ML19347E773

Responds to NRC 810303 Ltr Re Violations Noted in IE Insp Repts 50-277/80-33 & 50-278/80-26.Corrective Actions: Procedure Developed & Being Performed Weekly to Periodically Drain Unit 2 Rms.Details Withheld (Ref 10CFR2.790)

ML19347E773
Person / Time
Site:	Peach Bottom
Issue date:	03/23/1981
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19347E771	List: ML19347E773
References
NUDOCS 8105130364
Download: ML19347E773 (7)

Text

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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 1881 1981 PHILADELPHI A. PA.19101 swirtos L. oAtrac,, mmsee mE N,c"E E~cLc St a r c h 23, 1981 Docket Nos. 50-277 50-273 Insoection Reoort 50-277/30-33 50-278/30-25 Mr. Eldon J. 3 runner, Chief ,

Reactor Operations and Nuclear Support 3 ranch

".egion I US Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Brunner:

Your letter of March 3, 1931 forwarded conbined Ins 9ection Reports 50-277/30-33 and 50-278/80-26. Appendices A and 3 to the Report address certain itens which do not appear to be in full compliance with Tuclear Regulatory Coenission requirenents. These items are listed as Severity Level IV violations.

The items of apparent nonconpliance are restated in Anoendices A and 3 to this letter along with our responses. Iten 1, Aanendix 3 deals witn natter concerning physical s e cu'r i t y and, therefore, it is requested that this information be withheld from public disclosure pursuant to Section 2.790 of the Cocaission's rules. An affidavit in supoort of the request is attached hereto.

Very truly yours,

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P 1I L A D E L P'lI A ELECTRIC CO'f P ANY

'ESPON93 TO IYSPECTIO" it E P O P.T " U 'f 3 E *'. S 50-277/30-33 and 50-279/10-26 APPE" DIX A

1. Technical s'pecification 3.9.C.3 states in part: "... tha off gas radiation monitors shall be operable or ooerating whenever steam oressure is available to the air e jectors. If these requirements are not satisfied, a nornal orderly shutdown shall be initiated within one hour."

Contrary to the above, fron about 6:30 a.m. Novenber 23, 1930 to about 9:00 a.=. Movember 24, 1930 the off-gas monitors were inonerable for seriods in excess of onc hour and no shutdown was initiated.

This Severity Level IV Violation is applicable to D?R-44, and is recurrent.

Resnonse The reduction in off gas a sap le flow was the result of water being transferred from the normal collect *un and drain system to the sampling systes. This transferrence as caused by a combination of recent modifications to t. collection and drain systen and systes dynamics resulting from never reduction initiated on November 22, 1980, at aoproxinately 10:00 n.n.

The oroblem was first noticed at aporoximately 6:30 a.m. on Nove=her 23, 1930, following a load reduction, when the off gas radiation monitor low flow a la rn was received in the cottrol room. Shift :ersonnel promptly investigated the croblen, found water in the off gas radiation monitor sampling system, and attenoted to re-establish full sacrie flow. Sample flow vas restored by aoproximately 9:00 a.m. Sovesber 24, 1930 by ourging the samnling system o f wa ter. It was believed by Shift Suoervision that the off-gas radiation monitoring system had remained onerable during the event even t h o u.3 h sas,le flow was reduced. On November 24, a temporary off 3as radiation nonitoring systen was installed to pernit special testing of t'e oermanent monitoring systes. The results of this testing, performed on Movember 25 and 25, indicated that the off gaa radiation nonitoring systen was actually inoperable '2r periods of time during the event.

Following the event the tenporary radiation nonitoring systen vss left in service to act as a backup and vill remain in service until nodifications to the system as described belew are completed. Although minor power level changes were made during the oeriod of inocerability, off gas values were similar before and after the event. Additionally, .eekly off gas grab saacles ,

were analyzed for isotocic cocoosition, and indicated no l unanticioated change tros previous w e e'< l y samples. As discussed  !

in the Ins 7ection Report, the radiation conitors do not cerforn l 1

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Page 2 any trio functions, but rather are provided as on2 of two early indications of accelerated fuel rod f ailu re . Other process radiation instrumentation which monitor for fuel f ailu re s (nain stean line nonitors) showed no unexpected changes during the event.

Subsecuent to the event a soecial procedure was developed to seriodically drain the Unit 2 radiation monitoring system to orevent a similar occurrence. The crocedure is currently being performed weekly. Modification to the drain systen for the Unit 2 off gas radiation nonitor sampling systea is scheduled to be concleted during the next outa2e of sufficient duration, at which time these neasures will be discontinued. This codification 9as previously casoleted on Unit 3. To prevent a similar occurrence in the future, tynical values for the off-gas radiation monitors at different oower levels will be posted in the vicinity of the recorder, and the off gas sonitor level vill be recorded once ser shift in the surveillance log. This event was originally recorted in Licensee Event Report 2-8C-31/1? on November 26, 1930.

