ML20032B263

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IE Insp Repts 50-277/81-20 & 50-278/81-22 on 810904-1006. Noncompliance Noted:Inadequate Procedures Governing Shutdown Operations Resulting in Pressurization of Unit 3 Reactor Vessel Below Min Temp
ML20032B263
Person / Time
Site: Peach Bottom  
Issue date: 10/15/1981
From: Blough A, Cowgill C, Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20032B255 List:
References
50-277-81-20, 50-278-81-22, NUDOCS 8111050363
Download: ML20032B263 (17)


See also: IR 05000277/1981020

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

Region I

50-277/81-20

Report No. 50-278/81'22

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50-277

Docket No. 50-278

DPR-44

c

License No.DPR-56

Priority

Category

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Licensee: Philadelphia Electric Company

2301 Market Street

Philadelphia, Pennsylvania

Facility Name:

Peach Bottom Atomic Power Station, Units 2 and 3

Inspection at:

Delta, Pennsylvania

Inspection conducted: September 4 - October 6,1981

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Inspectors:

C. J. Cowgill, III, Senior Resident Inspector

date signed

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00TJ5iw

A. K. biough, Kesident inspector

date signed

date signed

OCT J t %i

Approved by:

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E. C. McC'abe, Jr. , Chief, Reactor

date signed

Projects Section No. 2B, DRPI

Inspection Summary:

Inspection of September 4

>ctober 6,1981 (Combined Inspection Report Nos. 50-277/

81-20 and 50-278/81-22 )

Areas Inspected:

Routine, on-site regular and backshift inspections by the Resident

Inspectors (69.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Unit 2; 63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br /> Unit 3). Areas inspected included accessible

portions of the Unit 2 and Unit 3 facilities, operational safety, event followup,

radiation protection, physical security, control room observations, LER review.

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Circular followup, surveillance testing, review of TMI Action Plan requirements,

requalification training, emergency preparedness, outstanding item followup and

periodic reports.

Resul ts: Noncompliances:

none in 13 areas, one in one area.

(Failure to have

adequate procedures governing shutdown operations which ressl+ed in the pressuri-

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zation of the Unit 3 Reactor Vessel below the minimum allowable temperature for

pressurization, Detail 5.)

Region I Form 12

8111050363 811106

(Rev. April 77)

PDR ADOCK 05000277

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DETAILS

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Persons' Contacted

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W. H. ' Alden, Engineer-in-Charge, Nuclear Section -

R. J. Costagliola, Electric Production Quality Assurance Supervisor

J.' K. Davenport, Maintenance Engineer

G. F. Dawson, E&C Engineer

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  • R. S. Fleischmann, Assistant Station Superintendent-

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A. Fulvio, Results Engineer

' N. Gazda, Health Physics, Radiation Protection Manager.

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F. W. Polaski, Reactor Engineer

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S.:R.. Roberts, Operations Engineer

D. C. Smith, Outage Coordinator-

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S. A. Spitko, Site Q. A.-Engineer

S. Q. Tharpe, Security Supervisor.

  • W. T. Ullrich, Station Superintendent

A. J. Wasong, Test Engineer

J. E. Winzenried, Technical Engineer

R.-H. Wright, Test Engineer

'Other licensee employees were also contacted during the . inspection.

  • Present at exit interviews on-site and for summation of preliminary

inspection findings.

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2.

Previous Inspection Item Update

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(Closed) Infraction (277/80-11-03)', failure to perform negative pressure. test

before using respirator. The licensee's response ~ addressed training for use.

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of-respirators. Through attendance at General Respiratory Training -(during _a

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previous-inspection period), observations of personnel in-plant, and discus .

sions with workers regarding respirator training, the inspector determined

that negative pressure test requirements are understood and are being.followed.

No unacceptable conditions were identified.

(Closed) Unresolved Item (79-20-01 and 79-22-01), entries in C0 and AC0

log books as compared to entries in shift supervision log _ books and admin-

istrative procedure requirements. This issue was addressed'in combined

reports 81-19 and 81-20. A licensee response to that report is required,

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and NRC will review corrective actions.

For record purposes, this item

is closed.

(Closed) Inspector Follow Item (80-35-03 and 80-28-01) liconsee action to

achieve reliable scram discharge volume continuous monitoring system. The

inspector noted that licensee actions, which included efforts to eliminate

electronic noise, precisely locating transducers for' minimum crud interfer-

ence, and testing different coupling compounds, have resulted in reliable

operation for several months. The equipment is operable at Unit 2 but has

been removed at Unit 3 following long-term scram discharge pipe modification.

