ML20199F511
| ML20199F511 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/27/1985 |
| From: | OPERATIONS ANALYSIS CORP. |
| To: | |
| Shared Package | |
| ML20199F501 | List: |
| References | |
| PECO-110, NUDOCS 8606240353 | |
| Download: ML20199F511 (7) | |
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.e .m APPRAISAL OF PEACH BOTTOM ATOMIC POWER STATION ;
PLANT AND SYSTEM OPERATING PROCEDURES Docket Nos. 50-277 and 50-278 PHILADELPHIA ELECTRIC COMPANY Report No. PEC0/110 Table of Contents Page I. INTRODUCTION 1 II. METHODOLOGY l A. Screening Phase 1 B. Evaluation Phase 1 C. Detailed Review Phase 2 III. RESULTS 3 -
A. Screening Phase 3 B. Evaluation Phase 3 C. Detailed Review Phase 4 IV. EVALUATION 5 V. RECOMMENDED ACTIONS 5 VI. ATTACHMENTS A. Requirements List - Five (5) Page Sample B. Eighty-Five (85) Procedure Presentation Items 8606240353 850827 PDR ADOCK 05000277 P PDR Operations Analysis Corporation L 1
m - y APPRAISAL OF PLANT AND SYSTEM OPERATING PROCEDURES FINAL REPORT I. INTRODUCTION This Final Report documents the completion of the Appraisal of Plant and System Operating Procedures of the Peach Bottom Atomic Power Station in accordance with the " Appraisal Plan for the Review of Peach Bottom Power Station's Plant and System Operating Procedures" as submitted by the Philadelphia Electric Company on August 15, 1984.
The Appraisal Plan was approved by the Nuclear Regulatory Commission on September 4, 1985. The Final Report was scheduled for submittal twelve (12) months after receipt of Nuclear Regulatory Commission approval of the Plan.
II. METHODOLOGY The Appraisal was performed in three (3) phases; Screening, Evaluation and Detailed Review. The methodology of each phase is summarized in the following subsections.
A. Screening Phase -
The work performed during the Screening Phase consisted of examining the Peach Bottom Technical Specifications and FSAR to identify items which established the actions, setpoints, limits, cautions, sequences, and parameters necessary for safe operation.
Each such item was labelled a Procedure Presentation Item (PPI).
The Screening Phase efforts yielded a total of one thousand four hundi ad - and seventy (1,470) Procedure Presentation Items. The Procedurc Presentation Items comprise the Requirements List (formerly called the Requirement Screening List) database.
B. Evaluation Phase The Evaluation Phase consisted of searching the Peach Bottom plant and system operating procedures to determine whether the Procedure Presentation Items were actually " included in" appropriate procedures. Each Procedure Presentation Item located in the plant and system operating procedures was entered on the Requirements List. If a Procedure Presentation Item was located in multiple station procedures, all of the procedures were entered into the database.
Each Procedure Presentation Item on the Requirements List was coded in accordance with the results of the evaluation into one of the following categories:
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II. METH060 LOGY (continued)
B. Evaluation Phase (continued) e " Included In" Procedures - when a Procedure Presentation Item was determined to be appropriately " Included In" a plant or system operating procedure the procedure identification and title were entered on the Requirements List to complete the Procedure Presentation Item information.
e "Not Included In" Procedures - when after a reasonable search, a Procedure PresentatTon Item could not be located in a plant or system operating procedure the item was classified to be "Not Included In" in plant or system operating procedures. In this situation the Procedure Presentation Item was labeled " omission" on the Requirements List.
e Procedure Deviation - when a Procedure Presentation Item was determined to be in conflict with, inconsistent with, or vary significantly from the values, terms or status of the corresponding information in a procedure, the information was promptly brought to the attention of the Philadelphia Electric Company Project Leader.
For information, a random sample of pages from the completed Requirements List is attached to this report.
C. Detailed Review Phase The Detailed Review Phase was the more thorough search of plant and system operating procedures for the purpose of determining if Procedure Presentation Items categorized as Omissions or Not '
Included in Procedures were in procedures other than those searched during the Evaluation Phase. During the Detailed Review Phase Procedure Presentation Items were reviewed for compliance with the Appraisal Plan criteria. The effort during the Detailed Review was concentrated on the one hundred sixty (1,405 PPI less the 1,245 "found" PPIS) Procedure Presentation Items that were not found
" included in" plant or system operating procedures, i.e. omissions.
