ML20138G003
| ML20138G003 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/24/1997 |
| From: | Stanley H COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-456-97-02, 50-456-97-2, 50-457-97-02, 50-457-97-2, NUDOCS 9705060123 | |
| Download: ML20138G003 (8) | |
Text
Commonwealth fidimn Company
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liraidwoml Generating Station Rourc al, llox H i firaco ille, IL 60 6073X,19
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e Tel H10i584801 April 24,1997 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Reply to Notice of Violation NRC Inspection Report 50-456(457)/97002 Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-457
Reference:
J.L. Caldwell letter to H.G. Stanley dated March 28,1997, transmitting i
Notice of Violation from N~RC Inspection Report 50-456(457)/97002 The referenced inspection report summarizes observations made during a six week inspection period that ended on February 21, 1997. During this inspection period, two violations were identified.
Comed's response to these violations is included in the attachment to this letter.
The corrective action process at Braidwood has undergone several changes in the last year to improve its effectiveness. Senior station management has taken a more active role in the screening and assignment ofissues, and the fmal resolution is reviewed and approved i
by the station PORC committee. This increased involvement demonstrates strong senior management support for the corrective action process, and helps to ensure line ownership of the issues requiring resolution.
2 A key improvement initiated in mid 1996 was the assignment of effectiveness reviews for those corrective actions resulting from a root cause investigation. Given the time required for the investigation, identification and approval of corrective actions to prevent recurrence, and final implementation, the efTectiveness reviews assigned in 1996 are beginning to come due. As this process continues, it is expected that the response to corrective actions found to be ineffective will ultimately be successful in addressing the root causes ofidentified problems at Braidwood.
j In addition, a set of performance metrics has been developed for use by all stations to monitor the effectiveness of the Corrective Action Program. Among others, these metrics include monitoring the identification of problems requiring resolution, number of outstanding corrective actions, timeliness of corrective action completion, and number of repeat occurrences. Monitoring and responding to theses performance measures will ensure that the effectiveness of the corrective action process can continue to be improved.
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t Documen1. Control Desk Pace 2 The following commitments are included in the attached response:
Radiation Protection is developing policies or procedures related to instrument signout and i
Radiologically Protected Area (RPA) set-up/ removal.
The Radiation Protection and Operating Departments are perfomiing tailgates to remind personnel of the expectations associated with hose usage.
If your staff has any questions or comments concerning this letter, please refer them to i
Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801, l
extension 2980.
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I. Gene Stanley ite Vice Preside 1
Braidwood Nuclear Generating Station Attachment cc:
A.B. Beach, NRC Regional Administrator, Region III G.F. Dick, Jr., Project Manager, NRR C.J. Phillips, Senior Resident Inspector F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS l
i o:confid\\siterp\\corresp\\ l 997\\97037. doc i
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grfACHMENT1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97002-01) 1.
10 CFR Part 50, Appendix B, Criteria XVI, Corrective Actions, requires that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, defective material and equipment, and nonconformances are promptly 1
identified and corrected. In the case of significant conditions adverse to quality, the j
measures shall assure that the cause of the condition is determined and corrective action i
taken to preclude repetition.
Licensee Event Report (LER)96-001, " Inadequate Control of Staged Roofing Materials Leads to a Loss of Offsite Power due to a Loss of Both Unit 2 Station Auxiliary Transformers,"
and the licensee's response to NRC violation 96002-01 provided corrective actions to be taken at the Braidwood station to prevent recurrence of conditions that caused the loss of offsite power on January 18,1996. The following corrective action was listed in LER 96-001: "To prevent recurrence of staged construction materials from blowing off the roof, materials staged on the roof will be limited to materials that will not blow ofTthe roof, such as buckets of tar, etc. Materials that could potentially blow off the roof will be staged en the roof daily for the work to be performed that day or stored in an area that will prevent them from being blown off."
