IR 05000277/1985024

Insp Repts 50-277/85-24 & 50-278/85-20 on 850611-14.No Violations Noted.Major Areas Inspected:Emergency Preparedness,Licensee Audits,Knowledge & Performance of Duties & Discussion Re 850524 Radiological Release

ML20205B525
Person / Time
Site:	Peach Bottom
Issue date:	08/29/1985
From:	Amato C, Harpster T, Hawxhurst J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205B519	List: IR 05000277/1985024 ML20205B515
References
50-277-85-24, 50-278-85-20, NUDOCS 8509120126
Download: ML20205B525 (9)

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U.S. NUCLEAR REGULATORY COMMISSION <

REGION I

Report No. 85-24/20 Docket N /278

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License N DPR-44/50 Priority Category C

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Licensee: Philadelphia Electric C Market Street Philadelphia, Pennsylvania 19201 Facility Name: Peach Bottom Atomic Power Station Inspection At: Delta, Pennsylvania Inspection Conducted: June 11-14, 1984 Inspectors: WN . [4/ t 8 -N

1. a'mesJfHawxhurst',TeamLeader date Tmergency Preparedness Specialist t . / 78 h Char a o,/E ) Specialist da

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Approved by:

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T.Hfpster, ction Leader 'l '

dpe Inspection Summary: Inspec on on June 11-14, 198 (Report Nos. 50-277/85-24; 50-278/85-20).

Areas Inspected: Routine, unannounced, emergency preparedness inspection, covering Licensee Audits and Knowledge and Performance of duties and also a follow-up discussion concerning the May 24, 1985 radiological releas The inspection involved 76 inspection hours by two regional inspector Results: No violations were identified. Five items from prior inspections were closed; four items remain open. No new items were opened as a result of this inspection.

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8509120126 850906 PDR O ADOCK 05000277 i PDR

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DETAILS f 4 Persons' Contacted i D. Ahmuty, Admin. Support Coordinator

• G. Bailey, Emergency Planning Analyst (Contractor)

• R. Fleischman, Station Superintendent

*R. Kankus, Director Emergency Planning

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J. Law, Supervisor Eng. Tec W. Knapp, Corporate Health Physics Sup S. Levin, Chief,- Radioactive . Material Licensing (Maryland Bureau of Radiation Protection)

S. J. Mannix, Supv. Site Nuclear Training C..Mengers, Sr. Eng. QA-Division

• 0. Odell, Chemical Engineer

• D. Oltmans, Senior Chemist

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M. Restaino, Shift. Technical Advisor D. Ronhold, Corpo' r ate Health Physicist K. Schlecker, Physicist Emergency Planning

• A. Trapuzzano, Site QA Auditor

• Denotes persons whom attended the exit meetin . Review of Open Items From Prior Inspections

! 50-277/81-28-47, 50-278/81-32-47 (Closed) Revise appropriate procedures regarding personnel monitoring and decontamination, i

, The inspectors reviewed HP0/CO-7 Rev. 5 and determined that the procedure adequately considered personnel monitoring and decontam-

! ination. Forms and diagrams are include /278/83-06-03 (0 pen) Complete mechanical maintenance program for siren The inspectors reviewed Section 7.2.1.12 of the PBAPS Emergency Plan, held discussions with the licensee and noted .that a formalized pro-gram for maintenance of the siren systems was not complete. The licensee indicated that the siren system is-periodically checked but

. no written procedures to provide surveillance and maintenance were available. The licensee plans to develop a formal program to main-tain the sirens and assure the reliability of this prompt alerting system at PBAPS, as stated in the Plan.

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50-277/83-33-02, 50-278/83-31-02 (Closed) Incorporate-revisions to the

[PBAPS] Emergency Plan as shown in Enclosure I to this inspection report 4 [50-277/83-33,50-278/83-31] during the next revisio l

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The inspectors held discussions with the Director of Emergency Planning for PECO concerning revisions to the Emergency Plan, requested in En-

closure 1 of Inspection Report No. 50-277/83-33, 50-278/83-31 inspectors noted that most concerns detailed in Enclosure 1 will be addressed in the July 1985 Emergency Plan revision. The exceptions are as follows:

l (3) 30-minute minimum staffing for the emergency organization. The

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licensee has requested an exception (4/15/83)*, and;

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(7) whether the TSC, E0F and OSC meet the design criteria of NUREG-069 A detailed description of the design of the TSC and E0F is provided l i in correspondence dated: 1/2/80; S. L. Daltroff, PECO, to '

H. R. Denton, NRC and 6/1/81; S. L. Daltroff, PECO to D. G. Eisenhut, NRC. The licensee has requested an exception to some of the re-

, quirements(4/15/83)*.

