ML20195E882
| ML20195E882 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, Waterford, Comanche Peak, Crane |
| Issue date: | 06/15/1988 |
| From: | Grimsley D NRC |
| To: | Boley K Public Citizen's Critical Mass Energy Project |
| Shared Package | |
| ML20195E886 | List: |
| References | |
| FOIA-88-25 NUDOCS 8806240150 | |
| Download: ML20195E882 (9) | |
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INFORMATION ACT (FOIA) REQUEST v
JUN 151988 ee..
ooc.it si. s~ es it Qu'iS t t a Boley, Kenneth PART 1.-RECORDS RELI ASED OR peOT LOCAftD ISee checked 6osesi No agency records subect to the 'equest have been located
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No addetonal agency records swbiect to the request have been located Agency records sub,ect to the request that s's contif ed e Append.m _ D are already available for punc irepecton and copying m the NRC Pw%c Document Room.
y 1717 H Street. N W, Washington. OC agency records sst,ect to the roovest thrt s'e denti ied e Appenom - C -E,- F r4 e t*+9 ** * * 'or pope escutoe and coeveg se toe NRC Put+c occum.ri f
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Room 1717 H Street. N W. Wasaegton. DC, m a folder under th*s FO A arte' a e 'equester came Ihe moepropretari ge'sson of the Groposaksl that you 4@'eed to acCect e a fMchcre.'O%ersation evth a fremter of few staff is rWe toeg reaje 3, stable for pub c enspecten and Coving at the NRC PwMC DCCument Room,1717 H $treet, N W Mshegton. DC. e a folde* weder the FOtA number and 'equester name inclosed es eformaton on hovir yow may obtae access to and the cha'ges for Copv5P9 WOrds placed m the NRC Pu%C Document Room.1717 H S'reet. N W, Washeg*v, DC.
g Agency records m.,btect to the request are enclose # Any applicable charge for copes c' t*w records provided and cavment procedures Fe noted m the comments secton.
Records subject to the request Pfve been referfed to another Fede'al agencytest for rFN* and direct response to you in ve of NRC 3,esporae io the request no foreher acton e eeirg u.ee on sepe.i e e, dated - _
PART ll.A-INFORMATION WITHHELD FROM PUBLIC DISCLOSURE Certa n informaron en the requesied records e boeg wthheld from cubl*c d'setosw e sv%snt to the Fot A esemptoms described e au for the reasons s sted e Pa't it, sec-e X
tons 8, C. and D Any re4ased Cortsoes of the docwmeets for *Ach orWV Da't of tM Word is beeg wthheld are beq reade avadatse for pw%c esCecton and Copying e the NRC Pw%c Docurrent Room,1717 H St'tet. N W, Washington. DC e a fosoer i.wr this FOIA numcer ar.d requester name Corerrents
- Copies of the records identified on Appendix C,1-11, Appendix E,1-4, Appendix F,1-17, and Appendix G document number is are enclosed.
j We have been inforried by the staff that publicatio-NUREG-0525 is also subject to the request. A copy of this publication may bt purchased at the PDR or:
U.S. Government Printing Office Superintendent of Documents i
P. O. Box 37082 Washington, DC 20013-7982 Telephone: 202-275-2060 Additional records subject to your request have been identified in responses to a previous FOIA request and its appeals.
These responses are maintained in the PDR in folders FOIA-87-90 and F01A appeals 87-A-36 and 87-A-52 under the name of Bauman.
You may obtain copies of those records by referring to the above F0IA folders.
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G 8806240150 000615 PDR FOIA BOLEY 80,25 PCR
JUN 151988 FREEDOM CF INFORMATION ACT RESPONSE FOiA NUMIE2 St.
F01A-88-25 out PA27 to B-APPLICAOLE FOfA EXEMPTIONS necords suthect to the request that are descri.ed in the enclosed Appendices M.1_M are being ethheld en thair entirety or m part under FOtA 8
Exemptons and fof the reasons set forth below pursuant to 5 U.S C. 5521bl and 15 Cnt s siai of NRC Regutatens.
- 1. The wthhe6d irdormaton e property classfed pursuant to Executrve Order 12356 (EXEMPTCN 1)
- 2. The wthheM information reistes soiety to the internal personnel rules and procedu es of NRC- (EXEMPTON 21 r
- 3. The withhe6d informaton e specAcaay enentted from pv%C drsclosure by statute endicated. (EXEMPTON 3l Secten 141145 of the Atomic trergy Act Nch prohibits the deciosure of Restncted Data or Former+v Restncted Data i42 U $ C. 21612166>
Secten 147 of the Atormc Enera, Act *Nch prohets the doctosure of Unclass,fied Sa'egweds infewton 142 U.S C 21671
- 4. The wthheld eformaton e a trade secret or commerce or feanc$ eformaton that is being *rthheid for the reasorval indicated ' EXEMPTION 41 The eformaton e cons 4ered to be conf 4 ente bwoness (propretarvi eformaton.
The eformaton a cons 4ered to be propretat eformaton puesvant to 10 CFR 2.790tdH11.
The informatica was submrt+ed and recorved e conteence from a fore $n source pursuant to 10 CFR 2 790edn21.
- 5. The wethheed informaton connets of eteragency or etraagency records that are not avadable through decovery dureg htsaten. Decioswee of predecoccalinformaton
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would tend to enhibit the open and feart enchange of ietas esseetel to the dobberstrwe process Where records are wthheld en ther entrety, the facts are cettncab8y e,emed um me p,edeceo,. et-con Th.re si.e.,e no c.nnnauv uoresswo fact a po,t,ons b.ca me reino of th. facu.ooid p.rma en an@ rect inquary eto the predececr$ process of the agency. (EXEMPTION 5) 6 The wthheid etymation e esempted from putAc dscioswee because its declosure novid result in a c$ea4v unwananted invasion of sersonal privacy. (EXEMPTON 6)
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- 7. The withbe64 eformaton conssts of ewestgatory records compsed for ten enforcement pu pons and e teing weed for the ruson(s) edicated (EXEMPfl0N h r
oiscioso,e id ete ere.* an en+orcem.ni procading becas ei covid revesi me scop.. dir.cion. and focos v.nfo,c.,neni.norts. and mus cooM posmory snow enem to taae acton to sheid potentei wrongdoing or a volaton of NRC reos,oreents from evestgators (EXEMPTON 7(AP Deciosure
- owed constnuta an vnwonanted e.asion of persor* prwacy iEXEMPTCN hCH The snformaton consets of naaes of ededwais and other eformaton tN dociosure of wh.ch would revul coatites of confeeatet sources. iEXEMPTON h0H PART 11 C-DENylNG OFFICIALS Pursuant to 10 CFR 9 9 and or 915 of the U S. Nweteer Regulatory Commason regutetens. n has toen cietermined that the eformaton withheid e eienet from producten or deciosw e e
and met,is p,oducten o, dociose,e e contrarv io te pubac interest. The persons reioons.bie for the deni.: ar. those onice,ns id.niifed beio, as dea es o+fece.s and the v
oivoon e Row and Reco,ds. Omce e Aomestreon. ior any een+s mai may be app.ad io me Eoco,e o,ecio, fo Operatons e OENviNG OFFICIAL TITLL OF FIC E RECOROS DENIED APPELLATE OFFICIAL Director Office of As indicated on secn=
ipo Ben B. Hayes s
Investiaations appendices E, F and G X
PART 11 D-APPEAL RIGHTS The denial by each denying offmeiidentded in Part ll.C may be oppealed to the Appellate Official identified in that secton, Any such appeal must be in writing and must be made wthin 30 days of receipt of this response. Appeals must be addressed as appropriate to the Enecutrve Deector for Operations or to the Secretary of the Commessaan, U S. Nuctear Regulatory Commission Washmgton, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an Wtel FOIA Deceon."
secc poRu aos teori ti U S, NUCLEAR REGULATORY COMMISSION
- i. e FOIA RESPONSE CONTINUATION
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APPENDIXC RECORDS ret. EASED TO REQUESTER da i f t<cb>v$O Ifa a )
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APRENDIX h DOCUMENTS AVAILABLE IN THE POR F0IA REQUEST NUMBER 88-25 OATE ORIGINATOR RECIPIENT DESCRIPTION 4/29/87 PNO-1-87-38 (Accession W. 8705040185) 6/2/87 R. Gallo, NRC, C. A. McNeill, Jr.,
Combined Inspection Region 1 PSE&G 50-272/87-12 and 50-311/87-15 (Accession No.
8706090174) 7/87 NUREG-0525, Rev.13, Safeguards Summary Event List (SSEL) Pre-NRC through December 31,1986 (Accession No. 8708240212) 11/23/87 E. Wenzinger, NRC, W. Josiger, New York Insp. Report 50-286/
Region I Power Authority 87-24 (Accession No.
8712010239) 9/11/86 Preliminary Notification of Event or Unusual Occurrence
-- PN0-1-86-72. (1 page) (ACCESSIN NO. 8609160438) 10/2/86 Preliminary Notification of Event or Unusual Occurrence
-- PHO-1-86-72A. (1 page) (ACCESSICN NO. 8610090443) 11/02/82 Transmittal ltr w/ inspection Report No. 50-295/81-32(DETP)'
50-304/81-40(DETP)
( (, p ACCESSION NO. 8211080277 gg* d
FOIA 88-?S 9 f f E NOlg E-c 3e,1,enne)
WITHHOLDING EXEMPTION NO.
1.
Various Investigation Status Record (1page)
Release 2.
08/20/86 Transmittal memorandum, White (1 page)
Ralease to Murley 3.
08/20/86 Report of Inquiry Q1-86-011 (3 pages)
Portions, 6 & 7(c) 1 08/06/86 Report of Interviaw with individual (3 pagas)'
Portions, 6 6 7(C) 4 (Exhibit 2)
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Pe: F919-J8-2' (ire N rtial) i APPENDIX F WITHHOLDING DETERMINATIONS 1.
03/20/84 Routing Slip to Hayes, Fortuna &
(1 p)
Release i
Ward from Gilbert 2.
09/27/84 Investigation Status Record (1 p) 7(0), portions 3.
10/03/84 Handwritten Note (1 p) 7(0), entirety 4
11/06/84 Memo to File, thru R. Herr, (3 pp) 6,7(C),&
from D. Driskill 7(D), portions 5.
11/23/84 Handwritten Investigator's (3 pp) 5, entirety Notes 6.
12/03/84 Memo to Jeanne from Connie (1 p)
Release 7.
12/20/84 Memo to File f rom B. B. Hayes (1 p) Release-Portions Outside i
Scope of Request 8.
01/09/85 Fascimile Sheet with (3 pp)
Release attachment 9.
02/05/85 Memo to Tea Gilbert (2pp)
Release from R. K. Herr 10.
02/21/83 :'eno to Hayes thru llerr fron Driskoll (4 cages)
Release 11.
2/25/85 Fascimile Sheet with (3 pp)
Release *
Attachment:
Memo to R. D. Martin from B. B. Hayes, dated 2/22/85, ra: '
01 ossessmerit of L?t.L Renewed Inves'tigation 12.
