ML20134G313
| ML20134G313 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/29/1997 |
| From: | Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 9702100362 | |
| Download: ML20134G313 (3) | |
See also: IR 05000277/1996006
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January 29, 1997
Mr. D. M. Smith, President
PECO Nuclear
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Nuclear Group Headquarters
Correspondence Control Desk
P. O. Box 195
Wayne, Pennsylvania 19087-0195
SUBJECT: COMBINED INSPECTION REPORT NOS. 50-277/96-06; 50-278/96-06
Dear Mr. Smith:
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This refers to your January 23,1997 correspondence, in response to our December 27,1996
letter.
Thank you forinforming us of the corrective and preventive actions documented in your letter.
These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
ORIGINAL SIGNED BY:
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Walter J. Pasciak, Chief
Projects Branch 4
Division of Reactor Projects
Docket Nos. 50-277; 50-278
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9702100362 970129
ADOCK 05000277
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Mr. D. Smith
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cc:
T. Mitchell, Vice President
G. Rainey, Senior Vice President, Nuclear Operations
G. Edwards, Plant Manager, Peach Bottom Atomic Power Station
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D. Fetters, Vice President, Nuclear Station Support
G. A. Hunger, Jr., Chairman, Nuclear Review Board and Director, Licensing
J.W. Durhem, Sr., Senior Vice President and General Counsel
T. Neissen, Director, Nuclear Engineering Division
G. Lengyel, Manager, Experience Assessment
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cc w/cy of licensee's ltr:
C. D. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.
B.W. Gorman, Manager-External Affairs, Public Service Electric & Gas Co.
P. MacFarland Goelz, Manager, Joint Generation, Atlantic Electric
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R. McLean, Power Plant Siting, Nuclear Evaluations
J. H. Walter, Chief Engineer, Public Service of Maryland
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R. Ochs, Maryland Safe Energy Coalition
J. Vannoy, Acting Secretary of Harford County Council
L. Jacobson, Peach Bottom Alliance
TMI - Alert (TMIA)
Nuclear Safety Information Center (NSIC)
NRC Resident inspector
Commonwealth of Pennsylvania
State of Maryland
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Mr. D. Smith
Distribution w/cy of licensee's ltr:
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Region I Docket Room (with concurrences)
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W. Dean, OEDO
J. Shea, NRR
J. Stolz, PDI-2, NRR
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Inspection Program Branch, NRR (IPAS)
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PUBLIC
D. Screnci, PAO
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DOCUMENT NAME:
a: reply.pb
To receive a copy of this document, inecate in the box:
"C" = Copy without ettechment/ enclosure
'E' = Copy with ettechment/ enclosure
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'N' = No copy
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0FFICE
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NAME
WPasciak f/
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DATE
1 09/97 6
0FFICIAL RECORD COPY
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Thomm2 N.Mitchen
Vce President
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Peach Bottom Atomsc Power Stnon
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PECO NUCLEAR
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A Unit of PECO Energy
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Fax 717 456 4243
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January 23,1997
Docket Nos. 50-277
50-278
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License Nos. DPR-44
DPR-56
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station Units 2 & 3
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Response to Notice of Violation (Combined Inspection Report No.
50-277/96-06 & 50-278/96-06)
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Gentlemen:
In response to your letter dated December 27,1996, which transmitted the Notice
of Violation concerning the referenced inspection report, we submit the attached
response. The subject report concemed a Routine Resident Integrated Safety
inspection that was conducted July 7,1996 through September 7,1996. A Pre-
decisional Enforcement Conference concerning these issues was conducted
December 6,1996.
If you have any questions or desire additional information, do not hesitate to
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contact us.
c[(/h
Thomas N. Mitchell
Vice President,
Peach Bottom Atomic Power Station
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Attachments
cc:
W. T. Henrick, Public Service Electric & Gas
R. R. Janati, Commonwealth of Pennsylvania
H. J. Miller, US NRC, Administrator, Region I
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W. L. Schmidt, US NRC, Senior Resident inspector
H. C. Schwemm, VP - Atlantic Electric
R. l. McLean, State of Maryland
A. F. Kirby lil, DelMarVa Power
CCN #97-14005
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RESPONSE TO NOTICE OF VIOLATION
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Restatement of Violation
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10 CFR Part 50, Appendix B, Criterion Ill, Design Control, requires in part, design
control measures shall provide for verifying or checking the adequacy of design
changes. Appropriate measures include design reviews, calculational methods or
a suitable test program. ANSI N45.2.11, to which you are committed, requires in
Section 6,2 that where changes to previously verified designs have been made,
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design verification shall be required for the changes, including the evaluation of the
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effects of those changes on the overall design.
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Contrary to the above, between June 1995 and July 1996, evaluation of the effects
of design changes on the overall design were not made to verify the adequacy of
Modification P-0231. Prior to June 1996, PECO did not fully understand how the
modification affected other important safety systems. As a result, the adequacy of
the design change was not understood for all the aspects of providing the
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cmergency diesel generators with an automatic transfer of generator governor and
voltage regulator from the droop to the isochronous mode of operation.
