IR 05000277/1988035
| ML20206D686 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/03/1988 |
| From: | Blumberg N, Drysdale P, Finkel A, Gallo R, Rebelowski T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20206D676 | List: |
| References | |
| 50-277-88-35, 50-278-88-35, NUDOCS 8811170215 | |
| Download: ML20206D686 (15) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-277/88-35
$1F278/dIST ~5
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Docket No.
50-277 5F27H License No.
OPR-44 DR36 Licensec: Philadep ~hia Electric Company
>Tl)TBox 7526
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Philadelphia, Pennsylvania 19101 Facility Name:
Peach Bottem Atomic Power Station Units _2 and 3 i
i Inspection At: Delta, Pennsylvania Inspection Conducted:
September 26-30, 1998 Inspectors:
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A. Finkel, S ior Reacter Engineer dats f
Au" P. Drys 6 ale, Reactor Engineer
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fRebeow.Juw
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,1, Senior Reactor Engineer N
Reviewed by:
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Norman J. Blumberg(' Chief, Operational ath Programs Section, Operations Branch, DRS, RI Approved by:
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i Robert M. GTilo, Ch1ef, 0 rat ns date Branch, DRS, RI Inspection Su-eary:
Routtee Unannounced Comb',ned Inspection on september 26-30,1988Tkeport Nos. $F27T/e!Ris and 50-275f/S3T35)
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Areas !_nspected: An inspection was perforced to assess the licensee's
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performance in the areas of maintaining surveillance proceduras and records
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that verify component availability to meet the technical specification requirements; the observation of surveillance testing; a review of design
changes and modifications for both completed and ongoing equipment changes and j
previously identified unresolved items including corrective actions identified
in the licensee's Plan for Restart of PBAPS,Section II, Revision 2.
Results: Within the functional areas of Surveillance Testing and Design Modifications, two unresolved findings were ideatified: ('l) The Plant Technical
i and Operations groups rN not have an administrative requirement to use
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verification criteria to determine if surveillance test procedures are t
adequately prepared and can be performed completely and specifier.lly as written
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I (Paragraph 3.4); (2) In the area of modifications, the installation of heat l
detection wiring in vertical electric cable trays, was found at a distance greater than 12 inches away from the cable tray.
The criteria for placement of detector wiring has not been estsblished.
(Paragraph 4.3.6)
The Plant Maintenance /I&C group uses established guidelines to verify the adequacy of surveillance test procedures for which it has responsibility.
This results in surveillance test procedures which are technically adequate, clearly t
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written, and verified to be completely workable prior to their issue.
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DETAILS 1.0 Persone Contacted she names and positions of the persons contacted during the ir.spection period and those in attendance at the management exit meeting are listed in Attachment A to this report.
2.0 Surveillance Procedures and Records (61700)
2.1 Inspection Scope
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In order to ascertain whether the surveillance of safety related systems and components was being conducted in accordance with approved procedures, as required by the Technical Specifications and NRC commitments, the inspector reviewed the Surveillance Test (ST)
procedures to assure that they addressed the items described in section 2.2.
2.2 Inspection Requirements The surveillance test (ST) proceduris listed in Attachment B were reviewed to determine that they complied with their Technical Specification (TS) commitments and incorperated the following
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criteria:
f The ST procedure defined the Technical Specification criteria
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to be verified by the test.
Prerequisites and preparation for test were specified.
- Accept / reject criteria were specified.
- Manager'$upervisor reviews and signatures were required on the i
test sheets.
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As found/as lef t requirements were defined and required to be
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I System interfaces were defined.
- Test frequencies were defined.
- j The inspectors' review of the above criteria is documented in Findings, Paragraph 2.4 f
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2.3 Vertf tcation of Surveillance Test Scheduling The licensee controls the scheduling of their technical specification surveillance testing through their Surveillance Test and Records System (STAR) program.
The STAR program lists all technical specification surveillance tests, procedures, and testing frequencies. This data is provided to the operational staff organization to aid in planning their daily and weekly test schedules.
The inspector reviewed the PBAPS Routine Surveillance /RT Schedule for the week of September 28, 1983 - October 2, 1988 against the STAR listing for the months of September / October 1988.
