ML20147F735
| ML20147F735 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/20/1997 |
| From: | Mitchell T PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9703270169 | |
| Download: ML20147F735 (5) | |
Text
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Thomas N.Mitchell Vice Presidein Peach Bottom Atomic Power Staton a
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'PECO NUCLEAR PECO Energy Company 1948 Lay Road 4
A Unit of PECO Energy gta P 7
9032 Fax 717 456 4243 March 20,1997 i
Docket Nos. 50-278 License Nos. DPR-56 j
i U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station Units 2 & 3 Response to Notice of Violation (Combined Inspection Report No.
50-277/97-03 & 50-278/97-03)
Gentlemen:
i In response to your letter dated February 10,1997, which transmitted the Notice of Violations concerning the referenced inspection report, we submit the attached response. The subject report concerned a radiological environmental monitoring program and meteorological monitoring program inspection that was conducted December 9,1996 through January 24,1997. The required date of response to the Notice of Violations was requested to be changed from 30 days from the date of the letter transmitting the violation to 30 days after receipt of the violation. The inspection report was received February 18,1997. An extension to the required i
due date of the response was granted via telephone on February 19,1997, by John R. White, Chief-Radiation Safety Branch, Division of Reactor Safety to Ronald K. Smith, Peach Bottom Experience Assessment.
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If you have any questions or desire additional information, do not hesitate to contact us.
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Thomas N. Mitchell
. I Vice President, y{
,I Peach Bottom Atomic Power Station Attachments CCN /197-14016 9703270169 970320 PDR ADOCK 05000277 G
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W. T. Henrick, Public Service Electric & Gas -
R. R. Janati, Commonwealth of Pennsylvania i
H. J. Miller, US NRC, Administrator, Region i I
W. L. Schmidt, US NRC, Senior Resident inspector l
H. C. Schwemm,VP - Atlantic Electric l
R. l. McLean, State of Maryland A. F. Kirby ill, DelMarVa Power I
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RESPONSE TO NOTICE OF VIOLATIONS 97-03-01 & 97-03-02 RestatementofViolations
- 1. 10 CFR 50.59(b)(1), states, in part, that the licensee shall maintain records of changes in the facility..., to the extent that these changes constitute changes in the facility as described in the safety analysis report. These records must include a written safety evaluation which provides the bases for the determination that the change..., does not involve an unreviewed safety question.
Contrary to the above, on July 18,1996, the licensee made a change to the facility that invols ed penetrating the turbine building wall that was not t
described in the safety analysis report. The safety evaluation record failed to provide the bases for the determination that the penetrations,which resulted in an unmonitored release to the environment, did not involve an unreviewed safety question.
This is a Severity Level IV Violation (Supplement IV).
- 2. Technical Specification 5.5.4 states that the program for the control of radioactive effluents, and for maintaining the doses to members of the public from radioactive effluents as low as reasonable achie c able, conforms to 10 CFR 50.36a. The program shall be contained in the ODCM, be implemented 4
by procedures, and include remedial actions to be taken wheneverthe program limits are exceeded. The program shall include: (1) monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM; and (2) limitations to ensure gaseous effluent treatment systems are described in the i
ODCM.
Offsite Dose Calculation Manual 3.8.C.5 indicates that the turbine building atmosphere is processed through permanently or temporarily installed equipmentin the turbine building and the vent stack prior to discharge. In addition, the UFSAR (Section 10.15.3) describes that exhaust ventilation air from the turbine building and radvraste building is discharged to the atmosphere from the (monitored reactor building vent stack) roof.
Contrary to the above, from July 18 to July 29,1996, during a modification to the turbine building, the licensee did not assure the turbine building i
atmosphere, exhausted through penetrations in the turbine building wall, was processed through permanently or temporarily installed equipment, and vented and discharged to the atmosphere through the monitored reactor building vent stack.
This violation is a Severity Level IV Violation (Supplement IV).
