ML20077C543
| ML20077C543 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/15/1991 |
| From: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CCN-91-14068, NUDOCS 9105210474 | |
| Download: ML20077C543 (7) | |
Text
CCN l 91-14068 si
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rtaca mors%rns runia or isctu tw t pl?) 4547014 D. P. Miller, Jr.
Vice President 10 CFR 2.201 Docket Nos. 50-277 50-278 U. S. Nuclear Regulatory Commission ATlN: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station - Units 2 & 3 Response to Hotice of Violations (Combined Inspection Report Hos. 50-277/91-08:50-278/91-08)
Dear Sir:
In response to your letter dated April 10, 1991, which transmitted the subject inspection Report and Notices of Violations, we submit the attached response. The subject Inspection Report concerns a routine resident safety inspection during the period February 12 through March 18, 1991.
If you have any questions or require additional information, please do not hesitate to contact us.
Sincerely,
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R. A. Burricelli, Public Service Electric & Gas T. M. Gerusky, Commonwealth of Pennsylvania 9105210474 910515 PDFt ADOCK 05000277
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Document Control Desk
..Pb90 2 J. J. Lyash, USNRC Senior Resident Inspector T. T. Martin, Administrator, Region I, USNRC H. C Schwenun, Atlantic Electric R. I ?Mlean, State of Maryland J. Urban Delmarva Power 1
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bcc: J. W. Austin A4-4N, Peach Bottom J. A. Basilio 52A-5, Chesterbrook G. J. Beck 52A-5, Chesterbrook J. A. Berrstein 51A-13 Chesterbrook R. N. Charles SIA-1, Chesterbrook Commitment Coordinator 52A-5, Chesterbrook Correspondence Control Program 618-3, Chesterbrook J. B. Cotton 53A-1, Chesterbrook G. V. Cranston 638-5, Chesterbrook E. J. Cullen S23-1, Main Office A. D. Dycus A3-IS, Peach Bottom J. F. Franz A4-IS, Peach Bottom A. A. Fulvio A4-IS, Peach Bottom D. R. Helwig 51A-ll, Chesterbrook R. J. Lees, NRB 53A-1, Chesterbrook C. J. McDermott 513-1, Main Office D. B. Miller, Jr.
SMO-1, Peach Bottom PB Nuclear Records A4-25, 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 R_esponse to Notice of Violation 91-08-02 Restatement of Violation Technical Specification (TS) 6.8.1 requires that written procedures and policies be cstablished and implemented that meet the requirements of Section 5.1 and 5.3 of ANSI N18.7-1972. ANSI N18.7-1972 Section 5.1.2 requires that procedures be followed, the requirements for use of procedures be prescribed in writing, and that rules be established that prov',de methods by which temporary chances to approved procedures can be made. The following examples of failure to adhere to these reqilrements were identified:
Administrative Procedure A-3, " Temporary Changes to Procedures," Revision 12, Section 7.10.3 requires, in part, that for System Operating Procedures, Abnormal Operating Procedures and General Plant Procedures, placement of a copy of the temporary change (TC) on the Control Room Procedures Cart, completion of the "Index of Temporarily Changed Procedures for Control Room Use," and "tapture" of the associated procedure in the controlled procedure volumes using a red mylar cover.
(Note: Capture means to place the affected procedure located in the procedure book within a red mylar cover; when an operator sees the red mylar cover, he is to use the revised procedure located in the temporary change section of the Control R0s Procedures Cart.).Section 7.10.4 requires for Surveillance Tests (ST) which are available in the control room, that the TC be logged in the " Temporary Change to Test Procedure Index," that the approved TC traveler and a copy-of the revised procedure be place in the " Temporary Change to Test Procedure Log Book," and that the procedure be captured" in the controlled procedure volumes.
Section 7.15.1 states that the Operations Support Group (OSG) shall, on each normal work day, review the temporary changes processed on the previous day for correct implementation, remove and discard any temporary changes that have expired, and ensure that a stamped controlled copy of the current revision of the applicable procedure is in place for those
-temporary changes that are removed.-
Contrary to the above, between February 21 and March 15, 1991, TC numbers 91-0262, 91-0263,.91-0250, 91-0332, 91-0321, 91-0204, 91-0159, 91-0156, 91-0200, 91-0503, and 91-0500 were not processed in accordance with procedure A-3 in that they were not " Captured," indexes and logs were not
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updated or expired TCs were not removed in a timely manner.
In addition, the daily review performed by the OSG in accordance with A-3 did not identify and correct the errors.
I This is a Severity level IV VMlations (Supplement I).
Reason for Violation The process to control temporary changes (TCs) to procedures, Administrative Procedure A-3, requires the initiator of a procedure change to prepare and properly distribute the TC to all specified locations.
The verification
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, 'Page 5 sign-offs of the associated traveler that accompanies the TC, however, did include the steps requiring preparation and distribution of TCs as
.ated in A-3.
This resulted in some TCs not being appropriately captured, updated or deleted.
