ML20067C106

Responds to NRC Re Violations Noted in Resident Safety Insp Repts 50-277/90-22 & 50-278/90-22 on 901030 to 1203.Corrective Actions:Tubing Leak on Isolation Valve AO-2520 Repaired on 901106 to Establish Backup N2 Supply

ML20067C106
Person / Time
Site:	Peach Bottom
Issue date:	02/05/1991
From:	Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CCN-91-14014, NUDOCS 9102110200
Download: ML20067C106 (9)

Text

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-. P . 14014 PillLADELPillA ELECTRIC COMPANY Pf ACH halTOM AIUMIC POWIR STATION It D.1. Box 208 Delta. Itnns)1vanta 17314 rsu n sortu%Tus emir of areitem n (71)4 W 70ld D 11. Mmet, Jr.

Vice Prestent February 5, 1991 Docktt Hos. 50-277 50-278 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, OC 20S55

SUBJECT:

Peach Bottom Atomic Power Station - Units 2 & 3 '

Reply to Notice of Violations (CombinedInspectionReportHos. 50-277/90-22; 50-278/90-22)

Dear Sir,

In response to your letter dated December 28, 1990, which tras mitted the Notice of Violations concerning the referenced Inspection Report, we submit the attached responses. The subject Inspection Report concerned a routine resident safety inspection during the period October 30 through December 3, 1990.

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

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cc: R. A. Burricelli, Public Service tiectric & Gas T. M. Gerusky, Commonwealth of Pennsylvania J. J. Lyash, USNRC Senior Resident inspector T. T. Martin, Administrator, Region 1. USNRC H. C. Schwemm. Atlantic Electric rt. 1. McLean, State of Maryland J. Urban, Delmarva Power h

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• Page-2 bcc: J..A. Basilio 52A-5,-Chesterbrook

- G. J.-Beck 52A-5, Chesterbrook J. A.-Bernstein 51A-13 Chesterbrook R. N.. Charles- .

51A-1, Chesterbrook Commitment Coordinator- .

52A-5, Chesterbrook Correspondence Control Program 618-3, Chesterbrook J. B. Cotton- 53A-1, Chesterbrook E.1J. Cullen S23-1, Main Office A. D. Dycus A3-IS, Peach Bottom

~E. P. Fogarty A4-4N, Peach Bottom J. F. Franz A4-15,-Peach Bottom An A. fulvio- A4-1S, Peach Bottom D. R. Helwig 51A-11, Chesterbrook '

R.-J.-Lees,.NRB- 53A-1. Chesterbrook

- C. J McDermott S13-1. Main Office D. B. Miller. Jr. SM0-1, Peach Bottom.  !

=PB~ Nuclear Records A4-25, Peach; Bottom J. M. Pratt B-2-S, Peach Bottom L. B. Pyrih 638-5 Chesterbrook J. T. Robb- 51A-13, Chesterbrook

- D..M. Smith: 52C-7, Chesterbrook J

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, Document-Control Desk

Pebruary.5, 1991-

, Page_3 K;JLY TO NOTICE OF VIOLATION 90-22-01 Restatement of Violation A. The. Code of federal Regulations, Title 10, Part 50, Appendix 8. Criterion XVI, " Corrective Action," states in pcrt that measures shall be established to assure thet conditions adverse.to quality, such as defective materiel and equipment, are promptly identified and corrected.

1. Contrary to the above, on November 5, 1990, a leak was caused and identified in the-supply line from the' seismically qualified nitrogen l supply to.the boot seal of inboard primary. containment isolation valve A0-2520. Immediate corrective actions were not implemented and the bottle depressurized to zero psig. Since the outboard valve was already inoperable with its boot seal deflated, a potential. primary containment. leak path would have existed in the ,

event of a design basis accident.

2.. Contrary to the above on May 3-4, 1990, and since August 29,=1990,

. primary l containment isolation valve A0-2519 was inoperable. Data collected during daily.surveillances indicated that, leakage in excess of the allowable existed.. making the seismically qualified  ;

backup nitrogen supply inadequate toLassure valve operability. '

Philadelphia Electric Company did not declare the valve inoperable,-

and did not initiate' action to promptly repair _the valve. .

