IR 05000277/1982009

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IE Insp Repts 50-277/82-09 & 50-278/82-09 on 820421-0519. Noncompliance Noted:Failure to Have Instructions for Seismically Qualified Air Supplies to Containment Ventilation Valves & to Supervise Control Rod Handling
ML20053E873
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 05/19/1982
From: Blough A, Cowgill C, Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20053E864 List:
References
50-277-82-09, 50-277-82-9, 50-278-82-09, 50-278-82-9, NUDOCS 8206100166
Download: ML20053E873 (15)


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50-277/820321 50-277/820429 U.S. NUCLEAR REGULATORY COMMISSION 50-277/820512 50-277/820513 50-278/820504 Region I 50-277/82-09 Report No. 50-278/82-09 50-277 Docket No. 50-278 DPR-44 c

License No. DPR-56 Priority Category c

Licensee:

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

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

Delta, Pennsylvania Inspection conducted: April 21 - May 19, 1982 Inspectors:

6//9hl A. R. Blowyh, Resident Inspector date signed C/UMas stieks C. /J.

gill, III, Senior Resident Inspector date signed date signed b

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Approved by:

t. C. McCabe, dr., Chief, Reactor date signed Projects Section No. 2B, DPRP Inspection Summary:

April 21 - May 19,1982 (Combined Inspection Reports 50-277/82-09 and 50-278/82-09)

Routine, on-site regular and backshift resident inspection (82 hours9.490741e-4 days <br />0.0228 hours <br />1.35582e-4 weeks <br />3.1201e-5 months <br /> Unit 2; 69 hours7.986111e-4 days <br />0.0192 hours <br />1.140873e-4 weeks <br />2.62545e-5 months <br /> Unit 3) of:

accessible portions of Unit 2 and Unit 3; operational safety; radiation protection; physical security; control room activities; licensee events; surveillance testing; housekeeping and fire protection; periodic reports and outstanding items.

Resul ts: Violations:

Four (failure to have appropriate instructions for seismically qualified air supplies to containment ventilation valves, Detail 3, failure to proper-ly supervise irradiated control rod handling in the spent fuel pool, Detail 3; failure to follow fire protection / housekeeping procedures -- two examples, Detail 4; failure to post surface contamination areas -- two examples, Detail 4).

8206100166 820524 PDR ADOCK 05000277

PDR Region I Form 12 (Rev. April 77)

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DETAILS I.

Persons Contacted W. H. Alden Engineer-in-Charge, Nuclear Section B. Bowen, Electrical Engineer, Construction Division M. J. Cooney, Superintendent, Generation Division (Nuclear)

J. K. Davenport, Maintenance Engineer G. F. Dawson, I&C Engineer E. Firth, Site Emergency Planning Coordinator R. S. Fleischmann, Assistant Station Superintendent N. Gazda, Engineer, Applied Health Physics A. Hilsmeier, Senior Health Physicist K. Hunt, Reactor Engineer

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W. Knapp, Director, Radiation Protection Section

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J. Mitman, Results Engineer S. Nelson, Engineer, Health Physics Technical Support F. W. Polaski, Assistant Outage Manager S. R. Roberts, Operations Engineer D. C. Smith, Outage Manager S. A. Spitko, Site Q. A. Engineer S. Q. Tharpe, Security Supervisor W. E. Tilton, Refuel Floor Supervisor

  • W. T. Ullrich, Station Soperintendent H. L. Watson, Engineer, Chemistry

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J. E. Winzenried, Technical Engineer Other licensee employees were also contacted.

  • Present at exit interviews on site and for summation of preliminary inspection findings.

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Previous Inspection Item Update (Closed) Unresolved Item (277/80-04-07 and 278/80-04-09), use of check-off list C.0.L.S.3.9.1.H for locally verifying status of boot seals on contain-ment ventilation valves.

In June,1981, the licensee completed modifying all containment ventilation valves to provide control room annunciation of

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a deflated boot seal. Therefore, the checkoff list is no longer pertinent.

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Plant Operations Review 3.1 Lojp/andRecords-DocumentsReviewed I

sampling review of logs and records was spot-checked for accuracy, completeness, abnormal conditions, significant operating changes and trends,, required entries, operating and night order propriety, correct equipment and lock-out status, jumper log validity, conformance to Limiting Conditions for Operations, and proper reporting. The fol-lowing logs and records were reviewed.

