IR 05000277/1990080
| ML20062F236 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/09/1990 |
| From: | Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20062F232 | List: |
| References | |
| 50-277-90-80, 50-278-90-80, NUDOCS 9011270157 | |
| Download: ML20062F236 (42) | |
Text
_ _.
._...
',
'
,,
'
.-
U. S. NUCLEAR REGULATORY COMMISSION REGION 1 Docket / Report No.
50-277/90-80 License No. DPR-44 50 278/90-80 DPR-56 Licensee:
Philadelphia Electric Company Peach Bottom Atomic Power Station P. O. Box 195 Wayne, PA 19087-0195 Fadlity:
Peach Bottom Atomic Power Station Units 2 and 3 Dates:
September 17 - October 3,1990 Inspectors:
J. J. Lyash, Team Leader D. Butler, Consultant, RTS H. Stramburg, Consultant, RTS H, Wang, Reactor Engineer, NRR D. Waters, Consultant, RTS Approved By:
ON '!.
L \\ !ct /90 A
L L. T. Doerflein, Chiej Date Reactor Projects Secti6n 2B Division of Reactor Projects Areas Inspected:
Tee inspection assessed the adequacy of licensee corrective actions implemented or initiated in response to NRC Safety System Function Inspection (SSFI)90-200.
In addition to evaluation of licensee response to the specific SSFI findings, the team evaluated the effectiveness of several licensee programs, c,o11270157 90i10*
_,
FDR ADOck 0500
'
..
- -..... _....
'
'
,
,,
'
.-
TABLE OF CONTENTS Page EX EC UTI V E S U M M AR Y.....................................
il 1.0 INTRODUCTION
......................................
2.0 INSPECTION SCOPE AND OBJECTIVES.......................
3.0 INSPECTION M ETHODOLOG Y.............................
4.0 LICENSEE CORRECTIVE ACTION PROCESS REVIEW.............
4.1 Program Procedure Review
.........................,,,
4.2 Review of Corrective Action Document Backlog and Disposition......
4.2.1 Nonconformance Reports
.........................
4.2.2 Corrective Action Requests........................
4.2.3 Engineering Work Requests........................
4.3 Review of Long-Term Actions Taken to Prevent Recurrence
........
5.0 LICENSEE PROGRAM FOR REVIEW AND APPROVAL OF ENGINEERING ANALYSES AND CALCULATIONS
..........................
6.0 LICENSEE 10 CFR 50.59 EVALUATION PROGRAM
...............
7.0 RESOLUTION OF ESW/ECW OPERABILITY CONCERNS...........
7.1 ESW/ECW Analyses and Calculations.....................
7.2 ESW/ECW Baseline Testing Program
.....................-
7.3 ESW/ECW Maintenance and Modi 6 cation of Piping and Components..
7.4 ESW/ECW Periodic System Performance Testing Adequacy........
7.5 ESW/ECW Operating Procedures........................
8.0 LICENSEE PROGRAM FOR CONTROL OF SAFETY-RELATED FASTENERS
........................................
9.0 ASSESSMENT OF LICENSEE RESPONSE TO SSFI OPEN ITEMS......
10.0 C O N C LU S I ON.......................................
APPENDIX A DOCUMENTS REVIEWED i
... _. _ _
'
,
,.
'
-.-
EXECUTIVE SUMMARY
Peach Bottom Atomic Power Station
Inspection Report 9017
- During early 1990 the NRC conducted a SSFI at the Peach Bottom facility to evaluate the operational readiness of the emergency service water (ESW) and high pressure coolant injection (HPCI) systems. The SSFI identified significant weaknesses with the licensee's approach to analysis, maintenance and testing of the ESW system. The cumulative effect of these weaknesses caused the NRC to question the system's ability to perform its function. Subsequent testing by the licensee confirmed that, for Unit 2, the system could not provide adequate cooling water now in all cases. Two issues identified by the team were later treated as a Severity Level 111 violation.
The objective of this team was to assess the adequacy of the licensee's response to the findings of the SSFI team, and to evalcate the extent to which the findings were indicative of programmatic weaknesses. The team found that in general the licensee had identified and implemented effective corrective actions in response to the SSFl. Issues had been clearly identified, corrective action plans established and implementation of the correc ive actions was progressing. Licensee senior management has been involved in assessing and monitoring the staff's response.
The licensee's follow up analyses, maintenance and testing of the ESW was adequate to establish system operability. The ongoing surveillance program implemented by the licensee provides information which will ensure identification of any additional ring header or cooler degradation, and maintenance of system operability. _ The team was concerned that the licensee had not implemented or scheduled any inspection of the large bore supply piping associated with the system. The licensee evaluated this concern and committed to complete a series of inspections of this piping before startup from the Unit 2 refueling outage scheduled to begin in January, 1991. A clear understanding of piping condition is important given the little margin available for the Unit 2 portion of the system. In the long-term planned licensee modincations will resolve this problem.
Several program areas were evaluated by the team including the corrective action process, control of design analyses and calculations, program for performance of 10 CFR 50.59 evaluations and control of safety-related fasteners were evaluated and found to be functioning adequately. The review indicated that program weaknesses had existed, but licensee efforts during the past two l years have corrected many. A steady improving trend in these areas was noted by the team.
Several weaknesses were identified by the team which warrant further licensee evaluation. These include the potential use of Nonconformance Reports to effect design changes, inadequate implementation of the Equipment Trouble Tag program, questions regarding the independent l verincation program and the need to further assess the practices employed for installation of l safety-related fasteners.
!
il l
_ _ _ _ _ _ _ _... _. _.....
.
.
.
.
.
-
, -
,,
'
.~
DETAILS 1.0 INTRODUCTION Safety System Functional Inspection (SSFI)90-200 conducted at Peach Bottom in early 1990 evaluated the operational readiness of the emergency service water (ESW) and high pressure coolant injection systems (HPCI). The team identified fourteen open items, including two which were subsequently processed as Severity Level 111 violations. The report also included discussion of many other issues that were not assigned numbers. These un-numbered concerns, however, required appropriate licensee response.
-
A SSFI Corrective Action Review Team inspection was conducted from September 17 to October 3,1990, to address the significant issues raised in Inspection Report 90-200. The team was tasked with inspection of the 14 numbered items, other issues discussed in the report, and programmatic areas implicated as weak by the SSFI Rndings. The issues targeted for review
-
were discussed with the licensee prior to the inspection. The licensee prepard information
.
packages for evaluation by the team during the preparation week. Following preparation the
_
team conducted inspections in the licensee's corporate engineering offices and at the Peach E
_
Bottom facility.
- 2.0
INSPECTION SCOPE
AND OBJECTIVES The inspection objective was to evaluate the effectiveness of licensee corrective actions implemented in response to the SSFI, and to assess aspects of certain licere.~.ruverall programs.
The team included three contract inspectors, one inspector from the NRR Special Inspection Branch and a Team Leader. Five days of preparation, six days of direct inspection and four days
-
ofin-office close-out and documentation were performed. The team reviewed licensee corrective actions in response to the 14 numbered items in the SSF1 report, and other issues discussed in the SSFI report but not assigned unique numbers. The team focused on evaluation of the general ESW technical problems described in Section 7 of this report, and the effectiveness of the licensee programs described in Sections 5 through 6, and 8.
3.0 INSPECTION METHODOLOGY
_
The inspection team consisted of mechanical and instrument & controls discipline engineers, and several general operations oriented engineers. The team began the effort by reviewing the
_
licensee's analyses and corrective actions in response to the SSFI team Gndings. The team developed inspection plans to evaluate several program areas that exhibited weakness, as determined by the SSFI team. The team selected inspection samples which allowed evaluation
__
of areas reviewed by the SSFI, and issues of a similar nature not within the scope of the SSFl.
--
Based on these reviews the team reached conclusions regarding the adequacy of the licensee's response to the SSFI and the degree to which the issues are indicative of program strengths or weaknesses.
_
_.
__
r_
-
_ --___
-____. - - -_- --__ _ ____-_-_-_-___-_____-__________________- - - __
___
___- _
- _ _ - _ _ _ _ _
_
__
_ _ _...
',
-
..
-
,.
4.0 LICENSEE CORRECTIVE ACTION PROCESS REVIEW
! awing the SSFI, the NRC issued a Notice of Violation (NOV) and Civil Penalty that
>
inciuded a violation for failure to implement adequate corrective actions in response to known denciencies in the ESW system. The technical resolution of the ESW operability crucerns is discussed in Section 7 of this report. However the focus of the violation was the licensee's failure to act promptly to resolve what had been identined internally as an indeterminant system design, analysis and test status. In the written response to the enforcement action the licensee described a series of program procedures which had been implemented just before or following the SSFl. The implementation of these procedures is viewed by the licensee as representing a signincant improvement in their ability to identify potential safety issues, raise them to the appropriate level of management attention and implement effective corrective action. The response also referred to the licensee's self assessment program and implementation ofimproved engineering department communication and turnover processes as long-term corrective actions which will prevent recurrence.
During the current inspection the team reviewed the licensee's program procedures and discussed their implementation with a cross-section of licensee staff and management. A sample of recently closed corrective action documents was selected to assess the technical adequacy and inanagement approval of closure. The backlog and a sample of issues were reviewed to ensure that appropriate priorities had been assigned and that the backlog was being effectively managed.
The documents selected for review were generated within the past year. In this way the tean.
evaluated the current performance of the licensee's corrective action process.
4.1 Program Procedure Review The team corducted a review of the licensee's corrective action process as it was applied to the Peach Bottora plant to determine if the process was capable of properly evaluating and dispositionin); significant concerns. Program documents which control non-conformance and corrective action programs are:
o NOA-25, " Corrective Action," Revision 2; o
Muclear Generation Administrative Procedure (NGAP) NA-02R001, " Identification and evaluation of Potentially Reportable Items and Events of Potential Public Interest,"
Revision 0; o
NGAP NA 02A002, " Investigation of In-house Events," Revision 0; o
NGAP NA-03N001, " Control of Nonconformances," Revision 1; o
NQA-16, "Open items," Revision 1, o
NEDP 3.11, " Procedure for Processing Engineering Work Requests " Revision 1.
.
.
.
..
..
These program procedures appear to provide adequate guidance to the staff. The team centered its implementation review on activities carried out in accordance with Procedures NQA-25, Corrective Action Requests (CARS), NA-03N001, Nonconformance Reports (NCRs) and NEDP 3.11, Engineering Work Requests (EWRs). Approximately 70 documents of the three types which were prepared and evaluated since September 1989, were selected for detailed review.
4.2 Review of Corrective Action Document Backlog and Disposition 4.2.1 Nonconformance Reports The licensee formed a NCR Quality Review Task Force in early 1990 in response to an NRC concern on the quality of the licensee's Engineering Division NCRs. The team reviewed the results of this effort. The NCR Task Force performed several reviews of NCRs from both the Peach Bottom and Limerick stations.
An initial scoping study of 19 randomly selected damments revealed 5 that were determined to not have adequatejustification of the disposition.
