ML20062D869

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Forwards IE Inspec Rept 50-277/78-26 on 780919-22 & Notice of Violation
ML20062D869
Person / Time
Site: Peach Bottom Constellation icon.png
Issue date: 10/20/1978
From: Brunner E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Daltroff S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20062D862 List:
References
NUDOCS 7812010016
Download: ML20062D869 (2)


See also: IR 05000277/1978026

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UNITED STATES

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NUCLEAR REGULATORY COMMisslON

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431 PARK AVENUE

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KING OF PRUSSI A. PENNSYl.V ANI A 19406

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Docket No. 50-277

2 0 007 1978

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Philadelphia Electric Company

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ATTN: Mr. S. L. Daltroff

Vice President

Electric Production

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2301 Market Street

Philadelphia, Pennsylvania 19101

Gentlemen:

Subject:

Inspection 50-277/78-26

This refers to the inspection conducted by Mr. E. Greenman of this

office on September 19-22, 1978, at Peach Bottom 2, Delta, Pennsylvania,

of activities authorized by NRC License No. DPR-44 and to the discussions

of our findings held by Mr. Kalman with Mr. R. Fleischmann of your staff

at the conclusion of the inspection.

Areas examined during this inspection are described in the Office of

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Inspection and Enforcement Inspection Report which is enclosed with this

letter. Within these areas, the inspection consisted of selective

examinations of procedures and representative records, interviews with

personnel, and observations by the inspector.

Our inspector also verified the steps you have taken to correct the

items of noncompliance brought to your attention in a letter dated June

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30, 1977. We have no further questions regarding your action at this

time.

Based on the results of this inspection, it appears that certain of your

activities were not conducted in full compliance with NRC requirements,

as set forth in the Notice of Violation, enclosed herewith as Appendix

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A.

These items of noncompliance have been categorized into the levels

as described in our correspondence to you dated December 31, 1974. This

notice is sent to you pursuant to the provisions of Section 2.201 of the

NRC's " Rules of Practice," Part 2. Title 10, Code of Pederal Regulations.

Section 2.201 requires you to submit to this office, within twenty (20)

days of your receipt of this notice, a written statement or explanation

in reply including:

(1) corrective steps which have been taken by you

and the results achieved; (2) corrective steps which will be taken to

avoid further items of noncompliance; and (3) the date when full compliance

will be achieved.

7812010016

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Philadelphia Electric Company

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2 0 QCT 1978

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part

2, Title 10, Code of Federal Regulations, a copy of this letter and the

enclosures will be placed in the NRC's Public Document Room.

If this

report contains any information that you (or your contractor) believe to

be proprietary, it is necessary that you make a written application

within 20 days to this office to withhold such information from public

disclosure. Any such application must be accompanied by an affidavit

executed by the owner of the information, wh.'ch identifies the document

or part sought to be withheld, and which contains a statement of reasons

which addresses with specificity the items which will be considered by

the Commission as listed in subparagraph (b) (4) of Section 2.790. The

information sought to be withheld shall be incorporated as far as possible

into a separate part of the affidavit.

If we do not hear from you in

this regard within the specified period, the report will be placed in

the Public Document Room.

Should you have any questions concerning this inspection, we will be

pleased to discuss them with you.

Sincerely,

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.

M

Eldon J.

unner,

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Reacto

perat'o

ad uclear

Support Bran

Enclosures:

1.

Appendix A, Notice of Violation

2.

Office of Inspection and Enforcement Inspection Report

Number 50-277/78-26

cc w/encis:

W. T. Ullrich, Station Superintendent

s

Troy B. Conner, Jr. , Esquire (Without Report)

Eugene J. Bradley, Esquire (Without Report)

Raymond L. Hovis, Esquire (Without Report)

Warren Rich, Esquire (Without Report)

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APPENDIX A

NOTICE OF VIOLATION

Philadelphia Electric Company

Docket No. 50-277

Based on the results of an NRC inspection conducted on September 19-22,

1978, it appears that certain of your activities were not conducted in

full compliance with conditions of your NRC Facility License No. DPR-44,

as indicated below.