(a) Shift Supervision Log, April 21 - May 18, 1982 (b) Reactor Engineering Log, Unit 2 - April 21 - May 18 (c) Reactor Engineering Log, Unit 3 - April 21,May 18 (d) Reactor Operators Log, Unit 2 - April 21,May 18 (e) Reactor Operators Log, Unit 3 - April 21 - May 18

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(f) C0 Log Book - April 21 - May 18 (g) STA Log Book - April 21 - May 18

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(h) Night Orders - Current Entries

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(i) Radiation Work Permits (RWP's) - Varicus in both Units 2 and 3, April - May

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(j) Maintenance Request Forms (MRF's) - Units 2 and 3, (Sampling)

April - May

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(k)

Ignition Source Control Checklists (Sampling) - April - May (1) Operation Work & Information Data - April - May Control Room logs were compared against Administrative Procedure A-7,

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" Shift Operations." Frequent initialing of entries by licensed oper-ators, shift supervision, and licensee on-site management constituted evidence of licensee review.

No unacceptable conditions were identified.

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3.2 Facility Tours Daily tours and observations included the following:

-- Control Room - (daily).

-- Turbine Building - (all levels).

-- Reactor Building - (accessible areas).

-- Diesel Generator Building.

-- Yard area perimeter exterior to the power block, celuding Emergency Cooling Tower and torus dewatering tank.

-- Security Building, including CAS, Aux SAS, and control point monitoring.

-- Vehicular control.

-- The SAS and power block control points.

-- Security Fencing.

-- Portal Monitoring.

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-- Personnel and Badging.

-- Control of Radiation and High Radiation areas, including locked door checks.

-- TV monitoring capabilities.

-- Shift turnover.

Off-Shift lnspections during this inspection period and the areas examined were as follows:

DATE AREAS EXAMINED April 26 Unit 2 Reactor Building, Unit 2 Refuel Floor May 5 Unit 2 Reactor Building, Control Room May 12 Unit 2 Reactor Building, Cable Spread-ing Room, Unit 2 Battery Rooms, Control Room May 13 Control Room, Radwaste Building, Per-sonnel Decontamination

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May 17 & 18 Control Room

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3.2.1 Control Room Manning.

Staffing frequently was checked again~st 10 CFR 50.54(k), the Technical Specifications, and comitments to the NRR letter of July 31, 1980.

Presence of a senior licensed operator in the control room complex was verified frequently.

No unacceptable condi-tions were identified.

3.2.2 Fluid Leaks. The inspector observed sump status, alarms, and pump-out rates, and discussed leakage with licensee personael. No violations were identified.

3.2.3 Monitoring Instrumentation.

The inspector frequently confirmed that selected instruments were operating and indicated values were within Technical Specification requirements.

Daily, when the inspector was on site, ECCS switch positioning and valve lineups, based on control room indicators and plant observations were verified.

Observations included flow setpoints, breaker positioning, PCIS status, and radi-ation monitoring instruments, and neutron monitors.

No violations were identified.

3.2.4 Off-Normal Alarms.

Selected annunciators were discussed with con-trol 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 status and plant conditions.

3.2.5 Piping Vibration. On April 27 the inspector noted vibration of the Unit 3 HPCI steam supply drain line.

Initial licensee investigation was inconclusive.

In the Unit 3 Torus Room on April 29, the inspec-tor noted slight vibration of the Unit 3 HPCI steam line. The licen-see determined that a steam trap in the drain line was allowing con-tinuous steam flow and wrote a maintenance request.

No other signifi-cant or unusual piping vibration was identified.

3.2.6 Environmental Controls. The inspector observed visible portions of main stack and ventilation stack radiation recorders and periodically reviewed traces from backshift periods to verify that radioactive gas release rates were within limits and that unplanned releases had not occurred.

3.2.7 Equipment Conditions.

The inspector verified operability of selected safety equipment by in-plant checks of valve positioning, control of locked valves, power supply availability and breaker positioning..Se-lected major components were visually inspected for leakage, proper lubrication, cooling water supply, operating air supply, and general conditions.

Systems checked included Unit 3 HPCI, RHR 'A'

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Core Spray

'A', and Standby Liquid Contro.

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Selected Emergency Service Water System valves and safety instrument root valves, including Unit 3 low condenser vacuum scram instrument valves, were also checked.

The inspector reviewed selected blocking permits (tagouts) for conformance to licensee procedures.

