IR 05000277/1994005

Insp Repts 50-277/94-05 & 50-278/94-05 on 940405-08.No Violations Noted.Major Areas Inspected:Licensee Mgt Control in Area of Design Change & Mod,Technical Adequacy of Design Changes & Progress in Needs Improvement Program

ML20029D480
Person / Time
Site:	Peach Bottom
Issue date:	04/28/1994
From:	Chaudhary S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20029D477	List: IR 05000277/1994005
References
50-277-94-05, 50-277-94-5, 50-278-94-05, 50-278-94-5, NUDOCS 9405060013
Download: ML20029D480 (8)

Text

-

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

I

'

DOCKET / REPORT NOS.: 50-277/94-05 50-278/94-05 (

LICENSEE:

PECO Energy Company

,

FACILITY:

Peach Bottom Atomic Power Station, Units 2 and 3

i Delta, Pennsylvania f

DATES:

April 5-8,1994 l

/[h 2F 19#

INSPECTOR:

[

h Suresh Chaudhary, Sr. Reactor Grfgineer

'Dite

'

Materials Section Division of Reactor Safety l

APPROVED BY:

2f

'

Michael Modes, Chief Date Materials Section Division of Reactor Safety Areas Insoected: An announced inspection was performed of the licensee's management control program in the area of design change and modifications, technical adequacy of design l

changes, progress in the "NEEDS" improvement program, and the overall effectiveness of the licensee's engineering organization to provide effective engineering and technical support to plant operations to assure safety.

Results The licensee's engineering and technical support program is satisfactory. The l

licensee has implemented several new initiatives to further strengthen these programs. No violations were identified.

9405060013 940428 PDR ADOCK 05000277

.

G pop i

.

DETAILS 1.0 PURPOSE AND SCOPE The purpose of the inspection was to determine the effectiveness of the licensee's engineering i

organization in providing engineering, technical support, and guidance to the plant to assure safety. The scope included design changes and modifications implemented by the licensee within the scope of 10 CFR 50.59; the licensee's organizational structure, adequacy of staff'mg in the engineering area, and overall management attention and emphasis on the role of engineering in assuring and maintaining the design basis, including configuration control; l

and the safe operation of the plant systems (including improvement in reliability and safety performance of plant systems).

2.0 FINDINGS 2.1 Engineering Organization The Peach Bottom Atomic Power Station (PBAPS) engineering and technical suppoit activities were reorganized in 1993 under the NEEDS program. In this new organization, the director of site engineering reports to the vice president of PBAPS. There are four sections within the site engineering department, i.e., plant engineering, component engineering, design engineering, and performance and reliability. All four of the sections are headed by a manager.

The plant engineering section has four groups: nuclear steam supply system (N9SS), balance of plant (BOP), instruments and control (I&C), and reactor engineering. The activities of these groups are focused towards operability, reliability, and performance of plant systems rather than maintenance and/or design change. System engineers in this group are designated as system managers for assigned systems. The qualification requirements for these system engineer / managers are comprehensive and effectively implemented.

The component engineering section has the responsibility for the wide range of component engineering activities. These include snubber, valves, erosion / corrosion program, in-service

.

inspection (ISI), nondestructive examination (NDE), and special testing and/or monitoring of components in the plant system.

The design engineering section is divided into four engineering discipline basis, i.e.,

mechanical, I&C, civil / structural, and electrical. This responsibility includes: design of small modifications, design basis documentation, configuration control, and disposition of engineering change requests (ECRs), and nonconformance reports (NCRs). The staff has been augmented to support the new responsibility of small me.ification design, and the day-to-day operational and technical issue resolution.

l

-.

.

-

- -

.

__

-

,

j

.

The programs, procedures, and performance section's responsibility include procedure development for ECRs and NCRs; defining, coordinating, and developing a small modification program and process; development and review of temporary modification (TPA)

in the plant; and the performance monitoring.

l l

2.2 Staffing and Technical Training j

l There are approximately one hundred and ten (110) engineers and support personnel assigned to the site engineering group at the PBAPS. This group is further supported by the Nuclear

,

engineering division staff engineers at the Chesterbrook office of the licensee.

The licensee continues to have a broad-based administrative and technical training program l

l for the site and corporate engineering staff. The training is grouped under three general areas, i.e., core training, which is equired of all engineers, the position specific training, which is related to an individual's assigned area of responsibility, and the third group is elective training based on desires and need of the staff as approved by the engineering l

management. The training program closely follows the program described and recommended i

m ACAD 91-017, a document published by the National Academy for Nuclear Training.

!

l Based on the discussion with the engineering staff and supervisory engineers, the inspector found the engineers to be knowledgeable and familiar with the area of their responsibility.

The training program is comprehensive and appears effective in improving and maintaining l

the proficiency of the engineering staff.

!

2.3 Assessment of Engineering Performance The inspector reviewed documents that provide a basis for an assessment of the site engineering department's performance. Performance indicators have been developed and approved by the licensee management for the engineering organization. These indicators are comprehensive, well documented, and are regularly distributed to licensee management.

