IR 05000278/1998005
| ML20216D004 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/07/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20216C997 | List: |
| References | |
| 50-278-98-05, 50-278-98-5, NUDOCS 9805190474 | |
| Download: ML20216D004 (17) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.
50-278
License No.
DPR-56 Report Nos.
98-05 l
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Licensee:
PECO Energy Company i
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Facility:
Peach Bottom Atomic Power Station Unit 3 Dates:
March 30 to April 24,1998 Inspectors:
A. McMurtray, Senior Resident inspector l
M. Buckley, Resident inspector
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B. Welling, Resident inspector I
9905190474 980507 DR ADOCK O
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EXECUTIVE SUMMARY
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Peach Bottom Atomic Power Station NRC Inspection Report 50-278/98-05 This special inspection reviewed the events related to the discovery of foreign materialin the 3A core spray pump in March 1998.
i The foreign material exclusion requirements for the emergency core cooling systems
l (ECCS) suction strainer replacement during refueling outage 3R11 failed to provide adequate controls for the ECCS suction strainers and associated system. The i
controls were focused on the torus area and failed to adequately consider the components and work activities directly associated with the ECCS system. This failure resulted in foreign material entering the 3A core spray pump. In addition, the corrective actions for a number of foreign material control deficiencies identified by Quality Assurance were narrowly focused and did not address the overall inadequacies with foreign material controls. The licensee did not establish instructions and procedures of a type appropriate to the circumstances for the ECCS
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suction strainer modification activities. This is considered an apparent violation of l
10CFR50, Appendix B, Criterion V, instructions, Procedures, and Drawings.
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(Section M1.1)
Engineering did not take a thorough, rigorous approach in evaluations related to
foreign material controls for the ECCS suction strainer modification. Engineering
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l also did not adequately consider FME controls on the components and work activities directly associated with the ECCS system during reviews of the FME plan.
The engineering oversight of the modification work activities was inadequate due to a lack of accountability for FME coordination and the lack of documented formal observations by non-QA personnel. (Section E.4.1)
The 3A core spray subsystem was not maintained operable for the period December
24,1997, through March 13,1998, while the Unit 3 reactor was at power. This is considered an apparent violation of Peach Bottom Atomic Power Station Technical l
Specification 3.5.1. System engineering personnel missed an opportunity to identify the degraded condition of the 3A core spray pump after surveillance testing i
in December 1997. (Section E4.1)
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TABLE OF CONTENTS l
E X EC UTIV E S U M M A RY.............................................. ii l l. M ain t e n a n ce................................................... 1 M1 Cond uct o f M ainten ance................................... 1 M 1.1 Control of Foreign Material During ECCS Suction Strainer
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Replacement and 3A Core Spray Pump Degradation.......... 1 Ill. Engi ne e ring................................................... 6 E4 Engineering Staff Knowledge and Performance................... 6
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E4.1 Inoperable 3A Core Spray Pump
........................6 E8 Miscellaneous Engineering issues............................ 11 E 8.1 (Closed) LER 50-278/3-98-001," Failure of 3A Core Spray Pump to Meet Performance Requirements Due to Foreign Material"..... 11 i
V. Management Meeting s.......................................... 12 X1 Exit Mee ting Sum m ary................................... 12 X2 Review of Updated Final Safety Analysis Report (UFSAR) Commitments.12 ATTACHMENTS Attachment 1 - List of Acronyms Used
- Inspection Procedures Used i
- Items Opened, Closed, and Discussed Attachment 2 - 3A Core Spray Pump Testing Performance Table
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Report Detal_l3 ll. Maintenanca M1 Conduct of Maintenance M 1.1 Control of Foreian Material Durina ECCS Suction Strainer Reolacement and 3A Core Sorav Pumo Dearadation d.
Insoection Scooe (62707 & 62702)
The inspectors reviewed the events leading to the discovery of foreign material in the 3A core spray pump. This foreign material caused degraded pump performance, rendering the pump inoperable.
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Observations and Findinas During core spray system testing on March 22,1998, the 3A core spray pump failed to meet discharge pressure and flow specifications. On March 25, maintenance technicians performed boroscope inspections of the 3A pump after it failed additional testing and observed some fibrous material at the impeller.
