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{{Adams | |||
| number = ML20198R242 | |||
| issue date = 10/03/1997 | |||
| title = Discusses Insp Repts 50-456/97-09 & 50-457/97-09 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000 | |||
| author name = Beach A | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) | |||
| addressee name = Stanley H | |||
| addressee affiliation = COMMONWEALTH EDISON CO. | |||
| docket = 05000456, 05000457 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-456-97-09, 50-456-97-9, 50-457-97-09, 50-457-97-9, EA-97-265, NUDOCS 9711130199 | |||
| package number = ML20198R245 | |||
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE | |||
| page count = 4 | |||
}} | |||
See also: [[see also::IR 05000456/1997009]] | |||
=Text= | |||
{{#Wiki_filter:. . _ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ - - ~ ~ ~ ~ ~ ~ - | |||
* | |||
, | |||
s# "%o UNITEo STATES | |||
y.- k NUCLEAR REGut.ATORY COMMISSION | |||
q S REGION Hi | |||
I | |||
E' 1E '31 WARRENVILLE ROAD | |||
g usLE, ILUNois 00532-4351 f* | |||
***** | |||
October 3, 1997 | |||
EA 97-265 , | |||
. | |||
Mr. H. G. Stanjay | |||
p | |||
Site Vice President | |||
Braidwood Station | |||
Commonwealth Edison Company | |||
RR #1, Box 84 | |||
Braceville, IL 60407 | |||
SUBJECT: NOTICE OF VIOLATION f ND PROPOSED IMPOSITION OF CIVIL PENALTY - | |||
$55,000 (NRC Inspectiori 6 sport No. 50-546/97009; 50-457/97009) | |||
Hb | |||
Dear Mr. Stanley: | |||
This refers to the inspection conducted from May 20 through June *o 0,1997, at the Braidwood Unit 1 | |||
and Unit 2 reactor facilities. An exit meeting ws conducted on June 30,1997, and the inspection | |||
report was issued on August 26,1997. A predecisional enforcement conference was conducted on | |||
September 11,1997, tn discuss t'a inspection issues related to strict compliance with Technical | |||
Specifications (TS) for the Emerg 2 cy Core Cooling System (ECCS) subsystems. Specifically, | |||
these issues are related to the Centrifugal Charging (CV) system, a subsystem of ECCS, | |||
Based on the information developed during the inspection and the information that you prwided | |||
during the conference, the NRC has determined that a violation of NRC requirements occurred. | |||
The violation is cited in the enclosed Notice of Violation (Notice) and Proposed imposition of Civil | |||
Penalty and the circumstances surrounding it are described in detailin the subject inspection | |||
report. | |||
The violation in the enclosed Notice involves the failure to strictly comply with TS surveillance test | |||
requirement 4.5.2.b(1) which requires the ECCS pump casings and discharge piping high points | |||
outside of containment be vented at least once every 31 days. On February 16,1996, a Braidwood | |||
Station system engineer discovered that the CV pump casing and high points were not being vented | |||
every 31 days as required. The decision to not strictly comply with the TS was partially based by | |||
the Braidwood Station staff on the fact that the CV pump casings did not have vents. A subsequent ' | |||
operability justification determined that the intent of the TS was being met based on factors such as | |||
the pressure in the piping and the CV system design and piping configuration. However, this y | |||
operability justification failed to recognize that TS requirements were not being strictly met and that | |||
a TS change was needed. The failure to recognize that the TS requirements J ! Y were not | |||
met and to seek a TS change was identified by the NRC. | |||
The potential safety consehe3delfl!EldiMs low. Venting of the ECCS is required to | |||
ensure that no air is entrained in the ECCS that could result in water hammer or air binding that | |||
could prevent proper pump /6@hlM pMo&n66 Due to the pressure in the CV system piping and | |||
the system contiguration, this was not likely to occur. In addition, the ultrasonic testing, performed | |||
by the Braidwood Station staff, of3 elept34 igh points found no entrained air. However, while | |||
< | |||
the potential safety consequenN EOM, latory significance is high. The Braidwood Station | |||
9711130199 971003 | |||
PDR ADOCK 05000456 | |||
"" | |||
l.llI.ll11ll . . lil.Ill. I.llll . | |||
. | |||
. | |||
