IR 05000277/1986025

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-277/86-25

ML20237C075
Person / Time
Site:	Peach Bottom
Issue date:	12/09/1987
From:	Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8712210008
Download: ML20237C075 (2)

Text

{{#Wiki_filter:_ - _ - _ _ - . _ _ _ _ - - _ _ _ _ _ _ _ __

..  ..
, , .  .

h' DEC 0 9 IW Docket Nos. 50-277 50-278 Philadelphia Electric Company ATTN: Mr. J. W. Gallagher Vice President Nuclear Operations 2301 Market. Street-Philadelphia, Pennsylvania 19101 Gentlemen: Subject: Inspection No. 50-277-86-25 This refers:to your letter dated September 25, 1987, in response to our' letter dated July 22, 1987.

-Your letter provided. additional information on four items fc,r which we requested clarification in our July 22, 1987 (W. V.' Johnston, NRC_to J. W. Gallagher, PECo) letter. We find the information to be responsive to our

  .

request.

. Thank you for informing us of the corrective and preventive- actions documented - in your letter. These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely, 0.,L;,121;icu,1ry: William V. Johnston, Acting Director Division of Reactor Safety cc w/ enc 1: Dickinson M. Smith, Manager, Peach Bottom Atomic Power Station John S. Kemper, Senior Vice President, Engineering and Production

-
 *,.
 -Thomas S. Shaw, Jr., Vice President, Production Troy B. Conner, Jr. , Esquire W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric
. Rm  G.'Leitch, Nuclear Generation Manager yg  Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)

Raymond L. Hovis,. Esquire r e4o

$$mo Thomas Magette, Power Plant Siting, Nuclear Evaluations W. M. Alden, Engineer in Charge, Licensing Section-mz  Doris Poulsen, Secretary of Harford County Council

om

 ' Public Document Room (PDR)

Local Public Document Room (LPDR)

#'  Nuclear Safety Information Center (NSIC)
%

NA NRC Resident Inspector Commonwealth of Pennsylvania d6

        / I g
"#

RL LIM 1 86-25 - 0001.0.0

        '

OFFICIAL RECORD COPY t w__________

[[ . . l_ .. f . Philadelphia Electric Company 2 l bec w/ enc 1: Region I Docket Room (with concurrences) Management Assistant, DRMA (w/o enc 1) Section Chief, DRP j Robert J. Bores', DRSS

     .l t
     >
     !
     ;-

l D RI urphy/pj PKEapen 12/f/87 12/C /87 1 0FFICIAL RECORD COPY RL LIM 1 86-25 - 0002.0.0 12/05/87

     !
     !

_- J

     -- - - _ - _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _

,

, .y
*
 .8, e ..

p . a. .

/
.

PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 ' PHILADELPHIA PA.19101 (215) 841 5020 M. J COONEY

- n. . 7f..[J "
 '.".. .. . .,,  September 25, 1987 Docket Nos. 50-277 50-278 Mr. William V. Johnston, Acting Director Division of Reactor Safety-Region I U. S. Nuclear _ Regulatory Commission ATTN: Document Control Desk-Washington, D. C. 20555 SUBJECT: Additional.Information in Response to
'

Inspection Report No. 50-277/86-25 for Peach Bottom Atomic Power Station REFERENCES: 1) Letter from W. V. Johnston, NRC, to J. W. Gallagher, PECO, dated July 22, 1987.

2) Letter from J. W. Gallagher, PECo, to W. V. Johnston, NRC, dated April 24, 1987.

Dear Mr. Johnston:

This is in response to your letter (Reference 1) which requested clarification of four items in our response (Reference 2) to Inspection Report No. 50-277/86-25. The NRC was informed that an extension to the due date would be needed to complete preparation of this response. Your requests are restated herein followed by our response.

. Fire Watch Requirements For Weekly Diesel Generator Test NRC Request: In response to the Notice of Violation, your corrective actions are not clear as.to whether you will permit the plant operator performing the weekly diesel generator full load test to satisfy your fire watch requirement if the Cardox system'is defeated, or whether an individual with no other If the job related duties other than a fire watch will be used.

former'is the case, please provide your justification.

