ML20209J484
| ML20209J484 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/24/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8705040296 | |
| Download: ML20209J484 (11) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (215) 841 5001 April 24, 1987 sosum w.aatomowan Docket Nos. 50-277 50-278 Mr. William V. Johnston, Acting Director Division of Reactor Safety U.S. Nuclear Regulatory Commission Region I ATTN:
Document Control Desk Washington, D.C.
20555
SUBJECT:
Response to Inspection Report No. 50-277/86-25 for Peach Bottom Atomic Power Station
Dear Mr. Johnston:
Your letter dated March 11, 1987 transmitted Inspection Report No. 50-277/86-25 concerning the special operational safety inspection conducted on December 8-19, 1986 at Peach Bottom.
Appendix A of the letter identified certain activities which appeared to have not been conducted in full compliance with NRC requirements.
Appendix B of the letter identified one item which appeared to be a deviation from commitments in the Final Safety Analysis Report.
Attachments A and B to this letter provide restatements of these items followed by Philadelphia Electric Company's responses, respectively.
Your letter also identified four areas of weakness which we were requested to address in this inspection report response.
Attachment C to this letter addresses the areas of weakness.
An extension to April 24, 1987 i
for responding to this inspection report was discussed on April 16, 1987 between W. M. Alden (PECo) and Mr. K. G. Murphy (NRC, Region I) and was found acceptable.
If you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, 8705040296 870424 DR ADOCK 0500 7
%g/,
Attachments cc:
Addressee William T. Russell, Administrator, Region I, USNRC T.
P.
Johnson, NRC Resident Site Inspector f60j li j
Attachment A Page 1 of 3 Docket Nos. 50-277 50-278 RESTATEMENT OF VIOLATION As a result of the team inspection conducted on December 8-19, 1986, at Peach Bottom Atomic Power Station, Unit 2, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violation was identified:
A.
Technical Specifications 3.14.B.4, paragraph a.,
states, in part, that a continuous firewatch with back-up fire suppression equipment for an unprotected diesel generator room is required within one hour.
Station administrative procedure A-12.1, paragraph 2.1.3, requires that a dedicated Technical Specification firewatch must be posted within one hour after a Cardox System switch in a diesel generator room is placed in the " defeat" position.
Procedure A-12, paragraphs 7.2.3 and 7.2.4, specifies Technical Specification firewatch as a firewatch having "no job related duties other than firewatch duties."
Contrary to the above, an operator designated as the firewatch, performing diesel generator surveillance testing (ST 8.1) with the Cardox System disabled, was observed on two occasions to be outside the diesel roora.
On December 10, 1986, at approximately 1:00 a.m.,
the operator left the E-3 dicsel room to telephone the Control Room and on December 24, 1986, at approximately 12:45 a.m.,
the operator was found outside the E-1 diesel room.
The failure to provide a continuous dedicated firewatch constitutes a violation.
This is a Severity Level IV Violation (Supplement I).
RESPONSE TO VIOLATION Admission or Denial of Alleged Violation:
Philadelphia Electric Company (PECo) acknowledges that the violations did occur on December 10 and December 24, 1986 as stated in the Notice of Violation.
These events were reported to the NRC in Licensee Event Report 2-86-25 dated January 24, 1987.
Reason for Violation:
This violation occurred because the plant operator failed to adhere to procedures.
As identified in the Notice of Violation, the requirements of Administrative Procedures A-12 and A-12.1 were not satisfied.
In addition, a prerequisite of System Operating Procedure S.8.4.A,
" Manual Start of Diesels", states:
Attcchm*nt A Pega 2 of 3 Docket Nos. 50-277 50-278 "When leaving any diesel room, always rearm the injection Cardox system by operating the disable switch
" and "Cardox shall not be disarmed for more than 15 minutes without shift supervision approval (will require a Technical Specification fire watch)."
The plant operator was performing an activity covered by this procedure and did not follow this direction to rearm the Cardox system upon leaving the room.
Extent or Significance of Violation:
The automatic injection mode of the diesel Cardox system was defeated; however, the manual actuation mode remained operable.
Additionally, the diesel room Cardox injection system alarm (red revolving beacon and horns), which actuates on a valid automatic Cardox injection signal, remained operable.
Disarming the Cardox system while performing the weekly Diesel Generator Full Load Test is not required, but is done by a few plant operators out of concern for personnel safety.
