IR 05000277/1979026

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IE Insp Repts 50-277/79-26 & 50-278/79-28 on 791001-31. Noncompliance Noted:Conducting Refueling Operations W/O Having Mode Switch Locked in Refuel
ML19294B402
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 01/09/1980
From: Greenman E, Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19294B392 List:
References
05-278-79-28, 5-278-79-28, 50-277-79-26, NUDOCS 8002280304
Download: ML19294B402 (10)


Text

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-277/79-26 Report No.

50-278/79-28 50-277 Docket No.

50-278 DPR-44 C

License No.

DPR-56 Priority Category C

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Licensee:

Philadelphia Electric Company 2301 Market Street Philadelohia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station Units 2 and 3 Inspection at: Delta, Pennsylvania Inspection conducted: October 1 - October 31, 1979 Inspectors:

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/-4f-FC E. G. Greenman, Resident Reactor Inspector date signed date signed date signed Approved by:

0 0 MM,h I / 9 l 80 E. C. McCabe, Jr., Chief, Reactor Projects date signed Section No. 2, RO&NS Branch Inspection Summary:

Inspection on October 1 - October 31, 1979 (Combined Inspection Recort Nos. 50 'i77/79-26 and 50-278/79-28 Areas Inspected:

Routine, onsite and corporate office regular and backshift inspections by the resident inspector (58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> Unit 2; 59 hours6.828704e-4 days <br />0.0164 hours <br />9.755291e-5 weeks <br />2.24495e-5 months <br /> Unit 3).

Areas inspected included refueling activities, physical security, radiation protection for operations / refueling, plant operations, facility tours, control room inspection, LER review onsite, followup on previously identified unresolved items, organization and administration, review of periodic and special reports, and IE Bulletin / Circular followup.

Results:

Noncompliances - None in ten areas, one in one area.

(Deficiency - conducting refueling operations without having the mode switch locked in refuel, Detail 3).

Region I Form 12 (Rev. April 77)

8002280 3bf

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DETAILS 1.

Persons Contacted C. E. Andersen, Operations Engineer J. W. Austin, Project Engineer - Construction Division B. Clark, Senior Engineer - Nuclear Section

  • M. J. Cooney, Superintendent-Generation Division
  • R. S. Fleischmann, Assistant Station Superintendent E. C. Kistner, Chief Mechanical Engineer D. Marano, Supervising Engineer - Civil Section J. F. O'Rourke, Mechastical Engineering Division
  • W. T. Ullrich, Statior. Superintendent J. Winzenried, Technical Engineer Other licensee employees were contacted during the inspection.

These included engineering personnel, administrative personnel, reactor operators, shift supervision, maintenance personnel, contractor personnel, health physics and security personnel.

  • denotes those present at exit interviews on October 5 (corporate),

October 9 (site), and for summation of preliminary inspection monthly findings (reference Detail 9),

2.

Previous Inspection Item Update (Closed) Unresolved Item (277/77-38-03) - RHR Pump Foundation Cracks.

The inspector has reviewed enginearing evaluations indicating that cracking of the concrete cccurred due to an insufficient concrete cover around the four inch diameter sleeves.

The one and one half inch anchor bolts extend down past these sleeves into the slab below the foundation. The licensee's evaluation concludes that embedment of the anchor bolts is adequate to carry loads applied by the RHR pumps.

The inspector also reviewed the RHR pump uplift and shear loads per anchor bolt.

The licensee has performed additional inspections which indicate that conditions are unchanged and has recommended an annual followup inspection. The inspector had no further questions regarding this item.

3.

Plant Operations Review a.

Loos and Records 1.

Documents Reviewed A sampling review of logs and records was made to:

identify significant changes and trends; assure that required entries were being made; to verify that operating and night orders conform to Technical Specification requirements; check correctness of communications concerning equipment operating and lock-out status; verify jumper log conformance to proce-dural requirements; and to verify conformance to limiting conditions for operations.

Logs and records reviewed were:

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a.

Shift Supervision Log, October 1 - October 31, 1979 b.

Unit 2 Jumper Log - Current entries c.

Unit 3 Jumper Log - Current entries d.

Reactor Engineering Log - Unit 3 - Current entries e.

Reactor Operators Log Book Unit 2 - October 1 -

October 31, 1979 f.

Reactor Operators Log Book Unit 3 - October 1 -

October 31, 1979 g.

AC0 Log Book, October 1 - October 31, 1979 h.

Plant Record Sheets - Sampling Audit i. Maintenance Request Forms (MRFs) Unit 2 and Unit 3 -

Sampling Audit - October,1979 j.

Radiation Work Permits - various in both Unit 2 and Unit 3 during October, 1979 k.

