IR 05000277/1993015
| ML20059B220 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/19/1993 |
| From: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 9310280092 | |
| Download: ML20059B220 (2) | |
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'0CT ~191993 Docket Nos. 50-277 50-278 Philadelphia Electric Company ATTN: Mr. D. Vice President Peach Bottom Atomic Power Station RD 1, Box 108 Delta, PA 17314 ;
Dear Mr. Miller:
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Subject: Combined Inspection Report Nos. 50-277/93-15 and 50-278/93-15
This refers to your September 29, 1993 correspondence, in response to our August 23,1993
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letter.
Thank you for informing us of the corrective and preventive actions documented in your letter.
These actions will be examined during a future inspection of your licensed program. ,
Your cooperation with us is appreciated. f i
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Sincerely, I._ -. --Ori;'jr.3i S$,ned Dyh :
3 n., n ,t. White
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Edward C. Wenzinger, Chief I Projects Branch 2 Division of Reactor Projects
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gQO 9310280092 931019 I I PDR ADOCK 05000277 p ll
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OCT 1 9 ;993
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.o Philaddiphia Electric Comapany 2 cc: l D.M. Smith, Senior Vice President J. Doering, Chairman, Nuclear Review Board !
G. Rainey, Vice President, Nuclear Services Department ,
G. Cranston, General Manager, Nuclear Engineering Division l G. Edwards, Plant Manager, Peach Bottom Atomic Power Station l I
A. J. Wasong, Manager, Experience Assessment G. A. Hunger, Jr., Manager, Licensing Section l J.W. Durham, Sr.. Senior Vice President and General Counsel
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cc w/cy of licensee's ltr:
C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co. ]
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B.W. Gorman, Manager-External Affairs, Public Service Electric & Gas Co.
R. McLean, Power Plant Siting, Nuclear Evaluations J.H. Walter, Chief Engineer, Public Service of Maryland R. Ochs, Maryland Safe Energy Coalition l
D. Poulson, Secretary of Harford County Council Public Document Room (PDR) ,
Local Public document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector ;
Commonwealth of Pennsylvama i
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bec w/cy of licensee's ltr Region I Docket Room (with concurrences) l E. Wenzinger, DRP !
C. Anderson, DRP M. Boyle, Acting PDI-2, NRR J. Shea, NRR l
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RI:DRP RI:DRP t >G j) 1 CAnderson 10h1/93 h"Ed'enzinger 10/ /93
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OFFICIAL RECORD COPY -
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CDN9314139
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/ *t, PIIILADELPIIIA ELECTRIC COMPANY
- i PEACH BorlOh! ATONilC POWER STATION
- R. D.1, Box 208 Wre to Delta, Pennsyinnia 17314 *
rtAcn morrou-mz rom r.m or EXCELLI.NCE (717) 456-7014 D. B. Miller, h.
Vico President September 29, 1993 Docket Nos: 50-277 50-278 U.S. Nuclear Regulatory n,mmke: ion Attn: Eh' w nt Control Desk Washington, DC 20555 SUBIECI': Peach Bottom Atomic Power Station - Units 2 & 3 Response to Notice of Violation (Combined Inspection Report No. 50-277/93-15; 50-278/93-15)
Dear Sir:
In response to your letter dated August 23, 1993, which transmitted the Notice of Violation in the referenced inspection report, we submit the attached response. 'Ihe subject inspection concerns a routine residents' safety inspection that was conducted June 15 through August 2, 1993.
If you have any questions or require additional information, please do not hesitate to contact us.
