ML20111D161
| ML20111D161 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/08/1985 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8503180104 | |
| Download: ML20111D161 (3) | |
Text
c-o PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (215) 84f 5008 SHIELDS L. DALTnopy ELtcfm c Pn c sose March 8, 1985 Docket Nos. 50-277 50-278 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory' Commission Region I G31 Park Avenuc King of Prussia, PA 19406
Dear Mr. Martin:
Your letter of Pcbruary 6, 1985, forwarded combined Inspection Report 50-277/84-33 and 50-278/84-27.
Appendix A of s
in your report addresses one item which does not appear to be full compliance with Nuclear Regulatory Commission requirements.
This item is restated below along with our response:
r Technical Specification 6.8 requires implementing the recommendations of ANSI N18.7.
Section 5.3 of ANSI N18.7 (1972) requires procedures for implementing the cmcrgency plan actions.
Administrative Procedure A-21, Revision 5, April 20, 1981, Generation of Emergency Plan Procedures, requires procedures to include necessary action levels.
Contrary to the above, from about October 12, 1984, to about 5:00 p.m. October 16, 1984, Emergency Plan Impicmenting Procedure EP-101, Revision 9, dated October 12, 1984, Classification of Emergencies, was inadequate in that the procedure specified emergency action levels for the reactor building ventilation and main stack radiation monitors that were in three instances above full scale for the instruments, and the emergency action 1cycis for the ventilation stack high range radiation monitor were apparently incorrect, as the value specified for an Alert was below the normal background reading.
Also, procedure EP-101, Revision 8, effective from January 10 to October 12, 1984, contained one instance where a specified action level for the reactor 8503180104 850308
r Mr.. Tho, mas T. Mar tin Page 2 building ventilation stack was above full scale for the instrument.
This is a severity Level IV Violation (Supplement I).
Response
This violation was caused by procedural deficiencies in EP-101, " Classification of Emergencies."
EP-101, Revision 9, specified the following Emergency Action Levels (EAL's) for the associated radiation monitoring instruments:
Action Level Instrument EAL (cpm)
Site Emerg.
Rx Bldg Vent. (Norm. Range) 2.5P6 or Rx Bldg Vent. (Hi Range) 1.5P8
-General Emerg.
Rx Bldg Vent. (Norm. Range) 2.5P7 or Rx Bldg Vent. (Hi Range) 1.5P9 The radiation monitoring instruments are capable of indicating the EAL's specified above.
The process radiation signals for the normal range instruments are digitally displayed and an analog signal is then generated to drive the associated recorder.
Operation of a range selector switch is required to change the recorder range, but the switch operation has no ef fect on the digital display.
The digital display will continue to indicate increasing radiation levels regardless of a full scale indication on the recorder.
Proceduro EP-101 was inadequate because use of the digital indication was not specifically stated in the procedure, and because a range switch change to record the indication was not procedurally addressed.
The Alcrt EAL specified in Revision 9 of EP-101 for a reactor building ventilation release was 1.5P7 counts per minute (cpm) on the High Range monitor.
The bottom of scale of this instrument is 1.0P7 cpm, but because this instrument would be downscale during normal conditions, a light source is used to create a live zero.
The device causes an instrument reading on scale at approximately 1P8 cpm.
Because of an oversight, the artifical elevated "zero" was not considered when the Alert EAL was revised and incorporated into EP-101.
The normal range instrument EAL that procedurally accompanied the High Range instrument EAL in Revision 9 of EP-101 would have prompted operators to enter an Alert.
In addition, a calculated value which was i
m
/
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gir. Thomas. T. Martin Page 3 outside the normal. instrument range was incorporated into EP-101, Revision - 8 and 9 for the Main Stack General EAL.
However, the procedure also included an EAL for the IIigh Range monitor which was within the instrument range and would have prompted escalation into a General Emergency.
When informed of the procedure problem by the NRC inspector, a temporary procedure change was immediately initiated to correct the inadequacies. 'On November 6, 1984, Procedure EP-101 was revised (Revision 10) to reduce the !!ain Stack and Reactor Building ventilation General and Site EAL's to values which can be observed on the normal range recorders without operating the range celector switches.
As a result, all references to the high range monitors, except for the !!ain Stack General EAL, were no longer required and were deleted from the procedure.
These corrective actions resolved the deficiencies identified by your inspection.
We are continuing our review of the EAL values.to determine their practicality
-and we expect future revision with the establishment of new EAL's.
Should you require additional information, please do not hesitate-to contact us.
Very truly yours, f?{}7, 21 cc:
T.
P. Johnson, Site Inspector m