02/26/85 Letter to V. Toensing (3 pp)
Release from B. Hayes 13.
02/27/85 Memo to R. D. Martin (2 pp)
Release
. rom B. B. Hayes 14.
02/27/85 Memo to B. Hayes from (1 P)
Release R. A. Fortuna
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l* 33-25 WE01XF (Continued) 15.
12/20/85 Hand.rltten investigator s notes (3 pp) 5, 6, 7(C) &
7(D), entirety 16.
Undated Typewritten investigatior's (2 pp) 5, entirety notes: re: Leddick 17.
// 7/36 Letter to Zech fre.a nared Indivicual (1 pace,'
6, T. 7C-portiens
- /.coE:iDIX n F0!A-88-025 WITHHOLDING DETERMINATIONS 1.
02/26/85 Report of Investigation 4-84-043 (19 pp) 6, 7(C) &
WATERFORD STEAM ELECTRIC STATION:
7(D), portions ALLEGED CONCEALMENT OF DRUG ABUSE ACTIVITY BY LOUISIANA POWER &
LIGHT REACTOR OPERATORS 2.
Exhibit I to ROI 4-84-043 (2 pp)
Confidentiality Statement (1 p) 7(D), portions (Confidential Source)
Report of Interview (1 p) 7(D), portions (Confidential Source) 3.
Exhibit 3 to ROI 4-84-043 (4 p)
Confidentiality Agreement (1 p) 7(D), portions (Confidential Source)
Report of Interview (3 pp) 6, 7(C) & 7(D),
(Confidential Source) entirety 4.
Exhibit 4 to ROI 4-84-043 (7 pp) 6, 7(C) & 7(D),
Typewritten and handwritten entirety Notes of Confidential Source 5.
Exhibit 5 to R01 4-84-043 (1 p) 7(D), entirety Memo to File (Confidential Source)
Exhibit 7 to ROI 4-84-043 (2 pp)
Release 6*
Report of Interview with W. Friloux, Jr.,
dated 11/19/84 7*
Exhibit 8 to ROI 4-84-043 (2pp)
Release Statement of W. C. Nelson dated,11/20/84 o.
Exhibit 9 to ROI 4-84-043 (3 pp)
Release Statement of J. M. Cain dated,11/20/84 J
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APPEl1 DIX G (Continued)
F01A-88-025 WITHHOLDING DETERMINATIONS 9.
Exhibit 10 to ROI 4-84-043 (63pp)
Release Transcript of R. P. Barkhurst dated,12/04/84 10.
Exhibit 11 to ROI 4-84-043 (3 pp)
Release Statement of W. Cavanaugh, !!!
dated, 12/05/84 11.
Exhibit 12 to ROI 4-84-043 (1p)
Release Statement of R. D. Martin dated, 12/07/84 10.
Exhibit 13 to ROI 4-84-043 (2 pp)
Release Statement of R. S. LeddicK dated,12/06/84 13.
Exhibit 14 to ROI 4-84-043 (2 pp)
Release Report of Interview with R. S. Leddick, dated 12/06/84 14.
Exhibit 15 to ROI 4-84-043 (1 p)
Release i
Supplemental Statement of 1
J. M. Cain, dated. 12/10/84 1o.
Exhibit 18 to ROI 4-84-043 (2pp)
Release Statement of R. K. Herr, dated. 02/25/85 l
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cs is es 18:29 NO.221 001 fall.!MINARY $0TIFICATf 0N OF $ANGUAR05 EVENT--PMS-V- 05 g May 13, Isas Thi$ preliminary ne'tification constitutes EARLY notice of events of POS$1SLE national secur'Ity or vblic interest significance.
The information presented is as initia11 received wit out. verification or evaluation and (a basically all that is Itngwn by !f
$thff as of this date.
LicenSte fatflency Classification:
FACllITY: Palo Yneda Nua.lvar Generating Station Units 1 and 11 Notif1C4tien of Unusual Event Wintersburg, Arizona jg Docket Hos. 50 520/50-529 Site Area Emergency 5
ARNISTS FGR SAtt Of DRtKi5 g
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1880t Applicable as a.rtst,1t of a savan-month undurcover investigation by the A'rizrma On May 13. 1905 Department of Public Saf ety (DPS) (State Police), six arrasts wara made for the sale of divy:. tu unden:cver of flycr0 of the DPS, by pursons do are either workers 41, or The arrests were for the selv v drugs who formrly worke+ at the Palo Verdo >14nt.
(prieerily cocaine) off the plant site and inciuda:
ona AP5 I AC maintwnante cwoloyee; one APS warehouse er.ployvet two AVS r,ccha'11 Cal meintenance employees, one contract employee of Volt, and one contract cmoloyee of Kelley Services.
The licensen is ravirri.ing the work complutud by the six sub.iects identified in the investigation to detemine their invol tetrPnt in critical safety-relat0d activities
..within the plant.
APs has notif' icd thefedia. The Artzona OPS and Region V hav responded to enedia inquiries.
The.1At was notified at 10:00 a.m., DDT, $y 13, 1965 This 18relininary Nutifleation is issued for infomation only.
This Inf unNLlun l> current as of 2:W o.m., PDI, May 13,' 1905.
COMTACT:
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N $4. 2.'.7 6 Nill-hhillits t/W h1NiN" Air Rights Mail Cha ruan Palladino 100 M tR '
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RElitBI T P0lM POR Resident inspector _
(3/17/83)
't PUBLIC CITIZEN Buyers Up C Corps: Watch C Cnucal Moss O Health Research Group a UUgation Group C Tax Croup January 7, 1988 Don Grimsley, Director Division of Rules and Records Nuclear Regulatory Commission NEDOM OF INFORMADOM MNBB 4210 ACT RE
[ h ] QUESTgg Washington, DC 20555 Attn Freedom of Information Act Request g,
Dear Siri Pursuant to the federal Freedom of Information Act, as amended, 5 U.S.C. S 552, Public Citizen's Critical Mass Energy Project hereby requests copies of any and all records that provide:
- 1) Accounts of incidents involving licensed reactor operatcra and senior reactor operators in violation or possible violation of Fitness for Duty guidelines.
This includes, but is not limited to, any and all Licensee Event Reports and Preliminary Notices of Occurrence or of Safeguards about incidents of a licensed operator having used drugs or having been under the influer.ce of alcohol while on duty,
- 2) Information about the steps taken by the U.S. Nuclear Regulatory Commission or its licensees with regard to the licensed operators mentioned by Mr. J. Partlow of the Office of Nuclear Reactor Regulations at the "Briefing on Status of Implementation of Fitness for Duty Program" held in Washington, D.C.
on Tuesday, December 1, 1987, as recorded by Marilynn M. Nations of Ann Riley & Associates, Ltd.
On page 72 of the briefing transcript, Mr. Partlow mentioned these licensed operators as beino involved in the only five cases,of licensed operators being involved "in some sort of Fitness for Duty matter."" This request
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includes, but is not limited to, records containing information about the present status of their licenses and the nature of their Fitness for Duty involvement.
This request does not seek any information about any specific individual or records otherwise covered by Exemptions 6 or 7 of the Freedom of Information Act.
This request pertains to all records in the possession of the U.S.
Nuclear Regulatory Commission, its contractors or licensees.
In this request, "record" includes, but is not limited to, databases which contain the requested information or any other memoranda,
- reports, studies, reviews, letters, computer memories and printouts, audio and video tapes, movies and other forms of comunication, in the possession of any individual or office in the U.S. Nuclear Regulatory Commission, whether generated by the U.S. Nuclear Regulatory Commission, its contractors, or any other source.
215 Pennsyhurua Ave. SE O Washingtors DC 20003 O (202) 5464996
.g> e f?f???WN 0f
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Public Citizen's Critical Mass Energy Project is a nationally known non-profit public interest organization founded in 1974.
We will use these documents in a study we are presently researching and plan to issue on the adequacy of training programs presently in place for nuclear power plant workers.
We plan to broadly disseminate the information contained therein to the press and the general public.
Our past publications have attracted attention in the local, national and trade media.
Thousands of copies of the reports have been sold or distributed to members of the public, industry, and citizen groups.
Since furnishing these documents "will significantly contribute to public understanding of government opinions or activities" we request a complete waiver of any processing or duplicating costs you might incur in providing these records to us.
If you rule otherwise, please notify us before filling the request.
Nothing in this request should be considered a request for the private records of any specific individual.
Hence, no provisions of the Privacy Act should be deemed applicable.
If all or any parts of this request are denied, please cite the specific exemptions on which you rely in refusing to release the documents.
Further, since the Freedom of Information Act provides that the remainder of a file must be released if only portions are exempt from disclosure, we request that we be provided with all non-exempt portions which are reasonably segregable.
Of course, we reserve our right to appeal the withholding or deletion of any informstion.
As provided in the Freedom of Information Act, we will expect to receive the requested records or a final determination within ten working days.
If your office is unable to fully respond to this request in that time, send us a written ertimate of when the request will be completed.
If you have any questions about this request, please telephone me at 202-546-4996.
Thank you for your attention to this request.
Sincerely,
'ht K
ne Bo ey Nuclear S fety Policy Analyst critical Mass Energy Project of Public Citizen i
/@ Ceout*g UNITED $TATES i
e-n NUCLEAR HEGULATORY COMMISSION j
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KINO OF PRUS$1 A, PENNSYLVANI A 19406
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Qb Docket Nos. SC-277/0PR-44 g. 3 (4-06 50-278/DPR-56 Philadelp.hia Ele:tric Company ATTN:
Mr. John 5. Kemper I
Senice Vice President, Nuclear 2301 Market Street Philadelphia, Perinsylvania 19101 Gentlemen:
Subject:
Combined Inspection 50-277/88-01; 50-278/88-01 i
This transmits the findings of the routine resident safety inspection by Messrs. L. E. Myers, R. J. Urban, and T. P. Johnson on January 1,1933, to February 5,1988, at the Peach Bottom Atomic Power !tation, Delta,
)
These findings were based on observation of activities, interviens, measurements and document reviews, and have been discussed with Mr. J. M. Franz, Plant Manager at Peach Bottom.
A copy of this letter and the enclosures are being placed in the NRC Public Document Room.
A relatively new item appears in the attached inspection report (see Detail 12)
I covering the subject of assurance of quality.
Assurance of Quality is an area of evaluation NP,C has recently added to the SALP process. Activities at all levels of a licensee's organization are needed to assure quality.
We will be i
evaluating those activities in all functional areas.
Inspectice findings
)
applicable to the assurance of quality may be found in various details of inspection reports.
Noteworthy findings, both strengths and weaknesses, will be included in a separate detail item, as it is done in the attached report, when appropriate. Reporting guidance has been provided to our resident inspectors in this area. They will be glad to discuss it with you or your staff.
Areas examined during this inspection are described in the NRC Region I Inspection Report that is enclosed with this letter.
