ML20031D137
| ML20031D137 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/23/1981 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20031D136 | List: |
| References | |
| NUDOCS 8110090387 | |
| Download: ML20031D137 (5) | |
Text
I PHILADELPHIA ELECTRIC COMPANY 23O1 P ARKET STREET P.O. BOX 8699 1081 -1981 PHILADELPHIA PA.19101 1215)8415003 JOSEPH W. GALLAGHER stscthic enocuct oN capantessNI september 23, 1981 Docket Nos. 50-277 50-278 Inspection Nos. 50-277/81-18 50-278/81-19 Mr.
R.
R.
Keimig, Chief Reactor Projects Branch 2 Division of Resident and Project Inspection Region I U.S.
Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Keimig:
Your letter of August 24, 1981 forwarded combined inspection Report No. 50-277/81-18 and 50-278/81-19.
Appendix A to the report addresses certain areas which do not appear to be in fu'l compliance with Nuclear Regulatory Commission Requirements.These items of non-compliance are restated below along with our response.
A.
Technical Specification 6.8.1 requires in part:
" Written procedures and administrative policies shall be established, implemented and maintained..."
Procedure A-30, " Plant Hour,ekeeping Controls," Revision 4, dated May 21, 1981, sta tes in part : "a.
Maintenance of Fire Fighting Capabilities:...The storage of equipment and material shall not impede accessibility to fire fighting equipment...and operability of firedoors.
All fire doors and watertight doors shall be maintained closed except when required to accommodate the movement of personnel or equipment...."
Ohd$
.Pcga 2 contrary to the above:-
1.
On July 14, 1981, Fire Door No. 128-(on the 135-foot-elevation in the Radwaste Building) was blocked in the open position; 2.
On July 28, 1981, Fire Door No. 134 (on'the 116-foot elevation in the Turbine Building,to the Laundry) was open; and 3.
On July 31, 1981, Fire Station 135-21 (on the 135-foot elevation in the Unit 2 Reactor Building) was obstructed by a large portable cart and container.
This is a Severity Level V Violation (supplement I) applicable to DPR-44 and DPR-56.
RESPONSE
The three items listed in this violation are responded to separately.
1.
On July 14, 1981 Fire Door No 228 in the Radwaste Building was found to be blocked open.
The inspector reported the incident to a senior licensee representative who had the door unblocked and closed.
Personnel who generally work in the radwaste building were counseled as to the importance of maintaining the door closed.
Additionally the door was inspected and a maintenance request generated for repair to a hinge binding problem which probably caused the door to be blocked open initially.
Subsequent inspections by site personnel indicate that the door is now being kept closed.
2.
On July 28, Door No. 134 a fire door between the turbine and radwaste building on elevation 116 was found open.
Two contract personnel passed through the doorway without attempting to close it.
The inspector informed them of the j
requirement and the door was then closed. The Philadelphia Electric Company personnel who supervise these centract workers were instructed to inform all three shifts of the vendor personnel about the importance of keeping the door closed.
The door in question is a water tight door which is not required to be closed for internal flooding protection.
Recognizing the difficulty in maintaining the water tight door closed 4.n an area of continuous traffic, PECO initiated procurement of a self closing fire door in the spring of 1981.
This door has been installed in series with the existing water tight door since the inspection to insure the integrity of this fire barrier.
3.
As stated in the inspection report, on July 31, 1981 Fire Station 135-21 on elevation 135 of the Unit 2 Reactor i
Paga 3 building was found to appear obstructed by a large portable cart and container..PECO recognizes the importance of not obstructing fire fighting equipment and has Administrative Procedures for their control as noted in the notice of violation.
However'a subsequent investigation by PECO personnel ascertained that the empty cart could have been stepped across or rapidly moved and neither cart or container impeded access to the hose reel or fire extinguisher.
Based on these facts, PECO feels that this item of non-compliance warrants reevaluation.
B.
