ML20138G279

Insp Repts 50-277/96-06 & 50-278/96-06 on 960707-960907. Violations Noted.Major Areas Inspected:Operations, Surveillance & Maintenance,Engineering & Technical Support & Plant Support

ML20138G279
Person / Time
Site:	Peach Bottom
Issue date:	09/07/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138G258	List: ML20138G253 ML20138G261 ML20138G279
References
50-277-96-06, 50-277-96-6, 50-278-96-06, 50-278-96-6, NUDOCS 9610210100
Download: ML20138G279 (32)

See also: IR 05000277/1996006

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket / Report No.

50-277/96-06

License Nos. DPR-44

50-278/96-06

DPR-56

Licensee:

PECO Energy Company

P. O. Box 195

Wayne, PA 19087-0195

Facility Name:

Peach Bottom Atomic Power Station Units 2 and 3

Dates:

July 7 - September 7,1996

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Inspectors:

W. L. Schmidt, Senior Resident inspector

F. P. Bonnett, Resident inspector

R. K. Lorson, Resident inspector

R. L. Nimitz, Senior Radiation Specialist, OCS

Approved By:

W. J. Pasciak, Chief

Reactor Projects Branch 4

Division of Reactor Projects

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9610210100 961010

PDR

ADOCK 05000277

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PDR

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EXECUTIVE SUMMARY

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Peach Bottom Atomic Power Station

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Inspection Report 96-06

This integrated inspection report includes aspects of resident and region based inspection

of routine and reactive activities in: operations; surveillance and maintenance; engineering

and technical support; and plant support areas.

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Overall Assurance of Quality:

PECO operated both units safely over the period.

PECO responded well to identify and correct several equipment deficiencies in a timely

manner including mechanical prcblems with the Unit 3 high pressure coolant injection

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(HPCI) system, a Unit 3 safety relief valve (SRV) bellows failure, an electrical problem with

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the Unit 2 drywell sump flow integrator display, and several problems related to an

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electrical storm on August 17.

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Plant Operations:

Routine observations showed that operators conducted normal activities including shift

turnovers and pre-shift briefings well. Operators co7tinued to demonstrate good

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communication skills. Operators responded well to stabilize plant conditions following .

several transient events including: an electrical storm, a dual reactor feedwater pump.

lockup at Unit 2, a Unit 2 battery ground, a Unit 3 off-gas recombiner isolation, and HPCI

system gland seal condenser water leak at Unit 3 Operators took proper actions to enter

technical specification (TS) action statements as required.

Equipment operability, material condition, and housekeeping were acceptable in all cases.

Several minor discrepancies were brought to FECO's attention and were corrected. The

inspecto'rs identified no substantive concerns as a result of these walkdowns.

The inspector did note a performance weakn ass in that the operators did not identify that

the turbocharger air inlet damper was not properly positioned in accordance with system

operating (SO) procedures during the E2 emt rgency diesel generator (EDG) 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run.

PECO took actions to address this weakness

Maintenance and Surveillance:

PECO performed the NRC observed surveillance etivities well. The emergency service

water (ESW) and HPCI system testing verified system operability. Auxiliary operator

attention during the HPCI system identified and allowea correction of steam admission

valve stroke timing problems. The EDG 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> testing met 5 TS surveillanca

requirements (SR). Several issues regarding the E-2 EDG test concem'ac the turbocharger

air inlet damper operation and fuel oil filter operation remain to be reviewed in o future

inspection.

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(EXECUTIVE SUMMARY - CONTINUED)

PECO nuclear maintenance division (NMD) personnel and engineering responded well to the

HPCI steam admission valve stroking issue. Based on observation of the valve stroking

during testing, the inspectors believe that the system would have performed its safety

function, as designed prior to the repair. However, the need to remove the system from

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service to perform the repair could have been precluded had PECO implemented the vendor

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guidance on measuring and trending the pilot chamber pressure.

The inspector reviewed and closed licensee event report (LER) 3-96-002, finding that PECO

implemented thorough corrective actions to address mis-wiring of a residual heat removal

(RHR) room cooler fan, which caused it to rotate in the wrong direction. The safety

significance of this event was low since the wiring problem affected only one of the four

RHR pumps. The RHR pump would have started, but could have been adversely affected

by long term high room temperatures following an design basis accident (DBA). The

inspector considered this PECO identified and corrected violation a Non-Cited Violation,

consistent with Section Vll.B.I of the NRC Enforcement Manual.

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Enaineerina:

PECO performed wellin identifying issues surrounding the operation of the EDG and their

control circuits. However, weak analysis of an issue dealing with the time delay start of an

RHR pump in response to a loss of coolant accident (LOCA) with the associated EDG in

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test caused PECO to miss TS and updated final safety analysis report (UFSAR) compliance

issues. The inspectors found that modification review and subsequent post-installation

testing did not identify the RHR pump time delay issue. Further, previous PECO actions

taken to review the modification, as the result of prior problems with post-modification

testing verification of design function, did not identify this issue. Collectively, the

inspector considered that these issues represented an apparent violation of TS 3.8.1.17,

10 CFR 50.59,10 CFR 50 Appendix B; criterion Ill, " Design Control" and 10 CFR 50

Appendix B, Criterion XVI " Corrective Action." (Apparent Violation 96-06-01)

During the period, the inspectors observed good engineering support to identify and correct

equipment problems including: excellent system manager support to the HPCI steam

admission valve timing problem (See Section M4.2) and excellent support to restore power

to the Unit 2 feed pumps following a loss of power lock-up (See Section 02.2).

Engineering also provided excellent analysis of the effects of the electrical storm (see

Section 02.2).

Members of the NRC staff inspected PECO implementation of the 10 CFR 50.63, alternate

AC (AAC) system including the Conowingo Hydro-Electric Power Station and the station

blackout (SBO) equipment and procedures. Severalissues were identified dealing with the

NRC staff assumptions of how the Conowingo station supplied power to the SBO line and

the hydro-generation system reliability. The staff also questioned the use of wooden utility

pole in the Conowingo switchyard and the lack of instrumentation in the Peach Bottom

control room for monitoring the availability of the SBO line. This item was considered

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unresolved pending review of PECO's answers to the questions posed in the report

(Unresolved item 96-06-02).

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(EXECUTIVE SUMMARY - CONTINUED)

The inspectors completed their review of a previously identified issue where the standby

gas treatment system was operated in a mode not discussed in the UFFAR (Unresolved

item 95-27-02). Operation in this mode led to the inability of the syste.J to be single

failure proof and the inability under these conditions to meet the TS required 0.25 inches

of water negative differential pressure. This constituted an unidentified unreviewed safety

question in accordance with 10 CFR 50.59. The inspector considered this a violation of

10 CFR 50.59 (Violation 96-06-03). However, because of PECO's response to the

unresolved item and the corrective actions taken there is no response required to this

violation and Unresolved item 95-27-02 and Violation 96-06-03 were closed.

Plant Suooort:

PECO Energy, effectively implemented the revised Department of Transportation (DOT) and

NRC radioactive material shipping regulations (effective April 1,1996). The radiological

controls planning and preparation for the Unit 2 outage were considered very good.

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Improvement in management oversight of outdoor radioactive material storage areas and

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vendor dosimetry processing appeared warranted.

PECO's corrective actions for this event were adequate. However, the inspector

considered PECO's pre-job planning for this modification to be weak and noted that one

week elapsed from the initiation of the event until PECO implemented positive measures to

secure the unmonitored release path. This item will be further reviewed during an

upcoming NRC specialist inspection.

The inspector reviewed standby liquid control (SLC) system borated water sampling and

analysis. The inspector considered it a weakness that key shift operations personnel were

unaware of the SLC tank sampling evolution; particularly since the sampling procedure

required air mixing of the tank contents. The inspector noted that if not properly secured,

the air mixing could potentially affect the SLC system operation. The PECO system

manager indicated that the procedure would be reviewed to determine if any addh;onal

guidance was required.

