IR 05000277/1981016
| ML20010H520 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/31/1981 |
| From: | Blough A, Cowgill C, Mccabe E, Sanders W, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20010H510 | List: |
| References | |
| 50-277-81-16, 50-278-81-17, NUDOCS 8109240565 | |
| Download: ML20010H520 (20) | |
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50277-810520 50277-810612 50277-810622 50278-810622 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-277/81-16 Report No.
50-278/81-17 50-277 Docket No.
50-278 DPR-44 C
License No. DPR-56 Priority
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Category C
Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania
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Facility Name:
Peach Bottom Atomic Power Station, Units 2 and 3 Inspection at:
Delta, Pennsylvania Inspectioncondu.g: June 1-30, 1981 q
Inspectors:
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j C."Ji Cow y, III, Senior Resident date s'igned Inspector f%w aR v/w/r1 A."RI BlouO ResiderM. Inspector date signed WL/ W~
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i g R. White, Radiation' Spec.alist da't6 igr(ed Approsed by:
F0ll b 3l Ol E. C. McCabe, Jr., Chief, Reactor date' si g'ned Projects Section No. 2B, DRPI Inspection Summary:
Inspection of June 1-30, 1981, (Combined Report Nos. 50-277/81-16 and 50-278/81-17)
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m Areas Inspected: Routine, onsito regular and backshift inspections by the resident inspectors (75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> - Unit 2; 53 hours6.134259e-4 days <br />0.0147 hours <br />8.763227e-5 weeks <br />2.01665e-5 months <br /> - Unit 3) and two region-based specialists (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Unit 2; 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Unit 3). Areas inspected included accessible portions of the Unit 2 and Unit 3 facilities, operational
safety, event followup, radiation protection, physical security, control room observations, LER review, TMI Action Plan followup, outstanding item followup, IE Information Notice followup and peri'adic reports.
Results: Noncompliances: One (violation of allowable technical specification instantaneous release rate limit, Detail 4).
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DETAILS
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Persons Contacted l
R. Castagliola, General Supervisor, Quality Assurance B. Clark, Senior Engineer, Generation Division (Nuclear)
M. J. Cooney, Superintendent, Generation Division (Nuclear)
l W. Corse, Assistant Site Q. A. Engineer
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J. K. Davenport, Maintenance Engineer G. F. Dawson, I&C Engineer
- R. S. Fleischmann, Assistant Station Superintendent A. Fulvio, Results Engineer N. Gazda, Health Physics, Radiation Protection Manager A. H11smeier, Engineer, Health Physics and Chemistry Support T. Hinkle, ISI Coordinator F. W. Polaski, Reactor Engineer S. R. Roberts, Operations Engineer D. C. Smith, Outage Coordinator S. A. Spitko, Site Q. A. Engineer S. Q. Tharpe, Security Supervisor
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T. Ullrich, Station Superintendent H. L. Watson, Chemistry Supervisor l
J. E. Winzenried, Technical Engineer Other licensee and contractor employees were also contacted.
- Present at exit interviews on site and for summation of preliminary inspection findings.
2.
Outstanding Item Update (0 pen) Unresolved Item (80-31-02 and 80-23-02), review Mair.tenance Request Forms (MRFs) for Modification 79-104.
The licensee provided MRFs 2-60-M-0-81, -83, -84, and -85 for replacement of APRM and IRM by pass switches with a more reliable switch. No problems with these documents were identified, but the inspector noted that the erope of this modification also included the Source Range Monitor (SRM) and Rod Block-Monitor (RBM) by pass switches.
The associated MRFs were requested from the licensee. This item remains open.
3.
Plant Operations Review a.
Logs and Records (1) Documents Reviewed A samp'ing review of logs and records was made to:
identify significant changes tnd trends; assure that required entries were made; verify that operating orders and night orders conform to Technical Specification requirements; check correctness of communications concerning equipment and lock-out
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status; verify jumper log conformance to procedural requirements; and verify conformance to lin'iting conditions for operations.
