RS-13-257, Updated Request for Relaxation of Confirmatory Order EA-04-170

Updated Request for Relaxation of Confirmatory Order EA-04-170

ML13338A607
Person / Time
Site:	LaSalle
Issue date:	11/01/2013
From:	Gullott D Exelon Generation Co
To:	Zimmerman R NRC/OE
References
EA-04-170, RS-13-257
Download: ML13338A607 (7)

Text

1 4300 Winfie!d Warrerwii:e,IL 630 D Office Lii RS-13-257 RS-13-257 November 1, November 1, 2013 Roy P.

Roy P. Zimmerman Director, Office Director, Office of Enforcement U. S.

U. S. Nuclear Regulatory Commission Washington, DC Washington, DC 20555-0001 20555-0001

Subject:

Updated Request for Updated for Relaxation of of Confirmatory Order EA-04-170 EA-04-170

References:

from M.

1) Letter from M. R.

R. Johnson (U. S. NuclearNuclear Regulatory Regulatory Commission)

Commission) to to C. M.

C. M. Crane Crane (Exelon (Exelon Generation Generation Company, Company, LLC),LLC), "Confirmatory Order Modifying License (Effectively Immediate),

Modifying Immediate), Reclassification of Severity Level, and Level, and Reduction of Civil Penalty (NRC (NRC Office Office of of Investigations InvestigationsReport Report No. 3-2004-009)," dated November 22, No. 2005 22,2005 Letter from

2) Letter fromD. D.J.J. Enright Enright(Exelon (Exelon Generation Generation Company, Company, LLC)LLC) to to U. S. Nuclear Nuclear Regulatory Commission, "Change Regulatory "Change of Maintenance Maintenance-Modification Contractor,"

-Modification Contractor,"

dated December 29,2006 dated 29, 2006

3) Letter from from D.D. M.

M. Gullott Gullott(Exelon (ExelonGeneration Generation Company, LLC) LLC) to U. u. S. Nuclear Nuclear Regulatory Commission, "Request "Requestfor for Relaxation RelaxationofofCondition Condition5.b 5.bofof Confirmatory Confirmatory OrderOrder EA-04-170,"

EA-04-170,"dated dated September September 11, 2013 11,2013

4) Letter from B. L. Burgess (U. S. Nuclear Nuclear Regulatory Regulatory Commission)

Commission) to to M. Crane (Exelon C. M. (Exelon Generation GenerationCompany, Company,LLC), LLC), "LaSalle "LaSalle County CountyStation, Station, Units Units 1 and 2, NRC Integrated Inspection Report 05000373/2006003; 05000373/2006003; 05000374/2006003," dated dated May May 2, 2006 2,2006

5) Letter from B. L. Burgess (U. (U. S.

S. Nuclear Nuclear Regulatory Regulatory Commission)

Commission)to to M. Crane (Exelon C. M. (Exelon Generation GenerationCompany, Company,LLC), LLC), "LaSalle "LaSalle County CountyStation, Station, Units Units 1 and 2, NRCNRC Integrated Inspection Report Report 05000373/2007002; 05000373/2007002; 05000374/2007002,"

05000374/2007002," dated datedApril April 27, 20072007

Dear Mr. Zimmerman:

Zimmerman:

By letter letter dated November 22, 2005 (Reference 22,2005 (Reference 1), 1), the the U.U. S.

S. Nuclear NuclearRegulatory RegulatoryCommission Commission (NRC) issued issued aaConfirmatory ConfirmatoryOrder OrderModifying Modifying License License (Effective (Effective Immediately)

Immediately) (EA-04-170)

(EA-04-170) to to Exelon Generation Company, LLC (EGC) as part of a settlement LLC (EGC) as part of a settlement agreement agreement between EGC and EGC and the the NRC NRC concerning concerning anan apparent apparentviolation violationinvolving involving three three employees employeesofofThe TheVenture Venture(Venture),

(Venture),

contractors contractors toto EGC, EGC, andand their their foreman, foreman, also alsoaaVenture Ventureemployee, employee,who whoentered entereda aHigh HighRadiation Radiation Area Area (HRA)

(HRA) inin the the LaSalle County Station (LaSalle)

(LaSalle) Unit Unit 11 Reactor ReactorBuilding Building raceway raceway to to conduct conduct preparations for valve valve replacement replacement on on January 25, 2004. The Thecontractors contractorsdiddid not not sign sign onto onto the the required required HRA HRA radiation radiation work work permit permit (RWP)

(RWP) or or receive receive the therequired requiredbriefing briefingfor forworkworkininthetheHRA.

