IR 05000277/1980005

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IE Insp Repts 50-277/80-05 & 50-278/80-05 on 800301-31. Noncompliance Noted:Failure to Follow Fuel Receipt Insp Procedures & Failure to Wear Personnel Dosimetry.Portions Withheld (Ref 10CFR2.790)
ML20003A740
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 06/27/1980
From: Blough A, Cowgill C, Greenman E, Mccabe E, Troskoski W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20003A737 List:
References
50-277-80-05, 50-277-80-5, 50-278-80-05, 50-278-80-5, NUDOCS 8102050843
Download: ML20003A740 (21)


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O u.S. NuCtEAa Recut 4T0av COMM1SSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-277/80-05 Report No. 50-278/80-05 50-277 Docket No.

50-278 DPR-44 C

License No. DPR-56 Priority Category C

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Licensee:

Phildelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:

Peach Bottom Atomic Power Station Units 2 and 3 Inspection at:

Delta, Pennsylvania Inspection conduc*=d-March 1-31, 1.980 Inspectors:

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MM6N Cowgi I, Resident Reactor Inspector V Tjate signed

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c,I nieo A. R. Blough, Resident Reactor Inspector date signed f%tQ,g cluit.

E. G. Greenman, Resident Reactor Inspector date signed Other Accompanying MAM4 - fL

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Personnel:

W. M. Iroskoski, Reactor Inspector date sig'ned Aaproved by:

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._E. C. McCabe, Jr., Chief, Reactor Projects date signed

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Section No. 2, RO&NS Branch Inspection Summary:

Inspection on March 1-31, 1980 (Combined Inspection Report Nos. 50-277/80-05 and 50-278/80-05)

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Areas Inspected:

Routine, onsite regular and backshift inspection by the resident inspectors (49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br /> Unit 2; 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> Unit 3). Areas inspected included preparations i

for a refueling outage, accessible portions of the Unit 2 and Unit 3 facilities, radiation protection, maintenance activities, physical security, plant operations, facility tours, control room inspection, followup on previously identified items, implementation of Three Mile Island Lessons Learned requirements, Bulletin and Information Notice followup, and review of periodic and special reports.

Results: Noncompliances - None in eight areas, four in four areas (Infraction -

failure to follow fuel receipt inspection procedures, Detail 4; infraction - failure j

tc wear personnel dosimetry, Detail 6; infraction - failure to adhere to escort requirements, Detail 9; and infraction - failure to establish written procedures, Detail 3).

Region I Form 12 (Rev. April 77)

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Persons Contacted C. E. Andersen, Operations Er.gineer W. H. Barley, Health Physics Supervisor V. S. Boyer, Senior Vice President Nuclear

  • R. S. Fleischmann, Assistant Station Superintendent C. F. Lauletta, Training Coordinator F. W. Polaski, Reactor Engineer S. R. Roberts, Results Engineer R. J. Scholz, Chemistry Supervisor J. Spencer, Maintenance Engineer S. Q. Tharpe, Security Supervisor
  • W. T. Ullrich, Station Superintendent A. J. Wasong, Test Engineer J. E. Winzenried, Technical Engineer Other licensee employees were also contacted during the inspection.
  • present at exit interviews and for swunation of preliminary inspection findings.

2.

Previous Inspection Item Update (0 pen) Infraction (79-28-01 and 79-31-01) - Failure to review contents of all abnormal and emergency procedures by licensed operators. The licensee has initiated the required review and is proceeding with the review on a schedule which should complete assignment of the procedures as required reading for all licensed operators by July,1980 and completion of the reading assignments and documentation a few months thereafter. This item remains open pending inspector verification of completion of the assigned reading by all licensed operators.

(0 pen)UnresolvedItem(79-29-01) and update Inspection 278/78-34 - In-strumentation and Control Problems related to Control Room Alarms, alarm malfunctions and erroneous indication.

Progress has been made towards resolving this problem and the number of alarms has decreased.

