ML20078J972
| ML20078J972 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/30/1995 |
| From: | Kaup K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9502080331 | |
| Download: ML20078J972 (4) | |
Text
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. O C:mmenw:alth Edis:n
. Z_ /) Braldwood Nuclear Power Station es Route #1, Box 84 V
Braceville, lilinois 60407 Telephone 815/458-2801 January 30, 1995 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk
Subject:
Braidwood Nuclear Power Station Units 1 and 2 Reply to a Notice of Violation Inspection Report Numbers 50-456/94026; 50-457/94026 NRC Docket Numbers90-456; 50-457
References:
1)
L.
F. Miller letter to K.
Kaup dated December 29, 1994, transmitting NRC Inspection Reports 50-456/94026; 50-457/94026 Enclosed is Commonwealth Edison Company's (Comed) reply to the Notice of Violation (NOV) which was transmitted with the letter and Inspection Report identified in reference 1.
The NOV cited a Severity Level IV violation requiring a written response.
Comed's response is provided in the attachment.
If your staff 'nas any questions or comments concerning this letter, please refer them to Kevin Bartes, Braidwood Regulatory Assurance Supervisor, at (815)458-2801, extension 2980.
/
'6 f f c-f arl L.
up Site Vice President Braidwood Station Attachment cc:
J.
B. Martin, NRC Regional Administrator - RIII R.
R. Assa, Project Manager
.NRR S. G.
Du Pont, Senior Resident Inspector K. A.
Strahm, Vice President PWR Operations or\\contid\\sitevp\\corresp\\1995\\svp006.wpf t { \\ t'
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T ATTACHMENT REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 50-456/94026; 50-457/94026 VIOLATION (456(457)/94026-01)-
Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering activities referenced in Appendix A, Regulatory Guide 1.33, Revision 2, February 1978, which includes plant startup and procedure adherence.
Contrary to the above, on November 15, 1994, the licensee failed to properly implement 2BwGP 100-1, " Plant Heatup," Step 64, and failed the air supply to the feedwater regulating valves (FRVs) and feedwater regulating bypass valves (FRBVs) with the valves in the open position vice the closed position as directed by the procedure.
Contrary to the above, on November 2, 1994, during performance of BwMS 3150-013, " Diesel Driven Auxiliary Feedwater Pump Coupling Inspection and Grease Change-Out," steps in the procedure were skipped and steps in the procedure were not signed off as completed before proceeding to the next step as required by BwAP 100-20, " Procedure Use and Adherence."
This is a Severity Level IV violation (Supplement 1).
REASON FOR THE VIOLATION:
The first example of this violation was due to a personnel error by the operator along with a lack of self checking in that he misinterpreted the procedure step.
As a result, the Nuclear Station Operator (NSO) did not cycle the Feedwater regulating valves and the Feedwater regulating bypass valves closed as was directed by the procedure.
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J ATTACHMENT REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 50-456/94026; 50-457/94026 ILEASON FOR THE VIOLATION (continued)-
The second example of this violation was the result of a lack of awareness by Mechanical Maintenance personnel that BwMS 3150-013 was designated as a continuous use procedure.
The majority of the coupling inspection and grease change-out procedures are 4 -
designated as reference use.
Because the mechanic performing this surveillance was familiar with doing this task, he incorrectly assumed that BwMS 3150-013 was also a reference use procedure.
As a result, steps were not signed off after being performed and some steps were skipped.
The supervisor in charge of the job was in error in that he did not sign off the prerequisites even though they had been met.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
When the NRC Resident Inspector alerted the Unit Supervisor that the Feedwater regulating valves and the Feedwater regulating bypass valves were not closed as directed by the procedure, the error was confirmed and the step was performed correctly.
When the Illinois Department of Nuclear Safety Inspector alerted maintenance personnel that the steps in BwMS 3150-013 should have been signed off as they were performed, maintenance personnel verified that the procedure was designated as continuous use and subsequently signed off the performed steps.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION:
The Shift operations Supervisor discussed the importance of attention to detail, self checking, procedure adherence, and pertinent training with the NSO and Unit Supervisor involved in the first event.
The event was clso discussed with all other operating crews.
The maintenance supervisor involved in the second event and his f
crew discussed the event and particularly the requirement for oigning off steps as they are performed for continuous use procedures.
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A ATTACHMENT REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 50-456/94026; 50-457/94026 CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION (continued)-
The Mechanical Maintenance Department Head discussed continuous use, reference use, and information use procedure requirements; the importance of signing off prerequisites and steps as they are performed; and the requirements of BwAP 1,00-20, " Procedure Use and Adherence," with Mechanical Maintenance personnel in department meetings.
Maintenance department heads are performing random spot checks in the field to ensure that procedures are being signed off as required by BwAP 100-20.
A procedure task force clarified the requirements of procedure adherence as defined by BwAP 100-20 and then revised the procedure as appropriate.
BwMS 3150-013 has been revised and is now designated as a reference use procedure.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
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