Workers then disassembled the pump and found foreign material wrapped around the impeller shaft, covering part of the impeller vanes. The PECO Valley Forge Laboratories determined through chemical analysis and material comparison that the material was a rigging sling protector pad. Several of these pads were used for the emergency core cooling system (ECCS) suction strainer replacement work during refueling outage 3R11. Maintenance personnel performed boroscope inspections of the piping between the pump suction valve and the discharge check valve and l
found small bunches of fibers that were determirad to be remnants of the sling
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protector pad.
The licensee's immediate corrective actions included repairs to mu pump, the
initiation of a root cause investigation, and engineering analyses of the foreign material and its potential impact on the system and the reactor vessel. The engineering activities are discussed in section E4.1 of this report.
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Licensee Review - Preliminarv Results The licensee determined that the foreign materialin the 3A core spray pump most likely resulted from activities during the October 1997,3R11 ECCS strainer
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modification. The existing strainers were replaced with strainers containing j
considerably larger surface areas. The strainers were rigged into the torus in j
sections and then assembled underwater, inside the torus by divers.
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The licensee's investigation team identified three possible scenarios to explain how
the sling protector may have been introduced into the strainer modules / core spray l
piping:
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The sling protector was introduced into a strainer module following the quality verification cleanliness check, while the module was staged in the i
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i reactor building or while it we rigged into the torus. Due to the i
configuration of the strainer modules, the sling protector could have been j
hidden from view during subsequent inspections by divers.
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The sling protector entered the core spray piping during the rigging and/or placement of a shim pack after the strainer modules were bolted together.
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The sling protector was dropped and then floated into a strainer module while the strainer was being assembled in the torus. This was considered the least likely scenario.
The investigation team determined that the root cause of the event was a "tunnal vision" focus on FME controls during the ECCS suction strainer modification. They found that FME controls established by the modification team were focused primarily on the torus, rather than on the ECCS subsystems affected by the modification work. Two causal factors were identified: 1) failure to use FME covers on the strainer modules as they were staged in the reactor building, and 2)
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less than adequate controls for accountability of rigging material used near the internals of the new components that would become part of the ECCS subsystems.
A number of planned corrective actions were identified during the investigation.
The licensee expects these actions to address FME controls for major modification and complex maintenance activities, and they include specific action related to ECCS suction strainer work. The corrective actions were planned for implementation prior to the installation of the Unit 2 strainer modification,in October 1998.
NRC Review The NRC conducted an independent review of the events related to the discovery of foreign materialin the 3A core spray pump. The inspectors interviewed a number of licensee personnel involved, both directly and indirectly, with the 3R11 suction strainer modification. The inspectors also reviewed licensee written information and relied on inspector observations during the 3R11 modification activities.
As a result of this review, the inspectors identified a number of inadequacies and weaknesses in FME controls during the suction strainer modification. Most importantly, the inspectors found significant gaps in the FME controls for the strainer modules and other components installed at the ECCS suction piping. These
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o gaps resulted from the focus of the strainer modification FME plan, maintenance work orders, FME controls, and oversight, on the torus and failure to adequately
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consider the strainers, components and piping. The inspectors also noted that Quality Assurance (OA) personnel had identified several findings related to poor
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FME controls throughout the modification work effort. However, the corrective actions for these findings were too narrowly focused and did not address the overall inadequacies in FME controls. Details of the inspectors' findings are described below:
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ECCS Suction Strainer FME Plan inappropriate to Circumstances The inspectors noted that tiie FME plan did not address the exclusion of foreign material from the strainer modu!es either during staging or while in the torus. The plan, which was drafted by the vendor and approved by the modification team, primarily documented the requirements, controls, and logkeeping for the torus.
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The inspectors' learned that the FME plan was adapted from the PECO admidstrative procedure A-C-131-8," Specific FME Requirements for the Torus i
Proper (PBAPS) or Suppression Pool (LGS)." This PECO procedure was written to cover individual maintenance activities in the torus, rather than the extensive scope of work that was involved with this modification. As such, the FME plan did not fully consider the large number of materials and the nature of the working conditions that made overall FME controls more difficult than in a small, well-defined work area.
