IR 05000278/1992027

Ack Receipt of Informing NRC of Steps Taken to Correct Violations & NRC Administered Exam Weakness Noted in Insp Repts 50-277,50-278/92-27 & 50-277,50-278/92-18

ML20128C369
Person / Time
Site:	Peach Bottom
Issue date:	01/29/1993
From:	Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 9302040001
Download: ML20128C369 (2)

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JAN 201993 Docket No. 50-277 50-278 Philadelphia Electric Company A1TN: Mr. D. Vice President R. D.1 Box 208 Delta, PA 17314

Dear Mr. Miller:

SUBJECT: PEACH BOTTOM ATOMIC POWER STATION - UNITS 2 AND 3 RESPONSE TO NOTICE OF VIOLATION 92-27-01 AND NRC ADMINISTERED EXAM WEAKNESS CORRECTIVE ACTIONS (COMBINED INSPECTION REPORT NOS. 50-277/92-27; 50-278/92-27 AND 50-277/92-18; 50-278/92-18)

This refers to your letter dated December 19, 1992, in response to our letter of November 16, 1992, concerning Notice of Violation 92-27-01, and our letter of October 16,1992, concerning .

exam weaknesses.

Thank you for informing us of the corrective n.nd preventive actions documented in your letter.

The corrective actions taken in response to procedures usage concerns appear to be adequate.

Actions in response to the Notice of Violation will be examined during a future inspection of your licensed program.

Ycur cooperation with us is appreciated.

Sincerely, 03:l1 SEED BY ED"MRD C. '.VELZlMGEis Edward C. Wenzinger, Chief Projects Branch 2 Division of Reactor Projects 9302040001 930129 PDR ADOCK 05000277 G pop

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Philadelphia Electric Comapany 2 cc:

D.M. Smith, Senior Vice President G. Rainey, Vice President, Nuclear Services Department G. Cranston, General Manager, Nuclear Engineering Division .-

K.P. Powers, Plant Manager, Peach Bottom Atomic Power Station G.J. Beck, Jr., Manager Licensing Section R.N. Charles, Chairman Nuclear Review Board A.A. Fulvio, Regulatory Engineer, Peach Bottom Atomic Power Station -

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

cc w/cy of licensee's ltr:

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

J. A. Isabella, Director, Generation Projects Dept., Atlantic Electric B.W. Gorman, Manager-External Affairs, Public Service Electric & Gas Co.

R. McLean, Power Plant Siting, Nuclear Evaluations J.H. Walter, Chief Engineer, Public Service of Maryland D. Poulson, Secretary of Harford County Council Public Document Room (PDR)

local Public document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania bec w/cy of licensee's ltr:

Region I Docket Room (with concurrences)

W. Hehl, DRP E. Wenzinger, DRP C. Anderson, DRS J. Lyash, DRP B. Norris, DRP C. Miller, PDI-2, NRR

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P Gws Q <Gj u car.dcrson RConte 13 enzinger 1tg/93 93 1/]f93 I OFFICIAL RECORD COPY i

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,m. Pl!ILADELPIllA; ELECTRIC COMPANY

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. rexn sorrow-rur rowen oe rscnan sca (717) 456-7014 D. B. Miller, Jr.

- Vice President December 14,-1992 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 SUBJECT: Peach Bottom Atomic Power Station - Units 2 and 3

_ Response to Notice of Violation 92-27-01 and NRC Administered Exam .

Weakness (Combined inspection Report Nosl 50-277/92-27; 50-278/92 27-and 50-277/9218; 50 278/92-18)

Dear Sir,

in response to the referenced inspection report dated October 16,1992, which -

requested a _ response to a weakness identified during NRC administered -initial examinations and the referenced inspection report dated November 16,1992, which -

transmitted the Notice of Violation, we submit the attached response. The response for these inspections has been combined due to the related riature of concern. The subject inspections concern NRC administered _ examinations conducted August 28 through _

September 3,1992, and a routine residents' safety inspection that was' conducted October 6 through October 31,1992, if you have any questions or require any additional information, please do not!

hesitate to contact us.