(Closed) Inspector Follow Item (81-14-02 and 81-15-01), contact security' guard

for more detailed information regarding statements made to media. The~ guard

did.not return to. work following the security force labor action. The inspec-

tor was not able to independently substantiate assertions regarding " clock

round" records.

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3.

Plant Operations Review

a.

Logs and Pecords

(1) Documents Reviewed

A sampling review of logs and records was made to:

identify signi-

ficant changes and trends; assure that required entries were being

made; to verify that operating orders and night orders conform to

Technical Specification requirements; check correctness of communi-

cations concerning equipment and lock-out status; verify jumper log

conformance to procedural requirements; and to verify conformance

to limiting conditions for operations.

Logs and records reviewed

were:

(a) Shift Supervision Log, September 4,1981 - October 6,1981

(b) Reactor Engineering Log - Unit 2, September,1981

(c) Reactor Operators Log - Unit 2 - September 4 - October 6,1981

(d) Reactor Operators Log

Unit 3 - September 4 - October 6, 1981

(e) C0 Log Book - September 4 - October 6, 1981

(f) STA Log Book - Sampling, September,1981

(g) Night Orders - Current Entries

(h) Radiation Work Permits (RWP's) - Various in both Units

2 and 3, September, 1981

(i) Maintenance Request Forms (MRF's) - Units 2 and 3, (Sampling)

September, 1981

(j)

Ignition Source Control Checklists (Sampling), September,1981

(k) Operation Work & Information Data - September,1981

Control room logs were reviewed pursuant to requirements of Admin-

istrative Procedure A-7, " Shift Operations." Frequent initialing

of entries by licensed operators, shift supervision, and licensee

on-site management constituted evidence of licensee review. Logs

were also reviewed to assure that plant conditions including

abnormalities and significant operations were accurately and

completely recorded.

Logs were also assessed to determine that

matters requiring reports to the NRC were being processed as

suspected reportable occurrences.

No unacceptable conditions

were identified.

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Facility Tours

During the course of this inspection, which also included shift turnover,

the inspector conducted ouily tours and made observations of:

-- Control Room - (daily)

-- Turbine Building - (all levels)

-- Reactor Building - (accessible ar: is)

-- Diesel Generator Building

-- Yard area and perimeter exterior to the power block, including

Emergency Cooling Tower and torus dewatering tank

-- Security Building, including CAS, Aux SAS, and control point

monitoring

-- Lighting

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-- Vehicular Control

-- The SAS and power block control points

-- Security Fencing

-- Portal Monitoring

-- Personnel and Badging

-- Control of Radiation and High Radiation areas including locked

door cht.ks

-- TV monitoring capabilities

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Off-Shift Inspections during this inspection period ano the areas examined

were as follows:

DATE

AREAS EXAMINED

September 10

Control room observations,

tour of Cable Spreading Room and

Unit 3 Reactor Building

September 16

Control Room Observations

September 22

Control Room observations

September 23

Control Room observations

September 24

Tour of Unit 3 Reacto- Building,

Control Room observations

September 25

Control Room observations,

tour of Protected Area

September 30

Control Room observations;

tour of Protected Area, Unit 2

Reactor Buildings and Vital Pump

Structure

October 1

Control Room observations; tour of

Protected Area, Unit 2 and Unit 3

Reactor Buildings, and the Cable

Spreading Room

October 6

Control Room observations,

Tour of the Turbine Building

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-- Off Normal Alarms. Selected annunciators were discussed with control

room operators and supervisi 1 to assure they were knowledgeable of

plant conditions and that corrective action, if required, was being

taken.

Examples of specific alarms discussed during the report period

were: APRM High; Rod Withdrawal Block; 'A' Diesel Fuel Storage Tank

Level, High/ Low; Standby Liquid on Pipe Temperature, High/ Low; and

Condensate Storage Tank Level, High/ Low. The operators were knowledge-

able of alarm status and plant conditions.

-- Control Room Manning. On frequent occasions during this ins

the inspector confirmed that requirements of 10 CFR 50.54(k)pection,

, the Tech-

nical Specifications and comitments to the NRR letter of July 31, 1980

for minimum staffing were satisfied. The inspector frequently confirmed

that a senior licensed operator was in the control room complex.