The inspector reviewed several trend reports in the areas of: ECRs, NCRs, design equivalent changes (DEC), engineering work requests (EWRs), modification change ECRs, corrective maintenance equipment trouble tag (CM-ETT) resolution, backlog of open procedure changes, open temporary changes to permanent procedures. In all these areas, the trend was positive, indicating the effectiveness and efficiency of the new organization structure. The inspector noted the general strength of the engineering organization that included technical capability, responsiveness to requests, work prioritization, depth of experience at site and at corporate office, opportunity and availability of training, and cooperation with other groups to efficiently resolve technical concerns and problems.

_ _ - _ _ _ _ _.

_ _ - _ _ _ _ _

l l

.

.

i i

2.4 Communication The inspector found good communication amongst PBAPS engineering sections, and interface with other plant departments. These came in various forms; such as, PORC meetings daily leadership meetings, wide distribution of performance indicators, the plant " Chronic Equipment / System Problem" list maintained by various engineering sections, and the reports l

of the experience assessment group. "he general communication of plant-wide interest is l

disseminated through the "Today at PBAPS" newsletter, which updates employees on events related to operations at PBAPS.

2.5 Engineering Backlog A review of the data and the trend report of the engineering backlog indicated that the total backlog of engineering workload was gradually declining. The trend graph showed that the total of all open design change documents (nonconformance reports and engineering change requests: NCR and ECR) for PBAPS had steadily declined from a high of approximately 1,800 in June 1993 to approximately 1,100 in February 1994.

The inspector noted that there was no backlog of modifications that were planned and scheduled for the 1993 refueling outage. However, there was no easy reference or assembled data that could readily indicate the extent and volume of engineering backlog in the day-to-day engineering support work load in the sense that it was not apparent to the inspector or the PBAPS engineering management as to how much or how many requests for engineering assistance were pending beyond the requested action rate.

,

!

i l

2.6 Control of Temporary Modifications l

The inspector reviewed the licensee's procedure for control of temporary modifications, which at PBAPS is called, " Temporary Plant Alterations" (TPA). This procedure, A-42, l

Revision 18, has been in effect at the plant since February 1,1993.

The procedure covers all temporary changes in plant systems and equipment, regardless of l

their classification as safety or nonsafety-related. The procedure is clear and specific, and l

establishes strict requirements and criteria for implementation and control, and assigned l

responsibility and authority.

2.7 System Engineering l

.

The inspector reviewed the role of system managers in monitoring the system performance, l

and assuring the safety of system operation and reliability. The inspector noted that the

system managers closely monitor the design, configuration, and performance of systems i

assigned to them. They monitor the performance trend, trouble-shoot any performance problem, and perform a periodic walkdown inspection of the system to assess the physical and equipment condition. The periodic assessment reports of the system performance by the I

.

_

..

-. -

-

-

-

-

-

.

-

. _.

.

-

!

system manager to the department manager were of high technical quality and indicated the l

close monitoring of the system operation and performance. The system managers actively

and effectively participate in the planning and design of any modification needed on their assigned systems. Such close monitoring of performance and reliability of system operations j

'

!

to assure safety is a strength of the PBAPS.

!

2.8 Engineering Initiatives i

2.8.1 Assessment of System Performance

The inspector reviewed a sample of engineering work that site engineering had initiated to

analyze and understand some technical problems to enhance the safety of the plant

operations, i.e.,1) flux tilt test using multi-channel analyzer, 2) excessive fluid usage in electro-hydraulic control (EHC) system, 3) feedwater heat inspection, testing, and failure j

analysis, and 4) evaluation of PBAPS wide-range level response during reactor scram.

l The inspector noted that these studies and analyses done by in-house engineers and consultants were comprehensive and of high technical quality. These efforts reflected the

licensee's engineering management's emphasis on the proactive engineering efforts to prevent unanticipated system problems and/or mitigate any identified precursor to develop into a

system problem. The reports reflected a thorough assessment of the system and associated

,

concerns, and emphasis on plant safety.

<

I j

2.8.2 Engineering Support to Unplanned Events The inspector reviewed approximately thirteen " PEP ISSUE" summaries. These reports covered the period of December 1993 to April 1994, and covered the following events:

.l e

ST-054-754-3,127-8 relay failed to actuate

]

HV-3-30-31896 was removed without print update e

cooling tower reliability below average j

l

PCIS group 2 and 3 isolation occurred on RPV low water level i

3B recirculation pump speed control erratic and sluggish j

3A recirculation pump partial runback while swapping 3G4 feeds

auxiliary boiler problems e

e conflicting ST results indicate RCIC flow controller may bc inoperable HPCI declared inoperable due to disconnected oil line

t e

% scram from 3A RPS M-G set voltage regulator failure j

incomplete emergency MCR ventilation sequence e

oil dip-stick from E-4 air compressor found on floor

)

-

w..

~

. -. - ~,. -,... -

i

.

5 In all of the above reports, the inspector found that the problem was clearly and concisely recorded, and the immediate corrective action was implemented and veri 6ed. The final analysis and disposition of the report indicated adequate technical analysis and evaluation, which included the probable cause, consideration of current and generic ramifications of the problem, and recommendation of corrective action to prevent recurrence of the same problem.

