ML20129B434

Forwards Insp Rept 50-373/96-09 & 50-374/96-09 on 960717-0820.No NOV Presently Being Issued for Apparent violations.Pre-decisional Conference to Discuss Apparent Violations Scheduled for 960927

ML20129B434
Person / Time
Site:	LaSalle
Issue date:	09/11/1996
From:	Caldwell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Subalusky W COMMONWEALTH EDISON CO.
Shared Package
ML20129B439	List: IR 05000373/1996009 ML20129B434
References
EA-96-335, NUDOCS 9609230056
Download: ML20129B434 (4)

See also: IR 05000373/1996009

Text

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september 11, 1996

EA 96-335

Mr.- W. T. Subalusky, Jr.

Site Vice President

LaSalle County Station -

Commonwealth Edison Company

2601 North 21st Road

Marseilles, IL 61341

SUBJECT: NRC INSPECTION REPORT NOS. 50-373/96009,50-374/96009

Dear Mr..Subalusky:

-

This refers to the special inspection conducted by Kerry D. Ihnen and Hershell

'A. Walker,of this office on July 17 to August 20, 1996, at your LaSalle County

Station, Units 1 & 2. The purpose of the inspection was to review the

circumstances surrounding the injection of quantities of foam sealant into the

safety-related service water tunnel and to determine whether activities

authorized by the license were conducted safely and in accordance with NRC

requirements. Areas examined during the inspection are identified in the

enclosed report. Within these areas, the inspection consisted of selective

! ~ examinations of procedures and representative records, interviews with

. -personnel, and observation of activities in progress. At the conclusion of

the inspection, the findings were discussed with those members of your staff  ;

identified in the enclosed report.

.

l

i

l Based on the results of this inspection, several apparent violations of NRC

requirements were identified and are being considered for escalated  !

enforcement action in accordance with the " General Statement of Policy and

Procedure for NRC Enforcement Actions" (Enforcement Policy), V'JREG-1600.

One of the apparent violations, ' involving failure to provide adequate control

over safety related maintenance activities, was very significant and was the

'

initiating cause of the inadvertent injection of sealant into the service ,

'

< water tunnel. The injected sealant material had the potential to cause the

loss of the ultimate heat sink for both reactor units. Other apparent

violations, involving' failures to take adequate and timely actions to correct

i the service water problems, were also very significant because effective

actions could have significantly reduced the period of risk.

.

Another apparent violation involving failure to perform a 50.59 safety

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evaluation or screening, was significant because one of the changes appeared

to include an unreviewed safety question. Finally, apparent violations were

L identified involving inadequate procedures or failure to follow procedures, I

and failure to provide adequate records of maintenance and inspection

'

activities. The specific examples were less significant, but these issues are

important as they. reflect the level of discipline ' utilized by your staff in

conducting licensed activities. The details pertaining to each apparent

. violation are described in the enclosed inspection report.

1

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2 9609230056 960911

PDR

G ADOCK 05000373

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_ _ _ . . _ ._ _. _ . _ ___ _ . _ . . _ _ . . _ _ _ - . . _ _ . . . __

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g

W. T. Subalusky -2-

No Notice of Violation is presently being issued for these inspection

findings. In addition, the nus.ber and characterization of apparent violations

described in the enclosed inspection report may change as a result of further

NRC review.

A pre-decisional enforcement conference to discuss these apparent violations

has been scheduled for September 27, 1996. The decision to hold a pre-

decisional enforcement conference does not mean that the NRC has determir,ed

that a violation has occurred or that enforcement action will be taken. This

conference is being held to obtain information to enable the NRC to make an i

enforcement decision, including a common understanding of the facts and i

circumstances surrounding the violations, their root causes, your  !

opportunities to identify the apparent violations sooner, your corrective l

actions, and the significance of the issues. i

i

In addition, this is an opportunity for you to point out any errors in our  ;

inspection report and for you to provide any information concerning your

perspectives on 1) the severity of the violations, 2) the application of the  ;

factors that the NRC considers when it determines the amount of a civil

penalty that may be assessed in accordance with Section VI.B.2 of the

Enforcement Policy, and 3) any other application of the Enforcement Policy to

this case, including the exercise of discretion in accordance with Section

VII.

l

You will be advised by separate correspondence of the results of our

deliberations on this matter. No response regarding these apparent violations i

is required at this time.

l

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

this letter and its enclosure will be placed in the NRC Public Document Room.

i

Sincerely, 1

l Original signed by John A. Grobe, Acting g g

, James L. Caldwell, Acting Director

Division of Reactor Projects

l Docket Nos.: 50-373, 50-374 .

