ML20042G464
| ML20042G464 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/20/1990 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9005140263 | |
| Download: ML20042G464 (6) | |
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) 1400 opus Place Commonwealth Edison c
4 Donners Gr:vA lilinois 60515 4
i March 20,1990 Mr. A. Bert Davis Regional Administrator U. S. Nuclear Regulatory Commission Region lli 799 Roo;evelt Road Glen Ellyn,IL 60137
Subject:
Braidwood Station Units 1 and 2 Response to inspection Reports Nos.
50-456/90-002 and 50-457/90 002 NBCLD_ochatBos. 50-456 and 50-457
Reference:
(a)
G. C. Wright letter to C. Reed dated February 16,1990
Dear Mr. Davis:
Reference (a provided the results of the inspection conducted by P. R. Rescheske and V). P. Lougheed from January 16, through January 31,1990 of activities at Braidwood Station. Reference (a) indicated that certain activities appeared to be in violation of NRC requirements. The Commonwealth Edison Company response to the Notice of Violation is provided in the Enclosure.
An extension for submittal of this response on March 20,1990 was granted by Mr. G. Wright on March 19,1990.
if you have any questions regarding this response please direct them to this cifice, f
a T. J.
ach Nuclear Licensing Manager Enclosure cc: NRC Resident inspector - Braldwood NRC Document Control Desk WhII
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t ENCLOSURE COMMONWEALTH EDISON COMPANY'S RESPONSE TO INSPECTION REPORT NUMBERS 456/90002 and 457/90002 VIOLATION: (456/90002-01; 457/90002-01) 10 CFR 50, Appendix B, Criterion III, requires in part, that design changes be subject to design control measures commensurate with those applied to the original design.
These design control measures shall provide for verifying the adequacy of the design.
Further, measures shall be established for the selection and review for suitability of application of materials and parts.
t Contrary to the above, Temporary Alteration 88-1-019, which installed a diode across a pressurizer PORV solenoid in February 1988, was not subject to design control measures commensurate with those applied to the original-design.
The licensee failed to perform a design analysis and seismic evaluation, and failed to determine that the diode was suitable for this safety-related application.
RESPONSE
Commonwealth Edison (Edison) agrees with the violation which deals with two related but separate issues.
The first issue being the review performed for Temporary Alteration 88-1-019 and the second issue being a programmatic inadequacy in the temporary alteration program.
As required by Station Procedure BwAP 330-2, " Temporary Alterations," a review by the station technical staff is performed for all safety related temporary alterations.
In addition, an onsite review is performed to evaluate the adequacy of this review and determine any additional requirements appropriate for the application. Copies of all safety related temporary alterations are sent to the Corporate Engineering Department (Engineering) upon installation.
Per Engineering Procedure, NSED/PSD Q.60, entitled " Engineering Review of Safety Related Station Temporary Alterations," Engineering is required to perform a design review within thirty (30) days of receipt of the temporary alteration document.
Because of this timely review, any significant deficiencies can be readily identified and corrected.
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In the case of Temporary Alteration 88-1-019, a review by a Braidwood Station System Test Engineer and a station Onsite Review had been l
performed to determine the acceptability of the diode for installation.
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These reviews identified appropriate failure modes and specified critical characteristics (i.e., mil spec, voltage rating and diode type) to ensure the diode's suitability for the application.
Additionally, Engineering performed a followup review in accordance with the program requirement to do this within 30 days.
However, the Station review did not include a detailed seismic evaluation as to the effect of the diode on the seismi.
qualification of the main control panels, The Engineeering review did consider seismic effects but this was not specifically documented.
Because of the negligible effect of the diode mass on the mass of the panels, this lack of a documented seismic review or a formal calculation
'e does not result in a significant safety issue.
NSED/PSD Q.60 Revision 1, dated May 5, 1989, contains a checklist that provides the means to document the results of these seismic evaluations.
However, Temporary Alteration 88-1-019 was issued before this checklist was available and as a result it did not have the proper documentation currently required.
To correct this a documented seismic review will be completed using this checklist for Temporary Alteration 88-1-019.
As a result of the reviews discussed above and the negligible effect on the seismic qualification of the main control panels, the installed condition of Temporary Alteration 88-1-019 is considered to be acceptable.
However, Temporary Alteration 88-1-019 is planned to be superseded by Minor Modification 20-1-89-001.
Additionally, Braidwood Station has reviewed NRC Information Notice 89-81,
" Inadequate Control of Temporary Modifications to Safety-Related Systems." Edison considers that the concerns expressed in the Information Notice to have been adequately addressed by Braidwood Station Procedure BwAP 330-2, " Temporary Alterations."
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
4 The corrective action taken with respect to Temporary Alteration 88-1-019 was to request Engineering to re-perform the evaluation of the temporary alteration to determine the effect of the diode installation on the seismic qualification of the main control panels and to verify the acceptability of the diode for this application. Additionally, existing safety related temporary alterations will be reviewed to determine which temporary alterations include the installation of parts or material. These will be forwarded to Engineering for review to determine whether an additional seismic evaluation is necessary.