Breaker, switch and valve positioning was verified.

Included were:

Permit No.

Equipment 2-82-166 Unit 2 Refuel Bridge (Auxiliary Hoists)

3-10-M2-5 M0-10-89C (HPSW Discharge from 2C RHR Heat Exchanger)

On April 28, in the Unit 3

'C' RHR Room, the inspector checked the seismic backup air supply bottles for containment ventilation Valves A0-3511 and A0-3512, the primary containment isolation valves in the Torus Exhaust to Standby Gas Treatment.

Both bottles had adequate pressure (greater than 500 psig) and properly adjusted regulators (75 psig), but the bottle for A0-3511 was not chained into its bracket.

If a seismic event had occurred, both the normal (non-seismic) and the backup air supplies for Valve A0-3511 could have been lost.

Since the redundant valve (AO-3512) was fully oper-able, Primary Containment integrity should not have been lost.

Further, a drop in A0-3511 boot seal pressure would have been annunciated in the con-trol room.

When informed, the licensee promptly corrected this deficiency and also checked supplies for other containment ventilation valves, but did not determine when or how the bottle had become unchained.

a FSAR Section 5.2.2 lists ability to withstand the maximum credible earth-quake as a safety design basis of the Primary Containment System.

10CFR50 Appendix B Criterion III requires the design basis to be translated into procedures and instructions.

10CFR50 Appendix B Criterion V requires pro-cedures and instructions to be appropriate to the circumstances. The in-spector reviewed procedure ST 7.9.2, Revision 2, August 29, 1980, Daily Check of Containment Isolation Valve N2 Bottle Pressure.

The procedure

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requires a daily check of bottle pressure and requires bottle replacement,

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an activity which disturbs the seismic restraint, when the pressure is low.

I No pcccedure requires verification of the seismic restraints, either routinely or following bottle replacement.

Failure to have appropriate l

instructions in this case is a Violation (278/82-09-01).

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On May 11, 1982 the inspectors noted frequent secondary containment door local alarms during Unit 2 fuel handling and discussed with the Operations Engineer the apparent lack of worker attention to second-ary containment door status.

About 7:25 a.m. on May 12, 1982, the inspector noticed a defeated (taped over) limit switch or, a Unit 2 Reactor Building 135-foot elevation access door.

The limit switch monitors door position for secondary containment status indication and alarm. An illuminated blue light over the door indicated the door needed to be shut for secondary containment integrity, but a guard at the door was keeping it open due to a security lock fail-ure.

(This condition had not existed during prior inspection at 7:00 a.m.) A licensee Quality Assurance inspector had independently identified the problem and was interviewing the guard. After ensur-ing the guard corrected the condition, the QA inspector informed shift supervision and wrote a nonconformance report. Since fuel handling) operations were not in progress (due to refuel bridge mal-function during this event, Technical Specification requirements for secondary containment were not violated.

The inspector will review licensee corrective actions, including response to the QA finding, for this event and will continue to evaluate licensee adherence to containment integrity requirements (277/82-09-01 and 278/82-09-02).

3.2.8 Refueling Activities. The inspector periodically spot-checked administrative controls on fuel handling, and on May 12 observed core alterations. The inspector verified that a senior licensed operator was directly supervising the refueling activities, approved procedures were being followed, core component movements had been authorized, and refueling platform inspections and source range monitor tests had been done.

No violations were identified during core alterations. Movement of components within the fuel pool are discussed in Detail 3.3 below.

3.3 Followup on Events Occurring During the Inspection

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3.3.1 Penetration Sealant Material Explosion. About 2:45 p.m. on A3ril 29, I

a bag of trash containing penetration sealant foam exploded w1en it was picked up for removal from the Unit 2 Reactor Building 135-foot elevation. There was a flash of light but no sustained fire and no equipment damage. Although the trash had been handled as potentially containinated, subsequent surveys showed that it was not radioactively contaminated. The inspector toured the area about 4:15 p.m. on April 29 and discussed the event with workers and licensee engineers. The licensee, theorizing that combustible gases had evolved from the

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I sealant, took samples of the foam for analysis.

Also, the licensee

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promptly checked other trash bags, beginning with those at the com-pactor station, for additional foam debris.

Licensee review of this

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event indicated that the sealant, Dow Corning 3-6548 Silicone RTV Foam, gives off hydrogen gas while curing. The manufacturer recom-mends ventilation during foaming and curing. The licen:ee suspend-ed use of the sealant, pending revision of procedures to ensure adequate ventilation of both new seals and waste sealant material.

