ML20211Q848

From kanterella
Jump to navigation Jump to search
Notice of Violation from Insp on 970714-0815.Violation Noted:Licensee Failed to Assure That Degraded Voltage Relay Testing for Divs 11,12,21 & 22 Was Performed Under Suitable Environ Conditions
ML20211Q848
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 10/17/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211Q839 List:
References
50-456-97-12, 50-457-97-12, NUDOCS 9710230030
Download: ML20211Q848 (5)
v • d • e


Text

. . . . . . . .

NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50-456; 50-457 Braldwood Nuclear Power Station, Units 1 & 2 License Nos. NPF 72; NPF 77 During an NRC inspection conducted on July 14 through August 15,1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

1. 10 CFR 50, Appendix B, Criterion XI,
  • Test Control,' requires that a test program be established to assure that all testing required to demonstrate that structures, systems, and components (SSCs) will perform satisfactorily in service is identified and performed in accordance with written test procedures which include provisions for assuring that the testing is performed under suitable environmental conditions.

Contrary to the above:

-- a.

The licensee failed to perform Braidwood Electrical Maintenance Department Surveillance (BwHS) 4009-035, ' Containment Penetration Conductor -

Overcurrent Protective Devices From 480 Volt Switchgear," for the 2D reactor evitainment fan cooler (RCFC) high speed fan breaker and the 1D RCFC low speed fan breaker on February 28,1996 and April 19,1997, under suitable environmental conditions. Specifically, the breakers were manually cycled to ensure no excessive binding or friction existed in the operating mechanism just prior to testing the overcurrent protective devices. As a result, the environment was altered and the data obtained did not rep"esent testing under suitable environmental conditions.

b.

The licensee failed to assure that degraded voltage relay testing for divisions 11, 12,21, and 22 was performed under suitable environmental conditions.

Specifically on April 6,1997; April 20,1997; April 8,1996; and March 26,1997; division 11,12,21 and 22 degraded voltage timers were preconditioned by performing BwHS 4002-091, " Time Delay Relay Surveillance," just prior to performing Braidwood Surveillance Procedure (BwVS) 3.2.2 4, 'Undervoltage Time Response 18-Month Surveillance," to meet requirements set forth in Technical Specification Table 4.3 2.

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

(50-456/97012 01; 50-457/97012 01) 2.

10 CFR 50.59(a)(1) requires, in part, that a licensee may make changes in the facility as described in the safe'y analysis report, make changes in the procedures as described in s

' the safety analysis report, and conduct tests or experiments not described in the safety analysis report, without written Commission approval, unless the proposed change, test, or experiment involves a change in the licensee's technical specifications or an unreviewed safety question.

9 9710230030 971017

Notice of Violation 2 10 CFR 50.59(b)(1) requires, in part, that the licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section and that those records must include a written safety evaluation which must provide the basis for a determination that the change, test, or experiment does not involve an unreviewed safety question,

a. Braidwood Updated Final Safety Analysis Report (UFSAR), Revision 6, Section 6.3,
b. 10 CFR 50.34(b)(6)(ii), ' Contents of Applications; Technical Information," states that the Final Safety Analysis Report shallinclude managerial and administrative controls to be used to assure safe operation and that the information on the controls to be used for a nuclear power plant shall include a discussion of how the applicable requirements of 10 CFR 50, Appendix B," Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants," will be satisfied, Braidwood UFSAR, Revision 6, Chapter 17, " Quality Assurance," states that the Braidwood quality assurance program is conducted in accordance with the Commonwealth Edison Quality Assurance (QA) Program for Nuclear Generating Stations which was submitted to and approved by the NRC ss Topical Report CE 1.

Braidwood UFSAR, Revision 6, Chapter 17,

  • Quality Assurance," also states that Commonwealth Edison Topical Report CE-1-A is the basis for the QA program at Braidwood.

Commonwealth Edison Topical Report CE-1 A, Revision 65f, Section 20 Paragraph 3.3.1, states that the station manager shallindependently review and approve the findings and recommendations developed by personnel performing the Onsite Review and Investigative (OSR) Function.

