IR 05000456/1997007
| ML20216H838 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/13/1998 |
| From: | Caldwell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kingsley O COMMONWEALTH EDISON CO. |
| References | |
| 50-456-97-07, 50-456-97-7, 50-457-97-07, 50-457-97-7, EA-98-002, EA-98-2, NUDOCS 9804210245 | |
| Download: ML20216H838 (4) | |
Text
April 13, 1998
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-456/97007(DRP);
NO. 50-457/97007(DRP))
Dear Mr. Kingsley:
This will acknowledge receipt of your letter dated July 16,1997, in response to our letter dated June 17,1997, transmitting a Notice of Violation associated with Inspection Report No. 50-456/97007(DRP); 50-457/97007(DRP) for the Braidwood Station. In your letter, you stated that you do not agree with Violation No. 50-456/97007-01(DRP); 50-457/97007-01(DRP).
Your position was that taking the Feedwater Pump Discharge Valve 2FWOO2A out-of-service in the open position to perform maintenance on the valve operator did not require a written safety evaluation per 10 CFR 50.59. You concluded that this activit was a maintenance activity and
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not a change to the facility as described in the safety analysis report. Your staff acknowledged that although the valve was classified as a non-safety-related component, it received an automatic closure signal during a feedwater isolation. Your staff also acknowledged that the automatic closure function of the valve was described in the Updated Final Safety Analysis Report (UFSAR).
On December 16,1997, we conducted a re-inspection of the circumstances surrounding the removal of the feedwater pump discharge valve from service. Our inspector reviewed the design basis for the discharge valve and its isolation (closure) signal, the Accident Analysis, and the UFSAR. During this review, the inspector determined that the purpose of the closure signal for valve 2FW002A (to provide backup to the feedwater isolation function) was accurately described in the UFSAR and reflected in the design control drawing (electrical print E-4030). The j
inspector also determined that the Accident Analysis did not take credit for discharge valve closure as a means of mitigating any accident. Section 15.1.4.1(c) of the UFSAR clearly defined the automatic isolation function as a " redundant isolation of the main feedwater lines."
Therefore, the UFSAR had previously taken into account having the feedwater pump dischage valve out-of-service because the isolation function could still be accornplished if this valve was not available.
l After careful review of your response, re-inspection of the circumstances associated with the
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issue, and consultation with NRR, we are in agreemer,t with your position that removal of the
{Q feedwater pump discharge valve from service for corrective roaintenance was not a change to U
the facility as described in the safety analysis report and thue did not require a safety evaluation
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in accordance with 10 CFR 50.59; therefore, no violatior.>ccune'
9804210245 980413 PDR ADOCK 05000456 O
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. We would point out, however, that 10 CFR 50.59 does not exempt the maintenance process from safety evaluations. Your position, as stated in your response letter, that you "will follow the existing industry and NRC guidance to perform 50.59s for OOSs (out-of-services) for components not covered by Technical Specifications but 'taken credit for in Accident Analysis' and relied upon in the NRC SERs" does not fully conform to the regulation. The regulation is not limited to components taken credit for in the Accident Analysis. The regulation addresses changes to the facility and procedures as described in the safety analysis report. The evaluation to determine if j
an unreviewed safety quertion exists is required for changes to systems, structures, and components that are described in the safety analysis report.
Additionally. even though we have determined that your actions with respect to this issue did not constitute a regulatory violation, the implementation of your maintenance process, in this specific case, was weak. Your staff defeated the automatic valve closure function before they were prepared to actually conduct the planned maintenance activity. The valve remained in this degraded condition, with the automatic function defeated, for five days before postponing the maintenance activity to another time. These actions were not commensurate with the importance of the automatic closure function of the valve as detailed in the UFSAR.
With respect to the other violations addressed in your response, we have reviewed your corrective actions and have.no further questions at this time. These corrective actions will be examined during future inspections.
Sincerely,
/s/ James L. Caldwell James L. Caldwell Deputy Regional Administrator Docket Nos.: 50-456;50-457
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See Attached Distribution DOCUMENT NAME: G:\\bni\\ bra 97007.ty SEE PREVIOUS CONCURRENCES To receive a copy of this document. Indicate in the box: "C" = Copy without attachment / enclosure "E" = copy with attachment / enclosure
"N" = No copy OFFICE Rill l
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NAME DuPont:sn Lanksbury Clayton gd Grant Lieberman G$f/w}!!
DATE 04/ /98 04/ /98 04/10/98 04/ /98 02/ /98 643/90 CoFFICIAL RECORD COPY
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O. Kirgsley-2-We would point out, however, that 10 CFR 50.59 does not exempt the maintenance process from safety evaluations. Your position, as stated in your response letter, that you will follow the existing industry and NRC guidance to perform 50.59s for OOSs [out-of-services) for components not covered by Technical Specifications but 'taken credit for in Accident Analysis' and relied upon
- in the NRC.SERs" does not fully conform to the regulation. The regulation is not limited to components taken credit for in the Accident Analysis. The regulation addresses changes to the facility and procedures as described in the safety analysis report. The evaluation to determine if an unreviewed safety question exists is required for changes to systems, structures, and components that are described in the safety analysis report.
Additionally, even though we have determined that your actions with respect to this issue did not constitute a regulatory violation, your maintenance process, in this specific case, was not adequate. Your staff defeated the automatic valve closure function before they were prepared to actually conduct the planned maintenance activity. The valve remained in this degraded condition, with the automatic function defeated, for five days before postponing the maintenance activity to another time. These actions were not commensurate with the importance of the automatic closure function of the valve as detailed in the UFSAR.
' With respect to the other violations addressed in your response, we have reviewed your
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l-corrective ections and have no further questions at this time. These corrective actions will be L
examined during future inspections.
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Sincerely, l
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/s/ James L. Caldwell
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James L. Caldwell Deputy Regional Administrator l'
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Docket Nos.; 50-456; 50-457 See Attached Distribution
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DOCUMENT NAME: G:\\brai\\ bra 97007.ty To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure
"N" = No copy OFFICE Rlll u ! l (L Rlli lC Rlil l
Rlli l-OE,m n
Rill NAME DePin{: Imo Lanksburi4 Clayton GranklWPD&4.ieb'erm'a P Caldwell j
DALE 04/998 04/9/98 04/ /98 04/f/!i8 08/9/98 f 04/ /98 OFFICIAL RECORD COPY b
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. s.Lo cc:
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 T. Tulon, Site Vice President-Braidwood Station Manager T. Simpkin, Regulatory Assurance Supervisor Richard Hubbard Nathan Schloss, Economist Office of the Attomey General State Liaison Officer Chairman, Illinois Commerce.
Commission L
Distribution:
J. Lieberman, OE J. Goldberg, OGC B. Boger, NRR SAR (E-Mail)
Project Mgr., NRR A Beach J. Caldwell B. Clayton SRI Braidwood DRP
TSS i
DRS (2)
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RlliPRR PUBLIC IE-01 Docket File GREENS I
IEO (E-Mail)
h DOCDESK (E-Mail)
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