IR 05000277/1992009
| ML20198D425 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/13/1992 |
| From: | Lyash J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198D401 | List: |
| References | |
| 50-277-92-09, 50-277-92-9, 50-278-92-09, 50-278-92-9, NUDOCS 9205210030 | |
| Download: ML20198D425 (17) | |
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U. S. NUCLEAR REGULATORY COh1 MISSION
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REGION 1 ;
Docket / Report N /92-09 License Nos. DPR-44 50-278/92-09 DPR-56 Licensee: _ Philadelphia Electric Company !
Peach Bottom Atomic Power Station P. O. Box 195 '
Wayne, PA 19087-0195 Facility Name: Peach Bottom Atomic Power Station Units 2 and 3 .
Dates: March 31 - May 4,1992 ;
inspectors: J. J. Lyash, Senior Resident inspector
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L. E. Myers, Resident Inspector M. G. Evans. Resident inspector R. J. Paolino, Lead Reactor inspector D. ht Skay, Technical Intern Approved By: eb [Iq/PZ
'Date Jfj7Lygsti, Acting Chief ;
- Reactor Projects Section 2B
, Division of Reactor Projects
. Areas Inspected:
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The inspection included routme, on-site regular, backshift and deep backshift review of accessi-
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ble portions of Units 2 and 3. The inspectors reviewed operational safety, radiation protection, .
physical security, control room activities, licensee events, surveilkmcc testing, engineering and
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technical support activities, and maintenanc .
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9205210030 920514 PDR ADOCK 05000277- '
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SUMMARY Peach Bottom Atomic Power Station I
Inspection Report 92-09 Plant Operations During the report period a condensate header vent line weld failed, causing a signincant leak l'
and prompting a rapid plant shutdown. The ir.spectors observed the control room and in-plant response. The reactor operators and shift supervision handled the fast power reduction and i scram in an excellent manner (Section 2.1).
The licensee developed procedure GP-23, * Diesel Generator Outages," to establish the adminis-trative controls for removing an emergency ciesel generator (EDG) from service and for assessing the impact when an EDO is found to be ineperable. The inspector found the procc-dute to be clear, to provide good direction to the operators, and to be a good method of ensuring safety system reliability (Section 7.0). '
The inspector found the li ensee's Shift Manager Course to be quite comprehensive and a very good tool to communicate management's expectations to the new Shift Managers (Section 1.0).
Radiological Protection Licensee Health Physics personnel quicby and effectively responded to contain the spill follow-ing the Unit 2 shutdown on April 7. In addition, the licensee adequately investigated and resolved a potential unmonitored release associated with the spill (Section 2.0).
i The inspector concluded that the licensee had taken reasonable action to evaluate an anomalous reading on a personnel thermoluminescent dosimeter badge (Section 5.0).
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d Assurance of Ouality q Several weaknesses have continued to exist in the&ensee's implementation of the clearance and tagging process. ~ Previous licensee root cause analyses and corrective actions have not been effective in resolving the weaknesses. However, the inspector found that the licensee has recently taken extensive action to evaluate the problems, and to actively pursue more aggressive corrective actions (Section 7.0).
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The licensee continues to monitor the performance of safety-related solenoid operated valves (SOV) closely. They have taken conservative actions in response to two recent SOV failures on emergency service water room cooler air cperated valves (Section 7.0).
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DETAILS PLANT OPERATIONS REVIEW (71707)*
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The inspector completed NRC Inspection Procedure 71707, " Operational Safety Verification,"
by directly ou wing safety significant activities and equipment, touring the facility, and
interviewing and discussing items with licensec personnel. The inspector independently verified safety system status and Technical Specification (TS) Limiting Conditions for Operation (LCO),
reviewed corrective actions, and examined facility records and logs. The inspectors performed .
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of deep backshift and weekend tours of the facilit On April 3,1992, the inspector toured the Unit 2 drywell before close-out following the March 27 unplanned shutdown. The shutdown was due to problems with the reactor vessel level instrumentation served by the 2B condensing chamber and reference leg (Inspection Report (IR)
92-07). The inspector c.bserved the radiological protection measures in place to control access and work in the drywell. These measures included the radiation work permit (RWP), health physics (HP) pre-briefings and instructions, radiological postings, access control provisions and surveys. During the tour, the inspector checked equipment physical condition, housekeeping, and valve and instrument alignments. The activities inspected were acceptabl Early in 1992, the licensee promoted two Shift Supervisors to Shift Manager. During this inspection period, the inspector evaluated portions of the licensee's training and indoctrination program for new Shift Managers to determine if it adequately addressed relevant management issues. The inspector reviewed the " Shift Manager Course Session Learning Guides," Revision ;
0, dated December 1991. Topics of the " Sessions" included cautious decision-making, resolving competing priorities, operatir.g philosophy, procedure adherence, applying design bases, and post-maintenance and post-modification testing. Each candidate was required to prepare for the learning " Session" by viewing videa tapes, reading documents and event descriptions, answering questions about study materials and completing assigned activities, such as interviews or additional research. _ Following preparation, each candidate met with a mentor to conduct the various " Sessions." The mentors included the Vice President-Peach Bottom, the Plant Manager, tne Superintendents for Operations, Technical and Maintenance, and Shift Manager incumbent The inspector reviewed the training materials, discussed them with the Shift Managers, and found the course to be quite comprehensive and a very good tool to communicate management's i expectations to the new Shift Manager .0 FOLLOW-UP OF PLANT EVENTS (93702,71707)
During the report period, the inspector evaluated licensee staff and management response to i plant events to verify that the licensee had identified the root causes, implemented appropriate corrective actions, and made the required notification *
The inspection procedure from NRC Manual Chapter 2515 that the inspectors um! as guidance a parenthetically listed for each report section.
