IR 05000277/1988013
| ML20195D243 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/08/1988 |
| From: | Linville J, Williams J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20195D228 | List: |
| References | |
| TASK-2.B.3, TASK-2.F.1, TASK-TM 50-277-88-13, 50-278-88-13, NUDOCS 8806230077 | |
| Download: ML20195D243 (37) | |
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V. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket / Report No. 50-277/88-13 License No OPR-44 50-278/88-13 DPR-56 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station Units 2 and 3 Inspection At: Delta, Pennsylvania Dates: April 23 - June 3, 1988 Inspectors: T. P. Johnson, Senior Resident Inspector R. J. Urban, Resident Inspector L. E. Myers, Resident Inspector Reviewed By: .
- d## h9 H: Wi'liams, Project Engineer ' date Approved By: /4 '. Gfn vil l e , @4f, ' date ctor Projects Section 2A, vision of Reactor Projects
~ Summary Areas-Inspected: Routine, on site regular and backshift resident inspection (138 hours0.0016 days <br />0.0383 hours <br />2.281746e-4 weeks <br />5.2509e-5 months <br /> Unit 2; 135 hours0.00156 days <br />0.0375 hours <br />2.232143e-4 weeks <br />5.13675e-5 months <br /> Unit 3) of accessible portions of Unit 2 and 3, operational safety, radiation protection, physical security, control room activities, licensee events, surveillance testing, refueling and outage activities, maintenance, and outstanding item Results: The licensee identified four violations during the perio Two were associated with failure to submit a special report regarding the control room Cardox system (section 6.2.5) and failure to submit an LER in 30 days (section 6.2.7). The Technical Specification operability and testing requirements for shutdown cooling isolation instrumentation and i logic is unresolved (section 4.1.2). Event follow-up was conducted. The third licensee identified violation (section 4.2.4) was noted for failure to follow a surveillance test procedur Incorrect oil was found in the 2B RHR pump motor upper reservoir (section 4.2.1). Weaknesses were noted with respect to post maintenance testing and turnover following maintenance and modification work (sections 4.4.1 and 11.3). Concerns were identified with
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electrical safety precautions (section 8.2). Good follow-up by licensee personnel was noted for two radiological control events (section 9.2, and 11.2). The fourth licensee identified violation was associated with radiography procedures (section 9.3). Shift Manager oversight of operations activities was determined to be good (section 11.1). Weaknesses were noted with respect to protected area barrier drawings and the security plan (section 10,5).
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TABLE OF CONTENTS Page l
l l 1.0 Persons Contacted............................................ 3
} 2.0 Facility and Unit Status..................................... 3 3.0 Previous Inspection Item Update.............................. 3 4.0 Operations Rev1ew........................................... 10 4.1 Station Tours..................................... .... 10 4.2 Followup on Events............ ........................ 13 4.3 Logs and Records....................................... 18 4.4 Ref uel i ng Outage Activi ti es . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 4.5 Engineered Safeguards Features System Walkdown. . . . . . . . . 22 4,6 Plant Operations Review Committee (PORC) Positions. . . . . 22 4.7 Peach Bottom Simulator Evaluation...................... 23 5.0 Emergency Preoarednesc....................... ............... 23 6.0 Revi ew of Li censee Event Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 7.0 Surveillance Testing.......... ............................. 27 8.0 Maintenance Activities.......................... ........... 27 9.0 Radiclogical Controls.... .................................. 30 10.0 Physical Securit ... ... ................................ 32 11.0 Assurance of Quality............................. ......... 34 12.0 In-Office osvitw of Special Reports......................... 35 13.0 Unresolved Items............................ .. ..... ...... 35 14.0 Management Meetings......... . .... . ..... ............... 35 I
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DETAILS 1.0 Persons Contacted
- J. M. Cockroft, Superintendent, QA J. B. Cotton, Superintendent, Operations T. E. Cribbe, Regulatory Engineer G. F. Daebeler, Superintendent, Technical
- D. J. Foss, Compliance Engineer
- J. F. Franz, Plant Manager
- 0. E. McGarrigan, Superintendent, QC
- J. B. McLaughlin, Modification Engineer J. C. Oddo, Nuclear Security Specialist
- F. W. Polaski, Assistant Superintendent, Operations K. P. Powers, Peach Bottom Project Manager J. M. Pratt, Manager, Peach Bottom QA G. R. Rainey, Superintendent, Maintenance D. M. Smith, Vice President, Peach Bottom Atomic Power Station Other licensee and c;atractor employees were also contacte "Present at exit interview on site and for summation of preliminary finding .0 Facility and Unit Status 2.1 Unit 2 The unit remained in cold shutdown during the inspection perio Reactee vessel disassembly was performed in order to conduct inspections on the reactor vessel shroud access manways. System maintenance outages continued during the period. Plant modifications, corrective and preventive maintenance, and system testing were performe .2 Unit 3 The unit remained defueltd, and RHR and recirculation pipe i installaticn in the crywell continued during the inspection period. At the end of the period, pipe installation was 80%
complet .0 Previous Inspection Item Update (92701, 92702)
3.1 (Closed) Inspector Follow Item (277/86-12-04, 278/86-13-04).
Information tags are neither controlled nor auditabl The i
licensee revised the procedures for controlling information tags.
l These tags either reference an operator aid control number per
- procedure A-95, or a blocking permit number per procedure A-41.
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The inspector reviewed administrative procedures A-26, 41 and 95;
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'hecked selected tags in use on the control room panels; and, c
discussed this item with licensee operators, engineers and '
management personnel. The inspector noted-that information tags in use had a controlled number. In discussions with' operations management personnel, the inspector noted that the licensee intends'to include.the use of information tags in the operations
"Watchstanding Manual" which is being written. In addition, in-place information tags are also being reviewed for possible incorporation into permanently mounted operator aids on panels inside and outside the-control room. The inspector follow. item is close .2 (Closed) Inspector Follow Item (278/86-07-02). Control rod blade (CRB). cracking and. follow-up per GE rapid information communication service information letter (RICSIL) number 2. The affected CRB design was modified by machining the bale handle and i spline to allow water flow past the crud. trap area. In addition, the sheathing weld was changed from a complete weld to an !
intermittent weld. Thirteen spare CRBs were returned to GE for rework. The CRBs were then inspected, accepted and used in Unit 3. Three CRBs removed from the Unit 3 core were also inspected and documented in report NEOC 31493A dated December 198 The inspector discussed this item with licensee engineers and had no '
furt er questions at this time. The inspector follow item is i considered close .3 (Closed) Unresolved Item (277/86-25-06). Periodic underwater !
visual examination of sluice gates. The emergency service water I and high pressure service water sluice gates (MO-2233A/B and
M0-3233A/B) provide isolation of the pump structure from the river intake. The sluice gates were periodically tested; however, no -
7 underwater visual inspection was performed. The licensee reviewed their preventive maintenance (PM) program. The PM program was modified to include a once per refueling diver inspection of the .
sluice gate, frame, and seat surfaces. The Unit 2 gates were !