HRA.

November 1, 2013 November U. S.

U. S. Nuclear Nuclear Regulatory Commission Page 2 Page The actions of the Venture The Venture employees employeesresulted resultedininan anapparent apparentviolation violation of of LaSalle LaSalle Technical Technical Specifications (TS)

Specifications (TS) 5.7.1, 5.7 .1, "High "HighRadiation RadiationAreasAreaswith withDose Dose Rates Rates NotNot Exceeding 1.0 1.0 rem/hour rem/hour at 30 Centimeters at Centimeters from from the Radiation Radiation Source Sourceor or from from any any Surface SurfacePenetrated Penetratedby bythetheRadiation,"

Radiation,"

which requires that an appropriate which appropriate RWP RWP be beutilized utilizedby byradiation radiation workers workersand andthat thataapre-job pre-jobbrief brief be provided prior be prior to entry into any any HRA.

HRA. TheThe NRC's Office Office ofof Investigations determined determined that that two of the three Venture of Venture craftcraft workers workers and and the theVenture Ventureforeman foremanwillfully willfully violated violated thethe station stationradiation radiation procedures implementing implementing the TSs.

Confirmatory Order Confirmatory Order EA-04-170 EA-04-170 required required EGCEGC to to require require that Venture revise its Operating Procedures to incorporate incorporate certain obligations with respect to entry obligations with respect entry into into an an HRA.

HRA. Those obligations included obligations included aa requirement that Venture Venture employees assigned assigned to to work work in in radiation radiation areas would read, understand, would understand,and andsignsigna apledge pledgecommitting committingtotofollowing following allall radiological radiological requirements.

requirements.

Venture updated its procedures Venture procedures to to incorporate incorporate the the pledge pledgerequirement.

requirement.

At the At the time time Confirmatory ConfirmatoryOrder OrderEA-04-170 EA-04-170was wasissued issued onon November November 22, 22, 2005, the Maintenance-Modification Contractor Maintenance-Modification Contractor was was The Venture (Venture).

(Venture). In In Reference Reference2,2,EGC EGCnotified notified the NRC that Venture would would be replaced replaced by by Stone Stone& & Webster Webster Construction, Construction, Inc.,Inc., aa subsidiary subsidiary of of the Shaw Shaw Group Group (Shaw),

(Shaw), as asthetheMaintenance-Modification Maintenance-Modification Contractor Contractor at at LaSalle LaSalle effective effective January 1, January 1, 2007.

2007. At Atthat thattime, time, Stone Stone&& Webster WebsterConstruction, Construction, Inc. Inc. adopted adopted the the requirements, requirements,in in entirety, of entirety, of the the Venture Venture Operating ProceduresProcedures associated associatedwith withthetheHRA HRA entry entry requirements requirements identified in identified in the the Confirmatory Confirmatory Order. Order. On On February February13, 13,2013, 2013,Chicago ChicagoBridge Bridge&&Iron Iron(CB&I),

(CB&I),

acquired the Shaw Shaw Group Group and and its its subsidiary, subsidiary, Stone Stone& & Webster Webster Construction, Construction, Inc.,Inc., the Maintenance-Modification Contractor Maintenance-Modification Contractor at at LaSalle. The Thespecific specificVenture Ventureobligations obligationscontained containedinin Confirmatory Order Confirmatory Order EA-04-170 EA-04-170 that that were assumed assumed by byStone Stone&&Webster WebsterConstruction, Construction,Inc., Inc.,

continue to be be metmetby byCB&I.