ThisisaSeverity'LevelIVViolation(Supplement!).

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Document Control Desk F6bruary 5, 1991

• Page 4 Event Description A.1 The valve operator and boot seal of the Containment Isolation Valves are supplied pressure by the Instrument Air System under normal operation.

In the event of a loss of instrument air, backup nitrogen (N2) is supplied from compressed gas cylinders to maintain boot seal pressure.

For a Design Basis seismic event or loss of offsite power, the normal I supply to the valves would be lost, and the boot seals would be supplied by the N2 cylinders to maintain containment integrity.

On November 5, 1990, an operator replacing the compressed nitrogen gas cylinder that supplies backup gas pressure to the A0-2505 valve disturbed the N2 supply line to the A0-2520 valve causing it to leak. The operator made a temporary repair and then immediately notified the Shift Supervisor in the control room that the leak was stopped but would require further maintenance. The Shift Supervisor initiated a Maintenance Request form which was to be completed the next day.

During the porformance of Surveillance Test (ST) 7.9.2-2, " Daily Check of Seismic Gas Supply 80ttic Pressures" on November 6, 1990, the N2 cylinder that supplied A0-2520 was discovered empty. An Equipment Trouble Tag was in place at that time identifying the tubing leak. While replacing the cylinder, the Operator noticed that the leak was rapidly bleeding down the gas pressure so he isolated the bottle and notified the Control Room Supervisor who requested immediate maintenance repair. The System Engineer also became involved at this time and noted that the A0-2520 valve was in line with the Outboard A0-2521A valve, which had its boot seal deflated in order to perform maintenance.

An operability ietermination was then initiated to evaluate the Primary Containment isolation Capability of the A0-2520 valve. The importance of the backup N2 supply was not well understood and the lack of guidance given in the Technical-Specifications delayed the operability determination. A determination was made to declare A0-2520 inoperable for the purpose of the primary containment isolation due to the lack of backup H2 to the boot seal. Technical Specification 3.7.'u.2 was entered for an inoperable isolation valve. The N2 tubing on A0-2520 was repaired a short time later re-establishing the N2 supply and the valve was returned to an operable status. Although a p7tential containment leak path existed through the boot seals of the inboard and outboard Containment Isolation Valves due to the condition of the backup N2 supply, the boot seal was continually supplied pressure from instrument air. The actual integrity of the boot seal and primary containment was never compromised. During the investigation of the event, it was determined that Tech Spec 3.7,0.2 did not apply since A0-2521A was already considered an inoperable isolation valve due to maintenance activities. It-was concluded that Tech Spec 3.7.A.3 involving containment integrity should have been entered. Tech Spec 3.7.A.3 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to re-establish containment integrity, or the reactor must be placed in cold shutdown in the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Tech Spec compliance was

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. February 5, 1991 o Page 5 met but there was confusion in determining the appropriate Tech Spec to us9.

Event Description A.2 A resident NRC inspector discovered on November 8, 1990, that the bottle pressure for the backup N2 supply to A0-2519 was less than the acceptable value specified in ST 7.9.2-2. The Shift Supervisor was immediately notified. The bottle was found with a leaking regulator and was replaced. The inspector then reviewed a sample of surveillance test data recorded for A0-2519 since January, 1990, and identified that A0-2519 was inoperable on May 3-4, 1990. Subsequently, additional reviews performed by the System Engineers determined that the valve was inoperable since August 29, 1990. During these periods the leakage rate was such that the seismic backup N9 supply to A0-2519 would not have provided the required 20 day supply in case of a Design Basis seismic event or loss of offsite power. The 20 day supply requirement was contained in a Justification for Continued Operation (JCO) tnat was not adequately addressed in the. 1T 3 at shift personnel were not aware of this requirement. Additionally, toe ST only monitored bottle pressure and did not address leak-rates.

