ML20149F916
| ML20149F916 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/16/1997 |
| From: | Stanley H COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-456-97-07, 50-456-97-7, 50-457-97-07, 50-457-97-7, NUDOCS 9707220364 | |
| Download: ML20149F916 (12) | |
Text
Commonweahh Edison Company
- ltraidwood Generating Station Route #1, Ika 81 g
liraceville, IL Wlo7-9619 Tel 815-65&28o1 l
July 16,1997 Document Control Desk U.S. Nuclear Regulatory Commission Washington D.C. 20555
Subject:
Reply to Notice of Violation NRC Inspection Reput 50-456(457)/97007 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 June 17,1997, transmitting Notice of Violation from NRC Inspection Report 50-456(457)'07007 Results from a six week inspection that ended on May 20,1997, were documented in the inspection report specified in the Reference above. A Notice of Violation was transmitted with the referenced report and included three Severity Level IV Violations. Comed's response to these violations is included in the attachment to this letter.
The cover letter transmitted with the Inspection Report specifically requested that information be provided on actions Braidwood Station plans to take (or has taken) to ensure that our corrective actions process is effective. Braidwood's corrective action process 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 final resolution is reviewed and approved by the station's Plant Operation Review Committee (PORC).
This increased involvement demonstrates strong senior management support for the corrective action process, and helps to ensure line ownership of the issues requiring resolution.
A key improvement initiated in 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 apprcval of corrective actions to prevent recurrence, and final j
impleme tation, the effectiveness reviews assigned in 1996 are beginning to come due. As this
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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.
In addition, a set of performance metrics has been developed for use by all Comed Nuclear Q)/
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 these performance measures will ensure that the effectiveness of the corrective action process can continue to be improved.
9707220364 970716 PDR ADOCK 05000456 G
PDR lil.EI.EI.El.ll.iiWi.lllllllll.li p
A Unicom Company
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- Document Control Desk. 7/16/97 Pace 2 The following commitments are included in the attached response:
i BwVS 0.5-2.SI.2 and BwVS 0.5-2.SI.2-3 will be reviewed for clarity and revised as e
necessary.
'l A training class is being developed to include information on expectations associated with
- the roles and responsibilities oftest Directors. In addition, a Test Director certihcation form is being created which w.ill be included in the System Engineer Certification Program.
~ The transient fire load procedure will be evaluated to ensure steps are clear to the
-e procedure users. Appropriate revisions will be made once the evaluation is completed.
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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' ne Stanley e Vice President N
raidwood Nuclear enerating Station j
Attachment o:konfidadmaastare97110mt. doc cc:
A..B. Beach, NRC Regional Administrator, Region 111 G. F. Dick, Jr., Project Manager, NRR C. J. Phillips, Senior Resident inspector F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS l
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d A'ITACIR4ENT 1 l
REPLY TO NOTICE OF VIOLATION-VIOLATION (50-456(457V97007-01)
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10 CFR 50.59 states, in part, that the licensee may make changes in the facility as described in the safety analysis report without Commission approval provided the change
. does not involve a technical specification or an unreviewed safety question and a written safety evaluation must be performed and retained which provides the basis for the determination that the change does not involve an unreviewed safety question.
Contrary to the above, on April 18, 1997, the inspectors identified that the licensee had taken the _open Unit 2 motor driven feedwater pump discharge isohttion valve (2FWOO2A) out-of-service for maintenance without first conducting a written safety evaluation. This disabled the valve's automatic function to close on a feedwater isolation signal as described in the Updated Final Safety Analysis Report.
On April 14,1997, Feedwater Pump Discharge Valve 2FWOO2A was taken Out-of-Suvice (OOS) in the open position to perform maintenance on the actuator. The valve was OOS for a duration of approximately 4.5 days and it was retumed to senice. This valve is non-safety related, powered from a non-ESF power supply, and is not addressed in the Technical Specifications. However, this valve is described in the UFSAR. Because of this, NRC management communicated that a 50.59 safety evaluation should have been performed for the 00S to evaluate the acceptability of that-action.
Engineering subsequently researched the matter and determined the following: The current industry 50.59 guidance (NSAC-125) and the most recent proposed NRC guidance (NUREG 1606) agree that it is important to distinguish " changes" (which require 50.59 evaluations) from maintenance activities or other activities already evaluated. Both guidance documents agree that systems or components removed from senice for maintenance under Technical Specification LCOs do not require 50.59 evaluations.
