ML20133E219

Notice of Violation from Insp on 960805-09.Violation Noted: on 960809,PECO Nuclear Was Not Adequately Monitoring Performance or Condition of Numerous Sys & Components Against Established Goals

ML20133E219
Person / Time
Site:	Peach Bottom
Issue date:	01/03/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133E209	List: ML20133E206 ML20133E219
References
50-277-96-07, 50-277-96-7, 50-278-96-07, 50-278-96-7, EA-96-370, NUDOCS 9701100245
Download: ML20133E219 (3)

Text

. 1 ENCLOSURE NOTICE OF VIOLATION PECO Nuclear Docket Nos. 50 277 and 50 278 i Peach Bottom Atomic Power Station License Nos. DPR-44 and DPR-56 I Units 2 & 3 EA 96-370 l l

During an NRC inspection conducted between August 5 9, 1996, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the particular violation is set forth below:

10 CFR 50.65(a)(1) requires, in part, that the holders of an operating license shall monitor the performance or condition of structures, systems, or components, against licensee established goals,in a manner sufficient to provide reasonable assurance that such structures, systems, and components, within the scope of the rule, are capable l of fulfilling their intended functions. When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken. 10 CFR 50.65(a)(2) requires, in part, that monitoring as specified in l paragraph (a)(1)is not required where it has been demonstrated that the performance l or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance, such that the structure, system, or component remains capable of performing its intended function.

Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 1, endorses NUMARC 93-01, " Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," as an acceptable method for implementing the requirements of 10 CFR 10.65. Regulatory Guide 1.160 states that the methods described in the guide will be used in the evaluation of the effectiveness of maintenance activities oflicensees who are required to comply with 10 CFR 50.65 unless a licensee has proposed an acceptable alternative method for compliance.

NUMARC 93-01, Section 9.3.2, states, in part, that performance criteria for risk significant structures, systems, and components should be established to assure that reliability and availability assumptions used in the plant specific probabilistic risk assessment, individual plant examination, or other risk determining analysis are maintained or adjusted when necessary. Standby systems are to be treated similarly.

NUMARC 93-01 also indicates that non-risk-significant operating systems are monitored using appropriate plant-level performance criteria.

Contrary to the above, on August 9,1996, PECO Nuclear was not adequately monitoring the performance or condition of numerous systems and components against established goals, nor had PECO Nuclear demonstrated the ef fectiveness of preventive maintenance on these systems and components. The affected systems included the reactor protection system, emergency ventilation systems for the diesel generator building and the control room, the reactor recirculation system, the electrohydraulic control system, the feedwater system, the turbine bypass valves and the main steam 9701100245 970103 PDR ADOCK 05000277 G PDR

Enclosure 2 safety relief valves (MSRVs). The monitoring of the effectiveness of preventive maintenance had not been adequately demonstrated in that the selected system performance criteria were not demonstrated to be fully effective because the licensee did not always follow the guidance of Regulatory Guide 1.160/NUMARC 93-01 and did not adequately justify those criteria selected that deviated from Regulatory Guide /NUMARC for all SSCs in the Maintenance Rule scope, as evidenced by the following examples:

• Safety Grade Instrument Gas (SGIG), the Control Rod Drive (CRD) standby pump, the Reactor Protection System (RPS), Control Room Emergency Ventilation (CREV), and the Emergency Diesel Ger erator (EDG) building ventilation, are risk significant standby systems, which had train level performance criteria that did not include an unavailability criterion.

• Reactor Recirculation, EHC, and Feedwater are nonrisk significant systems with performance criteria established at the plant level. However, the performance criteria did not include unplanned capability loss factor, which was needed to measure functional performance.

• Adequate performance criteria for the EHC, turbine bypass valves, and MSRV systems were not implemented to effectively monitor an important Maintenance Rule function (reactor pressure control) of these systems. These systems were only monitored using the plant level criteria of unplanned shutdowns.

• The MSRV system is a risk-significant standby system, which was only monitored at the plant level using unplanned shutdowns. (01013)

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

Pursuant to the provisions of 10 CFR 2.201, PECO Nuclear is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector at the f acility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or,if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

I l Fnclosure 3 Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential l commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at King of Prussia, Pennsylvania this 3rd day of January 1997 l

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