IR 05000456/1997009

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

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: ML20198R242 ML20198R259
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)

Text

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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 ,

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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)

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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

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the potential safety consequenN EOM, latory significance is high. The Braidwood Station 9711130199 971003 PDR ADOCK 05000456

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.. 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.

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f 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,

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 .

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DISTRIBUTION:

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Residont inspector, Braidwood.

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