Generif weaknesses were found in instructions contained in NGAP NA-03N001, failure to follow procedure instructions by personnel, and communication and enforcement of management standards and policies. An expanded study of 125 NCRs from a total population of 1206 dispositioned between October 1988, and July 1990, revealed 11 that were judged to have insufficient justincation and required a 10 CFR 50.59 safety evaluation. The root causes for these deficiencies were similar to those determined in the first review. No unreviewed safety question was identified during e;ther of the reviews performed by the licensee. Corrective action was implemented, consisting of a one-A.y workshop on management and quality expectations for NCRs involving Engineering Divuon branch heads, and the formation of a multi-disciplined Design Review Board to revie", modincation packages, NCRs, EWRs and other engineering design activities. Changes to Procedure NA-03N001 were also initiated.
The team's review of NCRs connrmed the weaknesses defined by the task force, especially for those documents dispositioned in late 1989 and early 1990. For later documents, the team noted that the quality of engineering justincations and the depth of review were markedly improved, Although no direct causative factor was evident, the team believed that the improvement may be a result of the improved 10 CFR 50.59 review program discussed in Section 6.
The NCR process is coordinated by the NQA organization, either at the site or at the engineering ofnces. The coordinat.on and handling of the identified nonconforming conditions, including operability determinations, appeared to be satisfactory. It was observed that formal involvement of site management in reviewing significant NCRs at the time they are initiated and at the time they are returned as dispositioned by the responsible organization, was not part of the corrective action program. Informal discussions between plant and engineering personnel usually occurred during the disposition process. The licensee's process is adequate, but early management involvement with significant NCRs may strengthen the process.
The team found indications that the NCR process has been improperly used to perform plant design danges and design document changes. The team found two NCRs which described
-
.
.,
,.
-
,.
problems with system performance but in neither case did a nonconformance with design documents exist. The dispositions of the NCRs, P90ll8 (relocation of an instrument pressure tap) and P90451 (upgrading pressure control valves on containment purge and vent valve backup nitrogen supply) implemented modifications to plant equipment to achieve propei performance.
Both of the NCRs were dispositioned as " repair". Three additional NCRs, also dispositioned
" repair," corrected nonconforming conditions but also specified changes to plant design such as replacing spring supports with rigid supports, changing the size of spring supports, or reducing fuse size in equipment to ensure breaker coordination. The NCRs involved were P90407, P89784-312 and P90085. Nine other NCRs, some dispositioned " repair" and some dispositioned "use as is," required changes to design documents resulting from the disposition, but the NCR package did not appear to provide complete information to constitute a design change package.
These nine NCRs were P90437, P90438, P90443, P90538, P90232, P90369, P90433, P90275 and P90171. The team noted that adequate safety reviews were conducted for the identified NCRs and that independent design review was accomplished.
,
Appendix B to 10 CFR 50, Section III, Design Control, states " Design c..
ges, including field changes, shall be subject to design control measures commensurate with those applied to the original design..." The team was concerned that the performance of design changes and design document changes under the NCR program in the manner described was not consistent with the above-referenced regulations and industry standards.
Additionally, formal design review requirements such as design checklists, management and safety committee reviews, post-implementation testing and modincation turnover, and proper configuration control measures did not appear to be applied to these NCRs. This item remains unresolved pending NRC review of the licensee's follow-up evaluation of this concern (UNR 90-80-01),4.2.2 Corrective Action Requests The licensee uses the CAR process as described in NQA Procedure 25, to document and track j
to resolution signincant non hardware related issues. Generally problems identined by QA, or l
by other licensee groups, which reflect management performance or program weakness are documented for review and follow-up using a CAR. CARS receive a-heightened level of management involvement and require independent assessment of corrective action adequacy by l
the QA organization prior to closure. Additionally, the process imposes time constraints on -
l proposal and implementation of the corrective actions. The inspectors reviewed the associated program procedure, the number and subject of CARS present in the licensee's backlog, and the technical adequacy and timeliness of resolution of a sample of CARS. Generally the process ensured timely and effective corrective action. CARS clearly focused management attention and elicited action. The inspector was concerned, however, about the status and resolution of CAR
!
PA 89-34-09, which questioned the adequacy of daily channel checks for certain safety-related instrumentation.
l l
The licensee's QA organization issued a CAR dated March 14,1990, documenting problems with l
the licensee's approach to instrument channel checks. The primary issue in the CAR is that as
'
a result of recent modifications there is no longer an analog indicator associated with the reactor l
.
--
w w
'
..
.
,.
'
...
pressure sensors which provide wide range pressure compensation and the low pressure permissive for core spray and low pressure coolant injection. TS require a daily channel check of these instruments, but no discrete check is being performed. The response from the licensee's engineering department was that a 100 psig drift in indicated pressure would result in a three inch offset in wide range level (due to the pressure compensation of the wide range), which would not be significant and would be identified by reactor water level channel checks. Based on recent experience this is not credible. The licensee's QA and Operations departments were not satisfied with this response and are evaluating alternatives.
During late August and early September the licensee experienced reactor water level
. instrumentation calibration problems which resulted in exceeding certain TS instrument setpoints.
The adequacy of the licensee's channel check procedures was bought to be a contributor to the duration of the problems. The team questioned if this CAR was an early opportunity to identify the channel check program weaknesses. The team also questioned the adequacy of the analyses associated with the modl6 cation to remove the reactor pressure analog indicators in that it changed the system design without adequate consideration of the ability to continue to implement the TS channel check requirement. This issue and the licensee's resolution of the CAR will be reviewed in conjunction with existing item NV 90-17-03.
4.2.3 Engineering Work Requests The Engineering Work Request (EWR) process is used to document, track and resolve questions or problems identified by the station that require substantial input by the corporate engineering organization. Issues which would result in it,hiation of an EWR include known problems for which engineering evaluation beyond the capability of the plant staff is needed, or assessment of an indeterminate condition or discrepancy for which the significance or resolution are not clear. In the broad sense the EWR is an important element in the licensee's corrective action process. The inspector reviewed the licensee's governing administrative procedure for EWRs and assessed implementation of the provisions contained by reviewing a sample of completed EWRs. The inspector also evaluated the technical adequacy of the completed EWR responses, and the signi6cance and schedule for evaluation of EWRs currently being carried in the backlog.
The licensce's administrative-procedure for processing, review and closure of EWRs was-reviewed by the team and appeared adequate. The licensee maintains the EWR backlog at a small and easily manageable level. EWRs are assigned to a group and an individual within the -
engineering organization. An effective administrative tracking system is in place.
The team reviewed a sample of EWRs initiated or dispositioned during the past two years.
Technical resolutions of the identified issues were adequate, but the level of detail of review and documentation was not consistent. In some cases the EWR response addressed only the speciGc questioned asked, when additional review or guidance would have been appropriate. For example, EWR P50097, initiated in 1989, was a request by the station to evaluate the need to track and evaluate certain reactor pressure vessel thermal cycles. One of the questions asked was if all thermal cycles listed in the analysis needed to be tracked. The EWR reply simply said yes,
<
.
,
.-
-
,.
with no additional amplification or recommendations. Following closure of this EWR, it appears that the issue was not pursued by engineering or the plant staff. The same issue was raised during a NRC inspection in July 1990 and is the subject of unresolved item 90-14-02. Better communication and clearer definition of the division of responsibility between the station and engineering may have resulted in more prompt resolution of the question. In general the quality of engineering response to EWRs has improved during the last year as evidenced by the sample reviewed by the team.
The prioritization of EWRs and timeliness of review and closure appeared adequate. One exception was noted. The team was concerned with the schedule for review associated with EWR P51292. This EWR was initiated by the station to request engineering review of NRC Information Notice 89-55, " Degradation of Containment Isolation Capability by a High Energy Line Break," in July,1989. An interim engineering response was not issued until June,1990, and indicated that the problem described in the Notice could exist at Peach Bottom, but that physical walkdowns in the primary containment were needed to make a final determination. The Unit 3 restart and Unit 2 mid cycle outage were completed following initiation of the EWR, However, no inspection had been completed during these outages. The Unit 3 mid-cycle and Unit 2 refueling outages are planned for the near future, but it did not appear that the inspections would be accomplished. The Notice still remained open in the licensee's tracking system. The licensee informed the team ina the inspections were planned for implementation during the next unit refueling outages. /..thouh the team felt that evaluation of this Notice had not been timely, performance during the next catage on eac'. unit is the next reasonabic opportunity. The team reviewed the status oflicensee sponse b other NRC Information Notices. Recently the licensee initiated a review of the adequacy on closure for all Notices at the request of the Nuclear Review Board. This effort is progressing and will ensure proper closure.
4,3 Review of Long-Term Actions Taken to Preveid Recurrence i
The primary focus of the Severity Level III NOV issued following completion of the SSFI was failure of the licensee staff and management to ensure that effective corrective actions were taken in response to weaknesses and uncertainties identified with the design, operation and testing of the ESW system. The licensee had a number of opportunities during the life of the plant to
!
address the issues, and failed to act effectively. Many of these opportunities predate the extended shutdown and extensive performance improvement program completed in 1989. During that period the licensee generated or revised many of the corrective action process program procedures discussed in the preceding sections. Their written response to the violation references these previously implemented procedures as the basis for concluding that the root causes of the failure to correct the ESW deficiencies have been corrected. Based on the team's review of these procedures and of a large sample of specific corrective action documents it appears that the process is functioning adequately. The thoroughness, timeliness and documentation has clearly improved, and contemporary issues appear to be evaluated and communicated well.
Following the SSFI, the licensee established a matrix of all issues identified and the corrective actions planned or implemented. This matrix was reviewed by senior licensee management to
!
e i
,
..
'
-
,.
'
verify that it adequately addressed the findings. The team requested to review the licensee's root cause analysis of the ESW Dndings. The licensee responded that a root cause aN1ysis had been done by the InJependent Safety Engineering Group (ISEG). The team reviewed the ISEG report dated July 24, 1990. The recomm:ndations included in the report had been input to the licensce's tracking system, but at the time of the inspection no responsible individuals had been assigned. The licensee stated that ownership for each recommendation would be assigned. The matrix and ISEG report appear to outline a comprehensive corrective action plan to address the ESW issues.
Two ongoing actions to prevent recurrence were discussed in the licensee's response. The first was that a program would be implemented to formalize and enhance the turnover process as it relates to transfer of restv.,nsibilities between technical personnel at the station, within the engineering organizatios and between the station and engineering. The licensee, after additional consideration, has concluded that a formal turnover process beyond the general guidance already
,
available on transfer of responsibilities, is not needed. The licensee stated that management is sensitive to the need for control of information and issue transfer. The licensee cited the effectiveness of the turnover associated with the recent engineering reorganization as evidence of this. The licensee is also implementing the Plant Information Management System (PIMS)which will provide for better tracking of identined issues. The inspector concluded that development of a formal turnover process may not be needed if implementation of PIMS is completed and management sensitivity to this issue is maintained.
The second factor discussed in the licensee's response was that ongoing self-assessments would monitor the effectiveness of the cited corrective actions. The licensee stated that no specific self-assessment activity or audit was planned, but that the overall self-assessment and QA program would perform this function.
5.0 LICENSEE PROGRAM FOR REVIEW AND APPROVAL OF ENGINEERING ANALYSES AND CALCULATIONS i
l The SSFI inspection identified an apparent weakness in the li" a's program for review, approval and control of engineering analyses and calculationL die identified weakness was based on problems with retrieving several ESW system design calculations and denciencies found in basic assumptions, references, methodology, review and approval, and docementation control l
of calculations. In addition, design information was found to lack proper bas:s or calculations l
and analyses were non existent.
