ML19345E802
| ML19345E802 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/30/1980 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19345E800 | List: |
| References | |
| NUDOCS 8102060166 | |
| Download: ML19345E802 (5) | |
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PHILADELPHIA ELECTRIC COMPANY rmU 2301 M ARKET STREET P.O. BOX 86 99 PHILADELPH;A PA.19101 JOSEPH W. GALLAGMER esserme=((E/ro'.".osn.r..,
12:51841-5003 October 30, 1980 Re: Docket Nos. 50-277 50-278 Inspection Nos. 50-277/80-24 50-278/80-18
!! r. Eldon J.
Brunner, Chief Reactor Operations & Nuclear Support Branch Region I United States Nuclear Regulatory Comatission 631 Park Avenue King of Prussia, PA 19406
Dear !! r. Brunner:
This letter is in response to combined Inspection u.eport 50-277/80-24 and 50-278/80-18 dated October 8,
1980.
Appendix A to your letter addresses two items which do not appear to be in full compliance with Nuclear Regulatory Conmission requirements.
Items A and B,
categorized as an infraction and a deficiency respectively, are restated in the attached Appendix A with our responses.
Anpendix B to your letter contains an infraction which does not appear to be in full compliance with Nuclear RcGulatory Commission requirements and pertains to the details of the l
physical security plans of a licensed facility.
Therefore, it is hereby requested that the information included in the attached j
Appendix 3 be withheld fron public disclosure pursuant to Section 2.790 of the Commission's Regulations.
'An affidavit in support.
of this request is attached hereto.
The-infraction is restated j
in the attached Appe.ndix B with our response.
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Very truly yours,
,k BA L j Attachment l
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i 8102060 M Y
PHILADELPHIA ELECTRIC COMPANY RESPONSE TO INSPECTION REPORT NUMBERS 50-277/80-24 and 50-278/80-18 APPENDIX A A.
Technical Specification 3.11.D requires in part, "... Snubbers listed in Table 3.11.D.1 shall be operable 3xcept From and after the time that a anubber is determined to be inoperable, continued reactor operation is permissible only during the succeeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />..."
Contrary to the above, Philadelphia Electric Company was advised by the architect-engineer on June 5, 1980 that Snubber 10-GB-S-44 listed in Table 3.11.D.1 was inoperable.
Plant operation then continued for a period of 43 days with this snubber inoperable and no shutdown being initiated.
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Response
Snubber 3-10GB-S44 on the Unit 3 RUR system was determined to be inoperable as part of the review of seismic analyses for as-built-safety related piping systems required by Bulletin 79-14.
The following operating and reporting criteria are stipulated in Bulletin 79-14 Supplement 1 dated August 15, 1979: "If either part of the evaluation shows that the system may not perform its intended function during a design basis earthquake, the licensee must promptly comply with applicable action statements and reporting requirements in the Technical Specifications." When a support or hanger was deter. mined to be inoperable during the Bulletin 79-14 review, the piping system to which it is attached was analyzed for system operability under Design Basis Earthquake (DBE) conditions.
If the resulting analysis determined that the system remained operable, the inoperability of the hanger or support was not considered reportable.
The results of the final stress calculations for Snubber 3-10GB-S44 and its associated piping were received on June 7, 1930 fron l
our architect engineer.
Although the snubber was determined to j
be inoperable, the analysis for the associated piping verified that the system would be operable under DBE conditions.
Therefore, on June 7,
1980 it was determined-through review of l
the final stress calculation results that the failure of the snubber would not have prevented the-RHR system from performing its safety function and would not have jeopardized the' safe operation of Unit 3.
Because this item was not reportable under-Bulletin 79-14 requirements, and because snubber operability historically has been judged on the physical operation of,the snubber and not calculated stress characteristics, its significance with respect to-Technical Specification 3.11.D was not recognized by reviewers.
On July 17, 1980, during a review of Unit 3 Bulletin 79-14 results, the site inspector' identified-the subject 1 snubber as l
being inoperable.
Upon notification corrective action was initiated to comply with Technical Specification requirements and prompt written notification to the NRC was provided by means of LER 3-80-16/IP.
The importance of complying with applicable Technical Specifications when performing a Bulletin review and the criteria by which snubber operability is determined was emphasized to the cognizant personnel.
B.
Technical Specification 6.9.2.9,
" Prompt notification with written followup," states in part, "The types of events listed below shall be reported...within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />...with a written followup report within ten working days...
Performance of structures, systems or components that requires remedial action or corrective measures to prevent operation in a manner les's conservative than assumed in the accident analysis in the safety analysis report..."
Contrary to the above, on nine occassions as listed below, no report was made to the NRC when the licensee was informed by its architect-engineer of seismic restraint inadequacies which required corrective action to prevent operation in a manner less conservative than assumed in the accident analysis in the safety analysis report.
The pipe supports involved and the dates of architect-engineer notifications were:
Comnonent System Date Informed M-295-61 Main Steam Sample June 16, 1980 6-HF-S4 Feedwater Long Path July 2, 1980 Recirculation I
M-295-76, PC-11 Reactor Pressure July 2, 1980 and PS-104 Vessel Drain Drawing Detail High Pressure July 9, 1980 No. X Service System M-295-77 Reactor Pressure July 2, 1980 CSP-H901 Vessel Drain 27HC-S6 Condensate Transfer June 30, 1980 System l
27HC-S56 Condensate Transfer June 30, 1980 System l
Reactor Pressure Reactor Pressure June 30, 1980 j
Vessel Column B Vessel Level Instrumentation I
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" e's p o n s'e The supports listed above were identified as system operability problems during the Unit 2 refueling outage as part of the nulletin 79-14 as-built seismic review.
During our review, when an overstressed support was identified, the architect-engineer used a parallel path approach by designing a modification to correct the overstressed condition and by simultaneously analyzing system operability.
The dates indicated in the notice of violation as "Date Informed" are the dates on which we received the modification details which did not determine system operability.
Results were received by the licensee from the architect-engineer on July 18, 1980 which identified the system operability problems listed above.
These itens were discussed in detail on July 22, 1980 with the site inspector.
it was our judgment that the reporting requirenents concerning the supports were fulfilled by the August 1,
1980 submittal of Bulletin 79-14 Unit 2 review results.
Subsequent review of Technical Specification 6.9.2.9 indicates that the identified inoperability problems warranted prompt notification through the Licensee Event Report (LCR) system.
The incorrect determination that these items did not require prompt notification was made based on the fact that they were reportable under Bulletin 79-14 and that the unit was in the cold shutdown condition.
The Technical Specification requirements concerning prompt notification have been reviewed with the appropriae. personnel.
It was emphasized that the licensee's responsibility to report such items is not relieved by other reporting requirements or by the unit being in cold shutdown.
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APPENOXX B J
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I THIS PAGE, CONTAINING 10 CFR 2.790 INFORMATION, NOT FOR PUBLIC DISCLOSURE, i
IS INTENTIONALLY LEFT BLANK.
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