IR 05000277/1980026

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IE Insp Repts 50-277/80-26 & 50-278/80-19 on 800724-28. Noncompliance Noted:Failure to Properly Post Radiologically Controlled Area & Failure to Issue Proper Dosimetric Devices
ML20003A742
Person / Time
Site: Peach Bottom  
Issue date: 08/14/1980
From: Caphton D, Rekito W, Wiggins J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20003A737 List:
References
50-277-80-26, 50-278-80-19, NUDOCS 8102050856
Download: ML20003A742 (8)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-277/80-26 50-278/80-19 Docket No. 50-277 50-278 License No. DPR-44 DPR-56 Priority Category C

Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

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Facility Name:

Peach Bottom Atomic Power Station Inspection at:

Delta, Pennsylvania Inspection conducted:

July 24, 1980 - uly 28, 1980 Inspectors:

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. Rekito, Reactor Inspector dat'e signed l JiA

&b J. Tj WigViiis or Inspector date signed N/

O Approved by:

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D. L. Caphton, Chief, Nuclet.r Support datesigned Section No. 1, Reactor Operations and Nuclear Support Branch Inspection Summary:

Inspection on July 24,1980 to My 28,1980 (Combined Report No.

50-277/80-26 and 50-278/80-19)

Areas Inspected:

Routine, unannounced inspection of containment integrated i

leak rate test activities (Unit 2 only); containment local leak rate test i

procedures (Unit 2 only) shutdown plant activities (Unit 2 only) and licensee action on previous inspection findings.

The inspection involved 54 inspector-hours (Unit 2 - 53 hours6.134259e-4 days <br />0.0147 hours <br />8.763227e-5 weeks <br />2.01665e-5 months <br />, Unit 3 -1 hour) onsite by two regional based inspectors.

Results:

Of the four areas inspected, no items of noncompliance or deviations were identified in three areas; two apparent items of noncompliance (deficiency, failure to properly post a radiologically controlled area - Paragraph 6; deficiency, failure to issue proper dosimetric devices - Paragraph 6) were identified in one area.

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DETAILS

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1.

Persons Contacted R. Blum, Bechtel Corporation M. Burgess, Bechtel Corporation J. Doering, Results Engineer N. Gazda, Health Physics Supervisor J. Maisler, Health Physicist J. Mitman, Test Engineer

  • S. Roberts, Results Engineer

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  • S. Spitko, Site QA Engineer
  • W. Ullrich, Station Superintendent H. Wilkerson, Bechtel Corporation NRC Personnel C. Cowgill, Senior Resident Inspector A. Blough, Resident Reactor Inspector The inspector also talked with and interviewed other licensee personnel during the inspection including members of the technical and health physics staffs.
  • Denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (277/80-21-01):

Incorporation of proper acceptance criteria into the Unit 2 Containment Integrated Leak Rate Test (CILRT) procedure.

The inspector reviewed procedure ST 12.5, Rev. 2 and found the acceptance criteria specified mass point analysis and provided for appropriate corrective adjustments.

This item is considered resolved.

(Closed) Unresolved Item (277/80-21-02):

The Unit 2 CILRT valve lineup for the drywell pressure transmitters isolated these devices and two valves were missing from the feedwater system valve lineup.

The inspector reviewed procedure ST 12.5, Rev. 2 used for performance of the 1980 Unit 2 tes'.

In this procedure, the drywell pressure transmitters were not isolated and were test pressure boundaries.

The two drain line valves were included in the feedwater system valve lineup.

This item is considered resolved.

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(Closed) Unresolved Item (277/80-21-03):

Chilled Water System - Drywell Cooling containment isolation valves ar not leak rate tested.

The inspector reviewed the local leak rate test procedure for testing the Chilled Water System isolatiori valves.

Further information is found in paragraph 4 of this report.

This item is considered resolved.

(0 pen) Unresolved Item (278/77-28-05):

Type B and C local leak rate test dates for penetrations N-231 A and B disagreed with the dates in the 1977 Unit 3 Technical Summary Report.

An amended version of the Unit 3 report was not available for review.

(0 pen) Unresolved Item (278/77-28-07):

Apparent inaccurate reporting of MSIV 808 leakage in the 1977 Unit 3 Technical Summary Report.

An Amended version of the 1977 report was not available for review.

(Closed) Infraction (278/77-28-01):

Failure to incorporate calibration corrections to raw temperature, pressure and vapor pressure data for the 1976 Unit 3 CILRT.

