ML20057C228
| ML20057C228 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/22/1993 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20057C221 | List: |
| References | |
| 50-277-93-17, 50-278-93-17, NUDOCS 9309280097 | |
| Download: ML20057C228 (18) | |
See also: IR 05000277/1993017
Text
{{#Wiki_filter:. . - -. . _ ~ -. . .- - - . - . , . U. S. NUCLEAR REGULATORY COMMISSION - ' REGION I Docket / Report No. 50-277/93-17 License Nos. DPR-44 . 50-278/93-17 DPR-56
Licensee: Philadelphia Electric Company Peach Bottom Atomic Power Station , P. C. Box 195 ! Wayne, PA 19087-0195 ' Facility Name: Peach Bottom Atomic Power Station Units 2 and 3 Dates: August 3 - September 13,1993 . l Inspectors: W. L. Schmidt, Senior Resident Inspector B. S. Norris, Acting Senior Resident inspector F. P. Bonnett, Resident Inspector R. K. Lorson, Resident Inspector
07 mI Pkth3 Approved By: 4 C. J. Anderson, Chief V V Date - ! Reactor Projects Section 2B ! - Division of Reactor Projects ! , l ,
, ! f i + i l > f , 9309280097 930922 ! PDR ADDCK 05000277 ! G PDR " i I . v.-- - . _ - , . ,_. . . - ~ _
. _. - . . . EXECUTIVE SUMMARY Peach Bottom Atomic Power Station j i Inspection Report 93-17 . Plant Oocrations ' ! The operations personnel responded promptly and appropriately to the '3B' recirculation pump seal failure. (Section 1.0) The inspectors concluded that adequate measures were implemented ' to monitor the remaining '31r recirculation pump seal. The inspector observed that operations personnel took appropriate actions when the test acceptance limits were exceeded during the l Unit 2 modification acceptance test for the setpoint setdown function of the digital feedwater control system. (Section 1.0) ) ! During the installation of the reactor water level backfill modification on Unit 2, the inspector
noted a procedural weakness regarding the isolation of the reactor vessel water level l instrumentation. (Section 3.2.2) This weakness resulted in the generation of a false low reactor level signal and ECCS initiation signals on two occasions. As a result of another occurrence, the licensee appropriately initiated an orderly shutdown of Unit 3 upon recognizing that all but , one of the residual heat removal pumps were inoperable. Maintenance and Surveillance The Unit 2 outage to install the reactor vessel water level backfill modification was generally well managed. The inspectors observed that licensee personnel installing the modification appeared knowledgeable and employed good housekeeping practices. (Section 3.1) t The licensee declared the Unit 3 high pressure coolant injection system inoperable when speed and flow oscillations were observed during surveillance testing. The licensee determined that ! - component drifting and dirt caused an improper response to the flow feedback signal. The l inspector questioned whether the HPCI system would have automatically initiated and injected - j within its' design limits (URI 93-17-01). (Section 2.1)
Engineering and Technical Supoort During the modification acceptance testing for the reactor vessel water level instrumentation , backfill modi 6 cation, PECO identified that the new in-series, piping class boundary, check l valves were not functionally tested as specified in ASME code, Section XI. In-service testing ! was performed on the eight check valves which disclosed three failed valves. These valves were replaced and retested satisfactorily. (Section 3.1.2) 1 9 ii
- .. - - . t j . TABLE OF CONTENTS Page j 1 EXECUTIVE SUMMARY il . . . ................................... 1.0 PLANT OPERATIONS REVIEW I ............................. 1 2.0 FOLLOW-U P OF PLANT EVENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2 2.1 Unit 3 High Pressure Coolant Injection System Inoperable 2 .......... 2.2 Unit 3 Plant Shutdown Required By Technical Specifications . . . . . . . . . 3 -i 2.3 Licensee Event Report Update 4 - ........................... 3.0 M AINTENANCE ACTIVIT f OBSERVATIONS . . . . . . . . . . . . . . . . . . . . 5
. 3.1 Unit 2 Outage 5 . . ................................... , 3.1.1 Feedwater Control System Modi 0 cation Acceptance Test 5 .; ....... ... 3.1.2 Reactor Vessel Water IAvel Backfill Modification Installation 6
........ 4.0 SURVEILLANCE TESTING OBSERVATIONS . . . . . . . . . . . . . . . . . . . . . 6 j . ' 5.0 PLANT SUPPORT . . . . . . . . . . . . . 7 ......................... 5.1 Radiological Controls . . . . . . . . . . . . . . . . . 7 ... ........... 5.2 Physical Security . . 7 ................. ........... ... 5.3 Employee Concern Program (TI 2500/028) . . . . . 7 .............. . 6.0 PREVIOUS INSPECTION ITEM UPDATE , . . . . . . . . . . . . . . . . . . . . . 8 7.0 M A N AG EM ENT M EETI N'GS . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 . 1 .. iii l 4 - - - - --- - - - . - . , - - . - . - r.- .--