CB&I. (Stone (Stone&&Webster WebsterConstruction, Construction,Inc. Inc.will willbebereferred referredtotoasasCB&I). CB&I).

EGC recognizes the seriousness seriousnessofofthe theJanuary January25, 25,2004 2004apparent apparentviolation violationand andisisnot notdisputing disputing the reasons reasonswhy whythetheNRCNRCissued issuedthe theConfirmatory ConfirmatoryOrder Orderinin2005.

2005.However, However,the theConfirmatory Confirmatory Order addressed addressed eventsevents that that occurred occurred moremore than than nine nine years years ago, ago, and andLaSalle LaSalle and and itsits Maintenance-Modification Contractor have have complied complied with with the the Confirmatory Confirmatory OrderOrder requirements requirements for for more than seven years. years. During During thatthatperiod, period, LaSalle LaSalle and and EGC EGC mademadeaanumber numberof of improvements to the Radiation Radiation Protection Protection program program that that incorporates incorporatesthe theVenture Venturepledge pledge elements. For Forthis thisreason, reason,asasexplained explainedininmore moredetail detailbelow, below,EGC EGCisisrequesting requesting that thatthetheNRCNRC relax the the conditions conditionsof of Confirmatory Confirmatory Order OrderEA-04-170, EA-04-170,which whichspecify specifythe thefollowing:

following:

1. Exelon will will document document in LaSalle station station procedures proceduresorortraining trainingmaterial, material,the thefollowing following corrective actions:

actions:

a. revise revise initial initial radiation radiation worker worker training training material materialto tohighlight highlightHRAHRAentry entry requirements and and consequences consequencesfor forthe theradiation radiationworker workerifif requirements requirements are are not not met; met;

b. revise RWP revise RWP instructions instructionsthatthatallow allow HRAHRA entry entry toto state state"high "high radiation radiation entry entry brief required;"

required;"

c.

c. add add warnings warnings to to worker worker acknowledgments acknowledgments on on the the computer computer screenscreen duringduring the the access access control control electronic electronic dosimetry dosimetrylog-inlog-inprocess; process;

November 1, 2013 1,2013 U. S.

U. S. Nuclear Regulatory Commission Page 3

d. add the radiation radiation protection protection aid for conducting HRA briefings; and HRA briefings;

e. require aa signature from require transient refueling from transient refueling outage outage workers workers prior prior to to issuance issuance of dosimetry of dosimetry that that acknowledges acknowledges their their understanding understandingof ofHRA HRA entry entry requirements and the consequences consequencesfor forviolating violating them.

them.

2. Duringthe During thefirst first1010days, days,or orlonger longeras as necessary, necessary, of the next two refueling refueling outages, outages, LaSalle will LaSalle willhave have greeters greeters at primary access accesspointspointstotothe theradiologically radiologicallycontrolled controlled area to enhance enhance awareness awarenessofofradiological radiological controls.

controls.

3. For the For the next next two two refueling refuelingoutages, outages, allall transient transient refueling refueling outage outage workers, except except as as specifically authorized specifically authorized by by the the Radiation Protection Manager, Manager, will will be required to to attend and passpassaadynamic dynamiclearning learningactivity activity on on proper properHRA HRA entry.

entry.

4. LaSalle will LaSalle willperform performan an industry industrybenchmark benchmark evaluation evaluation of of HRA HRAcontrols, controls, and and evaluate changes to changes to existing existing practices practices priorprior to to the the next next refueling refueling outage.

outage.

