ML20097D561
| ML20097D561 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 06/05/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9206110018 | |
| Download: ML20097D561 (8) | |
Text
_ _ _ _,
'N Commonze:lth Edison
) 1400 Opus Pl:ca
] Downers Grove, Illinoit 6051S 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 Inspection Report Nos. 50-456/92007:50-457/92007 NRC Docket Numbers 50-456 and 50-457 Referen.w: B. Clayton letter to C. Reed dated May 8, 1992, transmitting NRC Inspection Report 50-456/92007;50-457/92007 Enclosed is Commorswealth idison 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 concerns implementation of procedures. CECO's response is provided in Attachment A.
Braidwood Station is concerned with this violation in light of the recent number of personnel errors and is taking aggressive action to improve in this area. A brief summary of Braidwood's initiatives
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is included in Attachment B.
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If your staff has any questions or comments concerning this letter, please reier them to Denise Saccomando, Compliance Engineer
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at (708) 515-7285.
Sincerely, k b.
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T.J. Kovach Nuclear Licensing Manager Attachments A. Bert Davis, NRC Pegional Administrator - RIII cc:
R. Pulsifer, Project Manager - NRR S. Dupont, Senior Resident Inspector 9206110018 920605 PDR ADOCK 05000456 6
0 PDR 7NLD/1859/1
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ATTACHMENT A-i RESEONSLIOJ1011CLOLV10LAll0N
.IRSEECII0lLREEDRL50:A561920011_50_457132001 VIOLATION'(456(457)/92007-01):
j Technical Specification (TS) 6.8.1 requires that written procedures be I
L established, implemented, and maintained covering activities
-referenced in-Appendix A of Regulatory Guide 1.33. Revision 2, February 1978.
Contrary to the above;
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1a.-On February 13, 1992, licensee personnel failed to comply with station procedure 8'0" 130-1, " Station Equiprisent Out of Service Procedure," when orK.
9&enly initiated on the "B" hydrogen recombiner after <se W,
^ Sit was.taken oct-of-service, resulting in entry i nq G s 4 X, condition for Operation (LCO) 3.0.3.
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.b.-On March 7, 1992, licensee personnel failed to recognize that the boron concentration of the 1A Safety Injection ecctimulator was above the TS limits, as specified in station procedure 1Bw05 SI-la, " Safety-
= Injection Systems "'resulting in delayed entry into TS LCO 3.5.1 for an inoperable accumulator.
.c. On March 15, 1992, licensee personnel failed.to comply with station procedure BwAP.330-1, " Station Equipment Out of Service Procedure,"
when the wrong fuses were pulled to support the out-of-service for valve 2MSO46,.resulting in a reactor trip.
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REASON _ EOR _IH LV10LAU 0L.45 fd45DIR007-Dia :
The primary cause of the February 13, 1992, event was the failure of a mechanic to perform an Out of Service (005) verification and a self check.
The Mechanical Maintenance Senior Mechsnic (MMD-A) was not
-sware that there was another recombiner on the Unit I side of the auxiliary building.
The MMD-A failed to match the component equipment identification (EID) listed in the package for the OA recombiner with the EID label on the recombiner in the field.
Additionally, the MMD-A failed to walk down the 005.
The MMD-A believed that the 005 walkdown previously performed by the Electrical Maintenance Department was sufficient. Observing an 005 tag hanging on a valve close to the OB reccmbiner, the MMD-A incorrectly assumed that it wat. for the work to be performed.
Contributing to this event was the failure of the Mechanical Maintenance Supervisor (MMD-S) to clarify the duties and task to his crew.
The job turnover from EMD to MMD was conducted at the worker level, but should have taken place at the supervisory level.
Consequently. an inadequate pre-job briefing was conducted between the MMD-S and the MMD-A.
No pre-job briefing was conducted with the other MMD crew members.
Another contributing cause to the event was station policies and procedures concerning out-of-service card verification, and self checking were not adequately understood by the personnel involved in the event.