The licensee stated, however, that alternate sealing methods do not meet 10CFR50 Appendix R criteria for the fire barrier upgrade pro-gram (completion due in March,1984).

Therefore, use of RTV sealant, which has been used successfully at other plants for several years, will continue once procedures are revised.

No violations were iden-tified.

3.3.2 Inadvertent Control Rod Lift in the Spent Fuel Pool. About 3 p.m.,

April 29, an auxiliary hoist was used to move a control rod within the pool.

(This rod had been cut to remove poison pins for testing and was therefore about two feet shorter than normal.) When the hoist was withdrawn, its grapple caught an adjacent rod and lifted it to within about one foot of the fuel pool surface. The operator was having trouble with the grapple's air hose take-up reel over-head and was not watching the grapple.

When area radiation alarms sounded, the hoist was innediately lowered.

Exposures to four work-ers on the fuel floor at the time were 142 millirem, 41 millirem, 17 millirem, and 20 millirem, respectively.

The licensee curtailed use of the auxiliary hoists pending comple-tion of his investigation. The inspectors reviewed the event and the licensee's investigation.

Discussion with station management and the Fuel Floor Supervisor and review of the investigation reports showed that the senior licensed operator supervising the control rod movement was not on the refueling bridge when the blade was lifted near the surfaca of the pool. After directing the bridge operator to withdraw the auxiliary hoist grapple, the supervisor left the

bridge to remove his protective clothing. The inspector asked what procedure covered the control rod moves.

Both the Reactor Engineer and Fuel Floor Supervisor stated that FH-6C was in effect.

Procedure FH-6C, Revision 11, March 8,1982, Fuel Movement and Core Alteration Procedure During a Fuel Handling Outage, applicable to all movement of core components in the fuel pool during a fuel handling outage, re-quires that a Fuel Handling Supervisor who holds a senior licensee direct and supervise all operators assigned to the fuel floor.

The senior licensed operator was not on the fuel bridge supervising l

the bridge operator when the control rod was lifted.

Failure to follow procedures violates Technical Specification 6.8 and Regulatory Guide 1.33 (November 1972) requirements for implementation of proced-

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ures for refueling equipment operation (277/82-09-02).

l The Fuel Floor Supervisor and a member of station management reinstruc-ted personnel involved in fuel handling regarding their responsibili-ties. The individuals directly involved in this event were verbally reprimanded.

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Fire Protection / Housekeeping 4.1 General On frequent occasions the inspector checked fire protection and house-keeping controls.

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 plant tours, the inspector noticed that outage acti-vities were being allowed to seriously degrade housekeeping, as dis-cussed below.

4.2 Unit 2 Reactor Building Tours, May 5 and May 10 About 9 a.m., May 5, the inspector noted poor housekeeping conditions in the Unit 2 Reactor Building 135-foot elevation, including accumu-lations of dirt and debris, plastic bags, boots and gloves.

Several temporary lights were out.

In addition, two fire equipment stations were obstructed.

Fire station 135-21 was blocked by two welding ma-c.hines, and station 135-22 was blocked by a large table. Technical C#ication 6.8 and Regulatory Guide 1.33 (November 1972) require impbentation of procedures for fire protection systems and for general control of maintenance, repair, and modification work.

Pro-cedure A-30, Revision 4, May 21, 1981, Plant Housekeeping Controls, states that placement of equipment and material shall not impede accessibility of firefighting equipment.

Failure to follow this procedure is a Violation (277/82-09-03).

Further, dirt and debris was accumulating in contaminated areas.

In some places, dirt from inside the area appeared to be spreading to unposted areas. About 10:30 a.m., at the inspector's request, the licensee checked for loose surface contamination at nine locations in the Reactor Building 135-foot elevation. Along the west border of the North Accumulator Isle, one spot read 4,000 disintegrations per minute per 100 square centimeters by masslin smear. Technical Specification 6.11 requires adherence to radiation protection pro-cedures.

HP0/C0-100, Revision 13, January 25, 1982, Health Physics Guides Used in the Control of Exposure to Radioactive Material, re-quires " Contaminated Area" signs or a radiation tape barrier for areas with removable contamination above 1,000 disintegrations per minute per 100 square centimeters.

