ML20236D720
| ML20236D720 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/22/1987 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8707310040 | |
| Download: ML20236D720 (3) | |
See also: IR 05000277/1986025
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Docket Nos.
50-277
50-278
Philadelphia Electric Company
ATTN: Mr. J. W. Gallagher
Vice President
Nuclear Opera' tuts
2301 Market Street
Philadelphia, Pennsylvania 19101 ,s
Gentlemen:
Subject:.
InspectionReportNo.50N7and50-278/86-25
This refers to your letter d2ted ?pril 24, 1987, in response to our letter
dsd March 11, 1987.
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Thank you .# informing us of the corrective and preventive acticos that you
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have takeh to the Notice of Violation and Deviation as well as the four areas
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of weakness identif.ed. Your actions taken and planned will be examined during
future inspections 6f your licensed program.
We note, however, that a few
items of your response require further clarification pr f or to our inspections,
with some additional consideration on your part.
In relponse to the Notice of Violation, your corrective actions are not clear
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as to whether you will permit the plant operator performing the weekly diesel
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generator full load test to satisfy your fire watch requirement if the Cardox
system is defeated, or whether an individual with no other job related duties
other than a fire watch will be used.
If the former is the case, please
provide your justification.
In response to the Notice of Deviation, you indicated that as of April 14,
1987, you were in full coth(testing you had done,3as witnessed by the inspec
liance with your FSAR commitrpnts regarding testing
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of the relays. During the
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one relay performed unsatisfactoriD/ in the no+dbnservative direction.
You
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also indicated that this rdlay will be replaced.with 'a new relay which is on
order. Please describe any compensatory actions you may, have taken as a result
of the unsatisfactory performance until the rela / is replaced and indicate the
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expectedcompletionoftherelayr@lacement.
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In your response to the area 9f weakness regarding emerged:y cperating
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procedures, ' you have deferre! the completion date of activities beyond .our
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understanding at the conclusioi)t of the exit.
It was oQ understanding that a
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revision, to the emergency dperating procedures wouldg made in August 1987.
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B7073i00A0 B70722
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ADOCK C0000277
RLPB286-2N('/
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JFFICIAL RECORD COPY
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07/20/87
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Philadelphia Electric Company
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Your response leads one to conclude that these revisions are expected to be
completed as late as June 1988 with operator training in these procedures to
be completed as late as December 1988.
.Please explain the delay in the
completion of the revision and training in emergency operating procedures.
Finally, we request you clarify your response regarding the weakness in
maintenance and testing
support equipment.
In your response regarding
maintenance on the diesel generator and switch gear room fans, you indicated
that the fans were included in the preventive maintenance program but that
maintenance has not been performed in accordance with the program schedule and
that accessing some of these fans may impact operability of safety related
systems.
Furtherr. ore, your response implies that no preventive maintenance
will be performed on this equipment until at least next year while you
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determine the means to perfc m such preventive maintenance tasks. We consider
that deferral of preventive maintenance on these fans may also affect
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operability of safety related systems.
Please provide information to support
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your proposition that deferring preventive maintenance until next year is an
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acceptable approach.
Please respond to these requests within 60 days of the date of this letter.
Where good cause is shown, consideration will be given to extend the response
time.
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Your cooperation with us in this matter is appreciated.
Sincerely,
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Original gg, ,gg,,-
William V. Johnston, Acting Director
Division of Reactor Safety
cc:
Dickinson M. Smith, Manager, Peach Bottom Atomic Power Station
John S. Kemper, Senior Vice President, Engineering and Production
Thomas S. Shaw, Jr., Vice President, Production
Troy B. Conner, Jr. , Esquire
W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric
G Leitch, Nuclear Generation Manager
Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)
Raymond L. Hovis, Esquire
Thomas Magette, Power Plant Siting, Nuclear Evaluations
W. M. Alden, Engineer in Charge, Licensing Section
Doris Poulsen, Secretary of Harford County Council
Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
OFFICIAL RECORD COPY
RL PB2 86-25 - 0002.0.0
7/20/87
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Philadelphia Electric Company
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bec:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
Section Chief, DRP
Robert J. Bores, DRSS
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7/b/87
7/8/87
7/7187
7/2:V87
OFFICIAL RECORD COPY
RL PB2 86-25
0003.0.0
07/06/87
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PHILADELPHIA ELECTRIC COMPANY
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2301 MARKET STREET
P.O. BOX 8699
PHILADELPHIA, PA.19101
(2151 841 5001
April 24, 1987
JOSEPH W. G ALLAGMER
m........,
m............
50-278
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Mr. William V. Johnston, Acting Director
Division of Reactor Safety
U.S. Nuclear Regulatory Commission
Region I
ATTN:
Document Control Desk
D.C.
20555
SUBJECT:
Response to Inspection Report No. 50-277/86-25
for Peach Bottom Atomic Power Station
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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
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requirements.
Appendix B of the letter identified one item which
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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
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Inspection report response.
Attachment C to this letter
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addresses the areas of weakness.
An extension to April 24, 1987
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,
WJ f"
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Attachments
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cc:
Addressee
William T. Russell, Administrator, Region I,
T.
P.
Johnson, NRC Resident Site Inspector
(,',.ll~;q)cd
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Attachment A
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Page 1 of 3
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Docket Nos. 50-277
50-278
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RESTATEMENT OF VIOLATION
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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 CPR 2, Appendix
C), the following violation was identified:
A.
