ML20202F232

Notice of Violations from Insp on 971112-21 & 980115. Violations Noted:Licensee Failed to Follow NSWP-A-15 & Bwap 330-10 Requirements to Issue PIF for Tempering Line Snubber Considered Inoperable on 971110

ML20202F232
Person / Time
Site:	Braidwood
Issue date:	02/11/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20202F193	List: IR 05000457/1997021 ML20202F187 ML20202F232
References
50-457-97-21, NUDOCS 9802190155
Download: ML20202F232 (3)

Text

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.s NOTICE OF VIOLATION

- Commonwealth Edison Company Docket No. 50-457

- Braidwood Station Unit 2 License No. Nt)F-77 l As a result of an inspection conducted on November 12-21,1997, violations of NRC l' requirements were identified. In accordance v<ith the "Genaral Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violation is listed below.

l_ 1. 10 CFR 50, Appendix B, Criterion V reouires in part that activities affecting quality shall-i be preceribed by documented procedures of a type appropriate to the circumstances.

Contrary to the above, as of November 10,1997, the procedure which was used to fill arid vent the 2D feedwater system, an activity affecting quality, as prescribed by BwOP FW-3, " Fill and Vent of the Feedwater System," Revision 6, was inappro' riate for the circumstances. Sections of feedwater piping between the Feedwater Sh toff Valve (2FWOO60) ano the Feedwater Isolation Valve (2FWOO9D) were not adequately vanted, and as a result, saiety-related components were damaged by the feedwater system waterhammer event that occurred on November 10,1997.

This is a Seventy Level IV violation (Supplernent I) (457/97021-01(DRS)). e 2, 10 CFR 50. Appendix B, Criterion V requires in part that activities affecting quality shall be prescribed by documented proceduras and shall be accomplished in accordance with these procedures,

s. Braidwood Procedure, BwAP 100-20 " Procedure Use and Adherence," Revision 7E I, paragraph D.9 required, in part, that wnen an Individual perceives that any procedure cannot be performed as written, the individual's supervisor is required -

to initiate a permanent or temporary change, or use Braidwood Procedure, BwAP 100-20T1 to document any deviations from a procedure.

Contrary to the above, on Novamber 10,1997, when the Procedure 2BwGP 100-2, "P! ant Startup," Revision 9, could not be performed as written, the licensee failed to follow BwAP 100-20 to issue a procedure revision or change.

Specifically, ,tep F.14.h of this procedure caused valves 2FWO35A-D to close and instruclans had not bcen provided to reopen these valves. The operators took manual at; ions, not described in the procedure nor documented in an approved procedure change process, to open these velves and restore feedwater flow.

This is a Severity Level IV violation (Supplement 1) (457/97021-02(DRS)).

I b. Braidwood Procedure, BwAP 330-10 " Operability Determinations,' Revision 3E1, paragraph F.5, requirea "Any on-site personnel knowledgeable of a possible OPERABILITY ISSUE, identified to them by any source, MUST promptly notiy the Shift Manager (SM), or designeo and write a PIF". Also the Commonwealth Edison Procedure, NSWP A-15," Comed Nuclear Division Integrated Reporting Program," Revision 1, paragraph 6.1.1 required "All station individuals or

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contractors should irsitiate an Exhibit A, (Problem identification Form (PlF)), when -

a problem is recognized."

Contrary to the above:

(1) On November 10,1997, the licensee had failed to follow NSWP-A-15 and BwAP 330-10 requkements to issue a PIF for the tempering line snuboer considered inoperable. Specifically, the 2D feedwater tempering line snubber had been determinad to be inoperable (based on station operator log entries) and a PIF had not been issued to document the inoparable stetus of this equipment.

(2) On November 10,1997, the licensee failed to follow NSWP-A 15 and BwAP 330-10 requirements to issue a PIF when a pro'clem was recognized /identif;ed on steam generator 2D main feedwater line snebbers (2FWO5011S, .FW95013S, & 2FWO5022S).

Specifically, problems with thes3 mubbers had been recognized / identified in action requests (970084651,970084666, 970084667) on November 10,1997, and corrected prior to documenting the problem in PlF A1997-5074 " Snubbers 2FWO5011S,2FWO5013S, & 2FWO5022S Suspect," on November 13,1997.

This is a Severity Level IV violation (Supplement ;) ?57/97021-W(DRS)).

Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby required to submit a written statement or explanation to the U.S. Nucien Regalatory Commission, ATTN:

Document Control Desk, Wasliington, D.C. 20555 with a copy to the Regional Administrator, Region 111, and a copy to the NRC Resident inspector at the facility that is the subject of this Notica, within 30 days of the date of the letter trar,smitting this Notice of Violation (Notice). This reply should be clearly marked as c " Reply to a Notice of Violation" and should include for each violation: (1) the rwson for the violation, or, if contested, the basis for disputing tlie violat%r. or severity level, (2) tne corrective steps that have be6n taken and the resuits achieved, (3) the corrective steps that will be taken to avoid fuither violaticas, and (4) the date whei i all compliance will be achieved. Your response may reference or include previous docketed correspondence,if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such ot' ?r action as mey be proper should not be taken. Where good cause is shown, consideration wili De given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

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'.e Notice of Violation 3 j Because your response will be placed in the NRC Public Document Room (PDR), to the extent

_ possible, it should not include any personal privacy, proprietary, or safeguardo information so -

- that it can be placed in the PDR without redaction, if personal privacy or proprietary information is necessary to provide an acceptable response, than please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If'you request withholding of such material, you met specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information), if safeguards information is necessary to provide an acceptable response, please provide the leve! of protection described in 10 CFR 73.21.

Dated al Lisle, Illinois the lit?i day of February 1998 7

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