ML20147C781

Responds to NRC Re Violation Noted in Insp Rept 50-456/87-42.Corrective Actions:Surveillance Requirement Added to Program for Station Training Dept to Verify & Update Personnel Who Qualify for 10CFR55 Exemption

ML20147C781
Person / Time
Site:	Braidwood
Issue date:	01/11/1988
From:	Butterfield L COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
4084K, NUDOCS 8801190339
Download: ML20147C781 (5)

Text

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/ N Commonwealth Edison

) One First National Plaza. Chica0o, Illinois oc o kONy} Address Reply to: Post Omco Box 767 Chicago,lilinois 60690 0767 January 11, 1988 Mr. P. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Station Unit 1 Response to Inspection Report No.

50-456/87-042 NRC Docket No. 50-456 Reference (a): W. L. Forney letter to C. Reed dated December 14, 1987

Dear Mr. Davis:

This letter in in response to the inspection conducted by Messrs.

T. M. Tongue and T. E. Taylor from October 25 through December 1, 1987 of activities at Braidwood Station. Reference (a) indicated that certain activities appeared to be in violation of NRC requirements. The Conunoawealth Edison Company response to the Notice of Viol ^ation is provided in the enclosure.

If you have any further questions on this matter, please direct them to this office.

Very truly yours, t L. D. Butterfield Nuclear Licensing Manager Enclosure cc: NRC Resident Inspector - Braidwood NRC Document Control Desk g i I L 4084K 8801190339 880111 MI4 N PDR ADOCK 050 g 6 0

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-s ENCLOSURE Commonwealth Edison Company Response to Inspection Report 456/87-042 Viola _ tion (456/87-042-01) 10'CFR 50.54(i)_ states, "Except as provided in 55.13 of this chapter, the licensee may not permit the manipulation of the controls of any facility by anyone who is not a licensed operator or senior operator as provided in part 55 of this chapter."

10 CFR 55.13, "General exemptions," states, "The regulations of this part do not require a license for an individual who -

"(a) Under the direction and in the presence of a licensed operator or senior operator, manipulates the controls of -

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"(2) A facility as part of the individual's training in a facility licensco's training program as approved by the Commission to qualify for an operator license under this part." ,

10 CPR 55.53, "conditions of licenses," states, "Each license contains and is subject to the following conditions whether stated in the license or not:

"(a) Neither the license nor any right under the license may be assigned or otherwise transferred.

"(b) The license is limited to the facility for which it is issued."

Contrary to the above, on September 20, 1987, an individual holding a senior operator license on a similar facility and not participating in an approved training program was allowed to manipulate the controls of (and thereby make reactivity changes to) the Braidwood Unit I reactor. At the time, the reactor was in Mode 1 and at 34% power.

Response

Braidwood Station acknowledges that the reactivity changes, identified in the violation, did occur.

On July 27, 1987, an individual from another utility was assigned to Braidwood Station for six weeks of observation training as part of the hot participation program. This training program was completed on September 4, 1987. On September 20, 1987, another individual from the same utility specifically requested to perform two reactivity changes for training. This request was made of the two Nuclear Station Operators (NSO) assigned to Unit One. The individual in question, under the direct supervision of the NSO's, performed the following activities:

1. At 2200 the individual changed reactivity by placing rod control in manual with rods at 204 steps on Bank "D". Using the in-hold-out switch, he stepped Bank "D" rods out to 210 ateps.

2. Starting at approximately 2200, the individual initiated a 100 gallon dilution by setting the pure water batch integrator for 100 gallons. At 2235 the dilution was completed.

The NSO, assigned to the Unit for this period, signed and dated the individual's training plant evolutions, observed log sheet. This log sheet was the exact same form as that used by the July through September authorized trainee.

On October 1, 1987, as a result of an event at another station where controls which directly affect reactor power were manipulated by an individual :.at authorized by NRC regulations, Nuclear Operations Division issued a letter defining tha personnel allowed to manipulate the reactor controls.

On October 19, 1987, the utility for the individual cited, telecopied the log sheet containing the reactivity changes discussed above.

This was received by Braidwood Station Operating Management where an initial review of the log sheet was conducted. Based on this review, it was felt that no problem existed since the individual involved held a current Senior Reactor Operator (SRO) license.

On October 20, 1987, the information contained in the log sheet was reviewed by additional management personnel and once again the consensus was that no problem existed as the individual held a current Senior Reactor Operator license and that corrective action for this type of event was put in place based on the October 1, 1987, transmittal from Nuclear Operations Division.

On October 23, 1987, late in the afternoon, after the item came to the attention of the Station Manager, it was determined that a formal review of the evolution was warranted. A preliminary review indicated that the individual involved in the event was believed to have been an authorized trainee. Based on this finding, it was decided that additional review could wait until Monday October 26, 1987, as no approved guidelines and regulations appeared to have been exceeded.

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On October 26, 1987, as a part of this additional review, separate interviews with the NSOs were conducted without prior notice. The results of the interviews indicated that the event occurred as described above. The action by the individual in question seemed to be appropriate and consistent with their own training, and prior observation training program involvement.

On october 27, 1987, following verification of the above information, the resident inspector was informed. A delay of eight days was  ;

cited in the base inspection report from receipt of the information l regarding the evolution, to informing the Resident Inspector. The sequence of actions taken from the date of discovery of the evolution to formal discussions with the Resident Inspector has been delineated above and should address this concern. Once the problem was fully identified and verified, the Resident Inspector was informed of the fact that the evolution had taken place. Additional investigation failed to identify any other instances of unauthorized manipulations of the reactor controls.

The Station Control Room Engineer (SCRE) was not interviewed until October 30, 1987, as it was evident that he was not involved with the event. The results of the october 30th interview verified this conclusion.

Corrective Action Taken and Results Achieved The corrective actions taken were:

1. A letter was issued on October 1, 1987, from Nuclear Operations Division defining personnel allowed to manipulate the reactor controls. This letter was reviewed with licensed shift personnel.

2. The Station Training Department issued a letter on October 28, 1987, specifying by name the individuals in license training who currently qualify for the exemption described in 10 CPR 55. A copy of this letter is available to control Room personnel.

There have been no other cases of reactor control manipulations by unauthorized individuals prior to or since the above isolated event. There is no safety significance to this event, as it occurred, because the actions were accomplished under the direct supervision of a licensed operator and the evolutions were performed utilizing Station approved procedures.

Corrective Action Taken to Avoid Further Violation Effective January 11, 1988, a surveillance requirement was added to the station General surveillance program for the Station Training Department, to verify and update, as necessary, the letter specifying the personnel who qualify for the 10 CFR 55 exemption.

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There are no personnel at Braidwood Station, currently from another utility, partic.ating in the six week observation training program and there are none scheduled to participate.

Date of Full Compliance Full compliance was achieved on January 11, 1988.

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