ML20199D107

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-277/97-05 & 50-278/97-05.Actions Will Be Examined During Future Insp

ML20199D107
Person / Time
Site:	Peach Bottom
Issue date:	11/06/1997
From:	Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
50-277-97-05, 50-277-97-5, 50-278-97-05, 50-278-97-5, NUDOCS 9711200259
Download: ML20199D107 (2)

See also: IR 05000277/1997005

Text

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November * 5, 1997

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Mr. D. M. Smith, President

PECO Nuclear

Nuclear Group Headquarters

Correspondence Control Desk '

P. O. Box 195

Wayne, Pennsylvania 19087 0195

SUBJECT: INSPECTION REPORT NOS. 50 277/97 05 AND 50 278/97 05

Dear Mr. Smith:

This letter refers to your October 13,1997, correspondence, in response to our

September 12,1997, letter, ,

Thank you for informing 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,

1

Clifford J. Ander(on, Chief

Project Branch No. 4

Division of Reactor Projects

Dacket Nos. 50 277:50-278

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9711200259 971106

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Mr. D. M. Smith 2

cc:

G. A. Hunger, Jr., Chairman, Nuclear Review Board and Director, Licensing

T. Mitchell, Vice President, Peach Bottom Atomic Power Station ,

G. Rainey, Senior Vice President, Nuclear Operations

J. B. Cotton, Vice President, Nuclear Station Support

T. Niessen, Director, Nuclear Quality Assurance

A. F. Kirby, Ill, External Operations Delmarva Power & Light Co.

G. Edwards, Plant Me ager, Peach Bottom Atomic Power Station

G. J. Lengyel, Mane ar, Experience Assessment

J. W. Durham, Sr ienior Vice President and General Counsel

T. M. Messick sger, Joint Generation, Atlantic Electric

W. T. Hennck, enager, External mffairs, Public Service Electric & Gas

R. McLean, Pow. Plant Siting, Nuclear Evaluations

J. Vannoy, Acting. 3ecretary of Harford County Council

R. Ochs, Maryland Safe Energy Coalitior

J. H. Walter, Chief Engineer, Public Service Commission of Maryland

Mr. & Mrs. Dennis Hiebert, Peach Bottom Alliance

Mr. & Mrs. Kip Adams

Commonwealth of Pennsylvania

State of Maryland

TMl- Alert (TMIA)

Distribution:

Region i Docket Room (with concurrences)

W. Axelson, DRA

P. Swetland, DRP

A. Linde, DRP

Nuclear Saf aty information Center (NSIC)

NRC Re=ident inspector -

i

PUBLIC

W. Dean, OEDO

i

L. M. Padovan, PM, NRR

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l J. Stolz, PDl 2, NRR

Inspection Program Branch, NRR (IPAS)

R. Correia, NRR

F. Talbot, NRR

DOCDESK

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DOCUMENT NAME: P:

to receNo a copy of this document. Indicate in the bes: 'C' = Copy without attachment!onclosure 't* = Copy wrth attachment / enclosure 'N' = No copy

OFFICE Rl/D,/ l Rl/DRP / l l

NAME WSchmidt P CAnderson /l'c '

DATE 11/06/97 'i>' 11/ cu/97 11/ /97 11/ /97 11/ /97

0FFICIAL RECORD COPY

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PEC'O NUCLEAR gogg P

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A Unit of PECO Energy

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Fax 717 456 4243

Docket Nos. 50-277

50-278

License Nos. DPR-44

DPR-56

October 13, 1997

U. S. Nuclear ReDulatory Commission

Attn.: Document Control Desk

Washington, DC 20555

Subject: Peach Bottom Atomic Power Station Units 2 & 3

Response to Notice of Violation (Combined Inspection Report No.

50-277/97-05 & 50-278/97-05)

t

Gentlemen:

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in response to your letter dated September 12,1997 which transmitted the Notice

- of Violation conceming the referenced inspection report, we submit the attached

response. The subject report concerned a Residents' Integrated Safety inspection

which was conducted June 8 through August 9,1997,

If you have any questions or desire additionalinformation, do not hesitate to

contact us.

Ik*k

Thomas N. Mitchell

Vice President,

Peach Bottom Atomic Power Station

Attachments

cc: W. T. Henrick, Public Service Electric & Gas

R. R. Janati, Commonwealth of Pennsylvania

H. J. Miller, US NRC, Administrator, Region i

R. S. Barkley, US NRC, Interim Senior Resident inspector

T. M. Messick, Atlantic Electric ,

R.1. McLean, State of Maryland ,

A. F. Kirby Ill, DelMarVa Power

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CCN 97-14060

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bec: OEAP Coordinator 62A-1, Chesterbrook  !