Logs and records reviewed were:
(a) Shift Supervision Log, June 1-30, 1981 (b) Reactor Engineering Log - Unit 2, June, 1981 (c) Reat.cor Operators Log - Unit 2 - June 1-30, 1981 (d) Reactor Operators Log - Unit 3 - June 1-30, 1981 (e) C0 Log Book - June 1-30, 1981 (f) Radiation Work Permits (RWP's) - Various in both Units 2 and 3, June, 1981 (n) Maintenance Request Forms (MRF's) - Units 2 and 3, (Sampling) June, 1981 (h) Ignition Source Control Checklists (Sampling), June,1981 (1) Operation Work & Infor_matien Data - June, 1981 Control room logs were reviewed pursuant to requirements of Administrative Procedure A-7, " Shift Operations".
Frequent initialing of entries by licensed operators, shift supervision, and licensee on site management constituted evidence of licensee review.
Logs were also reviewed to assure that plant conditions including abnormalities and significant operations were accurataly and completely recorded.
Logs were also assessed to determine that matters requiring reports to the NRC were being processed as suspected reportable occurrences. No unacceptable conditions were identified.
(2) Facility Tcurs (a) During the course of this inspection, which also includeo shift turnover, the inspector conducted daily tours and made observations of:
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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 Yard area and perimeter exterior to the power block,
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including Emergency Cooling Tower and torus dewatering tank
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Security Building, ir. eluding CAS, Aux SAS, and
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control point monitoring
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Lighting Vehicular Control
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The SAS and power block control points
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Security Fencing Portal Monitoring
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Personnel and Badging
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Control of Radiation and High Radiation areas including locked doors checks
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TV monitoring capabilities
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Weapons requalification range (about 3 miles-off-site)
Off-shift inspections during this inspection and the areas examined were:
DATE AREAS EXAMINED June 4 Control Room June 5 Turbine Building Tour June 9 Weapons Requalification
' June 15 Weapons Requalification June 17 Control Room, Health Physics Controls June 18 Tour of protected area June 19 Control Room June 22 Event Response (Unplanned Noble Gas Release),
Protected Area Lighting Off-Normal Alarms.
Selected annunciators were discussed
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with control room operators and supervision to assure they were knowledgeable of plant conditions and that corrective action, if required, was being taken.
The operators were knowledgeable of alarm statur and plant conditions.
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Cor. trol Room Manning. On frequent occasions during this inspection, the inspector confirmed that requirements of
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10 CFR 50.54(k), the Technical Specifications, and commitments to the NRR letter of July 31, 1980 for minimum i
staffing were satisfied.
The inspector frequently confirmed that a senior licensed operatar was in the control room complex. No unacceptable conditions were identified.
Fluid leaks. On June 30, the inspector noted a small leak
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on a threaded ccanection in the air supply to torus vacuum breaker 2502A. When notified, shift supervision inspected the leak and initiated a maintenance request.
No other fluid leaks were identified which had not been identified previously by the licensee or for Unich necessary corrective action had not been initiated.
The inspector observed sun.p stacus, alarms, pump-out rates, and held discussions with ifcensee personnel.
No unacceptable conditions were identified.
Piping Vibration.
No significant piping vibration or
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unusual conditions were identified.
Monitoring Instrumentation. The inspector frequently
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confirmed that selected instruments were operatirg and indicated values were within Technical Specification requirements. On a daily basis when the inspector was on site, ECCS switch positioning and valve lineups, based on control room indicators a d plant observations were verified.
Examples of ins rumentation observcd included:
flow setpoints, breaker positioning, PCIS status and radiation monitoring instruments.
No unacceptable conditions were identified.
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Fir 9 Protection. On frequent occasions the inspector
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vetified the licensee's measures for fire protection. The inspector observed control room indications of fire detection and fire suppression systems, spot-checked for proper use of fire watches and ignition source controls, checked a sampling of fire barriers for integrity, and observed fire fighting equipment stations.