[ - -- - -

_ - ._. _ _ _ - _ _ _ ___ _ _ _ _ _ - _ _ _ _ _ _ _ .- _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _

.
. ..

t

*

Mr. William September 25, 1987 Page 2 . Response

          ]

The plant operator is not permitted to satisfy the diesel fire watch requirements because he has duties other than fire watch duties to perform while in the room. However, a fire watch is not required during the weekly test because.the Cardox system is defeated for only a short period of time (less than 15 minutes). If the automatic injection mode of the Cardox is defeated for more than a nominal 15 minutes, steps will be taken to establish a dedicated fire watch (someone other than the operator). The fire watch would be in place within one hour from the time the Cardox was defeated to satisfy Technical Specification 3.14.B.4, unless the automatic Cardox protection is restored in that time period. Defeating the Cardox system only inhibits the automatic injection feature for that room and does not disable the diesel room alarm system (red revolving beacon and horn). A dedicated fire. watch is not necessary while the-operator is located in the diesel room with the Cardox system defeated since the operator's observations and the alarm system could alert the operator to a fire, in which case he would rearm the system.

To perform the weekly diesel generator test the operator enters the diesel room and performs the prestart line-up and checks with the automatic injection mode of the Cardox defeated. This normally takes less than 15 minutes. A local red light indicates to the operator the defeated status of the automatic injection mode of the Cardox. Once the. diesel generator has been started, the operator rearms the Cardox and leaves the room. The operator does not remain in the room for more than a few minutes while the diesel generator is operating due to the loud noise and the heat. The operator does reenter the room at some point during the test, defeat the automatic injection mode of the Cardox and record data required for the test. This also should take less than 15 minutes. Upon completion the operator rearms the Cardox and leaves the room.

The procedure for starting the diesel generators (S.8.4.A) and the weekly test procedure (ST 8.1) require the operator to always rearm the Cardox when leaving the room, and to request shift supervision's permission to keep the automatic injection mode of the Cardox defeated for more than 15 minutes. If shift supervision approves, they will take steps to establish a fire watch within the next 45 minutes. The fire watch will be a person with no duties other than fire watch duties.

Defective DC Bus Low Voltage Alarm Relay NRC Request: In response to the Notice of Deviation, you indicated that as of April 14, 1987, you were in full compliance with your FSAR commitments regarding testing of the relays. During the testing you had done, as witnessed by the inspector, one relay performed unsatisfactorily in the non-conservative direction.

. _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ - _ _ _ _ - _ _ - _ _ _ _ _ - _ - _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _

 .
. .
. .  .

Mr.. William September 25, 1987 Page 3

.

l You'also indicated'that this relay will be replaced with~a new L relay.which is on order. Please describe any compensatory l actions you may have taken as a result of the unsatisfactory performance until the relay is replaced and indicate the expected completion of the relay replacement.

Response:

, A replacement relay has been received from the ! manufacturer; however, upon inspection it was determined that it l is notLidentical in design to the failed relay. Therefore, its installation will be implemented as a modification. The replacement will be completed by October 31,.1987.

Compensatory actions are not currently considered l necessary because: 1. The failed relay monitors DC voltage at the 20D12 250 vde bus which is~ powered by two battery chargers.when AC power is available and by two 125 vde batteries during loss of AC power. The voltage at-the output of each of those batteries is monitored by low voltage . alarm relays which also annunciate in the control room. The 20D07'250vde bus is also powered by these two batteries and is equipped with a low voltage control room alarm relay which was tested satisfactorily on January 29, 1987. These other alarm features provide an important measure of compensation for the failed alarm relay. Attached is a figure presenting the configuration of this system.

2. A weekly surveillance test monitors the battery voltage, and battery charger voltage is checked daily.

3. The 250 vde bus with the failed relay provides electric power to only one system (RCIC on Unit 2), which is required to be operational only during power operation. Presently Unit 2 is shutdown and the failed alarm relay will be replaced prior to startup.

l 4. The batteries were replace,d in 1985 with new l batteries.

Schedule For Emergency Operating Procedure Revisions NRC Recuest: In your response to the area of weakness regarding emergency operating procedures, you have deferred the completion date of activities beyond our understanding at the conclusion of the exit. It was our understanding that a revision to the emergency. operating procedures would be made in August 1987.