These types of problems were identified during Operation Support Group (OSG) reviews and were immediately corrected. This audit method, however, was found to be inadequate in that these problems were corrected without evaluating or investigating the cause of these incidents.
Corrective Steps Taken and Results Achieved immediate corrective action was taken to capture all outstanding TCs, update the TC indexes and logs, and remove all expired TCs. The OSG audit program was examined and strengthened so that discrepancies are now thoroughly evaluated. Additionally, a monthly TC report has been initiated which tracks identified TC errors and categorizes them by error type and responsible initiating organization. This report is distributed to appropriate superintendents for their review and for the purpose of identifying and correcting adverse trends, i
A review of Administrative Procedure A-3 was also conducted.
This review identified that a revision would be required to ensure consistency between the traveler and the procedure.
Corrective-Steps That Will be Taken to Avoid Future Violations i
Administrative Procedure A-3 will be revised by June 4, 1991, to ensure that the traveler that accompanies the TC is consistent with direction given in the procedure to properly process and implement TCs. The traveler will be revised to incorporate three additional verification sign-offs requiring the TC initiator to distribute copies to required control room locations, make appropriate index or log entries, and include a copy of the TC with the procedure where required. Management review of the monthly TC report will monitor the effectiveness of the procedure revision.
l Additionally, the existing TC process is currently under review.
This review and any associated enhancements will provide better control and efficiency of the TC process.
l Date When Full Compliance was Achieved Full compliance was achieved on March 16, 1991, when the noted discrepancies were corrected and additional existing items were identified and resolved.
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~Page 6 Response to Notice of Violations 91-08-03 kestatement of Violations Technical Specification (TS) 6.8.1 requires that written procedures and policies be established and implemented that meet the requirements of Section 5.1 and 5.3 of ANSI N18.7-1972. ANSI N18.7-1972 Section 5.1.2 requires that procedures be followed, the requirements for use of procedures be prescribed in writing, and that rules be established the policies methods by which temporary changes to approved procedures can be made.
The following examples of failure to adhere to these requirements were identified:
Administrative Procedure A-42, " Control of Temporary Plant Alterations,"
Revision 15. Section 7.8.2, requires that the Document Control Center distribute the designated marked-up temporary plant alteration (TPA) drawings and prints in accordance wito A-6, " Drawing Control."
A-6, Revivion 17, Section 7.2.4, requires that drawings and prints affected by a change document list all open change documents and a copy of the change document be-attached to the affected controlled copies at each file location.
Contrary to the above, as of March 19, 1991, marked-up drawings associated with Unit 2 TPA numbers 02-12 and 33-1, and Unit 3 TPA number 62-4 were not listed on or attached to the affected controlled copies of drawings as required by procedures A-42 and A-6.
This condition had existed for an extended period of time, since IPA installation in March of 1990, April of 1990, and August of 1989 respectively.
This is a Severity Level IV Violations (Supplement I).
Reason for Violations The process to control temporary plant alterations (TPAs) Administrative Procedure A-42, requires the installer of a TPA to submit a copy of the TPA package to the Document Control Center (DCC) when the TPA is installed.
In two of the-three examples cited the OCC was not notified that the TPAs had been installed, therefore affected drawings were not updated as required by Administrative Procedure A-6.-Drawing Control.
The third example was a case where the DCC was notified of an installed TPA, but failed to adequately update and control the affected drawings.
Corrective Steps Taken and Results Achieved As a result of this finding, a review of TPAs was initiated to ensure that all the affected drawings were properly annotated. Additional discrepancies were identifled'and an event investigation was initiated to correct these problems and determine the cause of the' incidents.
The investigation identified that most discrepancies were a result of TPA initiators failing to notify the DCC when TPAs had been installed.
This requirement was l
contained within Administrative Procedure A-42, however, there was not a sign-off step to verify that the package had been sent to the DCC.
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Document Control Desk Page 7 An indepth review of A-42 and the TPA process was completed and A-42 is currently under revision to simpilfy and clarify the requirements. A monthly audit comparing DCC drawings with the Control Room TPA log is currently being performed until the procedure changes can be finalized.
In the interim, training was conducted as part of Technical Staff and Management Continuing Training in March, 1991, to address problems associated with the TPA process.
The requirements and importance of properly implementing the TPA process was re-emphasized and a check-list was provided to the technical staff attendees that listed the administrative steps, including the requirement to forward a copy of the completed TPA to the DCC. Staff attendees were encouraged to u a the checklist when initiating, installing, or removing a TPA uro ~, the procedure can be revised.
Corrective Actions That Will Be Taken to Avoid Future Violations The revision and approval of A-42 and the TPA process is scheduled to be completed by August 1, 1991.
The major thrust of this revision is to simplify the process so that the procedure enhances user compliance.
Additionally, the checklist of administrative requirements is being built into the TPA package sign-off steps.
This will capture any requirements contained within the procedure and will provide verification that appropriate actions are taken.
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Date When full Compliance Will Be Achieved Full compliance will be achieved August 1, 1991, when Administrative Procedure A-42 is revised to more adequately address the proper implementation process of temporary plant aiterations.
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