During a tour of the Turbine Building on June 24, the inspector noted that the eatertight door to the laundry area, clearly marked " Fire Dcor; Keep Closed", was open.
The inspector informed station management and shift supervision, who promptly shut the door. A modification to add a self-closing fire door at that location is still outstanding (reference combined reports 50-277/81-05 and 50-278/81-05).
While touring the pump structure on June 25, the inspector noted combu>tibles, including rags, cardboard, and blocks of wood (apparently not fire-treated), in the vicinity of the Unit
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3 HPSW pumps in the Emergency Pump P.oom.
There was also evidance of smoking.
Shift supervision was informed and promptly removed the combustible material. The inspector reviewed licensee procedures and determined that the Emergency Pump Room was designated neither as a vital housekeeping area nor as a "no smoM ig" area. Also, the Diesel Generator Building is not specified "no smoking" by the procedures, even though it is so controlled.
The licensee indicated that hot;sekeeping and smoking controls over these areas would be re evaluated. This 2rea will be reinspected (81-16-01 and 81-17-01).
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Followup on Events Occurring During the InspjLctjpg (1) High Pressure Service Water (HPSW) Li se Failure A region-based in.spector reviewed the repair and testing activities associated with a pipe failure in an 18" diameter X 0.296" minimum wall, carbon steel spool piece located downstream and velaed to valve 32-11B on the Unit 2 HPSW system. An area of the pipe adjacent to the valve and surrounding the leak was incrementally measured for wall thickness and recorded on a layout to determine the extent of the internal corrosion. The measurements were made with ultrasonic techniques per specification SWI-15. The recorh of the plotted wall thickness show the thinnest wall thickness to be 0.060", with both leaks 1.5" downstream from the valve. All of the pipe area under the required minimum wall of 0.296" was contained in an area on the bottom of the pire 13" circumferentail and 15.5" frca the end of the valve. The licensee stated that the internal erosion resulted from the turbulence caused by throttling the flow with the valve.
In addition to replacing the defective pipe, wall thickness inspections were planned for the "A" line as well as the lines in Peach Bottom Unit 3.
The inspector identified no unacceptable conditions.
(2) Reactor Scram At 9:29 a.m., June 22, a Unit 2 13KV auxiliary power bus was lost and the reactor scrammad from low water level.
Loss of condensate pumps powered from the bus caused the reactor feed pumps to trip on law suction pressure. Main steam lines isolated.
High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) systems automatically initiated.
The offgas recombiner system operating machanical compressor also lost power, and the consequant pressure increase in the suction line resulted in an unplanned, above limit, noble. gas release (reference Detail 4). The inspector observed conditions in the control _ room and verified that: safety
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systems and operators had responded properly; appropriate notifications had been made; and gaseous radioactive release
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rates had returned within limits. The cause of the lost 13KV bus was shorting of a breaker when workers installing a redification at a higher elevation in the Turbine Building spilled potable water onto the breaker panel.
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Prior to the unit restart the inspector discusseo corrective actions with licensee personnel and observed in plant equipment to verify that corrective action for the electrical problem had been completed. Additionally, the inspector discussed Emergency Plan implementation inconsistencies noted during this event (see Detail 4) with station management and operating shift personnel.
The inspector will continue to monitor plant
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operations and-adherence to procedural requirements in future inspections.
4.
Unplanned Radioactive Noble Gas Release in Excess of Allowable Limits
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On June 22, 1981, the resident inspector and a radiation specialist reviewed an unplanned release of radioactive noble gas as reported in Licensee Event Report No. 2-81-35/IP, dated June 22, 1981, against the
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following criteria:
i Technical Specification 3.8.C.1 " Airborne Effluents":
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Philadelphia Electric Company, Emergency Plan - Peach Bee, tom Atomic
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Power Station, December, 1980:
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Philadelphia Electric Company. Emergency Plan Implementing Procedures; i
EP-101, " Classification of Emergencies", Revision 0, April 1. 1981:
EP-102, " Unusual Event", Revision 0, April 1, 1931:
ED-103, " Alert Condition", Revision 0. April 1, 1981:
EP-316, " Cumulative Population Dose Calculations", Revision 0, April 1, 1981:
EP-205, " Radiation Survey Team", Revision 0, April 1, 1981:
l EP-207, " Personnel Safety Team", Revision 0, April 1, 1981:
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NUREG-0654, Criteria for Pre.naration and Evaluation of
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Emergency Response Plans and Preparedness in Support of Nuclear Power Plants On June 22, 1981, the Unit 2 reactor scrammed due to a loss of a 13KV plant load bus (see detail 3).