During their continuing review process PECO identified several examples where the UFSAR

did not agree with current radiological material / waste and radiological control practices.

Also, the inspectors identified that the outdoor storage of radioactive materials was not

specifically described within the UFSAR. The specific issues presented no apparent

immediate safety concerns, however, the UFSAR should be updated to reflect current

practices, as appropriate. The review of the above matter relative to 10 CFR 50.59 and

the updating of the UFSAR in accordance with the 10 CFR 50.71(e)is considered an

unresolved item pending NRC evaluation. (Unresolved item 96-06-04).

The inspector closed Violation 95-23-01 - Failure to follow radiological controls in the " Hot

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Shop" and Unresolved item 95-27-01 - Review of 49 CFR Subpart H training requirements.

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TABLE OF CONTENTS

EX EC UTIVE SU M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

TA B L E O F C O NT E N T S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

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SUMM ARY OF PLANT ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

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OPERATIONS

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01

Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

01.1 General Comments

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02

Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . 1

02.1 Routine Pla nt Tours . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

O2.2 Equipment Challenges

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04

Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . 2

04.1 New Fuel Receipt Activities (60705) . . . . . . . . . . . . . . . . . . . . . 2

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MAINTENANCE AND SURVEILLANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

M1

Conduct of Maintenance and Surveillance . . . . . . . . . . . . . . . . . . . . . . 3

Emergency Service Water Flowrate Verification . . . . . . . . . . . . . . . . . . 3

High Pressure Coolant injection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Emergency Dit sel Generator Endurance Testing . . . . . . . . . . . . . . . . . . 3

M4

Maintenance Staff Knowledge and Performance . . . . . . . . . . . . . . . . . . 5

M4.1 Electrical Cable Installation (62707)

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M4.2 High Pressure Coolant injection System Steam Admission Stop

Valve Balance Chamber Pressure Adjustment - Unit 3 . . . . . . . . . 5

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Miscellaneous Maintenance issues

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M8.1 (Closed) Licensee Event Report (LER) 3-96-002, Low Pressure

Coolant injection System Declared Inoperable Due to

inadequate Post-Maintenance Testing . . . . . . . . . . . . . . . . . . . . 6

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ENGINEERING

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Conduct of Engineering

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E1.1

EDG Modification Design issues - Apparent Violation 96-06-01

and Update to Unresolved item 96-04-04

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E2

Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . 10

E2.1

Station Blackout Line Review - Unresolved item 96-06-02 . . . . . 10

E2.2 Improper Control of the Standby Gas Treatment System -

Violation 96-06-03; (Closed) Unresolved item 9 5-27-02 . . . . . . 13

IV

PLANT SUPPORT . . . . . . . . . . . .

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R1

Radiological Protection and Chemistry Controls

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R 1.1 Radioactive Material Shipping - Temporary Instruction

2515/131 - Implementation of the Revised Regulations . . . . . . . 14

R1.2 Unit 2 Refueling Outage Radiological Controls

(Planning and Preparation)

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R1.3 External Exposure Controls - Use of National Voluntary

Laboratory Accreditation Program Accredited Dosimetry . . . . . . 16

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(TABLE OF CONTENTS - CONTINUED)

R2

Radiological Effluent Controls Program Review . . . . . . . . . . . . . . . . , . 18

R2.1 Holes Cut into Turbine Building Exterior Wall - Unit 3 . . . . . . . . 18

R3

Procedures and Documentation in Radiation Protection and Chemistry

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R3.1 Radioactive Material Shipping -Implementation of the Revised

R e g ula tio n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

R4

Staff Knowledge and Performance in Radiation Protection and

C h e m i s t ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

R4.1 Standby Liquid Control Tank Sampling

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Staff Training and Qualification in Radiation Protection and Chernistry . 21

R 5.1 Radioactive Material Shipping - Training of Personnel on the

Revised Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

R7

Quality Assurance in Radiological Protection and Chemistry

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R7.1 Radioactive Waste Processing, Handling, Storage, and

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Shipping (Program Audits)

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Misceila neou s is sue s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

R8.1 Verification of Updated Final Safety Analysis Commitments

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R8.2 Previous Findings

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(Closed) Violation 95-23-01

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(Closed) Unresolved item 9 5 - 2 7 -01 . . . . . . . . . . . . . . . . . . . . . . . . . . 24

S1

Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . 24

S1.1 Control of Safeguards Information . . . . . . . . . . . . . . . . . . . . . . 24

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M AN AG EM ENT M EETI N G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

X1

Exit M eeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

LIST OF ACRONYMS USED

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SUMMARY OF PLANT ACTIVITIES

Unit 2 began the inspection period operating at 70% power and continued end-of-cycle

coastdown operations throughout the period, ending the period operating at 51% power.

Unit 3 began the inspection period operating at 100% power and remained at this power

for essentially the entire period. Throughout the period PECO reduced reactor power for

the following:

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July 16

Power reduced to 72% to perform main condenser waterbox cleaning.

PECO returned the unit to 100% power operation on July 17.

August 2

Power reduced to 70% to transfer the steam jet air ejectors and repair

a steam leak from the packing of the steam isolation valve. PECO

returned the unit to 100% power operation on August 3.

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August 6

Entered OT-106, " Condenser Low Vacuum" and reduced power to

85% in response to an off-gas recombiner isolation. The isolation

occurred while adjusting the 3B steam jet air ejector discharge

pressure. PECO returned the unit to 100% power on August 7.

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August 10

Ref Jced power to 55% to transfer the steam jet air ejectors. PECO

returned the unit to 100% on August 11.

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OPERATIONS

01

Conduct of Operations'

01.1 General Comments (71707)

Routine observations showed that operators conducted normal activities including shift

turnovers and pre-shift briefings well. Operators continued to demonstrate good

communication skills. Operators responded well to stabilize plant conditions following

several transient events including: an electrical storm, a dual reactor feedwater pump

lockup at Unit 2, a Unit 2 battery ground, a Unit 3 off-gas recombiner isolation, and a HPCI

system gland seal condenser water leak at Unit 3.

02

Operational Status of Facilities and Equipment

O2.1 Routine Plant Tours

a.

Scope

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The inspectors used Inspection Procedure 71707 to perform routine tours of the facility

' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardize

reactor inspection report outline. Individual reports are not expected to address all outline

topics.

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and also to walkdown accessible portions of the following engineered safety feature (ESF)

systems:

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HPCI - Units 2 and 3

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safety-related 125/250 VDC batteries - Unit 2

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RHR - Unit 2

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high pressure service water (HPSW)- Units 2 and 3

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ESW- Units 2 and 3

EDGs - Units 2 and 3

Equipment operability, material condition, and housekeeping were acceptable in all cases.

Several minor discrepancies were brought to PECO's attention and were corrected. The

inspectors identified no substantive concerns as a result of these walkdowns.

02.2 Equipment Challenges

a.

Scoce

The inspectors reviewed the actions taken by PECO to identify, assess, track, and correct

several emergent equipment problems involving the Unit 3 HPCI system, a Unit 3 SRV

bellows failure, the Unit 2 drywell sump flow integrator, and several problems related to an

electrical storm on August 17.

b.

Observations and Findinas

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Operability determinations and interim corrective actions initiated for the above deficiencies

were prompt and appropriate. PECO responded well to troubleshoot and correct the HPCI

and drywell integrator equipment deficiencies. Operators promptly restored equipment

affected by the electrical storm including: reactor core isolation cooling (RCIC), main stack

radiation monitoring, the SBO line, and a Unit 2 safety-related battery.

PECO operators responded well to an alarm indicating that the 3-71C SRV bellows had

failed. Troubleshooting determined that the bellows had failed and that the pressure

setpoint sensing section of the valve was inoperable, however, t.his did not affect the

ability to open the valve from the control room nor the automatic depressurization (ADS)

function of the valve. Operators correctly entered the SRV limiting condition for operation

action statement. A drywell entry will be required to repair the bellows.

c.

