IR 05000373/1997023

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-373/97-23 & 50-374/97-23 on 980323

ML20248C174
Person / Time
Site:	LaSalle
Issue date:	05/26/1998
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O COMMONWEALTH EDISON CO.
References
50-373-97-23, 50-374-97-23, NUDOCS 9806020077
Download: ML20248C174 (2)

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( 4 May 26, 1998 Mr. Oliver President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West lll 1400 Opus Place, Suite 500 Downers Grove,IL 60515 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-373/97023(DRS); 50-374/97023(DRS))

Dear Mr. Kingsley:

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This will acknowledge receipt of your letter dated May 8,1998, in response to our letter dated March 23,1998, transmitting a Notice of Violation associated with the inadequate design control of a Unit 2 floor and equipment drain sump modification at LaSalle County Station. We have reviewed your cor.setive actions and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely, original /s/ G. E. Grant Geoffrey E. Grant, Director 1 Division of Reactor Projects

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l Docket Nos.: 50-373; 50-374  !

License Nos.: NPF-11; NPF-18 Enclosure: Ltr dtd 5/8/98 from F. Dacimo, Comed to USNRC See Attached Distribution DOCUMENT NAME: G:DRS\LAS05228.TY g v. c. . ..,y or iin. oocom.ni. ino c. in es. no.: e copy .Nx . s.: . . .;.. e cony .iin .,i.cnm.nii.noo.u,. u . no cony l OFFICE Rill jlu Rlli Q7 Rlli l# Rill I NAME Duncan:sd 4, Jacobsoh W \\ Hills D# Grant ((G I i DATE 05/).l/98 05h V98 \(\ N l 05/t f/98 05/2W9O( L 1 OFFlCIAL QD COPY

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9906020077 980526 PDR ADOCK 05000373 a voR

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C 4 . 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 I. Johnson, Licensing Director DCD - Licensing F. Dacimo, Site Vice President T. O'Connor, Station Manager P. Bames, Regulatory Assurance Supervisor cc w/ encl: Richard Hubbard Nathan Schloss, Economist Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission Distribution:

Project Mgr., NRR w/ encl A. Beach w/enci J. Caldwell w/enci B. Clayton w/enci SRI LaSalle w/enci DRP w/enci TSS w/ encl DRS w/enct Rlli PRR w/enct PUBLIC IE-01 w/enci l Docket File w/enci GREENS l

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. Lgsalle Generating Station

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l . Marwillex IL 613419'57 Tel HiS-3574761 May 8,1998 United States Nuclear Regulatory Commission 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 i Report 50-373/374-97023 I 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 conceming this letter, please refer them to Harold D. Pontious, Jr., Regulatory Assurance Manager, at (815) 357-6761, extension 2383.

Respectfully,

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Fred R. Dacimo Site Vice President

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LaSalle County Station Enclosure cc: vn. B. Beach, NRC Region ill Administrator '

' M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle

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' ATTACHMENT t

RESPONSE TO NOTICE OF VIOLATION

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NRC INSPECTION REPORT 373/374-97023 VIOLATION: 373/374-97023-03

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During an NRC inspection conducted on December 22,1997, through March 6,1998, a violation of NRC requirements was identified.

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10CFR50, Appendix B, Criterion 111, " Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. These { 1 measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that j deviations from such standards are controlled.

Contrary to the above, on March 20,1997, design change package 9500087 1 to install permanent screens in the Unit 2 floor drain and equipment sumps I to prevent foreign materialintrusion 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 licensee 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.

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i REASON FOR VIOLATION:

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The violation resulted from a programmatic breakdown between the

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modification and work control processes. Specifically, the work request (WR) packages associated with Design Change Package (DCP) 9500087 j 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 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. 1 CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

The WR packages were located and electronically linked to DCP 9500087.

The DCP sta'us in EWCS was reset from canceled to active, and the DCP is being trackeJ as a " partially installed" design change. The DCP will be

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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.

I CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS:

To prevent misplacement, original design change packages will be retained by Design Engineering. Only copies of the packages will be issued to the field. This policy has been in effect since November 1997 l

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(NTS 373-100-97-02303.03).

To prevent disconnection of work requests from their associated design

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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 ACHil:iVED:

Full compliance was achieved on February 28,1998, when DCP 9500087 was reset to active status, l

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