ML20080C688
| ML20080C688 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/09/1994 |
| From: | Kaup K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9412190199 | |
| Download: ML20080C688 (6) | |
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.U.S.^ Nuclear Regul'at"ory Commission.
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Subject:
Braidwood' Nuclear Power StationLUnits.l'and'2; Reply to alNotice..of Violation'
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t Inspection Report Nos.
50-456/94022;.50-457/94022' NRC Docket. Numbers 50-456 and 50-457-
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References:
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E. GL'Greenman?lett'er.to K. Kaup. dated l
November 14,' 1994, transmitting.
NRC Inspection Report 150-456/94022; 50-457/94022 4
Enclosed-is Commonwealth' EdisonL Company's (Comed)' reply to. the -
Notice..of' Violation (NOV); which was stransmitted with. the' 16tter and.Inspecti.on Report identified in' reference'1.
The'NOV cited ~
two Severity Level,IV violations. requiring a1 written' response..
' Comed's response is providedLin.the attachment.
I If.your staff has any questions or comments concerning.this:
' letter, please refer.them-to Kevin,Bartes, Braidwood Regulatory' t
Assurance Supervisor,7at.(815)458-2801,.. extension 2980'.
a arl L. Kau Site Vi e-P sident-
'Braidwood Station
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Attachment cc:
J.'B. Martin, NRC' Regional Administrator!- RIII
- R. R. Assa, Project Manager - NRR d
S. G. Du'Pont, Senior Resident Inspector i
l; 9412190199 941209 l8 i.
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REPLY TO A NOTICE OF VIOLATION INSPECTION' REPORT ~
50-456/94022; 50-457/94022
' VIOLATION '(456 (457) /94022-01) :
Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering cctivities referenced in Appendix A, Regulatory Guide 1.33, Revision 2, February 1978, which includes preparations'for refueling.
t a.
Contrary to the above, on October 1, 1994, the' licensee.
failed to properly implement BwFP FH-3, "New Fuel Transfer To/From Storage Vault," during new fuel movements from.the' new fuel vault to the spent fuel pool.
This resulted'in~the mispositioning of 19 fuel assemblies.
b.
Contrary to the above, on October 21, 1991,.the licensee failed to properly maintain and implement BwFP FH-14,
" Operation of Refueling Machine," during fuel' movements from-the spent fuel pool to the reactor vessel.
This is'a Severity Level IV violation.
REASON FOR THE VIOLATION (456 (457) / 94022-01a) :
The reason for this violation is that the fuel handling crew applied less than adequate attention to detail while removing the new fuel assemblies from the new fuel storage vault (NFSV).'.They also failed to self check that NFSV location F5 had been emptied prior tc moving to cell location E6 which resulted in the mispositioning of the 19 new assemblies.
Contributing to this violation was the use of plastic bags to cover individual fuel assembly cells-for foreign'materiali exclusion.
Placement of the bags prevented the~ fuel handlers from verifying the presence or absence of new fuel assemblies.in the cells.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED '(456 (457) /94022-01a) :
q The Fuel Handling Supervisor realized that a problem existed and suspended new fuel assembly moves until the cause of the problem was identified and amended nuclear component ~ transfer lists (NCTL) were written to rearrange the fuel as ' appropriate.
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LATTACEMENT I
REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 50-456/94022; 50-457/94022
~ CORRECTIVE" STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION
-(456(457)/94022-Ola):
A Braidwood' Event Review Presentation was held on-Monday October 3,1 1994, with all'the fuel handling personnel available on shift, to discuss the event, identify further problems, and determine corrective actions.
No additional problems:were-identified.
As'a method of ensuring that self checking occurs and the correct
' fuel assembly is moved, a temporary procedure change was written for BwFP FH-3, "New Fuel Transfer To/From Storage Vault."
This procedure change requires a triple verification before a now fuel assembly can be removed from the NFSV.
This procedure will be permanently revised prior to the next refueling outage which is currently scheduled to begin for Unit 1 on September 30, 1995.
The Fuel Handling department has revised their policy for using plastic bags to cover individual. fuel assembly cells.
The.
plastic bags will be temporarily removed from the cells in an
'NFSV until all fuel assemblies from that particular NFSV have.
be'en removed.
