ML20148H663

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-456/96-16 & 50-457/96-16 Issued on 970331.Corrective Actions Will Be Reviewed During Future Insps
ML20148H663
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 06/06/1997
From: Grobe J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Stanley H
COMMONWEALTH EDISON CO.
References
50-456-96-16, 50-457-96-16, EA-97-110, NUDOCS 9706110017
Download: ML20148H663 (3)


See also: IR 05000456/1996016

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                                                           June 6, 1997                                                          l
     Mr. H. G. Stanley
     Site Vice President
     Braidwood Nuclear Power Station                                                                                             '
     Commonwealth Edison Company
     R.R. #1, Box 84                                                                                                              i
     Braceville,IL 60407
     SUBJECT:           NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-456/96016(DRS);
                        50-457/96016(DRS))
     Dear Mr. Stanley:                                                                                                            ,
                                                                                                                                 l
              This will acknowledge receipt of your April 28,1997 letter in response to our
     March 31,1997 letter transmitting a Notice of Violation associated with the above
     mentioned inspection report. This report summarized the results of the fire protection
                                                                                                                                 ,
     inspection at your Braidwood Plant. We have reviewed your corrective actions and have
     no further questions at this time. These corrective actions will be examined during future
     inspections.
                                                        Sincerely,
                                                        /s/ J. A. Grobe                                                          ,
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                                     "
 9706110017 970606                                      John A. Grobe, A-ting Director                                           ;
 gDR   ADOCK 0500              6                        Division of Reactor Safety
     Docket No. 50-456
                                                                                                                            (
     Docket No. 50-457                       11000u-                                                                           (
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     Enclosure:         Ltr dtd 04/28/97, H. G. Stanley,
                          Comed, to US NRC w/ encl                                {{\,\hf\hlk}llhk!,!!! i, i
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     See Attached Distribution
                                           SEE ATTACHED CONCURRENCE _S
     DOCUMENT NAME: G:                                                                                                           !
     To receive a copy of this document, indicate in the box "C" = Copy w/o attach /enct T = Copy w/ attach /erycl *N' = No copy
        OFFICE        Rlli:DRS                   Rill:DRS          l      Rill:DRP              l    ./ fl@{tS JV
        NAME          Schrum/kjc                 Westberg                 Lanksbury                  J $ $ (6r/Grobe
     ]] DATE         06/ /97                     06/      /97             06/      /97                9 6/,{   /9 A/             !
                                                  OFFICIAL RECOR D COPY                               /'                         :
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                EA 97-110
                Mr. H. G'. Stanley
                Site Vice President
                Braidwood Nuclear Power Station
                Commonwealth Edison Company                                                                                                            ;
                R.R. #1, Box 84
                Braceville,IL 60407                                                                                                                    j
                SUBJECT:          NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-456/96016(DRS);
                                  50-457/96016(DRS))                                                                                                   l
                Dear Mr. Stanley:
                                                                                                                                                       :
                          This will acknowledge receipt of your April 28,1997 letter in response to our
                March 31,1997 letter transmitting a Notice of Violation associated with the above
                mentioned inspection report. This report summarized the results of the fire protection
                                                                                                                                                        !

, inspection at your Braidwood Plant. We have reviewed your corrective actions and have i

                no further questions at this time. These corrective actions will be examined during future
                inspections.
                                                                   Sincerely,
                                                                   John A. Grobe, Acting Director
                                                                   Division of Reactor Safety
                Docket No. 50-456
                Docket No. 50-457                                                                                                                       l
                                                                                                                                                        !
                Enclosure:         Ltr dtd 04/28/97, H. G. Stanley,                                                                                     I
                                    Comed, to US NRC w/ encl                                                                                           i
                See Attached Distribution
   DOCUMENT NAME: G:\DRS\ BRA 060_7.DRS
 ; Ts receive e copy of this document, indicate in the box: *C" = Copy w/o attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy
                                                                                                                                                        j
    OFFICE        Rlil:DRS           l 1:_     Rill:DRS         l9      Rill:DRP           lg       RMylCS f                   NS ng
    NAME          Schrum/kjc ha h4 Westberg g                           Lanksbury O n L             ClaytoX                   Uac@Yptrobe
    DATE          06/01/97                     06/03/97                 06/ tl /97                  07 /97 N                   06/ fly                  l
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                                                             OFFICIAL RECORD COPY                                                                      i
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        h. G. Stanley                                                            2                           June 6, 1997                               !
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                                                                                                                                                        :
        cc w/o encl: T. J. Maiman, Senior Vice President,
                              Nuclear Operations Division
                          D. A. Sager, Vice President,
                              Generation Support

