IR 05000456/1997021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-456/97-21 & 50-457/97-21 Issued on 980211.Corrective Actions Will Be Examined During Future Inspections

ML20217J421
Person / Time
Site:	Braidwood
Issue date:	04/03/1998
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O COMMONWEALTH EDISON CO.
References
50-456-97-21, 50-457-97-21, NUDOCS 9804060296
Download: ML20217J421 (2)

Text

1. April 3, 1998 CD[Dc8 Mr. Oliver President, Nuclear Generation Group Cornmonwealth Edison Company ATTN: Regulatory Services Executive Towers West lil 1400 Opus Place, Suite 500 Downers Grove, IL 60515 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-456/97021(DRS); 50-457/97021(DRS))

Dear Mr. Kingsley:

This will acknowledge receipt of your letter dated March 11,1998, in response to our letter dated February 11,1998, transmitting a Notice of Violation associated with the above

mentioned inspection report at the Braidwood Generating Station. We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely,

l original /s/ M. Leach for John A. Grobe, Director Division of Reactor Safety Docket No. 50-456;50-457 Enclosure: Ltr dtd 3/11/98 from T. Tulon, Comed to USNRC l

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DATE 04//]]98 04/1498 ( Y " 04/3/98 -) 04/5/98 OFFICIAlbtECORD COPY 9904060296 900403 ADOCK 05000456 PDR G PDR

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. q cc w/o encl: M. Wallace, Senior Vice President D. Helwig, Senior Vice President G. Stanley, PWR Vice President J. Perry, BWR Vice President b. Farrar, Regulatory Services Manager 1. Johnson, Licensing Director DCD - Licensing T. Tulon, Site Vice President BraidwM Station Manager T. Simpkin, Regulatory Assurance Supervisor cc w/ encl: Richard Hubbard Nathan Schloss, Economist Office of the Attomey General State Liaison Officer Chairman, Illinois Commerce Commission Distribution:

Docket File w/ encl- DRP w/enci PUBLIC IE-01 w/enci TSS w/ encl A. Beach w/ enc! DRS (2) w/enci Deputy RA w/enci Rlli PRR w/enci Rill Enf. Coord. w/ encl RAC1 (E-Mail)

SRI Braidwood w/ encl IEO (E-Mail)

Project Mgr., NRR w/enci DOCDESK (E-Mail)

GREENS

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.-. firaidwood Gencratmg Statuan

• Houte si, flux H e I liraceville. IL 60407%I9 Tel H l 5-s 58-2801 l March 11,1998 Document Control Desk US Nuclear Regulatory Commission Washington, D.'C. 20555

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Subject: Reply to Notice of Violation NRC Inspection Report 50-456(457)/97021 Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-457 Reference: J. A. Grobe letter to O. dated February 11,1998, transmitting Notice of Violation from Inspection Report 50-456(457)/97021 Results from a NRC special inspection performed to review details from a Unit Two feedwater system hydraulic transient, which occurred at Braidwood Station on November 10, 1997, are documented in the Inspection Report referenced above. Three Severity Level IV violations were included in the inspection report. Comed's response to the violations is documented in the attachment to this letter.

Braidwood Station appreciates the comments made in the report concerning the response to the event. including the initiation of appropriate actions for affected systems and components as well as the investigation and assessment of the event. While we work hard to prevent challenges to the plant, we recognize that if an event does occur. it is important to promptly identify the event circumstances so an appropriate resolution can be implemented.

The following commitments were made in the attachment to this letter:

e Operations will review this event with respect to the unit designator convention rules that hase existed and also review the current practice of using unit designators on unit speci6c components.

• Operations uill review the Electronic Work Control System (EWCS) dattbase for single unit specific components in an attempt to identify unit differences. Based on the results. operating procedures will be enhanced to delineate these unit specific valves.

• Three sy stems will be selected and rei imed for their vulnerability to water hammer es ents.

Consideration will be system perforr anu. with respect to existing high point vents along with appropriate fill and s ent procedures si n,unni omp.nn y-]Q { f)' fp S

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March 11,1998

• Forrnal training will be provided to Operations persennel as part of operator requalification trr.ining to discuss details associated with this event. including the root causes and corrective

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actions.

• * A review of the guidance associated with PIF initiation and addressing operability issues as specified in NSWP A 15 and BwAP 33010 will be done to ensure requirements are clear. The procedures will be revised as necessary, If your staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801, extension 2980.

