ML20216D376
| ML20216D376 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/26/1997 |
| From: | Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Stanley H COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20216D383 | List: |
| References | |
| 50-456-97-09, 50-456-97-9, 50-457-97-09, 50-457-97-9, EA-97-265, EA-97-321, NUDOCS 9709090301 | |
| Download: ML20216D376 (7) | |
See also: IR 05000456/1997009
Text
{{#Wiki_filter:- r2 'p . . , g M4g UNITE] STATES ,c . 4 NUCLEAR REZULATORY COMMISSION t g S REGION lli \\ % ! 801 WARRENVILLE RoAo y\\ ...../ usLE, ILuNOts 00532-4351 August 26,1997 EA 97-265 EA 97 321 Mr. H. G. Stanley Site Vice President Braidwood Station Commonwealth Edison Company RR #1, Box 84 Braceville,IL 60407 SUBJECT: NRC INSPECTION REPORT 50 456/97009(DRP): 50-457/97009(DRP) < NOTICE OF VIOLATION Dear Mr. Stanley: On June 30,1997, the NRC completed an inspection at your Braidwood 1 & 2 reactor facilities. The enclosed report presents the results of that inspection. , During the 6-week period covered by this inspection period, your conduct of activities was I generally characterized by safety-conscious operations. Specifically, the preparation for and conduct of the Unit 1 startup, as observed by the inspectors on May 24 25, demonstrated excellent safety focus and strong control room teamwork. Inspectors also ' found that your post event response to the spill of sater from the boric acid storage tank was well organized, timely, and demonstrated a good safety focus. However, based on the results of this inspection, one apparent violation of NRC requirements was identified and is being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. On May 22,1997, during a review of Technical Specification (TS) surveillance test requirements, NRC inspectors identified that the centrifugal charging pump casings and discharge piping high points outside of containment had not been vented as required by TS 4.5.2.b.1. In fact, the subject casings and piping had never been vented during Modes 1,2, and 3. This is considered an apparent violation of TS 4.5.2.b.1 which requires that each emergency core cooling system (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. We are also concerned that you did not seek a TS change after \\ discovering in February 1996 that your staff's surveillance testing practices relative to this issue were not in strict compliance with the TS. No Notice of Violation is presently being issued for the failure to vent the centrifugal charging pump casings and discharge piping. In addition, the number and characterization of the apparent violations described in the enclosed inspection report may change as a result of further NRC review. ,. . ,/ g{{{{M.l{{i {*{[kkk ' h 0709090301 970826 ' PDR ADOCK 05000456 .L . - O PDR '
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_ . _ _ _ _ - _ _ _ _ - - _ - - - _ - , , . . H. G. Stanley 2- A predecisional enforcement conference to discuss the apparent violations has been scheduled for Peptember 11,1997, at 10:00 a.m. (CDT) in the Region lli office in Lisle, Illinois. This meeting will be open to the public. The decision to hold a pre-decisional enforcement conference does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. This conference is being held to obtain information to enable the NRC to make an enforcement decision, including a common understanding of the facts and circumstances surrounding the violation, their root causes, your opportunities to identify the apparent violation sooner, your corrective actions, and the significance of the issues. In addition, this is an opportunity for you to point out any errors in our inspection report and for you to provide any information concerning your perspectives on: 1) the severity of the violations, 2) the application of the factors that the NRC considers when it determines l the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other application of the Enforcement Policy to this case, including the exercise of discretion in accordance with Section Vll. You will be advised by separate correspondence of the results of our deliberations on this matter. No response regarding the apparent violations is required at this time. The inspectors were also concemed about several other violations that occurred during the inspection period. The first violation involved the failure to have an adequate procedure
for draining portions of the chemical and volume control system. The lack of an adequate procedure resulted in a 1900 gallon spill from the Unit 1 boric acid storage tank. The inspectors also identified that the spill occurred because operators had a weak understanding of the system configuration, did not use a procedure to perform the draining evolution, and did not use good practices such as ensuring a clear drainage path and adequately verifying drain flow during the evolution. The inspectors concluded that even if the inadequate procedure had been used and followed the spill would have occurred. A degraded flood seal in the boric acid storage tank room floor allowed leakage into the Unit 2 diesel driven auxiliary feed pump room and onto the diesel engine and its associated components rendering the pump inoperable. Second, a violation was identified for failure to test four manual isolation valves in accordance with the TS. These valves met the definition of a containment isolation valve but were not listed as containment isolation valves in the TS and were not verified closed every 31 days as part of a TS surveillance test. Operators demonstrated a good questioning ottitude by raising the issue of the need to tost these valves. However, your staff's review of this issue failed to identify that testing these valves was required by the technical specifications. Review by the inspectors and by the Office of Nuclear Reactor Regulation (NRR) concluded that the valves in question do fall under the technical specification requirements. - . . . ._.