Fire System Status Sheets (sampling) - October, 1979 1.

Night Orders - Current entries m.

Operations Work and Information Data - October, 1979 n.

Surveillance Test Results - Selected sample The control room logs were reviewed against requirements of procedure A-7, revision 10, dated October 10, 1979,

" Shift Operations".

Frequent initialing of entries by licensed operators, shift supervision, and licensee onsite management constituted evidence of licensee review.

Logs were also reviewed to assure that plant conditions including abnormalities and significant operations were accurately and completely recorded.

No unacceptable conditions were identified.

2.

Review of Control Room Operations Area of Ooerability Assianment The licensee via revision of A-7, dated October 10, 1979, has established the following guidelines and administrative requirements to be observed by control room operators:

a.

There are always to be at least two licensed operators in the main section of the control room (i.e., able to observe annunciators if they actuate).

b.

The Unit 2 AC0 is to remain within the following confines:

1.

The south end of the control room to the north end of the C0's console.

2.

East to west walls.

c.

The Unit 3 AC0 is to remain within the following confines:

1.

The north end of the control room to the south end of the C0's consol.

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2.

East to west walls, d.

The C0 has access to and need to observe operators anywhere in the control room including the recombiner and meteorological panels.

During periods of single unit transients or other unusual conditions, shift supervision may direct that the above guidelines be altered for safety.

The inspector held discussions with various operators regarding the area of responsibility.

This area is considered unresolved pending further review of east and west wall conditions versus operator's interface for personnel located in the main section of the control room (physical mobility limitations) and further clarification regarding the physical configuration of the C0 console and electrical panels.

The inspector noted that this procedure was currently under further review and revision (79-26-01 and 79-28-01).

3.

Facility Tours During the course of this inspection which also included backshifts, the inspector conducted daily tours and made observations of:

Control Room - (daily)

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Turbine Building - (all levels)

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Reactor Building - (accessible areas)

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Diesel Generator Building

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Yard area and perimeter exterior to the power block

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Security Building including CAS, SAS

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-- Auxiliary SAS and contr ' points inc!uding the power block

-- Maintenance Shop (hot area)

Security Fencing

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Lighting

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-- Vehicular Control Badging and Escorting

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-- Portal Monitoring Contrc' of Radiation and High Radiation Areas

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Personnel

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The following determinations were made by the inspector:

Refueling Activities (Unit 3). On October 8, 1979,

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ST 12.1, " Refueling Interlock Functional Test", was completed and refueling activities were conducted during the remainder of the afternoon shift, midnight shift, and into the day shift, October 9, 1979. On October 9, 1979, the mode switch was found in the

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refuel mode with the key in place and refueling oper-ations had been conducted.

The key appeared to have been left in the mode switch since 9:15 PM, October 8, 1979. The licensee immediately removed the key and it was returned to shift supervisior. The inspector also confirmed that numerous blocks and administrative controls were in place on usage of the mode switch prior to identification of this problem.

Technical Specification 3.10. A.1 requires that the mode switch shall be locked in the " Refuel" position during core al terations.

This failure to maintain the made switch locked during core alterations constitutes a deficiency level item of noncompliance (79-28-02).

The inspector confirmed that PORC reviewed and approved on October 11, 1979, a procedural change to ST 12.1, " Refueling Interlock Functional Test", which requires that if fuel handling is to be done, lock the reactor mode switch in refuel and return the key to shift supervision.

The licensee's evaluation and corrective action to preclude recurrence have been reviewed on site.

The licensee was in compliance on October 9, 1979 and prior to the conclusion of this inspection.

Consequently, no additional response is required.

Monitoring Instrumentation.

The inspector frequently

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confirmed that selected instruments were operational and indicated values were within Technical Specification limits.

On a daily basis when the inspector was on site,

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ECCS switch positioning and valve line-ups based on control room indicators and plant observations were verified.

In-plant instrumentation was also frequently verified.

Examples of instrumentation observed included flow setpoints, breaker positioning, PCIS status, nuclear instrumentation including verification of SRM minimum count requirements and SBLC parameters.

No unacceptable conditions were identified in this area of inspection.

Valve Pcsitioning.

The inspector indapendently verified

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that selected valves in safety related systems were maintained locked as required and were properly positioned.

System status of RCIC, ESW, Core Spray, and SBLC were checked.

The NRC, on October 19, 1979, issued Amendment No. 62 to License DPR-44 for Unit 2, which permitted continued operation of Unit 2 without performance of a pump flow rate capacity test on the A/C subsystem of the Core Spray System until January 3, 1980.

No unacceptable conditions were identifie ~

Plant Housekeeping and Fire Protection.

