ML20248D082

Notice of Violation from Insp on 980310-0420.Violation Noted:On 980303,licensee Failed to Implement Braidwood Administrative Procedure 2321-18T11,Step E.1,for Sf Pool Skimmer Strainer Level Control

ML20248D082
Person / Time
Site:	Braidwood
Issue date:	05/19/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248D069	List: IR 05000456/1998005 ML20248D065 ML20248D082
References
50-456-98-05, 50-456-98-5, 50-457-98-05, 50-457-98-5, NUDOCS 9806020318
Download: ML20248D082 (3)

Text

NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos.: 50-456; 50-457 Braidwood Station License Nos.: NPF-72; NPF-77 During an inspection conducted from March 10 through April 20,1998, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure fo.- NRC Enforcement Actions," NUREG-1600, the violations are listed below:

1. Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978.

Section 9.e of Regulatory Guide 1.33 recommends that general procedures be developed for modification work.

Braidwood Administrative Procedure (BwAP) 2321-18T11, " Determination of Temporary Alterations (TALTs)," Revision 3E1, Step C.1, defines a temporary alteration as a change to the fit, form, or function of any operable system, structure, component, or circuit that does not conform to approved drawings or other approved design documents.

BwAP 2321-1BT11, Step E1, requires if a system or component is retumed to service with a temporary change installed then the temporary change must be converted to a temporary alteration.

Braidwood Design Drawing 583F017, " Spent Fuel Pool Cooling System Skimmer Strainer Assembly Arrangement and Installation Assembly," Revision 3, indicates that the original design of the spent fuel pool skimmer strainers consisted of tee-handled adjustment assemblies attached to the side of the spent fuel pool to position the strainers within the spent fuel pool.

Contrary to the above, as of March 3,1998, the licensee failed to implement Braidwood Administrative Procedure 2321-18T11, Step E.1, for the spent fuel pool skimmer strainer level control. The original design of the spent fuel pool skimmer strainer level control was altered in that the tee-handled adjustment assembly was replaced with a rope attached to the suction hose and a temporary alteration evaluation had not been completed.

This is a Severity Level IV violation (Supplement l} (50-456/98005-03(DRP);

50-457/98005-03(DRP)).

2. Technical Specification 5.6.2, states that the spent fuel storage pool is designed and shall .

l be maintained to prevent inadvertent draining of the pool below elevation 423 feet 0 inches.

Contrary to the above:

a. On March 3,1998, the inspectors identified that the spent fuel pool design would not have prevented inadvertent draining below 423 feet 0 inches because the spent fuel pool skimmer system discharge line entered the pool and extended down to an elevation of 419 feet 6 inches without a siphon break.

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Notice of Violation <

b. On March 17,1998, the licensee identified that the flexible piping for the spent fuel pool skimmer suction was broken at an elevation of 420 feet. This indicated that contrary to Technical Specification 5.6.2 the spent fuel pool configuration was not being maintained to prevent inadvertent draining below 423 feet.

This is a Severity Level IV violation (Supplement I) (50-456/98005-04(DRP); 4 50-457/98005-04(DRP)).

3. 10 CFR Part 50, Appendix B, Criterion XVI, states, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.

Nuclear Station Work Procedure A-15, " Commonwealth Edison Nuclear Division Integrated Reporting Program," Revision 1, Step 1.1, states, in part, that the purpose of the Commonwealth Edison nuclear division integrated reporting program is to provide a consistent method for identifying conditions adverse to quality, establishing methods of investigating those conditions, identifying the root cause, developing appropriate I

corrective actions that will prevent recurrence, and providing data that can be used for trending. Step 6.1.1 of this procedure states, in part, that station individuals should initiate a problem identification form when a problem is recognized.

Ccntrary to the above, on September 12,1997, the licensee failed to initiate corrective actions with a problem identification form as required by Nuclear Station Work Procedure A-15, Step 6.1.1. The licensee failed to initiate corrective actions after identifying that the use of the Tri-nuclear underwater filtration systems in the spent fuel pool constituted a temporary alteration. Thus, as of April 20,1998, corrective actions were not initiated for cont:VI of this temporary modification.

This is a Severity Level IV violation (Supplement I) (50-456/98005-05(DRP);

50-457/98005-05(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:

l 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 Notice, an order or a demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why 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.

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If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001.

Because your response will be placed in the NRC Public Document Room, to the extent possible, I it should not include any personal privacy, proprietary, er safeguards information so that it can be l placed in the Public Document Room without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you mynt specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois this 19th day of May 1998 I-l i

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