ML20235U149
| ML20235U149 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 09/24/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 3607K, NUDOCS 8710130384 | |
| Download: ML20235U149 (7) | |
Text
(~'N Commonwealth Edison N-
) One First Nitional Plaza, Chicago, Illinois
(
O' KdC. 3ss Reply to: Post Office Box 767
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Chicago, Illinois 60690 0767 September 24, 198?
l Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Braidwood Station Units 1 and 2 Response to Inspection Report Nos.
50-456/87023 and 50-457/87022 NRC Docket Nos. 50-456 and 50-457 Reference (a):
C. E. Norelius letter to Cordell Reed dated August 25, 1987
Dear Mr. Davis:
This letter is in response to the inspection, conducted by Messrs.
T.H. Tongue, W. J. Kropp, T. E. Taylor and'N. Choules during June 21 through August 1, 1987, of activities at Braidwood Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company recponse to the Notice of Violation is provided in the enclosure. Commonwealth Edison does not believe that Violation 2.b is an example of the cited violation.
It is Braidwood's position that the j
Technical Specification surveillance requirement was fulfilled at all times.
The basis for our position is included in the enclosure along with a request that this example of the violation be withdrawn.
If you have any further questions on this matter, please direct them to this office.
Very truly yours,
. $. b":
L. D. Butterfield Nuclear Licensing Manager 1m Attachment 1
cc: NRC Resident Inspector - Braidwood Document Control Desk 8710130304 870924 3
PDR ADOCK 05000456 3607K o
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ATTACHMENT COMMONWEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT NO.
456/87-023 VIOLATION (456/87-023-02 1.
Technical Specification 3/4.7.1.5 requires each Main Steam Isolation valve (MSIV) to be operable in Modes 1, 2, and 3.
In Mode 2, with ona MSIV inoperable, the valve must be maintained c2osed in order to continue operation. Otherwise, the reactor must be in Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Hot Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Contrary to the above, on June 5 and 6, 1987, the 1B MSIV was inoperable for maintenance, and open for over 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> while the reactor remained in Mode 2 (startup).
RESPONSE
Commonwealth Edison acknowledges that the IB MSIV was inoperable for maintenance and open for about 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> and 40 minutes while the reactor remained in Mode 2.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED R
Upon discovery, the valve was closed and secured in the closed position via a specially fabricated hydraulic pump / cylinder assembly and two 3/4" diameter wire ropes with come-alongs.
Subsequent calculations performed by the Technical Staff verified that the two 3/4" diameter wire ropes were adequate to regag the valve closed in place of the single 1/2" diameter wire rope that had broken.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION l
Maintenance Procedure BwMP 3200-010, Revision 0 " Periodic Inspection and Repair of MSIV Actuators" is deficient in that it provides no guidance for l
depressurizing the actuator cylinder prior to maintenance on the actuator.
It j
had been erroneously believed that depressurizing the accumulators would depressurize the entire hydraulic system. This procedure is expected to be l
revised by October 15, 1987, to provide guidance for depressurizing the MSIV l
actuator and to provide proper cable sizing for blocking the MSIV closed.
This event was reviewed with Mechanical Maintenance Department on July 31, 1987 to make them aware of the results and highlight the significance.
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The event will also be reviewed with each operating Shift to emphasize the need to thoroughly investigate and resolve all alarms. These i
reviews are expected to be completed by October 31, 1987.
l DATE WHEN FULL COMPLIANCH I
All corrective actions are expected to be in place by October 31, 1987.
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i GENERAL DISCUSSION By Reference (a) a requect was made that Braidwood address specific concerns related to personnel not believing instrumentation and the need to pursue conflicting information.
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As noted in the body of Reference (a) the Nuclear Station Operator on shift did notice the " Steam Line Isolation" annunciator clear and realized that the alarm clears when all four MSIV's are open. He conferred with the Shift Engineer and an Equipment Attendant was summoned to the Control Room for instructions prior to being dispatched to investigate the situation. The Shift Foreman entered the Control Room and indicated that he had just been at the valve and it was closed. The investigation was terminated at this time.
This event will be reviewed with each operating Shift, emphasizing the importance of proper, complete investigations of alarms. Additionally, all members of each operating crew will spend, together as a crew, one full day away from the Station attending a program on Professionalism in Operations.
Among the many aspects to be stressed are good, complete followup checks on all work items.
Braidwood operating Management continues to emphasize the Station philosophy of taking the time to do the job right the first time.
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VIOLATION (456/87-023-01) 2.
Technical Specifications, Paragraph 4.0.2, requires that surveillance shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance interval.
Contrary to the above the licensee exceeded the 25% extension of some surveillance intervals.
Examples of these failures to perform the surveillance within the extended time interval are as follows:
a.
On May 4, 1987, while preparing to perform quarterls surveillance IBWVS 0.5-2.1, "ASME surveillance Requirements for SX Valves," the licensee discovered that the critical.date (normal frequency plus 25%) for the surveillance had been exceeded.
l b.
On May 27, 1987, the licensee discovered that surveillance 1BwoS 3.3.6-1, " Accident Monitoring," had exceeded its critical date due to a scheduling error, c.
