ML20212F877
| ML20212F877 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/28/1997 |
| From: | Tulon T COMMONWEALTH EDISON CO. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 50-456-97-09, 50-456-97-9, 50-457-97-09, 50-457-97-9, NUDOCS 9711050127 | |
| Download: ML20212F877 (4) | |
Text
Qunmonw ra!th Idrum Company Ilreldwtnid Ccncrating Stat (tin Route el, Ikix H i liracetille, IL N)lo7%lii TelMIC W M01 6
October 28,1997 Mr. James Lieberman Director, Oflice of Enforcement U.S. Nucle.ar Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
Subject:
Braidwood Station Units 1 and 2 Reply to a Notice of Violation and Proposed imposition of Civil Penalty NRC Docket Numbers 50-456 and 50-457
References:
- 1) G. E. Grant letter to H. G. Stanley dated August 26,1997, transmitting NRC Inspection Report Number 50-456 (457)/97009
- 2) G. E. Grant letter to H. G. Stanley dated September 17,1997, transmitting NRC Predecisional Enforcement Conference Report
- 3) A. B. Beach letter to H. G. Stanley dated October 3,1997, transmitting Notice of Violation and Proposed Imposition of Civil Penalty from NRC Inspection Report 50-456/457/97009
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Details from an inspection conducted at Braidwood Statiot during a six-week period ending on June 30,1997, were documented in a report transmitted with Reference 1.
A Predecisional Enforcement Conference was held on September 11,1997, to discuss an apparent violation that was issued in the report. This apparent violation was associated with a literal Technical Specification compliance concern where Emergency Core Cooling System (ECCS) pump casings and discharge high points outside of
/
g containment were not vented as required. A summary of the discussion that was held dl at the Enforcement Conference was transmitted with Reference 2.
Finally, the Reference 3 riecument was transmitted with a Notice of Violation and Proposed Imposition c: Civil Penalty which resulted from the disposition of the apparent violation.
t Comed's response to the violation is included in the Attachment to this letter. Also, please find enclosed a check in the amount of $55,000 made payable to the Treasurer of the United States.
9711050127 971029 PDR ADOCK 05000456 PDR
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- Document Control Desk -
10/28/97 Page 2
. The importance of strict Technical Specification compliance.has been communicated to Station personnel. Braidwood Station takes compliance issues very seriously and works to expeditiously resolve _any concerns that are identified. It is understood that the Technical Specifications _ are to be implemented as written or appropriate regulatory communications are to be initiated to resolve any compliance issues.
The fo!!owing commitment was made in the Attacht, nt to this letter:
The Plant Operational Review Committee (PORC) at both Braidwood and Byron Stations will review Technical Specification compliance. issues raised at either-station. This is expected to be a redundant examination of compliance questions.
This redundant review will be conducted for approximately a one year period, at which time a determination will be made whether this process should be cen::nued.
If your staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801, extension 2980.
i l
T' thy J.:Tulon
' e Vice President
- 5raidwood Nuclear Generating Station-Attachment -
cc; A.B.-Beach, NRC Regional Administrator, Region III -
G.F. Dick, Jr., Project Manager, NRR C.J. Phillips, Senior Resident Inspector _
F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS Document Control Desk a:t.ac'97122mtdoc
, ATTACIBiENT I REPLY TO NOTICE OF VIOLATION ylOLATION (50456(4571/9700'))
Technical Specification 3.5.2 requires that two independent emergency core cooling system (ECCS) subsystems be operable with the units in Modes 1,2, and 3 with each subsystem comprised of a) one operable centrifugal charging pump; b) one operable safety injection pump; c) one operable residual heat removal (RHR) heat exchanger; d) one operable RHR pump; and e) an operable flow path capable of taking suction from the refueling water storage tank on a safety injection signal and automatic opening of the containment sump suction valves.
Technical Specification Surveillance 4.5.2.b(1) requires that eac: ECCS subsystem be demonstrated operable at least once per 31 days by venting the ECCS pump casings and discharge piping high points outside of containment.
Contrary to the above, since commercial operation began in 1987 and 1988, respectively, for Unit I and Unit 2 and continuing until May 1997, an ECCS subsystem consisting of the centrifugal charging (CV) pump had not been demonstrated operable at least once per 31 days by venting the casing and CV high points outside containment when the units were in Modes 1,2, and 3.
REASON FOR THE VIOLATION in 1996, a Problem Identification Form (PIF) w:.s generated by an individual in Braidwood's System Engineering group which questioned whether the Station was in compliance with Technical Specifications because the centrifugal charging (CV) pump casings and dead leg of piping to 1/2 S18801 A/B valves were not vented every 31 days.
This question was evaluated.
It was erroneously concluded that the intent of Technical Specification 4.5.2.b(1) was satisfied based on the fact that the CV pump was under constant pressure and the design of the pump had the suction and discharge lines off the top of the casing (therefore, casing vents would not be required and therefore, were not installed). Station personnel believed 4
- the system was dynamically vented and the Technical Specification requirements were being satisfied.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED A Notice of Enforcement Discretion (NOED) was requested and granted to both Braidwood and Byron Stations on May 24,1997, for the operating units. In addition, appropriate licensing submittals were made. Approval of the final submittal was granted on August 13,.997.
I
, ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION -
VIOLATION (50-456(457)/97009)
The CV system configuration was reviewed and the locations of dead leg CV piping (piping which could not be directly vented) were identified. It was determined that Ultrasonic Testing (UT) was an effective method to verify no air had accumulated in these dead leg piping locations. UT testing is now performed at the identified locations on the required frequencies. No voids have been identified at Braidwood Station. The UT exams 6 the piping support the conclusion that the CV system's functional capability to perform its intended safe
- function was not impacted. In addition to the CV system, the Safety Injection (SI) ana Residual Heat Removal (RH) system configarations were also reviewed. No unvented piping outside of containment was identified for those systems.
ACTIONS TAKEN TO PREVENT RECURRENCE A memorandum issued by the Braidwood's Site Vice President was distributed to Station personnel on September 10, 1997, stressing the importance of literal compliance with Technical Specifications. In addition, a more detai!ed version of this letter was provided to personnel from selected work groups. The importance ofliteral compliance was also communicated to the Shift Managers and Engineering personnel.
Both Braidwood and Byron Stations performed an independent review of selected Technical Specification surveillances.
Several Technical Specification sections were reviewed based on their highest potential for difficulties to be encountered. This review involved a comparison between the words in the Technical Specifications with the actual approved surveillances. The review revealed no additional compliance issues.
The possible need for license amendments are routinely evaluated as !icense compliance concerns are raised. In addition, the Plant Operational Review Committee (PORC) at both Braidwood and Byron Stations will review Technical Specification compliance issues raised at either station. This is intended to be a redundant examination of compliance questions in addition to the normal reviews conducted by each site line organization. This redundant review will be conducted for approximately a one year period, at which time a determination will be made whether this process should be continued.
DATE WHEN FULL COMPLI ANCE WAS ACHIEVED Full compliance was achieved when the appropriate License Amendments were issued.
The final submittal was approved on August 13,1997.
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