ML20247E762
| ML20247E762 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/08/1998 |
| From: | Tulon T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-456-98-02, 50-456-98-2, 50-457-98-02, 50-457-98-2, NUDOCS 9805180455 | |
| Download: ML20247E762 (6) | |
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May 8,1998 Document Control Desk US Nuclear Regulatory Commission Washington, D.C. 20555 l
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Subject:
Reply to Notice of Violation NRC Inspection Report 50-456(457)/98002 Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-457
Reference:
G. Li. Grant letter to O. D. Kingsley dated April 8,1998, transmitting Notice of Violation from inspection Report 50-456(457)/98002 l
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3 Results from a six-week inspection that ended on March 9,1998, were documented in the Inspection Report specified in the above reference. A Notice of Violation (NOV) was also transmitted with the above reference and included two Severity Level IV violations related to procedures which lacked proper guidance for independent verifications and fire l
watch concerns. Comed's response to the violations is included in the attachment to this letter.
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l Braidwood has continued to place emphasis on the station's fire protection program.
Examples of actions that have been implemented or are being pursued include: adding l
employees to the fire watch staff to allow for better interaction of fire watch personnel in l
the field, simplifying fire protection processes to ensure fire zone checks are done
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consistently, enhancing procedures, and addressing the backlog of work requests associated with fire protection (with special focus on items generated greater than one year ago).
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l In addition to the efforts being pursued in the fire protection area, the Station has also i
been working to improve the quality of the work instructions provided to workers. The I
site has focused attention on administrative procedures by starting a review cycle for i
these procedures and working to eliminate any redundant or unnecessary instructions that j
may hinder worker's performance.
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9805100455 980508 PDR ADOCK 05000456
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The' Station recognizes the significance of maintaining a strong fire protection program and providing clear guidance to plant personnel. Efforts will continue in these areas to l
resolve identified weaknesses and improve performance.
l The following commitments were made in the attachment to this letter:
The requirements stated in BwAP 100-18,"Braidwood Flation Independent Verification Procedure,"
will be communicated to personnel in Engineering and the Procedure Writing Group.
Procedure reviews will be pursued until there is sufficient confidence that independent verification t
requirements are properly characterized in Station procedures.
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The Engineering Support Training Advisory Committee will evaluate the independent verification
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requirements stated in BwAP 100-18 and the NOD Writer's Guide for consideration ofinclusion in periodic continuing training.
If your staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801, extension 2980, i othy J. Tulon ite Vice President Braidwood Nuclear Generating Station Attachment ec:
A.B. Beach, NRC Regional Administrator, Region Ill S. Bailey, Project Manager, NRR C.J. Phillips, Senior Resident Inspector F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS i
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ATTACHMENT I REPLY TO NOTICE OF VIOLATION (50-456:457/98002-02)
- 1. Technical Specification 6.8.1.a requires that procedures be established, implemented, and maintained for activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, Section 1.c, states that there should be administrative procedures for equipment control of safety-related systems.
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 I system (safety-related).
Braidwood Administrative Procedure (BwAP) 100-18,"Braidwood Station Independent Verification Procedure," Revision 3, Step E.1, states, in part, that independent verifications of proper system alignment shall be required during the perfonnance of 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 Surveillance Procedure 0.5-3.SX.1-1 "ASME (American Society of Mechanical Engineers) 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 IB/2B Essential Service Water Pumps,"
Revision 1.
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REASON FOR Tile VIOLATION Steps F.1.3 and F.1.4 of 1/2BwVS 0.5-3.SX.1-1 and 1/2BwVS 0.5-3.SX.1-2 were added on June 12,1992, and step F.1.7 was added in a procedure revision implemented in May 1996. The failure to recognize that the procedure lacked independent verification requirements in the initial procedure and subsequent revisions is attributed to a weakness in the revision and review process applied to the subject procedures. Personnel involved in the procedure revision development and review were not aware of the specific independent verification requirements stated in BwAP 100-18, paragraph E.1.d.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED 1/2BwVS 0.5-3.SX.1-1 and 1/2BwVS 0.5-3.SX.1-2 were reviewed and revised on March 3,1998, to include the necessary instructions for performing independent verifications.