Conclusions

PECO responded well to identify and correct several equipment deficiencies in a timely

manner,

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Operator Knowledge and Performance

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04.1 New Fuel Receipt Activities (60705)

PECO began receipt of the new fuel assemblies in preparation for the Unit 2 refueling

outage on July 30. NMD personnel exercised caution during the handling and inspection of

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the new fuel assemblies. The appropriate procedures were present on the refueling floor.

Health physics (HP) personnel maintained proper radiological controls during the evolution.

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MAINTENANCE AND SllRVEILLANCE

M1

Conduct of Maintenance and Surveillance

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a.

Scone

The inspectors reviewed safety-related system surveillance testing of the ESW, HPCI, and

the EDGs.

b.

Observations and Findinas

Emeraency Service Water Flowrate Verification

The inspector observed portions of ESW flow verification surveillance testing, done to

verify adequate system flow to components including the emergency core cooling systems

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(ECCS) pump room coolers and the EDGs Auxiliary operators conducted the testing well

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and test results demonstrated system operability.

Hiah Pressure Coolant Iniection

The inspector observed the normal quarterly pump valve and flow testing at Unit 3. During

the initial start, the operator in the pump room identif%d leakage from the gland seal

condenser and requested that the control room stop the test. Communications between

the local operator and the control room were very good. During this start attempt, the

operator also noticed that the steam admission valve did not appear to open smoothly.

Following repairs to the gland exhaust condenser the surveillance test was rerun. The

inspector observed this test from the HPCI pump room. Prior to the test, engineering

personnel had stroked the steam admission valve using the oil system and it performed

properly. Engineering personnel were present during the system start to observe the

operation of the steam admission valve. The inspector observed that the valve started to

open normally and then opened quickly to the full open position, then partially re-closed,

and opened normally. The engineering personnel directed that the control room secure the

turbine until repairs to the steam admission valve could be completed.

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See Section M4.2 below for a discussion of the resolution of the steam admission valve

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issues,

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Emeraenev Diesel Generator Endurance Testina

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The inspector made the following observations:

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Material condition before, during and after each test was good. However, the

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exhaust header to turbocharger gasket leaks continue to cause oilleakage and oil

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soaked lagging - which if not properly addressed could lead to a fire hazard.

During walkdown of the running E2 machine using the PECO SO procedure 52A.8.C

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- Diesel Generator Running Inspection, all conditions appeared normal, except that

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at approximately 2600 kW the inlet damper to the turbocharger combustion air inlet

plenum did not indicate open as required by the SO. Step 4.11 of the procedure

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states that when the machine is running with a load of at least 1900 to 2100 kW

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the operator should verify that combustion air has changed over to the outside air

filter by verification that the air inlet damper plunger is down. At loads less than

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1900 kW, the turbocharger inlet air is supplied by the engine driven supercharger.

The damper operates by the differential pressure generated as the turbocharger inlet

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plenum pressure decreases due to increased air flow through the turbocharger as

load increases.

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The inspector observed that the plunger was up at 2600 kW. The inspector also

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observed that the plunger was in the same position as the plungers for all the other

EDGs that were not running at the time. The inspector discussed this with the

operator, who stated that the plunger was in the correct position for the given

condition.

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The inspector subsequently reviewed the EDG technical manual and discussed the-

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condition with the system manager. It appeared that the plunger should have been

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down, but because the EDG was able to achieve its rated load capacity as

demonstrated by the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> load test, PECO did not have a specific safety concern

at the time.

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PECO committed to provide additional guidance to operators on the required

position of the air inlet plunger and to review the operation of the plunger during the

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next time the EDG was operated.

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The inspector found that the fuel oil pump discharge duplex filter (i.e., a filter with

two elements in parallel that may be switched from one element to the other using

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an internal switching valve) element in service had been switched during the 24

hour run. In general terms the only reason to switch filters is due to a high

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differential pressure conditions. Operators are required by SO 52.A.8D to verify

that the filter differential pressure is less than 10 psid. At 13 psid an installed

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annunciator alarms indicating that the operator should switch from the in-service to

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the standby filter element.

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The inspector noted that the SO did not provide guidance on what to do if the 10

psid was exceeded. Review of the annunciator alarm response procedure showed

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that the operator is not required to initiate a work order to replace the filter element

with the high differential pressure. It concerned the inspector that the procedures

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did not provide specific guidance to ensure that a dirty filter element would be

replaced and that no documentation indicated why the filter elements had been

switched during the E2 run. This was a concern since during a subsequent diesel

run for testing or in response to an accident, the operator could be left with two

dirty high differential pressure filter elements, which eventually could cause the EDG

to become unable to carry required loads.

c.

Conclusions

The surveillance activities observed were performed well. The ESW testing proved system

operability. Operator attention during the HPCI system identified and allowed correction of

a steam admission valve operating problems. The EDG 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> testing met the TS SRs.

The inspector did note a performance weakness in that the operators did not identify that

the turbocharger air inlet damper was not properly positioned in accordance with the SO

during the E2 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run. PECO took actions to address this weakness. Several other

outstanding issues with regard to the E-2 EDG test remain to be reviewed during a

subsequent report. Specifically, verification that the EDG air turbocharger air inlet damper

is functioning properly and that fuel oil filters are required to be changed out following

swapping from one to the other.

M4

Maintenance Staff Knowledge and Performance

M4.1 Electrical Cable Installation (62707)

The inspector compared the bend radius of several safety-related cables to the PECO

design criteria contained in drawing E-1317. The inspector reviewed the specified cable-

dimensions and then measured the bend radius for the selected cable installations and

determined that the cables met the E-1317 minimum bend radius requirements.

M4.2 High Pressure Coolant injection System Steam Admission Stop Valve Balance

Chamber Pressure Adjustment - Unit 3

a.

Insnection Scooe

The inspector reviewed PECO's response to a HPCI turbine steam admission stop valve

operating anomaly (See Section M1) and to an unexpectod HPCI turbine roll which

occurred while attempting to adjust the HPCI stop valve steam balance chamber pressure,

b.

Observations and Findinas

PECO attributed the HPCI steam admission stop valve operating anomaly to an improper

steam balance chamber pressure. PECO initially attempted to adjust the balance chamber

pressure in accordance with PECO maintenance procedure M-C-756-014 which generally

conformed to the guidance contained in General Electric Service information Letter (GE SIL)

352. During the initial adjustment, the HPCI turbine unexpectedly rolled and reached a

speed of 5000 revolutions per minute. The reactor operator alertly recognized this

abnormal condition and promptly isolated the turbine steam supply to stop the turbine.

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PECO attributed the HPCI turbine roll to a gage block that had been sized to the full length

of the pilot valve stroke and installed per M-C-756-014 to properly position the stop valve

pilot valve assembly during the balance chamber pressure adjustment. The gage block

unseated the steam admission stop valve and caused the turbine roll. PECO determined

that the short duration HPCI turbine roll did not cause any system damage. The inspectors

performed a external inspection of the HPCI system and concurred with PECO's

assessment.

.

PECO successfully adjusted the stop valve steam balance chamber pressure utilizing a

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revised process which included an initial adjustment performed with a gage block

constructed to be less than the full pilot valve stroke. PECO then successfully retested and

declared the HPCI system operable on August 16. The inspectors noted that PECO's

engineering support throughout this event was good.

The inspectors noted a preventive maintenance (PM) program weakness in that PECO had

not been periodically monitoring the turbine stop valve balance chamber pressure as

,

recommended by GE SIL 352 and the vendor manual. The inspector reviewed PECO's

performance enhancement program (PEP) investigation for this event and noted that one of

the assigned corrective actions was to develop a PM program to periodically monitor the

balance chamber pressure.

c.

Conclusions

PECO nuclear maintenance division personnel and engineering responded well to this issue.

Based on observation of the valve stroking during testing, the inspectors believe that the

system would have performed its safety function, as designed prior to the repair.