This failure to post a contami-nated area is a Violation (277/82-09-04). Three other smears showed surface contamination approaching the procedural limit (i.e., 600-

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800 disintegrations per minute per 100 square centimeters).

The licensee promptly posted the contaminated areas and began clean-ing to reduce contamination in unposted areas.

During a tour about 2 p.m., May 5, the inspector noted that unposted areas were somewhat cleaner and some cleanup was being done inside contaminated areas.

On May 6, the inspector noted that the previously obstructed fire l

equipment stations were clear,

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During a tour about 2 p.m., May 10, the inspector noted that housekeep-ing conditions in the Reactor Building 135-foot elevation had again degraded. Trash, litter, and debris was accumulating in several loca-tions. Most notable was the clothing change area (used by personnel involved in maintenance, repair and modification work) near the south-east corner of the building. Articles of anti-contamination clothing (including plastic boots, plastic and cloth gloves, coveralls, and caps), plus numerous small plastic bags and papers littered the floor in the area. At several locations this litter had accumulated in piles, posing a fire hazard.

For example, near Motor Control Center E-324-RB an estimated fifty plastic bags were in one pile. Technical Specifica-tion 6.8 and Regulatory Guide 1.33 (November 1972) require procedures for general control of maintenance, repair and modification work. Ad-ministrative Procedure A-30 states that garbage, trash, scrap and litter shall not be allowed to accumulate and create conditions which will adversely affect quality.

Failure to prevent development of fire hazards from accumulating litter on May 5 and May 10 also violates Procedure A-30.

Also, during the May 10 tour the inspector noted spread of dirt and debris from posted surface contamination areas to unposted areas. At the inspectors request, a Health Physics technician checked removable surface contamination by masslin smear of an area near the control rod drive access hatch.

The smear read 15,000 disintegrations per minute per 100 square centimeters.

Failure to post this area for surface con-

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tamination is another example of violation of HP0/C0-100.

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Health Physics technicians promptly posted the contaminated area. The inspector pointed out the unacceptable housekeeping conditions to the Maintenance Engineer.

The inspector then expressed concern to the Outage Manager and to the Assistant Station Superintendent that outage activities on the Reactor Building 135-foot elevation are not being effectively controlled and that corrective measures from the inspec-tor's May 5 findings brought about only temporary improvements.

4.3 Fire in the' Unit 2 Condenser Area About 10:25 p.m., May 12, there was a small trash fire ignited by weld-ing slag in the Condenser Area. Although it was quickly extinguished, l

using one fire extinguisher, it began smoldering again at 12:10 a.m.,

May 13. An Unusual Event was declared and required notifications made.

The Fire and Damage Team extinghished the fire, using hoses. No equip-ment damage, personnel injury, or spread of contamination resulted.

The licensee attributed the fire to excessive trash buildup and stopped work in the area pending cleanup.

The licensee also accelerated his normal housekeeping inspection schedule throughout the plant. On May 14 the Station Superintendent stated that all areas of Unit 2 had been inspected, deficiencies were being pursued ~ Unit 3 inspections were in

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progress, and the accelerated inspection program would continue.

4.4 Ongoing Evaluations The inspector will closely follow and evaluate licensee efforts to im-prove housekeeping.

Also, housekeeping will be discussed at the next Systematic Assissment of Licensee Performance (SALP) management meeting (277/82-09-05; 278/82-09-03).

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5.

Review of Licensee Event Reports (LER's)

5.1 In-Office Review The inspector reviewed LER's submitted to NRC:RI to verify that the details were clearly reported, including the accuracy of the descrip-tion and corrective action adequacy. The inspector determined whether further information was required, whether generic implications were indicated, and whether the event warranted onsite follc,wup. The fol-lowing LER's were reviewed:

LER No./

LER Date/

Event Date Subject 2-82-07/3L Refuel floor Outboard Isolation Valve April 20, 1982 failed to close due to solenoid failure; March 21, 1982 the redundant valve was kept shut during repairs.

  • 3-82-06/IP Calculational error in computer analysis May 5, 1982 of MCPR for Unit 3 Reload 4.

May 4, 1982

  • 2-82-11/IP Significant personnel contamination.

May 14, 1982 May 13, 1982

  • denotes reports selected for onsite followup.

5.2 Onsite Review For LER's selected for onsite review (denoted by asterisks above), the inspector verified that appropriate corrective action was taken or responsibility assigned and that continued operation of the facility was conducted in accordance with Technical Specifications and did not constitute an unreviewed safety question as defined in 10CFR50.59.

