ML20236T013
| ML20236T013 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/10/1998 |
| From: | Doering J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 50-277-98-05, 50-277-98-5, 50-278-98-05, 50-278-98-5, NUDOCS 9807270373 | |
| Download: ML20236T013 (7) | |
Text
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John Doering, Jr.
Vice President Peach Bottom Atomic Power Station P,ECO, NUCLEAR es m eme<ur co-a #v l
1848 Lay Road A Unit of PECO Energy De ta P 7 9032 S
Fax 717 456 4243 g
E-mait jdoenng@peco-energycom July 10,1998 Docket Nos. 50-277 50-278 l.
License Nos. DPR-44 l
DPR-56 i
U. S. Nuclear Regulatory Commission hM
-M l
Attn.: James Lieberman, Director g
l Office of Enforcement One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 l
Subject:
Peach Bottom Atomic Power Station Units 2 & 3 i
Response to Notice of Violations (Combined Inspection Report No. 50-277/98-05 & 50-278/98-05) and Payment of Civil Penalty Gentlemen:
1 In response to your letter dated June 11,1998, which transmitted the Notice of Violation (NOV) and Proposed Civil Penalty, concerning the referenced inspection report, we submit the attached response. The subject report concemed two NRC inspections conducted between February 12 and March 3,1998, and between March 30 and April 24,1998. Also enclosed is a check in the amount of $55,000 for payment of the civil
- penalty.
- If you have any questions or desire additional information, do not hesitate to contact us.
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n John D ring, Jr.
Vice President,
.l Peach Bottom Atomic Power Station l
Attachments -
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N.J. Sproul, Public Service Electric & Gas
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R. R. Janati,' Commonwealth of Pennsylvania H. J. Miller, US NRC, Administrator, Region I -
A. C. McMurtray, US NRC, Senior Resident inspector R. l. McLean, State of Maryland A. F. Kirby 111, DelMarVa Power / Atlantic Electric
. CCN 98-14053 9907270373 980710 F PDR ADOCK 05000277 8
PDR; I
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OEAP Coordinator 62A-1, Chesterbrook Correspondence Control Program 618-3, Chesterbrook NCB Secretary (11) 62A-1, Chesterbrook G. R. Rainey 63C-3, Chesterbrook J. Doering SMB4-9, Peach Bottom
-J. B. Cotton 62C-3, Chesterbrook R. W. Boyce 63C-3, Chesterbrook E. J. Cullen S23-1, Main Office l
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
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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 A4-5S, Peach Bottom i
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' COMMONWEALTH OF PENNSYLVANIA :
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I COUNTY OF YORK J. Doering, being first duly sworn, deposes and says:
That he is Vice President of Peach Bottom Atomic Power Station; the Licensee herein; that he has read the enclosed response to the NRC Notice of Violation and Proposed Imposition of Civil Penalty for NRC Inspection Report Nos. 50-277/98-03 and 50-278/98-05 for Peach Bottom Atomic Power Station, Unit 2 and Unit 3, Facility Operating License Nos. DPR-44 and DPR-56, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
l-W y-Vice President Subscribed and sworn to before me this /h d day alf of 1998.
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v Notary Public Notarial Seat Sara Baker, Nota.y Public Delta Doro, York County.
My Comnussion Expires May 19,2000 Member, Pennsylvania Association of Notares
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RESPONSE TO NOTICE OF VIOLATION 98-05 g,
Restatement of Violation
'1.
10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures and Drawings, requires in part, that activities affecting quality be prescribed by documented instructions or procedures, of a type appropriate to the circumstances.
t Contrary to the above, during the emergency core cooling system (ECCS) suction strainer replacement modification in October 1997, the licensee did not establish instructions and procedures appropriate to the circumstances to prevent foreign material L
from entering the 3A core spray subsystem. Specifically, the modification FME plan, l
although providing FME controls for the torus, did not consider controls for the strainers.
l The lack of instructions and procedures documenting controls for the strainers resulted j
in foreign material, in the form of a rigging sling protector pad, being left in the system.
I Admission of the Violation l
PECO Energy acknowledges the violation.
. Reason (s) For The Violations l
The cause was attributed to the failure to develop and implement comprehensive project l
FME controls during the Unit 3 ECCS suction strainer replacement modification. The project team had a " tunnel vision" focus on torus foreign material controls and were not adequately focused on ECCS system foreign material controls. The focus on the torus as the primary FME zone resulted in a missed opportunity to perform a broad FME plan review following the NQA identified FME plan implementation weaknesses during the j
i-modification. In addition, the lessons learned from the 1996 Limerick violation concerning less than adequate FME control practices for the suppression pool inadvertently reinforced the project team's inappropriate focus on the torus as the primary FME control zone during the modification.
The FME controls established by the modification team were primarily focused on the l'
torus proper and less on the individual ECCS subsystems being affected by the i
modification. A-C-131, exhibit 8 addressed controls required to maintain the cleanliness l
of the torus proper but did not include controls required for breaching system boundaries l
within the torus. This led to the primary causal factor for the event being a failure to use l
FME covers on suction strainer modules while they were being staged in the reactor building prior to lowering into the torus. Additionally, less than adoquate controls were put into place for accountability of rigging material that encroached on the new components being installed. Clean checks were performed on the new components
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however, the controls employed were less than adequate to maintain the required
- assurances. This external versus intemal focus is further supported by the decision to rely on the torus swim through as the primary criteria for the FME plan close-out, without specifical!y dispositioning the individual ECCS systems.
