IR 05000277/1997001

Insp Repts 50-277/97-01 & 50-278/97-01 on 970112-0308.No Violations Noted.Major Areas Inspected:Operations, Surveillance & Maint,Engineering & Technical Support & Plant Support

ML20140C671
Person / Time
Site:	Peach Bottom
Issue date:	04/14/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20140C669	List: IR 05000277/1997001 ML20140C663
References
50-277-97-01, 50-277-97-1, 50-278-97-01, 50-278-97-1, NUDOCS 9704170450
Download: ML20140C671 (31)

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l U. S. NUCLEAR REGULATORY COMMISSION i

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Rf.GION I i

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Docket / Report N /97-01 License Nos. DPR-44 1 i

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50-278/97-01 DPR-56 i t

Licensee: PECO Energy Company i

P. O. Box 195 j

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Wayne, PA. 19087-0195 i

Facility Name: Peach Bottom Atomic Power Station Units 2 and 3 ,, )

! Dates: January 12,1997 - March 8,1997 )

! i Inspectors: W. L. Schmidt, Senior Resident inspector

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l-l M. J. Buckley, Resident inspector  !

L A. Lohmeier, Senior Reactor Engineer  !

! D. Florek, Senior Operations Engineer  ;

L. Dudes, Reactor Engineer  !

l Approved By: M. C. Modes, Chief Reactor Projects Branch 4

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Division of Reactor Projects l

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) 9704170450 970414 PDR ADOCK 05000277 G PDR i i

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EXECUTIVE SUMMARY

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Peach Bottom Atomic Power Station

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inspection Report 97 01 ,

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This integrated inspection report includes aspects of resident and region' based inspection

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of routine and reactive activities in: operations; surveillance and maintenance; engineering '

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Overall Assurance of Quality:

, 4 Overall PECO Nuclear (PECO) operated both units very well over the period. Management ,

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and engineering responded well to equipment problem :

i PORC meetings were effective covering normal activities and in the review of overall plant l

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health and department specific plant equipment and performance issue ('

1 Plant Operations:

i Operators performed routine tasks well, documenting clear control room log entries and

action request (AR) information for equipment problems and associated operabiiity determinations. The observed operator turnovers indicated good information transfer and

! plant status continuity between shifts. Operators noticed several equipment operability J

issues during surveillance testing and properly documented them in AR i The licensee had effective procedures in place to restore the control rod drift alarms

function, and took appropriate actions to provide verification of rod position followmg i

. individual reed switch failure I

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' I Lack of attention to detail by a reactor operator caused a mispositioned control rod. This .

posed no significant risk to safety; however, it did reflect poor operator performance. The !

inspector noted that PECO took appropriate actions to address this isolated issu The licensee conducted the job performance measures (JPMs) for the requalification of j opcrators in a satisfactory and effective manner, noting weaknesses in performance for l

] feedback into the next requalification training schedul PECO implemented timely and effective corrective measures in response to a series of 5 procedural adherence event l

, Maintenance:

A review of Unit 3 high pressure coolant injection (HPCI) stop valve and E-1 emergency diesel generator (EDG) maintenance issues showed that previous troubleshooting and/or corrective actions did not prevent repeat equipment performance problems. in each case (HPCI Section M.3.2 and E-1 EDG Srtion E2.5) these issues did not affect the operability

of the systems when initially identif!- ! by operatcrs, but did result in another removal of

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the systems from service to allow corrective maintenance. This indicated the need for continued focus on the depth of troubleshooting and the effectiveness of correcting issues

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after an initial proble Engineers, operators, and technicians properly conducted surveillance tests, including the core. spray (CS) logic system functional testing (LSFT) at both unit The maintenance rule program appropriately determined maintenance preventable functional failures (MPFFs). Some additional care was needed to ensure that performance enhancement program (PEP) reports were properly coded with functional failures (FF) and MPFF data, and that plant level indicators contained specific plant transient and shutdown dat Overall the AR system functioned well, personnel documented problems properly and operations management provided good operability determinations. Some improvement was possible in the documentation on the ARs of actions, such as technical specification action statement entries, when equipment was found inoperabl Electricians properly followed procedures and were very knowledgeable during replacement of two safety-related 125 VDC battery cell PECO took adequate corrective actions and properly reported a condition where improperly calibrated feedwater temperature instruments caused indicated core thermal power to be-lower than actual. Improperly calibrated test equipment and failure to understand the effects of feed water temperature on core thermal power caused this event. The inspectors considered the review of the controls over use of test equipment and the failure to understand the effects of feed water temperature an unresolved item, pending additional -

revie Engineering:

The Core Engineering review conducted over the period found: ,

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e The engineering staff knowledgeable with respect to station systems and j procedure '

• The modifications, both temporary and permanent, prepared with sound technical l foundations and detailed implementation practice * The performance enhancement, non-conformance, and troubleshooting processes performing well, allowing engineering to identify root causes for problem l l

• Excessive vibration in the HPCI steam line was not an operability concern, but will l

remain unresolved open until the problem cause has been fully addresse With respect to recent equipment problems, the inspectors found that PECO took good actions to identify and resolve the causes and that engineering management provided excellent support for these troubleshooting activities. These issues included: repeated E-1 EDG power fluctuation while operating loaded in the droop mode, E-3 fluctuations while operating carrying a lightly loaded bus in the droop mode, drywell sump pump operating iii

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i problems, and HPCI stop valve and gland condenser gasket issues. The E-1 EDG power fluctuation would not have affected EDG operability in the accident mode of the machine.

! The inspectors concluded the engineering staff had aggressively addressed the previous

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post-modification problems and that corrective actions taken should prevent recurrences of

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these types of issues. Based on this review inspectors closed two violations which dealt with modification testing issues on EDGs and drywell leakage instrumentation.

i Plant Suooort:

, The inspectors completed numerous tours of the plant site, including the Unit 3 torus

! room. Generally, radiological conditions and postings were acceptable. However, there

! were instances where poor housekeeping lent to general clutter in several areas. Further, during observation of HPCI system pipe hanger installation in the Unit 3 torus room, the

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inspector observed workers using an area beyond a contaminated rope as a tool j storage / lay down location. This instance was minor, however, it indicated the need to

! reinforce the requirements for crossing a contaminated area boundary during work. The inspector discussed this weak performance with the radiation protection manager.

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, PECO performed wellin evaluating and responding to an unexpected reactor coolant i

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conductivity increase following a reactor downpower maneuver at Unit 3. PECO determined that the conductivity increase was most likely due to a control rod blade i leaking boron to the coolant. The inspector considered the issue unresolved pending review of PECO calculations and industry data in support of the effect that control rod 1 - boron leakage may have on the core shutdown margin required by technical specifications.

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The licensee took appropriate corrective actions as a result of finding a locked high

]  : radiation door unlocked, contrary to Technical Specification Section 5.7. This licensee-j identified and corrected violation was treated as a non-cited violation. The inspectors

! found that PECO was using a Draft NRC NUREG 1022 to justify not reporting this violation

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of the administrative section of technical specifications and considered this an unresolved l i item pending further NRC review.

