IR 05000277/1978025
| ML19322A056 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/07/1978 |
| From: | Beckman D, Greenman E, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19322A049 | List: |
| References | |
| 50-277-78-25, 50-278-78-30, NUDOCS 7901020100 | |
| Download: ML19322A056 (6) | |
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O U.S. NUCLEAR REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT Region I 50-277/78-25 Report No.
50-278/78-30
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50-277 Docket No.
50-278 DPR-44 C
Category C
License No.
DPR-56 Priority
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Licensee:
Philadelphia Electric Company
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2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Peach Bottom Atomic Power Station, Units 2 and 3 Inspection at:
Delta and Philadelphia, Pennsylvania Inspection conducted:
August 30 - September 1 and 13,1978 kan-ji - 7-7f Inspectors:
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E.,G de ma6, Reactor Inspector date signed ku Mc w
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D. A. Bdckman, Reactor Inspector
' date signed date signed Approved by:
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E. C. McCabe, Jr., Chief, Reactor Projects date signed Section No. 2, RO&NS Branch Inspection Summary:
Inspection on August 30 - September 1 and 13,1978 (Combined Report Nos. 50-277/78-25 and 50-278/78-30)
Areas Inspected:
Routine, unannounced inspection of plant operations; inoffice and onsite review of 10 CFR 21 implementation; Bulletin response; Safety Review Committee audits; and, independent inspection effort.
The inspection involved 23 inspector-hours onsite and at the corporate offices by two NRC regional based inspectors.
Results: Of the four areas inspected, no items of noncompliance were identified in three areas. One item of noncompliance was identified in one area related to audits of actions taken to correct deficiencies not performed at least once per six months by the 0&SR Comittee (Infraction - Details, 5).
l 7901020100
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Region I Form 12 (Rev. April 77)
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DETAILS 1.
Persons Contacted
- W. Birely, Staff Engineer R. Castagliola, Senior Engineer - QA Division
- R. Fleischmann, Assistant Station Superintendent R. Voore, Superintendent - QA Division S. Roberts, Results Engineer W. Willsey, Secretary - 0&SR Committee J. Winzenried, Technical Engineer Other licensee employees were contacted during the inspection.
These included reactor operators, shift supervision, engineering personnel, technical support personnel, health physics and security personnel.
denotes those present at the exit interview
2.
previous Inspection Item Update (Closed) Unresolved Item (277/78-15-04; 278/78-19-04):
NRC manage-ment to review the acceptability of licensee interpretation of Technical Specification 6.5.2.8.c audit requirements for 0&SR Com-mittee. The inspector presented the results of the NRC management review and inspected the records of 0&SR audits conducted pursuant to this specification during 1976-1978.
The inspector determined that the scope and content of the audits were consistent with the results of the NRC management review and the Technical Specifications.
The inspector had no further questions regarding this matter. An item of noncompliance was, however, identified with regard to the frequency of audit performance as discussed in Details, 5.
3.
Facility Tour
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Facility tours were conducted on an unescorted basis of Unit 2 and and Unit 3 facilities.
Areas examined included the reactor building, process areas, turbine decks, access controls and exterior areas. The inspector confirmed that access control was in effect and that mini-mum control room staffing requirements were satisfied on the midnight shift, August 31, 1978.
Inspections were conducted to determine the
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general state of cleanliness, housekeeping, adherence to fire pro-tection guides and to observe plant conditions. The inspector checked equipment operability and verified by comparison of selected control room instrumentation that limiting conditions for operation were being satisfied.
Status of off normal alarms were discussed with various operating personnel.
Operators were knowledgeable of plant conditions.
No unacceptable conditions were identifie _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
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4.
10 CFR 21 Implementation An inoffice and onsite inspection was conducted to determine the licensee's compliance with 10 CFR 21. The following procedures addressing 10 CFR 21 requirements were reviewed:
l A-13, " Procedure for Reporting Defects and Noncompliances,"
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Revision 0, dated January 6, 1978; A-4, " Plant Operations Review Committee Procedure," Revision
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ll, dated January 26, 1978; and, A-27, " Procedure for Material Control System," Revision 8,
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dated April 14, 1978.
The inspector verified that the following procedures or controls have been established and are adequate to assure implementation of Part 21 requirements as follows:
Procedures for evaluating deviations or informing the licensee,
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or purchaser, of deviations (21.21(a)) - Procedure A-4, para-graph B Procedures for informing a director or responsible officer of:
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1) deviations evaluated to be a defect; or 2) failures to l
comply relating to a substantiated safety hazard (21.21(a)) -
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Procedure A-13, paragraph 4 Controls or procedures which will assure that a director or
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responsible officer will inform the Commission as required
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when receiving information of a defect or reportable failure l
to comply (21.21(b)) - Procedure A-13, paragraph 4 Controls or procedures to assure that each procurement document
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for a facility or basic components, when applicable, specifies that provisions of 10 CFR Part 21 apply (21.31) - Procedure A-27, paragraph 4.n.
