ML20039A003
| ML20039A003 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/02/1981 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20038D164 | List: |
| References | |
| NUDOCS 8112160126 | |
| Download: ML20039A003 (6) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 1881 -1981 PHILADELPHIA. PA.19101 (2151 841 5001 swistos L c ALTaorr sucr..c moovem December 2, 1981 Re: Docket Nos. 50-277 50-278 Inspection Nos. 50-277/81-19 50-278/81-20 Mr.
R.
R. Keimig, Chief Reactor Projects Branch 2 Division of Resident and Project Inspection Region I U.S.
Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Keimig:
Your letter of November 5, 1981, forwarded combined inspection reports 50-277/81-19 and 50-278/81-20.
Appendix A of these reports addresses several activities which do not appear to be in full compliance with Nuclear Regulatory Commission Requirements.
These items are restated below along with our response.
A.
Technical Specification 3.7.D and Table 3.7.1 require that primary containment isolation valves, including High Pressure Coolant Injection (HPCI) steam line exhaust drain valves, be operable during power operation, or that at least one valve in each line with an inoperable isolation valve be in the isolation position, or that an orderly shutdown be initiated.
Contrary to.the above, from about 11:30 AM, August 8,
- 1981, until about 7:20 AM, August 9, 1981, HPCI Turbine Exhaust Drain Line Isolation Valve AO-4248, which had been found failed shut on August 8, 1981, was manually blocked open during power operation rendering its primary containment isolation function inoperable; no valve in that drain line was placed in the isolated (shut) position and an orderly shutdown was not initiated.
This is a Severity Level III Violation (supplement I) applicable to DPR-44.
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Mr.
R.
R. Keimig Page 2
RESPONSE
The failure to initiate an orderly unit shutdown or close the redundant isolation valve constituted a failure to meet the Technical Specification Limiting Conditions for Operation (LCO) requirements for primary containment isolation valves.
The cause of this failure was personnel oversight.
As detailed in LER 2-81-37/lP and IT licensed personnel took certain mitigating actions based on their concerns regarding operation with the HPCI system out of service.
At the time of the event the unit was operating near full power with 2 of 3 reactor feed pumps in service.
Tripping of a reactor feed pump in this operating condition would have certainly resulted in a low level scram and probably the attendant need to initiate the HPCI.
With this concern in mind, attention was placed upon assuring continued HPCI operability by maintaining the HPCI exhaust line drained (by manually blocking open AO-4248), verifying the isolation capability of the redundant valve, and expediting maintenance on the failed solenoid valve.
These considerations not withstanding, the licensed personnel who took these mitigating actions, rather than fully complying with the Technical Specifications, have been disciplined and forcefully instructed regarding the initiation of shutdowns and other actions required by the Technical Specifications.
Further we agree that the conclusions stated in the inspection report are correct; namely, had the proper log entries been made and proper post-maintenance testing been specified and performed the period of valve inoperability would have been reduced.
The individuals involved in both of these activities have been counseled in regard to proper performance of these functions.
Your letter expressed concern about the implementation of our management control systems in this area.
As implied in this statement, Administrative Procedures A-7 and A-26 address the proper actions which should have been taken in response to this occurrence.
In order to further stress the importance of adhering to such procedures and controls, this pcrticular occurrence is being discussed, with other items, 10 meetings held l
with shift supervision, licensed, and non-licensed operators.
Emphasis is being placed upon the importance of referencing and completely reviewing and complying with the Technical Specifications.
These discussions will be completed by December 30, 1981.
B.
Criterion V, Appendix B, 10 CFR 50, requires activities affecting quality to be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances.
The licensee's approved QA Plan, Revision 4, January 1980, i
l
Mr.
R.
R.
Keimig Page 3 Section 2, requires that personnel participating in an
-activity be aware of and use proper and current drawings.
Peach Bottom Procedure A-6, Revision 7, April 19, 1981, requires that controlled drawings be updated to show significant changes and requires that operating personnel use controlled-copies.
Drawing M-372, Containment Atmosphere Dilution System, is included in the scope of Procedure A-6.
Contrary to the above, by August 18, 1981, the control room copy of drawing M-372 had not been updated to include the Unit 2 radioactive gas sampler containment isolation valve installed in October, 1980.
Further, a later revision to M-372, distributed on August 21, 1981, did not legibly show the radioactive gas sampler containment isolation valve on-controlled copies in the control room and shift supervision office.
This is a Severity Level V Violation (Supplement I) appli-cable to DPR-44.
RESPONSE
Modifications to the radioactive gas sampling system installed an isolation valve.