, - . . . . . . .. . . H. G. Stanley 3- Thltd, a violation was identified by NRC inspectors where the Maintenance Rule was not properly implemented for the post accident neutron monitors (PANM). Your staff failed to perform an adequate historical review of PANM performance for the 3 years prior to the implementation date for the maintenance rule. As a result, they did not identify that the performance of the PANM had not been effectively controlled through the performance of appropriate preventive maintenance. Available maintenance history demonstrated that the PANM did not meet reliability goals. This oversight resulted in the failure to properly categorize the monitors, the failure to establish and monitor appropriate goals, and the failure to establish corrective actions. l ! These violations are cited in the enclosed Notice of Violation, and the circumstances surrounding the violations are described in detailin the enclosed report. Please note that you are required to respond to this letter and should follow the instructions specified in the l enclosed Notice when preparing your response. Your response should not only detall the
actions to be taken for the specific issues identified, but should also be broadly focused on f what actions you plan or have taken to ensure that your corrective actions process is , j effective. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. , In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC Public Document Room (PDR). Sincerely, Y ' Geoffrey E. Grant, Director Division of Reactor Projects Docket Nos: 50-456, 50-457 License Nos: NPF-72, NPF-77 Enclosures: 1. Notice of Violation 2. Inspection Report 50-456/97009(DRP); 50 457/97009(DRP) See attached distribution
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,>4 . . H. G. Stanley 4 cc w/oncl: T. J. Maiman, Senior Vice President Nuclear Operations Division D. A. Sager, Vice President, Generation Support H. W. Keiser, Chief Nuclear Operating Officer T. Tulon, Station Manager T. Simpkin, Regulatory Assuranca Supervisor 1. Johnson, Acting Nuclear Regulatory Services Manager Richard Hubbard Nathan Schloss, Economist Office of the Attorney General State Liaison Officer 1 Chairman, Illinois Commerce Commission 1 Document Control Desk Licensing l l
_ - . _ _ . _ - _ _ _ _ _ _ _ _ _ . . H. G. Stanley 3- Third, a violation was identified by NRC inspectors where the Maintenance Rule was not properly implemented for the post accident neutron monitors (PANM). Your staff failed to perform an adequate historicalleview of PANM performance for the 3 years prior to the implementation date for the maintenance rule. As a result, they did not identify that the performance of the PANM had not boon effectively controlled through the performance of appropriato preventive maintenanco. Available maintenance history demonstrated that the PANM did not moot reliability goals. This oversight resulted in the failure to properly categorize the monitors, the failure to establish and monitor appropriate goals, and the failure to establish corrective actions. These violations are cited in the enclosed Notice of Violation, and the circumstances surrounding the violations are described in detailin the enclosed report. Please note that you are requiiod to respond to this letter and should follow the instructions specified in the
onclosed Notice when preparing your response. Your response should not only detail the actions to be taken for the specific issues identified, but should also be broadly focused on what actions you plan or have taken to ensure that your corrective actions process is effective. The NRC will use your response,in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC Public Document Room (PDR). Sincerely, /s/ M. L. Dapas for Geoffrey E. Grant, Director Division of Reactor Projects Docket Nos: 50-456,50 457 License Nos: NPF-72, NPF-77 Enclosures: 1. Notice of Violation 2. Inspection Report 50 456/97009(DRP); 50-457/97009(DRP) , See attached distribution PLEASE SEE PREVIOUS CONCURRENCES DOCUMENT NAMD R$1NSPHPTSJOWERSiBRAhBRA97009 DNP v. . . . ..,y .e ini. .. ni no... . . in. . c . c.,y in.oi .ti.cnm.nie.nci . . c.,y .in .ti. cam.nii.n .. N . N. copy OF rice NH l MN l Nil l ' NH l HIH l6 uut t on9 .,.. r. , sa..,o,in ci, vion t.,*.yr S.cie.n M2.1 6.etion A4.1 DAi[ 08/ 19 7 08/ 19 7 081 19 7 08/ 19 7 08/1h 7 ot tict Nu j, u ut o,.n, //p,; p h r Dart ei 9g 197 OFF6CIAL RECORD COPY
__ .. . . . H. G. Stanley 3- effective. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC Public Document Room (PDR). Sincerely, !
Geoffrey Grant, Director ' Division of Reactor Projects l Docket Nos: 50 456, 50-457 Licenso Nos: NPF 72, NPF 77 Enclosures: 1. Notice of Violation 2. Inspection Report 50 456/97009(DRP); 50 457/97009(DRP) cc w/ encl: T. J. Maiman, Senior Vice President Nuclear Operations Division i D. A. Sager, Vice President, Generation Support H. W. Keiser, Chief Nuclear Operating Officer T. Tulon, Station Manager T. Simpkin, Regulatory Assurance Supervisor l. Johnson, Acting Nuclear j ! Regulatory Services Manager Richard Hubbard Nathan Schloss, Economist Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission Document Control Desk-Licensing DOCUMENT NAME: M.UNSPAPT SiPOWE RS SRMSRA 9,009.DhP To receve e copy of tNo document. secate en the hos *C* e Copy vethout ettechment/ enclosure "E' = Copy wdh stischmentlenelosure "N* = No
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- _ _ ____ _ _ - __ _ _ _ . . H. G. Stanley -4- t cc w/ encl: T. J. Maiman, Senior Vice President Nuclear Operations Division D. A. Sager, Vice President, Generation Support H. W. Keiser, Chief Nuclear Operating Officer T. Tulon, Station Manager T. Simpkin, Regulatory Assurance Supervisor 1. Johnson, Acting Nuclear Regulatory Services Manager Richard Hubbard Nathan Schloss, Economist Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission Document Control Desk Licensing l Distribution: Docket File w/ encl DRP w/ encl OC/LFDCB w/enci Rlli PRR w/enct PUBLIC IE-01 w/enct CAA1 w/enci(E mail) SRI Byron, Braidwood, Zion w/eri i Rlli Enf Coordinator, w/enct Project Mgr., NRR w/ encl A. B. Beach, w/ encl RAC1 (E-Mail) Deputy RA, w/ encl TSS w/enci DRS (2) DOCDESK (E mail) J. Lieberman, OE w/enci J. Goldberg, OGC w/enci R. Zimmerman, NRR w/enci i }}