Notification of the Syttem Engineer on bottle change-out was also not being accomp'lished in accordance with the ST. Operations personnel did not understand that the reason the System Engineers were to be notified-was to evaluate. abnormal leak rates. Although the backup N2 supply for A0-2519 was in a degraded condition, the boot seal integrity was maintained by the normal supply of instrument air.

Reasons for the Violation The operability requirements and importance of the Backup N2 System were

-not fully understood by Operations. Additionally, the ambiguity of the Tech Specs was also a contributing factor. ST 7.9.2-2 was inadequate in that it did not address leak rates, JC0 requirements, or the importance of notifying System Engineers after bottle replacement.

Corrective Steps Taken and the Results Achieved The tubing _ leak on A0-2520 was repaired on November 6, 1990, re-establishing the back-up H2 supply. The N2 cylinder that supplied A0-2519 was replaced on November 8, 1990. Evet Investigations were initiated for both incidents to determine caues and develop corrective measures to prevent recurrence. On November 36, 1990, a meeting was held with staff management and the NRC to discuss the results of these investigations and planned corrective arthat Operations personnel were verbally informed of these incidents and the resulting impact on operability determinations. A follow-up package of information was provided to appropriate Operations personnel on December 7, 1990, to further enhance their awareness and ur<derstanding of the backup nitrogen supply system and associated operability requirements.

Additionally, this package also contained information concerning the

Document Control Desk j February 5, 1991

' + Page 6 importance and reasoning why the system engineer is required to be notified whenever a bottle is replaced. This discussion was also provided to heighten Operations sensitivity to proper review and disposition of the surveillance test results.

Operations personnel were also provided with an analysis of Technical Specification 3.7,0.2 and 3.7 A.3 as they pertained to these events.

This discussion examined the operability determinations and the interpretations proposed during and after the incident, and provided guidance on how to correctly interpret these Tech Soecs.

Criteria to address allowable leakage rates and sign-offs for System Engineer notification were also provided through a temporary change to ST 7.9.2-2. In addition, System Engineers now monitor the results of ST 7.9.2-2 to correct any problem where excess leakage could result in an inability to successfully maintain the 20 day back-up supply.

Corrective Steps That Will Be Taken To Avoid future Violations A modification (Mod 1316) is currently in progress on Unit 2 to install a backup pressure supply to the boot seals of the Containment Isolation

-valves from the Containment Atmospheric Dilution (CAD) system. This modification, which has already been installed on Unit 3, will eliminate the requirement for the bottle supplied backup N2 system for these valves. The projected date of completion for this modification is March 15, 1991. Once Mod 1316 is completed, ST 7.9.2-2 will be permanently revised to comnletely address the operability concerns for N2 bottles used in other applications.

Existing JCO's will be reviewed for required procedure revisions and training issues. A tracking mechanism will he established for action items resulting from JCO's.

Date When full Compliance Was Achieved full compliance was achieved November 8, 1990, when the N2 cylinder supplying A0-2519 was replaced and the 20 day backup supply was achieved.

'The H2 backup supply to A0-2520 was re-established on November 6, 1990, when the N2 supply line leak was repaird.

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REPLY TO NOTICE OF VIOLATION 90-22-03 R'estatement of Violation B. Technical Specification (TS) 6.S.1 states that written procedures and administrative policies shall be established and implemented that meet the requirements.of ANSI N18.7-1972,_ Section 5.3, and Regulatory Guide (RG)1.33(1972). ANSI N18-7. Section 5.3.6, and RG 1.33, Section ti,  ;

require procedures'for the control, storage and use of measuring and test.

equipment (M&TE). TS 6.5.16 states that the Plant Operation Review Committee (DORC) shall be responsible for review of all procedures required by TS 6,8. ,

Contrary to the above, as of December 3, 1990, the licensee had not established or implemented a PORC approved procedure addressing the control, storage and use of-M&TE as required by the TS 6.8.1'and 6.5.16.

This is.a Severity Level-IV Violation (Supplement !).

Event Description-

-The~ Instrument and Controls (l&C) Shop was originally the Station Test .