No

unacceptable conditions were identified.

-- Fluid Leaks. The inspector observed sump status, alarms, pump-out rates,

and discussed leakage with licensee personnel. At 12:30 p.m. , September

25, 1981, the inspector identified a floor drain backing up on the 165

foot elevation of the Unit 3 Turbine Building. When notified, shift

personnel took prompt ccrrective action. No items of noncompliance

were identified.

-- Piping Vibration. No significant piping vibration or unusual conditions

were identified.

-- Monitoring Instrumentation. The inspector frequently confirmed that

selected instruments were operating and indicated values were within

Technical Specification requirements. On a daily basis when the inspec-

tor was onsite, ECCS switches positioning and valve lineups, based on

control room indicators and plant observations were verified.

Examples

of instrumentation observed included flow setpoints, breaker position-

ing, PCIS status, radiation monitoring instruments, and Standby Liquid

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Control System parameters. No unacceptable conditions were identified.

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-- Equipment Conditions. The inspector verified operability of selected

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safety equipment by in-plant checks of valve positioning, locked valve

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contro.1, power supply availability and breaker positioning. Selected

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major components were visually inspected, as applicable, for leakage,

proper lubrication, cooling water supply, operating air supply, and

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general conditions. On September 23 and 24, the inspector independ-

ently checked the lineup of all Standby Liquid Control System valves.

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On September 25, while verifying the status of the feedwater system,

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the inspector noted that the lock was unlocked on a twelve-inch feed

pump bypass valve at Unit 2.

The valve was properly positioned and

the chain to the locking device was in-place.

When notified. shift

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supervision promptly locked the valve. The inspector noted that the

valve was not on the locked valve lists and was not shown as locked

on the system drawing. Locking of this valve was being done admini-

stratively by the licensee. The inspector expressed concern, however,

that more attention to control valve locking devices may be needed,

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and will continue to routinely monitor the licensee's controls over

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all locked valves.

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-- Fire Protection. On frequent occasions, the inspector verified the licen-

see's measures for fire protection. The inspector observed control room

indications of fire detection and fire suppression systems, spot-checked

for proper use of fire watches and ignition source controls, checked a

sampling of fire barriers for integrity, and observed fire-fighting equip-

ment stations. No unacceptable conditions were identified.

4.

IE Circulars Which Require No Response

Inspection was performed for the following IE Circulars to verify that the

Circular was received by licensee management, review for applicability was

performed, corrective action (if any) was initiated and/or evaluated, and

supporting documentation evidencing licensee review was contained in PORC

minutes.

Findings were as follows:

a.

IE Circular 80-08, "BWR Technical Specification Inconsistency - RPS

Response Time"

The circular reported that some GE BWRs have a Technical Specification

maximum allowable reactor protection system (RPS) response time of 100

milliseconds, whereas 50 milliseconds had been used in safety analyses.

The licensee's PGRC review (meeting 80-67) indicated that the condition

was applicable to reach Bottom. The inspector reviewed Technical Speci-

fication Amendments 76 (Unit 2) and 75 (Unit 3). These amendments re-

vised the allowable RPS response time to a maximum of 50 milliseconds.

Licensee review indicated that actual response times had been less than

50 milliseconds in the past.

The inspector reviewed a sampling of these

tests.

No unacceptable conditions were identified.

b.

IE Circular 78-17, " Inadequate Guard Training / Qualification"

This circular reported examples of inadequate guard training or qualifi-

cation and of falsified records. Licensee reviews and audits identified

no similar problems. The inspector has not identified unacceptable con-

ditions in this area.

PORC review and closure of this circular was ver-

ified (PORC meeting #80-002).

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5.

Review of Licensee Event Reports (LER's)

The inspector reviewed one LER submitted to E. NRC:RI office to verify that

the details of the event were clearly reported, including the accuracy of

the description of cause and adequacy of corrective action. The inspector

determined whether further information was required from the licensee, whether

generic implications were indicated, and whether continued operation of the

facility was conducted in accordance with Technical Specifications. Report

accuracy, compliance with current reporting requirements and applicability

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to other sit? systems and components were also reviewed. The following LER

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was reviewed:

LER No.

LER Date

Event Date

Subject

3-81-14/IP September 29, 1981 September 28, 1981 Ptessurization of the

reactor vessel by non-

nuclear means with

suppression pool water

above maximum permissi-

ble volume

-- LER 3-81-14/1P

On September 28, 1981, the licensee inadvertently pressurized the Unit 3

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reactor vessel with temperatures below 1200F, the minimum allowable temper-

ature for pressurization.