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Corrective Steos That Have Been Taken And The Results Achieved On March 28,1998, the foreign material was removed and alllow pressure ECCS pumps satisfactorily completed a four hour confidence run indicating a lack of foreign materialin the system. In addition, Performance Enhancement Program (PEP) Report (10008136) was initiated on March 26,1998, to investigate the event, determine potential causes and develop appropriate corrective actions to be incorporated during the ECCS modification scheduled during 2R12. Also, fifteen major modification jobs performed during 3R11 were assessed to determine if they
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included issues similar to this event involving two distinct FME zones. The assessment concluded that there were no FME control or detection issues similar to the ECCS suction strainer modification.
- Corrective Stoos That Will Be Taken To Avoid Further Violations A-C-131, Foreign Material Exclusion Program, will be evaluated based upon this event j
to emphasize the need to establish additional controls when breaching a system internal to the Torus. Also, the requirements of A-C-131 associated with the development of an j
FME plan for major or complex system maintenance or major or complex modifications '
will be evaluated and be revised as appropriate.
Following the development of the FME plan for the Unit 2 ECCS suction strainer replacement modification, independent critiques of the installation instructions, design sad rigging plans for the modification will be performed to identify opportunities to j-
. maximize FME controls. Positive active and/or passive safeguard barriers will be engineered into the Unit 2 ECCS suction strainer replacement modification to assure that the foreign material cannot be introduced into the strainer assemblies during installation. In addition, the design has been modified to enable all required shim packs to be bolted directly to the pipe or strainer flanges prior to being lowered into the torus.
This eliminates the need to use rigging in a manner that encroaches within the ECCS system boundary thus minimizing the possibility that foreign material will be
' inadvertently introduced into the system.
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Date.When Full Compliance Will Be Achieved l
Full compliance was achieved on March 28,1998, when the foreign material was removed and alllow pressure ECCS pumps satisfactorily completed a four hour j_
confidence run indicating a lack of foreign materialin the system.
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Restatement of Violation 2.
. Peach Bottom Atomic Power Station Unit 3 Technical Specification 3.5.1, " Emergency Core Cooling System (ECCS) and Reactor Core Isolation Cooling (RCIC) System",
requires that each ECCS injection / spray subsystem be operable when in modes 1,2, and 3. If one low pressure ECCS injection / spray subsystem is inoperable, the subsystem shall be restored to' operable status within seven days.
l-Contrary to the above, at some time between December 24,1997 and March 13,1998, while the Unit 3 reactor was in Mode 1, the 3A core spray subsystem was not maintained operable. During core spray system testing on March 22, and 24,1998, the 3A core spray pump failed to meet discharge pressure for the given flow specifications.
Specifically, the discharge pressure and flow ratio were 207 psig and 3450 gpm, l
respectively, and the flow curve required a minimum pressure of 214 psig for that flow i
rate. The minimum required discharge pressure was not met, and the pump was inoperable, because of fibrous material (a rigging sling protector pad) wrapped around l
the impeller shaft and parts of the impeller vanes, as well as small bunches of fibers from the protector pad being located in the piping between the pump suction valve and l
the discharge check valve.
p Admission of the Violati_9n PECO Energy acknowledges the violation.
l Reason (s) For The Violation l..
The 3A Core Spray pump was tested in full flow on October 30,1997 as part of the Emergency Core Cooling System (ECCS) strainer mod Acceptance Test Plan (ATP).
l This test indicated that the pump was operable with no detectable difference from historical pump performance data. The pump was next tested on December 24,1997, in accordance with ST-O-014-301-3. Test data indicated that the pump was operable, but that performance differed from historical data. Specifically, the flow was higher than l
normal and the discharge pressure was lower than normal. On March 22,1998, the 3A Core Spray pump was again tested in accordance with ST-O-014-301-3 but failed to meet the performance requirements. Subsequent troubleshooting was performed on March 23 through March 25,1998 to determine the cause of the degraded pump performance. The troubleshooting identified foreign material, which was believed to be a rigging sling protector from the ECCS modification completed during 3R11, in the 3A Core Spray pump impeller. The pump was declared inoperable on March 24,1998.
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h The investigation into the source of the foreign material concluded it was most likely introduced during 3R11. In addition, there was a missed opportunity for the system manager to further investigate the cause of the slightly degraded pump performance identified during the December 24,1997, pump valve and flow test. _The plot of the ST
- data showed that the pump fell within the acceptable region and was therefore considered operable. However, when this data was compared to the historical pump performance data, it did show a shift in pump performance. Based on this, the 3A Core Spray pum'p was considered to have been inoperable since the startup of unit 3 following 3R11 on November 3,1998.
' Corrective Stoos That Have Been Taken And The Results Achieved f
The foreign material was removed from the 3A Core Spray pump and the pump re-assembled to ensure no pump performance deficiencies due to foreign material p
intrusion. Four hour confidence runs were performed for all low pressure ECCS pumps j
on March 28,1998. All of the requirements of the ST were met. In addition, the results l
of the test for each pump fell within the " historical data range" as monitored by system t
managers.
L Corrective Steos That Will Be Taken To Avoid Further Violations This event will be shared with all system managers to highlight the importance of monitoring system performance and the need to not only include acceptability criteria in tests (e.g., STs and RTs), but a comparison to historical data. Also, the lessons leamed from this event will be incorporated into'the System Manager Handbook. In addition, Engineering will enhance pump curves used for evaluating surveillance test data to highlight the historical trend. This will allow immediate feedback to the system manager for evaluation of data within the acceptable band, but outside of historical data. An Engineering Desktop Computer System will also be implemented to allow improved monitoring capabilities by system managers.
l Date When Full Compliance Will Be Achieved Full compliance was achieved when a four hour run test, which augmented the pump's capacity test for IST, was conducted satisfactorily on March 28,1998, thereby establishing that the pump was operable.
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