IR 05000277/1998003
| ML20249A481 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/11/1998 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20249A482 | List: |
| References | |
| 50-277-98-03, 50-277-98-3, 50-278-98-05, 50-278-98-5, EA-98-105, EA-98-221, NUDOCS 9806160482 | |
| Download: ML20249A481 (6) | |
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[*g UNITED STATES
[
g NUCLEAR REGULATORY COMMISSION
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY - $55,000 (NRC Inspection Report Nos. 50-277/98-03 & 50-278/98-05)
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Dear Mr. Rainey:
This letter refers to the two NRC inspections conducted between February 12 and March 3, 1998, and between March 30 and April 24,1998, for which exit meetings were held on March 4,1998, and April 27,1998, respectively. During the inspections, the reports of which were sent to you on March 30,1998, and May 7,1998, apparent violations of NRC requirements were identified. On May 21,1998, a Predecisional Enforcement Conference was conducted with you and members of your staff, to discuss the violations, their causes, and your corrective actions.
I Based on the information developed during the inspections, and the information provided during the enforcement conference, two violations of NRC requirements are being cited and are described in the enclosed Notice of Violation and Proposed imposition of Civil Penalty (Notice). The first violation involves the failure to establish adequate instructions and procedures to prevent foreign material from entering the 3A core spray subsystem during a j
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replacement modification of emergency core cooling system (ECCS) suction strainers in October 1997. Although the foreign materials exclusion (FME) plan developed for the f
modification provided FME controls for the material entering and leaving the torus, the plan /[
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l-did not provide similar controls for the suction strainers, resulting in foreign material, in the I
form of a rigging sling protector pad, being left in the 3A core spray subsystem after the modification. As a result, the second violation occurred involving the failure to maintain the
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- 3A core spray subsystem operable in that during testing on March 22,1998, the 3A core l-spray pump failed to meet discharge pressure and flow specifications. Following that test, i
further testing and evaluation of the pump was conducted and revealed fibrous material (from the rigging sling protector pad) wrapped around the impeller shaft and parts of the impeller
' vanes, as well as small bunches of this fibrous material in the piping between the suction valve and pump discharge check valve.
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9806160482 980611 PDR ADOCK 05000277 G
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The NRC is concerned that adequate controls were not in place to preclude foreign material from entering the Unit 3 CS and RHR systems during the replacement of the strainers.
Although your staff, at the beginning of the outage, initially logged all material that was introduced into, and removed from the torus, this practice was discontinued near the end of the outage. At the time, approximately 4000 items had been logged into the torus while only approximately 2000 items had been logged out. In place of this FME control, you enhanced your originally planned torus catwalk walkdowns and dive swim through of the ur;derwater torus portion. While these walkdowns were capable of detecting foreign materialin the torus, they were not capable of detecting foreign materialinside the piping with the suction strainers.
However, your engineering personnel, during reviews of the FME plan and other evaluations, apparently did not recognize this inadequacy. In addition, the engineering oversight of the modification work activities was poor in that there was a lack of accountability for FME coordination, as well as a lack of formal observation of activities by personnel other than Quality Assurance personnel.
The NRC is also concerned that even though your QA organization, while overseeing the outage, identified several deficiencies with your FME controls, your corrective actions at the time to address those deficiencies were narrowly focused on specific findings, and did not lead to earlier identification of the fibrous materialin the system. For example, a QA Surveillance Report issued in August 1997, prior to the outage, indicated that no FME controls were defined in written instructions or practiced during mock-up training. Another QA Surveillance Report issued in October 1997 indicated that FME controls at the torus entrances needed to be strengthened. That same report documented several deficiencies, including difficulties with the system for accounting for items taken into the torus; omission of details in the required logs; inattentiveness by plant monitors to individuals going into the torus with material; and a lack of a copy of the FME administrative procedure at the control point. In addition, a OA Surveillance Report issued on December 22,1997, indicated a breakdown of the FME controls during the suction strainer modification, noting that stringent FME controls in the torus were viewed as a challenge to the schedule rether than a necessary means of maintaining system cleanliness, and the contractor's acceptance of a final inspection in lieu of FME controls during work was a concern. Two days later, on December 24,1997, during a quarterly surveillance test of the 3A care spray pump, the discharge pressure was found to be 212 psig, yet this finding was not questioned even though the observed discharge pressure during the previous
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five years of tests had been typically between 220-225 psig, providing indications of a degraded core spray pump which could have lead to earlier identification of fibrous material in the system.
