ML20126B837
| ML20126B837 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/14/1992 |
| From: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CCN-92-14135, NUDOCS 9212220231 | |
| Download: ML20126B837 (5) | |
Text
_ _
'ccA 9bl4135 PillLADELPIIIA ELECTRIC COMPANY PEACH !)DT'iOM AIUMIC POWER STATION R. D.1, ikix 208 n.
Delu, Pennsylvania 17314 etAcn normu--nas rowin or excturna pl7) 4$6-7014 l D. B. Miller. Jr.
Vice President December 14, 1992 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
- Peach Bottom Atomic Power Station - Units 2 and 3 Response to Notice of Violation 92-27-01 and NRC Administered _ Exam Weakness (Combined Inspection Report Nos. 50 277/92-27; 50-278/92-27
'g and 50-277/92-18; 50-278/92-18)
Dear Sir,
in response to the referenced inspection report dated October 16,1992, which requested a response to a weakness identified during NRC administered initial examinations and the referenced inspection report dated November 16,1992, which transmitted the Notice of Violation, we submit the attached response. The response for these inspections has been combined di's to the related nature of concern. The subject inspections concern NRC administered examinations conducted August 28 through September 3,1992, and'a routine _ residents' safety inspection that was conducted October 6 through October 31,1992.
If you have any questions or require any additional information, please do not-hesitate to contact us.
Sincerely, h
N I
/
Cc' T. T.~ Martin, US NRC, Regicq l
'J. J. Lyash, US NRC Senior Resident inspector
- 210053 9212220231 921214 U{ [
6 PDR ADOCK c500o277-G PDR l
V
U. S. Nuclear Regulatory Commission Page 2 cc:
R. A. Burricelli, Public Service Electric & Gas T. M. Gerusky, Commonwealth of Pennsylvania R. I. McLean, State of Maryland H. C. Schwemm, Atlantic Electric C. D. Schaefer, DelMarVa Power bec:
J. W. Austin A4-4N, Peach Bottom J. A. Basilio 52A 5, _Chesterbrook G.J. Beck 52A 5, Chestt arook J. A. Bernstein 51 A-13, Chesterbrook R. N. Charles 51 A-1, Chesterbrook Committment Coordinator 52A 5, Chesterbrook Correspondence Control Program 618-5, Chesterbrook J. B. Cotton 53A-1, Chesterbrook G. V. Cranston 638-5, Chesterbrook E. J. Cullen S23-1, Main Office A. D. DyCJs A3-1S, Peach Bottom A. A. Fulvio A4-4N, Peach Bottom C. J. McDermott S13-1, Main Office D. B. Miller, Jr.
SMO-1, Peach Bottom PB Nuclear Records Doctype 231 K. P. Powers A4-1S, Peach Bottom J. M. Pratt B-2-S, Peach Bottom G. R. Rainey 51 A-11, Chesterbrook J.T.Robb 51 A-13, Chesterbrook D. M. Smith 52C-7, Chesterbrook -
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RESPONSE TO NOTICE OF VIOLATION 92-27-01 l
)
Restatement of Violation Technical Specification (TS) 6.8.1 states that written procedures shall be established, implemented and maintained that meet the requirements of Sections 5.1 and 5.3 of ANSI N18.7-1972. Section 5.3.4.2 states, in part, that shutdown procedures shall be provided to guide operators following reactor trips, and shall include instructions for establishing or maintaining hot standby or cold shutdown conditions. The major steps involved in shutting down the plant shall be specified, including detailed instructions for the 4
performance of such actions as monitoring and controlling cool-down rates. Procedures ST-0-028 500-2, Revision 0, and ST-0-028-500-3, Revision 0, " Recording Reactor Vessel Temperatures," establish the requirements for monitoring and recording of reactor vessel temperature and pressure during heat-up and cool-down, and for verification of compliance with TS limitations.
Contrary to the above, the licensee did not adequately implement Procedure ST-0-028-500-2 during a Unit 2 evolution on September 13,1992, and Procedure ST-0-028 500-3 during a Unit 3 evolution on October 16,1992. Specifically:
A.
