ML20138H772

Forwards Insp Rept 50-277/96-06 & 50-278/96-06 on 960707-0907 & Forwards Notice of Violation

ML20138H772
Person / Time
Site:	Peach Bottom
Issue date:	12/27/1996
From:	Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20138H777	List: ML20138H772 ML20138H794
References
EA-96-264, EA-96-346, NUDOCS 9701060228
Download: ML20138H772 (3)

See also: IR 05000277/1996006

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December 27,1996

EA 96-264

EA 96-346 I

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Mr. D. M. Smith, President l

PECO Nuclear  !

Nuclear Group Headquarters

Correspondence Control Desk

P. O. Box 195

Wayne, Pennsylvania 19087-0195

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SUBJECT: NOTICE OF VIOLATION

(NRC INSPECTION REPORT NO. 50-277/96-06 AND 50-278/96-06) ,

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Dear Mr. Smith: j

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This letter refers to the NRC inspection conducted from July 7,1996 to September 7,1996, l

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at the Peach Bottom Atomic Power Station facility and to the apparent violation described in

the report associated with the emergency diesel generator and residual heat removal pump

interactions. The findings of the inspection were discussed with members of your staff during

an exit meeting on September 19,1996. In addition, the NRC inspection report was sent to ,

you with our letter, dated October 10,1996. On December 6,1996, a Predecisional  !

Enforcement Conference was conducted with you and members of your staff to discuss the  ;

related violation, its causes, and your corrective actions.

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Based on the informe' an developed during the inspection, and the information provided during 4

the conference, or Violation of NRC requirements was identified. The violation is set forth  !

in the enclosed f.otice of Violation. It involves the failure to verify the adequacy of the

modification der gn of Modification P-0231 prior to implementation as required by 10 CFR 50,

Appendix B, Criterion Ill, Design Control. Modification P-0231 provided for automatic

emergency diesel transfer from the droop to the isochronous mode of operation.

Modificatir,n P-0231 was first installed for two diesel generators in June 1995, but a full

understareding of its effects on other systems was not realized until June 1996, when

simulator runs were made. In cases where the plant response changes, the adequacy of the

new design must be verified, as required by 10 CFR Part 50, Appendix B, Criterion lil, and as

specified in ANSI N45.2.11-1974, to which you are committed. We are particularly concerned

that your staff did not understand all of the effects of the modification on the facility prior to

implementation of the modification. In your response to this letter, please pay particular

attention to what corrective actions you will put in place to ensure that the effects of future

modifications are understood prior to implementing them. {

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During the predecisional enforcement conference we discussed at length the scenario that

involved an emergency diesel generator operating in the test mode and the effect of a

subsequent loss of coolant accident signal on the operability of the associated offsite power

source. It is our understanding that, until June 1996, your staff assumed that the emergency

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Mr. D. M. Smith 2

pumps would load onto the bus consistent with their assigned time delay sequences. During

the predecisional enforcement conference, your staff gave the position that,in consideration

of the actual starting sequence of the pumps, no specific evaluation would have been

necessary for this scenario because no credit was taken in the licensing basis for the diesel

generator bein0 on the bus. The point does not apply since you are required to understand

the effects of design changes on the overall facility design prior to implementation of the

modification.

it is also important to note that we recognize that your staff self-identified this issue during

simulator runs in June 1996, and subsequently, in your "PBAPS EDG Licensing Basis," dated

July 16,1996, your staff completed verification of the design of the modification. We will

review this document during a future inspection of your licensed activities.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part to

determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and

its enclosures wil! be placed in the NRC Public Document Room.

We appreciate your cooperation.

Sincerely,

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Original Signed By:

Richard W. Cooper,11, Director

Division of Reactor Projects

Docket / License No. 50-277/DPR-44

50-278/DPR-56

Enclosure:

1. Appendix A, Notice of Violation

cc w/ encl:

G. A. Hunger, Jr., Chairman, Nuclear Review Board and Director, Licensing

T. Mitchell, Vice President, Peach Bottom Atomic Power Station

G. Rainey, Senior Vice President, Nuclear Operations

D. B. Fetters, Vice President, Nuclear Station Support

T. Niessen, Director, Nuclear Quality Assurance

C. D. Schaefer, External Operations - Delmarva Power & Light Co.

G. Edwards, Plant Manager, Peach Bottom Atomic Power Station  ;

G. J. Lengyel, Manager, Experience Assessment l

J. W. Durham, Sr., Senior Vice President and General Counsel

P. MacFarland Goelz, Manager, Joint Generation, Atlantic Electric

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Mr. D. M. Smith 3 '

B. W. Gorman, Manager, External Affairs

R. McLean, Power Plant Siting, Nuclear Evaluations

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J. Vannoy, Acting Secretary of Harford County Council

R. Ochs, Maryland Safe Energy Coalition

J. H. Walter, Chief Engineer, Public Service Commission of Maryland

L. Jacobson, Peach Bottom Alliance

Commonwealth of Pennsylvania i

State of Maryland

TMI - Alert (TMIA) l

Distribution w/ encl:

Region i Docket Room (with concurrences)

Nuclear Safety Information Center (NSIC)

i NRC Resident inspector ,

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PUBLIC

K. Gallagher, DRP

D. Screnci PAO

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Distributio,1 w/ encl: (Via E-Mail)  :

W. Dean, OEDO

J. Shea, NRR

J. Stolz, PDI-2, NRR  !

Inspection Program Branch, NRR (IPAS)

R. Correia, NRR

R. Frahm, Jr., NRR

R. Zimmerman, ADPR, NRR

F. Davis, OGC  !

A. Nicosia, OGC

J. Lieberman, OE (OEMAIL)

D. Holody, EO, RI

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