ML20078B714
| ML20078B714 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/19/1994 |
| From: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9410260225 | |
| Download: ML20078B714 (6) | |
Text
9
('erzld R. P.airesy
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Vice President 4
s Peach Bottom Atomic Power Station i
PECO ENERGY
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Delta. PA 17314 9739 717 456 7014 i
October 19, 1994 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 i
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station Units 2 & 3 j
Response to Notice of Violation (Combined inspection Report No.
50-277/94-13 & 50-278/94-13)
Gentlemen:
In response to your letter dated September 19,1994, which transmitted the Notice of Violation concerning the referenced inspection report, we submit the attached response. In addition, we have included at your request, a discussion of the actions which have been taken or planned to address the timeliness and justifiability of operability determinations. The subject report concerned a routine resident safety inspection that was conducted from July-17,1994, through August 27,1994.
If you have any questions or desire additional information, do not hesitate to contact us.
=
Gerald R. Rainey Vice President Peach Bottom Atomic Power Station i
Attachment CCN #94-14163 ph(
941o260225 941019 PDR ADoCK c500o277 I
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cc:
R. A. Burricelli, Public Service Electric & Gas 1
R. R. Janati, Commonwealth of Pennsylvania i
T. T. Martin, US NRC, Administrator, Region I dent inspector H C. Schw mm VP Itlant El ri R.1. McLean, State of Maryland i
A. F. KirbY lll, DelMarVa Power 1
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4 RESPONSE TO NOTICE OF VIOLATION Restatement of Violation Technical Specification 6.8.1 requires that procedures be implemented for the following activities:
Operation of the reactor building ventilation and standby gas treatment systems.
Maintenance on the high pressure coolant injection system.
Contrary to the above:
On August 17,1994, procedures were not implemented for the operation of the reactor building ventilation and standby gas treatment system.
Specifically, the reactor building to outside atmosphere differential pressure was not maintained at Unit 3, in accordance with procedure SO 408.1.A-2 " Reactor Building Ventilation System Startup and Normal Operation" and at Unit 2 in accordance with procedure SO 9A.7.G
" Standby Gas Treatment Manual Startup on Equipment Cell Exhaust".
On July 18,1994, procedure S12M-23-GOV-X109 was not implemented for maintenance on the Unit 2 high pressure coolant injection system.
Specifically, technicians failed to perform steps as directed when a timing requirement was not met and failed to perform procedural steps in the sequence specified.
This is a Severity Level IV Violation (Supplement 1).
Reason for the Violation A.
System Operating (SO) Procedure 40B.1.A-2, " Reactor Building Ventilation System Startup and Normal Operation" required -0.1 to -0.4 inches of water differential pressure between the reactor building and outside atmosphere. This procedure referenced three separate plant locations that monitored reactor building differential pressure, however, each instrument indication was different. Operations became desensitized to the different readings and rationalized that the Main Contro! Room indication was sufficient to use in lieu of local parel indications. In addition, operation logs did not require reactor building differential pressure indicators to be recorded. SO 40B.1.A-2 referenced SO 40B.8.A-2 " Routine inspection of Reactor Building / Refuel Floor Ventilation System" that provided instructions to verify proper system operation. This procedure was inadequate in that it did not provide control for starting or securing fans to ensure a continuous negative differential pressure after initial start of the system.
SO 9A.7.G, " Standby Gas Treatment System Manual Startup on Equipment Cell Exhaust" allowed standby gas treatment (SBGT) to be used as a reactor building exhaust fan when secondary containment differential water pressure could not be maintained between -0.25 and
-0.4 inches. The capacity of the SBGT fan, however, was only one-third the capacity of a normal exhaust fan. As a result, the required differential pressure could not be obtained without the use of other reactor building fans. Operations personnel failed to change the procedure when the desired results could not be achieved. Personnel did not fully comprehend management expectations that any procedural deviation, regardless of perceived significance, should be resolved by fixing the problem or by revising the appropriate procedure before continuing work.
B.
On July 19,1994, Maintenance personnel were performing Sl2M GOV-XXCO " Calibration Check of HPCI Turbine Governor (EG-M, RGSC),
revision 0. The HPCI turbine control system includes a ramp generator that controls turbine acceleration on a system start. During performance of the test, the procedure required that the ramp switch be closed and the time required to ramp from idle voltage to a previously recorded voltage be measured and recorded. The procedure defined an acceptable limit of 10-12 seconds for the voltage ramp. The technician was required to watch the voltage rise from the time the ramp switch was closed until the ramp stopped and record the time with a stopwatch.