Technical Specifications 3.14.B.4, paragraph a.,
states, in
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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 room.
On December 10,
]986, at approximately 1:00
a.m.,
the operator left the E-3
diesel room to telephone the Control Room and on December 24,
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1986, at approximately 12:45
a.m.,
the operator was found
outside the E-1 diesel room.
The failure to provide a
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continuous dedicated firewatch constitutes a violation,
This is a Severity Level IV Vjolation (Supplement I).
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RESPONSE TO VIOLATION
Admission or Denial of Alleged Violation:
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Philadelphia Electric Company (PECo) acknowledges that the
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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:
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Attachment A
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Page 2 of 3
Docket Nos. 50-277
50-278
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"When leaving any diesel room, always rearm the injection Cardox
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system by operating the disable switch
" and "Cardox shall not
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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.
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Extent or Significance of Violation:
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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 noerable.
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
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precaution is considered acceptable as long as it is done in
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accordance with the fire protection procedural requirements
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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 the 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
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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.
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Attachment A
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Page 3 of 3
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Docket Nos. 50-277
50-278
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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.
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Attachment B
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Page 1 of 2
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Docket Nos. 50-277
50-278
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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
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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.
This is a deviation applicable to Units 2 and 3.
RESPONSE TO DEVIATION:
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Admission or Denial of Alleged Deviation:
PECo acknowledges the importance of the DC low bus voltage alarm
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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:
The DC batteries are thoroughly inspected and tested weekly,
quarterly, and annually.
In addition, battery charger voltage is
checked daily on an operator round.
Therefore, PECo is confident
that the batteries have been tested and inspected as required to
demonstrate their capability to supply power to the safety-
related loads.
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Attachment B
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Page 2 of 2
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Docket Nos. 50-277
50-278
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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
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tests performed in accordance with Technical Specification
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4.9.A.2.
Battery system low voltage would have also been
indicated in the control room by the 125 vdc power distribution
panel low voltage alarms for individual batteries.
Corrective Actions and Results Achieved
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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 years.
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Date When Full Compliance Will be Achieved:
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Full compliance was achieved on April 14, 1987 when testing of
the relays was completed.
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Page.1 of 5
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Docket Nos. 50-277
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50-278
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AREAS OF WEAKNESS
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1)
Updating emergency operating procedures and resolving human
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factors problems.
The inspectors noted that some emergency operating procedures
were not well integrated into the symptom-based emergency
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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 addreE3'the specific
concerns raised during the inspection regarding the
containment venting and blackout emergency operating
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,
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tubing and pipe fittings.
The new venting procedure is
expected to be completed and approvsd 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.
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Attachment C
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Page 2 of 5
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Docket Nos. 50-277
50-278
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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
operating procedures and operating procedure checkoff lists
are being revised to reflect this new valve labeling.
Another program is in progress to label other plant equipment
such as pumps, compressors, fans, tanks, and instruments.
Drawing revisions are being made as appropriate.
These
relabeling programs are expected to be completed in 1988.
This new labeling will be incorporated into plant procedures
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.
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
maintained and updated by the Engineering and Research
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
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.
Durino 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
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
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
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Attachmen't C
Page 3 of 5
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Docket Nos. 50-277
50-278
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maintenance task has been changed to require an as-found
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test.
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4)
Maintaining and testing supporting equipment.
Response:
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Recognizing the need to improve the preventive maintenance
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program, two projects were initiated in 1986 to evaluate the
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program and recommend improvements.
One project examined
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failure and corrective maintenance history of fifteen systems
considered important to safety or plant reliability.
Based
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on this research, appropriate preventive maintenance tasks
and frequencies for these systems will be recommended.
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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 appropriate.
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
A maintenance request form (MRF) 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
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Senior Plant Staff.
Low priority tasks may be delayed by the
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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
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guidelines published in INPO 85-038, " Guidelines for Conduct
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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:
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Attachment C
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Page 4 of 5
Docket Nos. 50-277
50-278
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A.
Maintenance Deficiency Corrective Actions.-
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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
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preventative maintenance and maintenance tracking
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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
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equipment outages or insufficient resources to properly
plan and carry out the preventive maintenance.
An
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evaluation to determine the means.for performing these
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preventive maintenance tasks (safety blocking, the
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impact of scaffolding, etc.') will be performed this
year.
Accessing some of these fans may impact the
operability of safety-related systems.
B.
Equipment Deficiency Corrective Actions
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
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interview.
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2.
The diesel generator local control panel space
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heaters, including those that were found not
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operating by the inspectors, have been turned on
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and will be checked periodically.
Operating
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Procedure S.8.4.E,
" Routine Inspection of Diesel
Generators", will be revised to include a daily
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check of the space heaters.
This will minimize
corrosion of contacts in the cabinets.
Contacts
inside the control cabinets have been inspected and
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those items showing signs of corrosion will be
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replaced during the next diesel generator
maintenance outage this year.
3.
An air leak on the E-2 diesel generator air start
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system, which was reported by an NRC inspector, was
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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.
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Attachment C
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Page 5 of.5
Docket Nos. 50-277
50-278'
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C.
Human Factors Deficiency Corrective Actions:
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1.
The inspectors found some diesel generator
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equipment identification in procedures, on plant
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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
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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 3ube oil P&ID.
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3.
NRC inspectors questioned PECo staff on correct
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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 discussions with
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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 inc1.ude-
daily checks for proper shutdown oil levels and
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proper running oil levels under the running
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inspection section of the procedure.
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