfy the appropriate criteria in

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Section Vll.B.2, " Violations identified During Extended Shutdowns or Work Stoppages," of the

" General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement

Policy), NUREG-1600, Notices of Violation are not being issued. Specifically, in reference to

the violations, although the violations were NRC identified, enforcement action was not

. considered necessary to achieve remedial action; the violations were based upon activities prior

to the events leading to the shutdown; the violations would not be categorized at a severity level

higher than Severity Level II; the violations were not willful; and actions specified in -

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Confirmatory Action Letter Rlll-96-008B effectively prevent the restart of LaSalle County Station

without implicit NRC concurrence.

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For the remaining violations, you are required to respond to this letter and should follow the

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Instructions specified in the enclosed Notice when preparing your response. The NRC will use

your response, in part, to determine whether further enforcement action is necessary to ensure

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compliance with regulatory requirements.

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

enclosures, and your response will be placed in the NRC Public Document Room (PDR).

Sincerely,

s/G. E. Grant

Geoffrey E. Grant, Director

Division of Reactor Projects

Docket Nos.: 50-373; 50-374

License Nos.: NPF-11; NPF-18

Enclosures:

1. Notice of Violation

2. Inspection Report 50-373/98005(DRS); 50-374/98005(DRS)

cc w/encts:

M. Wallace, Chief of Staff

D. Helwig, Senior Vice President

G. Stanley, PWR Vice President

J. Perry, BWR Vice President

D. Farrar, Regulatory

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Services Manager

1. Johnson, Licensing Director

DCD - Licensing

F. Dacimo, Site Vice President

T. O'Connor, Station Manager

P. Bames, Regulatory Assurance

Supervisor

Richard Hubbard

Nathan Schloss, Economist

Office of the Attomey General

State Liaison Officer

Chairman, Illinois Commerce

Commission

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Distribution:

J. Goldberg, OGC w/encls

J. Lieberman, OE w/encls

B. Boger, NRR w/encls

SAR (E-Mail)

Project Mgr., NRR w/encls

C. Paper!ello w/encls

J. Caldwell w/encls

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B. Clayton w/encis

SRI LaSalle w/encls

DRP w/encls

TSS w/encls

DRS w/encls

Rlli PRR w/encls

PUBLIC IE-01 w/encls

Docket File w/encls

GREENS

LEO (E-Mail)

DOCDESK (E-Mail)

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