The loss of the bus caused the trip of a
!!ydrogen Recombiner Mechanical Compressor. As a consequence, the pressure in the compressor suction line increased, causing radioactive noble gases to leak. The gases vented through the recombiner ventilation exhaust system to the Unit 3 Reactor Building roof vent. The peak release rate was 182% of :he allowable instantaneous release rate specified in Technical Specification 3.8.C.1.
The licensee identified the isotopes involved in the release as:
Xe-138 ~ 72%
Xe-133 7.2%
Xe-135 ~ 6.8%
Kr-87 ~ 6.1%
Kr-88 ~ 5.4%
Kr-85m ~ 3.1%
The peak release (in excess of Technical Specifications) was for a duration of 7 minutes at an average release rate af 6600 uCi/sec, resulting in about 2.77 curies released.
The remainder of the release lasted for about 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, at an average release rate of 760 uCi/sec, resulting in about 8.5 curies released. The total activity released during this event was about 11.4 curies.
The inspector reviewed the licensee's calculation of possible dose to the population using EP-316.
The calculation verified a 0.08 millirem accumulated dose at the station's perimeter in the worst case cor.dition.
Upon completion of the incident analysis, the licensee initiated action to replace the snubber drain valves on both Mechanical Compressors associr.ted with the operation of the recombiner to preclude further release via this pathway.
Release of radioactive materials in excess of Technical Soecification limits is an item of noncompliance (81-16-02; 81-17-02).
In further review, the inspector noted that the station's Emergency Plan states the following in Section 4.0. Emergency Conditions:
"The Interim Emergency Director or the Emergency Director determines the emergency classification.
T'.e classification nomenclature is used to provide an indication of the scope or character of the situation.
The following classifications are discussed in this section:
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1.
Unusual Event 2.
Alert Conditions 3.
Site Emergency 4.
General Emergency The following sections present discussions of each emergency class
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and accident scenario which are typical of each emergency class.
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The accident scenarios can be classified many ways: type of event (i.e., LOCA, LOCA + ECCS failure, LOCA + containmcnt failure), by type of release (gaseous liquid), by release point (ground. level, roof vent, mainstack), etc. Table 4..C lists the types of events and I
releases and their respective emergency action levels for the Alert, Site, and General Emergencie:."
i While Section 4.1.1. UNUSUAL EVENT, and Section 4.1.2. ALERT CLASS,
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provide general discussion of the conditions which determine the category l
of.such a release, Table 4.2 of the Emergency Plan provides the following specific information:
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Symptoms or
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Description Class EALs Response
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Radioactive Material
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Release
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al) Instantaneous Unsual Event 1) A spike on gaseous. Investigate
release exceeding effluent monitors:
source of Technical Spect-a) main stack >
release, j
fication limits cps
b) roof vent >
Operate to
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cpm reduce the release within
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limits 2) analysis of parti-y culate filters or Investigate or charcoal source of
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cartridge release, Operate
main stack >
to reduce the uCi/sec release within
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limits
uCi/sec
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a2) Release exceeding Unus;al Event A report of the sum-Investigate the Technical mation of individual source of Specification release data within release.
quarterly average the quarterly period.
Operate to reduce the release within limits I
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b)
Releases Alert Condition 1) Main Stack >
Investigate.
4-exceeding 10
. cps source of times the 2) Roof vent >
release. Activate
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Technical cpm.