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TABLE OF CONTENTS EX EC UTIVE S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii T A B LE O F C O NT E NTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v I O P E R AT I O N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . 1 02.1 Substitute Control Rod Positions - Unit 3 . . . . . . . . . . . . . . . . . . 1 04 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . 2 04.1 Inadvertent Control Rod Mispositicn . . . . . . . . . . . . . . . . . . . . . 2 05 Operator Training and Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 '

08 Miscellaneous Operations and issues . . . . . . . . . . . . . . . . . . . . . . . . . . 5 08.1 (Closed), Violation 96-04-01: Procedural Implementation and

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Adherence Deficiencies .............................. 5 11 M AINTEN ANCE AND SURVEILLANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 M1 Conduct of Maintenance and Surveillance . . . . . . . . . . . . . . . . . . . . . . 6

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M 1.1 125 VDC Battery Cell Replacement . . . . . . . . . . . . . . . . . . . . . . 7 M1.2 Surveillance Activities ............................... 7 M1.3 Maintenance Rule - Maintenance Preventable Functional Failures.......................................... 7 M 1.4 Action Request ( AR) Review . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 M2 Maintenance and Material Condition of Facilities and Equipment . . . . . . 9 M2.1 Inappropriate Procedure Temporary Change . . . . . . . . . . . . . . . . 9 M3 Maintenance Procedures and Documentation . . . . . . . . . . . . . . . . . . . 10 M3.1 (Open) Unresolved item 97-01-01 - Core Thermal Power Greater Than Technical Specification Limit - Due To improperly Calibrated Feedwater Temperature Instruments . . . . . . . . . . . . 10 M3.2 High Pressure Coolant injection Stop Valve Timing and Gland Condenser Gasket Failure - Unit 3 . . . . . . . . . . . . . . . . . . . . . . 10 lli ENGINEERING.............................................. 12 E1 Conduct of Engineering ............................. . . 12 E2 Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . 12 E2.1 Modifications .................................... 12 E2.2 Temporary Plant Alterations (TPAs) . . . . . . . . . . . . . . . . . . . 13 E2.5 Engineering Support of Facilities and Equipment . . . . . , . . . . . . 14 E3 Engineering Procedures and Documentation . . . . . . . . . . . . . . . . . . . . 17 E Commercial Grede Dedication . . . . . . . . . . . . . . . . . . . . . . . . . 18 E3.2 Vendor Manual Documentatier Control . . . . . . . . . . . . . . . . . . 18 E5 Engineering Staff Training and Qualification . . . . . . . . . . . . . . . . . . . . 18 E7 Quality Assurance in Engineering Activities . . . . . . . . . . . . . . . . . . . . 19 v

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TABLE OF CONTENTS (Continued)

E8 Miscellaneous Engineering Activities . . . . . . . . . . . . . . . . . . . . . . . . . 19 E8.1 (Open) Unresolved item 95-18-01 HPCI Steam Line Vibration .. 19 E8.2 (Closed) Violations 95-11-02 and 95-26-02; Emergency Diesel Generator inoperable and Drywell Drain Tank inoperable due to Modification Testing Deficiencies ................ . ... 20 E8.3 Design Basis Document Review ~ . . . . . . . . . . . . . . . . . . . . . . . 20 IV PLA NT S U PPO RT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............. 21 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . 21 l R 1.1 Review of Reactor Water Conductivity increase Following Load lg Drop - Unit 3 - (Open) Unresolved !!em 97-01-02- Effect of Control Rod Boron Leakage on Core Reactivity . . . . . . . . . . . . . 21 l R8 Miscellaneous Radiological Protection issues . . . . . . . . . . . . . . . . . . . 22 R8.1 Unlocked High Radiation Area Door and (Open) Unresolved item 50-277/97-01-03 Use of Draft LER Reportability .

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i SUMIAARY OF PLANT ACTIVITIES l l OPERATIONS

01 Conduct of Operations'

PECO Energy (PECO) operated both units well throughout the period with no significant

transients occurring at either uni Operators performed routine tasks well, documenting clear control room log entries and

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action request (AR)information for equipment problems and associated operability

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determinations. The observed operator turnovers indicated good information transfer and plant status continuity between shifts. Operators noticed several equipment operability  !

issues during surveillance testing and properly documented them in AR .O2 Operational Status of Facilities and Equipment  ;

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02.1 Substitute Control Rod Positions - Unit 3 i

! Scope:

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On February 21, during a tour of the control room, the inspector discussed the use of  ;

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substitute positions for control rods when the rod position indication system (RPIS) fails to provide reliable indication. The inspectors reviewed procedures and the impact of a substitute rod position relative to the required verification of rod position, and discussed  ;

this review with appropriate operations and engineering pertonne l

' Observations and Findinas: ,

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PECO properly controlled and monitored control rods 02-35, 34-11, 46-43, and 46-31 at Unit 3, each rod had a failed position 48 reed switch. Operations used approved procedures to:

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o Verify the position ni a rod after reed switch failure per abnormal operation procedure (AO) 62C. I- i t

e install a jumper to clear rod drift alarms at position 48, per AO 62C.3-3. The common rod drift alarm occurs whenever a rod does not have an even position indication or when it has an odd oosition indication, while the rod is not selected for movement. This procedure allows for the substitution of the installed fully withdrawn reed switch (position 49) to U ive a partial position indication, plus the normal red back light fully withdrawn indication, e input substitute rod position information into the rod worth minimizer (RWM) per AO 59A.2-3. This procedure allowed input of a maximum of 10 substitute control rod positions, t

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' Topical headingt such as o1, M8, etc., are used in accordance with the flRC standardized reactor inspection report outline. Individus! teports ara not expected to address all outline topic i e e a b

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Further, the inspector found that the rod drift alarm and the fully withdrawn roo back light >

indication on the full core display provided adequate indication for operations to conduct

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the technical specification (TS) required verification of control rod position every 24 nour ; Conclusions: {

The licensee had effective procedures in place to restore the control rod drift alarm function, and took' appropriate actions to provide verification of rod position when RFIS did not provide reliable rod position informatio Operator bowledge and Performance  ;

04.1 Inadvertent Control Rod Misposition - Unit 3  !

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On February 15, with Unit 3 at 100% of rated power, while performing ST-0-003-560-3, f

" Control Rod Exercise-Fully Withdrawn," the reactor operator (RO) selected control rod 58- )

39 and moved it in, from position 48 to position 46. Subsequently, after becoming !

distracted by a telephone cal l, the operator returned to the test and mistakenly moved ,

control rod 58-43 in, from position 48 to position 46, without first returning control rod 58-39 to position 48, Observations and Findinos: ]

The RO self-identified the mis-positioned control rod, entered the appropriate off normal procedure (ON), after dir.cussion with control room supervision (CRS) restored the control rods to their designated positions (fully withdrawn), and informed the on call reactor enginee The inspector found no safety significance to the mis-positioned control rod based on the ,

following: 1 e Rod movement was in the insert direction; I

e Each control rod won located at the core edge and had low rod reactivity worth; e The RWM allowed the rod movement since these rods are in the same rod group; i I

e Thermallimits were not affecte PECO took aggressive corrective actions through the initiation of a PEP (10006659) to ensure appropriate immediate actions, track the determination of a cause, evaluate the possible actions to reduce the distraction during performance of this test, and discuss the issue at manage'nent meetings and during shift turnove l

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3 Conclusions:

A lack of attention to detail by the RO in mispositioning a control rod posed no significant risk to safety. This, however, reflects poor operator performanc Operator Training and Performance 4 Scoce:

The inspector monitored operator requalification job performance measures (JPMs) on the morning of February 26 in the plant and at the simulato Observations and Findinas:

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The licensee conducted JPM testing at the simulator and simulated activities in both Unit 2 i and Unit 3 control rooms and plants. The PECO evaluator provided clear initial conditions, timely initiating cues, identified reference procedures, and kept a check off list as the operators performed the JPMs. Operators satisfactorily accomplished all critical steps and satisfied the pass criteria. The evaluator noted in the comments section of the JPM, that operators did not always fully performed all steps as expected to allow further feedback to the operators during subsequent training.

i Conclusion: l The licensee conducted the JPMs for the requalification nf operators in a satisfactory and effective manner, noting weaknesses for feedback into the next requalification training l schedul l l

07 Quality Assurance in Operations )

Plant Operations Review Committee Meetinas Scope:

The inspectors assessed the performance of several normally scheduled plant operations review committee (PORC) meetings (January 23,30, February 27, and March 6) and the l February Overview PORC meeting on February 10.

i Observations and Findinas:

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The membership requirements for a quorum were met in all cases. Of particular interest j were issues dealing with plant safety and the control of offsite releases: I

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• Modification (MOD) to allow burning of radioactively contaminated waste oilin a station auxiliary boile '

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• TPA to install a mechanical clamp and remove the normal recirculation pump speed control on the 2B motor generator se * Review performance enhancement program (PEP) 10006509 - Unit 2 ccre thermal power greater than license limit due to erroneous feedwater temperature instrument calibratio * Review of PEP 10006454 -lack of full understanding of MOD P00231 effect * Review of the 10 CFR 50.59 paperwork for the MOD P00086, which will construct the building housing the planned adjustable speed drives (ASDs).

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• The presenters of the items were well prepared and' presented the materialin a-logical manne * PORC members asked good questions and challenged the presenters to demonstrate

'that no unanalyzed safety effects would be possible as a result of the activities -

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• Discussion of the PEP issues appropriately focused on the interim and final corrective actions planned to prevent recurrenc * In review of the ASD building modification, PORC appropriately addressed lessons ;

learned from previous problems with possible unmonitored releases during the- j construction of the new plant access buildin l i

With respect to the Overview PORC meeting, topics included the standard plant tiealth l check and operational status overview, plus special update presentations on core reactivity 4 management, radiation protection issues, and PECO's response to the 10 CFR 50.54 (f) l letter, dated February 4,.199 * The presentations were well prepared and presente f i

• Plant health issues focused on problems that would have affected the ability of the .

units to respond to a transient. These included the unexpected need to remove the i 343 start up transformer from service due to a load tap changer problem; removal i of the E-1 EDG from service due to repeated KW fluctuations; and removal of the ;

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Unit 3 HPCI system from service due to fast operations of the steam stop valve and a leaking gland seal condenser gaske * Core reactivity management included recent problems with the plant thermal limits computer program, and a Unit 3 conductivity spike most likely caused by the wash- '

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out of boron from a damaged section of a control rod blad * The radiation protection department discussed the corrective actions for several recent issues including: improperly labeled radioactive material drums on the Unit 2 )

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refueling floor, a radioactively contaminated welding machine being found at a

. contractors facility, and improperly controlled master key ,

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j Conclusion:

[ PORC meetings were effective covering normal activities and in the review of overall plant I

health and department specific plant equipment and performance issues, j

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08.1 (Closed), Violation 96-04-01: Procedural Implementation and Adherence

. Deficiencies.

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! The inspectors reviewed PECO's corrective actions taken in response to violation 94-04-

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01, which cited three examples of failure to follow station procedures, specifically for:

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e The transfer of the Unit 2 B RPS power supply, using procedure SO 60F.6.A- i

• Control room emergency ventilation (CREV) visual internal inspection and installation of test equipment, per ST M-40D-905- ;

1 1 I * The control of secondary containment breaches, during chemistry sampling, per A-C-13 !

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i Observations and Findinas:

, With respect to the RPS MG set issue, in NRC inspection 50-277/96-04 the inspectors

. closed LER 50-277/96-006 for this event finding PECO's corrective actions acceptabl With respect to the CREV issue, the licensee took the following corrective actions:

e A permanent procedure revision TC 96-205 was initiated and approved prior to continuation of the tes * PECO reviewed similar filter efficiency testing and found other procedures needing ]

changes before being performed These revisions included a review by the vendo I e Management expressed their expectations for procedure adherence by vendors and use of a Level 1 procedure for the testing tea PECO, with respect to the secondary containment control issue, implemented several corrective actions, which included the follmving:

e immediaieiy closing door #437 and informing the shift managemen * The personnel working on the roof were briefed on A-C-134 requirements regarding breach of hazard barrier , . . .- .- - .

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• The security guard posted on the 234' elevation, below the roof hatch, received a f

briefing to insure that the door remained closed except for passag !

• The plant procedures GP-16 and CH-428 were changed to clearly identify the result and requirements for opening door #437 and #43 ,

4 * Keys for doors #436 and #437 now have tags that alert security personnel at the

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guardhouse, that to obt::in either of these keys requires a current copy of GP-16 ;

i and shift supervision approva :

In each example of this violation, PECO took immediate actions following identification and j effective long term actions followed to prevent recurrence. Although PECO found no l underlying cause for these failures, an all-employee meeting on August 9,1996, included a discussion of the implementation of procedures, specific examples, and PECO management

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communicated their expectation for procedure usage, compliance, and the importance of -

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Conclusions

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PECO implemented timely and effective corrective measures in response to a series of

procedural adherence event ;

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11 MAINTENANCE AND SURVElLLANCE i l M1 Conduct of Maintenance and Surveillance 2 1

, in review of the maintenance activities conducted over the period, the inspectors noted l

that the Unit 3 high pressure coolant injection (HPCI) stop valve (see Section M3.2) and E-

{ 1 emergency diesel gevierator (EDG) issues (see Section E2.5) appeared to be repeat

, problems. While each of these issues did not affect the operability of the systems when i initially identified by operators, they did cause another removal of the systems from service to allow corrective maintenance. Further, the repetitive nature indicated that previous i troubleshooting and or corrective actions did not fully identify or correct all the equipment performance issues.

! The inspector observed the core spray (CS) logic system functional testing (LSFT) at both units, finding the engineering, operations and instrument and controls personnel did a very good job, properly following the procedure and employing good communications i techniques. A sample of selected tested relays indicated proper testing of safety functions i in accordance with TS.

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M1.1 125 VDC Battery Cell Replacement Unit 2 Scope: ,

On February 19, the inspectors observed _ the performance C en at power replacement of cells 7 & 8 of the 2A 125 VDC station battery using procedure M-057-013, "125 Volt Station Battery P.emoval; Replacement and Cell Post Cleaning During Shutdown or At Power." The battery cells were replaced because of scale buildup at the bottom of the plate Conclusion:

The inspectors found the work to be performed professionally. The observation included the positioning and jumpering of the spare parallel bank of battery cells, wh'ch meintained ;

the battery capable of performing its safety function during the cell replacemen i Technicians used the work package with great attention to detail and demonstrated ,

experience and knowledge of their assigned tasks. Supervisors and the system manager monitored the job's progres .