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -____ _______ _____ _ | |||
.. | |||
H. Stanley -2- | |||
f | |||
staff continued to operate outside of TS requirements even after discovering that the TS was not | |||
being strictly complied with and NRC involvement was necessary in order to ensure that strict | |||
compliance with the TS requirements and the necessary TS changes were made. The failure to | |||
request the necessary TS changes denied the NRC the opportunity to determine whether safety | |||
issues were involved, | |||
Based on the foregoing, this violation has been categorized in accordance with the * General | |||
Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement Policy), NUREG- | |||
1600 at Severity Level ill, in accordance with the Enforcement Policy, a base civil penalty in the | |||
amount of $55,000 is considered for a Severity Level lli violation. Because your facility has been | |||
the subject of escalated enforcement actions within the last 2 years', the NRC considered whether | |||
credit was warranted for /dentification and Corrective Action in accordance with the civil penalty | |||
assessment in Section VI.B.2 of the Enforcement Policy, | |||
identification credit was not warranted because Braidwood Station staff had an opportunity to | |||
currect the violation in February 1996 when the TS noncompliance was identified. The NRC | |||
identified the continued violation of the TS surveillance testing requirements during the 1997 | |||
inspection. | |||
Corrective Action credit was warranted based on the corrective actions implemented and discussed | |||
at the enforcement conference. The corrective actions included (1) ultrasonic testing inspection of | |||
vulnerable areas in the CV system; (2) review of selected TS surveillance tests to verify strict | |||
compliance; (3) submittal of appropriate license amendment requests; (4) revision of affected | |||
procedures; and (5) distribution of a Station Manager letter which stresses strict compliance with | |||
TS requirementa. | |||
Therefore, to emphasize the importance of compliance with technical specifications, I have been | |||
authorized, after consultation with the Director, Office of Enforcement, to issue the enclosed Notice | |||
of Violation and Proposed imposition of Civil Penalty (Notice)in the amount of $55,000 for the | |||
Severity Level lli violation. | |||
You are required to respond to this letter and should fo!!ow the instructions specified in the enclosed | |||
Notice when preparing your response. The NRC will use your response, in part, to determine | |||
whether further enforcement action is necessary to ensure complianco with regulatory requirements. | |||
A $100,000 proposed civil penalty and a Notice of Violation was issued on May 16,1996 | |||
for Severity Level 111 problems (EA 96-070 and EA 96-102) related to configuration control | |||
of the hydrogen monitoring system and out of service problems associated with the safety | |||
injection system. | |||
l | |||
_._O | |||
. | |||
_______-_ | |||
. . | |||
, | |||
* | |||
, | |||
- | |||
f | |||
H. Stanley 3- | |||
In accordanca with 10 CFR 2.790 of the NRC's '' Rules of Practice," a copy of this letter, its; | |||
enclosure (s), and your response will be placed in the NRC Public Document Room (PDR). | |||
Sincerely, | |||
9 | |||
A. Dill Beach | |||
Regional Administrator | |||
Docket No. 50-456 & 50-457 | |||
License No. NPF 72 & NPF-77 | |||
Enclosure: Notice of Violation and Proposed | |||
imposition of Civil Penalty | |||
ec w/ encl: R. J. Manning, Executive | |||
Vice President, Generation | |||
M. Wallace, Senior Vice | |||
President, Corporate Services | |||
H. G. Stanley, Vice President | |||
PWR Operations | |||
Liaison Officer, NOC-BOD | |||
- D. A. Sager, Vice President, | |||
Generation Support | |||
D. Farrar, Nuclear Regulatory | |||
c Services Manager . | |||
l. Johnson, Licensing | |||
Operations Manager | |||
Document Control Desk-Licentbg | |||
Braidwood Station Manager | |||
T. Sim gkin, Regulatory | |||
Assurance Supervisor | |||
Richard Hubbard | |||
Nathan Schloss, Economist | |||
Office of the Attorney General i | |||
. State Liaison Officer | |||
Chairman, Illinois Commerce | |||
Commission . | |||
_ | |||
! | |||
.s. | |||
i<'. | |||
- H.. Stanley | |||