The inspector

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observed housekeeping conditions, fire hose station and equipment status, and observed the licensee's fire protection procedures and practices as well as the usage of firewatches.

The licensee's adherence to "no smoking" areas was also examined.

The Unit 3 outage as well as the number of contractor personnel on site was continuing to impact negatively on housekeeping conditions.

No specific unacceptable conditions were identified.

-- Fluid Leaks.

No significant fluid leaks were identified which had not also been identified by the licensee nor for which necessary corrective action had not been initiated.

The inspector also observed sump status, alarms, pump out rates, and held discussions with licensed personnel.

No unacceptable conditions were identified.

Piping Vibration.

No significant piping vibration or

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unusual conditions were identified.

Anchor plates, bolts, and seismic restraints as well

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as inspections conducted pursuant to IE Bulletins were observed.

No unusual or unreported conditions were identified.

-- Off Normal Alarms.

Selected annunciators were discussed with control room operators to verify that operators and supervision were knowledgeable of plant conditions and that corrective action, if required, was being taken.

Control Room Manning. On frequent occasions during

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this inspection, the inspector confirmed that require-ments of 10CFR50.54(k) and Technical Specifications for minimum staffing requirements were satisfied.

No unacceptable conditions were identified.

4.

Reactor Water Chemistry a.

Primary Coolant Sampling and Chemical Analysis The following surveillance tests for the periods as indicated were reviewed by the inspector to assure that Technical Specification limits were being satisfied.

b.

Conductivity and Chloride Ion Content in Primary Coolant During Normal Operation Surveillance Test 7.2.3.A and Peach Bottom Daily BWR Chemistry Analysis - October 1-28, 1979.

Inspection at Unit 2 confirmed that conductivity was being main-tained within a range of 0.15 to 0.23 micrombos/cm at 250C.

Technical Specification 3.6.B.2a requires

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conductivity to be maintained within a 5.0 micrombos/cm limit for an operating unit.

Unit 3 was shutdown for refueling throughout the period of inspection.

Chlorides parts per billion (ppb) for the time frames as referenced were verified less than 20 ppb at both Units 2 and 3.

Technical Specification limits are 0.2 parts per million.

c.

Determination of Dose Eouivalent Microcuries/ Grain I-131 in the Primary Coolant The licensee analyzes the following nuclides:

I-131, I-132, I-133, I-134, and I-135. Test data reviewed dated October, 1979 for Unit 2 indicated a totql microcuries/ml I-131 equivalence of 1.97 x 10-0 Unit 3 was shutdown for refueling throughout the period of inspection. The Technical Specification limit is 2.0 microcuries per gram whenever the reactor is critical.

No unacceptable conditions were identified.

d.

Analysis of the Time Reactor Water Chloride and Conductivity are Above Specified Limits Reactor water quality can exceed the five micrombos limit for two weeks per year.

Inspection of Peach Bottom Daily BWR Chemistry Analysis for Unit 2 during the period October 1-28 showed all conductivity measurements were within specifications.

Unit 3 was shutdown throughout the period.

Inspector review of procedure ST 7.2.3.C, " Analysis of the Time Reactor Water Chloride and Conductivity are Above Limits", will be incorporated into a subsequent report.

4.

IE Bulletin / Circular /Information Notice Followup a.

IE Bulletins Inspection was performed for the following IE Bulletins to verify that the Bulletin was received by site and corporate licensee management and to confirm that the licensee was complyir.g with Bulletin requirements. Additionally, inspections were conducted on October 5, 1979 at corporate engineering offices and supporting engineering evaluations were reviewed.

IE Bulletin 79-02, " Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts and Amendments Thereto"

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The inspector was apprised that the licensee would be unable to meet completion dates as described in a licensee letter to Region I dated August 7, 1979.

The licensee had been required to provide an expedited testing schedule for anchor bolts sufficient to support statements on system operability for each unit.

The status of the licensee's program, modifications for additional test inspection criteria, and program completion schedules were reviewed.

The licensee indicated that PECo would be able to meet the following schedule.

1.

Completion of all Unit 3 testing by October 27, 1979 and all Unit 2 testing by December 15, 1979.

2.

Upgrading of all Unit 3 base plate safety factors to above two before startup after the Unit 3 refueling outage currently in progress.

3.

Upgrading of all base plate safety factors to five or greater on Unit 3 by November 15, 1979 and on Unit 2 by January 12, 1980.

4.

Completion of all required hanger modifications on Unit 3 by November 17, 1979 and on Unit 2 by January 26, 1980.

5.

Installation of all new hangers required to relieve loads on existing hangers on Unit 3 by December 15, 1979 and on Unit 2 by February 16, 1980.

6.

