ML20076D242
| ML20076D242 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/22/1991 |
| From: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CCN-14108, NUDOCS 9107260141 | |
| Download: ML20076D242 (6) | |
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.CCE,14108 PilllADELPIIIA ELECTRIC COMPANY l'i:ACil IKWnW AIDMIC l'OWI R $1ATION R D.I,ikw 20M iss Iktta linnyIvania 17314 revn strrrmtus Mm a a or s us airv i f17)4 % '014 D B, Millet, Jr.
Vice Presdent July 22, 1991 10 CPR 2.201 Docket tkaa. 50-277 50-278 U.S. Nuclear Regulatory-Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station - Units 2 & 3 Response to Notice of Violation 91-16-01/01 (Combined Inspection Report Nos. 50-277/91-16; 50-278/91-16)
Dear Sir:
In response to your letter dated June 19, 1991, which
. transmitted the Notice of Violation in the referenced Inspection Report, we submit the attached response.
The subject Inspection Report concerns a routine resident safety inspection during the period-April 23 through June 8, 1991.
If you-have any questions or require additional information, please do not h9sitate to contact us.
Sincerely,
/
cc:
R.
A. Burricelli, Public Service Electric & Gas Gerusky, Commonwealth of Pennsylvania T.
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Lyash, USNRC Senior Resident inspector-T.-T. Martin, Administrator, Region I, USNRC H. C. Schwemm, Atlantic Electric R._I.
McLean, State'of Maryland-J. Urban, Delmarva Power
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I Document Control Desk l
Page 3 Ebect-J. W. Austin A4-4N, Peach Bottom 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 61B-3,Chesterbrook J.
B.
Cotton 53A-1, Chesterbrook
.l G. V.
Cranston 63B-5, Chesterbrook i
E. J. Cullen S23-1, Main Office A. D. Dycus A3-1S, Peach Bottom J. F. Franz A4-IS, Peach Bottom A. 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.
SMO-1, Peach Bottom PB Nuclear-Records.
A4-2S, Peach Bottom J. M.
Pratt B-2-S, Peach Bottom J. T.
Robb 51A-13, Chesterbrook D.
M.
Smith 52C-7, Chesterbrook
Document Control Desk Page 4
' Response to Notice of Violation 91-16-01/01
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Bestatement of Violatio.D 10CFR Part 50, Criterion XVI, Corrective Action, and the Philadelphia Electric Company Quality Assurance Plan require that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
In-the case of a significant condition adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, as of May 21, 1991, the licensee had not implemented corrective action to resolve carbon dioxide fire suppression system design deficiencies which could impact the-ability of the high pressure coolant injection (HPCI) system to perform its intended function.
Specifically, failure or spurious actuation of non qualified fire suppression system components would result in loss of the safety-related HPCI compartment coolers.
In 1988 the-same deficiencies with non-qualified fire suppression system components were identified by the licensee and corrected relative to the emergency diesel generators.
However, actions were not taken to correct the same deficient conditions relative to the Unit 2 and Unit 3 HPCI systems until identified by the inspector.
This is a Severity Level IV Violation (Supplement I).
Reason for Violation The identification of deficiencies in the Peach Bottom diesel Cardox circuitry in 1987 were the result of a deficiency identified at Limerick Generating Station where non qualified devices were i
found to trip the diesels on initiation of the fire suppression system.
The inves',1gation and evaluation of this deficiency and associated corrected actions were reported in Licensee Event Report (LER) 2-87-28.
At that time the deficiencies _were thought to be design specific-to the diesel generators.
The review'and
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evaluation focused on diesel operability, and not on fire system-interlocks with other safety systems.
Fire suppression system components were also. inadvertently missed-during the HPCI System EQ upgrade in April of 1990 and were again
-not realized in a-subsequent HPCI EQ review which began in January 1991.- The HPCI Equipment Operability Report (EOR) was used as the basis for the list of HPCI equipment to be_ qualified.
