ML20236N682

Forwards Response to Violations Noted in Insp Repts 50-277/98-02 & 50-278/98-02.Corrective Actions:Six Test Procedures Which Involve HPCI Monitoring Are Also Being Revised to Include Following Statement

ML20236N682
Person / Time
Site:	Peach Bottom
Issue date:	07/10/1998
From:	Doering J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-277-98-02, 50-277-98-2, 50-278-98-02, 50-278-98-2, NUDOCS 9807150211
Download: ML20236N682 (6)

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• . John Doering, Jr.

l . Vice Pr:sdent Peach Bottom Atomic Pomt Staten

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PECO NUCLEAR nco m- compeev 1848 Lay Road A Unit of PECO Energy Delta. PA 17314-9032 717 456 4000 Fax 717 456 4243 E mail: jdoenng@peco-energycom July 10,1998 Docket Nos. 50-277 l 50-278 '

l License Nos. DPR-44 DPR-56 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 Violations (Combined Inspection Report No. 50-277/98-02 & 50-278/98-02)

Gentlemen:

In response to your letter dated June 9,1998, which transmitted the Notice of Violation  !

(NOV), concerning the referenced inspection report, we submit the attached response.

The subject report concerned a Residents' Integrated Safety inspection that was conducted March 15,1998 through May 4,1998.

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

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John oering, Jr.

Vice President, Peach Bottom Atomic Power Station Attachments MT/mt cc: N.J. Sproul, Public Service Electric & Gas R. R. Janati, Commonwealth of Pennsylvania H. J. Miiler, US NRC, Administrator, Region i 1 A. C. McMurtray, US NRC, Senior Resident inspector R. l. McLean, State of Maryland i- 7'] g A. F. Kirby ill, DelMarVa Power / Atlantic Electric

. ,. m CCN 98-14052 9807150211 900710 DR ADOCK 050007 7

P bec: OEAP Coordinator 62A-1, Chesterbrook Correspondence Control Program 61B-3, Chesterbrook l NCB Secretary (11) 62A-1, Chesterbrook

G. R. Rainey 63C-3, Chesterbrook J. Doering SMB4-9, Peach Bottom l J. B. Cotton 62C-3, Chesterbrook R. W. Boyce 63C-3, Chesterb,ook E. J. Cullen S23-1, Main Office ,

T.A.Shea SMB4-6, Peach Bottom G. D. Edwards 62A-1, Chesterbrook J. G. Hufnagel 62A-1, Chesterbrook -

C. J. McDermott S13-1, Main Office M. E. Warner A4-1S, Peach Bottom G. L. Johnston SMB3-5, Peach Bottom R. L. Gambone A4-1S, Peach Bottom R.A.Kankus 63C-2, Chesterbrook G. J. Lengyel A4-4S, Peach Bottom M.J. Taylor A4-SS, Peach Bottom I

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RESPONSE TO NOTICE OF VIOLATION 98-02 Restatement of Violation

1. Technical Specification 5.4.1 requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in

, Regulatory Guide 1.33, Appendix A, November 1972. The procedures listed in Regulatory Guide 1.33, Appendix A, include emergency core cooling systems.

Contrary to the above, prior to March 22,1998, PECO failed to properly maintain system operation procedure SO 23.1.18-2, "High Pressure Coolant injection (HPCI) System Manual Operation," resulting in inadequate instructions for the operation of the HPCI '

vibration monitoring equipment. This procedure did not allow for the vibration monitoring equipment warm-up time of 30 minutes required to ensure equipment reliability.

Reason (s) For The Violations While performing surveillance procedure (ST) ST-O-023-301-2, Revision 19, "HPCI Pump, Valve, Flow and Unit Cooler Functional and in-Service Test" to verify operability of the unit 2 HPCI system on March 13,1998, NRC inspectors questioned operations shift management as to the significance of the high HPCI vibration meter and recorder readings in the control room. The control room supervisor referred to the operating procedure, SO 23.1.B-2, Revision 11. "HPCI System Manual Operation" for the limit on vibration. The control room meter indicated a reading of greater than 5.0 mils with spikes as high as 5.92 mils. The procedure requires the HPCI turbine be tripped immediately if greater than 3.5 mils vibration is observed. Based on the inspectors'

observations and information provided by operators locally monitoring the HPCI booster pump vibration, the operators questioned the reliability of the control room monitoring equipment and the unit 2 HPCI turbine was shutdown. The HPCI system remained inoperable until additional testing and monitoring indicated that vibration readings were within the acceptable range.

The incident was discussed with operation and ! & C personnel in addition to the system manager. The discussions indicated that it was not readily recognized by the system manager nor others that a warm-up time was required due to the design of the instrument. Some station personnel who worked with this type of instrument for a number of years were aware of the warm-up period for this instrument.

This instrument utilizes a vacuum tube design which does not function properly until it warms up to operating temperature. Although known to some personnel, this system requirement had not been annotated in operations or surveillance procedures.