M1.2 Surveil:ance Activities

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The inspectors observed the conduct of portions of the following surveillance test, identifying no negative issues:

o CS LSFT Unit 2 and 3 e EDG Testing e HPCI Cold Quick Start >

i e RCIC Inservice test (IST)

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M1.3 Maintenance Rule - Maintenance Preventable Functional Failures Scope:

To determine the effectiveness of equipment performance monitoring for systems, structures and componente (SSCs) using the maintenance rule, the inspector reviewed several PEP functional failure (FF) and maintenance functional failure (MPFF)

determinations, and the maintenanca rule quarterly reports for the last thrae quarters of-1996. The inspector also discussed the identified MPFFs with the maintenance rule coordinator and the operational events coordinator, O6servations and Findinos:

l The PEP system provided the documentation for FF and MPFF determinations:

e The threshold for the review of equipment failures appeared prope j

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e inputting of a FF and/or MPFF designator in a searchable field, once determinations were made, allowed personnel to search to find FFs and MPFF over any given

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• Several MPFF determinations as documented in completed PEP evaluations were not in the searchable field. PECO, subsequently, properly updated these fields.

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However, this did not appear significant, but additional review / oversight may be .

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4 * Based on a review of six PEPS, FF and MPFF determinations were well documente This included why or why not a FF or an MPFF occurre ,

in review of the last three quarterly maintenance rule reports for 1996:

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4 o S.SCs designated for enhanced monitoring under section (a)(1) of the maintenance ( rule were listed clearly. Further, the engineering department's equipment focus list i contained the MPFFs for the last 24 months and the (a)(1) SSCs to ensure the

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tracking and trending of needed corrective action * PECO determined that several human errors during maintenance caused loss of system function or actuation of safety systems and coded them appropriato!y as i

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MPFFs. The inspector noted three such examples in the recent 24 month With respect to plant level monitoring of system i l

c The determination that an MPFF did not occur with respect to a Unit 3 -loss of i offgas system train, appeared proper. The system manager did note that the i resulting reactor downpower would be tracked in the unit capacity factor indicator, j The inspector iound that this indicator was developed based on the daily monitoring !

of generator output, and that only large magnitude losses were specifically addressed. This could result in lower level losses not being tracked or trende !

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1 * The two Unit 2 reactor scrams during October 1996 were not shown in the forced i outage rate performance indicator. These had been missed apparently due to a clerical error. PECO, subsequently, updated the indicator. Based on this, the 1 3 performance criteria was not exceede l

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The maintenance rule and operational event coordinators were very familiar with individual equipment and human performance issues, the FFs and MPFFs, and the corrective actions

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" Conclusions:

l The maintenance rule program for determining appropriate MPFFs. Some additional care was needed to ensure that PEPS were properly coded with FF and MPFF data, and that the plant levelindicator contained specific plant transient and shutdown dat . . .

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M1.4 Action Request (AR) Review: Scoce:

The inspector reviewed the use of the AR system in the documentation of plant problems / conditions and the resulting operability determination Observations and Findings:

Based on a detailed review of one week's worth of ARs (greater than 150 individual items):

• Plant personnel used the AR system appropriately to document equipment and system performance problem * The operations crew documented good operability determinations, when neede ,

• When equipment was determined to be inoperable, there was variability in the amount of information provided, in some cases, the TS actions statement was referenced, and in others, it was not. While the inspector did not note any instances where that appropriate TS was not entered, the documentation on the AR should be consisten Conclusions:

Overall, the AR system functioned well, personnel documented problems properly and cperations management provided good operability determinations. Some improvement was possible in the documentation of actions on the ARs, such as technical specification action statement entries, when equipment was found inoperabl M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Inappropriate Procedure Temporary Change Scope:

The inspector reviewed the generic actions taken by PECO to address a previous issue with an inappropriate temporary change to a procedure, caused by an ineffective review of the Updated Final Safety Analysts Report (UFSAR). The specific issue dealt with battery cell charging and the UFSAR limit on terminal voltage, and was treated as a nurcited violation ,

in NRC Inspection 50-277/96-0 Conclusion:

Based on interviews with shift supervisors and engineers, PECO adequately reinforced the need and importance of reviewing existing design basis documentatio Further, the previous specific corrective actions for the battery cell charging issue remain in effect and are adequat . . - - . -.

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M3 Maintenance Procedures and Documentation j

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M3.1 (Open) Unresolved item 97-0101 - Core Thermal Power Greater Than Technical Specification Limit - Due To improperly Calibrated Feedwater Temperature j Instruments '

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l The inspectors reviewed PECO's identification on Smuary 21 that Unit 3 had been operating with inaccurately calibrated feedwater temperature instruments since June 12, l 1995. The instruments indicated 5 F higher than actual temperature. Since the feedwater instruments provide an input to the core power calculation program (heat balance), this resulted in calculated core power being less than actual core power, and i while operating at an indicated power of 100%, actual power was greater than 100%. l PECO classified the magnitude of the power indication error as 0.6%.  ! Observations and Findinas:

PECO properly identified the issue after a scheduled calibration of the feed instrurnents l caused an increase of indicated reactor power above 100%. Operators reduced power  !

appropriatel The PECO investigation into this issue (PEP 10006509) was thorough and included good discussion of root and contributing causes for this problem. Interim corrective actions appeared appropriate. PECO, subsequently, submitted LER 50-278/97-01 documenting the event, in accordance with 10 CFR 50.7 Of particular interest, PECO determined that lack of knowledge and reference document regarding how feedwater temperatures could affect core power was a major contributo Further, due to this lack of knowledge, prior identification of an inaccurate test device used to calibrate the feed temperature instruments in 1995 was not linked to having an effect on core powe Conclusion:

PECO took adequate corrective actions and properly reported this event. However, the inspector considered the knowledge of plant instrumentation inputs that could affect core thermal power and the controls over use of test equipment an unresolved item, pending additional review. (Unresolved item 97-01-01)

M3.2 High Pressure Coolant Injection Stop Valve Timing and Gland Condenser Gasket Failure - Unit 3 The inspectors reviewed PECO's corrective actions resulting from a January 21 fast opening of the Unit 3 HPCI steam stop valve, and the subsequent failure of the gland exhauster condenser cooling water gasket. The inspector noted that this event repeated an August 1996 event. Following the August event, the inspectors, as documented in NRC Inspection Report 60-277/96-06, noted that PECO had not been following the

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recommendations of a GE service information letter (SIL), dealing with establishing the f steam stop valves' balance chamber pressur l

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Following the recent fast opening of the valve and the gasket leak, the operator properly

' secured the system.