inspected on June 3, 1987, per maintenance request form (MRF) i rumber 866208 Results indicated that both gates were fully i
seated. The Unit 3 gates are scheduled to be inspected per MRF number 8762225 and The inspector reviewed the PM records and
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MRFs, and discussed this item with licensee engineers. Based on the above, the unresolved item is close ;
3.4 (Closed) Violation (277/88-01-03). Improper issuance of '
respiratory protective devices. A worker was issued and used a i respiratory protective device for which he was not qualified. The ,
licensee responded to the violation in a letter dated March 28, ;
198 Procedure HP-512, "Issuance and Control of Respiratory
Equipment", was revised to clarify responsibilities of issuance
, attendants to issue only equipment for which the individual was L qualifie The attendants were subsequently trained in the
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revised procedure. The lesson plan for training issuance-attendants emphasizes the qualification requirements including the
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proper size of the mask. The inspector discussed this with
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licensee personnel and had no further questions. The inspector also verifieo that other corrective actions were performed as ,
stated in the licensee's response letter. Based on the above, the violation is close .5 (Closed) Violations (277/87-07-04; 278/87-07-03 and 277/87-24-02; 278/87-24-02). Failure to survey adequately and to properly post radiation areas. The licensee responded to these violations in letters dated June 10, 1987, and February 17, 1988. The licensee initiated a comprehensive program of procedure revisions, technician upgrade and evaluation, and training as corrective actions to prevent recurrence. The Health Physics Deficiency Report Procedure, HP-600, has been replaced with procedure A-110,
"Radiological Occurrence Reports" This procedure is an administrative procedure that provides for immediate involvement in corrective action by the applied health physics supervisor and timely follow-up corrective actions. Several recent incidents have demonstrated its effectiveness in providing timely corrective actions (see section 11.0 of this report). The procedure for
"Establishing and Posting Controlled Areas" was superseded by HP-215, Rev. 2. This new pro;edure defines the classification for posting and eliminates posting signs on radiation rope, which when dropped, temporarily could degrade the posting. Procedure A-108, Rev. O, "Control of Radioactive Material", was written to delineate responsibilities for control of radioactive material, and to provide for the release of radioactive material from radiation areas, and from areas in radiologically controlled areas tc unrestricted area In addition, this procedure specifies the methods for control of hot particle In AugJst 1987, Applied Health Physics was reorganized to provide first line supervisors who have area responsibilities and authority. Contractor personnel used as senior health physics technicians will meet the experience standards of ANS/ ANSI ' Performance evaluation programs have been implemented for all technicians. A weekly "all hands meeting" has been initiated to discuss current events, practices, station information and other items of interest. The periodic training program for HP technicians will uncergo revisions based upon the technician's performance evaluation and will be implemented in the near futur Based upon review of the licensee's response, revised procedures, and immediate and follow-up corrective actions, the inspector had no further questions and the violations are close .6 (0 pen) Violation (88-10-01; 88-10-01). Seismic Mounting of Control Room Panels. Certain control room and cable spreading room panels were not mounted in accordance with the original
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' design, Therefore, these panels may not be able to withstand a seismic event.~ LER 2-88-05 adequately addressed the violation, so no written response was requeste The inspector reviewed Modification Package 2376, "MOD for a Control Room Panel Anchorage Evaluation." ihe MOD package contains all relevant information, including _the safety evaluation and engineering work letter (EWL). In' order to expedite th modification, a decision was made to modify _all of the control room panels and the suspect cable spreading room panels, taking no credit. for existing weld The modification used for all'the panels is based on worst case loading using peak seismic accelerations. The buic modification consists of 1-1/2 inch long fillet welds between the panel base channel and the floor
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embedment. These welds are to be' spaced at nine inch intervals on the exterior portions of the panels. The inspector witnessed in progress welding (sec' ion 8.1) and noted that al; necessary precautions stated in che EWL were being followed. The inspector examined several completed welds and found them to be adequat No violations were noted. This violation will remain open pending review of the updated MOD package (details to repair cable spreading room panels), further inspection on in progress welding, and completion'of the modificatio .7 '(Closed)-Inspector- Follow Item (277/83-35-01; 278/83-33-01). Post accident sampling system (PASS) items associated with TMI Action
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Plan (TAP) items II.B.3 and II. These TAP items were inspected in NRC Combined Inspection 277/83-35-01; 278/83-33-0 Open items associated with these TAP items and the licensee's resolution are described below:
TAP Item II. . Installation of the dissolved gas modification (M00) for the existing PASS at Units 2 and 3. The licensee's action on this item was initiated upon receipt of the MOD kits from Generil Electric (GE), MOD 580 was performed on both units
'or this dissolved gas system. Modification Acceptance Test sMAT) 580 was completed on Unit 2 in July 1935 and on Unit 3 l
in May 1987.
!y Establishment of surveillance test (ST) procedures for the L PASS ano associated analytical systems addressing instrument calibration and test on a scheduled frequency. The licensee developed and implemented the following STs to address this item: ST-7.6.9, 7.6.9a, 7.5.7, 7.5.8, 2.25.37.1 thru 4.
i The establishment of procedures or guidelines addressing the preparation and set-up of the Unit 1 facility for
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-8-post-accident analysis, and management of analytical sequence of PASS sample The licensee developed and implemented procedure EP-205. A15 to address this ita . Establish analytical data sheets that consider the effects of dilution on reported analytical results. The licensee developed these data sheets in procedure EP-205.A1 . Train and qualify sufficient numbers of personnel in post-accident laboratory procedures. The licensee currently has nine qualified personnel per Training Manual PAA (Post Accident Analysis) #668. Requalification occurs every 18 month . Evaluate the adequacy of current sampling bottles in PASS operation; consider the use of large mouth bottles for sample acquisitio After GE evaluation, the licensee acquired for use large mouth sample bottles for PASS operation This was responded to in a letter to the NRC dated 2/16/8 . Evaluate the representativeness of air samples collected from the PASS in view of long sample line lengchs, low flow velocity and right angle bends. The licensee responded to this request in a letter dated 2/16/8 . Provide a safety evaluation for the use of the Unit 1 facility as a laboratory for the analysis of post accident samples. The licensee performed an analysis, #657 safety evaluation dated 3/28/84, that concluded that no unresolved safety question was involve TAP Item II. . Identify the typ-i of detectors utilized in the high range noble gas monitor and provide response characteristic The licensee identified the detector type as a plascic scintillator and provided documentatio . Evaluate and amend as necessary the dose conversion factor used in Emergency Procedure EP 316. The licensee indicated that the conversion factor had been evaluated and was found to be excessively conservative. The procedure (EP 316) was revised to reflect a more realistic assessmen . Evaluate the capability of analyzing iodine cartridges having dose rates in excess of 200 mrem /hr and revise procedures as necessary. The licensee evaluated this item and revised procedure EP-205.A1 . - - _ _ _ _ _ _ ___ - _ _ _ _ _ . - _ _ _ _ _ _ _ _ _ _
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_ . Evaluate the significance.of exposure to personnel when removing filters from the high-range effluent monitoring system during post-accident conditions; and shield, relocate or amend the sampling method as necessary. The licensee developed a revised method-of sampling effluents. Procedures
~ST 7.5.lf and ST 7_.6.9 implement this revised metho . Develop _a surveillance procedure to address calibration and testing of containment high-range monitors. The licensee developed surveillance procedures ST 7.6.8 and ST 4.8.2-2/3)
i to perform this calibratio NRC Review The inspector reviewed the following documentation:
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. TAP Items and NUREG 0737 requirements,
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licensee correspondence referenced,
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licensee procedures and safety evaluation referenced above, and other related test, operating and maintenance procedures, In addition, the inspector walked down portions of the Unit 2 and Unit 3 PASS with the system engineer. Simulated actions to obtain-PASS liquid-and gaseous samples were observed per licensee implementing procedures.' The inspector determined that the system l engineer and chemistry personnel were knowledgeable of PASS design, operations, testing, and maintenance activitie In addition, PASS activities have been reviewed during previous annual emergoncy plan exercise Based on the above', the open item and TAP Items II.B.3 and II. are closed for Units 2 and .8 (Closed) Unresolved Item (277/84-23-01; 278/84-18-01). Improve procedural controls for containment air sampling system. This item was updated in NRC Inspection 277/85-26 and 278/85-26. TL -
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licensee has revised procedures ST 9.17-2 (Rev. 5), ST 9.17-3
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(Rev. 8) and ST 4.8.3 (Rev. 3) to include requirements for increased containment air sampling when the containment sump pumpout system'is out of service or when increased pumpouts are noted. The inspector reviewed these procedures and Technical Specification 3.6.C and 4.6.C. No unacceptable conditions were noted and the unresolved item is considered resolveu and close .9 (Closed) Unresolved item (277/87-3i-04, 278/87-32-04). High Pressure Service Water (HPSW) pump discharge eneck val'.e operability tes Surveillance testing (ST) sid not rovide aay explicit provision to verify that backflow througn an idle HPSW
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pump would not occur. The licensee revised procedures ST 6.10-2 and ST 6.10- Revision 9, step 9 of these STs provides for this verification for check valve operability. The inspector reviewed these revised STs and verified adequac The unresolved item is close .10 (0 pen) Unresnived Item (277/88-01-02; 278/88-01-02). Shroud Access Cover Cracking. See section 4. .0 Operations Review 4.1 Station Tours (71707)
The inspector observed plant operations during daily facility tours. Most accessible areas of the station were inspecte . Cuntrol Room and facility shift staffing was frequently checked for compliance with 10 CFR 50.54 and Technical Specification The presence of a senior licensed operator in the control room was verified frequen+.l Operator attentiveness to plant operations was determined to be adequat . The inspectcr frequently observed that selected control room instrumentation and recorder traces confirmed that ir,struments were operable and indicated values were within Technical Specification requirements and normal operating limit Engineered safety features system switch positioning and valve lineups were verified daily based on control room indicators and plant observation On May 20, 1988, during a routine morning contral room tour, the inspector noted that the Unit 2 reactor water cleanup system was being prepared for operation to support the reactor cavity floodup for steam separator removal. The operators were waiting for isolation valve final surveillance testing before performing system startu The inspector questioned whether or not the l primary containment isolation (FCIS) signals were tested l because these valves are PCIS group 2 The inspector reviewed Technical Specification (TS) 3.7.0 and 4. This TS only requires operability and testing during reactor power operating conditions. The inspector further questioned licensee personnel with regards to the operability of the shutdown cooling (SDC) isola +1on valves because they are PCIS group 2 The inspector brought up his concern at the 8:30 a.m.