The daily / weekly scheduled tests were verified by the inspector to be within the dates listed in the STAR program. No deficiencies were identified.
2.4 Findings The surveillance test procedures reviewed satisfied their applicable section of the Technical Specifications, NRC commitments and test criteria outlined in paragraph 2.2.
The licensee's STAR system schedules ST procedures to be performed within the time specified in their Technical Specification (TS).
If ST's are not performed within the TS time span, a repor; is sent to the station management for information and action. No deficiencies were identified.
3.0 Surveillance Testing Review (Module 61725)
3.1 inspection Scope Selected surveillance tests were reviewed to ensure procedural adequacy and compliance with Technical Specification requirements; and to evaluate the effectiveness of surveillance test performance.
3.2 Inspection Requirements The irspector witnessed the performance of selected surveillance tests which had been scheduled during this inspection period. The inspection included a review of the procedures (See Attachment B) for technical adequacy; and witnessing of the performance of procedure steps to ensure the adequacy of the procedure and the effectiveness of personnel performing the work.
3.3 Surveillance Test Witnessing 3.3.1 Functional Test Of Scram Discharge Volume High level Switch
[ST 2 X fl $7DM )
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The scram discharge volume level switch (LS-2-3-231) test is a Plant Maintenance /I&C surveillance test and was performed
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in accordance with ST 2.4.11 B/0/E, The test was perfortred by four qualified Instrument and Control technicians in coordination with Health Physics. Quality Conteol, and Control Room personnel. The test was conducted in an efficient and professional manner, and in compliance with all procedure requirements.
Instrument and Control test personnel were found to be kr.owledgeable of the sy', tem being tested and were also very familiar with the control, performance, reporting, and revision processes required fer ST procedures. After completion of the test, the inspector verified ti.at proper supervisory reviews and approvals of successful test completion weie obtained and documented. No deficiencies were identified.
3.3.2 Fire System Weekly Check (ST 16.2.1)
The weekly check of the CO inventory for the Cardox system and
the condition of the batteries for the diesel driven fire pump is a Plant Operations surveillance test and is performed in accordance with ST 16.2.1.
During preliminary discussions of this ST with the control room Shift Superviter, the Chief Operator, and the Plant Operator, it was determined that the ST could not be immediately performed because of inadequate instructions con * sined in two System (S) procedures invoked by the ST.
The Shift Supeevisor initiatted a Procedure Suggestion Form to identify specific problems with the 5 procedures. The ST was delayed to a later date.
The revised S procederes were returned to the control room the following day to allow the ST
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to nroceed on a timely basis; however, this test was not perforced during the remaindir of the inspection period. No deficiencies were ideitified.
3.3.3 Standby Liquid Control (SLC) Functional Test (ST 13.18-2)
the inspector witnessed performence of ST 13.16-2. This test is a Plent Technical surveillance test and was perforced by Plant Operations personnel directly under the control of the Plant Technical group.
During the performance of preliminary steps in ST 13.18-2, operators determined that the ST could not preceed because an 5 procedure (S.3.6. A COL) invoked by the ST contained inaccurate instructions and could not be performed as written.
The Plant Technical group took necessary actions to implement a Te.aporary Procedur.: Change and the SLC functional test was subsequently allowed to resu=e. No deficiencies were identified.
3.4 Findi_nn Within the secpe of this inspection, no procedure violation or deviations were identified.
Reviews of work performance and written instructions indicate that surveillance tests overall are controlled
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and conducted in a satisfactory manner.
It was noted in particular that Plant Maintenance /I&C surveillance tests were written and performed in an exemplary f ashion.
In addition, operations personnel were observed to take conscientious and appropriate actions when they encountered inadequate instructions which could not be performed as writton (see pa*agraphs 3.3.2 and 3.3.3 above).
However, two of the three surveillance tests witnessed could not be performed because they referenced inadequate instructions. This item
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was discussed with the cognizant Plant Technical and Operations managers who committed to establish administrative requirements for verifying that test procedures are adequate for performance.
This is an unresolved item pending confirmation that specific verification criteria have been developed to determine, prior to performance, that procedures can be performed as written.