Sincerely, i
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oc: R. A. Burricelli, Public Service Electric & Gas .I W. P. Dornsife, Ctamonwealth of Pennsylvania 1 W. L. Schmidt, USNRC Senior Resident Inspector l T. T. Martin, Administrator, Region I, USNRC i H. C. Schwemm, Atlantic Electric j R. I. McIman, State of Maryland l C. D. Schaefer, Delmarva Power i
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Documen't Control Desk Page 2 boc:
J. A. Bernstein 51A-13, mesterbrook Cbmmitment Coonlinator 52A-5, mesterbrook Correspondence Control Pnagram 61B-3, mesterbrook J. B. Cotton 53A-1, mesterbrook G. V. Cranston 63B-5, mesterbrorA E. J. Cullen S23-1, Main Office J. Doering 53A-1, mesterbrook G. D. Edwards A4-IS, Peach Bottam A. A. Fulvio SMB-4, Peach Bottom G. H. Gellrich A4-1S, Peach Bottam G. A. Hunger 52A-5, mesterbrook D. P. leQuia A2-4N, Peach Bottam M. C. Kray 52A-5, mesterbrook N. J. McDermott S13-1, Main Office D. R. Meyers SMB-4, Feach Bottam D. B. Miller, Jr. SMB-4, Peach Bottom PB Nuclear Records SMB-1, Peach Bottom ,
R. M. Moore PS2-2, Peach Bottom T. J. Niessen SMB-3, Peach Bottom F. W. Polaski SMB-4, Peach Bottom G. R. Rainey 52A-6, mesterbrook D. M. Smith 52C-7, mesterbrook J. S. Stankiewicz PB 'IC, Peach Bottom A. J. Wasong A4-4S, Peach Bottam
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Pdge 3 RESIONSE 70 IKTfICE OF VIOIATION 93-15-01 Restatement of Violation A. Technical Specification 6.8.1 states that written procedures shall be established, implemented and maintained that meet the requirements of Sections 5.1 and 5.3 of ANSI N18.7-1972. ANSI 18.7-1972, Section 5.1, states, in part, that " operators shall adhere to procedures," and ANSI Section 5.3, states, in part, that " Nuclear Power Plants shall be operated in accordance with written procedures."
contrary to the above, the licensee did not properly implement procedures while withdrawing a control rod. Specifically: On June 24, a power increase was commenced by withdrawing control rod 14-31 to its fully withdrawn position without adhering to GP-5, Section 5.0, " Power Operations," which requires power increases to be performed under the guidance of procedure RE-31, " Reactor , Engineer Start-Up/Ioad Drop Instructions." RE-31 specified the position for control rod 14-31 to be notch 34 vice fully withdrawn. Operator error resulted ir. control rod 14-31 being mispositioned for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
This is a Severity Invel IV Violation (Supplement I).
Dacknround On June 24, 1993, follwing a load drop of the Unit 2 reactor to 60% power, repair on the high pressure coolant injection (HPCI) system check valve AO-18 was ;
initiated. During the work evolution, the Maintenance Job leader called the l control room and questioned if pwer could be reduced further to decrease work !
area radiation levels. The Control Room Shift Supervisor (SSV) obtained the appropriate identification of the control rods to be manipulated frcan the Reactor .
Engineer (RE) ard directed the Reactor Operator (RO) to insert the appropriate l control rod listed in Table 1 of General Procedure (GP) 3-2, Attachment 1, " Unit l 2 Shutdwr1 Rod Insertion Soquence Instruct.lons". The RO fully inserted control J rod 14-31 from position 34 to 0 ard GP 3-2, Attachment 1 was signed off by the !
SSV. After control rod 14-31 was inserted, the Chief Operator noticed that the j
'B' Reactor Feed Pump (RFP) had taken a IM#/hr dowrraard step in flw. Cbntrol rod 14-31 was verified to have reduced reactor power by 20 MNe, which_was more than had been anticipated. As preparations were being made to remove the B RFP from service, the Maintenance Job Leader contacted the Shift Manager (SM) and indicated that HPCI system check valve AO-18 was ready to be stroked. This call came within two minutes of the first call questioning a power reduction. The SM l relayed this information to the crew and the RO proceeded to stroke the valve. l The valve was satisfactorily stroked twice. The decision was then made to I withdraw control rod 14-31 back to its original position. The SSV directed the RO to withdraw the control rod, but a targeted position for the red was not given. The RO proceeded to fully withdraw the control rod to position 48. This resulted in a control rod mispositioning that existed for one hour and fifty.
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Ibcument Control Desk Page 4 Reason for the Violation The guidance provided in GP-5, " Power Operations" was less than adequate to direct Operations personnel to enter Reactor Engineerity (RE) procedure RE-31,
" Reactor Engineeriry Startup/ Load Drop Instructions." There also was no specific direction from GP-5 for Operations personnel to ccraplete Exhibit RE-31-09, 1
" Control Rod Position Data Sheet" to document rod withdrawal. Personnel stated ;
that had the appropriate guidance or reference been given to RE-31, the procedure would have been utilized.