Based on the results of this inspection, it appears that one of your activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A.
This violation has been categorized by severity level in accordance with the revised General Statement of Policy and Procedure for NRC Enforcement Actions,10 CFR Part 2, Appendix C (Enforcement Policy 1987).
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P,hiladelphia Electric Company '
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The response requested by this letter is not su.c ct to the clearance procedures of the Office of Management and Budget as re; aired by the j
Paperwork Reduction Action of 1980, PL 96-511.
Your cooperation with us is apprecicted.
Sincerely, is! /'
~ad.,.
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,b gh' L William F. Kane, Director, Division of Reactor Projects
Enclosure:
NRC Region ! Combined Inspection Report No. 50-277/88-01 and 50-278/88-01 cc w/ encl:
Jack Urban, General Harager, Fuels Departtrent, Delmarva Power i
- 0. M. Smith, Vice President, Peach Bottom Atomic Power Station J. W. Gallagher, Vice President, Nuclear Services W. H. Hirst, Director, Joint Generation Projects Departeent, Atlantic 3
Electric J. F. Franz, Plant Manager, Peach Bottom Atomic Power Station Troy B. Conner, Jr., Esquire (Without Report)
Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)
Raymond L. Hovis, Esquire (Without Report)
Thomas Magette, Power Plant Siting, Nuclear Evaluations W. M. Alden, Director, Licensing Section E. C. Kistner, Chairman, Nuclear Review Board Doris Poulsen, Secretary of Harford County Council Public Document Room (PDR) local Public Document Room (t.PDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Pennsylvania i
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ApiENDIX A NOTICE OF VIOLATION Philadelphia Electri: Company Docket Nos. 50-277 Peach Bottom Atomic Power Station License Nos. OPR-44 Unit 2 Curing an NRC inspection conducted from January 1 to February 5.1983, a violation was identifiea in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C).
The particular violation is set forth below:
A.
Technical Specification section 6.8.1 requires th;.t written
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procecures be established, implemented, and maintained that neet the requirements of section 5.1 of ANSI N18.7-lis72, and Appendix A of Regulatory Guide 1.33 (November 1972).
ANSI N18.7-1972, section 5.1 requires the station to be operated in accordance with written procedures.
Regulatory Suide 1.33, Appendix A, section G, part 0, requires procedures for respirator equipment.
Health physics (HP) procedure Hp-500, key. O, "Respiratory Protection Program," requires all individuals to be responsible for using respiratory protective equipment for whicn they are qualified, and supervisors to be responsible for assuring that workers under their authority are using the correct respiratory equipment. HP-512, Rev. O, "Issue and Control of Respiratory Protection Equipment," requires issue control point attendants to 1
issue respiratory ecuinnt for which the it.fivid;tl is W. 'Utd.
Contrary to the above, on January 20, 1983, a worker was issued and used a mask which the worker was not qualified to wear with the apparent knowledge cf the worker's supervisor; and, the issue control point attendant issued a respirator (Ultraview mask) to an individual who was not qualified to wear it.
1 This is a Severity Level IV violation (Supplement IV)
Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company, is hereby required to submit to this office within thirty days of the date i
of the letter which transmitted this Notice, a written statement or 1
explanation in reply, including:
(1) the corrective Steps which have been taken and the results achieved; (2) ccrrective steps, which will be taken to j
avoid further violations; and (3) the date when full compliance will be achieved. Where gocd cause 15. shown, consideration will be given to extending this re*ponse time.
i l
uNTSd bY S M f
. - ~..
U. S. NUCl. EAR REGULATORY COMMISSION REGION I Decket/ Report No. 50-277/85-01 License No OPR-44 50-278/88-01 DPR-56
. censee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Pench Bottom Atomic Power Station Units 2 and 3
- specuen At: Deita, Fennsylvania Cates: January I to February 5,1983 1-spectors:
T. P. Johnson, Senior Resident Inspector R. J. Urban, Resident Inspector L. E. Myers, Resident Inspector Reviewed By:
h- [h/ /hbW A fdf
. H. Wil) ams, Pr ect Engineer date t
4 proved By:
b d
2// '). /
J: C. Wi nvi l l e,
- 14f,
/
ate P. actor Projec Section 2A, l
ivision of Re. tor Projects
~St.mma ry l
Areas Inspected: Routine, on site regular and backshif t resident inspection i
(167 hours0.00193 days <br />0.0464 hours <br />2.761243e-4 weeks <br />6.35435e-5 months <br /> Unit 2; 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> Unit 3) of accessible portions of Unit 2 and 3, j
operational safety, radiation protection, physical security, control room activities, licensee events, surveillance testing, refueling and outage activities, maintenance, and outstanding items.
i Results: One violation for failure to follow respiratory protection 1
procedures was identified (section 9.2).
Pieparations for Unit 2 "refuel" mcde operation and hydrostatic test were generally good (section 4.4).
4 However, a weakness was identified with re>; ect to QA/QC review of open items to suppert refuel mode and hydrostatic testing preparatinns (section j
4.4.4).
One violation for failure to follow circulattag. water system i
operating procedures was identified by the licensee (section 4.2.1).
This reculted in flooding a room. A special report for a liquid radioactive release was reviewed (section 5.0).
Reactor vessel shroud access hole cover 3
I cracking is unresolved (section 4.5.1).
An inattentive security watchman was identified by the licensee (section 10.5).
1 i
J
,7
%d W
,.......e Page 1.0 Persons Contacted............................................
1 2.0 Facility and Unit Status.............................
1 3.0 Previous Inspection Item Update.
1 4.0 Operations Review............................................
2 4.1 Station Tours........................
2 4.2 Followup on Events Occurring During the Inspection......
6 4.3 Logs anc Records....................................
9 4.4 Unit 2 Refueling Outage Activities..........
. 10 4.5 Unit 3 Refueling Outage Activities.....................
16 4.6 ingineered Safeguards Features (ESF) System Walkdown.... 18 4.7 Col d We a t h e r Pre p a ra t i on s.............................
19 5.0 Special Report On Radioactive Release.......................
20 6.0 Review of Licensee Event Reports (LERs)..................
21
- 7. 0 Surv e i l l a n c e Te s ti ng.......................................
22
- 8. 0 Ma i nte na n ce Ac ti vi ti e s.....................................
23 9.0 Radiological Controls.......
24 10.0 Ph>;ical Security....
27 11.0 Assurance of Quality...
31 12. 0 U n r e s o l v e d I t e m s..........................................
3 2 13.0 Management Meetings........................................
32
e DETAILS
- .0 Persons Contacteg
- T.E. Cribbe, Regulatory EngineerJ. B. Cotton, Superintendent, O "G. F. Caebeler,
- A. B. Connell, CA SupervisorSuperintender.;, Technical
'J.
F. Franz, Plant Manager
- 0. P. Le0aia, Superintendent, Services F. W. Polaski, Assistant Superintendent
- D. P. Potocik, Radiation Protection Manager
, Operations G. R. Rainey, Su;erintendent, MaintenanceK. P. Fewers, P D. M. Smitn, Vice President, Peach Bottom Atomic Po wer Statien Other licensee and contractor employees were also contacted.
'Present at exit interview on site and for summatien findings.
of prelimina ry 2.0 Facility and Unit Sta y 2.1 Unit 2 The u-4 t re-W er ir Refue'.ing outage recovery ef forts and reactora ::'d cc-period.
hydrostatic testing preparations continued d Control rod testing in the refuel mode was complet d vessel uring the period.
2.2 Unit 3 e.
replacement outage, which began on October 1The e period.
The pipe
- Fe end of retcval were complete and pipe cutting activititne inspectt0 By or pipe 3.0 Previous Inspection Item Update es were undernay.
1 i
3.1 As-Found Setpoints,(Closed) Unresolved item (277/86-25-09) in accordance with Docurentation of SRV IW-3510, as-found testing of relief and safety valthe ASYE Code, Se required.
tn be tested in accordance with IWV-3513Any valve that failed ves is a valves testing of SRVs had been performed in the pa tunreso
(
rmine if as-found j
passed or failed, ard to record these results is, whether they (ST) procedure 13.32, l
i n surveillance te:t
\\
\\
i i
2 Tre ir m -t:r deterrined threugh discussions with a.aintenance ermineer that a:,-found testing had not been performed in the past (prior to 1987).
To check for corrective actions, the inspector examinee m.; lyle Lcbsrasory n;o *s, ro iewed Si 13.32, "Safety and Relief Valve Replacement," Rev. 5A, (not yet PORC approved), and 0C1-020, "Instruction for the Establishment of Quality Asst. ance Requiremonts in Procurenent Documents," Rev. 2, 02/C2/33.
Wyle Laboratory is now performing as-found testing of all relief and safety valves received from Peach Bottom.
In addition, proposed revision (6) of ST 13.32 requires that the purchase ordar request as-found testing by Wyle Laboratory.
It also contains a chart to record the as-found lif t setpoints of removed SRVs and a formula to determine how many additional valves need to be tested if any fail.
In addition, step 7.4 of 0C1-020 requires that the purchase order request as found testing from the vendor.
Based upon the above information, this unresolved item is closed.
3.2 (0 pen) Unresoi<ec I.et (~4-277/57 25-03; 7,2-17L i7-25 C1j.
A Generator Lube Oil Fires in Exhaust Manifold.
This item was left unresolved pending licensee determination of root cause, implementa-tion of corrective actions ano determination of reportability.
Since the last incident of an apparent fire in the E-2 diesel generator exhaust on December 29, 1987, none have occurred. The E-2 diesel generator has been tested five times and the inspector has observed four of these surveillance tests (see section 7.0).
Lube oil leaking from the exhaust manifold as well as moderate seeking was observed.
However, no fires were evident.
This unresolved item remains open pending licensee and vendor evaluation.
4.0 Operations Review 4.1 Station Toun The inspector observed plant operations during daily facility tours. Most accessible areas of the station were inspected.
4.1.1 Control Room and facility shift staffing was frequently checked for compliance with 10 CFR 50.54 and Technical Specifications. The presence of a senior licensed operator in the control room was verified frequently.
Operator attentiveness to plant operations was determined to be adequate, l
l
3 4.1.2 The inspector frequently observed that selected control room instrumentation and recorder traces confirmed that instruments were operable and indicated values were within Technical Specification requirements and normal operating limits.
Engineered safety features system switch positioning and valve lineups were verified daily based on control room indicators and plant observations.
4.1.3 Selected control room of f-normal alarms (annur:iators) were discussed with control room operators anc shift supervision to assure they were knowledgeable of alarm status, plant conditions, and that corrective action, if required, was being taken.
In addition, the applicable alarm cards were checked for accuracy.
The operators were knowledgeable of alarm status and plant conditions.
4.1.a The inspector checked for fluid leaks by observing sump status, alarms, and pump-out rates; and discussed reactor coolant system leakage with licensee personnel, a.1.5 Shif t rdief and turnover activities were conttored daily, including periodic backshif t observations, to ensure compliance with administrative procedures and regulatory guidance.