The inspectors determined that the ECCS Suction Strainer FME Plan was inadequate -
for the circumstances of the planned modification work. The FME plan did not address FME controls for the strainer modules and components, and the plan did not fully consider the extensive scope of activities in the torus.
. Inadequate Foreign Material Controls During Staging of Strainer Modules During the early stages of the modification work, quality verification (OV) personnel performed the strainer cleanliness checks immediately prior to rigging the modules into the torus. Later, due to some delays associated with the QV checks, the modification team allowed the strainers to be staged without FME covers for up to eight hours after the OV checks. If the period exceeded eight hours, the cleanliness checks were re-performed prior to lowering the strainers into the torus.
The staging area, although roped-off, was not controlled as an FME exclusion area, nor were cny personnel assigned to monitor FME controls. The strainers were j
located adjacent to a high traffic area near the entry point to the drywell. Licensee
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personnel stated during interviews that they observed, on occasion, some materials (e.g. notepads, cans) left on top of the strainer modules, in addition, the inspectors learned that rigging equipment was sometimes left in the staging area, and that sling protectors could have been introduced into the strainers from this equipment.
The inspectors determined that there was a failure to maintain FME controls while the strainer modules were staged, either by using cevers or by controls over the staging area. This represented a notable gap in overall FME controls for the modification work.
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FME Covers Not Installed on Strainers During Rigging / Movement j
The inspectors found that FME covers were not installed on the strainer modules both as they were lowered into the torus and as they were moved within the torus.
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These rigging evolutions included at least three separate re-positions of the rigging equipment.
The inspectors determined that not using FME covers provided another opportunity for foreign material to enter the modules. Further, the inspectors found that this practice was not fully consistent with guidance in Peach Bottom Administrative Procedure A-C-131, " Foreign Material Exclusion." This procedure documented that FME requirements should consider controls to prevent loss of FME during
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installation and removal of support commodities such as rigging.
Material Accountability Not Maintained for Rigging Gear During interviews, the inspectors learned that the project personnel did not log the rigging gear used to lower the strainer modules into the torus in the material accountability log. Modification project personnel stated that they could not verify that all rigging components and subcomponents that entered the torus through the equipment hatch subsequently exited the torus after rigging evolutions.
The inspectors noted that according to the licensee's original FME Plan and administrative procedures, items introduced into the torus were to be logged on the FME Material Control Log. Two logbooks had been set up for this purpose, one for the torus personnel hatch, and the other for the equipment hatch. The equipment hatch was used for rigging the strainer modules and components. Although some pre-staged rigging equipment used in the torus had been recorded. the rigging
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equipment that came in direct contact with the strainers was generally not recorded. The insoectors noted that the sling protectors were used during these rigging evolutions.
As & cussed previously, the licensee determined that the rigging sling protector could have been introduced during this portion of the modification work. The
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inspectors considered the lack of material accountability for the rigging gear during strainer movement into the torus to be another example where FME controls were poor during ECCS strainer modification work.
Final FME Checks of Strainers Were Limited
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The final Fh'd inspections of the ECCS suction strainers were performed only by the divers. The maintenance work packages reviewed by the inspectors' contained only a note that the diver was to "look in each strainer and spool piece for FME prior to bolt-up,"instead of a specific action step with signature. Although QV personnel were required to verify the cleanliness of the ECCS piping nozzles, they were not required to perform final FME checks of the strainers.
During interviews, the inspectors learned that there were challenges to performing thorough underwater inspections of the strainers. Due to the configuration of the l
strainers and limitations posed by lighting and/or the divers' helmets, some licensee personnel stated that they believed that a full FME check was difficult to perform.
