ML20134D209
| ML20134D209 | |
| Person / Time | |
|---|---|
| Site: | Braidwood |
| Issue date: | 01/21/1997 |
| From: | Stanley H COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9702050023 | |
| Download: ML20134D209 (3) | |
Text
Commonwealth liliwn Company O
Ilraidwood Generating Station Route 01, llox Hi liraceville, 11. 60 4073>619 Tel HI 4458-280I i
l January 21,1997 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Reply to a Notice of Violation from Inspection Report 50-456(457)/96014 Braidwood Nuclear Power Station Units I and 2 NRC Docket Numbers 50-456 and 50-457 l
References:
- 1) J. L. Calduell letter to H. G. Stanley dated January 3,1997, transmitting
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Notice of Violation from NRC Inspection Report 50-456(457)/96014 1
Reference I contains the Severity Level IV Notice of Violation (NOV) identified during a six week inspection period that took place from September 6 - October 18, 1996. Comed's response to this NOV is included in Attachment 1.
j Braidwood Station is aware and actively pursuing the resolution of identified problems associated with procedmes. In the situation described in the cited NOV, a Unit Supervisor was preparing for upcoming surveillances ahead of time by reviewing them and marking up applicable sections. This j
action is encouraged so our workers can execute their tasks in a controlled and deliberate manner. In this case, the surveillances were updated and put in the control room books and files shortly after the 1
execution copy of the procedure was obtained for use in the field. As a result, the wrong revision was used. The process ofinforming the Shift has been modified and the mechanism has been discussed with the appropriate Operations personnel.
If your staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801, extension 2980.
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- 1. Gene Stanley Site Vice President Braidwood Station HGS /fb/wcow a I
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Attachment cc:
A. B. Beach, NRC Regional Administrator -Rill R. R. Assa, Project Manager - NRR C. J. Phillips, Senior Resident inspector F. Niziolck, Division of Engineering, Oflice of Nuclear Safety -IDNS 9702050023 970121 PDR ADOCK 05000456 G
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1 ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456/457/96014-01) 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above on September 10,1996, operations personnel in the control room were perfomiing IBwOS 8.1.1.2.a-2, " Unit One IB Diesel Generator Operability Monthly (Staggered) and Semi-annual (Staggered) Surveillance," Revision 15 dated September 9,1996.
The inspectors observed that the non-licensed operator in the, Msel generator room was using IBwOS 8.1.1.2.a-2, Revision 14El dated June 28, 1996, wah was inappropriate for the circumstances.
This is a Severity Level IV violation (Supplement 1) (50-456/96014-01).
REASON FOR THE VIOLATION:
The wrong revision of IBwOS 8.1.1.2.a-2, ' Unit One IB Diesel Generator Operability Monthly (Staggered) and Semi-annual (Staggered) Surveillance" was used was because clerical personnel updated the surveillances in both procedure books and files in the control room as well as in Central Files after the Unit Supenisor had pulled the surveillances to review them and mark up applicable sections.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
During the surveillance, the NSO running the diesel generator contacted the Unit Supenisor at step f.5 of IBwOP DG-ll (the surveillance procedure used in conjunction with IBwOS 8.1.1.2.a-2 to perform the IB diesel generator monthly surveillance). It was determined at that point that a discrepancy existed betweca the two procedures and efforts were made to contac*
the appropriate System Engineering personnel to resolve the conflict. As this was going on, the visiting NRC inspector questioned the operator in the diesel room about the procedure revision and it was detenninca that the wrong revision was being used in the field.
Upon the discovery of the wrong revision, the Unit Supervisor retrieved a copy of the newer revision (Rev.15) and dispatched a copy to the IB Diesel Generator room. In addition, the Shift Engineer was contacted. After a comparison between the two revisions was done, the duty Shifl Engineer and oncoming Shift Engineer agreed to continue with the surveillance and cransfer all applicable steps to the newer revision. The surveillance was ultimately completed satisfactorily.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATION:
A mechanism is in place to prevent this situation from recurring. Each day, the Office Support Clerk provides a list of all procedure transmittats to the appropriate Unit Supervisor (in the past, the transmittals were given to the Shift Engineer) These transmittals infonn the Shift of procedure / surveillance updates. Discussions have been held with the appropriate Operations 1
i ATTACHMENT I REPLY TO NOTICE OF VIOLATION 1
VIOLATION (50-456/457/96014-0l) personnel to enhance their awareness of the transmittal update process. In addition, guidance.
on providing this information has been included in the Shift Clerk's job notes maintained for that position.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED:
i Full compliance for this violation was achieved when the outdated revision was removed from use.
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