The inspector reviewed the calibration data sheets used as input for the CILRT computer program with a representative tsf the Bechtel Corporation.

The inspector verified that during a Type A tast, the computer program applies calibration corrections to the raw input data before using this data i; calculate the leak rate.

The calibration correction procedure is a standard part of the computer program supplied by Bechtal.

This item is considered closed.

3.

Containment Integrated Leak Rate Test (CILRT)

a.

General On July 25-28, 1980, the Peach Bottom Atomic Power Station performed a CILRT as required by 10 CFR 50 Appendix J and TS 4.7A.

The test was performed in accordance with ST 12.5, Revision 2 " Integrated Leak Rate Test". The inspector reviewed the test procedure, witnessed preparations for and various portions of the test.

Details of the test are discussed below.

b.

Valve Lineups The inspector noted that 12.5 Revision 2, contained valve lineups to verify that the root ves, for instrumentation were in the proper position, but individual instrument isolation, bypass and vent valves were not addressed in the procedure.

The licensee agreed to perform the I and C normal instrument surveillance, TC-8 coincident with the CILRT valve lineup thus certifying that these instruments would be properly aligned.

Performance of TC-3 was documented in the events log.

No items of noncompliance were identified.

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c.

Instrumentation j

The inspector reviewed the calibration records for resistance temperature detectors, dew point hygrometers, pressure detectors, i

and the verification test flow meter.

Their calibration prior to the CILRT met applicable accuracy requirements and were traceable to the National Bureau of Standards.

No items of noncompliance were identified, d.

Tours The inspector conducted inspection tours independently and with licensee personnel both before and during the CILRT.

During these l

tours test boundaries were surveyed for evidence of leakage and on a

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sampling basis, selected valves were verified to be in the correct positions.

These selected valves included vent paths external to the test volume.

No items of noncompliance were identified.

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Chronology July 26 0717 Commenced pressurization of the containment 0805 Pressurization stopped due to reception of

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a Fire Alarm in the Drywell.

Drywell entry made verifying no fire

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existed.

0848 Re-commenced pressurization 1330 Completed pressurization at 62.20 psia.

1430 Drywell sumps pumped down 1455 Leakage survey tour discovered air flow through the verification test flowmeter and isolated the temporary valve P-4 on the test panel.

1600 Pressurized containment to 64.204 psia.

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l July 27 0245 Started an extra Drywell cooling fan and, due to increasing reactor l

temperature and lowering level, shifted RHR cooling loops.

0340 Drywell sump pumped down 0450 Repressurized to 64.670 psia Continued leakage surveys

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0900 Completed re-stablization of temperature within containment and commenced accumulation of official test data.

1915 Completed leak rate test with calculated leakage of.042 wt% / day at the 95% upper confidence level.

1930 Verification test established with a superimposed leak rate of 4.37 CFM.

July 28 Continued to measure leak rate.

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Continued to regulate RHR in the Shutdown

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Cooling mode to obtain containment temperature stabilization per ST 12.5 step G.3.

1000 Completed verification test.

The inspector identified no items of noncompliance.

f.

Results Preliminary calculations indicate that the leak rate at the 95%

upper confidence level is 0.042 weight percent per day.

The test acceptance criteria is 0.375 weight percent per day.

The inspector noted that the leak rate of 0.042 is not corrected for change in containment free volume due to water accumulation in the sump or addition of local leak rate test results for systems in operation during the test.

These systems include RHR, RWCV, CW to DW, RBCW, and ILRT test sensing lines.

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The inspector observed data recording, transcription and calculations during the test.

In addition, the inspector independera y calculated several mass values and the leak rate, using ra, data from the test to verify the accuracy of the licenset's leak rate calculations.

No unacceptable conditions were identified.

4.

Local Leak Rate Testing (LLRT)

a.

Documents Reviewed ST 20.126 Chilled Water Isolation, revision - dated 7/18/80

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l RBCW Drywell Isolation Valves, revision 0, dated 7/11/80

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Dwg. No. M-316, revision 13, Cooling Water - Reactor Building

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Dwg. No. M-327, revision 20, Chilled Water System -Drywell

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Cooling b.

Scope The inspector reviewed the LLRT procedures listed above for technical adequacy and compliance with 10 CFR 50 Appendix J, ANS 45.4, and Peach Bottom Technical Specifications.