Event Description: About 6:45 p.m. , September 28, a control operator made

preparations to change the position of the mode selector switch from refuel

to shutdown. The control rom (CRD) hydraulic system was operating, which

added water to the reactor vessel (about 150 g(.p.m.) and the Reactor Water

Cleanup (RWCU) system was operating to remove letdown) water (about 150

g.p.m.).

As a part of the preparat1on, the Unit 3 operatar turned the CRD

system off to prevent a hydraulic shock to the control rod drive assemblies.

(An automatic scram occurs when the mode switch is placed in shutdown.)

The operator did not reduce the amount of letdown on RWCU. To maintain

reactor vessel water level, the operator used the condensate and feedwater

systems which were operating in preparation for a plant startup. When the

desired level was achieved, the feed system injection valve was shut, but

due to seat leakage past the valve, reactor water level continued to increase.,

To maintain level, water from the reactor was drained to the suppression pool.

Reactor vessel level continued to increase, and on two occasions rose above

the main steam line penetration, whici isolated the reactor vent path.

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reactor was being vented via the main steam lines to the condenser and the

reactor head vent valves were closed.) The reactor pressurized when the vent

paths were isolated. The first time, the maxinum pressure was 32 pounds per

square inch (psi) and the second, the maximum pressure was 78 psi. When

pressure reached 78 psi, operators vented the reactor via the head vents and

restored water level to below the main steam line penetrations.

Initial

reactor water temperature was 1380F and decreased to 1100F during the event.

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Causative Factors

The inspector reviewed operating procedures, Unit 3 operating logs, control

room charts, held discussions with operators and supervisory personnel, and

determined that the following problems contributed to the event.

During discussions with licensed operators on shift and the Engineer Opera-

tions, the inspector determined that no specific operating limits regarding

minimum temperature had been provided. The operators involved were not aware

of the specific temperature limit for pressurizing the reactor vessel. When

asked what the allowable temperature was, they referred to a curve in the

Technical Specifications being used in the control room titled, "Philadel-

phia Electric Co., Peach Bottom II and III Minimum Pressurization Tempera-

ture." This curve identified 100 F as the minimun allowable temperature

when pressurizing the reactor vessel. There was no revision or page number

on the sheet, and the figure (3.6.A.2) was not listed as an effective figure.

(The licensee immediately removed this figure from the Technical Specifica-

tions when shown by the inspector). The correct curve, figure 3.6.2., page

164a, identified 120*F as the minimur. sllowable temperature for pressuriza-

tion.

During discussions with operators involved, they stated they had not

recognized the fact that pressure in the reactor vessel had increased above

0 psi until 10:17 p.m., whicn was the time of the second peak. They also

stated that they had been preoccupied with maintaining water level and

keeping the condensate system operating.

Findinc;s

The reactor was pressurized at a temperature below the temperature allowed

in the Technical Specifications curves on page 164 and 164a.

Inspector

review identified that no procedures governing plant operation in the cold

shutdown condition or refuel condition existed.

Facility procedure GP3,

which governs plant shutdown and cooldown, addresses conditior:s to the con-

clusion of cooldown or filling the reactor vessel for refueling.

10 CFR 50 Appendix B requires that activities affecting quality be governed by docu-

mented instructions or procedures.

The failure to have adequate procedural

control governing plant operations, including those conditions under which

the reactor vessel can be pressurized when in cold shutdown or refuel mode

of operations, is a violation (81-22-07

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During the time when the reactor was pressurized above zero psi, torus

Water level was above the maximum allowable volume. The purpase of main-

taining the voluine within a specific range is to ensure that adequate

volume exists to prevent over-pressurization of the primary containment.

The primary system was at a temperature significantly less than 212*F.

Based on existing temperature, the safety significance is considered mini-

mal.

Regarding operation of the reactor water cleanup (RWCU) system and conden-

sate system (CS) during this event, the inspector expressed concern to

station management that the event could have oeen pre u v ed by reducing

the letdown from the RWCU or securing the condensate system (stopping the

running condensate pump).

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6.