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On April 7,1992 the licensee began an orderly Unit 2 shutdown f am about 100% power. The [
shutdown was required because a one inch vent line failed at a welded connection on the condensate supply header to the offgas recombiner condenser. The operators began a fast power reduction per procedure GP-9-2, " Fast Reactor Power Reduction," and placed the mode switch to shutdown at 43% power. A reactor scram and prirary containment isolation system (PCIS)
group 11 and 111 isolations occurTed. The licensee notified the NRC of the reactor scram and the resultant emergency safeguards feature (ESP) actuations via the Emergency Notification Syste Shortly after the shutdown, licensee personnel isolated the leak. The failure of the one inch vent line occurred on the 116 elevation of the turbine building above the hot tool room and resulted in contamination of a large area of this elevation. Licensee HP personnel quickly and effective-ly posted and controlled access to the affected areas. IIP visonnel i noted that water appeared to have reached a drain that discharged via an unmonitored release path, and took action to prevent any additional water from entering the drain. The licensee conducted an investigation and concluded that an unmonitored release had not occurre The licensee repaired the vent line and returned the unit to criticality on April 8. After bringing the turbine generator on line, the licensee discovered problems with the offgas recombiner system and the unit was taken off line. Following troubleshooting and adjustments to the glycol chiller system, the licensee returned the unit to service on April 1 The resident inspectors observed the fast power reduction and reactor scram in the control roo The reactor operators and shift supervision handled the evolution in an excellent manner. The Shift Supervisor effectively msnitored plant conditions using the appropriate off nonnal and transient response procedures. The inspectors observed implementation of radiological controls in the area of the leak during the event. The inspectors followed licensee activities involving repair of the vent line, investigation of a possible unmonitored release, and cleanup of the contaminated areas and reviewed Check Off List (COL) GP-18, " Scram Review Procedure.*
The inspectors determined that the licensee's follow-up to this event was appropriate and had no further question .0 SURVEILLANCE TESTING OBSERVATIONS (61726,71707)
The inspector observed conduct of surveillance tests to verify that approved procedures were being used, test instrumentation was calibrated, qualified personnel were performing the tests, and test acceptance criteria were met. The inspector verified that the surveillance tests had been properly scheduled and approved by shift supervision prior to performance, control room operators were knowledgeable about testing in progress, and redundant systems or components were available for service as required. The inspector routinely verified adequate performance of daily surveillance tests including instrument channel checks and jet pump and ccmtrol rod operability. The activities inspected were acceptaNe
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3 MAINTENANCE ACTIVITY OBSERVATIONS (62703)
The inspector observed portions of ongoin) .aintenance work to verily proper implementation of maintenance procedures and controls. 1% inspector verified proper implementation of administrative contro!s including blocking permits, fire watches, and ignition source and radiological controls. The inspector reviewed maintenarne procedures, action requests (AR),
work orders (WO), item handling reports, RWPs, material certifications, and receipt inspection During observation of maintenance work, the inspector verified appropriate QA/QC invol-vement, plant conditions, TS LCOs, equipment alignn.cnt and tumover, post maintenance testing and reportability review. The activities inspected were acceptabl .0 RAD'OLOGICAL CONTROLS (71707)
The inspector examined work in progress in both units to verify proper implementation of flP procedures and controls. The inspector momtored ALARA implementation, dosimetry and badging, protective clothing use, radiation surveys, radiation protection instrument use, and ,
handling of potentially contaminated equipment and materials. In addition, the inspector verified compliance rith RWP requirements. The inspector reviewed RWP hne entries and verified that persont r! ' ad provided the required information. The inspector observed personnel working in the RW1 areas to be meeting the applicable requirements and individuals frisking in accordance with HP procedures. During routine tours of the units, the inspector veri 0ed a sampling of high radiation area doors to be locked as required. The activities inspected were acceptabl In July 1990, the licensee processed the personnel thermoluminescent dosimeter (TLD) badges for June 1990 and identi6cd an anomalous reading on one badge. The badte showed a beta skin dose of 2,784 millirem and a whole body dose of 38 millirem. The enosure of the TLD indicated virtually a pure beta source. The licensee investigated the exposure and concluded that the badge had been intentionally exposed to a 2 millicurie strontium / yttrium (SR/Y-90) instru-ment check source, and that the individual involved had not received the spesure. At that time, the inspector reviewed the licensee's evaluation of the exposure and concicded that it was adequate OR 90-25, Section 5.2).