The team performed a detailed review of the licensee's overall program and practices pertaining to control of analyses and calculations. Historical documentation concerning the licensee's past
'
practices was compared to recent methods of control via administrative procedures.
The team noted that in the past the majority of calculations and analyses were performed, maintained and controlled by the vendors contracted for their performance. The licensee did not receive the documentation as a " turnover package" at completion of the task. However, the
_ _ _ - _ _ _ _ _ _ _ -
. _ _ _ _ _ _ _ _
_ _ _ -.
,a
,
a'
'
..
vendor was required to maintain document or design control measures. Tht +.4eient calculations identined by the SSFI were vendor developed and maintained, The team discussed the problems associated with vendor supplied analysis and calculations with the licensec and reviewed Procedure NE-041, " Interface Specification," Revision 0.
This procedure was recently implemented and establishes the standards that vendar analyses must meet for licensee acceptance. The procedure appeared adequate to control tne activities of vendors providing engineering services. As previously performed calculations are revised to support
.nodifications, the licensee will upgrade them and transfer control from the vendor.
Additionally, a long term program to transfer all calculations and analyses to licensee control is under development.
For those tasks performed by the licensee's staff, direction and ontrol is provided via admir.istrative and technical procedures. The licensee provided copies of current Nuclear Engineerir.g Department Procedures, NEDP 3.4, " Procedure for Design Control," Revision 19, and NEDP 3.9, " Procedure for Preparation and Control of Design Calculations," Revision 12, for the team's review. The team found that the procedures were adequate to govern the development, review and approval of analyses and calculations prepared by the licensee.
In order to evaluate the licensee's performance in adhering to the requirements of the procedures, the team reviewed a population of 10 new or revised calculations. No technical errors or omissions were found, however, two of the safety related calculations were found to have administrative deficiencies:
,
o Calculation ME-64, Revision 1, was deficient in two areas. The list of attributes verified during the independent review was not included as required by Procedure NEDP 3.9, Paragraph 6.3.4, and the revised areas of the calculation were not clearly identified as required by Procedure NEDP 3.9, Paragraph 6.4.1.1.
o Calculation EB-33, Revision 3, was deficient in that the revision number was not
- Indicated as required by Procedure NEDP 3.9, Paragraph 6.4.1.1. This procedure requires a revision bar and a triangle containing the applicable revision.
Both calculations were prepared, reviewed and approved under the referenced governing procedures. The minor deficiencies appeared to result from a lack of attention to detail and strict adherence to procedure requirements. The team concluded that the current licensee program for development and control of calculations and analyses is adequate, Implementation of the program was found to be generally good.
6.0 LICENSEE 10 CFR 50.59 EVALUATION PROGRAM The SSF1 identified two instances where the licensee failed to prepare adequate written safety evaluations to provide a basis for a determination that design changes to the ESW and ECW systems did not involve an unreviewed safety question. In view of the violation the team
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
._
_
_
_ _ _ _ _ _.
_ _ _.
_.
'
.. -
..
,
'
..
'
performed a review and assessment of the licensee's process for development, review and approval of 10 CFR 50.59 cvaluations.
The process is controlled by NGAP NA-02R002, "10 CFR 50.59 Reviews,' Revision 0. Z -
procedure was effective 12/1/89 and constitutes an improved pmgram designed 1 be used foi facility design changes, tests and experiments, in addition, the use of the procedure was expanded to apply to certain NCR dispositions, UFSAR changes, Q-list revisions and procedure revisions.
The guidance contained in NSAC 125, ' Guidelines for 10 CFR 50.59 Safety Evaluations," June 1989, was incorporated in the procedure to ensure that the process was consistent with industry practice. This new procedure resulted in requirements to provide increased documentation of the justifications and rationale used to support conclusions reached in evaluations, increased requirements for interfacing group review and approval, and the opportunity for additional management review and approval of evaluations.
The team reviewed the procedure as well as training provided to evaluators and reviewers on application of the procedure. Discussions were held with engineering and plant management personnel charged with implementing the improved program, and with Quality Assurance and independent Safety Engineering Group (ISEG) staff members responsible for as;essment of program effectiveness. The following observations resulted from the review:
o The procedure increased the scope of information considered during review of the licensing basis far the plant over that contained in NSAC-125 to include other commitments either imposed by or made to the NRC. This is considered a strength, o
The training program for engineering and plant personnel was comprehensive and provided good reference material for use in preparing or reviewing 10 CFR 50.59 e,aluations. It was noted that over 400 personnel were afforded the training and that the training was designed to be given once as opposed to being repeated on a p:riodic basis.
The licensee believed that continuing supervisory reviews of work products, including safety evaluations, was sufficient to ensure a high quality level of evaluations without the need for periodic retraining, o
The commitment tracking program was in the process of being upgraded and expanded to provide a comprehensive data base of commitments and make it more casily usable by researchers. Commitments made since licensing of both Peach Bottom and Limerick will
'
be available onscreen using the PIMS when the system is complete. The licensee is planning to have the database prepared and training and familiarization completed by early 171. This appears to be a useful tool for ensuring adequate knowledge of
,
comnntments for conducting 10 CFR 50.59 reviews and other plant activities.
l o
Plant activities (Temporary Plant Alterations [TPAs], procedure changes, new procedures, test procedures, etc.) that result in the performance of safety evaluations are routed to the Nuclear Review Board (NRB) for review. At Peach Bottom, this review is performed by the ISEG with summary reports to the NRB. It was noted that only activities that l
.
.
.-
,
-
,.
resulted in a safety evaluation after a safety determination was performed were subject to the ISEG review. The team observed that only one or two of the safety evaluations reviewed by ISEG e ver the past six months (approximately 50 reviews) required follow-up for clarification or were deemed to be insufficiently performed. The individuals interviewed in the ISEG stated that they had observed increased quality of safety reviews since the issuance of NGAP NA-02R002. This observation was echoed by several members of plant management.
The team reviewed safety determmations and safety evaluations associated with selected TPAs, procedure changes, NCRs, CARS, plant modi 0 cations and Technical Sl,ecification submittals prepared between September 1989, and August 1990. Approximately 50 documents were selected. The team found that more recent safety evaluations (since December 1989) performed by both the engineering and site organizations had the increased formality and rigorous jusufication of determinations expected from the newly applied process, it appeared that the 10 CFR 50.59 cualuation process was being adequately applied and that review and assessment of the process was active and capable of determining weaknesses.
7.0 RESOLUTION OF ESW/ECW OPERABILITY CONCERNS The SSFI identified that the licensee had not performed adequate calculations and analyses to support the operability of the U.SW system. The closed loop cooling modes associated with the ECW and emergency cooling tower (ECT) 1.ad not been evaluated to ensure sufficient coolant flow, calculations had not been performed to determine acceptatic net positive suction head for the booster pumps and to correlate the throttling of the pump discharge valve with system flow.
Additionally, the licensee failed to perform and document adequate safety evaluations as required by 10 CFR 50.59 for modifications made to system equipment.
The licensee acknowledged these inconsistencies and deficiencies and indicated that testing would i
be conducted to verify operability. Where needed calculations would be performed to provide necessary assurance and baseline information. The approach implemented by the licensee following completion of the SSFI included: 1) performance of several safety evaluations and needed analyses; 2) conduct of a baseline testing program to establish ESW operability for Unit 3, Unit 2 and in the dual unit mode; 3) performance of maintenance and modifications to the system in support of establishing operability, and 4) development of an ongoing surveillance testing program., Each of these elements is discussed in detail below.
l 7.1 ESW/ECW Analyses and Calculatione, The SSFI identified that the fluid system calculations and analyses performed during the design anc* construction of the ESW and ECW systems included several signincant nonconservative assumptions, inaccuracies, and they were not validated against the as-built system configuration.
Analyses establishing the design heat loads, heat exchanger heat transfer capabilities and predicting room peak temperatures were also deficient. Additional analyses completed since construction indicated that deficiencies existed but were not followed up.
. _ _ _ _ _ _ _ _
_
._.
__
_ _ _ _ _ _ ___
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
.
.
..
'
,.
,
The licensee, with contractor assistance, performed the analyses needed to establish the maximum heat load in each ECCS and RCIC pump room during design basis accident conditions. This information was combined with heat exchanger heat transfer estimates and the maximum allowable room temperatures dictated by equipment qualification limits. The end result was the determination of the minimum acceptable ESW Gow rate through each cooler. The inspector reviewed the HPCI and RCIC analysis. This analysis was selected because the present condition of the ESW system makes it limiting for Unit 2. The inspector evaluated the data, assumptions, methodology and results. No ct..scrns were identined.
The SSFI also identined that the ECW/ECT system had not been appropriately modeled.
Operational experience hows that the booster pump associated with this mode of operation trips on low suction pressure if manual throttling of the discharge valve is not implemented. The affect of this action on cooling water flows had not been adequately analyzed. Also during 1979 the licensec :solated the reactor building closed cooling water (RBCCW) system from ESW, Although this isolation climinates a large flow path to the booster pump suction, its impact was
' adequately analyzed.
The licensee evaluated these concerns and revised the Safety Evaluation, "10 CFR 50.59 for MOD 5095 Emergency Cooling Water System Upgrade PBAPS, Units 2 & 3," Revision 7. This safety evaluation addresses the impact on ESW of isolating the RBCCW crosstic. The licensee is pe: forming an -
1ation of the impact of this isolation on the RBCCW system and the loads cooled by it. Th, acensee stated that this evaluation would be complete by early November,1990.
Calculation PM 106 was prepared to support and document the acceptable range of booster pump suction pressures. The calculation confirmed the need to throttle the ESW booster pump discharge valves in order to ensure suf0cient back pressure, and established a range of suction pressure values that if maintained would ensure adequate flow through the component heat exchangers. The team found the calculations and the safety evaluation acceptable. However, the use of a gate valve for long term throttling is not a recommended practice due to the dif0culty of controlling Dows and excessive valve wear. The licensee is aware of the problem and implemented acoustic monitoring of the valve during system operation. But the team observed that no provision for continued monitoring or modi 0 cation was identified.
7.2 ESW/ECW Baseline Testing Program l
l The SSFI identified that the licensee failed to conduct adequate design basis performance testing of the ESW system after construction. Additionally they had not implemented a technically adequate surveillance testing program to assure continued system operability in all modes.
Further, operating history indicated problems with system blockage due to corrosion and silt, and with ESW booster pump operation.
Following the SSFI the licensee shutdown Unit 2 for a mid-cycle outage. The ESW system was aligned to support Unit 3 and the minimum required Unit 2 cooling loads. The remaining Unit 2 loads were isolated. The licensee implemented a performance test in this alignment and verified that the system was adequate to support continued Unit 3 operation.
-
.
-
- -
.*
.
..
-
,.
in order to assess the condition of the Unit 2 piping the licensee performed several diagnostic tests. Safety Evaluation, "10 CFR 50.59 Review for Opening of Cross Tie Valves 0-3': 511 A
& B on the Common Cross Tie Line Between Discharges of ESW Pumps OAP 57 and OBP 57 PBAPS, Units 2 & 3," Revalen 0, was performed to support the crosstie of ESW to Unit 2 while Unit 3 was in operation. The safety evaluation verined that the ESW ;ystem would continue to provide balanced and adequate now to Unit 3 following the crosstic. The team reviewed the evaluation and the precautions required during testing and concluded that they were adequate.
