ML20091R693
| ML20091R693 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/22/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9202060013 | |
| Download: ML20091R693 (3) | |
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C;mm:nwealth Edisin l
~ ) 1400 Opus Pl:ce (v} Downers Grove, Illinois 60515 O
p
.y [ p January 22, 1992 U.S. Nuclear Rennlatory Commission Attn: Document Control Desk Hashington, DC 20555
Subject:
Braidwood Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos. 50-456/91024; 50-457/91024 HRC_RockeL Rumbers 50 456 and 50-457
Reference:
B. Clayton letter to Cordell Reed dated December 27, 1991 transmitting NRC Inspection Report 50-45fp91024: 50-457/91024 Enclosed is Commonwealth Edison Company's (CECO) response to the Notice of Violation (NOV) which was transmitted with the reference letter and Inspection Report.
The NOV cited one Severity Level IV violation requiring a written response.
The violation concerned the failure to comply with the Out of Service procer e.
CECO's response is provided in the following attachment.
If your staff has any questions or comments concerning this letter, please refer them to Denise Saccomando, Compilance Engineer at (708) 515-7285.
Very truly yours,
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50 ach Nuclear Licensing Manager Attachments cc:
A. Bert Davis, NRC Regional Administrator - RIII R. Pulsifer, Project Manager - NRR S. Dupont, Senior Resident Inspector 04006S QD 9202060013 920122 PDR ADOCK 05000456
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ENCLOSURE RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 456/91024; 457/91024 V10LAll0H1 10 CFR Part 50, Appendix B, Criterion V, as implemented by Commonwealth Edison Company's Quality Assurance Program, requires, inpart, that activities affecting quality be accomplished in accordance with documented instructions, procedures or drawings. Administrative Procedure BwAP 330-1, " Station Equipment Out-of-Service (005) Procedure," Revision 12, Paragraph C.3.a.(2) requires for activities requiring verification that the assigned operator verify proper placement of each 005 tag and the equipment 00S position.
Contrary to the above, on November 4, 1991, after verification was determined necessary to place the Unit 2 "2A" seal filter out of service, the operator failed to verify that the 00S tags were riaced on the proper equipment and that the equipment was in the proper 005 position.
REASON FOR_THE VIQLATION On November 4, 1991 an 005 was placed on the Unit 1 "lA" seal filter rather than the Unit 2 "2A" seal filter.
The 005 was intended to isolate and dialn the "2A" seal filter in order to change the filter. Operating personnel failed to properly verify that the 00S tags were placed on the proper equipment and that the equipment was in the proper 00S position.
Whei the floor plug was removed to change the "2A" filter, the filter housing filled with contaminated water and overflowed.
Investigation of this event identified that the operators involved went to the wrong valve location and did not read the valve tags fully.
Construction tags, which can be more difficult to read than normal valve tags were affixed to the equipment.
The operators concentrated on identifying the correct valve number and train letter but failed to recognize that they were on the wrong unit. Additionally, the operator failed to follow B,aldwood Station Administrative Procedure, BwAP 330-1 " Station Equipment Out of Service" when performing independent verification.
CORRECl1VElCI1ON TAKEN AND THE RESULIS_AC}ll1VEDI The Unit 2 "2A" seal filter was immediately isolated to prevent any additional spillage and the "2B" filter was placed in operation.
The area l
around the "2A" seal filter, where water had spilled, was decontaminated and cleaned.
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-d Braidwood Station's Senior Management recognizes that a thorough review of the independent ve,'ification program is warranted because of this event.
The Assistant Superintendent of-Operations has organized a team of station personnel to review the independent verification program and make recommendations for improvement.
The team has proposed the development of a procedure that would consolidate the existing segments of the independent verification program, along with program enhancements, into one procedure.
CORRECIIYLSIEESJ11AI3I LLJ EJAKEHJ0_AVOI D_EURIHERJ10LAll0N :
Senior station managements' expectations for removing equipment from service properly along with the correct method for performing indeper. dent verification were reinforced with the individuals involved in this event.
The Assistant Superintendent of Operations (A50) discussed this event with both licensed and nonlicensed operating personnel in tailgate training sessions.
Emphasis was placed on the failure to meet performance expectations with respect to performing OOS and independent verification activities.
The description tags on the valves were removed and replaced with more visible tags.
To assist station personnel in locating unit specific seal filter valves, unit colors will be painted on the floors in the valve rooms that contain the seal filter valves.
This is expected to be completed by March 1, 1992.
A procedure will be developed that consolidates the existing segments of the independent verification program, along with enhancements to the program, into one procedure.
The expected completion dated for this procedure is July i
1, 1992, t
IllLDAIE3HEtLEULLlotELIANCLlilLLDLACH11VIDI full compliance was achieved when the Unit 2 "2A" seal filter was properly isolated and the personnel involved were counselled on adherence to the 00S piotedure.
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