Radiation Survey Specification 3) analysis of parti-Team to monitor i
for greater culate filter or in plant and plume
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than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> charcoal cartridge: path
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a) main stack >
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i uCi/sec b) Roof Vent >
uCi/sec 4) containment rad.
monitor >
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The numerical values missing here, are provided in the station's Emergency Plan Implementing Procedures. The Emergency Action Leveis specified in EP-101 indicate an ALERT condition exists when the roof vent monitor indicates greater than 5.5 E+4 counts per minute. No time duration ;s specified, nor is a time duration specified in EP-103.
The inspector determined that in this event the roof vent monitor indicated as high as 7 E+4 counts per minute for less than 5 minutes.
According to EP-101, this Emergency Action Level (EAL) would be
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sufficient te classify the event as an Alert Class Emergency and
consequently implement procedure EP-103, " Alert Condition".
Rather, only portions of EP-102 were implemented.
For example, EP-102 states, in part:
"The Interim Emergency Director shall:
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In the event of high radiation, excessive radioactive
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contamination, or excessive gaseous radioactive release:
(1) Activate the Interim Radiation survey Team in accordance with EP-205.
Direct the Team to report to the hazard area and conduct rurveys in accordance with HP0/C0 procedures to determine the magnitude of the radiological hazards.
(2) Activate the Interim Personnel Safety Team in accordance with EP-207.
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If the event results in a radiation release, direct the Radiation Monitoring Teaan Leeder to calculate the activity released and estimate dose rates in accordance with EP-316, Part I.1.A or III.1.A.
Refined determination of off-site dose rates (EP-316, Part I.1.B and C. or III.1.B and C.) shall normally be directed by the Emergency Director, in accordance with EP-201".
During review of this event, the inspector noted that items e.(1) and e.(2) were not performed. According to the Assistant Station Superintendent, it was the Interim Emergency Director's perogative to determine what portions of the procedure should be implemented; the basis for this allowance being the note which appears in this EP as well as EP-103, " Alert Conditions"; EP-104, " Site Area Emergency"; and, EP-105,
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" General Eseegency", which states:
"THE JUDGEMENT OF THE INTERIM EMERGENCY DIRECTOR OR EMERGENCY DIRECTOR IS VITAL IN PROPER CONTROL OF AN EMERGENCY AND MAY TAKE PRECEDENCE OVER GUIDANCE IN THE EMERGENCY PROCEDURES AND EMERGENCY IMPLEMENTING PROCEDURES".
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Evaluation From this review the following inconsistencies were identified:
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While the licensee's decision to classify this occurence as an Unusual Event is consistent with the Station's Emergency Plan and the guidance presented in NUREG-0654, the licensee's procedure EP-101, " Classification of Emergencies", is not consistent with the 14..:ensee's Emergency Plan in terms of classifying an event.
2.
The licensee's failure to fully implement EP-102 based on the procedural note which allows the (Interim) Emergency Director's judgment to take precedence over the procedure arbitrarily, and without qualification is not consistent with the Emergency Plan or NUREG-0654. While the decision not to activate the Personnel Safety Team was reasonable under the circumstances, it was appropriate to activate the Radiation Survey Team to verify site and perimeter radiation levels.
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EP-205 does not provide direction on gaseous releases.
These items are unresolved pending further licensee and NR
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(81-16-03; 81-17-03)
5.
IE Information Notice Followup -- IE Information Notice No. 81-06: " Failure of ITE Model K-600 Circuit Breaker" During preventive maintenance at the Rancho Seco facility, an ITE Model K-600 breaker was observed not to trip.
Investigation revealed that the tripping coil wire was too small for the mating lug used and had slipped loose. The information notice indicated that Models K-1600 and K-3000 may have the same deficiency and recommended licensee reviews for applicability to their facilities.
The inspector reviewed licensee internal correspondence and discussed the matter with a licensee representative.
Licensee review indicated that ITE Model K-600 and K-1600 breakers, purchased in 1966, are used in 480 volt load centers at Peach Bottom.