Sincerely,

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- T. T. Martin, US NRC, _ Region i J. JJ Lyash, US NRC Senior Resident inspector -

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U. S. Nuclear Regulatory Commission Page 2 cc: R. A. Burricelli, Public Service Electric & Gas T. M. Gerusky, Commonwealth of Pennsylvania R.-l. McLean, State of Maryland H. C. Schwemm, Atlantic Electric C. D. Schaefer, DelMarVa Power bec: J. W. Austin A4 4N, Peach Bottom J. A. Basilio 52A 5, Chesterbrook G.J. Beck 52A 5, Chesterbrook y J. A. Bernstein 51 A 13, Chesterbrook R. N. Charles 51 A 1, Chesterbrook Committment Coordinator 52A 5, Chesterbrook -

Correspondence Control Program 618 5, Chesterbrook --

J. 8, Cotton 53A 1, Chesterbrook G. V, Cranston 63B 5, Chesterbrook E. J. Cullen S23-1, Main Office  ;

A. D. Dycus A3-1S, Peach Bottom -

A. A. Fulvio A4 4N, Peach Bottom C. J. McDermott S131, Main Office

D. B. Miller, Jr, SMO-1, Peach Bottom i PB Nuclear Records Doctype 231 l K. P. Powers A4-18, Peach Bottom  ;

J. M. Pratt - B-2-S, Peach Bottom G. R. Rainey 51 A 11, Chesterbrook.

J.T.Robb - 51 A-13, Chesterbrook

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D. M. Smith 52C-7, Chesterbrook i

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RESPONSE TO NOTICE OF VIOL.ATION 92-27-01 Restatement of Violation Technical Specification (TS) 6.8.1 states that written procedures shall be established, implemented and maintained that meet the requirements of Sections 5.1 and 5.3 of ANSI N18.7-1972. Section 5.3.4.2 states, in part, that shutdown procedures shall be provided to guioe operators following reactor trips, and shall include instructions for establishing or maintaining hot standby or cold shutdown conditions. The major steps involved in shutting down the plant shall be specified, including detailed instructions for the performance of such actions as monitoring and controlling cool-down rates. Procedures ST-0-02B 500-2, Revision 0, and ST-0-028-500-3, Revision 0, " Recording Reactor Vessel Temperatures," establish the requirements for monitoring and recording of reactor vessel temperature and pressure during heat-up and cool-down, and for verification of compliance with TS limitations.

Contrary to the above, the licensee did not adequately implement Procedure ST-0-028-500-2 during a Unit 2 evolution on September 13,1992, and Procedure ST-0-028-500-3'

during a Unit 3 evolution on October 16,1992. Specifically; A. Procedure ST-0-02B-500-2, Section 6.2, establishes the requirements for data recording with the reactor vessel shell temperature below 220 degrees F and the reactor vessel not vented. Step 6.2.2 requires the performer to record reactor vessel temperature and prassure at least every 15 minutes. Contrary to the above, from September 13,1992, at 3:30 a.m. until September 14,1992, at 10:00 a.m.,

the Unit 2 reactor vessel shell temperature was below 220 degrees, the reactor vessel was not vented and reactor pressure was not recorded.

B. Procedures ST-0-028-500-3, Step 6.2.3, requires that if the reactor is shutdown, then verify reactor pressure is below the limits specified by TS Figure 3.6.2 and initial the appropriate block provided on data sheet 1. Contrary to the above, from 2:00 a.m. until 11:00 a.m. on October 16,1992, the verification required by Step 6.2.3 was not adequately completed in that Unit 3 reactor pressure was above the limits specified by TS Figure 3.6.2. The limit violation was not identified nor documented on data sheet 1 by the Reactor Operator. This contributed to a significant delay in recognition that the pressure limit had been exceeded.

C. Procedure ST-0-028 500-3, Step 6.2.5, requires verification of shift management review of each individual data sheet as each is completed. Contrary to the above, on October 16,1992, data sheets were not reviewed by shift management as each was completed. For example, five data sheets covering the period of 4:45 a.m.

through 5:00 p.m. on September 16,1992, were not reviewed by shift management until after 6:40 p.m. on that date. This contributed to delay in recognizing the pressure limit violation described in item B above.