- - - _ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - . - - - - - - . -- - - - . , . . DETAILS 1.0 PLANT OPERATIONS REVIEW (71707)* l l The Philadelphia Electric Company (PECO) safely conducted normal operating and shutdown activity at Peach Bottom Atomic Power Station (PBAPS) Unit 2 (Unit 2) and Unit 3 (Unit 3) over the period. The inspectors completed NRC Inspection Procedure 71707, " Operational Safety Verification," by directly observing safety significant activities and equipment, touring the facility, and interviewing and discussing items with licensee personnel. The inspectors independently verified safety system status and Technical Specification (TS) Limiting Conditions for Operation (LCO), reviewed corrective actions, and examined facility records and logs. The inspectors performed 9 hours of deep backshift and weekend tours of the facility. Unit 2 was operating at 100% power at the beginning of the inspection period. Operations conducted a planned manually scram on August i1, to perform a modification acceptance test of the setpoint setdown function of the digital feedwater control system (Section 3.1.1) and to install a modi 6 cation on the reactor vessel water level instrumentation (Section 3.1.2). PECO restarted the unit on August 16, and maintained reactor power at about 12% to complete the reactor vessel water level instrumentation modification acceptance testing. Unit 2 reached 100% power on August 23, and essentially operated at this power level for the remainder of the inspection period. Unit 3 began the period operating at 100% power near the end of the fuel cycle, ending the period at 88% power. In order to maximize the power generation during the coast down, the licensee raised reactor pressure to about 1005 pounds per square inch (psig), and allowed L pressure to coast down along with power. As a result, the increased pressure increased l reactivity which caused an increase in electrical output. PECO evaluated this strategy in l Engineering Work Request (EWR) A0761522 and in the safety analysis report for the upcoming l power rcrate. The inspector reviewed the documents and agreed that the reactor was being operated within its design parameters. Other than the planned shutdown on Unit 2, the Units did not experience any major transients or engineered safety feature (ESF) actuations. During the report period, the inspectors evaluat- ed licensee staff and management response to plant equipment problems to verify that the licensee had identi6ed the root cause, implemented appropriate corrective actions, and made the required noti 6 cations. The inspectors observed control room operations and noted that supervi- sion maintained good oversight of activities and responded appropriately to equipment problems. One noteworthy, non-reportable event occurred on Unit 3. On August 5, the Unit 3 control Room Staff observed that the '3B' Recirculation Pump first stage seal had failed. Operators noted pressure oscillations with high temperature and high Cow alarms for the second stage seal. The operators entered the System Operating (SO) Procedure (SO 2A.2. A-3) to shutdown l The inspection procedure frorn NRC Manual Chapter 2515 that the inspectors uwd as guidance is
parenthetically listed for each report section. l \\ ___ ]
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. k 4 2 . the recirculation pump and GP-9, " Fast Reactor Power Reduction." The operators reduced i recirculation pump speed to a minimum and inserted the appropriate control rods to reduce . reactor power. The recirculation pump was not secured because the pump seal temperature [ decreased to an acceptable value during the power reduction. PECO initiated a Reportability Evaluation / Event Investigation Form (RE/ elf) to determine the cause of the failure.
The licensee consulted with the vendor of the pump seal and determined that continued _ pump , seal operation was acceptable until the Unit 3 refueling outage in September. Operators
continued to closely monitor the seal cavity temperatures, and drywell sump pump-out rates to l detect further seal degradation. A shift update notice (SUN) and briefing package were issued to all operators which included a strategy to be followed in the event the second seal failed. i The inspector reviewed the SUN, discussed the seal problem with the lead maintenance - foreman, and observed the operators attentiveness in the control room. At the close of this report, the licensee has not been able to determine the cause of the scal's failure. However, the i pump seal was scheduled for replacement and disassembly during the upcoming refueling - outage.