However, the need to remove the system from service to perform the emergent repair

could have been precluded had PECO implemented the vendor guidance on measuring and

trending the pilot chamber pressure. PECO plans to review implementation of the vendor

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guidance as part of the PEP, in the near future.

M8

Miscellaneous Maintenance issues

M8.1 (Closed) Licensee Event Report (LER) 3-96-002, Low Pressure Coolant injection

System Declared inoperable Due to inadequate Post-Maintenance Testing

This LER identified that, during a preventive maintenance activity in January 1996, the 3C

RHR room cooler fan motor had been mis-wired so that the fan would rotate in the reverse

direction. Additionally, PECO identified that the post-maintenance testing had not been

adequate since it did not detect the improper fan rotation. PECO determined that the

improper fan configuration could have rendered the 3C RHR pump inoperable for longer

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than the seven day time period permitted by TS 3.5.1. The inspector noted that PECO

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implemented thorough corrective actions; and that the safety significance of this event

was low since the RHR pump would have started and only have been affected by a long

term temperature increase in the room and because the wiring problem only affected one

of the four RHR pump room coolers. This PECO identified and corrected violation is being

treated as a Non-Cited Violation, consistent with Section Vll.B.I of the NRC Enforcement

Manual.

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ENGINEERING

E1

Conduct of Engineering

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E1.1

EDG Modification Design issues - Apparent Violation 96-06-01 and Update to

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Unresolved item 96-04-04

a.

Scooe

inspection Report 96-05 discussed severalissues dealing with the control circuits of the

EDGs and associated loads. In order to allow determination of the regulatory significance

of these issues, PECO was asked to provide an analysis of the licensing basis for the

EDGs. During review and determination of the licensing basis PECO identified two

additional issues.

The identified issues included:

e

an EDG running during a routine test, with its output breaker open, would not have

automatically loaded onto its associated emergency bus following a LOOP event

(i.e. the EDG output breaker would close, trip and remain open without operator

action);

e

the EDG output breaker would not automatically re-shut onto the emergency bus for

other LOCA/ loss of offsite power (LOOP) sequences. PECO believes that these

sequences are outside the design and licensing bases;

e

the associated RHR pump breaker would not remain shut following a LOOP /LOCA

event if the EDG was initially running in parallel with an off-site source; and

e

the RHR pump start sequence would be altered if either the E3 or E-4 EDGs were

operating in parallel with off-site power, and a LOCA (no LOOP) occurred; the C or

D RHR pump would immediately start (these pumps are normally started 8 seconds

after a LOCA), followed by an A or B RHR pump start 2 seconds after the LOCA.

The inspectors continued to review the EDG output breaker issues to determine their safety

and regulatory significance.

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b.

Findinas

The inspectors conducted a detailed review of the RHR pump time delay issue discussed

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above. The following list represents a chronology:

PECO completed a calculation (unreviewed by NRC) which they believed showed

that the offsite power system and the supplied components would not be adversely

effected by the timing sequence problem. PECO also discussed making a change to

the test procedures and providing information to the operation department - stating

that the calculation resolved the issue.

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PECO made preparations to run the 24-hour endurance testing on the E4 and E2

EDG to meet the 24-month frequency.

On August 7, the inspector identified that the RHR pump time delays for starting on

offsite power were included in TS and that the problem affected all the EDGs and

associated RHR pumps, not just E3 and E4. The inspector informed NRC and PECO

management that a TS change would be required if the RHR pump would knowingly

not start as defined in TS.

1

On August 9, during a control room tour the inspector found that PECO engineering

had issued a shift update notice (SUN) stating that the offsite source could support

the early starting of an RHR pump and that the time delays for the pumps would be

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declared inoperable during testing. The inspector believed that the PECO issued

direction to the operators represented a change to the TS time delays for the RHR

pumps. PECO stated that they had not changed the TS since they were entering

)

the LCO for the instruments.

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The inspector stated to PECO, after discussions with the NRR PM, that this still

appeared to be an unauthorized change since the pump, if required to start, would

still knowingly start at a time that was different from the TS allowable limits, if its

associated EDG was running in the test mode. Further, the bases of TS did not

assume both relays would function outside their allowable limit, which would be

analogous to this condition. Rc6 , the TS assumed a failure of a relay to function.

This was why the design was sWie failure proof (i.e. two relays in parallel).

The inspector also stated to PECO that it appeared that the design and installation

of modification P-231 caused the problem and that if the situation had been known

4

at the time, they would have had to answered "YES" to a TS change being

required, while preparing the modification 50.59 evaluation.

PECO put all EDG testing on hold until the TS issue could be resolved.

On August 20, during a review of the TS SRs and the 50.59 safety evaluation for

the modification the inspector found:

The safety evaluation for modification P231 clearly stated that the EDG in

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test was to return to standby and loads were to automatically energize from

offsite power.

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SR 3.8.1.17 required that an EDG in test return to a standby condition and

that loads automatically sequence onto offsite power (as they would for a

LOCA without a LOOP) following a LOCA.

The inspector discussed the issue with the NRR PM and NRC Region I management

- the decision was that PECO, with the current design, could not meet this SR - 3.8.1.17. The inspector discussed this issue with PECO management. PECO

management determined that this specific SR was only applicable during EDG

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testing. This position was discussed with NRR and found acceptable.

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PECO determined that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> endurance testing could be conducted by

declaring the EDG inoperable and by making the associated RHR pump unable to

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start and declaring it inoperable.

The inspector identified the following during the review:

When the EDGs were run for testing between the implementation of the improved

standard TS (January 1996) and July 1996, TS requirements for RHR pump start

time could not be met. As such, either plant would have been placed in an

unanalyzed condition if a LOCA had occurred during EDG testing. Specifically, the

station voltage study included the time delays for RHR pump starts as stated in TS.

The technical issue did not appear to be of large safety significance due to the

relatively short period of time that EDGs were run. Further, only one EDG was

tested at a time - the other three station EDGs and their associated RHR pumps

were operable.

PECO engineering review identified the technical issue. However, PECO did not

identify the TS compliance issues. Further, PECO used a calculation to justify

knowingly not meeting the TS time delays and documented this in a shift update

notice (SUN) to the operations department. This approach changed the timing

sequence outlined in the UFSAR, which was the sequence on which the TS time

delays were based.

Modification P-231 did no.

complish its design intent as stated in the safety

evaluation for return of an EDG in test to standby and automatically sequence loads

onto offsite power, following a LOCA. Further:

The design review for the modification did not identify the conflict between

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the EDG breaker opening and the RHR pump starting following a LOCA.

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Post-modification testing was inadequate because it did not verify the

sequencing of RHR pumps following a LOCA with an EDG in test.

The RHR pump starting tin,e delay issue was not identified as part of PECO's

corrective actions following a previous escalated enforcement action dealing with

this modification. PECO stated in response to the previous escalated notice of

violation (PECO letter dated September 18,1995, in response to NRC Notice of

Violation, dated August 17,1995, based on inspection Report 95-11 findings), that

the modification acceptance testing for Modification P-231 had been completely

reviewed, with no additional problems identified.

c.

Conclusion

PECO performed wellin identifying issues surrounding the operation of the EDG and their

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control circuits. However, the analysis of the TS and the UFSAR was weak with respect

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to the RHR pump time delay issue with an EDG in test. The inspectors found that 1) the

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TS time delays could not have been met during EDG testing,2) PECO did not know that TS

limits existed for the time delays or that TS surveillance testing required that loads

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sequence onto the bus in accordance with the time delays,3) the use of a calculation and

a SUN amounted to an unauthorized change to the TS,4) modification review and

subsequent post-installation testing did not identify the RHR pump time delay issue, and

51 previous actions taken to review the modification, as the result of a previous problems

with post-modification testing verification of design function did not cause this issue to be

identified. Collectively, the inspector considered that these issues represented an apparent

violation of TS 3.8.1.17,10 CFR 50.59,10 CFR 50 Appendix B; criterion Ill, " Design

Control" and 10 CFR 50 Appendix B, Criterion XVI, Corrective Action." (Apparent

Violation 96-06-01)

E2

Engineering Support of Facilities and Equipment

During the period the inspectors observed good engineering support to identify and correct

equipment problems including: excellent system manager support to the HPCI steam

admission valve timing problem (See Section M4.2) and excellent support to restore power

to the Unit 2 feed pumps following a loss of power lock-up (See Section O2.2).