Completion of a small pipe program for Unit 3 by December 15, 1979 and for Unit 2 by January 1,1980.

The inspector determined that for areas where the overall factor of safety as compared to ultimate strength was greater than two but less than original design that the licensee's program to upgrade was proceeding expeditiously.

Inspection findings for seismic qualification of any safety system piping or components will continue to be examined on a case by case basis until the 79-02 program is completed.

Confirmation of the licensee's commitments are contained in a letter from Region I to the Philadelphia Electric Company dated October 24, 1979.

The inspector further stated his understanding that all Unit 3 outstanding items would be furnished on site for NRC review prior to startup.

This area is unresolved pending review by the inspector to verify that the licensee has satisfied his commitments with respect to IEB 79-02 (79-26-02 and 79-28-03),

IE Bulletin 79-14, " Seismic Analyses for As-Built Safety Related Piping Systems and Supplements Thereto"

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Discussions were held with responsible licensee representatives to determine the licensee's existing schedule for evaluation and inspection.

IE Bulletin 79-14 specified completion within 120 days of the July 2,1979 Bulletin date.

The inspector reviewed the licensee's inspection results, which when extrapolated, indicated only a minimal number of nonconformances had or would be identified and that nonconformances identified to date did not affect system operability.

The licensee provided the following Bulletin completion schedule.

1.

All inaccessible Unit 3 checks will be completed during the current refueling outage.

2.

Checks of an addition 21 3,500 feet of accessible Unit 2 and Unit 3 piping will be completed within three weeks of the conclusion of the Unit 3 refueling outage or November 15, 1979, which ever occurs first.

3.

Unit 2 will be shutdown to complete inaccessible Unit 2 piping checks by March 1, 1980 or the checks will be completed during any outage of sufficient duration to provide access, which ever occurs first.

4.

The licensee will submit a report of program status to Region I by October 31, 1979 and a first programmatic report will be submitted to the NRC within 30 days of completing IEB 79-14 or by June 15, 1980, which ever occurs first.

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The inspector further stated that nonconformances would be examined on a case by case basis with respect to system operability.

These understandings were confirmed in a letter from Region I to the Philadelphia Electric Company dated October 24, 1979.

This area is unresolved pending program review and the licensee satisfying commitment requirements (79-26-03 and 79-28-04).

5.

Non-Routine Event Review The inspector reviewed the following non-routine events onsite and in the NRC site office for safety significance, circumstances, and relationship to Technical Specification protective limits.

The licensee's PORC review, evaluation, and corrective action was also veri fied.

LER Number Title 2-79-44-1P and 2-79-44/1T-0 IE Bulletin 79-02 inspection found one support associated with the Emergency Water System (ESW) where two bolts failed due to excessive shell projection.

Only one of these bolts, however, failed to meet torque requirement The licensee's calculated factor of safety for this hanger was 2.88.

The inspector confirmed that the involved ESW line was manually isolated. The licensee initiated a shutdown until repairs were completed.

The ESW was restored to normal and the shutdown was terminated.

6.

Oraanization and Administration Technical Specification 6.5.2.10 requires in part that minutes of the Operation and Safety Review Committee meetings shall be prepared, approved, and forwarded to the Vice President, Electric Production, within 14 days following each meeting.

Minutes of meetings as follows were reviewed:

Meeting No. 87, held May 4,1979 Meeting No. 88, held May 17, 1979 Meeting No. 89, held June 8, 1979 Meeting No. 90, held June 15, 1979 Review of corporate logs indicated that the minutes were forwarded to the required corporate official within 14 days.

No unacceptable conditions were identified.

7.

In-Office Review of Monthly Operating Reports The following licensee reports have been reviewed in office c site.

Peach Bottom Atomic Power Station Monthly Operating Report for:

September, 1979 dated October 10, 1979 This report was reviewed pursuant to Technical Specifications and verified to determine that operating statistics had been accurately reported and that narrative summaries of the month's operating experience were contained therein. Additionally, Peach Bottom Unit 3 refueling outage information was reviewed in detail.

No unacceptable conditions were identified.

8.

Unresolved Items Unresolved items are items about which more information is required to ascertain whether they are acceptable items, items of non-compliance, or deviations.

Unresolved items are discussed in Details 3 and 4.

9.

Presentation of Preliminary Findings During the period of the inspection, licensee management was periodically notified of the preliminary findings by the resident inspector (see Detail 1). A summary was also provided at the conclusion of the inspection and prior to report issuance.

The item of noncompliance was identified to site management on October 9, 1979.

Additionally, the resident inspector attended an exit interview conducted by a region-based inspector on November 1, 1979 (IE Combined Inspection Report Nos. 50-277/79-27 and 50-278/79-30).