This precaution is considered acceptable as long as it is done in accordance with the fire protection procedural requirements specified in A-12, A-12.1 and S.8.4.A.
The operator had job related duties other than fire watch duties and, therefore, did not constitute a fire watch as defined in A-12.
However, the operator left tne diesel rooms for short periods of time and remained nearby; thus, he would have been able to respond to a Cardox injection system room alarm.
Upon actuation of the room alarm, it's reasonable to conclude that the operator would have rearmed the automatic Cardox injection system and evacuated the room.
Therefore, the safety significance of this event is considered to be minimal.
Corrective Actions Taken to Prevent Recurrence of Violation and Results Achieved:
The plant operator was counseled about his failure to adhere to procedures.
The requirements associated with disarming the automatic mode of the Cardox injection system were discussed with him.
This event has also been reviewed with all operations personnel.
The importance of maintaining automatic Cardox protection or a continuous fire watch has been re-emphasized.
For additional assurance that this event does not recur, the Diesel Generator Full Load Test ST 8.1 was revised to include a caution statement regarding the requirements associated with defeating the automatic injection mode of the Cardox system.
This procedure revision was reviewed with operations personnel.
Atti. chm:nt.A' Paga 3 of-3 Docket Nos. 50-277 50-278 Date When Full Compliance Was Achieved:
PECo believes full compliance was achieved on March 30, 1987 after reviewing the event with operations personnel and submitting LER 2-86-25.
4 4
1 5
4 4
Attachm:nt B Pcge 1 of 2 Docket Nos. 50-277 50-278 RESTATEMENT OF DEVIATION:
As a result of an inspection conducted on December 8-19, 1986, the following deviation from the licensee Final Safety Analysis Report (FSAR) commitment was identified.
FSAR Section 8.7.4.2 states, " Low battery voltage is annunciated in the main control room."
FSAR Section 8.7.5 states, "The system is tested and inspected as required during the life of the plant to demonstrate its capability to provide power to the safety-related loads".
Contrary to the above, as of December 17, 1986, the low voltage battery annunciation generated from the DC undervoltage relays, which is required to confirm capability of the DC Buses to provide power to the safety related loads, was not tested or inspected.
l This is a deviation applicable to Units 2 and 3.
RESPONSE TO DEVIATION:
Admission or Denial of Alleged Deviation:
PECo acknowledges the importance of the DC low bus voltage alarm during a blackout scenario to warn the operators of battery depletion and that this Notice of Deviation is valid.
Reason for Deviation:
The importance of testing this alarm feature was not recognized, and consequently was not incorporated into the test program.
Extent or Significance of Deviation:
l The DC batteries are thoroughly inspected arid tested weekly, quarterly, and annually.
In addition, battery charger voltage is checked daily on an operator round.
Therefore, PECo in confident that the batteries have been tested and inspected as required to demonstrate their capability to supply power to the safety-related loads.
Attachm:nt B Page 2 of 2 Docket Ncs. 50-277 50-278 As a result of not testing the alarm relays, one 250 vdc bus low voltage relay was allowed to be in a non-conservative condition (low setpoint).
Failure to test these relays in itself would not prevent the battery from operating as designed to meet its load requirements as demonstrated by service tests and performance tests performed in accordance with Technical Specification 4.9.A.2.
Battery system low voltage would have also been indicated in the control room by the 125 vde power distribution panel low voltage alarms for individual batteries.
Corrective Actions and Results Achieved The one relay which failed to perform satisfactorily when tested during the NRC inspection was inspected and will be replaced following receipt of a new relay which is on order.
Six of the remaining seven relays were subsequently tested by January 20, 1987 and performed satisfactorily.
The one remaining relay could not be tested with the bus it monitors energized because it is not fused to permit de-energization as are the other seven relays.
It was tested on April 14, 1987 while the bus was de-energized during a scheduled static inverter modification.
A modification is being initiated to install a fuse to facilitate subsequent testing of this relay.
Corrective Actions to Avoid Future Deviation:
The DC battery low voltage alarm relays have been added to the preventive maintenance program to be tested once per two yearc.
Date When Full Compliance Will be Achieved:
Full compliance was achieved on April 14, 1987 when testing of the relays was completed.