Technical Specification 6.8, Procedures, states in part:
" Written procedures shall be established, implemented and maintained..." Surveillance test procedure ST 2.2.05 (Funct),
1 4
" Functional Test of DPIS 2-13-84," Revision 10, dated June 8, 1981, performed July 1, 1981 states in part: " Inform the Reactor Operator that the automatic isolation should be reset i
and the system returned to normal per procedure S.3.5.E."
Procedure S.3.5.E., Revision 8, dated May 19, 1981, requires i
completion of Procedure S.3.5. A to prepare the system for automatic operation.
Procedure S.3.5.A.,
Revision 7, dated August 5, 1980, requires completion of the line up in accordance with C.O.L.S.3.5.A,
" Reactor Core Isolation Cooling System," Revision 10, dated May 30, 1980 which specified "OPEN" for valve AO-137.
i contrary to the above, Valve AO-137 was found closed following surveillance testing performed July 1, 1981, until noted by the inspector on July 2, 1981.
1 This is a Severity Level VI violation (supplement I) applicable to DPR-44.
RESPONSE
As stated in the inspection report, on July 2, 1981 the inspector i
noted that the valve was closed.
The reactor operator was informed and reopened the valve.
Investigation has indicated I
that AO-137 was erroneously manually closed in the process of resetting the isolation caused by performance of ST 2.2.05.
The closure was not a direct result of the performance of ST 2.2.05.
The operators involved and all shift technical advisors were counseled on the importance of verifying proper system lineup after completion of surveillance testing which removes safety components from service, and during front panel checks at the beginning of each shift.
Criteria will be developed by November 1,
1981 to provide. proper redundant verification of return to service of equipment important to safety following surveillance testing.
This criteria will be provided to shift personnel for l
implementation prior to procedure revision.
The documentation feature for redundant verification on surveillance test procedures will be implemented by revising the tests as l
~
Pag 3 4 previously committed in a letter from S.
I-.
Daltroff to D.
G.
-Eisenhut dated December 22, 1980.
C.
Technical Specification 6.i
" Radiation Protection Program,"
states: " Procedures for personnel radiation protection shall be prepared consistent with requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure."
Health Physics Procedure HPO/CO-5, " Selection and Use of Anti-C Clothing," Revision 6, dated April 30, 1980, states in part: " Anti-Contamination clothing requirements for an area are specified by the health physics technician and listed on the Radiation Work Permit (RWP)...
If no RWP is required, the requirements are usually posted, contact health physics for entry clothing requirements."
The procedure requires that the individual determine the Anti-Contamination Clothing requirements from the RWP, area posting, or health physics and don the specified clothing.
Contrary to the above on July 13, 1981 an individual failed to adhere to the posted protective clothing requirements for the torus entry area, 135' elevation of Unit 3, Reactor Building.
The posted instruction required coveralls, surgeons cap, two sets of plastic shoecovers, and two pairs of gloves. No othor protective clothing requirements were identified by the health physics technician, and no RWP was in ef fect.
At the time of the observation, the individual was wearing only one pair of shoecovers and a pair of perforated gloves.
This is a severity Level V violation applicable to DPR-44 and DPR-56.
RESPONSE
As stated in the inspection report, the contract employee was ordered to exit the area by HP Technicians.
An immediate frisk was performed and no contamination was detected.
The contractor's safety representative and the individual's immediate supervisor weDa notified.
The individual was counseled on the importance of strict adherence to posted health physics instruction.
The area in question,2 the torus entry area, (100-400 cpm /ft / surface contamination) presented a minimal radiological hazard to the individual.
Very truly yours,
&, L p
T~
COMMONWEALTH OF PENNSYLVANIA :
ss.
COUNTY OF PHILADELPHIA J. W. Gallagher, being first duly sworn, deposes and says:
That he is Manager of the Electric Production Department of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing response to Inspection Report No. 50-277/81-18 and 50-278/81-19 and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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Subscribed and swo n to before me this day
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