Report accuracy, compliance with current reporting requirements and applicability to other site systems and components were also reviewed.

5.2.1 LER 3-82-06/IP. General Electric Company (GE) informed the licensee on May 4 of an error in minimum critical power ratio (MCPR) calculations, i.e., for pressurization events MCPR values in the Reload 4 Licensing Submittal could be nonconserv-ative. This could make the existing Technical Specification Limit nonconservative by 0.01 for about 270 fuel bundles.

GE had started a more detailed review. The licensee began admin-istratively limiting MCPR ratio to.95.

Review of operating history indicated that MCPR ratio had not exceeded.98 this cycl,

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On May 5 the inspector reviewed the Reload 4 Licensing Submittal, spot-checked computer printouts and surveillances, and discussed the matter with licensee engineers and operators to verify the licensee's actions.

On May 6, GE provided results of a more de-tailed analysis indicating that the errors were smaller than originally thought and existing Technical Specifications were adequate.

No violations were identified.

5.2.2 LER 2-82-11/IP. About 4 p.m., May 13, three workers were con-taminated while performing eddy current testing on the 2B Reactor Water Cleanup non-regenerative heat exchanger. One worker's anti-contamination clothing was contaminated to 26 Rad per hour Beta, and an about one-inch by one-inch area of the skin of his right shoulder was contaminated to 72 millrad per hour Beta and 2 milliroentgen per hour Gamma (contact readings).

All individuals were wearing air-supplied respir-ators.

All three individuals were decontaminated onsite by 5 p.m.

Whole body counting on May 13 showed about eight percent of maximum permissible body burden for one individual and three percent for the other two. The licensee made appro-priate reports to the NRC Headquarters Duty Officer, temporar-ily removed the individuals involved from entering radiation areas pending dose assessment and investigation, and suspended work on the heat exchanger. This event will be reviewed in detail by NRC Region I Radiation Specialist inspectors in combined inspection report 277/82-08 and 278/82-08.

6.

Surveillance Testino 6.1 Observations The inspector observed surveillance to verify that testing had been properly approved by shift supervision, control room operators were knowledgeable regarding testing in progress, approved procedures were being used, redundant systems or components were available for service as required, test instrumentation was calibrated, work was performed by qualified personnel, and test acceptance criteria were met. Completed documentation was also reviewed.

Parts of the fol-lowing tests were observed:

-- ST 2.6.010, Revision 2, November 30, 1981, Functional Test of PS-3-5-11C performed at Unit 3 on May 11; and

-- ST 3.1.2, Revision 6, March 15, 1982, SRM Core Monitoring Test, performed at Unit 2 on May 12 (required daily during core alter-ations).

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The inspector identified an error in signal-to-noise ratio calculations on ST 3.1.2.

The error was conservative, and all actual ratios were well above the minimum allowable. The inspector discussed the error with the Shift Supervisor and the Operations Engineer.

On May 14 the inspector checked a completed ST 3.1.2 and noted that calculations

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were correct.

6.2 Document Reviews 6.2.1 Conductivity and Chloride Ion Content in Primary Conlant. The inspector reviewed Surveillance Tests 7.2.3.A and 7.2.3.C and Peach Bottom Daily BWR Chemistry Analysis for April 26 to May 9, 1982.

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

conductivity at 25 C 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 limits are 10 umho/cm conductivity and 1.0 ppm.

chlorides.

Inspections at Unit 3 for the period indicated that the maximum conductivity and chloride con-entrations were 0.40 umho/cm and less than 0.02 ppm, respectively. Through May 9 the 1982 total time above the specific "two weeks per year" limits for conductivity and chlorides were 3.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> and 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, respectively.

No unacceptable conditions were identified.

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6.2.2 Dose Equivalent Microcuries/ Gram (uCi/gm) I-131 in the Primary Coolant. Surveillance Test 7.2.la for April 1982 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 quantity and isotopic mixture actually present.

The Technical

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Specification Limit is 1.0 microcuries per gram.

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sampling frequency is required above 0.02 microcuries per gram.

A monthly Unit 3 sample on April 15 indicated 9.11E-4 micro-

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curies per gram.

Unit 2 remained shut down throughout the month.

No violations were identified.

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7.

Radiation Protection During this report period, the inspector examined work in progress in both units, including the following:

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Health Physics (HP) controls b.