- | |||
-4- | |||
/ | |||
DISTRIBUTION: | |||
' PUBLIC IE 01 | |||
SECY /\ | |||
CA | |||
* | |||
LCallan, EDO t | |||
AThadani, DEDE | |||
,s . LChandler, OGC | |||
JGoldberg, OGC ' . | |||
SCollins, NRR | |||
. , | |||
RZimmerman, NRR | |||
; | |||
Enforcement Coordinators. | |||
Rl, Rll and RIV- . | |||
: Residont inspector, Braidwood. | |||
. RCapra, NRR | |||
GDick, NRR | |||
JGillitand, OPA t | |||
HBe;i, OlG | |||
g- | |||
' | |||
. GCaputo, 01 | |||
' LTrempei, OC - | |||
' | |||
TMartin, AEOD | |||
- OE:ES. | |||
OE:EA (2) ' | |||
GJohnson, OC/DAF.. | |||
RAO: Rill | |||
SLO:Rlli - | |||
l | |||
PAO:Rlli | |||
OC/LFDCB ' | |||
- DRP | |||
- Docket File | |||
. , | |||
._ | |||
%- g | |||
< , . | |||
. | |||
. o | |||
}} |
Latest revision as of 07:25, 15 December 2020
ML20198R242 | |
Person / Time | |
---|---|
Site: | Braidwood ![]() |
Issue date: | 10/03/1997 |
From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | Stanley H COMMONWEALTH EDISON CO. |
Shared Package | |
ML20198R245 | List: |
References | |
50-456-97-09, 50-456-97-9, 50-457-97-09, 50-457-97-9, EA-97-265, NUDOCS 9711130199 | |
Download: ML20198R242 (4) | |
See also: IR 05000456/1997009
Text
. . _ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ - - ~ ~ ~ ~ ~ ~ -
,
s# "%o UNITEo STATES
y.- k NUCLEAR REGut.ATORY COMMISSION
q S REGION Hi
I
E' 1E '31 WARRENVILLE ROAD
g usLE, ILUNois 00532-4351 f*
October 3, 1997
EA 97-265 ,
.
Mr. H. G. Stanjay
p
Site Vice President
Braidwood Station
Commonwealth Edison Company
RR #1, Box 84
Braceville, IL 60407
SUBJECT: NOTICE OF VIOLATION f ND PROPOSED IMPOSITION OF CIVIL PENALTY -
$55,000 (NRC Inspectiori 6 sport No. 50-546/97009; 50-457/97009)
Hb
Dear Mr. Stanley:
This refers to the inspection conducted from May 20 through June *o 0,1997, at the Braidwood Unit 1
and Unit 2 reactor facilities. An exit meeting ws conducted on June 30,1997, and the inspection
report was issued on August 26,1997. A predecisional enforcement conference was conducted on
September 11,1997, tn discuss t'a inspection issues related to strict compliance with Technical
Specifications (TS) for the Emerg 2 cy Core Cooling System (ECCS) subsystems. Specifically,
these issues are related to the Centrifugal Charging (CV) system, a subsystem of ECCS,
Based on the information developed during the inspection and the information that you prwided
during the conference, the NRC has determined that a violation of NRC requirements occurred.
The violation is cited in the enclosed Notice of Violation (Notice) and Proposed imposition of Civil
Penalty and the circumstances surrounding it are described in detailin the subject inspection
report.
The violation in the enclosed Notice involves the failure to strictly comply with TS surveillance test
requirement 4.5.2.b(1) which requires the ECCS pump casings and discharge piping high points
outside of containment be vented at least once every 31 days. On February 16,1996, a Braidwood
Station system engineer discovered that the CV pump casing and high points were not being vented
every 31 days as required. The decision to not strictly comply with the TS was partially based by
the Braidwood Station staff on the fact that the CV pump casings did not have vents. A subsequent '
operability justification determined that the intent of the TS was being met based on factors such as
the pressure in the piping and the CV system design and piping configuration. However, this y
operability justification failed to recognize that TS requirements were not being strictly met and that
a TS change was needed. The failure to recognize that the TS requirements J ! Y were not
met and to seek a TS change was identified by the NRC.
The potential safety consehe3delfl!EldiMs low. Venting of the ECCS is required to
ensure that no air is entrained in the ECCS that could result in water hammer or air binding that
could prevent proper pump /6@hlM pMo&n66 Due to the pressure in the CV system piping and
the system contiguration, this was not likely to occur. In addition, the ultrasonic testing, performed
by the Braidwood Station staff, of3 elept34 igh points found no entrained air. However, while
<
the potential safety consequenN EOM, latory significance is high. The Braidwood Station
9711130199 971003
PDR ADOCK 05000456
""
l.llI.ll11ll . . lil.Ill. I.llll .
