ML20217F829

Responds to NRC Re Violations Noted in Insp Repts 50-277/97-08 & 50-278/97-08 on 971123-980117.Corrective Action:Temporary Change Was Initiated to Test Procedure on 971215

ML20217F829
Person / Time
Site:	Peach Bottom
Issue date:	03/25/1998
From:	Mitchell T PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-277-97-08, 50-277-97-8, 50-278-97-08, 50-278-97-8, NUDOCS 9804010167
Download: ML20217F829 (4)

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• Thomas N.Mitehell

• Vice President Peach Bottorn Atomic Power Station A

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. PECO NUCLEAR e; = ; g p "v A Unit of PECO Energy hP 7 4032

$7 d5 Fax 717 456 4243 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 March 25, 1998 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 Violation (Combined Inspection Report No.

50-277/97-08 & 50-278/97-08)

Gentlemen:

In response to your letter dated February 20,1998 which transmitted the Notice of Violation concerning the referenced inspection report, we submit the attached response. The subject report concerned a Residents' Integrated Safety inspection which was conducted November 23,1997 through January 17,1998.

If you have any questions or desire additional information, do not hesitate to contact us.

@/6A&w Thomas N. Mitchell Vice President, Peach Bottom Atomic Power Station Attachments cc: N. J. Sproul, Public Service Electric & Gas R. R. Janati, Commonwealth of Pennsylvania H. J. Miller, US NRC, Administrator, Region I \

A. C. McMurtray, US NRC, PBAPS Senior Resident inspector ,)

R. l. McLean, State of Maryland A. F. Kirby lil, DelMarVa Power /

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9804010167 980325 PDR ADOCK 05000277 G PDR CCN 98-14022

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RESPONSE TO NOTICE OF VIOLATION 97-08-01 l

Restatement of Violation L Technical specification 5.4.1 requires, in part, that written procedures be l established, implemented, and maintained covering the applicable procedures L recommended in Regulatory Guide 1.33, Appendix A, November 1972. The -

procedures listed in Regulatory Guide 1.33, Appendix A, include those covering procedure adherence and temporary change method, and equipment i maintenance.

! Contrary to the above, in November 1997, operations personnel did not fully adhere to routine test procedure RT-O-040-620-2, Revision 4, " Outbuilding i HVAC and Outer Screen Inspection for Winter Operation," and did not follow i l ' instructions for temporary changes, as described in administrative A-3, Revision

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17, " Temporary Changes to Procedures and Partial Procedure Use." Specifically, .  !

L personnel did not fully complete the routine test procedure and did not initiate a

l. temporary change when building thermostats could not be set to the temperature 1 l specified in the procedure. -l This is a Severity Level IV violation (Supplement 1).

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• Reason (s) For The Violation Routine Test (RT) -O-040-620-2, " Outbuilding HVAC and Outer Screen Inspection for Winter Operation" was performed by Operations personnel on October 3 & 4,

.1997. This test inspects and verifies operability of Outbuilding Electric Heating and.

Ventilation equipment and sets up equipment for fall and winter operation. This L test also verifies proper operation of outer screens and associated freeze protection equipment. This test requires Operations personnel to switch on ,

various unit heaters, raise and lower the thermostat setting and verify that the I

. heaters function properly. . Operations personnel were also required to adjust the thermostat setting on various unit heaters to an as-left value of 60 degrees F. ,

During the performance of testing and setting the unit heater thermostats, it was I identified that some of the thermostats could only be set as low as 65 degrees F.

L Operations personnel recorded this step as " unsatisfactory" for each unit heater l which could not be set at 60 degrees F and classified the overall results of the test i

as unsatisfactory. Operations personnelinitiated a Procedure Performance j Improvement Process (PPIS) action request to revise the as-left thermostat i

settings of the new unit heater controllers to 65 degrees F. Operations personnel believed that documenting the appropriate steps as unsatisfactory and initiating a PPIS action request to correct the thermostat setting discrepancy were the appropriate actions to take to initiate the change. It was later determined that the steps which were documented as " unsatisfactory" were actual procedure steps -

which could not be performed as written. In addition, since the procedure error was in the actual numerical value of the setting, the change was required to be processed in accordance with administrative procedure A-3," Temporary Changes to Procedures and Partial Procedure Use." This was not realized by Operatic personnel performing the test. As a result, the appropriate change process v, j not implemented to correct the identified test deficiencies.

l Corrective Steos That Have Been Taken and the Results Achieved Once this issue was brought to the attention of Operations personnel, a temporary change'was initiated to the test procedure on December 15,1997. As-left thermostat settings were changed from 60 degrees F to 65 degrees F for the

' appropriate unit heater controllers. A partial test was initiated to functionally check and set the unit heaters to the revised thermostat reading. The partial test was completed on January 15,1998.

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On January 2,1998, Peach Bottom adopted a "back to basics" approach with a l primary focus on three fundamental areas for 1998. These fundamental areas include safety culture, procedure use and work package use. This initiative was rolled-out to plant personnel in the way of briefing sheets on January 5,12 and 15, 1

1998. In addition, these focus improvement areas have also been discussed with l employees and work teams by immediate supervisors and management.

, .The Senior Manager of Operations has met with the Shift Supervisors and the l Shift Managers on each shift team individually to reinforce the expectation around procedure usage and the back to basics approach. The Senior Manager of Operations also met with each shift team during Operator Re-qualification training cycle 96-12 to reinforce these expectations. In addition, the Event Free Operations program includes a strong supervisory and management presence in the field and reinforces management expectations for proper procedure usage .

Shift management observations around procedure usage and quality are resulting in clarification and reinforcement of expectations to personnel for proper procedure usage and overall improved procedure quality.

l Corrective Steps That Will Be Taken to Avoid Further Violations The Senior Manager of Operations will continue to emphasize a heightened

awareness of procedural compliance to Operations personnel and management expectations for proper procedure usage. In addition, procedure improvements as a result of increased supervisory and management observations are being tracked to ensure procedure quality improvement. Management expectations concerning procedure adherence and the proper use of procedures will continue to be communicated.

l i Date When Full Comoliance Was Achieved Full compliance was achieved on December 15,1997 when a temporary change to RT-O-040-620-2 was implemented to change as-left thermostat settings of appropriate unit heater controllers from 60 degrees F to 65 degrees F. A partial l test which included the revised thermostat settings was completed January 15, 1998.

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