Prior to Unit 2 restart Surveillance Test ST 21.5 1, " Dual Unit ESW Test of ESW te ECCS Ring Headers and Emergency Diesel Generator Coolers," was performed to demonstrate the ability of ESW to supply adequate now to both units, under design basis conditions. The final conduct of the test followed throttling of the ESW Dow to the emergency diesel generators (EDG) and valving out of one of two room coolers in each emergency core cooling system (ECCS) and reactor core isolation cooling (RCIC) system pump room. These modifications to the system Dow path were needed to divert additional Dow to the in service coolers to meet the minimum now required by the analysis. The steps provided in this surveillance procedure adequately determine the driving pressure available at the emergency diesel generators and the supply and return ring headers for later use in verincation of minimum ESW system Dow rates.
Surveillance tests ST 21.5 2 & 3, "ESW Flow Through ECCS Room Coolers and RHR Pump-Seal Coolers," Units 2 & 3, were subsequently performed to demonstrate the ability of the ECCS room coolers and seal water coolers to pass the required design Dow. The team reviewed the test results and no outstanding concerns were noted. It is clear that while adequate Dows are being supplied, very little margin exists.
The licensee also performed Special Procedure SP-1353, "ESW Booster Pump Discharge Valve Throttling Limit Determination," to verify the ability to throttle the ESW booster pump discharge valves. The team reviewed the results of the testing and noted an apparent deficiency with respect to the pressure instrumentation used during the test. Pressure transmitter PT-0550, "ESW Booster Pump Discharge Pressure," had a calibration sticker dated September 27,1988, af0xed at the time of test performance, April 14, 1990. The team concluded that this calibration cycle was excessive and requested further infonaation. The licensee provided a more recent calibration record dated February 14, 1990. The licensee stated that they intend to delete the use of calibration stickers. Deletion of the calibration sticker program provides increased opportunity for use of out of calibration test instrumentation and will require sensitivity to this area by individual test performers. It also reduces the effectiveness of management and QA/QC routine Geld observations.
The team concluded that the licensee had conducted adequate baseline testing to establish the ability of the ESW system to support operation of both units. Testing performed on the ECW/tiCT system was also adequate.
!
!
l l
.
_
_ _ _. _ _ _
.
'.
.-
-
,.
7.3 ESW/ECW Maintenance and Modification of Piping and Components The SSFl i(,ntified weaknesses in the licensce's approach to maintenance and modi 0 cation of the ESW system. The licensee repaired equipment failures and now blockage without taking adequate action to assess the system condition and to permanently correct the problem.
As discussed above the licensee implemented an extensive baseline and ongoing ESW test program. The results of this testing identified that the Unit 2 portion of the system had degraded to the point where minimum flows could not be obtained with the system in its normal configuration. The licensee implemented a piping inspection and cleaning program in an attempt to remove the blockage. This program was not successful in increasing flow to the required value. The licensee implemented two system alignment modifications which serve to divert now to the weak parts of the network, it was determined that the EDG coolers were passing signincantly more now than required. The licensee implemented a modincation to throttle the cooler inlet valves to ootain a lower now rate.
Safety Evaluation, "10 CFR 50.59 Review for Throttling of ESW Flow to the Emergency Diesel Generators PBAPS 6280 Equip 1-18 2 (Diesel Generators)," Revision 2, was performed to assess this modification. The safety evaluation provided necessary information and analysis to support throttling ESW flow to the EDGs, Adequate precautions and considerations were included to ensure sufficient design margins for continuous diesel operation and testing was identified to preclude damage to the valves being used for throttling.
The licensee also implemented a modincation to isolate now to one of the two redundant coolers in each Unit 2 ECCS and RCIC pump room, thereby diverting additional now through the remaining cooler. Safety Evaluation, "10 CFR 50.59 Iteview for the Temporary Isolation of the Standby ECCS and RCIC Unit Coolers," Revision 1, was reviewed by the inspector. This safety evaluation provided the basis for the realignment. This is identified as a temporary adjustment until modification 5110 to replace the degraded ring headers is completed on Unit 2 during the next refueling outage. The safety evaluation addresses isolation of the standby coolers, and the practice of " falling open" the inlet valves on the primary coolers. While this modi 0 cation reduces the level of redundancy in the cooling system design, it does not introduce a limiting single failure and is permissable by the facility TS. These modifications in conjunction with the ongoing test program ensure short term ESW operability.
The team reviewed the overall testing, inspection, cleaning and modification program applied by the licensee. Also historical maintenance and testing histories for the system were reviewed.
As a result of various piping leaks on Unit 2 the licensee inltiated a laboratory analysis of deposits and material found in the 3" ESW pipe. The report,
- Metallurgical Laboratory Note No.84-822," dated August 23,1984, indicated that the maximum thickness of deposits was 1-1/4 inches and the maximum pit depth equaled a wall reduction of approximately 52%. The report stated that the deposits were typically a result of low Dow rates and intermittent use.
,
-
"
i i
imm-_-
--
r
-1 l
Long term resolution of this problem includes the aircady completed replacement of the Unit 3 ring header with six inch piping, and a planned similar modi 0 cation to Unit 2 in the next refueling outage. The licensee has a chemical injection system installed to aid in inhibiting i
biofouling and corrosion, but the system had not been operable. The licensee is taking steps to place the system in opera: loa.
These actions focus or the ESW ring headers and the individual coolers. The team was concerned that no inspection, cleaning or testing was in place to assess the condition of the large bore ESW piping which delivers coolant Gow to the ring headers on both units. Given that the larger pipe is similar in characteristics to the ring headers, the team questioned if similar corrosion and silt buildup was present. The Unit 3 ESW system and ECCS coolers have experience three test failures since the new piping was installed. Those failures were due to flow blockage by loose materials.
Since the ring headers and coolers represent the limiting components of system resistance, the in-place now testing program would not indicate the condition of the large pipe until the potential degradation had progressed to an advanced stage.
The team expressed concern that although a limiting How restriction may not be evident, the potential may exist for system upset or a seismic event to dislodge some of the material and plug the smaller ring headers or coolers. Additionally, pipe wall thinning may be a concern. The team's concern regarding this possibility was heightened because of the very small flow margins available to the Unit 2 cooling loads and the isolation of the redundant coolers.
In response to the teams concerns the licensee committed to perform a series of visual, l
ultrasonic, camera and radiograph inspections of the large bore piping. These inspections will
!
be completed by the conclusion of the next Unit 2 refueling outage, scheduled to begin in
,
January,1991. The licensee also stated that material samples will be taken for corrosion analysis
!
and testing for microbiological induced corrosion. The inspections will help to determine the actual condition of the pipe, and the need for any corrective action.
l The team considered licensee actions to establish interim operability of the system, in conjunction with the commitment to implement the piping replacement mod 10 cations and large bore piping
.
inspections adequate to resolve this issue.
!
7.4 ESW/ECW Periodic System Performance Testing Adequacy The SSFI identined sign 10 cant weaknesses with respect to the ongoing surveillance test program applied to the ESW system. The testing did not demonstrate the ability of ESW to perform its function nor provide meaningful data for trending system performance.
The licensee acknowledged the denciencies and following completion of the baseline testing program described in Section 7.2, established new or revised test procedures. Procedures reviewed by the team included:
o ST 21.5-1, " Dual unit ESW test of ESW to ECCS ring headers and diesel generator coolers," performed quarterly or after maintenance that may affect ESW system Dow rates;
.
,
i
,.
,
..
.
l
,.
o ST 21.5-2, "ESW flow test through ECCS room coolers and RHR pump seal coolers -
Unit 2," performed monthly, o
ST 21.5-3, "ESW flow test through ECCS room coolers and RHR pump seal coolers,
Unit 3," performed quarterly.
The SSF1 team reviewed the surveillance test procedures for purpose, scope, technical adequacy and frequency of testing. Test results obtained since implementation were reviewed. ST 21.51 aligns the ESW system and its cooling loads in the design basis configuration. Each of the two ESW pumps is run, one at a time, and the cooler inlet and outlet header pressures are measured.
The lowest of the two measured differential pressures
- (dp) is then used as the baseline for
_'
performance of the periodic individual cooler flow rate tests. Performance of ST 21.51 quarterly assures that any additional degradation in the supply and return piping or pump performance will be detected. ST 21.5 2 and ST 21.5-3 measure individual cooler flow rates at the previously established dp. The Unit 3 test is performed quarterly because the supply and outlet ring headers were replaced with an improved design during the last outage. The Unit 2 headers are scheduled for replacement during the January 1991 outage. Monthly Unit 2 testing will continue until the replacement is complete.
ST 21.5 2 had been performed six times with one cooler failure identified. HPCI cooler 2AE56 failed to provide acceptable flow rates due to foreign material obstructing the now path. After required maintenance and flushing activities were complete adequate Dow capability was restored.
ST 21.5-3 had been performed three tim.:s with three system failures identined. HPCI room cooler 3BE56 failed the flow tests in June 1990 and again in September 1990. RCIC room
!
cooler 3DE55 also failed the September 1990 Dow test. This appears to be the result of silt input and loose corrosion product transport. The piping configuration in the area of these coolera makes them susceptible to blockage. The licensee is evaluating possible solutions.
The team concluded that the testing approach and procedures implemented by the licensee adequately demonstrate continued ESW system operability. Test results indicate that some flow blockages are occurring in susceptible sections of the piping. However, the percentage of tests performed that have failed is not excessive.
7.5 ESW/ECW Operating Procedures The SSF1 inspection identified deficiencies in Procedure SO 48.1.B, " Emergency Cooling Water System Startup," that could adversely affect system heat removal capability and prevent it from I
meeting its function during accident conditions. These deficiencies were carried as an unresolved item (90-200-10) pending NRC review of the licensee's corrective action.
The team reviewed Revision 6 of the subject procedure to determine the adequacy of corrective actions, and found that the procedure no longer referenced the lineup of the RBCCW system as l
'
part of the procedure requirements. Procedure SO 33.7.B, "ESW System Backup to RBCCW Heat Exchangers," was deleted as well. Direction waa also provided for maintaining the ESW
. _
. _.
__
,.
,
,
,
Booster pumps within a suction pressure range of 0-8" Hg (as specified by ca*:ulation PM 106)to ensure thtt excessive now restriction would not be experienced by the.'.CCS room and equipment cocJers. The booster pump discharge valves were throttled to a pos. tion determined bv testing performed during the March April outage to maintain the suction pressure range.
Additional guidaice was developed and provided to the operator to adjust the th ottled position in case the suctior, pressure range was not met or the running booster pump trippeJ. Instructions were provided to monitor now for cavitation if throttling was required be)ond the limits established by the referenced testing. The procedure changes made by the licensee appeared adequate to resolve the concerns identified by the SSFI inspection team, in comparing Procedure SO 48.1.B with calculation PM 106, the safety evaluation and the test results, additional deficiencies were found that had not been addressed by the licensee when resolving the specific SSFI issues. The deficiencic; were:
o Page 5 of the revised safety evaluation provided justincation for maintaining ESW return now to one ECT cell instead of two. This minimizes the need to throttle the ESW Booster pump discharge gate valves while still ensuring the required heat removal capability. The team noted that Procedure SO 48.1.B specified instructions in the note on Page 4 and steps 4.3,4,9 and 4.10 to line up a second cell. The team was concerned that these steps could result in tripping of the ESW Booster pumps by lowering the discharge pressure and were not consistent with the safety evaluation. The licensee concurred and initiated corrective action to revise the procedure and remove the directions, o
Step 4.11 of Procedure SO 48.1.B specified compensatory steps to restart an ESW Booster pump following a low suction pressure trip during Gooding conditions such that access to the pump structure was not achievable. Since the suction pressure gage reads out locally, r:o information is available to the control room operator to ensure that the required suction pressure range is maintained. The licensee reviewed the conditions under which access to the pump structure would be restricted due to the postulated flooding condition, and cietermined that such conditions were unrealistic. The licensee committed to revise the procedure and diminate the actions specified in Step 4.11 if supported by a 10 CFR 50.59 determination, nr develop guidance based on control room indication for operator action to ensure proper cooling flow.