Section of the Research and Testing-(R&T) and.later Testing and Laboratories--(T&L). The R&T Divisiorrwas identified in the Quality Assurance (QA)Plantobe"responsibletotheElectricProduction Department for the performance of maintenance of instrumentation as

= delegated." Additionally, the R&T--Division Administrative Procedures for the controls of-instrument maintenance activities were to be prepared and

approved.in!accordance with the QA Plan.- These procedures required

. approval by management 11evel personnel in'both R&T and QA.

In addition to site equipment maintenance and calibrations, R&T was-cresponsible for the c$libration of the test standards used by the site. ,

This was accomplished off-site and was controlled by appropriate .

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procedures. These procedures, though not PORC approved, .had significant technical and quality review.

The Construction. Division and Maintenance Department were also major-

, users.of measuring and-test equipment (H&TE). To control the use of M&TE-Construction utilized the Construction Division-Implementing Procedures

. (C0!P). Maintenance eventually developed their own PORC and QA approved

- Maintenance Administrative (MA)-procedures. Control of M&TE however, was

considered R&T Department responsibilities.

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- As a result-of.the shutdown of Peach Bottom in 1987, signifIcant  :

' organizational and personnel changes were implemented. One of these  :

. reorganizations consisted of removing the I&C Group from T&L and

. including it within the Station organization. T&L Administrative L

procedures were not adequately addressed during this reorgy Ization and original personnel famillar with the requiraments of T&L procedures were I

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PageL8 re-assigned, resulting in a lack of experienced personnel and administrative control.

Nuclear Qual 1ty Assurance (HQA) conducted an audit (PA-89-24) of M&TE Control f_ rom October 10-25, 1989. During this audit _NQA identified several performance discrepancies, including the lack of an approved method to control M&TE. HQA noted that.the station was awi 0 of the need for an administrative procedure and that one was in development, it was believed that the procedure would be approved in the near term and was not tracked to a firm completion date. Reassignment of personnel and changes in the Maintenance /l&C Organization were made however, and the procedure was never issued. Corrective Action Request PA-89-24-02 remains open until the Administrative procedure is PORC approved.

During the Unit 3 mid-cycle outage, I&C personnel identified some Rosemount transmitters outside of their expected calibration band. Upon review of the corrective actions to address this problem, the Resident NRC-. Inspector identified that a PORC and QA approved procedure establishing and implementing a M&TE program had not bcen established, lt Reasons for'the Violation The, reasons for the violation include less than adequate turnover of-responsibilities during the transfer of I&C personnel to the station and previously not having T&L procedures PORC approved. - The transition of the_I&C-Group from T&L to the station without adequately incorporating

- appropriate T&L administrative controls resulted in not having a controlling document for M&TE in place.

Correct'ive Steps Taken And Results Achieved A-Maintenance Guideline has been established for Maintenance /l&C use which contains the appropriate direction for use, control, issue,.

segregation, review and storage of M&TE until a M&TE Administrative Procedure is implemented. Other T&L-. procedures are currently being incorporated into PORC approved station procedures as necessary.

-Additionally, actions have been taken to improve the M&TE process. The I&C M&TE Room was enlarged to allow better control and organization of test equipment as well as establishing improved access centrol. A computer bar code system has also been implemented-to imptove equipment traceability.

.An Administrative Foreman position has been established, whose duties

-include control of.the M&TE Room and review of Out-of-Tolerance reports.

Additional personnel have been assigned to the M&TE-Room and procedure development.

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j. .. february 5,_1991 Page 9 Corrective Steps lhat Will Be Taken To Avoid Future Violations An Administrative Procedure has been drafted for the control of M&TE at PBAPS which includes provisions fce the use, issue, segregation and storage of M&TE as well as the review for cut-of-tolerance reports. This procedure will-be appropriately reviewed and approved by the Plant OperatingReviewCommittee(PORC)andQualityAssurance. This procedure will be approved for use by March 15, 1991.

Date When Full Compliance Will Be Achieved Full compliance will _be achieved upon the completion of a PORC approved

-procedure addressing the control, storage and use of M&TE. This procedure will be completed and PORC approved by March 15, 1991.

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