IR 05000277/1986008

Mgt Meeting Repts 50-277/86-08 & 50-278/86-08 on 861016. Major Areas Discussed:Licensee Identified Noncompliances of 10CFR50,App R Requirements & Plans to Achieve Compliance, Including Timetable for Completing Mods

ML20214D258
Person / Time
Site:	Peach Bottom
Issue date:	11/13/1986
From:	Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214D232	List: IR 05000277/1986008 ML20214D229
References
50-277-86-08-MM, 50-277-86-8-1, 50-277-86-8-MM, 50-278-86-08, 50-278-86-8, NUDOCS 8611210440
Download: ML20214D258 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-277/86-08 Report Nos. 50-278/86-08 50-277 Docket Nos. 50-278 DPR-44 License Nos. DPR-56 Priority --

Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Units 2 & 3 Meeting at: U.S. NRC, Region I, King of Prussia

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Meeting conducted: October 16, 1986 NRC Personnel: ~-

_g[/ 3 !88 A: 'G.V Kra sopou10:. , Reactor Engineer, DRS ' date Approved by: b //

C. #nderson, Chief, Plant Systems Section date Meeting Summary: Management Meeting at the NRC Region I office on October 16, 1986 to discuss licensee identified non-compliances of the 10CFR50, Appendix R requirement The licensee described the non-compliances and the interim compensatory actions taken pendina full compliance with the requirement The licensee also described their plans to achieve full compliance and they presented a timetable for completing the modifications required for compliance.

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8611210440 DR 861114 ADOCK 05000277 PDR i

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DETAILS 1.0 Participants

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1.1 Philadelphia Electric Company (PECO)

W. Alden, Engineer in Charge, Licensing W. Birely, Senior Engineer, Licensing W. Boyer, Supervising Engineer W. Brady, Engineer R. Lees, Assistant Chief Electrical Engineer W. Mindick, Senior Engineer

G. Morely, Supervising Engineer G. Reid, Senior Engineer C. Swenson, Compliance D. Spaner, Engineer G. Termino, Engineer U.S. Nuclear Regulatory Commission (USNRC)

C. Anderson, Chief, Plant Systems Section J. Durr, Chief, Engineering Programs Branch

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P. Eselgroth, Chief, Projects Section 2A G. Gears, NRR Project Manager T. Johnson, Senior Resident Inspector

, A. Krasopoulos, Reactor Engineer S. Pullani, Lead Reactor Engineer 2.0 Background The inspection of Peach Bottom Units 2 and 3 during March 17-21, 1986 for compliance with the 10CFR50, Appendix R requirements resulted in the issuance of a Conformatory Action Letter (CAL) by the Region on April 11, 1986.

r The CAL specified the licensee's schedule to complete the Appendix R Safe Shutdown confirmatory program and stated that they would inform the Region

if any violations from the Appendix R requirements are identified.

l The purpose of this Management Meeting was to discuss: the Appendix R violations identified by the licensee as requested by the CAL; the interim compensatory actions taken and the long term corrective actions planned by the license .0 Presentation and Discussion Following the initial introductions, Mr. Jacque Durr, Chief of the l

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Engineering Programs Branch opened the meeting by asking the licensee to describe the violations as identified by their safe shutdown re-evaluation.

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The licensee distributed a document titled " Appendix R Task Force Deficiency Summary" which is included as Attachment 1 to this repor The licensee proceeded to explain that their re-evaluation of the safe shutdown capability identified about 50 deficiencies in about 20 fire area The deficiencies were classified as falling into three categories:

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Changes in initial assumptions

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Spurious Operation

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Other items The licensee stated that they have established, as an interim compensatory '

measure, fire watches to patrol the affected areas pending their achieving full complianc The adequacy of the fire watches established by the licensee was questioned by Regional Management. The licensee indicated that they would consider enhancing their program of interim fire watche The licensee stated _that Unit 2 compliance would be given highest priorit Full compliance with Appendix R for Unit 2 is scheduled for the end of the spring 1987 refueling outag However, for Unit 3 full compliance is scheduled for the next Unit 3 refueling outage in late 1987. Regional Management stated that a I

justification for continued operation should be prepared for NRC review.

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Attachment 1 PHILADELPHIA ELECTRIC COMPANY APPENDIX R SAFE SHUTDOWN ANALYSIS AGENDA i

Introduction W. M. Alden R. J. Lees Overview of Task Force Review W. J. Boyer Deficiencies and Causes W. J. Mindick Compensatory Actions W. C. Birely Corrective Actions W. J. Boyer Implementation of Corrective Actions W. J. Boyer l

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APPENDIX R TASK FORCE DEFICIENCY SUMMARY I. Changes in initial assumptions:

l Associated DC loads were not included in the battery calcula-tions. Calculations now include the largest credible high im-pedance fault. The effect is that batteries are depleted at a faster rat Area Parameter 13N-I Instrument power * (MOD 2085)

2-III DG exciter control (MOD 2078)

2-IV Reactor press, torus temp, drywe11 tem (MOD 2085, 1029E)

• These items also resulted from the censolidation of fire areas without proper review of instrumention concern Hot shorts and grounds on the ungrounded DC system were originally assumed to not cause undesired effect Un-grounded DC systems are new assumed to become grounded as a result of the fire and the potential for blown control fuses and spurious operation are now included in the analysi Area Effect 43II, 44I, 45I, 46I Blown control power fuse for ESW (MOD 1351D)

37-II, 38-I, 39-I, 48-I, 50-II Blown control power fuse for ESW (MOD 1351D)

351, 36II, 37III Tripping of RHR pump breaker (MOD 2078)