,

Engineering also provided excellent analysis of the effects of the electrical storm (see

Section O2.2).

E2.1

Station Blackout Line Review - Unresolved item 96-06-02

a.

Scope

On July 9, members of the NRR staff reviewed the implementation of PECO's commitment

to 10 CFR 50.63 " Station Blackout." PECO made commitments relative to 10 CFR 50.63

in their August 6,1992 submittal and their July 13,1995 submittalin support of a TS

change allowing use of the SBO line to lengthen the allowable out-of-service time for a

single EDG. The AAC power source used by Peach Bottom consists of (1) a dedicated

direct power line, buried beneath the Conowingo pond between the Conowingo Hydro

Electric Station and Peach Bottom, and (2) installed hydroelectric wrbines at Conowingo

configured to be able to feed the tie line and associated switchgear and transformers at

'

both Conowingo and Peach Bottom.

The inspectors walked down the Conowingo Hydroelectric Station, including the generating

equipment, the switchyard, and the control room. The inspectors also reviewed operating

procedures with Conowingo staff to determine the contingency steps necessary to

reconfigure Conowingo generating equipment to feed the SBO tie-line. At Peach Bottom,

the inspectors walked down the switchyard and the control room and discussed

procedures for energizing safety-related switchgear from the SBO line,

b.

Observations and Findinas

The inspectors developed the following facts based on the walkdowns:

Of the 11 hydro units at the Conowingo Station, six units (6,7,4,5,10, and 11)

may be used as an SBO power source for Peach Bottom. The other units could be

used as SBO power sources, but require additional switching operations and have

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not been tested to connect to the Peach Bottom safety-related buses within one

hour,

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in addition to the 11 units, there are two smaller auxiliary hydro-generators

(1500 kW,440 Vac) used to supply station auxiliaries (battery chargers, oil pumps,

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etc.), in tM event of a loss of offsite power at Conowingo. Normally, offsite power

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(220 kVi, inrough a step down transformer, supplies the auxiliary power.

e

The Conowingo staff described how auxiliary power, including auxiliary hydro-

2

generators are always in operation and that with auxiliary power available, startup

,

and operation of the generating units is straightforward,

e

Procedures were available at the Conowingo Station to energize the SBO line during

complete loss of offsite (220 kV) power by utilizing one of the six hydro units,

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The Conowingo staff indicated that Conowingo is a peaking station, with limited

'

times during the year when the main hydroturbines are neither generating power nor

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operating as electrical condensers (spinning reserve).

e

The SBO line is normally energized, from the Conowingo switchyard. If a hydro-

generating unit is not supplying the SBO line it is energized from the PECO offsite

grid.

e

The SBO line from the Conowingo transformer, in the Conowingo switchyard, to the

underground conduit was supported by a wood utility pole, in addition, physically

adjacent transformers, which serve commercial lines, also route their output power

to the grid via adjacent wood utility poles,

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In the Peach Bottom control room circuit breaker and transformer tap changer

controls are present, however, in the normal standby condition there is no direct

indication of the voltage or frequency of the SBO line.

The inspectors developed the following issues:

o

During the review of the SBO rule implementation at Peach Bottom, the NRC staff

mis-understood that the SBO line is always energized through a hydro unit. In their

submittal dated August 6,1992, PECO stated that five of the eleven generating

units at Conowingo are normally running as electrical condensers and are available

as spinning reserves. In such a condition, PECO estimated that the time required to

provide power to the 33kV SBO system would be about five minutes. In the

August 6,1992 submittal, PECO also stated that if no Conowingo units are in

service, the initial actions required by the Conowingo operators would be to start

several of the Conowingo units and that these actions would take an additional ten

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minutes. At the time, the NRC staff did not understand that this statement implied

that there were times when the main hydroturbines at Conowingo are neither

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generating power nor operating as electrical condensers,

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In the August 6,1992 submittal, PECO stated that because the SBO line would be

normally powered, it was considered an on-line system in accordance with

NUMARC 87-00, item B.13. As such, PECO provided target availability numbers for

the SBO line but stated that there is no target for reliability for normally on-line

systems. The inspectors noted that there are times that the SBO line is powered

from the grid and no Conowingo hydroturbines are generating or serving as spinning

reserves. As such, the NRC staff does not consider the SBO AAC source (the SBO

line and generating units) to be a normally on-line source.

In its submittal dated August 6,1992, PECO stated all components of the SBO line

would be " capable of withstanding the effects of likely weather-related events."

The inspectors observed all major componen" of the line and concluded that, with

the possible exception of the wooden utility

1s, all components appeared to be

adequately protected from weather-related events.

In a letter dated July 13,1995, submitted in support of a revision to the TS that

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allowed out of service t me for inoperable diesel generators, the licensee stated that

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voltage and frequency on the SBO line would be verified periodically during times

the EDG was inoperable. During the walkdown, the NRC staff did not observe

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direct indication of voltage and frequency associated with the Conowingo line.

c.

Conclusion

Based on the findings discussed above, the implementation of 10 CFR 50.63 was

considered an unresolved item (Unresolved item 96-06-02), PECO needs to address the

following concerns:

The frequency with which at least one of the SBO hydro-generators is operating,

the frequency with which at least one of the SBO hydro-generator is operating as an

electrical condenser, and the frequency with which none of the SBO hydro-

generators are not operating.

The reliability of the AAC source given that there are times when none of the SBO

generating units are on-line. The licensee did not provide any reliability data for the

hydro units. The staff accepted the availability of 95 percent based on the

understanding that at least one of the hydro units that supply power to the

Conowingo line will be operating all the time. Since the hydro unit will not be

operating all the time, the licensee needs to address how the NUMARC 87-00

criterion on reliability for AAC power source is being met.

Clarify how the use of wood utility poles was consistent with the stated design

criteria of being " capable of withstanding the effects of likely weather-related

events." The licensee needs to provide justification on the use of wooden poles

and exposed cable connecting the underground portion of the AAC line at the 33 kV

substation at Conowingo to meet the requirements of NUMARC 87-00, Appendix B,

item B.3.

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Clarify how these periodic voltage and frequency verifications are performed

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including a discussion of the location of associated instruments and location of

associated displays. On July 13,1995, in response to Condition 3 (documented in

!

the NRC letter dated April 7,1995), the licensee stated that the periodic

surveillance of the SBO line would include verification of voltage and frequency to

ensure connection capability to the PBAPS onsite distribution system. Also,

!

provide details on the verification of the connectability of the AAC line.

E2.2 Improper Control of the Standby Gas Treatment System - Violation 96-06-03;

-(Closed) Unresolved item 95-27-02

a.

Scope

As documented in inspection Report 95 27, the NRC found that PECO procedures allowed

the possibility that the standby gas treatment (SBGT) system could be run in an

unanalyzed mode. Specifically, the inspectors found that operation of this safety-related

system taking a suction on the reactor buiWing equipment cell exhaust during reactor water

cleanup (RWCU) system resin regeneration had not been analyzed in the updated final

safety analysis report. Subsequently, PECO identified that system procedures allowed

operating configurations where it would not have been able to provide the design negative

pressure differential on the secondary containment following a design basis accident with a

single failure. At the time PECO took corrective actions to address the concerns during

subsequent SBGT operations.

However, the issue remained unresolved pending safety significance review of PECO

answers to several questions concerning the previously unidentified single failure

vulnerability.

1.

What would be the overall effect on reactor building negative pressure if the

postulated single failure occurred?

2.

How would operators respond to the postulated single failure condition and in what

time frame?

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3.