2.9 Review of Modification / Design Change Packages The inspector selected three modification / design change packages for a detailed review to ascertain the procedural and technical adequacy of design change, validity of technical analysis and safety evaluation, and general completeness of the packages. The design changes were as follows:

2.9.1 Replacement of Recirculation M-G Set The objectives of this modification were to replace the M-G sets with solid state adjustable speed drive (ASD) systems to improve the reactor recirculation system (RRS) reliability and availability. The new ASD systems operation will not require support from the service water system and M-G set lube oil system, will install a recirculation pump trip (RPT) system, and improve core thermal response to plant scrams.

The reactor recirculation system (RRS) consists of two recirculation pump loops external to the reactor vessel, which provide the driving flow to the reactor vessel jet pumps.

Each M-G set (two M-G sets per unit) utilizes a constant 60 Hz,4.16 kV power supply to produce a variable voltage and frequency power source for the associated recirculation pumps.

The new ASD systems is to produce a variable voltage and frequency power source for the associated recirculation pump.

2.9.2 Fire Alarm System Upgrade The objective of this modification was to upgrade the existing fire alarm system to correct a

" masking" problem that occurred when more than one alarming devices were in alarm condition, and to improve the system operation, maintenance, and reliability.

"

m

__

l l'.

!

l

!

l-2.9.3 Installation of Equalizing Line and Access Platform for Diesel Driven Fire Pump The objective of this modification was to install a 1%" diameter equalizing line for the Diesel Driven Fire Pump Test Header Discharge Valve, HV-0-37D-12301, to eliminate the i

j high differential pressure (dP) whenever the discharge valve must be opened to perform pump operability / performance testing. - Additionally, this modification would provide a permanent platform in the circulating water pump structure for valve

maintenance / performance testing and activities related to the fire protection system. To i

avoid inadvertent opening, this new valve will be locked closed and will be controlled by station procedures.

l In reviewing the design change package, the inspector noted that the modification packages were well documented and contained good safety analyses. Technical analyses and design i

bases were documented in detail, and the design and operating considerations were logically and clearly laid out. Post-modification testing also was specified in the design change package. The design change and the package was of good technical quality and well cantrolled.

2.10 Engineering Assurance and Self-Assessment The inspector reviewed documentation of nuclear quality assurance (NQA) oversight of PBAPS engineering activities. The results of these activities are documented in surveillance j

reports, monitoring reports, and audit reports. The inspector reviewed five audit reports by l

site QA of the onsite engineering activities at PBAPS, and three assessment reports by

corporate QA organization of the areas of engineering calculations, work procedures, and technical adequacy of modification design efforts for selected modifications. Additionally, a number of surveillance and monitoring reports generated by site QA were reviewed.

l The inspector noted that the audit and assessment reports were comprehensive and of high l

quality. The observations documented in audit reports and the assessments in the corporate l

assessment reports were significant, logical, and displayed 'a thorough understanding of the area audited.

'

The PBAPS engineering assurance program appears to be comprehensive and effective. The reports provide a clear discussion of the scope and results of each audit and assessment.

3.0 CONCLUSIONS Based on the above review of documentation, observations, and discussions with management and technical personnel, the inspector concluded that the licensee's engineering programs were satisfactory. The engineering department has effectively implemented a self-assessment program, which provides valuable insight into the program weaknesses before they become a problem and negatively impact the plant safety.

i I

l l

.

r

- -___ -__ _ -_ _.

.

.

In summary, the licensee design change and modification program is satisfactory, the organizational staffing and interface with other departments and groups are adequate to effectively perform its technical support mission and to maintain the plan's design basis.

4.0 MANAGEMENT MEETINGS The inspector met with licensee representatives at the entrance meeting on April 5,1994, and i

at the exit meeting on April 8,1994, at the Peach Bottom Atomic Power Station in Delta, Pennsylvania. The names of licensee personnel contacted is shown on Attachment A.

The findings of the inspection were discussed with licensee management at the April 8,1994, exit meetings. The licensee did not disagree with the findings of the inspector.

l i

i

.

-

- -.

.-

..

.. - -

-. -... -. -

.

.

.__

.

.

i

.

.

ATTACHMENT A Personnel Contacted

PECO Energy Company J. Armstrong Sr. Manager, Plant Engineering J. Carey PSE&G K.. Cutler Engineer, I&C A. Fulvio Manager, NQA J. Jordan Manager, Engineering Licensing D. Keene Manager, I&C Design Engineering

'

B. Knieriem DP&L D. McGinnis

' Reactor Engineer Manager R. McKinley Electrical I&C Branch W. Nelle lead Assessor, NQA T. Niessen Director, Site Engineering M. Snodgrass Sr. O.D. Consultant -

T. Wasong Manager, Experience Assessment C. Wiedersum Manager, Mechanical Design Engineering

'

Atlantic Electric H. Abendroth Atlantic Electric U.S. Nuclear Regulatory Commission P. Bonnett Resident Inspector W. Schmidt Senior Resident Inspector i

?

!

t --

.

..

.

.

.