These will also be forwarded to the Station parts dedication group to verify the suitability of the parts and material for the specific application, based on the existing design characteristics. u r -
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e The immediate corrective action taken with respect to the Temporary Alteration Program was to stop approving safety related temporary alterations until the mechanism was verified to be in place to ensure the 1
appropriate review is performed and a determination of suitability of parts and material has been completed prior to installation of safety related temporary alterations, i
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION:
Braidwood Station Administrative Procedure, BwAP 330-2 " Temporary Alterations" will be revised to ensure the appropriate review is performed and a determination of the suitability of parts and material has been completed prior to installation of safety related temporary alterations.
Additonally BwAP 330-2T1, " Temporary Alteration form" will be revised to include a statement to determine the effect of the temporary alteration on the seismic capability of a seismic Class I component.
DATE Of FULL COMPLIANCE:
Braidwood Station Administrative Procedure, BwAP 330-2 " Temporary Alterations" is expected to be revised by June 1, 1990.
Engineering reviews of Temporary Alteration 88-1-019 are expected to be completed by May 1, 1990.
Review of the other temporary alterations is expected to be i
completed by June 1, 1990.
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VIOLATION: (456/90002-02)
Technical Specification (TS) Section 3.6.1.1 requires that primary containment integrity be maintained whenever the reactor is in Modes 4 through 1.
TS 4.6.1.1.a requires, in part, verification of containment integrity every 31 days by ensuring that containment isolation devices, including blind flanges, are secured in the closed position. Contrary to the above, blind flanges on penetration P-63, P-64, and P-74, which were added during the refuel outage, were not verified to be intact within the required surveillance interval.
These flanges were verified intact during performance of the Type B local leak rate test on November 24, 1989.
To-be within the 31 day period (plus twenty-five percent allowable extension) a surveillance was required to have been performed by December 30, 1989.
However, the next verification did not occur until January 19, 1990.
RESPONSE
Commonwealth Edison Company acknowledges that the blind flanges on containment penetrations, P-63, P-64, and P-74, which were added during the Braidwood Station Unit I refuel outage, were not verified to be intact within the required surveillance interval.
The flanges were verified in place during performance of the local leak rate tests on November 22, 1989 prior to the modification being declared operable and again on January 19, 1990.
This event had no effect on the safety of the plant or the public.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
An NRC Inspection Team performing a review of Braidwood Station modification packages recommended to the System Technical Engineer (STE) that the applicable procedures should be reviewed to ensure that the blind flanges on containment penetrations, P-63, P-64, and P-74 had been added.
The STE identified that the flanges had not been added to 1Bw0S 6.1.1.a-1,
" Unit One Primary Containment Integrity Verification of Outside Containment Isolation Devices" and immediately initiated a Temporary Procedure Change to add the flanges to the procedure.
Through discussions with the Station Regulatory Assurance Department it was determined that a Technical Specification surveillance requirement had not been met.
A Deviation Report was initiated and the Station Control Room Engineer was notified. A Limiting Condition for Operation was entered. A partial performance of IBw0S 6.1.1.a-1 with the Temporary Procedure Change was performed. Containment integrity was vertfled and the Limiting Condition for Operation was exited.
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_ y-1 CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATION:
At the time of this event a contributing factor was the use of BwAP 1610-Tl revision 0, " Station Checklist", which placed the responsibility 4
of identifying.all affected procedures with the STE Revision I to BwAP 1610-T1, which requires the STE to contact and document the department providing_information concerning the_ procedures affected by the i
modification, had been approved and was being inserted into existing modificattor, packages.
Although the STE had contacted the appropriate departments, the documentation supporting this was lost.
l Insertion'of the Revision I forms has now been completed.
This will 1
ensure individual department representatives knowledgeable of that department's procedures will be able to determine the impact of modifications upon their department's procedures.
Additionally, the
-l' station Modificdion-Procedure, BwAP 1610, will be further revised to include a new checklist.
This checklist.will include a description of the modification and will be forwarded to the appropriate departments for review..These reviews will be performed by a person knowledgeable of that department's procedures. The reviews will be returned to the STE, compiled and included in the modification package.
A tailgate trair.ing session has been held for STEs to discuss this event and the corrective actions taken.
Additional tailgate training sessions will be held with appropriate department personnel to discuss the-importance of providing adequate information regarding procedures affected by modifications.
DATE.0F' FULL COMPLIANCE:
The blind flanges on penetrations P-63, P-64 and P-74 have been verified 1
to be intact by completion of the necessary surveillance.
Revision of 4
Modification Procedure BwAP 1610,.is expected to be completed by Jbae 1, 990.
The tailgate training sessions are expected to be completed by 1
June 1, 1990.
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