No inadequacies were identified.
4.1.6 The inspector observed the main stack and both reactor building ventilation stack radiation monitors and recorders, and periodically reviewed traces from backshift periods to verify that radioactive gas release rates were within limits and that unplanned releases had not c: curred.
No inadequacies were identified.
4.1,7 The inspector observed control room indications of fire dete: tion ins;rumentation and fire suppression systert.5, monitored use of fire watches and ignition source controls, checked a sampling of fire barriers for integrity, anc observed fire-fighting equipment stations.
No inadequacies were identified.
4.1.8 The inspector observed overall facility housekeeping conditions, including control of combustibles, loose trash and debris.
Cleanup was checked during and after maintenance.
Plant housekeeping was generally acceptable.
4.1.9 The inspector observed the nuclear instrumentation subsystems (source range, intermediate range and power range monitors) and the reactor protection system (RPS) to verify that the required channels were operable.
4 During a olant tour en January 10, 1988, the inspe:ter noted that Quality Control (QC) non-conformance repcet (NCR) tags were hanging on two of the three Unit 2 reactor protection system (RPS) power supply panels (2BC757 and 2CC757) in the 4 KV switchgear rooms. QC NCR tags #CD-P-986-1 through 4 dated January 6 1988, documented a problem with the Brown-Bevert Corporation (BBC) undervoltage (UV) relays.
The inspector proceeded to the control room to pursue the operability of the RPS for Unit 2.
Unit 2 was in the cold shutdown condition with the reactor mode switch in the shutdown position.
Technical Specification (TS) 3.1 requires the RPS function (including the power supply panels system) to be operable while in the refuel, starty; or run modes.
Thus, the RPS was not required to be operable in shutdown mode.
However, control room licensed personnel were not aware of the NCR on the RPS. No documentation (e.g., LCO log, MRF log, equipment status log, plant status report, shif t turnover information, operator's log, etc.) could be found for the apparent RPS problem (except for the NCR tag).
On January 11, 1988, the inspector questioned QC personnel regarding the NCR.
Apparently a 10 CFR Part 21 repcrt had been nade by BBC regar:ing UV relays on December 23, 1987.
This was in response to a licensae concern of a relay failure at Limerick on June 11, 1987 (1.ER-87-012).
Electrical engineering had notified construction QC of the concern, and QC issued an NCR in acccedance with procedure ERDP-15.1, "Procedure for Handling Nonconformances", Rev. 12. Constru nicn QC rather than Operations QC had been notif te -Mause the RPS power supply panels were being change' Modification #1916.
However, at that timt
- WPS panels were turned over to operations in preps ition for hydrostatic testing (including placing the mode switch refuel). Apparently, ERDP-15.1 doesn t require a notification of operations when NCRs are identified.
The licensee stated that procedure QADP-9.1, "QC Procedures for Control of Nonconformances", Rev. 2, does require operations notification.
The inspector reviewed the associated documentttion including the LER, BBC and licensee letters TS 3.1, GP-11C (RPS Refuel Mode Operation), the QC NCRs, and plant operations review comt.iittee (PORC) minutes.
The inspector determined that the UV relay problem occurs when DC control power is reapplied to the RPS panels. The result is a f alse trip signal causing the UV relay to trip,
5 thus opening the RPS power supply breakers.
Thus, it is a fail safe condition (RPS de-energizes), which occurs only when the DC control power is reappl'ed af ter being deenergized.
The licensee is initiating corrective action to replace these UV relays.
This condition apparently dces not make RFS inoperable.
Repairs are scheduled prior to plant startup.
The inspector expressed concern that operations and control room personnel were unaware of an NCR on safety related ecuioment, The licensee stated that they agreed l
with the
- .or's concern.
Noreally operations QC l
NCR$ are a nted per procedure QADP-9.1 which includes
" ions notification for an e;uiptea.t operabili.,
..t e rmi n a t i on.
In this case, construction QC issued m e NCRs because of RPS modification activity.
The inspector stated that the licensee should cake the two NCR procedures consistent.
The licensee agreed and stated that the new proposed reorganization of QA would include a consolidation of procedur.
This item will be reviewed in e future inspection (se' i v sect't n 4.4.4).
No violatinns were noted.
4.1.10 The inspector frequently verified that the required off site electrical power startup sources and emergency on site diesel generators were cperacle, i
4.1.11 The ia.spe: tor monitored the frequency of in plant and control room tours by plant and corporate management.
The tours were generally adequate.
4.1.12 The inspector verified on a weekly basis, the operability of selected safety related equipment and systems by in-plant checks of valve positioning, control I
of locked valves, power supply availability, operating procedures, plant drawings, instrumentation and breaker l
positioning.
Selected major componerts were visually inspected for leakage, proper lubrication, cooling water supply, operating air supply, and general conditions.
No significant piping vibration was detected.
The l
inspector reviewed selected blocking permits (tagouts) for conformance with licensee procedures. No inadequacies l
were identified, l
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l
6 4.1.13 The inspe: tore cerformed backshift and weekend tours of the facility on the following days:
Sunday, January 10, 1988, 7:00 a.m. - 1:00 p.m.; Saturday January 16, 1938, 7:00 a.m. - 12:00 Noon; Friday, January 22, 1988, 2:00 a.m. - 6:00 a.m.; Sunday, January 24, 1988, 3:00 a.m. -
7:45 a.m.
4.1.14 The inspectors verified that the licensee's use of overtime was consistent with regulatory requirements and
~
administrative pec:edure A-40, "Working Hour Restrictions."
4.1.15 The inspector verified that the QC shif t inspectors were performing periodic control room tours.
4.2 Follow'.o On Events 0: curring During the Inspection t.2.1 Ur.it 2 Condensate Pump Pit Room Flood on January 14, 1988 On January 14, 1988, at 10:50 p.m., the 2C circulating water pump was starteJ in accordance with system operating procedure S.9.2.A.
At 11:14 p.m., Unit 2 turbine building floor and drain sump high level alarms actuated. A plant operator was dispatched to investigate. He reported that there was about 18 inches of water in the condensate pump pit room.
The 2C circulating water pump was immediately removed from service (about 11:20 p.m.).
The shift manager inspected the area with health physics personnel. No increase in radiation or contamination levels as noted.
The licensee began cleanup of the water and the room.
The water in the room was pumped to and processed by the radioactive waste systems.
The licensee's investigation determined that when the 2C circulating water pump was started, water leaked through a partially open six inch condenser water box vent valve (A2 manual gate valve).
A review of check off list (COL) S.9.2.A noted that the valve position was denoted as being "partially open" and "valve won't fully close on equipment trouble tag (ETT) #013914".
The reference to the ETT (equipment trouble tag) was reviewed.
A maintenance request form (MRF) #3-28-M87-7309 was written on September 3, 1987, identifying the problem with ti.i; vent valve. MRF investigation determined that the problem did not exist.
The MRF was subsequently cancelled.
7 The licensee identified two concerns:
(1) The circulating water system was placed in service with a known and documented valve out of position (COL S.9.2.A).
(2) The investigation of MRF 3-29 v?-7309 wa:
inaaequate as the identified problem was apparently not confirmed.
The inspector learned of this event during a control room tour at about 7:00 a.m., on January 15, 1988. The inspector reviewed the licensee's investigation, COL S.9.2. A, the MRF, the ETT, control room loos and procedure S.9.2.A.
In addition, the inspector toured the Unit 2 condensate pump pit room at 8:00 a.m.,
and noted that there was about six inches of water on the l
floor.
No water damage to any electrical equipment was noted.
The inspector also attended the 8:30 a.m.
morning management meeting in the control room.
This event was discussed and reviewed by plant management at this meeting.
The inspector examined the 2A water box vent valve and confirmed that the valve was partially open.
Verification was by valve stem position and by remote indicator position.
ETT #013914 was also vert fied to be attached to the valve operating handwheel.
The inscector discussed the event with control room
)
personnel including the shift supervisor.
The shift supervisor signed of f COL S.9.2. A in the "as reviewed by" blank.
The shift supervisor stated that he had noted the valve was out of position.
He also stated that he subsequently got involved in a Unit 3 evolution to run a reactor recirculation water ouro.
This apparently distracted him from the Unit 2 circulating water COL abnormality.
Technical Specification (TS) section 6.8.1 requires that written procedures be estslished, implemented, and maintained that meet the requirements of sections 5.1 and 5.3 of ANSI N18.7-1972, and Appendix A of Regulatory Guide 1.33 (November 1972).
Regulatory Guide 1.33 (November 1972) Appendix A, section 0, requires operating procedures for circulating water systems.
Procedure S.9.2.A, "Placing Circulating Water System in Normal Operation," Rev. 2, requires that COL S.9.2. A be performed prict starting any circulating water pumps.
However, the A2 water box inlet valve was open rather than in the closed position as required by COL S.9.2.A.
8 This out of position valve resulted in-the flooding of the Unit 2 condensate pump pit room.
Failure to follow procedure S.9.2.A and COL S.9.2.A is a violation of TS 6.8.1(277/88-01-01).
However, since the violation was licensee identified and the criteria of 10 CFR 2, Appendix C are met, no Notice of Violation is being issued.
In addition, no major equipment damage occurred, no misoperation of safety related equipment occurred, and no spill of radioactive water occurred. However, the inspector expressed concern over the apparent inattention to detail.
The inspector also discussec the event, including his concerns with licensee management.
Licensee corrective actions' included:
review of the event by the Human Performance Evaluation System, cleanup of wat r and pump room, repair c' the valve, discussions with the shift supervisor, attempting to identifying the engineer who investigated the MRF.
The inspector reviewed the corrective actions, discussed them with management and had no further questions at this time.
4.2.2 Unit 3 Reactor Protection System (RPS) Scram Signal on January 19, 1988 At approximately 9:15 p.m. on January 19, 1988, Unit 3 received a scram header low air pressure alarm in the control room.
The instrument air line upstream of the scram valve pilot air isolation valve (116) for control rod hydraulic control unit (HCU) 14-47 became disengaged at the swagelock fitting.
To isolate the leak, the air header was isolated, thereby allowing the entire HCU bank to bleed down.
The scram inlet and outlet valves for forty HCUs opened (the others were blocked for maintenance) allowing reactor water to drain into the scram discharge volume.
This resulted in a scram dischtrge volume high water level (50 gallon) scram signal. However, no actual scram occurred because portions of the RPS were defeated while the Unit 3 core is off loaded. All control rods were fully inserted and no rod motion occurred.
The air leak was repaired and the affected HCUs were returned to normal.
The licensee made a four hour ENS call at 10:50 p.m.
9 The inspector reviewed the licensee's investigatior.,
control room logs and the upset report.
The event was also discussed with licensee engineers and operators.
The licensee intends to submit an LER for this event.
The LER will be reviewed in a future inspection.
No violations were noted.
4.2.3 Unit 2 Group III Isolation on January 20, 1988 At 10:50 a.m., on January 20, 1988, a partial group III containment ventilation isolation occurred on Unit 2.