The incident raised poter:tial concerns about the effectiveness of TLD badge, security badge and source controls. Later, NRC specialist inspectors performed evaluations of these program areas and concluded that the licensee had implemented adequate controls for personns TLDs (IR 91-07) and check sources OR 90-07). In addition, NRC specialist inspectors evaluated the licen-see's protected area access and security badge controls as part of the routine NRC security inspection program, as documented in IR 91-10 and IR 91-19. No concems were identified during these inspections. During the current period, the inspector reviewed the licensee's follow-up reports on the incident to determine if an adequate investigate had been complete The inspector also discussed the incident and associated documents with the licensee Support Superintendent and the responsible corporate security investigator. The inspector concluded that
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the licensee had taken reasonable actions to evaluate the incident. No additional inspector follow-up is planne .0 PHYSICAL SECURITY (71707)
The inspector monitored security activities f ' compliance with the accepted Security Plan and associated implementing procedures. The inspector observed security staffing, operation of the Centra' and Secondary Access Systems, and licensee checks of vehicles, detection and assess-ment aids, and vital area access to verify proper control. On each shift, the inspector observed protected area access contrcl and badging procedures. In addition, the inspector routinely inspected protected and vital area barriers, compensatory measures, and escort procedures. The inspector and no signi6 cant observation .0 PREVIOUS INSPECTION ITEM UPDATE (92702,92701)
(Closed) Unresolved Item 89-23-001, Licensee to Create an Unoer Tier _ Document That De-scribes and Controls the Environmestal Oualification Praes The licensee has written procedure A-C-52, "The Equipment Qualification Program," to
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. describe and control the Environmental Qualification process. The procedure and attached exhibits have been extensively reviewed by licensee personnel and found to be technically ade-quate. However, the document, which the licensee originally committed to complete by Oc-tober 1991, has not been approved by the Plant Operations Review Committee (POkC). The licensee attributes the delay, in part, to an on-going dfort to reclassify procedures in accordance with the Nuclear Groups Procedural Document Master Plan. Because of the amount of detail contained in the procedure, the licensee has not decided which group should control the complet-ed document. The licensee has-indicated that the procedure's status will be resolved and the procedure is scheduled for final PORC review at the next monthly meeting. The inspector reviewed the procedure and found it to be adequate. Based on the above, this item is close (Closed) Unresolved Item 89-29-001, Lipc_nsee Used Unsupported Data in Calculation of Hieh
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Rance Radiation Monitor Accuracy.
l Calculation PE-135, dated March 27,1992, determines the error caused by Post LOCA insula-tion resistance degradation of instrument loop components associated with the Primary Contain-
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l ment Post-LOCA Radiation Monitoring System (PCPL-RMS). The PE-135 calculation quanti-l fies the insulation resistance degradation for the " worst case" PCPL-RMS loop per unit. The results of calculation PE-135 indicete that at a temperature of 235 degrees F, the cable's insulation resistance degradation, in conjunction with the logarithmic amplifiers offset voltage, yields a worst case leakage currentin the signal cable in the downscale direction. During Post-LOCA high temperature conditions, cable insulation resistance degradation allows leakage f currents to ground / shield, thereby introducing a bias error into the performance of the PCPL-
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RMS This bias error is significant at the lower range of the PCPL-RMS, but becomes less signi6 cant and eventually negligible towards the upper range of the PCPleRMS. The analysis in Calculation PE-135 further demonstrates that, during Post-Accident conditions, the PCPL-RMS satisnes the Regulatory Guide 1.97, Revision 2, accuracy recommendations for the range of radiation values during which the operator must take corrective or mitigating actions. Since the PCPL-RMS provides indication of gross radioactivity in the primary containment, to allow operators to assess plant conditions and initiate corrective action, plant personnel at Peach Bottom do not take any action based on the primary containment radiation levels until a nominal 400 R/hr is detected. For Peach Bottom Units 2 and 3, the range of indication for which the channel accuracy is not within the factor of two are 0.69 R to 1,63 R for Unit 2, and 1.78 R ta 3.75 R for Unit 3. The licensee has indicated this information will be made available to plant operators. This item is close (Closed) Violation 90-06-001, Operation witn the Emergency Service Water System in a Deraded Conditio During August 1989, the licensee operated Unit 2 at power for about 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> with the emer-gency service water (ESW) system inoperable. After completing ESW maintenance activities, the licensee did not open two ESW manual isolation valves from the 'B' ESW pump discharge to the Unit 2 emergency core cooling system (ECCS) room coolers. A flow path from the 'A'
ESW pump to the Unit 2 ECCS coolers remained available, but the emergency diesel generator (EDG) serving the '.A' ESW pump was inoperable. During a design basis accident, which includes a loss of off site power, the 'A' ESW pump ,,ould not have started and the Unit 2 ECCS room coolers would not have received adequate cooling water flow. While the licensee identified ad corrected the mispositioned valves, they did not recognize that the Technical