On June 17, 1987, the licensee discovered that IBwOS 3.2.1-808 had excegf.*d its critical date due to a scheduling error, The original comp >*er data input had a-frequency of 550 days. Tae actual TechrJeal Specification requirement is 92 days. On February 9, 1987, I
the schedule error was noted and the frequency was changed to 92 days. When the frequency was changed, the licenree failed to perform the surveillance and change the next due date which would have prevented exceeding the critical date.
RESPONSE
Commonwealth Edison acknowledges that items a. and c. above are examples of exceeding the 25% extension of the surveillance interval.
However, we do not believe that item b. above is an example of the cited violation. It is Commonwealth Edison's positior,that the Technical Specification surveillance requirement was fulfilled at all times. Our position is set forth in the attached response with a request that this example of the violation be withdrawn.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED - 2.a Procedure 1BWVS 0.5-2.1 was successfully executed on May 2, 1987.
l This was prior to the applicable Deviation Report being issued (on May 4, 1987), as noted in the Inspection Report.
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CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION - 2.a The surveillance data packagc cover sheet, BwAP 1400-9T1, was revised on March 18, 1987.
The revision includes boxes to be checked to indicate a complete or partial surveillance. This revision was implemented subsequent to the erroneous January 30, 1987, " complete surveillance" entry of the partial surveillance into the General Surveillance Program. This revision should i
insure that a partial surveillance is not inadvertently considered as a I
complete surveillance.
i A review has been performed of Technical Staff surveillance and Operating Department surveillance to determine if other partial surveillance were credited as complete surveillance. None were found.
j DATE OF FULL COMPLIANCE - 2.a Full compliance has been achieved.
RESPONSE - 2.b Braidwood Station acknowledges that Procedure 1BwOS 3.3.6-1 was not scheduled or executed between March 29, 1987 and May 27, 1987. Upon j
discovery, the procadure was promptly executed with satisfactory results.
1 However, it is Braidwood's position that the Technical Specification surveillance requirement was fulfilled at all times. 'the requirement in question is a monthly Channel check of the Accident Mcnitoring Instrumentation.
1 By definition 1.6 of the Braidwood Technical Specifit:ations:
A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation.
This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
The parameters in question are displayed in the control room. All control room instrumentation is required by BwAP 335-1, " Operating Shift Turnover and Relief" to be monitored at each shift change. All off-normal indications are required to have written comments explaining the deviation.
These walkdowns are documented in accordance with the above procedure.
Performing the walkdowns separately are a minimum of two Nuclear Station
Operators and the Station Control Room Engineer. These walkdowns are administrative 1y reviewed by a minimum of two other individuals, the Shift Engineer and Shift Foreman. Braidwood is confident that the walkdowns required by BwAP 335-1 are sufficient to provide a qualitative assessment of a channel's condition. This belief is strengthened by the NRC's determination of the adequacy of shift turnovers, as d cumented in the Operational Readiness Inspection Report, 50-456/87018, pages 3-6:
Turnover between individuals were observed to be lengthy and methodical, implementing detailed checklists and performing panel walkdowns.
Operators were alert and attentive to panel instruments and alarms at all times.
All shifts were found to be fully aware of plant status.
In addition to fulfilling the channel check requirement via BwAP 335-1 and IBwOS 3.3.6-1, 18 of the 22 parameters are further monitored by other surveillance. This inherent conservatina ensures that the failure of a single administrative control does not result in a Technical Specification violation. For scheduling purposes, only IBwOS 3.3.6-1 is designated in the surveillance program as fulfilling the Technical Specification requirement.
For the reasons stated above, Braidwood has determined that a qualitative assessment of the Accident Monitoring Channels behavior was conducted at a frequency much greater than the required monthly interval.
Additionally, a citatiori for a Technical Specification violation in this case l
would indicate that no credit can be taken for redundant controls or l
activities. This defeats any incentive to take extraordinary measures to ensure Technical Specification compliance.
Braidwood does not believe that this is a Technical Specification violation and requests that this example of the cited violation be withdrawn.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED - 2.c Procedure 1BwOS 3.2.1-808 was successfully executed on June 17, 1987.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION - 2.c Procedure BwAP 1400-2 " Surveillance Request Form Completion" was revised on September 18, 1987 to insure that surveillance due dates are checked if the base frequency is changed. Additionally, the General Surveillance Program will be revised to provide a warning to check due dates if frequencies are changed.
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DATE OF FULL COMPLIANCE The General Surveillance Program revision is expected to be complete.
by. January 31, 1988..
GENERAL DISCUSSION.
Braidwood Station acknowledges that the three instances cited did occur,.and two of the occasions rendited in Technical Specification
--violations. 'It must be noted that the root cause of each occurrence is l
- different, and actions taken to date have been effective in ensuring that
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surveillance are not missed,'for the.same reasons.
However, because of several inconsistencies in'the execution and'
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administration of the surveillance program that.have' occurred, Braidwood requested.that INPO perform an. independent assessment of the adequacy of'the
. surveillance. program.' This evaluation was-conducted from August'- 10-13, 1987.
No' programmatic inadequacies were identified. Recommendations for enhancements were made, and these recommendations are currently being evaluated by the.
station.
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