Contrary to the above:

a. On July 30,1996, a 10 CFR 50.59 safety evaluation to gag closed safety injection pump discharge relief valve 2Sl8851 failed to provide an adequate basis, in writing, that the change did not involve an unreviewed safety question.

Specifically, the evaluation failed to address the fact that American Society of Mechanical Engineers (ASME) Section lli Code requirements for relief valves (Article NC 7000) would not be met with 2Sl8851 gagged closed.

1

Notice of Violation 3

b. On March 31,1997, the licensee failed to perform a 10 CFR 50.59 safety evaluation to revise Braldwood Administrative Procedure (BwAP) 1205 3,
  • Onsite Review and Investigative Function," to allow the Plant Onsite Review Committee (PORC) to fulfill the OSR function although the station manager was the chairman of the PORC and his/her ability to independently review and approve the findings and recommendations developed by personnel performing the OSR function as required by Topical Report CE 1 A could be affected.

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

(50-456/97012-02;50-457/97012-02)

3. 10 CFR 50, Appendix B, Criterion Ill,' Design Control," requires that measures shall be established to assure that applicable regulatory requirements and the design basis, for those structures, systems, and components to which the apDendix applies, are correctly translated into spec;fications, drawings, procedures, and instructions.

10 CFR 50, Appendix 0, Criterion 111 also requires that design control measures shall provide for verifying or checking the adequacy of the design, such as by performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program, f

Contrary to the above, on July 23,1997, design control measures established for checking the adequacy of calculation PSA 9513, Revision 0," Byron /Braidwood Minimum Auxiliary Feedwater Flow for Feed Line Break Analysis," failed to identify non-conservative and unrealistic flow resistance assumptions.in the calculation.

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

(50-456/97012-03;50-457/97012-03)

4. 10 CFR 50, Appendix B, Criterion XVI," Corrective Actions," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, on July 22,1997, the team identified that since initial plant construction the Unit i refueling water storage tank (RWST) heater had not been mounted to the RWST tunnel floor in accordance with design drawings. As a result, the probability of a seismic event challenging the integrity of the Unit i RWST heating system and draining the RWST was increased.

This is a Severity Level IV violation (Supplement 1) (50-456/97012 04)

o '

Notice of Violation 4

5. 10 CFR 50, Appendix B, Criterion V, ' instructions, Procedures, and Dravdogs,' requires, in part, that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with those procedures.

Braidwood Administrative Procedure (BwAP) 1250-2,

  • Problem Identification and investigation Procedure," Revision 5, dated July 2,1996, requires that a person identifying a problem that may affect the operability of plant systems or equipment shall immediately notify the rhift engineer.

Contrary to the above, on February 21,1997, licensee personnel failed to inform the shift engineer when a problem regarding 2A safety injection (SI) pump lube oil filter inlet pressure, which may have affected the operability of the 2A SI pump, was identified.

This is a Severity Level IV violation (Supplement 1). (50-457/97012-05)

6. 10 CFR 50, Appendix B, Criterion XV,
  • Nonconforming Materials, Parts or Components,"

requires, in part, that measures shall be established to control material, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shallinclude, as appropriate, procedures for "

identification, documentation, segregation, disposition, and notification to affected

  • organizations.

Contrary to the above, on February 18,1997, licensee measures failed to effectively control and prevent the installation of a non-environmentally qualified breaker in a harsh environment. Specifically, the licensee installed a non environmentally qualified circuit-breaker in the 1 A residual heat removal pump minimum flow valve circuit breaker cubicle, which was considered to be a harsh environment.

This is a Severity Level IV violation (Supplement 1). (50-456/97012-06)

Pursuant to the provisions of 10 CFR 2.201, Commonwealth "dison is hereby required 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, Region 111, and a copy to the NRC Rosident inspector at the facility that is the subject of this Notice, 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" Ma 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 adequate reply is not

Notice of Violation 5 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 other action as may be proper should not be taken. .Where good cause is shown, consideration will be given to extending the response time. Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

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 PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then 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 must 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 govide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

E Dated at Lisle, Illinois '

this 17 th day of October 1997 1

_ _ . _ _ . _ _ _ _ _ _ - - _ - - _ _ -

Retrieved from "https://kanterella.com/w/index.php?title=ML20211Q848&oldid=3246681"