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dnothy J. Tulon Site Vice President Braidwood Nuclear Generating Station Attachment cci A.B. Beach, NRC Regional Administrator. Region 111 S. Bailey, Project Manager, NRR C.J. Phillips, Senior Resident Inspector F. Niziolek. Division of Engineering. Office of Nuclear Safety, IDNS u C nrcs98019tjt. doc i

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REPLY TO NOTICE OF VIOLATION-(50-456:457/97021-Oi)

1. 10 CFR 50, Appendix B, Criterion V requires in part that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances.

Contrary to the above, as of November 10.1997, the procedure which was used to fill and vent the 2D feedwater system, an activity affecting quality, as prescribed by BwOP FW-3," Fill and Vent of the Feedwater System,l' Revision 6, was inappropriate for the circumstances. Sections of feedwater piping between the

Feedwater Shutoff Valve (2FW006D) and the Feedwater Isolation Valve (2FWOO9D) were not adequately vented, and as a result, safety-related components were damaged by the feedwater system waterhammer event that occurred on November 10,1997.

REASON FOR THE VIOLATION Main feedwater system operating procedure BwOP FW-3," Filling and Venting the Feedwater System," did not provide adequate instructions to the operators to properly fill, vent, or compress and flush the air pocket in the main feedwater line. Steps F. 8 h, i,j, and k in the procedure refer to opening and closing the manual high point vent valves

"_FWO92 A through D and _FW102 A through D". These high point vents are included in the plant design for Unit 1, however not for Unit 2. The differences in plant design were not appropriately considered during the procedure review. As a result, the procedure did not provide adequate instructions for Unit 2.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED BwOP FW-3 was revised to provide proper direction for equalizing pressure across the 2FWO39A-D valves and additionally gives specific direction for filling and venting the Unit 2 feedwater piping. The station start-up procedure (BwGP 100-2) has also been rev sed to ensure minimal differential pressure across the preheater bypass valves NWO39A-D) prior to stroking the valves. This piucedure now directs the operator to

. the resised operating procedure (BwOP FW-3)if the differential pressure is excessive.

ACTIONS TAKEN (TO BE TAKEN) TO PREVENT RECURRENCE Operations personnel were tailgated on the feedwater hammer event. The procedure inadequacies were discussed during the tailgate sessions.

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,[ ATTACliMENT 1 REPLY TO NOTICE OF VIOLATION (50-456:457/97021.-Qjj

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Operations will review this event with respect to the unit designator convention rules that

. have existed and also review the current practice of using unit designators on unit specific components.

Operations will review the Electronic Work Control System (EWCS) database for single unit specific components in an attempt to identify unit differences. Based on the results.

operating procedures will be enhanced to delineate these unit specific valves.

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Three systems will be selected and reviewed for their vulnerability to water hammer events. Consideration will be system performance with respect to existing high point vents along with appropriate fill and vent procedures.

Formal training will be provided to Operations personnel as part of operator requalification training to discuss details associated with this event, including the root causes and corrective actions.

DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on November 11,1997, when BwOP FW-3 was revised to eliminate the noted deficiencies.

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ATTACHMENT I

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REPLY TO NOTICE OF VIOLATION (50-456:457/97021-02)

2. 10 CFR 50, Appendix B, Criterion V requires in part that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures.

a. Braidwood Procedure, BwAP 100-20," Procedure Use and Adherence,"

Revision 7El, paragraph D.9 required, in part, that when an individual perceives that any procedure carmot be performed as written, the individual's supervisor is required to initiate a permanent or temporary

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change, or use Braidwood Procedure, BwAP 100-20T1 to document any deviations from a procedure.

Contrary to the above, on November 10,1997, when the Procedure 2BwGP 100-2," Plant Startup," Revision 9, could not be performed as written, the licensee failed to follow BwAP 100-20 to issue a procedure revision or change. Specifically, step F.14.h of this procedure caused valves 2FWO35A-D to close and instructions had not been provided to reopen these valves. The operators took manual actions, not described in the procedure nor documented in an approved procedure change process, to open these valves and restore feedwater flow.

REASON FOR THE VIOLATION 1/2 BwGP 100-2," Plant Startup," did not provide adequate guidance on restoring the feedwater isolation valves to the desired lineup following Reactor Trip Breaker testing because this action had been considered a " skill of the craft" function. As a result of workers considering this function to be " skill of the craft," no procedure deviation form was initiated.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED 1/2 BwGP 100-2 was reviewed and revised to provide specific guidance on feedwater isolation .ntvd:) realignment following reset of the feedwater isolatmo sgnal. This procedure was also reviewed to determine if human factor improvements could be made.

Appropriate revisions will be made prior to the next scheduled refueling outage.

Following a Unit Two trip which occurred on January 26,1998, the revised procedure was successfully executed during the unit startup.

