ML20064B164

Responds to NRC Re Violations Noted in Insp Repts 50-456/90-13 & 50-457/90-16.Corrective Actions:Auxiliary Feedwater Pumps 2A & 2B Returned to Svc

ML20064B164
Person / Time
Site:	Braidwood
Issue date:	09/17/1990
From:	Kovach T COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9010150021
Download: ML20064B164 (6)

Text

'

\ Commonwealth Edison acD  !

, /  !

' ) 1400 Opus PI:ce (t -

7 Downers Grove, Illinois 60515 i

. 'V i September 17, 1990 1

Mr. A. Bert Davis  :

Regional Administrator U. S. Nuclear Regulatory Commission ,

Region III  ;

I 799 Roosevelt Road .

Glen Ellyn, IL 60137  ;

Subject:

Braldwood Station Units 1 & 2 Response to Inspection Report Nos. 50-456/90-013 and 50-457/90-016 i EC_DroiteLNm_50-456 and 50-67  :

Reference:

(a) E. G. Greenman letter to Cordell Reed dated August 17, 1990 l

Dear Mr. Davis:

I l

Reference (a) provided the results of the inspection conducted by Messrs.

T. E. Taylor, J. A. Hopkins, B. L. Jorgensen, M. A. Kunowski, M. Begel, M. Peck, and Ms. D. Calhoun from June 17 through July 28, 1990 at Braidwood Station.

Reference (a) indicated that the single missed surveillance did not result in a significant degradation of safety, but that there appears to be a weakness in the overall management control of non-routine Technical Specification surveillance activities. Reference (a) requested that Commonwealth Edison Company provide a description of the actions planned by Braldwood Station to strengthen the management control in this area. This is provided in Enclosure 1.

Reference (a) also indicated that certain activities appeared to be in violation of NRC requirements as described in the Notice of Violation. The Commonwealth Edison Company response to the Notice of Violation is provided in the  ;

Enclosure 2.  ;

If you have any questions regarding this response, please direct them to

! t this office.

• 2 f-T. J ovach

$O Nuclear Lievnsing Manager SS 8@ Enclosure i MS g g $$

8

-tr cc: NRC Resident Inspector - Braidwood .

Mcs NRC Document Control Desk

\g\

/scl:ID282:1 IE l

. i

• . j

. ENCLOSURE 1 J

COMMONHEALTH EDISON COMPANY'S RESPONSE TO INSPECTION REPORT NUMBERS 456/90013 and 457/90016 A Braidwood Station review of the missed non-routine surveillances mentioned in the Inspection Report Indicates that there was a unique set -

of circumstances surrounding each event. For each event corrective actions specific to that event have been implemented to preclude  :'

recurrence. There are, however, some similarities that occur in these' events. Communications between individuals, where pertinent facts were not transmitted, resulted in missed surveillances. Also, unclear delegation of responsibility and failure to follow-up to ensure that actions had been completed impacted the missed surveillances. Braidwood Station will continue to emphasize the importance of communications i between various departments and personnel and the need to follow-up in 'i order to eliminate deficiencies caused by improper communications.

Braldwood Station recognizes the importance of adequate management control over non-routine technical specification surveillances. In order 1 to properly evaluate the existing controls and identify areas of ,

improvement in the current program the following actions are being implemented:

1) Braidwood Station is issuing a General Information Notice (GIN) to station personnel describing the missed non-routine surveillances and the importance of proper communications between station departments to ensure non-routine surveillances are satisfactorily completed. This GIN was issued on September 14, 1990.

2) Braidwood Station is undertaking a review of non-routine surveillances to determine if any programmatic deficiencies exist i

in the method of identifying and ensuring completion of these i

surveillances. This review is expected to be completed by October 5, 1990.

3) Commonwealth Edison's Corporate Assessment Group is being requested to perform an assessment of Braldwood Station's non-routine surveillance program. This assessment is expected to be completed by October 31, 1990.

r1 l

l

/sc1:ID282:2

i i

, ENCLOSURE 2 f COMMONHEALTH EDISON COMPANY'S RESPONSE TO INSPECTION REPORT i NUMBERS 456/90013 and 457/90016 VIOLATION: (457/90016-01)

Technical Specification (TS) 6.8.1.a requires that written procedures be established, implemented, and maintained for the activities in Appendix A  !

of Regulatory Guide 1.33, Revision 2, February 1978. Sections 1.c and i 1.d of Appendix A pertain to Equipment Controls and_ Procedure Adherence. [

t Step D.1 of Braidwood Procedure BwAP 330-1 " Station Equipment t Out-of-Service (005) Procedure," requires the licensee to review all TS 00S equipment to assure opposite train operability and determine if any corrective actions are necessary to satisfy the TS or surveillance requirements.

Contrary to the above on June 1,1990, the Shif t Control Room Engineer l (SCRE) authorized the 2A Auxiliary Feedwater Pump to be placed DOS while

! the 2B Emergency Diesel-Generator (EDG) was inoperable for maintenance.

Failure to follow the procedure resulted in the operating shift being unaware the+ :omponents in opposite Engineered Safety Features (ESF) trains were 005 for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 46 minutes.