However, for components not covered by Technical Specifications, NSAC-125 suggests the performance of 50.59s for components "taken credit for in Accident Analysis" and NUREG 1606 for components which are "part of the licensing basis",
l' A resiew of the UFSAR and NRC SER indicated that it is not the Feedwater Pump Discharge -
Valves, but rather the Feedwater Isolation Valves and the Feedwater Control Valves which are i
j "taken credit for in Accident Analysis" (for example UFSAR Tables 15.1-1 and 15.1-2 and i-Technical Spccification Table 3.6-1), and which were relied upon by the NRC in accepting the design of the Feedwater System (see SER Section 10.4.7). Therefore, under current industry and the most recent proposed NRC guidance, a 50.59 safety evaluation for the OOS of the FW Pump Discharge Valves would not be required.
Additionally, it should be noted that the proposed NRC guidance has been issued for public comment. The industry is presently providing conunents and developing revised industry gmdance (Draft NEI 96-07) for the NRC's consideratwn. Those comments melude a proposed revision to clarify that, for important components which may not be covered by Technical Specifications, the Maintenance Rule now provides a mechanism for evaluating the effects of removal of components from service for maintenance. Therefore, a 50.59 safety evaluation is not required.
Based on this information, Braidwood Station believes that a written safety evaluation was not required when the Unit 2 motor driven feedwater pump discharge isolation valve (2FW002A)
. was taken out-of-service. The Station will continue to provide comments and support the industry efforts as the common guidance document is revised. Until the revised guidance can be agreed upon, Braidwood will follow the existing industry and NRC guidance to perform 50.59s for 00Ss for comp'onents not covered by Technical Specifications but "taken credit for in Accident Analysis and relied upon in the NRC SERs. The review performed by Licensed Senior Reactor Operators which is reqmred by the OOS procedure presently provides a mechanism to ensure that this guidance is followed.
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! ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIO.LATION (50-456(457)/97007-02a) 2.
Technical Specification (TS) 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, dated February 1978.
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Regulatory Guide 1.33, Appendix A, requires the use of procedures for the control of maintenance that can affect the performance of safety-related equipment.
SMP-M-04, " Foreign Material Exclusion," Revision 0, Section 6.4.2 requires that covers must be placed on all system breaches when the opening is leR vaattended or is not required to be open for work, inspection, or testing.
Contrary to the above:
On April 21, 1997, inspectors observed the IB diesel unattended with foreign material exclusion (FME) covers missing from two of the cam shan access ports.
On April 25,1997, inspectors observed that the FME cover was removed from the 1 B diesel right cylinder bank and the diesel was unattended.
REASON FOR THE VIOLATION The Foreign Material Exclusion (FME) covers were missing from portions of the cam access ports because the cam gallery FME covers were installed without a gap between each opening as designed. As a result, approximately six inches at the end of each camshan gallery had been leR exposed and unprotected. This defickncy was not reported or corrected at the time of the FME cover installation. In the other identified deficiency, workers did not replace the FME cover on the IR cylinder head prior to leaving the area. Interviews revealed that the individuals were not aware that a FME cover was not in place. The individuals were knowledgeable of FME requirements and indicated that they would have known to reestablish the cover to satisfy FME requirements. In both identified cases, the diesel generator crew failed to self check to ensure the interded actions had been performed before leaving the area.
During the review of this problem it was determined that a work step for inspecting, cleaning, and performing a final Quality Control closure inspection had not yet been performed to close out the work on the diesel generator. This step would have served as a final barrier for ensuring that debris was not present prior to closing out the system.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED Once Station personnel were made aware of the two deficiencies, FME barriers were installed as required. In addition, the diesel generator crews were counseled on the expecta ions concerning FME requirements for the diesel generator overhaul activities.
l ACTIONS TAKEN TO PREVENT RECURRENCE The Station's expectations concerning FME requi ements for all maintenance activities were reinforced with the Mechanical Maintenance Department.
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ATTACHAENT 1.
REPLY TO NOTICE OF VIOLATION VIOL ATION (50-456(457V97007-02a) -
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when proper FME barriers were installed to correct both of the identified deficiencies.
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ATTACHMENT 1
- REPLY TO NOTICE OF VIOLATION VIO.LATION (50-456(457)/97007-02b)
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Regulatory G,ide 1.33, Appendix A, describes the use of specific procedurea for surveillance tests listed in the technical specifications.
BwVS 0.5-2.SI.2, " Safety injection System Check Valve Stroke Test," Revision 15, Step F.4.24 requires the recording of the flow rate for IB SI pump (IS10lPB).
This flow rate is the sum of the readings from flow instruments F1-922 and F1-
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972.