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ATTACllMENT I REPLY TO NOTICE OF VIOLATION (50-456:457/97021 02)

ACTIONS TAKEN (TO BE TAKEN) TO PREVENT RECURRENCE Operations personnel were tailgated on this procedure inadequacy and the importance of submitting a procedure change request if a procedure enhancement is necessary.

A review of BwGP procedures was conducted to determine if other procedure steps needed additional detail provided. Procedure revision requests were submitted based on this review.

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DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on January 30,1998, when the revision to 1/2 BwGP 100-2, step F.14.i was completed.

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Violation 50-456:457/97021-01 2. 10 CFR 50, Appendix B, Criterion V requires in part that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures.

b. Braidwood Procedure BwAP 330-10," Operability Determinations," Revision 3El, paragraph F.5, required "Any on-site personnel knowledgeable of a possible OPERABILITY ISSUE, identified to them by any source. MUST promptly notify the Shift Manager (SM), or designee and write a PIF" Also, the Commonwealth Edison Procedure, NSWP-A-15," Comed Nuclear Division Integrated Reporting Program," Revision 1, paragraph 6.1.1 required "All station individuals or contractors should initiate an Exhibit A (Problem Identification Form (PIF)), when a problem i:, =ugnized."

Contrary to the above:

(1) On November 10,1997, the licensee had failed to follow NSWP-A-15 and BwAP 330-10 requirements to issue a PIF for the tempering line snubber considered inoperable. Specifically, the 2D feedwater tempering line snubber had been determined to be inoperable (based on station operator log entries) and a PIF had not been issued to document the inoperable status of this equipment.

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ATTACHMENT 1

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REPLY TO NOTICE OF VIOLATION (50-456:457/97021-03)

(2) On November 10,1997, the licensee failed to follow NSWP-A-15 and BwAP 330-10 requirements to issue a PIF when a problem was recognized / identified on steam generator 2D main feedwater line snubbers (2FWO5011S,2FWO5013S, & 2FWO5022S).

Specifically, problems with these snubbers had been recognized /

identified in action requests (970084651,970084666,970084667) .

on November 10,1997, and corrected prior to documenting the problem in PIF A1997-5074," Snubbers 2FWO501IS,

2FW05013S, & 2FWO5022S Suspect," on November 13,1997.

REASON FOR THE VIOLATION in both examples specified in the violation, where operator log entries were made to document Limiting Conditkia for Operating Action Requirements (LCOAR) 7.8-la entries resulting from damaged supports and three " suspect snubbers" were repaired and tested using the Action Request program, Problem Identification Forms (PIFs) were not promptly initiated as required by station procedures. Following initial walkdowns of the affected areas, PIFs were planned to be generated by one of the walkdown participants.

The Investigation Team Leader believed that initiating additional PIFs was unnecessary because it was the team's belief that the identified concerns would be addressed by the initial PlF generated for the water hammer event.

On November 10,1997, when a severely damaged support was discovered during the walkdown, Operations was notified as required. This notification resulted in entry into LCOAR 7.8-la. The Unit Supervisor expected the engineer who made the notification and was most knowledgeable of the damage done to the support to initiate a PIF. Since it had been determined that additional PIFs were unnecessary because an initial PIF had been written documenting damage to the feedwater line and the line had been declared inoperable, subsequent PIFs were not initiated.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED PIF t/A1997-05074 was generated to document the concerns associated with snubbers 2FWO501IS. 2FWO5013S and 2FWO5022S. It was concluded that all LCOAR requirements were satisfied and the three suspect snubbers were functionally tested or stroked as required and successadly met established acceptance criteria. No evidence of degradation was ider.tifiel for these snubbers.

BwAP 330-10. " Operability Determinations," Attachment B, which was not initially

. requested because LCOAR 7.8-la had been entered following the initial containment entry, was later completed for the six inch tempering line and determined that the line

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[ ATTACHMENT I REPLY TO NOTICE OF VIOLATION ($nd%44"F97021-Oil was operable. In addition, a BwAP 330-10, Attachment C was also completed which showed that the tempering line and penetration 2PC-99 were operable.

' ACTIONS TAKEN (TO BE TAKEN) TO PREVENT RECURRENCE The Investigation Team Leader and engineer who participated in the walkdowns of the affected areas were counseled on the event and the inappropriate action of not generating

Problem Identification Forms for the identified structural concems.

- A review of the guidance associated with PIF initiatior and addressing operability issues

' as specified in NSWP-A-15 and BwAP 330-10 will be done to ensure requirements are clear. The procedures will be revised as necessary.

DATE WHEN FULL COMPLIANCE WAS ACHIEVED

- Full compliance was achieved when the individuals who failed to initiate Problem Identification Forms for identified concerns were appropriately counseled.

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