6S-I Tripping of HPCI (MOD 1457)

turbine Previous analyses did not address putting excess inventory into the reactor vessel. The analysis now reflects the need to shut down systems which are not required for safe shutdown but which could cause the loss of the safe shutdown capabil-ity by overfilling the reacto . . ,__ . _ - - -- . -

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Appandix R Task Force -2-

Deficiency Summary

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Area Effect 6S-I, 13N-III, 13S-II Inability to isolate

. HPCI (MOD 2080)

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25-IV Inability to isolate RCIC (MOD 1352A,

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1353A)

i Previous analyses did not include consideration of separation between manholes for imbedded conduit The analysis now examines the separation between redundant cables within the various compartments of the manhole Area Effect

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50-II Less than 3 hr. sep-Yard aration between re-dundant HPSW/ESW

pumps (MOD 2078)

Yard Less than 3 hr. sep-aration between re-dundant DG cable (MCD 2091) Previous analyses assumed that instrument air could be es-tablished for a fire in Fire Area 13S by cross-connecting the

! Unit 2 and Unit 3 headers. It has been determined that this solution is not feasible due to timing constraints and the possibility that parallel air headers may be damaged by the fire such that pressure could not be maintained. (FA-13SIII MOD 1950)

Previous Hi/Lo pressure boundary analyses did not factor the environmental effects of a Hi/Lo pressure boundary failure into the safe shutdown analysis. Fire damage to the control cables of the RPV head vent valves could result in the in-crease of drywell temperature, which has potential adverse effects on equipment operabilit I Spurious operations

! Spurious operations that occur at inopportune times could re-sult in equipment damage.

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! Fire damage to logic cables in the RHR system could

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cause the RHR pump-breakers to close prior to power being available from the emergency bu If this oc-curs, the breaker logic will trip and lock up and must be cleared at the switchgear prior to restarting the pum (FA-34-III MOD 2078)

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, Appendix R Task Force -3-Deficiency Summary 4 Fire damage to logic cables could start the RHR pumps with no minimum flow protection on the pump. The avail-able time before damage occurs to the RHR pump is con-

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sidered to be too short for the operator to recognize the situation and to take manual action to secure the

! RHR pum (FA-6S-II, 13N-II MOD 2084) Spurious operations of equipment or components that could de-feat system function that were overlooked or not included in previous analyse . Fire damage to the fire protection system cables in the diesel generator building could initiate CO, injection in individual diesel bays. Since the dieser takes com-bustion air from its room, the diesel would stop on loss of ai (FA-44II, 45II, 46II, 54II MOD 2078) Fire damage to control cables for the ESW sluice gates could cause these gates to close and block ESW flow path. (FA-25II, 39II, 50I lock open sluice gates) Fire damage to control cables for the ESW discharge valve could cause the valve to close and block the ESW flow pat This item was identified, but not installed for Alternative Shutdown and overlooked for Safe Shutdow (2-I, 25-III, 34-II, 36-III, 43-I, 54-I MOD 2079) Fire damage to logic cables for HPCI could isolate the system. (13S-I MOD 2078) Fire damage to bus current transformer cables could trip the bus and lockout the diesel generator breaker (34-I, 35-II, 36-I, 37-I MOD 2078) Fire damage to control cables for a HPCI AC valve could cause the valve to close and disable the HPCI syste (FA-25I Mod 1352A, 1353A)

II Other items 1 The field walkdown of safe shutdown conduits identified that some safe shutdown conduits were inaccurately shown on de-sign drawings. (2-II MOD 2085) Fire damage in FA-30 results in the loss of both the primary and backup power sources to the RHR and HPSW flow instrument (MOD 1029E, 2085)

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. Appendix R Task Force -4-Deficiency Summary Emergency lighting was installed for analyses submitted 9/16/83, 7/11/83, and 7/22/83. During subsequent analysis, further installations of emergency lighting was de ferred pending final design of Alternative Shutdown and completion of the Safe Shutdown reverification program. The locations have now been identified (Table A-4 of FPP) and design for installation is in progress. (MOD 2081) Fire damage results in the loss of power to a diesel genera-tor auxiliary motor control center. The diesel is used for safe shutdown in the area. (6N-II, 40-I MOD 2078) The associated circuit analysis identified one molded case circuit breaker which requires a trip setpoint change to pro-vide proper coordinatio (Associated circuit by common power source) (MCD 2083) The associated circuit analysis identified a motor control center section 20DllA separated from its main motor control center 20Dll that had no overcurrent protection. (Associated circuit by common enclosure) (MOD 13S2A, 1353A) Fire damage in Unit 3 results in the loss of a Unit 3 torus temperature loop fed from a common unit power supply. (13N-I)

(MOD 2085)

I Previously identified items Unit 2 Process and Diagnostic Instrumentatio Previous commitment was for end of upcoming Unit 2 re-fueling outag (Mod 1029E) Frovide thermal magnetic trip devices to MCC Previous Associated Circuit Analyses identified need for thermal magnetic breaker Modification was on hold pending equipment qualification of device (Mod 1029J, K, L) Spurious closure of HPCI and RCIC steam valves The potential for these valves to defeat system operation was identified during the 3/86 audit and reported en 5/22/86. This report identified the condition on one RCIC valve and one HPCI valve. The reverification iden-tified the concern on one additional RCIC valv (Mod 2079) Unit 2 relief valve capability Previous commitment was for end of upcoming Unit 2 refueling outage (Mcd 1950)

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- . Appendix R Task Force -5-Deficiency Summary

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i i Testable check equalizer valves on RHR and CS.

Previous Hi/Lo pressure boundary analysis identified

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need to address valves. Mechanical analysis now demon-

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1 Unit 2 and Common Alternative Shutdown ~

i Previous commitment was for end of upcoming Unit 2 re-j fueling outage (Mod 1351,1352) -

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