(50-277/88-35-01 and 50-278/83-35-01)
4.0 Design _ Changes and Modifications Units 2&3(37700,377011 4.1 Inspection Scope The licensee's Design Change and Modification Program was inspected to ascertain if the licensee had implemented a program relating to the control of design changes ano modifications in accordante with N.18.7-1976, ANSI 45.2.11-1974 and ANSI 45.2-1971.
(See Attachment B)
4.2 !_nspection Requirement The design modifications were reviewed and observations rade to determine that applicable licensee procedures were followed and that the specific criteria listed below were addressed.
Safety evaluattens were performed (10 CFR 50.59 requirements)
Engineering design changes and modifications were promptly
reviened by the on-site Plant Operations Review Cor.stttee
Th= level and type of involvement of the quality control organization was adequate for the selected modification Drawings of modifications were updated and in place
As-built information conformed to the installation drawings
personnel were trained on modified systems on a timely basis
The above attributes were used to establish inspection criteria.
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4.3 Observation and Review of Design Modification
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Observations and review of completed and in p-ogress rrodifications were conducted in the following areas:
4,3.1 Modification 83-018C_dunits 2 & 3) Replacement of Diesel
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l Generator Air Go~lant Flexible fioses (
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This modification requir$J the licensee to replace installed non-conforming diesel generator air coolant flexible hoses.
The hose replacement included the addition of a bushing street
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reducing tee and nipple. During th inspector observations, in
the field, three of the four diesel generator hose replacements
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were observed to have a similar installation. However, the E-1 l
diesel mechanical fitting (street-reducing tee) was rotated 180'
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during installation and did not agree with the configuration of the other three diesels. There was no physical effect on the system since all intern.. pathways for the coolant were similar, i
The licensee issued a maintenance request to establish a similar
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configuration on the E-1 diesel, No deficiencies were r
identified.
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I 4,3,2 Modification 1930, (Unit 2) Replacement of Unit 2 Tu bine g
he_rjencyBearingLube01) Pump _ Batteries Balan F o FPlant (BOP)
j This modification addressed the new battery installation in a l
non-safety related system.
The inspector identified a loose
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battery rack end strap (non-seismic rack) causing minor movement of battery spacers.
In addition, a slight discoloration was noted on battery cases. The Itcensee is pursuing the proper placement of the end strap and the performance of normal house-keeping in this area. The battery room was secured and ventilation flow was noted, The modification acceptance cest L
is required prior to closecut of this installation, No other
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deficiencies were identified.
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Modification 16362 (unit 2 Rectreulation Motor Generator l
PD) Set koom Area Fire Ip)rinkler System 4.3.3 t
t T 6. ;. modificati,n extended the existing M3 set room sprinkler l
system used to protect structural steel members that support
safe shutdown fire barriers from the effects of a postulated
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fire. All piping, hangers, and location of new sprinkler heads were observed in place according to the drawings.
The modification hydraulic acceptance test was found to be satisfactory, No deficiencies were identified.
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4.3.4 Modification 2387 and 2389. (Unit 2) Ve* tilation Modifications This modification installed various ventilation screens and i
gratings at several locations. The ventilation system in the j
west wall of the motor generator and diesel generator rooms was observed to be completed and the final snodification package was being reviewed by the licensee. The new grating was installed
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as planned with all bolting in place. No deficiencies were I
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identified.
i 4.3.5 Modification 1548, 1777 (Unit _2 & 3) Main Steam Isolation i
Elve (HilV) Stem Anti-Rotation Modification j
This modification to the MS!V provides a positive method to i
prevent stem rotation at the threaded connection to the air I
operator valve. By the design of the stem, it is positively
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locked in place. The modification is incomplet; on the 66B and
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SOB valves because additional modification acceptance tests I
(MATS) need to be conducted when steam is available to verify that the valves operate per design. Work packages reviewed included the safety evaluation and dstai'ed working drawings.
Tais modif t:ation is common to both pla.ts and will be closed i
a fter all 16 valves (eight per plant) tre completed.
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st.orage of spare parts was verified.
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identified.
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4.3.6 Modification 13518. (Unit e) Installation _of Hvit Detection
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This modification provides lirear beat detection cable in all cable trays in tha Emergency Shutdown pane) Area, Fire Area 25.
The detector cable that is installed has a temperature rating i
of ;.55'F.