Procedure ST-0-02B-500 2, Section 6.2, establishes the requirements for data recording with the reactor vessel shell temperature below 220 degrees F and the reactor vessel not vented. Step 6.2.2 requires the performer to record reactor vessel temperature and pressure at least every 15 minutes. Con +rary to the above, from September 13,1992, at 3:30 a.m. until September 14,1992, at 10:00 a.m.,
the Unit 2 reactor vessel shell temperature was below 220 degrees, the reactor vessel was not vented and reactor pressure was not recorded.
B.
Precedures ST-0-02B 500-3, Step 6.2.3, requires that if the reactor is shutdown, then verify reactor pressure is below the limits specified by TS Figure 3.6.2 and initial the appropriate block provided on data sheet 1. Contrary to the above, from 2:00 a.m. until 11:00 a.m. on October 16,1992, the verification required by Step 6.2.3 was not adequately completed in that Unit 3 reactor pressure was above the limits specified by TS Figure 3.6.2.
The limit violation was not identified nor documented on data sheet 1 by the Reactor Operator. This contributed to a significant delay in recognition that the pressure limit had been exceeded.
1 C.
Procedure ST-0-028-500-3, Step 6.2.5, requires verification of shift management review of each individual data sheet as each is completed. Contrary to the above, on October 16,1992, data sheets were not reviewed by shift management as each was completed. For example, five data sheets covering the period of 4:45 a.m.
through 5:00 p.m. on September 16,1992, were not reviewed by shift management j
until after 6:40 p.m. on that date. This contributed to delay in recognizing the l
pressure limit violation described in item B above.
This is Severity Level IV Violation (Supplement 1).
t
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Reason for the Violation Insu#icient guidance had been provided for the development and use of data sheets as part of a procedure. As a result, the implementation of procedure ST-O-028-500-2(3),
Revision 0, " Recording Reactor Vessel Temperature" was less than adequate. Although the text in ST-O-028-500-2(3) was technically correct, the data sheet was incorrectly formatted for recording pressure in conjunction with temperature and did not include sufficient prompts to ensure accurate data analysis and timely review.
On September 13,1992, at 3:30 a.m., when reactor vessel conditions of shell temperature less than 220 degrees and the vessel not vented were established, the operator initiated temperature data collection on Unit 2 every 15 minutes as required. However, because the data sheet was constructed such that the blocks for pressure data were located under the header " REACTOR HEATUP/COOLDOWN" and not under the header "NO FORCED CIRC /LESS THAN 220 DEGREES F & NOT VENTED /GP 12.1", the operator failed to record pressures. The operator did not read step 6.2.2 in the body of the procedure that states " RECORD Reactor Vessel temperature and pressure from the following instruments at least every 15 minutes on Data Sheet 1:".
Subsequent cperators over several shifts did not recognize the requirement to record pressures for the same reason, and from 3:30 a.m. on September 13,1992, until 9:30 a.m. on September 14,1992, Unit 2 pressure readings were not recorded.
On October 16,1992, following a Unit 3 MSIV closure reactor scram with reactor vessel i
cooldown in progress, the reactor operator was recording pressure and temperature data on the data sheet as required, but did not properly analyze the data on Tech Spec Figure 3.6.2. Although a space to indicate the results of this analysis was provided, the data sheet did not specify the analysis requirements or prompt the operator to reference the Tech Spec figure. Additionally, a blank for Shift Management review was provided, however, there was no guidance on the data sheet to perform this review as each data sheet is completed.
i The requirements to record temperature and pressure and analyze the data were correctly specified in the procedure text, but were not adequately presented on the data sheet. The operators relied on the data sheet to provide guidance and prompts for correct data collection, analysis and review, and did not refer to the body of the procedure. The development process for this procedure did not adequately consider j
human factoring between the procedure body and data sheet.