It was determined that Licensed operator Trainirs did not include trainity on RE-31 prior to the current license class. The current class had been presented with an overview of RE-31, but not to adequate detail. The SSV stated that he was unaware that Exhibit RE-31-09 was required to be cxxpleted.
The attention of control room personnel was interrupted during rod movements as a result of several distractions. 7his included a step change in flow of the B RFP and the need to stroke HPCI system check valve AO-18. The crew's questioning attitude during the rod manipulation was redomi as a result of these distractions. In addition, the role and responsibilities of the RO and RE were not fully utilized to provide an effective barrier for errors.
i Communication was less than adequate concerning the control rod withdrawal. J In the communication between the SSV ard the RO and between the RO and the RE, no target position was stated for the withdrawal of control red 14-31. Although 1 repeatbacks were used during the communication exchange, a target rod position was never stated.
Oorrective Actions Taken and Results Achieved l l
After the control rod mispositioning was identified, Operations personnel l immediately entered off normal procedure (ON)-122, " Control Rod mispositioned i precedure" and returned control rod 14-31 to position 34. l Event investigation 2-93-264 was initiated to evaluate the root causes of the mispositioning and to develop appropriate corrective actions to prevent recurrence. j General Procedure (GP)-5, " Power Operations" was temporarily changed and later revised to require rod movements be recorded in Exhibit RE-31-09.
An all hards meeting was conducted for the Reactor Engineering group by the RE Manager to review the events, re-emphasize RE-31 requirements and to reinforce the roles and responsibilities of the RE durirg control rod movement. A shift management meeting was also conducted where the event was reviewed ard management expectations concernire rules ard responsibilities during rod manipulation were
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Management expectations concernirg procedure usage were reinforced by the Operations Senior Manager ard the Site Vice President to the Shift Managers.
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Document Cbntrol Desk Page 5 Mditionally, the operations Serviws Manager distributed a letter to Shift Management personnel ard to the RE ranager explaining the interim corrective actions for the co2 fuel red mispositioning ard , established requirements and guidelines for future control red manipulation. Reactivity manipulations involving control rods will be supervised so that pmonnel involved can remain focused on the task and will not be distracted by other control room activities.
This will include limitirg or stopping other activities to ensure that personnel are not distracted durity red movement. Additionally, control rods will be moved only by the use of appropriate procedures with the core position and target position of the control rod positively identified by the licencel operator prior to control rod movement. '1he RE will specify the control rod group, control rod number and the control rod target position to shift supexvision prior 'n ranipulation. Shift sup m ision orders to the RO will include the control red number, direction of the novement and target position for any evolution governed by procedure concerning control rod rovement.
Corrective Steps That Will Be Taken to Avoid Future Violations RE-31 will be revised to include specific communication requirerrents for the Reactor Ergineer to use with the Shift Supervisor, proper instruction on where to record control rod movement information and enhancenents to Exhibit RE-31-09. A revision to RE-31 will be conpleted by December 3, 1993.
Licensed Operator Training lesson plans will be enhanced to include additional coverage of operator responsibilities associated with RE-31. This will be completcd by December 31, 1993.
Inte When Full Conpliance was Achieved Full canpliance was achieved June 24, 1993, when control red 14-31 was returned to position 34 as required by RE-31, " Reactor Equipaent Startup/Ioad Drop Instructions".
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Document Control Desk Page 6 RESEONSE TO NCTI' ICE OF VIOIATION 93-15-02 Restatement of Violation B. 7bchnical Specification 6.8.1 states that written procedures shall be established, implemented and maintained that meet the requirements of Sections 5.1 and 5.3 of ANSI N18.7-1972. ANSI 18.7-1972, Section 5.1, states, in part, that " operators shall adhere to procedures," and also that "if documentation of an action is required, the procedure should be present and follcwed step-by-step, and n - ary data should be recorded as the task is perfonaed." ANSI Section 5.3, states, in part, that
" Nuclear Power Plants shall be operated in accordance with written procedures."
Contrary to the above, the licensee did not properly estab]ish or implement applicable procedures during a maintenance evolution.