This is Severity Level IV Violation (Supplement 1).

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'The . weaknesses observed during the NRC administered exams can be attributed to insufficient emphasis of procedure reference and usage by SRO upgrade candidates during the examination process. Actions by SRO upgrade candidates was based on their :

experience inctead of appropriate procedure reference.- This;was a result of past experience when procedure quality was low or procedural guidance for activities _was insufficient. The performance exhibited by the instant SRO candidates, however, reflected the appropriate standards for procedure usage that _was expected and taught during-licensed operator training, increased emphasis and reinforcement is required during plant -

operations and requal training to augment operator procedure reference and usage to ensure expectations of standards are met.

Corrective Actions that have been Taken and the Results Achieved for the Violation Procedures ST-0-028 500 2(3) data sheets have been temporarily changed and will be-revised to improve human factors for collecting temperature and pressure readings and verification that the data has been recorded. The procedure was previously revised to reference the applicable Tech Spec figure 3.6.2 on the data sheet.

The events concerning use of the data sheet were discussed and evaluated with the appropriate personnel. Additionally, the subject of procedure reference and usage was discussed at the Shift Manager meeting on December 11,1992.

Corrective Actions Tsken in Resqonse to Insoection Recort 92-18 and Generic Procedural Usaae Concerna Operations management reviewed the examination results and observations with the SRO :

upgrades who exhibited weakness in procedural reference and usage. This discussion included communication of expectations and a review of the possible causes for exhibited weaknesses. The benefits -of rigorous reference to' procedures and potential

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consequences of complacency were also discussed with licensed operators.

L An open discussion was held with Operations Management and licensed operators to -

communicate expectations and to examine issues in the area of procedural usage.

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Training has been improved for the present Licensed Operator Training Class by the _

assignment of an experienced shift supervisor as a mentor to the classf Part of his duties will be to ensure procedural expectations are met by the entire class.

The task analysis used by Operations to determine training needs has also been reviewed L for tasks which did not have a procedural reference. Selected tasks for which procedural l

guidance will be developed have been prioritized.

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Operators were requested to submit procedure requests _for evolutions that should be proceduralized, but were not. This resulted in over sixty procedure requests which have -

been evaluated and prioritized for completion.

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The ST/SO Procedure Rewrite Project has recently been completed to upgrade existing procedures to higher standards.

Corrective Steos that will be taken to avoid Further Violations An extensive evaluation of procedure ST-0-02B 500-2(3) development and usage  ;

problems will be completed by February 15,1993. This evaluation will address generic. l concerns associated with procedures that contain data sheets. The Procedure Writers Guide will be appropriately upgraded by Marc i,1993, to properly reflect procedural ~l requirements on data sheets, to improve human factors of procedures and to better incorporate a method to identify how procedures are to be implemented.

A revision to procedure ST-0-02B 500 2(3) to ince rate the temporary change now in effect is scheduled for January 8,1993. This rev)u . will also include interim corrective actions identified by the above evaluation. It is anticipated that the final evaluation findings will result in a subsequent revision.

Training will be conducted to increase operator understanding of the app'ication' of -

pressure / temperature limits. Procedures and training will be evaluated in the area of preventing or mitigating reactor coolant stratification to identify needed improvements.

A letter from the Plant Manager to Operations personnel to review this svent and to reinforce Operations Management expectations concerning procedure performance will be issued in December,1992.

Shift supervision will further reinforce procedural compliance expectations of operators by January,1993, and on a continuing basis by discussing operating or training topics. This discussion will focus on expectations of procedural adherence during training and while operating plant equipment, the importance and requirements of procedure adherence, and examples of experience assessment reports which exemplify the consequences of not following procedures and stated expectations.

Existing standards and expectations for procedure adherence will be emphasized to licensed operator training instructors by December,1992. Through licensed operator requalification classes, operator compliance with procedure requirements and management expectations will be enhanced.

Date when full complian_qo was achieved Full compliance was achieved on September 14,1992, when the. Unit 2 reactor vessel was vented and pressure readings were no longer required and on October 16,1992, when Unit 3 prescure and temperature readings were within the acceptable limits of Tech Spec curve 3.6.2.

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