ML20215H820
| ML20215H820 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/28/1987 |
| From: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20215H818 | List: |
| References | |
| 50-456-87-07, 50-456-87-7, 50-457-87-06, 50-457-87-6, NUDOCS 8705070078 | |
| Download: ML20215H820 (2) | |
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NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on February 15 through April 11, 1987, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the following violations were identified:
a.
10 CFR 50, Appendix B, Criterion II, as implemented by Commonwealth Edison Company Quality Assurance Manual, Section 2.0, states that the Quality Assurance program shall provide control over activities affecting quality.
Contrary to the above, prior to March 29, 1984, Avoid Verbal Orders (AV0s) were utilized by the construction electrical contractor, L.K. Comstock, to direct the electrical craft in the rework or reinstallation of electrical components but were not described or proceduralized in LKC's Quality Assurance Program.
As a result, measures were not established to ensure that the installation activities directed by these AV0s were subsequently inspected by the LKC Quality Control Department.
This is a Severity Level IV violation (Supplement II).
b.
10 CFR 50, Appendix B, Criterion V, as implemented by Commonwealth Edison's Quality Assurance Manual requires that " Maintenance which can affect the performance of safety-related equipment shall bc properly preplanned according to written procedures and in accordance with documented instructions, procedures, or drawings...."
Contrary to the above, several maintenance lubrication program administrative requirements as prescribed by Procedure No. BwAP 370-1,
" Station Lubrication Program," were not being performed. Additionally,-
the licensee did not have instructions or procedures for authorization j
of lubrication activities nor provisions for post lubrication restoration functional checks.
This is a Severity Level IV violation (Supplement I).
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c.
Technical Specification, Section 3.7.11 action statement, requires that "With one or more of the required fire rated assemblies and/or sealing devices inoperable, within one hour either establish a continuous fire watch on at least one side of the affected assembly, or verify the operability of fire detectors on at least one side of the inoperable assembly and establish an hourly fire watch patrol."
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Contrary to the above requirements, the licensee failed to establish the required fire watches within the stated time period.
Three examples of such occurrences are as follows:
(1) On February 17, 1987, at approximately 1035 hours0.012 days <br />0.288 hours <br />0.00171 weeks <br />3.938175e-4 months <br />, the Operating Department was informed that detection zone 10-8, located in the 401' elevation of the auxiliary building was in TROUBLE alarm.- Per Technical Specification 3.7.11, Fire Rated Assemblies, a continuous fire watch was required to be established in the area within one hour after the detection zone beccme inoperable.
A review of the available Main Control Room alarm history indicated that the alarm was received on February 13 at 1606 hours0.0186 days <br />0.446 hours <br />0.00266 weeks <br />6.11083e-4 months <br />.
A period of ninety-one hours and thirty-nine minutes passed before a continuous fire watch was established in the area.
(2) On March 28, 1987, an hourly fire watch failed to patrol the 416' elevation of the auxiliary building within the required one hour time limit.
The fire patrol was 25 minutes late due to the patrolman not having signed the latest Radiation Work Permit.
(3) On March 31, 1987, the hourly fire watch requirement was not met due to late relief of the fire watch assigned to patrol the auxiliary building 426' and 451' elevations.
This is a Severity Level IV violation (Supplement I).
With respect to Item a., the inspection showed that action had been taken to correct the identified violation and to prevent recurrence.
Consequently, no reply to the violation is required and we have no further questions regarding this matter. With respect to Items b. and c., pursuant to the provisions of 10 CFR 2.201 you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in rtoly, including for each violation:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3; the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
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M /997 bd Wated
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William 5. Eittle(Director Braidwood Project