Item A is a Deficiency.

Item B is an Infraction.

A.

Technical Specification 6.8.1, states in part that, " Written pro-

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cedures . . . shall be established, implemented and maintained . .

Contrary to the above, two prerefueling procedures, FH 21.2 and FH

5, were performed prior to completion of the prerequisites for

these procedures in that: The individual steps of procedure FH

21.2 were completed by August 31, 1978, while a prerequisite pro-

cedure, M 4.18 was not completed until September 9,1978, and the

individual steps of procedure FH 5 were completed by July 24, 1978,

while a prerequisite procedure, M 17.1, was not completed until

August 22, 1978.

B.

Technical Specification 6.8.1, states in part that, " Written Pro-

cedures...shall be established, implemented and maintained...."

Step 3.d of Procedure FH 6c, " Fuel Movements and Core Alteration

Procedure during a Fuel Handling Outage", Revision 5, dated March

14, 1978, states that the grapple operator must always watch the

fuel bundle during fuel transfer.

Contrary to the above, at approximately 2000 on September 21, 1978,

the grapple operator failed to look at a spent fuel bundle from the

time the bundle approached the upward limit of its travel during

removal from the reactor core until after the first phase of its

horizontal movement was completed.

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U.S. NUCLEAR REGULATORY COMMISSION

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OFFICE OF INSPECTION AND ENFORCEMENT

Region I

Report No. 50-277/78-26

Docket No.

50-277

License No.

OPR-44

Priority

Category

C

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Licensee:

Philadelohia Electric Comoany

2301 Market Street

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Philadelphia, Pennsylvania 19101

Facility Name:

Peach Bottom Atomic Power Station, Unit 2

' spection at: Delta, Pennsylvania

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Inspection conducted:

September 19-22, 1978

Inspectors.

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/o/1/ M

GjfoTge Kapn, Reactor Inspector

date signed

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Edwarc'Greenman, Reactor Inspector

date signed

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date signed

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Approved by:

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D. L. CaEhton, Chief, Nuclear Support

date signed

Section No. 1, RO&NS Branch

Inspection Summary:

Insoection on September 19-22, 1978 (Report No. 50-277/78-26)

Areas Insoected: Routine, unannounced inspection by two NRC regional based

inspectors of preparation for refueling, refueling activities including:

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facility tours and offshift observations of fuel movement; and, independent

effort. The inspection involved 58 inspector-hours onsite by two regional

based inspectors.

Results: Of the five areas inspected, no items of noncompliance were identi-

fied in three areas. Two items of noncompliance were identified in two areas:

(Deficiency - failure to complete procedure prerequisites prior to performing

procedures, paragraph 4.c; and, Infraction - failure to observe fuel bundle

during movement, paragraph 5.c).

7812010031

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Region I Fonn 12

(Rev. April 77)

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DETAILS

1.

Persons Contacted

Principal Licensee Representatives

  • R. Fleischmann, Assistant Station Superintendent

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  • F. Polaski, Reactor Engineer

S. Roberts, Test Results Engineer

D. Smith, Outage Coordinator

J. Spencer, Maintenance Engineer

W. Tilton, Fuel Floor Supervisor

W. Ullrich, Station Superintendent

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J. Winzenreid, Technical Engineer

Other licensee employees and contractor personnel were contacted

during the inspection. These included engineering personnel,

reactor operators, shift supervisors, security personnel, health

physicists and General Electric Technicians.

denotes those present at the exit interview.

2.

Previous Inspection Item Uodate

(Closed)ItemofNoncompliance(277/77-19-03): Unauthorized changes

to procedures / failure to review temporary changes within seven

days.

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a.

The inspector verified that procedure M 4.20 and procedure

21.4 were revised to include a workable sequence of steps and

noted that a statement was included in each procedure cautioning

against unauthorized deviations from the presc-ibed steps.