• Letter to Mr. D. Eisenhut, Division of Licensing (4/15/83), Sub-ject: Response to NUREG-0737, Supplement 1.

50-277/83-33-06, 50-278/83-31-06 (0 pen) Consider actual meteorological

measurements in the rapid dose assessment calculation.

The inspectors reviewed EP-316, the licensees rapid dose. assessment

, method, held discussion with the licensee and noted that plans to revise the dose assessment method include adapting a new refined dose model. An i interim procedure will be considered by the license /83-33-07, 50-278/83-31-07 (0 pen) Consider possible ground level release pathways in the dose assessment calculation; for example, an un-

monitored release from a steam-line break acciden The inspectors reviewed Section 14.6.5 of the PBAPS FSAR, held discussions with the licensee and noted that a methodology to consider possible un- '

monitored ground level release pathways would be developed. The licensee

stated that.the procedure will be completed prior to the October 1985

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annual exercis /84-33-01, 50-278/84-27-01 (Closed) Failure to provide accurate

initiating conditions for identifying severity of emergencies within EP-101, Rev. The inspectors reviewed PBAPS EP-101, Rev. 9, 10 and 11, discussions were held with the licensee's chemistry staff and certain emergency action level calculations were checked. The licensee indicated and the inspec-

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tors verified that the offsite Dose Calculation Model used to determine

the set points in EP-101, Rev. 11 was as recommended in NUREG-0133. The inspectors determined that the model calculations are correct and con-servative. A check of the instrument settings showed they are on scale and consistent with calculations and Technical Specification limits 3.8.C.1. The licensee also. indicated that new chart paper was ordered to i

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, allow operations to increase the scale on RR-3/3979 the stack vent mon-i itors to 10**com.

l 50-277/278/85-03-01 (0 pen) Modification of EP-315 to conform with gen-i erally accepted NRC guidance on atmospheric dispersion calculations for emergency preparedness, which includes a method to determine atmospheric stabilit The licensee has indicated that they are currently in the process of up-grading their program in this area. The inspectors determined that more information about the planned scope of the upgrades and modifications were '

necessary to resolve this item; the licensee has agreed to provide more information during future inspections and plans to complete the program revisions by October 198 /278/85-03-02 (Closed' Provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing capability for radiological assessment in the PBAPS emergency response organization.

t A review of. the various appendices of EP-209, all dated 1985, shows at least two names for each position. The Alternate Dose Assessment Team Leader position will be double staffed to include plant personnel as in-

dicated in a memo dated 6/14/85. Appendix P is the 60 minute call-out is for key personnel who in-turn call needed and available staff. This item is close /278/85-03-04 (0 pen) Provide the required emergency preparedness

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training as identified in PBAPS Emergency Plan (12/83) Section 8, "Emer-gency Plan Training".

The Emergency Response Training Program has been INPO certifie Seven-teen detailed and seven abbreviated lesson plans have been or are in pre-

paratio Several PBAPS staff members (200-250) whose names are listed in the EP-209 series will be trained by 20 September 1985. Two lesson plans judged by the inspector to be of. excellent quality have been received and

the two fundamental courses are now being offered. Shift supervisors, shift technical assistants and technical staff are being trained. No key managers have received training. The delay in the start of training is attributed to the inability to identify and qualify instructors. Nuclear Site Training will track staff training against a matrix and document trainin PECO Corporate ER group is responsible for the training pro-gram. Stone and Webster has been contracted to prepare lesson plans and hold the training courses. While the licensee has shown good faith and

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has made progress, training is still incomplete and the violation will remain open.