The cause of the isolation was a nameplate screw that became dislodged, fell into a control room panel, and caused an indicating light to electrically short.
This caused a fuse to blow in the containment logic resulting in de energization of r,everal containment valve solenoids.
No valve movement occurred as the valves were already closed.
The licensee retrieved the screw, replaced the fuse and inspected the panels for damage.
No damage was found.
A four hour ENS call was made at 1:30 p.m.
Unit 2 was in cold shutdown with reactor coolant temperature at about 150 degrees F at the time of the isolation signal.
The inspector reviewed the licensee's investigation, reviewed control room logs, interviewed personnel and examined the control room panels.
The licensee intends to submit an LER, and the inspector will review it in a future inspection.
No violations were noted.
4.3 Logs and Records The inspector reviewed logs and records for accuracy, completeness, abnormal conditions, significant operating changes and trends, required entries, correct equipment and lock-out status, jumper log validity, conformance with Limiting Conditions for Operations, and proper reporting.
The following logs and records were reviewed:
Control Room Shift Supervisor Log, Reactor Engineering Logs, Unit 2 Reactor Operator Log, Unit 3 Reactor Operator Log, Control Operator Log Book and STA Log Book, QC Shif t Monitor Log, Radiation Work Permits, Locked Valve Log, Maintenance Request Forms, Temporary Circuit Modification Log, and Ignition Source Control Checklists.
Control Room logs were compared with Administrative Procedure A-7, Shif t Operations.
Frequent initialing of entries by licensed operators, shif t supervision, and licensee on site management constituted evidence of licensee review.
No unacceptable conditions were identified.
1C 4.4 Unit 2 Refueling Outace Recovery Activities In preparation for the Unit 2 reactor pressure vessel hydrostatic test (RPV hydro), the inspectors reviewed plant system operability, procedures, PORC activities, training and QA/QC activities.
The following sections discuss areas reviewed during this report period.
4.4.1 Emergency Service Water (ESW) System The ESW system provides cooling water to the diesel generators and to emergency core cooling system (ECCS) room coolers in the event of a loss of normal service water.
Feach Bottcm has had a recent history of corrosien and fouling problems in ESW system carbon steel pipes.
As a result, reduced flow rates began to occur, especially in the core spray room coolers.
In an attempt to alleviate the problem, hydrolazing and chemical injection were performed in late 1985 and early 1986; however, only minimal success u s btained.
During the Unit 2.987 refueUng outage, monthly surveillance tt:. ' ;T) 91.F -2, "ESW Flow Test Through ECCS Room Cooler' 2HR 5 eel Coolers and Core Spray Motor Oil Coolers - Uni. 2," failed to completely pass.
Core spray room cooler 2CE57 failed to :neet the minimum acceptance criteria of 13 GPM, and other core spray room coolers were close to being unacceptable.
In response, the licensee initiated a safety evaluation to allow for a temporary reduction in allowable ESW flow rates to the core spray roo" coolers.
In late December 1987, during core spray pump testing, a test engineer noted that the 20 core spray pump motor was running hotter than the others.
Upon further investigation, the licensee found that ESW flow to the motor oil cooler was extremely low.
To correct the problem the 3/4" supply and return lines to the motor oil cooler were replaced in January 1988, when it was found to i
be fouled with mineral deposits.
To determine ESW system readiness for the RPV hydro, the inspector spoke with the system engineer and reviewed the safety evaluation, recent surveillance tests, the ESW P&lD, and observed maintenance activities to replace ESW motor oil cooler piping.
l
11 Core spray roorn cooler operability is necessary so that the core spray system can.be declared operable to support the performance of the RPV hydro. The safety evaluation dated November 24, 1987, reduced the minimum acceptable ESW flow rates to all core spray room coolers from 13 GPM to 8 GPM.
Licensee analysis determined that at S GDM with 71 degree F water, core spray room temperatures can be maintained below the limit of 126 degrees F.
The analysis is valid only during November through mid-April when the highest river water temperature recorded from 1970 to 1986 was 71 degrees F; the actual highest monthly average temperature during this time frame was 61 degrees F.
Also, the analysis is only valid for the performance of the RPV hydro, and the flow rates will be returned to acceptable values prior to Unit 2 restart.
The inspector found the safety evaluation to be acceptable based on the following facts:
ESW flow rates to core spray room coolers will be returned to acceptable values prior to Unit 2 4
startup; The temporary ESW flow rate reduction is only valid for the RPV hydro during unit shutdown; Current river water temperatures are far less than 71 degrees-F and the RpV hydro will be complete before mid-April; Decay heat removal requirements are minimal at this time; Only one of two room coolers need to be operable to declare tt core spray pump operable; and At least. ie of the two room coolers in each core spray room has a flow rate greater than 13 GPM.
Through discussions with the system engineer, the inspector was informed of future plans for the ESW systes. Before Unit 2 restart, selected ESW piping will be replaced so that adequate flow is restored.
Improvements in the ESW pipe replacement modification will be the use of pickled carbon steel pipe, clean out traps, spool pieces, plug valves with taps, and a redesigned system to reduce stagnant water in the piping.
Pickled carbon steel piping should reduce mineral deposits and resist corrosion better than
I2 non-pickled carbon steel piping. Clean out traps and spool pieces will allow for visual inspection and improved hydrolazing.
Plug valves with taps will provide improved flow measurement capabilities and system flow balancing techniques.
Eliminating stagnant water will reduce mineral deposition and corrosion as c'11 the continued use of chem.ical injection.
The inspector reviewed the performance of ST 21.5-2, which was conducted on 1/19/88 and 1/21/88. Flow rates in at least one of the two room coolers in each of the four core spray rooms was greater than the original minimum acceptance criteria of 13 GPM and the flowrate to all the room coclers was greater tnan tne nes acceptance criteria of 8 GPM.
However, the flow rate to cooler-DE58 in the C RHR pump room failed to meet the minimum acceptance criteria of 30 GPM.
To resolve the problem, the licensee updated the November 24, 1987, ESW flowrate safety evaluation to temporarily reduce ESW flow to the RHR room coolers.
The inspector reviewed Rev. 2 of the ESW safety evaluation dated January 22, 1988.
ESW flow to the RHR room coolers has been temporarily reduced from 30 GPM to 15 GPM.
Licensee calculations determined that this reduced flowrate with colder river water (less than 71 degrees F) would maintain the room temperature less than 128-degrees F during a design basis accident (maximum acceptable room temperature limit).
The inspector determined the safety evaluation to be acceptable based on the same reasons cited earlier in this section.
The inspector had no further questions or concerns regarding ESW system operability for the Unit 2 hydro.
No violations were noted.
4.4.2 Main Steam Relief and Safety Valves The purpose of the main steam relief and safety valves is to prevent over pressurization of the nuclear system, thereby protecting the process barrier from failure.
For the review, the inspector sposa with maintenance and test engineers, ar.d examined surveillance test (ST) procedures, Technical Specifications (TS), Wyle Laboratory Test Reports, and Section XI of the ASME Code.
13 The inspector revfewed ST 13.32, "Safety and Relief Valve Replacement," Rev. 5, dated 12/9/86.
ST 13.32 requires replacing at least five relief valves and one safety valve each operating cycle, with the intent that all valves be replaced every two cycles.
This ST is in agreement with TS 4.6.0.1 and is also more conservative ta-t'e ASv5 Code. S w "- Y!
u 3 9.,. 9, ST 13.32 Lad not ceen revise since an unresolved item was openec pertaining to recording as found lif t settings in the ST (see section 3.1).
The inspector questioned licensee engineers regarding the revision to ST 13.32. The ST had been revised and it was ready to go to the PORC for final approval.
I t
The inspector obtained a preliminary copy of Rev. 6 to ST 13.32. The as found lift pressures will be recorded t
on the data sheet for all future tests.
However, the inspector noted that the intent of TS 4.6.D.1 had been i
lost in proposed revision 6.
The inspector brought his I
concern to the attention of a maintenance engineer.
The procedure was revised and the inspector had no further concerns or questions on ST 13.32.
The inspector will review the procedure again after PORC approval.
l The inspector examined ST 13.32, Rev. 5, that was performed on November 19, 1987.
During the current refueling outage, five relief valves and one safety valve were removed and shipped to Wyle Labc,ratory for as found testing, refurbishment, and as left testing certification. One relief valve and one safety valve f ailed their respecthe as found lif t tests.
Relief valve #22 lifted at 1124 psig instead of 1105 2 11 psig and safety valve BL 1104 lifted at 1183 psig instead of 1230 12 psig.
In accordance with the ASME Code,Section XI, Subse: tion IWV-3513, one additional relief valve and one adi'tional safety valve were sele:ted #:-
testing. They bcth passed their respective as found lif t tests and no further actions were required.
To ensure relief valve operability for the automatic depressurization system (ADS), ST 20.131, "LLRT-ADS Accumulator Check Valve and Solenoid Valve Functional,"
Rev. 4, 7/17/87, is performed once per cycle. The inspector reviewed ST 20.131 performed on the following dates:
11/18/87; 12/02/87; 12/29/87; 01/07/83; and 01/11/88. At this point the licensee had determined that the A,B,G and K ADS relief valves were satisfactory. Hoaever, upon review of the 01/11/88 performance of ST 20.131, the inspector noted that the A ADS relief valve cet only one of two acceptance criteria. The irspector questioned a test engineer
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15 The meetings were conducted in accordance with Technical Specification 6.5.1 and administrative procedure A-4.
The inspector also verified that training on all applicable _ Unit 2 modifications was performed by reviewing training records and questioning licensed operators.
No unacceptable conditions were noted.
4.4.4 Ouality Assurance / Ouality Control (QA/QC) Activities to Support Vessel Hydro The inspector reviewed QA/QC activities in order to support placing the reactor mode switch in refuel and vessel hydrostatic test.
In section 4.1.9 of this report, the inspector noted that a construction QC nonconformance (NCR) tag was applied to the RPS power supply panel UV relay witnout the knowledge of operations personnel.
In further followup to this
- or:cer., the inspe: tor rs,'ewed in detail the QA/QC activities to verify that Unit 2 was ready for the refuel mode, and for subsequent hydrostatic testing.
The inspector questioned QA and QC personnel regarding open items (e.g., QA audit findings, stop work orders, QC NCRs, QA deficiencies, and other conditions adverse to quality) that may impact Unit 2 major milestones in general, and refuel mode and hydrostatic testing in specific.
The licensee has a Quality Assurance Trending and Tracking (QATTS) computer listing of all these open items. However, their potential affect on refuel mode and hydrostatic tests could not initially be determined.
QATTS only identifies open items that affect plant startup.
0A and QC personnel had no plans to perform an independent review of open items for potential impact on refuel mode and hydrostatic test operations.
General procedure (GP)-11C, "Reactor Protection System Refuel Mode Operation" and special procedure (SP)-1046, "Plant Conditions Necessary to Perform RPV Hydro",
delineate the requirements for system operability, open maintenance items, surveillance testing, completion of modifications, etc.
