ML20045C339

Responds to NRC 930521 Ltr Re Violations Noted in Insp Rept 50-457/93-06 & Proposed Imposition of Civil Penalty.C/As: Licensee Has Reviewed Associated Paperwork & Determined That 1RC8070 Valve Properly Left in Open Position.Fee Paid

ML20045C339
Person / Time
Site:	Braidwood
Issue date:	06/17/1993
From:	Farrar D COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9306220385
Download: ML20045C339 (5)

Text

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[ ~., Ccmmonwsalth Edison n, 1400 Opus Place Downers Grove, lilinois 60515 .

June 17, 1993 Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washing;on, DC 20555 Attn: Document Control Desk

Subject:

Braidwood Nuclear Power Station Unit 2 Response to Notice of Violation Inspection Report Nos. 50-457/93006 NRC Docket Numbers 50-457 i

Reference:

A. Bert Davis letter to L. O. DelGeorge dated May 21, 1993, transmitting Notice of Violation and Proposed Civil Penalty - $50,000 50-457/93006 Enclosed is Commonwealth Edison Company's (CECO) response to the Notice of Violation (NOV) which was transmitted with the referenced letter and Inspection Report. The.NOV cited a Severity Level III violation, ' requiring a written response, and a ,

$50,000 civil penalty.. CECO's' response and payment of the' civil penalty are provided in the attachment.

If your staff has any questions or comments concerning this letter, please refer them to Denise Saccomando, Compliance Engineer at (708) 663-7285.

Sincerely, D.L. Farrar ,

Nuclear Regulatory Services Manager Attachment cc: J. Martin, NRC Regional Administrator - RIII Ramin Assa, Project Manager - NRR S. Du Pont, Senior Resident Inspector g l b'. l)[ ,

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ATTACEMENT RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-457/93006 VIOLATION (457/93006):

Technical Specification 3.4.11 requires, in part, that at least one reactor vessel head vent path be operable during reactor operations in modes 1-4. With one reactor vessel head vent path inoperable, startup and/or power operation in modes 1-4 may continue provided, in part, that the inoperable vent path is restored to operable status within 30 days. Otherwise, the plant must be in hot standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Contrary to the above, from November 17, 1991, to March 6, 1993, a period in excess of 30 days, Unit 2 was operated in modes 1-4 and both reactor vessel head vent paths were inoperable, and the unit was not brought to hot standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and place'd in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. i REASON FOR THE VIOLATION:

Braidwood acknowledges that Technical Specification 3.4.11 was violated by having the 2RC8070 reactor head vent valve locked ,

closed from November 17, 1991, to March 6, 1993. CECO believes the safety consequences of the event were minimal. The reactor head vent valves are not modeled in any current accident analysis. Also, Probabilistic Risk Assessment shows that the frequency of events in which these valves would be needed is very low. However, Braidwood views the event as serious and has taken aggressive corrective actions.

On March 11, 1993, Operations was draining the Reactor Coolant System (RCS)in preparation for removal of the reactor head.

Concurrently, the incore thermocouple conoseals were being disconnected. While the Reactor Operator was stabilizing the level, he noticed the level indication w6s increasing. A Field Supervisor, sent to investigate the RCS vent paths for proper alignment, found the 2RC8070 valve locked closed. He proceeded to open the valve and the reactor level indication stabilized.

Braidwood believes that mechanisms were available to control the position of the 2RC8070 valve. However, these mechanisms were not properly utilized and therefore were not effective.

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, I ATTACHMENT ,

l RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-457/93006 i

Surveillances and lineups, when properly sequenced, control component position. In this event, Braidwood Operating Surveillance (BwOS) 4.11.A-1, " Reactor Head Vent Path Locked Valve 18 Month Surveillance," was not performed after the valve manipulations were complete. This surveillance verifies that 2RC8070 is in the locked open position.