Resolution is incomplete. As of this inspection, only 4 of nine additional instrument technicians authorized to be hired by the licensee and who meet ANSI N18.7-1971 are on the staff. The licensee has 27 instrument technicians on site fulltime supporting I&C activites for Unit 2 and Unit 3.

In 1978 23 tech-nicians were available.

(Detail 2)

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3.

Plant Operations Review a.

Logs 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 comuni-cations concerning equipment operating an'd lock-out status; and to verify conformance to limiting conditions for operations.

Logs and records reviewed were:

(a)

Shift Supervision Log, March 1 - March 31, MSJ (b) Reactor Operations Log Book Unit 2, March 1 - March 31,1980 (c)

Reactor Operations Log Book Unit 1, March 1 - March 31,1980 (d) ACO Log Book, March 1 - March 31, 1980 (e) Maintenance Request Fonn (MRFs) - Unit 2 (f) Plant Record Sheets - Sampling Audit (g) Night Orders - Current Entries (h) Surveillance Test Results - Selected Sample (i) Radiation Work Pennits - Various in both Unit 2 and Unit 3 (j)

Ignition Source Control Check Sheets - Various in both Unit 2 and Unit 3 (k) Fire System Status Sheets (Sampling) - March,1980 (1)

Refueling Floor Log Unit 2 (Sampling) - March, 1980 (m) Refueling Floor Fuel Status Board The control room logs were reviewed against requirements of Pro-cedure A-7, revision 11, dated December 20, 1979, " Shift Opera-tions".

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

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

No unacceptable con-ditions were identified.

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

Control Room - (daily)

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Unit 2 Refuel Floor

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Turbine Building

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Reactor Building

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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 SAS, Aux SAS, and control

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points to the power block Security Fencing

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Lighting

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Vehicular Control

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Badging and Escorting

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Portal Monitoring

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Control of Radiation and High Radiation Areas

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Personnel

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Off-shift inspections during this inspection and areas

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examined were as follows:

March 3, 1980, Control Room observations

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March 4, 1980, Control Room observations and security

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measures

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March 5,1980, Control Room observations

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March 6,1980, Control Room observations

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March 7, 1980 Licensee compliance with procedures and

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license conditions for radioactive waste processing (Detail 2.c)

March 10,1980, Control Room observations

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March 11, 1980, Control Room observations

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March 12, 1980, Control Room observations

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March 13, 1980, Control Room observations

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March 14,1980, Unit 3 Startup Control Room

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March 18, 1980. Control Room observations

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March 19, 1980, Control Room observations

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March 20, 1980, Control Room observations

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March 21, 1980, Control Room observations

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March 26, 1980, Control Room observations

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March 27, 1980, Control Room observations

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March 28, 1980, Control Room observations

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During routine facility tours, the following observations were made by the inspector:

Off-Normal Alarms.

Selected annunciators were dis-

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cussed with control room operators and supervision to assure they were knowledgeable of plant conditions and that corrective action, if required, was being taken.

Examples of specific alarms discussed during the report period were: APRM High; Rod Withdrawal Block; Standby Liquid or Pipe Hi-Lo Tenperature; Condensate Storage Tank High-Low Level; and Radwaste Tank Level High.

The operators were knowledgeable of alarm status and existing plant conditions. Additionally, the inspector reviewed the licensee's progress in eliminating lit annunciators and maintaining a valid alarm status. The current Control Room Annunciator and Instrument Status indicated the following:

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ANNUNCIATOR AND INSTRUMENT /

PROBLEM DESCRIPTION RESOLUTION--

PANEL Main Steam Line Leakage Alam up for no apparent Need Modifica-(20C205L)

reason tion to delete

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alarm A Cooling Tower Lift Pump Wet pit is drained for Screens Hi Dif. Pressure Pump Maintenance (20C212L)

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B Drywell Fan Failure Fan is running but alarm Outage Required-(20C212R)

is up Unit 2 outage is in progress Regenerative Heat Exch.