Correspondence Control Program 61B-3, Chesterbrook

NCB Secretary (11) 62A-1, Chesterbrook

D. M. Smith 63C-3, Chesterbrook

G. R. Rainey 63C-3, Chesterbrook

T. N. Mitchell SMB4-9, Peach Bottom- i

L J. B. Cotton 62C-3, Chesterbrook

T. J. Niessen 53A-1, Chesterbrook

E. J.' Cullen . S23-1, Main Office

+ E. W. Callan SMB4-6, Peach Bottom

G. A. Hunger 62A-1, Chesterbrook '

J. G. Hufnagel 62A-1, Chesterbrof k

C. J. McDermott S13-1, Main Office -

G. D. Edwards A41S, Peach Bottom

V. Cwietniewicz PB-TC, Peach Bottom

R.A.Kankus 61C 1, Chesterbrook

G. J. Lengyel A4-4S, Peach Bottom

R. K. Smith A4 5S, Peach Bottom

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RESPONSE TO NOTICE OF VIOLATION 97 05-02

Restatement of Violation

Technical specification 5.4.1 requires, in part, that written procedures be

established and maintained covering the bypass of safety functions.

Contrary to the above, PECO did not properly maintain written procedures for the

bypass of the main control room (MCR) ventilation system isolation when a

Division i MCR radiation monitor was inoperable. Specifically, Procedure GP-25 ,

Appendix 13, MCR Ventilation Isolation, Division 1, failed to provide complete

instructions for maintaining radiation monitor RIS-0760A in a tripped condition.

Consequently, on or about July 10,1997, a PECO technician removed the monitor

from a tripped condition, contrary to technical specifications.

This violation represents a Severity Level IV problem (Supplement 1).

Backaround Information

On July 8,1997, Maintenance Instrument and Control (l&C) technicians contacted

the instrument manufacturer of the "A" channel Main Control Room Emergency

Ventilation (MCREV) radiation monitor RIS-0760A concerning a problem where

the monitor was indicating higher than three other channels. This monitor samples

the main control room air it.itake for radiation and initiates a trip on a high radiation

signal. After discussion with the manufacturer, l&C personnel determined that the

pre-amplifier was the most probable cause of the monitor indicating high. Although

the readings were higher than the other instruments, the instrument was still within

the operating band. The higher readings actually put the monitor in a more

conservative direction with the instrument operating closer to the trip point. A

routine calibration check and quarterly functional test had also been recently

performed successfully.

Maintenance Planning created a work order to evaluate and replace the pre-

amplifier if necessary. Shift Management declared the MCREV sub-system

inoperable on July 9 at 5:30 p.m. to allow l&C to investigate and perform work

activities, Technical specifications 3.3.7.1 allowed six nours before the channel

would need to be placed in the trip condition. The pre-amplifier was replaced

within this time frame, but troubleshooting following the replacement revealed that

the higher than normalindication had not changed.

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At approximately 10:30 p.m., I&C technicians informed the control room of their

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results and that they could not continue due to working hour limitations. Since the

six hour tech spe; limit was running out, the Operations shift decided to enter GP.

25 Append * id - MCR Ventilation isolation, Division I and placed the "A" MCREV .

radawn monitor RIS-0760A in the trip condition by turning the key lock switch to

"OFF" locally at the monitor. Tags were placed on the redundant MCREV

channels as a precaution in the main control room, but were not placed on the

local monitor that was tripped. These actions were in compliance with the

procedure as it was written.

The on shift I&C technicians continued to summarize their troubleshooting

activities with the Operations shift who afterwards requested to talk with the l&C '

- subject matter expert (SME). At approxirnately 10:45 p.m., the I&C SME was

called to the control room. The shift discussed the activities with the l&C SME and

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questioned if any further troubleshooting could be performed. It was determined

that the instrument grounds were the on!y item that had not been previously

checked. The l&C SME communicated to the shift that he was going to continue

work and check the radiation monitoring instrument grounds to see if there could

be excessive noise affecting the instrument. Although the shift questioned the l&C

SME on how the grounds were to be checked, they were not aware that this

testing would involve taking the lochi radiation monitor out of the trip condition.

Following the control room briefing, the l&C SME went to the local panel for the "A"

MCREV radiation monitor RIS-0760A. The l&C SME placed the key-lock switch to

"ON" and initiated troubleshooting activities. During these activities various

grounds where checked within the monitor, but no appreciable differences in the

readings were noted. At approximately 12:45 a.m. on July 10,1997, the l&C SME

concluded troubleshooting activities. The I&C SME notified the control room that

he had completed work and that troubleshooting would resume on day-shift.

