IR 05000277/2002007

IR 05000277-02-007, IR 05000278-02-007, on 04/01-07/01-2002, Exelon Generation Company, Peach Bottom Atomic Power Station; Units 2 and 3. Drill Evaluation, Event Response

ML022000347
Person / Time
Site:	Peach Bottom
Issue date:	07/19/2002
From:	Blough A Division Reactor Projects I
To:	Skolds J Exelon Generation Co, Exelon Nuclear
References
EA-02-121, EA-02-142 IR-02-007
Download: ML022000347 (20)

Text

uly 19, 2002

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION - NRC INSPECTION REPORT 50-277/02-07, 50-278/02-07

Dear Mr. Skolds:

On July 1, 2002, the NRC completed an inspection at the Peach Bottom Atomic Power Station.

The enclosed report documents inspection findings that were discussed with Mr. Jay Doering, and other members of your staff on June 25, 2002, and July 1, 2002.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspection consisted of a review of emergency preparedness activities associated with your staffs formal critique of a February 14, 2002, emergency preparedness exercise and your staffs emergency response to the Alert declared at Peach Bottom on June 2, 2002.

Based on the results of this inspection, we identified two preliminary findings of low to moderate safety significance (White). The findings do not present an immediate safety concern. One finding is associated with an inadequate critique of a February 14, 2002, emergency preparedness exercise. The weaknesses and deficiencies observed by the inspector were not identified and discussed during the Exelon critique. These weaknesses and deficiencies were related to the operating crew in the simulator not recognizing conditions or effectively communicating key information needed by the Emergency Director to classify the simulated event as a General Emergency. Emergency classification is a risk significant planning standard. The finding was determined to have low to moderate safety significance, in accordance with Emergency Preparedness Significance Determination Process (MC 0609, Appendix B, Sheet 1), because there was a failure to identify a risk significant planning standard problem during a critique.

The second white finding is associated with the length of time that it took Exelon to declare an Alert emergency classification during an actual event that occurred on June 2, 2002. On that date, the cardox (carbon dioxide) fire suppression system unexpectedly discharged into the E-3 emergency diesel generator room of the Diesel Generator Building. A cardox system discharge into a diesel generator room creates an atmosphere in the room that is life threatening to plant

John personnel in the room. Exelons Alert emergency classification was not timely, (10CFR 50.54, 50.47, and Appendix E require prompt notification) because it occurred 31 minutes after toxic gas was released into the Diesel Generator Building. This finding was determined to have low to moderate safety significance using the Emergency Preparedness Significance Determination Process (MC 0609, Appendix B, Sheet 2) because this finding was associated with the improper implementation of a risk significant planning standard during an actual event.

The failure to effectively critique the February 14, 2002, emergency preparedness exercise is an apparent violation of 10 CFR 50, Appendix E, IV.F.2.g. The failure to make a timely Alert declaration on June 2, 2002, is an apparent violation of 10 CFR 50.54(q), 50.47(b)(4), Appendix E IV.B, and Appendix E IV.D.1. Both apparent violations are being considered for escalated enforcement action in accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions (Enforcement Policy), NUREG-1600. The current Enforcement Policy is accessible from the NRC Web Site at http://www.nrc.gov.

Although both are separate findings that occurred over a period of time, one in a training environment and the other in an actual event, both are related to your staffs apparent difficulty in recognizing conditions that are directly associated with emergency action levels. Both findings also appear to have been related to prior issues contained in your corrective action program.

We believe that we have sufficient information to make our final significance determination for both findings. Nevertheless, you have the opportunity to either request a regulatory conference to discuss your evaluation and any differences with the NRC evaluation of either or both issues, or to send us your position in writing. Please contact Dr. Mohamed Shanbaky at (610) 337-5209 within 7 days of the date of this letter to inform the NRC of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination and enforcement decision, and you will be advised by separate correspondence of the results.

Since the NRC has not made a final determination in these matters, no Notices of Violation are being issued at this time. In addition, please be advised that the characterization of the apparent violations described in the enclosed report may change as a result of further review.

In addition, the inspectors identified one issue of very low safety significance (Green). This issue was determined to involve a violation of NRC requirements. However, because of its very low safety significance and because it has been entered into your corrective action program, the NRC is treating this issue as a non-cited violation, in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you deny any non-cited violation noted in this report, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Peach Bottom facility.

John In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (The Public Electronic Reading Room).

If you have any questions please contact me at 610-337-5229.

Sincerely,

/RA/

A. Randolph Blough, Director Division of Reactor Projects Docket Nos. 50-277, 50-278 License Nos. DPR-44, DPR-56 Enclosure: Inspection Report 50-277/02-07, 50-278/02-07

John