IR 05000277/1998006
| ML20237F010 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/25/1998 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| 50-277-98-06, 50-277-98-6, 50-278-98-06, 50-278-98-6, NUDOCS 9809010391 | |
| Download: ML20237F010 (3) | |
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l Mr. G. Rainey, President l PECO Nuclear'
Nuclear Group Headquarters-
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Correspondence Control Desk .
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P.O. Box 195
- Wayne, Pennsylvania 19087-0195 l - SUBJECT:
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COMBINED INSPECTION REPORT NOS. 50-277/98-06 AND 50-278/98-06
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Dear Mr. Rainey:
This letter refers to your August 15,1998 correspondence, in response to our ~
( July 16,1998 letter in which we identified four violations of NRC requirements.
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Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.
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l l We also acknowledge the actions that you identified and have taken to address the issue L of the number of valve mispositioning events that have occurred.- We will continue to l monitor your performance in this area to assess whether your actions have been effective
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Your cooperation with us is appreciated.
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Sincerely,
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Clifford J. Anderson, Chief Projects Branch 4
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L Division of Reactor Projects /
i Docket Nos. 50-277;50-278 l
l l' 9909010391 990925 I PDR ADOCK 05000277 .
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I Mr. ,
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cc w/ Licensee Response Ltr:
R. Boyce, Director, Nuclear Quality Assurance j G. J. Lengyel, Manager, Experience Assessment
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J. W. Durham, Sr., Senior Vice President and General Counsel j T. M. Messick, Manager, Joint Generation, Atlantic Electric l
j W. T. 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. H. Walter, Chief Engineer, Public Service Commission of Maryland Mr. & Mrs. Kip Adams l Commonwealth of Pennsylvania State of Maryland l
TMl - Alert (TMIA)
cc w/o Licensee Response Ltr:
G. Edwards, Chairman, Nuclear Review Board and Director, Licensing l J. Doering, Vice President, Peach Bottom Atomic Power Station l J. Hagan, Vice President, Nuclear Station Support A. F. Kirby, Ill, External Operations - Delmarva Power & Light Co.
M. Warner, Plant Manager, Peach Bottom Atomic Power Station Mr. & Mrs. Dennis Hiebert, Peach Bottom Alliance l
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Mr. Distribution w/ Licensee Response Letter:
Region i Docket Roorn (with concurrences)
B. McCabe, OEDO R. Capra, PDI-2, NRR M. Thadani, NRR B. Buckley, NRR R. Correia, NRR F. Talbot, NRR C. Anderson, DRP D. Florek, DRP M. Campion, ORA R.Junod,DRP Nuclear Safety Information Center (NSIC)
NRC Resident inspector PUBLIC Inspection Program Branch, NRR (IPAS)
DOCDESK DOCUMENT NAME: A:\RL906.PB To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy
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OFFICE Rl/gR% Rl/DRP NAME DFf?'ek V CAnderson Cl#
DATE 0 @ 98 0864/98 OFFICIAL RECORD COPY L
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- J hn Dorring.Jr. i
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Vce President
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Peach Bottom Atomic Power Station
'T PECO NUCLEAR esco enersv comnemv 1848 Lay Road A Unit of PECO Energy P 7 490 2 gt S 0 Fax 717 456 4243 E-mait idoenng@peco energycom l August 15,1998 l , Docket Nos 50-277 50-278 License Nos. DPR-44 j DPR-56 l
l U. S. Nuclear Regulatory Commission L Attn.: Document Control Desk Washington, DC 20555 Subject: Peach Bottom Atomic Power Station Units 2 & 3 Response to Notice of Violations (Combined Inspection Report No. 50- {
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277/98-06 & 50-278/98-06)
l Gentlemen:
In response to your letter dated July 16,1998, which transmitted the Notice of Violation (NOV), concerning the referenced inspection report, we submit the attached response.
The subject report concerned a Residents' Integrated Safety inspection that was conducted May 5,1998 through June 22,1998.
l If you have any questions or desire additional information, do not hesitate to contact us.
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' John Doering, Jr.