Reading Downscale Further investi-Inlet Pressure gation required (20C04A)

LPRM Meter Dim light display (20C05A)

A, B, & C Condensate Pump Alam will not clear Vibration mod Hi Vibration has not been (20C207L)

completed Condensate Storage Tank Alam will not reset Further investi-Hi-Lo Level gation required (20C207L)

CR 2-12-132 Cleanup Inlet Recorder spiking Further investi-Conductivity gation required (20C04A)

CR 2-12-135 Cleanup Outlet Recorder spiking Further investi-Conductivity gation required (20C04A)

A Recirc Pump Seal Alam will not reset Further investi-Stage 2 Hi-Lo Flow gation required (20C205L)

Cleanup Non-Regen Heat Calibrate TS

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Exch. Outlet Hi Temp 2-12-115 (20C204R)

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A Cleanup Recirc Pump Alarm should be up when Relocate switches to Flow pump is not running out of hi rad (20C204R)

areas B Cleanup Recirc Pump Alarm will not clear lo Flow when pump runs (20C204R)

Computer MG Set MG set trips on start.

Trouble A&B recirc MG sets / bad (20C209R)

brushes on D.C. motor Off-Gas Recombiner Diff-Alarm will not clear Calibrate erential Temp Hi-Lo (Unit 200C196)

Hold-Up Pipe Hi-Lo Alam up, flow normal Calibrate Pressure (Unit 2 00C196)

SJAE A Discharge Pressur.e Alam will not clear Calibrate Hi-Lo (00C196)

SJAE B Discharge Pressure Alarm will not clear Calibrate Hi-Lo (00C196)

Cin-up non regen. heat exch.

Alam up.

Outlet Temp Calibrate TS-outlet Hi Temp approx. 100 deg. F 3-12-115 (30C204R)

Main Steam Line Leakage Alarm up for no apparent Need modifica-(30C205L)

reason tion to detete this alarm A,B,C, Cond. Pump Hi Only 2 of 6 probes Modification not Vibration reading properly yet complete (30C207L)

LI-3914 Sup. Pool Level Reading Low Calibrate (30C03-4)

B Recirc Pump Motor Seal Alarm will not clear Calibrate FS-3-Stage 2 Hi-Lo Flow 2-26B (30C204M)

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F D/W Cooler Air Hi Temp Temp normal. Alarm wili Further investi-(30C212R)

not clear gation required Gen. Stator Clg. Water Hi Temp nomal. Alam will Further investi-Temp.

not clear gation required (30C208R)

TR-3-02-3-089 Rx Vessel Skin Recorder reading low Calibrate Temps (30C21)

MG Supply Fan 2A-BV44 Low TS-20425 will not reset Repair or Replace Air Temp TS-20425 (00C133)

MG Supply Fan 2A-BV 44 Low TS-30425 will not reset Repair or replace Air Temp TS-30425 (00Cl33)

Xl-5885 Reads downscale Shaft Voltage Test (30C088)

LR-5805 Reads high Calibrate Suppression Pool Level Recorder (30C03-3)

FR-3522 Drywell Reads 6 SCFM with Calibrate Nitgrogen Makeup Flow system shutdown (30C03-3)

A Recirc Pump-Motor Alarm up level nomal Oil Hi Level Off-Gas Recombiner DTR 5025 Differential Temp Hi-La (00C196)

SJAE B Discharge Alam will not clear Calibrate Pressure Hi-Lo (Unit 3 00C196)

Holdup Pipe Hi-Lo Alam up, pressure no.wl Calibrate Pressure (Unit 3 00C196)

Off-Gas Holdup Pipe Alam up, flow normal Calibrate Low Flow (Unit 3)

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March 14,1980, Unit 3 Startup. During off-shift

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inspection on March 14, 1980, the inspector observed portions of a Unit 3 reactor startup following an outage recovery.

The startup was observed from sub-

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criticality to the point at which heat was being added to the reactor coolant system. The inspector verified that the startup was being conducted in accordance with approved station procedures and observed step by step

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operations.

