ML20249A602
| ML20249A602 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 06/11/1998 |
| From: | Tulon T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-456-98-05, 50-456-98-5, 50-457-98-05, 50-457-98-5, NUDOCS 9806170131 | |
| Download: ML20249A602 (8) | |
Text
Commonwealth lifiv>n Company liraidwood Generating Station
. Route *l,ik)x HI firaceville.11.G407%I9 Tel 8104M2801 June 11,1998 Document Control Desk US Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Reply to Notice of Violation NRC Inspection Repott 50-456(457)/98005 Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-457
Reference:
G. E. Grant letter to O. D. Kingsley dated May 19,1998, transmitting Notice of Violation from Inspection Report 50-456(457)/98005 During a six-week inspection period that ended on April 20,1998, three Severity Level IV violations associated with spent fuel pool design issues were identified. These violations were documented in a Notice of Violation transmitted with the Reference letter. Comed's response to these violations is included in the attachment to this letter.
In the Reference letter, a request was made for Braidwood. Station to provide details on actions that have been taken or are being taken to ensure our corrective actions process is effective. As part of a corrective action improvement effort initiated two years ago, effectiveness reviews for items classified as "significant conditions adverse to quality"
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have been routinely assigned. Discretionary effectiveness reviews are also routinely performed at the direction of the Corrective Action Process (CAP) Manager. These
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reviews are scheduled to appropriately assess the individual and collective effectiveness of corrective actions taken to prevent recurrence. Since this process has been in effect, a significant number of effectiveness reviews have been performed.
T#ol In. addition, the station has been tracking the number of repeat events that occur.
Specifically, the number of events that result from previously investigated problems are monitored. Actions are required whenever two investigations are required in a month in an area where a root cause investigation had previously been conducted (within the past two years).
9906170131 980611
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t Document Control Desk June 11,1998.
- Page 2 The following commitments were made in the attachment to this letter:
Exempt change # E-204)-%-272 will be completed to replace the existing SFP skimmer with
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a floating skimmervessel.
=' Nuclear Station Work Procedure (NSWP) A-21 " Temporary Modifications," will be issued following the approval process in the Nuclear Generation Group. Training will be prosided to personnel as determined through the site's procedure resiew and approval process Braidwood Station will process a License Amendment Request to resise tie Design Feature
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description to identify a minimum Spent Fuel Pool level sufficient to ensure that the Standard Review Plan vace criteria will be met.
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.
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othy J. Tulon ite Vice President -
Braidwood Nuclear Generating Station l
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- TTr/FB/980X4jt. doc Attachment.
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cc:
C. J. Paperiello, Acting NRC Regional Administrator, Region III l
S. Bailey, Project Manager, NRR C.J. Phillips, Senior Resident Inspector F. Niziolek, Division of Engineering, Office ofNuclear Safety, IDNS I
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- ATTACHMENT 1
' REPLY TO NOTICE OF VIOLATION (50-456:457/98005-03) l 1.
Technical Specification 6.8.1.a states, in part, that written procedures shall be
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established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated Febmary 1978, Section 9.e of Regulatory Guide 1.33 recommends that general L
procedures be developed for modification work.
Braidwood Administrative Procedure (BwAP) 2321-18TI 1, " Determination of Temporary Alterations (TALTs)", Revision 3El, Step C.1, defmes 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 2321-18Til, Step F1, requires if a system or component is returned 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 i
Braidwood Administrative Procedure 2321-18Til, Step E.1, for the spent fuel w
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.
REASON FOR THE VIOLATION Following the recognition of the station's practice of using a rope on the Spent Fuel Pool (SFP) skimmer instead of the as built design (a T-handle), an investigation was conducted. Personnel from Operations, Fuel Handling, and I
System Engineering were interviewed to determine why the change to the skimmer design was not processed as a temporary alteration. Several employees remembered seeing the rope used on'the installed SFP skimmers for approximately six years, however none of these individuals thought to question l
the configuration as an unauthorized temporary alteration.
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ATTACHMENT 1
. REPLY TO NOTICE OF VIOL' TION A
-(50-456i457/98005-03)
The Temporary Alteration procedure in effect during the time frame that the rope was thought to be installed was reviewed. - It was determined that the definition of a mechanical alteration was sufficiently vague to allow this configuration to not be defined as a temporary alteration.
The root cause of this event was also attributed to a knowledge-based deficiency on the part of the individual (s) who failed to question the unauthorized temporary alteration. It is believed that station personnel developed a mindset that using rope to secure the installed SFP skimmer was an acceptable and evaluated practice.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The spent fuel pool skimmer assemblies were removed from the SFP and the skimmer loop was isolated by Out of Service (OOS) # 980002891.
Operability Determination # 98-021 was completed which determined that with the rope configuration the SFP skimmer and related structures, systems and components (SSCs) remained capable of performing their specified function. It was concluded, however, that the use of the ropes for level adjustments was an unauthorized temporary alteration.
1 Nuclear Operations Notification (NON) # BW 98-17 was issued to communicate this identifico concern to other Comed sites.
ACTIONS TAKEN (TO BE TAKEN) TO PREVENT RECURRENCE Additional emphasis has been placed on understanding and recognizing unauthorized temporary alterations in the plant. For example, Engineering personnel received training on this subject during Second Quarter Continuing Training (1997) and " clean sweeps" were pursued to locate any potential unauthorized temporary alterations in the plant.
Information on Temporary Alterations was communicated to station personnel
. during monthly communication meetings conducted by each work group in May 1998.
