ML20043G813

Responds to NRC 900515 Ltr Re Violations Noted in Insp Repts 50-277/90-06 & 50-278/90-06.Corrective Actions:Surveillance Test 6.16, Motor Driven Fire Pump Operability Test, Will Be Revised

ML20043G813
Person / Time
Site:	Peach Bottom
Issue date:	06/13/1990
From:	Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9006210158
Download: ML20043G813 (5)

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PHILADELPHIA ELECTRIC COMPANY b '

PEACll BOTTOM AlOMic POWER STATION R. D. I, Box 208

• 4 m %( Delta. Penmyh anta 17314 rex.si norrtai-nis rowsm os tscatttNca (717) 4 % 7014 D. B. Miller, Jr.

Vice President June 13, 1990 Docket Hos. 50-277 50-278 A

U.-S. Nuclear Regulatory Commission ATTH: Document Control Desk i j

Washington, DC 20555

SUBJECT:

Peach Bottom Atomic Power Station - Units 2 & 3  :

Response to Notice of Violations (Combined Inspection Report Nos. 50-277/90-06;50-278/90-06) .

Dear Sir:

In response to your letter dated May 15, 1990 which transmitted the subject Inspection Report and Notices of Violation, we submit the attached response. The subject inspection _ Report concerns a routine resident safety inspection during the period February 20 through April 2, 1990.

If you have any questions or require additional information, please do not hesitate to contact us.

Sincerely, ,

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Attachment ,

cc: R. A. Burricelli, Public Service Electric & Gas T. M. Gerusky, Commonwealth of Pennsylvania J. J. Lyash, USNRC Senior Resident Inspector

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T. T. Martin, Administrator, Region I. USNRC -

H. C. Schwemm. Atlantic Electric' J. M. Teitt, State of Maryland i J. Urban, Delmarva Power i

9006210150 900613 PDR ADOCK050g7 "

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Attachment  ;

Response to Notice of Violation 90-06-03 Restatement of Violation Technical Specification 6.6.1 requires that written procedures and r administrative policies shall be established, implemented, and maintained that '

meet the requirements of Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A or Regulatory Guide 1.33 (November 1972). Section 5,1.5 of ANSI N18.7-1972 requires procedures for control measures such as locking to secure and identify equipment in a controlled status. Appendix A of Regulatory Guide 1.33, Section A.3, also requires equipment control administrative procedures (e.g., locking).

Administrative procedure A-8, " Control of Locked Valves," Revision 6, Section

• 7.1.3 requires the rt: questor to complete a locked valve request, receive shif t management approval for each locked valve to be manipulated, inform the control room operator of the planned manipulation and to obtain the applicable locked valve key from the control room key cabinet.

1. Contrary to the above, on February 15, 1990, while performing ST 6.16,

" Motor Driven Fire Pump Operability Test," Revision 12, a non-licensed operator manipulated three locked manual valves (HV-0-370-12443, 12444, and 12345) without obtaining locked valve requests, shift management approval, and a locked valve key in accordance with procedure A-8. As a result the locking device for HV-0-370-12444 was not re-applied following the test.

2. Contrary to the above, on March 19, 1990, while conducting work under-maintenance request form 9001918, a test engineer unlocked and manipulated locked manual valves HV-2-33-21078A and 210788 (Reactor Core isolation Cooling System "A" and "B" room cooler inlet block valves) without obtaining locked valve requests and shift management approval as required by procedure A-8.

This is a severity Level IV Violation.

Corrective Steps Taken and Results Achieved On February 15, 1990 three locked manual valves were manipulated without obtaining locked valve requests with shift management approval, and a locked valve key as required by Administrative Procedure, A-8 " Control of Locked Valves" during the performance of ST 6.16. " Motor Driven Fire Pump Operability Test". The operator involved erroneously thought he did not have to use a lock valve. request form in A-8 since he was unlocking frangible locks on Fire Protection Valves and he was already in possession of the frangible lock key.

Management discussed the procedure compliance inadequacy with the operator involved and stressed the importance of following A-8, " Control of Locked' Valves". Discharge block valve, HV-0-37C-12444 for the Motor Driven Fire Pump '

was found to have it's locking device unsecured on March 2, 1990. A review of the Limiting Conditions for Operation (LCO) log, Locked Valve log and the permit system indicated no documented movement of HV-0-37C-12444, from February 15, 1990 through March 2, 1990. Additionally, there was no indication of movement in the operations shift log for the electrically

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supervised valve. It appears that the operator involved did not restore the chain t.nd lock to HV-0-370-12444 after performing ST 6.16. " Motor Driven Fire Pump Operability Test". The valve was found in the appropriate open position with the chain and lock hanging around the valve, but not locked. Immediate corrective action consisted of locking HV-0-370-12444. A review of ST 6.16 revealed-a deficiency where the step to reopen HV-0-37C-12444 did not state to relock it or-independently verify the return to its original open position.

The other valves were procedurally required to be relocked and included independent verififcation of appropriate positioning.