J Contrary to the above, the inspectors identified that on April 28, 1997, the test director failed to record and sum the flow rate reading from FI-972 with the flow rate obtained from F1-922.
If the flow rate was properly calculated, the acceptance criteria of Step F.4.24 may have been exceeded.
I REASON FOR THE VIOLATION On April 28,1997, during the performance of BwVS 0.5-2.SI.2, " Safety injection System Check Valve Stroke Test" Procedure, only one of two required flow rat.:s (FI-922 and FI-972) was recorded in step 4.24.1 since the procedure only prompted for one of the two flow rates. After the problem was identified, a review of the revision history for the surveillance procedure was done. It was concluded that the space for recording the flow value for F1-972 had been inadvertently left out in a past revision and this was not identified during the procedure review process. The individual who performed the surveillance procedure did not recognize the space was missing and only recorded one of the values.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED After the completion of step 4.24, the B SI pump was immediately shut down and an operability determination was performed which showed that the actual pump flow would have been acceptable. Review of the stated acceptance criteria showed that the acceptance criteria was inadequate for the step being perfomied. The stated criteria incorrectly combined the actual check valve operability mimmum flow criteria (612 ppm) with a pump runout maximum flowrate (655 gpm). The purpose of step 4.24 is to ensure that the pump discharge valve achieves its full open position and not m verify that the pump would be capable of delivering a flow required during a i
design basis accident.- The total pump flow determined from this step would be expected to be greater than the stated 655 gpm acceptance criteria value based on the fact that the B Si pump recirculation valve (S18920) is still open when the pump discharge valve is returned to its full open position. In addition to the acceptance criteria discrepancy, it was also identified that the procedure inapp,ropriately directed the Test Director to obtain information from installed mstrumentation mstead of using high precision instrumentation specifically installed for the execution of the surveillance.
ACTIONS TO BE TAKEN TO PREVENT RECURRENCE BwVS 0.5-2.SI.2 will be revised to resolve the identified discrepancies. Correct acceptance criteria will be specified for step 4.24 and the revision will direct the Test Director to obtain data from the high precision instrumentation installed during the surveillance.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when an operability determination was done which demonstrated that the actual result was acceptable.
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' ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)M7007-02c) 2c)
Regulatory Guide 1.33, Appendix A, requires the use of specific procedures for surveillance tests listed in the technical specifications.
BwVS 0.5-2.SI.3-2, " Safety Injection Fystem Check Valve Stroke Test,"
Revision 8, Step D.2 and TS 4.5.2.h.b. instructs the operator not to exceed a centrifugal charging (CV) pump flow of 550 gallons per minute (gpm) in order to protect the pump against run out.
Contrary to the above, the inspectors identified that on April 28,1997, during the performance of BwVS 0.5-2.Sl.3-2, the test director received indication that l A CV pump flow was greater than 550 gpm and did not inform the operating crew to secure the pump. This could have led to cavitation and possible pump damage.
REASON FQ_R THE VIOLATION While performing BwVS 0.5-2.SI.2-3, " Safety injection Check Valve Stroke Test," the Test Director obtained data from a temporarily installed differential pressure flow indicator (across the IFE-917 flow element) that indicated that the l A CV pump exceeded the Technical Specification 4.5.2.h.(1).(b) pump runout flow limit. Precaution step D.2 in the surveillance procedure stated that the pump should not be nm beyond that limit, however the Test Director failed to recognize that the indicated pump flow had exceeded the Technical Specification pump runout flow limit.
The major contributmg factor for the problems encountered during the surveillance was that the Test Director was preoccupied with the concern that the reactor cavity was being filled during the particular section of the surveillance and the individual wanted to perform that section promptly to avoid overfilling the refueling cavity. This mind set prevented the individual from performing adequate self-checks during the surveillance.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED After the problem with the surveillance was identified, all data recorded in BwVS 0.5-2.SI.2-3 was reviewed to determine the operability status of the l A CV pump. It was found that the initial I A CV pump flow was calculated in errcr due to the use of an incorrect differential pressure cell scale conversion factor. When the calculation was corrected, it was determined that the lA CV pump actually had not been in a runout condition. Also, it was determined that a step in the procedure that is listed after the cavity fill is completed requires the acceptance criteria flowrate to be recorded. This documented flowrate was found to be acceptable. The Station concluded from this infomiation that the l A CV pump would fulfill the necessary ECCS requirements.
