ML20090E497
| ML20090E497 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/02/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9203090464 | |
| Download: ML20090E497 (3) | |
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' h Ccmmonw3alth Edison r 1400 Opus Place V
Downers Grovis,13lnols v0$15 March 2,1992 UL. Nuclear Regulatory Commirlon Attn: Document Controf Desk Washin0 ton, DC 20555
Subject:
3raldwood Nuclear oower Station Units I and 2 Response to Notice of Violation Inspection Report Nos. 50 t56/91026; 50 457/G1026 NRC Docket Numbers 50 456 and 50 457 aoforonco:
B. Clayton lottor to C. Rood dated February 3,1992 transmitting NRC Inspection Report 50 456/91026;50 457/91026 Enclosed is Coinmonwealth Edison Company's (CECO) response to the Notice of Violation (MOV) which was transmitted with the reference letter end Inspection Report. The NOV cited one Severity Level IV violation requiring a written response The violation concerned the failure to comply with an administrative procedure, vehich requires that shift operatom be aware of changes in plant statusc CECO's response is provided in the following attacament.
ll your staff has any c uestions or comments concerning this letter, please refor them to Den ne Saccomando, Complianco Engineer at (708) 515-7285.
Very truly your, L.)$dvach Nu616ar Licensin0 i, lana-or Attachment ec:
A Bart Davis, NRC Regional Administrator - Rlli R. Pulsifer, Project Manager NRH S. Dupont, Senior Resident inspector 0 G 0 0')8 9203090464 920302 PDR ADLCK 050o0456 G
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l ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 456/91026: 457/01026 VIOLATION:
During an NRC inspection conducted on December 14,1991 through January 17,1992, a violation of NRC requirernents V as identified, in accordance with the "Goneral Statement of Policy and Procedu'a for NRC Enforcement Actions,' 10 CFR Part 2, Appendix C (1991), t 10 following violation is listed below:
i Braldwood Unit 1 and 2 Technical Specificatior G.0.1 requites that written procedures shall be established, implemented, and malt tained covering the following activilles:
The apalicable procedures recommended in appendix A of Regulatory Guide 1.33, Revision 2 February 1978, which includes administrative proceduros.
Contrary to the above on January 10,1992, the licensee f ailed to comply with Administrative Procedure DwAP 3001, Stop C.S. which rec luires that shift operators be made aware of changes in plant status. Personnelinadver.ently removed 2A containment spray pump, rather than the 2A residual heat removal pump, from service for preverNtivo maintenance, and failed to inform the shift operators of the error.
This is a Severity Level IV violation (Supplomant 1)
REASON FOR THE V!OLATION:
On January 13,1992, at 7:00 A.M., fuel handling personnel were assigned the task of chan0 ng the oilin the 2A Residual Hoat Removal (RH) Pum). At 8:30 A.M.,
l the fuel handlers changed the oilin what they thou iht was the 2A R 1 purnp; however, they were working on the P A Containment Spray pt.mp. The lubrication activity was completed at 9:10 A.M. Later that morning,d changed the oilin the wrong p el handlers returned to the RH/CS aump room and determined that they ha The fue; handlers then changed the oilin the 2A RH pump and were done at 0:05 A.M. The fuel handlers returned to the office and paged their supervisor to communicate th6 situation. The fuel handling supe visor returned to the office at approximately 11:45 A.M. with a priority job for the fuel handlers. At that timo, the fuel hardiers woro unsuccessful in communicating to their supervisor that the oil in the CS pump had been changed. At 12:15 P.M., an operator contacted the fuel handling supervisor to inquire il work activities had been perfortned earlier on the 2A CS pump.
The supervisor pursued this question with his fuel handlers and was informed by them that they had worked on the wrong pump. The fuel handling supervisor immediately contacted the Operating Engineer who directed the supervisor to contact the Shif t Engineer. The fuel handling supervisor immediately notified the Shift Engineer.
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ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 456/91020; 457/91020 (continued)
The fuel handlers were not aware of thu requirement to contact the Shif t Engineer of the change in the status of a plant component as per BwAP 3001,
" Conduct of Op9tations." They intended lo notify their Irnmediate supervisor In lieu of the Shift Engineer.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
On January 14,1992, the Fuel Handling Department stayid a departmental stand down to discuss this event with Senior Station Managemen:. Management expectations regarding compliar.ce with BwAP 3001 and the need for attention to detail was stressed. As a result of this stand d,wn. fuel handling supervisors along with the fuel handlers developed a Lubi,ation Task Omckflut. This checklist is used as an aid to ensure the lubrication jot is perfortned as intended. Additionally, a caution statement is included to notify the Shift Engineer if work has begun on the wrong component. This checklist was initiated on January 20,1992.
A General Information Notice (GIN) was issued to the Station employees.
This GIN described the subject event and stressed the irnportance of Informing the Shif t Engineer of the change in status of plant components.
CORRECTIVE ACTIONS TAKEN TO PREVENT FURTHER VIOLATION:
The station will develop a new procedure, BwAP 10010, Conduct of Station Personnel," which wili be mode ed after BwAP 3001, " Conduct of Operations." This procedure will specifically address the reponing of adverse conditions which affect plant safety to the Shift Engineer. This procedure is expected to be issued by July 1, 1992. Training on this procedure will be developed for initial and centir'ulng training.
Lesson plans are expected to be completed by August 1,1992.
Finally, BwAP 3701, " Station Lubrication Program," w,Il be revised to incorporate the Lubrication Task Checklist. This revision is expected to be issued by May 1,1992.
DA1E WHEN FULL COMPLIANCE WAG ACHIEVED:
f Full compliance was achieved on January 14,1992, when management's expectations regarding compliance with BwAP 300-1 was reviewed with fuel handling personnel.
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