GP-2, " Normal Plant Startup", revision 19, dated November 11,1979; and GP-2A, '.' Reactor Startup and Heatup", revision 12, dated September 10, 1979 and the Technical Specifications were used as a basis for acceptability. The inspector also observed that:

the reactor operator monitored neutron level and reactor period instrwnentation closely; the reactor operator did not exceed a reactor period of 30 seconds as re-quired by startup procedures; reactor coolant tempera-ture was recorded every 15 minutes to meet heatup limitations described in Section 3.6.1 of the Technical Specifications; and the reactor operator paused at a neutron level of 10,000 cps to record data as required by Proceoure GP-2A. Staffing requirements were also verified for licensed irdividuals in the control room.

The observed portions of the startup were conducted in a safe and professional manner.

No unacceptable condi-tions were identified.

Control Room Manning. On frequent occasions during

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this inspection, the inspector confirmed that require-ments of 10 CFR 50.54(k) and the Technical Specifica-tions for minimum staffing requirements were satisfied.

No unacceptable conditions were identified.

Fluid Leaks.

No significant fluid leaks were identi-

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fied which had not also been identified by the licensee nor for which necessary corrective action had not been inititated. The inspector observed sump status, alarms, pump-out rates, and held discussions with licensee personnel.

The licensee reviewed sea' leakage on a Unit 2 feedwater pump.

No unacceptable conditions were identified.

Piping Vibration.

No significant piping vibration or

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unusual conditions were identified.

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Monitoring Instrumentation. The inspector frequently i

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confirmed that selected instruments were operating and indicated values were within Technical Specification requirenents. On a daily basis when the inspector was

on site, ECCS switch positioning and valve lineups, based on control room indicators and plant observations were 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.

b.

Reactor Water Chemistry The following surveillance tests for the periods indicated were re-viewed by the inspector to assure that Technical Specification Limits-were satisfied.

(2) Conductivity and Chloride Ion Content in Primary Coolant Surveillance Tests 7.2.3.A and 7.2.3.C and Peach Bottom Daily BWR Chemistry Analysis - March 1-30, 1980.

Technical Specification 3.6.B requires prior to startup and when operating at rated pressure,. reactor water conductivity at 25 C

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of less than or. equal-to 5.0 umho/cm and chloride concentration less than or equal to 0.2 ppm.

Reactor water quality may exceed these limits for up to two weeks per year. Maximum limite are established as 10 umho/cm conductivity and 1.0 ppm chlorides.

Inspections at Unit 2, for the report period, indicated that con-ductivity was maintained less than the 5 umho/cm limit throughout all periods of operation. Chlorides exceeded.2 ppm for 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> during the month with a maximum value of.43 ppm. Through March, the 1980 total time above the.2 ppm chlorides limits and the 5.0 umho/cm conductivity limits are 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> respec-tively.

Inspections at Unit 3 for the period, indicated that, during operation, the maximum conductivity and chloride concentrations reached.were 0.93 umho/cm and.055 ppm respectively.

Through March, no time above the specified "two weeks per year" limits has been accumulated.- No unacceptable conditions were.identi-fied.

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(3) Detemination of Dose Eouivalent Microcuries/ Gram I-131 in the Primary Coolant Surveillance Test 7.2.1.A was reviewed.

The licensee analyzes the following nuclides:

I-131, I-132, I-133, I-134, and I-135 and computes dose equivalent I-131 -- that amount of I-131 which alone would produce the same dose as the quanity and isotopic mixture actually present. The Technical Specification Limit is 2.0 microcuries per gram.

Increased sampling frequency is re-quired if any analysis exceeds 0.02 microcuries per gram. The representativesampleforUnit2,analyzedonMarch11,19g0, indicated a dose equivalent I-131 concentration of 4.5x10-microcuries per gram. At Unit 3, a sample on March 10, 1980 indicated a dose equivalence of 3.0x10-3 microcuries per gram.

The inspector also confimed that the required surveillance frequency was being satisfied.

No unacceptable conditions were

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Radioactive Waste Processing Evaluations On March 7, 1980, during a review of plant conditions and operations in progress the inspector determined that the licensee had placed the liquid radwaste filter out-of-service and was processing liquid rad-waste using an alternate path via the fuel pool cooling system de-mineralizer. The path was utilized to prevent buildup of excessive liquid radioactive waste inventories.

