ML19305D922
| ML19305D922 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/28/1980 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19305D918 | List: |
| References | |
| NUDOCS 8004160187 | |
| Download: ML19305D922 (3) | |
Text
,
i O
PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.Oi. BOX 8699 PHILADELPHI A. PA.19101 swistos o4LTnorr ELECTRIC PRODUCTION February 28, 1980 Re: Docket N os. : 50-277 50-278 Inspection No.: 50-277/79-29 50-278/79-32 Mr. Eldon J.
Brunner, Chief Reactor Operations & Nuclear Support Branch US Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia. PA 19406
Dear Mr. Brunner:
Your letter of February 8, 1980, forwarded combined Inspection Repo'rts 50-277/79-29 and 50-278/79-32.
Appendix A to your letter addresses two items as not appearing to be in full compliance with Nuclear Regulatory Commission requirements.
Both items are infractions and are restated with our responses.
A.
Technical Specification 6.1.1,
" Radiation Protection Program", requires that p roce du re s f or personnel radiation protection shall be p repared consistent with requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to f or all operations involving p ers onnel exp osure.
Health Physics Procedure HP0/CO-4, " Radiation Work Permits",
revision'13, dated Herch 20, 1979, requires in part in Section VI that all p ers onnel who desire to enter the area covered by the RWP shall read and be familiar with the data and the instructions on the RWP, sign their own name, and time in, dosimeter reading, provide name, date, Contrary to the above requirement, on N ove mb e r 8, 1979, one individual f rom the operations staff entered the Unit 3 165 foot elevation turbine and turbine hall areas for an 8004160l9T
n b.
Mr.
E.
J.
Brunner, Chief Page 2 inspection without signing in or p roviding app rop riate data l
required by RWP 3-I-5 governing such inspection entries.
(Recurrent item).
Response
On November 8, 1979, during the startup of Unit 3, a verbal report of a steam / water leak on the high p ressu re turbine inlet piping was received by Shift Supervision.
A member of the operations staff entered the area to investigate a potentially serious p roblem ; however, he failed to sign the p osted RUP.
The observed leakage was not serious and no additional action was required immediately.
Total exp osure to the p ers on involved was approximately 10 mrem.
Reference has been made to Inspection Report 79-23/25 as being similar to this occurrence.
Item 3 of Appendix A of that report involved pers ons performing routine work in an area of low radiation which was controlled by an RWP, without signing in on the RWP.
The recent occurrence involved a knowledgeable individual who t ook approp riate safety and HP precautions and entered an area of potential high radiation with a portable instrument for measuring dose rate.
The decision to enter the area was made after a judgment that a p otential emergency situation could have existed and that there was a need f or immediate action.
Based on the p recautions which were taken, the health and saf ety of the individual were not compromised.
The operations staff and operating pers onnel have been reminded of the imp ortance of following the RWP procedures at all times.
Procedu re HP0/CO-4 contains certain p rovisions for entering a radiation area to expedite work or inspections without filling out the RWP first.
In order to clarify the circumstances for which an expedited entry is permissible, a review of the procedure will be perf ormed and app rop riate revisions made as required.
j B.
10 CFR 10 Appendix B, Criterion XVI, states in part:
" Measures shall be es tablished t o ensure that conditions adverse to quality, such as failures, are p romp tly identified and corrected Contrary to the above, a cable tray penetration (Nomenclature ZB2MV180), located in the Unit 2 Reactor Building 135 foot elevation was found on November 8,
- 1979, to have a broken seal which comp romised the seal and fire protection capability.
Additionally, the seal enclosure j
contained trash and debris, constituting a potential fire
s Mr.
E.
J. Brunner, Chief Page 3 hazard.
This seal had last been inspected on April 23, 1979, and no measures or licensee inspection had identified and corrected this penetration inadequacy.
Response
The fire seal on the cable tray penetration was opened on April 23, 1979, as part of a new cable installation f or the security system.
This penetration was.docunented as being temp orarily sealed on April 23, 1979, in accordance with Construction Division Implementing Procedure 16 (CDIT-16).
A terp ora ry seal was used because of the uncertainty involved with f.he routing of additional secu rity system cables in this area.
Parmission for extended use of the temporary seal f or more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> was obtained f rom shif t supervision and documented as required.
The t emp ora ry seal was apparently damaged after installation and as a result, the exp osed enclosure was later f ound t o contain trash and debris.
After discovery of the broken fire seal, Const ruction Division personnel removed the trash and debris from the floor penetration and p ermanently resealed the tray.
The fire seal was inspected and accepted the f ollowing day, N ove mb e r 9, 1979, in accordance with CDIP-16.
The deficiency of Procedure CDIP-16 to require documented periodic f ollow-up inspections of temporarily sealed penetrations led to this inf raction.
Therefore, procedure CDIP-16 vill be revised by March 31, 1980, to require a documented weekly review and inspection to assure the integrity of all temp orarily sealed penetrations.
Operations shift pers onnel have also been reques ted t o inspect fire seals as part of the periodic inspections of assigned plant areas required by Administrative Procedure A-30.
The " Request for Housekeeping" f orm has been revised to remind the op erat or t o check fire seals and list those which are damaged.
Very truly yours,
.y7 re n
-