ML20149G808
| ML20149G808 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/01/1994 |
| From: | Kaup K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9411070423 | |
| Download: ML20149G808 (7) | |
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Braidwood Nuclear Power Station
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Route #1, Box 84 V 'J Braceville, Illinois 60407
, (j Telephone 815/458-2801 November 1, 1994 SVP/94-050 U.S. Nuclear Regulatory Commission Washington, DC 20555' Attn: Document Control Desk
Subject:
Braidwood Nuclear Power Station Units 1 and 2 Reply to a Notice of Violation Inspection Report Nos. 50-456/94021; 457/94021 NRC Docket Numbers 50-456 and 50-457
References:
1)
L.
F. Miller letter to K. Kaup dated October 6, 1994, transmitting NRC Inspection Report 50-456/94022; 50-457/94021 Enclosed is Commonwealth Edison Company's (Comed) reply to the Notice of Violation (NOV) which was transmitted with the letter and Inspection Report identified in reference 1.
The NOV cited a Severity Level IV violation requiring a written response.
Comed's response is provided in the attachment.
In accordance with the telephone conversation on October 31, 1994, between Sara Reece-Koenig, Corporate Regulatory Services, and Nicholas Hilton, NRC Region III, this response will address examples 2, 3,
4, and 6 of the violation.
comed was granted a 30 day extension for responding to examples 1 and 5 to allow thorough root cause investigation of the issues.
If your staff has any questions or comments concerning this letter, please refer them to Kevin Bartes, Braidwood Regulatory Assurance Supervisor, at (815)458-2801, extension 2980.
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Karl L.
saup Site Vice President Braidwood Station KLK/JML/nu-Attachment cc:
J.
B. Martin, NRC Regional Administrator - RIII R.
R. Assa, Project Manager - NRR S.
G.
Du Pont, Senior Resident Inspector
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411070423,43393 R
ADOCK 05000456 D
ATTACHMENT REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 50-456/94021; 50-457/94021 VIOLATION (456(457)/94021-01)-
Technical Specification 6.8.1 required that written procedures shall be established, implemented, and maintained covering activities referenced in Appendix A, Regulatory Guide 1.33.
Revision 2, February 1978, which includes preparations for refueling, procedure adherence, and radiation protection.
Seven examples contrary to the above follow:
1.
BwFP FH-31, " Fuel Handling Cleanliness Zones and Requirements," required personnel accountability be accomplished in a cleanliness zone II area by logging each individual in and out of the control point using the ingress, egress and equipment accountability form (BwFP FH-31Tl).
Contrary to the above, on August 10, 1994, the licensee failed to log individuals in and out of a cleanliness zone II area control point using FH-31T1.
2.
BwFP FH-31 required that a cleanliness zone II area be posted with a large, conspicuously placed sign having general instructions for entry.
Contrary to the above, on August 10, 1994, the licensee failed to post a cleanliness zone II area with an appropriate sign referencing the appropriate procedure with general instructions for entry.
3.
BwFP FH-31 required that an entrance to a cleanliness zone II area include applicable procedure and logs in the area as required.
Contrary to the above, on August 10, 1994, the licensee failed to have the applicable procedure and logs in the area as required.
l 4.
BwAP 100-20, " Procedure Use and Adherence," required that when an individual perceives that a procedure cannot be performed as written, that the individual inform supervision of the situation for evaluation.
The supervisor will then evaluate the situation and determine the appropriate course of action.
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ATTACHMENT REPLY TO A NOTICE OF VIOLATION (CONTINUED)
INSPECTION REPORT 50-456/94021; 50-457/94021 Contrary to the above, on August 4, 1994, while securing the 2C condensate / condensate booster pump, nuclear station operators perceived that the governing procedure could not be performed as written, but nevertheless performed equipment manipulations outside:
the procedure without directly informing supervision and receiving guidance as required.
5.
BwRP 5000-7, " Unescorted Access To and Conduct in Radiologically Posted Areas," required that personnel entering a radiologically posted area read and understand all radiological signs which appear at the access control point, and ensure that he or she has been issued a routine thermoluminescent detector (TLD) badge and at least one secondary dosimeter.
Contrary to the above, on August 30, 1994, two licensee employees who entered the radiologically protected area (RPA) failed to read and understand the radiological signs which appeared at the "PA control point, and failed to obtain secondary dosimetry as required.
I 6.
BwAP 575-5, " Release of Material from a Radiologically Posted Area," required that " solid material shall not be given an unconditional release (from the Radiation Protection Area) until the material has been decontaminated and determined to be free of detectable radioactive material".
Contrary to the above, on August 18, 1994, the licensee discovered an eddy current cover plate with 10,000 2
dpm/100 cm smearable contamination on one bolt hole 2
opening and 18,000 dpm/100 cm smearable contamination on another bolt hole opening released outside the Radiation Protection Area without being decontaminated and free of detectable radioactive material.
Also contrary to the above, on August 30, 1994, the licensee discovered a reactor cavity decontamination 2
paint container and a chair with 2,000 dpm/100 cm 4
smearable contamination released outside the Radiation Protection Area without being decontaminated and free of detectable radioactive material.