The licensee's representative explained that these procedures were developed and incorporated into the LLRT program to satisfy the NRC concern identified as unresolved item No. (277/80-21-03) and achieve greater conformance to 10 CFR 50, Appendix J.

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The inspector reviewed the recorded test results and noted that tile leakage was to be added to the ILRT leak rate as a correction because the CW and RBCW systems were in service during the ILRT.

No items of noncompliance were identified.

5.

10 CFR 50, Appendix J, Exemption Requests In response to an NPC request, Philadelphia Electric Company conducted a detailed study of the containment leakage testing program at Peach Bottom to determine the degree of conformance with 10 CFR 50, Appendix J.

The results of this study were presented to the NRC in a letter from PECO dated August 13, 1976 which identified several areas of the leakage rate test program which were not in full conformance with provisions of 10 CFR 50, Appendix J and formally requested exemption from those requirements.

One such exemption was from local leak rate (type C) testing six containment isolation valves on the Reactor Building Closed Cooling Water System and the Chilled Water System.

Part of the basis offered was that containment leakage paths which include these valves are tested during the ILRT.

The inspector identified an apparent contradiction between this exemption request and the current leakage testing program which includes LLRTs of these valves, as described in paragraph 4 of this report, and does not include these leakage paths in the ILRT.

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The inspector stated to the licensee's representative that a revision to his Appendix J exemption request appared to be needed in order to reflect the current status of the containment leakage testing program.

The statfan superintendent acknowledged this and stated that a review of the matter would be done and appropriate action taken.

This matter is considered unresolved pending review of licensee's actions to resolve the apparent contradiction and is designated item No. (277/80-26-01).

6.

Plant Tours The inspector walked through various areas of the plant to observe i

operations and activities in progress, implementation of radiological

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controls, and the general condition of safety related equipment.

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these tours, the inspector identified two items of noncompliance discussed below.

On July 25, 1980, while touring the Drywell access area at elevation 135 i

in Reactor Building No. 2, the inspector r.oted an area near the Control Rod Drive Access Hatch that was bounded by yellow and magneta tape.

A step-off pad was located at the boundary but no posting signs were evident.

The situation was immediately brought to the attention of the-Health Physicist (HP) stationed at the control point.

The HP confirmed that a contaminated area sign appeared to be required and a sign had existed the previous day.

The HP agreed to post the proper sign as soon as possible.

A review of this problem was conducted by the inspector with representatives'of the licensee.

It was determined that a survey of the area taken to support RWP No. 2-94-0645 on July 24, indicated that-dpm/100cm{nationlevelsonareasofthefloorrangedfrca1,000to8,000 the contam A survey conducted on July 26 produced similar results.

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The levels found, exceed the values which require posting with a sign as specified by procedure HP0/CO-11, Establishing and Posting

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Radiologically Controlled Areas".

The failure to properly post this area constitutes an item of noncompliance at the deficiency level l

(277/80-26-02).

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On July 20, while monitoring the input of CILRT data into the Bechtel computer remote terminals, in the Unit 2 Cable Spreading Room, the inspector visually observed that one of the Bechtel employees was wearing the Eberline Thermoluminescent dosimeter (TLD) belonging to a test engineer employed by the licensee.

Further investigation showed that the test engineer possessed the Bechtel employee's TLD.

The Eberline TLD is read monthly and is the basis for determining monthly employee radiation exposure at Peach Bottom.

The licensee also requires an additional dosimetric device (a Harshaw device) be issued to personnel allowed within the restricted areas.

The Harshaw device is used to monitor daily exposures.

The two men mentioned above did possess their proper Harshaw device. The licensee immediately reissued new Eberline TLD's to both men and indicated that dose evaluation reports would be filed in each man's exposure record.

The licensee's representative committed to perfom an investigation of the circumstances surrounding this occurrence and to perform an audit of all badges at the guardhouse during a backshift to insure that personnel possess their proper dosimetric devices.

The failure to possess proper dosmetric devices constitutes an item of noncompliance at the deficiency level (277/80-26-03).

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7.

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.

An unresolved item disclosed during the inspection is discussed in Paragraph 5.

8.

Exit Interview The inspector met with licensee representatives (see Details 1 for attendees) at the conclusion of the inspection on July 28, 1980.

The inspector summarized the scope and findings of the inspection at that time.

Regarding the unresolved item in paragraph 5, the Station Superintendent committed to review the matter described in this report and take appropriate action.

Regarding the two items of noncompliance in paragraph 6, the Station Superintendent acknowledged these findings.

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