ML20090H937

Forwards Payment in Response to 840618 Notice of Violation & Proposed Imposition of Civil Penalties in Amount of $30,000.Corrective Actions:Personnel Reinstructed on Use of Maint Request Form

ML20090H937
Person / Time
Site:	Peach Bottom
Issue date:	07/18/1984
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
EA-84-039, EA-84-39, NUDOCS 8407270277
Download: ML20090H937 (9)

Text

a OM PHILADELPHIA ELECTRIC COMPANY 23ol MARKET STREET P.O. BOX 8699 PHILADELPHIA, PA.19101 1215)841-4502 Tc"I c*sIo"c7t July 18, 1984

$NG0NES ReMG AND RESE ARCH Docket Nos. 50-277 50-278 EA No. 84-39 Mr. Richard C. DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. DeYoung:

By letter dated June 18, 19 8 4 , R . C . Young , N RC , to V. S. Boyer, PECo, Philadelphia Electric Company received a Notice of Violation and Proposed Imposition of Civil Penalties EA No. 84-39.

Philadelphia Electric Company agrees with the description of the events contained in your letter and the notice and your indicatica that the events cited in each of the violations Assessed a Civil Penalty was identified and properly reported to the NRC by the Company. Philadelphia Electric Company appreciates your recognition of the prompt corrective actions taken by our staff and your mitigation of the Civil Penalty.

A restatement of the violations follows below along with our responses.

II. Violations Not Assessed a Civil Penalty Restatement of Violations II.A, II.B and II.C

" Technical Specification 6.8 and Regu.atory Guide 1.33 (November 1972) require implementation of written procedures for troubleshooting, for control of maintenance and for surveillance tests.

j[h 8407270277 840718

0 PM ADOCK O$000277 l G PDR t

_ . . _ .~ . - -, .. . _ _ _ _ . _ . _ . _ . _ ._

l, _  :

- Mr. Richard C.'DeYoung July 18, 1984 Page 2 i

Contrary to the above, written procedures, as required above, were not adequately implemented as evidenced.by the following examples:

p

, A. Administrative Procedure A-26, Revision 23, dated June 24, 1983, Procedure for Corrective Maintenance,

. requires immediate investigation of plant problems and initiation of a Maintenance Request Form (MEP)

! for problems that cannot be corrected within eight hours.

4 However, problems.with testing and operating the RWM and RSCS during a plant shutdown on November 17, 1983, were not sufficiently investigated to correct i the problem within eight hours, and no MRF was initiated.

4 B. Administrative Procedure A-47, Revision 2, dated

April 14, 1980, Procedure for the Generation of

Surveillance Tests, requires'that surveillance test

procedure steps which document completion of

! Technical Specification related surveillance

requirements to be indicated with an asterisk. The

test results section shall-be signed only if'all

asterisked steps are completed satisfactorily.

i 1 '

Technical Specification Surveillance Requirement 4.3.B.3a states that a group notch mode of RSCS shall be demonstrated to be operable by nttempting to move

! a control rod more than one. notch in the first program group after reaching'50 percent rod density

~

i i- on a reactor startup.

, However, ST 10.6, Revision 10, dated July 18, 1980, _

Rod Sequence Control System (RSCS) Function Test, was I written and implemented without making the Technical l

Specification requirement an asterisked step. As a-l result, completed tests do not contain documentation

of the completed Technical Specification surveillance t- requirement, and they were signed-off as satisfactory.

l

! C. Surveillance Test Procedure ST 10.5, Revision 11, i dated July 18, 1980, RWM Operability Check, requires, in an asterisked step, selection and listing ~of at l

i n

- _ _ . . . . _ _ . . . - _ u _:_ . _ - _ _ . _ _ __ .- . _ . , _ . . . _ u u... .,_.;..

I I' i July 18, 1984 Mr.' Richard C.'DeYounh ' l \ ,

Page 3

( g{

\ y ,

?

