ML20140E813

Responds to NRC Re Violations Noted in Insp Repts 50-456/97-05 & 50-457/97-05.Corrective Actions:Action Request Was Generated to Complete Floor Plug Installation & Maint Memo 200-18, Floor Plug Removal Revised

ML20140E813
Person / Time
Site:	Braidwood
Issue date:	06/09/1997
From:	Stanley H COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-456-97-05, 50-456-97-5, 50-457-97-05, 50-457-97-5, NUDOCS 9706120210
Download: ML20140E813 (9)

Text

r Commonweahh I:dison Company

, liraidw om! Generating Nation Route ol. Ilox 81 f

liracniUc, ll. GH07-%19 Td Mi%1W2801 June 9,1997 l l

l U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attention: Document Control Desk l

Subject:

Reply to Notice of Violation I NRC Inspection Report 50-456(457)/97005 i Braidwood Station Unit I and Unit 2 i NRC Docket Numbers 50-456 and 50-457 i

Reference:

J. L Caldwell letter to H. G. Stanley dated May 9,1997, transmitting )

Notice of Violation from Inspection Report 50-456(457)/97005 )

l The Reference letter contains an Inspection Report documenting observations made ]

during a six week period which ended on April 7,1997. A Notice of Violation (NOV),

which includes four Severity Level IV violations, was transmitted as part of the Inspection Report. Comed's response to these violations is included in the attachment to this letter.

As mentioned in the cover letter to the Inspection Report, a good safety focus was demonstrated during the inspection period. Braidwood Station has focused efrorts in this 1 area and recently completed a refueling outage in a safe, conservative manner. We are pleased with this performance and will continue to communicate our expectations to station workers regarding our safety culture commitment.

The following commitments were made in the attached response:

e Braidwood will address the disposition of the PD pump in August,1997.

Once complete, procedure revisions will be evaluated.

. A systematic review of floor plugs will be completed and revisions will be done to appropriate drawings and documents as required.

. Braidwood will revise the applicable surveillance procedures used for response time testing for the Emergency Core Cooling Systems (ECCS).

• The Plant Barrier impairment (PBI) procedure will revised to reflect the j requirement of performing a Safety Evaluation or Screening for changes to g ventilation system access doors and internal doors, floor plugs, and other ventilation boundaries, where these changes alter the system as described in the (

UFSAR.

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9706120210 970609 hlllllllllllgl'gllggg PDR ADOCK 05000456 .,,,j,,,

G PDR A linicom company

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t l If your staff has any questions or comments concerning this letter, please refer them to l Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801, j ' extension 2980.

l l Sincerely, 1

I6 l . Gene Stanley l Site Vice Presid i .Braidwood Nuclear Generating Station c:\conrid admasst arc 67106mtAw cc: A. B. Beach, Regional Administrator - Region III, h%C C. J. Phillips, Senior. Resident inspector - Braidwood Station G. F. Dick, Jr., Project Manager, NRR F. Niziolek, Division of Engineering - Office of Nuclear Safety - IDNS l

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i ATTACHMENT 1

! ', REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97005-01) 1

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

Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978, requires l procedures for events that require emergency boration.

Contrary to the above, on March 25,1997, the inspectors observed that IBwFR-S.1, " Response to Nuclear Power Generation /ATWS Unit 1", Revision l A, Step 4a, had not been maintained in that it directed operators to start the l

chemical and volume control system positive displacement charging pump if neither of the centrifugal chargmg pumps could be started. The positive displacement charging pump has been out-of-service and has not been run for about 10 years.

REASON FOR THE VIOLATION During an earlier revision to the Abnormal Operating Procedures (OAs), discussions were I held to determine whether references to the Positive Displacement (PD) pump should remain in the OAs and Emergency Operating Procedures (EOPs) considering the PD pump had been out of service for a number of years. At the time, it was determined that l the preferred course of action was to leave the reference of the PD pump in the OAs /

EOPs as the Station intended to repair the pump and return it to service. As a result, the PD pump reference was left in the procedure being revised as well as the other applicable OAs / EOPs.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The Emergency Operating Procedure in question was evaluated by Station personnel. It was determined that the procedure could be performed as written based on current usage rules and operator training programs.

ACTIONS TAKEN TO PREVENT RECURRENCE Braidwood will address the disposition of the PD pump in August,1997. Once complete, procedure revisions will be evaluated.

Longstanding out of services were reviewed for their effect on EOPs. No additional issues were identified.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved once the PD pump status is dispositioned in August, 1997, and the applicable procedures are evaluated to determine if revisions are necessary.

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ATTACHMENT 1 l REPLY TO NOTICE OF VIOLATION l VIOLATION (50-456(457)/97005-02) 1

2. 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Actions," states, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.