Surveillanc-

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The inspector observed portions of selected surveillar.e tests to verify that

testing had beer, properly approved by shift supervision, control room operators

were knowledgeable regarding testing in progress, approved procedures were being

used, redundant systems or components were available for service as required,

test instrumentation was within its required calibration period, work was per-

fermed by qualified personnel, and test acceptance criteria were met. Portions

of the following tests were observed:

-- ST 6.5, "HPCI Pump, Valve, Flow, Cooler," revision 25, dated June 2,1981,

performed September 23, 1981, following system maintenance; and

-- ST 6.8.1, " Daily RHP. ' A' System and Unit Cooler Operability," revision 11,

dated January 5,1981, performed September 23, 1981, due to 'E-4' diesel

inoperability.

Additionally, for ST 6.5, the inspector aserved portions of system lineup

for testing and r< coration after testing. The inspector indOendently

observed important carameters during the tests and reviewed test data for

accuracy and co9leteness.

One portion of the test requires throttling of

the HPCI pump discharge to establish and record pump parameters for inservice

inspection (ISI) requirements. When first performed, this portion yielded

unacceptable results--licensee personnel identified this, and repeated that

portion of the test, achieving acceptable results by more precisely throttling

the pump discharge.

The inspector reviewed ST 3.3.2.A, " Calibration of APRM System for Single

Loop," revision 0, dated May 27, 1981, to verify that Technical Specification

requirements for single loop operation were properly implemented. Although

the existing procedure meets the requirements, the following comments were

provided to the licensee:

-- The graph of drive flow versus total flow is hard to read and includes a

much wider range of flows than required for the test; and

-- Test calculations appear to present the potential of a scram being set

at exactly the Technical Specification limit, whereas licensee procedures

usually incorporate a margin for setpoint and instrument drift.

The inspector reviewed completed test ST 7.1.1, " Standby Liquid Control Tank

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Baron Solution Concentration," revision 8, dated January 3,1980, performed

after water was added to the poison tank on September 21, 1981. The inspector

verified that test data was complete and in conformance with Technical Speci-

fication requirements. The inspector also verified that the procedure was

properly approved and, as written, satisfies the Technical Specification

surveillance requirement.

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7.

Radiation Protection

During this i port period, the inspector examined work in progress in

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accessible areas of the Unit 2 and Unit 3 facilities. Areas examined

included:

a.

Health Physics (HP) controls

b.

Badging

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Usage of protective clothing

d.

Personnel adherence to RWP requirements-

e.

Surveys

f.

Handling of potentially contaminated equipment and materials

Additionally, inspections were conducted of usage of friskers and portal

monitors by personnel exiting various RWP areas, the power block, and_the

licensee's final exit point. More than 30 people were observed to meet

frisking requirer _ats of Health Physics procedures during the month. A

sampling of high radiation doors was verified to be locked as required.

No unacceptable conditions were identified.

8.

Physical Security

The inspector spot-checked compliance with .the accepted Security Plan and .

implementing procedures, . including operations of the CAS and SAS; over 20

spot-checks of vehicles on-site to verify proper control, observation of

protected area access control and badging procedures, inspection of physical

barriers, checks on control of vital area access and escort procedures.

On September 22, the inspector noted a loose core plate on.the North Control

Room door, and immediately informed the security supervisor.- The core plate

could be swung aside, making the locking mechanism visible and more-easily

accessible, but the locking device could not be easily defeated.

Licensee

examination of the door, for which a new locking device had been recently

installed, identified that exit through the door would not be possible in

event of a security computer outage. The licensee stationed a guard on the

door, until corrective maintenance could be accomplished. The inspector

'erified, on September 23, that the door had been repaired. No items of

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noncompliance were identified.

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9.

Review of TMI Actior Plan (TAP) Requirements

The inspector reviewed the sta'.us of licensee action of the following TAP

requirements to verify that the licensee is meeting his NRC commitments.

a.

TAP Item I.A.2.1.4 - Modify SR0 and R0 Training

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Licensees were to modify SR0 and R0 training programs in accordance with

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NRR letter dated March 28, 1980. Licensees were to submit programs to

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NRR:0LB for review. The inspector verified that the program had been

submitted, and reviewed actual training to verify that it was conducted

as described in the program.

Licensed operator training has been modified to provide:

basic instruc-

tion in heat transfer, fluid flow, and thermodynamics; training in the

use of installed plant systems to control or mitigate an accident in which

the core is severely damaged; and increased emphasis on reactor and plant

transients. Additionally, the program provides for three months training

on-shift as an extra person in the control room. The inspector reviewed

records for the most recent class of operator trainees and discussed train-

ing with recently licensed operators. No unacceptable conditions were

identified.