\ s

least three rods to verify operability of the RWM rod

'~

select error function. / t i i ,

( .. .

However,.on May 28,1983, St 10.5 was completed and

, signed-off as satisfactory when only one rod was y

listed as having been used to verify the operability of the rod select error function.

. s i Thiis is a Severity. Level IV vidl t$10,n (Supplement I) ."

l Response to Violation II.A /

i

The Rod Worth Minimizer (RWM) and Rod Sequence Control ,

i System (RSCS) ' surveillance tests were not satisfactorily I completed on November 17, 1983.s As authorized by the Technical Specifications, a second licensed operator was

- assigned'to fill the function:of the Rod Worth Minimizer.

1 The Rod' Sequence Control System surveillance test

! deficiency was being investigated when the main turbine I experienced high vibration and efforts were directed to

accelerate the plant shutdown. .The plant scrammed shortly.thereafter,,so the Rod-Sequence Control System-l test'could not have been completed even if.the problem  ;

i had'.been identified.' Since both tests could not be 2 completed, the documents were not retained, and because

! the ' attention .of the control 4 room personnel was focused  !

{ oh the: plant shutdown and scram, the Maintenance Request-Formo were' not initiated.

8 i .

i Both the Rod. Worth Minimizer and the Rod Sequence Control system functional tests were performed satisfactorily and j no discrepanices were' identified prior to reactor startup j- on November 21, 1983.

. t a

1 On April 10, 1984, a letter was distributed to all Senior

! Engineers requeuting them to remind their personnel that

'once~a surytsillance test'is begun, the document must be inalntained and must eventually be filed in the station i

files. 'This letterialso reminds personnel that problems .:

l which cannot-be corrected within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> through the.use ofsplant procedure.s require the initiation of a Maintenance Request' Form, l

i 4

6 t

.k-g,

(,

I 5 I

)

\l' j A ,,

-( ( \ S r, s y [

s

}' '

, . ,. . fe ; - - _

_m . _ , -_ .i! _ . . _ , - _ _ . . _ . . . _. , n., . __,$_-

Mr. Richard C. DeYoung July 18, 1984 Page 4 4

Response,to Violation II.B This violation was caused by a typographical error.

ST 10.6 - Rod Sequence Control-System (RSCS) Functional Test, Revision 8, dated August 11, 1977, was revised on October 13, 1978 to add steps.for-procedure clarification. When the revision was submitted for typing, the step which demonstrated the operability of the Group Notch mode of RSCS af ter reaching 50 percent rod density on a reactor startup was indicated with an asterisk. During the typing, however, the asterisk was j mistakenly deleted from the procedure step. The step was typed next to the bottom of the page and when the procedure was copied, the sign-off blank was not reproduced on the copy.

Although the step was not identified by an asterisk, the

surveillance test requires documentation of additional 1 actions required if other portions of the test do not i function properly or if other discrepancies were noted during the performance of the test. If the step failed to produce the expected results, this requirement would identify and document the discrepancy.

ST 10.6 - Rod Sequence Control System (RSCS) Functional Test was revised and retyped on April 10, 1984, to correct the typographical errors identified in this inspection.

In addition, the clerical staff responsible for retyping revised or newly drafted procedures have been given guidance on~ areas to review when a procedure is typed.

The clerical staff has also been instructed to obtain a second proof by the individual who submitted the document for revision prior to distribution of the document.

t Response to Violation II.C 4 This violation was caused by errors incurred during the review of ST 10.5 after its completion. Individuals performing the test review failed to note that two control rods were not documented on the surveillance test. The operator performing the test selected three control rods to verify operability of the Rod Worth Minimizer rod select error function, but neglected to record two of three rods he selected on the procedure.

E m - , a s - -- - -<

,t  ?

.j, 9

tl -

Mr. Richard C. DeYoung

• July 18, 1984

' / Page 5 1 s

l

^

? s i

The, operator who performed the test has been counseled on the'importance..of fully completing surveillance tests.