! Vice President, Peach Bottom Atomic Power Station i
Attachments MT/mt l
cc: N.J. Sproul, Public Service Electric & Gas R. R. Janati, Commonwealth of Pennsylvania H. J. Miller, US NRC, Administrator, Region I l A. C. McMurtray, US NRC, Senior Resident inspector R. l. McLean, State of Maryland A. F. Kirby Ill, DelMarVa Power / Atlantic Electric CCN 98-14062
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bec: OEAP Coordinator 62A-1, Chesterbrook Correspondence Control Program 61 B-3, Chesterbrook NCB Secretary (11) 62A-1, Chesterbrook G. C-3, Chesterbrook J. Doering SMB4-9, Peach Bottom J. B. Cotton 62C-3, Chesterbrook i
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R. W. Boyce 63C-3, Chesterbrook E. J. Cullen ,
S23-1, Main Office T.A.Shea SMB4-6, Peach Bottom G. D. Edwards 62A-1, Chesterbrook J G. Hufnagel 62A-1, Chesterbrook C. J. McDermott S13-1, Main Office M. E. Warner A4-1S, Peach Bottom G. L. Johnston SMB3-5, Peach Bottom R. L. Gambone A4-1S, Peach Bottorn R.A.Kankus 63C-2, Chesterbrook G. J. Lengyel A4-4S, Peach Bottom M.J. Taylor A4-SS, Peach Bottom
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.* I RESPONSE TO NOTICE OF VIOLATION 98-06 Restatement of Violation l
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1. Technical spedfication 3 3.7.1 requires, in part, that when a channel of the Main l l Control Room Emergency Ventilation (MCREV) system instrumentation is inoperable
that the channel be placed in trip within six hours.
Contrary to the above, on May 15,1998, the inoperable 'B' u 2. .iel had not been placed in the tripped condition for approximately 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />. The 'B' channel of MCREV instrumentation was inoperable due to an inoperable radiation monitor (RIS-07608).
Reason (s) For The Violations l
l The cause of this event vias the failure to verify that when the GP-25 jumper was installed, the trip coil actually changed state indicating that insertion of the GP-25 trip was successful. GP-25 procedure guidance provides details forjumperinstallation and l guidance for posting notification that the equipment is inoperative during trip insertion.
However, the procedure does not require positive verification that the installed jumper l actually resulted in the desired trip to meet Tech Spec required actions.
There were two causal factors that led to GP 25, Appendix 14 jumper not inserting the trip as designed. The first is that procedure GP-25, Appendix 14 does not require the installer to verify a change in circuit configuration after the jumper has been installed or specify the identifiable impact this activity has on the facility. The second factor was a
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loose termination screw on the trip relay coil. The loose termination was found during l subsequent troubleshooting and corrected. Investigation into this event revealed that this termination had been disturbed during a modification to the MCREV system that added varisters to twelve relays.
Corrective Steps That Have Been Taken And The Results Achieved A visualinspection of the terminal screws on other relays was conducted and revealed
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similar loose terminations. The loose screw problem was generic to the coil contacts where varistors had been installed as part of the modification. The loose screws were tightened and the MCREV system was returned to operability. It was determined that the other loose terminations did not adversely impact system performance.
A review of the procedure writers guide was performed to determine if there was adequate direction (i.e., steps) to positively verify changes to the facility while performing tests. It was concluded that adequate direction was included in the procedure writers guide.
A Licensee Event Report (LER,2-98-003) for both Peach Bottom units, documenting this event was sent to the NRC on June 15,1998.
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Corrective Steps That Will Be Taken To Avoid Further Violations A review of the General Plant and Maintenance procedures will be performed to determine if positive verification steps exist. Maintenance practices will be reviewed to determine if they contain appropriate direction for the installation and removal of wires, lugs, and other devices associated with terminal blocks. Procedures will be revised as
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This event will be discussed with work groups to heighten their awareness of the need to self-check. An information Notice will be issued to workers with Station Qualified Reviewer (SQR) certification, reinforcing the expectation associated with changes to j l the facility and positive verification steps.
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Date When Full Compliance Will Be Achieved Compliance was achieved on May 15,1998 when the "B" channel of MCREV was declared operable. I
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Restatement of Violation 2. 10 CFR 50 Appendix B, Criterion XVI, " Corrective Action," requires, in part, that
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measures be established to assure that conditions adverse to quality, such as failures, malfunctions, and deficiencies are promptly identified and corrected. In the case of signi.ficant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
l Contrary to the above, site engineering personnel failed to take prompt and effective corrective actions following the identification of errors affecting several procedures for l the residual heat removal system. Specifically, Quality Assurance personnelidentified l
and reported the errors in September 1997, but the unit 2 procedures were not revised '
until around March 24,1998. The failure to revise the unit 2 procedures resulted in the residual heat removal system valve, HV-2-10-65, being left incorrectly positioned when l plant operators used an unrevised procedure on March 4,1998.