.
.
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -____ _______ _____ _
..
H. Stanley -2-
f
staff continued to operate outside of TS requirements even after discovering that the TS was not
being strictly complied with and NRC involvement was necessary in order to ensure that strict
compliance with the TS requirements and the necessary TS changes were made. The failure to
request the necessary TS changes denied the NRC the opportunity to determine whether safety
issues were involved,
Based on the foregoing, this violation has been categorized in accordance with the * General
Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement Policy), NUREG-
1600 at Severity Level ill, in accordance with the Enforcement Policy, a base civil penalty in the
amount of $55,000 is considered for a Severity Level lli violation. Because your facility has been
the subject of escalated enforcement actions within the last 2 years', the NRC considered whether
credit was warranted for /dentification and Corrective Action in accordance with the civil penalty
assessment in Section VI.B.2 of the Enforcement Policy,
identification credit was not warranted because Braidwood Station staff had an opportunity to
currect the violation in February 1996 when the TS noncompliance was identified. The NRC
identified the continued violation of the TS surveillance testing requirements during the 1997
inspection.
Corrective Action credit was warranted based on the corrective actions implemented and discussed
at the enforcement conference. The corrective actions included (1) ultrasonic testing inspection of
vulnerable areas in the CV system; (2) review of selected TS surveillance tests to verify strict
compliance; (3) submittal of appropriate license amendment requests; (4) revision of affected
procedures; and (5) distribution of a Station Manager letter which stresses strict compliance with
TS requirementa.
Therefore, to emphasize the importance of compliance with technical specifications, I have been
authorized, after consultation with the Director, Office of Enforcement, to issue the enclosed Notice
of Violation and Proposed imposition of Civil Penalty (Notice)in the amount of $55,000 for the
Severity Level lli violation.
You are required to respond to this letter and should fo!!ow the instructions specified in the enclosed
Notice when preparing your response. The NRC will use your response, in part, to determine
whether further enforcement action is necessary to ensure complianco with regulatory requirements.
A $100,000 proposed civil penalty and a Notice of Violation was issued on May 16,1996
for Severity Level 111 problems (EA 96-070 and EA 96-102) related to configuration control
of the hydrogen monitoring system and out of service problems associated with the safety
injection system.
l
_._O
.
_______-_
. .
,
,
-
f
H. Stanley 3-
In accordanca with 10 CFR 2.790 of the NRC's Rules of Practice," a copy of this letter, its;
enclosure (s), and your response will be placed in the NRC Public Document Room (PDR).
Sincerely,
9
A. Dill Beach
Regional Administrator
Docket No. 50-456 & 50-457
License No. NPF 72 & NPF-77
Enclosure: Notice of Violation and Proposed
imposition of Civil Penalty
ec w/ encl: R. J. Manning, Executive
Vice President, Generation
M. Wallace, Senior Vice
President, Corporate Services
H. G. Stanley, Vice President
PWR Operations
Liaison Officer, NOC-BOD
- D. A. Sager, Vice President,
Generation Support
D. Farrar, Nuclear Regulatory
c Services Manager .
l. Johnson, Licensing
Operations Manager
Document Control Desk-Licentbg
Braidwood Station Manager
T. Sim gkin, Regulatory
Assurance Supervisor
Richard Hubbard
Nathan Schloss, Economist
Office of the Attorney General i
. State Liaison Officer
Chairman, Illinois Commerce
Commission .
_
!
.s.
i<'.
- H.. Stanley
-
-4-
/
DISTRIBUTION:
' PUBLIC IE 01
SECY /\
CA
LCallan, EDO t
AThadani, DEDE
,s . LChandler, OGC
JGoldberg, OGC ' .
SCollins, NRR
. ,
RZimmerman, NRR
Enforcement Coordinators.
Rl, Rll and RIV- .
- Residont inspector, Braidwood.
. RCapra, NRR
GDick, NRR
JGillitand, OPA t
HBe;i, OlG
g-
'
. GCaputo, 01
' LTrempei, OC -
'
TMartin, AEOD
- OE:ES.
OE:EA (2) '
GJohnson, OC/DAF..
RAO: Rill
SLO:Rlli -
l
PAO:Rlli
OC/LFDCB '
- DRP
- Docket File
. ,
._
%- g
< , .
.
. o