ML20097G673
| ML20097G673 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/12/1992 |
| From: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CCN-92-14075, NUDOCS 9206170209 | |
| Download: ML20097G673 (7) | |
Text
CdN 92-14n75 f
%c PIIILADELPIIIA ELECTRIC COMPANY C'h PEACll 110T1DM AlDMIC POWER STATION R D.1, Box 208 ggg Delta, Fennsylvania 17314 l
- ym nornus-tur esta or axcrurwr (717) 4 4 7014 D. B. Miller, Jr.
Vice Prestent June 12, 1991 Docket Nos. 50-277 50-278 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Sta'. ion - Units-2 & 3 Reply to Unresolved Items froit Combined Inspection Report' Nos. 50-277/92-80: 50-278/92 In response to your letter dated May 11, 1992, which transmitted the Unresolved Items concerning the referenced Inspection Report, we submit our interim corrective actions taken and future actions to address these areas.
The subject Inspection Report concerned the findings of an Integrated Performance Assessment Team Inspection conducted February 24 through March 13, 1992.
If you have any questions or require additional information, please do not hesitate to contact us.
1 Sincerely, t
cc:
R. A. Burricelli, Public Service Electric & Gas T. M. Gerusky, Commonwealth of Pennsylvarsia J. J. Lyash, USNP.C Senior Resident-_ Inspector T. T. Martin, Administrator, Region I, USNRC H. C. Schwemm. Atlantic Electric R. I. McLean State of Maryland C. 0.-Schaefer, Delmarva Power
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9206170209 9206:2 I
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bcc: J. W. Austin A4-4N, Peach Bottom J. A. Basilio 52A-5, Chesterbrook G. J. Beck 52A-5, Chesterbrook J. A. Bernstein 51A-13. Chesterbrook
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R. N. Charles 51A-1, Chesterbrook Commitment Coordinator 5?A-5, Chesterbrook Correspondence Control Program 618-3, Chesterbrook J. B. Cotton 53A-1. Chesterbrook s
l G. V. Cranston 638-5, Chesterbrook i
E. J. Cullen S23-1,-Main Office A. D. Dycus A3-1S, Peach Bottom A. A. Fulvio A4-4N, Peach Bottom D. R. Helwig 51A-11. Chesterbrook C. J. McDermott S13-1 Main Office D. B. Miller, Jr.
SM0-1. Peach Bottom PB Nuclear Records
- A4-2S, Peach Bottom K. P. Powers A4-1S, Peach Bottom J. M. Pratt-B ~-S, Peach Bottom J. T.-Robb 51A-13, Chesterbrook D. M. Smith 52C-7, Chesterbrook s
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9 Document Control Desk Page 3 Restatement of Unresolved Item 92-80-01, " Assessment of Inoperable Control Room Instrumentation" The Team identified three instances in which the effect of inoperable control room instrumentation had not been effectively evaluated with respect to-emergency operating procedure implementation. The Team expressed concern for the total number of inoperable control room instrumentation, the cumulative offect of the inoperable equipment on operator and plant response to transients, and the effectiveness of operational evaluations for inoperable instrumentation.
Response
At the time'of the IPAT inspection, the existing list of control room equipment and instrument deficiencies was reviewed by personnel from tne Maintenance /I&C and Operations Sections.
Each deficiency was assessed for its individual impact on plant operations including transients and emergencies.
As a result of these individual assessments, several-deficient instruments were identified as having impact on-the ability to use emergency operating procedures. The identified deficiencies were assigned higher priority for repair, and in one case, a reading training package and an operator aid were prepared to brief operators about a potentially difficult-procedural condition.
In addition to the individual deficiency assessments, the net-impact of all known deficiencies was cvaluated. Although operators were challenged more than desired, operations management was= satisfied that-the conditions did not degrade the ability _to safely operate the plant. The need for improving the assessment and control of control room enuipment deficiencies was recognized and stressed to operators.
