ML12342A412

Reply to a Notice of Violation Regarding Inspection Reports05000456/2012004-03; 05000457/2012004-03

ML12342A412
Person / Time
Site:	Braidwood
Issue date:	12/07/2012
From:	Enright D Exelon Generation Co
To:	Document Control Desk, NRC/RGN-III
References
BW120120 IR-12-004
Download: ML12342A412 (4)

See also: IR 05000456/2012004

Text

December 7,2012 BW120120 U.S. Nuclear Regulatory

Commission

A TIN: Document Control Desk Washington, D.C. 20555-0001

Subject: Reference:

Braidwood

Station, Units 1 and 2 Facility Operating

License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Reply to a Notice of Violation;05000456/2012004-03; 05000457/2012004-03

Letter from Eric R. Duncan (U.S. NRC) to Michael J. Pacilio (Exelon Generation

Company, LLC), "Braidwood

Station, Units 1 and 2, Nuclear Regulatory

Commission

Integrated

Inspection

Report 05000456/2012004;

05000457/2012004

and Notice of Violation," dated November 8,2012 In the referenced

letter, based on the results of an inspection

completed

on September

30, 2012, the NRC concluded

that Braidwood

Station was in violation

of 10 CFR 50, Appendix B, Criterion

III, "Design Control", which requires, in part, that design control measures shall provide for verifying

the adequacy of the design, and that the design basis is correctly

translated

into procedures

and instructions.

The NRC requested

Exelon Generation

Company, LLC (EGC) to respond to the Notice of Violation

within 30 days of the date of the referenced

letter. EGC does not contest the violation.

Attachment

1 to this letter contains EGC's response to the Notice of Violation.

This letter contains new regulatory

commitments, which are identified

in Attachment

2. If you have any questions

regarding

this reply, please contact Mr. Chris VanDenburgh, Regulatory

Assurance

Manager, at (815) 417-2800.

Daniel J. Enright Site Vice President

Braidwood

Station Attachments:

1) Reply to Notice of Violation

2) Summary of Regulatory

Commitments

cc: Regional Administrator

-NRC Region III NRC Senior Resident Inspector

-Braidwood

Station

ATTACHMENT

1 Reply to Notice of Violation

In a letter from Eric R. Duncan (U.S. NRC) to Michael J. Pacilio (Exelon Generation

Company, LLC), dated November 8, 2012, the NRC issued a Notice of Violation.

The violation

of NRC requirements

was identified

during an NRC inspection

completed

on September

30, 2012. The violation

is listed below: Title 10 of the Code of Federal Regulations

Part 50 (10 CFR 50), Appendix B, Criterion

III, 'Design Control', requires, in part, that design control measures shall provide for verifying

the adequacy of the design, and that the design basis is correctly

translated

into procedures

and instructions.

Contrary to the above, from initial plant construction

to September

30, 2012, the licensee failed to verify the adequacy of the design of the Braidwood

Unit 1 and Unit 2 recycle holdup tanks, which are safety-related

components

subject to the requirements

of 10 CFR 50, Appendix B, Criterion

III, and failed to correctly

translate

the design basis of the Braidwood

Unit 1 and Unit 2 recycle holdup tanks into procedures

and instructions.

Specifically, the license failed to evaluate the effect of dynamic loads on inlet piping from Unit 1 and Unit 2 residual heat removal system suction relief valves that discharge

to the recycle holdup tanks and, as a result, failed to verify the adequacy of the recycle holdup tank design to withstand

design loads that would result from a discharge

of residual heat removal system suction relief valves into the recycle holdup tanks. This violation

is associated

with a Green Significance

Determination

Process finding. Response: 1 ) Reason for the violation

The failure to restore compliance

in a timely manner was caused by inadequate

Engineering

oversight

and prioritization

of dual site projects and over-reliance

on existing multi-site

Engineering

Design processes

to drive the issue to resolution.

This is documented

in the corrective

action program in issue report 1404575. The delays were caused by linear prioritization

of available

resources

based on perceived

risk significance.

