IR 05000277/1993008
| ML20035G038 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/13/1993 |
| From: | Conte R, Hansell S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20035G016 | List: |
| References | |
| 50-277-93-08, 50-277-93-8, 50-278-93-08, 50-278-93-8, NUDOCS 9304260057 | |
| Download: ML20035G038 (11) | |
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i U. S. NUCLEAR REGULATORY COMMISSION
REGION I
i REPORT NO.
93-08
r FACILITY DOCKET NOS.
50-277 50-278
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FACILITY LICENSE NOS.
DPR-44 l
t DPR-56
LICENSEE:
Philadelphia Electric Company Peach Bottom Atomic Power Station P. O. Box 195 Wayne, PA 19087-0195 l
FACILITY:
Peach Bottom Atomic Power Station, Units 2 and 3
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INSPECTION AT:
Delta, PA DATES:
March 22 - 26,1993
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INSPECTORS:
A. L. Burritt, Operations Engineer
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S. L. Hansell, Operations Engineer S. A. Arredondo, Health Physicist
/3 INSPECTOR:
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S. L. Hansell, Operations Engineer 7 '
Date
/J APPROVED BY:
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Richard J. Conte, phief Date BWR Section, Operations Branch
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Division of Reactor Safety Insoection Summary: Inspection from March 22 - 26.1993 (Report Nos. 50-277/93-08 and 50-278/93-08)
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9304260057 930419 PDR ADOCK 05000277 O
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Areas inspected: The inspection was in the area of plant operations and was modeled after the techniques of major team inspections, but on a smaller scale. The primary objective was j
to ensure that the facility's operations department conducted activities in a safe manner and in accordance with both regulatory requirements and licensee-approved prccedures.
Results: The operators performed their duties safely in accordance with NRC requirements
and, generally, in accordance with licensee-approved procedures. Reactivity manipulations were planned and controlled, with a commitment to safe reactor operation. The Alarm
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Response Procedures (ARPs) were of high quality and contained clear concise information.
The ARPs were used routinely by the operators for both normal and unexpected plant
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l conditions. Reactor Water Cleanup (RWCU) filter demineralizer flow control valve problems make it difficult for the operators to control the system in accordance with the operating procedtre. Further, the excessive use of air to maintain plant floor surfaces posed a potential threat to the service air system operation and associated plant equipment.
There were two items of concern. The first was the operating shift's decision to control the main turbine during a planned power reduction which deviated from the Shutdown General Procedure, without using a temporary procedure change. The second was the plant decision process to use the Troubleshooting, Minor Rework, and Test Support (TMT) procedure instead of using the Clearance and Tagging procedure to ensure personnel safety for work on the drywell chiller. The details for these two items are contained in report sections 3.6 and 3.7 respectively.
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DETAILS 1.0 PURPOSE OF INSPECTION
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The primary objective was to ensure that the facility's operations department conducted activities in a safe manner and in accordance with both regulatory requirements and licensee approved procedures. A secondary objective was to assess the interface and support between operations and the other departments as there interactions occurred.
2.0 SUMMARY OF PLANT ACTIVITIFE Units 2 and 3 were at 100% reacto power throughout the inspection period. Both units were conducting daily activities, such as surveillance testing and maintenance. The inspectors observed the two operating crews respond to plant equipment malfunctions and several control room overhead annunciator alarms. There were also three reactivity control evolutions conducted during the observation.
3.0 REVIEW OF FACILITY OPERATIONS 3.1 Scope Because this effort was intended to be a performance-based inspection, the inspectors spent most of their time in the Units' 2 and 3 control rooms observing plant operations. The I
observations were made during the day and afternoon shifts. The inspectors reviewed work in progress, observed operator response to plant equipment malfunctions, reactivity manipulations, shift turnovers, logkeeping, control room management, performance of surveillance, and accompanied operators on their tours.
3.2 General Unit operators generally used and adhered to licensee-approved procedures. No technical specification limiting conditions for operations (LCOs) were discovered beyond what the Unit staffs had already identified. The operators were readily able to explain to the inspector the status or cause of any alarm or clearance. All turnovers were professional, thorough and communicated the necessary information to ensure a smooth transition between operating crews. Imgkeeping was good; and, in one case, a reactor operator trainee detected a faulty average power range monitor (APRM) meter selector switch.
