United States Nuclear Regulatory Commission - Protecting People and the Environment

EA-97-110 - Braidwood 1 (Commonwealth Edison Company)

October 2, 1997

EA 97-110

Mr. T. Tulon
Site Vice President
Braidwood Nuclear Power Station
Commonwealth Edison Company
R.R. #1, Box 84
Braceville, IL 60407

SUBJECT: NOTICE OF VIOLATION (NRC Inspection Report Nos. 50-456/457-96016)

Dear Mr. Tulon:

This refers to the inspection at Braidwood Station completed August 14, 1997. This inspection reviewed the fire protection program and several Licensee Event Reports (LER) that documented post-fire safe shutdown deficiencies. The initial report of this inspection was sent to you by letter dated March 31, 1997. A pre-decisional enforcement conference was held on May 14, 1997. The NRC staff concluded that they required additional information to substantiate the technical positions you presented at the conference before they could reach an enforcement decision. Your staff provided this information by letter dated June 27, 1997. The NRC technical staff completed its review of this information on August 14, 1997.

The NRC determined that two violations of NRC requirements occurred. This determination was based on the information developed during the inspection; the information that your staff provided during the pre-decisional enforcement conference; LER 50-456/95013-01 and LER 50-456/96011; and your June 27, 1997, letter responding to questions proposed at the predecisional enforcement conference. The two violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding each violation are described in detail in the inspection report.

The first violation was identified by your staff and involved five examples of the failure to provide adequate fire protection for safe shutdown equipment. These examples existed since initial plant operations and were resolved in 1996 when your staff performed additional fire protection modifications. This violation was caused by an inadequate post-fire analysis for protection of safe shutdown capability. The NRC considered this violation to be safety significant because some of the equipment required to achieve and maintain safe shutdown may be rendered inoperable by a fire.

Therefore, this violation has been categorized according to the "General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) NUREG-1600 as a Severity Level III violation.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 was considered for Severity Level III violations occurring before November 12, 1996. Since most of the noncompliance period occurred before November 12, 1996, a base civil penalty of $50,000 was considered for this case. Because your facility has been the subject of escalated enforcement actions within the last two years1, the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. You were given credit for Identification of this violation and for initiating prompt and effective Corrective Action. The Corrective Actions discussed at the conference included circuit modifications and cable re-routing to ensure the availability of safe shutdown equipment. Additionally, your staff developed the Appendix R Enhancement Plan to review current safe shutdown analysis and identified no further deficiencies.

Therefore, to encourage continued identification and prompt and comprehensive correction of violations, I have been authorized not to propose a civil penalty in this case.

The second violation involved inadequate testing of roll-up fire doors where ventilation system configuration changes that affected door function were not considered in the test procedure and acceptance criteria. This violation is a concern because plant personnel (including supervisors) from several plant organizations failed to recognize t the test deficiencies and function of the roll-up fire doors . This violation was classified in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600 as a Severity Level IV Violation.

The NRC has concluded that information regarding the reason for the two violations, the corrective actions (taken and planned) to correct and prevent recurrence of the violations, and the date when full compliance will be achieved is already adequately addressed on the docket in Inspection Report 50-456/457-96016, LER 50-456/95013-01, and LER 50-456/96011-00. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your positions. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.

In accordance with 10 CFR 2.790 of the NRC's "Rules or Practice," a copy of this letter, its enclosure, and your response (if you elected to provide a response) will be placed in the NRC Public Document Room (PDR).

    Sincerely,

    A. Bill Beach
Regional Administrator

Docket Numbers 50-456; 50-457
License Numbers NPF-72; NPF-77

Enclosure: Notice of Violation

cc 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 Services Manager
I. Johnson, Licensing Operations Manager
Document Control Desk-Licensing
Braidwood Station Manager
T. Simpkin, Regulatory Assurance Supervisor
Richard Hubbard
Nathan Schloss, Economist
Office of the Attorney General
State Liaison Officer
Chairman, Illinois Commerce Commission


Notice of Violation

Commonwealth Edison Company
Braidwood Station
 

Docket Numbers 50-456; 50-457
License Numbers NPF-72; NPF-77
EA 97-110

During an NRC inspection conducted on October 13, 1996, to August 14, 1997, two violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

Braidwood Station Operating Licenses, NPF-72 and NPF-77, Section 2.E, required in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report, as supplemented and amended, and as approved in the NRC safety evaluation report dated November 1983 and its supplements.