The inspector reviewed the course schedule for a class beginning Septem-

ber 14, 1981. The inspector noted that the three months on-shift time

has been integrated into the classroom schedule, rather than being

performed as a block. The licensee believes this will enhance both

practical experience and exam performance.

In reviewing the course

schedule, the inspector was unable to determine whether basic heat

transfer and mitigation of core damage would be covered to the depth

indicated in the licensee's program description to NRR. A licensee

representative stated that the program description would be satisfied;

the inspector will review this item in a later inspection (81-20-01 and

81-22-02).

b.

TAP Item II.B.4 - Training for Mitigating Core Damage

Licensees are required to develop and implement a training program to

teach the use of installed equipment and systems to control or mitigate

accidents in which the core is severely damaged.

Based on a NRR letter dated March 28, 1980, the licensee provided this

training to all licensed operators in October 1980. The inspector reviewed

attendance records and also reviewed the instructor's lesson plan to verify

that criteria of the NRR letter were met.

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NUREG-0737 clarified this requirement, stating that STAS and operating

personnel shall receive all training listed in the NRR letter, while

managers and technicians in the Instrument and Controls (I&C), Health

Physics (HP), and chemistry departments shall receive training commen-

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surate with their responsibilities.

Based on the clarification of NUREG-0737, an additional two-day training

session was developed by individuals who had attended a vendor training

course. The cession is being given in August and September 1981. Re-

quired attendees include all licensed operators and senior licensed

a tant Station Superintendent, Oper-

operators (which ircludes the As

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ations Engineer, ' 'chnical Engineer, Results Engineer, and I&C Engi.ieer),

the Station Superintendent, Radiation Protection Manager, and the

Maintenance Engineer. The inspector reviewed both the course outline

and course harJouts and verified that items required by the NRR letter

were covereo in detail. The licensee stated that no additional tech-

nician training is warranted at this time, but further training may be

necessary following post-accident sampling modifications. No items of

noncompliance were identified.

10. Requalification Training

The inspector reviewed aspects of requalification training to verify that

NRC requirements are being met and that the program has been revised in

response to the TMI Action Plan (ir.corporating an NRR letter, " Qualification

of Reactor Operators," dated March 28,1980).

The inspector verified that a revised program description has been submitted

to NRR. Although the licensee is conducting his training in accordance with

the revised program, no revision to the implementing p ocedcre, A-50, " Train-

ing Procedure," has been distributed. A licensee representative stated that

issuance of the procedure revision had been delayed due. to axtensive internal

review and comment on proposed revisions.

The inspector will review the

revised procedure after distribution (81-20-02 and 81-22-03).

The inspector reviewed the requalification training program and lecture

schedule to verify incorporation of required training in heat transfer,

fluid flow and thermodynamics. Lesson plans, records of lecture attendance,

and quiz results were also spot-checked.

No unacceptable conditions wers

identified.

The NRR letter required licensees to revise the criteria for participation

in accelerated requalification to be consistent with the new passing grade

for written exams (80% overall and 70% each category). The licensee's

program description requires those scoring less than the above grades on

annual written exams to be placed in an accelerated review program. Written

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re-evaluations are to be made following the review program until satisfactory

performance is demonstrated. The inspector reviewed the results of the 1980

written examination and determined that one individual had scored less than

70% on the " Safety and Emergency Systems" section. The individual, an engineer

(senior licensed operator), is not currently performing any duties at Peach

Bottom. The inspector was shown a memorandum from the Station Superintendent

dated March 3,1981 stating that the individual should not perform licensed

duties until he had successfully been reexamined in the weak area. The

individual completed some additional study but had not completed a review

program or been reexamined. The individual relinquished his license in

September 1981. The inspector had no further questions on this matter.

The program requires operators scoring less than 80% in a section of the annual

exam to participate in requalification lectures in that section. Within a

sampling of about twenty cases, the inspector identified one discrepancy. One

required attendee had not participated in a " Radiation Control and Safety"

lecture given during March and April, 1981. The' licensee indicated that the

training would be provided. This. matter is unresolved, ~ pending further licen-

see action (81-20-03 and 81-22-04).

For those whose attendance at a leacture

is mandatory, additional training is required if a grade of less than 80% is

achieved on the quiz at the conclusion of the session. The inspector verified,

on a sampling basis, that additionai training is provided when required.