The operations were being supervised by engineers on the technical staff. These operations are required by Technical Specifications and Regulatory Guide 1.33 (November 1972) to be covered by approved written procedures.

The inspector detemined that no procedure covering these operations had been reviewed by the PORC, approved by the Station Superintendent and issued for implement action as of March 7,1980 when this operation was in progress. The licensee stated that this same evolution had been conducted previously, however, a fomal pro-cedure had been delayed pending a decision on the most effective method of accomplishing the evolution.

Further 'nspection in this area indicated that this use of the fuel pool coeling system demineralizer, the principal alternate path of procesdng liquid radwaste when the liquid radwaste filter is out-of-service, had been listed in the index of procedures during initial development of PBAPS BWR operating procedure, however, the actual procedure had not been implemented. This failure to establish, imple-ment and maintain written procedures is contrary to Technical Specifi-cations Section 6.8 and constitutes an item of noncompliance (80-05-01 and 80-05-01). This is a recurrent item of noncompliance in that a

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similar example of failure to establish, implement and maintain written procedures was reported in Combined Inspection 50-277/80-04 and 50-277/80-04, wherein a round sheet used in adminstrative control of a seismically qualified nitrogen supply to containment venti'ation valves had been used without incorporation to system procedures.

(80-04-04 and 80-01-07)

4.

Licensee Refueling Preparations - Unit 2 The inspector reviewed and observed aspects of new fuel receipt and re-fueling preparations to verify compliance with regulatory requirements and approved procedures.

a.

New Fuel Receipt (1) Procedures Reviewed The inspector reviewed the following licensee documents to verify that properly reviewed and technically adequate procedures were available for the receipt, inspection, and storage of new fuel.

FH-1, " Receipt of New BWR Fuel", revision 3, dated July 18,

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FH-5, "New Fuel Inspection, Channeling, and Placement in the

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Fuel Pool", revision 17, dated January 11, 1980.

FH-5, Appendix B " Inspection Plan", revision 8., dated July

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19, 1978.

FH-6C, " Fuel Movement and Core Alterations Procedure During

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a Fuel Handling Outage", revision 9, dated January 14, 1980.

Additionally, the inspector reviewed procedures and check-off lists related to the receipt and inspection of fuel assemblies and irradiated and unirradiated fuel channels to verify that acceptance criteria had been satisfied. Twelve of the check-off sheets reviewed contained inadequacies that included:

(a) No documentation that new fuel channels had been checked for-fastener and channel gap as required per step 20.

(b) No documentation that irradiated channels were "Go-No-Go" capscrew tested per step 19.

The check-off sheets containing these inadequacies had been verified as properly completed by the fuel inspector and had also been accepted by the QC inspector. The licensee when apprised of these findings was unable to determine if the undocumented steps had been perfonned. As a result the licensee subsequently

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audited all FH-5, Appendix B, Attachment B check-off sheets, and determined that re-inspection of 20 fuel bundles was required.

This failure to properly follow fuel inspection procedures is contrary to the Technical Specifications, Section 6.8 and con-stitutes an item of noncompliance (277/80-05-02).

b.

Refueling Preparations (1) Procedures Reviewed The following procedures concerning refueling activities were reviewed and technical adequacy and to verify that they had been properly reviewed and approved by the licensee.

x (a) Fuel Handling, Transfers, and Core Verifications FH-5, "New Fuel Inspection, Channeling, and Placement

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in the Fuel Pool", revision 17, dated January 11, 1980.

FH-6C, " Fuel Movement and Core Alterations Procedure

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During a Fuel Handling Outage", revision 9, dated January 14, 1980.

FH-12, " Core Post-Alteration Verification", revision 2,

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dated June 4, 1976.

(b) Handling and Inspection of Other Core Internals

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FH-10, "New Channel Inspection", revision 2, dated

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Feburary 17, 1976.

FH-10A, "New Channel Fastener Receiving Inspection",

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revision 1, dated January 8, 1976.

FH-15, " Fuel Bundle Inspection and Criteria for Bundle

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Associated with Perforated Channels", revision 1, dated January 5, 1976.