The inspector had no further questions regarding this matter

at this time,

b.

Cognizant licensee personnel have been briefed on requirements

regarding the review requirements on temporary procedural

changes. Technical Specification 6.8.3.c was changed and now

requires PORC review of temporary changes within 14 days

versus 7 days.

(Amendment 37, dated December 13, 1977). The

inspector had no further questions regarding this matter at

this time.

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(Closed) Item of Noncompliance (277/77-19-04):

Failure' to follow

procedures.

a.

Procedure FH 6C was revised to permit fuel handling prior to

completing the refueling platform check-off sheet at the start

of each shift. An inspection of the refueling related check-

off lists did not detect discrepancies. The inspector had no

further questions regarding this matter at this time.

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3.

Plant Tour

The inspectors examined various areas of the Unit 2 and 3 facilities

including the reactor building, Unit 2 containment process areas,

turbine deck, Unit 2 refueling floor, and exterior areas.

Inspections were conducted to determine the general state of house-

keeping, cleanliness, adherence to fire protection guides and to

observe plant conditions. The inspectors checked equipment status,

operability and verified by comparison of selected control room in-

strumentation that, limiting conditions for operation were being

satisfied at Unit 3, and that nuclear instrumentation indicated

compliance with Technical Specification requirements for refueling

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in progress at Unit 2.

Status of off-normal alarms were discussed

with various operating personnel. Operators were knowledgeable re-

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garding these alarms. The inspectors also verified that minimum

staffing requirements were satisfied, during the course of various

control room tours.

No unacceptable conditions were iden'tified.

4.

Preparation for Refueling

a.

Documents Reviewed

(1) Procedure FH 5, Revision 14, July 19, l'78, New Fuel

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Inspection, Channeling and Placement in the Fuel

Pool, including Associated Check-Off List

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(2) Procedure M 17.1, Revision 3, December 11, 1975, Reactor

Building Cr.ane Maintenance, including Associated

Check-Off List

(3) Procedure M 4.17, Revision 0, October 15, 1975, Fuel Pre-

paration Machine Inspection, including Associated

Check-Off List

(4) Fuel Receipt and Inspection Records for 260 New Fuel

Assemblies

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(5) Procedure FH 21.1.3, Revision 1, April 2,1976, Check-Out

of the Refueling Platform Hoist and Load Cells

(6) Procedure M 4.20, Revision 1 July 28,1977, Refueling

Platform Electrical Inspection, including Associated

Check-Off List

(7) Procedure FH 21.4, Revision 2, August 11, 1977, Fuel

Preparation Machine Operational Check-Out, including

Associated Check-Off List

(8) Procedure FH 21.2, Revision 1, March 23,1978, Check-Out

of the Service Platform and Associated Protective In-

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terlocks, including Associated Check-Off List

(9) Procedure M 4.18, Revision 0, October 15, 1975, Service

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Platform Mechanical Inspection, including Associated

Check-Off List

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(10) Procedure M 4.19, Revision 1, Service Platform Electrical

Inspection, including Associated Check-Off List

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(11) Procedure FH 21.1.1, Revision 0, October 23, 1975, Start-Up

of the Refueling Platform, including Associated Check-Off

List

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(12) Procedure FH 21.1.2, Revision 1, April 2,1976, Check-Out

of Refueling Platform. Bridge, Trolley, Monorail and

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Hoists in the Fuel Fool, including Associated Check-Off

List

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(13) Procedure FH 21.1.6, Revision 1, April 2,1976, Check-Out

of the Air Compressor, Air Lines and Solenoid Valves,

including Associated Check-Off List

(14) Procedure FH 21.1.7, Revision 1, April 2,1976, Check-Out

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of Refueling Platform Bridge, Trolley, Monorail and

Hoists in the Reactor Cavity, including Associated Check-

Off List

b.