These items were reviewed by the inspector (see section 4.4.3).
However, there were no requirements for QA/QC to perform an independent review of these items and no requirement to perform a review of QA/QC open items.
This is a weakness.
The inspector
I 16 discussed this weakness with QA and QC personnel, e.'
licensee QA and plant management.
The licensee acknou-ledged this concern.
An independent search of QATTS was performed, and no new potentially adverse items were found that could affect refuel mode or hydrostatic test.
The licensee further stated that a review of QA procedures, the QA Plan and QA practices would be performed during the implementation of the proposed new QA organization.
No violations were noted.
4.5 Unit 3 Pipe Replacement Refueling Activities 4.5.1 Unit 3 Shroud Access Hole Cover Cracking On January 21, 1988, the licensee identified cracks in each of the two reactor vessel core support structure access hole covers on Unit 3.
These 20.5 inch diameter by 5/8 inch thick covers seal construction access holes in the shroud support ledge, which is at the bottom of the annulus between the core shroud and the vessel wall.
The covers and the shroud support ledge are Inconel Alloy 600 material; the connecting weld is also Inconel (Alloy 182 or 82).
The creviced geometry of the weld indicates the presence of an intergranular stress corrosion cracking (IGSCC) susceptible condition.
The welds were volumetrically examined using a custom ultrasonic test (UT) fixture developed by the vessel manufacturer (GE).
Intermittent short cracks were found in the weld heat-affected zone around the entire circumference of the covers.
It is estimated that cracking exists over 50% to 60% of the circumference with cusps as oeep as 70% through wall.
These welds have not previously been examined and this cracking may represent a generic concern for certain vessel types.
The licensee evaluated the postulated failure of the access cover.
Three initial concerns were raised:
Loose Part - In the event of complete failure of the access cover weld during normal reactor operation, the slightly higher bottom head area pressure would lift the cover out of its recess.
It would most likely fall to one side, but there is a potential for it to be swept into the recirculation pump suction line and cause severe pump damage.
17 Core Flow Bypass (Normal Operation) - Loss of one or both cover plates would allow some recirculation system flow to bypass the core, f rom the jet pump discharge'through the open access hole to the recirculation pump suction.
Core Flow Bypass (LOCA) - If the access hole cever plate welcs were to fail as a direct consequence of a recirculation-suction line break, the bypass path would prevent the emergency core cooling system from reflooding the core to the 2/3 level.
The inspector reviewed the licensee's initial evaluation dated January 26, 1988, and plant drawings of the access cover.
The inspector also discussed this condition, and various safety concerns that are pertinent to both Unit 3 and Unit 2 with licensee engineers.
Pending licensee (and vendor) evaluation including corrective a:tient, and s2seque.t NRC review, the cracked access covers are unresolved on both units (UNR 277/88-01-02; 278/85-01-02).
4.5.2 Unit 3 Drywell Inspection On January 20, 1988, the inspectors toured the Unit 3 drywell.
Items inspected included:
work in progress, health physics controls, housekeeping and cleanliness, high radiation and high airborne area postings, and ALARA practices. Overall house-keeping and cleanliness was satisfactory.
However, the inspectors noted a considerable amount of recent graffitti (as compared to the last Unit 3 drywell inspector tour) in the drywell. The inspector informed licensee engineers ard manage-ment of this observation.
The licensee initiated action to remove the graffitti, and to inform workers that this type of activity was unacceptable behavior.
The inspectors will continue to periodically inspect the drywell during the outage.
No violations were noted.
4.5.3 Plant Conditions to Support the Unit 3 Outage The licensee has written and approved a number of special pro-cedures (SP) to control and implement tb> necessary plant con-ditions for the Unit 3 pipe replacement activities. This includes SP-10608, "Overall Coordination Procedure for Recircu-lation Pipe Replacement," Rev. O, 01/14/88.
The inspector reviewed this procedure and selected temporary changes, independently verified the implementation of selected step, and discussed the procedure with licensee engineers and ope this.
) un'cceptable conditions were noted.
s' 18 4.5.4 Unit 3 Decontamination Results The licensee ccmpleted the. chemical decontanination of Unit 3
- c;;tcr recircuistion piping and the reactar w6ter cleanup system the first week of January 1988.
The low oxide metal ion method was used, (LOMI technique) followed by nitric permang-nate, and then completed with LOMI. As previously described in NRC Inspection Peport 278/87-24, this metted was thought to be-ef f ective in reducing the dif ficult to rer;ve chromate oxides.
In September 1987 this method was used on recirculation pump: A between the discharge and suction valves.
The results indicat'.
that the method was effective in reducing contamination and in lowering the radiation levels in the general area of the pump; so the method was used for the system. After chemical decon-tamination was completed, the pumps were run briefly to deter-mine if further reduction of exposure rates would occur.
The results indicate the method reduced general exposure levels by a factor of 2.7 in the overall areas of the RWCU system and contact levels by a factor of 7.4.
The re:irculatien sytter c4 ring excesure levels vero reduced by a factor 3.7 and contact by 14.7.
Tne actual expenditure of man-rem to do the decontamination was 30.1 compared to the estimate of 39.0.
The results of recirculation pump B impeller housing decontamination were not as effective as they were for the A pump.
3 The inspector reviewed the decontamination procedures, observed in plant. activities, and reviewed the licensee report of results.
No unacceptable conditions were identified.
i 4.6 Engineered Safeguards Features (ESF) System Walkdown The inspe: tor performed a detailed walkdown of portions of the Residual Heat Removal (RHR) system in order to independently verify the operability of the Unit 2 system. The RHR walkdown included verification of the following items:
Inspection of system equipment conditions.
Confirmation that the system check-off-list (COL) and operating procedures are consistent with plant drawings.
Verification that system valves, breakers, and switches are properly aligned.
Verification that instrumentation is properly valved in and operable.
l w
19 Verification that valves required to be locked have approcriate locking devices.
Verification that control room switches, indication; and controls are satisfactory.
Ver* cation that surveillance test procedures properly imple-ment the Technical Specifications surveillance requirements.
No unacceptable conditiors were noted.
4.7 Cold Weather Preparations In combined inspection report 50-277/87-02; 50-278/87-02, the inspector reviewed the licensee's cold weather preparation program.
In that report problems were noted concerning the timely completion of routine test (RT) 6.0, "Winterizing Procedure," Rev.
2, dated 11/15/82.
The celay was attributed to RT 6.0 being misplaced af ter it was submitted to typing for a revision.
Inspector followup was to be performed in a future inspection.
For this revie,v, the inspector examined RT 6.0 (Rev. 3, dated 02/18/87), spoke with maintenance personnel, and during a cold spell, walked down tanks and structures that would be susceptible to freezing.
RT 6.0 was started on September 30, 1987.
The procedure was entirely complete except for repairs to three outer screen heaters and a trash rake.
To compensate for the inoperable heaters, portable electric heaters were placed in service to help prevent freezing. A maintenance engineer stated that the three heaters would probably not be repaired until after winter because all heaters would be out of service if a blocking permit was applied.
The maintenance engineer stated that there were only three minor instances of freeze related problems that were brought to his attention. One was a drain line for the neutralizing tank in the water plant, the second was a chlorination line at the circulating water structure, and the third was general freezing problems at the outer screen structure before the portable electric heaters were installed.
The inspector toured exterior structures and tanks to spot check conformance with RT 6.0, and to inspect th.e areas for freezing problems. The inspector did not observe any serious freezing problems during the tour.
However, the inspector noticed some ice built up inside 6 of 31 travelling water screens at the outer structure.
The screens were continually running, deicing air
,<as operating, and the ice build-up was not interfering with the
=
20 screen. As a precaution, the licensee placed a portable heater en the most severely iced travelling screen.
The inspector had no further concerns in this area.
Modification 84-170 removed ten deicing air spargers instead of repairing them af ter they were damaged. Blank flanges were installed and the isolation valves were closed.
The inspector noticed unusual bloci ng tags used on these closed isolation valves. The mainteno.4ce engineer stated that he had also.
Questioned the use of these tags. The, licensee removed these tags and replaced them with operator aid tags.
The inspector had no further questions.
The inspector concluded that adequate protective measures for freeze protection were taken.
Most freeze protection devices were in service (steam heating space heaters, deicing air and heat trace). No violations were noted.
5.0 Special Report On Radioactive Release T5e literses rade t scecial repert rega-ding e Decar.be-16, 1007, i
release of liquid racioactive waste from the "B" laundry drain tank.
Technical Specification (TS) 3.8.B.4 requires that liquid radioactive waste be treated by one of three filters and/or demineralizers when the j
monthly average dose exceeds a value of 0.12 mrem.
Since this value was exceedea by the release, the TS requires a special report within 30 days, explaining why the ef fluent was not treated, the action taken to restore the filters and demineralizers to stry'ce, and corrective actions taken to prevent recurrence.
The inspector reviewed this special report dated January 11, 1988, and procedure HP0/C0-18, "Processing Liquid Radioactive Waste." The inspector also discussed this event and the report with cognizant licensee personnel. The lio.uid ef fluent was contaminated with urea from the winter of 1986-1987.
The urea had been used by the licensee as an ice melting agent on the plant yard during the winter to prevent injuries. The urea was tracked into the plant on workers shoes and-contaminated the mop water used in contaminated areas. The mop water activity was 7.4 E-10 microcuries per milliliter.
The effluent was being held in the laundry drain tank where it was sampled for radioactive materials, other possible contaminants, and water quality.
The procedure referenced TS 3.8.B.4 quantities but did not clearly specify that a TS variance would result in entry into a TS.
In addition, the procedure form did not sensitize the chemical technician and his supervisor that a TS would result from a variance.
The effluent was released after the chemical supervisor obtained a signoff from the shift supervisor on the variance. The water was treated th ough a similar filter as required by TS. However, this is not the same filter as specified.
The TS identified filter cannot be cross connected to the laundry drain tank.
The licensee g
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21 has submitted a TS change to add the laundry waste drain tank filter to the TS 3.8.B.4 filter list.
However, this TS change was not approved prior to the release.
The licensee's immediate corrective actions were to revise procedure HP0/C0-18 to clarify the TS requirements for a release variance.
Other actions were to c0u sel and train the chemical technicians and supervisors of the consequences of a TS release-variance.
The inspector had no further questions regarding the special report.
1 No violations were identified.
6.0 Review of Licensee Event Reports (LERs) 6.1 LER Review The inspector reviewed LERs submitted to the NRC to verify that the details were clearly reported, including the accuracy of the description and corrective action adequacy.
The inspector determined whether further information was required, whether gereric implications were indicated, and whether the event warranted on site followup.
The following LERs were reviewed:
LER No.
