ML20216B061

Notice of Violation from Insp on 980127-0309.Violation Noted:On 971010,21,1219 & 980105,licensee Failed to Require Independent Verification of Proper Sys Alignment for safety-related Valves Repositioned in Steps F.1.4 & F.1.7

ML20216B061
Person / Time
Site:	Braidwood
Issue date:	04/08/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20216B037	List: ML20216B032 ML20216B061 ML20216B076
References
50-456-98-02, 50-456-98-2, 50-457-98-02, 50-457-98-2, NUDOCS 9804130359
Download: ML20216B061 (2)

Text

.

NOTICE OF VIOLATION l

Commonwealth Edison Company Docket Nos. 50-456; 50-457 Braidwood Station License Nos. NPF-72; NPF-77 Braceville, Illinois  ;

. During an inspection conducted from January 27,1997, through March 9,1998, two 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:

l

1. Technical Specification 6.8.1.a requires that procedures be established, implemented, l and maintained for activities recommended in Appendix A of Regulatory Guide 1.33, i Revision 2, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, Section 1.c, i states that there should be administrative procedures for equipment control of safety-

l. related systems.

t Braidwood Updated Final Safety Analysis Report, Section 9.2.1.2.3, states, in part, that the entire essential service water system is designated as a Safety Category 1 system (safety-related).

! Bra!dwood Administrative Procedure (BwAP) 100-18, "Braidwood Station Independent l Verification Procedure," Revision 3, Step E.1, states, in part, that independent verifications of proper system alignment shall be required during the perform.ance of l

safety-related surveillance test procedures in which valves are repositioned.

Contrary to the above on October 10,1997; October 21,1997; December 19,1997; and January 5,1998, the licensee failed to require the independent verification of proper system alignment for safety-related valves repositioned in steps F.1.4 and F.1.7 of Braidwood Sunreillance Procedure 0.5-3.SX.1-1 "ASME [American Society of Mechanical )

Engi ners) Surveillance Requirements for the 1 A/2A Essential Service Water Pumps,"

! Revision 1: and Braidwood Surveillance Procedure 0.5-3.SX.1-2, "ASME Surveillance Requirements for the 1B/2B Essential Service Water Pumps," Revision 1.

L

!- This is a Severity Level IV violation (Supplement l} (50-456/98002-02(DRP); i 50-457/98002-02(DRP)).

I n 2. Technical Specification 6.8.1.g states, in part, that written procedures shall be j l

established, implemented, and maintained covering the Fire Protection Program '

! implementation. i SWAP 1100-1, " Fire Protection Program," Revision 3, implemented the Fire Protection  ;

Program. SWAP 1110-1, Attachment 4, "GOCAR [ Gene O'Donnell Contingency Action Requirements] Index Carbon Dioxide Fire Suppression Systems," Revision 2, stated that with one or more carbon dioxide systems unavailable to the Unit i lower cable spreading room, establish a continuous fire watch within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in accordance with BwAP 1100-13,

" Fire Watch inspection." BwAP 110013, Revision 6, Step D.4, stated, in part, that a continuous fire watch shall require that each location within the specified area be  ;

observed at least once every 15 minutes, with a margin of 5 minutes.

9804130359 980478 PDR G ADOCK 05000456 l .

PDR =

I

]

l Notice of Violation '. Contrary to the above, on January 29,1998, the Unit i lower cable spreading Room 1Z1

' of Zone IZ had no cart >on dioxide suppression system available and was not patrolled by a continuous fire watch every 15 minutes for three separate 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> penods, as required i by BwPA.1100-13, Step D.4.

This is a Severity Level IV violation (Supplement I) (50-456/98002-03(DRP). j 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. Nuclear Regulatory Commission, ATTN.:

Document Control Desk, Washington D.C. 20555 with a copy to the Regional Administrator, U.S.

Nuclear Regulatory Commission, Region lil, 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 l- letter transmitting this Notice of Violation (Nohce). This reply should be clearly marked as a L " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the l violation, or, if contested, the basis for disputir.g 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 i

or include previous docketed correspondence, if the consspondenco adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice,

sn order or a demand for information may be issued as to why the license should not be l modified, suspended, or revoked, or why such other schon as may be proper should not be L taken. Where good cause is shown, consideration will be given to extending the response time.

l.

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.

Because your response will be placed in the NRC Public Documeat 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 proprietasy information is I

,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 muni L specifically identify the portions of your response that you seek to have withheld and provide in l l detail the f.cses for your claim of withholding (e.g., explain why the disclosure o', information will L 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 level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois this 8tn dayof April 1998

)

i I

i

.