The team concluded that following implementation of the procedure changes discussed above, the SSF1 concerns regarding the operating procedure for the ECW/ECT would be resolved.-
8.0 LICENSEE PROGRAM FOR CONTROL OF SAFETY-RELATED FASTENERS The SSFI identified several discrepancies with the installation of safety related fasteners in the llPCI system. The specific examples were relayed to the licensee for evaluation it.e team also expressed concerns regarding possible program weaknesses which led tc, their installation. The
.
.
. _ _
_
.
-
',
i
..
'
'
,.
licensee documented each of the discrepancit.c Sntified by the team on a NCR. Each NCR was reviewed by the licensee's technical staff and dispositioned "use as is." No fastener replacement was required.
During this inspection the team reviewed the licensee procedures addressing control of the installation of fasteners. These included:
o Specification NE-004, " Torquing of Flange Bolts," Revision 0, August 10, 1990; o
Maintenanze Guideline M G 4.2-7,
" Bolting / Torquing Guideline,"
Revision 0.
Septembe 19, 1990; o
Administrative Guideline AG 26.5, " Defects Found and Work Performed," Revision 0, August 2,1990; o
Specification M 300, " Piping Materials, Instrument Piping Standards and Valve Classifications," Revision 12 wi h Addendum 2, September 18, 1990; t
o Installation Procedure IP 5.2,
- Procedure for Installation of Piping / Tubing Systems,"
Revision 7, May 31,1990,
'
o Installation Procedure IP 5.6, " Procedure for Installation of Supports and Structural Steel," Revision 8, May 31,1990.
These procedures were in place prior to the SSFI, but some were revised by the licensee to enhance the level of detail and clarity in response to the inspection findings. The licensee also revised the following training procedures and modules to provide better instruction for safe bolting and torquing:
o General Training GM4 08 401, " Torquing," Revision 1, April 19,1990, o
Training Module 90-02B, " Bolts and Bolting," Revisim 1, June 5,1990.
The team reviewed these documents and found that NE-004 provided torquing requirements for ASME Classes 2 and 3 and ANSI B31.1 Piping. MG-4.2-7 defines the responsibility and requirements for the inspection, installation, and torquing of bolted connections except for electrical and structural connections. MG 4.2-7 also requires inspection activities to ensure that proper markings are present or transferred to studs or bolts. Addendum 2 to Revision 12 of M-300 provides a list of all piping classes currently in use at PBAPS. Installation Guidelines IP 5.2 and IP 5.6 provide the requirements for bolted connections not covered in MG 4.2-7. The training outlined above has not yet been fully implemented. The licensee stated that formal train-ing will be provided to site and mobile maintenance personnel and MG 4.2-7 will be added to general training.
..
- -
.
.
--
',
,.
'
,.
It appears that the licensec has established procedures and guidance addressing the specincation and installation of safety related fasteners.
The problems noted by the SSFI are likely implementation and not procedural weaknesses. While the changes made to these procedures were not substantial, the licensee improvement in the training program and commitment to implement it should improve worker practices. None of the dencient conditions identined by the SSFI impacted system operability. The licensee did not perform any in-0cid walkdowns of other installed lasteners to determine the scope of the weakness. However, the licensee pointed out that the heighten awareness of the system engineers and maintenance supervisors should detect improper fasteners in the field. The team concluded that this area should receive inspector review, including inspection of a larger sample of installed bolted connections, prior to closure (see UNR 90 200-14, Section 9.0 of this report).
9.0 ASSESSMENT OF LICENSEE RESPONSE TO SSFI OPEN ITEMS The team reviewed the licensee's actions in icsponse to the 14 open items identified by the SSFl.
In addition, the team selected for review 17 additional issues discussed in the report which required some corrective action by the licensee. The status and disposition of each open item and issue is addressed eparately below. The 14 open items are either closed or updated. The t.pdated items will received additional review in the future. The subset of the 17 other issues which will require additional follow up review are assigned open item numbers within the text, item 90-200-01 (Closed)
The SSFI identified a violation of 10 CFR 50, Appendix B, Criterion XVI. This violation addressed the licensec's failure to identify ESW flow deficiencies from initial plant start up until 1983, and the failure to initiate corrective action once the ESW system deficiencies were identined. This item is closed based on the review of the licensee's corrective action process and the technical resolution of the ESW operability concerns. These areas are discussed in Sections 4.0 and 7.0 respectively, hem.20 200-02 (Closed)
The SSFI identined a violation of 10 CFR 50.59 requirements. Written safety evaluations were not performed, documented or maintained assessing the effect of throttling the ESW Booster
!
pump discharge valve on the system now nor the effect of isolating the RBCCW system from the ESW system. The licensee provided the following new or revised safety evaluations to the team for their review:
l o
10 CFR 50.59 for Mod 5095, Emergency Cooling Water System Upgrade, Revision 7; l
o 10 CFR 50.59 Review for the Temporary Isolation of the Standby ECCS and RCIC Unit Coolers, Revision 1;
-
,
'.
..
-
..
o 10 CFR 50.59 Review for Throttling of ESW Flow to the Emergency Diesel Generators 6280-EQUIP l-18-2 (Diesel Generators), Revision 1, o
10 CFR 50.59 Review for ESW Operability During Unit 3 Operation / Uni: 2 Testing, Revision 1.
The safety evaluations satisfactorily address the specific concerns identified in the violation and provide adequate assurance that current ESW system operations are consistent with safety requirements for the system. An evaluation of the effect of RBCCW isolation on safe operation of the plant considering those components cooled by RBCCW was not complete at the close of this inspection, but was expected to be complete by November 1,1990. Review of these evaluations in conjunction with the programmatic review described in Section 6.0 support closure of this item.
Item 90-200-03 (Closed)
The SSF1 identified a cross wiring situation between the min A and Train B ESW pump logic circuitry networks in which the wiring was terminated on adjacent control switch terminals. This configuration did not appear to meet industry electrical separation or single failure criteria.
The licensee provided the team with an evaluation and analysis to justify that this configuration provided adequate train separation and satisfactory independence to meet their committed design criteria. The separation criteria appeared to be adequately justified with reference to industry I
standards and licensing requirements in effect at the time of initial licensing of the Peach Bottom plant.
Further, the analysis of the four failure modes of the control switch appeared to demonstrate that the configuration would not result in a common failure of the two trains of ESW pumps.
item 90-200-04 (Closed)
,
L The SSF1 identified that adequate documentation did not exist to show that the ECT fan controls and associated cables could withstand a scismic event.
l The licensee provided the team with ECT equipment specifications. Based on a review of the specifications, the team concluded that the ECT equipment ie seismically qualified.
With regard to the seismic adequacy of the ECT cable raceways, the licensee provided the team with the current status or the issue and future plans for verification of the raceway seismic qualification. The team was informed that the ECT conduits and conduit supports were installed to the same criteria as the conduits and conduit supports in the rest of the plant. The licensee also stated that a consulting engineering firm conducted a walkdown of conduits and cable trays in Nc ember 1988 and concluded that a safety concern did not exist at Peach Bottom regarding seisn " adequacy of raceways and supports. The licensee is developing plans to verify this conclusion as part of their commitment to the NRC to confirm the seismic adequacy of plant
.
-
-
' ',
..
,.
equipment in response to Unresolved Safety Issue USI A-46, " Seismic Quali0 cation of Equipment in Operating Plants." The team concluded that the licensee's actions were adequate to resolve the SSFI concerns.
Item 90-200-05 (Closed)
The SSFI identified that an incorrect value had been used in Station Blackout Procedure, SE-ll, for the HPCI system suction transfer temperature setpoint. The 200 'F value in SE ll was above the maximum temperature for adequate net positive suction head (NPSH) for the HPCI pump. The licensee agreed that the 200 'F transfer point for the HPCI pump was unsatisfactory and committed to revise procedure SE-ll to indicate 190' F.
The team reviewed procedure SE-II, Revision 3, dated March 16, 1990, and found that paragraph 16.b was revised to read "when torus temperature reaches 190 'F, then transfer suction to the CST." Since the maximum temperature of the torus without causing cavitation to the HPCI pump was calculated by Bechtel to be 196 'F, the team considered the revised procedure acceptable.
Item 90-200-06 (Closed)
The SSF1 identined inadequacies in the HPCI system control logic fusing con 0guration, in that fuse design for certain support components did not provide needed selectivity. The team also found that the llPCI alternate shutdown logic circuit may not be provided with adequate fuse protection.
The licensee issued and dispositioned NCR P90107, which provided justification for contin ied operation with the current fusing arrangement and required future modification for final closure.
The team's review determined that the problem was adequately described and that suf0cient detail was provided to ensure proper understanding of the problem and corrective action. The justincation for' continued operation covered the period until the fuses can be replaced by Modi 0 cation 5243, which is scheduled to be implemented during the upcoming refueling outage and completed by April 1991. The approved disposition of the nonconforming condition contained in the NCR appears to be adequate pending implementation of the referenced modification.
.
l Item 90-200-07 (Closed)l The SSFI found that licensec maintenance personnel were using uncontrolled documents in the field. The team observed uncontrolled copics of electrical drawings placed at one breaker cubicle l
to facilitate maintenance and testing activities.
The licensee issued a memorandum to all supervisors prohibiting the use of uncontrolled documents in the field, and stated that the proper use of procedures and drawings would be included in the technical staff's training program. The team reviewed the memorandum dated
'.
..
,,
August 16, 1990, issued by the Peach Bottom Atomic power Station (PBAPS) Plant Manager to distribution, indicating the expectations on the use of controlled prints in the field The team also reviewed the training plans prepared by the PBAPS Training Department addressing the proper use of procedures and drawings. Inside cach training plan, there were paragraphs i
emphasizing the importance of using appropriate and controlled documents and also stating that use of uncontrolled documents was not acceptable. The training was initiated in March 1990 for ce technical, maintenance and I&C staffs, and is expected to be finished by the week of October 12, 1990.
The team considered the licensee's correcL /e actions adequate to resolve the original concern.
However, additional review of the use of uncontrolled drawings during maintenance activities will be conducted as follow up to recently issued violation 90-12-02 related to this same area.
Item 90-200-08 (Closed)
The SSFI found, during a walkdown of the ECT system, that valve 0-4811211 A, ESW to ECT vent valve, was in the open position, it was required to be closed by the system check off list (COL) and the system drawing. The licensee immediately placed the valve in the corrective position and initiated an event investigation report (EIR) to determine the cause and duration of the condition.
'
The licensee's ElR indicated that "the exact root cause of the event cannot positively be determined, it is believed that this valve mispositionir, occurred as a result of the inadequacy of SP 630-3." The procedure included a step to open the valve, but none to reclose it following completion of the test. The licensee's proposed corrective action is to revise procedure SP 630-3 to provide specine instructions for closing the valve.