No inadequacies in the technical content of procedures was identified.

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14 (2) Core Reload Review The inspector determined that the licensee has submitted a pro-posed core reload Technical Specification change to the Office of Nuclear Reactor Regulation (NRR) Reload 3-Cycle 4.

RRI dis-cussion with the NRR project manager confimed receipt by the NRC.

(3) Observations The inspector observed pre-refueling work over the refueling bridge.

Items inspected included:

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Pre-fuel handling surveillance testing; (b)

Radiation Work Permit adherence;

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Radiation monitoring practices; (d) Area housekeeping acceptability; (e) Maintenance of secondary containment integrity; (f) Use of properly qualified operators; (g) Control of loose materials over the vessel.

No unacieptable conditions were identified.

5.

IE Bulletin /Circriar/Infomation Notice Followup

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IE Inf'; tion Notice 80-06, " Notification of Significant Events"

~.ormation Notice 80-06, issued on February 27, 1980, contained an MC Notice of Rule Making. The new regulation (10 CFR 50.72) became effective on February 29, 1980 and required license holders to report certain events to the NRC Operations Center within one hour cf occur-rence.

Prior information had also been provided to the licensee by the RRI regarding 10 CFR 50.72, which had been implemented prior to February 29, 1980 through instructions to operating shift personnel from the Station Superintendent.

The inspector reviewed administra-tive procedure A-31, " Procedure for Prompt Notification of NRC",

revision 3, dated March 4, 1980 and determined that it requires shift supervision to notify the NRC Operations Center Duty Officer via the OPX network within one hour following the occurrence of:

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(1) Any event requiring initiation of the licensee's emergency plan or any section of that plan.

(2) The exceeding of any Technical Specification Safety Limit.

(3) Any event that results in the nuclear power plant not being in a controlled or expected condition while operating or shutdown.

(4) Any act that threatens the safety of the nuclear power plant or site personnel, or the security of special nuclear material, including instances of sabotage or attempted sabotage.

t (5) Any event requiring initiation of shutdown of the nuclear power plant in accordance with Technical Specification Limiting Condi-tions for Operations.

(6)

Personnel error or procedural inadequacy which, during nomal operations, anticipated operational occurrences, or accident conditions, prevents or could prevent, by itself, the fulfillment of the safety function of those structures, systems, and components important to safety that are needed to (i) shutdown the reacter safely and maintain it in a safe shutdown condition, or (ii)

remove residual heat following reactor shutdown, or (iii) limit the release of radioactive material to acceptable levels or reduce the potential for such releasc.

(7) Any event resulting in manual or automatic actuation of Engineered Safety Features, including the Reaccor Protection System.

(8) Any accidental, unplanned, or uncoatrolled radioactive release.

(Nomal or expected releases from maintenance or other opera-tional activites are not included).

(9) Any fatality or serious injury occurring on the site and requiring transport to an offsite medical facility for treatment.

(10) Any serious personnel radioactive contamination requiring ex-tensive onsite decontamination or outside assistance.

(11) Any event meeting the criteria of 10 CFR 20.403 for actification.

(12) Strikes of operating employees or security guards, or honoring of picket lines by these employee,

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The procedure requires shift supervision to identify, to the NRC Duty Officer, the fact that a report is being made pursuant to 10 CFR 50.72 and, for items (1) thru (4) above, to maintain an open and continuous communications channel.

The inspector verified

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that the previsions of the licensee procedure are adequate to properly implement the requirements of 10 CFR 50.72.

No unacceptable conditions were identified.

b.

IE Bulletin 80-04, " Analysis of a PWR Main Stream Line Break With Continued Feedwater Addition" This Bulletin was issued to Boiling Water Reactor License holders for information.

No response or action on the part of the only licensee was required. The inspector has no further questions regarding IE Bulletin 80-04 c.

IE Bulletin 80-05, " Vacuum Condition Resulting in Damage to Chemical Volume Control System (CVCS)"

This Bulletin was issued on March 10, 1980 and is r.ot applicable to Boiling Water Reactor License holders.