Contrary to the above, corrective actions to LER 96-001 were not adequate to preclude repetition. Specifically, on Febmary 19,1997, and on February 20,1997, materials that could potentially blow off the roof were found on the auxiliary building roof and fuel handling building roof and were not stored in an area that would prevent them from being blown ofL REASON FOR THE VIOLATION As a result of problems encountered during roofing activities in January,1996, corrective actions were put in place to minimize the potential of having materials blow off the roof. Construction materials staged on the roof would be limited to materials that would not blow off the roof, and materials that could blow off would be staged on the roof daily for work to be performed that day j
or stored in an area that would prevent them from blowing off. During the more recent roofing activities where work was being done on the Auxiliary Building and Fuel Handling Building roofs, tooling and a minimal supply of roofing materials were staged on the roof with tarps placed over the material. These measures were taken to secure the area for work, while minimizing the amount of material on the roof. Efrorts had been taken to prevent items from blowing off the roof, including installing fencing next to the roof edge.
During mid-shift on February 3,1997, roofing work was suspended due to inclement weather conditions and concerns raised by Chemistry personnel about fumes generated as a result of the l
rooting activities.
On February 19,1997, pieces ofinsulation were found on the ground. This material was cleaned up and dumpsters in the area were covered with tarps since it was believed the loose insulation material came from there. The next day, the concern regarding the inadequate housekeeping on the roofs was identified. It is believed the Auxiliary Building / Fuel Handling Building roofs were left 1
l ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97002-0l) in this condition when the job was suspended earlier in the month. Management did not
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aggressively monitor the roofmg contractor's work activities. As a result, the Station was unaware that the contractors had lea the roofin a substandard condition.
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L CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED 1
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' After. the concern regarding the debris on the Auxiliary / Fuel Handling Building roofs was l
identified, the Construction Superintendent, Field Engineer and a Shift Manager immediately i
inspected the roofs. In addition, the Station Manager and the Construction Superintendent inspected the areas later that same day. Based on the conditions observed, the contractor, j
Crowther Enterprises, was contacted and arrived on site that afternoon. Immediately following l
their arrival, clean up and securing of materials and tools was initiated for both roofs. All loose j
materials were disposed of and clean up was completed on February 20,1997.
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I CORRECTIVE ACTIONS TO PREVENT RECURRENCE Due to the sensitivity of this event and the additional roofing projects that are scheduled for the l
balance of 1997, the Constmetion Superintendent has assigned the Facility Maintenance Lead j
Supenisor to provide additional oversight on all roofing projects. Presemly, the responsible Field Engineer and the Facility Maintenance Lead Supervisor are conducting daily unannounced inspections to assure that tools / materials are secured and proper housekeeping is maintained.
l On February 21,1997, the owner of Crowther Enterprises met with the responsible Field Engineer and discussed concerns associated with the potential for materials to blow off the roof, housekeeping, and safety. The owner pledged to enhance all efforts associated with the roofing activities and appointed a full time General Manager to the project. This individual is responsible for ensuring that all expectations and requirements are met and to oversee Crowther's Field Superintendent. The project did not resume until February 24,1997, when the Crowther's General Manager arrived on site.
i A briefing was held with the entire Crowther roofing crew to reinforce Braidwood's expectations.
This briefing was held with the responsible Field Engineer and the Facility Maintenance Lead Supervisor. The discussion covered the event documented in LER 96-001-00 and the associated corrective actions. In addition, the consequences of failure to comply with the site requirements was clearly stated.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when the de,bris was removed from the roofs and actions were taken to enhance the level of management oversight for the roofing project.
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i ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97002-02) i 2.
Technical Specification 6.8.1.a, states that procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, " Quality Assurance Program Requirements," Revision 2, February 1978.
Procedures for contamination control and procedures for radiation monitor calibrations are specified in Regulatory Guide 1.33.
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Braidwood Procedure, BwAP 575-2, Hose Identification, states, m part, "It may be necessary, in certain situations, to run a hose across a contaminated / clean area 1
boundary.
In a situation such as this, steps must be taken in order to avoid l
contaminating the clean area."