LER Date Event Date Subject 2-87-11, Rev. 01 Unit 2 HPCI Inoperability December 31, 1987 September 29, 1937
- 2-87-25 Unit 2 Partial Group III Containment Isolation January 4, 1988 December 2, 1987
- 2-87-26 Unit 2 Shutdown Scram and Group II/III January 5, 1988 Containment Isolation December 6, 1987
- 2-87-29 Unit 2 Group III Containment Isolation January 25, 1988 December 21, 1987
- 3-87-11 Unit 3 Partial Group II Containment December 29, 1987 Isolation November 29, 1987
22 6.2 LER Follewuo For LERs selected for followup and review (denoted by asterisks above), the inspector verified that appropriate corrective action was taken or responsibility was assigned, and that. continued operation of the facility was conducted in accordance with Technical Specifications and did not constitute an uareviewed safety question as defined in 10 CFR 50.59.
Report accuracy, compliance with current reporting requirements and applicability to other site systems and components were also reviewed.
6.2.1 LER 2-87-25 concerns a Unit 2 partial Group III containment isolatior, on December 2,1987.
The licensee determined root cause to be personnel error during modification acceptance testing.
The event was reviewed in NRC Inspection 277/87-29; 278/S7-29.
No inadequacies were noted relative to this LER.
6.2.2 LER 2-87-26 concerns a Unit 2 shutdown scram signal and Group II/III containment isolation signal on December 6, 1987, during instrument surveillance. testing. The root cause was determined to be a leaky instrument root valve. The event was reviewed in NRC Inspection 277/87-29, 278/87-29.
No inadequacies were noted relative to this LER.
6.2.3 LER 2-87-29 concerns a Unit 2 Group III containment isolation on December 21, 1987.
The root cause was personnel error (a non-licensed operator pulled the wrong fuse during blocking).
The event was reviewed during NRC Inspection 277/87-29, 278/87-29.
No i
inadequacies were noted relative to this LER.
6.2.4 LER 3-87-11 concerns a Unit 3 Group II (RWCU) isolation on November 29, 1987.
The root cause was a procedural deficiency associated with the Unit 3 pipe decontamination. The event was reviewed during NRC Inspection 277/87-29, 278/87-29. No inadequacies were noted relative to this LER.
1 7.0 Surveillar.ce Testing The inspector observed surveillance tests to verify that testing had been properly scheduled, approved by shif t supervision, control room operators were knowledgeable regarding testing in progress, approved procedures were being used, redundant systems or components were available for service as required, test instrumentation was calibrated, work was performed by qualified personnel, and test acceptance criteria were met.
Parts of the following tests were observed:
23 ST 10.8, "CRD Exercise Test," Rev. 11, perfo,med on Unit 2 on February 1, 1988.
ST 6.10-2, "HP5W Pump and Valve Operability and Flow Rate Test -
Unit 2 Only," Rev. 7, 2/12/87, performed on January 22, 1988.
ST 8.1, "Diesel Generator Full Load Test," Rev. 28, 1/12/88, performed on:
E-1, December 30, 1987 and January 4, ISB8; E-2, January 8, 19 and 28, and February 5, 1958.
In addition, a review of the following completed surveillance tests was performed:
ST 15.61A-2, "Calibration Test of HPCI Pump Room Smoke Detectors,"
Rev. O, 7/6/82 performed on Unit 2 on January 21, 1988.
STs identified in section 4.4 and 4.4.2.
No inadequacies were identified.
8.0 Maintenance Activities 1
The inspectors reviewed administrative controls and associated documenta-tion, and observed portions of work on the following maintenance activi-ties:
Document Equipment Date Observed MRF 87-11304 20 Core Spray Motor January 5, 1988 011 Cooler MRF 87-11237 thru Diesel Generator Fire Doors January 19, 1988 87-11240 Administrative controls checked, if appropriate, included blocking permits, fire watches and ignition source controls, QA/QC involvement, radiological controls, plant conditions, Technical Specification LCOs, equipment alignment and turnover information, post maintenance testing and reportability. Documents reviewed, if appropriate, included maintenance procedures (M), maintenance request forms (MRF), item handling reports, raoiation work permits (EdP), material certifications, and receipt ir,spections.
i In addition, a review of the following completed maintenance procedures was performed:
M1.1 "Main Steam 6" RV-70 A and B Safety Valve R'eplacement," Rev.
6, 2/10/87, performed March 1987.
24 A
M1.6, "Main Steam 6" x 10" RV-71 A-L Relief Valve Replacement,"
Rev. 9, 9/5/85, performed May 1987.
No inadequacies were identified.
9.0 Radiological Controls 9.1 Routine Observations During the report period, the inspector examined work in progress in both units, including health physics procedures and controls, ALARA implementation, dosimetry and badging, protective clothing use, adherence to radiation work permit (RWP) requirements, radiation surveys, radiation protection instruments use, and handling of potentially contaminated equipment and materials.
The inspector observed individuals frisking in accordance with HP procedures. A sampling of high radiation doors was verified to be locked as required. Compliance with RWP requirements was verified during each tour.
RWP line entries were reviewed to verify that cersorr.el had p*evic:d the re:u re: i nfo-maticr. and people working i
in kh? areas were observed to be meeting the applicable requirements. No unacceptable conditions were identified.
9.2 Allegation Concerning the Respiratory Protective Program The NRC received an allegation concerning an individual required to wear a respiratory protective device (RPD) for work in an area that had the potential to be an airborne radioactivity area.
The concern was that the mask d'd not pass the necative fit test.
The inspector investigated the circumstances surrounding this allegation by interviewing appropriate individuals, reviewing procedures, various signof f sheets, reports, results of tests, exposure records, and radiation work permits (RWP).
9.2.1 Description of the Event The worker had been trained, fitted, tested, and qualified to wear an "Ultraview" small size mask RPD on June 2, 1987.
The worker had been instructed in respiratory protection training.
He understood that if an individual has a chang > in weight, facial injuries, or extensive teeth recons +
' tion that may result in a change in facial dimensions. Se should request a refit of the mask.
The worker haa gained an appreciable amount of weight since the initial qualification in June 1987. The worker was requested by his foreman to be a firewatch in the Unit 2 drywell, a RPD required area, on i
January 20, 1988.
The worker explained that he had gained weight since the qualification ana had not worn a mask since that tice.
The foreman told the worker that
25 1
he would be scheduled as soon as possible for refit and requalification; however, he was again requested to make the drywell entry. At about 8:30 a.m., the worker made the entry to be a firewatch in the drywell wearing the cask he was qualified to use, utilizing an air hose.
Upon relief in about two hours the worker told the foreman be was suf fering from headaches caurad by tightner.s about the head frem using the shall mask, and tne foreman assured the worker he would be refit.
Later inat morning the foreman requestec that he resume the drywell firewatch at about 12:30 p.m.
The worker said he could because he would get a larger size mask f rom the mask issue cage.
Before the worker made the entry, the foreman fcund out the worker had been issued a redium mask for which he was not qualified.
The foreman apparently then allowed the entry by the worker.
The worker made the drywell entry and completed the firewatch duty until relieved about two hours later.
On January 26, 1988, the worker had a new foreman who requested him to make an entry into the Unit 2 drywell to be a firewatch.
The worker refused to make an entry into an airborne radioactivity area because the mask (a small Ultraview) he was qualified to wear leaked.
That is, the mask failed the negative fit test that each
'-dividuti i s required to do prica to mask use.
His original foreman did not get this new information during the first entry on January 20, 1935.
The supervisor of the worker who was responsible for the scheduling of refit tests did not immediately s:hedule the refit est since the worker's qualification was to expire within about two weeks after January 20, 1988. Upon finding cut about the worker's concerns, the worker was immediately refitted and qualified for the Ultraview mediua size mask curing the morning of January 26, 1988. Upon being requalified, the worker was requested to make an entry into an area requiring RPD as a firewatch. The worker refused, stating that the mask issue cage would not have the new qualification paperwork. A heated discussion began between the vorker, the foreman, and the supervisor during which the worker was told the proper qualification would be obtained for the mask issue cage. This argument was subsequently broken up by the steward who happened onto the noisy discussion.
The worker was not required to make an entry that day.
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1 9.2.2 NRC Findings and Conclusions
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The inspector reviewed the mask fit issuance re.ceds for January 20, 1988, and determined that for the first entry, the worker was issued the proper mask, for which the worker was qualified, a small size Ultraview.
For the second entry, the worker
,.s issued a medium si:e Ultraview for which the work a was not qualified.
Proce-dure HP-512, Rev. O, "Issue and Control of Respiratory Protection Equipment", states that individuals and the supervisors of users are responsible to ensure that respiratory protection equipment is used in accordance with l
instructions, training provided, and procedures. The issue control point attendant is responsible to verify respiratcr qualification of each individual prior to issuarce for the j
equipment issued. Also, HP 500, Rev. O, "Respiratory i
Protection Program", requires that individuals and super-visers be responsible for ensuring that workers use the correct respiratory protection equipment.
The inspector also reviewed these procedures ccvering the respiratory protection program, fit tests and qualification, and the issuance of the mask.
The procedures are adequate in defining responsibilities for qualification, issuance and negative fit tests of masks.
Interviews with the worker, other workers, the foreman and supervisor indicated that the individuals were adequately trained in the respiratory protection procedures, and knew their responsibilities for qualification, issuance and negative fit tests of masks.
The procedure for issuance of the masks (HP-512) lacks clear definition of the issue control attendant responsibilities in issuing the mask for which the individual is qualified and lacks clarity in section 7.1.2 to assure that the issued mask or equipment is that for which the individual is qualified.
On January 20, 1988, a mask was issued to the worker for which he was not qualified by the attendant and with the knowledge of the worker and his foreman.
In addition, the worker used this mask for a drywell entry at about 12:30 p.m.
Technical Specification sectiors 6.B.1 requires that written procedures be established, implemented, and maintained that meet the requirements of section 5.1 of ANSI N18.7-1972 which requires that the plant will be operated in accordance with written procedures, and Regulatory Guide 1.33, Appendix A, section G, part b which requires procedures for respiratory equipment.
Failure to follow procedure HP-500 and HP-512 is an apparent violation of TS 6.8.1 (277/88-01-03).
l 27 i
The ir.spector noted that the Respiratory Issue 1.0g did not record the mask by type and size but only by serial nu:rber which made the tracking of the issued respiratory equipment difficult.
In addition, 'tne log lacks a quality control check requiring the attendant to write and confirm the equipment with the qualification list.
The inspector reviewed the results of the whole body count of January 27, 1988, to determine if the worker had an intake while using the RPD on January 20, 1988.
At this time the results are not detertrined.
The inspector nad questions involving the method of reporting and the value of minimum detectable activity for each radioisotope determined.
This will be reviewed in a future inspection.
The licenste initiated several immediate corrective i
acticns.
The first concerned the responsibility of the issuance control point attendant to issue only respiratory equipment for which the individual is qualified. Atten-dants involved in this incident were restricted from issuance until they were retrained and counseled in their responsibility to issue RPD - in strict adherence to pro-cedures. A sign was posted at each issue cage reminding individuals of their responsibility.