Reason (s) For The Violations The reason R the violation was that the procedures were not revised in a timely manner prior to performing the test. This issue was identified by site NQA in September 1997. An evaluation to revise the procedures was issued to Plant Engineering on October 14,1997, with a due date of February 27,1998. The procedure revision request was processed using the procedure revision process rather than the temporary procedure change and therefore was not performed in a timely manner. On February 27,1998, the revision of the procedure was completed and the procedure was sent to Document Services for distribution with an effective date of March 24,1998. The procedure was performed using the current revision of the procedure since the new revision was not yet effective, and resulted in the mispositioned valve.
Contributing to this problem was that NCR 96-03167, which is a non-MOD ECR, was completed on March 25,1997, did not identify all affected procedures to be revised.
Corrective Steps That Have Been Taken And The Results Achieved Non-MOD ECRs with a high potential to impact station documents were reviewed to determine those requiring procedure revisions. Fifteen 3R11 ECRs were also reviewed to determine if impacted procedures were identified and updated correctly. These reviews identified several procedures as requiring revision. The revisions to the affected documents were initiated and changes made.
A Technical Information Notice (TIN 97-017 Rev.1) was issued to provide information on the responsibilities for procedure and program updating. The TIN also provided information to aid in the search for affected procedures / documents. In addition, a "For Your Information" (FYl) regarding the need to perform timely procedure / program updates for non-MOD ECRs was sent to affected station personnel.
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Corrective Steps That Will Be Taken To Avoid Further Violations A review of our procedure revision processes is being conducted under our corrective action program.
A monthly review of non-MOD ECRs about to be implemented will be performed. This l review will continue until it is determined that sufficient improvement has occurred. The
! lack of proper training is being addressed by having all Lead Site Representatives (LSRs) attend Lotus Notes training as part of their qualification program.
Date When Full Comollance Will Be Achieved Compliance was achieved on March 24,1998, when the revised procedures became effective. The RHR - 65 valves that were found in the improper position were retumed to their proper position on March 17,1998.
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! Restaternent of Violation l
3. Technical Specification 3.4.1 requires, in part, that with one recirculation loop in operation, the Reactor Protection System (RPS) instrumentation, " Average Power l Range Monitors Flow Biased High Scram," allowable value shall be reset for single l recirculation loop operation. The reset of the " Average Power Range Monitors Flow
! Biased High Scram" allowable value for single loop operation may be delayed for up to l 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after transition from two recirculation loop operation to single loop operation. l Contrary to the above, the inspectors identified that on June 8,1998, plant personnel did not reset the Unit 3 RPS Instrumentation, " Average Power Range Monitors Flow Biased High Scram" within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after transition from two recirculation loop to single recirculation loop operation.
Response On June 8,1998, with one recirculation pump in operation and one idling due to a recirc runback, sufficient recire flow mismatch existed to result in single loop operation.
Due to both pumps remaining in-service, operations personnel failed to recognize the single loop condition. The operating crew recognized the failure to meet surveillance requirement (SR) 3.4.1.1 which requires recirc loop jet pump flows to be matched within specified limits. Therefore, the crew incorrectly entered Action Condition 3.4.1.D due to failure to satisfy LCO 3.4.1 and SR 3.4.1.1. The misinterpretation was due to less than adequate procedure guidance and individual knowledge of technical specifications regarding single loop criteria. Further review of the TS basis describe that a failure to satisfy the recirc mismatch criteria constitutes single loop operation.
Based on the above discussion, the operating crew was focused on compliance with Action Condition 3.4.1.D which required an Action Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> - 28 minute time to match the recirc loop flows was believed to be acceptt.ble by the operations crew.
Corrective Steps That Have Been Taken And The Results Achieved As a result of this event, a detailed review of TS, the design basis documents (DBO)
and procedures were performed for single loop operation. This review noted a General Electric (GE) report contained in the DBD that identified piping stresses could result from prolonged and excessive mismatch of jet pump flows. As a result of this, GE was requested to review data from the event and provide an analysis as to its affect on the reactor. GE issued their report on June 11,1998, which identified the critical component of concern as the Loop A Jet Pump Riser Braces and concluded based on BWR/3 information that it is unlikely that a crack was initiated due to this situation.
Troubleshooting was performed to prove functionality of the 3B Recirculation Pump Runback Relay. Reactor engineering also performed an evaluation of the plant conditions which existed .during this event and concluded the single loop operating limits'were acceptable.
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in addition, GP-5, " Power Operation" was temporarily changed to require operators to f restore jet pump flow mismatch to within Tech. Spec. Limits within one hour or trip the l low speed pump to preclude this situation from re-occurring.