5. In In addition addition totothe the corrective correctiveactions actions already already documented in in Exelon's Exelon's December December17, 17, 2004 response, response, Exelon Exelon will require that will require that Venture Venture revise revise itsits Operating Operating Procedures, which are which are applicable fleet-wide, further assure fleet-wide, to further assure compliance compliancewith with HRA HRA entry entry requirements and and totospecifically specifically include include the thefollowing following requirements:

requirements:

a. that a discussion discussion of of pertinent pertinent radiological practices be conducted radiological practices conducted at at each each daily shift brief; brief;

b. Venture employees that Venture employees who whowill will work work in in radiation radiation areas areaswill will read, read, understand, and understand, and sign a pledge pledge to to attest attest to to his his/her commitmentto

/her commitment tofollow follow all all radiological radiological requirements.

requirements. (Each pledge will will be co-signed co-signed by by the the Venture Venture site site manager, project superintendent, or project superintendent, orsite site as as low as reasonably reasonably achievable achievable (ALARA) coordinator coordinator and will will be be retained for for a period of one one year.);

year.);

c. that Venture superintendents will be present at at select select pre-job pre-job briefs briefs involving involving HRA entries; and and

d. that Venture will participate in will participate in Exelon Exelon Radiation Radiation Protection Protection Manager peer peer group meetings at least least semi-annually semi-annually to evaluate and take take action action on on radiation protection issues.

radiation protection issues.

6. Exelon willconduct Exelon will conduct aa review review of ofthe the implementation implementation and and effectiveness effectiveness of of its its and and Venture's corrective corrective actions covered in this this Order.

Order. ThisThis review review shall be conducted conducted for at least the the next next two two refueling outages at refueling outages at LaSalle.

LaSalle. The Theresults resultsofofeach eachreview reviewwillwill be made made available available for for NRC review review upon upon request. The Thereview review shallshall bebeconducted conductedby by knowledgeable knowledgeable individuals individuals independent independentof ofthe theLaSalle LaSallefacility.

facility.

7. The LaSalle LaSalle Plant Plant Manager Manageror orSite SiteVice Vice President Presidentwill will meet meetwith with contract contractleadership leadership prior to the prior to the next two two refueling refueling outages outages to establish personnelpersonnel expectations expectationsinin following radiological work requirements.

following radiological requirements.

November 1, 1, 2013 U. S.

U. S. Nuclear Regulatory Commission Page 4

8. The licensee licensee shall shall paypay aacivil civil penalty in the amount amount of of $10,000

$10,000 withinwithin 30 days of of the date of of this Order, in accordance accordance with with NUREG/BR-0254.

NUREG/BR-0254. In In addition, addition, at at the the time time ofof making making the the payment, the licensee shall submit a statement indicating licensee shall submit a statement indicating when and by when and by what method payment payment was was made, made,totothe theDirector, Director,OfficeOffice ofof Enforcement, U.S. U.S.

Nuclear Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville, MD Rockville, MD 20852-2738.

20852-2738.

In Reference 3, EGC In EGC submitted aa request requestthat thatthe theNRCNRCrelax relaxoneoneprovision provisionof ofthe theConfirmatory Confirmatory Order,Section IV, Condition 5.b.

IV, Condition 5.b. Following Following discussions discussionswith with Mr.

Mr. Steven Steven Orth Orth of of the the NRC NRC on on October 9, 2013, EGC is providing providing this this updated updated request.

In EGC's view, In view, good cause causeexists existsforforrelaxation relaxation of of (i.e.,

(Le., for for cessation cessationof) of)the therequirements requirements of of Confirmatory Order EA-04-170 in its entirety.

• Redundancy. The Thespecific specificprovisions provisionsininthe theradiation radiationpledgepledgeand andthe theobligation obligationofofCB&ICB&I contractor employees employees to to follow follow all radiological requirements are all radiological are institutionalized institutionalized via EGC's General Employee General EmployeeTraining Training(GET)

(GET)atatLaSalle, LaSalle,NEIT,NEIT,and/orand/orCB&ICB&I orientating orientatingtraining.

training.

