ML20059D365

Responds to NRC Re Violations Noted in Insp Repts 50-277/93-24 & 50-278/93-24 on 930914-1030.C/A:PEP Investigation I000410 Initiated to Evaluate Causes of Incident & Developed C/A to Prevent Recurrence

ML20059D365
Person / Time
Site:	Peach Bottom
Issue date:	12/29/1993
From:	Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9401070188
Download: ML20059D365 (4)

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.CCN 93-14176' PIIILADELPIIIA ELECTRIC COMPANY Pl.ACil IlOTTOM ATOMIC POWIR STATION R. D.1, liox 208 N AM Delta, Penmylvania 17314 rau n narrow-su, com m nuu exx (717) 4 $6-7014 December 29, 1993 U. S. Nuclear Regulatory Mmica Attn: Document Control Desk Washington, DC 20555

Subject:

Peacil Bottan Atanic Power Staticm Units 2 & 3 Rocpanse to Notice of Violation (Mined Inspection Report No. 50-277/93-24 & 50-278/93-24)

In response to your letter dated November 22, 1993, which tran=mitted the Notim of Violation in the refuus.ul inspection apvrt, we subnit the attached response. '1he subject inspection concerns a routine residents' safety inspection . -

that was conducted September 14 tluough ot+%r 30, 1993.

If ycal have any questions or require additional inforration, please do not hesitato to contact us.

Sincerely,

(

G. R. Raincy Vi President GRR:RYS: bah AttadmeiL3 cc: R. A. Ikirrimlli, Public Servim Electric & Cas W. P. Dornsife, Cbmmonwealth of Pennsylvania W. L. Scinnidt, Senior Resident Inspector, US NRC T. T. Kutin, Aininistrator, Region I, US NRC R. I. Mclean, State of Maryland H. C. Sctiwem, Atlantic Electric C. D. Sctiaefer, DelParva Power

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Em:uruse to Notice of Violation 93-24-02 Technical Specification 6.8.1 requires that written prrvwhnus arrA policies be established and implemented that meet the requitmods of Sectidis 5.1 ani 5.3 of ANSI N18.7-1972. ANSI 18.7-1972, Sectica 5.1.2 requires tlut prrvwhmes be followed, the requirements for use be prescribed in writing, and that rules be established that provide melluis by which tenporary changes to approved ,

proccdures can be made. The followirq example of failure to adhere to these requita m ds was identified:

Administrative Frocedure A-4.2, " Station Qualified Reviewer Frugmu,"

Revision 1, Section 7.1.4, requires that the station qualified reviewers (SQR) shall review the package for technical accuracy and adterence to quality piup ma requirements. The Ibclear Quality Assurance - Plan, Surveillance Testirg Section 11.4 requires that shift operations permauel shall have overall control of the tests affectirg plant operations, to assure that testing systems do not adversely affect the safe operation of the plant.

Contrary to the above, on October 19, 1993, a Station Qualified Reviewer did not perform an amte technical review of a teuporary cnange to routine test pivaudure, RP X013 210.3, " Reactor Core Isolation Cooling (BCIC) Overspeed Trip Test." narther, Operation's Nmmuel did not exercise control of the test by runniry the RCIC system with steam while a piping breach existed. As a result, an inadvertent release of radioactive cantamination into the Unit 3 reactor building occurred. >

This is a Severity Invel IV Violation (Supplement I).

Byitround On October 19, 1993, station pumauel were scheduled to perform routine test (RF)-X-013-210-3, " Reactor Core Isolation Coolirq (RCIC) Overspeed Trip Test". A master clearance was in effect en the RCIC system that had been specifically written to allow for turbine overspeed testirg. Durirg preparaticn for the overspoed test, however, it was identified that the auxiliary steam to RCIC was blocked by another clearance. While the clearance issue was beirq resolved, maintenance personnel entered the RCIC room and removed a 12 foot section of the RCIC drain line that did not meet minim 2m wall thichxss requirencnts. The drain line was removed in response to a is uyliaroe report (NCR) and associated work order that were not part of the RCIC overspeed test.  ;

This work had been added to the outage by the scope control comnittee and was j controlled under a one tag sub-clearance which was attached to the RCIC master clearance. When station personnel returned to the room and began system line-up verification, the missirq drain line was identified. 7be potential to exhaust-steam through the remaved drain line during the overspeed test was recvf sized and  !

a temporary charge (7C) was initiated on the RCIC overspeed test. The purpose  !

of the 7C was to fail closed RCIC stemline drain air operated valves (AO)-35 ard AO-34 to isolate this removed line and prevent auxiliary steam from entszing the i RCIC rocan. 7he 7C was reviewod ard approved and the RCIC overspeed test was  !

performcd satisfactory. Durirq restoration of the RCIC stemline drain valves, however, a puff of resichm1 steam exhausted frtn the section of cut drain line  ;

into the RCIC rocxn. This exhaust was auxiliary steam that had t-w- = trapped i betwocn motor operated valves (10)-131 ard }D-16 following the ots:pletion of overspoed testing.