Exempt change # E-20-0-96-272 has been scheduled to replace the existing SFP
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skimmer with a floating skimmer vessel.=
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION (50-456:457/98005-03)
A Nuclear Station Work Procedure (NSWP) A-21," Temporary Modifications,"
will be issued following the approval process in the Nuclear Generation Group.
Training will be provided to personnel as determined through the site's procedure review and approval process.
DATE WHEN FULL COMPLIANCE WAS ACHIEYED Full compliance was achieved when the spent fuel pool skimmer assemblies were removed from the fuel pool and the OOS was placed to isolate the skimmer loop.
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' ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION (50-456:457/98005-04) 2.
Technical Specification 5.6.2, states that the spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 423 feet 0 inches.
Contrary to the above.
On March 3,1998, the inspectors identified that the spent fuel pool a.
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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On March 17,1998, the licensee identified that the flexible piping for the spent fuel pool skimmer suction was broken at an elevation of 42') 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.
REASON FOR Tile VIOLATION The 423 foot elevation was placed in the Technical Specification design features description because this value represents the elevation of the anti-siphon hole in the spent fuel pool (SFP) cooling discharge line. Consideration of the clean-up loop configuration and potential failure modes were not considered. These j
discrepancies occurred during the initial generation of the Technical
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Specifications.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED 1
Upon identification of the condition, a review of the design was initiated. It was concluded that the design is a standard Westinghouse design and is in compliance with Regulatory Guide 1.13 and that the Standard Review Plan (SRP) acceptance criteria of 10 feet above the fuel was met for potential dewatering scenarios.
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'The spent fuel pool skimmer assemblies were removed from the SFP and the skimmer loop was isolated by Out of Service (OOS) # 980002891.
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I ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION (50-456:457/98005-04) l ACTIONS TAKEN TO PREVENT RECURRENCE Due to the generic nature of the cooling and clean-up design, this issue has been referred to the Westinghouse Owner's Group (WOG) for consideration. In addition, repairs to the clean-up loop have been scheduled and a periodic replacement of the flexible hose with a five-year interval has been initiated.
Finally, Braidwood Station will process a License Amendment Request to revise the Design Feature description. This revision will identify the minimum Spent Fuel Pool level sumcient to ensure that the SRP acceptance criteria will be met.
DATE WHEN FULL COMPLI ANCE WILL BE ACHIEVED Full compliance will be achieved upon issuance of the L,icense Amendment revising the Design Feature description by the Omce of Nuclear Reactor Regulation (NRR).
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' 'TTACHMENT1 A
REPLY TO NOTICE OF VIOLATION (50-4,56:457/98005-05)
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.10 CFR Part 50, Appendix B, Criterion XVI, states, in pan, 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 Reponing 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 ofinvestigating those conditions, identifying the root cause, developing appropriate 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.
Contrary 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 Procedu : A-15, Step 6.1.1. The licensee failed to initiate corrective actions allei 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 control of this temporary modification.
REASON FOR THE VIOLATION
- Tri-Nuclear filters were originally used at the station during refueling activities, however due to water clarity concerns in the fuel pool, the use and capacity of this type of filter unit was expanded to normal operations.
The Braidwood Fuel Handling System Engineer issued a letter dated October 4, 1995, to the Fuel Handling Supervisor and a Maintenance Supervisor to address the adequacy of documentation of evaluations associated with portable equipment used in and around the Spent Fuel Pool and / or the Refuel Cavities. This letter concluded that the use of the Tri-Nuclear filter system was not a temporary alteration.
On September 12,1997, the same individual acting in a different job function generated a follow up memorandum which' revised the previously issued position and recommended that "a' station PIF be written to track this issue to completion unless the analysis and associated 50.59 have already been written." Engineering evaluated this information and determined that the use of Tri-Nuclear filter units should be governed by procedure, and that a more formal seismic evaluation should be documented.
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION l
(50-456:457/98005-05)
It was determined that a Problem Identification Form (PIF) was not required l
because personnel believed that adequate tracking would be provided by the Engineering Request (ER) process, the procedure tracking process, and a previous PIF which was generated as a result of earlier water clarity concerns in the Spent Fuel Pool.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED A Problem Identification Form (PIF) was written on April 1,1998, when it was recognized that the issue was not captured in the Corrective Action Program.
Corrective Actions for the PIF included the completion of ER # 9703068 to complete calculation BRW-DIT-98-0099. This calculation was completed to document the seismic efTects of placing the Tri-Nuclear filter units on top of the spent fuel racks at Braidwood. It was determined that the condition of operating with the Tri-Nuclear filter unit in the fuel pool was bounded and acceptable.
ACTIONS TAKEN TO PREVENT RECURRENCE BwFP FH-33, " Operation of the Tri-Nuclear Underwater Filtration Systems," was developed to provide guidance on the use of Tri-Nuclear filter units in the Spent Fuel Pool.
The Engineering Manager communicated the circumstances associated with this violation to Engineering personnel.
In December 1997, a tailgate was conducted with Engineering personnel to communicate the importance of promptly communicating any anomolous conditions which might affect plant / system operability to Shift management and to follow the requirements stated in the station's Problem Identification procedure. More recently, on May 28,1998, a memo was issued from the Corporate Engineering Vice President to all engineering personnel in the Nuclear Generation Group. This memo communicates expectations associated with generating Problem Identification Forms (PIFs).
l DATE WHEN FULL COMPLI ANCE W AS (WILL BE ACHIEVED)
Full compliance was achieved on April 1,1998, when the requirements of NSWP A-15, " Commonwealth Edison Nuclear Division Integrated Reporting Program,"
were satisfied.
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