ML20095J961
| ML20095J961 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/29/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9205040228 | |
| Download: ML20095J961 (3) | |
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April 29, 1992 U,S. Nuclear. Regulatory Commission Washington,.DC-20555 Attn: Document Control' Desk
Subject:
'Braidwood Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspecti_on Report Nos. 50-456/92004:50-457/92004 NRC Docket Numbers 50.456 and 50-457
Reference:
B. Clayton letter to C. Reed dated March 30, 1992,
' transmitting NRC Inspection Report 50-456/92004:50-457/92004 Enclosed _is--Commonwealth Edison Company's (CECO) response to the Notice of. Violation (N0V) which was transmitted with the reference letter and Inspect'on Report.
The NOV cited one Severity Level IV violation requiring a= written response.
The violation concerns the documentation of abnormal valve positions.
CECO's response is provided in.the following attachment.
If your' staff has any 4 '. cions or commen;s concerning this letter, please. refer them to Denise Saccomando, Cenpliance Engineer at (708) 515-7285.
Sincerely, Op T.J. Kovach Nuclear Licensing Manager.
Attachment cc:
A. Bert. Davis, NRC Regional Administrator - RIII R. Pulsifer, Project. Manager - NRR S. Dupont,: Senior Resident Inspector
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-ATTACHMENT AESE0NSLIQJ011CLOLVIOMUON NRC: INSPECTION REPORT 50-456/92004; 50-457/92004 VIORTION TechnicalLSpecification 6.8.1 requires that written procedures shall be established,-implemented,-and maintained covering the activities referenced in Appendh A # Regulatory Guide 1.33, Revision 2, February 1978.
Contrary.to:the above, during January 26-28, 1992, normally open valve ONT099 was maintained in the closed position, without being documented in the_" Component Abnormal Position Log" as required by step C.8 of
-Administsative Procedure BwAP 340-2, "Use of Mechanical and Electrical Lineups."
REh10E_ LOR _ IRE Y10MT_10H:
Commonwealth Edison = agrees that shift personnel-did not use the p
-Component Abnormal Position Log in accordance with BwAP 340-2, "Use of L
Mechanical and Electrical Lineups." The appropriate documents were not l
used due.to deficient work practices.
Prior to the event, a nitrogen system modification was in progress to provide a high-pressure' nitrogen source from a tube trailer bypassing the existing compressor._ The modification had not been released to
~0perations although'it'had'oeen used for an extended time period.
0n. January 25, 1992, Operations was restoring the nitrogen system after increasing the-1B-and 10 Safety Injection (SI) accumulator pressures when'a leak in the system was suspected.
It was believed that the check valve downstream of the nitrogen compressor bypass valve (0NT099)-
iinstalled by.the modification, was allowing backflow.
In an effort to troubleshoot the leakage, on January 26, 1992, valve ONT099 was closen, but-was not : documented in the Component Abnormal Position Log. _ Further troubleshooting-was performed which resulted in three additional valves L
(0NT9338A, ONT080D and ONT0810) being closed. :At this point, isolation fof the high pressure nit
- ogen system from the low pressure nitrogen system-was' accomplished._ The valve-manipulations were documented in the Shift foreman Turnover Log, bu' not in the Co,monent Abnvrmal Position Log.
'On January 28,.1992, Operations was unable to increase nitrogen pressure
=in the-1B'and 10 SI accumulators and discovered that valvt s DNT099 and
-0NT9338A were closed. :These valves were opened and the SI occumulators t
-were pressurized. A leak was'then identified on the Unit 2 side of the nitrogen system.
The nitrogen supply header _ isolation valves to the SI
-accumulators'(2SI8965A-and 25189658) were closed to isolate the leak.
TheseLvalves'had been inappropriately left open, contrary to Bw0P SI-8,
" Increasing SI Accumulator: Pressure," for operator convenience aw ALARA--
' considerations. On January 30, 1992, Operating identified the leak and l initiated-repairs. ' Valves ONT080D and ONT081D were then opened to place the, nitrogen system in a narnal' lineup.
-ZNLD/1769/2!
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CORRECllVLSIEES1TAKEN AND RESULISlCillEYED:-
- A review was performed to determine if any additional modifications installed, but not yet_ released to Operations had any direct impact or; o-r C O plant operation or~ safety; No additional modifications were identified.
Operator Aid 92-009 was issued on February 3,1992, to clarify operation of the nitrogen system pending the modification's r-lease to Operations and completion.of-required training.
The Operator Aid included piping diagrams. showing what parts of the system were modified.
-Bw0P SI-8_was revised on February 3, 1992, to specifically reference procedure Bw0P NT-9, " Nitrogen Tube Trailer Operation," for verification of nitrogen system availability prior to increasing SI accumulator
-pressure.
On February 19, 1992,- the Assistant Superintendent of Operations issued a e mo to Operating crews expressing expectations regarding prt sdural compliance.
Items discussed included this event and appropriate actions to be taken when a procedure does not work or :ould be improved.
Additionally, Operations management discussed their expectations with Operations Shift Engineers'specifically regarding the importance of using the Component Abnormal Position Log.
On February 27, 1992, the Daily Orders issued by the Operating Engineer included a clarification of the nitrogen system status and system l
-operation.
At the direction of the Assistant Superintendent of Operations, tiaining for licensed operators was conducted on the administrative use and
_ procedural raquirements of the Component Abnormal Position Log in accordance with BWAP 340-2.
This training was completed on April 3, 1992.
- CORRECIIVLSTEPS TAKEN TO AVQID FURTtia VIOLATION:
An evaluation is being conducted on the use of the Componart Abnormal Position tog This review will be completed by May 15, 1992.
Appropriate' actions will be taken based on the evaluation results.
A General Information Notice (GIN) describing the subject event will be issued oy May 31', 19923 to Station employees.
This GIN will specifically address the importance of following procedures and suggest appropriate actions to be taker when a procedure could be improved.
Additional y, the use of the Component Abnormal Position Log will be addressed.
This_ event.and subject violation will be included in required reading packages for licensed and nonlicensed operators.
Required reading packages will be issued by Mey 30, 1992.
A grotip comprised of representatives from the Technical Staff, Site Engineering, Construction, and Operations is evaluating the modification process, the out-of-service process'and methods by which portions of modifications may be made available to operations.' The evaluation will be-completi.d by June 30, 1992. Appropriate actions will be taken based on the evaluation results.
DATE WHEN_1ULL lQELIAHCE WILL BE ACHIEYED:
Full = compliance was achieved on January 30, 1992, when the nitrogen
-system was placed in a normal lineup.
ZNLD/1769/3