ML20148C223
| ML20148C223 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/07/1997 |
| From: | Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| 50-277-97-03, 50-277-97-3, 50-278-97-03, 50-278-97-3, NUDOCS 9705150191 | |
| Download: ML20148C223 (3) | |
See also: IR 05000277/1997003
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May 7, 1997
Mr. D. M. Smith, President
PECO Nuclear
Nuclear Group Headquarters
Correspondence Control Desk
P. O. Box 195
Wayne, Pennsylvania 19087-0195
Dear Mr. Smith:
SUBJECT:
INSPECTION REPORT NOS. 50-277/97-03 & 50-278/97-03, RESPONSE TO
This refers to Mie +elephone conference held on April 15,1997 between
Einssrs. G. Lenly!!i and R. Smith of your organization end Messrs. J. White, R. Nimitz, and
'As. L. Peluso of t.iis office. The purpot,e of the telephone conference was to discuss
deficiencies we noted in your March 20,1997 response from Thomas N. Mitchell to our
letter, dated February 10,1997, which identified two violations resulting from our
inspection of your activities. These violations involved f ailure to assure that the turbine
building atmosphere was processed through the turbine building gaseous waste treatment
system as specified in the Offsite Dose Calculation Manual (ODCM), and failure to provide
an adequate safety evaluation to support certain aspects of modification to the turbine
building in accordance with 10 CFR 50.59.
During this telephone discussion we conveyed several concerns with the response.
Principally, the discussion of reasons for the violations did not clearly identify root or
proximata causes. Accordingly, we could not conclude that the corrective actions you
specified effectively addressed the causes of the violation. Additionally, your response
indicated that your safety evaluation was based on the premise that the Turbine Building
was maintained at a negative pressure so that air would n: be expected to be released
through the penetrations. However, no information was provided as to why the Turbine
Building was not maintained at a negative pressure, as presumed by your safety
evaluation. Further, no commitment was made to document and report your estimate of
the unmonitored release as specified in Technical Specification 5.6.3 and ODCM
requirement 3.10.2.
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Mr. D.M. Smith
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Based on this telephone discussion, we understand that you will submit a supplemental
response to these violations by May 17,1997 in accordance with the instructions provided
in the Notice of Violation conveyed in our February 10,1997 letter. In accordance with
10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and your response
will be placed in the NRC Public Document Room (PDR).
Sincerely,
- fEG 'mpsila,
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James T. Wiggins, Director
Division of Reactor Safety
Docket Nos. 50-277; 50-278
License No. DPR-56
cc w/ encl:
G. A. Hunger, Jr., Chairman, Nuclear Review Board and Director, Licensing
T. Mitchell, Vice President, Peach Bottom Atomic Power Station
G. Rainey, Senior Vice President, Nuclear Operations
D. B. Fetters, Vice President, Nuclear Station Support
T. Niessen, Director, Nuclear Quality Assurance
A. F. Kirby,111, External Operations - Delmarva Power & Light Co.
G. Edwards, Plant Manager, Peach Bottom Atomic Povver Station
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G. J. Lengyel, Manager, Experience Assessment
J. W. Durham, Sr., Senier Vice President and General Counsel
J. A. Isabella, Manager, Joint Generation, Atlantic Electric
W. T. Henrick, Manager, External Affairs, Public Service Electric & Gas
R. McLean, Power Plant Siting, Nuclear Evaluations
J. Vannoy, Acting Secretary of Harford County Council
R. Ochs, Maryland Safe Energy Coalitiois
J. H. Walter, Chief Engineer, Public Service Commission of Maryland
Mr. and Mrs. Dennis Hiebert, Peach Bottom Alliance
Mr. and Mrs. Kip Adams
L. Jacobson, Peach Bottom Alliance
Commonwealth of Pennsylvania
State of Maryland
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TMI - Alert (TMIA)
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Mr. D.M. Smith
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Distribution w/ encl:
Region 1 Docket Room (with concurrences)
K. Gallagher, DRP
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Nuclear Safety information Center (NSIC)
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D. Screnci, PAO (1)
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NRC Resident inspector
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PUBLIC
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DRS File (1)
W. Dean, OEDO
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J. Shea, NRR
J. Stolz, PDI-2, NRR
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inspection Program Branch, NRR (IPAS)
R. Correia, NRR
D. Taylor, NRR
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DOCUMENT NAME: G:\\RSB\\ WHITE \\PB970303. REP
To recche a copy of this
kate in the box: "C"=
without attachment / enc)osure T = Copy with attachment / enclosure
'N' = No copy
OFFICE
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DATE
04/f /97
04/26/97 //
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OFFICIAL RECORD COPY
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ThommaN.Mitch ll
Vce President
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Peach Bottom Atomic Power Station
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PECO NUCLEAR
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1848 Lay Road
A Unit of PECO Energy
Deha.PA 17314-9032
717 456 4000
Fax 717 456 4243
March 20,1997
Docket Nos. 50-278
License Nos. DPR-56
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U. S. Nuclear Regulatory Commission
Attn.: Document Control Desk
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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:
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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
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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
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.
if you have any questions or desire additionalinformation, o not hesitate to
contact us.