Your response leads one to conclude that these revisions are expected to be completed as late as June 1988 with operator _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ -

_ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . - - - - - - - - - - . _ _ . __ - - - . - - - . - .- -. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

            ,
 ,
.  .           l
 .
.

Mr. William September 25, 1987 Page 4 i

.

training in these procedures to be completed as late as December 1988. Please explain the delay in the completion of the revision and training in emergency operating procedures.

, Response: The dates provided in our response for completion of the containment venting and blackout procedure revisions were established by station management with the understanding that no schedular commitments regarding these two procedures were made during the inspection. We regret this apparent misunderstanding.

We concentrated our efforts on incorporating Revision 3 of the BWR Owners Group Emergency Procedure Guidelines into the Peach Bottom TRIP Procedures. Associated procedure revisions were approved in August, 1987 and operator training has been completed. Completion of this project has permitted us to focus more attention on revising the containment venting and blackout procedures. Revision of the containment venting procedure has i

            '

been rescheduled for completion by November 30, 1987 and the blackout procedure by January 31, 1988. Operator training on each of these procedures will be completed within one licensed operator requalification training cycle following procedure approval (less than 4 months).

Preventive Maintenance on Diesel and Switch Gear Room Fans NRC Request: Finally, we request you clarify your response regarding the weakness in maintenance and testing support equipment. In your response regarding maintenance on the diesel generator and switch gear room fans, you indicated that the fans were included in the preventive maintenance program but that maintenance has not been performed in accordance with the program schedule and that accessing some of these fans may impact operability of safety related systems. Furthermore, your response implies that no preventive maintenance will be performed on this equipment until at least next year while you determine the means to perform such preventive maintenance tasks. We consider that deferral of preventive maintenance on these fans may also affect operability of safety related systems. Please provide information to support your proposition that deferring preventive maintenance until next year is an acceptable approach.

Response: We acknowledge that our response did imply that no preventive maintenance would be performed on the fans until next year; however, that was not our intention. At the time, we t _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

 . _ ._ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _  _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _  _____
. .
. . ..

Mr. William September 25, 19 B'

-

Page 5 i intended to do as much of the preventive maintenance (PM) on these fans as possible within the next few months. We l anticipated, however, that we may complete some of the PM aftez the end of the year. ,' Since the inspection of December 8-19, 1986 e considerable progress has been made in this area. Vibration monitoring has been performed on one of the Battery Room Exhaust Fans (OBV-36) and all of the and Diesel Generator Room Supply Fans (OAV-64, OBV-64, OCV-64 and ODV-64). Couplings on both of the Battery Room Exhaust Fans and one of the Diesel Generator Room Supply Fans (ODV-64) have been lubricated. The motor on one of the Diesel Generator Room Supplemental Supply Fans (ODV-91)  ! has been disassembled, inspected, and reconditioned. As part of

          '

the reconditioning, an electrical megger test was performed, and the shaft and bearings were inspected. This motor was found t'o be in excellent condition.

The remaining PM to be performed on the Dieset ,

            >

Generator Room Supply Fans (OAV-64, OBV-64, OCV-64 and ODV-64) h.

consists of an electrical megger test on each motor and coupling lubrication on the OAV-64, OBV-64 and OCV-64 fans. This work is scheduled to be completed during the annual diesel generator inspections which are in progress and scheduled to be completed in October 1987.

The remaining PM to be performed on the Battery Room Exhaust Fans (OAV-36 and OBV-36) consists of an electrical megger test of both fan motors, and vibration monitoring on the OAV-36 fan. The electrical megger test of the OBV-36 fan motor will be ,e d done this year. The OAV-36 fan is presently out of service for ';

           ,, /

corrective maintenance. The remaining PM on this fan will be performed in conjunction with the corrective maintenance ,'

            ,
            ;

activity. Vibration data will be taken after this motor is  ! ;

           '

returned to service.

