ML20216D475

Notice of Violation from Insp on 970520-0630.Violations Noted:Licensee Had Not Demonstrated That Performance or Condition of Pams Was Being Effectively Controlled Through Performance of Appropriate Preventive Maint

ML20216D475
Person / Time
Site:	Braidwood
Issue date:	08/26/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20216D383	List: IR 05000456/1997009 ML20216D376 ML20216D475
References
50-456-97-09, 50-456-97-9, 50-457-97-09, 50-457-97-9, NUDOCS 9709090327
Download: ML20216D475 (3)

Text

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NOTICE OF VIOLATION l Commonwealth Edison Company Docket Nos. 50-456; 50-457 Braidwood Station License Nos. NPF-72; NPF-77 Braceville, Illinois As a result of an inspection conducted from May 20 through June 30,1997, t!.ree 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

1. 10 CFR 50.65(a)(1) requires, in part, that the holders of an operating license monitor the performance or condition of structures, systems, and components against licensee established goals, in a manner sufficient to provide reasonable l assurance that such structures, systems, and components, within the scope of the '

rule, are capable of fulfilling their intended functions. When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken.

10 CFR 50.65(a)(2) specifies,in part, that monitoring as specified in 10 CFR 50.65 paragraph (a)(1) is not required where it has been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance, such that the structure, system, or component remains capable of performing its intended function.

Contrary to 10 CFR 50.65(a)(2), the inspectors identified that as of July 10,1996, at which time the licensee elected not to monitor the performance or condition of the post accident neutron monitoring system against licensee-established goals pursuant to the requirements of Section (a)(1), the licensee had not demonstrated that the performance or condition of the post accident neutron monitoring system was being effectively controlled through the performance of appropriate preventive maintenance. This was evidenced by recurrent and sustained periods between July 10,1993, and July 10,1996, where the post accident neutron monitoring system was out-of service and unable to perform its designated function.

This is a Severity Level IV violation (Supplement I) (50-456/97009-02(DRP);

50-457/97009-02(DRP)).

2. Technical Specification 6.8.1.a states,in part, that prucedures shall be established, implemented, and maintained covering the activities referenced in Appendix A, of Regulatory Guide 1.33, Revision 2. February 1978. Regulatory Guide 1.33, Appendix A, Section 3.n. discusses the need for instructions to drain the chemical and volume control system. The boric acid storage tanks are part of the chemical and volume control system.

9709090327 970826 PDR ADOCK 05000456 G PDR

-i 2 Notice of Violation -2 Contrary to the above, as of June 9,1997, procedure BwOP CV 24, " Draining The CV System," Revision OE1, used to drain the chemical and volume control system, was inadequately established in that it did not include instructions to drain the boric acid storage tanks. The failure to have an adequate procedure for this evolution resulted in the Unit 1 boric acid storage tank being drained to the floor of the boric acid storage tank room.

This is a Severity Level IV violation (Supplement 1) (50 456/97009-01(DRP)).

3. Technical Specification 4.6.1.1.a, states, in part, that primary containment integrity shall be demonstrated at least once per 31 days by verifying that all penetrations not capable of being closed by operable containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, '

or deactivated automatic valves secured in their positions.

The Technical Spocification 4.6.1.1.a surveillance test requirement is implemented by 1(2)BwOS 6.1.1.a 1, " Unit One (Two) Primary Containment Integrity Verification Of isolation Devices Outside Containment," Revision 7E2.

Contrary to the above, on October 4,1996, the licensee identified that the instrument vent and drain valves for pressure indicators 1(2)PI-929, which were required to be closed to maintain containment integrity, were not listed in surveillance test procedure 1(2)BwOS 6.1.1.a 1, " Unit One (Two) Primary Containment integrity Verification Of isolation Devices Outside Containment,"

Revision 7E2 and had not been verified closed on a 31-day frequency.

This is a Severity Level IV violation (Supplement 1) (50 456/97009 04(DRP);

50-457/97009-04(DRP)).

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 111,801 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 letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and 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 received within the time specified in this Notico, an order or a demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why j

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Notice of Violation- 3-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.

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. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Lisle, Illinois this 2futi day of August,1997

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