ML20082S565

Responds to NRC Re Violations Noted in IE Insp Repts 50-277/83-27 & 50-278/83-27.Corrective Actions:Exact Procedural Controls Re Safe Operation Prior to Return to Power After Trip Discussed W/Senior Staff

ML20082S565
Person / Time
Site:	Peach Bottom
Issue date:	11/22/1983
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20082S559	List: ML20082S565
References
NUDOCS 8312140204
Download: ML20082S565 (5)

Text

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PHILADELPHIA ELECTRIC COMPANY 23o1 M ARKET STREET P.O. BOX 8699 PHILADELPHIA PA.191o1 SHIELDS L. DALTROFF ELECTatc *R C lose November 22, 1983 Docket Nos . 50-277 50-278 Inspection Report Nos. 50-277/83-27 50-278/83-27 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Starostecki:

Your letter dated October 24, 1983, forwarded Combined Inspection Report 50-277/83-27 and 50-278/83-27. Appendix A addresses four items which do not appear to be in full compliance with Nuclear Regulatory Commission Requirements. Per your October 24, 1983, letter, Item A.4 does not require a reply since corrective action on this item was completed and verified by the Inspector during the inspection. Items A.1, A.2 and A.3 are restated below along with our response.

A.1 Technical Specification 6.8, Procedures, requires that written procedures and administrative policies be implemented that meet Section 5.1 and 5.3 of ANSI 18.7-1972. ANSI 18.7-1972, Section 5.1.1, requires delineation of responsibilities to determine the circumstances, analyze the cause, and determine that operations can proceed safely before the reactor is returned to power after a trip. Procedure GP-18, Revision 1, July 6, 1983, Scram Review Procedure, requires the completed scram review check-of f list, C.O.L. GP-18, to be reviewed by the Operations l

l 8312140204 831209 PDR ADOCK 050002 G

Mr.'Richcrd.W. Starostecki Page 2 1 Engineer or alternate prior to subsequent plant st art up .

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< Contrary to the above, a plant startup was commenced on ' October '2, 1983, and the C.O.L. GP-18 from a scram on September 27, 1983, had not been reviewed by the Operations Engineer or alternate.

This -is ~ a Severity Level V Violation ~ (Supplement I) applicable ' to DPR-56.

RESPONSE

A Immediately after the scram, the Technical Engineer (Op rations Engineer was not on-site at time of the scram) proceeded to the Control Room. He was briefed on the scram F by the STA and he inspected the completed C.O.L. GP-18, the computer alarm typer output, and the reactor charts.

Although the procedure C.O.L. GP-18 review signoff blank was i not signed or initialed, review of the transient by the 4 Technical Engineer was documented in the STA Logbook i

following the scram.

i The' Operations Engineer, Station Superintendent, Technical Engineer, Shif t Technical Advisor, and Shif t Supervision were all briefed on or involved with the transient and were L

j satis fied with the saf ety system operation and transient analysis following the transient. A thorough review -of l

C.O.L. GP-18 had been completed, the transient was analyzed and the safety systems were verified to operate properly.

The Operations Engineer mistakenly signed the GP-2A check-

- .off list for the October 2 start-up showing that he had reviewed C.O.L. GP-18 when in f act he had not. He recalled

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reviewing a C.O.L. GP-18, but it was for a previous scram that occurred on September 12, 1983. Both scrams wero similar, had no improper operation of equipment, and had almost no operational effects on the power plant. ,

l-Upon notification by the inspector of the signoff omission, i the Assistant Operations Engineer immediately performed a formal review of C.O.L. GP-18 for the October 2 scram.

} As a result of this incident, the importance of complying with the exact requirements in procedural controls has been

! discussed with the senior staff. This should preclude future occurrences.

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4 Mr. Richard W. Starostecki Page 3 A.2 Technical Specification 6.8, Procedures, requires that written procedures and administrative policies be

' implemented that meet Sections 5.1 and 5.3 of ANSI 18.7-1972. ANSI 18.7-1972, Section 5.1, requires that written administrative policies assure.that procedures, including revisions thereto, are distributed to and used by the personnel performing the prescribed activity. Administrative Procedure A-2, Revision 25, September 7, 1983, Administrative Procedure for Control and Use of Documents requires that. procedures to be used as Check-off lists or for surveillance testing lue obtained from the sain office files of the latest revision of procedures or copied from an up-to-date revision of the procedure.