The control room atmosphere was adequate for the conduct of operations, ne shift management was sensitive to potential overcrowding and took steps to reduce the number of personnel in the control area when appropriate. Communication within the shift crew as well as at an interdepartmental level was, generally, adequate. The noteworthy exceptions were an apparent miscommunication between health physics and operations resulting in a premature automatic control room ventilation isolation. Additionally, a reactor operator did l
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not report a number of reactor water cleanup pump trips to shift management on two different occasions. There does not appear to be a clear standard on when a reactor operator should report equipment status changes and equipment malfunctions to shift management.
3.3 Procedures The operators used the appropriate plant procedures for normal and off-normal plant operations. The operations personnel conducted their routine activities such as shift tumover, logkeeping, surveillance, and equipment control by approved plant procedures.
The inspector observed the operators' routine use of the overhead alarm response procedures (ARPs) for both normal and unexpected plant conditions. The operating crews used the ARPs to combat the following four unexpected plant conditions: (1) control room ventilation high radiation isolation; (2) loss of indicating power light for the Unit 3 main generator exciter relay; (3) reactor recirculation pump high lube oil temperature; and (4) reactor recirculation pump vibration monitoring trouble. The alarm response procedures were of high quality and contained clear, concise information.
The inspector reviewed selected residual heat removal (RHR) shutdown cooling operating, off-normal, and annunciator response procedures. The contents of the procedures were adequate and system controls were operated in a logical order, and the procedure information matched the control panel labels. The off-normal and alarm response procedures provided sufficient information to mitigate systam and equipment malfunctions.
The inspector reviewed the preparation and issuance of temporary change 93-124 associated with procedure SO 5A.4.A-2, " Condensate Filter Demineralizer System Draining." The change was implemented in accordance with A-3, "Tempomry Changes to Procedures," and appeared to be technically appropriate.
t 3.4 Equipment Control
Overall, the operators' control of plant equipment was gocxi. The inspector had two
observations related to the control of the station service air system and the reactor water
cleanup (RWCU) system.
First, the control room operators were required to respond to repeated station service air low pressure conditions due to air chipping of the plant floors. The inspector no'ed the first service air low pressure condition during a plant tour. The next time the alarm occurred was on the day shift observation in the Unit 3 control room.
The Unit 3 station service air low pressure overhead alarm annunciated at approxima'ely i
7:50 a.m. The reactor operator (RO) trainee acknowledged the alarm and discussed the problem with the unit RO. The RO speculated that the air problem was probably due to an excessive number of plant workers using air chippers on the plant floors. The RO and his
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l trainee started the third station air compressor on Unit 3. When questioned by the inspector, the RO stated that the service air low pressure alarms were a common occurrence due to the
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ongoing work. The inspector did not observe the RO contacting the plant operator or plant workers to verify the reason for the low air pressure condition. After approximately twenty minutes the service air low air pressure alarm cleared. The inspector did not observe
anymore service air low pressure alarms the final three days of the inspection.
Second, several deficiencies were noted with operation of the RWCU system. The RWCU I
problems appeared to be due to system design and to a lesser extent the control room operation of the RWCU system. There were two RWCU system deficiencies that made it more difficult for the operator to manipulate the system in accordance with the operating procedure.
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The first RWCU deficiency was identified when the inspector observed the task of placing the RWCU filter deminemlizers in service from a standby condition. This task was hampered by the erratic operation of the filter demineralizer flow control valves. The inspector noted the Unit 3 reactor operator (RO) executing the written information in the RWCU procedure SO-12.1.A-3, "RWCU System Startup For Normal Operations or Reactor Vessel Level Connol." The evolution was coordinated with the plant operator at the local
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RWCU filter demineralizer control panel. When the plant operator attempted to raise the
"A" and "B" RWCU demineralizer flow from zero to 125 GPM in manual control, flows
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oscillated from 125 GPM to almost zero flow. The oscillations were the greatest when the filter demineralizer flow controller was switched from manual to automatic. It also appeared that placing both filter demineralizers in service at the same time contributed to the erratic system flow and subsequent pump trips.
The RWCU system flow oscillations resulted in a low flow condition which caused the "A" and "B" RWCU pumps to trip after the designed 12 second time delay. The RO restarted both.RWCU pumps and attempted to place both filter demineralizers back in service, but continued erratic operation of the flow control valve resulted in the trip of the RWCU pumps two more times.
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The second RWCU deficiency was noted when the RWCU pump low flow trip and associated annunciator did not automatically reset in the control room after the first pump trip. The RWCU pump low flow trip requires that an operator manually push a reset button in the reactor building. The reset pushbutton is physically located one level below the RWCU demineralizer control panel.