Contrary to the above, the inspectors identified a plant barrier between Fire Zones 11.3-0 and 11.4-0 at Auxiliary Building elevation 383, column N-18, that had been degraded since June 6,1996. This barrier was needed to satisfy requirements stated in Deviation A.4 of the Fire Protection Report.

REASON FOR THE VIOLATION l

On June 6,1996, a Plant Barrier Impairment (PBI) was requested for the removal of the 364',383', and 401' N-18 Auxiliary Building equipment floor plugs. The plugs had been removed to facilitate equipment movements in support of other maintenance activity. An extension to the duration of the PB1 to allow the floor plugs to remain open for the Unit 1 l

mid-cycle outage (alp 02) was requested and approved.

The Station's Fire Protection Report includes a requirement to have fire resistant caulking for these particular floor plugs. However, the floor plugs were not recognized as fire barriers nor were the barriers documented as such on the corresponding design drawings.

Maintenance Memo 200-18, " Floor Plug Removal," documented these barriers as "No Requirements", which diminished the sense ofimportance in completing the reinstallation of the barriers.

The floor plugs were set in place on all three elevations on January 21,1997. The floor plugs on the 364' and 401' elevations were properly caulked and the corresponding PBis were closed out. However, the caulking of the 383' floor plug could not be completed because the supply of caulking material was depleted. As a result, the PBI for the 383' floor plug remained open to track the completion. Additional caulking had been ordered to complete the caulking job.

The PBI was being used as the tracking method. This process was not suflicient to drive the work to completion.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED 1 Ar Action Request (AR) was generated to complete the floor plug installation. This

! activity was completed on April 18,1997.

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ACTIOAS TAKEN TO PREVENT RECURRENCE Maintenance Memo 200-18, " Floor Plug Removal", has been revised to indicate the requirement to install fire resistant caulking as committed in the Fire Protection Report.

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ATTACHMENT 1 RiiPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97005-02)

The reinstallation of floor plugs will be controlled by ARs which will be converted to minimal work requests. The Maintenance Memo referenced above includes a step l requiring an AR to be generated for reinstallation of floor plugs if one does not exist. This l' requirement has been communicated to the Work Analysts and Maintenance First Line l Supervisors.

l A systematic review of floor plugs is being performed. Appropriate document and l drawing revisions will be made to ensure that the function of the floor plug seal (i.e. fire l protection, flood, etc.) is clearly stated and the applicable seal detail satisfies the design l function.

DATE WHEN FULL COMPLI ANCE WAS ACHIEVED Full compliance was achieved when the 383' floor plug was caulked as required. ,

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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97005-03) l 3. 10 CFR Part 50, Appendix B, Criterion XI, states in part, that a test program shall i be established to assure that e.Il testing required to demonstrate that stmetures, l systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures.

! to the above, the ins ectors found that testing to measure Chemical Contrary (,CV)d b Volume preconditione pump and Residual Heat Removal (RH) pump response times was y the operation of the system immediately prior to response time measurement on the_ system. Additionally, no surveillance test existed that tested the startup of the CV pump as it would under accident conditions. All existing surveillances required first manually starting the charging pump auxiliary lube oil pump.

BEASON FOR THE VIOLATION The current test method for determining the response time of the Chemical Volume (CV) ,

sets flow conditions to match the assumed pump accident(as obtained conditions, whichinisBwVS expected0.5-2.SI.2-3) to be between 520 and 550 gpm. Response1 taken after simulated seal injection flow is set to 80 gpm through the charging header.

l The remainder of the 520 to 550 gpm flow is directed through the cold leg in}ection lines.

l The CV pump is operated prior to taking the response time to estabhsh the 80 gpm l simulated seal injection flow by throttling the charging header flow.

For the Residual Heat Removal (RH) pump, the response time is obtained in BwVS 0.5-  !

2.RH.2-2 at a time during a refuehng outage where the RH system will not cause any reactivity excursions. In order to set flow conditions to match the assumed accident ,

conditio'ns, the procedure currently starts the pump recirculating back to the RWST and ramps flow up to establish flow at about 4500 gpm. The 1 Tow is throttled up in a controlled manner to ensure that the response time is taken under flow conditions that mimic the assumed accident analysis requirement of 3804 gpm. The flow is throttled to the desired condition in order not to exceed the design capability of the pump which could occur with the system line up during the test. Once the requisite flow is established, the pump is shut off. It is subsequently restaned to obtain the response time.

Braidwood Station agrees that exercising the CV and Ril systems prior to obtaining response times may have inadvertently prewnditioned the equipment.