l morning meeting with operations management personne The inspector asked whether the PCIS signals arm logic l
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for low reactor water level were operable and current for surveillance testing (ST). The licensee stated that TS do not require the instrumentation and logic to be operable or tested. However, Unit 2 PCIS instrumentation and logic was tested prior to the hydrostatic test of the reactor vessc-1 on March 1, 198 The inspector reviewed applicable TS operability testing for PCIS group 2A and 2B valves, and they are summarized below:
TS Section Test / Frequency 4.7.D. simulated actuation /once cycle 4.7.D.1.b(1) valve cycling /3 months 4.2.A/4. logic system functional /6 months 4.2.A/4. instrument functional / monthly 4.2.A/4. instrument calibration /3 months The inspector reviewed special procedure SP-1046 for plant conditions in support of the Unit 2 hydrostatic tes This SP tested portions of the above TS surveillance requirement The inspector reviewed the BWR-4 standard TS and the BWR-5 standard TS (NUREG-0123). The BWR-4 TS do not address the SDC isolation instrumentation and logic other than for reactor operations (similar to Peach Bottom TS). However, the BWR-5 TS address this item and require operability and testing in cold shutdown and refueling modes of operation The inspector also reviewed NSAC-88, Residual Heat Removal Experience Review and Safety Analysis for Boiling Water Reactors (BV!DT, March 1986. The NSAC-88 report reviewed loss of coolant intentory events in BWRs while in cold shutdown conditions. This document recommends that BWR procedures require that automatic isolation of shutdown cooling be maintained fully operational during shutdown periods. The automatic isolation feature includes these valves, instrumentation and logic system The issue of SDC TS operability and testing in other
"reactor operating modes" (e.g. , cold conditions) is unresolved (277/88-13-01; 278/88-13-01).
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4. Selected control room off normal alarms (annunciators)
were discussed with control room operators and shif supervision to assure they were knowledgeable of alarm status, plant ~ conditions, and that corrective action, if required, was being taken. In addition, the applicable alarm cards were checked for accuracy. The operators
.were knowledgeable of alarm status and plant condition . The inspector checked for fluid leaks by observing sump status, alarms, and pump-out rates; and discussed reactor coolant system leakage.with licensee personne . Shift relief and turnover activities were monitored daily, including periodic backshift observations, to ensure compliance with administrative procedures and regulatory guidance. Shift Manager conduct of shift turnovar meetings was determined to be good. In specto r ..
attendance at periodic meetings noted that the plant status, problem areas, and interface difficulties were
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covered in adequate detail. The meeting atmosphere in the control room was noted as being professiona . The inspector observed the main stack and both reactor building ventilation stack radiation monitors and recorders, and periodically reviewed traces from backshif t periods to verify that radioactive gas release-rates were within limits and that unplanned releases had not occurred. No inadequacies were identifie . The inspector observed control room indications of fire detection instrumentation and fire suppression systems, monitored use of fire watches and ignition source controls, checked a sampling of fire barriers for integrity, and observed fire-fighting equipment stations. With the exception of items discussed in sections 6.2.5, 6.2.7, and 10.2 no inadequacies were identified.
4. The inspector observed overall facility housekeeping i
cos.Jitions, including control of combustibles, loose
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trash and debris. Cleanup was checked during and after maintenanc Plant housekeeping was generally acceptabl . The inspector observed the nuclear instremen.' tion subsystems (source range, intermediate rarge and gewer range monitors) and the reactor protection system to verify that the required channels were operable, t
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4.1.10 The inspector frequently verified that the required off site electrical power startup sources and emergency on site diesel generators were operabl .11 The inspector monitored the frequency of in plant cnd control room tours by plant and corporate managemen Management was noted to be in the control room and in the plant periodically. The inspector met the Nuclear Committee of the Board (NCB) on May 20, 1988. The NCB was on site to meet with plant and corporate managemen .1.12 The inspector verified on a weekly basis, the operability of selected safety related equipment and systems by in plant checks of valve positioning, control of locked valves, power supply availability, operating procedures, plant drawings, instrumentation and breaker positionin Selected major components were visually inspected for leakage, proper lubrication, cooling water supply, operating air supply, and general condition No significant piping vibration was detected. The inspector reviewed selected blocking permits (tagouts)
for conformance with licensee procedures. No inadequacies were identifie .1.13 The inspectors performed backshift and weekend tours of the facility on the following days-
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May 12, 1988; 5:00 - 6:00 May 24, 1988; 4:00 - 6:00 May 28, 1988; 4:00 - 7:00 May 29, 1988; 6:55 - 11:25 June 2, 1988; 4:30 - 6:00 June 3, 1988; 5:30 - 6:00 .1.14 The inspector verified that the QC operations monitors were performing periodic control room tour .2 Followup On Even'.s Occurring During the Inspection (93702)
4. B RHR pump Motor Problem on April 21, 1988 The 28 RHR pump was ceing used for shutdown cooling (SOC) when a high motor winding temperature clarm occurred at 1:42 p.m., on April 21, 1988. The Unit 2 reactor operator verified that the computer alarm point was in an alarmed condition (85 degrees C); he then checked control room pump / motor indications. Motor amperage was noted to be 250 amps, which was higher than the normal of 235 amps. The 2B RHR motor bearing temperatures were normal. Under the direction of the
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Shift Supervisor, the 2B RHR pump was secured. The 20 RHR. pump was placed in the SDC mode for Unit The licensee decided to inspect the 2B RHR pump and'
motor.' Motor bearing inspections, motor stator winding resistance checks and pump inspections were normal. A sample of upper and lower motor bearing oil revealed that the upper bearing (combined thrust and guide)
reservoir contained the wrong ~ oil Viscosity measurements were determined to be 300 saybolt seconds universal (SSU) which was higher than the specification of 140-160 SSU. The licensee drained the upper reservoir and replaced the oil with the correct oil (Gulf Harmony 32).
