ML20248H145

Responds to NRC Re Violations Noted in Insp Repts 50-277/98-03 & 50-278/98-03 on 980212-0303.Corrective Actions:Plant Staff Who Routinely Determine Reportability & Write LERs Have Been Counseled on Present Event

ML20248H145
Person / Time
Site:	Peach Bottom
Issue date:	06/02/1998
From:	Doering J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-277-98-03, 50-277-98-3, 50-278-98-03, 50-278-98-3, NUDOCS 9806080077
Download: ML20248H145 (5)

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• John Doering, Jr.

Vice President

& Peach Bottom Atomic Power Station v

PECO NUCLEAR

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esco enerov cemnenv 1848 Lay Road A Unit of PECO Energy Delta. PA 17314-9032 717 456 4000 Fax 717 456 4243 E-mait jdoenng@peco-energycom June 2,1998 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission Attn.: Document Control Des'k 4 Washington, DC 20555 {

Subject:

Peach Bottom Atomic Power Station Units 2 & 3 Response to Notice of Violations (Combined Inspection Report No. 50-277/98-03 & 50-278/98-03)

Gentlemen:

In response to your letter dated March 30,1998 which transmitted the Notice of Violations concerning the referenced inspection report, we submit the attached response. The subject report concerned a Special Inspection on the 2A reactor feedpump turbine which was conducted between February 12 and March 3,1998.

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

% 4 John Doering, Jr.

Vice President, Peach Bottom Atomic Power Station Attachments

_ -n gy,g eoauoO cc: N.J. Sproul, Public Service Electric & Gas l R. R. Janati, Commonwealth of Pennsylvania H. J. Miller, US NRC, Administrator, Region I A. C. McMurtray, US NRC, Senior Resident inspector T. M. Messick, Atlantic Electric R. I. McLean, State of Maryland A. F. Kirby 111, DelMarVa Power CCN 98-14037 I} I n'

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9906000077 990601 77 l OR ADOCK O O\

. l bec: OEAP Coordinator 62A-1, Chesterbrook Correspondence Control Program 61B-3, Chesterbrook NCB Secretary (11) 62A-1, Chesterbrook D. M. Smith 63C-3, Chesterbrook G. R. Reiney 63C-3, Chesterbrook J. Doering SMB4-9, Peach Bottom J. B. Cotton 62C-3, Chesterbrook T. J. Niessen 53A-1, Chesterbrook 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 61C-1, Chesterbrook G. J.' Lengyel A4-4S, Peach Bottom M.J. Taylor A4-5S, Peach Bettom 1

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RESPONSE TO NOTICE OF VIOLATION 98-03 Restatement of Violation 10 CFR50.73 (a) requires, in part, that the licensee submit a Licensee Event Report (LER),

within thirty days, for any deviation or conditic n prohibited by the plant's Technical Specifications.

Contrary to the above, the NRC identified that as of March 3,1998, an LER had not been submitted for the event on April 1,1997, involving a condition prohibited by Technical Specification Section 3.3.2.2, "Feedwater and Main Turbine High Water Level Trip Instrumentation." Specifically, the 2'A' Reactor Feedwater Pump Turbine high water level trip capability was inoperable for greater than two hours while Unit 2 reactor power was >

25%. The main turbine trip functior: rad the trip functions on the two other reactor feed pumps remained operable during this time.

This is a Severity Level IV violation (Supplement 1).

Reason (sl For The Violation On April 1,1997, while completing operator actions to remove from service the 2A reactor feedpump turbine (RFPT), the feedpump failed to trip on a momentary signal from the main control room push-button. The turbine had already been secured per procedure from injecting several hours earlier. The tripping of the turbine and closure of the stop valves is a follow-up action by operations personnel.

At the time the turbine failed to trip, operations personnel declared the 2A RFPT inoperable and took all appropriate technical specification (TS) actions to maintain compliance. When tha deportability determination was made, responsible personnel verified that all required TS actions had been met and determined that the event was not reportable.

The plant staff used NUREG -1022, revision 1 (draft), " Event Reporting Guidelines 10 CFR 50.72 and 50.73", section 3.2.2 in making their determination. Under item (2), Limiting Condition for Operation, it states, "For the purpose of this discussion, it is assumed that there was firm evidence that a condition prohibited by TS existed before discovery, for a time longer than permitted by TS." The conditions discovered during investigation of the feedpump turbine trip mechanism included some dirt and oil film buildup in the trip dump valve. This was believed to be the apparent cause of the failure to trip. Since the trip feature had been .,accessfully tested during refueling outage 2R12 in October 1996 and

" firm evidence that a condition prohibited by TS existed before discovery" was not determined, the plant staff did not report the event under 10 CFR 50.73. Plant staff I

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and personnel investigating the evident did not believe that the conditions noted comprised

" firm evidence" and that the condition existed beyond the TS action times. 1 In subsequent discussions with the NRC residents and interpretation of the deportability position by Office for Analysis and Evaluation of Operational Data (AEOD) personnel, it was made apparent that the plant staff interpretation of NUREG -1022 was narrow. Under item 1 (3), Technical Specification Surveillance Requirements, it states that, "It should be f assumed that the discrepancy occurred at the time of its discovery unless there is firm evidence, based on a review of relevant information (e.g., the equipment history and cause of failure) to believe that the discrepancy existed previously."

Upon further review, it was apparent that plant staff did not consider this second statement in making their determination. Since the dirt and oil buildup conditions (cause of failure) noted in the trip dump valve were the result of less than e 3 equate maintenance (equipment history), the plant staff should have concluded that those conditions impacted 2A RFPT operability longer than TS action times Corrective Steos That Have Been Taken and the Results Achieved 1 The April 1,1997 f ailure to trip event was discussed in an Licensee Event Report (LER) 2-97-009, submitted on December 9,1997 for a similar failure to trip event on November 9, 1997. The November event was originally attributed to intermittent mechanical binding of some trip mechanisrn subcomponents. At the time of LER 2-97-009 submittal, this binding was also believed to be the most likely cause of the April 1 event. Therefore, the April 1 event was communicated to the NRC in LER 2-97-009.

Corrective Steos That Will Be Taken To Avoid Further Violations Plant staff who routinely determine deportability and write LERs have been counseled on this event and the broader view of NUREG - 1022 that is required in making these determinations.

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Date When Full Comoliance Was Achieved Full compliance was achieved on December 9,1997 when the April 1,1997 event was  !

reported to the NRC in LER 97-009.

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