Vibration monitoring of the Diesel Generator Room ( g Supply Fans and Battery Room Exhaust Fans will continue '

           (

periodically under a Predictive Maintenance Program. f I f

            (

In January 1988, another one of the Diesel Generator Room Supplemental Supply Fan motors will be disassembled, inspected and reconditioned. If the motor is found to be in , excellent condition (similar to the ODV-91 motor) then another '

           ,

motor will be inspected in January 1989, and the last motor will , be inspected in January 1990. If the results of a motor inspection reveal abnormal degradation, the schedule for I inspection of the remaining motor (s) will be accelerated as 'I appropriate. Inspection and reconditioning will remain as the ,1,f 1 designated PM on the Diesel Generator Room Supplemental Supply 1 Fan motors until completion of a modification to facilitate / vibration monitoring. After the modification is completed, vibration monitoring and electrical megger tests of these fan motors will be scheduled accordingly in lieu of disassembly, inspection and reconditioning.

L _ _ __ _ _ _ _ . _ __ . - _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

- - . _ . _ _ _ _ _ _   -
     ,, , -     3,  ,  _ , , .
     -
         ^

p \ N. , ~$

 .  ,      . - .. s. .  ,    ,,
  **
        ) *.

1,N , \

.        t '3         ,.

Mr. William V. Johnstdn '

        <-
            
            '

Sep*.2mbli 25, )987 g ) \. 1 / '- Prpje 6 F l-

 -
  ,.,

l-y @v:r' ( q [ .h ' s- (- 6 ..

. p'.
'

k' If yop have any qsntions er require additionaa\ '3-information, pleirae do not hesitrate 'to contact us.

( s

             ?
           ' '
      ! :y  \,
             ' '    l T. -

t t' i k'

       ~

p ,

           ,

e, . . l

         '

Very trdly yours,>

                      ,
   ,
       ,'
    ; e  \j
             '
             , /$4L 4f2    '
            /  >
       '
<             /  h     ,

t.

./, ' s k 'f ec: Addressee- l t /% T. Russell, Administrator, Region'I P.'g.Cohnson, Resident Site Inspector

              '
   / '14                   -i
              ,
              ,
             [     #     e
              ,
            '

N g

            -

s 'N ? /

            '

N (j s

           ,
  *          <           , <

t I y ,.

      < '                ' a e  3,
           ,

m,.

   ,.         ,  , . .

           ,   % ._ y
      ,.     ';; ; ,'
      \     '~r

                       .k
  +r ,

s j t c

        \
. ,i
-'p-  \

3 s

'l
\> 'r.              I s    !           -

t-

     ' ~             't      y
       \                ;
     '

e n

    't  \i i s I. t I,     I        g b       Y,.       5
    ,

4:

    (,
         \

I t

                <
     '

r

    ,  \            f
    \             k, (.      t
    \

t

    '

s i

           ;  g     (      .
     ? ;       ,'

s

     . -
      '
          ,
             ,

sc , s t' s., , , . \, t 1 h  !. '

  ,,

t

                     ,

r b , t i 4 g

    .
  %  k   k    %

                     ;
  * \

g, t' \ ., ' ' b p  !

                     \*
            '

j

  .
           ( i      .

I ,' '

                     ',

s - s. I I s j

         -^       _ _ . _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

m 78 A ,' 1 osa h t 7/22 ~ "- iD P e s ~ ~ d c e - - N III v a k 00 t t o c55 T

   /

5 A D , 2 r y

Crv ee gd I.L _ Ct rc ed v l

      -

_

D

2 a5 2 t5 f 2 a2 h2 C1 _ B1

      ~
      -

_ _ _ l a r t u - e _

   -

N _

        -

s

 .

t t.

E_ . u

t D O F P e O d C

    ;1 5 q   v t

D _ t A 0 t

O Gi CY l t g ,

T A N T I E- + 2

O D G- _ - - B I I D E E M R

    -

_ _ D

2 C I E f-

    -

_ A F - E I I r\' 1 P L P

 !

t

   .
    - -4  a
      - _

f O - _ I I ~ r.. S S I ' _

     ._ -

V ' g - If I_ '

     -
 )

i.

-

    *~ )s [c

_

    ~ _ 4 il r y ee re

_gd ed

. Arv At v 2 a5 2 t5     )

h2 a2 de R , C1 B1 1

  ~    i _

a _ f ( A(;, e i n o d t vr 1l

S el e 2 winr

ota P sP i

    )

I - - '

       ,

}}