The inspector concluded that the control room operator's response to the recirculation pump seal j failure was prompt and appropriate. Additionally, the preventive measures to monitor the remaining seal allowed continued safe operation of the pump until the upcoming outage. , i 2.0 FOLLOW-UP OF PLANT EVENTS (71707, 92701, 92702) During the report period, the inspectors evaluated PECO's staff and management response to , ' plant events to verify proper identification of the root causes, to ensure the implementation of appropriate corrective actions, and to ensure that all required noti 6 cations were made. Events occurring during the period are discussed individually below. 2.1 Unit 3 High Pressure Coolant Injection System Inoperable On August 9, while performing monthly surveillance test (ST)-O-023-300-3, "HPCI Pump, Valve, and Flow," the operating crew observed speed and Dow oscillations and declared the Unit 3 high pressure coolant injection (HPCI) system inoperable. Operators had just placed the HPCI turbine in-service when the demand signal from the flow indicating controller (FIC)-3-23- 108, which controls the steam flow to the HPCI turbine, began to oscillate between 30% and 80%. The oscillating demand signal caused the turbine speed and system flow to oscillate. The oscillation stabilized after the operators took manual control of the FIC. The turbine was secured, the system declared inoperable, and the appropriate seven day LCO entered. The licensee notified the NRC via the Emergency Notification System (ENS). j - . - - - . .Y
- _ - -- -- .- - .- l . , , l . 1 3 ! The licensee initiated an investigation into the cause of the FIC demand signal oscillation. The
FIC was removed from the control panel and inspected, cicaned, and bench tested. The licensee determined from their investigation, that drifting of the control and gain pots and dirt caused an improper response to the Dow feedback signal. The controller was replaced. The ' gain pots were adjusted to tune the flow feedback response, and the system was retested satisfactorily. The HPCI system was declared operable at 2:30 p.m., on August 10, 1993,
within the LCO time. . 1- l j' The FIC is an analog General Electric Manual / Automatic Controller (GEM AC). Due to its age, , ' PECO initiated an evaluation to determine what corrective actions are required to ensure
continued operability of these type controllers. One consideration, presently under review, is j the replacement of this controller in the HPCI and reactor core isolation cooling (RCIC) systems ! with a more modern functionally equivalent controller.
The inspector determined that the safety significance of this event was low. From the review > of the licensee's conclusions, the inspector agreed that the HPCI system was capable of ,' injecting water into the reactor, in its manual mode. Due to the existing controller oscillations, however, the inspector questioned whether the HPCI system would have automatically initiated
and injected within its design limits. This item will remain unresolved pending further review l (URI 93-17-01).
2.2 Unit 3 Plant Shutdown Required By Technical Specifications I On August 14, the licensee began an orderly shutdown, required by TS, of Unit 3 after determining that three of the four residual heat removal (RHR) pumps were inoperable. At the time of the event, Unit 3 was operating at 100% power. At the time, Unit 2 was already shutdown while PECO installed the reactor vessel water level backGli modification. As a result of a poor isolation of a reactor vessel level transmitter two false Lo-le-Lo (-160") vessel water level and a loss of coolant accident (LOCA) signal occurred at Unit 2. Operators had intentionally blocked all the Unit 2 automatic emergency core cooling systems (ECCS) actuation signals during the modification installation. Therefore, the false Lo-la-Lo vessel level signal had no signiGcant affect on Unit 2. However, at Unit 3, the Unit 2 LOCA signal caused the auto-start-logic for the '3A' and '3B' RHR pumps to be defeated. This cross-unit LOCA signal defeating of auto-start-logic was designed to prevent overloading of the emergency diesel generators. One other Unit 3 RHR pump (3D) had previously failed a surveillance test and was considered inoperable. This condition rendered both of Unit 3's containment cooling loops inoperable. Technical specifications required PECO to place Unit 3 in cold shutdown within 24 hours. The licensee initiated a Unit 3 shutdown while the I&C Technicians cleared the LOCA signal. The licensee exited the shutdown LCO approximately seven minutes after declaring the i event. The actual change in Ur.it 3 power level was minimal. The licensee notified the NRC I via the ENS. i .. . - _ 4 . - ., ,.