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Reasor.s for the Violations L
l Modification P00248 involved the construction of the new Plant Entrance and j
Radiological Laboratory Building. Associated work activities included penetrations to be made in the west wall of the Unit 3 Turbine Building to install ventilation duct t
i supports. On July 16.,1996 a sample hole was cut in the west wall of the Unit 3 Turbine Building for radiologicalcontrols to smear the work area. The smear was l
counted and determined to be clean. On July 18,1996 the first of seven 3' x 5' j
apenings was cut for duct support installation. It was at this time a wor ker who was working on the outside of the Turbine' Building was identified with short-lived activity (less than 100 counts per minute) on his hand. On July 19,1996 a Health i
Physics (HP) supervisor instructed workers on the radiological hazards of short-1 lived activity and RCA exit requirements. Subsequently,five of the seven openings were cut in the Turbine Building. Following this incident, various HP, j
Chemistry, Project Management and Engineering personnel performed several l
walkdowns and inspections of the work area. Temporary flat sheeting was 4 -
observed installed over the corrugated outer wall of the Turbine Building and air flow was felt flowing from inside the Turbine Building to the outside. An air sample I
was taken inside the Turbine Building near the openings on July 25,1996 that identified short-lived activity, but no long-lived isotopes. A meeting was held on
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July 29,1996 with various work groups where it was decided to stop work until appropriate compensatory measures could be developed and implemented.
During modification design activities prior to work performance, a 10 CFR 50.59 i
safety evaluation was prepared to support the modification work. Although the design activities on which the safety evaluation was based and developed considered the Turbine Building ventilation system, the potential for a release j
pathway was not thoroughly evaluated and documented in the safety evaluation.
j Specifically,the safety evaluation did not reference the ODCM and provide i
justification for any deviation from the ODCM requirements. The safety evaluation j'
was based on the premise that the Turbine Building as a whole was maintained at a slightly negative pressure so that air would not escape out through the Turbine j
j Building penetrations. Therefore, a contingency plan for any potential outside i_
release paths or pockets of potential positive pressure was not developed for this l
interim configuration. As a result, the radiologicaireview of the work package did i
not consider or include requirements to monitor air flow. The failure to adequately consider and document the potential for an outside release with appropriate contingencies resulted in Turbine Building atmosphere being exhausted through
. penetrations in the Turbine Building without being appropriately processed or monitored.
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Corrective Steos That Have Been Taken & the Results Achieved Niolations 1&2)
An air sample was taken on July 25,1996 when it was realized that the atmosphere from inside the Turbine Building was flowing outside. Dose rates were calculated from the sample using a conservative assumption that the outside release was 10 percent of the total Reactor Building vent flow (2E4 cubic feet per minute). Results of that calculation were 3.2E-5 mrem /yr total body and 5.1E-5 mrem /yr skin. This compares with ODCM limits of 500 mrem /yr total body and 3000 mrem /yr skin.
Work activities were stopped on July 29,1997. The following conditionswere developed and required to be implemented prior to work being allowed to continue:
- 1. Information was added to the work orders to work only one opening at a time.
This reduced the area open to the outside environment.
- 2. Permanent corrugated closure material was required to be available to reduce the amount of times the penetration was open to the outside environment.
- 3. HP was required to take appropriate air samples during the work evolution to monitor and controlwork.
Corrective Steos That Will Be Taken to Avoid FurtherViolations Niolations 1&2)
Personnelinvolved in this incident will present lessons learned from the event to appropriate individuals who are qualified to perform 50.59 determinations and Safety Evaluationsto reinforce the use of the ODCM and otherlicensing base documents.
This event will be communicated to appropriate personnelinvolved in the work planning process. Additionally, communication of lessons learned from this event will be presented through the PECO Nuclear Newsletter' PECO Nuclear Experiences'.
Date When Full Comoliance Was Achieved Full compliance was achieved for the violations on July 29,1996 when work activities were stopped and the work package was revised to include proper radiologicaland work control precautions. These actions precluded the potential for an unmonitored release due to temporary monitoring and included precautions that should have been addressed in the 50.59 safety evaluation.