The inspector confirmed the 2B RHR pump motor abnormal condition by reviewing control room logs; discussing the event with operators, engineers, and chemistry and maintenance personnel; and, by reviewing results of the chemical analysis and examining the oil. In addition, the inspector reviewed maintenance, lubrication and chemistry procedures, and technical manuals associated with the 2B RHR pump moto Based on discussions with the motor vendor (GE), the licensee does not believe that the higher than normal motor amps and the high motor winding temperature resulted from the high viscosity oil in the motor upper bearing reservoir, The pump had bee running continuously in the SDC mode for over one month. After the motor inspections were complete, the licensee restarted the 28 RHR pump on April 27, 1988. The inspector observed the pump start from the control roo Indications on the pump and motor were normal (pump flow and pressure, motor winding and bearing temperatures, motor amps and vibration). The licensee concluded that
, the pump / motor was operating consistent with design parameters. The licensee implemented expanded monitoring of the 2B RHR pump in accordance with RT
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8.11, "Routine Monitoring of Pump Motor Temperatures,"
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Rev. 2. Parameters monitored every four hours included:
motor amps; pump flow; motor upper and lower bearing temperatures; and motor winding temperatur The inspector met with the RHR system engineer on April 29, 1988, to discuss this even The licensee has not determined how the wrong oil was put into the 28 RHR
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motor upper bearing reservoir. Recently completed maintenance and preventive maintenance procedures on the I
28 RHR pump motor documented that the correct oil was i
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use Other RHR motors were checked and the correct chemical results were noted. The inspector reviewed procedure M-10.24, "RHR Pump Motor Maintenance." This procedure states that the oli to be used is "PEco Code No. 119-49271". 'The inspector confirmed that. code number to be Gulf Harmony 32 by reviewing an uncontrolled cross reference list used by machinists in maintenance. In addition, lubrication cards useo by operations personnel were reviewed. These cards are also uncontrolled; however, the correct oil was listed for the RHR motors. The licensee is currently reviewing their entire lubrication progra These maintenance and operations oil sheets are scheduled for review and revision (if appropriate). The rubrication program will be reviewed in a future inspectio The inspector continued to monitor the 2B RHR pump and motor during the inspection period. No further abnormalities were noted. On May 21, 1988, the 2B RHR pump was shut down in order to run the 2D RHR pump-in the SDC mod The 24 day RHR pump run was norma No violations were note .2.2 Unit 3 Engineered Safeguard Features (ESF) Actuation on May 6, 1988
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An unexpected automatic actuation of an ESF system occurred g at 4:27 p.m., on May 6, 1988 on Unit 2. The ESF actuation i
was a group II reactor water cleanup (RWCU) containment isolation. The RWCU isolation occurred during application of a system blocking permit. A fuse was pulled and this caused de-energization of the RWCU high temperature isolation logi RWCU was out of service at the time and no valve movement occurred. The licensee replaced the fuse, reset the isolation logic and made an ENS call. In addition, the blocking permit was revise The licensee determined that blocking permit number
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2-12-M88-1156 was being applied for maintenance work on a RWCU temperature indicating switch (TIS-2-12-89A).
The permit called for pulling fuse F-3 (12A-F1) in panel 20C06 This also de-energized the RWCU non-regenerative
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heat exchanger outlet temperature indicating switch (TIS-2-12-99). TIS-2-12-99 de-energization results i7 a RWCU group II containment isolation signal. The license?
is currently implementing changes to the permit process and A-41, "procedure for Control of Safety Related Equipment."
, This was in response to a licensee and NRC identified concern (NRC open item UNR 277/87-22-01).
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The inspector reviewed the following items related to this ESF actuation:
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blocking permit 2-12-M88-1156
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maintenance request form 2-12-M88-1156
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electrical schematic drawings MI-S-21 and E-368
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suspected LER
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preliminary upset report P-2-88-11
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control room logs In addition, the inspector interviewed operations and engineering personnel. The licensee intends to submit an LER for this event. The LER will be reviewed in a future inspection. Licensee corrective actions included discussions with the personnel involved in writing and approving the permit, and implementation of revised procedure A-4 No violations were note .2.3 Unit 3 Engineered Safeguard Features (ESF) Actuation on May 7, 1983 An unexpected actuation of an ESF system occurred at 9:04 a.m., on May 7, 1988, on Unit 3. The ESF actuation was a group II reactor water cleanup (RWCU) containment isolation. The RWCU isolation occurred during non-vital 13KV bus (3R4 and 4R4) switching. The RWCU system was out of service and no valve movement occurred. An apparent breaker malfunction of 3-4R4 resulted in a loss of power to the 4R4-R-B non-vital 480 volt motor control center (MCC). This MCC was supplying temporary power to the 30Y035 safety related 120 VAC panel due to a maintenance outage on the E-33 4KV bus. The licensee re-energized the affected buses, reset the logic and made an ENS cal The inspector reviewed the liceru e's preliminary upset report number 3-88-03, the SLER, i control room log In addition, the inspector discussed the event with operations personnel and engineers. The LER will be reviewed in a future inspectio No violations were noted.
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4.2.4 Unit 2 Reactor Protection System (RPS) Actuation on May 12, 1988 An unexpected actuation of the Unit 2 RPS occurred at 9:28 a.m., on May 12, 1988. The RPS actuation was caused during system surveillance testing (ST). An apparent test engineer (TE) error while installing a jumper caused fuse SA-F23A to blow and relays 5A-K19A and C to de-energize. This action subsequently caused the scram discharge volume instrument volume high level trip to become unbypassed in both RPS channels. A full reactor scram occurred with the unit in a cold shutdown condition. No rod motion occurred as all rods were fully inserte The licensee replaced the fuse, reset the scram signal and made an ENS call. Surveillance testing was suspended pending licensee investigatio Licensee investigation determined that the root cause was a personnel error due to inattention to detai The TE, when placing the jumper, failed to exercise caution and the jumper became shorted when it touched the cabine The licens2e also noted that the TE failed to follow procedure ST 1.18A, in that the steps were not follosed in the correct order. This failure to follow the procedure led directly to the electrical shorting with the jumper. Failure to follow ST 1.18A is a licensee identified violation (277/88-13-02).
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The inspector reviewed the following documents:
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suspected LER
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preliminary upset report 2-88-12
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ST-1.18A, "RPS 'A' Logic ceram Reset Timers Functional," Rev. 0
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electrical schematic drawing MI-S-54
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control rcom logs The inspector also interviewed selected control room operators and engineers. The LER will be reviewed in a future inspectio .2.5 ESF Actuations on May 20 and 22, 1988 Unit 3 ESF actuations (PCIS group III half inboard isolations) occurred as a result of the tripping of the RPS alternate power supply feed to the A RPS bus. In each case, reactor building ventilation isolate The alternate RPS feed tripped on overvoltage due to voltage rises on the #3 startup source. The May 20, 1988,
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the May 22, 1988, overvoltage trip occurred due to a malfunctioning transformer load tap changer, The licensee o reset the isolations and restored building ventilation.
L .The reason for the rise in the load tap changer voltage is under investigation. Two four hour ENS reports were made and the senior. resident inspector was notified at hom The inspector reviewed both events including control room logs, the licensee's SLER, and held discussions with operators and engineers. The LER will be reviewed in a future inspectio No violations were note .3 Logs and Records (71707)
The inspector reviewed logs and records for accuracy, completeness, abnormal conditions, significant operating changes and trends, required entries, correct equipment and lock-out status, jumper log validity, conformance with Limiting Conditions for Operations, and proper reporting. The following logs and records were reviewed:
Control Room Shift Supervisor Log, Reactor Engineering Logs, Unit 2 Reactor Operator Log, Unit 3 Reactor Operator Log, Control Operator Log, STA Log, QC Shift Monitor Log, Radiation Work Permits, Locked Valve Log, Maintenance Request Forms, Temporary Plant Alteration Log, and Ignition Source Control Checklists. Control Room logs were
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compared with Administrative Procedure A-7, Shift Operation Frequent initialing of entries by licensed operators, shift supervi-
-sion, and licensee site management constituted evidence of licensee review. No unacceptable conditions were-identifie .4 Refueling Outage Activities (60710)
4. Unit 2 System Outage Work The licensee is conducting system outages on Unit 2 in order to complete open maintenance work items (MRFs).