The individuals who performed the review for this .

. surveillance test.aave since left Philadelphia Electric Company for reasons unrelated to this error, cs ,

In addition, ST 10.5, RWM Operability Check, was revised

- on, November 8, 1983, to make the need for data entry on

. the surveillance test more obvious to-the individual

, pgrf.orming the test, and more obvious to the individual reviewing th'e completed document. 3 I. , Violations Assessed a Civil Pena,ity RestatementofV!lat[onI.A i

" Technical Specification 3.6.A.l requires uhat the average rate of change of reactor coolant temperature not exceed 100 degrees E in any one-hour period during normal heatup or cooldown.

Contrary to the above:

, 1. During the heatup of Unit 3 on January 24, 1984, between 9:15 a.m. and 10:15 a.m. and between 9:30 a.m. and 10:30 a.m., the average rate of change (average over an hour) of the reactor coolant temperature, as indicated on the B recirculation loop l temperature recorder, exceeded 100 degrees.F per hour. The actual temperature changes over the respective one-hour periods were-102 degrees F and 111 degrees F'.

2. During heatup of the Unit 2 reactor,_on January 31 1984, between 4:20 a.m. and 5:20 a.m., the-reactor coolant temperature, as indicated by the A.and B Recirculation Loop temperature traces, increased:110 degrees F.

Violation I.A. has been categorized with Violation I.B and Violation I.C as a Severity Level III' problem (Supplement I).

(Civil Penalty $30,000. distributed. equally amongi the

violations)."

I s

+- ,-g w +-r e 9 ap 9p -y y 4w+4,, ++- m

l Mr. Richard C. DeYoung July 18, 1984 Page 6 Response to Violation I.A This violation was caused by personnel error.

During the startup of the Unit 3 reactor on January 24, 1984, operator trainees under the supervision of Reactor Operator were recording and calculating the reactor coolant temperature changes in accordance with ST 9.12 ,

(Reactor Vessel Temperatures) . The Reactor Operator's '

review of the Surveillance Test data identified the calculation errors.

The immediate action taken by the Reactor Operator was to reduce the heatup rate.

The Reactor Operator, the Utility Reactor Operator involved with the startup, and the Shift Supervisor each received disciplinary action for their lack of attention to detail.

During startup of the Unit 2 reactor on January 31,-1984, a reactor operator, while performing ST 9.12 (Reactor Vessel Temperatures), noted that the heatup rate was exceeding the Technical Specification limit. In responding to this event, the operator failed.to take adequate corrective action rapidly enough to prevent reactor coolant temperature from rising by more than 100 degrees Fahrenheit within a one-hour period.

The Reactor Operator, the Utility Reactor Operator involved-in the startup, and the Shift Supervisor have each received disciplinary action for their lack of attention to detail.

i A letter from the Station Superintendent to all Licensed Operators was-distributed on April 10, 1984 to discuss the_heatup rate Technical Specification violations, clarify operator responsibilities, and tx) further express '

management's commitment to procedure compliance. This

letter was attached to the April 10, 1984 shift meeting l

notes and reviewed.during shift meetings to ensure that all operations personnel were aware ~of its contents.

Restatement of Violation I.B

" Technical Specification 3.6.A.2,' Thermal and t

Pressurization Limics, and Figure 3.6.2,. prohibit reactor.

l l

l l

. . . ;. .. . , , . .-. - . . . ;,- , , , +

l

,8 Mr. Richard C. DeYoung July 18, 1984 Page 7 vessel pressurization above atmospheric pressure at vessel temperatures below 120 degrees F.

Contrary to the above, for approximately five minutes at about 5:30 p.m. on January 25, 1984, the Unit 3 reactor vessel was pressurized above atmospheric pressure to about 10 psig, and at the time, the reactor vessel temperature was below 120 degrees F. (about 110 degrees F).

