ML20115F024
| ML20115F024 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/16/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9210220227 | |
| Download: ML20115F024 (5) | |
Text
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Ctmm:nwealth Ediscn 1400 opus Place Downers Grove, lilinola 60515 October 16,1992 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk
Subject:
Braldwood Nuclear Power Station Units 1 and 2 Response to Notice of Violation inspection Report Nos. 50-456/92017; 50-457/92017 -
NRC Docket Numbers 50-456 and 50 457
Reference:
B. Clayton letter tr C. Reed dated September 18,1992, 3
transmitting NRC Inspection Report 50 456/92017;50 457/92017 of Violation (NOV) which was transmitted with the refere(nce letter and Inspectio, Enclos Report. The NOV cited one Severity Level IV violation and one unresolved item both requiring a written response. The violation concems the failure to convert valve closure devices installed under the Nuclear Work Request Program to Temporary Alterations.
CECO's response is provided in attachment A.-
The unresolved item concerns the control of work which Irivolves systems or components important to safety, but which are not controlled by Limiting Condition for Operating Action Statements. CECO's response is provided in attachment B.
If your staff has any questions or comments concerning this letter, please refer them to Denise Saccomana,o, Compliance Engineer at (708) 5 5 7285.
Sincerely, fhsuw 0&
T.J. Kovach Nucleer Licensing Manager 220040 Attachments-cc:. A. Bert Davis, NRC Regional Administrator Rill t)[L R. Pulsifer, Project Mar,ager - NRR -
f.
S. DuPont, Senior Resident inspector
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ATTACHMENT A RESPONSE TO NOTICE OF VKX.ATION INSPECTION REPORT 50-456/92017; 50-457/92017 VIOLATION (456(457)/92017-03):
Technical Specification 6.8.1 requires that written rocedur9s shall be established, Imps.nented, and maintained coveri the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, ebruary 1978, Braldwood Administrative Procedure (BwAP) 2321 18," Temporary Alterations,"
BwAP 2321 18 states, in part, All tem virary alterations installed in accordance with Exclusion Numbers 1,2, and 4 lisued above must be converted to this procedure if the system / component becomes OPERA 9LE with the temporary alterations still Installed." - Exclusion Number 1 states, in part, f
" repairs /rehacement' troubleshooting of malfunctioning oc ulpment identified on
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l a Nuclear ork Request. This work will be covered by ot 1er administrative controls."
Contrary to the above, following the operability determination made by Site Engineering on August 7,1992, alterations to 1MS019B,2MS019A, and 2MS019C; original y Installed in accordance with Exclusion Number 1, of Braidwood Administrative Procedure (BwAP) 2321 18, were not converted to Temporary Alterations as required by BwAP 2321-18.
REASON FOR THE VIOLAT10N:
Commonwealth Edison (CECO) acknowledges the violation which resulted from the failure to convert the mechanical strongbacks on the referenced MS019 valves to Temporary Alterations. The cause of this event was that Operating, Technical Statt, and Mechanical Maintenance personnel did not classify the Installation of the strongbacks as Temporary Alterations.-
Personnel involved did not recognize that Temporary Alterations were necessary. Usually a Temporary Aiteration is applied in conjunction with an-out of servicu in this case none of the three valves were specifically taken out of service to lnstall the strongbacks; therefore, it was not recognized that the valves were being left in a condition different from their original design.
The procedure that covers the definition and processing of Temporary Alterations was not used by the groups involved.
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ATTACHMENT A (continued)
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
Immediate corrective action was to have Engineering review the strongback installations using Engineering and Construction Procedure, ENC OE-40.1,
" Evaluation and Review of Potontial Design Concerns for Impect on Plant Operability." The installations were determined to be operable. Subsequently, the installations were classified as Temporary Alterations and the appropriate documentation was initiated in accordance with BwAP 2321-18. This was completed on August 28,1992.