• Scope. TheTheConfirmatory Confirmatory Order Order commitments commitments amended amendedonly only the the LaSalle LaSalle license licenseand andapply apply to CB&I employees only; CB&I employees only; however, however, aa substantial substantial number of other supplemental workers workers regularly access regularly access the the radiologically radiologically controlled controlled areaarea (RCA)

(RCA) who who areare not required to take the radiation pledge.

radiation pledge. The The institutionalization institutionalization (discussed above) above) and and robust robust barriers/interlocks barriers/interlocks (discussed below)

(discussed below) helphelp toto ensure ensurethat thatallallLaSalle, LaSalle,Maintenance-Modification, Maintenance-Modification, and other other contractor employees employees understand understandthe theimportance importanceofofthe theradiological radiologicalrequirements, requirements,including including the requirement requirement to sign on to a RWP and obtain a pre-job brief prior to entering the LaSalle to sign on to a RWP and obtain a pre-job brief prior to entering the LaSalle HRA.

• barriers/interlocks. Numerous improvements have been Robust barriers/interlocks. been implemented implemented at LaSalle LaSalle and EGC EGC fleet-wide fleet-wide since the imposition imposition of the the Confirmatory Confirmatory Order. Order. TheseThese barriers barriers and and interlocks interlocks are robust, procedurally based, based, firmly firmly rooted in management expectations, in management expectations,and and help to assure assure worker worker adherence adherence to to HRA HRA entry and associatedassociated requirements.

requirements.

The robust barriers/interlocks barriers/interlocks referred to above above include include the the following:

following:

â

? HRA locks/barriers-- access HRA locks/barriers access points points are arenow now locked locked andand thethelocks locks arearecontrolled controlled by by Radiation Radiation Protection. A A documented documentedHRA HRA brief brief is conducted by by Radiation Radiation Protection Protection prior to entry prior to entry toto an an HRA.

HRA. BothBoth of of these these requirements are contained contained in in EGC EGC procedure procedure RP-AA-460, RP-AA-460, "Controls for for High High and and Locked High High Radiation Areas." Areas."

â

? Trip tickets are now required for personnel Trip tickets personnel entering enteringthe theRCARCA at atLaSalle LaSalleand andfleet-wide.

fleet-wide.

Among other things, the the trip trip tickets contain aa prompt prompt for for personnel personnel to to acknowledge acknowledgeHRA HRA entry requirements, requirements, including including an an HRA HRA brief by Radiation Protection per EGC EGC procedure procedure RP-AA-1008, RP-AA-1008, "Unescorted Access AccessTo Toand andConduct ConductininRadiologically RadiologicallyControlled ControlledAreas."

Areas."

â

? The computer accessed accessedby bypersonnel personnelentering enteringthe theRCARCA contains contains aascreen screenrequiring requiring individuals individuals to to electronically electronically sign sign acknowledging that that they they must mustreceive receivean anHRAHRAbrief brief before entering entering an anHRA.HRA.

November 1, 2013 1,2013 U. S. Nuclear Nuclear Regulatory Regulatory Commission Commission Page 55 In addition addition to to these these barriers/interlocks, barriers/interlocks, the the following following administrative controls have have also alsobeen been implemented:

• As part ofof plant plant unescorted unescorted accessaccess inprocessing, inprocessing, contract contract personnel personnel must must complete complete aa human performance performance(HU) (HU) dynamic dynamiclearning learningactivity activity (DLA) which, among other (OLA) which, other things, things, contains an HRA awareness component.

HRA awareness component.

• Radiation Protection Business Radiation Protection Business Plan Tier 3 performance indicators have been been developed developedand and are regularly reviewed reviewed by by senior senior leadership. These Theseperformance performanceindicators indicatorstrack trackand andtrend trend radiation worker performance and radiation worker and include include criteria criteria for HRA entry issues.

HRA entry issues.

• A strict HU A strict HUaccountability accountabilityprocess process hashas been developed developed withwith expectations expectationsfor for the theconduct conductof of HU Review Boards HU Review Boards per EGC procedure procedure HU-AA-101-1002, HU-AA-101-1002, "Human Performance Performance Review Review Board,"

Board," forfor any any HRAHRA radiation radiation worker worker performance performance issue. issue.

