ML20148H663

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-456/96-16 & 50-457/96-16 Issued on 970331.Corrective Actions Will Be Reviewed During Future Insps

ML20148H663
Person / Time
Site:	Braidwood
Issue date:	06/06/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Stanley H COMMONWEALTH EDISON CO.
References
50-456-96-16, 50-457-96-16, EA-97-110, NUDOCS 9706110017
Download: ML20148H663 (3)

See also: IR 05000456/1996016

Text

{{#Wiki_filter:1 o i - June 6, 1997 l Mr. H. G. Stanley Site Vice President Braidwood Nuclear Power Station ' Commonwealth Edison Company R.R. #1, Box 84 i Braceville,IL 60407 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-456/96016(DRS); 50-457/96016(DRS)) Dear Mr. Stanley: , l This will acknowledge receipt of your April 28,1997 letter in response to our March 31,1997 letter transmitting a Notice of Violation associated with the above mentioned inspection report. This report summarized the results of the fire protection , inspection at your Braidwood Plant. We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections. Sincerely, /s/ J. A. Grobe , t 9706110017 970606 John A. Grobe, A-ting Director

" gDR ADOCK 0500 6 Division of Reactor Safety Docket No. 50-456 Docket No. 50-457 11000u- ( ( .__ Enclosure: Ltr dtd 04/28/97, H. G. Stanley, {{\\,\\hf\\hlk}llhk!,!!! i, i Comed, to US NRC w/ encl , See Attached Distribution SEE ATTACHED CONCURRENCE _S DOCUMENT NAME: G: ! To receive a copy of this document, indicate in the box "C" = Copy w/o attach /enct T = Copy w/ attach /erycl *N' = No copy OFFICE Rlli:DRS Rill:DRS l Rill:DRP l ./ fl@{tS JV NAME Schrum/kjc Westberg Lanksbury J $ $ (6r/Grobe ]] DATE 06/ /97 06/ /97 06/ /97 9 6/,{ /9 A/ ! OFFICIAL RECOR D COPY /'

a . EA 97-110 Mr. H. G'. Stanley Site Vice President Braidwood Nuclear Power Station Commonwealth Edison Company

R.R. #1, Box 84 Braceville,IL 60407 j SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-456/96016(DRS); 50-457/96016(DRS)) l Dear Mr. Stanley:

This will acknowledge receipt of your April 28,1997 letter in response to our March 31,1997 letter transmitting a Notice of Violation associated with the above mentioned inspection report. This report summarized the results of the fire protection inspection at your Braidwood Plant. We have reviewed your corrective actions and have i , no further questions at this time. These corrective actions will be examined during future inspections. Sincerely, John A. Grobe, Acting Director Division of Reactor Safety Docket No. 50-456 Docket No. 50-457 Enclosure: Ltr dtd 04/28/97, H. G. Stanley, Comed, to US NRC w/ encl i See Attached Distribution DOCUMENT NAME: G:\\DRS\\ BRA 060_7.DRS

Ts receive e copy of this document, indicate in the box

• C" = Copy w/o attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy

j OFFICE Rlil:DRS l 1:_ Rill:DRS l9 Rill:DRP lg RMylCS f NS ng NAME Schrum/kjc ha h4 Westberg g Lanksbury O n L ClaytoX Uac@Yptrobe DATE 06/01/97 06/03/97 06/ tl /97 07 /97 N 06/ fly OFFICIAL RECORD COPY i "

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i ! h. G. Stanley 2 June 6, 1997 , !

cc w/o encl: T. J. Maiman, Senior Vice President, Nuclear Operations Division D. A. Sager, Vice President, Generation Support l H. W. Keiser, Chief Nuclear l Operating Officer T. Tulon, Station Manager ~' T. Simpken, Regulatory Assurance Supervisor i 1. Johnson, Acting Nuclear- Regulatory Services Manager

Document Control Desk - Licensing cc w/ encl: Richard Hubbard Nathan Sch!oss, Economist, Office of the Attorney General

State Liaison Officer i Chairman, Illinois Commerce Commission Distribution: Docket File.w/ encl _.,7f SRis, Braidwood, Byron,~ R. A. Capra, NRR w/enci W'IE-01 w/enell2' . Zion w/enci TSS w/enci l OC/LFDCB w/ encl LPM, NRR w/ encl DRP w/ encl A. B. Beach, Rill w/ encl DRS w/ enc! J.' L. Caldwell, Rlll w/ encl Rll! PRR w/ encl Rill Enf. Coordinator w/enci l t 4 2 ! _ ... . _ - . - - - - - .