During the Detailed Review Phase the 1984 Revision to the Updated FSAR was issued. The FSAR Revision involved eleven (11) Chapters and six (6) Appendicies of the Safety Analysis Report and was '
comprised of one hundred eighty-nine (189) pages and thirteen (13) diagrams.
The FSAR Revision material was reviewed to determine if the revisions would have any of the following effects on Procedure Presentation Items: -
e Add a new Procedure Presentation Item o Delete a Procedure Presentation Item, or e Alter an existing Procedure Presentation Item OperationsAnalysisCorporation
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III. RESULTS The results of the first phases (Screening and Evaluation) were furnished in the respective Interim Reports. For convenience a summary of those reports are included in the following subsections.
A. Screening Phase The Screening Phase required the services of seven (7) consultants with experience and knowledge in the technical disciplines of the Technical Specifications and the Safety Analysis Report. The Updated Final Safety Analysis Report was used during the Screening Process. The Screening was performed by having individuals with particular expertise review assigned sections of the Technical Specifications and associated chapters of the Safety Analysis Report. A secondary screening was performed by a computer assisted word search using the IBM STAIRS program.
As the result of these searches a total of one thousand four hundred and seventy (1,470) Procedure Presentation Items were '
identified during the Screening Phase. The Procedure Presentation Items were tabulated onto a Requirements List using the WORDSTAR program and IBM PC XT. The Screening Phase was completed on February 8, 1985.
B. Evaluation Phase Of the one thousand four hundred and seventy (1,470) Procedure Presentation Items identified during the Screening Phase, l sixty-five (65) were deleted from the database during the .
Evaluation Phase. The deleted Procedure Presentation Items did not i meet the Appraisal Plan criteria. The Evaluation Phase concluded with one thousand four hundred and five (1,405) Procedure Presentation Items.
1 During the Evaluation Phase eighty-nine (89%) percent, or one 1 thousand two hundred and forty-five (1,245), Procedure Presentation Items were confirmed to be correctly " included in" appropriate plant and system operating procedures.
During the course of the Evaluation Phase one deviation was found.
A deviation is an instance in which a Procedure Presentation Item 4 is incorrectly or improperly incorporated into a procedure. The deviation involved the torus water level lower limit. The Technical Specification value is 14.6 feet. In eight (8) procedure usages the correct value was used. In one (1) procedure (Procedure COL GP-2A, Revision 5, " Reactor Startup Order") an incorrect value of 14.5 feet was given. Procedure COL GP-2A was promptly changed, then reviewed. Approval of the change was recommended by the Peach Bottom Plant Operating Review Committee within one (1) hour of the Operations Analysis Corporation. notification of the deviation. The deviation was subsequently found in two (2) other procedures.
These procedures were COL GP-2A SINGLE LOOP, Revision 0, " Reactor Startup Order - Single Loop Operation" and ST 10.4, Revision 13,
" Relief Valve Manual Actuation". These procedures were immediately OperationsAnalysisCorporation
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, ,. III. RESULIS,(continued)
B. Evaluation Phase (continued) corrected in the same manner. Note: The Technical Specification lower limit on torus volume is expressed in terms of cubic feet rather than water level in feet. To ensure accuracy, a secondary calculation of torus volume versus torus water level was conducted by Operations Analysis Corporation. This analysis verified the correspondence of the torus low volume limit (in cubic feet) with the low level limit (in feet of water) as now correctly expressed in all of the Peach Bottom procedures.
C. Detailed Review Phase The Detailed Review Phase commenced with one hundred and sixty (160) Procedure Presentation Items that were "not included in" plant or system operating procedures.
During the Detailed Review Phase seventy-nine (79) Procedure Presentation Items were confirmed to be " included in" plant and system operating procedures, and an additional Procedure Presentation item was identified.
Review of the FSAR Revision material resulted in the identifying three (3) new Procedure Presentation Items. The review confirmed the accuracy of fourteen (14) Procedure Presentation Items and determined that the one (1) needed to be altered to be compatible with the FSAR Revision.