The inspector additionally audited a sampling of procurement documents to confirm that documentation specified the applicability of 10 CFR 21 on the documents.
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Controls or procedures to assure licensee maintenance of records
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(21.51(a)) - Procedure A-4, paragraph B i
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Controls or procedures for posting (21.6).
Posting require-
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ments were not specifically addressed in procedures.
In-i spection determined that the regulations of 10 CFR 21, Section 206 of the Energy Reorganization Act of 1974, and procedure notices were posted as required by 10 CFR 21.6, in a con-spicuous location (main entrance bulletin board in the Administra-tion Building, ground level). The inspector also discussed a lack of postings at Unit 1 with a licensee representative. The licensee stated that all personnel working at Unit 1, routinely were in the Administration Building. The inspector had no further questions.
Controls or procedures to assure the preparation and appropriate
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disposition of records offered to the licensee (21.51(b)).
Re-view of the licensee's procedures indicated that the licensee
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had not addressed the requirements of 10 CFR 21.5.1.b.
A cognizant
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licensee representative stated that this area would be reviewed and covered procedurally as applicable. This item is considerad unresolved (78-25-01; 78-30-01).
5.
Operations and Safety Review (OS&R) Commiti.ee The inspector reviewed the audits conducted by the 0&SR Committee during 1976-1978, which were intended to satisfy the requirements of Technical Specification 6.5.2.8.c.
This specification requires that audits be performed under the cognizance of the O&SR Committee, which shall encompass the results of all actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety at least once per six months.
The licensee has established an 0&SR Comittee audit program which provides for auditing corrective actions taken in response to 0&SR, QA audit findings and NRC inspection findings during the routine
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performance of audits in each of the audit program's other subject areas.
The inspector determined that the scope and content of the audits of corrective actions appeared to be acceptable as discussed in Paragraph 2, but that the frequency of the audits listed below
did not satisfy the requirement to audit corrective action at least
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once per six months. These audits were identified by the 0&SR ?.udit l
Plan, dated September 1,1978, as being subject to either annual or l
biennial performance. The audits individually included auditing of corrective actions within their respective subject areas and col-i lectively provided the scope required by the Technical Specification.
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Most Recent Previous Audit Performance Performance j
Plant and Shift Operations 11/16/77 2/15/77 Surveillance Testing 1/4/78 12/7/76 Maintenance of Instruments 3/26/78 12/31/76 Inservice Inspection 12/27/77
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Mechanical and Electrical 12/19/77 12/10/76 Maintenance Modifications 12/6/77 12/17/76 00A Activities 12/5/77 12/5/76 LER Corrective Action 11/30/77
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Seven of the eight audits most recently performed to collectively satisfy the subject Technical Specification were conducted between eight and twelve months prior to this inspection. These audits had been previously performed between nine and twelve months prior to their most recent performance.
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Failure to perform the audits required by Technical Specification 6.5.2.8.c at least once per six months is an infraction level item of noncompliance (277/78-25-02; 278/78-30-02).
6.
IE Bulletin Followup IE Bulletin 78-03, " Potential Explosive Gas Mixture Accumulations Associated with BWR Offgas System Operations."
The licensee's response to Bulletin 78-03 was reviewed.
Inspection confirmed that licensee management had forwarded copies of the Bul-letin response to appropriate management representatives, that PORC had reviewed this matter, and that the response was submitted to the NRC within the required time frame.
The inspector reviewed SIL No.150, " Prevention of Offgas System Detonations." PORC review was conducted and indicated that adequate ventilation flow was available to dilute to less than 4%.by volume, thus maintaining any buildup of hydrogen to below the flammability limit. The licensee determined that drains should not be re-routed, in that, any airoorne radioactivity
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caused by an offgas leak ~or blown loop seal would constitute the first mechanism for detection and provide a mechanism available to isolate any leak into a plant area. System inspection indicated that no color coding was provided to identify specific hazards associated with the offgas system. This item will be reviewed further during a subsequent inspection. The inspector also re-viewed Procedure OT ll, " Explosion - Air Ejector Discharger,"
Revision 2, and Procedure A-12. " Ignition Source Control," and verified that measures were in place to minimize potential for and mitigate consequences of such an explosion should it occur. The licensee's response further stated that the recombiner bypass line provided in the original design, will not be used (78-25-03; 78-30-03).
7.
Unresolved Items Unresolved items are those items for which more information is needed to verify acceptability.
Detail 4 contains an unresolved item.
8.
Exit Interview An exit interview was conducted on September 1,1978, with licensee representatives (denoted in Detai1~ 1) at the conclusion.of the in-spection. The inspector summarized the purpose and scope of the inspection and the findings. A subsequent exit interview was con-ducted at the corporate offices on September 13, 1978. Licensee representatives acknowledged inspection findings.
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