ML20248M122
| 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: |
| 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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O. Kingsley
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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
Enclosures:
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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