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. PECO took good actions to evaluate the cause for this repeat issue, determining that the i ' temperature of the stop valve's balance chamber had a direct effect on the steam pressure in the balance chamber and thus on how fast the valve opened. If the pressure was .

established near the lower end of the acceptable band with the valve warm, as the valve .l'

' cooled, the pressure would decrease due to the effect of having to re-warm the valve j body, thus the valve may open more quickly. PECO reset the valve pressure to the high l end of the acceptable band, and installed instrumentation recommended by the GE SIL to ,

monitor valve position verse balance chamber pressure. Subsequent testing, after allowing

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l 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the system to cool to ambient conditions, demonstrated adequate balance l

chamber pressure and valve movemen .l PECO determined that the gasket failure was due to over-pressurization of the condenser 7 cooling water as the turbine came up to speed quickly following the quick opening of the l stop valve. This possibility was discussed in the GE SIL. PECO believed, as they had  !

previously, that correcting the stop valve problem will also correct the condenser over- l pressurization problem. However, PECO was reviewing the need to install a modification -l to the cooling water line as discussed in the GE SI j The inspector agreed with PECO's determination that the stop valve quick opening and the gasket failure would not have prevented designed system operation, and therefore this war not an MPFF. However, the inspector did note a negative issue during this review, i specifically during the October 1996 HPCI quarterly TS testing, operators noted that the J valve opened quickly on the first turbine run, but not during subsequent runs. The ]

operator documented this on an AR, along with a determination that the system was i operable. However, the operators did not document generation of this issue in the control room log. At that time, since the relation between valve temperature and balance chamber ;

pressure was not understood, PECO choose not to perform any corrective maintenanc Conclusions:

PECO took adequate actions to resolve the fast opening of the HPCI turbine stop valve and I to improve the monitoring of the balance chamber pressure. Ho vever, this was a repeat problem, that resulted in the system again being removed from service to allow corrective maintenance. Further, a fast opening of the valve during the October 1996 surveillance test could have been documented better and could have lead PECO to the same conclusion reached following the January 1997 tailur l

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111 ENGINEERING E1 Conduct of Engineering The engineering division director and the inspectors discussed the performance trends of engineering activity indicated in the PBAPS Monthly Update Report, December 1996,

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Performance Indicator Summary. The inspectors noted continuation of the wide scope of performance trends monitored by PBAPS engineering that provide for direct or indirect assessment of engineering activity. Review of gross power generation charts for 1996 and licensee ovent reports did not indicate any focused cause of power interruption resulting from ineffective engineering. Open non-conformance reports were reduced, electric diesel generator unavailability improved, and temporary plant alterations installed showed significant reduction E2 Engineering Support of Facilities and Equipment E Modifications Scope:

The number of modifications being planned and implemented at the PBAPS has been reduced since the last SALP cycle. The inspectors reviewed the procedures required for plant modifications and selected two safety-related rnodifications for a detailed revie The inspectors measured the adequecy of the modifications using technical proficiency, proper safety pesspective, and regulatory guidelines as criteria. The following modifications were chosen:

• ECR 96-00776, " Unit 3 HPCI Steam Supply Line and Drain Pot Line Shake." (MOD-P00634);

• ECR 95-04972, " Unit 2 Core Spray Downcomer Repair," (Mod P00335) Observations and Findinas:

The Unit 3 hPCI steam supply line continues to experience vibration at the main stearn line junction. ,P PECC engineering staff has performed a stress analysis on the piping to assure opebility (see Section E.8). While the PECO engineering staff has determined that the vibrations are acceptable for continued operation, a modification program was developed to reduce the vibratory effects on the steam line. This includes three phases that will reinforce existing piping supports, provide for additional supports, and alter the configuration of the drain line to reduce the vibration. Specifically,6 rigid supports will be added to the 10-inch steam line,3 existing springs will be replaced with rigid struts, and 1 spring will be removed. These tasks will be performed while the HPCI system is in hot stand-by, in a manner that avoids system inoperability. Once the supports have been installed or altered, PECO engineering personnel will then monitor the system to determine if the vibration has been reduced to an acceptable level. If necessary, the drain line piping will be shortened and the test line contcining valve 3-23C-31171 will be removed to ;

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increase the rigidity of the line. Since the function of the test line can be duplicated via another flow path, there is no compromise to safety when it is remove The inspector found the 10 CFR 50.59 review and ensuing safety evaluation to be thorough, clear, and demonstrativa of a sound technical approach to the problem. The ;

modification engineering change request (ECR) also included stress calculations, design '

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input documents, UFSAR updates, ' revisions to the ISI program and plant support documentation, such as fire and radiation protection documents. The package was reviewed and no safety cr regulatory issues were identified. However, the complex nature

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of this problem requires that PECO engineering be diligent in its review and implementation of this modification, and all the engineering assumptions used to support the modificatio The inspectors also reviewed the contingency plan for the repair of the Unit 2 core spray I downcomer. A similar repair was implemented in Unit 3 during the last refueling outag l'

The purpose of the modification was to ensure the structuralintegrity of the core spray downcomer in the event crack indications were detected during the NRC Bulletin No. 80-13 augmented ISI examinations. The modification for Unit 3 was reviewed in NRC inspection :

50-278/95-18 and found to include sound engineering and planning. The contingency l modification was not implemented for the Unit 2 downcomer during the 2R11 outag Conclusions:

The number of safety-related modifications at the PBAPS has decreased significantly. The modifications reviewed were well planned and were demonstrative of sound engineering practices. The FECO engineers interviewed had extensive knowledge of all aspects of the modifications and displayed a strong technical proficiency. No safety or regulatory issues were identified during the modifications revie .

E2.2 Temporary Plant Alterations (TPAs) Scope: ,

There has been a significant red Jction of TPAs over the last SALP cycle. The inspectors reviewed the procedure engineer;ng parsonnel follow for planning and implementing TPAs (MOD-C-07, Rev. 2). The following TPA packages were reviewed in detail:

• ECR No. 96-01965, " Spurious A/C Station Battery Ground Alarm"

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• ECR No. 96-03053, " Remove Atarm Input Indication for RV-71D Bellows Leakage"

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• ECR No. 97-00196, " Unit 3 HPCI Stop Valve"

• ECR No. 96-01155, "TPA to Support Service Water Pump Operation During HPSW Maintenance"  !

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14 Observations and Findinas: ,

The procedure was clear, thorough, and reflected a well thought out implementation pla The inspector reviewed the ECRs for the TPAs currently installed in the two units. During a walkdown to verify that the TPAs had been installed in the plant with the appropriate '

, equipment, jumpers and leads that were clearly marked and required documentation was in the control room, the inspector concluded that all elements of the procedure had been

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completed. The responsible engineer for ECR 96-01965 and 96-03053 was interviewed

because both ECRs impacted a portion of the safety relief valve power and logic syste The engineer explained the technical issues associated with the two ECRs and satisfied the

inspector that there was no common link between the two problems, and the function of ;

the SRVs was not compromise l

. Conclusions:

The TPAs reviewed were examples of good engineering practices and implementation of lessons learned. The packages were all thorough and could be easily verified via independent walkdowns, discussions with responsible engineering staff and documentation review. No safety or regulatory issues were ldentified as a result of the TPA audi !

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, E2.5 Engineering Support of Facilities and Equipment i Scoce:

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The inspectors reviewed equipment issues in which PECO engineering had a significant part of the investigation and evaluation, including several problems with EDG load fluctuations end HPCI stop valve issues.

