ML20197J152
| ML20197J152 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/23/1997 |
| From: | Tulon T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-456-97-15, 50-457-97-15, NUDOCS 9801020096 | |
| Download: ML20197J152 (4) | |
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TriHitt W 2H01 December 23,1997 Document Control Desk US Nuclear Regulatory Commicsion Washington, D.C. 20555
Subject:
Reply to Notice of Violation NRC Inspection Report 50-456(457)/97015 Braidwood Nuclear Power Station Units 1 and 2 NRC Dociet Numbers 50-456 and 50-457
. eference:
G. E. Grant letter to T. J. Tulon dated November ; - 1997, transmitting R
Notice of Violation from inspection Repo-t 50-456(07)/97015 Results from a six week inspection that ended on September 22,1997, were documented in the Inspection Report specified in the above reference. In addition, a Notice of Violation (NOV) was transmitted with the above reference and included two Severity Level IV violations. No written response was rr, ired for one violation associated with a post modification testing concern because corrective actions had been implemented and were evaluated during the inspection period. Comed's response to the other violation is included in the attachment to this letter.
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Braidwood Station believes the efforts in progress to resolve concerns associated with the Configuration Control and Out of Service (OOS) processes will be effective. Action plans for improving performance in these areas, panicularly from a human factors perspective, will continue to be a key focus area. Examples of actions which have been or are being N
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taken include: Human Error Reduction Training, Quarterly Reinforcement sessions to communicate standards and expectations, and Self Check Simulator training to reinforce the concept of peer checking and observation skills.
The following commitment was made in the attachment to this letter:
Formal training will be provided to shift personnel in the Operations Department on administrative procedures associated with the positior.ing of components and the required method of verifying component positions.
9001020096 971P7.3 PDR ADOCK 05060456 G
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1 Document Control Desk.
Dur.oer 23,1997.
- Page 2 if your staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood-Regu' story Assurance Supervisor, at (815) 458-2801, Lextension 2980.
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M Timothy J. Tulon
. Site Vice President
' Braidwood Nuclear Generating Station THM1YnsJoe '
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- Attachment cc:
~A.B. Beach, NRC Regional Administrator, Region 111 G.F. Dick, Jr., Proiect Manager, NRR C.J. Phillips, Senior Resident inspector F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS a
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ATTACHMENT 1r c,_
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REPLY:TO NOTICE OF VIOLATION -
l(50456i457/97015-0.1)J 1;
10 CFR Part $0, Appendix B, Criterion XVI, states in part, measures shall be established to assure that conditions adverse to quality are promptly identified and 1
corrected. In the case of significant conditions adveise to quality, the measures j
. shall assure that the cause of the condition is determined and corrective action 1
- taken to preclude repetition.
14,1997, l censee personnel verified the i
Contrary to the above, on August
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position of the 2B containment spray eductor drain valve (2CS012B) without 4
removing and reinstalling the locking device as required by BwAP 340-2, "Use Of l
Mechanical And Electrical Lineups," Revision 15El, Step C.3.c.8. On August 20, 1997, the licensee found 2CS0123 closed as required, but unlocked. BwOP CS-M2," Operating Mechanical Lineup Unit 2," Revision 3, required that 2CS012B be e
locked cloredJ The proper positioning of plant components has been a recurring issue? Training of operators on valve position verification was performed in 1996 as part of corrective actions for this problem; however, these corrective actions to t preclude repetition have not been fully effective.
S REASON FOR THE VIOLATION On August 12,1997, twc Equipment Attendants (EAs) were assigned to perform a return to service (RTS) on the Unit Two Containment Spray (CS) System. They were instructed s
to remove two Out-of-Service (OOS) cards, close 2CS012B and place a lock and chain on the valve, q
Two days later, two EAs were assigned to do a RTS for the 2B CS pump and a partial L
valve lineup on the CS System.! After receiving instructions on the assignment during a L
pre-job briefing, the individuals signed out the necessary keys as required by procedure to L
position the CS valves and verified the other CS valve keys were hanging in the Locked Safety Related Valve Key Cabinet. This cabinet is kept locked and access is controlled.
The two operators performed the RTS and partial lineup. They verified valve 2CS012B =
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- was closed and locked. One'EA visually verified the closed position of the valve, tested the valve handle in the closed directica, and pulled on the chain to ensure it was closed and latched. The other EA observed the valve position verification process performed by_
l the first individual and visually determined the valve was locked closed. No physical E
contact was made with the valve or lock during this verification. It was determined that
' both individuals did not' comply with step C.3.c.8 of BWAP 340-2, "Use of Mechanical
!and Electrical Lineups," which requires the locking device to be removed before verifying g,g
. the val #s required position and then reinstalling the locking device when the position
- check is complete.
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i ATTACilMENT 1 REPLY TO NOTICE OF VIOLATION (10-456A57/97015-01)
On August 20,1997, when an operator performing rounds found valve 2CS012B closed but not locked and the chain and lock located on the floor near the valve, a Root Cause investigation was initiated. During the investigation, interviews with station personnel were conducted and a historical review of work activities performed on the valve was conducted. The investigation was unable to identify any reason nyhy the valve would have been unlocked.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED When the problem with 2CS012B not being locked closed was recognized, two operators were di. atched to place the valve in the locked closed position as required by procedure BwOP CS-M2," Operating Mechanical Lineup Unit 2" 3
ACTIONS 'l AlsEN (TO BE TAKEN) TO PREVENT RECURRENCE All shin personnelin the Operations Department were tailgated on administrative procedures associated with the positioning of components and the cequired method of verifying component positions. This action will be followcd up with formal classroom training on the same subject.
A revico; of accessible locked valves in the field was conducted to ensure that the lock and chain were installed properly, the hasp and chain length were adequate for the application, and the valve was in its proper position. No discrepancies were noted.
BwAP 330-11," Operations Locked Sa cty Related Valve Key Control," the procedure r
which governs locked safety valve key control, was rewritten to more clearly explain the key sign out process and to make the procedure easier to use. Detailed directions were also provided on the proper completion and use of the " Shin Managers Locked Safety Related Key Log" The Scorecard program will continue to be used for in-field evaluation and improvement of human performance within Operations.
DATE WlENJULL COMPLI ANCE WAS ACillEVED Compliance was achieved when 2CS012B was placed in the locked closed position as required.
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