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION (50-456:457/98002-02)
ACTIONS TAKEN (TO BE TAKEN) TO PREVENT RECURRENCE The independent verification requirements documented in BwAP 100-18, "Braidwood Station Independent Verification Procedure," and the NOD Writer's Guide have been reviewed. The Engineering Support Training Advisorv Committee will evalmte the information stated in these documents for consitration ofinclusion in periodic continuing training.
The requirements stated in BwAP 100-18 will be communicated to personnel in Engineering and the Procedure Writing Group.
Approximately 650 procedures maintained by System Engineering and Operations have been reviewed to date to ensure compliance with the requirements stated in BwAP 100-
- 18. These reviews have resulted in the identification of approximately 90 procedures that require enhancements. Some of the revisions have been completed, while other revisions are currently being pursued. The site will continue to pursue the precedure reviews until there is sufficient confidence that independent verification requirements are properly characterized in Station procedures.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when 1/2BwVS 0.5-3.SX.1-1 and 1/2BwVS 0.5-3.SX.1-2 were revised to incorporate guidance for independent verifications.
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ATTAC11 MENT 1 REPLY TO NOTICE OF VIOLATION (50-456:457/98002-03)
- 2. Technical Specification 6.8.1.g states, in part, sat written procedures shall be l
established, implemented, and maintained covering the Fire Protection Program implementation.
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BwAP 1100-1," Fire Protection Program," Revision 3, implemented the Fire Protection Program. BwAP 1110-1, Attachment 4,"GOCAR (Gene O'Donnell l
Contingency Action Requirements)Index Carbon Dioxide Fire Suppression I
Systems," Revision 2, stated that with one or more carbon dioxide systems j
unavailable to the Unit I le;..d ceble spreading room, establish a continuous fire watch within I hour in accordance with BwAP 1100-13," Fire Watch Inspection."
BwAP 1100-13, revision 6, Step D.4, stated, in pert, that a continuous fire watch shall l
require that each location within the specified area be observed at least once every 15 minutes, with a margin of 5 minutes.
l Contrary to the above, on January 29,1998, the Unit I lower cable spreading Room IZ1 of Zone IZ had no carbon dioxide suppression system available and was not I
patrolled by a continuous fire watdi 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 /> I
periods, as required by BwAP 1130-13, Step D.4.
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REASON FOR THE VIOLATION It was determined that the individual assigned to perform the continuous fire watch did not read the post orders as required and assumed that his firewatch post was for fire zone lZ2. Based on a review done of the fire routes assigned to the individual who monitored the incorrect fire zone, it was determined that routes were missed on January 28,1998 and January 29,1998, due to the erroneous assumption.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The individual who had been assigned to perform the firewatch was relieved of his post i
following the identification of the concern. The individual who replaced the initial l
firewatch was questioned to ensure he was aware of his responsibilities. Whcn it was determined that the replacement individual was cognizant of his duties, this firewatch l
proceeded to promptly check fire zone lZ1 and continue monitoring the area as required.
The Braidwood Station Fire Marshal evaluated the circumstances of the event. It was determined that other fire watch personnel had entered zone lZ1 at different times during the two days the individual had made the improper assumption. In addition, fire 3
t ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION (50-456:457/98002-03) detection equipment, hose stations, fire extinguishers, and the station's fire brigade were available at the time zone 1Z1 was not monitored as required.
The fire watch inspector who made the improper assumption was appropriately disciplined. In addition, the individual was counseled regarding the importance of reading post orders on a shiftly basis and informed of the proper use of three way communications.
ACTIONS TAKEN TO PREVENT RECURRENCE Firewatch personnel were retrained on the subject of three way communications to enhance communications during job tumover when specific job tasks are assigned as well as improving communications in the field. Firewatch personnel now perform verbal turnovers in addition to reviewing post orders at the start of each continuous post.
Additional supervisors have been added to the firewatch work force to allow for additionaljob interaction with the firewatch field workers. As a result of this increase in staff size, additional route checks take place on a daily basis.
The Station has enhanced BwAP 1100-13," Fire Watch Inspection," to simplify processes and provide clearer work instructions to workers for compensatory fire watch actions.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when fire zone 1Z1 was monitored as required.
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