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Quality Assurance identified FME Controls and Plan Deficiencies: But Corrective Actions for these Deficiencies Were Narrowly Focused I
Quality Assurance (QA) assessors performed three surveillances of FME controls for the ECCS suction strainer modification, covering several days of observation. The first surveillance was a review of mock-up training in July 1997. The assessor found that no FME controls were defined in written mock-up instructions or practiced during the mock-up. He also identified that the FME plan needed to be reviewed and strengthened, in the second surveillance, QA identified numerous deficiencies associated with l
FME controls at the torus entrances. These findings were noted early in the modification work activities and included such items as:
Difficulties in record keeping and maintaining the FME material control logs
Details omitted from the logs
Workers not checking in with the FME control point personnel, and
inattentive control point personnel Large amounts of consumables taken into the torus
Administrative Procedure A-C-131 was not present at the torus entrance
The QA assessors were concerned that some items that entered the torus may have been omitted or improperly deleted from the logs. The assessors also noted that there were a large number of line items logged into the torus,' making accounting more difficult. These findings and concerns were brought to the attention of the
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modification project manager and others involved with the modification. Members of the project team took prompt actions to correct the specific deficiencies. The project team then requested the QA assessors to review the corrective actions taken by the team, and the assessors noted improvements.
The project team did not recognize that the considerable number of individual QA findings were indicative of a broader FME problem. Further, when assessing the i
effectiveness of the corrective actions, the team relied heavily on the expertise of the independent assessment organization instead of using members of the project team or the maintenance department.
The inspectors reviewed the corrective actions taken by the project team and
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l determined that they were narrowly focused. Although the team addressed the individual QA findings, some of QA's overall concerns were not fully resolved. In addition, the inspectors'were concerned about the in-line review role that QA performed during the resolution of these findings.
l The third QA surveillance report was issued following the outage and provided an overall review of FME controls. The assessors took issue with the acceptance of a final swimthrough /walkthrough inspection in lieu of completing the material control j
log. The report also stated that stringent FME controls in the torus were viewed as a challenge to the schedule rather than a necessary means of maintaining system cleanliness.
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The inspectors noted that the O'. organization identified a number of FME control
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deficiencies to the project team. While QA did not recognize the overall mis-directed focus of FME controls for the modification, the assessors provided
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numerous indicators of a potentially broader problem. The inspectors determined j
that the project team and managers involved with the modification missed an j
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opportunity to pursue a comprehensive approach to the resolution of the j
deficiencies.
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Key Findings
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The inspectors determined that the following important findings most likely contributed to the introduction of foreign materialinto the 3A core spray system l
strainer / piping:
inadequate Foreign Material Controls During Staging of Strainer Modules e
FME Covers Not Installed on Strainers During Rigging / Movement
Material Accountability Not Maintained for Rigging Gear
Final FME Checks of Strainers Were Limited
These findings, as well as the deficiencies associated with the FME plan, reflected inadequacies in work orders, procedures, and instructions with respect to foreign material' controls. Based on these findings, the inspectors determined that the licensee did not establish instructions and procedures of a type appropriate to the circumstances for the ECCS suction strainer modification activities. This is considered an apparent violation of 10CFR50, Appendix B, Criterion V, instructions, Procedures, and Drawings. (eel 50 278/98-05-01)
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Conclusions The foreign material exclusion requirements for the emergency core cooling systems (ECCS) suction strainer replacement during refueling outage 3R11 failed to provide adequate controls for the ECCS suction strainers and associated piping. The controls were focused on the torus area and failed to adequately consider the components and work activities directly associated with the ECCS system.' This failure resulted in foreign material entering the 3A core spray pump. In addition, the corrective actions for a number of foreign material control deficiencies identified by Quality Assurance were narrowly focused and did not address the overall inadequacies with the foreign material controls. The licensee did not establish instructions and procedures of a type appropriate to the circumstances for the ECCS suction strainer modification activities. This is considered an apparent violation of 10CFR50, Appendix 8, Criterion V, instructions, Procedures, and Drawings.
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lit. Enaineerina E4 Engineering Staff Knowledge and Performance E4.1 Inocerable 3A Core Sorav Pumo i
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Insoection Scooe (37551. 92700)
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The inspectors reviewed the role of engineering in both the Unit 3 ECCS suction l
strainer replacement modification and in the analysis of the degraded performance of the 3A core spray pump. This review included the operability determinations and analyses that were performed by engineering personnel after the pump was declared inoperable, b.