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Recent Eauipment Problems: l e (Closed) Unresolved item 96-09-01 Emergency Diesel Generator Power Fluctuations l

l As discussed in NRC Inspection Report 50-277/96-09, on December 10 and December 27, l 1996, the local and control room operators observed power swings of approximately 250 KW and frequency fluctuations (60.5 to 59.5 Hz) when increasing and decreasing i generator load through its mid range (1200-1450 KW). Although PECO determined that i the observed power and frequency oscillations were not an operability issue because the l power oscillations only affected the EDG power at the lower to moderate loading ranges, the licensee had yet to determine the cause. This issue remained unresolved pending NRC !

review of PECO's actions to determine the cause, corrective actions, and the possible l affects on the EDGs capability to perform its safety functio Following the performance of ST-O-052-201-2, "El DIESEL GENERATOR LOAD RUN," on January 24, PECO declared the EDG inoperable due to observed power swings of 200 to 300 KW while increasing load, 500 KW at rated load, and a 500 KW during shutdow PECO made this decision due to a lack of confidence in the ability of the machine to l

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respond to an accident in the isochronous mode, and possible inability to control bus !

frequency to allow re-powering a 4KV buses from off-site power following a los Initially, PECO instrumented the EDG governor control and in consultation with the Woodward Governor Corporation representative found the governor operating as expecte After a load run of the diesel on January 25, with " FUEL OIL LOW PRESSURE" and "DC FUEL OIL PUMP RUNNING" alarms, and a noted pitch change in the EDG operation, PECO investigated the possibility of a fuel oil problem. The subsequent replacement of the engine drive fuel oil pump relief valve (RV-0571 A) resulted in successful test runs on January 28,1997. PECO declared the E1 operable, but decided to test it on a weekly basis to ensure early detection of any problem not identifie On February 4, PECO again declared E1 inoperable following a load swing from 200KW to 2600KW and back to 200KW in a several second period. Review of test data showed no fuel oil system perturbations. PECO decided to replace the electric (EGA) and mechanical (EGB) speed governor assemblie The inspector observed the EDU testing following governor rep!acement, finding good operations, engineering r.nd maintenance communications and support. System manager management support was excellent during this trouble-shooting activity. During a test run following governor replacement, PECO identified fluctuating voltages around a closed contact in the governor droop /isochronous conversion relay (CCCR), while in the droop mode. PECO replaced this relay speculating that these voltage fluctuations were caused by changing contact resistence and that this feed back into the electronic governor circuit was causing the load swing The inspectors found that the EDG would have been capable of performing its safety function even with the observed load fluctuation in the droop mode. Further detailed troubleshooting was needed to identify the problem with the CCCR relay due to the complex nature of the control systems. The inspectors also noted that during previous troubleshooting in December 1996, PECO had looked at the CCCR relay and performed a static contact resistance check, identifying no problems. However, the inspectors were concerned that the load fluctuation repeated itself and that if more detailed troubleshooting had been conducted during prior instances, additional EDG out-of-service time could have been avoide * E3 Emergency Diesel Generator Parameter Fluctuations On March 6, operators declared the E-3 EDG inoperable because of observed fluctuations in generator output load (50 KW), frequency (0.5 Hertz), current (10 amps), and voltage while the only supply to the E-32 bus in the droop mode. The EDG was under a low load condition (350 Kw) while supplying the E-32 bus. These fluctuations were repeated during a test run of E3 on March 7, while instrumentation recorded data for engineering evaluation. Since this condition had not been observed on the other EDGs, engineering determined no cornmon cause failure had occurred, and the other EDGs remained operabl Engineering's evaluation of test data indicated that the fluctuations observed showed only a minor instability of the EDG governor, well within the design criteria, and would not

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adversely affect the overall operation of the governor control system transient respons To further confirm this evaluation, PECO performed ST-O-052-123-3, "E3 D/G RHR Pump Load Reject Test," followed by RT-O-053-203-2, "E3 Diesel Generator Load Run," with Sdtisfactory results.

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PECO returned the E3 EDG to operable status on March 7. Engineering believed the governor tuning scheduled during the 18 month overhaul and inspection starting May 11, 1997, will enhance the low load stability characteristics of the E3 EDG. The E3 EDG will continue on its normally scheduled testing frequenc * Drywel! Equipment Drain Sump - Unit 2 Control room operators noticed since the Unit 2 refueling outage, that the drywell equipment drain sump "A" pump was not pumping, possibly due to a broken motor to .

pump coupling. Further, they noticed that the "B" pump was short cycling (not pumping the entire contents of the equipment sump) once it started, and that a hi-hi level alarm occurred every other time the pump started, i

, The system manager for the drywell sumps analyzed the conditions and determined that there was a possible problem with a flow restriction in the 4" pipe that connects the i equipment sump to the separate drain pump sump outside the shield wall. This restriction would account for the short cycling of the pump. Further, he determined that the lead / lag pump start circuitry and the fact that the A pump was not operable led to the hi-hi sump l level alarm every time the B pump was called upon to start as the lag pump (i.e., every l other time the sump required pumping). l l

The system manager prepared a TPA, which modified the lead / lag circuit to allow the B I pump to start on the hi-hi level signal, and placed a time delay in the circuit to prevent the j hi-hi level alarm if the B pump was pumping down the sump, but which would alarm if the )

pump was unable to lower the level below the alarm setpoin I The PORC discussion of and presentation of the TPA were effectiv l The inspector reviewed the completed TPA installation documentation in the control room I and found it in proper orde PECO plans to keep this TPA in place urtil a forced outage or until the next refueling l outage. At which time, the A pump and the blockage in the 4" line will be evaluate Conclusion:

The inspectors concluded that PECO took good actions to identify and resolve the cause of l for the equipment problems discussed above. Engineering management provided excellent support for these troubleshooting activitie With respect to the E-1 EDG issue, the inspector determined that the load fluctuation with the EDG operating in the droop mode would not have been an issut: while operating in the safety-function mode (Isochronous), and closed Unresolved item 96-06-01. Further, PECO

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took very aggressive actions following the February 4 repeat of load fluctuations, including detailed monitoring of electrical control signals. However, it concerned the inspector that the problem with the CCCR relay could have been identified and corrected earlier, supplanting the need for additional EDG out-of-service tim The E3 EDG was capable of performing its safety function even while declared inoperable by PECO for load / frequency oscillations, while in the droop mode carrying only the safety bus, PECO engineering was aggressive and conservativa in its safety focus while confirming the operability status of the ED The system manager properly addressed an operator identified operational issue with the Unit 2 drywell equipment sumps, using a TPA. The TPA evaluations and installation documentation appeared appropriat As discussed in section M3.2 above the HPCI system manager performed wellin identifying the ceuse for a repeated problem with the stop valve operatio E3 Engineering Procedures and Documentation Scope:

The inspactors reviewed the following procedures widely used in the engineering organization to evaluate safety perspective and adherence to regulatory requirements and commitments. For each procedure reviewed, the inspectors chose examples of work packages that exhibit the completed procedures:

• PEP program, (LR-C-10, Rev. 5)

e Control of Non-conformance (NCRs), (A-C-901)

• Troubicshooting; Minor Hework; and Testing Support Process, (A-42.1, Rev.6) Observations and Findinas:

The inspectors selected several hardware failures and operational events to evaluate the effectiveness of the PEP program, which included root cause analysis and provided for enhancement recommendations to all plant orgrinizations. Three PEPS were examined during this inspection. The first, PEP 10004829, detailed the investigation of an excessive vibration level on a reactor feedpump due to a loose part lodged in the pump impeller. PEP No.10004816 provided a post scram review which attributed a " turbine overspeed signal" as the cause of the transient. Lastly, PEP No. 10006281 outlined the sequence of events in which the average power range monitors (APRMs) were calibrated using non-conservative core power thermal values. Each PEP provided detailed issue descriptions, immediate corrective actions, root cause investigations, and evaluation descriptions that recommend long term corrective actions. The inspectors found the PEPS to be comprehensive documents that allow for pro-actively improving plant performance after each event or identified non-conformanc The inspectors reviewed the NCR procedures and the listing of all outstanding non-conformances, and no regulatory issues were identifie . - - - .. . - - . -- . . . - - ..~... _ . - -- - - ..~.-. .