CORREC11VE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION:
Additional training will be provided to licensed operators on this event in their next Re ulred Reading Package. This Required Reading Package will be issued b November 15,1992.
Additional training will be provided to the Technical Staff and Mechanical Maintenance departmonts on this event and the current requirements for Temporary Alteration classification. Emphasis will be placed on the use of strongbacks and blocking devices as Temporary Alterations to mechanical devices. This training will be completed by November 15,1992.
Braldwood Station will revise BwAP 2321 18 to clarify that the type of installation described in this event is considered a Temporary Alteration.
Additionally, Braldwood Station will review the scope and wording of the BwAP 2321-18 to ensure that he practices outlined in the procedure meet Station management's expectation. During this review, it will also be determined if these types of installations should continue to be covered by the Temporary 1
Alteration procedure, or by another process. This review will be completed by November 15,1992. Revisione to the procedure will be completed and appropriate training wl!I be conducted by February 28,1993.
DATE WHEN FULL COMPLIANCE WILL DE ACHIEVED:
Full compliance was achieved on August 28,1992, when the three installations
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were accepted as Teraporary A!terations by Onsite Review 92-073 in accordance with procedure BwAP 2321-18,"Tomporary Alterations."
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4 ATTACHMENT B
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RESPONSE TC ONRESOLVED IEM INSPECTK)N REPOHT 50-456/92017; 50457/92017 UNPES3.VED ITEM (456(457)/92017-04):
Tne control of work which involves systems /componer.ts important to safety, but which are not controlled by Limiting Condition for Operation Action Statements is considered a weakness. When the Nuclear Work Request (NWR) was placed on hold for lack of parts, a timely operability assessment was not performed, the job was not listed in the " held section of the station's three day rolling schedule, and the NWR was left on a desk (with the chance that it could be misplaced). This is considered an Unresolved item.
RESPONSE
An operability assessment is normally initiated in accordance with BwAP 33010. "O>erability Determination of Safety Related Equipment," This procedure s used for situations in which an operability determination of a safety related component or system 5 difficuh or uncertain. The rocedure NWR's or states that routine processing of Nuclear Work Requests (Opera lity Equipment Out of-Services should be performed with the Determination procedure in mind.
Specif!cally,in the case of the MS019 valves, three NWR's were written because the valve operators were binding and required excessive force to operate. When the NWR's were processed, an operability assessment was not deemed necessary based on the NWR descriptions. This was appropriate because the scope of the work (Installation of the strongback) was not fully known. Later, after installation of the strongbacks on the MS019 valves, an operability assessment was not immediately performed. The valves were perceived as being operable because they were capable of being closed using the strongbacks. P. ersonnel should have contacted onsits engineering to evaluate the adequacy of the strongback device. This evaluation would have included an operability assessment. A subsequent operability assessment determined the three MS019 valves to be operable.
The NWR's for Installation of the strongbacks were listed in the "hcid" sect!on of the Three Day Rolling Schedule. However, because they were awaiting parts, the NWR's were removed from the Three Day Rolling Schedule and placed on the Parts Backlog - Corrective NWR Report. The NWR's listed in this report are included for discussion in a biweekly Work Planning meeting that addresses NWR's which are waiting for parts. Once the parts ai > received, the NWR's will be placed back on the three day rolling schedule for the work to be perfonned.
While the NWR's ate or ;4rJ, they are in tne possession of the Maintenance personnel responsible w ai9tning parts These NWR's are tracked by the Station computerized Work Request Tracking System which Indicates the history of the NWR's as they are routed from one department to another as well as the current locations of the NWR's.
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.e ATTACHMENT B (continued)
RESPONSE:(continued)
The station's evaluation has determined that the NWR routing would not hav impacted the timeliness of the operability determination. The assessment was delayed because personnel did not reco nize that enginwering should be contacted for an evaluation of the stron ack device. The systems in place adequately maintain control of work wh h involves systems /com;onents important to safety, but which are not controlled by Limiting Conc ition for Operation Action Statements.
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