At that time, theLplastic bags will be replaced on
.the cells to maintain foreign material exclusion.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (456(457)/94022-Ola):-
Full compliance was achieved on October 3, 1994.
REASON FOR THE VIOLATION (456 (4 57) /94022-Olb) :
The reason for this violation is that fuel handling personnel relied on their past experience, training, and familiarity with BwFP FH-14 to enable them to execute the procedure.
As a result, the procedure was not properly followed or adequately implemented-as described in the Inspection Report.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED (456 (957 ) / 94022-Olb) :
To address the identified procedure adherence concerns, Fuel.
Handling management stopped the activities in progress and discussed the safety significance of the actions taken prior to resuming the activities.
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REPLY TO A NOTICE OF VIOLATION (CONTINUED)
INSPECTION REPORT 50-456/94022; 50-457/94022 CORRECTIVE STEPS TAKEN AND RESULTS' ACHIEVED (456 (4 57) /94022-01b CONTINUED) :
To address the concerns associated with not adequately implementing BwFP FH-14 for insertion and removal of fuel in the core, the fuel handlers stopped the activities upon being questioned by the NRC Resident Inspector.
An evaluation'was performed which determined that the weight figures were excessively high, due to a previous calibration error in the weight indicator.
Subsequently, core alterations'were resumed.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION (456(457)/94022-Olb):
Procedure BwFP FH-14 will.be evaluated for changes and revised as appropriate.
Additionally, the fuel handlers will be trained'on the revised procedure.
These actioris.will be completed prior to the next refueling outage which is currently scheduled to begin for Unit 1 on September 30, 1995.
Regarding the refueling machine labeling discrepancies identified in the Inspection Report, an evaluation will be performedLto identify any labeling changes that need to be made.
This action will be completed prior to core' offload'during the next refueling outages which are currently scheduled.to begin for Unit 1 on September 30, 1995, and for Unit 2 on March 2, 1996.
The Fuel Handling department will review all fuel handling procedures for consistency with actual practices.
These' actions will be completed prior to the next refueling outage which is currently scheduled to begin for Unit'1 on September 30, 1995.
DATE WHEN TdLL COMPLIANCE WILL BE ACHIEVED (456 (457) /94022-Olb) :
Full compliance was achieved on October 21, 1994.
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50-456/94022; 50-457/94022 VIOLATION"(457/94022-02):
Technical' Specification 3.9.5 requires.that during core alterations, direct communications shall be maintained between the control room and personnel'at the containment. refueling.
station.
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- Contrary to the abora, on October 15,1 1994, during transfer the reactor vessel upper internals from the reactor vessel'tc the upper internals storage 11ocation, a core alteration, direct communications was not maintained as required.
This is a Severity Level IV violation.
REASON FOR THE VIOLATION (457/94022-02):
- The reason for this violation is that a personnel error was made-on the part of the Fuel Handling Supervisor (FES) in'that he did
. not maintain the communications link with the control room.
The FHS positioned himself approximately 35 feet'from the speaker phone to observe remote television monitors to determine if a bundle or a control' rod was inadvertently lifted.
Also, he was able to hear the source range count in the containment while ensuring his dose would be as low as reasonably achievable.
He incorrectly believed he could hear the speaker phone from.this location.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED (457/94022-02):
The Unit NSO contacted personnel in the' Fuel Handling Building who alerted the FHS to call the control room.
Voice communications were then re-established.
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' REPLYiTO A' NOTICEi.0F; VIOLATION:
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! CORRECTIVE STEPS'THAT WILL~BE'TAKEN'TOiAVOID1FURTHER6 VIOLATION 2 tM' (457/94022-02).
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- CThe, Senior License:Holdet~. spoke to the individual (regarding ?
proper communication techniques to<be implemented while acting;*as.
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1A: telephone handsetswith a long cord has;been'identifiedfas the:
<,n proper method of communications.during coreJalterationsk This.
method has.since been'used;succ,essfully'for the. replacement;of-j the upper internals asiwell'as forlthe. placement-of theEreactor
> vessel head.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (457/94022-02):'
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. Full compliance! was achieved on' October 15,11994.:
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