Braidwood Undated Final Safety Analysis Report, Section 9.5.1, "Fire Protection System," stated in part that the design bases, system descriptions, safety evaluation, inspection and testing requirement, personnel qualification, and training are described in "Byron/Braidwood Stations Fire Protection Report in Response to Appendix A of Branch Technical Position APCSB 9.5-1."

Appendix 5.7, "Appendix E - Fire Protection Program for Nuclear Power Facilities Operating prior to January 1, 1979," in the above mentioned Fire Protection Report, stated in part that Byron/Braidwood complies with the requirements in 10 CFR 50, Appendix R, Section III.G, "Fire Protection of Safety Shutdown Capability."

10 CFR 50, Appendix R, Section III.G, specified in part that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage.

10 CFR 50, Appendix R, Section III.G.2 specified, except as provided in Section III.G.3, where cables of equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are in the same fire area, separation of cables of redundant trains by a fire barrier having a 3-hour rating, or 1-hour rating with fire detector and an automatic suppression system, shall be provided.

1. Contrary to the above, the licensee failed to provide fire barriers for redundant trains of equipment in the same fire zones, as evidenced by the following examples: (01013)

A. From initial Unit 1 startup in July 1988 to July 1996, the licensee failed to protect one train of control room ventilation (VC) system and two control cables associated with 1A diesel generator (DG) with rated fire barriers in Fire Zone 3.2A-1. In addition, the power cable to Unit 1 fire hazard panel (FHP), nonsegregated bus ducts, control cables to the ESF bus breakers, and the cables associated with an alternate source from Unit 2 cross-tie were unprotected in this zone. Aggregate effect of the equipment being damaged during a postulated fire was that hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.5.

B. From initial Unit 1 startup in July 1988 to July 1996, the licensee failed to protect one train of VC system with a rated fire barrier in Fire Zone 3.2B-1. In addition, the power cable to the Unit 1 FHP was unprotected and routed through the zone. Upon exceeding the critical temperature in the main control room (MCR) and the auxiliary electric equipment room (AEER), hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.6.

C. From initial Unit 2 startup in October 1988 to July 1996, the licensee failed to protect one train of VC system with a rated fire barrier in Fire Zone 11.4-0. In addition, the power cable to the Unit 2 FHP was unprotected in this zone. Upon exceeding the critical temperature in the MCR and the AEER, hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.42.

D. From Unit 1 initial startup in July 1988 to July 1996 and initial Unit 2 startup in October 1988 to April 1996, the licensee failed to protect one train of VC system, Unit 1 DGs, and miscellaneous electric equipment room (MEER) supply fans with rated fire barriers in Fire Zone 11.5-0. In addition, the power cable to Unit 1 FHP, cables associated with system auxiliary transformer (SAT) cooling fans were unprotected and routed through the same zone. The aggregate effect of the damaged equipment during a postulated fire is that hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.45.

E. From initial Unit 1 startup in July 1988 to December 1995, and from initial Unit 2 startup in October 1988 to April 1996, the licensee failed to protect one train of Unit 1 auxiliary feedwater (AF) system, VC system, and MEER supply fans with rated fire barriers in Fire Zone 11.6-0. In addition, the cables associated with SAT cooling were unprotected and routed through the zone; therefore, offsite power would not be available to the main feedwater pumps. The aggregate effect of the damaged equipment during a postulated fire was that hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.50 and Table 2.4-1.

This is a Severity Level III violation (Supplement I).

2. Contrary to the above, from June 4, 1990 to September 3, 1996 for Unit 1 and from October 1988 to September 3, 1996 for Unit 2, the 12 roll-up doors separating Units 1 and 2 DGs, ESF switchgear, non-ESF switchgear and MEERs from the turbine building, failed to meet the three-hour rated fire barrier requirement. Specifically, the doors failed to close completely when the ventilation system was operating in the outside air mode. (02014)

This is a Severity Level IV violation (Supplement I).

The NRC has concluded that information regarding the reason for these violations, the corrective actions taken and planned to correct the violations and prevent recurrence and the date when full compliance will be achieved is already adequately addressed on the docket in Inspection Report 50-456/457-96016, LER 50-456/95013-01, and LER 50-456/96011-01. However, you are required to submit a written statement or explanation pursuant to

10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region III, and copy to the Braidwood NRC Resident Inspector Office, within 30 days of the date of the letter transmitting this Notice of Violation. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because the response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information would create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois
this 2nd day of October 1997


1. EA 96-070 issued a Severity Level III violation and a $100,000.00 civil penalty on May 16, 1996, for configuration control problems that were identified during a January through March 1996, inspection.

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