S mce-the IPAT inspection, an improvement has been observed-in the ability of operations personnel to assess the_ impact of control room equipment deficiencies. _This improvement has been exhibited by Shift Management identifying several~.new deficiencies as having potential impact on emergency and transient procedures.
After the possible impacts were identified, the-deficiencies were evaluated for compensatory action and assigned higher priority for repair than the-nornal_non-LCO priority.
In order to preserve and further enhance the ascessment capabilities, formalized guidance is being developed-for use by.
Shift Management each time a.deficiencyLis identified. This guidance will-define the scope of review beyond LC0 and power generation requirements and-will present compensatory action options. Operator training will be used to: _
i introd)Ce and-emphasize the new guidance. This enhancement will-be completed by September. 1992.
Another program improvment being developed is a more effective method of_ _
- marking the_ control-room controls and indications-that.have deficiencies.- It-is expected that improvements will provide the operator with a quick-and-consistent' presentation of pertinent information about def_iciencies,:and therefore'.the improvements will enhance his' coping ability.
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Document Control Desk Page 4 Restatement of Unresolved Item 92-80-02, "Immediate Interim Corrective Actions to Self-Assessment Weatnesses" The recent station-wide self-assessment identified many opportunities for improved performance. The majority of areas are such that extended improvement programs are appropriate. However, the Team concluded several self-assessment weakness observations may require more immediate corrective measures to reduce the potential for future safety probicas. Specifically, the Team observed weaknesses in the administrative controls for maintenance troubleshooting development and work package quality, However, the licensee should assess all self-assessment observations for applicability.
Response
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A re-evaluation of the most recent NRC Systematic Assessment of Licensee Performance (SALP), the 1992 site wide self-assessment, the NRC IPAT findings, and the 1992 INP0 evaluation preliminary findings was conducted to determine if more inmediate correction actions need to be taken on identified issues.
A review of these inspections and self-assessment determined that twenty-eight items could potentially warrant more immediate corrective action. This information was transmitted to the responsible groups for resolution.
The twenty-eight items which have been re-evaluated for interim corrective action applicability fell primarily into the areas of resource management, adherence to established programs or programmatic controls and human performance.
These items were assessed against current performance to determine if any performance or safety problems or regulatory issues exist.
Performance and event history were evaluated to identify any recurring problems. The i
effectiveness of corrective actions taken was also evaluated to determine what actions neeo to be taken to continue improving performance.
Based on event history and performance trends, interim corrective actions were initiated to 4
ensure continuing improvement. These action; are being tracked at the morning Leadership Meeting.
Two specific.+1f-assessment -identified weaknesses that require inmediate corrective action were troubleshooting development and work package quality.
Cor.cerning troubleshooting development, the administrative procedure.was revised to address self-identified troubleshooting weaknesses.
Training has been initiated for the revised process. The training will include Maintenance
/ I&C craftsmen and technicians. Work package quality and consistency have been discussed with planning personnel at all hands meetings. The planning process guidance document has been completely re-written and will be placed in effect shortly after required reviews and training is completed. As PIMS continues to be implemented, the ready availability of accurate planning data and information should improve. The effectiveness of troubleshooting and work package quality corrective actions will continue to be monitored through self-assessment.
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Document Control Desk l-Page 5
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Restatement of Unresolved Item 92-80-03, " Assessment of Operational Impact l j
of-Installed Instrumentation found to be out of Calibration"-
I The Team noted that the licensee lacked procedures to ensure that' permanently.
j installed instrumentation found to be out of calibration is properly assessed for effect on related system operability.
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Response
A program to perform Out-Of-Tolerance (001) evaluations for installed plant-instruments used to determine Tech Spec operability is being developed.
l System Managers have been requested to evaluate'their system tp determine which instruments are used to determine Tech; Spec operability. A-database is 4
i being complied which will include the instrument, the-test used for determining Tech Spec operability, the Surveillance or PM in which it is j
calibrated, and the cal't:ation frequency, i
i Tne database will be usea by I&C to identify'to the System Manager those l
instruments found Out-0f-Tolerance during instrument. calibrations.
