ML20150E967

Notice of Violation from Insp on 880216-0307.Violation Noted:On 880218,deviation Rept Not Initiated After Identifying Departure from Accepted Equipment Performance Re Boric Acid Recirculation Line

ML20150E967
Person / Time
Site:	Braidwood
Issue date:	03/29/1988
From:	Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20150E964	List: ML20150E961 ML20150E967 ML20150E970
References
50-457-88-07, 50-457-88-7, NUDOCS 8804040215
Download: ML20150E967 (3)

Text

.. c NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-457 As a result of the inspection conducted on February 16 through March 7, 1988, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1987), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion XVI states, Measures shall be established to assure that conditions adverse to quality; . . . are promptly identified and corrected. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.

Administrative procedure BwAP 1250-2 (Deviation Reporting) defines:

"Deviation: A departure from accepted equipment performance or a failure to comply with administrative controls or NRC requirements which results in, or could, if uncorrected, result in a failure of an item to perform as required by Technical Specification or approved procedures."

BwAP 1250-2 Paragraph 3 (Processing of Deviations) specifies that the person identifying the deviation: "Initiate a Deviation Report (DVR)

Fo rn, 15- 52-1. Enter as much appliccble information as is known on Part 1 of the DVR and forward the DVR to the Supervisor responsible for the equipment or activity."

Contrary to the above, on February 18, 1988, licensee personnel, after identifying a departure from accepted 6quipment performance, a plugged boric acid recirculation line, failea to initiate a Deviation Report.

This is a Severity Level IV violation (Supplement I) (457/88007-01(DRS)).

2. 10 CFR 50, Appendix B, Criterion V states, "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

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s804040215 s80329 PDR ADOCK 05000457 L 0 TQrJo -

I Notice of Violation 2 Contrary to the above, the following examples were identified where procedure BwAP 330-1, "Equipment Out-of Service," Revision 5 dated January 7, 1988, was not appropriate to the circumstances; and where activities had not been accomplished in accordance with the procedure.

a. The procedure was not appropriate to the circumstances in that it '

failed to contain instructions describing the use of, and accounting for, instructions written on the Temporary Lifts. These procedural inadequacies resulted in the licensee not complying with the instructions written on Temporary Lifts 88-1-428 and 88-2-201.

(457/88007-028(DRS))

b. The Out-of-Service procedure was not appropriate in that it failed to ensure that the common Boric Acid Transfer Pump had the required  !

recirculation flow path when the Unit 2 Beric Acid Transfer Pump was taken Out of Service. (457/88007-02E(DRS))

c. The licensee failed to approve five Temporary Lifts (88-1-0048, 88-1-0049, ILC-MS114, MSXXX, and MS-1-428) in accordance with Section C.6.b. of the subject procedure. These Temporary Lifts were completely processed (Out-of-Service tags removed) without ,

the required documentation. (457/88007-02A(DRS))

d. The licensee felled on January 10, 1988, to restore Out-of-Service 88-096 in accordance with Section C.4.n. of the subject procedure by leaving recirculation valve 1AF009B in the Out-of-Service position, '

closed. This resulted in damaging the Diesel Auxiliary Feedwater Pump by operating it without a recirculation flowpath.

(457/88007-02C(DRS))

e. The licensee failed on February 17, 1988, to Temporary Lift the Out-of-Service (88-1-193) associated with the Diesel Auxiliary Feedwater Pump in accordance with Section C.6.c. of the Subject procedure by leaving a "dummy fuse" in the control circuitry.

This re wited in the pump failing to start when a remote start was attempted. (457/88007-02D(DRS))

This is a Severity Level IV violation (Supplement 1).

.i Notice of Violation 3 Pursuant to the provisions of 10 CFR 2,201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Consideration may be given to extending your response time for good cause shown.

Dated A $ .,

fg.

G. C. Nright, Chief f

Operations Branch, Division of Reactor Safety

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