Based on the answers to questions 1 and 2, what would be the overall effect on

offsite/onsite doses and operability of the SBGT filters?

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The inspectors reviewed PECO's February 28,1996, response to this unresolved item and

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the supporting engineering calculation.

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b.

Findinas

PECO concluded the following:

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While not able to maintain the designed 0.25 inches of water vacuum differential on

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the reactor building, the SBGT systems could have provided sufficient negative

pressure to ensure a monitored release for wind speeds up to 23 MPH.

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Plant procedures and routine actions would have enabled the operators to identify

and correct the low negative pressure conditions quickly following a LOCA.

As a bounding analysis, PECO also conducted an analysis to determine the effects

of no SBGT operation during the first 10 minutes following a LOCA which indicated

that neither the control room habitability dose per 10 CFR 50 Appendix A, General

Design Criteria 19 nor the offsite dose limits of 10 CFR 100 would be exceeded.

The inspectors found:

The SBGT system would have been able, with operator actions, to maintain

negative pressure and provide a monitored vent path, in all conditions. However,

operator action is not assumed by design for the first 10 minutes following a design

basis accident.

The calculations conducted were well documented and based on good engineering

judgement and used conservative assumptions,

c.

Conclusion

The operation of the SBGT system in a mode not described in the UFSAR, led to the

inability of the system to be single failure proof and the inability, under these conditions, to

meet the TS required 0.25 in of water negative differential pressure. This constituted an

unidentified unreviewed safety question in accordance with 10 CFR 50.59. The inspector

1

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considered this a violation of 10 CFR 50.59 (Violation E -06-03) However, because of

PECO's response to the unresolved item and the corrective actions taken there is no

response required to this violation. Unresolved item 95-27-02 and violation 96-06-03 are

considered closed.

IV

PLANT SUPPORT

R1

Radiological Protection and Chemistry Controls

R1.1 Radioactive Material Shipping - Temporary Instruction 2515/131 - Implementation of

the Revised Regulations

a.

Scoce (Tl 2515/133)

The inspector reviewed the implementation of the revised DOT and NRC radioactive

material shipping regulations (effective April 1,1996) outlined in Federal Register (FR)

Notices 60 FR 50292 and 60 FR 50248, dated September 28,1995. The inspector

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compared applicable effective regulations with the licensee's procedures and program, and

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discussed regulatory requirements with cognizant licensee representatives.

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b.

Observations and Findinas

The inspector ccncluded that the licensee implemented the effective (as of April 1,1996)

portions of the recent changes in DOT and NRC regulations. The licensee made revisions

to procedures to incorporate the changes including verification of updates to vendor

supplied computer programs. However, the inspector found that the licensee's program

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did not:

e

provide guidance relative to determination of the degree of uniformity of low

specific activity (LSA) radioactive material.

e

specifically address the unshielded dose rate criterion (1 rem / hour at 3 meters) for

packages of low specific activity and surface contaminated materials.

e

specifically address the new design specifications for casks outlined in 10 CFR

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71.73,

e

provide guidance relative to ensuring all radioactivity present (e.g., fixed, removable,

neutron activation produced) was accounted for, for shipping purposes.

Though the licensee's staff was aware of these specifications, the described program did

not contain specific guidance relative to implementation of the above requirements. The

inspector did not identify any violations associated with the lack of specific program

guidance. The licensee indicated that the radioactive material shipping program would be

reviewed for enhancement, as necessary.

c.

Conclusion

No safety concerns were identified. Overall, the licensee effectively implemented the

revised radioactive material shipping regulations and revised procedures accordingly.

R1.2 Unit 2 Refueling Outage Radiological Controls (Planning and Preparation)

a.

Scope (83750)

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The inspector selectively reviewed the radiological controls planning and preparation for the

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Unit 2 refueling outage. The inspector reviewed records, discussed outage planning with

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licensee representatives, reviewed various radiological controls goals including radiation

exposure goals, and observed activities to verify necessary planning and preparations and

management support for radiological controls planning. Areas reviewed included increase

of health physics staff; supervisory control over contract technicians; special training,

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including use of mockup training; work package review by health physics personnel, dose

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reduction methods, radwaste reduction; and use of lessons learned from previous outages.

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b.

Observations and Findinas

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The inspector's review indicated that the licensee provided overall effective planning and

preparation for outage radiological controls work activities, including outage work scope

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coatrol. The Station ALARA Council approved outage dose goals and objectives including

. an aggregate occupational exposure goal of 250 person-rem.

The licensee planned to increase the health physics staff to support outage work and

planned to use PECO radiation protection personnel in lead capacities over contracted

technicians. Lessons learned from previous outages were incorporated into outage

,

planning. Mock up training was provided as appropriate. The licensee appeared to be

effectively controlling work scope. The inspector reviewed expected accumulated radiation

exposure for the planned outage and noted general agreement with the Unit 2 outage

accumulated exposure goal. Identified tasks had been assigned to various radiation work

permits. The inspector noted that essentially all significant planned work had received an

ALARA review (243 person rem reviewed as compared to an expected 250 person-rem).

The licensee planned to use area based planning to control unnecessary scaffolding

removal and re-installation. The inspector noted that the licensee established a source

term reduction team whose purpose was to review the station radiological conditions and

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recommended initiatives to reduce radiation dose rates.

The following observation was made:

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The inspector questioned licensee ALARA personnel as to the effectiveness of dose

reduction techniques used for various outage tasks (e.g.,' control rod drive removal

and replacement, snubber inspections, and in-service inspections). In particular, the

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inspector attempted to determine the relative accumulated radiation e.xposure

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sustained by workers for various tasks as compared to similar reactor facilities

where the same task had been performed. The licensee's ALARA personnel were

not readily able to discuss relative performance as compared to similar facilities and

similar tasks. The inspector indicated such inter-comparisons may provide

opportunities for occupational exposure reduction. The licensee's personnel

indicated this matter would be reviewed,

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c.

Conclusion

The licensee implemented generally very good ALARA planning for the Unit 2 refueling

outage.

R1.3 External Exposure Controls - Use of National Voluntary Laboratory Accreditation

Program Accredited Dosimetry

a.

Scope (83750)

The inspector selectively reviewed the status of testing of the licensee's vendor supplied

personnel whole body monitoring device and the scope of accreditation provided by the

National Voluntary Laboratory Accreditation Program (NVLAP) for the vendor supplied

dosimetry. 10 CFR 20.1501(c) requires that personnel dosimeters that are used in

4

accordance with 10 CFR 20.1502(a) be processed by a processor accredited by the

.

NVLAP for the appropriate types of radiation. Voluntary and redundant dosimeters, as well

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as direct and indirect reading pocket ionization chambers and those dosimeters used to

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measure the dose to extremities, are excepted from this requirement. The inspector

reviewed records and discussed the program with cognizant licensee personnel,

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b.

Observatic.1s and Findinas

The inspector noted that, for a period prior to October 1994, the licensee had provided

personnel whole body dosimetry via its own NVLAP accredited onsite radiation dosimetry

program. In October 1994, the licensee outsourced the dosimetry program to a vendor.

The inspector requested applicable audits, test data, and scope of accreditation for the

vendor supplied dosimetry.

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The inspector determined that NVLAP's scope of accreditation fu the vendor provided

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dosimetry covered applicable testing criteria when use of the vendor dosimetry was -

initiated in late 1994. The inspector determined that the licensee initiated blind (spike)

testing of the vendor dosimetry during the first calendar quarter of 1995. The initial blind

spike test results indicated apparent difficulty by the vendor in assessing shallow radiation

dose. The licensed attributed the problem to a low average beta radiation energy (88 Kev)

at the station and indicated that the dosimetry would over-respond (i.e., provide

conservative results) to the low energy beta radiation. Notwithstanding the licensee's

identification of this problem, the inspector made the following observations.