Cs-.tive Stoos That Have Been Taken And The Results Achieved A Temporary Change to include a precautionary 30 minute warm-up time on the

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recorder and indicator was initiated on March 22,1998, for five operating and four test procedures.

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Corrective Steos That Will Be Taken To Avoid Further Vlolations Six test procedures which involve HPCI monitoring are also being revised to include a statement that if the HPCI vibration monitoring system, VBI and VBR-4(5) 06 displays inaccurate information during the first 30 minutes of operation it may be due to system warm-up time. A statement that if a vibration concern exists then the severity of the vibration should be verified in the HPCl Pump Room via local indication will also be j added. In addition, Engineering Change Requests (ECRs) have been initiated to evaluate the removal of these recorders and indicators from service since installed local indication is more accurate than the HPCI vibration monitoring system in the control room.

pate When Full Compliance Will Be Achieved Full compliance was achieved on March 22,1998, when a temporary change to SO 23.1.B-2 was implemented. The change provided the information that the HPCI vibration monitoring system, may display inaccurate information during the first 30 minutes of operation due to system warm-up time. It also included that if a vibration concern exists, the severity of vibration is to be verified in the HPCI Pump Room. j Revisions to the fifteen operating and test procedures that involve HPCI monitoring are i expected to be revised by September 1998. In addition, information on this incident and the HPCI vibration monitoring system will be included in the July 1998, Operation's

" Focus On Excellence" newsletter. This newsletter is required reading for all Operations personnel.

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Restatement of Violation

2. Technical Specification 5.4.1 requires, in part, that written procedures be established, implemented, and maintained covering the epplicable procedures recommended in Regulatory Guide 1.33, Appendix A, Novembar 1972. The procedures listed in Regulatory Guide 1.33, Appendix A, include restrictions for activities in radiation and high radiation areas PECO Health Physics procedure HP-C-215,' Establishing and Posting Radiologically Controlled Areas," Revision 2, required eac's Radiation Area to be conspicuously posted with a sign or signs bear.ng 6 i&diation sy mbol and the words, " CAUTION RADIATION -

AREA.'

Contrary t' o the above, on April 24,1998, the NRC identified that the radiation area signs at the access to the North Isolation Valve '<oom (NIVR), a known and surveyed radiation area, were not visible nor conspicuous.

Reason (s) For The Violations On Friday April 24,1998, an operator and an operations health physicist (H.P.) went to the North Isolation Valve Room (NIVR) to perform a draining procedure. The area was controlled as a high radiation ares due to the potential of a HPCI actuation and the subsequent potential dose rates in the room in excess of 100 millirem per hour. Actual survey data from tha routine survey program indicated that the highest general area was 22 millirem per hout and that the area was not a high radiation area as defined by 10 CFR 20.1003,10 CFR 20.1601, and Peach Bottom Technical Specification 5.7. The H.P. briefed the operator on the task and the radiological conditions in the area, opened the door and let the operator in to perform the work. When it was open, the door opened such that the radiation sign on the outside of the door posting the room as a High Radiation Area faced the wall and was no longer visible. The operator indicated to the H.P. that he saw a leak in the room. The H.P. verbally checked with the operator to ensure the operator was not wet and then proceeded around the corner of the NIVR to acquire protective clothing. During this time the operator remained inside the NIVR and did not have sight of the door, it was at this time the NRC inspector entered the area and observed that the door to the NIVR was left ajar and the radiation posting was no longer conspicuously posted.

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Corrective Steps That Have Been Taken And The Results Achieved Once this issue was brought to the attention of Health Physics personnel by the NRC inspector, the door to the NIVR was closed and additional postings were put in place to ensure visible and conspicuous notification. A Performance Enhancement Program (PEP) investigation (10008303) was initiated on April 26,1998, to investigate the event, determine potential causes and develop appropriate corrective actions. All controlled high radiation areas (28 areas) were monitored and reviewed for consistency with the posting standard and with the procedure. The locked high radiation areas were also evaluated for appropriateness of regulatory controls and human factors. In addition, Limerick's posting program was benchmarked for the ccntrol and posting of locked high radiation areas. This benchmarking was completed by May 15,1998.

The H.P. involved in the incident was counseled regarding this incident. In addition, an "all hands" meeting was held on May 15,1998, with all H.P. staff to stress the need to ensure continuous procedural compliance and to ensure there is a full understanding of applicable technical specifications. The meeting was also used to obtain feedback on how the Radiation Protection group could ensure that the incident does not re-occur.

Corrective Steos That Will Be Taken To Avoid Further Violations Radiological posting of various areas in the plant (e.g., units 2 and 3 RCIC turbine exhaust to torus line) are being evaluated to assure the plant is meeting its posting standards and create a " human factored" control of controlled high radiation areas.

Date When Full Comoliance Will Be Achieved Full compliance was achieved on April 24,1998, when the door to the NIVR was closed and the radiation posting was visible. Enhanced posting, similar to that at Limerick, of high radiation area doors was completed by June 21,1998.

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