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50-277/278/85-03-05 (Closed) Licensee emergency preparedness audits did not address: specific program requirements for emergency planning in the audit scope; NRC deficiencies identified during the emergency preparedness ,

exercises, and follow-up actions needed for problems identified ( i training) by audit The inspectors held discussions with a senior engineer in the QA division

, and emergency plan coordinator. The inspecters reviewed the audit in-t struction plan revision dated 6/85 and determined that the program and scope planned for the August 1985 audit will provide for a more detailed audit and follow-up progra Analysis of Puff Release

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3.1 Background The PBAPS Unit No. 3 reactor water clean-up system was isolated at 3:00 P.M. on May 22, 1985 to permit repairs to a valve seal. When the system was returned to service, a series of puff releases took l'

place beginning 12:35 A.M. on May 24th. The puffs contained filtered

noble gases, the activity of which exceeded a trip point value for Unit 3 vent monitor RR-3979. Annunciation was given. The Shift Technical Advisor'followed the procedures in EP-101, Rev. 09, page 4 of 12 to determine if an environmental technical specification had been exceeded following the instantaneous release. If so, a dec-

laration of Unusual Event is required. The Shift Technical Advisor's calculations indicated the resulting dose equivalent was 15.7% of the

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annual permissible total body dose. An Unusual. Event was not de-I clared since Environmental Technical Specification 3.8.C.1 values i

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were not exceeded. Following the release, the reactor water clean-

-up system was again isolated and corrective repairs made. The system was returned to service without incident on May 25t EP-101, Rev. 9 specifies use of an arithmetic scaling operation to determine if tech specs are exceeded. The peak count rate is

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divided by a count rate resulting from continuous operation for a year which will give rise to a fraction of the specified total body '

dose limit of 500 mrem /yr. Following the event, the licensee's-staff reviewed EP-101 and changed the value of the denominator used in the scaling operation. The-change resulted from altering.the fraction of 1 the annual total body dose assigned to each of the three site release-

point A plastic beta scintillator coupled to a photomultiplier tube mon-

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itors the reactor building vent flow. The output of the photomul-tiplier tube is " fed" to an eight decade digital device, the output of which is converted to a voltage analog which produces tracings on a strip chart recorder. The trigger values are marked on the strip J

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l chart recorder face and are correlated with emergency classifica-l tions. The upper range cf the strip chart recorder is 10 10 cpm; this t

value is two decades below the upper range for the digital devic .2 Review This area of the licensees emergency response was evaluated against

the references cited below to determine if

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-- the calculational methodology used is appropriate;

-- the licensee's staff calculations were correctly performed;

-- the PBAPS Unit 3 vent monitoring system is properly calibrated;

-- cognizant licensee personnel are aware of the basis for the methodology used and uncertainties in the calculational model; i -- the revised denominator term was correctly determined, and;

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-- the trip point value for PBAPS Unit 3 vent monitor RR-3/3979

is correctly se .

3.3 Findings The inspectors concluded that licensee personnel were generally

knowledgeable and did not error when computing the revised denom-inator and set point. The methodology used is outlined in the

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licensee's Offsite Dose Calculation Manual,Section IV. The revised

value is based on assigning 150 mrem / year as the contribution to i

total body dose following releases from the stack and each reactor j building vent. The revised EP-101 is identified as Rev. 1 Procedures specified in license Surveillance Test (ST) 7.6.3, Rev. 3, dated 2/20/85 are followed when calibrating the system. Kr-85 is l used as the source when calibrating the system. Three different con-centrations are used to develop a calibration curve the slope of

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which is the calibration facto Range bars are not drawn and the

, curve is not analytically fitte Error analysis is not undertaken.

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The' inspectors determined the trigger point for the vent monitors to be correctly set and the upper range of the digital device and strip chart recorder to match each other. The inspectors concluded im-provement.is necessary in the presentation of calculational results and calibration related information, the-following changes were identified:

• the calibration curve is a correlation curve and should be so named,. redrawn annually, and dated;

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= the " calibration" curve should be: drawn with range bars associ-ated with data points, with the slope analytically determined by

" fitting" the data, and with a " running" curve covering all years of

operation No violations were identifie !

3.3 References NUREG-0654, Rev. I 10 CFR 20 Table I, Appendix B PBAPS, EP-101, Rev. 9, 10 and 11, " Classification of Emergencies".