On March 19, 1990 locked ,alves HV-2-33-21078A and 201788, Reactor Core IsolationCooling(RCIC) System"A"and"8"roomcoolerinletblockvalves were unlocked without proper approval when a system engineer relinquished control rf the locked valve key to maintenance personnel who unlocked these additional valves that were not included on the Locked Valve 109 Immediate corrective action consisted of returning HV-2-33-21078A and 210788 to the appropriate locked position. A partial check-off list of the Unit 2 Emergency Service Water (ESW) system was performed to verify proper positioning of the valves. At the time of the event, Unit 2 was in cold shutdown and RCIC was not required tg be operable. Management and the. individuals involved also discussed the proced're u non-compliance. The importance of following Administrative Procedure A-8, " Control of Locked Valves" was discussed during a System Engineering Group All Hands meeting.

_ Corrective Steps Which Will Be Taken To Avoid Further Violations Surveillance Test (ST) 6.16. " Motor Driven Fire Pump Operability Test," will be revised to require independent verification (IV) of HV-0-37C-12444 restoration. The other locked valve restoration steps in ST 6.16 already requiredindependentverification(IV). Similar Fire Protection surveillances will be reviewed and revised as needed to ensure required IV is indicated for s restoration of locked valves. Appropriate operations personnel who possess

_ Fire Protection locked valve keys will be informed of this incident and will be cautioned to fully comply with A-8.

'Simi'ar to the System Engineering Group All-Hands meeting, the Maintenance Department will discuss the importance and significance of following Administrative Procedure A-8, " Control of Locked Valves" during their All-g Hands meeting.

Date When Full Compliance Will Be Achieved A locking device for HV-0-37C-12444, discharge block valve for the Motor Driven Fire Pump was installed March 2, 1990. Full compilance was achieved on March 19, 1990 with the return of Reactor Core Isolation Cooling System "A" i and "B" room cooler inlet valves HV-2-33-21078A ano 210788 to their normal 1 V locked position.

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J Response to Notice of Violation 90-06-04 .

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Restatement of Violation _

Technical Specification 6.8.1 requires that written procedures shall be l established, implemented, and maintained that meet the requirements of ,

Appendix A of Regulatory Guide 1.33 (November 1972). Regulatory Guide 1.33, Appendix A. requires implementation of radiation work permit (RWP) procedures.

Administrative procedure A-107, " Radiation Work Permit Program," establishes the RWP program, and Step 5.5 requires that individuals comply with the provisions of the RWP.

1. Radiation work permit 2-90-054200 required in special instruction 5 that individuals making entry to the Unit 2 torus room shall wear an alarming dosimeter and have positive health physics covtrage.

Contrary to the above, on March 27, 1990, two maintenance workers made two '

entries into the Unit 2 torus room, a posted high radiation area, without' complying with special instruction 5 of the Radiation Work Permit.

2. Radiation Work Permit 2-90-5491 required in the special instructions that individuals breaching or clearing sample lines to the waste surge tanks wear a filter respirator, a surgeon's cap, tape zipper and hood openings, <

and inform the controlling health physics technician of the breach so that he could be present.

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Contrary to the above, on March 28, 1990, four workers breached the sample

, line to the waste surge tank and cleared the line with nitrogen gas without complying with the special instructions on the Radiation Work Permit in that they did not inform health physics prior to breaching the system. and did not comply with the dress requirements.

This is-a severity Level IV Violation.

Corrective Steps Taken and Results Achieved Immediately after Health Physics identified these events, the individuals involved were denied access into any radiological controlled area. ,

Radiological Occurrence Reports (RORs) were promptly initiated for these  !

events and submitted to the appropriate work group supervisors for corrective '

action. The individuals involved were counseled and made aware of the importance of following radiation work permits (RWPs) and using good radiological work practices. Realizing the significance of these events, L meetings were held with appropriate management personnel and the individuals involved to discuss the events and develop measures to prevent recurrence, l Corrective Steps Which Will-Be Taken To Avoid Further Violations l A'. Peach Bottom each station work group was tasked by the Plant Manager to L develop Radiological Action Plans to improve radiological work practices.

These action plans were developed, in part, to focus on improvement in rad

( worker practices, minimize personnel contamination and strengthen root cause l

-analysis of Radiological Occurrence Reports (R0Rs). Additionally, a site

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distributed' letter issued from the Plant Manager on 4/23/90 emphasized the significance of ROR's and the constant vigilance needed for proper rad worker practices. This incident was also discussed during a Maintenance All-Hands

' Meeting.

Individuals involved in one incident were not stationed at Peach Bottom, but were PECo employees from Limerick Generating Station and the Nuclear.

Maintenance Division. These individuals developed a presentation entitled

" Safe Radiation Work Practices" which will be given to maintenance personnel from Limerick and Nuclear Maintenance to familiarize employees who do not routinely work at Peach Bottom with this incident, with safe radiological work practices and with the consequences of violating an RWP.

Date When Full Compliance Will Be Achieved Full compliance was achieved on March 28. 1990 when the workers involved were denied access into radiological controlled work areas until appropriate

. corrective action could be evaluated and taken.

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