- Specification' s (TS) had been violated, or that the plant had been operated in an unanalyzed condition, until pointed out by the Resident inspectors. In fact, licensee training performed foUowing the incident included the position that it was an undesirable but acceptable con 0gura-tion. The NRC issued a Notice of Violation, Severity Level IH, and a Civil Penalty for the even The licensee acknowledge $ the violation, submitted a response dated August 15,1990, and paid the civil penalty. The NRC and the licensee identined several weaknesses that contributed to the event. These factors, along with a discussion of the licensce's corrective actions follo * The licensee inappropriately used " Tag-Off" (TO) as the component position during restoration and permit removal.- The TO provision allows operators to remove blocking tags without regard to the component position, and requires subsequent completion of a
- check-off list (COL) for the components. However, there _were weaknesses in the l process for ensuring completion of adequate equipment COLs following use of the TO ( option and none was performed. These problems contributed to the failure to properly l position the valves, and failure to detect it before returning the system to servic Similar problems contributed to a second incident in February 1990 involving the ESW
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sluice gates. The licensee's evaluation and corrective actions in this area are described in' detail under Unresolved Item 90-06-002 later in this repor * The COLs for the ESW system were inadequate in that they did not include all needed system components. The Unit 2 and 3 ESW loops are normally cross-tied to eliminate single failure vulnerabilities. Because Unit 2 was in an outage at the time, the licensee used the Unit 3 COL to return the ESW system to service. The Unit 3 COL did not contain the Unit 2 valves needed to establish the cross-tie, and this was not recognized
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by the licensee, After identifying the weakness, the licensee reviewed all common system COLs and did not idecify any other problems. The licensee revised the ESW COLs to include the valves ne<.ded to establish the cross-ties in both the Unit 2 and 3 COLs. The inspector reviewed the revised ESW COLs to verify that the appropriate valves had been added. In addition, the inspector reviewed the COL for the standby gas treatment systca, coramon to both units. The COLs were satisfactor * The improperly positioned valves went undetxted for several shifts. This showed signi6 cant weaknesses in the quality of Reactor Operator (RO) and Shift rechnical Advisor (STA) turnovers and panel walkdowns. The Operations Management Manual (OM), Section OM-6, " Shift Mechanics," addresses control room shift turNyer require-ments. The OM required the Unit RO and the Chief Operator (CO$ to walkdown the control room panels to verify valve, pump and handswitch positicas. To facilitate the walkdown process, and to document its completion, the licensee listed specific systems or panels on the RO and CO turnover checklists. However, the ESW system had been omitted from the checklists and the guidance contained in_ Section OM-6 on walkdown requirements was unclear. The licensee believes that the lack of clear guidance and the omission from the turnover checklists caused the delay in detecting the incorrectly positioned valves. The inspector reviewed the errrent _OM and verified that the licensee
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had clarified the guidance in Section OM-6, and revised Exhibit OM-6:2, " Chief Opera-l tor Shift Turnover Record," to include a speciSc sign-off for inspection of the FSW system. The inspector observed performance of the inspection by two COs, discussed the requirement with other COs, and veri 6ed that they understood its inten * The licensee did not understand the correct application of the TS with respect to emer-gency power source operability. This was evident in the licensce's conclusion that continued operation in this con 6guration was allowed by TS. The TS definition of operability includes the requirement that the emergency electrical power source for a D safety-related system be functional. Specification 3.0.D allows the licensee to consider the : cads supplied by an inoperable EDG as operable, provided that the redundant trains and their normal and emergency power sources are operable. This TS allows the
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licensee to enter only the EDG LCO, rather than multiple system LCOs. However, the licensee had not established procedures for evaluating TS 3.0.D compliance whe*1 making or finding an EDG inoperable, or adequate training for the operations staff on its proper implementation. As a result, the licensee did not recognize that operation with
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both the 'B' ESW pump and the EDG that supplies the 'A' ESW pump inoperable, a
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plant shutdown was require Following the event the licensee developed and issued General Procedure (GP123,
" Diesel Generator Outages." The procedure establishes the administrative controls for removing an EDG from service, and for assessing the impact of an EDG that is discov-ered to be inoperable. The procedure contains a series of appendices, one for each safety-related 4 KV bus, that identines the effected systems and their redundant train The control room staff verines that for each system or component listed, the redundant train or component is operable. If a redundant train or component is inoperable, GP-23 provides direction on the actions that must be taken. The inspector reviewed procedure GP-23, Revision 1, and performed a detailed assessment of the procedure technical adequacy and consistency with the TS for several systems. The procedure is clear and provides good direction to the operators. The mspector also reviewed the LCO log to identify times when an EDG was inoperable during the last year. For the dates identi-Red, the inspector verified that the licensee had completed GP-23 and properly evaluted any discrepancie The licensee completed operator training addressing the event, the proper interpretation of TS 3.0 D and application of G"-23. The inspector reviewed training materials and records for 1) Required Reading Assignment RE-90-19C; 2) Licensed Operator Requal-incation Training item 90-07D, " Industry Events: Technical Specification 3.0.D and GP-23;" and 3) Licensed Operator Training Item 1840, " Technical Specincation LCOs."