The method of installation calls for placement of i
detector wires with a 6 foot long line wave on e.able trays with
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holding clips at 3 foot intervals. Observations of the r
- ouleted modification verified correct installation on hor zental cable trays. However, for some vertical cable trays the detection cable was displaced from the cable tray as rauch as 12 inches.
The detector wire displacerrent was attributed to l
misplaced or broken detector wire holding clips, caused by the
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weight of detector wire in a vertical position, moving the wire (
away from cable tray. The ability of the detector wire to i
provide early warning of an increase in cable tray temperature i
ray be compromised. The Itcensee has taken positive actions by f
initiating a reinspection of all vertical cable trays. Untti i
the ccepletion of the licensee's reinspection results and proper
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repiecerent of linear heat detection cable on the verticle cable i
trays this is considered an unresolved item. (50-277/SS-35-02 l
and 50-278/8S-35-02)
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Modification 13518 work package contained acceptable modification acceptance tests of the detection panels, safety 3 valuations, documentation of line splices, and material verifications, Na deficiencies, other than the above unresolved i+em, were identified, denerator (D5fTuel fr,Un't 2 & 3) Replacement of Diesel 4,3,7 Modification 88-010 f
ossoverliping This modific.". ion replaced diesel generator fuel crossover piping, The vendor previously had recognized a minor corrosicn problem, had issutil a maintenance bulletin, and had manufactured replacement piping kits. A materia! change was made from copper to mild steel piping tha,. is less susceptible to corrosion.
During testing no leakage of t'i newly installed lines was identified, No deficiencies were identified.
4,4 Finding The licensee has established appropriate criteria that results in preper modification reviews.
The licensee program for modificattoa includea a comprehensive document package that includes installation instructions, modification acceptance tests and quality control verification. The safaty evaltations reviewed by the inspector for the listed modificatio35 demonstrated a thorough licensee review.
The modification progra s appears ta be well controlled in areas of scheduling and follow up of identified non-conformances. One unresolved item was identifico in paragraph 4.3,6, no other significant deficiencies were identified.
5.0 Qualjty Contro1JQC) Interface with Surveillance testing and Modification In stallation s Testing j
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Several observations during this inspection noted the presence of QC pqrsonnel during the perforrance of surveillance testing and modification j
acceptance tests.
Results of QC monitoring are documented in a weekly Non-Conformar,ce Report (NCR) update, The Septerber 22, 1988 NCR listed
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83 deficiencies while the September 29 NCR noted 63 deficiencies that are plant restart items which indicates progress in the resolution to identified prcblems. Quality control reports in the modification package were detailed and indicated that QC observance was scheduled to witness modification acceptance tests. The quality control organizat, ton ensite 4ppears to provide an acceptable overview of the plant operations, raintenance and surveillances programs, No deficiencies were identified.
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a 6.0 Previously_Identifled Unresolved items
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.(, Closed) Deviation (277/278/86-25-04)
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The liceintee had iot performed testing during raintenance on 6he D.C. undervoltage relays to verify that they perfortted their dasign function of annunciating in the control room on low battery voltage.
In March 1987, the licensee performed a test of the 125 and 250 volt 0.C. relays including their annunciators in the control room.
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test results were recorded on form A-25.A-1 titled, "Instrument l
Preventive Maintenance Request." To ensure that these relays are
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pset of a scheduled maintenance program the relay requirements were l
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entered into the Maietenance Request Form (MAF) computer program as t
of October 6, 1987.
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The inspector reviewed the 125 and 250 volt D.C. tett results
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recorded on the A-25 A-1 and verified that they complied with the
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requirements of the test procedure.
The inspector also verified
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that the se relays were listed in the MRF com;. uter program for future i
testi'v.
This item is closed.
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l 6.2 [Closd) Unresolved Item (50-27?/86-25-05 and 50-279/86-25-05)
Calibration records dated May 26, 1985 and December 11, 1986,
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l indicated that the reset, points for ESW piep pressure switches PS-0246 A&B were net calibrated.
