ML20082Q528
| ML20082Q528 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/09/1991 |
| From: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CCN-91-14145, NUDOCS 9109120220 | |
| Download: ML20082Q528 (6) | |
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CcK 91-14145
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/ qprrou PII1LADELPIIIA ELECTRIC COMPANY ly' I'[ AC!t nor10M KlOMIC POWI R STATION
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Delu, h:nns)hania 17311 nu n monuw-t en rus s a or a u s atrs< a Fl?) 4 Wuh D. B. Miller, Jr.
Vice President gg g y991 10 CFR 2.201 Docket Nos. 50-2'i7 50-278 s
U. S. Nucleer Regu'tatory Commission ATTH: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station - Units 2 & 3 Response to Notice of Violation 91-16-02 (Comained Inspection Report Nos. 50-277/91-16; 50-278/91-16)
Dear Sir:
In response to your letter dated July 31, 1991, which transmitted the Notice of Violation discussed in the referenced Insnection Report, we submit the attached response. The subject inspection re90ct concerns a routiae resident safety inspection during the period April 23 through June 8,1991.
If you have any questions or require additional information, please do not hesitate to contact u<.
1 S'ncerely, [
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R. A. Burricelli, Public Service Electric & Gas T. M. Gerusky, Commonwealth of Pennsylvania J. J. 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 l
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I 9109120220 910909 PDR ADOCK 05000277
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Document Control Desk
'Page 2 bcc: J. W. AustinL A4-4N, Peach Bottom J. A. Basilio 52A-5, Chesterbrook G. J. Beck 52A-5, Chesterbrook J. /.. 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 G. V. Cranston 638-5, Chesterbrook E. J. Cullen S23-1, Main Office A. D.~Dycus A3-IS, Peach Bottom w
A. A. Fulvio A4 IS, Peach Bottom D. R. Helwig SIA-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 A4-25, Peach Bottom K. P. Powers A4-15 Peach Bottom J. M. Pratt B-2-S, Peach Bottom J. T. Robb 51A-13, Chesterbrook D. M -Smith 52C-7, Chesterbrook i
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Document Control Desk Page 3
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s Response to Notice of Violation-91-16-02 Restatement of Violation Technical-Specification 6.8.1 states, in part, t$.ut written procedures shall be established and implemented that meet the requirements of Sections 5.1 and 5.3 of-ANSI N18.7-1972. ANSI N18.7-1972 Section 5.1, states that procedures shall be followed. -Section 5.3 requires that 1) the purpose for which the procedure is intended be clearly stated; 2) each pror.edure identify the plant conditions-that shall exist prior to its use, and 3) precautions-be established to alert-the individual performing the task to those situations in which important measures be taken early or where extreme care shoLld be taken.
Contrary to the above, on May 29, 1991, adequate standby liquid control (SLC) system operating procedures had not been established and were r.ot implemented.
As a result, SLC solution tank temperature was raised significantly above the previously analyzed maximum temperature, placing the ability of the system to perform its intended function in an indeterminate state for about 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Specifically:
'A.
. Procedure S0 ll.l.A-3, " Standby Liquid Control System Setup for Operation," Revisicn 3, did not contain adequate prerequisites and orecautions.
The required plant condition was not specified, and precautions were not included to identify clearly the impact of procedure performance on system operability.
B.
Procedure 50 11.7 A-3, " Standby Liquid Control System Chemical Makeup,"
Revision 4, did not contain adequate precautions to identify the impact of elevated temperature on SLC pump operability.
C.
Alarm Response Ca"d Number 311. " Standby Liquid or Pipe Hi-Lo Temp,"
l Revision 0, did not include adequate instructions to ensure proper operatcr response to elevated SLC solution tank temperatures.
D..
The licensed operator controlli o 'he SLC make-up evolution did not adequately review the appliceble procedures, S0 11.1.A-3, and 50 11.7.A-
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3, prior to or during conduct of the evolution.
i This is_a Severity Level IV Violation (Supplement 1).
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Document Control Desk Page 4 Reasons for the Violation in prepcration f or heating the Steadby Liquid Control (SBLC) itorage tank for chemical addition, the Unit 3 Reactor Operator (RO) selected c.e wrv g procedure for use. The R0 referenced the requirements of Station Operating procedure (S0) 11.1.A-3, " Standby LiqutJ Control System Setup for Normal Operations, which contained parameters to initially fill and setup the system a
for operation after out-of-service maintenance.
This procedure required the tank to be heated to 150 degrees F during the fill process prior to initial chemical addition. This temperature requirement was transmitted to the Auxiliary Plant O!erator (APO) who initiated heat-up of the SBLC storege tank.
The procedure that should have been used was 50 11.7.A-3, Stanaby Liquid Control System Chemical Makeup, which controls the addition of demineralized water and/or chemicals to the system. This procedure required the operator to raise the temperature of the tank between 105-115 degrees F for chemical addition, not 150 degrees F.
Had the proper procedure been utilized, chemical addition to the SBLC storage tank would have been completed without overheating the tank.
A contributing factor to tne use of an inappropriate procedure was less than adeouate planning and coordination of the evolution.
The direction provided in the Night Orders required that the SBLC storage tank be heated for chemical addition, without reference to the appropriate procedure or process control limit. Additionally, a shift supervision review or pre-job briefing was not performed prior to initiating the work activity. These actions would have clarified the appropriate procedure and process.