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1 . . In order to ensure that the plant configuration was not altered without proper L documentation, the inspectors reviewed the engineering trouble shooting procedures and

-l examined ~a few examples of these activities, which were found to be performed .

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E3.1 Commercial Grade Dedication i 1 l

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1- The governing procedure for commercial grade dedication (CGD) (NE-C-270, Rev.2), the j i o administrative guidelines outlining management expectations (NE-CG-270, Rev.1) and the j i sampling plan for item acceptance (P-CG-3, Rev. 0) were reviewed by the inspecto l l Furthermore, several CGD packages were examined to assess adherence to the procedures l

and the quality of engineering in the process.

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[ Observations and Findinos ' '5

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Upon review of the CGD material evaluations, one example of a failure to follow a l

} procedure was identified. The failure modes for a check valve being dedicated for use in '!

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the diesel air starting system (ECR 96-01160) were not fully addressed as required in the j

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procedure. The inspectors concluded that the PECO engineering staff failed to document  :

i step 7.3.1, item No. 4 when performing a commercial grade dedication of a diesel  !

generator starting air check valve, per procedure No. NE-C-270, Rev 2. This constitutes'a  ;

violation of 10 CFR 50, Appendix B, Criterion V, " Procedures." The licensee identified the ]

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failure to follow procedure prior to placing the check valve into service in the plant. A l

' revised CGD package was issued addressing the failure modes of the valve. Additionally,  ;

• tha licensee has addressed the procedural error generically in a PEP action. This licensee- 1 identified and corrected violation is being treated as a non-cited violation consistent with l j Section Vll.B.1 of the NRC Enforcement Polic !

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j E3.2 Vendor Manual Documentation Control

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The inspector reviewed the control of vendor manuals. An adequate system is in place to ensure the continuous control of changes in equipment documentation.

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.1 E5 Engineering Staff Training and Qualification

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t The inspectors reviewed the qualification manuals for the component and mechanical j design engineering sections. The inspectors also interviewed several system engineers to I assess their education, training, and knowledge related to their system responsibilitie ' Observations and Findinos: i

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The inspectors found the training and qualification process to be consistent with the requirements of the activities'to be performed. The engineers and system managers  !

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interviewed displayed competence, technical ability, and a positive system ownership ,;

attitude of their systems and program *

E7 Quality Assurance in Engineering' Activitic '

The inspectors reviewed a summary of reports issued by the independent safety -

engineering group (ISEG) and nuclear quality assurance engineering oversight grou i Examination of several reports by the inspectors found that issues had been j comprehensively addressed and appropriate corrective action taken in resolution of the- 'l report finding i

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E8 Miscellaneous Engineering Activities i k

E8.1. (Open) Unresolved item 95-18-01 HPCI Steam Line Vibration

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,The inspectors reviewed the status of the HPCI steam line vibration problem first identified )

by the resident inspectors in 1994. Regional inspectors reviewed the vibration problem - 1 and PECO's exploratory analysis in 1995 during a routine engineering inspection. At that '

time, PECO engineering had not fully implemented a plan to address the excessive vibration f and the inspectors left the issue unresolved (URI 95-018-01).

During this inspection, the inspectors met with the engineering team assigned to address >

the vibration problem. The licensee discussed a modification plan to provide pipe supports to reduce the level of vibration. The plan also included installation of vibration ~ sensors on the main steam line, believed to be the source of the vibration. The inspectors reviewed a i

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comprehensive stress analysis with results that concluded the level of vibratory stress was below that which could cause fatigue failure and inoperability of the HPCI syste Observations and Findinas: l l

The inspectors recognized that the complex geometry of the pipe line and the multiplicity  !

of supports presents a difficult analytic problem to assure that the stress computation is l sufficiently precise to provide assurance of fatigue failure resistance. The vibration l appears to be severe based on the subjective observations made by resident and regional l inspectors. There has been observation of minor damage to supporting systems that could become generally more significant. At present, there are no known vibration standards that encompass this type of pipe vibration, other than comprehensive pipe system stress  !

analysis. This type of vibration has been experienced at another boiling water reactor facility, and the source of vibration identified. At that facility, changes in the main steam flow system were made to eliminate the vibration proble I Conclusions:

Based on the satisfactory results of the PECO stress analysis, the inspectors had no 1 disagreement with the current operability of the systems. However, since the vibration i severity had not been reduced, and the source of vibration has not been ascertained, URI  !

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95-018-01 will remain in effect pending determination of the cause of vibration and, either reduction of the vibration or further justification of the long term acceptability of this conditio E8.2 (Closed) Violations 95-11-02 and 95-26-02: Emergency Diesel Generator inoperable and Drywell Drain Tank inoperable due to Modification Testing Deficiencies Scope:

The inspector reviewed that programmatic corrective actions taken by PECO in response to these two violations, which both involved failure of modification acceptance testing to identify modification deficiencies. These violations affected the operability of technical '

specification required emergency diesel generators and drywell leakage monitoring systems. The main action taken by PECO included development and issuance of a new procedure:

I e Maintaining Configuration Control of Design Changes, (AG-123, Rev. 2)

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The inspectors reviewed AG-123, and to ensure consistent implementation of these  ;

guidelines completed a detailed review of modification type work package J Observations and Findinos: i AG-123 presented a reasonable approach to ensure that post-modification test;ng included all areas actually modified by work activities to ensure the reverification of design function )

The inspector noted no deficiencies during review of two modification activities: 1 e ECR MOD-5384, " Vent Stack Modification," l iI e AR A0942865, " Test Plan to Support Conduit Removal for the E2 Diesel Generator

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Bearing Replacement." j

Engineering personnel had a high level of sensitivity to the comprehensive checklist and 1 design reviews recommende The guidelines in AG 123 will be placed in the engineering modification manual to eliminate a procedure that is not common to both PECO nuclear unit Conclusion: j

The inspectors concluded that the engineenng staff had aggressively addressed the previous post-modification problems, and that corrective actions taken should prevent '

recurrences of these issues. The inspector considered both of these violations close I

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E8.3 Design Basis Document Review The licensee has completed the major part of the program to provide a design basis document (DBD) consistent with the technical specifications and plant operation. The inspector reviewed the DBD with a sample investigation of the source of the requirement to limit the startup and cool-down heating rates of the reactor. The inspector found that j the source was indicated in the DBD and was further provided on the computerized PIMS l system. The licensee is presently reviewing the DBD to improve its system of referencing related documentatio IV PLANT SUPPORT

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R1 Radiological Protection and Chemistry (RP&C) Controls The inspectors completed numerous tours of the plant site, including the Unit 3 torus j room. Generally, radiological conditions and postings were acceptable. However, there were instances where protective clothing was left at or near step-off pads, which lent to general clutter in several areas. Further, during observation of HPCI system pipe hanger j installation in the Unit 3 torus room, the inspector observed workers using an area beyond

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a contaminated rope as a tool storage / lay down location. This instance was minor,

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however, it indicated the need to reinforce the requirements for crossing a contaminated area boundary during work. The inspector discussed this weak performance with the radiation protection manage R1.1 Review of Reactor Water Conductivity increase Following Lond Drop - Unit 3 -

(Open) Unresolved item 97-01-02 - Effect of Control Rod Boron Leakage on Core Reactivity 1 Scope:

The inspectors reviewed PECO actions taken following an unexpected reactor water conductivity increase following a February 1 Unit 3 load drop. PECO documented these actions in PEP 1000657 Observations and Findinas:

When the operators noticed the conductivity increase, the chemistry department took good actions to evaluate its caus PECO correlated the conductivity increase with control rod movement and speculated that a control rod may have leaked, introducing boron and lithium into the coolant causing the increase in conductivit Additional reactor coolant samples and trending of the conductivity showed initially high lithium concentrations, which decayed off as the reactor water cleanup system removed the impurities. This also indicated that the leakage had reached some lower steady state rate below that which occurred during control rod movemen . .-- - . . .-.