Evtination will be done by the System Manager. System Managers'will evaluate the 00T condition and determine the effect it had on the system, determine the t
compensatory actions required and provide recommendations to Shift Management.
j regarding operability, a
The program will be procedurally controlled to establish %e actions require'd upon discovery of an 00T condition of installed plant instrumentation used to j-determine Tech Spec operability. The program will become effective on July.1, _
1992. At that time the data base will be. complete and affected~ personnel.will be trained. The program and its effectiveness will be evaluated in December j
1993.
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Document Control Desk Page 6 Restatement of Unresolved Item 92-80-04, " Adequacy of Modification, Temporary Plant Alteration, and Temporary Procedure Change Document Controls" The Team noted isolated instances in which procedures and drawings affected by i
plant modifications had not been properly revised. The Team observed several instances in which controlled drawings affected by TPAs were not properly annotated. Additionally, the Team observed apparent discrepancy with controlled drawing classification such that improper usage may occur,
Response
The review of Modification 5258 resulted in two isolated discrepancies where the Alarm Response Cards (ARCS) had not been updated to reflect the correct type of instrumentation installed and operator training documents had not been revised to indicate the correct tank volumes associated with the setpoint data revised by the modification. The ARCS were updated as part of the mod process to indicate the new tank level, but the change from level switch (LS) to level indicating switch (LIS) was inadvertently missed during the review process.
Attention to detail is an area being addressed by site management.
Concerning operator training documents, the Mod Training letter that-identified the change in tank level was not distributed to the Training Department. This c<ersight was corrected September 4, 1990, when Administrative Procedure A-14
" Plant Mr Pfications" was revised to include the Superintendent of Training on the Mod Training letter distribution list. Administrative Guideline (AG)-91,
" Plant Modifications" approved May 6, 1992, contains the McJification Training Bulletin (Exhibit 6) with the Superintendent of T.aining on distribution.
A reportability evalaation/ event investigation was initiated to investigate the problem of TPA affected drawings not being properly annotated. An audit of all open TPA packages and TPA affected drawings in the control room and at satellite drawing locations was conductti to confirm the list of druings that needed to be annotated. Additionally, tne following corrective actions have been completed:
Administrative Guideline (Ab;-/7, " Implementation of TPAs" was revised to provide clear direction to include the sneet number of each drawing affected by each specific TPA on the TPA control-form.
Each iaentified sheet affected by the TPA is now stamped by the Document Control Group (DCG).
Two 100% audits were performed in the control room and at satellite locations which contained drawings affected by TPAs to ensure that all drawings were annotated correctly.
The database used by DCG to track TPAs and drawings that require annotation has been computerized.
The DCG now tags drawings affected by TPAs in their site master file.
The Operations Support Group checks the TPA packages monthly against the-DCG database of annotated drawings to ensure accuracy. Any discrepancies are noted and resolved by DCG.
4 Document Control Desk Fage
- A monthly audit of all drawings affected by TPAs is performed by the DCG in the Control Room and the Station Library-to ensure appropriate drawings are annotated.
If any discrepancies are identified a 100% audit of all satellite locations is performed.
The scope of drawings identified in AG-77, which require annotation if affected by a TPA, was reviewed by Nuclear Engineering and plant technical staff with regard to drawing classification. This review determined that the scope of drawings that are annotated for TPAs is appropriate.
Temporary changes (TCs) to procedures are captured by the Procedure Issue Counter (Pl;) with a complete set also maintained in the Station Library.
Designated TCs are captured in the Control Room.
Post-use TC review and approval and any required procedure revision are tracked on a database by the Procedure Control Group (PCG). All subsequent users of a procedure with TCs, with a duration other than "one time use", will obtain the procedure with any existing TCs from the-Plc.
A listing of all open TCs is issued by:PCG co that actions required such as review of TCs within 14 days and revision of procedures required within 60 days is provided.
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