As documented in in References References 44 and and 55and andininaccordance accordancewith withthetheConfirmatory Confirmatory Order,Order, thethe Maintenance-Modification Maintenance-Modification Contractor Contractorrevised revisedits itsOperating Operating Procedures, Procedures, which are applicable to EGC fleet-wide.

fleet-wide. The Confirmatory Confirmatory Order Order commitments commitments amended amended only only the the LaSalle LaSalle license licenseand and apply to CB&I CB&Iemployees employees only. only. It should be noted that even It should even though thoughthe theConfirmatory Confirmatory Order Order was was specific to LaSalle, EGC, EGC, in in conjunction conjunction with with CB&I, implemented the requirements CB&I, implemented requirementsof ofthe the Confirmatory Order Confirmatory Order at at all all EGC EGC nuclear nuclear sites.

Performance by the Maintenance-Modification Maintenance-Modification Contractor Contractor since since the the January January 25, 25, 2004 2004 apparent apparent violation and violation and November November 2005 2005 Order Order demonstrates demonstrates the effectiveness effectiveness of of the measures measuresininplace place with with respect to HRA entry. Following HRA entry. Following issuance issuanceof ofthe theConfirmatory Confirmatory Order,Order, Shaw Shaw(CB&I)

(CB&I) hadhad one one instance (at instance (at Braidwood Braidwood Station on on October October8, 8, 2010) 2010)where wherean anindividual individualentered enteredananHRA HRAwithout without signing onto the HRA HRA RWP RWP and and without without receiving receivingthe the required required briefing.

briefing. AsAs an employee new new toto nuclear, the individual mistakenly assumed individual mistakenly assumed the the briefing briefing received the the previous previous daydaywaswasnot notaa daily requirement daily requirement and that it allowed allowed entry entry into into any any HRA.

HRA. Excluding Excluding that that one instance, there there have been been nonoother otherviolations violations associated associatedwith withCB&ICB&I or Shaw workers entering entering anan HRA HRA at LaSalle or other EGC nuclear sites.

LaSalle Compliance with with thethe Conditions of of the the Confirmatory Confirmatory Order Order associated associated with with the the first first two outages outages were determined satisfactory as documented documented in in NRC NRC Inspection Inspection Reports Reports 2006-003 2006-003 and and 2007-002 (References 4 and 5). As As stated statedinin Reference Reference55the theinspectors inspectorsreviewed reviewedLaSalle LaSalle procedures and procedures and training training material material and and attended attendedaapre-outage pre-outagedynamic dynamiclearning learningactivity activitytraining training session to assure assure that that the the licensee:

licensee:

• Revised initial radiation worker initial radiation worker training training material material to to highlight highlight HRAHRAentryentry requirements requirements and and consequences for consequences forthe theradiation radiation worker worker ifif requirements requirements are arenotnotmet; met;

• • Revised RWP instructions instructions that that allow allow HRA HRA entry to state state"high "high radiation radiation entry entrybrief brief required;"

required;"

• Added warnings to worker acknowledgments Added warnings to worker acknowledgments on the computer screen on the computer screen during the access access control electronic dosimetry log-in control process; log-in process;

• • Added warnings Added warnings to to worker workeracknowledgments acknowledgments on on the the computer computer screen screen during the access access control electronic dosimetry log-in control process; log-in process;

• • Added the radiation protection protection aid aid for for conducting conducting HRA HRA briefings; briefings; and and

November 1, 2013 U. S. Nuclear Regulatory Commission U.

Page 6

• Required a signature signature fromfrom transient transient refueling refueling outage outage workers workers prior prior to issuance issuanceof ofdosimetry dosimetry that acknowledges their understanding of HRA HRAentryentryrequirements requirementsand andthetheconsequences consequences violating them.

for violating The inspectors observed observed licensee licenseeactivities activities associated associated withwith the second second outage outagesince sincethe theinitial initial date of date of the Confirmatory Confirmatory Order to assure assure that:that:

• During the During the first first 10 10 days, days, or or longer as necessary, necessary,of ofthe theL2R1 L2R111 refueling refueling outage, LaSalle had greeters at greeters at primary access points primary access points to to the the radiologically controlledarea radiologically controlled areatotoenhance enhance awareness of radiological of radiological controls; and

• For the L2R1 L2R111outage, outage, all all transient transient refueling refueling outage workers, workers, except except as asspecifically specifically authorized by the Radiation Protection Manager, Manager, were required to attend and pass passaa dynamic learning activity activity on proper proper HRA HRA entry.