. _ __ . _ _ ._ . ! , i ' 4 ! . Inspector review indicated that the cause of the Lo-Lo-Lo level signal was that PECO had not fully isolated and equalized two wide range reactor vessel water level instruments. The transmitters LT-72B and LT-72 D, which share common instrument piping were isolated on the reference leg side by a manual hand valvejust downstream of the excess flow check valve. The ' variable legs were not isolated and the equalizing valves were not open. This allowed pressure ! to buildup in the isolated section of the reference leg tubing as the reactor building ambient i temperature increased. This caused the two transmitters to sense a lowering water level. Once the apparent level reached the Lo-Lo-Io setpoint the trip units for both transmitters caused a l LOCA signal to be sensed by the reactor protection system at Unit 2. If the transmitters had been properly isolated with the equalizing valves open this event would not have occurred. The licensee cleared the false -160 inch indication by removing LT-72B from service and opening ' the equalization valve. The LT-72D remained in-service. The inspector also determined that General Procedure (GP)-20, " Temporary Defeating of Core t Spray and RHR Pump and Diesel Generator Auto Starts During Outages." did not defeat the
cross-unit LOCA signal. The procedure defeated the automatic start signals to these ECCS ' , systems to prevent flooding of the reactor cavity during an outage. The licensee initiated a ' correction to GP-20 to address the LOCA signal effects on the opposite unit. Additionally, the licensee performed a review of the event and developed interim corrective actions to preclude a similar type of event from occurring during installation of this modification on Unit 3. These - actions include modifying the isolation procedure to open the reactor vessel water level instrumentation equalizing valve and development of a special procedure to control the I instrument's restoration. The licensee's final corrective actions are still being developed and are I tracked by the RE/EIF process. l 2.3 Licensee Event Report Update During the report period, the inspectors evaluated licensee staff and management response to plant events which occurred, as discussed in Section 2.0 of the report. In addition, the inspec- tors reviewed Licensee Event Reports (LERs) submitted by the licensee during the period for events which were of lower safety significance, and did not warrant immediate review and evaluation by the inspector at the time of the event. The inspector reviewed the following LERs and found that the licensee had identified the root causes, implemented appropriate corrective actions, and made the required notifications. LER No. LER Date LER Title 2-93-011 6/25/93 New fuel oil was added to a diesel generator fuel oil storage tank prior to completion of the chemical analysis. , 1 i 2-93-012 6/1/93 Missed fire protection system surveillance test. ,
. _ - ~ - _ ~ _ - . - . . 4 5 3.0 MAINTENANCE ACTIVITY OBSERVATIONS (62703) The inspectors observed portions of ongoing maintenance work to verify proper implementation of . maintenance procedures and controls. The inspectors veriGed that the licensee adequately implemented administrative controls including blocking permits, fire watches, and ignition souice and radiological controls. The inspectors reviewed maintenance procedures, action requests (AR), work orders (WO), item handling reports, radiation work permits (RWP), material certifications, and receipt inspections. During observation of maintenance work, the inspectors verified appropriate Quality Verification (QV) involvement, plant conditions, TS ' LCOs, equipment alignment and turnover, post-maintenance testing and reportability review. The inspectors found the licensee's activities to be acceptabic. - 3.1 Unit 2 Outage On August 11, operators manually scrammed Unit 2 from 100% power to conduct planned modification testing of the new digital feedwater system and to allow installation of a continuous makeup source for the reactor vessel water level instrumentation reference legs. The modiGeation was designed to prevent the buildup of non-condensable gases in the reactor vessel water level instrumentation reference legs as described in NRC Inspection Report 93-15 and NRC Bulletin 93-03. The inspectors attended planning and status meetings prior to and during the outage to evaluate the licensee's planning and coordination of activities. The inspectors observed minor maintenance activities performed during the outage on the recirculation and feedwater systems, noting acceptable administrative work controls, housekeeping and maintenance practices. The inspectors concluded that PECO managed the outage well. However, an inadequate isolation of Unit 2 reactor vessel water icvel instrumentation caused the - inoperability of two Unit 3 RHR pumps and entry into a shutdown LCO. (See section 2.2). 3.1.1 Feedwater Control System Modification Acceptance Test ' PECO installed a digital feedwater control system modification as discussed in NRC Inspection Reports 91-34, 92-32, and 93-01. This modification added a level setpoint setdown feature I designed to improve reactor water level control and minimi7e operator _ intervention following a reactor scram. The modiGcation acceptance testing (MAT) for the level setpoint seldown function required a reactor scram from full power and was not performed during the MAT for t the remainder of the digital feedwater control system. The level setpoint function has been - deactivated since installation. The MAT required the system to maintain reactor level between speci6ed limits for three minutes following a reactor senm from full power without operator action. . The inspector reviewed the MAT procedure and noted that appropriate prerequisites and test intervention points were included. The inspector considered the licensce's use of the simulator to train operators prior to performing the test a positive initiative. The inspector observed the test and noted that operations personnel took appropriate action when the test acceptance limits . .- -. _ . _ .
