ML20196B455
| ML20196B455 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/24/1998 |
| From: | Doering J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-277-98-08, 50-277-98-8, 50-278-98-08, 50-278-98-8, NUDOCS 9812010105 | |
| Download: ML20196B455 (3) | |
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John Doering, Jr.
i Vice President
+
Peach Bottom Atomic Power Station v
PECO NUCLEAR reco e" rov como v 1848 Lay Road A Unit of PECO Energy
{e%gP 7 9032 7
Fax 717 456 4243 j
E-mait jdoenng@peco-energycom November 24,1998 Docket Nos. 50-277 50-278 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 Response to Notice of Violations (Combined Inspection Report No. 50-277/98-06 & 50-278/98-08) i l
Gentlemen:
f In response to your letter dated October 28,1998, which transmitted the Notice of h
Violation (NOV), concerning the referenced inspection report, we submit the attached response. The subject report concerned a Residents' Integrated Safety Inspection that i
o was conducted August 11,1998 through September 21,1998.
I l
If you have any questions or desire additional information, do not hesitate to contact us.
2 tat m m x aug l
John Doering, Jr.
i Vice President, l
Peach Bottom Atomic Power Station A
Attachments
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MT/mi i
L cc:
N.J. Sproul, Public Service Electric & Gas R. R.' Janati, Commonwealth of Pennsylvania 4
H. J. Miller, US NRC, Administrator, Region l A. C. McMurtray, US NRC, Senior Resident Inspector R. I. McLean, State of Maryland A. F. Kirby 111, DelMarVa Power / Atlantic Electric
..at 9812010105 9811 4
PDR ADOCK O 7
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CCN 98-14089 L
RESPONSE TO NOTICE OF VIOLATION 98-08 i
i Restatement of Violation Peach Bottom Unit 3 Technical Specification 5.4.1 requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, November 1972. The procedures listed in Regulatory Guide 1.33, Appendix A, include reactor water cleanup system startup.
Contrary to the above, prior to September 12,1998, PECO failed to properly maintain system operation procedure (SO) 12.1.A-3, Revision 19, " Reactor Water Cleanup (RWCU) System Startup for Normal Operations or Reactor Vessel Level Control," resulting in two RWCU system events in August 1998. In the first instance, inadequate instructions for verifying the position of the 'B' non-regenerative heat exchanger vent valves led to a steam leak and unplanned entry into emergency operating procedures. In the second instance, inadequate instructions for verifying the 'B' demineralizer inlet valve position resulted in an engineered safety feature actuation (i.e., automatic system isolation) while placing the demineralizer in service.
This is a Severity Level IV violation (Supplement 1).
Reson(s) For The Violations The reason for the violation in the first instance was an inadequate shift turnover which resulted in wrong assumptions by the relieving shift. During the system isolation for maintenance, both trains were isolated and vented to support the maintenance activities. At the time of restoration, one shift partially restored the 'A' train but did not communicate that the 'B' train needed to be aligned. The relieving crew completed aligning the 'A' train and assumed the 'B' train did not have to be re-aligned since maintenance was performed on the 'A' train. Therefore, the vent valves on the 'B' non-regenerative heat exchanger were not closed as required.
The second instance was attributed to less than adequate control of equipment during a pos!
maintenance test (PMT). The maintenance PMT did not specify valve lineup requirements or direct equipment / valve manipulations to accomplish the stroke testing of the 'B' Filter /demineralizer (F/D) plenum vent valve. The technicians performing the PMT were aware of the need to manipulate valves to satisfy the logic to allow cycling the 'B' F/D plenum vent valve and did change valve positions to satisfy the logic. Following satisfactory completion of the PMT, the technicians initiated actions to return the valves to their correct position; however, they did not verify that the valves did go to their correct position. Since the 'B' demineralizer inlet isolation valve was not in its proper position during system restoration, the system was not re-pressurized as expected. During system restoration, sudden repressurization of the 'B' F/D resulted in a high flow isolation.
Corrective Steps That Have Been Taken And The Results Achieved in the first instance, the non-regenerative heat exchanger vent valves were closed to stop the leaks in the non-regenerative heat exchanger room. Operations checked other valves in the system to verify proper positions. The Reactor Water Cleanup System (RWCU) was returned to service on August 19, 1998.
In the second instance, the RWCU isolation was verified per procedure GP-88, 'PCIS isolation -
Groups 11 and 111', the isolation reset, and the RWCU system was returned to service on August 20, 1998.
C*rrective Steps That Will Be Taken To Avoid Further Violations The Vice President has appointed the Director - Outage Management to chair a multi-discipline team to review programs providing guidance for configuration management. This review is to identify and implement actions for improving the programs. The team has met several times establishing goals and a schedule for achieving various milestones in the project.
The Independent Safety Engineering Group (ISEG) recently performed a review of processes for control of equipment status during maintenance, testing and return to service. ISEG approached the review by developing a map of processes that cause equipment to be manipulated and involve a turnover from operations to a work group. ISEG then reviewed the procedures that govern the processes involved in the map. The review consisted of a task analysis that focused on barriers
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contained within the processes. These reviews were to identify gaps or potential weaknesses in the i
processes. Results of this initiative are being incorporated in a report currently in draft.
A review of the processes and current performance enhancement data indicate that there may be some programmatic weaknesses which have resulted in some configuration controlissues. These areas are being reviewed in more detail to determine what additional enhancements are required. The areas being reviewed are:
Performance Enhancement Program (PEP) data from PBAPS is being reviewed to determine if similar causes have resulted in a loss of system status control.
System status control process for on-line system outages.
Current procedural guidance for equipment / system status changes and guidance for declaring systems operable.
System status files in the control room to determine if they are an appropriate resource for 1
obtaining system status information.
Evaluate and implement corrective actions for improving the clearance and tagging process.
Operations recognizes that restoration / tag releases do not receive the same attention (planning and sequencing) as applying clearance tags.
j D-te When Full Compliance Will Be Achieved Full compliance was achieved on August 20,1998, when the Reactor Water Cleanup system was returned to service.
Prior Plant Status /Confiauration Control Corrective Actions Effectiveness The corrective actions initiated to address Violation 98-01 were to correct specific configuration control issues. The corrective actions were narrowly focused to correct specific human performance issues related to the event and therefore would not have been effecti a in preventing these recent events.