PBAPS Surveillance Test 7.6.3, Rev. 03, 2-20-8 PBAPS Technical Specifications, Limiting Conditions for Operation 3.8.C.l.

PBAPS Offsite Dose Calculational Manual (undated).

4.0 Emergency Response Training

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4.1 Review During the course of an inspection conducted during the period January 7 to 11,1985, a Severity Level V Violation was [50-277/

85-03-04,50-278/85-03-04] identified. The violation was based on

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training not meeting the requirements in Section 8 of the PBAPS Emergency Plan of 12/83. Table 8.1 of this plan, a training matrix,

, was not being followed. Training was not current and staff requiring training were not being trained. This area of emergency preparedness

, program was evaluated against the references given in Section below to determine if the licensee had remedied, by appropriate ac-

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tion (s), those problems which resulted in the above cited violation.

{ 4.2 Findings i The Emergency Response Training Program is now certified by the Institute of Nuclear Power Operations. Seventeen detailed and seven abbreviated lesson plans have been completed or are in preparation.

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Only two lessen plans were available at the time of this inspec-tion. These were judged to be of excellent quality by the inspec- ,

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tors. Two experienced trainers (both contractor employees) are on '

i staff. Several PBAPS staff members (200-250) whose names are listed

' in EP-209 series will be trained by September 20,-1985. Shift Supervisors, Shift Technical Assistants and Technicians are being

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trained. Key managers have not been trained as yet. Philadelphia Electric's Corporate Emergency Response Group is responsible for the

training. The Nuclear Site Training Group will administratively

support this effort as well as documenting and tracking staff train-ing against a training matrix. Two training sessions were audited, in part, and judged to be well prepared and delivered. The lesson

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plan was.followed. Group control was maintained by the instructor and questions were answered promptly and correctly. While the licensee has made progress and shown good faith, training is still incomplete. The reason given for the delayed start was inability-to identify and hire qualified instructor The Severity Level V violation remains ope .3 References Combined Inspection Nos. 50-277/85-03 and 50-278/85-03 10 CFR 2, Appendix C 10 CFR 50.47 and 50.54 Appendix E to 10 CFR 50 PBAPS Emergency Plan, Section 8 Regulatory Guides 3.1 of 1978 and 1982 and 8.27 PBApS Procedure EP-209 Rev. 08 and 09 INPO 82-026, Guideline, " Technical Instructor Training and Qualification".

5.0 Licensee Audits 5.1 Review The inspectors reviewed the PBAPS Emergency Plan section on program audits, held discussions with an engineer of the QA division and emergency plan coordinator. This area of the emergency program was evaluated against the references listed below, to determine:

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that an independent review has been conducted every 12 months in accordance with 10 CFR 50.54(t);

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that the recommendations, apparent deficiencies and non-com-pliance items identified by the auditors and the NRC were tracked and adequately resolved, and;

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the scope of the audits were defined and included evaluation o the adequacy of the interfaces with State and local govern-ment .2 Findings The inspectors found that audits were performed on a yearly basis for 1982,1983 and 1984. The audit program clearly established the frequency (every year) for the review; however, the inspector noted the scope of the audits were not well defined and subsequent reviews were inconclusive for 1982 and 1983. The licensee recognized the problem and has taken steps to improve the program. The interfaces with State and local government agencies will be reviewed annuall _

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l The PECO audit instruction, the basis for the yearly audit, was re- i vised to include a more detailed app' roach and the senior QA engineer will review the audit scope prior to the inspection. The next sched-

! uled licensee audit of EP is August 198 l

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Based on the above, the Audit Program appears tro be in compliance l with the requirements, t

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l 5.3 References i

'i PBAPS Emergency Plan Section 9 (12/83), " Emergency Plan Review".

Letter to R. S. Fleischmann from J. G. Fungheiser (12/17/84),

Annual Review of the Peach Bottom Emergency Pla CFR 50.54(t) (1/1/85).

6.0 Exit Meeting

The inspectors met with representatives of the PEC0 staff, indicated in

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Section 1, on June 14, 1985. No violations were identified as a result of the inspection. The licensee indicated that further steps would be taken to resolve the remaining open items in the Emergency Preparedness j area, i

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