, - . _ . - - - - - 1 . . 6 were exceeded. The inspector discussed the test results with site and corporate engineering personnel and noted that the licensee intends to leave this function deactivated pending future testing. The inspector had no further questions. . 3.1.2 Reactor Vessel Water Level Backfill Modification Installation The inspector reviewed the installation and testing activities associated with the reactor vessel water level instrumentation modi 6 cation. The modification was designed to provide a constant source of water from the control rod drive (CRD) system to the reactor vessel water level instrument reference legs. PECO staged, flushed, and performed a hydrostatic pressure test of the system components prior to the reactor shutdown. Following the shutdown, the licensee connected the system into the four reference legs, and performed the system startup and modification acceptance testing (MAT)-128. The inspector noted that the installation activities were well controlled. Personnel installing the modification appeared knowledgeable and employed good housekeeping practices. The licensee restarted Unit 2 on August 16, and continued conducting MAT-128, to verify the design intent and installation of the Backfill Modification. During the performance of the portion of the MAT that manually isolated the system, the licensee identified that the two new in-series check valves were not being functionally tested as specified in ASME code, Section XI. In-service testing (IST) was necessary because the check valves were located inside the qualiGed boundary to each reference leg. The Engineering Staff stated that IST was not necessary because the valves were bench tested at the Valley Forge Laboratory prior to their installation. The Plant Operations Review Committee (PORC) reviewed the concern and determined that the check valves were a part of the in-service program and thereby IST should be performed. The Engineering Staff determined the acceptance criteria for the check valves , was zero leakage at a differential pressure of 10 psid. The IST of the eight check valves I resulted in detection of three failures. These valves were replaced and retested satisfactorily. The MAT was completed and accepted by PORC. The backfill system was placed in-service , and the Unit start-up was continued. ) i The inspector observed selected portions of the pre-startup valve lineups, flushing, and M AT and noted that these activities were performed in accordance with the procedure _(MAT-128). The inspector observed the placing of the '2A' system in service and noted that the pre-job brief was thorough and communications were cicar throughout the evolution. 4.0 SURVEILLANCE TESTING OBSERVATIONS (61726, 71707) The inspectors observed conduct of surveillance tests to determine if approved procedures were used, test instrumentation was calibrated, qualified personnel performed the tests, and test acceptance criteria were satisfied. The inspectors verified that the surveillance tests had been properly scheduled and approved by shift supervision prior to performance, control room operators were knowledgeable about testing in progress, and redundant systems or components .
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7 were availabic for service, as required. The inspectors routinely verified adequate performance of daily surveillance tests including instrument channel checks, and jet pump and control rod operability tests. The inspectors found the licensee's activities to be generally acceptable. ' 5.0 PLANT SUPPORT (71707, 90712) 5.1 Radiological Controls The inspectors examined work in progress in both units to verify proper implementation of health physics (HP) procedures and controls. The inspectors monitored the ALARA (As law As Reasonably Achievable) program implementation, dosimetry and badging, protective clothing use, radiation surveys, radiation protection instrument use, handling of potentially contaminated equipment and materials, and compliance with RWP requirements. The inspectors observed that personnel working in the radiologically controlled areas were meeting applicable require- ments and were frisking in accordance with IIP procedures. During routine tours of the units, , the inspectors verified a sampling of high radiation area doors to be locked, as required.- All activities monitored by the inspectors were found to be acceptable. . 5.2 Physical Security The inspectors monitored security activities for compliance with the accepted Security Plan and associated implementing procedures. The inspectors observed security staffing, operation of the Central and Secondary Access Systems, and licensee checks of vehicles, detection and assess- ment aids, and vital area access to verify proper control. On each shift, the inspectors observed l protected area access control and badging procedures. In addition, the inspectors routinely inspected protected and vital area barriers, compensatory measures, and escort procedures. The inspectors found the licensee's activities to be acceptable. On August 10,1993, the Security Managers of the PBAPS and Limerick Generating Station met with the NRC Region I Security Section staff members at King of Prussia, Pennsylvania. The purpose of the meeting was to discuss the proposed revision to the Peach Bottom Security Plan, Contingency Plan, and Training and Qualification Plan, and to brief the staff regarding construction of a new security access facility at the Limerick station. The meeting was closed ' to the public due to the anticipated extensive discussion of safeguards information. The meeting was an effective forum for open discussion. 5.3 Employee Concern Program (TI 2500/028) The NRC is currently conducting a survey to determine if each licensee has an employee concerns program, and, if so, what the characteristics of that program are. The details of the inspectors' review are enclosed as an attachment to this report. , I i
. i l . 8 In summary, the licensee has two formal programs and one informal program to handle employce's concerns. The programs are directed mostly at quality concems; however, they also , provide for personnel and industrial safety issues. The programs are overscen by the Director,
Nuclear Quality Assurance. All site personnel, licensee and contractor, are informed of the - various programs as part of the initial site general employee training. This awareness is reinforced during the required annual refresher training. The inspector concluded that the , licensee's programs were adequate and well managed.