Shortly after this surveillance concem was identified, the individual who performed the surveillance was relieved of the duty of being a Test Director for major surveillances (as designated by Engineering management) for the remainder of outage AIR 06. In addition, the individual was counseled on the expectations for test personnel and their responsibilities, including the need to maintain constant awareness of data being equired. A training tailgate of this event was also provided to the System Engineering Depart.nent to reinforce surveillance performance expectations.
ACTIONS TO BE TAKEN TO PREVENT RECURRENCE BwVS 0.5-2.SI.2-3 will be reviewed and revised as necessary to clarify the guidance associated l
with expected actions in the event Technical Specification limits are exceeded.
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ATTACHMENT 1 4
REPLY.TO NOTICE OF VIOLATION i
VIOL ATION (50-456(457)/97007-02c)
A training class is being developed to include information on expectations associated with the roles and responsibilities of Test Directors. In addition, a Test Director certification form is being d
created which will be included in the System Engireer Certification Program.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED i
Full compliance was achieved when the data recorded in the surveillance was calculated using the correct scale factor and for ad to be acceptable.
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REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97007-03a) 3.
TS 6.8.1.g states, in part, that written procedures shall be established, implemented, and maintained covering activities of the Fire Protection Program.
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BwAP 1100-15, " Fire Prevention When Welding, Cutting, Grinding or Perfonning Open Flame Work (Hot Work)," Revision 7, Step F.2.c.10 instructs the job supenisor to ensure that a fire watch is available throughout the job and at least 30 minutes after. BwAP 1100-15, Step 6a states, in part, that one or more individuals in each welding, grinding, or open flame work area SHALL be designated to watch for potential fire or smoldering.
Contrary to the above, on April 23, 1997, the inspectors observed a contract worker assigned as the fire watch for welding that was in progress, sitting in the i
dark under the Unit I turbine hood. The inspectors infonned the operations shift field supenisor who with another senior reactor operator found the individual asleep (inattentive).
E_EASON FOR THE VIOLATION The welding personnel at the job site were busy working and were not aware that the individual assigned to the fire watch duty under the U-l "C" low pressure turbine hood had fallen asleep, it was detennined that the employee's inattentiveness was caused by fatigue. The worker had been involved in highly physical work in the morning and had eaten lunch shortly before beginning his assigrunent as a firewatch.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED A Station supenisor went to the work site where the Westinghouse employee was sleeping. The supenisor immediately woke the employee and counseled him on the need to remain attentive at his work station for personnel and plant safety reasons. In addition, the individuals chair was removed from the area to keep the individual more alert.
In addition to immediately waking the Westinghoure worker and counseling him on expectations, disciplinary action was taken.
ACTIONS TAKEN TO PREVENT RECURRENCE A tailgate session was conducted with all associated Westinghouse personnel to remind them of the importance of staying attentive at the work site for proper job safety.
Westinghouse now evaluates job assignment changes for the possible effect on an employee's attentiveness to duty. le addition, Westinghouse does not allow their employees to sit while i
perSrming the fire watet a uty.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when the individual assigned to the fire watch duty was awakened I
and retumed to the position after discussing the incident with the Station supenisor.
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i ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOL ATION (50-456(457)/97007-03 b) 5 3b)
BwAP 1110-3, " Plant Barrier impairment Program," Revision 3, Step D.6 states, in part, that a plant barrier impairment should be filled out for any impairment of a barrier. If a door is going to be left unattended a Plant Barrier Impairment (PBI) is required.
Contrary to the above, on April 22,1997, the inspectors discovered that a fire door from the condensate polisher room to the turbine building on the 401 foot elevation was propped open with a hose passing through it. No PBI had been prepared for the impaired door and no one was in attendance at the door.
REASON FOR THE VIOLATION During Shift 1 on April 21,1997, the diesel generator maintenance crew was working to clean the 1B Diesel Generator (DG) jacket water heat exchanger tubes. The water supply initially used did not provide adequate water quantity to perfonn the cleaning. As a result, the potable water drop at the 401' elevation in the Condensate Polisher (CP) Room was used.
A maintenance worker ran a water supply hose through the CP Room Fire door to provide the water supply to the 1B DG Room. Since time had been expended to obtain an extra hose for the set up, the worker was concerned that little progress was being made on the tube cleaning assignment. As a result of the worker's e;gerness to begin the tube cleaning work, the individual failed to recognize that the CP Room door was marked as a " Fire Door" Therefore, no Plant Barrier impairment (PBI) authorization was initiated.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED When the concern was identified, the hose was removed from the area and the fire door was closed, eliminating the need for a P131.
