ML20138F612
| ML20138F612 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/28/1997 |
| From: | Stanley H COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-456-96-16, 50-457-96-16, NUDOCS 9705060014 | |
| Download: ML20138F612 (3) | |
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Commonwealth 1.diwn C<nnpany liraidw ood Generating Station Route *l, Box 84 i
Ilrwesille. Il Nh07%19 rcl HI%1SM 2M01 April 28,1997 Document Control Desk U.S. Nuclear Regulatoly Commission Washington, D.C. 20555
Subject:
Reply to Notice of Violation NRC Inspection Report 50-456(457)/96016 Braidwood Nuclear PowerStation Units 1 and 2 NRC Docket Numbers 50-456 and 50-457
Reference:
G. E. Grant lettdto H.G. Stanley dated March 31,1997, transmitting
,, Notice of Viciation from NRC Inspection Report 50-456(457)/96016 The Inspection Rcport referenced e.bove contains details from a Fire Protection Inspection which began in October,1996. A Notice of Violation was transmitted with this report and included one Severity Level IV violation associated with hot work permit usage.
Braidwood recognizes the safety significance related to fire protection issues, including the use of hot work permits. Although Maintenance and Construction personnel did not j
satisfy Station expectations related to adhering to the administrative requirements for hot work permits, workers did satisfy expectations related to safety. Revisions to the hot l
work procedure and permit are expected to resolve the identified administrative concerns.
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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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ene Stanley ite Vice Presiden l
Braidwood Nuclear Generating Station Attachment
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cc:
A.B. Beach, NRC Regional Administrator, Region III
.F. Dick, Jr., Project Manager, NRR a ~ ^i ' +1 0 '1
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- C.J. Phillips, Senior Resident Inspector I
F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS
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ATTACHMENT I
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REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/96016-05)
Braidwood Technical Specification 6.8.1.a requires, in part, that procedures be l
established, implemented, and maintained for activities covered in Appendix A of l
Appendix A of Regulatory Guide 1.33 included fire protection program mplementation.
Braidwood Procedure (BwAP) 1100-15, " Fire Prevention When Welding, Cutting, Grinding, or Performing Open Flame Work (liot Work)," Revision 6, dated July 8, 1996, requires that applicable portions of the hot work permit be filled out and signed prior to work.
Contrary to the above, from January 16 to September 26,1996, applicable portions of numerous Braidwood Station Hot Work Permits were not filled out as required by BwAP 1100-15.
REASON FOR THE VIOLATION During an inspection of the Fire Protection Program, it was determined that hfaintenance /
Construction personnel did not always complete hot work permits in accordance with the procedure, BwAP 1100-15, " Fire Prevention when Welding, Cutting, Grinding, or Performing Open Flame Work (Hot Work)." This procedure allowed supervisors in charge of work to determine which precautions were applicable.
These individuals understood the safety significance of working on jobs requiring hot work permits, however they found the hot work permit process to be cumbersome and did not recognize the importance of filling out all of the information on the permit. As a result, some of the permits did not satisfy the procedure requirements.
l CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The problem was identified during an evaluation of hot work permits that were completed l
between hiay and October,1996. The permits were individually reviewed and most of the i
noncompliances were found to be administrative in nature and none would have impacted the safety in the plant. The Fire hfarshal discussed the problem with hiaintenance Supervision.
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ATTACIIMENT 1 y
REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/96016-05)
ACTIONS TAKEN TO PREVENT RECURRENCE BwAP 1100-15 was revised to clarify the requirements associated with using hot work permits. In particular, worker responsibilities are more clearly delineated. In addition to the procedure, the hot work permit (BwAP 1100-15Tl) was also revised.
Maintenance and Constmetion personnel have been trained on the requirements associated with properly completing hot work permits.
Station personnel attended awareness sessions where Station expectations related to procedure adherence were communicated.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Compliance was achieved once BwAP 1100-15 and the associated hot work permit were revised and appropriate personnel were trained on these revisions.
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