6.0 PREVIOUS INSPECTION ITEM UPDATE (92701, 92702) (Closed) Unresolved item 92-13-01, " Review of the Recirculation Pumo 30% Spechimiter Design Adequacy." ! During a recirculation pump trip on July 27,1992, the reactor water level swelled as a. result , of the trip which caused total feedwater How to runback to less than 20% flow. The 30% . i limiter for the remaining recirculation pump activated which caused a nmback of the pump's , speed from 60% to 30%. When the level transient cleared and feedwater flow returned to i greater than 20% Gow, the 30% speed limiter automatically reset rapidly. ramping the recirculation pump's speed back to it's original value. The inspector expressed concern to- ' licensee management regarding the automatic reset feature of the 30%. speed limiter. The licensee concurred and agreed to evaluate the acceptability of this design. I' The licensee immediately issued a required reading package to all Operations Department j personnel describing the event. The operators were trained to reduce the recirculation pump's l manual automatic (M/A) station speed setting immediately after a nmback occurred. Further, [ system operating procedures were changed to reDect these operator actions. The automatic reset feature is still active, however, due to the administrative changes and the configuration the + plant has to be in, the inspector agreed with the licensee that possibility for the reoccurrence of ! this event was low. ' i The licensee has initiated Modification 887, " Replacement of the Recirculation Pump Control
Circuit," to upgrade the recirculation flow control system. Some of the modification upgrades l include: 1) replacement of the obsolete " closed-loop" analog recirculation pump speed control i system with an "open-loop" manual control loop; 2) removal of the master controller and dual speed limiter from the recirculation pump speed control loop; and 3) installation of a manual reset pushbutton on the main control room panel to bypass the 30% limiter during start-up and ' normal operation of the recirculation system. i The inspector reviewed the modification package for this upgrade. The modi 0 cation is ! scheduled to be installed on Unit 3 during the upcoming refueling outage in September 1993, ! and on Unit 2 in 1994. The installation of the manual reset pushbutton in the 30% limiter circuit logic will prevent uncontrolled reactivity insertions due to increasing recirculation flow.-
The output signal from the manual control station on the main control panel to the Scoop Tube [ t I i i , .-. - __ . . . -,
. _ _ ._ . .. . , 9 Positioner will be maintained at 30% speed after a runback has occurred. The operator will be allowed to increase recirculation pump speed only after the 30% pump speed nmback has been reset. The inspector found this modification to the recirculation pump speed control logic to be satisfactory. This unresolved item is closed. (Closed) Unresolved Item 92-27-02, " Vendor Manual Control Deficiencies." During a NRC inspection in October 1992, the inspector determined that PECO had an effective vendor manual control program, but observed several administrative weaknesses. These weaknesses included: removal of vendor manuals from satellite stations without being properly signed out, an incorrect revision of a vendor manual maintained at a satellite station, the 60 day review cycle time was exceeded for 45 vendor manuals, and some procedures did not reference the appropriate vendor manual in the procedure reference section. During this inspection period, the inspector examined approximately 25 vendor manuals maintained at three of the satellite stations and observed that all manuals were either present or properly signed out. The inspector reviewed these manuals and noted that three of the manuals did not contain the correct revision. The inspector provided this information to the appropriate licensee personnel for correction. The inspector noted that procedure A-C-92, " Control of Vendor Manuals," required each user to verify that the vendor manual contains the proper revision. The inspector interviewed selected personnel in the maintenance, operation, and engineering departments and noted that personnel were familiar with this requirement. The inspector concluded that while user verification of the vendor manual should prevent use of an incorrect revision, the administrative process should ensure that the correct revisions are maintained at the satellite locations. PECO had previously identified the need to audit the satellite station manuals and had initiated a RE/EIF. The inspector interviewed the document services supervisor who indicated that the licensee was developing an audit program for the satellite station vendor manuals. The inspector was satisfied with the licensee's actions in this area. The inspector examined PECO's program for review of vendor manuals. The inspector noted that the licensee made progress in reducing the number of overdue engineering reviews. The inspector also noted that the licensee developed a performance indicator to track the status of outstanding reviews and was in the process of shifting these reviews to the on-site engineering group. The inspector concluded that these actions resolved this issue. The inspector reviewed procedure AA-C-5, " Preparation and Control of Procedures," which had been recently revised and noted that the procedure provided appropriate guidance regarding the use of cross references including vendor manuals in procedures. The inspector interviewed the document control center supervisor who indicated that this database had been recently audited and updated. The inspector had no further questions. This unresolved item is closed. -
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. 10 i (Closed) Unresolved Item 93-06-01, "Temocrary Chance to a Procedure Not Prooerly