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. * * , Lomnuinu ralth 1 divin Gimpam ' liraidwond Generating Nat on , Route a l . Itos H e lirat es ille.11. 60 sO*Mi! 9 'Irl 814-a5M 'Mol April 28,1997 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Subject: Reply to Notice of Violation NRC Inspection Report 50-456(457)/96016 Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-457 Reference: G. E. Grant letter to H.G. Stanley dated March 31,1997, transmitting Notice of Violation from NRC Inspection Report 50-456(457)/96016 The Inspection Report referenced above contains details from a Fire Protection Inspection <- which began in October,1996. A Notice of Violation was transmitted with this report and included one Severity Level IV violation associated with hot work permit usage. Braidwood recognizes the safety significance related to fire protection issues, including the use of hot work permits. Although Maintenance and Construction personnel did not satisfy Station expectations related to adhering to the administrative requirements for hot work permits, workers did satisfy expectations related to safety. Revisions to the hot work prccedure and permit are expected to resolve the identified administrative concerns. If your staff has any questions or co nments concerning this letter, please refer them to Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801, i extension 2980. r I ene Stanley - ite Vice Presiden Braidwood Nuclear Generating Station Attachment cc: A.B. Beach, NRC Regional Administrator, Region III G.F. Dick, Jr., Project Manager, NRR C.J. Phillips, Senior Resident Inspector F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS l owonfid sitevp conesp 1997 97040 du - i A i ok om o.mpam MAY 01 W R%5& C,00 l 'l- _______-_____-_-_____-__b.p>,

- _ _ _ _ - . _ - - .. .~ ' ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/96016-05) ! Braidwood Technical Specification 6.8.1.a requires, in pan, that procedures be established, implemented, and maintained for activities covered in Appendix A of Regulatory Guide 1.33. Appendix A of Regulatory Guide 1.33 included fire protection program implementation. ' Braidwood Procedure (BwAP) 1100-15, " Fire Prevention When Welding, Cutting, l Grinding, or Performing Open Flame Work (Hot Work)," Revision 6, dated July 8, 1996, requires that applicable portions of the hot work permit be filled out and signed prior to work. Contrary to the above, from January 16 to September 26,1996, applicable portions of numerous Braidwood Station Hot Work Permits were not filled out as required by BwAP 1100-15. REASON FOR THE VIOLATION During an inspection of the Fire Protection Program, it was determined that Maintenance / Construction personnel did not always complete hot work permits in accordance with the procedure, BwAP 1100-15, " Fire Prevention when Welding, Cutting, Grinding, or Performing Open Flame Work (Hot Work)." This procedure allowed supervisors in charge of work to determine which precautions were applicable. These individuals understood the safety significance of working on jobs requiring hot work permits, however they found the hot work permit process to be cumbersome and did not recognize the imponance of filling out all of the information on the permit. As a result, some of the permits did not satisfy the procedure requirements. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The problem was identified during an evaluation of hot work permits that were completed between May and October,1996. The permits were individually reviewed and most of the noncompliances were found to be administrative in nature and none would have impacted the safety in the plant. The Fire Marshal discussed the problem with Maintenance Supervision. l l i

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.,s ' ' ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/96016-05) ACTIONS TAKEN TO PREVENT RECURRENCE BwAP 1100-15 was revised to clarify the requirements associated with using hot work permits. In particular, worker responsibilities are more clearly delineated. In addition to the procedure, the hot work permit (BwAP 1100-15Tl) was also revised. Maintenance and Construction personnel have been trained on the requirements associated with properly completing hot work permits. Station personnel attended awareness sessions where Station expectations related to procedure adherence were communicated. DATE WHEN FULL COMPLIANCE WAS ACHIEVED Compliance was achieved once BwAP 1100-15 and the associated hot work permit were revised and appropriate personnel were trained on these revisions. 2 }}