No response or action on the part of the licensee was required.

The inspector had no further questions concerning IE Bulletin S0-05.

6.

Radiation Protection During this report period, the inspector examined work in progress in accessible areas of the Unit 2 and Unit 3 facilities. Areas examined included:

a.

Health Physics (HP) controls b.

Badging c.

Usage of protective clothing d.

Personnel adherence to RWP requirements e.

Surveys f.

Handling of potentially contaminated equipment and materials Additonally, inspections were conducted of employee usage of friskers and portal monitors by personnel exiting various RWP areas, the power block, and the licensee's final exit point of the security building.

In excess of 20 people were observed to meet frisking requirements as contained in HP procedures during the month. A sampling of high radiation doors was verified to be locked as required.

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On March 21,1980, at the 165' level in the Unit 3 turbine building, the inspector observed work being conducted in an area controlled by RWD 3-94-0057.

The nature of the work in the area was the dismantling of a feedwater heater. One individual was observed in the area at about 2:45 PM, not wearing his personnel dosimetry. Upon this discovery, he imedi-ately had his dosimetry passed to him by ancther licensee employee.

Health Physics procedure HP0/CO-10A, " Conduct in Controlled Areas - Mini-mize Exposure", requires that personnel always wear the dosimetry provided.

This failure to wear provided dosimetry in a controlled area constitutes an item of noncompliance (80-05-02) as required by HP0/CO-10A and RWP No.

3-94-0057.

7.

Review of Small Break Loss of Coolant Accident (SBLOCA) Procedures The inspector reviewed the licensee's implementation of modified SBLOCA procedures to verify timely and effective accomplishment based on NRC staff

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reviews of the accident at Three Mile Island.

Additionally, the inspector reviewed training in the procedural changes provided to the individual licensed operators.

a.

Review of Procedures.

In anticipation of new requirements resulting from NRC staff reviews of the Three Mile Island accident, General Electric submitted, for NRC staff review, SBLOCA analyses and guide-lines for operator actions. The NRC approved the guidelines and required licensee implementation by December 31, 1979. The inspector reviewed licensee procedures for timely implementation, general conformance to the guidelines, procedure clarity, in terms of actions and precautions, and flow of the procedures with respect to timely initiation of all operator actions.

Emergency Procedures E-2, " Main Steam Line Break - Outside the Dry-well, revision 3, dated March 19, 1980; E-3, "Small Line Break - Out-side the Drywell", revision 0, dated December 10, 1979; and E-25,

"Small Break - Loss of Coolant Accident (Inside the Drywell)", revision 0, dated Decomber 3, 1979 were reviewed in detail.

Findings were as follows:

(1) The procedures, in general, are consistent.with the guidelines, have sufficient clarity, and provide for accomplishment of actions in an acceptable time frame.

(2) Small Break Inside the Drywell Subsequent Operation Actions - Section 4.1 of the General Electric Guidelines (NEDO - 24708) describes measures to prevent flooding the steam lines while maintaining Reactor Vessel level in the normal range. Licensee emergency procedure E-25, page 9, provides the option to allow filling of the main steam line and flooding the reactor vesse.

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e

The inspector discussed the above difference with a senior licensee representative who stated that by flooding the main steam lines and operating the associated relief valves, an additional cooling path was available.

He further stated that this condition allowed the operator more flexibility because reactor level control was not restricted.

The difference between NED0 document 24708 and the procedure E-25 regarding flooding of the vessel is considered unresolved pending further NRC review (80-05-01 and 80-05-03).

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(3)

Part of the immediate actions of the GE Guidelines for a Pipe Break Outside the Containment involves noting, when all isolation valves in the suspected broken system are closed, that area symptoms (high temperature and high radiation) decrease.

This could be an indication of successful leak isolation.

Licensee procedures E-2 and E-3 for line breaks outside the containment do not contain this provision for monitoring area a

symptoms. The licensee has acknowledged the inadequacy and has prepared a change to each procedure.

This matter is considered unresolved pending inspector review of required changes (80-05-04 and 80-05-04).

b.

Training.