Observations and Findinas ECCS Suction Strainer Modification Oversight and Evaluations The ECCS suction strainer modification project team consisted of both engineers and project managers. Engineering personnel primarily provided general engineering oversight and technical support for problems with the installation and alignment of the strainer modules, shims, and piping doglegs. This oversight was provided by monitoring of video cameras and performing tours in the torus.
Some engineers on the project team occasionally monitored FME controls, material controllogkeeping, and housekeeping during tours and by using the video cameras.
However, the accountability of these tasks was not specifically established. For example, the modification team did not assign the duties for FME coordination / oversight to any member of the team or to other station personnel.
The modification project personnel did not perform any documented, formal observations of the vendor FME controls. Also, they did not utilize the services of the maintenance department's FME subject matter expert for oversight tasks.
On October 29,1997, the station suspended the use of the FME material control log for the torus. At this point in the modification work, all suction strainers were bolted in place. The station justified the termination of the log based on the fact that the strainers were intact and the final foreign material walkthrough and diver swimthrough would identify any items rernaining in the torus. At the time the FME material control log was suspended, there were about 2000 items remaining in the torus. These items were removed from the torus after logkeeping was suspended, without reconciling the logs. Therefore these items were not verified as removed through the use of the log.
The inspectors noted that there were a large number of items still logged into the torus when the material control log was suspended. During interviews, the inspectors learned that some licensee personnel believed that the suspension was due in part to the potential difficulty of reconciling the log.
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l When the FME' material controllog was suspended, engineering personnel were tasked with generating a non-conformance report (NCR) to evaluate the impact of
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l this ' action. Engineering personnel documented in an action request that an NCR was not required because the swimthrough and walkthrough would ensure that all material would be removed from the torus. Station management stated that a more thorough swimthrough than originally planned was a compensatory measure for the suspension of the log. Specifically, a licensed operator performed a hand-over-hand
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swim throughout the torus.
The inspectors noted that the justification document for the suspension of the material control log considered only the potential risk associated with the foreign materialin the torus. It did not address the possibility that any unaccounted material may be left in the strainers or associated ECCS piping. Also, this documentation showed that engineering personnel did not review the effectiveness of overall FME controls for the modification activities after the material control log was discontinued. This was especially apparent given that the suspension of the log was a reduction in FME controls.
Although the material control log was discontinued, the drop log was not suspended. The drop log was used to record items dropped in the torus. The inspectors noted during document reviews that engineering did not document the final disposition for several items in the drop log. Normally, engineering would have completed NCRs for all unrecovered items. Engineering personnel stated that they believed that allitems were recovered during the swimthrough, so no NCR or other documentation was required for the unrecovered items. However, this determination was not documented or reviewed.
NRC Inspection Report 50-277(278)/97 07,Section O2.3, discussed the excessive use of overtime by ECCS suction strainer project management personnel. The report noted that one engineering project manager worked nearly 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> a week over a three week period, and others worked similarly long hours. The inspectors documented a concern that some individuals worked on safety-related projects in a fatigued condition. The inspector followup item (IFl 50-277(278)-97-07-01)
remains open to review corrective actions. The inspectors were concerned that the excessive work hours had a potential to impact the oversight of the management team on all aspects of the suction strainer modification work, including the overall FME controls.
The inspectors determined that engineering personnel on the modification team did not take a thorough, rigorous approach to either the evaluation of the impact of suspending the FME material control log or the final disposition of the items remaining in the FME drop log. Engineering and project management personnel also did not adequately consider FME controls for the strair.er, components, or ECCS l
system during reviews of the FME plan or during oversight of the modification work j
activities.
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1 3A Core Spray Pump Performance and Operability issues October 1997:
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The station completed post-modification surveillance testing for all ECCS pumps, with satisf actory results. The 3A core spray pump was tested on October 30, 1997. The pump pressure and flow results for this and subsequent tests are summarized in Attachment 1 to this report.
December 1997:
On December 24,1997, the 3A core spray pump was tested as part of the routine
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quarterly surveillance testing. The results met the surveillance test acceptance l
criteria, but the pressure / flow performance had changed from the historic performance data and moved away from reference pump curve.