The plant management acknowledged that the RWCU system has design problems warranting system modifications. The plant management has implemented a program to collect the most important problems that impact the operators' ability to run the plant. The RWCU system
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was picked by the operators as one of the systems that could use improvements. The
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operators viewed the plant management's increased attention to plant problems as a positive J
initiative to provide them with reliable equipment to operate the plant safely.
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i The inspector monitored three reactivity control evolutions that were planned and coordinated by shift supervision, reactor engineers, unit reactor operators (ROs), and ROs in licensed
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training. The reactivity manipulations were normal evolutions that adjusted reactor recirculation pump speed and control rod configuration to account for fuel depletion and, in
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one case, to establish conditions for shifting reactor recirculation lubricating oil pumps.
All three evolutions were well coordinated by the shift supervisor, reactor engineer and RO.
Prior to each reactivity manipulation, the involved personnel held a preevolution briefing and discussed the expected plant response. The reactor engineer and RO monitored the key reactor parameters prior to and after the reactivity evolutions.
The RO and RO trainee independently verified all control rod positions and reactor core
location before and after each control rod group was moved. The inspector noted that the
ROs' self check of each control rod position, after the rod had time to settle, was a good
approach to ensure correct control rod position. The self check was an example of the licensee's commitment to safe reactor operation.
The inspectors monitored a number of other evolutions; swapping reactor recirculation lubricating oil pumps, reactor water cleanup pump "B" shutdown including removal of one filter demineralizer from service and subsequently, shutdown / isolation of the reactor water cleanup system. While observing these activities, the inspectors noted that for operations with potentially significant plant impact, a preevolutionary briefis held with personnel involvo:1. The briefs observed were formal and addressed expected plant response, potential problems, remedial actions, as well as individual responsibilities. Additionally, the inspectors noted direct shift management supervision during the conduct of significant evolutions.
3.6 Event Reviews The inspector reviewed follow-up actions taken in response to a control room ventilation isolation while transferring radioactive material on March 23,1993. This evolution was controlled under procedure A-108, " Control of Radioactive Material." The inspector focused on the reportability evaluation / event investigation form (RE/EIF) generated (2-93-133) and
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the facility's determination of reportability. The initial documentation on the RE/EIF was sufficient in-depth and detail to support a subsequent event investigation. The facility's assessment of reportability was consistent with the Identification and Evaluation of Potentially Reportable Items manual and 10 CFR 50.72. This was a repeat event, with circumstances similar to those identified in RE/EIF 2-91-321. The inspector could not determine what, or
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if any, corrective actions were taken for RE/ elf 2-91-321. This preceding situation was classified as a nonevent, and no investigation was performed. Plant management stated that the most recent case of control room ventilation isolation would be investigated and corrective actions implemented as appropriat,
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The inspector performed a review of draft licensee event report (LER) 3-93-002 and control l
room logs for an event which occurred on March 7,1993. At the time of the event, plant
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conditions were established for replacement of the main turbine master trip solenoid.
Reactor power was reduced to the point that if the main turbine was tripped it would not l
result in a reactor scram. While reducing power in accordance with GP-3, " Plant
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Shutdown," the shift completed control rod insertion, with reactor power at 23% and the
reactor protection system (RPS) input from turbine stop and control valves not bypassed.
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The shift elected to terminate the power reduction and to reduce the electro-hydraulic control (EHC) load set setpoint. This setpoint reduction resulted in opening turbine bypass valves
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and lowering main turbine first stage pressum enough to cause the bypass of the turbine valve inputs to RPS. The RPS bypass was established with approximately one and one half bypass valves open.
This manipulation was not in accordance with GP-3, step 6.2.c. The shift management did
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not implement a temporary procedure change and had no procedural guidance to support I
opening the bypass valves using the load set control.
This evoludon was of low safety significance since actual reactor power was within bypass
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capability. Additionally, Technical Specification Table 3.1.1, note 4, allows the RPS input from turbine stop and control valves to be bypassed when less than 30% reactor power. The licensee has committed to address this situation in RE/EIF 3-93-26, as well as to revise the appropriate general procedures to address specifically the operation with the turbine tripped and the reactor at power.