Regarding the concern associated with manually staning the auxiliary lube oil pump prior j to starting the CV pump, it has been a practice at Braidwood Station to first start the auxiliary lube oil pump based on the vendor's recommendation. This is done in order to l prevent any long term degradation of the CV pump bearings from the multiple starts l without the support of the auxiliary lube oil pump. It should also be noted that during the Emergency Diesel Generator Sequencing test, the CV pump does obtain a stan signal without the auxiliary lube oil pump already running. The Station believes the action of starting the auxiliary oil pump is technically justified and does not constitute unnecessary preconditioning. Reasons for this include:

1. IN 97-16, " Preconditioning of Plant Structures, Systems, and Components before ASME Code Insenice or Technical Specification Surveillance Testing," states that 4

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ATTACHMENT 1 1

REPLY TO NOTICE OF VIOLATION I VIOLATlON (50-456(457)/97005-03) l "in certain cases, the benefit of some preconditioning activities outweighs the benefits of testing in the as-found condition. For example, the stafThas approved l the practice of routine checking of Emergency Diesel Generator cylinders for l water accumulation before performing surveillance tests in order to prevent damage caused by hydrolocking." Westinghouse and the CV pump manufacturer i recommend that the auxiliary tube oil pump should be started prior to start-up of l the CV pump for all normal operations, including special tests. This action will '

prevent premature failure of the pump bearings due to multiple pump starts without oil flow to the bearings. Therefore, Braidwood's practice of starting the auxiliary lube oil pump prior to running a CV pump is consistent with the guidance l ofIN 97-16 regarding the benefit of some preconditioning activities.

2. Testing was performed measuring the start times with and without the auxiliary lube oil pump. A review of the test data demonstrated that there was no l significant (.1 second) difference between the response times obtained with the

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auxiliary lube oil pump running (hot start) and without the auxiliary lube oil pump running (cold start). l i

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED 1

l l Braidwood Engineering reviewed the CV and IUi response time surveillances to assess the i methodology. As part of the evaluation, they reviewed the technical requirements for l obtaining response time testing and the concerns with preconditioning of equipment.  !

Also, additional data vas obtained during the performance of the response time i surveillances for CV, RH, and SI pumps. This data was used to compare and evaluate the effects thet different system conditions have on response time results. The evaluation demonstrated that response times obtained under the different test conditions show that the Emergency Core Cooling Systems (ECCS) would have been capable of delivering the flow to the core during a design basis accident within the time frame specified in the l l accident analysis. There was no significant (.1 second) difference between the response l times obtained under hot start conditions (with the pump recently operated and the )

auxiliary tube oil pump running) and cold start conditions (with the pump not recently

! operated and without the auxiliary lube oil pump running)..  :

1 l ACTIONS TAKEN TO PREVENT RECU~RRENCE l

l Braidwood will revise the surveillance procedures used for response time testing for the CV and RH systems. The revisions will permit the collection of pump start response times l

l under flow conditions that approximate post-accident conditions but without operating the i pump to establish test flow conditions. Since the test flow conditions will not be '

established with the assistance of actual pump operation, a conservative system alignment will be made to ensure the test finws are above the minimum flow requirements for pump protection and below the pump runout limitations. Braidwood Station believes that any 5

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ATTACHMENT 1

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REPLY TO NOTICE OF VIOLATION i t VIOLATION (50-456(457)/97005-03)  ;

j difference in the measured response times between flow conditions established per the f existing and revised pro,cedures would be insignificant. '

l DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED J i

Full compliance will be achieved when the appropriate surveillance procedures are revised. j The necessary revisions will be completed pnor to the next execution of the procedures.  ;

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,. - ATTACHMENT 1 i R$ PLY TO NOTICE OF VIOLATION L VIOLATION (50-456(457)/97005-04) {

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! 4. 10 CFR 50.59, par I records of changes m,agraph (b)(1), states in part, that the licensee shall l evaluation which provides the bases for the determination that the change... does .

l not involve an unreviewed safety question:

i Contrary to the above, on February 25, 1997, the inspectors observed that the licensee had blocked open a doorway between the auxiliary building ventilation ,

exhaust plenum and the auxiliary building which placed the auxihanj building ventilation system in an abnormal lineup and had not performed a 10 CFR 50.59 safety evaluation.

REASON FOR THE VIOLATION  ;

i The the work in the auxilia i 50.5grocedure controllingen to be performed w the plenum door was locked open. building plenum ar CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED l t

Engineering completed a 50.59 Safety Evaluation for the open plenum access door. In i i addition, they immediately began requiring Safety Evaluations for PBI permits that j changed ventilation system boundaries as described m the UFSAR. r l ACTIONS TAKEN TO PREVENT RECURRENCE  !

The PBI procedure will be revised to reflect the new requirements of performing a Safety l Evaluation or Screening for changes to */entilation system access doors and internal doors,

floor plugs, and other ventilation boundaries where these changes alter the system as L described in the UFSAR. .

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DATE WHEN FULL COMPLIANCE WAS ACHIEVED l

l Full compliance was achieved when the 50.59 Safety Evaluation was successfully l l

completed.

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