System engineering personnel did not recognize this degraded performance of the pump, because they did not compare, in detail, the test results against the historical i
data. Since the acceptance criteria were met, plant procedures required no other further actions.
j Following the discovery of foreign material in the pump, engineering compared the December 24 results with a graph of historical pressure / flow data. Engineering i
management stated that there was an opportunity to identify the degraded condition j
in December. However, they did not necessarily expect that the engineers who i
reviewed the data would identify a degraded condition. Engineering management stated that they did not expect that the system engineers would initiate further I
actions after the one-time shift in results for the 3A core spray pump in December 1997, based on pump trending practices at the station.
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I Unit 3 was shutdown for maintenance outage 3J12 on March 13,1998. During j
this outage, the 3A core spray loop was removed from service and declared i
inoperable to support scheduled maintenance. The post-maintenance test for this work, performed on March 22,1998, was ST-O 014-301-3," Core Spray Loop A Pump, Valve, and Flow, and Cooler Functional and Inservice Test." This test also was used to meet the required 3 month Inservice Testing (IST) program test.
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The 3A core spray pump failed to meet the discharge pressure and flow acceptance J
criteria specified in the test acceptance criteria. The data showed that the pump operated below the technical specification required pump curve values during this test. The licensee performed four additional tests of the 3A core spray pump i
following the initial failure. Three of these tests were below the technical specification acceptance criteria. Engineering initiated a detailed troubleshooting plan to determine the cause of the pump failure following pump testing.
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The core spray system consists of two 100% capacity loops, each of which contains two 50% capacity motor driven centrifugal pumps that convey water from the torus to the vessel. In the case of low water level in the reactor vessel or high
. pressure in the drywell with low reactor vessel pressure, the core spray system automatically sprays water onto the top of the fuel assemblies to limit the maximum cladding temperatures during a design basis accident.
The licensee declared the 3A core spray pump inoperable on March 24,1998 following these tests. The 3A core spray loop remained inoperable through the testing described above.
Subsequent maintenance troubleshooting revealed that a rigging sling protector had entered the pump and wrapped around the impeller shaft. Engineering analysis determined that had the rigging sling protector remained in the pump, it would have eventually broken down into small fibrous strands during pump operation. Based on the material / chemical composition, melting points, and sizes of downstream components, engineering personnel determined that these strands would have no adverse impact on fuel bundles, reactor vessel components, or core spray system piping or nozzles. The inspectors reviewed these analyses, discussed them with PECO engineers, and ident:fied no concerns. The inspectors noted that the 3A core spray loop had not been lined up to the reactor vessel during or after 3R11.
Therefore, it was very unlikely that any of this foreign material entered the reactor vessel.
Engineering personnel also completed analyses of pump operability, including generic implications of foreign material bein0 present in other Unit 3 core spray or residual heat removal pumps. Engineering personnel determined that the foreign material most likely entered the core spray system during the 3R11 outage.
Engineering personnel concluded that the 3A core spray pump prob 91ly would have performed at less than the technical specificaticns performance crituia if called upon to mitigate an accident following the outage. Therefore, the pump was determined to be inoperable since 3R11.
Due to the generic implications of this event, the licensee decided to operate each Unit 3 residual heat removal and core spray pumps for a four hour period using applicable pump surveillance testing procedures. The four hour time period was based on engineering analysis. A!! pumps met their capacity requirements and performed within historical performance values.
The inspectors compared the duration of the pump surveillance testing in October and December to the possible pump operating duration during postulated accident conditions. The total run time for the surveillance tests in October and December was between 20 and 40 minutes. Based on the results of the December 24,1997 test, the sling protector probably traveled from its original position to the pump during this test and degraded the performance of the pump. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and design basis-documents and noted that the licensing basis for core spray pump operating duration was not documented. However, certain types of loss of coolant accidents
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required the core spray pumps to run for several hours. Therefore, the rigging sling protector likely would have caused degraded pump performance at any time following the 3R11 outage based on postulated accident conditions if it became lodged in the pump. The inspectors determined that the degraded pump performance during the December 24,1997, surveillance test indicated that the l
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rigging sling protector was lodged in the pump.
