ML20054L545
| ML20054L545 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/24/1982 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20054L538 | List: |
| References | |
| NUDOCS 8207080227 | |
| Download: ML20054L545 (7) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. DALTROFF stacin c em c tom June 24, 1982 Docket Nos. 50-277 50-278 Insp. Rep. 50-277/82-09 50-278/82-09 i
Mr. Richard W.
Starostecki, Director U.
S.
Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Starostecki :
Your letter of May 24, 1982 forwarded combined inspection report 50-277/82-09 and 50-278/82-09.
Appendix A addresses several items which do not appear to be in full compliance with Nuclear Regulatory Commission requirements.
These items are restated below along with our response.
NONCOMPLIANCE I
10CFR50 Appendix B Criterion V requires that instructions and procedures be appropriate to the circumstances.
10CFR50 Appendix B Criterion III requires that the design basis be translated into procedures and instructions.
FSAR Section 5.2.2 lists ability to withstand the maximum credible earthquake as a design basis of the Primary Containment.
Contrary to the above, procedures for inspection of seismically qualified air supplies to Primary Containment Isolation Valves in the Containment Atmosphere Control System were not appropriate :
no checks of seismic support of the supply bottle were required routinely, or following bottle replacement which disturbs the bottle's seismic restraint, and on April 28, 1982, the air supply bottle for 8207080227 820701 PDR ADOCK 05000277 o
Mr. Richard W.
Starostecki, Director Page 2 Torus Exhaust to Standby Gas Treatment Valve AO-3511 was not seismically restrained.
This is a Severity Level V Violation (Supplement 1) applicable to DPR-44.
RE SPON SE As stated in the inspection report, when informed of the deficiency, the seismic restraint on the backup air supply bottle was secured.
A review of the surveillance tests l
which checks the pressure in the backup air supply bottles on a daily basis was conducted.
These tests revealed that the bottle was being changed out more frequently than is usually required.
The usage was due to a small leak in the tubing leading from the bottle to the normal air supply.
The tubing was replaced.
The bottle which was in place on April 28, 1982, when the inspector noted the deficiency had been changed out on April 23, 1982.
It is therefore concluded that the seismic restraint was detached for l
approximately five days.
The surveillance test ST 7.9.2 Daily Check of Containment 4
Isolation Valve and ADS Backup N2 Bottle Pressure has been revised.
The procedure verifies the integrity of the system and now includes a visual inspection of the seismic bottle restraint.
This revision should prevent recurrences of this type.
NONCOMPLIANCE Technical Specification 6.8, Procedures, and Regulatory i
Guide 1.33 (November, 1972) require implementation of procedures for refueling equipment operation.
Procedure PH-GC, Revision 11, March 8, 1982, Fuel Movement and Core Alteration Procedure During a Fuel Handling Outage, is applicable during refueling outages and for all core components and requires that an individual holding a Senior Reactor Operator's license direct and supervise all operators assigned to the fuel floor.
Contrary to the above, about 3:00 p.m.,
April 29, 1982, during a refueling outage, the senior licensed operator assigned to the fuel floor was not supervising an operator manipulating the refuel bridge auxiliary hoist, an activity that resulted in unplanned lifting of a control rod and unnecessary radiation exposure to four persons :
the senior licensed operator had left the refuel bridge and was removing his protective clothing in order to leave the fuel floor.
J
Mr. Richard W.
Starostecki, Director Page 3 This is a Severity Level IV Violation (Supplement I) applicable to DPR-44.
RE SPONSE Personnel error caused this occurrence.
On April 29, 1982 a Hafnium (HF) test blade was to be relocated from the fuel prep machine to a control rod blade storage rack within the fuel pool.
The control rod blades upper handle assembly and velocity limiter had been cut of f by General Electric Company personnel so that the poison pins could be removed and sent to General Electric for hot cell examination.
This alteration made the control blade about 2 feet shorter than normal and included installation of a temporary handle on the HP test blade.
Using a pneumatically operated
'J' hook attached to the refuel bridge frame mounted hoist, the refuel bridge operator moved the HP test blade to the designated storage rack location.
The senior licensed operator and fuel accounting technician completed the required paperwork.
The hoist operator released the HF blade and began raising the hoist to put it in its normal storage location at the refuel bridge floor elevation.
At this time the senior licensed operator began making preparations to leave the fuel floor.
He began removing anticontamination clothing since no additional moves were scheduled.
As the open
'J' hook was being raised, it swung to an adjacent storage location and engaged a normal blade handle.
The hoist operator was experiencing dif ficulty with the overhead takeup reel for the air lines and failed to recognize that the
'J' hook had engaged another blade handle and was lifting it upward.
The hoists gear driven safety limit switch properly stopped the upward movement of the hook approximately ten feet under water.
The operator, believing the hook to be empty and failing to visually check the hook, pressed the override button to raise the hook out of the water to its storage position.
As the hook neared the surface of the water, the area radiation monitors began alarming and the control blade was quickly lowered to about eight feet below the pool surface.
The area radiation monitors cleared shortly af ter the lowering began.
The control blade and
'J' hook were inspected using binoculars and the blade was then carefully replaced into the storage rack.
Exposure to four individuals on the refuel floor prior to and during the period ranged from 17 to 142 millitems.
Instructions were given to the operator on the proper operation of the refueling bridge equipment.
Both the senior licensed operator and the operator were disciplined.
The importance of paying strict attention during all aspects of refueling bridge operation was emphasized.
