ML20203D915

Notice of Violation from Insp on 971216-980126.Violation Noted:In Nov 1989,licensee Failed to Initiate Deviation Rept & Take Corrective Measures to Preclude Repetition of Mechanical Failure to All 4 Main Feedwater Check Valves

ML20203D915
Person / Time
Site:	Braidwood
Issue date:	02/20/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203D912	List: ML20203D909 ML20203D915 ML20203D920
References
50-456-97-22, 50-457-97-22, NUDOCS 9802260197
Download: ML20203D915 (3)

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NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50-456; 50-457 Braidwood Station License Nos. NPF 72; NPF-77 Braceville, Illinois During an NRC inspection conducted from December 16,1997, through January 26,1998, three violations of NRC requirements were identified. in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

1. 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Actions," states, in part, that

" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action is taken to preclude repetition."

Braidwood Admini trative Procedure (BwAP) 1250-2, " Deviation Reporting," Revision 2, Step C.1, defined a deviation as "a departure from accepted equipment performance

...which results in, or could, if uncorrected, result in a failure of an item to perform as required by Technical Specification or approved procedures." Step C.3.a.4 required that a person identifying a deviation initiate a doviation report. Step C.3.d.1.b required that any additional corrective action required to investigate, correct the condition, or to prevent recurrence be determined and specified.

Contrary to the above, in November 1989, the licensee failed to iriitiate a deviation report and to take corrective measures to preclude repetition of a mechanic;l failure to all four main feedwater check valves (2FWO79A, B, C, and D). Insufficient clearance between the piston rod bushing and the valve bonnet bore was identified as the cause of all four check valve failures. On May 10,1997, and April 21,1997, maintenance work packages for the Unit 1 feedwater check velves FWO79A and FWO79D did not specify the steps to machine the rod piston bushing to as3ure adequate clearance with the valve bonnet bore.

This is a Severity Level IV violation (Supplement 1) (50-456/97022-01(DRP);

50-457/97022 01(DRP)).

2. Tecnnical Specification 6.8.1.a requires that procedures be established, implemented, and maintained for activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Regulatory Guide 1.33, Revision 2, Appendix A, Saction Ba, stated procedures of a type appropriate to the circumstances should be provided to ensure that tools gauges, instruments, controls, and other measuring and testing devices are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy.

Procedure BwAP 400-4, " Control of Portable Measuring and Test Equipment (M&TE),"

Revision 10E1, Step F.6.a.1.b, stated that the M&TE storage facility will be locked when unmanned.

9802260197 990220 PDR ADOCK 05000456 G PDR

Notice of Violation 2-Contrary to the above, on November 26, December 1,2, and 3,1997, the licensee failed to implement Procedure BwAP 400-4 Step F.6.a.1.b, in that the mechanical maintenance M&TE storage facility located on the 426-elevation of the auxiliary building was left unlocked and unattended. Additionally, on December 12,1997, the instrument maintenance department M&TE storage facility located on the 401 elevation of the turbine building was left unlocked and unattended.

This is a Severity Level IV violation (Supplement 1) (50-456/97022 02(DRP);

50-457/97022-02(DRP)).

3. 10 CFR Part 50, Appendix B, Criterion lit, " Design Control," states, in part, that " Measures shall be established to ensure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and instructions. These measures shallinclude provisions to assure that appropriate quality standards are specified and included in design documents, and that deviations from such standards are controlled."

Contrary to the above, on December 29,1997, the licensee had failed to assure that applicable regulatory requirements and the design basis were translated into specifications and drawings for two steel structures (local leak rate test shacks) which had been erected in the auxiliary building, a safety-related building, over containment penetrations, safety related components. Specifically, these structures were not included in design documents and in plant design drawings.

This is a Severity Level IV violation (Supplement 1) (50-456/97022 03(DRP);

50-457/97022-03(DRP)).

Regarding items 1 and 2, pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby requirad to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region !ll,801 Warrenville Road, Lisle, Illinois 60532, and a copy to the NRC Resident inspector at the Braidwood Station within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an acequate reply is not received within the time sp6cified 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 other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Regarding item 3, the NRC has concluded that information regarding the reason for the violation, the corrective action taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in Inspection Report 50-456/97022; 50-457/97022. Consequently, no reply to item 3 is required,

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and we have no further questions regarding this matter. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position, in that case, or if you choose to respond, proceed as with items 1 and 2 above.

! 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.

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 safeguards information so that

.. It can be placed in the POR without redaction, if personal privacy or proprietary information is j: necessary to provide an acceptable response, then please provide a bracketed copy of your L response that identifies the information that sh uld be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you mlal

! specifically identify the portions of your response that you seek to have withheld and provide in a' 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 provice me information required by 10 CFR 2.790(b) to support a request for withholding confiderA, cammercial or financial information). If safeguards information is necessary to provide ww:ceptable response, please 4 provide the level of protection described in 10 CFR 73.21.

i Dated at Lisle, Illinois l this 20th day of February 1998 4

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