The technician was expecting to see the voltage rise to a level of approximately 12 VDC and plateau out, out the ramp leveled out at approximately 11 VDC. The technician hesitated and did not depress the stopwatch until 12.04 seconds, Lithough the voltage ramp had concluded earlier. The Maintenance job leader considered the 0.04 insignificant digits and recorded the time as 12 seconds. Maintenance personnel recognized the delay in recording the voltage ramp and knew that previous test measurements found out of tolerance would require that the test be reperformed.
During the reperformance of the test, step 6.3.13 of the procedure required that steps 6.3.6 through 6.3.12 be repeated if previous adjustrnents had been made. Since adjustments had been made, technicians prepared to perform the retest. The Mainte.'ance job leader recognized that step 6.3.5 also needed to be repeated and rationalized that the noted step 6.3.6 was a typographical error and should have been documented as step 6.3.5. Maintenance personnel proceeded to complete steps 6.3.5 through 6.3.12. After problems were encountered during the retest, supervision was contacted. The procedure discrepancy was discussed and supervision directed personnel to stop the retest and obtain a temporary change form to properly delineate the testing sequence. A temporary change was obtained that same day and the procedure was correctly reperformed.
Corrective Actions That Have Been Taken Following both incidents, personnel involved were counseled concerning procedural compliance and proper work practices. Management stressed the expectation to cease work activities and correct procedure deficiencies before j
continuing work.
A temporary change (TC) was completed July 19,1994, to SI-2M-GOV-XXCO,
" Calibration Check of HPCI Turbine Governor (EG-M, RGSC)" to change the l
sequence of steps to be repeated in step 6.3.13 starting with step 6.3.5 rather than step 6.3.6. In addition, a permanent change to this procedure was q
completed September 17,1994.
A TC was completed August 17pto SO 9A.7.G, " Standby Gas Treatment System Manual Startup on EquTpment Cell Exhaust" to change the criteria for maintaining differential pressure. A TC was also completed August 19,1994 to SO 40B.1.A-2, " Reactor Building Ventilation System Start-Up and Normal i
Operation" to require the use of local indicators to more accurately monitor for negative differential pressure.
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Operations personnel initiated a log sheet in the NPO round sheets on August 19,1994, to ensure that reactor building negative pressure indications were monitored.
Corrective Steos That Will be Taken to Avoid Further Violations Permanent revision to SO 40B.1.A-2, SO 408.8.A-2 and SO 9A.7.G are underway and are scheduled to be completed November 1,1994. Additional procedures will be reviewed to ensure that consistency is maintained between procedures.
An engineering review has been initiated to evaluate a potential design change to enhance the accuracy of differential pressure indicating panel instrumentation. Completion of this evaluation is tentatively scheduled for December 30,1994.
Date When Full Comoliance Was Achieved Full compliance for example A was achieved on August 19,1994, after a temporary change to SO 408.1.A-2 was completed to require the use of local indicators for measuring differential pressure and on August 17,1994, after a temporary change to SO 9A.7.G was completed to change the criteric for maintaining differential pressure.
Full compliance for example B was achieved on July 19,1994, after a temporary change was made to the testing sequence of the HPCI Turbine Governor Calibration Check procedure and after the required voltage ramp was properly performed and recorded.
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-Actions Taken or Planned to Address the Timeliness and Justifiability of Ooerability Determinations Management expectations concerning the timeliness and justifiability of proper operability determinations have been clearly communicated to appropriate personnel. Management emphasized personnel accountability, responsiveness, and heightened the awareness for timely and accurate determinations. Actions in this area will be evaluated during performance appraisals that will result in j
positive reinforcement fcr timely and proactive action and appropriate 1
consequences for non-compliance.
The role of the unit coordinator will be re-evaluated to enhance the ability to apply more resources to properly screen plant operability issues. Additionally, the Operations Manual (OM) will be revised by December 30,1994, to further address operabihty, especially in the area of code issues. Operability i
determinations will also be periodically reviewed and discussed in requalification training to enhance the knowledge and skills of operations staff.
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