ML20236V182
| ML20236V182 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/27/1998 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| 50-277-98-02, 50-277-98-2, 50-278-98-02, 50-278-98-2, NUDOCS 9807310352 | |
| Download: ML20236V182 (3) | |
See also: IR 05000277/1998002
Text
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July E7, 1998
Mr.' G. Rainey, President
PECO Nuclear
Nuclear Group Headquarters
Correspondence Control Desk
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P.O. Box 195
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Wayne, Pennsylvania 19087-0195
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SUBJECT:
COMBINED INSPECTION REPORT NOS. 50-277/98-02 AND 50-278/98-02
Dear Mr. Rainey:
This letter refers to your July 10,1998, correspondence in response to our
June 9,1998 letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
Original Signed by:
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Clifford J. Anderson, Chief
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Projects Branch 4
Division of Reactor Projects
Docket Nos. 50-277;50-278
cc w/ Licensee Response Ltr:
R. Boyce, Director, Nuclear Quality Assurance
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G. J. Lengyel, Manager, Experience Assessment
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J. W. Durham, Sr., Senior Vice President and General Counsel
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T. M. Messick, Manager, Joint Generation, Atlantic Electric
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W. T. Henrick, Manager, External Affairs, Public Service Electric & Gas
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R. McLean, Power Plant Siting, Nuclear Evaluations
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J. Vannoy, Acting Secretary of Harford County Council
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R. Ochs, Maryland Safe Energy Coalition
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J. H. Walter, Chief Engineer, Public Service Commission of Maryland
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Mr. & Mrs. Kip Adams
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Commonwealth of Pennsylvania
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State of Maryland
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TMI- Alert (TMIA)
9807310352 980727
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ADOCK 05000277
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0FFICIAL RECORD COPY
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Mr. G. Rainey
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cc w/o Licensee Response Ltr:
G. Edwards, Chairman, Nuclear Review Board and Director, Licensing
J. Doering, Vice President, Peach Bottom Atomic Power Station
J. B. Cotton, Vice President, Nuclear Staticn Support
A. F. Kirby, Ill, External Operations - Delmarva Power & Light Co.
M. Warner, Plant Manager, Peach Bottom Atomic Power Station
Mr. & Mrs. Dennis Hiebert, Peach Bottom Alliance
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Mr. G. Rainey
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Distribution w/ Licensee Response Letter:
Region i Docket Room (with concurrences)
C. Anderson, DRP
D. Florek, DRP
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R.Junod,DRP
Nuclear Safety Information Center (NSIC)
NRC Resident inspector
PUBLIC
B. McCabe. DECO
R Pr.ps, PDI-2, NRR
Inspection Program Branch, NRR (IPAS)
M. Thadani, NRR
B. Buckley, NRR
R. Correia, NRR
F. Talbot, NRR
DOCDESK
DOCUMENT NAME: A:\\RL902.PB
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To rsceive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure
"E" =
Copy with attaptgent/ enclosure
"N" = No copy
' OFFICE
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GrFICIAL RECORD COPY
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Jahn Doering, Jr.
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Vice Presidern
Peach Bottom Atorme Power Staton
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.PECO NUCLEAR
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A Unit of PECO Energy
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Fax 717 456 4243
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July 10,1998
Docket Nos. 50-277 '
50-278
License Nos. DPR-44
DPR-56
U. S. Nuclear Regulatory ^ommission
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Attn.: Document Control sesk
Washington, DC 20555
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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:
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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
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conducted March 15,1998 through May 4,1998.
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If you have any questions or desire additional information, do not hesitate to ccvact us.