These materials adequately addressed the issues and the licensea completed them in a timely manner. The inspector discussed TS 3.0.D and procedure GP-23 with a sample of licensed operators. In all cases, the individuals were familiar with the TS and proce-dure. The inspector concluded that the licensee had taken effective action to resolve this proble * The licensee's investigation, root cause analysis and corrective actions following the incident were poor, and did not clearly resolve the weaknesses indicated. The Opera-tions Incident Investigation process in place at the time of the event exhibited severa performance weaknesses. The quality of the root cause analyses and specification of corrective actions was poor. Since that time, the licensee implemented the Reportability Evaluation / Event Investigation Form (RE/EIF) process, and extensive root cause analysis training for staff and management. These efforts significantly strenginened licensee performance in this area. While they have continued to make progress in enhancing their corrective action process, problems have continued to surface. In February 1992, the NRC issued Notice of Violation and Imposition of Civil Penalty NV3 91-33-02 due to corrective action program deHeiencies associated with poor follow-up to problems with automatic depressurization system equipment qualineations. Evaluation of the licensee's actions, and assessment of corrective aeSon program effectiveness will be completed during review of NV3 91-33-02.
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The inspector concluded that, with the exception of the issues related to the corrective action process, the licensee had adequately addressed the weaknesses identified in the violation and associated inspection report. Based on the above, this item is closed. The inspector will evaluate the effectiveness of ongoing licensee actions to strengthen the corrective action process in conjunction with NV3 91M3-0 (Closed) Unresolved item 90-06-002, Imoroper Restoration From Maintenance Aglivitie As described under violation 90-06-001 above, in August 1989 and February 1990 the ESW system became inoperable due to improper restoration from maintenance activities. The restoration errors were associated with the licensee's use of special condition tags (SCTs)
without c! car communications, improper use of TO, and failure to perform COLs to establish and verify the equipment's proper return to servic The licensee's conective action in response to these events incaided revisions to the Permit and
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Blocking Manual (PBM) in May 1990 to include direction on the appropriate use of TO and SCTs. In July 1991, the licensee implemented a new Clearance and Tagging Manual (CTM)
which replaced the PBM. - The inspector verified that the CTM provides improved direction about the use of SCTs and TO. However, the inspector noted that addiNnal . ents involving failure to perform the required COLs following the TO of a clearance have ocw ad as recently as October 1991. The inspector discussed this with the licensee who stated that an upward trend in the number of errors involving clearance and tagging had been identified. The licensee had initiated RF/EIF 2-94004 on January 13, 1992, to ensure that an analysis would be performed to determine the root causes and generic process problems associated with the clearance and tagging syste The licensee reviewed the clearance and tagging process from clearance request through remov-al, identified many process weaknesses, and completed the root cause analysis of the TO/ COL issue. The licensee found that if the Chief Operator elected to use the TO provision, there was no administrative mechanism in place to ensure performance of the required COL. As a short- ,
term corrective action following the October 1991 events, licensee management briefed opera--
tions shift supervision on the issues to make them aware of clearance restoration requirements ,
when using the TO option. The number of clearance errors since that time has been significant-lyles As a long-term corrective action the licensee has developed changes to the process for returning equipment to service following clearance removal. When tags are cleared as TO a copy of the clearance will be attached to the current system COL, and placed in a blue mylar folder in the system status file. Shift management is required to review the system configuration, including examination of the status file, before returning the system to service. The blue mylar folder will make the need to perform a new COL evident. The licenw has included a module on the clearance and tagging process in the ongoing licensed operator requalification training cycl The licensee is f' m alizing corrective actions in response to some of the other weaknesses identified during their review. The licensee has prepared revisions to the CTM and the Opera-
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tions Manual Section 10-(OM-10), " Equipment Control," to reflect the process changes, including the controls needed to ensure performance of the COLs. Licensee management stated that the revised procedures would be issued by June 1,199 The inspector reviewed numerous recent clearances and walked down applied and recently removed clearances and did not identify any concerns. In addition, the inspector attended a four hour licensed operator requalification training session. During the session the Shift Operations Manager discussed equipment control including the pending revision to the CTM, the Operations Manual, Administrative Procedures, and the requirements for use of TO and performance of COLs. The inspector concluded that the licensee had adequately corrected the concerns identi-fied in this unresolved item regarding the use of SCTs and TO through the process changes and training. The licensee has committed to revise the CTM and OM-10 to capture the applicable corrective actions. Since initiation of RE/EIF 2-92-004, the licensee has exter sively evaluated the clearance and tagging process and actively pursued corrective actions to improve the proces Based upon the licensee's actions, this item is considered close (Closed) Unresolved Item 90-10-001, Evaluate the Licensee's Corrective Actiom_in Resoonse to the Unexpected Loss of a Battery Charcer During Maintenanc On May 11,1990, instrument and controls technicians replacing a voltmeter on the '3B' battery charger caused a DC electrical system voltage transient. The transient caused the charger output fuse to blow, and battery voltages to drop below the operability limit of 123.5 volts (V). The operators did not immediately recognize that the voltage was below the operability limit because information in the TS basis and procedures conflicted. The licensee's Quality Assurance (QA)
organization had previously iden:ified this conflict and issued Corrective Action Request (CAR)
SFIP89-10. The licensee had closed the CAR based on actions planned to clarify the docu-i-
ments. However, the licensee did not complete these actions. The inconsistency resulted in an
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operational impact in that the operators did not take the appropriate actions. The concerns raised by the event requiring licensee management attention included 1) inadequate pre-job planning and job conduct; 2) conflicting minimum te.tery voltage operability limits; and 3)
premature closure of the CAR.