RESPONSE

Commonwealth Edison (Edison) acknowledges that an inadequate review on an L Out-of-Service (005) for the 2A Auxiliary Feedwater (AF) Pump allowed it I to be placed DOS at the same time as the 28 Diesel Generator. This created a plant configuration where components in opposite Engineered Safety Feature (ESF) trains were 00S at the same time. The 2B Diesel' Generator was taken 005 at 0549 on June 1, 1990. At 0800, the 2A AF Pump was taken 00S for a calibration surveillance on the 2A AF Pump Suction Pressure Switch. This resulted in a component from each of the two ESF trains being technically inoperable. This condition existed for a total of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 46 minutes when at 1436 on June 1, 1990 the surveillance on the 2A AF Pump was completed and the pump was returned to service. '

Edison's review of this event determined that there had been no negative impact on the health and safety of the public.

/sc1:ID282:3

C0kRECTIVEACTIONTAKENANDRESULTSACHIEVED:

i The 2A AF Pump was returned to service prior to the discovery that a  ;

component (2B Diesel Generator) in an opposite ESF train was 005. Upon discovery that these two components in opposite ESF trains were 00S at the same time, Technical Specification action' requirements were reviewed '

and verifted to have been satisfied during the occurrence. The 2B Diesel Generator was returned to service shortly thereafter.

CORRECTIVE ACTION TO AVOID FURTHER VIOLATION:

i Personnel involved in this event were included and participated in a Braldwood 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) Training will be conducted for appropriate operating shift personnel to review:

a) this event, b) the techniques of self-checking /self verification as related to out-of-service work, and c) the importance of following procedures.

2) A Status Board will be displayed in the control room giving the l status of components in the ESF trains. As a component is taken DOS, its ESF division status will be displayed on this board. By l

reviewing this visual display, the operating personnel will be able to quickly determine if a component in the opposite ESF train is 005. This will prevent components from opposite ESF trains oeing taken 00S at the same time.

DATE OF FULL COMPLIANCE:

The status board for the control room is expected to be installed and i

functional by November 1, 1990. The training of appropriate operating personnel is expected to be completed by December 31, 1990.

s

/scl:ID282:4

I

VIhLATION: (456/90013-01) l I

10 CFR 50, Appendix J, Section III.C.2(b)(til) requires that air locks i opened during periods when containment integrity is required by the ,

plant's Technical Specification (TS) shall be tested within three days  ;

after being opened. i Contrary to the above, a Unit I containment entry was made on June 8, 1990, with containment integrity required by TS, but a containment personnel air lock leak test was not completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The test was satisfactorily completed on June 15, 1990. Failure to perform the surveillance resulted in the Unit I containment air lock being potentially degraded for a period of time.

RESPONSE

Edison acknowledges that a containment personnel air lock leak test was not completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of a containment entry as required by Technical Specification 3.6.1.3. The cause of this event was a programmatic deficiency, a System Test Engineer (STE) had been monitoring the High Radiation Area (HHRA) Key Control Log, on a regular basis to determine when a leakage test of the containment personnel air lock was required in accordance with the existing program. During-the week of June 11, 1990 the STE reviewed the HHRA Key Log on a regular basis and did not observe any key issuance for containment entry. On June 15, 1990 the STE made his HHRA Key Log review and did not observe any new entries. Later that morning the STE was informed that a containment entry had been made. At 1030 the STE reviewed the HHRA Key Log. He observed that the last entry on the log sheet was dated the morning of June 8, 1990 for which a containment personnel air lock leak test had been completed. Puzzled by this discrepancy, the STE leafed through the blank pages of the log shaets, When the STE turned to the  !

last blank log sheet, he discovered that a second log sheet had been initiated. There were two entries on the second log sheet, one for that morning, and one for a containment entry made on the afternoon of June 8, 1990. The STE realized that a leak test had not been performed for the afternoon entry of June 8, 1990.

Edison's review of this event determined that there had been no negative impact on the health and safety of the public.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:

Upon identification by the System Test Engineer (STE) that a containment entry had been made and the surveillance test was not performed, the STE immediately initiated the performance of the leakage test surveillance.

The results of the surveillance were satisfactory.

i i

i i

-i

/sc1:ID282:5

>. f

• • C0hRECTIVEACTIONTAKENTOAVOIDFURTHERVIOLATION:  ;

1 The program to track containment entries has been changed from the existing program where the STE would monitor the HHRA Key Logbook to a program that will require a containnent entry checklist and a containment  !

entry logbook entry to be completed every time a containment entry is made. This will be accomplished by modifying Braldwood Station Procedure, BwAP 1450-1, " Access to Containment," to ensure all entries of the containment hatch are documented on the appropriate forms. In addition a new logbook BwAP 1450-1T2/3, " Unit One/Two Containment Entry ,

Log, " is now kept in the Shift Engineer's Office and requires the individual opening the containment hatch to fill out the logbook. The -

STE will review this logbook to determine containment hatch surveillance requirements.

• Additional corrective action includes the implementation of a Continuous Leakage Monitoring System for the Personnel Air Locks. A Technical Specification amendment to permit the use of this system (and as a result, eliminate the leak test requirement following each entry) was ,

previously submitted to the NRC on October 4, 1988 with a supplemental t submittal dated August 14, 1989. This is currently under NRR review and Edison is awaiting the approval of this amendnent request.

DATE OF FULL COMPLIANCE:

^

Braidwood Station Procedure BwAP 1450-1 has ber.1 temporarily changed to include the above described changes. Final revision of the procedure is  ;

expected by December 1, 1990, t

/sc1:ID282:6

. F

,