These open MRFs include corrective, preventive and modification work related items. At the close of this inspection period, 24 system windows were open and seven were closed. The first group of systems to be opened include the division 1 (A and C) safety related systems including: A loop (A and C) core spray, A loop (A and C) RHR, A recirculation loop, E-1 and E-3 diesel generators, A loop (A and C) high pressure service water, A fuel pool cooling, and A service wate ... .
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The A loop of core spray (A and C) was being prepared for surveillance testing (ST) the week of May 9, 198 The inspector reviewed the system status including emergency service water (ESW) piping replacement (modification 2371) work and the related modification acceptance testing (MAT). The inspector performed a walkdown of the system before and after ST performance (see section 4.5 of this report). The inspector reviewed core spray and ESW system check off lists (COL), P&I0s, and plar.t labeling. The inspector noted the following items:
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The ESW COL S.9.4.2.A was updated by temporary procedure chanoa (TPC) to reflect the new ESW valve P&ID M-315 did not reflect these new ESW valve The condition of the A and C core spray rooms was such that the ST could not have been safely performed (e.g., scaffold interferences, lagging work in progress, etc).
These items were also noted by various Shift Managers and discussed at shift turnover meetings during the perio The inspector discussed these items with licensee management on May 13, 15 and 17, 1988. The licensee agreed that -
weaknesses existed in the turnover process for the A loop of core spray. The inspector reviewed turnover activities associated with procedures A-14, Plant Modification; A-26, Procedure for Corrective Maintenance; A-89, Modification Acceptance Tests; and, A-41, Procedure for Control of Safety Related Equipment. No violations were note To correct these deficiencies associated with the Unit 2 A loop of core spray, the licensee proposed the following actions prior to MAT performance:
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System Engineer to review the MAT to determine if procedures need to be revised, revise procedures in their area of responsibility, and make revision recommendations to Operations and the Support Group,
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Operations update procedures as necessar System Engineer update COLs as require Modifications update Control Room P& id Technical (Plant Labeling Group) to label new component g L
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In addition, the licensee is in the process of reviewing procedure A-14 to incorporate the principles abov The licensee is performing modification (MOD) 2371 on the ESW system. The purpose of this MOD is to improve Emergency Service Water flow to the Unit 2 ECCS room coolers and equipment cooler All the ESW pipe and hand valves have been replaced in all the core spray rooms, the A and C RHR rooms, and the HPCI room. The remaining ESW pipe in the B RHR, D RHR and RCIC rooms has been cleaned using a high pressure water spray metho Additional pipe supports were installed to remove pipe loading from the ESW pipe to the room coolers and equipment cooler pipe nozzles. The water side of the room cooler tubes to being cleaned if necessary following inspection of several tubes in each cooler using a boroscop The inspector reviewed MOD packrge 2371 including: the safety evaluation and PORC approval, the engineering work letter, the construction job memorandum, associated drawings, and MAT 237 In addition, the inspector discussed this MOD with licensee engineers and examined in field installations. No unacceptable conditions were identifie During the review of the Unit 2 system outage work and recovery activities, no violations were note However, noted weaknesses associated with turnover activities will be reviewed in a future inspectio .4.2 Unit 2 Reactor Vessel Disassembly and Shroud Access Cover Inspection On May 18, 1988, Unit 2 reactor vessel disassembly began. The licensee implemented special procedure (SP)
SP-5000, "Coordination Procedure to Disassemble Unit 2 for Inspection of the Annulus Manways". SP-1129,
"Temporary Defeat of Core Spray and RHR Pumps, and Diesel Generator Auto Starts Prior to RPV Head Piping Removal" was also implemente The inspector reviewed these SPs and PORC position number 9. The inspector observed implementation of these SPs, and held discussions with licensee operators and engineers. The inspector determined that personnel were knowledgecble of the requirements and contents of the SP The inspector observed portiens of reactor vessel disassembly (see section 8.1). Based on these
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I observations, maintenance personnel knowledge and l conduct of these activities was determined to be good, f
f General Electric (GE) and the licensee performed ultrasonic test (UT) examinations on the Unit 2 180 degree and 0 degree shroud access covers on May 28 and 29, 1988. The inspector observed a UT demonstration on a test cover on May 27, 1988, and portions of these inspections on the 180 degree cover. Items checked included procedural adequacy, personnel manning and qualification, equipment installation and setup, MRF 2-4-M-88-5636, health physics controls, and licensee oversight of activitie The licensee's inservice inspection (ISI) group (level II/III personnel) and an EPRI ISI specialist were noted to be present during all observation The results of the UT examination will be reviewed in a future inspectio No unacceptable conditions were note . Unit 3 Pipe Replacement Outage The inspector continued to follow the Unit 3 pipe replacement outage and related activities. Periodic meetings were attended and implementation of procedure SP-1060C, "Overall Coordination Procedure for the Recirculation Pipe Replacement Project" was monitore Inspections of the Unit 3 drywell were performed as follows:
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On April 26, 1988, the inspectors entered the Unit 3 drywell to perform an inspection of pipe replacement activities, incl. ding health physics controls, housekeeping and cleanliness, and ALARA practices. The inspectors examined welding in progress on the N-1 (recirculation suction) and N-2 (jet pump) nozzles, and on valve HV-3-10-81A. The inspectors also observed grinding on valve HV-3-10-818. Overall house-keeping and cleanliness were good. The presence of health physics personnel in the drywell was goo First line supervision in the drywell was noted and is a good indication of management ;
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On May 17, 1988, the inspectors again toured the Unit 3 drywel Items inspected included work in progress, health physics controls, and l l
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ALARA practices. The' tour was made during a period of high work activity in the drywel The ,
radiation' postings were adequat The inspector noted that there was extensive mirror insulation damag The licensee indicated.that the affected insulation will be replaced. 0verall housekeeping and cleanliness was satisfactor The inspectors will continue to periodically inspect the drywell during the outage. No violations were observe .5 Engineered Safeguards Features (ESF) System Walkdown The inspector performed a detailed walkdown of portions of the core spray system in order to independently verify the operability of the Unit 2 syste The core spray system walkdown included verification of the following items:
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Inspection of system equipment condition Confirmation that the system check-off-list (COL) and operating procedures are consistent with plant drawing Verification that ' system valves, breakers, and switches are
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Verification that instrumentation is properly valved in and operabl Verification that valves required to be locked have appropriate ,
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Verification that control room switches, indications and controls are satisfactor Verification that surveillance test procedures properly implement the Technical Specifications surveillance requirement No violations were noted.