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k- g e-L P- ms*for the Violation A' lack of prtper work ocordination and control allowed potertially inconpatible work activities to be ocMv+ad similtaneously. 'Ihis unrwwmarily challerged the clearance and tagging process and the worker understanding of the inpact of applying auxiliary steam m the RCIC system.

'Ibe use of the master clearance to protect the naintenance personnel replacing the drain line was inawtwtiate since it did not fully ' isolate the workers from the atwilian steam system, a potential energy source. 'Ihe protecticn that was prtnidad by the master clearance was comprr=iaad when a normally runoved spool piece which m eis atwilinq steam to the RCIC system was installed to support overspeed testing. 'Ibe fact that the spool piece is normally runaved contributed to the failure to account for atwiliary steam as a potential energy source.

'Ibe use of a 'IC to provide worker protection when the potential to exhaust steam into the RCIC Itxxn through the cut drain line was irmwtwr iate. 'Ibe 'IC allowed for the test to continue arx1 was used toerwv siate for an ir*mte clearance. Although the use of a 'IC in this manner ' was not specifically prohibited by prrvwhtre, use of the 'IC allowed worker protection to be renoved before the steamline drain line replacement was ccupleted. In contrast, a revision to the clearance would have prevented the i.taa s i atwiliary steam from being released until after the drain line was rmaaambled because the Clearance would not have been removed until the work was cx:mpleted.

Finally, neither the system manager or the 'IC reviewers- realized the potential for a pocket of pressurized steam to exist in the RCIC systan followirg-the overspeed test. Therefore, they did not recognize that the 'IC created the potential to release auxiliary steam into the RCIC room through the cut drain line followirg restoratico of the drain valves.

Cuimt.ive Steos 'Ihat Have Been Taken and the Results Achieved Performance Enhars.uiuit F1ugam (PEP) investigation #I000410 was initiated to evaluate the causes of this irr:ident and to develop corrective actions to -

prevent recurrence.

Followirg the event, the Senior Manager Operations enphasized to shift management personnel that work must be performed in a controlled manner and that standards should not be cuve-"laad to ocmplete work when inadequate plans are tw wJnized. Additicmally, he stated that shift na%uit should ensure that systems are ready to be tested before testing is initiated.

'Ihe Outage Shift Manager coached the System Manager and Shift Supervisor involved with the tatporary charge on the'importance of. maintaining a questioning attitude and the need to " call a time out" when evolutions don't proceed accortiirg to the olan.

J

Cvuustive Steos ht Will Be Taken to Avoid Wrther Violations

'1his event will be inclurkvi in the 3R09 outage lessons lw2 to heighten awareness of the inportance to properly coortlinate work activities.

Miltionally, this everrt will be reviewed in a future Requalificatjal Week for Operations Marrymuit. 'Ihis event will be used to enphasize the emectations that clearance ard tagging issues require thorough evaluation and review, especially during outage work when off normal line-ups may be more prevalent.

'Ihese actions will be ocmpleted by June 30, 1994.

Overspeed tests for RCIC, High Prmsure Coolant Injection (HPCI) and Reactor Feed Punp Turbines (RFFfs) will be reviewed and Invised to imlude a prerequisite to evaluate in progress work orders on the amiated turbine. 'Ihis prerequisite will support system readiness for testing ard will enhance prucautions for per w u.el safety. 'Ibese actions will be ocmpleted by March 1, 1994.

Administrative Procedure A-3, " Temporary Gianges to Procedures" wilt be revised to prohibit 'IC's to suculares that could circumvent the clearance and tagging process when the applied clearance appears less than wVv]uate.

M11tionally, the Terary Change Screening Matrix will be revised to prevent the use of a 'IC in this manner. 'Ihis revision will be ocxnpleted by January 31, 1994.

'Ibe Clearance and Tagging Manual will be evaluated to include specific guidance on the tagging of auxiliary steam to RCIC, HPCI and RFFTs during outage ard non-cutaga corditions. In addition, master clearances for RCIC, HPCI and RFFTs in future outages will be evaluated to include darger tags on the auxiliary steam lines until turbine work has been ccupleted. 'Ihese actions will be conpleted by September 1,1994.

Date Hben Wil 0moliance Was Adlieved Full cxmpliance was adlieved October 19, 1993, after inadequacies of the temporary change to the RCIC overspoed test were identified ard corrective actions were initiated.

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