The licensee representative stated that the reset was routinely checked, but the calibration procedures would be revised tu ciarify the calibration requirements i
for reset points. The inspector reviewed the revised procedures j
($!2P-33-236-A1CO and $12P-33 236-BICO) to verify the licensee's l
se'. tons had been accomplished. The procedures contained instructions f
for recording the as-found and as-left reset prsssures and they also i
specified an acceptable lower limit for the reset pressure. This action satisfies the concerns of the above unresolved item.
This j
ites is closed.
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6.3 Corrective Action Identified in Licensee's plan for Restart of i
PBX) C $ection I C Revisigl j
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t 6.3.1 Corrective Action CA 3 4.4.7 LOPEN) Review and 'Jpgrade
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I n s t r um e n t a' t i o n a n dl o n t ro flu r v eIh a n c e Te s iTrej e d de s l
Instrumentation and Control (!&C) has completes the rewriting of their Surveillance Test procedures (STs) ocept for four
related to Technical Specifications (TS) ruuirecents ard 50 which are not related to TS requirements, The !&C monthly ST status report lists the complet!on of these procedures scheduled
for the month of December, 1983.
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This item remains open pending verification that the scheduled
!&C STs are completed during December, 1988.
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5.3.2 [ Closed)CorrectiveActionCA1-2.2
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Assess the feasibility of rescheduling surveillan;e tests so l
that the workload is divided among all three shifts.
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i The licensee las defined their program for per orming and r
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supporting three shi't surveillance testing (STs) in their
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letters of September 30, 1987, November 10, 1987 and
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January 21, 1938.
The license, has developed a three shift I
schedule using their authorized man power levels.
The present
workicad is reflected :- the schedalcd three shift surveillance t
performance program. Thi s item is closed.
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Unresolved Items t
Unresolved items are ratters about which more information is reqatred in f
order to ascertain whether they are acceptable items or violatichs, i
Unresolved items are discussed in paragraphs 3.4 and 4.3.6.
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Management Meetings The plant management was informed of the scope and purpose of this
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inspection at an entrance interview conducted on September 26, 1938.
The findings of the inspection were periodically discussed with the (
licensee's cognizant representatives during the course of this
inspection. The exit interview was conducted on September 30, 1988, t
at which time the findings of the inspection were presented (see
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Attachment A for attendees).
The licensee did not indicate that any
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p oprietary in? creation was contained within the scop 6 of this inspeciton.
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At no time during this inspection was written eaterial provided to the licensee by the inspectors.
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sf ATTACHMENT A Persons Contacted The following persons were contacted during the inspection period:
Peach Bottom Atomic Power Station
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C. Anderson, Operatior,s, Senior Staff S. Anderson, Q.C. Support
- J. Carolan, I&C Supervisor A. Chan, Modification Engineer a
- J. Cockroft, Superintendent QA
- T. Cribbs, Regulatory PBAPS K. Cutlar, System Engineer
- J.
Davis, NQA PBAPS
- G. Daegeler, Superintendent Technical
- G. Ge11 rich, Shift Manager
- M. Harmond, Modification Superintendent
- G. Hanson, Regulatory PBAPS
- A. Hegedus, Site Project Engineer J. Heynes, Surveillance Test Coordinator
- B. Hillman, Regulatory PBAPS S. Johnson, Reactor Operator
- D. LeQuia, Seperintendent Plant Services N. Lynch, Q.C. Inspector L. Martin, Fire Protection Engineer K. May, Fire Protection Engineer D. McGarrigan, Superintendent of Quality Control-Mechnical
- T. Mitchell, Operatior; Support Engineer D. Moyer, Reactor Engineer T. Nielson, Shift Supervisor
- T. Nierson, Jr., Shif t Manager
- F. Polaski, Assistant Superintendent Operctions
- M. Ryan, Senior Technical Support Engineer
- D. Smith, Vice President, PBAPS
- P. Sullivan, Modification Engineer E. Wallace, Shift Technical Advisor J. Winzenreid, Operations Senior Staff M. Wolfe, Instrument and Control Technician N. Yost, Shift Supervisor Persons marked with asterisk attended an exit meeting on September 30, 1988:
U.S. Nuclear Regulatory Commission
- N. Blumberg, Chief Operational Programs Section, DRS
- T Johnson, Senior Resident Inspector PB
- R. Urban, Resident Insoector, PB
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ATTACHMENT B The following pertinent reference documents are listed by the report paragraphs.