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However, coolant analysis did not identify tritiunt which would be expected to leak from a i control rod the first time a leak path was establishe PF.CO initiated a non-conformance report (NCR) that documented an initial determination  ;

that If the conductivity increase had been caused by a control rod leak, the amount of 2 ooron that leaked out would not have been significant with respect te maintenance of the 1 core shutdown margin.

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l PECO also determined that the control rod that was being moved at the time of the initial J increase had the most exposure of allin the cor ;

' Conclusion:

The inspector considered that PECO performed wellin evaluating and responding to the initial conductivity increase. The inspector considered the issue unresolved pending review of PECO calculations and industry data in support of the effect of long term control rod boron leakage on core shutdown margin required by TS 3.1.1. (Unresolved 97-01-02)

R8 Miscellaneous Radiological Protection issues R8.1 Unlocked High Radiation Area Door and (Open) Unresolved item 50-277/97-01-03 l Use of Draft LER Reportability Guidance l

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The inspectors reviewed the documented corrective actions, cause, and licensee event 1

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report (LER) reportability of an unlocked high radiation area doo Observations and Findinas:

i During performance of HP-C-202, "High Radiation Area Locked Door check," an HP '

technician found door #192, "Rx 2135" D/W Equipment Hatch Access (Neutron Door),"

unlocked. The HP took immediate actions to:

e Slam door shut and independently verified it locked; e Notify HP on call supervision and RP manager;

• Check keys assigned to operation and security and accountability verified; e Verify radiation levels, and no one in the area with a room survey; e Notifv Operations and Security; e Verify no unexpected exposure PECO initiated PEP 10006650 to document the corrective acticn and recognized this as a violation of Technical Specification 5.7, which required that high radiation areas above 1000 mr/hr be locked. In their investigation of this issue, PECO determined that the door, which does not have a normal knob and key arrangement, may not have been properly

'

secured since replacement of the lock several days prior to identification. The inspector agreed witn PECO that it was difficult to pull on the door to verify that it was locked due to its arrangemen l l

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The inspector que:tioNd PECO determining that submission of an LER on this condition '

was not required based on a statement in the Second Draft of NUREG 1022, Rev !

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In addition, the inspectors did a random check of high radiation area doors in Units 2 and 3

! and found all doors checked secure and locke '

! Conclusion: '

i

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The licensee took appropriate corrective actions as a result of finding an isolated unlocked i high radiation door, as discussed above. PECO determined that the arrangement of the

, door made it difficult to verify it locked and that the door most probably was not properly ,

secured following a recent lock replacement. This licensee-identified and corrected  :

' violation was treated as a non-cited violation, consistent with Section Vll.B.1 of the NRC

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l Enforcement Polic t

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l The use of a draft NUREG to avert reporting a violation of the administration section of i l technical specifications was cunsidered unresolved pending further review. Unresolved t

Item 97-014 '

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LIST OF ACRONYMS USED abnormal operating procedure (AO)

action request (AR)

j action statement (AS)

l administrative guideline (AG)

APRM gain adjust factor (AGAF)

as-low-as reasonably-achievable (ALARA)

l average power range monitors - neutron (APRMs) i l control rod drives (CRDs)

l control room deficiency list (CRDL'

l t ontrol room emergency ventilation (CREV) ,

i core power and flow log (CPFL) 1 j core spray (CS)

core thermal power (CTP)

'

design basis document (DBD) ,

design input document (DID) 'I diaphragm alternative response test (DART)

electro-hydraulic control (EHC) l eleventh refueling outage (2R11) 1 emergency core cooling system (ECCS)  !

- emergency diesel generators (EDG)  !

emergency preparedness (EP)

'

emergency service water (ESW) l end-of-cycle (EOC) l engineered safety feature (ESF) l engineering change request (ECR) )

engineering work request (EWR)

equipment study list (ESL)

functional failure (FF)

functional testing (FT)

general procedure (GP)

Generic Letter (GL)

health physics (HP)

high pressure coolant injection (HPCI)

high pressure service water (HPSW)

hydraulic control unit (HCU)

. improved TS (ITS)

independent safety engineering group (ISEG)

inservice inspection (ISI)

inspector followup items (IFls)

instrument and control (l&C)

intermediate range mornot - neutron (IRM)

job performance measures (JPMs)

licensee event report (LER)

limited senior reactor operators (LSROs)

l limiting conditions for operation (LCO) j load tap changer (LTC)

i local leak rate test (LLRT)

loss of coolant accident (LOCA)

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~ less of off-site power (LOOP)

low pressure coolant injection (LPCI)

lubricating oil (LO)

maintenance functional failure (MPFF)

modification (MOD)

- motor generator (MG)

non-conformance report (NCR)

nuclear maintenance division (NMD)

nuclear review board (NRB)

offsite dose calculation manual (ODCM)

offsite power start-up source #2 (2SU)

offsite power start-up source #3 (3SU) .

Peco Energy (PECO)

performance enhancement program (PEP)

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plant equipment operator (PEO)

plant operations review committee (PORC)

post maintenance testing (PMT)

primary containment (PC)

-

primary containment isolation system (PCIS)

primary containment isolation valve (PCIV)

protected area (PA)

quality assurance (QA)

radiologically controlled area (RCA)

rated thermal power (RTP)

reactor core isolation cooling (RCIC)

reactor engineer (RE)

reactor feed pump (RFP)

reactor operator (RO)

reactor protection system (RPS)

reliability centered maintenance (ROM)

residual heat removal (RHR)

residual heat removal (RHR)

rod position indication system (RPIS)

rod worth minimizer (RWM)

safety evaluation report (SER)

safety related structures, system and components (SSC)

safety relief valve (SRV)

scram solenoid pilot valve (SSPV)

secondary containment (SC)

- senior reactor operator (SRO)

shift technical advisor (STA)

shift update notice (SUN)

source range monitor (SRM)

specific gravity (SG)

spent fuel pool (SFP)

standby gas treatment (SGTS)

standby liquid control (SLC)

station blackout (SBO)

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surveillance requirement (SR)-

surveillance test (ST)

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I systems approach to training (SAT)

technical requirements manual (TRM)

technical specification (TS)

{ temporary plant alteration (TPA)

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., turbine bypass valve (BPV)  !

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turbine control valve (TCV) i turbine stop valve (TSV)

undervoltage (UV)

! unresolved item (URI) l i updated final safety analysis report (UFSAR) {

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