ML20215E549
| ML20215E549 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/01/1986 |
| From: | Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8610150368 | |
| Download: ML20215E549 (4) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (ats) est soto u.tcoo sv October 1, 1986 u...."."*,'.'..
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Docket No. 50-277 50-278 Inspection Report Nos. 50-277/86-12 50-278/86-13 Mr. William F. Kane, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Kane:
Your letter dated September 2, 1986 forwarded Combined Inspection Report Nos. 50-277/86-12; 50-278/86-13 for Peach Bottom Atomic Power Station.
Appendix A of your letter addresses one item which does not appear to be in full compliance with Nuclear Regulatory Commission requirements.
This item is restated below followed by our response.
Restatement of Violation:
As a result of the inspection conducted on June 18, 1986 - July 3, 1986, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violation was identified:
r The Technical Specifications require the testing of safety-related systems and componetits, within the minimum intervals specified for each, with the following examples:
Technical Specification 4.5.A.3 requires that each train of the low pressure coolant injection (LPCI) mode of residual heat removal (RHR) be tested monthly for pump and valve operability.
Surveillance Test (ST) 6.8, "RHR
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- Pump, Valve, Flow and Unit Cooler Functional" implements this requirement.
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Mr. Willicm F. Kano Octob3r 1, 1986 Page 2 i
Contrary to the above, ST 6.8 was not performed on the Unit i
2 "A" RHR system by June 29, 1986, exceeding the specified l-time interval by 25%.
I Technical Specification 4.5.B,1 requires that the high pressure service water (HPSW) system be tested monthly for-4 1
pump and valve operability.
ST 6.10-2, "HPSW Pump and Valve, Operability and Flow Rate Test - Unit 2 Only" implements this requirement.
i Contrary to the above, ST 6.10-2 was not performed on the Unit 2 HPSW system by June 29, 1986, exceeding the specified time interval by 25%.
j Technical Specification Table 4.1.1 requires that the Reactor Protection System safety instruments and control i
circuits be tested and identifies the minimum test I
frequencies for each trip channel and alarm.
ST 9.4, l
" Turbine Stop Valve Closure Functional", implements this requirement for the scram function provided by the closure of the turbine stop valves.
ST 9.14, " Turbine Control Valve I
Fast Closure Scram Functional" implements this requirement for the scram function provided by the fast closure of the j
turbine control valves, j
Contrary to the above, ST 9.4 was not performed on either j
the Unit 2 or the Unit 3 Reactor Protection System by June 15, 1986, the expiration date of the test grace period.
Also, contrary to the above, ST 9.14 was not performed on the Unit 2 Reactor Protection System by June 15, 1986, exceeding the specified time interval by 25%.
The above examples constitute a Severity Level IV Violation l
(Supplement 1) applicable to DPR-44 and DPR-56.
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Response
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Admission of Alleged Violation:
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Philadelphia Electric Company acknowledges the violation as stated l
above.
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l Reason for Violation l
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The surveillance tests identified in the violation are the responsibility of the Operations Group.
The tests were issued by I
the Surveillance Test Coordinator appropriately; however, the violation occurred because Operations supervision failed to ensure
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that the tests were completed in a timely manner.
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Mr. Willicm F. Kcn2 Octobor 1, 1986 Page 3 Corrective Actions Taken and Results Achieved:
ST-9.4 (Unit 2), ST-9.4 (Unit 3), and ST-9.14 (Unit 2) were completed on July 1, 1986.
ST-6.8 (Unit 2) and ST-6.10-2 (Unit 2) were completed on July 2, 1986.
All five tests were completed satisfactorily.
Corrective Actions Taker to Avoid Future Non-Compliance:
To ensure that surveillance tests are completed in a timely manner and to provide guidance for surveillance tests which cannot be completed prior to expiration of their grace period, the following steps have been added to Administrative Procedure A-43 (Surveillance Testing System):
"7.5 The Surveillance Test Coordinator shall issue, three times a week, a " Grace Period Report" to each Cognizant Engineer, for their specific area.
The Cognizant Engineer shall review the report and determine which tests cannot be performed before the grace period expires and submit a Completed Grace Period Surveillance Test Review Form to the appropriate Senior Engineer.
The appropriate Senior Engineer shall review the Grace Period Surveillance Test Review Forms and, if he concurs, inform the appropriate Superintendent of the condition.
The appropriate Superintendent shall approve the Grace Period Surveillance Test Review Form and return the form to the appropriate Cognizant Engineer who shall present the form to the PORC for review before the subject Surveillance Test becomes overdue.
After PORC action, the Grace Period Surveillance Form shall be attached to the subject Surveillance Test and a copy of the form sent to the Surveillance Test Coordinator who should maintain a file of working Grace Period Surveillance Test Review Forms.
The working Grace Period Surveillance Test Review Forms should be removed from the Surveillance Test Coordinator's file when the original form and subject Surveillance Test are received.
7.6 The Surveillance Test Coordinator shall issue weekly, an l
Overdue Test Report, a Grace Period Test Report, and a Test Awaiting Official Verification Report to the following; each Senior Engineer for their specific area, each Superintendent for his specific area, and the Plant Manager.
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7.7 The Surveillance Test Coordinator should inform the appropriate Cognizant Engineer when a test is three days from the expiration of its grace period."
This system focuses management attention on tests which are in theit grace period so that appropriate steps can be taken i
to overcome the obstacles which are interfering with timely completion of the tests.
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Mr. Willitm F. KOna October 1, 1986 Page 4 Date When Full Compliance was Achieved:
Full compliance was achieved on July 2, 1986 upon completion of the last of the five surveillance tests identified in this violation.
Pursuant to a September 30, 1986 telecon between G. M.
Leitch (PECo) and Mr. Peter Eselgroth (NRC), the written response to the concerns listed in Attachment 2 of the Inspection Report will be submitted by October 17, 1986.
This extension will permit consideration of reaterial to be discussed wi:h your staf f at the planned October 3, 1986 meeting in preparing the written response.
Should you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, cc:
T.
P. Johnson, Resident Site Inspector r
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