Procedures-normally direct Operations as to the proper component 1 position. In this event, Braidwood Operating Procedure (BwOP) 1 RC-3b, " Unit 2 Reactor Coolant System Fill and Vent," Braidwood l Technical Staff Surveillance (BwVS) 0.5-2.SI.2-3, " Safety l Injection System Check Valve Stroke Test," and BwVS 0.5-2.RC.2, " Reactor Coolant System Valve Stroke Test," did not provide specific instructions for manipulation of the 2RC8070 valve.

Braidwood Administrative Procedure (BwAP) 340-2T2, " Abnormal '

Component Position Log," normally tracks the position of components not left as described in procedures and surveillances ,

and positions of components not covered in any procedures. In this event, it was not clear to the operators that the Abnormal Component Position Log should have been used. R CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

Immediate corrective action was to restore the 2RC8070 valve to the locked open position.

Braidwood initiated an extensive team investigation using Root ,

Cause Analysis Techniques.

This event was discussed with Operations personnel. Emphasis was placed on proper component configuration and the use of the Abnormal Component Position Log.

A Lessons Learned Initial Notification was issued to all CECO nuclear sites describing this event.

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION:

Braidwood has reviewed associated paperwork for Unit 1 and determined that the IRC8070 valve was properly left in.the open -

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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-457/93006 EwVS 0.5-2.RC.2, " Reactor Coolant System Valve Stroke Test," and BwVS 0.5-2.SI.2-3, " Safety Injection System Check Valve Stroke Test," have been revised to control the as-left position of the 1/2RC8070 valves.  ;

Braidwood has developed procedure BwOP RC-15, " Reactor Head Vent," which governs the venting of the reactor vessel head.

BwOP RC-3a/b, " Reactor Vessel Fill and Vent," have been revised to ensure the 1/2RC8070 valves have been left in the locked open position.

P Braidwood General Operating Procedure (BwGP) 100-1, " Plant Heatup," has been revised to specify the sequence for performing BwOS 4 ll.A-1.

Braidwood has reviewed additional surveillances that specify steps for the manipulation of locked valves to identify any l surveillances that did not control the as-left position of the valves. This review identified BwVS 6.1.2.D-1.9, " Primary i Containment Type C Local Leakage Rate Tests of Chemical and Volume Control System." Subsequently, Braidwood has verified that valves referenced in this procedure were left in the appropriate position. This procedure has been revised.

A reading package has been issued to licensed and non-licensed operators describing this event.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Braidwood achieved full compliance on March 6, 1993, when Unit 2 j r

entered mode 5 and Technical Specification 3.4.11 was no longer applicable.

ADDITIONAL PROGRAM ENHANCEMENTS:  ;

Although the safety significance of the event was minimal, Braidwood has identified further related program enhancements because the event involves plant equipment status control.

BwAP 335-1, " Operating Shift Turnover and Relief," and its attachments have been revised to include the requirement to record BwCP's and step numbers in progress for procedures being coordinated from the main control room.

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ATTACHMENT ,

RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-457/93006 An Equipment Status Control Coordinator was assigned to the ,

recent Unit 2 refueling outage to coordinate lineup performance l and provide current status to Operations Management. BwGP 100-5, ,

" Plant Shutdown and Cooldown," has been revised to ensure that any additional plant equipment status control methods are established as appropriate prior to entry into mode 5. '

The Abnormal Component Position Log procedure has been revised to improve ease of use, including: elimination of unnecessary controls that discourage use, improved display and retrieval of  ;

entries, and periodic review of logs.

The locked valve program has been revised to require:

the valve key tag to specify the valve's normal required position, Operations personnel to log the as-left position of the valve in the locked valve log each valve manipulation to have as-left position independently verified and records retention of completed locked valve logs.

Critical Operating Lineup Procedures will be formatted to better sequence system restorations, taking into account plant conditions, following outages. A schedule for procedure revisions will be developed by June 30, 1993.  ;

A training module on the plant equipment status control process will be developed and incorporated into the initial and continuing training for licensed operators and non-licensed operators. Training will also include the use of: initial lineups, procedures, the Component Abnormal Position Log, and the Key Check Out Log. Classroom training will be completed by October 1, 1993.

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