Violation I.8. has been categorized with Violation I.A.

and Violation I.C. as a Severity Level III problem (Supplement I) .

(Civil Penalty - $30,000 distributed equally among the violationr)."

Response to Violation I.B The event was caused by personnel error. (Failure to follow procedures)

On January 25, 1984, Peach Bottom Atomic Power Station Unit 3 was in a cold shutdown condition. Upon completing maintenance on the reactor feed pump bypass valve, the permits were cleared and the system was set up for long path recirculation (feedwater system flush to the condenser). In setting up the feedwater system for long path recirculation, the operator _ failed to close the feedwater inlet valves to the reactor vessel as required in system procedure S.7.1.D. With a condensate pump in service, the operator opened the 5th heater outlet valve with the feedwater inlet valves open to the reactor vessel, thereby injecting condensate into the reactor vessel. Reactor vessel level increased approximately six feet and a minimal pressure increase was noted in the wide range reactor pressure strip chart recorder (PR 06-96). This pressure increase was estimated to be less than 10 psi, since the pen movement was much lesc than half of a 20 psig increment on the chart (0-1500 psi).

As a corrective measure, the responsible operator received specific counseling on the importance of following procedures.

In addition, this event was discussed in detail during l

shift meeting.

l l

.h-1 l Mr. Richard C. DeYoung July 18, 1984 l Page 8 l

As a further corrective action, the station superintendent directed the operations engineer to emphasize to the operators at shift meetings of the importance of following the approved written procedures of the plant, and that operators are required to know and use those procedures applicable to their day-to-day work.

Restatement of Violation I.C

" Technical Specification 3.3.C.3 specifies that the maximum scram time for 90 percent insertion of any operable control rod shall not exceed 7.0 seconds.

Technical Specification 3.3.A.2.C specifies that control rods with scram times greater than those specified in Technical Specification 3.3.C.3 shall be considered inoperable.

Contrary to the above, on November 17, 1983, control rod 34-27 had a scram time of greater than 12 seconds, as indicated on a strip chart recorder, but this condition was not recognized at that time and the control rod was not considered inoperable until a subsquent reactor scram on January 14, 1984.

Violation I.C. has been categorized with violation I.A.

and Violation I.B as a Severity Level II problem (Supplement I) .

(Civil Penalty - $30,000 distributed equally among the violations)."

Response to V_iolation I.C The event was caused by a failure of personnel to recognize and interpret the information displayed on the scram insertion time recorders as required by procedure ST 10.9, specifically Surveillance Requirement 4.3.C.2.

l The corrective action taken was to modify the procedure. q for scram time testing by including samples of timing traces of control rods that fail to scram, control rods that scram from various positions, and control rods with acceptable scrams to the procedure.

l l

1 1

l

l. ,1 s f Mr. Richard C. DeYoung July 18, 1984 -

i Page 9 In addition, the operators have been instructed to use a computer program to monitor all control rod positions following a controlled manual scram.

Conclusion We believe that Philadelphia Electric Company has acted responsibly and expeditiously in reporting events, investigating and analyzing the cause of each event, performing corrective actions and, where possible, implementing measures to prevent recurrence.

Philadelphia Electric Company recognizes your reduction of the base civil penalty as an acknowledgement of our responsiveness. Although we believe the imposition of a civil penalty is not the proper vehicle for promoting improved performance, we hereby enclose a check in the amount of $30,000 as payment of the imposed civil penalties.

In addition to discussing each of the aforementioned violations, your letter of June 18, 1984, included an Order Modifying License, Effective Immediately. At the present, our management has reviewed your Order Modifying License and is prepa. ring a plan in conformance with the order. In accordance with the instructions in your order, the Region I Administrator should anticipate receipt of our plan for his appraisal by August 17, 1984.

If we can provide further information, please contact us.

Very truly yours, EE",4v Attachment cc: Dr . T. E. Murley,-Administrator )

Mr. A. R. Blough, Site Inspector