IR 05000377/1998003
| ML20249C135 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, 05000377  |
| Issue date: | 06/19/1998 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| 50-377-98-03, 50-377-98-3, 50-378-98-03, 50-378-98-3, NUDOCS 9806260094 | |
| Download: ML20249C135 (3) | |
Text
June 19, 1998
SUBJECT:
COMBINED INSPECTION REPORT NOS. 50-277/98-03 AND 50-278/98-03
Dear Mr. Rainey:
This letter refers to your June 2,1998, correspondence in response to our March 30, 1998 letter.
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.
Your cooperation with us is appreciated.
Sincerely, Original Signed by:
Clifford J. Anderson, Chief Projects Branch 4 Division of Reactor Projects Docket Nos. 50-277;50-278 cc w/ Licensee Response Ltr:
T. Niessen, Director, Nuclear Quality Assurance G. J. Lengyel, Manager, Experience Assessment J. W. Durham, Sr., Senior Vice President and General Counsel
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T. M. Messick, Manager, Joint Generation, Atlantic Electric i
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-Commonwealth of Pennsylvania
. State of Maryland TMI-Alert (TMIA)
9906240094 990619
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Mr. cc w/o Licensee Response Ltr:
G. Edwards, Chairman, Nuclear Review Board and Director, Licensing J. Doering, Vice President, Peach Bottom Atomic Power Station J. B. Cotton, 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
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Mr. Distribution w/ Licensee Response Letter:
Region i Docket Room (with concurrences)
C. Anderson, DRP D. Florek, DR7 R. Junod, DRP Nuclear Safety Information Center (NSIC)
NRC Resident inspector PUBLIC B. McCabe, OEDO R. Capra, PDI-2, NRR Inspection Program Branch, NRR (IPAS)
M. Thadani, NRR B. Buckley, NRR R. Correia, NRR F. Talbot, NRR DOCDESK I
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DOCUMENT NAME: A:\\RL903.PB To receive a copy of,this document, indicate in the box: "C" = Copy without attachment / enclosure
"E" =
Copy with attactw@t/ enclosure
"N" = No copy l
OFFICE Rl/)Rp i Rl/DRP l
NAME DQ@k
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OFFICIAL RECORD COPY I
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John Doeting, Jr.
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Vice P esdant
Peach Bet om Atomic Power Sta::on
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PECO NUCLEAR at=~ comoeev
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1343 Lay Road A Unit of PECO Energy cer.a PA 17314 9032 717 456 4000 Fax 717 455 4243 E mait doenng@peco-energycom i
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June 2,1998 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission 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. 50-277/98-03 & 50-278/98-03)
Gentlemen:
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In response to your letter dated March 30,1998 which transmitted the Notice of Violations
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concerning the referenced inspection report, we submit the attached response. The i
subject report concemed a Special Inspection on the 2A reactor feedpump turbine which was conducted between February 12 and March 3,1998.
If you have any questions or desire additionalinformation, do not hesitate to contact us.
John Doering, Jr.
Vice President,
' Peach Bottom Atomic Power Station
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Attachments
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MT/mt cc:
N.J. Sproul, Public Service Electric & Gas
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R. R. Janati, Commonwealth of Pennsylvania
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H. J. Miller, US NRC, Administrator, Region i
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A. C. McMurtray, US NRC, Senior Resident inspector
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T. M. Messick, Atlantic Electric R. l. McLean, State of Maryland A. F. Kiroy ill, DelMarVa Power CCN 9814037 -
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OEAP Coordinator 62A-1, Chesterbrook Correspondence Control Program 618-3, Chesterbrook NCB Secretary (11)
62A-1, Chesterbrook D. M. Smith 63C-3, Chesterbrook G. R.' Rainey 63C-3, Chesterbrook
- J. Doering SMB4-9, Peach Bottom
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J. B. Cotton 62C-3, Chesterbrook T. J. Niessen 53A-1, 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 Bottom R. A. Kankus 61C-1, Chesterbrook G.J.Lengyel A4-4S, Peach Bottom M.J. Taylor A4-5S, Peach Bottom
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RESPONSE TO NOTICE OF VIOLATION 98-03
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Restatement of Violation 10 CFR50.73 (a) requires, in part, that the licensee submit a Licensee Event Report (LER),
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within thirty days, for any deviation or condition prohibited by the plant's Technical Specifications.