Proper planning and review of the job would have minimized the possibility of selecting an inappropriate procedure, it was also determined that the SBLC operating procedure did not contain adequate prerequisites or precautions concerning system operability in regard to tank high temperatur0 setpoints or overheating. This was a result of programmatic deficiencies in the transfer of engineering information regarding system operating parameters into plant procedures. Although information was in existence at the of fsite engineering of fices concerning the maximum operating temperatures of thc SBLC storage tank, this information was not included in the initial system setup procedure, the chemical makeup procedure or the alarm response card. This information had been.dentified in 1987 as a result of Modification 867, which changed the concentration of the SBLC solution. Questions were raised by the Plant Operations Review Committee (PORC) during the review of the Unit 3 Modification
- tceptance Test (MAT) and a graph was presented by Engineering depicting SBL'
'nk level versus t ak temperature and subsequent reduction in Het Positive Suction Head (NPSh, availability. Guidance as to the basis for the high temperatcres alarm setpoint or possible system impect of exceeding these limits, however, were not included in the modification training letter or system operating procedures.
A contributing cause for the lack of adequate proccdural precautions or prerequisites was less than adequate communications batween off-site engineering and plant system engineerir.g personnel concerning significant system operating parametdrs and constraints.
If the purpose of the tank l
- Document Control Desk Page 5 temperature limits had been properly communicated, it is likely that this information woulo have been incorperated into the applicalle system operating procedures.
Corrective Steps That Have Been Taken and Results Achieved Coaching was performed with the appropriate personnel concerning the importance of attention to detail with respect to proper procedure usage.
The operating procedurer involving SBLC chemical makeup and the storage tank temperature alarm response cards have been revised to include a caution which addresses tank temperatures and their imnact on SBLC system operability. A letter was also given to the Operators and Shift Technical Advisors that provided the basis for the SBLC high temperature alarm setpoint and its impact on tystem NPSH. Additionally, the procedure used to initially fill and setup the SBLC system has been revised to allow chemical mixing at temperatures similar to the chemical makeup procedures. This will eliminate future confusion between temperature setup requirements.
A review was performed concerning the dissemination of engineering information into plant procedures and programs. This review concerned programs that involve changes that could be introduced into system operating parameters.
The modification control program has been significantly enhanced since 1987 which in part has strengthened the control of changes to plant procedures as a result of modification.
Improvements have also been made in preserving important information.
Procedure changes that are based on commitments are now annotated.
Additionally, PORC forms were revised to specify material to be included in site training programs. Operations Support reviews the PORC minutes to identify the training issues.
These corrective actions will also serve to prevent recurrence of future violations.
Corrective Steps That Will Be Taken To Prevent future Violations Information concerning the SBLC tank overheating incident and the effects of low NPSH on positive displacement pumps will be conveyed to appropriate Operations and Techniccl Staff personnel. Additinnulla, on-site and off-sit; engineering personnel will be informed of this event and tFe need for effective communication concerning key system parameters.
A Design Basis Document Program is in progress which will consolidate pertinent design basis information for each system.
It is expected that these accuments will assist in ensuring that critical parameters are incorporated into site procedures.
Plant per sonnel will be instructed to perform more thorough reviews when changing procedure limits. PORC members will also be instructed to increase their scrutiny of all procedure limit changes.
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- Document Control Desk Page 6 Date When Full Compliance Was Achieved Full compliance was achieved on June 27, 1991, when Standby Liquid Control Operating Procedures were revised to include adequate precautions of system operabi'ity with respect to NPSH and high tank temperature.
Additional Concerns As requested in the Notice of Violation cover letter, additional information is herein provided describing our actions to ensure 1) proper planning and coordination of non-routine operating evolutions; 2) translation of important design and operability information into procedures and training; and 3) adequate review of engineering calculations.
Planning of non-routine operating evulutions is normally performed by Operations department unit coordinators in conjunction with plant staff and Operations personr.el. Coordination of non-routine evolutions are performed Lv either on-shift Operations personnel or the unit coordinators depending on the complexity of the evolution.
Staff review has identified that enhancements can be made to the planning and coordination of non-routine evolutiors. We plan to clarify the responsibilities of the unit coordinators to ensure that, depending on the complexity and/or significance of the evolution, appropriate precautior.s and contingencies are identified to Operations personnel.
Additionally, the plant scheduling group will assist in the planning and coordination of non-routine operating evolutions.
A review was conducted concerning the capture and dissemination of information into appropriate procedures and training.
This review identif ied that most processes were proceduralized in adequate detali to capture important information and subsequenc training. Aspects of the EWR and OEAP processes will be enhanced to ensure that information capture and training concerns are adequately addressed.
The Design Basis Document (DBD) program will also serve to provide important design information for the appropriate system procedures.
The procedures and critical operating parameters will be enhanced with inforr;ation obtained as a result of the DBD program.
Engineering personnel will be issued a training bulletin by September 2/,
1991, that describes the reason for inconsistencies in NPSH values used at the SBLC Enforcement Conference. This bulletin will stress that key inputs to calculations must have a cleerly accumentud and supported basis.
It will also stress that vendor supplied information used in calculations must be clearly understood by personnel performing the calculations. Additionally, a more rigorous questioning attitude on the part of the preparer, independent reviewer, and approvers must be performed to ensure that the calculation inputs, basis, methodulogy and outputs are understood and accurate.
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