The inspectors inspectors reviewed reviewed the the corrective corrective actions actionsoutlined outlined inin Exelon's Exelon's letter letter dated dated December 17, 2004, to to assure assurethat that[the

[thelicensee's licensee'scontractor]

contractor]ShawShawrevised revisedits itsoperating operating procedures, which procedures, which were were applicable applicablefleet-wide, fleet-wide, to to further further assure assurecompliance compliancewith withHRA HRAentryentry requirements. The inspectors inspectors verified through review verified through review of of selected selected records and observations observations that: that:

• Shaw employees who work work in in radiation radiationareasareas read, read, understand, and sign aa pledge pledge to to attest attest to his/her commitment to follow followall allradiological radiologicalrequirements requirementsand andthat that each each pledge was co- co-signed by the Shaw Shaw sitesitemanager, manager,project projectsuperintendent, superintendent,ororsite siteALARA ALARA coordinator coordinator and and were retained for for future audit during a period of at least 11 year; year;

• Shaw superintendents superintendents were present at select pre-job briefsinvolving were present at select pre-job briefs involvingHRA HRA entries; entries; and and

• Shaw participated in Exelon RP in Exelon RP Manager peer group meetings at at least least once oncepriorprior to to the the L2R1 1outage L2R11 outage andand had plans for semiannual evaluation evaluation with with the resultant commitment commitment to take necessary necessary action action on RP issues.

The inspectors inspectors reviewed reviewed the theExelon Exeloncorporate corporateauditauditofofConfirmatory ConfirmatoryOrder Orderaction action implementation to to assure assure that that Exelon Exelon conducted conductedaareview reviewof ofthe theimplementation implementation of of it's it's and and Shaw's corrective corrective actions covered in in the Order.

Order. TheTheinspectors inspectorsverified verified that that the thereview review was was conducted by conducted by knowledgeable knowledgeableindividuals individuals independent independentofofthe theLaSalle LaSallefacility.

facility.

The inspectors reviewed records of management meetings meetings and and attended attended aaLaSalle LaSalle PlantPlant Manager meetingmeeting with with contract leadership, leadership,specifically specifically first first line supervisors, supervisors, prior prior to their accessaccess to the plant and and start start of of contract contract workwork to assure assurethat thatduring during the theL2R1 L2R111 outage outage the the plant plant management clearly management clearly established establishedpersonnel personnelexpectations expectations in in following followingradiological radiologicalwork work requirements.

In summary, In summary, the barriers, interlocks, interlocks, and administrative administrative controls that have have been beeninstitutionalized institutionalized in the in the EGC Radiation Protection program and training have been been demonstrated demonstratedtotoeffectively effectively maintain proper radiation worker maintain worker practices practices at LaSalle and throughout the the EGC EGC fleet.

fleet. Therefore, Therefore, EGC has has concluded concludedthat thatthe theimpact impactofofrelaxation relaxationof ofthe theconditions conditionsof ofConfirmatory Confirmatory Order Order EA-04-EA 170 in its entirety entirety will willnot notadversely adversely impact impact the the radiological radiological work workpractices practices and and performance of of the CB&I C8&1 work force.

November 1, 2013 U. S.

U. S. Nuclear Regulatory Commission Page 7 Should you Should you have any questions questions concerning concerning this this letter, letter, please please contact contactMs.

Ms. Lisa Lisa A.

A. Simpson Simpson at at (630) 657-2815.

(630)

Respectfully, David M. Gullott David Manager - Licensing Licensing Exelon Generation Company, LLC Exelon cc: NRC Regional Administrator, Region Region III III NRC Senior Resident Inspector, LaSalle NRC LaSalle County County Station Station