Scope

The inspectors reviewed the receipt and inspection records as-

sociated with 260 new fuel assemblies. Refueling equipment,

check-out procedures and associated check-off lists were also

reviewed.

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c.

Findings

No discrepancies were noted in the new fuel receipt and in-

spection documents.

Through review of the maintenance request

forms and check-off sheets, the inspector noted that procedure

FH 21.2 Check-Out of the Service Platform and Associated

Protective Interlocks, was completed prior to the completion

of its prerequisite section.

Specifically, as a prerequisite

to performing procedure FH 21.2, procedures M 4.18, Service

Platfom Mechanical Inspection, and M 4.19, Service Platform

Electrical Inspection must be completed.

Examination of the

completed check-off sheet for procedure FH 21.2 indicated that

the prerequisite section had not been signed off as required

and subsequent investigation revealed that procedure M 4.18

was completed after procedure FH 21.2

A similar circumstance was found for the check-off sheet as-

sociated with procedure FH 5, New Fuel Inspection, Channeling,

and Placement in the Fuel Pool.

In this case, the Maintenance

Request Form for prerequisite procedure M 17.1, Reactor Building

Crane Maintenance, was not signed off until after FH 5 was com-

pleted. Howe'.er, it was ascertained that the crane procedure

was satisfactorily completed prior to handling new fuel. Failure

to complete procedure prerequisites is contrary to Technical Speci-

fication 6.8.1 and constitutes an item of noncompliance (78-26-01).

5.

Refueling Activities

a.

Documents Reviewed

(1) Procedure FH 6C, Revision 5, March 14,1978 Fuel Movement

and Core Alteration Procedure During a Fuel Handling

Outage

(2) Refueling Floor Log Book

b.

Scope

The refueling procedure was reviewed for compliance to Technical

Specification requirements. Refueling activities including

LPRM removal and spent fuel transfer were observed. Refueling

floor and control room manning, fuel status keeping, and control

room to refueling floor communications were compared to applicable

requirements. General refueling floor housekeeping and radiation

protection practices were inspected.

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c.

Findings

Items inspected were acceptable with the excepti n of the

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following item of noncompliance.

Item 3.d _ under the pre-

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caution section of procedure FH 6C states that the grapple

operator must watch the fuel bundle when the fuel bundle is

approaching the upper grid or the top of a fuel storage rack.

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The inspector noted that during the removal of a spent fuel

bundle from the core, the grapple operator did not once

observe the fuel bundle as required by procedures from the.

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time the fuel bundle _was several feet from the top.of its

vertical travel until after he had moved'the bundle several

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feet horizontally. At this time, fuel handling operations

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were suspended by the Senior Licensed Operator (SLO) and the

inspector reviewed the procedure with the two SL0s on the

refueling floor.

The' SLO on duty reviewed the applicable

procedural requirements with the grapple operator and fuel

handling operations were resumed.

The above instance of

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failure to follow procedures is contrary to Technical Specification.

6.8.1 and constitutes an item of noncompliance (78-26-02).

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6.

Outage Related Maintenance Activities

a.

Documents Reviewed

(1) Procedure M 1.6, Revision 2, May 15, 1978, Relief Valve

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Replacement

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(2) Procedure M 12.21, Revision 1, September 21, 1978, R.W.C.U.

System Chemical Cleaning Connection Removal ,

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(3) Modification Procedure 218, March 27, 1978

b.

Scope

The inspector reviewed the above referenced documents and in-

spected the modifications being done to valves M0 2-10-898, M0

2-10-89C, MO 3-10-89B and M0 3-10-89C in accordance with

modification procedure 21B.

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c.

Findings

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No discrepancies were identified in the inspection of the

above items.

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7.

Exit Interview

At the conclusion of the inspection onsite, the inspectors con-

ducted an exit interview with licensee representatives, identified

by an asterisk in Detail 1.

Items as described in the Details were

discussed. The licensee acknowledged inspection fin.d.ngs.

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