! License Nos: NPF-11; NPF-18 ,

'

l Enclosures

l 1. Inspection Report

<

No. 50-373/96009(DRP); 374/96009(DRP) i

i 2. Enforcement Policy: Section V, " Pre-decisional

i Enforcement Conferences"

SEE ATTACHED FOR DISTRIBUTION

File R: i

m .Name:. , .< .\..lNSPRPTS/..P.O..W..ER.S/.L.AS.A/LA.S96009.

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j arrier atti atti G atti AN b, . artt ah b

- .... .diii?. a_ W be. d F

., , ,,, A. .A L .,e, I l

0FFICIAL RECORD COPY J

, . _ _ _ _ _ _ -_____________-__-__l

_ - - . . - - . - - - - -- . . - - ._ _ _ - . . _- _ - - _ . - - - -

,

4>

l '

W. T. Subalusky -2-

! No Notice of Violation is presently being issued for these inspection -

1 findings. In addition', please be advised that the number and characterization

,

of apparent violations described in the enclosed inspection report may change

'

as a result of further NRC review,

s

, A pre-decisional enforcement conference to discuss these apparent violations

has been scheduled for September 27, 1996. The decision to hold a pre-

'

decisional enforcement conference does not mean that the NRC has determined  !

that a violation has occurred or that enforcement action will be taken. This  ;

conference is being held to obtain information to enable the NRC to make an  ;

'

i enforcement decision, including a common understanding of the facts involving

j root causes, opportunities to identify the apparent violations sooner,

corrective actions, significance of the issues and the need for lasting and  ;

effective corrective action.

l

1 In addition, this is an opportunity for you to point out any errors in our

inspection report and for you to provide any information concerning your

, perspectives on 1) the severity of the violations, 2) the application of the

i factors that the NRC considers when it determines the amount of a civil ^

3

penalty that may be assessed in accordance with Section VI.B.2 of the

"

Enforcement Policy, and 3) any other application of the Enforcement Policy to *

this case, including the exercise of discretion in accordance with Section

j VII. ,

! You will be advised by separate correspondence of the results of our

f deliberations on this matter. No response regarding these apparent violations

! is required at this time.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

this letter and its enclosure will be placed in the NRC Public Document Room. ,

'

e

l

Sincerely,

'

.

'

'

James L. Caldwell, Acting Director

Division of Reactor Projects

j Docket Nos.: 50-373, 50-374

!

License Nos: NPF-11; NPF-18

Enclosures:

-

1. Inspection Report

No. 50-373/96009(DRP); 374/96003(DRP)

2. Enforcement Policy: Section V, " Pre-decisional

Enforcement Conferences"

SEE ATTACHED FOR DISTRIBUTION

File Name:, .,R:.\..INSPRPTS/..P.O..W.ER.S/.LASA/LAS96009. DRP

m, . .. .. c... .iis.c,.m...f. .

.,, m .... - l6 .m n Ic .m I I

'

.... M t- 4.'44 c.i i, u *

.m .n. .iA .i 1

OJFICIAL RECORD COPY

,

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4

W. T. Subalusky -3-

,

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cc w/ encl: D. A. Sager, Vice President,

Generation Support

H. W. Keiser, Chief Nuclear

Operating Officer

D. J. Ray, Station Manager

J. Burns, Reg'Jlatory Assurance

'

Supervisor

'

O. Farrar, Nv lear Regulatory

a Services Manager

3 Richard Hubbard

Nathan Schloss, Economist

Office of the Attorney General

State Liaison Officer

Chairman, Illinois Commerce

Commission

j Document Control Desk-Licensing

I

Distribution:

Docket File w/ encl DRP w/ encl

PUBLIC IE-01 w/ enc 1 RIII PRR w/ encl i

OC/LFDCB w/ encl W. L. Axelson, RIII w/ encl l

SRI LaSalle, Dresden, RMB/ FEES (E-Mail) w/ enc 1 l

Quad Cities w/ encl A. B. Beach, w/ encl l

Project Manager, NRR w/ encl B. L. Burgess, w/ encl 1

RACI (E-Mail)

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