W
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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. Miller, US NRC, Administrator, Region I
'A. C. McMurtray, US NRC, Senior Resident inspector
- R. I. McLean, State of Maryland
A. F. Kirby lit DelMarVa Power / Atlantic Electric
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CCN 98-14052
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bec:
OEAP Coordinator
62A4. Chesterbrook
Correspondence Control Program
618-3, Chesterbrook
NCB Secretar) (11)
6?A-1 Chaeterbrook
G. R. Rainey
63C 3, ChesNorook
J. Doering
SM34-9, Peath Sc tom
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J. B. Cotton
62C-3, Chestettrook
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R. W. Boyce
63C-3, Chestertrook
E. J. Cullen
S23-1, Main Of fice
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
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R. L Gambone
A4-1S, Peach Bottom
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R.A.Kankus
63C-2, Chesterbrook
G.J.Lengyel
A4-4S, Peach Bottom
M.J. Taylor
A4-SS, Peach Bottom
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RESPONSE TO NOTICE OF VIOLATION 98-02
Restatement of Violation
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Technical Specification 5.4.1 requires, in part, that written procedures be established,
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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
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equipment warm-up time of 30 minutes required to ensure equipment reliabihty.
Be.ason(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 operabikty
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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
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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'
observaCons and information provided by operators locally monitoring the HPCI booster
pump vibration, the operators questioned the rehabikty of the control room monitoring
equipment and the unit 2 HPCI turbine was shutdown. The HPCI system remained
inoperable until additional testing and monitorirg indicated that vibration readings were
within the acceptable range.
The incident was discussed with operation and I & 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 untilit
warms up to operating temperature. Although known to some personnel, this system
requirement had not been annotated in operations or surveillance procedures.
Corrective Steps That Have Been Taken Anc' The Results Achieved
A Temporary Change to include a precautionary 30 minute warm-up time on the
recorder and indicator was initiated on March 22,1998, for five operating and four test
procedures.
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Corrective Steps That Will Be Taken To Avoid Further Violations
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Six test procedures which involve HPCI monitoring are also being revised to include a
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statement that if the HPCI vibration monitoring system, VBI and VBR-4(5) 06 displays
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inaccurate information during the first 30 minutes of operation it may be due to system
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warm-up time. A statement that if a vibration concern exists then the severity of the
vibration should be verified in the HPCI Pump Room via local indication will e!so be
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
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Date 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
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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.
Revisions to the fifteen operating and test procedures that involve HPCI monitoring are
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
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" Focus On Excellence" newsletter. This newsletter is required reading for all Operations
personnel,
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Restaternent of Violation
2.
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
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Regulatory Guide 1.33, Appendix A, include restrictions for activities in radiation and
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PECO Health Physics procedure HP-C-215, " Establishing and Posting Radiologically
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Controlled Areas," Revision 2, required each Radiation Area to be conspicuously posted
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with a sign or signs bearing the radiation symbol and the words, " CAUTION RADIATION
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AREA.'
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Contrary to the above, on April 24,1998, the NRC identified that the radiation area signs
at the access to the North Isolation Valve Room (NIVR), a known and surveyed
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radiation area, were not visible nor conspicuous.
Reason (s) For The Violations
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On Friday April 24,1998, an operator and an operations health physicist (H.P.) went to
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the North isolation Valve Room (NIVR) to perform a draining procedure. .he area was
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controlled as a high radiation area due to the potential of a HPCI actuation and the
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subsequent potential dose rates in the room in excess of 100 millirem per hour. Actual
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survey data from the routine survey program indicated that the highest general area was
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22 millirem per hour and that the area was not a high radiation area as defined by 10
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CFR 20.1003,10 CFR 20.1601, and Peach Bottom Technical Specification 5.7. The
H.P. briefed the operator on the task arid the radiclogical conditions in the area, opened
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the coor and let the operator in to perform the work. When it was open, the door
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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 imi 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 wn 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 consis:ency 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'd posting program was benchmarked for the control 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 Stens That Will Be Taken To Avoid Further Violations
Radiological posting of various areas in the plant (e.g., units 2 and 3 RCIC turbine
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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 postif _, similar to that at Limerick, of
high radiation area doors was completed by June 21,
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