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Corrective Steps That Will Be Taken To Avoid Future Violations Operations training will be revised to include this event and related Tech Spec and Design Bases Document (DBD) information concerning operation with a large jet pump loop flow mismatch. The use of the operating experience searches during unusual operating situations is being evaluated. This issue will also be reviewed with all system managers.
l A review of system Tech Spec bases and DBDs will be performed to identify important
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design basis information which may not be captured by procedures and programs. The Tech Spec bases will be enhanced to capture the concerns associated when operating with mismatched jet pump flows. A review is also being conducted to determine the need to modify the recirculation runback logic circuit to prevent future runbacks due to short duration voltage fluctuation.
Date When Full Comollance Will Be Achieved During this event, unit 3 compliance with Tech Spec 3.4.1 was not compromised.
Conditions of SR 3.4.1.1. and associated LCOs were met within Tech Spec allowable time limits.
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i Restatement of Violation 1 4. Technical Specification Surveillance Requirement 3.4.9.4 requires, in part, that the l difference between the temperature of the reactor coolant in the recirculation loop to be !
started and the coolant in the reactor pressure vessel be verified to be less than or equal to 50 degrees Fahrenheit. This verification is to occur once within 15 minutes prior to each startup of a recirculation pump and is required when in operating modes 1, 2, 3, and 4.
Contrary to the above, the licensee identified that from June 25,1996 until March 23,1998, Surveillance Requirement 3.4.9.4 had not been performed when the first recirculation pump of a unit was started. The required surveillance verification was not performed during six recirculation pump starts which occurred on both units during this time period. In addition, during one of these six recirculation pump starts on 1 October 29,1997 on Unit 3, the temperature differential was 84 degrees Fahrenheit within 15 minutes of the recirculation pump start.
l Reason (s) For The Violations An internal review of this event identified two causal factors; less than adequate procedure preparation, review and approval, and change configuration. During the implementation of the Improved Technical Specifications (ITS) in 1996 the Surveillance Requirement (SR) was changed from the original Custom Technical Specifications (CTS). The original CTS did not restrict the start of the first loop based on the temperature of coolant in the loop. The new ITS added Surveillance Requirement (SR) 3.4.9.4 to verify the difference between the reactor coolant temperature in the recirculation loop to be started and the RPV coolant temperature is less than or equal to 50 degrees Fahrenheit. This change from CTS to ITS was considered an administrative change and was not added to the implementing procedure ST-O-028-510-2 and 3.
Corrective Steps That Have Been Taken And The Results Achieved ST-O-028-510-2 and 3 have been revised to include a step to verify less than or equal to 50 degree Fahrenheit delta temperature between coolant temperature and loop temperature prior to start of the first recirculation pump.
NCR PB 98-00692 reviewed past performances of the ST and identified only one actual plant condition since the transition to ITS. A review of the thermal cycling, at a rate greater than fifty degrees was evaluated and determined to be within the existing Reactor Pressure Vessel and Recirculation analysis.
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es Corrective Steps That Will Be Taken To Avoid Further Violations A review of SRs for similar deficiencies will be conducted. The search willinclude verifying that changes categorized as administrative are either correctly implemented or were correctly identified. A random selection of SRs will be reviewed to assure that they are being correctly implemented.
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Compliance was achieved on April 17,1998, ST-O-028-510-2 and 3 were revised to I include a step to verify less than or equal to 50 degree Fahrenheit delta temperature between coolant temperature and loop temperature prior to start of the first recirculation !
pump. These revised procedures will be implemented the next time the units are in modes 1,2,3 or 4 during recirculation pump start.
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Response To Concern Of Number Of Valve Mispositionina Events l
l Site management is concemed with the number of valve mispositionings that have occurred and is taking action to address this issue. The Senior Manager - Operations l I
is leading a "Back-To-Basics"(B28) program focused on significantly reducing j unplanned plant configuration changes including valve mispositionings. The B2B .
approach is designed to raise personnel standards and behaviors in a wide spectrum of event contributors. Performance measures have been developed for EFO Behavior Observations, Unplanned Plant Configuration Changes and Ease of Plant Operations i
to monitor the effectiveness of improvement initiatives. These measures will be routinely reviewed by site management at the daily leadership meeting.
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In addition, a " Peer Check" program has been approved and is contained in the Operations Manual, in OM-P-11.4. Also, expectations regarding operator fundamentals are being reinforced through the Event Free Operations (EFO) program. Examples of operator fundamentals include self-check, 3-part communication, double verification independent verification, alarm response and pre-job briefings.
Each shift manager is conducting training with his shift this training cycle, emphasizing these expectations in conjunction with a review of operations standards. This training includes a video of Peach Bottom operators demonstrating appropriate fundamental behaviors.
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