ML20148H663
| 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
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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: ,
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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
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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 ,
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9706110017 970606 John A. Grobe, A-ting Director ;
gDR ADOCK 0500 6 Division of Reactor Safety
Docket No. 50-456
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Enclosure: Ltr dtd 04/28/97, H. G. Stanley,
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See Attached Distribution
SEE ATTACHED CONCURRENCE _S
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OFFICIAL RECOR D COPY /' :
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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 l
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Enclosure: Ltr dtd 04/28/97, H. G. Stanley, I
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
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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 l
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OFFICIAL RECORD COPY i
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h. G. Stanley 2 June 6, 1997 !
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cc w/o encl: T. J. Maiman, Senior Vice President,
Nuclear Operations Division
D. A. Sager, Vice President,
Generation Support
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H. W. Keiser, Chief Nuclear
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Operating Officer
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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:
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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
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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 i
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.
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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
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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
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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.
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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.
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