It was stated that this iten was recurrent. On January 19, 1990, the Unit 2 off gas radiation sonitors were inoperable for a period in excess of 10 hou rs . This event was reported in Licensee Event 3eoort 2-30-03/13, and in resconse to Insoection Renort 50-277/30-03 and 50-273/30-03. The'cause of this event was a pe rsonnel valving error, an! corrective action included changes to the startup checklist and writing of the systen orocedure and the systen check-off list. The event described in combined Insoection Denort 50-277/30-33 and 50-273/80-26 vas caused by imoroper system design and will be corrected by system modi *ication. Therefore, although loss of the off gas radiation monitoring systes on November 23 was a recurrent eveat, no further investigation into generic corrective action is believed n e~c e s s a r y .

2. Technical Specification 6.11 " Radiation Protection

?rogram," states, " Procedures for personnel radiation protection shall be p repared consistent with the requirements of 10 CFR 20 and shall be acoroved, '

maintained and adhered to for all operations involving personnel radiation exposure."

Procedure No. H?O/CO-10A, " Conduct in Controlled Arcas Minimize Exposure," ?evision 2, dated May 20, 1930, develooed pursuant to the above requirements states in part, "?urnose: This crocedure describes the rules which will 3overn the conduct of individuals assigned duties in controlled areas and outlines techniques for ain121 zing exposure... Procedure: 2. Signs aad radiation rone are posted at various areas to alert P00R ORIGINAL

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l nersonnel to the radiation conditions which exist... 3.

7adiation rope or tane is a barrier. Do not cross such rose or tape... If area of interest has no steo-off oad, contact uealth Physics for information regarding entry."

Contrary to the above, on November 25, 1930, at accroximately 2:30 p.a., three individuals disregarded soecial instructions on a sign and crossed through a rope ba rrier , at the southeast side of the 165" e leva tion of the Unit 3 reactor building into a location which contained a high radiation area. The sign stated, "No entry, use west side."

This Severity Level IV Violation is acclicable to OPR-56.

Resoonse As stated in the Insoection Report the individuals inmediately exited the area when advised of requirements by the inspector.

Two of the individuals involved were contract Health Physics personnel and the third was a contract janitorial employee. The contract Health Physics individuals were counseled by Mealth Physics Supervision on the day of the occurrence, and the contract janitorial employee was counseled by Health Physics Su,ervision the following day. None of the individuals had read the instructions regard.ing entry at the boundary, and all were recinded to read and obey all radiation signs.

Investigation of the incident revealed that positive control of the area was naintained since a Health Physics technician was within the radiation boundary until the survey vss completed and boundaries determined. It is exoected that he would have encountered, and oronerly directed, the three individuals who were instead identified by the inspector.

It was deternined that none of the individuals who incroperly entered the radiation a re a rece ive d a ny accreciable exoosure based on Marshaw badge readines.

The Insoection Reoort also expressed concern about management controls which allowed these events to occur. In both cases it appears that the events occurred despite proper managenent control. The loss of flow to the off gas radiation monitor was due to an unanticipated design problem and proner steps have been taken to correct the orobles. The individuals involved in the second incident had received oroper instruction. All individuals who are emoloyed on site receive General Employee Training, which includes instruction to read and obey all posted signs, including those associated u?ch radiation areas. Additionally, a pamphlet titled "'!u c le a Plant "ules" was distributed to site eersonnel in Decenber 1930, and is read and distributed te all personnel during General Enolayee T raining. This docum n n ludes an entire sectio.1 6f Health Physics rules.

3-PHILADELPHZA ELECTRIC COMPANY RESPONSE TO INSPECTION REPORT NUMBERS 50-277/80-33 and 50-278/80-26 APPENDIX B THIS PAGE, CONTAINING 10 CFR 2.790 INFORMATION, NOT FOR PUBLIC DISCLOSURE, IS INTENTIONALLY LEFT BLANK.

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I COMM0'WE ALT!Y 0? P EU'!3YLV ANI A :

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COUNTY OF ?MILADELPHIA  :

S. L. DALTROFF, being first duly sworn, deposes and states as follows:

1. !Ie is Vice President of Philadelphia Electric Coneany (hereinafter referred to as the " Company"); he is authorized to execute this Affidavit on behalf of the Connany; and he has read the foregoing letter to the United States Fuclear Regulatory Commission, Office of Insoection and Enforcement, containing the Conpany's response to Inspection Recort Nunber 50-277/30-33 and 50-273/90-26 (hereinafter referred to as "the Response"), and know s the contents thereof.

2. The Response which is sought to be withheld from public disclosure contains details of the physical security olans for Peach 3ottos Atonic Power Station.

3. To the best of his knowledge, infornation and belief, the inf o rma tion set forth in the letter has been treated as confidential and proprietary information and has been withheld from cublic disclosure by the Cocoany in accordance with the Company's practice of treating all information dealing with the details of s e cu ri ty procedures as confidential and proprietary information.

4 The Response should be considered by the Nuclear Regulatory Commission as confidential and proorietary information and be withheld from public disclosure on the grounds that it P00hBMIE .

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contains details of the physical security nians of a licensed facility, such disclosure is not required in the public interest, and such disclosure would adversely affect the interest of Philadelohta Electric Conpany.

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/ j Subscribed and Sworn to before me t h i s - A3.h day of bi R _ n 4%

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