Contrary to the above, procedures used for Check-off Lists and for surveillance testing were neither obtained from main office files of latest revisions nor copied from up-to-date revisions of the

. procedures, in that (1) on September 8 and 13, 1983, Surveillance Test ST 3.2.3, IRM Functional and Calibration Check, was performed using Revision 5, November 2, 1978, whereas the latest revision was Revision 6, June 13, 1983: and (2) on September 27, 1983, Check-off List C.O.L. GP-18, Scram Review

. Procedure,.was performed using Revision 0, March 23, 1983, whereas the latest revision was Revision 3, September 21, 1983.

This is a Severity Level V Violation (Supplement I) applicable to DPR-56.

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RESPONSE i

The Surveillance Test ST 3.2.3, IRM Functional and Calibration Check, had been recently revised to incorporate minor improvements in recording "as found" information.

When required for startup, the surveitlance test was removed and issued from a book of uncontrolled procedures kept available for startups.

The purpose of ST 3.2.3 is to verify the operability of the IRM channels. The outdated procedure revision still satisfied this purpose because the recent revisions were improvements in recording "as found" data only. Therefore, no immediate-corrective actions were necessary to enhance

f. performance of~the surveillance test.

w.. .

e Mr. Richard W. Starostecki

. Page 4 When Check-off List C.O.L. GP-18, Scram Review Procedure was i required for the September 27 Unit 3 scram, an outdated revision was issued.from a personal file of non-controlled procedures.

Per the April-14, 1983 NRC Inspection Report 277/83-05 and 278/83-05, the NRC inspector.has reviewed GP-18 and the system for evaluating plant. trips. The procedura and the evaluation process were considered technically adequate at the time. Since that date, changes were made to GP-18 in light of events at another plant. Because the past revision of GP-18 still satisfied the intent of the procedure, further immediate corrective actions were not required.

To prevent future occurrences, a letter has been sent to all Shift Superintendents, Shift Supervisors, and Shift Technical Advicors informing of the occurrences and instructing them to destroy files of uncontrolled procedures. The book of startup surveillance tests has been deleted and replaced with a single sheet listing the procedures used for a startup. Procedures required for i

startup will be removed from the controlled file or copied from books of controlled procedures available in the control room.

A.3 Technical Specification 6.8 and Regulatory-Guide 1.33 (November 1972) require implementation of written procedurec for fire protection equipment.

Administrative Procedure A-30, Revision 4, June.10, 1981, Plant Housekeeping Controls, states in paragraph

.9, Maintenance of Fire Fighting Capabilities, that the storage of equipment and materials shall not impede access to fire-fighting equipment.

Contrary to the above, access to fire-fighting equipment was impeded, either'through storage of material in front of equipment or by storage of the equipment away from its designated location, on September 26, 1983,.for Fire Stations 135-23, 135-13, i and 165-43; and on September 28, 1983, for Fire Stations 116-17 and 91-20.

This is a Severity Level IV Violation (Supplement I)

applicable to DPR-44 and DPR-56.

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Mr. Richard W. Starostecki Page 5

RESPONSE

Each discrepancy was caused by a lack of attention to detail-by individuals working in the areas. When informed of the ^

discrepancies by the inspector, the ptsblems were promptly .

corrected.

A letter has been sent to all Peach Bottom supervision reminding them and their personnel of their fire protection ~

responsibilities. Work groups are also requenced to report -

fire equipment discrepancies to their supervisors or shift' supervision immediately. In addition, requirements for fire protection have been added to the Nuclear Plant Rules.

These corrective actions should end any adverse fire protection trends.

Should you require additional information, please do not hesitate to contact us.

'V'ery truly yours,

/ r

/- l ;;L ate k Il ($f cc: Mr. A. R. Blough i

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