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4.6 Plant Operations Review Committee (PORC) Positions The' inspector reviewed Peach Bottom Technical Specifications (TS)
PORC positions. These positions interpret and give additional guidance on a specific TS. The inspector reviewed administrative procedure A-4.1, "Administrative Procedure for the Generation of
> Technical Specification PORC Positions". The purpose of this procedure is to generate a document that will assist the appropriate plant personnel in the consistent interpretation of the plant
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Technical Specifications that are found to be subject to interpreta-tion. The inspector reviewed the following approved PORC positions:
PORC Position Subject
- 2 Diesel Generator _ Operability
- 3 Fire Detection
- 4 Operability Testing of Low Pressure ECCS
- 9 Inspection of Vessel Internal Components No unacceptable conditions were note .7 . Peach Bottom Simulator Evaluation On May 4 and 5, 1988, the resident inspectors and members from ORS in Region 1 evaluated the Peach Bottom simulator. The simulator is located in Columbia, Maryland, at the Singer-Link facilit Unit 2, common, and remote shut down panels are simulated. The inspectors walked down the panels and observed plant evolution These evolutions included system startup and-shutdown, plant transients and accident scenarios. Specific deficiencies were discussed with licensee personnel. The majority of these had been previously documented, and corrective actions were underway or planned. The simulator will continue to be evaluated before final NRC acceptanc .0 Emergency Preparedness The licensee conducted an emergency plan drill on May 24, 1988. The drill was unannounced and occurred on the backshift. The purpose of the drill was to test the Peach Bottom backshif t call out procedures (EP-207) for additional personnel during the quarterly emergency dril In addition, the resident inspectors participated in the drill as NRC player The drill scenario began at 2:45 a.m., on May 24, 1988. The NRC inspector was notified at home at 3:00 a.m., and responded to the site at 3:45 a.m. The drill proceeded through the approved scenario and included all of the emergency classifications. The NRC inspectors participated in control room and technical support center (TSC)
activitie The drill was critiqued the following morning. Attendance at the critique included the inspectors, the drill controllers / evaluators, and the licensee player The licensee concluded that overall drill conduct was adequate. Shift Manager use of emergency procedures and event classification was goo _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ -_. _ . _ _ _ _ _ _ _ _____ ___-___ ____ _ __ __ __ _ _ --_ _
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Specific deficiencies and corrective actions were discussed. Although i the call out procedure was followed, it appears to be inefficient. As l a result, the TSC full activation was slow. Tne licensee intends to ,
review this call out procedure and initiate improvement This will be l reviewed in a future inspection. No violations were note .0 Review of Licensee Event Reports (LERs) (92703)
6.1 LER Review (90712)
The inspector reviewed LERs submitted to the NRC to verify that the details were clearly reported, including the accurary of the description and corrective action adequacy. The inspector determined whether further information was required, whether generic implications were indicated, and whether the event warranted on site follow-up. The following LERs were reviewed: -
LER N LER Date Event Date Subject 2-87-02, Rev. 1 Local leak rate test limit exceeded April 21, 1988 March 13, 1987
- 2-87-28, Rev. 1 Design deficiency that could permit DG trips April 22, 1988 during a seismic event December 17, 1987
- 2-87-30, Rev. 1 Primary containment isolation caused by off April 29, 1988 site power loss December 30, 1987
- 2-88-02 Shutdown scram caused by operator error March 25, 1988 March 1, 1988
, *2-88-05, Rev. 1 Control room and cable spreading room panels May 10, 1988 seismic design March 3, 1988
- 2-88-07 Fire barrier deficiencies and failure to May 16, 1988 report October 15, 1987
- 2-88-08 Failure to submit special report regarding April 26, 1988 Cardox out of service in the control room March 28, 1988 '
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-25-2-88-09 Release of treated liquid radwaste without May 2, 1988 sampling April 4, 1988
- 3-88-01 Primary containment isolation during DG and May 6, 1988 bus switching April 8, 1988 6.2 LER Followup (92700)
For LERs selected for follow-up and review (denoted by asterisks above), the inspector verified that appropriate corrective action was taken or responsibility was 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 10 CFR 5J.59. Report accuracy, compliance with current reporting requirements and applicability to other site systems and comoonents were also reviewe . LER 2-87-28, Rev. I revises corrective actions for a previously submitted LER regarding diesel generator (DG)
trips during a seismic event and loss of off site powe This was reviewed in NRC Inspection 277/88-10, 278/88-1 The licensee is pursuing two options as follows: (1)
upgrade the affected components; or (2) relocate DG air intake to outside the room. The licensee will update this LER when the option is selected. The inspector will review the revised LER in a future inspectio . LER 2-87-30, Rev. I revises root cause analysis 'nd corrective actions for a previously submitted LER regarding a loss of off site powe The event and initial LER were reviewed in previous NRC Inspection 277/87-29 and 277/88-02, respectively. The licensee concluded that the root cause was the failure of a time delay relay associated with the RPS motor generato The relay was replaced and it was added to the preventive maintenance program. No inadequacies were notel relative to this revised LE . LER 2-88-02 concerns a shutdown scram on Unit 2 on March 1, 1988. The root cause was a personnel error made by the licensed reactor operator. This event was reviewed in NRC Inspection 277/88-02, 278/88-02. No inadequacies were noted relativt to this LE . LER 2-88-05, Rev. 1 updates an LER that was the subject of an NRC identified violation of the seismic mounting of control room and cable spreading room panels. NRC Inspection 277/88-10, 278/88-10 reviewed the original
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-26-LE The welding repairs for this deficiency were reviewed in section 8.1 of this report. No inadequacies were noted relative to this LE . LER 2-88-08 concerns a failure to submit a special report regarding the inoperabiliy of the control room carbon dioxide (Cardox) fire protection system. The Cardox system was taken out of service on October 1, 1987, due to a blistered hose. An entry into the limiting condition for operation (LCO) log was made; however, the time limit was not tracked. On March 28, 1988, the station regulatory group discovered that a 31 day report (due November 15, 1987) had not been submitted due to the Cardox system being out of service for 14 days. This is a licensee identified violation of TS 3.14.8.4.b (277/88-13-03). Licensee corrective actions included: submittal of the information required by the special report in this LER; re-evaluation of the Cardox system for the control room; instructions to operations to ensure an SLER is initiated to track special report requirements; and, changes to the LC0 log. The long term actions will be reviewed in a future inspectio The licensee states in the LER that there were alternate means for control room fire suppression and detection as follows:
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portable extinguishers in the control roo fire hoses outside tFe control room
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smoke and heat detectors in the control room, and
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control room continually manne The inspector concluded that there was minimal effect on the plant fire protection program with the control room Cardox out of service with both units in a cold conditio .2.6 LER 3-88-01 concerns a Unit 3 containment isolation during diesel generator (DG) operation and bus switching on April 8, 1988. The event was reviewed in NRC Inspection 277/88-10. The licensee identified root causes as lack of procedural guidance and training for operators in the area of DG paralleling operations. The licensee revised the affected procedures and initiated a shift training bulletin to operator Long term corrective actions includes adding DG operations and paralleling to requalification trainin The inspector l
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-27-verified these action No inadequacies were noted relative to this LE .2.7- LER 2-88-07 concerns fire barrier-problems discovered during plant walkdowns. An LER was not submitted within 30 days as required by 10 CFR 50.73. This is a licensee identified violation (277/88-13-04) and is similar to a e recent NRC violation (277/88-10-02). Licensee corrective !
actions will be reviewed in a future inspectio .0 Surveillance Testing (61726)
The inspector observed surveillance tests to verify that testing had been properly scheduled, approved by shif t 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 me Parts of the following tests were observed:
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RT 8.11, Routine Monitoring of Pump Motor Temperatures, conducted on the 28 RHR pum ST 9.32-2, Unit 2 Reactor Cold Shutdown Log, Rev. 5
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ST 9.32-3, Unit 3 Reactor Cold Shutdown Log, Rev. 5 In addition, a review of the following completed surveillance test was performed:
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ST 6.6.F, Core Spray A Pump, Valve, Flow, Cooler - Flow Test, conducted on Unit 2 on May 18, 198 No inadequacies were identifie .0 Maintenance Activities (62703)
8.1 Routire Observations The inspectors reviewed administrative controls and associated documentation, and observed portions of work on the following maintenance activities:
Occument Equipment Date Observed MOD 2376 Control room panel welding May 24 and June 2, 1988 M5 CP104 480 volt breaker May 12, 1988 (MRF 88-0700) maintenance MRF 87-10741 Unit 2 motor operated valve May 18, 1908 (M00 2355) operator MO-2200A MOVATs
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-28-M-4.208 Detensioning the reactor head May 18, 1988 M-4.209 Removal of the reactor head May 18, 1988 Administrative controls checked, if appropriate, included blocking permits, fire watches and ignition source controls, QA/QC involvement, radiological controls, plant conditions, Technical Specification LCOs, equipment alignment and turnover information, post maintenance testing and reportability. Documents reviewed, if appropriate, included maintenance procedures (M), maintenance request forms (MRF), item handling reports, radiation work permits (RWP), material certifications, and receipt inspection No inadequacies were identifie .2 Electrical Safety On May 11,1988, at the 7:30 a.m. shif t turnover meeting, the inspector 13arned of an event that occurred on May 9, 1988. During this event an operator was shocked during removal of an electrical breaker from the 4PS4-W-B motor control center (MCC). The breaker (B centrifuge) was being removed for preventive maintenance per procedure 5.8.3.0, "Removing and Returning to Service of 480 Volt AC and 250 Volt DC Motor Control Center Buckets".