Contrary to the above, a green hose was found in a radiologically posted contaminated area located in Unit 2 turbine building around OPRIOJ, station l
l blowdown radiation monitor, on February 14,1997. The same green hose crossed the contaminated area boundary from a radiologically clean area and no measures 4
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were in effect to secure the hose in order to prevent the spread of contamination.
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REASON FOR THE VIOLATION OPRIOJ is the Station Blowdown Process Radiation Monitor located in the Unit 2 Condensate Pit in the Turbine Building. The area surrounding the OPRIOJ radiation monitor is not normally a.
contaminated area. A green hose is normally present for use in flushing the radiation monitor. At the time of the violation, the area had been temporarily set up as a contaminated area for maintenance work on the radiation monitor.
It is not known whether the Radiologically Protected Area (RPA) was set up with the green hose inside or whether the green hose was moved into the area after it had been set up as a RPA. While it cannot be readily determined how the problem occurred, it is apparent that at least one person from Operating or Radiation Protection was unaware of the procedure requirements for hose use.
This resulted in the procedure violation.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED Radiation Protection frisked the hose to check for contamination and removed the hose from the area. Since that time, the area has been decontaminated and is no longer a RPA.
CORRECTIVE ACTIONS TO PREVENT RECURRENCE The Operating Department is performing a tailgate on the event to remind Operations personnel of the expectations associated with hose usage.
The Radiation Protection Department sent out tailgate material on requirements associated with hose usage to all RP personnel.
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97002-02)
Radiation Protection is updating a checklist used when a RPA is established. A step is being added to the checklist requiring individuals to look for any hoses in the area as the RPA is being set up.
As a result of the unusual circumstances associated with the OPRIOJ radiation monitor, the Station will continue to evaluate additional long term corrective actions.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when the hose was frisked and removed from the contaminated area.
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION l
VIOLATION (50-456(457)/97002-02) b)
Braidwood Procedure, BURP $800-6, Administrative Controls for Health Physics
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Instrumentation, states, in part, "out-of-calibration instrumentation shall be stored and segregated to prevent inadvertent usage."
j Contrary to the above, an out-of-calibration radiation detector, model PRM-6, Braidwood Radiation Protection (RP) identification number 1355, was found in the plant at the radiologically posted contaminated area located in Unit 2 turbine building around OPRIOJ, station blowdown radiation monitor, on February 14, 1997. The posted calibration due date on the PRM-6 monitor was January 31,
- 1997, REASON FOR THE VIOLATION The individuals involved in this procedure adherence violation did not satisfy the Station's expectations associated with instrument signout and set up of a Radiologically Posted Area (RPA).
When setting up the RPA for maintenance on the OPRIOJ Radiation Monitor, the Radiation Protection Technician (RPT) did not sign out the GM Frisker using the instrument tracking program. Failure to log these instruments makes retrieval difficult when calibrations come due.
Some technicians found the process of signing out instruments time consuming and did not always
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comply with management expectations. In addition to not properly logging out the frisker, the RPT also did not request the Radiation Protection Supervisor to put the frisker or the newly created RPA on a daily checklist to ensure daily source checks would be performed. It was determined
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that neither the process of checking out instruments or adding information to the daily checklist was formalized in RP department policies or procedures.
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CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED Immediate corrective actions included removing the instrument from service and returning it to the calibration facility. The instrument was calibrated and all ranges were found acceptable and required no repairs. Shortly after the instrument was removed, the area was surveyed and deposted by Radiation Protection personnel.
l RP personnel were informed of this violation and re-trained on management expectations.
CORRECTIVE ACTIONS TO PREVENT RECURRENCE The logon to the instrument tracking program was modified, allowing the system to run continuously, This was done in response to Radiation Protection Technician's concerns that signing into the system is slow.
A process goveming instrument signout has been developed to simplify the method for signing out instruments. In addition, a process related to RPA set-up/ removal was developed to provide 5
ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97002-02) guidance and a checklist. These processes will be fonnalized in Radiation Protection policies or procedures.
DATE WHEN COMPLIANCE WAS ACHIEVED Full compliance was achieved when the frisker was removed from use.
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