Specifically: On July 9, during performance of Instrumentation and Control Work Order R0526192-01, a procedure was not present at the job site or in the control room. Additionally, the controlling procedure (IC-11-00574, " Calibration Procedure for G.E. H0J Amelator Invel Switches"), the work order, and the calibration data sheet all specified different torque values for the N2 charging connection cap. Finally, neither the work order nor the data sheet required the torque value to be recorded.
This is a Severity Invel IV Violation (Supplement I) .
Reason for the Violation On July 9, 1993, a Maintenance Instrument and Control (I&C) crew was performing preventative maintenance (H4) on Unit 3 Hydraulic Control Unit (HQJ)
instrumentation. The I&C crew was in the process of completing Work Order (W)
R0526192-01, " Unit 3 HCU Rack "C" Ammlator Instrunent R4's", that had been started the previous day. Two technicians were working in the reactor building and one technician was in the main control room to provide direction and record data. The testing required was routine for the technicians and the procedure was fairly general. It was normal practice for the technician in the control rocm to have the work order, appropriate procedures, and calibration sheets with him where he could relay instructions and information to the team in the field.
Prior to initiating work, the Maintenance I&C crew held a pre-job briefing where they discussed previously completed work and job responsibilities for the day.
The field technicians a_h that the technician in the control rocm had the work order and procedure with him, and did not attempt to take paperwork to the job site. The technician in the control room however, failed to take the work order or the procedure with him. Previous R4 had been performed on HQJ instrumentation without incident and the technician in the control roam inappropriately determined that only the calibration sheets would be sufficient.
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rWwnt Control Desk Page 7 A new work order was developed earlier in the year to perform HCU FM tasks by a nore streamlined process where procedural guidance and instruction was incorporated into the work order. This greatly ~ reduced the time, dose, and paperwork involved and was interded to give sufficient guidance during routine calibrations so that reference to procedure would be necessitated only if a rcre complicated HCU level detector replacement was required. Upon @ u]uent review of the work process, hwever, it was determined that the torque value for the N 2 charging connection cap required in the work order (minimum of 200 in/lbs.) was not in agreement with the procedure (200 in/lbs.) or the calibration sheets (150-200 in/lbs.).
It had previously been determined that the torque value could be higher than 200 in/lbs. if the connection leaked. This information was used as the basis for the torque value in the work order. The procedure and calibration sheets however, were not revised to be consistent with the work order. In addition, there was also a discrepancy where the work order or calibration sheet did not require the torque value to be recorded. Management oversight of these activities was ineffective in that work was allowed to be performed before the discrepancies noted were corrected.
Corrective Actions Taken and Results Achieved Work was stopped when it was learned that the work order and procedure were not present at the job site. Only after the appropriate work package was taken to the job site was work allwed to be completed.
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Event investigation 3-93-125 was initiated to evaluate the root causes of the noncampliance and to develop appropriate corrective actions to prevent rectunu;e.
A temporary procedure change was completed on IC-11-00574, " Calibration Procedure for G.E. HCU Amelator level Switches" to make torque values consistent with those stated in the work order. Additionally, work orders have been revised that require torque values to be recorded and double verified.
The I&C Manager reinforced management's expectation to Maintenance I&C foremen and technicians that proper paperwork should always be at the work site, ard that discrepancies identified in procedures or work orders are expected to be corrected by approved methods before work is initiated.
Cbrrective Actions That Will Be Taken To Avoid Future Violations A single procedure for the performance of preventative maintenance on hydraulic control unit instrumentation will be established to enhance work performance. This procedure will be developed by September 30, 1993.
Additionally, procedure IC-11-00574 will be retained for the replacement of level detectors.
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Ibte When Full Compliance Was Achieved Full compliance was achieved August 13,1993, when the torque values in IC-11-00574 were revised to agree with Work Order R0526192-01. Work on the Lhit 3 IIai instnmentation was completed after the apptrpriate work package was made available at the job site, and the work orders were revised that required torque values to be recorded arxl double verified.
