ML20085F911
| ML20085F911 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/11/1991 |
| From: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CNN-91-14166, NUDOCS 9110240020 | |
| Download: ML20085F911 (4) | |
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raum arreuw-nes rou s a op e u sis m i Fl?) 4 % '014 D. B. Miller, Jr.
Vice Pinuent October 11, 1991 Docket Nos 50-277 50-278 U. S. Nuclear Regulatory Commission ATTH: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station - Units 2 & 3 Response to Notice of Violation 91-24-01 (U3)
(Combined Inspection Report Hos. 50-277/91-241 50-278/91-24)
Dear Sir:
In response to your letter dated September 12, 1991, which transmitted the Notice of Violation in the referenced inspec. ion report, we submit the attached response. -The subject inspection report concerns a routine inspection of the engineering and technical support groups at the site.
This inspection was conducted July 15 19, 1991.
If you have any questions or require additional information, please do not hesitate to contact us.
Sincerely,
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cc:
R. A. Burricelli, Public Service Electric & Cas T. M. Gerusky, Conunonwealth of Pennsylvania J. J. Lyash, USNRC Senior Resident inspector T. T. Martin, Administrator, Region 1. USNRC
- 11. C, Schwemm. Atlantic Electric R. 1. McLean State of Maryland J. Urban. Delmarva Power 9110240020 _911011 a
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Document Control Desk Page 2 bcc: J. W. Austin A4-4N Pear.h Bottom J. A. Basilio 52A-5, Chesterbrook G. J. Beck
$2A-5, Chesterbrook J. A. Bernstein
$1A-13. Chesterbrock R. N. Charles 51A-1, Chesterbrook Commitment Loordinator 52A-5, Chesterbrook Correspondence Control Program 61B-3, Chesterbrook J. B. Cotton
$3A-i, Chesterbrook G. V. Cranston 63B-5, Ctesterbrook i
E. J. Cullen S23-1, Main Office A. O. Dycus A3-IS, Peach Bottom A. A. fulvio A4-IS, Peach Bottom D. R. Helwig
$1A-ll, Chesterbrook R. J. Lees. HRB
$3A-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-IS, Peach Bottom J. M. Pratt B-2-S, Peach Bottom J. 1. Robb SlA-13, Chesterbrook D. M. Smith 52C-7, Chesterbrook
Document Control Desk Page 3 Restatement of Violation Technical Specification 6.8 requires that written procedures and administrative policies shall be established, implemented and maintained that meet the requirements of Appendix "A" of USAEC Regulatory Guide 1.33 (November 1972).
Appendix-"A" of USALC Regulatory Guide 1.33 (November 1972) requir es the preparation of procedures foo.the control of modification work.
Peach Hottom Atomic Power Station procedure A-14. Revision 18. " Plant Modifications" requires that subsequent to the resolution of any t onrerns, the Superintendent of Operations, Or designee shall sign the final Modif Ication Turnover Form signifying Operations' acceptance of the modificotton testing.
The procedure states that the modification, within the scope of the turnover, is considered operable at this stage.
Contrary to the above, the lite,n Pressure Coolant injection System (HPCI) was considered operable when Uni', 3 was returned to power on January 23, 1991, even though concerns were twt resolved and the final Modification lurnover form was not signed by the Superintendent of Operations or designee.
This is a Severity Level IV violation.
(Supplement I)
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Background
A review of Unit 3 Modification 5275 f or replacing the HPCI-auxiliary oil pump relays with qualified relays was performed by the Operations shifL on January 20, 1991. The Maintenance Request form (MRI). Operation Verificot ton form
-(OVF), testing method and A-14. " Plant Modifications" paper work were included-in this review.
The testing and completion of work were found ac<eptable by
-shift management and the MRf and OVf were signed off as completed.
Additionally, review of form A_14-3, " Final Modification Turnover form",
indicated _that_no asterisked items required updating. Asterisked items
-indicate procedures and other programs that need revision prior to declaring the modification operable, lhe Shift Manager and Operations Support Engineer discussed the modification and it was determined that Unit 3 llPCl was operable, but that Operations Support would perform a follow-up review to verify proper completion of documentation. Unit 3 HPCI was determined operable and_a variance was doW mented on GP-2, Normal Plant Startup step-3.14.3.
The Shift Manager failed to sign-off the final Modification turnover form signifying modification acceptance prior te declaring HPCI operable due-
-to his misunderstanding of A-14 and miscommunication with the Operatlons Support Engineer concerning the Operations-Support review.
This follow up review identified various programmatic concerns with the modification process.
Corrective Steps Which Have Been lakcn and the Results Achieved As a result of the concerns an.1 deficiencies associated with the installation of Unit 3 Mod 5275, five corrective action requests (CAR's) were initiated on January 29.-1991, to evaluate weaknesses and non-conformances of the modification process. Meetings were also conducted between System Engineers
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Document Control Desk Page 4 and Operations Support to discuss and clarif y areas of concern associated with the modification.
It was decided that a Modification Acceptance lest (mal) would be performed to properly document acceptance testing.
The Operations Manual (0M) Section 10. "Equipme'
'ontrol", was revised June
- 27. 1991, to require the completion of any repe modif icat ions and special tests prior to the return of a system or equipt
, service.
A Modification Process integration Task force was w. ned in May. 1991, to evaluate and assess mod processes.
An evaluation was also initiated to determine the applicability of a corporate level procedure to control the overall modification process and to clarify appropriate process protocol.
The information and lessons learned from Unit 3 Modification $2/5 were applied during the review process of the Unit 2 modification.
lhis enabled the Unit 2 modification to be complet d in an effective and appropriate manner without the concerns associated with the Unit 3 modification.
Corrective Steps Which will be Taken to Avoid future Violations A review of modification process procedures including A-14. " Plant Modifications" NLDP 2.2, " Preparation of Ingineering Work letter (LWL) and Modification Memoranda and NGAP 10P005, " Design Equivalent Change Control" will be conducted to ensure that the process requirements are clear and consistent. The procedures will be revised as necessary to clarify the appropriate mechanisms or methods to be used during the modificalion process and to resolve any conflicts associated with the process.
Information regarding this incident, the modification process and procedures will be routed to Opera *. ions, lechnical and Projects personnel. Additionally, training on the modification process and procedural requirements will be conducted during Licensed Operator Requalification Training.
Date When full Compliance Will Be Achieved full compliance will be achieved when the Unit 3 HPCI Auxiliary 011 Pump is reassembled, the MAT is successfully completed, and the Final Modification Turnover form is signed.
lhis will be accomplished prior to the completion of the Unit 3 Outage scheduled for December 6, 1991.
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