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Thomas N. Mitchell
Vice President,
Peach Bottom Atomic Power Station
Attachments
CCN #97-14016
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cc:
W. T. H::nrick, Public Ssrvice Electric & Gas
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R. R. Janati, Commonwealth of Pennsylvania
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H. J. Miller, US NRC, Administrator, Region 1
W. L. Schmidt, US NRC, Senior Resident inspector
H. C. Schwemm,VP - Atlantic Electric
R. l. McLean, State of Maryland
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A. F. Kirby lli, DelMarVa Power
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RESPONSE TO NOTICE OF VIOLATIONS 97-03-01 & 97-03-02
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Restatement of Violations
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..., do is not involve an unreviewed safety
question.
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Contrary to the above, on July 18,1996, the licensee made a change to the
facility that involved penetrating the turbine building wall that was not
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 c6ntrol of
radioactive effluents, and for maintaining the doses to members of the public
from radioactive effluents as low as reasonable achievable, conforms to 10 CFR 50.36a. The program shall be contained in the ODCM, be implemented
by procedures, and include remedial actions to be taken whenever the program
limits are exceeded. The program shallinclude:(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
ODCM.
Offsite Dose Calculation Manual 3.8.C.5 indicates that the turbine building
atmosphere is processed through permanently or temporarilyinstalled
equipment in the turbine building and the vent stack prior to discharge. m
addition, the UFSAR (Section 10.15.3) describes that exhaust ventilation air
from the turbine building and radwaste 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
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atmosphere, exhausted through penetrations in the turbine building wall, was
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processed through permanently or temporarilyinstalled 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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Reasons for the Violations
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Modification P00248 involved the construction of the new Plant Entrance and
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Radiological Laboratory Building. Associated work activities included penetrations
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to be made in the west wall of the Unit 3 Turbine Building to installventilation duct
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supports. On July 16,1996 a sample hole was cut in the west wall of the Unit 3
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Turbine Building for radiologicalcontrols to smear the work area. The smearwas
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counted and determined to be clean. On July 18,1996 the first of seven 3' x 5'
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openings was cut for duct support installation. It was at this time a worker who
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was working on the outside of the Turbine Building was identified with short-lived
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activity (less than 100 counts per minute) on his hand. On July 19,1996 a Health
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Physics (HP) supervisorinstructed workers on the radiologicalhazards of short-
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lived activityand RCA exit requirements. Subsequently,five of the seven
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openings were cut in the Turbine Building. Following this incident, various HP,
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Chemistry, Project Management and Engineering personnel performed several
walkdowns and inspections of the work area. Temporary flat sheeting was
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observed installed over the corrugated outer wall of the Turbine Building and air
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. liow was felt flowing from inside the Turbine Building to the outside. An air sample
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was taken inside the Turbine Building near the openings on July 25,1996 that
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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.
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During modification design activities prior to work performwce, a 10 CFR 50.59
safety evaluation was prepared to support the modificat',on work. Although the
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design activities on which the safety evaluation vsas based and developed
considered the Turbine Buiidng ventilation system, the potentialfor a release
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pathway was not thoroughly eveluated and documented in the safety evaluation.
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Specifically,the safety evaluation dd not reference the ODCM and provida
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justification for any deviation from the ODCM requirements. The safety evaluation
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
Building penetrations. Therefore, a contingency plan for any potential outside
release paths or pockets of potential positive pressure was not developed for this
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interim configuration. As a result, the radiologicaireview of the work package did
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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 exhaused through
penetrations in the Turbine Building without being appropriately processed or
monitored.
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Corrective Steps That Have Been Taken & the Results Achieved Niclations 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 calculationwere 3.2E-5 mrem /yrtotal body and 5.1E-5
mrem /yr skin. This compares with ODCM limits of 500 mrem /yr total body and
3000 mremlyr skin.
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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 cwggated closure materialwas required to be available to reduce
the amount of umes 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 Further Violations 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 Evaluations to reinforce the use of the ODCM and other licensing 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 Compliance 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
radiological and 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.