As of the date of this inspection, the licensee had not resolved this issue and was

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continuing to review it. The problem append to be attributable to calibration

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difficulties associated with a very steep energy versus response curve for the

dosimeter when subjected to low energy beta radiation,

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The inspector's review of the fourth quarter 1995 NVALP test data indicated that

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the vendor provided personnel dosimeter failed dosimetry test Category Vil

(combined high energy gamma and beta radiation) of the applicable natior'al

standard (ANSI. N13.11). The licensee's Radiation Protection Manager was

unaware of this failure indicating apparent weaknesses in oversight of vendor

activities.

The individual directly tasked with oversight of radiation protection dosimetry issues

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appeared to have limited experience in personnel dosimetry programs. .The licensee

indicated direct supervisor oversight was provided for the individual's dosimetry

related activities. The licensee indicated a training / qualification program for the

individual would be established and implemented.

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The licensee was reviewing these matters at the close of the inspection.

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c.

Conclusions

The personnel whole body dosimeter used by the licensee had received NVLAP

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accreditation and appeared to provide reasonable radiation exposure measurement.

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However, the low energy response problem of the dosimeter should be resolved. Further,

there appeared to be a need for enhanced management oversight of the vendor provided

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dosimetry services.

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R2

Radiological Effluent Controls Program Review

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R2.1 Holes Cut into Turbine Building Exterior Wall- Unit 3

a.

Scope

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The inspector reviewed a PECO identified event involving a low level unmonitored release

from the Unit 3 turbine building (TB) which began on July 18 and ended on July 25. The

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inspector discussed the event with key HP personnel, attended briefings, and reviewed the

PEP investigation results.

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b.

Observations and Findinas

PECO was initially slow to identify, bm followed-up well, an unmonitored gaseous release

path from the TB. The event occurred during the installation of ventilation duct supports

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for the new plant egress and radiochemistry laboratory (PEARL) building.

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The following is the sequence of events:

7/16 Installation work began, HP technicians verified the TB roof area clean.

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7/18 A worker cuts the first opening through the side of the TB; thus creating the

unmonitored release path.

7/24 A PECO engineer expressed concern that the TB openings could represent an

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unmonitored vent path. PECO and contractor personnel assessed the work

site and concluded that there was minimal air flow through the TB oper.ings

and that no further action was necessary.

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7/25 HP technicians sampled the TB area inside the plant and detected noble

gasses. The TB openings were then covered and sealed.

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7/26 PECO initiated a PEP to investigate the event.

PECO assessed the possibility of an unmonitored release and determined that:

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The openings were not properly covered after completion of the work activities,

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The modification safety evaiuation did not address the potential for a release event.

2

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The TB is not part of the secondary containment so that a barrier breach document

was not required.

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PECO initially assumed that the TB was maintained at a negative pressure so that

no air could escape the TB except through the ventilation exhaust. PECO later

determined that some areas in the TB could experience a positive pressure based on

the ventilation line-up.

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The volume of air flowing to the outside with respect to the TB exhaust flow was

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insignificant. PECO calculated the potential release as about one-millionth of the

allowable limit based on a conservative airflow assumption that the combined

leakage through the openings was equivalent to ten percent of the total TB exhaust.

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As corrective actions PECO revised the work order activities to add the following additional

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work controls:

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HP was notified prior to cutting the final two openings and performed monitoring of

the openings once per shift.

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All openings were sealed or flashed with permanent siding at the end of each shift.

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Only one opening was made at a time.

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PECO's corrective actions for this event were adequate. However, the inspector

considered PECO's pre-job p.'anning for this modification to be weak and noted that one

week elapsed from the initiation of the event until PECO implemented positive measures to

secure the unmonitored release path. This item will be further reviewed during an

upcoming NRC specialist inspection.

R3

Procedures and Documentation in Radiation Protection and Chemistry

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R3.1 Radioactive Material Shipping -Implementation of the Revised Regulations

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a.

Scope (Tl 2515/133)

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The inspector selectively reviewed radioactive waste shipments made since implementation

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of the revised DOT and NF.J regulations (effective April 1,1996). The review was against

criteria contained in 10 CFR 20,61, and 71; and 49 CFR 100-199.

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b.

Observations and Findinas

The licensee did not make any Type B quantity shipments (e.g., resin shipments) since

implementation of the revised shipping regulations (April 1,1996). The licensee had made

several low activity / exempt quantity shipments. The inspector reviewed four such

shipments and determined that the radioactive waste shipping program was implemented

and the radioactive material contents o' packages were properly determined. Packages

were classified, described, packaged, marked, and labeled (as appropriate). Shipping

records were complete and well maintained. The individuals involved in shipping activities

were generally very knowledgeable of applicable requirements.

c.

Conclusion

No safety concerns or violations were identified. The licensee effectively implemented the

revised DOT a. d NRC radioactive material shipping regulations.

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R4

Staff Knowledge and Performance in Radiation Protection and Chemistry

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R4.1 Standby Liquid Control Tank Sampling

a.

Scope

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The inspector observed the sampling of the Unit 2 SLC tank following surveillance test

procedure ST-C-095-801-2, " Standby Liquid Control Tank Boron Solution Analysis" on July

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17. Additionally, the inspector observed a portion of the sample analysis performed

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according to chemistry procedure CH-C-105, " Boron Analysis By Automatic Titration."

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b.

Observations and Findinas

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The chemistry technicians followed ST-C-095-801-2 while drawing the sample from

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the SLC tank.

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The SLC tank sampling was not included in the work week plan and the on-shift

work control and shift supervisors were unaware that the SLC tank was to be

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sampled.

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The on-shift reactor operator (RO) was not aware that the SLC tank had been

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sampled. The chemistry technicians had informed the previous shift RO about the

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tank sampling, however, they did not sample the tank until about two hours into the

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next shift.

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The procedure did not provide any guidance for restoration of the SLC system

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during the sampling process if required by an event condition.

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e

One of the chemical reagents used in the enalysis had three different shelf life labels

attached to its storage bottle. The chemistry technician used the most limiting shelf

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life label to determine that the reagent had exceeded its shelf life, however, the

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inspector was concerned that the number of different tags could lead to confusion.

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c.

Conclusions

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The inspector considered it a weakness that ke/ shift operations personnel were unaware

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of the SLC tank sampling evolution; particularly since the sampling procedure required air

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mixing of the tank contents. The inspector noted that if not properly secured the air

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mixing could potentially affect the SLC system operation. The PECO system manager

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indicated that a the procedure would be reviewed to determine if any additional guidance

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R5

Staff Training and Qualification in Radiation Protection and Chemistry

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R5.1 Radioactive Material S' nipping - Training of Personnel on the Revised Regulations

a.

Scope (Tl 2515/133)

The inspector reviewed the training, on the revised radioactive material shipping

regulations, provided to personnel involved in radioactive waste generation, processing,

handling, storage, packaging, and shipping activities (as appropriate). The inspector

reviewed training records, lesson plans, and discussed training with cognizant licensee

personnel. The inspector reviewed organization charts and reviewed the training records of

selected personnel who were involved in the aforementioned activities.

b.

Observations and Findinas

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A vendor provided specific training on the revised regulations in late 1995. Applicable

personnel attended the training including radioactive material shipping personnel, quality

assurance personnel, and training personnel. Training personnel subsequently provided

training on the revised regulations for other personnel involved in radioactive waste

processing, handling, storage, packaging, and shipping activities (as appropriate).

The following observation was made.

The revised NRC/ DOT regulations, including corrections thereto, were formally

provided to the public via Federal Register Notices. The inspector noted that,

although the licensee receives Federal Register Notices, the licensee's radioactive

material shipping personnel were not made cognizant of these changes via the

licensee's internal distribution program. Rather, the personnel principally became

aware of the notices through industry meetings or other means. The inspector

questioned whether applicable personnel would be made aware of regulation

changes, within a timely fashion. The inspector did note that the licensee did

receive periodic updates of radioactive material shipping regulations via a vendor

service. However, it was not apparent which method of notification provided the

most timely update of the staff on important regulatory changes. The licensee

indicated the internal distribution of Federal Register Notices would be reviewed,

c.

