IR 05000456/1996016
| ML20198K385 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/02/1997 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Tulon T COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20198K390 | List: |
| References | |
| 50-456-96-16, 50-457-96-16, EA-97-110, NUDOCS 9710240008 | |
| Download: ML20198K385 (4) | |
Text
October 2, 1997
SUBJECT:
l 50-456/457 96016)
Dear Mr. Tulon:
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This refers to the inspection at Braidwood Station completed August 14,1997. This inspection reviewed the fire protection program and several Licensee Event Reports (LQ)
that documented post fire safe sieutdown deficiencies. The initial report of this inspection was sent to you by letter dated March 31,1997. A pre-decisional enforcement conference was held en May 14,1997. The NRC staff concluded that they required additional information to substantiate the technical positions you presented at the conference before they could reach an enforcement decision. Your staff provided this information by letter dated June 27,1997. The NRC technical staff completed its review of this information on August 14,199/.
The NRC determined that two violations of NRC requirements occurred. This determination was based on the information developed during the inspection; the information that your staff provided during the pre-decisional enforcement conference; LER 50-456/95013-01 and LER 50-456/96011; and your June 27,1997, letter responding to questions proposed at the predecisional enforcement conference. The two violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding each violation are described in detail in the inspection report.
The first violation was identified by your staff and involved five examples of the failure to provide adequate fire protection for safe shutdown equipment. These examples existed since initial plant operations and were resolved in 1996 when your staff performed additional fire protection modifications. This violation was caused by an inadequate post fire analysis for protection of safe shutdown capability. The NRC considered this violation to be safety cignificant because some of the equipment required to achieve and maintain safe shutdown may be rendered inoperable by a fire, u\\
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Therefore, this violation has been categorized according to the " General Statement of Policy and Procedure for NRC Enforcement Actions,"(Enforcement Policy) NUREG 1600 as a Severity Level 111 violation.
in accordance with the F' forcement Policy, a base civil penalty in the amount of $50,000 was considered for Se.arity Levei lll violations occurring before November 12,1996.
Since most of the noncompliance period occurred before November 12,1996, a base civil penalty of $50,000 was considered for this case. Because your facility has been the subject of escalated enforcement actions within the last two years', the NRC considered
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whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. You were given credit for Identification of this violation and for initiating prompt and effective Corrective Action. The Corrective Actions discussed at the conference included circuit modifications and cable re-routing to ensure the availability of safe shutdown equipment.
Additionally, your staff developed the Appendix R Enhancement Plan to review current safe shutdown analysis and identified no further deficiencies.
Therefore, to encourage continued identification and prompt and comprehensive correction of violations, I have been authorized not to propose a civil penalty in this case.
The secor d violation involved inadequate testing of roll-up fire doors where ventilation system configuration changes that affected door function were not considered in the test procedure and acceptame criteria. This violation is a concern because plant personnel (including superv! sors) from several plant organizations failed to recognize t the test deficiencies and fundion of the roll-up fire doors. This violation was classified in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600 as a Severity Level IV Violation.
The NRC has concluded that information regarding the reason for the two violations, the corrective actions (taken and planned) to correct and prevent recurrence of the violations, and the date when full compliance will be achloved is already adequately addressed on the docket in Inspection Report 50-456/457-96016, LER 50-456/95013-01, and LER 50-456/96011-00. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your positions. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
EA 96 070 issued a Severity Level 111 violation and a $100,000.00 civil penalty on May 16,1996, for configuration control problems that were identified during a January through March 1996, inspection.
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. In accordance with 10 CFR 2.790 of the NRC's " Rules or Practice,' a copy of this letter, its enclosure, and your response (if you elected to provide a response) will be placed in the NRC Public Document Room (PDR).
Sincerely, A. Bill Beach Regional Administrator Docket Numbers 50 456;50457 Licens6 Numbers NPF 72; NPF-77 Enclosure: Notice of Violation cc w/ encl:-
R. J. Manning, Executive Vice President, Generation M.Wallace SeniorVice President, Corporate Services H. G. Stanley, Vice President PWR Operations Liaison Officer, NOC BOD D. A. Sager, Vice President, Generation Support D. Farrar, Nuclear Regulatory Services Manager 1. Johnson, Licensing Operations Manager Document Control Desk Licensing Braidwood Station Manager T. Simpkin, Regulatory Assurance Supervisor Richard Hubbard Nathan Schloss, Economist Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission
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. - DISTRIBUTION-PUBLIC IE 01 SECY CA LCallen, EDO AThadani, DEDE LChandler, OGC L JGoldberg, OGC SCollins, NRR RZimmerman, NRR Enforcement Coordinators Rl, Ril and RIV Resident inspector, Braidwood RCapra, NRR GDick, NRR JGilliland, OPA HBell, OlG GCaputo, Ol TMartin, AEOD -
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