ML20134M981
| ML20134M981 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/19/1996 |
| From: | Stanley H COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9611260111 | |
| Download: ML20134M981 (7) | |
Text
Q2mmonwcalth liliv>n Gimpany liraidwood Generating Stat'
' Route ol, Ik)x 8 s liraceville, II. 604073Xil9 Tel 8i%158-2H01 November 19,1996 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Reply to Notice of Violation from NRC Inspection Report 50-456(457)/96012 Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-457
Reference:
- 1) LL. Caldwell letter to H.G. Stanley dated October 23,1996, transmitting Notice of Violation from NRC Inspection Report 50-456(457) 96012 Enclosed is Comed's response to the two violations which were transmitted with the letter identified in Reference 1. Both of these cited violations were characterized as Severity level IV and require a written response.
Each of the issues identified in the Notice of Violation have been thoroughly reviewed by Station personnel and appropriate actions are being taken. For example, the Station has been auditing aperture cards in the Control Room to verify they are
- maintained as required. In addition, the Station has been continuing its efforts to improve performance in the procedure adherence area.
The following commitments to the NRC are specified in Attachment 1:
i Control Room aperture cards are being audited against the Controlled Documents e
module.
j Hard copies of P& ids, C&lDs, and key diagrams will be located in the Control Room. A method ofidentifying status will be provided.
Unit 2 RTDBE drawings have been revised and sent to the Central Drawing Facility. They are expected to be returned to Central Files by the end of the year.
I 9611260111 961119 PDR ADOCK 05000456 G
PDR A I!nicom Company
i Document Control Desk Pags 2 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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. Gene tanley Site Vice President Braidwood Station HGS /fb
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A.B. Beach, NRC Regional Administrator, Region III R.R. Assa, Project Manager, NRR i
C.J. Phillips, Senior Resident Inspector F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS l
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ATTACIIMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-457/96012-02a) 1.
10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedurcs, and Drawings," requires that activities affecting quality be prescribed by documented instmetions, procedures, or drawings, of a type appropriate to the circumstances, and be accomplished in accordance with these instructions, procedures, or drawings.
A.
Braidwood Operations Procedure 2BwOS 8.1.1.2.a-2, "2B DG Operability Monthly (Staggered) And Semi-annual (Staggered) Surveillance," steps F.9.7 through F.9.9, required, in part, independent verification of the position of the 2B cmergency diesel generator (DG) day tank instrument leg drain valve,2DO2116B, the 2B DG starting air receiver drain valves, 2SA147B/D, and the 2B DG starting air separator drain valves,2SA14IB/D.
Contrary to the above, on August 21,1996, the diesel operators did not independently verify the position of valves 2D02116B,2SA147B/D, and 2SA141B/D as required by Surveillance Procedure 2BwOS 8.1.1.2.a-2, "2B DG Operability Monthly (Staggered) and Semi-annual (Staggered) Surveillance," steps F.9.7 through F.9.9 (50-457/96012-02a).
R!!ASON FOR THE VIOLATION:
An operator involved in the surveillance did not properly self check or verify the EPNs of the valves to be verified. These actions do not support the Station's expectations regarding Independent Verifications.
CORRECTIVE ACTIONS TAKEN' AND RESULTS ACHIEVED:
i The individual who did not properly perform the independent verification was counselled in accordance with Station policy.
Tailgates were given to Operations personnel on independent verifications. These tailgates were completed by September 12,1996, and covered the requirements specified in BwAP 100-18, "'iraidwood Station Independent Verification Procedure." The Station's expectations on procedure adherence, ".ain#ng proper questioning attitudes, and self checking when performing duties were also discussed during the sessions. In addition, the importance of having operators actually place their lumd on a valve to verify position was communicated.
CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID FUTURE VIOLATION:
BwAP 100-18 was resised and formally approved by September 30,1996. The intent of this revision was to clarify sections of the procedure, including more clearly defining " apart in time" and " apart in action" independent verifications.
Cycle 96-05 of non-licensed operator requalification training included a lecture on BwAP 100-18.
The Training Department conducted " hands on" training for the operators as another means of communicating how field valve verifications are to be performed. This training was donc using a valve mock-up and was completed in mid-October.
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A'ITACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-457/96012-02a)
Operators were taken in the field with their supervisors to perform field valve verifications. The intent of this activity was to ensure that operators meet the Station's expectations when performing field verifications.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
t Full compliance was achieved when the individual who improperly performed the independent verification was 2
counselled for his actions.
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VIOLATION (50-457/%012-02b) l.
10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type j
appropriate to the circumstances, and be accomplished in accordance with these instructions, j
procedures, or drawings.
B.
Braidwood Administrative Procedure, BwAP 1340-1, " Drawings issued Procedure," Resision 10, states, in part, timt drawing sets (piping and instrumentation diagrams (P&lDs) or l.
electrical schematics) which are issued and maintained current through Central File are l
marked as " AUTHORIZED FOR USE."
1 i
Braidwood Administrative Procedure, BwAP 330-1, " Conduct of Operations," Revision 18, requires, in part, that only controlled, approved documents, such as P& ids and selected schematics, are to be used by shift operating personnel to conduct operations, and that these documents are maintained current by being stamped " REVISION PENDING" where i
outstanding revisions of the drawing exist.
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Contrary to the above, as of August 8,1996, P&lDs and electrical schematics that were I
marked " AUTHORIZED FOR USE" and used by shill operating personnel in the control room had outstanding revisions and were not stamped " REVISION PENDING" as required (50-457/%012-02b).