SP 630-3,
- Integrated Test of the Unit 3 Emergency Cooling Water System," was in the licensee's commitment tracking program to be revi:ed by December 1,1990, to reDect the changes.
The licensee committed that the procedure will be revised prior to its next implementation Item 90-200-09 (Open)
The SSFI team observed several deficiencies regarding the lack of human factors considerrions in the Station Blackout procedure, and four specine deficiencies. The licensee stated that they would perform a human factors review of the procedure. Corrective actions for the four specific
deficiencies were also implemented.. Procedure SE-Il " Station Blackout" Revision 5 was PORC approved on September 13,1990. The revised procedure incorporated the changes recommended by the human factors review. The four specific denciencies and the licensee's corrective actions i
are discussed below, o
The licensee had not prestaged tools, meters, door blocks and other materials needed to expedite conduct of required activities.
-;
. - _ _ _ _ _ _ _ _ _ _ _
.
>
' ',
]
c.
..
i The licensee subsequently prestaged the necessary tools and equipment for performance of the actions outside the control room. The team inspected the prestage station and found that all tools and equipment were available. The inspector questioned if routine surveillance of the %1 inventory and functioning would be performed. The licensee
<
committed that the b6-il tools list would be included in routine surveillance test RT 19.7 t
before the next scheduled performance (the RT is performed semi annually).
o The employee simulating performance of the procedure was unfamiliar with the specine actions required to adjust the control system for the HPCI turbine, k
The licensee committed to determine the appropriate individual to perform the actions and to provide training.
Licensee operations management determined that non licensed operators will perform the actions required by SE-ll outside the main control room.
- Operations training committed to train the non licensed operators on the new revision of SE Il along with the use of prestaged tools during the training cycle starting October 9, 1990.
o The licensee will evaluate if two individuals are needed to operatt 'iPCI under blackout conditions.
t
'
The SSFI team was concerned that one individual could not perform the actions involved.
The task included adjusting a null voltage potentiometer in close proximity to an operating turbine while observing a portable voltage meter attached to a panel some distance away. The licensee indicated that one individual could perform this action if longer test leads were used. The revised SE ll, Appendix 4, indicated that 20 foot test leads were provided in the tool package for this action. The team is satisfied with this resolution.
L o
No cautions were present in the procedure concerning the potential for excessive radiation
exposure.
The newly revised SE-11 has a note in Appendix 4 which reads " stay time for th_e y
following tasks should be limited due to ALARA because of the physical proximity to the L
HPCI Turbine Steam Chest." This note satisfactorily addressed the SSF1 team's concern.
This item remains open pending the licensee revision of RT 19.7 and completion of the training
-
of non licensed operators on implementation of SE-11.
,
Item 00-200-10 (Closed)
The SSFI identined denciencies in Operating Procedure SO 48,1.B, " Emergency Cooling Water
>
,. System Startup," associated wita startup and operation of the ECW system, and the maintenance of adequate cooling Dow to equipment coolers. The review of the licensee's corrective actions and the team's conclusions are summarized in Section 7.5 above.
.
--
,-
..
..
Item 90 200-11 (Open)
The SSFI team identified that appropriate cautions against overheating during ESW pump operation against a closed discharge valve were not included in test procedures.
The licensee indicated that testing procedures ST 6.3, "ESW Pump, Valve, and Flow Test," and ST 13.21.1, *ESW Pump, ECT Fans, E6W Booster Pumps Test," will be revised to include cautions prior to steps that run the ESW pumps at shutoff head (pump discharge valves closed).
The revisions to both STs were not cc.upleted at the time of the follow up inspection, therefore, this item remains open pending MkC review of the revised surveillance test procedures.
Item 90 200-12 (Closed)
The SSFI team found that surveillance test procedures lacked the necessary detail in some cases to verify that safety related equipment and systems could accomplish their intended functions.
The licensee stated that a surveillance test procedure rewrite program with a schedule completion daic was in place to evaluate and revise surveillance procedures. The team also expressed several specific procedure adequacy concerns The ST rewrite program involves 100% of the procedures and has a completion date of September,1992. There were about 1600 test procedures to be evaluated and rewritten and all procederes were assigned a priority number from 1 to 8. Currently, the licensee is working on priority 3 and 4. The licensee also indicated that, if a test procedure with a lower priority needed to be performed, a temporary change to the procedure would be initiated in accordance with Administrative Procedure A-3, " Temporary Changes to Procedures." The temporary change would incorporate all changes needed to enable the test to be properly performed. -
Following is a description of the licensee's actions to resolve the specific concerns raised by the SSFl:
o ST 13.21, "ECW Pump, ECT Fan, ESW Booster pump Operability IST," did not establish acceptance criteria for pump running current, shutoff discharge pressure and suction pressure.
l The lleensee stated that the running current, shutoff discharge pressure and suction l
pressure were recorded for trend analysis only and did not require acceptance ranges.
The discharge and suction pressures were also used to determine the pump differential
!
pressure
- (dp) and the ranges of acceptance for dp were given. The team considered this response acceptable.
o ST 13.21 established an improper flow h'ignment by including the RBCCW system in the flow path.
The licensee committed in its response that ST 13.21 would be rewritten by November 20,.1990 to have the RDCCW heat exchanger valved out. This date is before the next
.
,
.
._
_
.
l i
-
.
.
..
'
.
..
performance, j
o Procedures required use of electrical jumpers without specifying the type or size af the jumper to be used.
Tk i mtce indicated that banana test jacks were to be installed in the plant to simplify
the q < clectrical jumpers for testing. The installation will be completed by the end of tne Unit 3 refuel outage (December 1991).
Maintenance guideline MG-6.3 2,
<
" Installation of Banana Test Jacks," Revision 1, described the proper way to install the
,
Jacks. The team reviewed this approach and considered it acceptable.
'
o The HPCI low steam pressure flow test specified performance at a nominal pressure of 150 psig, although the TS make no allowance for nominal readings.
The licensee stated in its response that PBAPS would be converted to the improved Standard Technical Specification (ISTS) with appropriate ranges for HpCI high and low steam pressure flow tests, and the inclusion of allowance for nominal readings. The ISTS conversion is not scheduled to be completed in the near future. The licensee indicated that a PORC approved engineering evaluation verified that performing the test at 170 psig i
did not constitute an unreviewed safety question. This item is also discussed under issue
-
number 27.
,
Based on the surveillance test rewrite program and the specific commitments made by the licensee this item is resolved, liem 90 200-13 (Closed).-
,
..
The SSFI team identified problems with personnel use of and adherence to procedures. The team was concerned that the specific examples discussed below were indicative of a more extensive performance problem.
While observing ST 21.5 2, "ESW Flow Test Through Room Cooler and RHR Pump Seal Cooler," the inspectors observed the following weaknesses:
<
o The surveillance test crew performed test steps out of sequence. The licensee responded that there were several contributing factors. The procedure was not written to be performed in the most expeditious manner.
Familiarity with the procedure led to performance of the steps in a manner that was technically acceptable but out of sequence with the written test. The test was long, and personnel felt the need to provide test -
results in a relatively short time, o-The surveillance test working copy was not completed as the test was performed. The test personnel were familiar with the test and checking off the steps as required by the procedure was thought to be unnecessary. The test personnel realized that they should
.
..
-
-.
_.
. -..
.
_ _ _ - - _ _ _ _ _ _ - _ _ - _ _ _ _ _ - _ _ _ _ _
. _ _
_ - _ _ _
__________ _ _________- ______--_-_-___- _ _ __ _ _____
,
..
.-
l
)
have signed off the test as it was being performed, but they felt confident that the test
'
was technically correct as performed.
)
o The procedure independent verification requirements were not adequately implemented.
The licensee indicated that the person performing the test had a different dennitica. af
,
independent verification than the inspector. The test personnel believed that independent
,
verification by personnel involved in performance of the same activity in the same area was acceptable. The inspector believed that independent verification required a second individual not involved in the performance of the activity, independent verincation has been defined in other PBAPS documents and regulatory guidance in this manner. This issue will remain unresolved pending review of the licensee's program for implementation of independent veri 0 cation during maintenance and testing activities (UNR 90-80-02).
o The SSF1 team reviewed ST 6.7.4.2, " Core Spray Motoi Oil Cooler Heat Transfer Capability," and noted that the thrust bearing temperature at starting was not recorded.
The thrust bearing temperature at 0,70 and 80 minutes were also not recorded. The licensee responded that these omissions occurred because the test personnel did not adhere to test procedures.
.
o The SSFI team reviewed ST 6.6 P 2, " Core Spray A loop Pump, Valve, Flow and Cooler Test Unit 2," and noted that the recorder's initials block in paragraph 78A, Step 77, was not filled in. No independent verification of fluke removal as required by paragraph 79 was performed. The lleensee indicated that test personnel failed to adhere
,
,
!
to the procedure in these instances.
The licensee concluded that the procedure compliance concerns were indicative of a general feeling among some of the staff that it was acceptable to deviate from a procedure if the deviation did not directly contradict procedure guidance and did not affect the technical adequacy of the procedure or procedure results, The licensee committed to the following corrective actions l
to resolve these concerns:
I o
Establish and clearly communicate performance expectations for procedure use and compliance and independent verincation.
'
o Provide instruction on procedure use and compliance to supervisors and have supervisors provide on the job training during actual procedure use to demonstrate acceptable procedure compliance and clarify expectations.
o Solicit and address procedural compliance issues from group personnel to ensure the approach to procedural compliance remains consistent and is properly understood by l
group personnel.
l During the current inspection the team observed a sample of surveillance test performances. In all cases pertonnel performed the testing in accordance with the procedure. The team reviewed
-.
. -
. -.
_,
_..
.
',
..
.
..
the licensec's response and corrective action plan and found that although the corrective action
,
plans look acceptable, most actions have not been completed, in response to continuing problems with procedure use and adherence and personnel attention to detail the Plant Manager initiated a task force to evaluate the root cause and recommend additional corrective actions.
This effort has the support of the Peach Bottom Vice President. Monitoring of task force progress and ongoing assessment of its effectiveness will be performed by the Resident inspectors, hem 90 20014 (Open)
The SSFI team identified fasteners of the wrong sizes, types, torques, thread engagements, and of indeterminate materials installed in HPCI. The origin of some quality related piping and
- fasteners installed in the HPCI System could not be traced through the maintenance request form (MRF) package records. MRF packages contained neither direct delivery system documentation or the required quality conformance data tags.
The team reviewed the corrective actions implemented by the licensee. These actions appear appropriate. The team was unable to assess their effectiveness during this inspection, as discussed in Section 8.0 of this report. This item will remain open pending additional NRC revicW, Issue 15 The SSFI identified several instances where original calculations and analyses could not be located, were used as working copics or were never developed. This raised concerns about the lleensee's design control program. The team's review of this issue is addressed in Section 7.0 of this report.
Issue 16 The SSF1 team identified concern over the licensee's lack of a suitable testing program which would have identified the ESW flow problems. The technical resolution of this issue is addressed in Section 7.0 of this report.
Issue 17 The SSFI team identified the lack of design calculations for the two ECT modes of operation.
This issue is addressed in Section 7.0 of this report.
Issue 18 The SSF1 report identified instances where design calculations associated with the electrical l
equipment serving the ESW system were not checked, references were not provided and -
l assumptions were not stated or validated. The licensee informed the team that a program l
l
a
,
!