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rw,mont Control Desk Page 9 RESICIGE 'IO NorICE OF VIOIATION 93-15-05 Restatemnt of Violation
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C. Technical Specification 6.8.1 states that written procedures shall be established, implemented and maintained that meet the requirements of Sections 5.1 and 5.3 of ANSI N18.7-1972. ANSI 18.7-1972, Section 5.1, states, in part, that " operators shall adhere to procedures," aM ANSI Section 5.3, states, in part, that " Nuclear Power Plants shall be operated in accordance with written procedures."
Cbntrary to the above, the licensee did not properly implement- their health physics (HP) pmcedures on several separate occasions durity the Unit 3 outage (July 4 - 14) . Specifically: (1) Two individuals were observed insida a contandnated area with their protective clothirq open in the chest / neck area. This is contrary to HP-510, " Selection, Use and Control of Protective Clothirg," Section 7.2.1. (2) Personnel exitdIg the ;
RNP area on the refuel floor ard the drywell were observed renoviry their l inner set of plastic gloves prior to removing their shoe covers. m is is i not consistent with HP-510, Exhibit 2, steps 9 and 10. (3) A contaminated boundary on the refueling floor was not marked in accordance with procedure HP-215, "Establishirq and Postiry Controlled Areas," in that the markiry tape was placed approximately 12 inches inside the bourdary rope. ,
(4) Iastly, a HP technician failed to sign out of the accountability log l after exiting the Unit 3 spent fuel pool ard reactor cavity RWP area as j required by procedure A-C-130, Section 7.8.1
'Ihis is a Severity IcVel IV Violation (Supplement I) .
Reason for the Violation In the first example, personnel failed to follow the proper stardard for I use of anti-C coveralls. 'Ihis event occurred when the Unit 3 Fuel Floor ambient temperature was elevated and heat stress was a concern. me line supervisor and HP technician failed to identify and correct the improper anti-C coverall usage.
No personnel contaminations resulted from this incident.
We involved personnel in the secord example failed to follow the recammended removal sequence for anti-C clothirg. W e use of cotton liners to hardle contaminated articles is not pennitted. We-reason for this discrepancy was inattention to detail by the involved Annel. No personnel contamination resulted from this incident.
Health physics stanchiens are located in " clean" areas. We stanchions have a 12 inch square base. 'Ihis prevents the rad rope and rad tape barriers for contaminated areas frem being in a straight vertical plane. We area in question on the Unit 3 Fuel Flcor was a " clean" area (le <1000 dm/100cm2) but the slight offset in the barrier was confusing to the worker. No A nnel contaminations resulted from this incident.
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Document Control Desk Page 10 An HP technician's name was inadvertently entered into the Unit 3 Fuel Floor personnel accountability log. We HP technician was involved with the job coverage of fuel sipping equignent set-up activities, however, this activity was not included in the accountability zone.
Corrective Action Taken and Results Achieve _d Actions were initiated to immediately correct the identified discrepancies.
A special cdition of the station newsletter devoted to proper radworker practices was published and distributed. An increased emahasis has also been placed on the adherence to proper radworker practices by line supervision and HP p m onnel.
Additionally, articles were published in the station newsletter reminding personnel to follow the recommended anti-C clothirg removal sequence.
HP-215 " Estab1lshirq and Postiry Controlled Areas " was revised to clearly state that rad tape is the barrier when used in conjunction with rad rope to post contaminated areas.
h e involved HP technician noted in the fourth example was contacted and was innodiately logged out of the personnel accountability log. HP technicians were reminded at the August 26, 1993 All Hands Meetings about the importance of attention to detail with accountability logs.
The inportance of line supervision to continually enforce radworker practices is a station ranagement expectation. mis was communicated by the station Vice President to the station s w isors at the July 22, 1993, Supervisors Meeting. Pre-outage roetings were held in September,1993, with line organization supervision, craft organizations, and HP management to emphasize the adherence to proper radworker practices and procedures.
Corrective Actions Wat Will Be Taken to Avoid Future Violations Site wide newsletters were published and will continue to be periodically published reminding personnel of the inportance of adherence to proper radworker practices. Additionally, the adequacy of radworker practices will be assessed durirg the Unit 3 Fall Refueling Outage. Radworker practices will continue to be part of the station's self assessnent program.
Date When Full Compliance Will Be Achieved Full Compliance was achieved immediately after the discrepancies were identified.
S e discrepancies were identified during the Unit 3 outage, July 4 - 14, 1993.
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