Processed." , . On April 22, 1993, the inspector identined that a temporary change (TC) to a high pressure l coolant injection system surveillance test (ST) procedure was not appropriately processed. The . ' licensee changed the acceptance criteria in the ST using a TC which constituted a change of l intent. Intent changes to any procedure can only be performed by revising the procedure. The inspector noted a weakness in the PORC review process. -{ The licensee has revised Administrative Procedure A-3, " Temporary Changes to Procedures." i This revision includes a matrix which the person initiating the TC fills out in order to evaluate , if the proposed change affects the intent of the procedure. The matrix consists of specific questions addressing the relationship of the procedure to the TS, the Updated Facility Safety l Evaluation Report (UFSAR), and 10CFR50.59. Further, the matrix causes the initiator to
evaluate if the proposed change would affect the acceptance criteria of an ST, would change an j existing pre-approved process which would result in a potential safety concern, and would disable an ESF feature or scram function.
e Prior to the TC being implemented, it is reviewed by a Station Qualified Reviewer (SQR) for technical accuracy, validity, and safety concerns. During this review, the SQR determines if l the procedure change has effected the intent of the procedure and if further review is required i by the PORC. The TC is then reviewed by the on-shift Supervisors for the same criteria. l 1 Based on these procedural and process changes, this item is closed. ! l ' (Closed) Unresolved Item 93-15-04, " Limited Senior Reactor Ooerators" During the last inspection period, the NRC raised questions with regard to the method used by , PECO to reactivate the licenses of their senior reactor operators limited to fuel handling I (LSRO). The inspector was concerned that this method did not meet the intent ofl0CFR55.53,
in that the LSRO's were not standing their under instruction. watch on the refuel floor during core alterations. , On August 24, the NRC staff met with PECO, at PECO's request, to discuss implementation of the dual-site, LSRO program. The minutes of the discussions between the licensee and the NRC are detailed in an NRC letter dated September 15, 1993. The NRC staff concluded that the overall performance of the LSRO program was very good and that requalification and reactivation activities met the requirements of 10CFR Part 55. The NRC staff did note that the j previous lack of documentation of reactivation program requirements represented a weakness. The NRC staff also noted that the LSRO procedure presented by the licensee adequately addressed that weakness. The inspectors had no further questions.
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.. . _ _ , t . I1 7.0 MANAGEMENT MEETINGS (71707,30702) The Resident Inspectors provided a verbal summary of preliminary findings to the station management at the conclusion of the inspection. During the inspection, the Resident inspectors verbally notified licensee management conce:aing preliminary findings. The inspectors did not , provide any written inspection material to the licensee during the inspection. The licensee did not express any disagreement with the inspection findings. This report does not contain propri- etary information. The following specialist inspection also occurred during the report period: , Date Sub,iect Reoort No. Ln_sacier , 8/2-6 Engineering / Tech Support (NEEDS) IR 93-18 Lohmeier 8/2-3 Occupational Exposure IR 93-19 Eckert 8/23-9/3 LSRO and Initial Exams IR 93-20 Florek . 'l ENCLOSURE Attachment to Tl 2500/028 " Employee Concerns Program" , r . t l l i ! l , r
-- .. i . . TI 2500/028 - Attachment EMPLOYEE CONCERNS PROGRAMS PLANT NAME: Peach Bottom 2 & 3 LICENSEE: Philadelohia Electric Co. (PECo) DOCKET #: 50-277 & 50-278 ' NOTE: Please indicate yes or no, if applicable, and add comments in the space provided. A. PROGRAM: ' l. Does the licensee have an employee concerns program? Yes Comments: There are two procedural programs and one informal program in effect: , A-C-905. Ouality Concerns & Allecations, applies to all PECo employees and contract i personnel associated with the nuclear group. 2NOA-29. Ouality Erit In/crviews, applies to all technical PECo and contracted Nuclear Quality Assurance (NQA) personnel. . Quality Erit Interview form similar to that in NQA-29 was developed by the Human
Resources (personnel) department to be used for all nuclear group personnel when completing assignment within the nuclear group. 2. Has NRC inspected the program? No Comments: Results of this inspection will be documented in inspection report 93-17. H. SCOPE: 1. Is it for: i a. Technical? Yes ' b. Administrative? Yes c. Personnel issues? Yes 2. Does it cover safety as well as non-safety issues? Yes Comments: All three ECP programs were designed for safety issues, but they allow for reporting of reporting of non-safety issues as well. Additionally, they can be used for suggestions to improve the operations within the nuclear group. 3. Is it designed for: a. Nuclear safety? Yes b. Personal safety? Yes c. Personnel issues - including union grievances? Yes 4. Does the program apply to all licensee employees? Yes Comments: See elaboration above in section A.I. 5. Does the program apply to contractors? Yes A-1
.- . ' 6. Does the licensee require its contractors and their subs to have a similar program? No 7. Does the licensee conduct an exit interview upon terminating employees asking if they have any safety concerns? Yes Comments: As explained, all NQA personnel are required to receive an exit interview. However, there is no requirement for any other personnel to be interviewed upon , sermination.