!
,,
,
'
..
scheduled for implementation over the next three years had been initiated to reconstitute all
protective relay calculations. Further, the specific items identified during the SSFI will be used as a pilot for standardir.ing the methodology for the reconstitution effort. The pilot review is
'
planned to be completed by the end of the fiut quarter of 1991. This action satisfactorily
'
addresses the SSFI concern.
Issue 19 i
- The SSFI re;nrt identified C.ie potential for a single fr.ilure condition that could prevent the
'
restart of an ESW pu@ iallowing an automatic or manual pump trip with the breaker anti pump circuitry locked in. The design of the ESW pump control logic did not allow reclosure of the pump breaker in the case where a trip signal (including a manual trip) had been generated following a low discharge pressure automatic pump start signal. This lock out is due to the
'
breaker anti pump circuitry.
No information was available to the control room operator i
cautioning that the condition existed and providing guidance on the steps needed for pump restart,
,
Th: licensee provided the team with revised alarm response cards (ARCS) which referenced
'Ab normal Operating Procedure AO 33.3, " Emergency Service Water Pump Breaker Manual Resit after lockout," Revision 0. The procedure provides the operator with guidance for resetting the enti pump circuitry locally to allow restart of the pump, The team reviewed the circaltry and determined that it satisfactorily met single failure criteria under the combination of a L OCA with a loss of offsite power, and that the procedure was adequate to assist the operator in restarting a locked-out ESW pump.
Information Notice (IN) 88 75 cited similar examples of locked out circuit breakers.. The licensee's initial review concluded that the problems identified in IN 88 75 did not apply to
Peach Bottom, although a number of circuits exist in safety related pump breakers with lock-out features similar to those identified in the IN. The team qustioned if detailed review of each affected breaker had been performed, in response to the tes'; concern the licensee performed' further reviews of the control logic of selected circuit bremis and determined that the breaker.
'
closing logics were not subject to lock out under conditiom similar to the ESW pumps as had been originally thought.
The team concluded that the ESW pump lock-out circuit concern was resolved with the institution of additional operating procedure guidance. However, implementation of a design change would more effectively address the issue.
Issue 20 The SSFI team, in response to concerns raised by the resident inspectors, identified that the L
i licensee had not adequately accounted for failure of the non safety related HPCI and RCIC system gland seal subsystem on equipment environmental qualification, e
-
i i
.
-
-.,
,,._,-,.s.,
..,,,,-
,
.
.., -.... - - -...
.. -..
,_ --
_
.___ _ ___ _ ___-_ ___
___.
_. _._
_
_
.._ _ -
_ __ _
_.._ _
._ _ -
_ - _ _._.__
!
.
...
r
..
i The licensee prepared a justification for interim operation (J10), it was determined by the J10 that all equipment required for safe shutdown and located in the HPC1/RCIC rooms were qualinable to operate up to 150 'F for a minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The team reviewed the JIO and found that the minimum quallned temperature for the equipment was 165 'F and minimum time qualified was 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The team found this evaluation acceptable and considered this item closed.
{
<
lasue 21 The SSFI report identined a concern that the lleensee had not consistently implemented the guidance contained in Regulatory Guide 1.47. Some recent modifications referenced this RG, while others did not. Specifically, the HPCI auxillary oil pump trouble alarm may not receive a timely operator response because it is combined with other non safety equipment trouble alarms.
The licensee provided documentation to the team stating that RG 1.47 was not a design requirement Peach Bottom and that a policy incorporating the requirements of the RG was not
- appropriate. This position was based on General Electric design document NEDO 10139,~which
- applied to the initial plant design and permitted alarms in conjunction with observation of on/off
'
status indicating lights and control switch positions to determine abnormal or failed equipment conditions.
The licensee stated that Design Basis Documents (DBDs) were being developed which would provide design engineers and other utility personnel with the applicable design commitments for
,
systems, components and equipment. Currently, a pilot program is in progress to develop 12
- DBDs with the goal of developing DBDs for each safety system.
)
The team reviewed the table of contents for the DBDs to assure that the applicable regulatory
guides and industry standards would be referenced. No plans exist, however, to develop a-
,
UFSAR revision that tabulates the degree of compliance with regulatory guides and industry
standards,' which the team considered to be a weakness.
Issue 22 -
- The SSF1 report identified concerns with EDG electrical loading tmder various post accident
. conditions. Plant modincations have resulted in a reduction of previously established design.
margins to the point where emergency bus loads would have to be reduced below 1400 Kw prior
!
to attempting a manual restart of a residual heat removal (RHR) pump. This load reduction is required to prevent bus voltages from dropping below the minimum required to maintain the
i remaining equipment in service. The applicable plant procedures did not include strong direction
!
^
to the operator to ensure that loads had been suf0ciently reduced, or provide guidance to' assist
>
in selecting loads for removal which would result in the needed reduction.
a
,
j..
ig a.
rse y
,,--#,..
.
,, -, - -_,
a
,,,,_
,
,,,,,
om
,...., _,,,
.,
,,m.,,.
... _ _..,,_,, _....,.,, _,, _., _., _ _
,__
_.
_.-_.__-_ _--.___
0,
..
,.
in response to the concern, the licensec committed to revise procedure SO 10.7. A 2, " Residual lleat Removal System LPCI Mode Manual Start,* to include specinc action steps, and to reference appropriate guidance on load reduction. Additionally, operator aids will be supplied to ensure proper selection of loads for removal when manually starting a RHR pump. This action satisfactorily addresses the SSFI concern.
Issue 23 The SSFl report identified concerns with the ability of the DC ground fault detection system to actuate in response to ecrtain faults.- This concern was primarily due to the inability of the licensee to recover supporting documentation. The licensee initiated corrective action to reconstitute the necessary calculations. This activity was underway at the time of this follow up inspection and is planned to be completed by October 31, 1990. This action satisfactorily addresses the SSFI concern.
Issue 24 The SSFI report identified several instances in the electrical protection systems where calculations were found to be deficient in terms of proper referencing, substantiation of assumption $.
methodology, checking / verification and control of documentation.
The licensee informed the team that in response to the deficient conditions a three year program was being initiahd to reconstitute all protective relay calculations. Further, the specific items identified during the SSFI will be used as a pi!ct program for standardizing the methodology for the reconstitution effort. This pilot project is planned to be completed by the end of the first quarter of 1991.
Issue 25 The SSFI report identified discrepancies between alarm response card information and the setpoints engraved on the control room and remote shutdown panel (RSP) annunciator windows.
Outdated ARCS were observed in a holder on the face of the Unit 2 RSP adjacent to the HPCI controls. Additionally, discrepancies were noted between drawings and check-off lists for the llPCI and ESW systems.
The lleensee took immediate corrective action during the initial inspection to remoa the outda!cd
. ARCS from the panel and established an action plan for investigation and resolution of the root cause of the deficiency. The Operations department conducted a walkdown of all alarm panels, comparing window information against procedures and prints. Discrepancies were documented and submitted for resolution under NCR P90362 and NCR P90564. Tne discrepancies were analyzed collectively and it war determined that no immediate safety concern existed. ARC revisions are currently being implemented. The documentation discrepancies noted for the drawings and valve lineups were minor in nature and are being corrected in accordance with the Unit 2 drawing walkdown and upgrade program.
-
--n-
- -_---,
n
,,,
e,,-
,n,
%
~m.
-
-
...
+
..
Issue 26 The SSF1 identined several denciencies with the operational performance of Special Procedure (SP) 630-2, " Integrated Test of the Unit 2 Emergency Cooling Water System." This issue is addressed in Section 7.0.
Issue 27 The SSFl report identified licensee weaknesses in the performance of surveillance test ST 10.1 3,
" Unit 3 HPCI Flow Rate at 150 psig Steam Pressure." The objective of this test is to satisfy the requirements of TS 4.5.C.l(3), which calls for the tening of the HPCI system flow rate at 150 psig steam pressure once per operating cycle. The last surveillance test was performed on November 26,1929, at a reactor pressure of 160 PSIG instead of 150 psig.
The licensee uses PORC Positions to provide management approved guidance to the operating staff on epolication of certain complex TS. NRC inspections have generally found this guidance i
to be appropriate and useful. The lleensee provided a copy of PORC Position No. 24, Revision 1, dated FebrurJy 14,1990, which concluded that the subject HPCI test method was acceptable.
The licensee altered the TS test point of 150 psig, to a allow a range of values,150 psig to 170 psig, usmg the PORC Position. The need for this relaxation stems from main turbine electro-hydraulic control system performance limitations which make operation of HPCI at this steam pressure dif0 cult. The team agreed that the previous test conducted at 160 psig was technically adequate, and that no safety concer: existed. However, the team was concerned that in this case the licensee used a PORC Position to alter a specine numerical limit in the TS. The team concluded that the licensee needs to evaluate a revision to the TS if the specified testing is not practical.
Issue 28 The SSFI report identified a weakness in the licensce's methodology used by maintenance for I
root cause analysis of equipment failures. Review of this area was not within the scope of this team inspection. Discussion of this area was included in the recently issued Peach Bottom SALP Report, and it will receive inspection follow-up in the future, hnte.22 The SSFl identified a weakness in the licensee's issuance, control and disposition of equipment trouble tags (ETTs). The licensee's procedures require placement of an ETF when a deficient material condition is identined in the plant. Processing of the ETF results in generation of an NCR or MRF to resolve the defect. Following completion of the work, licensee procedures require removal of the ETr. Instances were identified where ETrs remained in place on equipment after maintenance had corrected the dc0ciency, tags were placed on equipment but the licensee did not initiate a MRF or NCR, and the ability to track ETF status to ensure corrective action was implemented could not be demonstrated.
l I
____ ___
- _ _ _ _ _ _.
.
...
.
..
The licensee provided the SSF1 follow up team a response package which contained a draft of an Administrative Guideline AG 26.1, " Equipment Trouble Tag (ETT) Initiation and Processing." There was no documentation supporting a root cause analysis or identifying corrective action planned or taken. The team reviewed Administrative Procedure A 26, Revision 27, " Corrective and Preventive Maintenance Using Champs," which is currently used, and was in use during the SSFI, to establish requirements for the initiation and processing of ETrs. The guidance contained in the revised AG 26.1 mirrored the already established procedural requirements in A 26.
The team concluded that the procedures were clear, but that implementation had not been adequate. A sample of seventeen ETTs in place in the plant was selected by the team to determine the extent of the weakness. Of the seventeen only four had associated active hiRFs.
No htRFs could be identified for three and the h1RFs associated with the remaining ten had been either completed or canceled. Failure to initiate a hiRF after placement of an ETT, or failure to remove the ETT following compiction or cancellation of the hiRF has the potential to mask material deficiencies in the plant. Licensee personnel would not be likely to initiate a hiRF for a problem if the presence of an ETF implies that one has already been initiated. Additionally, operators may have less confidence in equipment performance if a substantial number of ETrs are present. The licensee agreed to evaluate the weakness and to implement corrective action.
This item will remain unresolved pending completion of the licensce's review and evaluation by the NRC (UNR 90-80-02).
Issue 30
"
The SSFI identified specific areas where housekeeping needed to be improved and where
'
unrestrained maintenance trolleys were stored in the area of safety related equipment.