Licensees were required to revise requalification programs to include control

manipulations listed in an enclosure to the 3RR letter. The inspector reviewed

the manipulations listed in the licensee's program description and determined

that the NRC requirements are met or exceeded. The licensee conducts simulator

training at the Limerick Training Center to accomplish the manipulations. The

inspector identified two discrepancies between the " Simulator Requalification

Reactivity and Control Manipulations Record Sheet" and the program description:

-- Plant shutdown is listed as an annual manipulation in the program descrip-

tion, but a biennial manipulation on the record sheet.

(Note: Records

reviewed indicated that operators were completing both the annual and bi-

ennial requirements during 1981 simulator training.)

-- Loss of instrument air is listed in the program ues 'iption, but cannot be

simulated at the Limerick Training Center and therefore is not on the

record sheet.

This matter is unresolved pending clarification by the licensee (80-20-04

and 80-22-05).

The inspector reviewed a sampling of records of annual oral examinations,

facility certification boards, simulator training, and on-shift training.

No unacceptable conditions were identified.

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11.

Emergency Preparedness _

The inspector discussed, with licensee representatives, their progress toward

reeting NRC requirements for prompt notifications and instructions to the

public in the event of an emergency.

On April 28, 1981, the licensee sent

a letter to NRC:NRR detailing implementation difficulties and requesting an

extension until July, 1982, for installation of a siren alert system in the

10-mile emergency planning zone. On September 4, 1981, a licensee represen-

tative stated that a contract for the sirens had been awarded and the licen-

see intended to make every effort to have the system operational by February,

1982. Prior tc awarding a contract, the licensee accomplished the following:

a.

A site-specific survey was completed and evaluated; the required numbers,

sizes, and locations of sirens were revised.

b.

A test program, involving installation and testing of two sirens, was

completed. Based on audibility and public acceptance data from the

tests, the preliminary design was re-evaluated,

c.

Specifications were prepared and reviewed with county emergency management

personnel to ensure compatibility with county equipment. The design in-

cludes .cout 70 sirens placed in five counties,

d.

Vendor bids were requested, received, and evaluated.

During this inspection period, the licensee completed detailed preparation

for siren installation, including training of installation and maintenance

crews. The inspector noted on September 30, that over a dozen sirens had

been received on-site and were being prepared for installation. The.inspec-

tor will continue to follow licensee progress in this area (80-20-05 and 80-

22 06 ).

12.

In-Office Review of Monthly Operating Reports

The following licensee reports have been reviewed in-office onsite. Peach

Bottom Atomic Power Station Monthly Operating Report for:

August 1981 dated September 11, 1981

This report was reviewed pursuant to Technical Specifications and verified

to determine that operating statistics had been accurately reported and

that narrative summaries of the month's operating experience were contained

therein. The inspector noted that the scheduled date for the next Unit 2

refueling outage had been changed from January 1, 1982 to February 20, 1982.

Station management indicated that relief from various TMI Action Plan items

with January 1, 1982 implementation dates would be formally requested to

allow rescheduling of tFe outage.

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13. Unresolved Items

Unresolved items are items about which more information is required to

,.

ascertain whether they are acceptable items, items of noncompliance, or

deviations. Unresolved items are- discussed in paragraph 10.

14. Management Meetings

a.

Preliminary Inspection Findings

A summary of preliminary findings was provided to the Station Superin-

tendent at the conclusion of the inspection.

During the period of this

inspection, licensee management was periodically notified of the prelim-

inary findings by the resident inspectors. The dates involved, the senior

licensee representative contacted, and subjects discussed were as follows:

Senior Licensee

Date

Subject

Representative Present

September 11

Routine Discussions

Station Superintendent

September 16

Routine Discussion

Assistant Station Superintendent

September 25

Routine Discussion

Assistant Station Superintendent

September 30

LER 3-81-14/IP

Station Superintendent

October 1

Requalification Training

Administrative Engineer

October 2

Routine Discussions

Assistant Station Superintendent

October 13

Summary of Findings

Station Superintendent

b.

Attendance at Management Meetings Conducted by Region-Based Inspectors

The resident inspectors attended entrance and exit interviews by region-

based inspectors as follows:

Inspection

Reporting

Date

Subject

Report No.

Inspector

September 7 (Exit)

Integrated Leak

277/81-21

W. Rekito

Rate Testing

October 5 (Entrance) Quality Assurance 277/81-23

G. Napuda

Review

278/81-25

o