The EOR was reviewed to identify equipment not already included in the environmental. qualification (EQ) program._ Equipment not already included was then walked down to identify the make, model, and installed configuration.
Documentation was then gathered and reviewed which resulted in the performance of maintenance activities, some equipment replacement, and qualification of equipment. In this case, the area unit coolers and its control station were found to be previously included in the EQ program; therefore, no detailed review of HPCI drawings was performed.
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s Document Control-Desk i
Page 5-During development of the component Q-list in 1987-1988, each component in the HPCI system and its auxiliary-supporting features were to be identified and classified.
HPCI relay 86-PC2-however, was not classified.
Although HPCI relay 86-PE2 did not have a safety function _lt should have been classified as non-safety related with spuvial requirements because the failure of the relay could prevent the HPCI system from performing its safety function.
The failure to classify and identify these components with respect to environmental qualification prevented identification of the problem during those reviews.
Corrective Steps Taken and Results Achieved A non-conformance report (NCR) was initiated to evaluate hardware problems regarding this incident.
An interim disposition of the NCR was-to remove the non-qualified relay from the circuit.
Temporary Plant Alterations (TPAs) were installed to bypass the affected component relay that trips the HPCI room cooler fans from an initiation signal of the carbon dioxide fire suppression system.
An evaluation was performed which determined that the effectiveness of the HPCI Cardox fire suppression system would not be reduced by continued-operation of the HPCI room coolers.
An investigation into why HPCI relay 86-PE2 was not classified during-the development of the compoaent 0-11st has been completed.
The individuals involved in the component Q-list development have
'..to what factors and been interviewed for additional insight methods were used for the Q-list clasFlIiCation process.
This
- review revealed that the HPCI room croler schematic diagram was reviewed and_that the-fire suppressi)n relay should have been classified.
It appears that the omi.tsion was an-oversight on the part of the reviewer and not due to a programatic concern.
This review was expanded to include a-critical evaluation of the component. classification program.
A weakness was identified with the timely resolution of open items-that were generated during the classification process and with controls placed on the resultant
. list-of_ components.
Actions to correct these weaknesses are currently underway.
-A task force was formed to review the HPCI system and verify that there_were no other components that were inadvertently excluded
-from the environmental qualification program.
This review included a documentLsearch and a walkdown performed in accordance with-a preplanned checklist.
This review has been completed and no other components have been identified as being omitted in the HPCI system.-
A review of other fire suppression interlocks in similar, auxiliary supporting systems has been completed.
This review determined that there were no non qualified fire suppression interlocks'that could affect the operation of any safety related equipment.
In addition, a review for non-qualified interlocks in auxiliary supporting systems was also completed.
These systems included Emergency
Document' Control Desk Page 6 Service-Water Room Coolers,_ Emergency Core Cooling System Room Coolers,_ Diesel.Cardox_ System, Standby Gas Treatment and Control Room-HVAC_ System.
This review identified potential 0-list-discrepancies in the Control _ Room IIVAC System that are currently under investigation.
Thore were no problems ider tified in the other. systems.
Additionally, a review.of the effect of spurious fire suppression system actuation on safety-related systems is.in progress.
A potential concern with the operation of the Standby Gas Treatment System.has been identified and is under investigation.
Corrective Steps that Will Be Taken to Avoid Future Violations The need co fully _ address generic implications has been emphasized
.to engineering personnel through training and self-assessment.
Engineering reviews are also more thorough and encompassing than they.were during this incident in 1987-1988.
Disposition of non-compliance reports now address generic concerns.
The correction of weaknesses-identified during the resolution of open items generated from the component classification process review will reduce _the potential for future error.
Corrective actions <concerning the controls placed on the qualified list of components and associated special requirement component list (ie.
-seismicior environmental) will also enhance the component classification process. _The additional reviews and associated ongoing-corrective actions will also reduce recurrence of this event on other systems.
-Date When Full Compliance was Achieved Full compliance-was achieved May 22, 1991, when the HPCI Room Coolers were returned to an operable status.
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