Although this
Mr. Richard W.
Starostecki, Director Page 4 particular incident was a unique operation, procedures have been revised to provide additional conservatism during future refueling bridge operations.
The procedures now require the use of a mechanical clamp which limits the upward travel of the hoist so that a grapple or tool remains at least seven feet under water during repetitive operaticns.
In addition, verbal instructions have been issued to Health Physics personnel regarding the need to survey during removal of any components from the fuel pool or reactor head cavity.
This requirement will be formalized via procedure by August 31, 1982.
Additionally, signs will be posted in the spent fuel and reactor cavity areas which address survey requirements when removing components.
NONCOMPLIANCE Technical Specification 6.11, Radiation Protection Program, requires adherence to radiation protection procedures.
Procedure HPO/CO-100, Revision 12, January 25, 1982, Health Physics Guides Used in the Control of Exposure to Radioactive Material, requires posting of areas with removable surface contamination above 1000 disintegrations per minute per 100 square centimeters with " Contaminated Area" signs or a radiation tape barrier line.
Contrary to the above, about 10:30 a.m.,
May 5, 1982, an area long the western border of the North Accumulator Aisle in the Unit 2 Reactor Building had removable surface contamination of 4000 disintegrations per minute per 100 square centimeters and was not posted with
" Contaminated Area" signs or a radiation tape barrier line.
Contrary to the above, about 2 p.m.,
May 10, 1982, an area near the control rod drive access hatch in the Unit 2 Reactor Building had removable contamination of 15,000 disintegrations per minute per 100 square centimeters and was not posted with " Contaminated Area" signs or a radiation tape barrier line.
This is a Severity Level IV Violation (Supplement IV) applicable to DPR-44.
RE SPON SE Considerable personnel activity and equipment usage on this elevation of the reactor building during the refueling outage contributed to this violation.
As stated in the inspection report, when notified of the contamination, the areas were properly posted.
Decontamination was begun to lower the level of contamination.
This effort resulted in a reduction in size of the controlled areas.
Health Physics t
Mr. Fdchard W.
Starostecki, Director Page 5 technicians were instructed to increase the frequency of these surveys to twice per shift in areas adjacent to controlled areas and to ensure proper posting.
These surveys will be continued until personnel activity decreases.
A control point operating procedure will be developed which will address the actions to be.taken by,the technicians assigned to control points during high personnel activity.
The procedure will be written and approved by September 30, 1982.
NONCOMPLIANCE Technical Specification 6.8, Procedures, and Regulatory Guide 1.33 (November 1972) require implementation of procedures for fire protection systems and. for, general control of maintenance, repair and modification work.
Plant housekeeping Procedure A-30, Fevision 4, May 21, 1981, states that placement of equipment and material shall not l
impede accessibility of fire-fighting equipment, and thst trash and litter shall not be allowed to accumulate and create conditions which will adversely affect quality.
Contrary to the above, about 9 a.m.,
May 5, 1982, in the Unit 2 Reactor Building 135-foot elevation, placement of two welding machines blocked access to fire-fighting equipment station 135-21 and a larger table blocked access to fire-fighting equipment station 135-22.-
Contrary to the above, about 9 a.m.,
May 5, 1982 and 2 p.m.,
May 10, 1982, in the Unit 2 Reactor Building, a fire hazard was created by accumulation of litter of-the following:
plastic boots, plastic and cloth gloves, coveralls, caps, plastic bags, papers, and dirt.
This is a Severity Level IV Violation (Supplement I) applicable to DPR-44.
RE SPON SE Upon notification the fire equipment stations were cleared and cleanup of the littered areas was begun.
The current refueling outage required a significant amount of maintenance work and personnel activity in the area noted in the violation.
Approximately 1400 people enter and exit this area on a daily basis which complicates housekeeping practices.
This number will decrease significantly after the refueling outage.
Following the identification of the above deficiency, shii; supervision's housekeeping inspections were increased from
I Mr. Richard li. Starostecki, Director.
Page 6 the required monthly inspections to a weekly basis.
Health Physics personnel also increased their housekeeping inspections.
All personnel were reinstructed via their supervision of 4
1 their respon~sibility for housekeeping requirements.
l Discussions were held on May 27, 1982 with the Station Superintendent and various group supervisors to determine j
effective methods for control of plant housekeeping as defined.in Administrative Procedure A-30.
As a result of this meeting contractor supervision are inspecting their
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respective work areas on each shift that work is being performed..and will be responsible for assuring cleanliness.
Documentation of this activity is provided to the Contractor Site Management and to Philadelphia Electric Company Site
' Supervi sion.
The Maintenance Division's Safety representative is inspecting on a daily basis, all maintenance work areas.
Documentation of these inspections and the corrective actions taken are provided to maintenance supervision and site supervision.
These inspections will be performed during both outage and non-outage conditions.
The Construction Division ~ committed to similar inspections.
I Philadelphia Electric Company believes that these measures will improve housekeeping and reduce fire hazards at Peach Bottom Atomic Power, Station.
If you have any questions, or require additional information, please don't hesitate to contact us.
Very truly yours, 7
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L. Daltroff, being first duly sworn, deposes and says :'
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That he is Vice President of Philadelphia ElecEric Company, l
the Applicant herein; that'he has read the foregoing resp 5nse to Inspection Report No. 50-277/82-09 & 50-278/82-09 and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best.of his knowledge, i
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Subscribed and sworn to.
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