Specifically, PECO failed to evaluate the effect of the modification on RHR pump
start time and the effect of changed RHR pump start time on the overall facility
design.
This violation represents a Severity Level IV problem (Supplement 1).
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Reason for the Violation
On June 6,1996, personnel working on the Peach Bottom Simulator discovered
a condition associated with the anti-pumping circuitry of the emergency diesel
generator (EDG) output breakers that was recognized to warrant further
investigation.
This investigation resulted in an in-depth study being performed by licensing and
engineering. This stuay included detailed design reviews of numerous scenarios
associated with an EDG in test mode. These reviews revealed that the identified
condition at the simulator would occur at the plant. Until this design review was
performed in June 1996, PECO did not fully understand how the EDG
modification (P-0231) affected other important safety systems. Specifically, as
stated in the NRC notice of violation dated December 27,1996, PECO failed to
evaluate the effect of the modification on RHR pump start time, and the effect of
changed RHR pump start time on the overall facility design". As stated at the
enforcement conference, PECO has determined that the modification
accomplished its design purpose to protect the EDG and did not cause an
adverse impact on the RHR start time. However, the in-depth study and
scenario review did reveal that PECO failed to identify the RHR pump start time
delay issue as part of the modification review process. Additionally, the
modification evaluation was less-than-adequate in that it did not identify other
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design issues associated with the modification as described in Combined
Inspection Report No. 50-277/96-06 and 50-278/96-06.
A review of the modification performed in July 1996, included the MOD Safety
Evaluation (SE) and the Design input Document (DID) for the EDG modification
(P-0231). The review of the SE and DID revealed that the changes to the
mechanical design features of the EDG were thoroughly discussed. In contrast,
the changes to the electrical design were not fully discussed. For example, the
DID for this MOD compares the pre-modification method of switching from droop
mode to isochronous mode under emergency conditions to the post-modification
response. However, this review revealed no documented evidence of an
evaluation of the effects of the modification on ECCS pump start sequences.
The modification reviews during design, included mechanical, structural,
instrumentation and controls and electrical. However, a thorough design
verification of the electrical design was not performed and documented;
specifically the change analysis performed was less-than-adequate. This
resulted in PECO not fully understanding the EDG MOD P-0231 design and its
impact on other systems.
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Corrective Steps That Have Been Taken and the Results Achieved
Upon discovery, appropriate plant procedures were revised and information
provided to the operating teams pertaining to an emergency diesel generator in the
test mode. Corrective actions and results achieved are as follows:
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EDG operating procedures, i.e. surveillance procedures, routine test
procedures and system operating procedures were revised to reflect
information learned during the in-depth study.
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Two communications were completed (June 6,1996 and June 18,1996)
to inform the shift operating teams of the condition observed at the simulator,
Operations Teams refreshed their understanding on the manual actions
required to reset breaker lock-out during a briefing held with each shift team.
Additionally, this issue was incorporated in the simulator lesson plan and
presented to the licensed operating staff in continuing training.
An in-depth study of the EDG design was performed. This study and verification
of the design entitled " PBAPS EDG Licensing Basis" was completed on July 16,
1996, and confirmed that the existing design meets all design commitments.
A review was performed to understand the conditions observed on the simulator
in relation to the installed circuit modification. Corrective actions and results
achieved are as follows:
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A Non-Conformance Report (NCR) evaluated the acceptability of the
identified conditions associated with an EDG in test. This NCR was approved
on September 12,1996, resulting in clarifying the description of the MOD P-
0231 in the UFSAR.
An Engineering Change Request (ECR) was generated to document a design
analysis of the PBAPS Emergency Diesel Generator / 4KV breaker interface
issues. Numerous scenarios (different combinations and time sequences of
LOCA, LOOP) were analyzed and documented by an expert team. This ECR
was approved on September 18,1996 and provides for an understanding of
the relationship of these scenarios to the design basis.
A revision to " Design Control and Processing of Engineering Change
Requests (ECRs)", (MOD-C-9) has been completed and issued November
25,1996, to include the need to document the impact of the ECR disposition
on existing plant Systems, Structures, and Components (SSC) with the
regard to operational parameters including complex component sequencing
(e. g. relay contacts).
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Corrective Steos That Will Be Taken to Avoid Further Violations
PECO will proceduralize the need to perform and document a thorough change
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analysis in the course of a design verification for safety-related modifications
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invo!ving electrical logic design changes. Procedures will be revised and issued
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by March 31,1997.
PECO will provide training to all Design Engineers on expectations for design
verification for safety-related modifications involving electrical logic design
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changes. This training will be completed by April 30,1997.
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PECO will provide appropriate procedural guidance to include expectations for
expert panel reviews for safety-related modifications involving electrical logic
design changes and the necessity to continue performance of these reviews.
These reviews will be monitored periodically to determine effectiveness of these
corrective actions. This will be implemented by April 30,1997.
Date When Full Compliance Was Achieved
Full compliance was met on July 16,1996 when an evaluation of the effects of the
design change on the overall design was performed and the design of the
modification was verified in the "PBAPS EDG Licensing Basis."
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