Contrary to the above, the NRC identified that as of March 3,1998, an LER had not been submitted for the event on April 1,1997, involving a condition prohibited by Technical Specification Section 3.3.2.2, "Feedwater and Main Turbine High Water Level Trip
' instrumentation." Specifically, the 2'A' Reactor Feedwater Pump Turbine high water level trip capability was inoperable for greater than two hours while Unit 2 reactor power was >
25%. The main turbine trip function and the trip functions on the two other reactor feed pumps remained operable during this time.
.This is a Severity Level IV violation (Supplement 1).
Reason (s) For The Violation On April 1,1997, while completing operator actions to remove from service the 2A reactor feedpump turbine (RFPT), the feedpump failed to trip on a momentary signal from the main control room push-button. The turbine had already been secured per procedure from
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injecting several hours earlier. The tripping of the turbine and closure of the stop valves is a follow up action by operations personnel.
At the time the turbine failed to trip, operations personnel declared the 2A RFPT inoperable and took all appropriate technical specification (TS) actions to maintain compliance. When the deportability determination was made, responsible personnel verified that all required TS actions had been met and determined that the event was not reportable.
The plant staff used NUREG -1022, revision 1 (draft), " Event Reporting Guidelines 10 CFR 50.72 and 50.73", section 3.2.2 in making their determination. Under item (2), Limiting Condition for Operation, it states, "For the purpose of this discussion, it is assumed that there was firm evidence that a condition prohibited by TS existed before discovery, for a time longer than permitted by TS." The conditions discovered during investigation of the feedpump_ turbine trip mechanism included some dirt and oil film buildup in the trip dump
- valve. - This was believed to be the apparent cause of the failure to trip. Since the trip feature had been successfully tested during refueling outage 2R12 in October 1996 and l
" firm evidence that a condition prohibited by TS existed before discovery" was not l-determined, the plant staff did not report the event under 10 CFR 50.73. Plant staff I
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and personnel investigating the evident did not believe that the conditions noted comprised
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" firm evidence" and that the condition existed beyond the TS action times.
In subsequent discussions with the NRC residents and interpretation of the deportability position by Office for Analysis and Evaluation of Operational Data (AEOD) personnel, it was
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made apparent that the plant staff interpretation of NUREG -1022 was narrow. Under item (3), Technical Specification Surveillance Requirements, it states that, "It should be assumed that the discrepancy occurred at the time of its discovery unless there is firm evidence, based on a review of relevant information (e.g., the equipment history and cause of failure) to believe that the discrepancy existed previously."
Upon further review,it was apparent that plant staff did not consider this second statement in making their determination. Since the dirt and oil buildup conditions (cause of failure) noted in the trip dump valve were the result of less than adequate maintenance (equipment history), the plant staff should have concluded that those conditions impacted 2A RFPT operability longer than TS action times Corrective Steos That Have Been Taken and the Results Achieved The April 1,1997 failure to trip event was discussed in an Licensee Event Report (LER) 2-97-009, submitted on December 9,1997 for a similar failure to trip event on November 9, 1997. The November event was originally attributed to intermittent mechanical binding of some trip mechanism subcomponents. At the time of LER 2 97-009 submittal, this binding was also believed to be the most likely cause of the April 1 event. Therefore, the April 1
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event was communicated to the NRC in LER 2 97-009.
Corrective Steos That Will Be Taken To Avoid Further Violatiens Plant staff who routinely determine deportability and write LERs have been counseled on this event and the broader view of NUREG - 1022 that is required in making these determinations.
pate When Full Camoliance Was Achieved Full compliance was achieved on December 9,1997 when the April 1,1997 event was reported to the NRC in LER 97-009.
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