At 7:10 p.m. , on May 9,1988, an auxiliary operator ( AO) removed this non-safety related breaker (08S29) from MCC 4PS4-W- Apparently, the breaker was too heavy for the A0, and when removed the breaker fell back into the MCC energized bus bars. A shock was received until the breaker frame welded itself to the MCC frame. The A0 felt numbness in his right arm for 15 seconds; however, no other health effects were note The operations shift reviewed the event and initiated an injury repor Based on this review, the Shift Manager drafted a memo to operations management delineating deficiencies in electrical safety training and equipmen The inspector reviewed this memo and injury report, reviewed procedure S.8.3.0, and interviewed the A0 who was shocked. The inspector also examined the breaker and MCC area. The inspector noted the damage to the MCC bus bars and frame are The inspector expressed concern for the lack of electrical safety training for operators and inadequate safety equipment. In addition, the inspector expressed concern that the A0 had attempted to lift a relatively large and heavy breaker (36" and over 100 lbs) by himself. Licensee management concurred with these concerns and initiated the following corrective actions:
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to review and revise A0 training to include electrical safety, and
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to label large breakers (over 36") to ensure two operators are available for removal / replacement, and
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to inform operators of this even Although no violatio..s were identified, electrical safety appears to be a weakness. This will be reviewed in a future inspectio .3 Maintenance Request Form (MRF) Backlog The licensee continues to work to clear the MRF backlog for Unit 2 and common, and Unit 3 open work items. This MRF backlog includes outage and non-outage MRFs, which are sub classified as either Q (safety related) or non-Q (non safety related), and as either corrective (CM) or preventive (PM). The licensee issues a weekly MRF summary (maintenance department) report that itemizes the open MRFs by section (i.e., status of completion), responsible work group, and trend information. The May 26, 1983 report shows the following status:
Category MRFs Open Unit 2 and Common Unit 3
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Preventive - Q 244 1363 Preventive - Non Q 844 1970 Corrective - Q 366 875 Corrective - Non Q 1290 1457 Total 2744 5665 In addition, a total of 2253 Unit 2 and 676 Unit 3 MRFs have been classified as work complete; however, the "Operations Verification Form (OVF)" has not been done. That is, section 7 (OVF) of the MRF remains upen. Additional licensee action in this area includes a program to reduce the MRF backlo The inspector reviewed: selected MRF summary reports; a partial listing of the open MRFs; selected safety related itRFs; the MRF backlog reduction program; and, the INPO maintenance performance indicators. The inspectnr also discussed the MRF backlog with licensee engineers and plant management. The inspector stated that reducing the backlog was important prior to restart of each unit. The licensee agreed and further stated that this item is being constantly monitored and reviewed periodically by managemen The licensee's unit goals for MRF backlog reduction are as follows:
(1) reduce non-outage backlog to less than 550; (2) complete all safety related overdue PMs; (3) have no overdue priority cms; and, (4) reduce the average age of backlog non outage MRFs consistent with INPO guidanc The inspector will conti,ue to monitor the licensee's progress in reJucing this MRF backlo .
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9.1 Routine Observations During the report period, the it.spector examined work in progress in both units, including health physics procedures and controls, ALARA implementation, dosimetry and badging, protective clothing use, adherence to radiation work permit (RWP) requirements, radiation surveys, radiation protection instrument use, and handling of potentially contaminated equipment and raaterial The inspector observed individuals frisking in accordance with HP procedures. A sampling of high radiation area doors was verified to be locked as required. Compliance with RWP requirements was verified during each tou RWP line entries were reviewed to verify that personnel had provided the required information and people working in RWP areas were observed to be meeting the applicable requirements. No unacceptable conditions were identifie .2 Contamination Event on April 29, 1988 On April 29, 1988, the night shift nealth physics (HP) technicians found shoe and clothing contamination on individuals exiting the power block radiologically controlled area The Applied Health Physics Group initiated a plant survey to determine the extent and source of the contamination, to isolate the contaminated areas, and to initiate decontamination activities to recover the area The contamination was determined to be limited to Unit 2 areas of the turbine building, reactor building, and passages between these area The areas were isolated and adequately poste Decontamination efforts recovered the areas by the following da The source of the contamination was the continuous pH praae located on an instrument rack adjacent to the cleanup sample sink outside the regenerative heat exchanger room (RHR) on the 165 foot elevation of the reactor building. The pH probe and its housing was either bumped by workers removing scaffolding and other equipment from the room late in the day, or by a worker during the night shif This caused the pH instrument to dump highly contaminated water (mrad smearable)
on the floor below the instrument rack. The contamination was then spread by personnel who passed by the area. It was determined that the plant operators (P0) office located on the 135 foot elevation of the turbine building was cc aminated by improper frisk of individuals, P0s, or others, going into the offic The P0 office is an eating, drinking and smoking area within the power block radiologically controlled area. Individuals that accessed this office during the period it was contaminated were whole body counted and none received any intake.
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-31-The prompt response and immediate corrective actions were reviewed by the inspector. This included interviews of HP technicians and supervisory personnel. The inspector also reviewed the logs and inspected the affected areas. The new administrative procedure A-110, revision 1, "Radiological Occurrence Review", indicated its effectiveness with prompt immediate corrective actions and timely follow-up investigation and corrective actions. Follow-up revealed some contamination of the carpet in the control room which was removed. Posting was enhanced in the P0 office and the use of this area is limited to P0s. A containment device is being considered for the pH probe to prevent inadvertent bumping of this instrumen The inspector had no further questions regarding this event and no violations were note .3 Radiography Incident on May 10, 1988 On May 10, 1988, contract radiographers for the pipe replacement project on Unit 3 were involved in two events which led to the temporary suspension of radiography activities. Procedure HP-108, revision 1, requires that the radiographer establish boundaries for radiation areas then verify the boundaries during the exposure in cooperation with a health physics technicia In addition, the radiographer and a health physics technician are to verify that the established boundaries are clear of personnel prior to the '
exposur At 5:40 a.m. on May 10, 1988, a radiography group in the Unit 3 drywell was preparing to obtain a weld exposure of the "A" recirculation pump. The group failed to notify and verify with a health physics technician the established boundary of the posted radiation area was less than 2.5 mR/hr as specified by the procedure. The health physics technician determined that during the exposure the radiation levels at the boundary of the posted radiation area were as high as 25 mR/hr. Another radiography group preparing weld exposures of the reactor water cleanup system ct 6:00 a.m., failed to notify and verify boundaries with the health physics technician and to clear the araa of personnel during 1he exposure. As a result of these licensee identified procedural violations (278/88-13-05) the radiography group activities were stopped on May 10, 198 A stop work order was initiated by the project manager on May 11, 1988. The contract radiography group's radiation safety office was called in during the investigations of the group's activitie Immediate corrective actions were; to retrain the radiography group in the classroom on procedures, verbatim compliance with procedures, Information Notice 85-43, and the communication
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coordination required between radiography and the health physics groups; and, reorganization of the radiography group to include an on site radiation safety office and a coordinator for each shift to provide adequate oversight and coordination. When the training and reorganization were completed the radiography group was allowed to resume their activities on May 13, 1988. The licensee's immediate response, corrective actions and training records were reviewed by the _ inspecto The inspector discussed the event with licensee personnel. The inspector hr.d no further questions at this time. Other than the licensee identified procedure violations, no _ additional problem areas were noted (278/88-13-05).