Paragraph 2.0 Surveillance Procedures Surveillance Procedures Reviewed ST 2.1.08A, Calibration Check of PT/ PISH /PSL 2.2.3.55A (Verify
operability and set point value).
ST 2.25.1.4, Calibration Check of RHR Discharge and Shutdown Suction
Header HI Press Switches PS 2-10-118 and PS 2-10-122A/B (Calibration check of RHR disch6rge header and shutdown suction header pressure switches).
ST 2.25.9, Calibration Check of Torus Room Water Level Transmitter
LT-2919 and Functional Check of ECCS Room Flood Instrumentation.
ST 2.2.02, Calibration Check o/ DPIS 2-23-76 (Verify operability and
setpoint of DPIS 2-23-76).
RT 6.5, EBOP Battery Quarterly Test (Test charge state of the station
EB0P batteries).
RT 5.44, Main Turbine Emergency Bearing Oil Pump Performance Test.
- RT 8.21.1, B0P Battery Weekly Check.
- Paragraph 3.0 Surveillance Tests 1.
Surveillance Tests (ST)
ST 13.18-2, Unit 2 Standby Liquid Relief Valve Setting Test, Tank
Recirculation, Injection of Demineralized Water to Reactor Vessel and Test of Explosive Valve.
ST 16.2.1, Fire System Weekly Check.
- ST 20.073.1, LLRT - Standby Liquid Control.
- ST 2.4.11 B/D/E, Functional Test of LS-2-3-L31 B/D/E.
- ST 8.6, Cardox Battery Check.
- ST 16.23, Fire System Valve Position Verification.
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System (S) Procedures S.13.2.2.G, Routine Surveillance of D/G Cardox System.
- S.13.2.2.H, Routine Surveillance of Turbine Building Cardox System.
- S.3.6. A COL, Standby Liquid Control Checkof f Li st.
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Administrative (A) Procedures A-3, Temporary Changes to Procedures.
- Paragraph A.0 Design Changes and Modifications 1.
Design Changes and Modifications ERDP 3.1 - Procedures for Haadling Modifications.
- ERDP 3.3 - Procedure for ! rformance of Safety Evaluations.
- ERDP 3.4 - Procedure for Design Control.
Nuclear Group Policy Statement 9.1 - Engineering and Modifications.
- ANSI N18.7-1976, Administration Control and Quality Assurance for
the Operational Phase of Nu: lear Power Plants.
ANSI N45.2.11-1974, Quality Assurance Requirements.
- ANSI N45.2-1971, Quality Assurance Requirements for Nuclear Power
Diants 2.
Modification Work Packages No.88-018, Replacement of Diesel Generator Air Coolant Flexible
Hoses.
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No. 1930, Replacement of Turbine Engineering Bearing Lube Oil Pump
Batteries.
No. 1636, Motor Generator Room Area Fire Sprinkler System.
- No. 2387, 2389, Ventilation Modifications.
- No. 1548, 1777, Main Steam Isolation Valve Stem Anti-Rotation.
- No. 1350, Installation of Heat Detection Cable.
- No.88-010, Replacement of Diesel Generator Fuel Crossover Piping.
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,P,aragraph 5 - Quality Control Documents Quality Control (QC) Interface Non-Conformance Status Sheet.
- Procedure CD 6.2, Procedure for the Control of Modification
Documents, Rey, No. 7.
Paragraph 6 - Previously Identified Unresolved Items 1.
Deviation No. 86-25-04 - Documentation Reviewed 87-093, Modification for Replacement of undervoltage relay on 250
VDC BUS 20P12 with upgraded replacement model.
Exhibit A-25.A-1, data sheets for Equipment Nos. 20008, 20P11,
30008, 30012, 30011, 30007 and 20012 associated with 87-093.
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Unresolved Item 86-25-05 SI2P-33-236-A1CO, Calibration Check of ESW Pump A, Pressure
Instrument PT/PI 0236A, PI 0236AX, PS/PI 0240A and PS 0246A.
SI2P-33-236-BICO, Calibration Check of ESW Pump B, Pressure
Instrumen'. PT/PI 02368, PI 0236BX, PS/PI 02408 and PS 02468.