3 REASON FOR THE VIOLATION:
l On August 8,1996, Station personnel were troubleshooting a channel failure and noticed that the aperture cards in the Control Room were not revised to reflect the as-built configuration of the plant as a result of the j
changes from the Resistance Temperature Detector Bypass Elimination (RTDBE) modification.
The differences between the loop schematic drawing and the actual plant conditions were r.oticed when Instrument Maintenance technicians determined a different card had failed than the one that Operating personnel had 1
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-ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION i
VIOLATION (50-457/96012-Qjtl 1
determined to have caused the channel failure. It was also id ntified that the P& ids were not revised, yet the Instrument Maintenance troubleshooting appendix had been updated to reficct the RTDBE modification.
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All" AUTHORIZED FOR USE" drawings are issued from Central Files where pending revisions to drawings are maintained.
ShiA personnel obtained the drawings used for their troubleshooting activities from the i
Control Room. Although these drawings are maintained current, they are to be used "FOR REFERENCE" only j
because the status of pending revisions have not been identified on the drawings. In this case, the RTDBE modifications had not yet been incorporated on the approved design drawings. The Operators did not ensure i
with Central Files or the Electronic Work Control System (EWCS) that the drawings used reficcted the most i
current conditions. The individuals assumed that the Control Room aperture card set contained current plant j
drawings.
j At the time of the event, there was a large backlog of drawing changes from the RTDBE modifications which needed to be updated. This backlog was due to the unavailability of drafling personnel and the time required to j
convert the manually marked up drawings to the computer drafted format.
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CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
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Additional designers were assigned the task of revising RTDBE drawings. All Unit 1 RTDBE drawings have i
been resised, processed by the Central Drawing Facility, and returned to Central Files. Unit 2 RTDBE drawings have been resised and sent to the Central Drawing Facility. They are expected to be returned to i.
Central Files by the end of the year, i
I Engineering has initiated a monthly drawing status report that identifies the number of outstanding drawing i
changes. This report can be used by engineering and station management to identify any delays in drawing
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incorporation. Also, a report is generated for personnel in the Shift Ollice and Central Files. This report specifies outstanding pending resisions on drawings.
A tailgate session was held with Operating crews on BwAP 1340-1," Drawings issued Procedure," to ensure j
that operators understand the use of the aperture card set in the Control Room. The tailgates were completed j
by September 27,19%.
j Presently, Control Room aperture cards contain the current approved revision of drawings and are classified j
"FOR REFERENCE." These drawings do not reflect any pending resisions to the drawings, such as design
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changes or drawing change requests (DCRs). Only " AUTHORIZED FOR USE" drawings issued by Central Files personnel may be used to perform safety related work, including troubleshooting. As an interim measure, f
Central Files is open 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day,7 days a week to support drawing issuance at all times.
CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID FUTURE VIOLATION:
Control Room aperture cards are being audited against the Controlled Documents module and discrepancies are being resolved.
Hard copies of P&lDs, C&lDs, and key diagrams will also be located in the Control Room. A method of identifying status will be provided.
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-457/96012-02b)
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Braidwood Station is in compliance in this area since only " AUTHORIZED FOR USE" drawings issued from Central Files may be used :o perform work.
VIOLATION (50-457/96012-04) 2.
10 CFR 50, Appendix B, Criterion II, " Quality Assurance," requires, in part, that actisities affecting quality shall be accomplished under suitably controlled conditions.
Surveillance testing required by technical specifications 4.8.1.1.2 to verify operability of the di;sel generator is an activity affecting quality.
Contrary to the above, on numerous occasions, including July 31, 1996, technical specification Surveillance IBwOS 8.1.1.2-a.1, "lA Diesel Generator Operability Monthly (Staggered) And Semi-Annual (Staggered) Surveillance," was not conducted under suitable conditions in that diesel generator sersice water valve ISX169A was manually exercised per the surveillance procedure prior to the start of the dicsci generator. ISX169A is required to open automatically upon the diesel generator start to ensure operability of the diesel engine (50-456/96012-04).
REASON FOR THE VIOLATION:
Operations and System Engineering personnel did not believe that stroking the ISX169A valve prior to starting up the diesel generator was considered preconditioning. Cycling of this valve was instituted as part of the original procedure, BwOP DG-11, " Diesel Generator Startup." The reason for cycling this valve was to verify proper cooling water flow was available to the diesel generator prior to engine startup and to verify annunciator operability status during the valve stroke (stroking the valve for this purpose was included as an internal Station commitment as a result of a failure of the IB DG on December 4,1989).
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVEDj Procedure resisions (1/2 BwCS 8.1.1.2.a-1,1/2 BwOS 8.1.1.2.a-2) were completed and copics were advanced to Central Files and the Shift office on October 29,1996. The steps to stroke the _SX169_ valve were removed l
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-457/96012-04) from each of the surveillance procedures. As a result of the removal of these steps, System Engineering has identified an alternate method of verifying annunciator operability during performance of BwOP DG-11.
CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID FUTURE VIOLATION:
The Station has determined that the removal of the requirement to stroke the _SX169_ valve from each of the Diesel Generator Operability Monthly (Staggered) and Semi-Annual (Staggered) Surveillances should be sufficient to prevent recurrence of this preconditioning violation.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance for this violation was achieved on October 29,1996, when the Diesel Generator Operability Monthly (Staggered) and Semi-Annual (Staggered) Surveillances were revised to remove the requirement to stroke the _SX169_ valve.
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