- - - -. ~. - -
Attcchm:nt C PagD 1 of 5 Docket Hos. 50-277 50-278 AREAS OF WEAKNESS 1)
Updating emergency operating procedures and resolving human factors problems.
The inspectors noted that some emergency operating procedures were not well integrated into the symptom-based emergency operating procedures and contained human factors deficiencies.
Response
We recognize that this area of weakness warrants attention and plan to review and revise emergency operating procedures and system operating procedures which are incorporated into emergency operating procedures by reference.
This effort will focus on human factors improvements including consistent equipment identification.
The process of contracting vendor personnel for this effort has been initiated.
Procedure revisions are in progress to address the specific concerns raised during the inspection regarding the containment venting and blackout emergency operating i
procedures.
A new containment venting procedure is being written which will consolidate the existing venting procedures into a single procedure and will provide the operators with criteria for selecting the various available vent paths.
The new procedure will address radiological and physical protection of personnel during local vent valve operation, and equipment required to perform the venting procedure such as tools, tubing and pipe fittings.
The new venting procedure is expected to be completed and approved by the end of the year, and operator training will be completed within less than six months after procedure approval.
The station blackout procedure is under review and it will be revised to provide proper integration with the Transient Response Implementation Plan (TRIP) procedures as recommended by the inspectors.
Other blackout procedure concerns raised by the inspectors such as, ventilation for the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) rooms, transfer of HPCI and RCIC suction to the suppression pool, manual operation of HPCI, and the ability to monitor plant parameters during the blackout will be addressed.
The revision is expected to be completed in the Second Quarter of 1988, and operator training will be completed within less than six months after procedure approval.
Attachmnnt C
. Pag 2 2 of 5
~
Docket Nos.-50-277 50-278 L
2)
Completely and consistently labeling plant equipment and ensuring correct procedural identification.
The inspectors noted that drawings, equipment' labels and procedures in several instances identified the same equipment with different names or numbers.
Response
A formal program, Critical Equipment Monitoring System
-(CEMS), has been in progress to correct labeling deficiencies on plant valves.
As part of the CEMS program, plant j
operating procedures and operating procedure checkoff lists-i are being revised to reflect this new valve labeling.
Another program is in progress to label other plant equipment l
such as pumps, compressors, fans, tanks, and instruments.
j Drawing revisions are being made as appropriate. -These relabeling programs are expected to be completed in 1988.
3 This new labeling will be incorporated into plant procedures 4
by coordinating these programs with the procedure review project discussed in our response to Area of Weakness No.
1.
3)
Providing complete technical information such as AC and DC circuit load lists.
J
Response
During-the inspection, station personnel were unable to produce electrical load lists.
PECo is in the process of developing a computerized representation of electrical loads.
This will be a software program which can display the electrical bus system and its loads upon request.
It will be l
maintained and updated by the Engineering and Research i
Department to reflect load growth and will be used for evaluation of electrical modifications by design engineers at Corporate Headquarters.
Station personnel will be able to i
view the system on computer terminals on-site or will be provided with computer printouts from the system.
The system is expected to be operational in the First Quarter of 1988.
During the inspection, a lack of documentation of "as-found" Safety Relief Valve (SRV) setpoints was identified.
This weakness in technical documentation has been determined to be 3
due to inadequate direction to the vendor that refurbishes SRVs and has been corrected.
All purchase orders contracting
]
the vendor laboratory to test and refurbish the SRVs, from this time on, will clearly require "as-found testing" and the i.
laboratories certification test report will document the "as-found setpoint" as well as the "as-left setpoint".
Station Quality Control will check for this requirement when reviewing the purchase order.
Additionally, the preventive
Attechm:nt C Prg3 3 of 5 Docket Nos. 50-277 50-278 maintenance task has been changed to require ar. as-found test.
4)
Maintaining and testing supporting equipment.
Response
Recognizing the need to improve the preventive maintenance l
program, two projects were initiated in 1986 to evaluate the program and recommend improvements.
One project examined failure and corrective maintenance history of fifteen systems considered important to safety or plant reliability.
Based on this research, appropriate preventive maintenance tasks and frequencies for these systems will be recommended.
The other project is verifying that the Environmental Qualification Program has been effectively implemented and that adequate controls and procedures to maintain Environmental Qualification of equipment have been established.
These projects will be completed this year.
After evaluating the results, changes will be made to the preventive maintenance program as appropriato.