Upon completion of the modification the valve was hand drawn on to the control room controlled copy in accordance. with ' procedure.
A delay in the official request by site construction to engineering design to include the valve ~ allowed the revised print to be issued with the valve only faintly shown.
The licensee representative who marks up the controlled drawings, saw the raint outline of the valve and did not recopy the valve on to the revised print.
The inspector notified the plant staff of this discrepancy and a licensee representative immediately corrected the discrepancy.
l Construction Division was notified and a letter was drafted
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advising engineering design to revise the print.
Construction Division has been appraised of the significance and importance of timely forwarding of pertinent information upon completion of modifications.
C.
Technical Specification 3.1 and Table 3.1.1 require, in the Startup and Run modes, that at least two APRM high flux instrument channels be operable in each reactor protection trip system, or that the affected trip system be tripped, or L
that all operable control rods be inserted within four hours.
Table 3.1.1, Note 11 states that an APRM is operable if there are at least two LPRM inputs per level.
l Contrary to the'above, from about 5:30 AM on April 24, 1981, until about 12:05 AM on April 27,-1981, with the' reactor in the!'Startup' and 'Run' modes, Reactor. Protection System Logic Trip System
'A' was at times receiving input from only L
o Mr.
R. R. Knimig Paga 4 one operable APRM, Logic Trip System
'A' was not tripped, and all operable control rods were not inserted.
This is a severity Level III Violation (Supplement I) applicable to DPR-44.
RESPONSE
As stated in LER 2-81-39/1T, the C level of APRM C was receiving input from only one LPRM.
When the C APRM was in service, the A Logic Trip System was at times receiving input
.from only one fully operable APRM because APRMs A and E were bypassed on occassion.
As soon as the situation was recognized the C APRM was bypassed and an investigation determined that a C level LPRM could be returned to service, thus restoring two C level inputs to APRM C.
Engraved placards have been ins *:alled on the reactor operator's console stating that APRMs must have at least two LPRM inputs per level to be operable.
Your letter also expressed concern about the implementation of our management control systems in this area.
In this instance our controls can and will be improved.
Procedures will be written or revised no later than December 30, 1981, which address actions to be taken prior to bypassing an LPRM to prevent operation with less than 2 LPRMs per level per APRM.
These procedures will require periodic surveillance of the LPRM inputs to APRMs to verify that each APRM has at least two LPRM inputs per level.
Additionally, a review of Technical Specifications dealing with thermal limits (sections 2.1.A.1, 2.1.B, 3.5.I, J, and K) will be conducted to verify adequate surveillance tests exist to ensure limiting conditions for operations and surveillance requirements ere met.
t D.
Technical Specification 4.6.A and Peach Bottom Surveillance i
Test ST 9.12, Revision 3, April 6, 1977, require, during heatups and cooldowns, logging of bottom head drain and recirculation loop "A" and "B"
temperatures at leash every 15 minutes until the difference between any two readiaqs taken over 45 minutes is less than 5 degrees F.
Contrary to the above, during cooldown on August 18, 1981, logging of temperatures was stopped at 5:00 AM although the temperatures had changed by 42 to 47 degrees during the previous 45 minutes.
This is a Severity Level VI Violation (Supplement I) applicable to DPR-44.
a 8r.- R. R. Knimig Paga 5 i
RESPONSE
During heat ups and cool downs, Technical Specifications F
require that recirculation loop A and B and bottom head drain temperatures be logged at 15 minute intervals until less than' a 5 degree change over a 45 minute period is attained.
On' August 18, 1981, during a cooldown, temperature logging was stopped at 220 degrees F with temperatures during the previous 45 minutes having changed approximately 45 degrees.
1 The surveillance test, ST 9.12, required for this-temperature logging has a dual purpose; to log temperatures as
- stated in D above, or to log temperatures when the vessel shell is below 220 degrees F and not vented.
The operator misunderstood the intent of the surveillance test and stopped logging temperatures when the vessel was at 220 degrees and.was e
vented.
The surveillance test has been revised to clearly define the differences ~in these two logging requirements and provide l
direction to continue temperature logging during cooldown until approximately 170 degrees F-is attained.. ~This surveillance test l
was revised and approved on November 25, 1981.
I i
very truly yours,-
)f r
I '1 i'
Site Inspector - Peach Bottom cc:
- P.O.
Box.399 Delta, PA 17341-0399 i
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COMMONWEALTH OF PENNSYLVANIA :
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COUNTY OF PHILADELPHIA S.
L. Daltroff, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing response to Inspection Report No. 50-277/81-19 and 50-278/81-20, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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