ML20105B018
| ML20105B018 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/11/1992 |
| From: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CCN-92-14108, NUDOCS 9209180114 | |
| Download: ML20105B018 (4) | |
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f '?Cl! '92-143 nn Pilli.ADEl#111A ELECTRIC COMI%NY PIACll DOTIUM ATUMIC POW 111 $1ATION It. D I,Ika 208 Delta, lYnmylvania 17314 ein aurium tne rou e a or a u n t 'u e
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' D. h. Miller, Jr.
Vt:e Pretident September 11, 1992 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 i
SUBJECT:
Peach Bottom Atomic Power Station - Units 2 and 3 Response to Notice of Violation 92-13-02 (Unit 3)
(Combined Inspection Report Hos. 50-277/92-13; 50-278/92-13 l
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Dear Sir:
In response to your letter dated August 6, 1992, which transmitted the i40tice of Violation in the referenced inspection report, we submit the attached response.
The subject inspection concerns a routine residents' safety inspection that was conducted from June 9 through July 27, 1992.
If ycu have any questions or require additional information, please do not hesitate to contact us.
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R.-A. Burricelli,'Public Ser & c Electric & Gas T. M. Gerusky, Commonwealth of Pennsylvania J. J. Lyash, USNRC Senior Resident Insoector
- 1. T. Martin, Administrator, Region 1 USNRC H. C Schwemm, Atlantic Electric R. 1. McLean, State of Maryland C. D. Schaefer, Delmarva Power l'70037 g(,
8 9209180114 920911 PDR ADOCK--05000277 O
O. S. Nuclear Regulatory Commission e'
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bec: 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 R. N. Charles SIA-1, Chesterbrook Commitment CoJrdinator 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 Off ice A. D. Dycus A3-IS, Peach Bottom A. A. fulvio A4-4N, Peach Gottom D. P. LcQuia PS2-9 Peach Bottom C. J. McDermott 513-1. Main Office D. B. Hiller, 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 G. R. Raincy SIA-ll, Chesterbrook J. 1. Robb SiA-13, Chesterbrook D. M. Smith 52C-7, Chesterbrook
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C U. $. Nuclear Regulatory Commission P, age 3 RESPONSE 10 NOTICL Of VIOLATION 92-13-02 Restatemerit of Violation 1
Technical Specification 6.8.1 requires that written procedures be established and implemented that meet the requirements of Sectior. 5.3 of ANSI N18.7-1972.
ANSI N18.7-1972 Section 5.3, requires that nuclear plants be operated in accordance with written procedures that provide an approved preplanned method of conducting operations.
PECo Operations Manual Section 9. Yrocedures and Operator Aids," directs operators to perform actions and carry out responsibilities in accordance with the approved Operating Procedure applicable'to the tasks.
Contrary to the above, on July 27, 1992, control room operators conducted activities without the use of written procedures establishing an approved method of conducting the operation.
Specifically, operators aligned the Unit 2 reactor water clean-up (RWCU) system in a configuration not in accordance with'that written and approved in System Operating Procedure 50 12.1.A-2,
" Reactor Water Cleanup System Startup for Normal Operations or Reactor Vessel level Control," Revision 7.
The system was sligned with three pumps in service and the demineralizer bypass valve partially open, although not provided for in S0 12.1.A-2.
Operation in this alignment caused an engineered safeguards features isolation due to high RWCU flow.
This is a Severity Level IV violation (Supplement 1).
-Reason for the Violation Operating Procedure 50 12.1.A.2, " Reactor Water Cleanup System Startup for Normal Operations on Reactor Vessel Level Control." provides direction for the startup and operation of the RWCU system. On July 27, 1992, three RWCU pumps were placed into service and the RWCU demineralizer byass valve was throttled open in an effort to reduce the reector pressure vessel dome-bottom head drain differential temperature to allow restart of the 2B recirculation pump. The system alignment for this activity and the simultaneous operation of three RWCU pumps was not an approved method of operation described in the procedure.
This activity resulted in the actuation of the primary containment isolation system (PCIS)_as a result of RWCU high flow.
Corrective Steps That Have Been Taken and Results Achieved The Shift Operations Manager issued a letter to the Shift Managers and Shift Supervisors that discussed managements' expectations concerning procedure usage. This letter contained a dit ussian of the importance for proper procedural auherence, and the_need to submit procedure requests for activities not contained in a procedure and for procedure improvements. Applicable
. governing documents that require procedure usage were also included with this o
letter.
Additionally, Operations Management met with each operating shift to l.
emphasize the need to perform activities and evaluations by procedure.
Section 9'of^the Operations Manual was revised and approved on August-27, 1992, to provide direction for Operations personnel with respect to actions to be taken-in the absence of.a procedure.
U. S. Nuclear Regulatory Commission P, age 4 Corrective Actions That Will Be Taken to Avoid f uture Violations-t Licensed and non-licensed Operations personnel have been surveyed to help identify if any additional evolutions or actions are performed without written
-procedures. The evolutions identified 63 a result of this survey will be evaluated and necessary procedures will be written. These actions will be completed by December 31, 1992.
Date When full Compliance Was Achieved full compliance was' achieved July 27, 1992, after the RWCU high flow isolation was reset and the RWCU system was returned to a pre established mode of operation described in procedure SO 12.1.A.2.
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