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                          H. W. Keiser, Chief Nuclear

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                              Operating Officer

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                          T. Tulon, Station Manager
                          T. Simpken, Regulatory Assurance
                              Supervisor                                                                                                                i
                          1. Johnson, Acting Nuclear-
                              Regulatory Services Manager                                                                                               *
                          Document Control Desk - Licensing
        cc w/ encl:       Richard Hubbard
                          Nathan Sch!oss, Economist,
                              Office of the Attorney General                                                                                            ;
                          State Liaison Officer                                                                                                         i
                          Chairman, Illinois Commerce Commission
        Distribution:
        Docket File.w/ encl _.,7f                   SRis, Braidwood, Byron,~           R. A. Capra, NRR w/enci

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                                                     Zion w/enci                       TSS w/enci
        OC/LFDCB w/ encl                            LPM, NRR w/ encl
        DRP w/ encl                                 A. B. Beach, Rill w/ encl
        DRS w/ enc!                                 J.' L. Caldwell, Rlll w/ encl
        Rll! PRR w/ encl                            Rill Enf. Coordinator w/enci

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                         liraidwond Generating Nat on
                         Route a l . Itos H e
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                        'Irl 814-a5M 'Mol
                       April 28,1997
                       Document Control Desk
                       U.S. Nuclear Regulatory Commission
                       Washington, D.C. 20555
                       Subject:                Reply to Notice of Violation
                                               NRC Inspection Report 50-456(457)/96016
                                               Braidwood Nuclear Power Station Units 1 and 2
                                               NRC Docket Numbers 50-456 and 50-457
                       Reference:              G. E. Grant letter to H.G. Stanley dated March 31,1997, transmitting
                                               Notice of Violation from NRC Inspection Report 50-456(457)/96016

<- The Inspection Report referenced above 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         i
                       the use of hot work permits. Although Maintenance and Construction personnel did not               !
                        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
                        work prccedure and permit are expected to resolve the identified administrative concerns.
                        If your staff has any questions or co nments concerning this letter, please refer them to
                        Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801,                   i
                        extension 2980.
                       r
                                                          -
                        I       ene Stanley
                            ite Vice Presiden
                        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

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         ATTACHMENT 1
         REPLY TO NOTICE OF VIOLATION
         VIOLATION (50-456(457)/96016-05)

! Braidwood Technical Specification 6.8.1.a requires, in pan, that procedures be

                 established, implemented, and maintained for activities covered in Appendix A of
                 Regulatory Guide 1.33.
                 Appendix A of Regulatory Guide 1.33 included fire protection program

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                 implementation.
                 Braidwood Procedure (BwAP) 1100-15, " Fire Prevention When Welding, Cutting,

l Grinding, or Performing Open Flame Work (Hot 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 Maintenance /
         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 imponance of filling out all of the information on the permit. As a result, some of the
         permits did not satisfy the procedure requirements.
         CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED
         The problem was identified during an evaluation of hot work permits that were completed
         between May and October,1996. The permits were individually reviewed and most of the
         noncompliances were found to be administrative in nature and none would have impacted
         the safety in the plant. The Fire Marshal discussed the problem with Maintenance
         Supervision.

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       ATTACHMENT 1
       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 Construction 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.
                                                     2

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