This is a Severity Level IV violation.
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ATTACHMENT REPLY TO A NOTICE OF VIOLATION (CONTINUED)
INSPECTION REPORT 50-456/94021; 50-457/94021 REASON FOR THE VIOLATION (EXAM 1)LES 2 and 3)-
BwFP FH-31, " Fuel Handling Cleanliness Zones and Requirements,"
was written by the Fuel Handling Department to clarify the cleanliness requirements for the reactor cavity, spent fuel pool, and new fuel storage area which are listed in BwAP 1100-18,
" Station Housekeeping / Material Condition Program."
BwFP FH-31 was approved on January 1, 1994.
However, once the procedure was approved, the Fuel Handling Department failed to comply with it prior to performing fuel moves due to inattention to detail, failing to review the procedure, and failing to reinforce its expectations with the workers.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED (EXAMPLES 2 and 3)-
A copy of BwFP FH-31 and the personnel accountability log from BwFP FH-31 were immediately placed at control point for the cleanliness zone II area in the new fuel storage area.
Fuel Handling management directed department personnel to meet the requirements of BwFP FH-31.
New cleanliness zone II signs were fabricated and posted at the area control point.
These signs correctly referenced BwFP FH-31 as the procedure to review for entry requirements.
l CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION I
(EXAMPLES 2 and 3)-
The importance of material and personnel accountability has been stressed at tailgate meetings with Fuel Handling management and bargaining unit personnel.
A surveillance activity has been established for the Fuel Handling Department to review procedure BwFP FH-31 prior to each refuel outage.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (EXAMPLES 2 and 3)-
Full compliance was achieved on August 13, 1994.
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l ATTACHMENT REPLY TO A NOTICE OF VIOLATION (CONTINUED)
INSPECTION REPORT 50-456/94021; 50-457/94021 REASON FOR THE VILLATION (EXAMPLE 4)-
When securing the 2C condensate / condensate booster pump, the nuclear station operator (NSO) inadvertently closed the wrong feedwater pump recirculation valve due to inattention to detail.
This resulted in an increase in flow from the 2C feedwater pump.
Although the Unit Supervisor was monitoring the actions of the NSO throughout this event, the NSO did not discuss the i
recirculation valve manipulation with the supervisor as described in Bwap 100-20, " Procedure Use and Adherence."
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED (EXAMPLE 4)-
The NSO recognized that the wrong valve was closed and observed the increased load on the 2C feedwater pump.
The NSO then tripped the 2C feedwater pump to protect it from being damaged.
I CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION (EXAMPLE 4)*
Operating Department management discussed with the NSO the importance of attention to detail, self checking, and effectively communicating to avoid conditions that could be hazardous to personnel or plant equipment.
Management reinforced the expectations described in BwAP 100-20 with the NSO, the Unit Supervisor, and the Shift Engineer on duty at the time of the event.
Additionally, the requirements of BwAP 100-20 were discussed by Operating management with all Operating crews in September 1994.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (EXAMPLE 4)-
Full compliance has been achieved.
4
f ATTACHMENT REPLY TO A NOTICE OF VIOLATION (CONTINUED)
INSPECTION REPORT 50-456/94021; 50-457/94021 REASON FOR THE VIOLATION (EXAMPLE 6)-
The materials found to be contaminated were not properly surveyed out of the RPA or they were removed from the RPA without a proper unconditional release survey due to a lack of awareness of Station policies regarding control of contaminated materials.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED (EXAMPLE 6)
The eddy current cover plate was decontaminated, resurveyed, and determined to be free of contamination.
The decontamination paint container and the chair were returned to the RPA.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION (EXAMPLE 6)-
On September 19, 1994, Braidwood Health Physics Department implemented a new Radioactive Material Control Program.
This program is designed to effectively control contaminated materials to prevent them from being removed from the RPA without proper survey and approval.
To raise awareness, Site personnel were handed a flyer explaining the program as they entered or exited the main access facility.
Additional program flyers were made available to personnel arriving and departing during off-peak hours.
Work groups that routinely enter the RPA were presented the program by Radiation Protection personnel at tailgate meetings.
A Radiation Protection Technician has been posted at the auxiliary building control point to monitor control of radioactive materials 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
Controls implemented include:
8 Materials and equipment that fit into the tool monitor are surveyed for unconditional release using the tool monitor.
5
ATTACHMENT REPli ?O A NOTICE OF VIOLATION (CONTINUED)
INSPECTION REPORT 50-456/94021; 50-457/94021 N
Materials and equipment that do not fit in the tool monitor are evaluated for the need to be removed from the RPA If approved for unconditional release, the materi.. is surveyed and tagged allowing it to be removea from the RPA.
m The Radiation Protection Department has implemented restrictions as to what can be unconditionally released from the RPA.
The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Radiation Protection Technician coverage will continue until the end of the current refueling outage on Unit 2 which is scheduled for November 22, 1994.
Radiation Protection is evaluating several methods for monitoring for radioactive material control to be implemented after the outage.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (EXAMPLE 6)-
Full compliance was achieved on September 19, 1994.
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