Badging c.

Protective clothing use d.

Adherence to RWP requirements c.

Surveys f.

Handling of potentially contaminated equipment and materials More than 50 people were observed meeting frisking requirements of Health Physics procedures. 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 in work associated with the Unit 2 outage. About 15 RWP's were checked during the month.

Line entries were reviewed to verify that personnel had provided the required information and about 40 people working in RWP areas were observed to be meeting the applicable requirements.

On May 11, the inspector independeatly verified that various radiation area postings contained appropriate information including expected rad-iation levels at boundaries.

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The inspector noted that doors for the North and the South Isolation Valve Rooms at both units were locked.

Each door, however, is of grate-type construction to preclude room over-pressurization in event of a high energy line break within the room. One could reach through an opening in the door and unlock it from the inside. The inspector reviewed sur-veys for the isolation valve rooms.

Radiation levels did not exceed 1,000 milliroentgen per hour; therefore, the rooms needed not be locked per Technical Specifications. The inspector informed the licensee that, should radiation levels exceed 1,000 milliroentgen in the future, the

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existing configuration would not be acceptable since it does not prevent l

unauthorized entry.

Later the inspector noted that the doors had been replaced, using a finer mesh grating, to correct the problem.

l No violations were identified in the above reviews; Health Physics findings relative to housekeeping are discussed in Detail 4.

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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, obser-vation of protected area access control and badging procedures on each shift, inspection of physical barriers, checks on control of vital area access and escort procedure.

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On April 28, 1982 the inspector noticed broken locking bars on Unit 2 'B'

and 'D' RHR Room equipment access plugs.

Review of the accepted Security Plan indicated that the locks were not required, due to the weight (several tons) of the plugs. The licensee uses the locks as an additional administra-tive control and, when informed, wrote a maintenance request to repair the locking bars.

No violations were identified.

9.

Emergency Plan Exercise On May 12 the licensee conducted an Emergency Plan exercise involving initiation of all levels of emergency classification and limited partici-pation by both Maryland and Pennsylvania. The inspectors observed selec-ted portions of the exercise including Control Room, Operations Support Center, Technical Support Center and Emergency Operations Facility acti-vities. The inspectors provided comments to licensee management.

A full scale exercise observed by NRC and FEMA representatives is scheduled for June 16, 1982.

No unacceptable conditions were identified.

10.

In-Office Review of Monthly Operating Reports Peach Bottom Atomic Power Station Monthly Operating Report for April 1982 dated May 11, 1982, was reviewed in-office pursuant to Technical Specifi-cations and verified to determine that operation statistics had been accur-ately reported and that narrative sumaries of the month's operating exper-ience were contained therin.

No unacceptable conditions were identified.

11. Management Meetings 11.1 Preliminary Inspection Findings A summary of preliminary findings was provided to the Station Super-intendent at the conclusion of the inspection.

During the inspection, i

l licensee management was periodically notified of the preliminary find-l ings by the resident inspectors.

The dates involved, the senior

!

licensee representative contacted, and subjects discussed were as l

follows:

Senior Licensee

,

i Date Subject Representative-Present April 28 Seismic Backup Air Supplies Station Superintendent i

to Containment Vent Valves April 30 Control Rod Lift Assistant Station Superintendent May 5 Housekeeping Maintenance Engineer May 5 Contamination Control Radiation Protection Manager

!

,

l

,

.

.

Senior Licensee Date Subject Representative Present May 6 Housekeeping, Contamination Station Superintendent Control May 10 Housekeeping Maintenance Engineer May 10 Housekeeping Outage Manager May 10 Housekeeping, Contamination Assistant Station Control Superintendent May 13 Housekeeping Station Superintendent May 14 Routine Discussions Station Superintendent May 19 Summary of Preliminary Findings Station Superintendent 11.2 Attendance at Management Meetings Conducted by Region-Based Inspectors The resident inspectors attended entrance and exit interviews by region-based inspectors as follows:

Reporting Date Subject Inspection Report No.

Inspector April 26 Health Physics 277/82-08,278/82-08 C. Rowe (Entrance)

'

April 29 Health Physics 277/82-08,278/82-08 C. Rowe (Exit)

April 30 Quality Assurance 277/82-07, t.??/82-07 G. Napuda (Exit)

May 13 Health Physics 277/82-08, 278/82-08 C. Rowe (Entrance)