Loss of tripping coil continuity would prevent remote-manual tripping; automatic and local-manual trips would still be effective.
Failures o? the remote-manual tripping feature of these breakers on-site had not t+an identified.
Licensee examination of one of these breakers reveale' thct the tripping coil wire was matched to the lug size..The licensee concluded that major disassembly (required for coil and lug examination) cf additional breakers was not warranted.
The inspector verified PORC review of this notice.
No unacceptable conditions were identifie.
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6.
Review of Licensee Event Reports (LER's)
The inspector reviewed LER's submitted to the NRC:RI office to verify that the details of the event were clearly reported, including the accuracy of the description of.cause and adequacy of coi ective action.
The inspector determined whether further information was required from
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the licensee, whether generic implications were indicated, and whether
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continued operation of the facility was conducted in accordance with Technical Specifications.
Report accuracy, compliance with current reporting requirements, and applicability to other site systems and
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components were also reviewed. The following LER's were reviewed:
LER No.
LER DATE Event Date Subject 2-81-32/1P May 23, 1981 May 20, 1981 Analysis shows concrete walls and 2-81-32/1T June 4, 1981 of computer room unstable under postulated tornado depressurization and Cardox injection.
2-81-34/IP June 12, 1981 June 12, 1981 Four cables in each unit and 2-81-34/1T June 26, 1981 associated with control of room coolers for RHR, Core Spray, HPCI and RCIC rooms were improperly routed.
2-81-35/IP June 22, 1981 June 22, 1981 Technical Specification allowable gross activity (gaseous) release rate was exceeded for seven minutes (see Detail 4)
Additionally, the inspector verified that computer room doors remairied physically blocked open as specified in 2-81-31/IP and IT.
The inspector discussed ECCS room cooler control circuitry with licensee representatives and determined that running appropriate coolers continuously, as stated in the I.E3, provides adequate short-tory, corrective action pending rerou:194 cables. Additionally, the inspector verified that selected cooling fans were in continuous operatio.
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7.
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:
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Health Physics (HP) controls b.
Badging c.
Usage of protective clothing d.
Personnel adherence to kWP requirements e.
Surveys f.
Handling of potentially contaminated equipment and materials Additionally, inspections were conducted of frisker and portal monitor usage by personnel exiting various RWP areas, the power block, and the licensee's final exit point. More than 50 people were observed to meet frisking requirements of Health Physics procedures dut 7g the month. A sampling of high radiation doors was verified to be locked as required.
Compliance with RWP requirements was verified during each tour; special emphasis was placed on RWP adherence at the Unit 3 drywell and torus.
Over 20 RWPs were checked during the month.
Several hundred line entries were reviewed to verify that personnel had provided the required information and about 30 people working in RWP areas were observed to be meeting the applicable requirements.
8.
Physical Security The inspector spot-checked compliance with the accepted Security Plan and implementing procedures, including operations of the CAS and SAS, over 20 spot-checks of vehicles onsite to verify proper control, observation of protected area access control and badging procedures on each shift, inspection of physical barriers, checks on control of vital area access and escort procedures. A qualitative assessment of the adequacy of protected area lighting was made during darkness on June 22, 1981.
The inspector observed portions of security guards weapons requalification training on June 9,11,12 and 15 to verify that training was conducted in a proper and professional manner and that qualification scores were accurately computed and recorded.
No unacceptable conditions were identified. The inspector noted, however, that many guards required considerable practice in order to attain the required requalification scores. Weapons requalification was also observed by a region-based inspector (reference combined report 50-277/81-17 and 50-278/81-18).
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During protected areas tours the inspector noted that out-of-date copies of procedure PP-25, ' Instruction to Personnel Escorts", were posted in two locations -- in the Administrative Building and by the entrance turnstile in the Security Building. No instances of use of out-of-date procedure use by personnel escorts were noted. When notified, the'
Security Supervisor removed both out-of-date procedures and posted a correct copy at the Securl*.y Building location. The inspector stated that a control system could provide assurance that posted procedures were l
kept up-to-date.