- During the current inspection period, the inspector reviewed the associated Licensee Event.
l- ' Report, procedure revisions, training materials and other licensee corrective actions. The inspector also discussed battery operability limitations with a sample of licensed operators to assess their level of understanding. After the event, the licensee reviewed all operating and surveillance procedures to ensure that they contained the correct voltage limit,123.5 V. The
- PORC approved and issued PORC Position _35 to establish clear battery and charger operability requirements, and to direct operator response to an inoperable battery. The licensee counseled l the maintenance planning personnel and craftsman involved in the event regarding the impor-I tance of proper job planning, and of self-checking during job performance, in addition, the licensee conducted a print reading training course for the maintenance planners (P213-40131) to help ensure better understanding of the types of drawings that should be reviewed and included in the work packages.
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The licensee reviewed the closure of CAR SFIP89-10, concluded that it had been closed prematurely, and reopened the CAR. The QA Manager issued a letter dated June 1,1990, to all QA personnel discussing the event, and stressing the need to evaluate the potential for t
operational impact and the need for near-term action when issuing or reviewing CARS. Later, the licensee revised Nuclear Quality Assurance Prccedure 25, " Corrective Action," to strengthen the process for operational impact screening, and to clarify CAR closure requirements with respect to the completion status of corrective actions. The actions implemented by the licensee adequately resolve this ite (Closed) Unresolved item 90-13-01, Licensee Interorelation anilmplementation of TS 3. Technical Specification 3.0.D applies to the relationship between emergency power supply availability and system operability. During inspection 90-13, the inspector was concerned that the licensee had not developed an adequate understanding of TS 3.0.D, and had not taken steps to ensure its proper implementation. Later, as discussed under Violation 90-06-001 above, the licensee developed procedure GP-23 to facilitate evaluation of an inoperable EDG and proper implementation of TS 3.0.D. The licensee completed operator training on the procedure and the TS. The inspector's review of these actions is described under item 90-06-001. In addition, the licensee is developing a complete revision of the TS for both units using the new Standard Technical Specifications. When this revision is complete, it will clarify the application of TS 3.0.D, and result in consistent LCO times. The inspector had no further questions. This item is close (Closed) Unresolved Item 91-04-001, Imoroner Implemen_lation of Administrative Procedures for Control of Combustibles in the Turbine Buildin The inspector observed several potential fire hazards in Unit 2 including untreated wood and packing material on the Unit 2 turbine floor; trash consisting of used plastic boots, gloves and rags in Unit 2 non-safety related cable trays; and scaffolding erected on the Unit 2 turbine noor that restricted access to the emergency fire fighting equipment storage cag The licensee determined that the above conditions were isolated and caused by inappropriate decisions. The licensee reviewed each area by room number and did not identify any safety-related equipment in the areas where the findings were noted. In addition, all affected areas were located in Unit 2 which was in a refueling outage. The licensee immediately corrected each discrepancy during the shift identified. The importance of housekeeping with respect to combustible material was discussed during the quarterly housekeeping meeting held March 12, 1991. To heighten the staff's awareness of the fire protection / prevention program, the i; ire Protection Supervisor emphasized the expectations and requirements concerning combustible controls and housekeeping at the June 12, 1991 Sepervisors Meeting. To maintain this height-ened awareness, fire protection / prevention wil' be a recurring topic at future Supervisors Meetings. Based on the licensee's actions, this item is close !
