ML20056B450
| ML20056B450 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/15/1990 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9008280302 | |
| Download: ML20056B450 (5) | |
Text
/
Commonwealth Edison k
7x
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) 1400 Opus Ptc)
/ Downers Crove, Illinois 60515
'O August 15, 1990 Mr. A. Bert Davis Regional Administrator U. S. Nuclear Regulatory Comiss3on Region III 799 Roosevelt Road Glen Ellyn, IL 60137
SUBJECT:
Braldwood Station Units 1 & 2 Response to Inspection Report i
Nos. 50-456/90-012 and 50-457/90-015 NRC Doske.LHos&50-456 and 10-451
REFERENCE:
(a)
W. D. Shafer letter to C. Reed dated July 18, 1990
Dear Mr. Davis:
Reference (a) provided the results of the inspection conducted by Messrs. T. E. Taylor, J. A. Hopkins, T.M. Tongue, M.A. Kunowski and Ms. D. Calhoun from April 29 through June 16, 1990 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.
If you have any questions regarding this response, please direct them ta this office.
Respectfully, T.
.F
'ach Nuclear Licensing Manager l-l~
.cc: NRC Resident Inspector - Braidwood NRC Document Control Desk l
9008286302 900815
~
PDR ADOCK 05000456 O
PDC 1924v:1 AUG201M
ENCLOSURE C0t910NWEALTH EDISON COMPANY'S RESPONSE TO INSPoCTION REPORT NUMBERS 456/90012 and 457/90015 t
VIOLATION:
(456/90012-01: 457/90015-01) 10CFR, Appendix B, Criterion V, requires that activities af fecting quality shall be prescribed by documented instructions and procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions and procedures.
Contrary to the above:
A) On June 3, 1990, inadequate instructions on the activities to take when a Temporary Lift Procedure expires, resul+.ed in the failure to rehang _four containment isolation valve tags at the power level identified in the expiration block; and B) on May 10, 1990, licensee personnel failed to follow the requirement of the Temporary Lift Procedure which resulted in contamination of large areas of the auxiliary building during containment spray fill and vent activities.
RESPONSE
Commonwealth Edison Company (Edison) acknowledges the two events described in the Notice of Violation.
Edison believes the June 3,1990 event involving the failure to rehang four containment isolation valve out-of-service (00S) tags was the result of inadequate instructions in procedure BwGp 100-3, " Power Ascension".
This p.acedure describes the actions necessary to accomplish a power increase from plant startup to full power and requires lifting the 00S on these valves to periodically drain the main steam lines.
There is no reminder in this procedure to rehang the 00S after exceeding 201 p?ver.
The May 10, 1990 contamination of the au::lliary building is b:..eved to
-have resulted from personnel error.
The operators involved failed tn verify accomplishment of the initial steps of Bw0P CS-3, " Filling and Venting the Containment Spray System" by f alling to verif y proper valve lineup for the operation.
Edison, therefore, believes these events arc not collectively related to the Temporary Lift Program but rather are an example of a deficiency of the Power Ascension Procedure and an example of personnel error.
Edison's review of these events determined that there had been no negative impact on the health and safety of the public.
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' CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
For the June 3,1990 event, the containment isolation valves were not placed 00S since the plant was in the process of shutting down, during which periodic steamline draining is required.
The valves are required to be placed in OOS above 20% power and the plant conditions were below 20% power. The vatves were placed in OsS following the next unit power ascension above 20% power.
For the May 10, 1990 event, the improper valve lineup was immediately corrected, the water was removed from the floor and the area was decontaminated.
CORRECTIVE ACTION TO AVOID FURTHER VIOLATION:
For the June 3, 1990 event the station is revising procedure 1/2 BwGP 100-3, " Power Ascension," to include a step directifg that the four containment isolation valves (steamline drain valves) be placed out-of-service after exceeding 20% power.
For the May 10, 1990 event the personnel involved were included and participated in a Braidwood Station Error Evaluation Presentation in order to identify the root and contributing causes of the event.
Based on the conclusions of this presentation, the following corrective actions are being initiated to prevent recurrence.
1.
A training tailgate session will be conducted for appropriate operating shift personnel to discuss this event.
2.
The operating department will expedite completing the permanent revisions for the temporary procedure changes that are currently in effect for the 00S procedure.
3.
An evaluation of operating methodology will be conducted to determine if independent verification and/or official completion sign-off should be required prior to permitting operation or initiation of major activities under the temporary lift 00S.
4.
The operating department will conduct an evaluation to determine methods of reducing the number of temporary lifts.
l DATE OF FUIL COMPLIANCE The corrective actions described above are expected to be completed by October 31, 1990.
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V101ATION:
(456/90012-02; 457/90015-02)
Technical Specification 6.8.la requires that written procedures be established, impic=ented, and maintained for the activities specifled in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978.
Section 7.e of Appendix A pertains to radiation protection activities.
Section C.3 of Braidwood Procedure No. BwRP 2240-1, " Radiation Work Permit Program," states that the requirements of the Radiation Work Permit must be complied with in all respects.
Contrary to the above, on April 17 and 26, 1990, a written ;
cedure pertaining to radiation protection activities was not implemented.
Specifically, protective clothing requirements of a Radiation Work Permit were not complied with resulting in no personnel contaminations.
RESPONSE
Commonwealth Edison Company (Edison) acknowledges the two instances I
of a failure to follow Radiation Work Permit (RWP) protective clothing requirements.
On April 17, 1990 a worker in the Unit 2 l
i containment was observed without the protective gloves required by a RWP. The worker had removed the gloves to remove and store his eyeglasses in a case. On April 26, 1990 another worker was observed I
in Unit 2 containment " blue checking" a valve (checking the valve seating characteristics by applying a liquid dye) without protective gloves as required by a RWP. Neither worker became contaminated as-l a result of these actions nor have any further incidents of this nature occurred.
l Edison's review of these events determined that there had been no negative impact on the health and safety of the public.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:
i For both incidents the workers were immediately instructed to re-don
'i the protective gloves.
For the worker who removed his glasses a heightened level of attention was given to his work activities.
This was accomplished by having Radiation Protection Technicians closely monitor his remaining work activities.
The worker observed
" blue checking" the valve without gloves was removed from the I
containment and counseled as to the importance of following a RWP.
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1 CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION:
The corrective actions taken by Edison as a result of this incident have been reviewed by the NRC Inspector and ha stated in the inspection report have been found " adequate." These corrective actions consisted of discussing these incidents with the work groups, emphasizing the need to follow RWP requirements.
Supervisors f rom Braidwood Station's Health Physics Department met with small groups of workers to disc ss:
- 1) their understanding of the incidents,
- 2) their concept of radiation and contamination,
- 3) their concerns in the area of radiation protection, and
- 4) how to improve their radiation protection performance.
Along with the above mentioned discussions the necessity of always wearing protective gloves while working in contaminated areas was presented to the workers in their weekly safety sheet.
DATE OF FULL COMPLIANCE:
All corrective actions associated with these events have been completed.
Full compliance has been achieved.
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