9.
Review of TMI Action Plan (TAP) Requirements The inspector reviewed the status of licensee action of the following TAP requirements to verify that the licensee is meeting his NRC commitments.
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TAP Item II.E.4.2 ' Containment Isolation Dependability" Position (6) of this item required, by January 1, 1981, that containment purge valves not meeting the operability criteria of the Staff Interim Position of October 23, 1979 be sealed closed. The inspector reviewed a letter from NRC:NRR to the licensee, dated November 5, 1980, which accepts the licensee's commitments in response to the staff interim position.
The inspector concluded, therefore, that the licensee meets January 1, 1981 requirements without sealing containment purge valves.
(Some containment purge valves have been sealed for other reasons, i.e. seismic concerns, as reported in 50-277/81-05 and 50-278/81-05).
The inspector 'so verified licensee compliance with containment ventilation a J purge valve commitments.
Licensee correspondence dated December 11, 1979 stated that:
1.
Use of large diameter purge and vent valves during power operation will be minimized and shall not exceed 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year, except if performed in a " batch" mode (at least one isolation valve in each line closed at all times).
2.
Valve opening is limited to 37 degrees whenever the reactor is not in the cold shutdown or refueling mode.
The inspector reviewed the following procedures:
S.3.9.1.A, "Inerting Primary Containment", revision 11, dated October 3, 1980.
.S.3.9.1.B, "De-inerting and Purging Primary Containment Via SBGTS,"
revision 7, dated October 3, 1980.
S.3.9.1.H, " Operating Procedure for Containment Purge, Inerting, and t
Exhaust Valves", revision 10, dated February 19, 1981.
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ST 9.16, " Containment Gross Leak Rate Detection", revision 10, dated February 26, 1980.
ST 7.9.2, " Daily Check of Containment Isolation Valve N2 Bottle Pressure," revision 2, dated August 29, 1980.
The inspector determined that the commitment to minimize purging is being met. Review of completed copies of ST 9.16 indicated that large diameter vent and purge valves were open in 1980 during operation for 69.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> at Unit 2 and 77 hours8.912037e-4 days <br />0.0214 hours <br />1.273148e-4 weeks <br />2.92985e-5 months <br /> at Unit 3.
With respect to limiting valve opening to 37 degrees, however, procedures were found to require this only when the reactor is both critical and above 105 psi pressure, rather than anytime the reactor is not in cold shutdown or refuel mode. The licensee was informed of this inconsistency on June 17, 1981 and initiated steps to
cor. form to the commitment and to revise procedures. On June 19,
with the unit in Hot Shutdown, the inspector verified, through discussions with operators and observations of selected valves, that spring clips were installed on valve operating mechanisms to limit opening to 37 degrees. A licensee representative also ir.ofcated th.t procedures had been revised and reviewed Ly FORC.
Resolution of this matter awaits further NRC review.
(81-16-J4 and 81-17-04).
b.
TAP Item I.A.1.3 " Shift Mant.ing: Limit Overtime" Overtime is to be avoided, to the extent practicable, for the plant staff who perform safety-related functions.
In the event overtime must be used, certain restrictions should be followed. Guidelines were listed in NUREG-0737.
The licensee has revised aaministrative procedures for licensed sh:ft staffing to meet the overtime guidelines of this TAP item.
Administrative procedure A-7, " Shift Operations", Revision 16, dated March 17, 1981, was reviewed and found to be in general agreement with NUREG-0737 for licensed shift staffing overtime limitations. A licensee letter dated March 10, 1981 clarified the licensee's position regarding the following NUREG-0737 statement:
"If a reactor operator or senior reactor operator has been working more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during periods of extended shuudown (e.g., at duties away from the control board), such individuals shall not be assigned shift duty in the control room without at least a 12-hour break preceeding such an assignment." The licensee's clarification states that: 1)-The licensee intends to permit deviations from this restriction, as for other restrictions, with approval of the Station Superintendent, his alternate, or higher levels of management.