The inspector reviewed the training received by licensed operators regarding SBLOCA procedures. Training sessions were con-ducted by the Technical Engineer and a senior Test Engineer, both of whom hold senior operators licenses.

The inspector verified, through review of attendance list signatures, that each individual possessing an operator's license or a senior operator's license attended one of the sessions, which were conducted on December 5, 7, 10, 12, 13, 21, 24, 26, and 31, 1979. The inspector verified that SBLOCA procedures had been incorporated into the annual walk-throughs of emergency procedures conducted by each licensed operator and senior licensed operator in the presence of a supervisor.

No unacceptable conditions were identified.

c.

Systems Considerations

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(1)

Instrumentation The inspector reviewed the instrumentation needed to carry out operator actions in the SBLOCA procedure.

The instrumentation for each action was verified to ensure that redundant instru-mentation existed and that emergency power sources were available for the subject instrumentatio _. _ _

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The inspector identified, through discussions with the licensee and verification of licensee Piping and Instrument Diagrams, that environmental effects, power supplies (with loss of off-site power and single failure in one instrument bus) and redundancy were considered. The instruments verified were reactor vessel level, condensate storage tank low level alam sensors and read-outs, suppression pool temperature and level, and reactor vessel pressure. No unacceptable conditions were identified.

(2) Containment Isolation As a result of the accident at Three Mile Island, NRC conducted indepth inspections at licensed facilities and issued Bulletin 79-08 which included a requirement to ensure that non-essential lines penetrating containment were isolated in accident condi-tions.

NRC Combined Inspection 50-277/79-11 and 50-278/79-12 and NRC staff evaluation of the Philadelphia Electric Company responses to IE Bulletin 79-08 for Peach Bottom Atomic Power Station, Units 2 and 3 discussed the' issue of containment isolation at Peach Bottom. No additional unresolved items were identified.

8.

In-Office Review of Monthly Operating Reports The following licensee report has been reviewed in-office onsite:

Peach Bottom Atomic Power Station Monthly Operating Report for February,1980 (dated March 10,1980).

This report was reviewed pursuant to Technical Specifications and verified to detemine that operating statistics had been accurately reported and that narrative sumaries of the month's operating experience were contained therein. No unacceptable conditions were identified.

9.

Physical Security The inspector verified compliance with areas of the Accepted Security Plan and implementing security procedures during periodic spot-checks (reference Detail 3). These included observation of operations of the CAS and SAS, over 50 spot-checks of vehicles onsite to verify proper license controls, observation of protected area access and badging procedure conduct on each shift, inspection of physical barriers, checks on control of access to tne vital areas, and escort procedure _ _. __. _ __ _. ___. _ _ _ _ _ _. _ - _. _ - _ _ - _... _ - _

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10. Unresolved Items Unresolved items are items about which more information is required to detennine whether they are acceptable items, items of noncompliance, or deviations. Two Unresolved items are discussed in Detail 7.

11. Management Meetings a.

Preliminary Inspection Findings During the period of this inspection, licensee management was per.iodi-cally notified of the preliminary findings by the resident inspectors (referenced Detail 1). A summary of preliminary findings was provided to the licensee at the conclusion of the inspection and prior to report issuance. The dates the licensee was apprised of preliminary findings, the senior licensee representative contacted, and subjects discussed were as follows:

Senior Licensee Representative Date Subject Present March 4, 1980 Radioactive Waste Prncessing (Detail 3)

C. E. Andersen March 7, 1980 Fuel Receipt Inspections (Detail 4)

R. S. Fleischmann March 13, 1980 Physical Security (Detail 9)

W. T. Ullrich March 21, 1980 Work in RWP Areas (Detail 6)

W. T. Ullrich March 31, 1980 Summary of Preliminary Findings W. T. Ullrich b.

Attendance at Management Meetings Conducted by Region-Based Inspectors The resident inspectors attended entrance and exit interviews by region-based inspectorsas follows:

Inspection Reporting Date Subject Report No Inspector March 28, 1980 Refueling Inspection 50-277/80-07 L. Bettenhausen Entrance Interview