The reason for this violation is primarily attributed to human factor deficiencies in a procedure with associated data sheets, however, the investigation also revealed weakness in operator procedure usage. An additional part of this issue is the observed weakness in procedure reference and use by SRO upgrade candidates during a recent i
NRC administered exam. Because procedure use concerns have been identified in both inspection reports, this response provides a perspective of this issue as well as corrective actions taken or planned.
l Thd weaknesses observed during the NRC administered exams can be attributed to insufficient emphasis of procedure reference and usage by SRO upgrade candidates during the examination process. Actions by SRO upgrne 7andidates was based on their experience instead of appropriate procedure referena. This was a result of past experience when procedure quality was low or procedural guidance for activities was insufficient. The performance exhibited by the instant SRO candidates, however, reflected the appropriate standards for procedure usage that was expected and taught during licensed operator training. Increased emphasis and reinforcement is required during plant operations and requal training to augment operator procedure reference and usage to ensure expectations of standards are met.
Corrective Actions that have been Taken and the Results Achieved for the Violation Procedures ST-0-02B-500-2(3) data sheets have been temporarily changed and will be revised to improve human factors for collecting temperature and pressure readings and verification that the data has been recorded. The procedure was previously revised to reference the applicable Tech Spec figure 3.6.2 on the data sheet.
The events concerning use of the data sheet were discussed and evaluated with the appropriate personnel. Additionally, the subject of procedure reference and usage was discussed at the Shift Manager meeting on December 11,1992.
Corrective Actions Taken in Resoonse to Insoection Recort 92-18 and Generic Procedural Usage Concerns Operations management reviewed the examination results and observations with the SRO upgrades who exhibited weakness in procedural reference and usage. This discussion j
included communication of expectations and a review of the possible causes for exhibited weaknesses.
The benefits of rigorous reference to procedures and potential l
consequences of complacency were also discussed with licensed operators.
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An open discussion was held with Operations Management and licensed operators to communicate expectations and to examine issues in the area of procedural usage.
Training has been improved for the present Licensed Operator Training Class by the l
assignment of an experienced shift supervisor as a mentor to the class. Part of his duties l
will be to ensure procedural expectations are met by the entire class.
The task analysis used by Operations to determine training needs has also been reviewed for tasks which did not have a procedural reference. Selected tasks for which procedural guidance will be developed have been prioritized.
l Operators were requested to submit procedure requests for evolutions that should be l
proceduralized, but were not. This resulted in over sixty procedure requests which have been evaluated and prioritized for completion.
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9 The' ST/SO Procedure Rewrite Project has recently been completed to upgrade existing procedures to higher standards.
Corrective Steos that will be taken to avoid Further Violations An extensive evaluation of procedure ST-0-028 500-2(3) development and usage problems will be completed by February 15,1993. This evaluation will address generic concerns associated with procedures that contain data sheets. The Procedure Writers Guide will be appropr:ats!y upgraded by March,1993, to properly reflect procedural requirements on data sheets, to improve human factors of procedures and to better incorporate a method to identify how prece6res are to be implemented.
I A revision to procedure ST-0-028-500-2(3) to omrporate the temporary change now in effect is scheduled for January 8,1993. This revisiod will also include interim corrective actions identified by the above evaluation. It is anticpted that the final evaluation findings will result in a subsequent revision.
Training will be conducted to increase operator understanding of the applicatt.1 of pressure / temperature limits. Procedures and training will be evaluated in the area of preventing or mitigating reactor coolant stratification to identify needed improvements.
A letter from the Plant Manager to Operations personnel to review this event and to reinforce Operations Management expectations concerning procedure performance will be issued in December,1992.
Shift supervision will further reinforce procedural compliance expectations of operators by January,1993, and on a continuing basis by discussing operating or training topics. This i
l discudcn will focus on expectations of procedural adherence during training and while operaang plant equipment, the importance and requirements of procedure adherence, and examples of experience assessment reports which exemplify the consequences of not following procedures and stated expectations.
Existing standards and expectations for procedure adherence will be emphasized to l
licensed operator training instructors by December,1992. Through licensed operator l
requalification classes, operator compliance with procedure requirements and management expectations will be enhanced.
Date when full comoliance was achieved Full compliance was achieved on September 14,1992, when the Unit 2 reactor vessel was vented and pressure readings were no longer required and on October 16,1992, when Unit 3 pressure and temperature readings were within the acceptable limits of Tech Spec curve 3.6.2.
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