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3.7 Work Control / Clearance and Tagging
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The control of plant work is governed by procedure A-26, " Plant Work Process," and A-42.1, " Troubleshooting, Minor Rework, and Testing Support Process." In general, the
operators complied with these procedures. However, the inspectors noted what appeared to
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be examples of work controlled under A-42.1 alone, with no clearance applied to system isolation boundaries to establish an appropriate level of personnel protection.
In one case, a troubleshooting, minor rework and test support (TMT) form was used to establish drywell chiller isolation boundaries in preparation for condenser head removal to perform a tube inspection and cleaning. Boundaries for this chiller work should have been i
established using a system / component clearance in accordance with the clearance and tagging
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manual (CTM). The work performed under the TMT relied on human boundaries for personnel safety at the job site. The workers depended on the assumption that the job was of short duration and workers would be in close proximity to the safety boundaries. Although this practice is not specifically prohibited by the CTM or A-42.1, it appears to be contrary to the intent of the CTM manual.
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The inspector reviewed approximately 120 TMT documents during the period of February 25,1993, to March 27,1993. Three additional potential examples of improperly controlling fluid or electrical system boundaries to ensure personnel safety were identified.
The facility committed to review each of the four cases identified and implement a formal investigation as appropriate.
3.8 Summary of Conclusions The operators performed their duties safely, in accordance with NRC requirements and generally in accordance with licensee-approved procedures. The alarm response procedures were of high quality and contained clear concise information. The ARPs were used routinely by the operators for both normal and unexpected plant conditions. RWCU system problems make it more difficult for the operators to control the system in accordance with the operating procedure. Further, the maintenance of plant floors posed a potential threat to the service air system operation and associated plant equipment. Reactivity manipulations were planned and controlled with a commitment to safe reactor operation.
There were two items of concern. First, is the operating shift's philosophy used to control the main turbine during a planned power reduction using the written guidance in the Shutdown General Procedure. Second, is the plant decision process to use the Troubleshooting, Minor Rework, and Test Support (TMT) procedure instead of the Clearance and Tagging procedure to ensure personnel safety for work on the drywell chiller.
4.0 EXIT MEETING The inspectors met with licensee representatives at the conclusion of the inspection on March 26,1993. The inspectors summarized and discussed the findings and observaticns made during the inspection.
4.1 Persons Contacted Philadelohia Electric Company
- K. Powers, Plant Manager
- G. Gellrich, Senior Manager Operations
- W. Eckman, Nuclear Quality Assurance
- J. Verner, ISEG
- H. Abendroth, Atlantic Electric
- D. IxQuia, Director, Maintenance S. Mannix, Manager, Operations Supervisor
- D. Meyers, Director, Site Support Services
- J. Starosta, Operations Support
- P. Dirito, Shift Manager, Operations
- R. Smith, Regulatory Inspection Coordinator
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- R. Smith, Regulatory Inspection Coordinator l
U.S. Nuclear Reculatory Commission
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- A. Burritt, Operations Engineer
- S. Hansell, Operations Engineer
- L Lyash, Senior Resident Inspector
- P. Bonnett, Resident Inspector M. Evans, Resident Inspector j
- S. Maingi, Pennsylvania State Representative The inspectors also contacted various senior reactor operators, reactor operators, and
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members of the operation support staff during the course of this inspection.
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- Denotes those present at the exit interview on March 26,1993.
i Attachment: Documents Reviewed
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A'ITACHMENT 1
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Documents Reviewed
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Procedure Number Title Revision
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SO-12.1. A-3
- RWCU System Startup For Normal Operations
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or Reactor Vessel Imvel Control" ARC #315-A4
"A Clean-up Recirc Pump High or low Flow"
ARC #315-B4
"B Clean-up Recirc Pump High or low Flow"
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ARC #202-E3
"C RFPT HI Vibration rev. 2
A-26 Plant Work Control rev. 31 t
A-42.1 Troubleshooting, Minor Rework, and Testing rev. 4 suppon process GP-3 Normal Plant Shutdown rev. 58 A-3 Temporary Changes to Procedures rev.14
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SO 6D.2.A-2 Reactor Feedwater Pump Shutdown rev. 5 A-41 Control of Safety-Related Equipment rev.8 L
Operations Manacement Manual (OMM)
Section 3 " Shift Management Responsibilities and Authority" rev. 6 Section 6 " Shift Mechanics" rev. 4 a
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Operator's Manual (OM)
Section 9 " Procedures at. Operator Aids" rev.6 Section 11
" Verification" rev. 4 Unit 2 Technical Soecifications Unit 3 Technical Specifications
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