Conclusion

No violations or safety concerns were identified. The licensee provided appropriate

training of personnel, on the revised radioactive material shipping regulations.

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R7

Quality Assurance in Radiological Protection and Chemistry (83750)

R7.1 Radioactive Waste Processing, Handling, Storage, and Shipping (Program Audits)

a.

Scope (83750)

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The inspector reviewed selected audits, assessments, and surveillances of the radiological

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controls program. The review was against criteria contained in Updated Final Safety

Analysis Report Chapter 13.8.

b.

Observations and Findinas

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The licensee implemeusd a generally broad based audit and surveillance program in the

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area of radiological controls. The quality assurance organization completed numerous

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performance based surveillances of ongoing activities. Audits were of good quality and

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appropriately qualified auditors were used to perform the audits, surveillances, and

assessments,

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The radiological controls organization initiated, in early 1996, a comprehensive radiological

controls program performance evaluation program. The program provided for a review and

evaluation of all program performance indicators on a quarterly basis that could be used to

identify areas for improvement in the radiological controls program. This was considered a

very good initiative.

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The licensee performed a comprehensive analysis of self-identified findings associated with

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nuclear maintenance group performance. The effort was initiated to identify root causes of

performance deficiencies and improve overall performance. The analysis was considered a

very good initiative.

c.

Conclusion

No safety concerns or violations were identified. Overall, surveillances and audits were of

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good quality as were licensee initiatives to improve performance.

R8

Miscellaneous issues

4

R8.1 Verification of Updated Final Safety Analysis Commitments

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a.

Scoce (83750)

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A recent discovery of a licensee operating its facility in a manner contrary to the UFSAR

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description highlighted the need for a special focused review that compares plant practices,

procedures, and/or parameters to the UFSAR description. While performing the inspections

discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that

related to the areas inspected.

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In particular, the inspector reviewed storage of radioactive materialincluding radioactive

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waste, relative to UFSAR descriptions and also reviewed the ,10 CFR 50.59 evaluation for

various outdoor radioactive material storage locations.

b.

Observations and Findinas

The licensee initiated a comprehensive review of the entire UFSAR in early 1996 to identify

incorrect or ambiguous statements and typographical errors. The review was performed in

two phases and involved a designated team of engineers. The licensee identified several

UFSAR issues with respect to the radiological controls area and radiological waste systems

and storage and brought them to the inspector's attention, as follows:

e

Relative to the solid radioactive waste portion of the review (UFSAR Chapter 9),

including ciry active waste, the licensee identified no incorrect statements, about 24

apparent ambiguous statements, and a number of typographical errors.

e

Relative to the liquid radioactis' traste portion of the review (AR Nos. A0999850,

A1025406), the lice nsee identified ses aral inaccuracies associated with UFSAR

(e.g., description of the location of the intake sample station depicted on UFSAR

Figure 9.2.5., lack of neutralization of the Chemical Waste Tank contents prior to

transfer, and accuracy of UFSAP. Figure 9.2.1B),34 apparent ambiguous

statements, and eight typographical errors.

e

Several inconsistencies associated with radiological controls program

elements / practices (AR No. A0998476) described in UFSAR Chapters 7,12, and 13

(e.g., use of electronic dosimetry versus pocket ion chambers, and use of two levels

of radiation protection technician training versus four levels).

In addition the inspector identified the following inconsistencies between the wording of

the UFSAR and observed plant practices, procedures and/or parameters, regard in outside

storage of radiological material / waste:

e

There was no apparent specific information, however, a licensee 10 CFR 50.59

evaluation identified several outdoor radioactive material storage / staging areas some

of which were not used. It appeared that the licensee should update the UFSAR to

reflect its outdoor radioactive material storage / staging practices.

e

The 10 CFR 50.59 evaluation, performed for outdoor storage of radioactive

material, did not addmss the storage of seven trailers behind the 135' elevation of

the radioactive wastr, building. The inspector noted that the trailer storage

appeared to be wel! within restrictions on radiation dose rates presented in the 10 CFR 50.59 evaluation, for other storage locations.

e

There were no surveillance criteria for evaluation of the material condition / integrity

of non-seven containers in outdoor storage locations. Several containers observed

at the South Yard exhibited significant rusting and faded and illegible radioactive

material information labels.

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The inspector's review did not identify any apparent significant safety concerns associated

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with the findings. The licensee had initiated actions (e.g., Action Requests) to review the

findings and update the UFSAR and applicable drawings, as appropriate.

.

c.

Conclusions

f

Several examples were identified by the licensee where the UFSAR did not agree with

current radiological material / waste and radiological control practices. Also, the inspectors

)

identified that the outdoor storage of radioactive materials was not specifically described

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within the UFSAR. The specific issues presented no apparent immediate safety concerns,

d

however, the UFSAR should be updated to reflect current practices, as appropriate. The

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review of the above matter relative to 10 CFR 50.59 and the updating of the UFSAR in

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accordance with the 10 CFR 50.70 (e) is considered an unresolved item pending NRC

evaluation. (Unresolved item 96-06-04).

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R8.2 Previous Findings

d

(Closed) Violation 95-23-01

This violation involved failure to sdhere to radiation protection procedures during work in

4

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the " Hot Shop" and involved contractor personnel. The inspector's review indicated that

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the licensee implemented the corrective actions outlined in its November 2,1995, and

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January 3,1996, responses to the violation dated September 22,1995. Of particular note

was the licensee's actions to develop a contractor contract specification for use in

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establishing contracts with contractors. A guidance document for use by station staff

when utilizing contractors was also developed.

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(Closed) Unresolved item 95-27-01

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During a previous inspection, the inspector was not able to verify licensee conformance

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with 49 CFR 172 Subpart H training requirements. Specifically, the licensee was not able

to provide sufficient records to indicate provision of appropriate training, identity of target

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populations who should have received the training, or a training plan for those individuals.

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The inspector's review indicated that the licensee reviewed the work activities of station

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work groups in order to evaluate the need to provide specific training relative to 49 CFR

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172 Subpart H requirements, identified the target populations needing the training, verified

that appropriate personnel had received the required training, and verified that a training

plan had previously been in place. The licensee determined that appropriate training had

been provided. The inspector selectively reviewed the training provided, including the

target populations, and concluded that appropriate training had been provided, including

"

certification.

4

S1

Conduct of Security and Safeguards Activities

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S1.1 Control of Safeguards Information

On July 10, PECO reported, according to 10 CFR 73.71, that a number of documents

containing safeguards information had not been properly controlled. PECO implemented

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appropriate controls for the affected documents. PECO subsequently reviewed the event

and indicated that the uncontrolled documents did not impact any plant safeguard

capabilities. The NRC plans to review this event during a future specialist security

inspection.

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V

MANAGEMENT MEETINGS

X1

Exit Meeting Summary

At the conclusion of the report period, on September 19, the inspectors discussed the

findings and conclusions and the overall period conclusions with members of licensee

management. In all cases the licensee acknowledged the findings and conclusions

presented,

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LIST OF ACRONYMS USED

Alternate AC (AAC)

Automatic depressurization (ADS)

Department of Transportation (DOT)

Design basis accident (DBA)

Emergency core cooling systems (ECCS)

Emergency diesel generators (EDGs)

Emergency service water (ESW)

General Electric Service information Letter (GE SIL)

Health physics (HP)

i

High pressure coolant injection (HPCI)

High pressure service water (HPSW)

Loss of coolant accident (LOCA)

Loss of offsite power (LOOP)-

Nuclear maintenance division (NMD)'

Performance enhancement program (PEP)

Preventive maintenance (PM)

Reactor core isolation cooling (RCIC)

Reactor water cleanup (RWCU)

Residual heat removal (RHR)

Safety relief valve (SRV)

Shift update notice (SUN)

Standby gas treatment (SBGT)

Standby liquid control (SLC)

Surveillance requirements (SR)

System operating (SO)

Updated final safety analysis report (UFSAR)

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