Delay can be attributed

to deficient "crew teamwork" under the classification

of "supervision

during work" (ref. TapRoot).

Engineers

at other sites took the lead to resolve this issue (Exelon plan for sharing of resources)

and, in the beginning, there was insufficient

Braidwood

oversight

of Lead Engineer progress.

Braidwood

personnel

focused on other site priorities, permitting

other personnel

to "drive" final resolution.

Poor communication

between the Site Points of Contact resulted in delayed Project Review Committee (PRC) approval for funding and EOC re-work of the required RELAP5 hydraulic

analysis of the piping since the EOC focused on Byron piping subsystems

and neglected

to evaluate the Braidwood

piping subsystems.

This was partially

the result of the original piping analysis feasibility

study performed

in 2009 using the Byron piping models as a cost-saving

measure and the EOC using this study as the starting point for the final analysis.

This resulted in a delay in completion

of the RELAP hydraulic

analysis.

Braidwood

has taken the Lead Role in resolution

and is working directly with the EOC to complete the last remaining

project segment. Page 1 of 3

2) Corrective

steps that have been taken and the results achieved The following

corrective

actions have been completed

to address this issue: * For the immediate

protection

of the Recycle Hold-up Tank (RHUT) from the effects of potential

steam relief, station procedures

were revised to ensure the relief piping to the RHUT remained covered by water whenever the RHUT was aligned to the relief header. * A detailed evaluation

of the RHUT under the conditions

of potential

steam relief from the Residual Heat Removal (RH) System relief valve was completed

in February 2010. The evaluation

was documented

in calculation

CN-CRA-09-29

to verify that the RHUT would be protected

with appropriate

submergence

of the relief header discharge

piping, * A revision of the Exclusion

Area Boundary (EAB). Low Population

Zone (LPZ) and Main Control Room (MCR) dose calculation

for RHUT failure was completed

in September

2011 and documented

in calculation

BRW-10-0010-M.

This Design Issue is receiving

elevated Senior Management

oversight

and support both within Exelon and the EOC. Further attempts to develop best-estimate

relief valve opening characteristics

have been suspended

and known. conservative, valve response parameters

will be used to permit timely completion

of the RELAP5 model. 3) Corrective

steps that will be taken * The priority for final resolution

of the identified

issue has been elevated within both Exelon and the EOC to ensure the necessary

piping analyses and any necessary

piping system modifications

are completed.

The dynamic piping analysis will be completed

based on existing, conservative, operating

parameters

by May 5, 2013. * Plant modifications

will be issued to 1) install low-point

drains and vents to eliminate

water traps in the exhaust piping where possible and 2) modify or add piping supports if necessary

to address the calculated

support loads. Issuance of the above modifications

will be completed

by August 16. 2013. * Plant modifications

will be installed

by June 30. 2014. * Issue resolution

is not required for the Emergency

Core Cooling System (ECCS) function of the RH system as system pressures

in the injection

and recirculation

modes are not high enough to challenge

the relief valve setpoint.

4) Date when full compliance

will be achieved Actions to restore full compliance

will be completed

by the end of the second quarter 2014 (June 30, 2014). Page 2 of 3

1. 2. 3. ATTACHMENT

2 Summary of Regulatory

Commitments

The following

table identifies

commitments

made in this document. (Any other actions discussed

in the submittal

represent

intended or planned actions. They are described

to the NRC for the NRC's information

and are not regulatory

commitments.)

COMMITTED

COMMITMENT

TYPE COMMITMENT

DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No) (Yes/No)

Exelon Generation

Company, LLC (EGC) will complete the dynamic piping analysis based on existing, conservative, operating

May 5,2013 Yes No parameters.

EGC will issue plant modifications

to: 1) Install low-point

drains and vents to eliminate

water traps in the exhaust piping August 16, 2013 Yes No where possible and 2) Modify or add piping supports if necessary

to address the calculated

support loads. EGC will complete the required modifications

by the end of the second Yes No quarter 2014 June 30, 2014 Page 3 of 3