Consequently, the actual practices employed by the workers for this job did not meet management's expectations.
An additional contributing cause was unclear wording in the package.
The step that required the MMD-S to sign for coordinating the 00S with EMD, and relevant information for identification of'the equipment's location was not clearly presented.
Braidwood Maintenance had previously instituted corrective actions on work package improvements on September 25, 1991,. Via Maintenance Memo 200-16, " Standardized Nuclear Hork Request (NHR) Packages," This memo provides for improved clarity in-the work package and pre-job briefing instructions for the-maintenance supervisors. The OB recombiner work package had been prepared prior to September 25, 1991 and did not contain these enhancement.
CORRECHYLSIEES_TMEtLAND._RESul.lS.ACHI EV ED :
'After-recognizing that the MMD crew had disabled the OB recombiner, the Shift Engineer immediately directed the MMD-A to begin its reassembly and entered Technical Specification LC0 3.0.3.
The OB recombiner was promptly reassembled, started, and checked for leakage.
No deficiencies were found, The OB recombiner was declared operable and the LCO was exited.
The MMD-A was counselled by the Master Mechanic on procedural adherence and the importance of self checking.
Additionally, the MMD-S was counselled on the need to conduct an adequate pre-job briefing to assure that-his crew has a clear understanding of the task.
Both the MHD-S and the MMD-A received administrative disciplinary action.
Maintenance supervisors have been instructed to conduct enhanced pre-job briefing open work packages prepared prior to the issuance of Maintenance Memo 200-16.
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CQRREC11VE STEPS Th&LHILLEEJAKEN 10_ AVQlD_LURitifR yJ0LAJ10B:
The station is evaluating potential team work enhancements, such as requiring work package turnover between departments to be held at the supervisory level and expanding pre-job briefings beyond the lead worker 1evel.
This evaluation will be completed by June 30, 1992.
A review of the procedure involving out-of-service verification, will be performed.. Revisions will be made to the procedure, as necessary, to reflect the proper station practice.
This action will be completed by June 30, 1992.. Appropriate training will then be conducted for each of the changes made to the procedure.
DAIE.fillEN FULI._COMELIARCLliLLL3LAQilf3ED:
Full compliance was achieved.on february 13, 1992, when the OB hydrogen i
recombiner was reassembled, tested satisfactorily, and declared operable.
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REASON FOR THE V10LAIl0!L45614521/91001-Olb:-
The cause of the event on March 7, 1992, das personnel error by the Station Control Room Engineer (SCRE) and the Chemist.,
Laboratory Supervisor (CLS).
1 The SCRE failed to recognize that the 1A accumulator boron concentration sample result was above the Technical Specification limit, even though the required concentration range was adjacent to the place provided for documenting the-sample result.
The SCRE believed that as long as the boron concentration was greater than 2000 ppm, it was acceptable.
Two thousand ppm is the lowest boron concentration allowed by Technical Specifications for the refueling water storage tank.
The CLS was aware that the boron concentration was above the 2100 ppm limit.
The CLS signed the section of IBw0S SI-1A which addresses the sample limits as being satisfactory.
The CLS believed the signature was for. sampling and analysis completion within the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> time clock.
Since the sample and analysis were done prior to expiration, the CLS signed the.section without reading the acceptance criteria.
Two.other factors contributed to this event.
When the sample result was obtained and identified to be outside the range specified on the data sample sheet, the CLS did not notify licensed shift personnel that the sample was out.of specification. Additionally, Chemistry did not obtain a confirmatory sample.
CORRECTIVE _ STEPS TAKEN AND REST lLISlCHIEVEQ:
At 1357 on March 7, 1992, a nuclear station operator (NS0) was informed of the 1A accumulator boron concentration.
The NSO realized that the concentration was above the limit.
The 1A accumulator was declared inoperable and a confirmatory sample was requested. At 1602,
'the boron concentration was determined to be within the limits and the 1A accumulator was declared operable.