At 3:00 a.m., while resetting an unrelated alarm, a Plant Reactor Operator (PRO)

observed the MCREV radiation monitor alarm reset. The PRO immediately

recognized that the alarm should not have cleared and notified control room

supervision. An investigation was initiated and the l&C SME was called at his

home to determine why the MCREV radiation monitor had reset. At approximately

3:25 a.m. it was determined that the local key-switch for MCREV radiation monitor

RIS-0760A had been placed back in service for troubleshooting and was left in the

"ON" position. The key lock switch was then placed in the "OFF" position and the

GP-25, Appendix 13 trip was re-established. .

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Reason For the Violation

GP 25, Appendix 13, *MCR Ventilation Isolation, Division I" was not adequate to

ensure the radiation monitor would be maintained in the trip condition. The

procedure allowed the tripped unit to be either removed or placed in service by the

use of a local key-lock switch rather than a jumper or other mechanical device. As

a result, the key-lock switch was taken to the *OFF" position to implement the trip.

When the unit was returned to the "ON" position to perform troubleshooting, the

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trip was negated. The procedure did not provide a serviceable method to insert

the trip. Additionally, even though the procedure required redundant components

to be tagged in the control room as a precaution, the actual local component that

was administrative!y removed from service was not required to be tagged.

Therefore, there was no localir sication to indicate that the radiation monitor had

been placed in the tripped condition per procedure

Communications between Operations and Maintenance l&C was less than

adequate. Although Operations was aware that the l&C SME was performing

troubleshooting and work activities on the radiation monitor, they were not aware

that the instrument was required to be re energized to support this testing. Better

communication of the activities planned should have identified the procedural

inadequacy where troubleshooting could rat be performed with the radiation

monitor in the "OFF" position or in the tripped condition.

The l&C SME was so focused on troubleshooting the instrument grounds that he

did not realize at the time that by placing the local radiation monitor key-lock switch

to the "ON" position for troubleshooting that he was negating the trip implemented

per GP-25, Appendix 13.

Corrective Steos That Have Been Taken and the Results Achieved

At 03:25 a.m. on July 10,1997, the key-lock switch for Radiation Monitor RIS-

0760A was placed in the "OFF" position in accordance with GP-25, Appendix 13,

which re-established the trip for the MrT4EV Division 1 Radiation Monitoring. A

local equipment status tag was placed on MCREV radiation monitor RIS 0760A to

prever.t further manipulation of the switch. All work activities on the radiation

monitor were suspended. In addition, later that day, GP-20, Append.ix 13 was

temporarily changed to trip the channel using a jumper, which maintained power to

the radiation monitor in the trip mode to allow troubleshooting activities.

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A review of other GP 25 Appendices was conducted to ensure that no other similar 4

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conditions existed where channel trips could be removed by the single action of

positioning key lock switches.

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- A Performance Enhancement Program (PEP) was initiated on July 10 to -)

investigate this event. Results of that investigation have been used to develop

this response.

Review of this event determined that although the MCREV "A" channel was

administratively declared inoperable per GP-25, Appendix 13, the radiation monitor -

was functional and capable of monitoring the radiation levels and providing a trip

function to MCREV. The testing that l&C performed during the troubleshooting

evolution verified that the radiation monite a as able to respond to input signals i

and provide correct indications. Additionally, the instrument was tested by the ,

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equipment manufacturer and found to be within specifications. The vendor testing -

of the detector and pre-amplifier determined that the radiation monitor that had

been placed back into service for troubleshooting was in calibration and capable of i

performing its function in the event of a high radiation signal to the "A" radiation

monitor. As a result, the "A" channel of the MCREV Radiation Monitor was

functional and would have performed appropriately.

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Corrective Steos That Will Be Taken to Avoid Further Violations ,

A revision to GP-25 Appendix 13 and 14 (for channels B and D) will be

implemented to incorporate the temporary changes which have been initiated.

This revision is the next step in the progression of the temporary change process. 1

This change willincorporate the use of some type of mechanical device to provide

the capability to energize equipment for troubleshooting or testing without

removing equipment from a tripped condition. This revision will be completed by

November 21,1997.

Additional information concerning this event will be provided to appropriate

Operations and Maintenance l&C personnel by November 30,1997.

Date When Full Comoliance Was Achieved

Full compliance was achieved on July 10,1997, when a temporary change (TC)

was implemented on GP-25, Appendix 13 to trip the appropriate channel using a

jumper instead of the appropriate key-lock switch. This change enabled the '

equipment to remain energized for troubleshooting without affecting the trip.

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