IR 05000456/1988007

Discusses Insp Rept 50-456/88-07 on 880301-17 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violations Appear to Be Symptomatic of Deficiencies Identified During Last SALP Period

ML20153G231
Person / Time
Site:	Braidwood
Issue date:	05/06/1988
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Oconnor J COMMONWEALTH EDISON CO.
Shared Package
ML20153G235	List: IR 05000456/1988007 ML20153G244
References
EA-88-091, EA-88-91, NUDOCS 8805110176
Download: ML20153G231 (4)

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MAY 6 1989 )_

Docket No. 50-456 License No. NPF-72 EA 88-91

Commonwealth Edison Company ATTN: Mr. James J. O'Conno President Post Office Box 767 Chicago, Illinois 60690-0767 Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NO. 50-456/88007(DRSS))

This refers _ to the NRC inspection conducted during the period March 1-17, 1988, of activities authorized by NRC Operating License No. NPF-72, at the Braidwood Station, Unit 1. The inspection focused on problems associated with degraded control room ventilation systems and identified violations of NRC regulatory requirements. The details are presented in the subject inspection report which was sent to you by letter dated March 25, 198 An enforcement conference was held on March 28, 1988, with Mr. T. J. Maiman and other members of your staff during which the violations, the causes, and your corrective actions were discussed. The enforcement conference was documented in Meeting Report No. 50-456/88012 which was sent to you by letter dated April 4, 198 The violations represent a failure to check the adequacy of a design change, failure to adequately demonstrate system operability, and failure to modify system components in accordance with instructions or drawings. These violations resulted in a delay in identifying an initial design erro As a result of this delay, the plant operated with the Control Room Ventilation Systems in a degraded condition from May 29, 1987 until November 21, 198 Subsequent to the design error, which improperly altered the trip function of differential pressure switches, neither the independent design change review nor the pre-service testing program detected the error before the systems were put into servic In addition, the failure to adjust the setpoints of the differential pressure switches masked the ability of routine surveillance testing to identify the design error. As discussed in the inspection report, potential violations of 10 CFR 50.59 and the applicable Technical Specifications were under consideration, but after further review it was concluded that any such violations were tne direct results of the violations contained in the enclosed Notic We have considered your arguments concerning the ability of the Control Room Ventilation System to function without the proper preheating of makeup ai HoweYer, our Concerns with the violations are based not only on the degraded CERTIFIED MAIL EETURN RECEIPT REQUESTED 8805110176 880506 PDR ADOCK 05000456 O DCD

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Commonwealth Edison Company 2 MAY 6 1998 system but also, and more importantly, on the underlying design control and testing issues. These violations appear to be symptomatic of deficiencies that were identified during your last SALP period (Inspection Reports No. 50-456/88001(DRP); No. 50-457/S8001(DRP)) and which resulted in rating declines from Category 1 to Category 2 in the functional areas of Quality Programs and Administrative Controls Affecting Quality and of Preoperational and Startup Testin To emphasize the need for improving implementation of procedures for des' jn changes to safety systems, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dollars (550,000) for the violations described in the enclosed Notice. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR, Part 2 Appendix C (1988) (Enforcement Policy), the violations described in the enclosed Notice have been categorized at a Severity Level III. The escalation and mitigation factors in the Enforcement Policy were considered, and no adjustment has been deemed appropriate. Although you did make a timely report after the problem was identified, the plant operated for more than five months with the Control Room Ventilation Systems in a degraded conditio You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document tha specific actions taken and any additional actions you plan to prever.t recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96-51 d#g'i*nsh' signed ha A, Bert Duis ,r'

A. Bert Davis Regional Administrator Enclosures: Notice of Violation and Proposed Imposition of Civil Penalty 06 w w c. ~ GW % F ru G"~- Inspection Report CE OGC OE:D DEDRO No. 50-456/SS007(DRSS) JLcehman LChandler JLieberman Jiaylor Meeting Report 4M M 4 47-ss 5-5-B6 $4%

No. 50-456/88012(DRSS)

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Commonwealth Edison Company 3 WAY 6 1988 Distribution cc w/ enclosure:

Mr. Cordell Reed Senior Vice President T. J. Maiman, Vice President, PWR Operations H. Bliss, Nuclear Licensing Manager M. Wallace, Manager of Projects M. Lohmann, Project Construction and Startup Superintendent W. Yahle, Construction Superintendent R. E. Querto Station Manager i P. L. Barnes, Regulatory Assurance Su DCD/DCB (RIDS)pervisor Licensing Fee Management Branch Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron D. W. Cassel, Jr., Es Richard Hubbard J. W. McCaffrey, Chief. Public Utilities Division H. S. Taylor, Quality Assurance Division E. Chan, OGC G. Berry, OGC Stephen P. Sands, NRR The Honorable A. Dixon Callihan, ASLB The Honorable Richard F. Cole, ASLB The Honorable Ivan W. Smith, ASLB The Honorable Gary J. Edles, ASLAP The Honorable Dr. W. Reed Johnson, ASLAP The Honorable Christine N. Kohl, ASLAP

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Connonwealth Edison Company 4 gjy 6 1989 Distribution

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OGPA DCD/DCB(RIDS)  :

J. M. Taylor, DEDRO (

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J. Lieberman, OE  !

L. Chandler, OGC .

T. Murley, NRR [

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PAO:RIII SLO:RIII M. Stabulak, RIII Enforcement Coordinators, RI RII, RIV, and RV

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