ML20235E050
| ML20235E050 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/18/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8709250463 | |
| Download: ML20235E050 (5) | |
Text
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.WHRC-9511LADELPHIA ELECTRIC COMPANY gQ$
2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA,19101 (215) 841 5001 September 18,.1987
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Docket Nos. 50-277 50-278 Mr.. William F. Kane, Director Division of Reactor. Projects Region I U.S. Nuclear Regulatory-Commission'
]
ATTN:
Document Control Desk Washington, D.C.
20555
SUBJECT:
Revised Response!to Combined Inspection Report'
'Nos.-50-277/87-10; 50-278/87-10
Reference:
Correspondence dated JuneL17, 1987 from J. W. Gallagher, PECo, to~W. F. Kane, NRC.
Dear Mr. Kane:
On June 17, 1987, Philadelphia Electric Company'(PECo) responded to Combined Inspection Report Nos.. 50-277/87-10; 50-278/87-10 and 50-277/87-09; 50-278/87-09, referenced aboi;e.
With respect'to the Notice of Violation'in Combined ~ Inspection Reports 50-277/87-10; 50-278/87-10, we requested that the NRC review.our^
findings and re-evaluate the Notice'of Violation.
On July'28, 1987, Mr. J. Linville (NRC Region I). informed W. M, Alden (PECo)-
by telephone that after. discussions.with the inspector and review of the event, the Notice of Violation'would star.d asLreported in the subject Inspection Report.
Attachment A of this letter provides a. restatement of that violation, followed by PECo's revised response.. This.
response addresses the findings of the Jaspector, as well as the findings of our internal investigation, The revisions in the response are indicated by a bar in the margin.- If you have any questions or require additional information, please.do.not hesitate to contact us.
8709250463 870918 E
Very truly yours, PDR ADOCK 05000277>,
G PDR M I
Attachment cc:
Addressee W. T. Russell, Administrator, Region I, USNRC T. P.' Johnson, Resident Site' Inspector
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Attachment A 1
1 Page 1 of 4 Docket.Nos. 50-277.
50-278 Restatement of Violation' l
During an NRC inspection conducted from March 24 to April 9, 1987, a violation was identified in accordance with-the NRC
- Enforcement Policy (10 CPR 2, Appendix C).
The particular
< violation is set forth below:
l A.
Technical Specification Section 6.8.1. requires that written procedures.be. established, implemented, and maintained that meet the requirements of Sections 5.1 l
and 5.3 of ANSI N18.7-1972, and Appendix A of Regulatory I
Guide 1.33 (November 1972).
ANSI N18.7-1972, Section 5.3.4.2, requires procedures-for plant shutdown, including decay heat removal.-
Regulatory Guide 1.33 (November 1972) Appendix A, Section C, requires operating procedures for shutdot:n i
cooling systems.
Procedure S.3.2.C.1, " Shutdown Cooling Mode - Manual Start and Shutdown", Revision 17, dated May 28, 1986, Step #7, requires that prior to place RHR in service, the loop is flushed by operating selected valvesHin a specific order.
Contrary to the above, at.approximately 9:25 p.m. on March 31, 1987, Procedure S.3.2.C.1, Step #7, was not performed in the required order resulting in a high j
pressure primary containment isolation system actuation.
This is a Severity Level IV Violation (Supplement 1),
i 3
Response to Violation Admission or Denial of Alleged Violation:
The Philade]phia Electric Company (PECo) concurs with the NRC findings that the Shutdown Cooling Mode of the Residual Heat Removal System was not properly placed into service and therefore, admits to the violation.
i Cause of the Event:
It is believed that either the procedure was deficient, or that the operator did not manipulate the valves in the proper.
sequence.
During power operation, the shutdown cooling suction
Attachment A
~
Page 2 of 4 Docket Nos. 50-277 50-278 l
1 piping is isolated by closing valves MO-18, MO-17 and MO-15 (A, B,
C, D).
The MO-15 valves, located downstream of MO-18 and MO-17, had been identified as leaking to-the torus, thereby draining this piping.
The RHR system is shown in Figure A-1.
The results of our investigation determined that the established procedure i
failed to provide caution statements and sufficient prerequisites for the verification of the status of the residual heat removal (RHR) system, consequently, when valve MO-17 is opened, a surge of water can enter this empty piping and cause the high pressure indication.
This can cause the subsequent isolation of the RHR l
system, Group 2B of the Primary Containment Isolation System.
l PECo concurs that operating the valves out of sequence, as i
described in the inspector's report, would also result in an RHR l
isolation.
We have been unable to determine with confidence which of these described causes was responsible for the isolation.
l Extent or Significance of Event:
l With respect to either cause, at no time did the operators lose i
the ability to remove decay heat from the reactor core.
Before and during the isolation, the main condenser was available for cooling.
Aside from the temporary isolation, the unit suffered l
no adverse consequences from the event.
Corrective Actions Taken to Prevent Recurrence and Results Achieved:
In the course of the investigation which followed the Inspection, the operators were interviewed.
During the interviews, the importance of understanding and following procedures was discussed.
Since the event, the Operations Staff has been counseled as to the importance of following both the words and intent of procedures.
In addressing procedural deficiencies, as reported in LER 03 03, a detailed review of the procedure used for shutdown cooling, S.3.2.C.1, was conducted following the incident, and a revision was implemented on July 23, 1987.
The revision incorporated human factors considerations, cautionary notes and additional steps throughout the procedure to correct this and other l
potential deficiencies in this procedure.
A corrective action program has been initiated to upgrade procedures, improve procedural compliance, and raise the levels of operator performance.
The program includes, in part, the following items:
Attachment'I A
..Page 3 of 4'
, Docket"Nos. 50-277.
50-278-i I.
'(1). a major procedure. review and' upgrade effort; s
(2). improving administrative control and" processing of procedures;.
c)
.(3) improving attitudes..'toward procedural compliance.through' l
- administrative.' training and performance evaluations; (4) increased Quality Control monitoring'of. operations.
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