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(Closed) Unresolved Item 91-16-003, Mtquacy of Licensee Analysis of Heating Steam Piping in the Area of Safety-Related Eoulomen Engineering Work Request (EWR) A0003777 issued on December 12,1991 to address Informa-tion Notice (IN) 90-53, " Potential Failures of Auxiliary Steam Piping and the Possible Effects on the Operability of Vital Equipment," did not include engineering analysis of the effects of an auxiliary steam line break on safety-related systems. Instead, it presented Probabilistic Risk Assessment (PRA) calculations discounting the need to perform an analysis due to low probabil-ity of occurrence. In addition, following licensee discussions with other utilities, plant walkdo-wns, procedure reviews and references to the Electric Power Research Institute (EPRI) pipe rupture data base, the licensee concluded that the plant configuration, together with existing procedures, provided adequate assurance that Peach Dottom was not subject to the concerns described in IN 90-5 ter, a licensee Safety Systems Functional Investigation (SSFI) of the EDGs identified a concern that a failure of the auxiliary steam line piping in one or more of the EDG rooms would result in a heat load that could potentially cause Cardox System initiation and subsequent failure of one or more EDGs. This SSFI concern and the NRC concerns noted in IR 91-16 prompted '
the licensee to initiate EWR A0037153 to investigate the impact of an auxiliary steam line failure on safety-relateo systems. Additionallicensee action included a memo, dated September 4,1991, from the Nuclear Engineering Division (NED) Manager stating the philosophy to be used in determining whether use of PRA analysis is appropriate. The NED Manager stated that PRA is an important tool to indicate relative risk and to assess beyond design basis consider-
ations for Peach Bottom. When addressing issues impacting design basis considerations of equipment important to safety, a PRA analysis shall not replace technical analyses, but may be used in addition to a technical analysis to provide supporting justification.
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The EWR investigation included: 1) a review of reactor capability following an auxiliary steam line break using a screening methodology, and 2) scoping calculations of room temperature increases due to postulated pipe cracks in piping to unit heaters and ventilating systems. The screening process enables a complete review of plant effects from a heating system pipc crac The investigation takes credit for plant configuration and other previously documented aaalyses which envelope the requirements and environmental condition. Using an Appendix R safe shutdown screening analysis and room heat-up calculations, the licensee documented that for all postulated auxiliary sicam pipe cracks the plant would have at least two safe shutdown method In addition, because the licensee had taken credit for the plant heating system being shut-off during the portion of the year when outside temperatures are above 80 degrees, administrative controls for shutoff and restart of the auxiliary heating system were incorporated into System Operating Procedure S024.1. A, "Startup of Auxiliary Steam System," Revision 3. Based on the licensee's actions, this item is close (Closed) Violation 91-24-001, Licenseg_Eailure to Follow Procedures for the Modification Prrees v ~
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- During review of Unit 3 Modification No. 5275, " Replace HPCI Auxiliary O_il Pump Relays with Qualified Relays / the inspector found that the licensee had failed to resolve concerns and
- obtain the required sign-off on the Final Modification Turnover Form, prior to considering HPCI operable on January 23,1991. The Maintenance Request Form (MRF) and the Opera-tions Verification Fonn (OVF), which fotmd the testing and completion of the modification acceptable, were signed by Shift Management. However, the Final Modification Turnover Form was not signed by Shift Management. Tne inspector also found that a Troubleshooting Control Form was inappropriately used to identify actions that were taken to " verify the operability of HPCI with new undervoltage relays" instead of a Modification Acceptance Test (MAT).
The licensee found that Shift Management did not sign the Turnover Form due to misunder-standing of A-14, " Plant Modifications" and miscommunication with Operations Support personnel concerning a follow-up review. In the follow-up review, the licensec identified various programmatic concerns with the modification process. As a resalt of these concerns, the licensee issued five CARS on January 29, 1991 to evaluate the weaknesses and nonconfor-mances. Meetings were conducted between the System Engineer and Operations Support per-sonnel to discuss and clarify areas of concern associated with Modi 0 cation 5275. The licensee decided that a MAT would be performed to properly document acceptance testing. In addition, the Operations Manual Section OM-10, " Equipment Control," wus revised June 27,1991, to require completion of any repairs, modifications and special tests, prior to returning a system or equipment to service. The licensee also convened a Modification Process Mtegration Task Force
- in May 1991, to evaluate and assess the modification process.
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Full compliance consisting of re-assembly of the Unit 3 HPCI auxiliary oil pump, completion of the MAT, and Final Modification Turnover Form approval was achieved on December 21, 1991. Based on the above, this item is close (Update) Unresolved item 91-27-001, Evaluate Licer see Corrective Actions in Restionse to Several Solenoid Operated Valve Reliahility ProblemL
< Maintenance records indicated that normally energized Automatic Switch Company (ASCO)
Model 200-832 solenoid operated valves (SOVs) had a high failure rate (failure to change state when deenergized). The licensee evaluated the high SOV failure rate at Peach Bottom, and contacted other facilities to gather informrtion. They concluded that the failures were due to break down of the silicon lubricant used during fabrication, causmg adhesion between the plug nut and the core. The failures occurred in normally energized SOVs because heat generated by the coil acceleratco lubricant breakdown. The licensee initiated weekly exercise of the normally energized SOVs to prevent binding, until the SOVs could be replaced with a lube-less mode However, based on two recent failures of normally energized SOVs on the ESW room cooler air operated (AO) valves (2B residual heat removal rystem in March 1992 and 2D core spray in April 1992) which were being stroked on a weekly basis, the liensee has concluded that stroking of the valves is not adequate to prevent binding, but only to detect failures. Therefore, as an interim corrective action until new replacement tube-less SOVs can be manufactured and
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o 13 installed, the licensee has increased the frequency of stroking of the EDG cooler outlet valves
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from weekly to daily as of May.1,1992, In addition, the licensee will implement a Temporary Plant Alteration (TPA) to fail open the ESW room cooler AO valves. The licensee plans to install the TPA during the week of May 4, upon completion of the supporting Safety Evaluation ;
and procedure revisions. Due to the potential for failure of these valves, if any EDG, ECCS or reactor core isolation cooling (RCIC) LCOs are entered before installation of the TPA, then the licensee will consider the need to increase the frequency of the ESW room cooler stroking to ensure no unidentified SOV failures occur coincident with the LCO condition. The licensee
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expects to receive the replacement SOVs in about 12 to 14 weeks, at which time installation will be expedite The inspector discussed the licensee's actions with respect to the normally energized SOVs with licensee personnel. The inspector found that the licensee's approach was safe and conscwative and should increase the reliability of ESW to the EDGs, and the ECCS and RCIC room cooler The inspector will continue to monitor licensee efforts to resolve permanently this component reliability concern.