C. INDEPENDENCE: 1. What is the title of the person in charge? Director, Nuclear Quality Assurance 2. Who do they report to? formal - Senior Vice President, Nuclear information only - President of the Company and Nuclear Committee of the Board I a ' 3. Are they independent ofline management? Yes i 4 Does the ECP use third party consultants? Not routinely. On the one occasion that the quality concem involved the NQA organization, an outside consultant was utili7ed. Sometimes other groups within the PECo organization will be asked to support an investigation. 5. How is a concern about a manager or vice president followed up? - No differently than any other concern. j D. RESOURCES: 3 1. What is the size of the staff devoted to tMs program? There is no formal group designated for the ECP. The Director, NQA, is responsible for the implementation of the program. A pool of interviewers and investigators is available to the Director, NQA. This pool includes QA inspectors, the Independent Safety . Engineering Group, Engineering, Corporate Security, and vendor representatives. 2. What are ECP staff qualifications (technical training, interviewing training, investigator [ training, other)? There are no formal requirements. Selection of individuals is based on experience, personnel background, and the specific issue. E. REFERRALS: 1. Who has followup on concerns (ECP staff, line management, other)? The Director, NQA, is responsible for ensuring all concerns are followed-up. I F. CONFIDENTIALITY: 1. Are the reports confidential? Yes , L A-2 ,
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2. . . > . . Who is the identity of the alleger made known to (senior management, ECP staff, line ! management, other)? q The Director, NQA, and his secretary are the only ones who have. access to the alleger's
identity. i ! 3. Can employees be: a. Anonymous? Yes b. Report by phone? Yes . G. FEEDBACK: ] 1. Is feedback given to the alleger upon completion of the followup? Yes Comments: normally, the alleger is contacted by telephone at home, followed by a registered letter with the details of the investigation
i 2. Does program reward good ideas? Yes . Comments: Suggestions are encouraged. If adopted, the employee can pursue a financial
award. ! -t 3. V o or at whit level, makes the final decision of resolution? ' 4 Are the resolutions of anonymous concerns disseminated? No i' 5. Are the resolutions of valid concerns publici7ed (newsletter, bulletin board, all hands meeting, other)? No i II. EFFECTIVENESS:
1. How does the licensee measure the effectiveness of the program? Comments: the licensee does not measure directly program effectiveness. However, Director, NQA, indicated that he felt the program was effective based on low utilization, ' issues were readily resolved, and no generic implications had been identified. 2. Are concerns: a. Trended? Not presently, but intends to start this year. I b. Used? No 3. In the last three years how many concerns were raised? 23 i Of the concerns raised, how many were closed? 20 - What percentage were substantiated? 65 % What percentage of substantiated were quality concerns? 60 %
4. How are followup techniques used to measure effectiveness (random survey, interviews, f other)? a Comment: Effectiveness is not measured. ! ! 5. How frequently are internai audits of the ECP conducted and by whom? j Never
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' , ) , s r i ) 9 J i I. AD5flNISTRATIVE/ TRAINING: 1. Is ECP prescribed by a procedure? Yes 1 1 2. How are employees, as well as contractors, made aware of this program (training, newsletter, bulletin board, other)? Comment: during the initial general employee training (GET) and annual GET refresher training l'l 1 ADDITIONAL COMMENTS: (Including characteristics which make the program especially effective, if any). ] 1 1 NAME: TITLE: PIIONE NUMBER: DATE COMPLETED: ) B. S .Norris SRI 717/456-7614 August 25,1993 A-4 ! \\ }}