The licensee completed immediate corrective action for the items identified. Further, the licensee revised Administrative Guideline AG 26.5, " Defects Found and Work Performed," to provide additional guidance to prevent recurrence. The specific steps delineated in the guideline are adequate. However, the institution of a guideline does not ensure corrective action in that adherence to the guideline is not required, as a procedure requirement would be. Housekeeping at Peach Bottom has been noted as a strength during past inspections, and remains good. Basef on this the team considered this action adequate.
Issue 31 The SSFI report identified that the ECT/ECW system DBD was not being developed concurrently with the ESW system DBD. The licensee provided the team with documentation I
which authorized and required completion of the identified DBDs by hiarch 31,1991, which was
!
satisfactory for closure of this item.
l l
l l
-
- _.
. -
=__
- - -
-
.
'.
.,
,
.*
.
10.0 CONCLUSION The team conducted an exit interview on October 3,1990, to brief licensee management regarding the inspection findings, it appears that the licensee has implemented an effectise program of corrective action in response to the SSFI, This program includes short term and long term r asures to prevent recurrence of the violations identified, and has received substantial management attention. Perhaps the most noteworthy effort is the licensee's self initiated program of internal SSFis. This effort, in conjunction with the developing DBD program, should help to identify anu eddress similar design, maintenance and test issues. Several areas requiring
'
additional NRC and licensee follow up were identified and are noted as unresolved items in the report.
.
.. _ _ -
..,,... -.
,. -... -
e.
.,
e
,
APPENDIX A
DOCUMENTS REVIEWED
Following is a list of the significant procedures, specifications, calculations and other
documentation reviewed by the team during the inspection. Additional support information was
also included in the review but has not been included in the listing.
Procedutts
NEDP 3.11
Procedure for Processing Engineering Work Requerts, Revision i
NA 03N001 Control of Nonconformances, Revision 1
NQA-16
Open items, Revision 1
NQA-25
Corrective Action, Revision 2
NA-02R001
Identification and Evaluation of Potentially Reportable items and Events of
j
Potential Public Interest, Revision 0
i
NA 02A002 Investigation of in house Events, Revision 0
SO 48.1.B
Emergency Cooling Water System Startup, Revision 6
SP 1353
ESW Ikmster Pump Discharge Valve Throttling Limit Determination, Revision
with TCs 90-0364, 90-0369, 90-0375, 90-0377, 90-0378, 90-0381
A 8:C
Locked Valve List Common, Revision i1
AG 12
PORC Administration, Revision 3
NEDP 3.3
Procedure for Performance of 10CFR50.59 Reviews, Applicatloas for
Amendment to Facility Operating Licenses, Changes to the PBAPS and LGS
UFSARs, and Completion of the Fire Protection Review Checklist, Revision 18
NA-02C001
Commitment Tracking Program, Revision 1
i
NA-02R002
10CFR50.59 Reviews, Revision 0
AG 66
Use of Form for Documenting 10 CFR 50.59 Reviews, Revision 0
ST 21.5.1
Dual Unit ESW Test of ESW to ECCS Ring Headers and Diesel Generator
Coolers
ST 21.5 2
ESW Flow Test Through ECCS Room Coolers and RHR Pump-Seal Coolers -
!
Unit 2
i
..
,
o
.,
I
.. *
v.
ST 21.5 3
ESW Flow Test Through ECCS Room Coolers and RHR Pump-Scal Coolers -
Unit 3
i
Safety Evaluations
Safety Evaluation for EWR P-51246
Safety Evaluation for SP 1355, diesel Oil Transfer Pump Performance Test
Safety Evaluation for ElR 3-90-032
Safety Evaluation for MOD 1542, Revision 1 - Drywell Cooler Fan logic
Licensee Audit Reports
Peach Bottom APS, NQA Audit PA 89-06, Audit of Conti.,i of Hardware Nonconformance
(NQA-24), April 18,1989
NCR Quality Review Task Force Report, June 1,1990
Icmocrary Plant Alterations
TPA 40-02 to Install Blanks on Rx Building Vent Supply to A and C RHR Rooms
TPA 62 3 to Remove digit display and clear rod drift
hiodifications
MOD #1419, Replacement of Safety Related Rosemount hiodel 1151 Electronic Transmitters
MOD 1498, Replacement of Testable Check Valves AO 18, AO-22 and AO 13A&B
hiOD 1891, Replace Drywell Spray, Suppression Chamber Spray, RCIC, HPCI, etc. Flow
!
Transmitters for RG 1.97
MOD 5011, Remose the RSCS and Lower RWM Low Power Setpoint
Correspondence and Other Documents
Memo, Gallagher to Pyrih, NCR Quality Workshop, July 31,1990
Memo, NCR Quality Task force to Pyrih, June 8,1990
Memo, Baker to Coyle, NCR NGAP Revision, LQDM 90-0234, August 31,1990
. _ _ _ _ _
_ _ -
To
g
..
..
.
Memo, NCR Quality Tad Force to Pyrih, September 18, 1990
Technical Specification Change Request 89-20
Memo, ST 21.5 2 Flow Out Tests,
- J. S. Ilumphries to William Jefferson, September 24,1990
.
Memo, ESW Room Cooler Failures During ST 1.5-2 (3),
September 28,1990
)
letter, Peach Bottom ESW/liPCI SSFl issues and corrective actions, ii.D. Honap to
]
distribution, August 06,1990
'
Study, ESW Piping (metallurgical laboratory note number 84 822), R. S. Fleischmann to
- E.C.
KistnerProperty "Contact" (as page type) with input value "E.C.</br></br>Kistner" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., October 04,1984
letter, NRC follow up inspection to SSFI performed on PBAPS ESW and liPCI systeras,
- J.G.
11ufnagel Jr. to J. A. IhsilloProperty "Contact" (as page type) with input value "J.G.</br></br>11ufnagel Jr. to J. A. Ihsillo" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., September 17, 1990
Calculations
.
Determine ESW Booster Pump Suction Pressure, Revision 0
ME-087
Verify the Stress in Conduit and Conduit Supports are within Allowable Limits,
Revision 0
EE Oll
LOCA/MSLB Temperature Effects on Drywell 111 Rad Monitors RE-
0103A,B,C,D and RE 9187A,B,C,D, Revision 0
EE-018
- Calculate Setpoint for level Switches LS-2898, 3898, Revision 0
ME-094
Verify Stress in conduit and Supports are within Allowable Limits Zone 78B,
Revision 2
EE-036
Calculate the Adequacy of the 200HP Diesel Generator Rating Using Motor Break
HP and Review KW Load Values in FSAR vs Current Plant Documentation,-
Revision 0
MB-084
Verify Stress in Conduit and Supports are within allowable Limits - 7one 78B,
Revision 1
ME-082
Verify Stress in conduit and Supports are within Allowable Limits - Zone 788,
Revision 2
MB-090
Verify Stresses in conduit and Supports are within Allowable Limits, Revision 2
l
l
'
.
-_..
- 1,
V'
,
.g
u
a.,
c-
o
ME-227
Design lead Shielding for Radwaste Resin H2O Drain Line
EE-033
Analysis of DC MOVs Voltage Adequacy for PBAPS Unit 2 - Response to NRC
Abdit Question Item #189 87-1 of Revision 2 -Including I'ait 3, Revision 3
670803
HPCI Pump Room Heatup Analysis
-2.2-001
670803
RCIC Pump Room Heatup Analysis
-2.2-002
Safety Evaluations
10CFR50.59 for Mod 5095, Emergency Cooling Water System Upgrade, Revision 7
10CFR50.59 Review for the Temporary Isolation of the Standby ECCS and RCIC Unit Coolers
CFR 50.59 Review for Throttling of ESW Flow to the Emergency Dies 01 Generators,
Revision 2
CFR 50.59 Review for Opening of Cross-Tie Valves 0-33-512 A & B on the Common Cross-
Tie Line Between Discharges of ESW Pumps OAP-57 and OBP-57, Revision 0
Training Documents
EAT-0001
Engineering Assurance and Training Branch Lesson Plan, Revision 0 (expanded
,
~
training regarding 10CFR50.59 reviews).
NEDP 2.1
Procedure for Training of Nuclear Engineering Department Personnel
NGAP-0010 Lesson Plan - rwuc! ear Training; 10CFR50.59 Reviews, Revision i
Tech Staff and Management Training,10CFR50.59 Reviews, Revision 0
Nuclear Quality Assurance - Independent Safety Engineering Group - Guideline
for Review of 10CFR50.59 Safety Evaluations, Revision 3
P50097
' Reactor Pressure Vessel Thermal Cycles
P50371
Wide Rar ge Reactor Water Level Loop Setpoint Calculations
P50397
ECT Pump Bolting Materiai
_
'o
.. g
.,
w
w
P50621
Tempomry Scaled Penetrations
P50656
hter.
Noding Blockouts Filled
P50704
Flood, Air Pressure and Radiation Seals for Conduits
P50821
Analysis of Failure of a GE CR120A Relay
P50837
Deletion of SCRAM Solenoid Pilot Valves From the EQ Program
P50860
MCC Walkdown Results
P51111
Safety Evaluation Review for Partially Installed Modifications
P51292
HELB Inside Containment - NRC IN 89-55
P51416
Inadequate Scaling of ECCS Rooms
P51527
Locked Valves
P51571
Internal Flood Setls
P90118
Relocation of an instrument tap
P90451
Upgrading pressure control valves on containment purge and vent valve backup
nitrogen supply
P90407
Replacement of check valve #62
P89784-312 Damaged feedwater piping supports
P90085
Inconsistencies between installed fuses and design drawings
,
a
P90443
Upgrading of DG cables
'
'P90437
Upgrading of DG cables
P90438
Upgrading of DG cables
,
l
l
P90538
Drawing change to indicate closed valve to match plant procedures
l
l
P90232
Throttling of ESW flow to the EDGs
,
c..
e,
.
..-
as
~.
$
O
190369.
Discrepancies between design documents on fuse sizes
P90433
Downgrading of valves and cables
19C275
Repair leak on ESW piping
P90171
Repair leak on ESW piping
P89908
Move space heaters
P900ll
Jet compressor steam flow low switch setpoint
P89839
Upgrade of spring pipe support
,
P90375
Testing and justification of fuses
,
P89982
Cracked HFA relays
P89781-533 Conduit seals on Rosemount transmitters
P89800 312
Repair pump hold-down bolt
P89961'
Er.ceeding pipe expansion program limits
P90463
Repair RBCCW room seals
P90510
Revise UFSAR radiation zones
P90048
Fusing of loads
P89947.
Equipment required following a MSLB
P90015
Revision to Q-list for HPCI
f-
P90376
DG crankcase drain line
190175
Blocked reactor core delta P transmitter
P89916
Seal hatch covers effect on Rx building ventilation system
P90158
LPCI manual pushbuttons effect on DG operability
l
P90034
Periodic maintenance of stored motois
- o., _%
.
..
CAlis
PS8912-01
Reservoir orientation on hydraulie snubbers
PC89049411 Processing of potentially repcrtable items
PA89 37-01 Absence of required limits in diesel oil transfer pump functional test
PA89 34-07 Elimination of diverse design feat.res in pressure sensors
,
!
PC89-040412 Use of teflon tape without a rework MRF
!
SFIP89-001
Battery /Switchgear Room Ventilation Damper Maintenanceav Alarm Procedures
SFIP89 009 Calibration and Trip Testing of Battery Charger AC Input Breakers
l.
,
3