- (Closed) Unresolved item 91-30-002, Licensee's Use of Temnorary Changes to_Ch;Lnge_le11
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Acceptance Criteri In August 1991, the licensee changed the acceptance criteria in routine test RT- B-033-600-2.,
" Flow Test of ESW to ECCS Coolers and Diesel Generator Coolers," in a nonconservative manner by use of a Temporary Change (TC). Technical Specification (TS) 6.8.3.a states that temporary changes to procedures may be made provided the intent of the original procedure is not altered. The licensee implements this TS through Admiuistrative Procedure A-3, " Tempo-rary Changes To Procedures." The inspector noted that A-3 stated " change of intent" is recognized to be a matter ofjudgment by those responsib!c for reviewing the proposed TC and that A-3 provided some guidance regarding situations that would normally conetitute a " change of intent." The inspector noted that A-3 did not specincally state that a change to acceptance criteria was a " change of intent." The inspector found that the guidance in A-3 was weak, and concluded that the using a TC to alter the acceptance criteria for RT-B-03M00-2 was not appropriat The licensee contacted other utilities about whether a change of acceptance criteria constituted a " change of intent." Based upon this review, the licensee revised A-3 to specify that altering
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or deleting acceptance criteria was a " change of intent." The inspector reviewed revised procedure A-3 issued on May 1,1992 and foimd the changes to be acceptable. The licensee informed applicable personnel of the change to A-3 through a Procedure Upgrade Notification i
. issued April 16,1992 to all supervisors and managers. This item is closed.
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l (Closed) Unresolved item 91-34-002, Evaluate the Acceptability of the Licensee's Instrument l
Bus Cross-tie Modification with Kesnect to Appfndix R Safe Shutdown Cap _ahilith I
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The licensee initiated Modi 6 cation No. 5209 to provide a long-term resolution of two outstand-iug problems associated with maintaining qualined control power to the common EDGs,-their associated 4 KV emergency buses, and Units 2 and 3 AC panels, during performance of mainte-nance and tests on Division I and 11 equipment during cold shutdown or refueling. This
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modi 6 cation provides alternate power feeds to safety-related motor control centers (MCCs) and battery changers, and 120 Vac instrument panels of the same division through a safety-related transfer switch. The tiansfer of power between Units 2 and 3 is manually controlled by administrati,e procedure, such that only one division / channel can be transferred at a time. The Unit 2 modi 6 cation was completed during the 8th refueling outage in the spring of 1991. The Unit 3 modi 6 cation was completed during its 8th refuelirg outage in the fall of 199 When using the alternate power feed from either unit, certain Gre areas must be protected to maintain the safe shutdown capability in the event of a fire in these areas. Existing plant design
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recuir( .ients in fire areas of Peach Bot:om use either 1 or 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Gre barriers. Since the use of the alternate power feed will not occur frequently or for long periods of time, the licensee implemented compensatory measures to detect and limit potential fires in the form of an administratively controlled fire watch. This action is consistent with the guidelines presented in NRC Generic Letter 86-10, " Implementation of Fire Protection Reqmrements." For areas in which Appendix R separation does not exist during use of the alternate power ' - J, the licensee will provide fire watch compensatory measures m the form of hourly patrols for areas with operable detection systems; and continuous fire v atch for areas with no operable detection system. Based on the above, this item is close .0 MANAGEMENT MEETINGS (71707,30702)
The resident inspectors provided a verbal sunimary of preliminary findings to the Peach Bottom Station Plant Manager at the conclusion of the inspection. During the inspection, the resident inspectors verbally noti 6ed licensee management concerning preliminary findings. The inspec-tors did not provide any written inspection raaterial to the licensee during the inspection. This report does not contain proprietary information. The inspectors also attended the entrance and exit interviews for the following inspections during the report period:
Date Subiect Report N Inspect 01 4/6-10/92 Non-radiological Chemistry 9'2-10 Kottan
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4/13-16/92 Operational Safeguards Response Evaluation TAC A3057 Orrik TAC A3058
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