As the result of the foregoing actions the status of the appraisal at the end of the Detailed Review Phase is as follows:
e Number of Procedure Presentation Items 1,328
" Included In" Procedures e Number of Procedure Presentation Items 81 "Nat Included In" Procedures The results of additional research involving the eighty-one (81)
Procedure Presentation Items not included in plant or system operating procedures are described below:
e Eight (8) Procedure Presentation Items have been included in one (1) new procedure (ST-3.10) that has been developed and is currently in the station review and approval process.
e Sixty-five (65) Procedure Presentation Items have had appropriate plant or system operating procedures identified as suitable for including the sixty-five (65) Procedure Presentation Items. When the identified procedures are revised, reviewed and approved the sixty-five (65) Procedure Presentation Items can then be considered as " Included In" plant and system operating procedures.
_4 OperationsAnalysisCorporation
. III. RESULTS (continued)
E. Deteiled Review Phase (continued) e Eight (8) Procedure Presentation items have not had appropriate plant or system operating procedures identified as suitable for including the eight (8) Procedure Presentation Items.
IV. EVALUATION The number and technical range of the Procedure Presentation items greatly exceeded the preliminary estimates of the Appraisal Team. The completeness of the Requirements List was greatly enhanced by the capability of the Philadelphia Electric Company's STAIRS computer program to perform word searches of the Safety Analysis Report.
The accuracy of the Peach Bottom plant and operating procedures was very good. Only one (1) deviation out of one thousand three hundred twenty four (1,324)- Procedure Presentation items was determined. This deviation was resolved as previously described in the RESULTS Section.
The completeness of the Peach Bottom plant and operating procedures was evaluated as good. Of a total of one thousand four hundred and nine (1,409) Procedure Presentation items on the Requirements List only eight-one (81), or six percent (6%), have not been confirmed as being included in plant or system operating procedures. A tabulation of the eighty-one (81) Procedure Presentation Items is attached.
The eighty-one (81) Procedure Presentation Items are classified by source: Technical Specifications; seventy-four (74), Final Safety Analysis Report; seven (7).
The nature ,of the eighty-one (81) Procedure Presentation Items is grouped by category: Limiting Condition for Operation; sixty-one (61),
FSAR Operating Requirements (FSAR); six (6), Surveillance; twelve (12) and Administrative; two (2).
It is the normal and expected practice at the Peach Bottom Atomic Power Station to have shift personnel and station staff supervisors refer
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directly to the Technical Specifications for situations involving surveillance test requirements and provisions for limiting conditions for operations. This practice was substantiated by interviews of operations personnel by the Assessment Team and by the observations of the Assessment Team.' On the basis of this normal and expected practice review of the eighty-one (81) Procedure Presentation Items indicates that none of them constitute an unsafe' or potentially unsafe situation by the circumstance that they are not presently included in the plant or system operating procedures.
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V. REC 000 G DAT10NS The Peach Bottom plant and operating procedures program was evaluated to be a satisfactory information source for operating the Units within the requirements of the Technical Specifications and Final Safety Analysis Report. However, the following actions are recommended to further strengthen the capability to operate, test and maintain the Units within the Technical Specification requirements. ,
- 1. Ninety-four percent (94%) of the Technical Specification and Final Safety Analysis procedural type requirements are presently incorporated into plant and system operating procedures. It is recommended that the remaining eighty-one (81) Procedure Presentation Items be incorporated into appropriate plant or system operating procedures'.
i 1 2. If it is determined by the Peach Bottom Station Staff that j certain Procedure Presentation Items are unsuitable for incorporation into a useful, viable procedure that the basis for this determination be documented. It is recommended that such documentation be reviewed and acted upon by the Plant Operations Review Committee.
- 3. It is recommended that the results of recommendations number one (No.1) and two (No. 2) be entered in the Requirements List on the PROCEDURE line of the particular Procedure Presentation Item.
- 4. It is recommended that the Requirements List be used as a reference by persons assigned to initiate or review procedure revisions. Use of the Requirements List will alert the revision preparer or reviewer of Technical Specification or Final Safety Analysis Report requirements that apply to the particular procedure. Note, the Requirements List is not a controlled document. Before final action is taken involving values, setpoints and conditions for procedure revisions, such items should be confirmed in the Technical Specifications.
- 5. Conversely, it is recommended that the Requirements List be consulted when changes are implemented to the Technical Specifications. The Requirements List data will alert the inquirer of the plant and system operating procedures that may be affected by the Technical Specification Change. In such situations both the Requirements List and the affected procedures should be revised.
- 6. It is recommended that the Requirements List be consulted when revisions to the Final Safety Analysis Report are issued. The Requirements List data will alert the inquirer of the plant and t
system operating procedures that may be affected by the FSAR 1 revision.
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