ML20237C536
| ML20237C536 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/23/1987 |
| From: | Butterfield L COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8712210366 | |
| Download: ML20237C536 (3) | |
Text
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) One First National Plaza, Chicago, Illinois '
n i( C J Address Riply to: Post Offics Box 767
~ 'v Chicago, Illinois 60690 0767 '
l October-23, 1987 l
Mr.' A. Bert Davis
' Regional Administrator.
U.S. Nuclear Regulatory Commission
~ Region III-799 Roosevelt Road-Glen Ellyn,.-IL 60137-i
Subject:
Braidwood Station Unit 1 Response to Inspection Report No.
l' 50-456/87-029 NRC Docket No. 50-456 Reference-(a):
C. E. Norelius letter to C. Reed dated September 25, 1987 i
Dear Mr. Davis:
6 This letter is in response to the inspection conducted by Messrs.
l T. M. Tongue, et. al.'on August 2 through September 12, 1987, of activities at
..Braidwood Station'. Reference (a) indicated that certain activities appeared to be in violation of NRC requirements. Attachment A of this letter contains Commonwealth Edison's response to the Notice of Violation enclosed with reference (a).
This violation involved the temporary alignment of the residual heat removal'(RHR) system during post maintenance testing of RHR train B.
While we acknowledge;that a procedure violation occurred during this event, our review of this matter has not concluded that a violation of Technical Specifications 3.5.2 and 3.0.3 occurred. We recognize there may be a difference of opinion regarding this issue and feel that additional discussions would be helpful in order to reach a common interpretation of the relevant Technical Specifications.
Commonwealth Edison, therefore, will initiate a request for a meeting with representatives from NRC Region III and the Office of Nuclear Reactor Regulation to discuss this subject. We are optimistic that this approach will yield a
' resolution of the issue which allows us the necessary flexibility for operation and maintenance of the affected equipment, while assuring safe operation of the plant.
If you have any further questions on this matter, please direct them to
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this office.
en Vrgy truly yours, N
L. D. Butterfield
' d oco Nuclear Licensing Manager uN on gd ag Attachment nw D$
cc: NRC Resident Inspector - Braidwood g
NRC Document Control Desk 0 1387 l
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,4 ATTACHMENT A Commonwealth Edison Company Response to Inspection Report 456/87-029 Violation (456/87-029-01)
Technical Specification (TS) 3.5.2 requires that.two independent emergency core cooling system (ECCS) subsystems shall be operable with each subsystem comprised in part of an operable flow path in Modes 1, 2, or 3.
Alteration of the discharge flowpath of Reactor Heat Removal (RHR) system is allowed in Mode 3 only.
Technical Specification 3.0.3, which applies when TS 3.5.2 is not met, requires that within one hour the licensee shall initiate action to place the unit in a Mode in which the specification does not apply.
Technical Specification 6.8.1 states that written procedures recommended in Appendix A or Regulatory Guide 1.33, Revision 2, February 1978, shall be established and implemented.
Procedure BwOP RH-5, Revision 51, "RH System Startup for Recirculation,"
Section E.4 states that in Modes 1-3, 1RH8716A and B must be open and in Section F.13 requires verification that.1RH8716A and B are open in Modes 1, 2, and 3.
Contrary to.the above, on August 8, 1987, while in Mode 1 at 29% power with the "B" Train of RHR out of service for maintenance, Motor Operated Valve IRH 8716A was closed. This resulted in the 1A RHR Train being capable of only injecting into two rather than four reactor coolant loop cold legs, thereby being inoperable. Consequently, both trains were inoperable for one hour and four minutes without taking action to place the reactor'in a mode in which TS 3.5.2 did not apply.
Response
Valve IRH8716A was in the closed position for one hour and four minutes on j
August 8, 1987. Commonwealth Edison acknowledges this activity was in j
violation of Braidwood Operating Procedure BwOP RH-5.
However, Commonwealth Edison does not believe that the level of degradation induced on the residual heat removal system during this event constituted a violation of Technical specifications 3.5.2 and 3.0.3.
Commonwealth Edison plans to schedule a
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meeting with the NRC to discuss this matter further.
Corrective Action Taken and Results Achieved Valve 1RH8716A was returned to its normally open position 64 minutes after it was closed on August 8, 1987. The personnel involved with this event have been counseled on the importance of procedural compliance and the programmatic requirements for temporarily deviating from approved procedures. This was completed August 10, 1987 3759K L-
,s Correctivg_ Action Taken to Avoid Further Violation caution cards were placed on the control switches for the RH8716 valves as of August 25, 1987. The caution cards further reinforce the fact that manipulation of the valves while in Modes 1 through 4 may result in a violation of the Technical Specifications. The caution cards will remain in place until the issue of Technical Specification compliance has been resolved.
Date of Full Compliance Pull compliance has been achieved.
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