The CLS and SCRE were counselled by Senior Station Management on the importance of attention to detail. Both the CLS and the SCRE received appropriate disciplinary' action.
The-Chemistry Supervisor conducted a tailgate meeting with the Chemit.try Department personnel to discuss this event and reporting requirements for samples out of specification.
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t CORRECIIY LSIEELIllALhlLLD EJAKEM_IO_AVOI D_LURIMERl! 0L ttI! ON :
The Chemistry Department will review current station chemistry r
procedure reporting requirements and confirmatory sample r
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. requirements to determine their effectiveness.
Chemistry will also review requirements for notifying a licensed shift supervisor for samples determined to be outside Technical Specification limits.
Procedure BwAP 330-10A1, " Operability Policy for Previously Identified Items," will be included in this review for chemistry sampling.
This review will be completed by June 30, 1992.
DAILHiiEM_EULL COMPLIARCLHILLBLACRIEVED:
Full compliance was achieved on March 7, 1992, when the boron sample for the 1A accumulator was within limits.
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l' REA50R.10fLIHLY10L&IION 4551451]I91001_-01.s:
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The cause of the event was personnel error by the NSO.
While placing the 005 cards in the auxiliary electric equipment room, the NSO did not recognize that 00S cards #10 and #11 wert for fuse 51 and fuse 52 respectively, iiie NSO read the information on the card and transposed the 005 f.atd number located on the bottom of the card for the fuse number.
Fuses 10 and 11 were removed and resulted in the isolation of feedwater to the 28 and 2C steam generators.
An automatic reactor trip occurred due to the level in the 2C steam generator reaching the low-low level setpoint of 177..
CORRECTIVE _SIEES.TAKEN AND RESULTS ACHlEVED:
The NSO was counselled by the Production Superintendent and the Assistant Superintendent of Operations on the importance of self checking and attention to detail.
The NSO received appropriate disciplinary action.
CORRECTIVE STEPS THAT HlLLEE_IEER.10lV01D_EURIHER.Y10L&Il0N:
Braidwood Operating personnel performed a review of 005 card labeling to examine if the information on the card can be rearranged to reduce the possibility of transpositioning.
Recommendations have been transmitted to the Corporate group responsible for the 005 computer
. program for consideration. Changes to this program are coordinated
.between Ceco's six nuclear stations.
Braidwood will follow the Corporate group evaluatir>n of these recommendations.
DATE HHEN FU.LL COMPLl6KE.HllkHL6CillEYED:
= Full compliance was achieved on March 15, 1992, when the incorrectly pulled fuses lwere replaced and the 005 was correctly performed.
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ATTACHNENT B ilRalDS00n_SIAUOfLINillAllVES i
As a result of Braidwood Surveillance Task Force recommendations and concerns about personnel performance and industrial safety, Braidwood Station formed the Human Performance Awareness (HPA) Team in January 1992.
The Assistant Superintendent of Maintenance leads the team which is comprised of~four bargaining unit and four management members.
.The team has developed and implemented a station HPA procedure which covers self checking and station briefings.
The self checking portion of the procedure defines self checking techniques and emphasizes responsibility for self checking by individuals, supervisors and managers.
Three levels.of briefings are covered as follows:
Heightened level of awareness briefings for activities involving multiple work groups.
Shift briefings for operating crews.
Pre-job briefings for work group supervisors and their work groups.
The HPA team is training station personnel on the procedure and will be compieted-by June 15, 1992.
The team will continue to monitor personnel performance and implement added-initiatives as necessary.
In March 1992, the Braidwood Station Manager conducted a series of station meetings-to communicate management expectations to all station personnel.- - The Station Maneger discussed-recent events involving personnel errors and emphasized the need for improvement.
Specific department supervisors conducted discussions the next day with.their personnel.
Followup on the feedback received from these discussions-is ongoing.
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