The crew members involved in the DG jacket water tube cleaning assignment were counseled for their involvement in this event.
The worker who ran the hose through the CP Room door was questioned regarding his knowledge of Plant Barrier impairment requirements. It was determined that the individual is aware of the requirements associated with an unattended open fire door.
ACTIONS TAKEN TO PREVENT RECURRENCE This event was discussed with Station personnel during a June 27, 1997, Human Performance Awareness Session to heighten awareness regarding degrading identified plant barrieas. In addition, the Station's Fire Marshal presented information to supervisory personnel on Fire Safety during a meeting held on June 3,1997.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when the hose was removed from the area and the fire door was closed.
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ATTACHMENT 1 I
REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457V97007-03c) 3c)
BwAP 1100-11, " Fire Prevention for Use of Lumber and Other Combustibles,"
Revision 7, Step C.3.a states, in part, that prior to moving major transient l
combustibles that will be left unattended into safety-related areas from normal l
storage areas, the responsible work group supenisor shall obtain approval from the Fire Marshal or designee.
-1 Contrary to the above, on May 19, 1997, the inspectors found combustible -
material in the auxiliary building on the 346 foot elevation. No transient fire load permit was found at the location and the inspector, through an inteniew with fire protection personnel, detennined that no transient fire load permit had been obtained.-
1 REASON FOR THE VIOLATION During refueling outage AIR 06, work was performed on the Essential Senice Water (SX) System which required sections of the system to be dewatered to allow valve maintenance work to be done.
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The dewatering equipment consisted of a network of hoses and temporary pumps set up between two elevations to facilitate water level control in the SX piping.
L The equipment and hoses were assembled in the Auxiliary Building to dewater the SX A-train.
l-During set up for this evolution, hoses were strung out between elevations 330' and 346' to temporary pipe headers, pumps, and floor drains. When the evolution on the A-train was completed, the hoses and equipment were moved the B-train side. Following an unsuccessful i-dewatering effort on the B-train, the hoses and er aipment were disassembled and stored in the general area on the 346' elevation. This equipment formed a pile approximately 4' high,10' long, l
and 6' wide and no Transient Fire Load Tag had been hung on the equipment because the workers who brought the equipment into the Auxiliary Building assumed that a Transient Fire Load tag was not needed.
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' Prior to assembling the dewatering equipment, the construction SX team members consulted Station personnel to determine fire protection requirements. Due to the fact that a continuous flood l
watch would be in effect during the dewatering operation, Station personnel determined that the l
flood watch would fulfill fire watch duties and all fire protection compensatory measures would be satisfied. The contractors assumed that having a continuous flood / fire watch in effect during the dewatering evolution would be the only fire protection compensatory actions needed for the entire job duration. They failed to question whether actions would be required when the equipment was 1-i being stored while not in use.
L Station personnel assumed that the dewatering equipment would be removed from the Auxiliary Building as soon as the job was completed and therefore they did not inform the contractors that a transient fire load tag would be needed if equipment was to be stored locally. When the equipment l
was set t.p for the evolution, the hoses would be strung out end-to-end, which was considered a L
minor transient fire load, not requiring a permit. However, with the equipment stored locally, the fire loading requirements would change and a transient fire load tag would be needed. The erroneous assumptions made by both the construction workers and the Station personnel were the i
major contributors to this event.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED l
After the problem was identified, the Fire Marshal evaluated the fire loading in the area and subsequently hung a transient fire load tag on the dewatenng equipment located in the Auxiliary Building.
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- ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97007-03c)
The construction SX. crews were counseled on the requirements of BwAP 1100-11, " Fire Prevention for Use of Lumber and Other Combustibles."
ACTIONS TAKEN/TO BE TAKEN TO PREVENT RECURRENCE The Fire Marshal's office has run articles in the Station's daily newsletter, "The Screaming Eagle," to heighten worker awareness levels on fire prevention procedure requirements.
On June 3,1997, the Station Fire Marshal presented information on fire protection requirements to Braidwood's Maintenance first line supemsors. The purpose of this presentation was to heighten awareness on fire door requirements, transient fire load tags, hot work permits, and fire protection equipment availability.
During outage periods, the Station's Fire Protection Coordinator will routinely monitor the plant to verify compliance with fire protection procedure requirements.
The transient fire load procedure will be evaluated to ensure steps are clear to the procedure users.
Appropriate revisions will be made once the evaluation is completed.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when the Fire Marshal was informed of the equipment stored in the
. Auxiliary Building, the fire loading in the area was evaluated, and a transient fire load tag was hung on the equipment.
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