10.0 Physical Security (71707, 71881)
10.1 Routine Observations The inspector monitored security activities for compliance with the accepted Security Plan and associated implementing procedures, including: security staffing, operations of the CAS and SAS, checks of vehicles to verify proper control, observation of protected area access control and badge issuance procedures on each shift, inspection of protected and vital area barriers, checks on control of vital area access, escort procedures, checks of detection and assessment aids, and compensatory measures. No inadequacies were identifie .2 Missed Firewatch At 6:33 a.m., on April 30, 1988, an Appendix R committed firewatch reported to the egress window to leave the site. At that time, the firewatch reported that she had lost her badge. The shift security assistant (SSA) was informed and a zone trace was performed on her badge number. After the SSA had reviewed the zone trace, it was determined that the firewatch had not used her badge since 11:06 p.m., on April 29, 1988. At that time the SSA was notified that the firewatch had located her badge in her pants pocket. The badge was then tested to determine if it would register on the computer af ter being carded into a badge reader. The card registered correctl The firewatch was detained for questioning by the SSA and a pECo security manager. She admitted to not performing her firewatch duties as required by her post orders and that she had falsified her firewatch log indicating that she had made her rounds. She stated that she did not perform three of her four rounds, thereby not passing through over 162 security doors. The firewatch's employment was subsequently terminate . _ _ _ _ _ _ , .
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Licensee management reviewed the incidents' reportability in accordance with 10 CFR 50.72, 50.73 and 10 CFR 73.7 It was determined to be not reportabl The inspector reviewed this event by speaking to licensee individuals and by reviewing recoros and reporting requirement The inspector determined the event to'be not reportable because the firewatch was not required by Technical Specifications. The inspactor had no further questions and no violations were note .3 Inattentive Guards At approximately 3:10 a.m., on May 2, 1988, a shift security assistant (SSA) and a watchperson found a watchperson and a traffic guard inattentive to their duties at the Unit 1 administration building and traffic pos These areas are located outside the protected area. The watchperson was sitting in a chair with her arms crossed, head tilted down and eyes close The traffic guard was sitting in a chair with his back towards the window, arms crossed, legs stretched out and his head tilted dow After a minute or two, the inattentive guards were startled when the watchperson slammed the door shut on the security vehicl Both the SSA and watchperson entered the building ar.d questioned both guards. They both replied that they had their eyes closed for only a minut The SSA contacted the Sergeant of the Guards and both individuals were relieved of their duties. The Unit 1 administrative building was searched for any unauthorized persons or naterial; none were found. Both individuals' employment was terminated after completion of the investigatio The inspector followed up on this event by speakirg to security personnel, and by reviewing the incident repor The inspector determined the event to be not reportable Decause both posts are outside of the protected area and are not compensatory post The inspector had no further questions and no NRC identified viclations were observe .4 Di 4 Arrests (Allegation 8F-A0030)
On May 11, 1988, the Federal Bureau of Investigation (FB;) made additional arrests of licensee employees resulting from t,e FBI's ongoing investigation into illegal drug activities in the vicinity of Peach Bottom Atomic Power Station. The FBI arrested three currently employed Peach Bottom technical employees alleging that they were involved in illegal drug activities prior to 198 Also, the U. S. District Court indicted a fourth Peach Bottom employee who previously had been suspended by the licensee with
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intent to dismiss for drug related activities. One of the individuals involved was the subject of an NRC Allegation (88-A0030) received on March 18, 198 The individual had been removed from the site in November 1987, drug tested negative and returned to the site per the licensee's fitness for duty program. At that time, random periodic testing was also instituted. Once arrested by the FBI, the individual was denied access to the site. The allegation is considered close .5 Safeguards Ever,t Report (SER) on May 21, 1988 On May 21, 1988, the licensee reported that during a routine supervisory walkdown possible degradation in the protected area was discovered. It is believed this condition had existed since March 5, 1988. There were apparently no compensatory barriers to prevent entry. The opening was subsequently posted at 1:24 by a security person and was covered with a barrier. A one hour Safeguards report was made and the senior resident inspactor was notified at home. The SER will be reviewed in a future inspectio During the review of this event, the inspector noted that this barrier had been removed for over two months without security knowledg When questioned, licensee security personnel were not aware of this barrier nor could they provide drawings that depicted the barrier. A review of the Peach Bottom security plan revealed that the barrier is not discussed. There appears to be a weakness with the Security Plan and with available protected area barrier drawings (UNR 277/88-13-06).
10.6 Fitness for duty (Allegation 88-A0034)
The NRC received an allegation regarding the fitness for duty of a Peach Bottom Atomic Power Station contractor employee on March 29, 1988. The inspector discussed this allegation with licensee managemen The individual was observed by licensee personnel, and no abnormalities were noted. Further observation of this employee by the licensee determined that no abnormalities or l problems assoc'ated with fitness for d'ity existed. The allegation is considered close .0 Assurance of Quality 11.1 Shift Manager Oversight of Operations Activities The inspectors noted good command and control of operational activities exhibited by the Shif t Managers during the inspection period. Specific examples include: professional conduct of shift turnover meetings (section 4.1.5); assurance that systems are readied for testing after modification and maintenance work ,
(section 4.4.1); electrical safety follow-up after an operator was l shocked (section 8.2); and, emergency procedure implementation end I event classification during an emergency drill (section 5.0).
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The~ inspectors noted good follow-up by radiological controls and health physics personnel for two events (section 9.2 and 9.3).
The _ events were a radiography source problem and a spread of
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modification acceptance testing (MAT) was weak. The basis for this_ conclusion was that. operations was performing core spray COLs and testing engineers were performing a MAT prior to formal operating procedure (including COL) and P&ID revision In addition, the new components were not labeled nor was the room in a condition to permit testin The licensee initiated corrective actions to ensure systems are ready for posc-maint9 nance testin .0 In-Office Review of Specir' Reports The ' inspector reviewed the f(ilowing:
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Annual Radiation Dose Assessment Report ho. 3 Peach Bottom Atomic Power Station, dated April 28, 198 Reactor Vessel Specimen Surveillance Test Results for Peach Bottom Atomic Power Station Unit 2, dated May .13, 198 No unacceptable conditions were noted, i- 13.0 Unresolved Items Unresolved items are items about which more information is required to ascertain whether they are acceptable violations or deviation Unresolved items are discussed in section 4. .0 Management Meetings 14.1 Preliminary Inspection Findings (30703)
! A verbal summary of prel'minary findings was provided to the Ma.ager, Peach Bottom Station at the conclusion of the inspection.
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l( During the inspection, licensee management was periodically notified verbally of the preliminary findings by the resident
?_ inspector No written inspection material was provided to the ig S licensee duririg the inspection. No proprietary information is ff included in this repor .2 Attendance at Management Meeting Conducted by Region Based Inspector (30703)
Inspection Reporting Date Subject Report N Inspector 5/9-20/88 Pipe Replacement 88-14/14 Kerch and NDE 14.3 Peach Bottom Restart Plan Meeting in Rockville, Maryland on May 19, 1988 The inspectoc attended a meeting on May 19, 1983, to discuss the Peach Bottom Restart Plan. Items discussed included questions on the following areas:
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Restart Plan Work and Schedule Process
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Current Restart Plan Work Status
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Operator Staffing and Training
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Organizational Survey Process
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Performance Evaluation Program
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Plant Procedure Revision Program
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Personnel Grievance and Disciplinary Process
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Overview of QA/QC Program
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Overview of NRB and NCB These items will be addressed in the Peach Bottom Restart Safety Evaluation Repor .4 NRC Public Meetings Public meetings to receive comments on PECo's revised Restart Plan were held in Harford County, Maryland and in York and Lancaster Counties, Pennsylvania on May 16 and 17, 1988. Individuals attending these meetings were given an opportunity tc express their views on the PECo Restart Plan to members of the NR The inspector attended the meeting .5 Peach Bottom Site Supervision Meeting April 27,1988
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The Peach Bottom. Plant Manager conducts a biweekly meeting (every oth9r Wednesday) with supervision from each site work group. This in qudes the PECo work groups including plant, project and I suppert; and, alst includes each contractor work oroup. The I meeting is used es a means to discuss current site issues and to l pass information directly to work group supervisor ..
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-37-The inspector attended the meeting held on April 27, 1988, at 3:30 p.m. At this meeting the following topics were disc.ussed:
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supervisor training
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management of change
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six keys to quality
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outage status
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control room etiquette
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operations department organization Also in attendance at this meeting were the PECo President and Executive Vice President-Nuclea The inspector concluded that this periodic site supervision meeting was a good vehicle to directly inform and interact with all site management personne ,