ML19341A116
| ML19341A116 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/04/1980 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19341A109 | List: |
| References | |
| NUDOCS 8101220149 | |
| Download: ML19341A116 (4) | |
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u, PHILAD ELPHI A Ei.TCTRIC COM PANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. D ALTROFF viCs PRasioist ELECTRIC PROOfJCTION November 19, 1980 Re: Docket "os.,50-277 50-278 Inspection Nos. 50-277/80-08 50-278/80-07 Mr. Eldon J.
Brunner, Chief Reactor Operations and Nuclear Support Branch Region I U.S.
Nuclear Regulatcry Commission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Brunner:
Your letter of October 28, 1980 forwarded combined Inspection Report 50-277/80-08 and 50-278/80-07.
Appendix A to your letter addresses three items which did not appear to be in full compliance with Nuclear Regulatory Commission requirements.
These items are categorized as infractions and are restated below with our responses.
A.
Health Physics Procedure HP0/CO-10a Revision 2,
" Conduct in Controlled Areas - Minimize Exposure" dated May 10, 1978, states in part..." Eating, smoking, and drinking are not permitted in the general plant areas.
Specific designated eating and smoking areas have been identified.
Permanent areas (unless temporary conditions prohibit) are:
a)
Control Room b)
Restrooms c)
Health Physics Field Offices d)
Refuel Floor Change Areas e)
Radwaste Control Room f)
Rx 3 - 195 Fan Room Area y p oO
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Mr. Eldon J.
Brunner Page 2 g)
R/U 165 h)
T-165 against wall of Control Room 1)
APO Field Office T-ll6 j)
T-116 near Sample Station" Contrary to the above, smoking prohibitions were not observed, in that, on April 14, 21, and 22, 1980 the inspector identified crushed, partially smoked cigarettes, used matches, and partially smoked cigars as well as trash, litter and debris in the following non-designated smoking areas.
1)
Cable Spreading Room 2)
Unit Three Electrical Panel 30 C 21 3)
Turbine building 165 foot level adjacent to the Unit Two Turbine 4)
At Door 343 to the Unit Three Reactor Building 5)
Unit 3 Reactor Building 165 Foot level:
a)
Behind safety related cable tray ZB 3tt 429 b)
In the Unit 3 Fuel Pool Cooling fleat Exchanger drains (a radiologically cor.; rolled area) c)
In the Vicinity of Ventilation Piping 6)
Grating in the Radwaste Exhaust Fan Room 7)
Unit 3 Control Room Ventilation Supply Radiation Monitor OBC-186 8)
Turbine Building, 116 foot level lay down area 9)
In the overhead above the control room where work was being conducted.
RESPONSE
The regulations concerning smoking, eating and drinking in the plant were discussed during Employee Refresher Training held during the end of April and early May 1980.
It was also verified that smoking areas specifically designated in IIP 0 / C O-10 a,
Revision 2 are clearly defined and conspicuously posted with signs identifying them as smoking areas.
Since the abuse of smoking areas was determined only through discovery of smoking materials outside approved smoking areas, the station was unable to identify and counsel individual offenders, however, all site personnel will be receiving written instructions on use of proper smoking, eating and drinking areas in a new document called "Special Nuclear Plant Rules".
This document is discussed in more detail in response to item B.
B.
Technical Specification 6.11 requires:
" Procedures for personnel radiation protection shall be prepared consistent with requirements of 10 CFR Part 20 and shall be approved,
i.
Mr. Eldon J.
Brunner Page 3 J
maintained and adhered to for all operations involving personnel radiation exposure."
Health Physics Procedure HP0/CO-4, " Radiation Work Permits",
Revision 14, dated September 24, 1979, states in part..."All personnel who desire to enter the area covered by the RUP shall read and be familiar with the data and instructions on the RWP and sign their own name.
Each person shall provide the following data:
name...date...
time in... dosimeter reading... authorized exposure..."
Contrary to the above, radiation work permit (RWP)
~
requirements were not met on April 8, 1980, in that the three individuals working in the Unit 2 Reactor Building 135 foot level at the Control Rod Drive control station, an area covered by RWP #2-03-0298 dated March 28, 1980, had not read the RWP, had not signed in on the RWP, and had not provided the required data on entering the area.
(Recurrent item)
RESPONSE
j As soon as the individuals were made aware that they were working l
in an area with RWP controls, they exited the area and signed in properly on the RWP.
A review of the RWP identification mechanisms for the area revealed that they were not adequate, so they were relocated to be more readily visible.
Additionally, the individuals who had been in the Control Rod Drive control station area were counseled by the Operations Engineer concerning the necessity of consulting Health Physics personnel to determine the need for RWP's prior to working in potentially contaminated plant areas.
We are continuing ou r ef f orts to make all site personnel more conscientious in following correct radiation protection, housekeeping, and security procedures.
These procedures were reviewed during the Employee Refresher Training held in April and May, 1980.
In addition, a 'ist of~"Special Nuclear Plant Rules" has been developed which ir.cludes items related to security, health physics, and safecy.
This document will be distribut'ed to site personnel who must indicate that they have read the rules and understand them.
We expect to have distributed and collected copies of these rules and regulations from all site personnel by l
December 31, 1980.
Thereafter, the Special Nuclear Plant Rules will be distributed annually as part of General Employee Training with copies retained by the Training Division of Philadelphia Electric Company.
l l
C.
10 CFR 50 Appendix B, Criterion XVI, " Corrective Action" l
states in part, " Measures shall be established to assure that l-conditions adverse to quality such as failure, malfunctions,
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l's Mr. Eldon J.
Brunner Page 4 def icient Les...a re promptly identified and corrected.
Contrary to the above, a safety related cable penetration (Nomenclature ZB3MV05), located in the Unit 3 Reactor Building 165 foot elevation was found on April 21, 1980 to have a broken seal which compromised the seal and fire protection capability.
Further, there was no evidence to demonstrate that the seal had been inspected nor had measures been taken to identify and correct this penetration inadequacy.
RESPONSE
As stated in the Inspection Report, the damaged seal was promptly fixed when identified by the NRC Inspector.
The Inspection Report also states that periodic inspection of the Unit 3 Reactor Building 165 foot elevation on April 16, 1980, as required by Administrative Procedure A-30, Plant Housekeeping Controls, did not discover this deficiency.
The cable penetration seal in question is one of many seals through which cablee in cable tray ZB3MV05 pass at the Unit 3 Reactor Building 165 foot elevation.
The cable tray has a protective enclosure which abuts the floor and surrounds the penetration.
Since the purpose of the periodic inspection of this area is primarily to verify the cleanliness of general plant areas, it is not normally expected'to identify.a deficiency such as this.
We will notify Maintenance and Construction personnel to exercise more care around all seals and to report any damaged seals as soon as they are discovered.
Very truly yours, s
s
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