The failure to exercise appropriate FME controls at Peach Bottom during the October 1997 outage indicates a significant lack of attention towards licensed responsibilities. This failure is particularly disturbing given the findings of your QA department, as well as the f act that the NRC had issued a Severity Level lil Notice of Violation to your Limerick facility in October 1996 for the failure to establish adequate controls to exclude foreign material from the Limerick I suppression pool. That failure resulted in substantial accumulation of debris on a suppression pool suction strainer causing some cavitation of an RHR pump. In my Octnber 17,1996, letter transmitting the Notice of Violation for Limerick, I noted that the findings demonstrated the importance of management taking appropriate action to assure that (1) the FME program is appropriately implemented, and (2) your staff is proactive in evaluating adverse conditions identified at one facility to ensure degraded conditions do not exist at the
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other facility. Notwithstanding those prior cautions, adequate FME controls were not
exercised at Peach Bottom during October 1997 and this represents a significant regulatory concern. Therefore, the violations are c'assified in the aggregate as a Severity Level lli problem in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600 (Enforcement Policy).
A base civil penalty in the amount of $55,000 is considered for each Severity Level lli j
vioiation or problem. Because Peach Bottom has been the subject of escalated enforcement actions within the last 2 years,' the NRC considered whether credit was warranted for
/ identification and Corrective Action in accordance with the civil penalty assessment process -
in Section VI.B.2 of the Enforcement Policy. Credit for identification is not warranted, even thouah you identified this violation during a required surveillance test, because you had prior opportunities to identity and preclude these violations as a result of the QA findings in October 1997. Cradit for your corrective actions is warranted because at the time of the enforcement conference, your actions were considered prompt and comprehensive. These actions included, but were not limited to, plans to (1) conduct an independent FME review of design and installation of modifications; (2) enhance training of staff on the FME plan; (3) benchmark other industry FME programs, including suction strainer replacement FME controls; and (4) assure accountability of all rigging material after each use. The NRC plans to continue to follow your actions closely to determine the effectiveness of your actions in precluding future problems.
Therefore, to emphasize ths importance of appropriate FME controls at your facilities, as well as appropriate response to QA findings, I have been authorized, after consultation with the i
Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed l
- Imposition of Civil Penalty in the amount of $55,000 for these violations.
During the conference, another apparent violation was discussed involving the 2A reactor j
feedwater pump turbine high water level trip function not being maintained operable. Upon i
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further review, the NRC has decided not to cite a violation based on information that you provided during the conference that the function was operable. Nevertheless, the NRC is concemed that this trip function exhibited degraded performance in April 1997 and November 1997, but a lack of systematic troubleshooting resulted in a failure to determine all potential
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causes of the degradations. Further, your corrective actions did not prevent subsequent
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degraded performance in December 1997 and February 1998.
At the enforcement conference, you admitted that your troubleshooting was neither comprehensive nor consistent, and you provided a number of actions to strengthen this program.
' You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with
- regulatory requirements.
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I 8 c.g., A Notice of Violation was issued on January 3,1997 for a Seventy level III violation of the maintenance
rule (Reference: EA 96-370).
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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, :.ad your response will be placed in the NRC Public Document Room (PDR).
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Sincerely, Hu ert J. Miller Regional Administrator Docket Nos. 50-277;50-278 License Nos. OPR-44; DPR-56 Enclosure: Notice of Violation and Proposed imposition of Civil Penalty s
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cc w/ encl:
D. Smith, President G. Edwards, Chairman, Nuclear Review Board and Director, Licensing J. Doering, Vice President, Peach Bottom Atomic Power Station J. Cotton, Vice President, Nuclear Station Support T. Niessen, Director, Nuclear Quality Assurance A. Kirby, Ill, External Operations - Delmarva Power & Light Co.
M. Warner, Plant Manager, Peach Bottom Atomic Power Station G. Lengyel, Manager, Experience Assessment J. Durham, Sr., Senior Vice President and General Counsel T. Messick, Manager, Joint Generation, Atlantic Electric W. Henrick, Manager, External Affairs, Public Service Electric & Gas R. McLean, Power Plant Siting, Nuclear Evaluations J. Vannoy, Acting Secretary of Harford County Council R. Ochs, Maryland Safe Energy Coalition J. Walter, Chief Engineer, Public Service Commission of Maryland Mr. & Mrs. Dennis Hiebert, Peach Bottom Alliance Mr. & Mrs. Kip Adams Commonwealth of Pennsylvania State of Maryland TMI-Alert (TMIA)
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b PECO Nuclear DISTRIBUTION:
PUBLIC SECY CA LCallan, EDO AThadani, DEDE JLieberman, OE HMiller, RI FDavis, OGC SCollins, NRR RZimmerman, NRR Enforcement Coordinators RI, Ril, Rlli, RIV BBeecher, GPA/PA GCaputo, 01 DBangart, OSP HBell, OlG TMartin, AEOD
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OE:Chron OE:EA DCS NUDOCS DScrenci, PAO-Ri NSheehan, PAO-Ri LTremper, OC Nuclear Safety Information Center (NSIC)
NRC Resident inspector - Peach Bottom s
100129
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