2)
During extended shutdowns the "12-hour break" is considered to be 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> away from duties at the contral board (i.e. not necessarily 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> off-site). The licensee has stated that, in practice,
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conditions resulting is an operator working 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> one day sometimes result in his coming back on duty with only eight hours t
break -- changing _ schedules to allow a twelve-hour break can disturb other operator's rest schedule (e.g., operator called to report to work at 3:00 a.m.).
The overtime restrictions for licensed operators have also been apnlied to STAS, since onsite STA sleeping quarters are not provided.
For other personnel involved in performing safety-related fcnctions
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on an operating unit, licensea procedures require:
3-1.
An individual shall not be scheduled in advance to work more than 12 consecutive hours (excluding meal periods), nor more than 14 consecutive days.
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2.
If circumstances arise which require an individual to work more than 12 consecutive hours, such work shall be authorized by his
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supervisor, who shatl document the cause on a " Staffing Deviation Form".
Licensee justificatior. for these alternatives to the NUREG-0737 guidelines was submitted in correspondence dated March 31, 1981.
The licensee believes that additional restrictions could result in a need to change personnel in the middle of specific work assignments resulting in job di3ruptions, a reduction in task-specific experience level, and turnover difficulties (e.g. lack of fece-to-face turnover). The inspector discussed these considerations with station management. No unacceptable conditions were identified.
c.
TAP Item I.C.5
" Procedures for Feedback of Operating
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Experience to P1 ant Staff" Each licensee shall have procedures to assure that operating information pertir.ent to plant safety originating both within and outside the utility organization is' continually supplied to operators and other personnel and is incorporated into training and retraining programs. Criteria were listed in NUREG-0737.
Licensee correspondence dated June 20, 1980 indicated that the required functions are performed through the Plant Operations Review Committee (PORC), the operating shift, and the Operating Expereince f.ssessment Committee (0EAC).
The inspector reviewed station administrative procedures governing PORC activities and shift operations, as well as a corporate level procedure regarding the OEAC activities. The procedures collectively cover all requirements
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of TAP item I.C.5., but the corporate level procedure in use has not been formally approved. This was identified in an audit by the licensee's Qualf'.y Assurance Division and is being corrected.
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No unacceptable conditions were identified. The inspector concluded that formalization of the OEAC procedure will complete the establishment of an acceptable arogran for feedback of operation experience to plant staff.
Routine inspection will verify the program's effectiveness.
10.
In-Office Review of Month'.y Operating Reports The following licensee reports have been reviewed in-office onsite.
Peach Bottom Atomic Power Station Monthly Operating Report for:
May 1981 dated June 12, 1981 This report was reviewed pursuant to Technical Specifications to verify that operating statistics had been accurately reported and that narrative summaries of the month's operating experience were contained therein. No unacceptable conditions were identified.
11. Unresolved Items Unresolved items are items about.which more information is required to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items are discussed in Details 3, 4, and 9.
12. Management Meetings a.
Preliminary Inspection Findings A summary of preliminary findings was provided to the Station Superintendent at the conclusion of the inspection. During this inspection, licensee management was periodically notified of the preliminary findings by the resident inspectors. The dates involved, the senior licensee representative contacted, and subjects discussed were as follows-
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Senior Licensee-Date Subject-Representative Present June 5 Routine Discussions Station Superintendent June 12 Routine Discussions Station Superintendent June 17 Containment Purge Technical Engineer Procedures June 19 Routine Discussions (+ation Superintendent
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June 22 Unplanned Radioactive Gutage Coordinator Reiease
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June 22 Energency Plan Assist. Station Implementation Superintendent June 26 Routine Discussions Station Superintendent Fire Protection b.
Attendance at Management Meetings Conducted by Region-Based Inspectors Inspection Reporting Date Subject Report No.
Inspector June 12 (Exit)
Security 50-277/81-17 R. Ladun (Weapons and 50-278/81-18 Requalification)