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Peach Bottom Atomic Power Station, Unit 3, Technical Specification 3.5.1,
" Emergency Core Cooling System (ECCS) and Reactor Core isolation Cooling (RCIC)
System," requires that each ECCS injection / spray subsystem be operable when in Modes 1,2, and 3. If one low pressure ECCS injection / spray subsystem is inoperable, the subsystem shall be restored to OPERABLE status within seven days.
l The inspectors determined that the 3A core spray subsystem was not maintained operable for the period from December 24,1997, through March 13,1998, while l
the Unit 3 reactor was at power (Mode 1). This is considered an apparent violation of Peach Bottom Atomic Power Station Technical Specification 3.5.1. (eel 50-278/98-05-02)
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Conclusions Engineering did not take a thorough, rigorous approach in evaluations related to
foreign material controls for the ECCS suction strainer modification. Engineering g
also did not adequately consider FME controls on the components and work
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activities directly associated with the ECCS system during reviews of the FME plan.
The engineering oversight of the modification work activities was inadequate due to lack of accountability for FME coordination and the lack of documented formal observation by non-QA personnel.
l The 3A core spray subsystem was not maintained operable for the period l
December 24,1997, through March 13,1998, while the Unit 3 reactor was at power. This is considered an apparent violation of Peach Bottom Atomic Power L
Station Technical Specification 3.5.1. System engineering personnel missed an opportunity to identify the degraded condition of the 3A core spray pump after surveillance testing in December 1997.
E8 Miscellaneous Engineering Isaues E8.1 (Closed) LER 50-278/3 98-OO1." Failure of 3A Core Sorav Pumo to Meet Performance Reauirements Due to Foreian Material" The inspectors performed an on-site review of PECO's root cause, evaluation of generic implications, and corrective actions for the degraded performance of the 3A core spray pump due to foreign material. Details of the event including causes and corrective actions are documented in this report. The implementation of corrective actions for this event will be tracked by the apparent violations in this report.
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V. Manaaement Meetinos l
X1 Exit Meeting Summary The inspectors presented the results of the inspection to members of licensee management on April 27,1998. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the
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inspection should be considered proprietary. No proprietary information was
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identified.
X2 Review of Updated Final Safety Analysis Report (UFSAR) Commitments i
A discovery of a licensee operatirig their facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that comparer. plant practices, procedures and/or parameters to the UFSAR descriptions. While performing the inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspect'>rs verified that the UFSAR wording was consistent with the observed pisnt practices, procedures and/or parameters.
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ATTACHMENT 1 LIST OF ACRONYMS USED ECCS emergency core cooling system eel escalated enforcement item FME foreign material exclusion IFl inspector followup item LER.
licensee event report PECO Peco Energy PDR public document room RHR residual heat removal SRV safety relief valve SR surveillance requirement TS technical specification URI unresolved item UFSAR updated final safety analysis report l
lNSPECTION PROCEDURES USED IP 37551 Onsite Engineering Observations IP 62703 Maintenance Observation IP 62707 Maintenance Observation IP 92700 Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-278/98-05-01 eel ECCS Suction Strainer Modification Procedures and Instructions inappropriate to Circumstances
50-278/98-05-02 eel 3A Core Spray Pump inoperable in Excess of TS 3.5.1 Time Requirements Closed
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50-278/3-98-001 LER Failure of 3A Core Spray Pump to Meet Performance Requirements Due to Foreign Material l
Discuse.ed
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l 50-277(278)/97-07-01 IFl Corrective Actions for Overtime Approval Control
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ATTACHMENT 2 3A CORE SPRAY PUMP TESTING PERFORMANCE TABLE
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DATE FLOW (GPM)
PRESSURE (PSIG)
TEST RESULT NOTES 07/15/97 3541 225 SAT 08/16/97 3487 230 SAT 09/24/97 3544 225 SAT 10/30/97 3523 225 SAT 12/24/97 3594 212 SAT CHANGE FROM l
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HISTORICAL PERFORMANCE l
03/22/98 3413 207 UNSAT l
03/23/98 3410 210 UNSAT 03/23/98 3420 205 UNSAT 03/24/98 3470 215 SAT
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03/24/98 3435 215 UNSAT 03/27/98 3566 225 SAT EACH HR DURING 4 HR RUN 3575 220 SAT 3578 220 SAT l
3584 220 SAT
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