Additional improvements will be established this year to more aggressively track and implement preventive maintenance tasks for these fifteen systems.
Preventive maintenance tasks will be assigned grace periods based on the importances of the task.
High priority tasks, such as Technical Specification, Environmental Qualification and NRC requirements will have no grace period.
A maintenance request form (MRP) will be initiated as required for each task prior to its due date.
The task can only be delayed or deferred with technical justification and the approval of the responsible member of Senior Plant Staff.
Low priority tasks may be delayed by the Preventive Maintenance Coordinator under certain circumstances.
This control will focus station management's attention on preventive maintenance tasks which are overdue.
Additionally, a quarterly preventive maintenance status report outlining overdue tasks will be prepared for station management review.
A corporate self-assessment of nuclear plant maintenance has been initiated to compare our programs with the INPO guidelines published in INPO 85-038, " Guidelines for Conduct of Maintenance at Nuclear Power Plants", October 1985.
This will be a comprehensive assessment which will examine, in part, preventive maintenance.
This assessment is expected to be completed before December 31, 1987.
During the NRC inspection several specific equipment, maintenance and human factors deficiencies mainly associated with diesel generators were identified.
The specific diesel generator equipment deficiencies have been corrected or are being addressed.
The following specific corrective actions have been taken:
Attrchmsnt C Pigs 4 of 5 Docket Nos. 50-277 50-278 A.
Maintenance Deficiency Corrective Actions:
The diesel generator fans, OAV64, OBV64, OCV64 and ODV64, diesel generator building supplemental supply fans, OAV91, OBV91, OCV91 and ODV91 and battery /switchgear room fans, OAV-36 and OBV-36, were identified by the inspectors as lacking an adequate preventative maintenance and maintenance tracking program.
This equipment is in the preventive maintenance program, but preventive maintenance has not been performed in accordance with the program schedule due to Technical Specification time restraints on equipment outages or insufficient resources to properly plan and carry cut the preventive maintenance.
An evaluation to determine the means for performing these preventive maintenance tasks (safety blocking, the impact of scaffolding, etc.) will be performed this year.
Accessing some of these fans may impact the operability of safety-related systems.
1 B.
Equipment Deficiency Corrective Actions t
1.
The loose electrical cable to one of the air start solenoid valves on the E-1 diesel generator was investigated.
Inspection revealed that the electrical cable, itself, was not loose; the flexible conduit which the cable is routed through was loose and was tightened prior to the NRC exit interview.
2.
The diesel generator local control panel space heaters, including those that were found not operating by the inspectors, have been turned on and will be checked periodically.
Operating Procedure S.8.4.E,
" Routine Inspection of Diesel Generators", will be revised to include a daily check of the space heaters.
This will minimize corrosion of contacts in the cabinets.
Contacts inside the control cabinets have been inspected and those items showing signs of corrosion will be replaced during the next diesel generator maintenance outage this year.
3.
An air leak on the E-2 diesel generator air start system, which was reported by an NRC inspector, was investigated and a small, leaking tube fitting was tightened.
4.
The caps on the Emergency Service Water (ESW) outlet test taps (downstream of normally closed hand valves HV-33-10901A, B, C and D) that were missing have been replaced.
i Attcchmant C P:ga 5 of 5 Docket Nos. 50-277 50-278 C.
Human Factors Deficiency Corrective Actions:
1.
The inspectors found some diesel generator equipment identification in procedures, on plant labels, and on drawings to be inconsistent and in some cases incorrect.
Diesel generator operating procedure checkoff lists are being revised, requests for drawing changes have been initiated, and changes to plant labeling will be implemented as part of the CEMS program (described in our response to Area of Weakness No.
2,
" Completely and Consistently Labeling Plant Equipment and Ensuring Correct Procedural Identification").
2.
Drawing changes have been initiated to correct the two valve line-up errors identified on the diesel generator lube oil P&ID.
3.
NRC inspectors questioned PECo staff on correct diesel generator bearing oil level and governor oil level, and the staff was unsure of the correct levels.
PECo staff has determined the correct operating oil levels through discussionn with diesel generator and governor manufacturers.
Appropriate placards showing correct oil level will be placed near the sight glasses and procedure S.8.4.E will be revised by June 1987 to include daily checks for proper shutdown oil levels and proper running oil levels under the running inspection section of the procedure.
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