ML20238A427

Responds to NRC 870731 1tr Re Violations Noted in Insp Repts 50-277/87-17 & 50-278/87-17.Corrective Actions:Complete Surveillance Test 12.2 on Torus & Drywell Headers & Nozzles Will Be Performed Prior to Unit 2 Startup

ML20238A427
Person / Time
Site:	Peach Bottom
Issue date:	08/31/1987
From:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8709090290
Download: ML20238A427 (5)

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d 'O PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.0, BOX 8699 PHILADELPHIA A. PA.19101 (215) 841 5001

'* * ' T ,* ',,",^ ',t ",* " * " August 31, 1987 NUCLEAA OPW S ATIONS Docket Nos. 50-277 50-273 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:

Response to Combined Inspection Report Nos. 50-277/87-17 and 50-278/87-17

Dear Mr. Kane:

Your letter dated July 31, 1987 transmitted Combined Inspection Report Nos. 50-277/87-17 and 50-278/87-17 for the inspection period of June 1,.1987 to July 17, 1987 at the Peach Bottom Atomic Power Station.

As a result cf this inspection, one alleged violation was identified concerning the failure to perform an air test._on the Residual Heat Removal System drywell containment spray headers and nozzles once per five years as required by Technical Specification 4.5.B l.d. Attached is our response to this alleged violation.

If you have any questior,s or require additional information, please do not hesitate to contact us.

Very truly yours, V L Attachments cc: Addressee W. T. Russell, Administrator, Region I, USNRC >

T. P. Johnson, Resident Site Inspector )

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Attachmsnt l

[ Page 1 of 3  !

[ Docket Nos. 50-277 50-278 Violation:

Technical Specifications section 4.5.B.l.d, requires an air test on the RHR drywell and torus containment spray headers and nozzles once per five years. Surveillance Test ST 12.2,

" Containment and Torus Spray Sparger Air Test," implements this requirement.

Contrary to the above, as of July 17, 1987, the A and B loop drywell header air tests per ST 12.2 for Unit 2 had not been performed for five years as it was last performed on July 24, 1980, and therefore was required to be completed by October 24, 1986.

Admission or Denial of the Violation:

Philadelphia Electric Company acknowledges the violation as stated, f

Reason for the Violation:

Prior to the use of the present computerized Surveillance Test and Records System (STARS), surveillance test intervals were identified, controlled and tracked by a manual system. The manual system correctly scheduled ST 12.2 (" Containment and Torus Spray Sparger Air Test") to be performed in 1982. As stated in the violation, the previous test was in 1980. ST 12.2 was not performed in 1982 since it was recognized that it had been performed in 1980.

The surveillance test should have been rescheduled to be completed in 1985 based on the 5 year testing interval as identified in Technical Specification 4.5.B.l.d. Instead, the surveillance schedule was not changed and when the conversion was made to the computerized Surveillance Test and Records System, ST 12.2 remained {

on its original surveillance interval based on the 1982 date, and I was not scheduled until the week of April 27, 1987. This was a l personnel error caused by a lack of an adequate mechanism in the '

manual ST program for rescheduling tests several years into the -

future, j

l Although not identified in the violation, the Inspection Report identifies a concern that the Surveillance Test and Records System program does not adequately differentiate between partially completed and fully completed surveillance tests. Corrective Actions to address this deficiency are discussed below.

Extent or Significance of The Violation:

r Attachment "t- -Page 2 of 3 Docket Nos. 50-277 50-278

.As stated above, the Surveillance Test and Records System program' scheduled the Surveillance Test 22.2 to be performed during the weekiof April 27, 1987. Since Unit 2 had been in an outage since March'14, 1987, ST 12.2 has been deferred until later in the outage: prior to startup. As stated in the Inspection Report, visual inspections were performed on the Unit 2 torus and drywell spray nozz1cr and headers by removing several nozzles. .No significant obstructions were identified that would interfere with the nozzle flow path. However, there was a minimum of surface rust in the piping between nozzles and a slight buildup of powder rust in one of the torus nozzles.

.The purpose of.ST 12.2 is to verify a flow path through the spray nozzles. Based on the visual inspection results, it is concluded.that the drywell spray system and nozzles were functional during the period of, time that ST 12.2 was outstanding.

Corrective Actions:

Although the visual inspection of the torus and drywell spargers was performed prior to knowledge of this violation, the inspection indicated that the nozzles and headers are in

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satisfactory condition.

A complete ST 12.2 on the torus and drywell headers and nozzles as required by' Technical Specification 4.5.B.1.d will be performed prior to Unit 2 startup.

Corrective Actions Taken To Prevent Recurrence and Results Achieved:

The surveillance interval in Surveillance Test and Records System has been corrected such that ST 12.2 will be completed on a five year interval, as required by Technical Specification 4.5.B.1.d based on the last previous. completion date in July 1980.

l The Surveillance Test and Records Syctem program is l- currently being reviewed to ensure that surveillance tests scheduled l at a frequency greater than one year have been correctly scheduled.

t:

Although not identified in the violation, the Inspection g Report identifies a concern that the Surveillance Test and Records l System program does not adequately differentiate between partially completed and fully completed surveillance tests. Corrective Actions to address this deficiency are discussed below, o

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Attachment Page 3 of 3 Docket Nos. 50-277 50-278 l To correct the inadequacy of the administrative controls I

and the Surveillance Test and Records System to track the, completion of partial surveillance tests, Procedure A-3, Procedure for Temporary Changea to Approved Procedures and Procedure A-43, Surveillance Test Program will be' revised to ensure that partially ccmpleted surveillance tests are reviewed by a Plant Operations Review Committee'(PORC) member to record on each partially completed surveillance test the reasons for completing'the partial test as opposed to a complete test, and whether additional testing is required to fulfill the surveillance test requirements.

The software for the Surveillance Test and Records System will be member,'the modified such partial or that completedupon completion surveillance of the testre"tew by the results can PORC be properly entered into the Surveillance Test and Records System. In the event that the surveillance test requirements were only partially met, the Surveillance Test and Records System will identify the need to complete the test within the specified surveillance interval.

Date W1en Full Compliance Will Be Achieved:

ST 12.2 (" Containment and Torus Spray Sparger Air Test")

will be completed prior to Unit 2 reactor startup. The review of the Surveillance Test and Records System to ensure that surveillance tests scheduled at a frequency greater than one year have been correctly scheduled will be completed by October 31, 1987.

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