All attendants were retrained and counseled in responsibilities and adherence to procedures. The procedures for testing and qualifica-tion, issuance, and use of RPDs were reviewed and temr.orary char.ges ini.iated to clarify responsibilities and issuance.
Vendors were made aure of to the incident, and if involved directly, counseled and retrained in responsibilities and procedures.
Long term corrective actions will be reviewed in a later inspection.
10.0 Physical Security 10.1 Routine Observations The inspector monitored security activities for compliance with the a cepted Security Plan and associated implementing procedures, including:
security staffing, operations of the Control Alarm Station (CAS) and Secondary Alarm Station (SAS), checks of vehicles to verify proper control, observation of protected area access control and badging procedures on each shift, inspection of physical protected and vital area barriers, checks on control of vital area access, escort procedures, checks of detection and assessment aids, and compensatory measures.
Except as discussed below, no inadequacies were identified.
28 10.2 Orug Detection Dogs l
On January 6,1988, between 2:30 p.m. and 7:30 p.m., trained drug detection dogs were brought on site unannounced.
The reain purpose of the visit was for training of employees using the dogs. Two teams of dogs, handlers, and PECo security personnel visited buildings both inside and outside the protected area.
Areas visited included Unit 1 facilities, the Technical Support Center, and the Emergency Operations J
Facility. One team entered the power block to gain access to the control room.
Test drug samples were hidden by teeai menebers to demonstrate drug detection techniques and abilities of the dogs and their handlerr.
Numerous questions were asked by plant personnel, including some concerning PECo's fitness for duty policy.
In addition to the educational sessions, general searches of the buildings <.ere cerducted; no cortraband was found.
l The licensee's investigation into alleged drug activities at Peach Bottom will continue.
The inspector will keep abreast of future I
activities (see section 10.4).
j 1
10.3 Excessive Time to Compensate for Door Alarm i
At 3:32 a.m., on January 20, 1988, a door to a vital area alarmed indicating a potential for unauthorized access to Unit 2.
The licensee took 18 minutes to respond to the alarm and to search the area for unauthorized individuals.
The guard dispatched to investigate the cause of the alarm and to search the area had l
difficulties with his key card accessing a vital door while in transit to the alarmed door.
The guard received instructions from the CAS operator by phor.e on how to proceed to the alarmed door without having to pass through any other key card doors. The guard followed the instructions and found the corresponding door un Unit 3.
The guard had resoonded to the wrong unit, Unit 3 rather than Unit 2.
When the CAS operator realized the guard had responded to the wrong unit, another guard was dispatched to Unit 2 to investigate and search the area.
The second guard arrived at the alarmed door at 3:50 a.m., immediately investigated the alarm, and searched the area for unauthorized individual (s).
None were found. The corporal of the guard assisted the first guard in carrying out a search of all vital areas and no unauthorized individuals were found.
The licensee made an emergency notification system call at 4:26 a.m., to report this safeguards Event.
The licensee failed to properly investigate the alarm and search for possible unauthorized individuals in the vital areas within ten minutes af ter the alarm.
Regional safeguard specialist inspectors were on site when this event occurred.
They investigated this event and
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29 i
reviewed the licensee's corrective ' actions.
The findings will be
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reported in NRC Inspection Report 277/88-02; 278/88-03. On January 27, 1988, the licensee-downgraded this event to recordcble based on current plant' conditions and vital area' doors.
10.4 Licensee's Ongoing Drug Investigation At 11:23 p.m., on January 7, 1988, the licensee made a one-hour security report that one of the individuals arrested on November 18, 1987, as a result of an FBI drug investigation, had implicated 23 additional people.
The licensee was: informed of,this by an FBI 3
contact. One of the individuals implicated was a licensed reactor operator and another was a non-licensed operator.
The licensee tested octn < individuals in accordance with their: fitness for duty program. The non-licensed operator tested positive.
He was removed from duty and denied access to the protected area.
The licensed operator tested negative.
At approximately 2:45 p.m., on January 12, 1988, a'PECo health physics (HP) technician found a white powdery substance in the HP break room. This room is on the second floor of the access control center in the protected area.
The substance was approximately one ounce and was in plastic sandwich bag secured with a twist tie.
The bag was under some papers on a file cabinet. The substance "fell out" when the HP technician was removing some of these papers.
Security was immediately notified.
The licensee performed a field test and the substance twice tested positive as cocaine.
(The field test is about 75% accurate.) The licensee informed the resident inspectors at 3:20 p.m., making a formal one hour repcrt. The licensee also-notified the FBs.
The substance was transported for further laboratory testing.
The licer.see informed the resident inspector on January 14, 1988, that a laboratory test determined the substance to be bicarbonate.
The licensee has determined the event to be recordable and not reportable.
1 On November 18, 1987, the FBI arrested six individuals who were accused of drug distribution at the Peach Bottom Atomic Power Station and in the surrounding York County area. The indictment by a Federal Grand Jury sitting in Harrisburg charged all of the defendants with conspiracy to alstribute and possess with the-intent to distribute methamphetamine.
Four licensee and two contractor employees were involved. On January 15, 1988, the U.
- 5. District Court for the Pennsylvania Middle District in Harrisburg found two of these defendants guilty and two not guilty. Previously, the two other defendants (one PEco and one contractor) had pleaded guilty to conspiracy and possession charges. The two found guilty (one PECo and one contractor) of conspiracy and possescion to distribute methamphetamine will be n - e f,,,,. 7 e - -,.,, -.
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The remaining two defendants (both PECo employees) are currently suspended and their status is under review.
At 12 noon on January 29, 1988, the licensee informed the resident inspectors of a suspect substance found by a contractor sapervisor in the protected area.
The substance was a small white ct;sule found in the administrative building southwest stairwell.
The substance in the caosule field tested positive for methamphetamine.
Field tests are not conclusive and the licensee sent the substance of f site to be laboratory tested.
On February 5, 1988, the licensee informed the residents that lab testing proved the substance to not be methamphetamine.
It was not a controlled substance.
The inspector reviewed the licensee's action for these events including corrective actions.
The inspector also discussed these with licensae security an: management personnel.
No viclations were noted.
10.5 Inattentive Watchnan on January 9,1988 ist 10:57 a.m., on January 9,1988, the PECo shif t security supervisor observed an inattentive compensatory guard (watchman).
The watchman was observed lying down on an electrical panel in a i
vital area with his eyes closed.
The PECo security supervisor i
approached the individual who then opened his eyes and said he wasn't sleeping. The watchman also stated he was feeling sick.
1 The watchman was relieved, escorted out of the protected area, and suspended pending an investigation.
A search of the vital area i
was conducted and no abncrmalities were noted, The w::c 2:n E d
.l been on shift since 6:00 a.m., and had assumed this post at 9:55 a.m.
The licensee made an ENS call at 12:30 p.m.
The watchman was subsequently terminated for his actions.
The inspector reviewed the licensee's investigation and discussed this event with security personnel and plant management.
In addition, NRC Inspection 277/88-03; 278/88-03 documented this event. The inspector had no further questions at this time.
The inspector stated that he was concerned as this was another instance of an inattentive security force personnel.
10.6 Security Event on January 24, 1988 Early in the morning on Sunday, January 24, 1988, planned maintenance on transformers (doble testing) required that some lighting panels being removed from service. Some of the lighting affected the protected area. In response to the loss of lighting, security personnel placed portable lighting at the affected area and established a compensatory post because of the dimness of the portable lighting.
The post used was an enclosed vehicle because of the extreme cold temperatures.
The engine was used to provide
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heating. During inspection rounds a supervisor came up to the vehicle and apparently startled the post guard.
The compensatory i
post guard stated that she saw the supervisor, but did not notice his approach. The event was not immediately investigated to determine the need to make an immediate report or a recordable report, but was mentioned to the inspector in the control room about three hours after the event.
The following Monday, January 25, 1988, the inspector reviewed the event with security personnel. The licensee i
responded by making an investigation of the event including an entry into the safeguards event log.
The supervisor had approached the vehicle from the passenger side and observed the guard with her head back.
The supervisor then wert arcuno to ;nt cre ar sicy witr. u oeing observed, and apparently startled the guard.
The supervisor questioned the guard as to what sne had observed when the supervisor approached the vehicle. The guard had not observed the approach of the supervisor i
because she did not know from which direction he had approached the vehicle. The guard complained of the exhaust fumes. It was determined that the post was compensated since the other posts had observed tFe seervisr It t ? ::
,P s t.tm y pc s t.
T5 m f re, the event was j
consicered to be a recordable event by the licensee.
In spite of instructions to prevent carbon monoxide poisoning from the use of operating vehicles, such as placement of the vehicle so that the wind can blow the fumes away from the fan intake and opening the windows to maintain air changes, the licensee initiated a study of additional methods to prevent the intake of exhaust fumes.
The inspector will review the corrective actions in a future inspection.
No violatior.s were noted.
11.0 Assurance of Quality 11.1 Involvement in Unit 2 Refuel Mode and Hydrostatic Test Preparations Management and PORC involvement in reviewing the plant conditions necessary to support Unit 2 "refuel" mode and hydrostatic test were good.
Procedures were developed, approved, and implemented to ensure that systems required to support these activities were operable, adequately tested and maintenance / modification activities were complete (see section 4.4.3).
On the other hand, weaknesses were identified in QA and QC involvement in this Unit 2 activity.
QA and QC were involved in the required programmatic review of surveillance, in monitoring, in inspection and in audit activities.
However, there was no QA and QC review of open items that could impact on system operability until the inspector questioned QA/QC personnel (see section4.4.4).
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32 11.2 Attention te Detail and Procedure Comoliance 1
Two instances of not following procedures were identifiM.
One involved licensed operators when placing the Unit 2 circulating water system into service (see section 4.2.1).
This resulted in a j
flooding of the condensate pump pit room.
The other instance involved the issuance and use of respirators by ccetractor personnel (see section 9.2).
This resulted in the use by a worker of a respirator mask for which he was not qualified.
These two instances irdicate that some workers are not paying attention to detat i and not adhering to procedures.
12.0 Unresolved Iteus Unresolved items are items about which more information is required to ascertain whether they are acceptable violations or deviations.
An unresolved item is discussed in section 4.5.1.
13.0 Management Meetings 13.1 Preliminary Inspection Findings A verbal sue. mary of preliminary findings was provided to the Manager, Peach Bottom Station at the conclusion of the inspection.
During the inspection, licensee management was periodically notified verbally of the preliminary findings by the resident inspectors. No written inspection material was provided to the licensee during the inspection.
Ne proprietary information is included in this report.
13.2 Attendance at Management Meetings Conducted by Region Based Inspectors Inspection Reporting Date Subject Report No.
Inspector Jan 13, Simulator Team 87-35/35 Howe 1988 Evaluations Jan 19-Security 88-03/03 Bailey 22, 1983 Feb 1-Mark I Containment 88-04/04 Chaudhary 5, 1988
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13.3 NRC/PECc Management Meeting on January 27, 1988 On January 27, 1988, a management meeting was htid at Peach B: tom.
A*, this meeting, PECo discussed the status of _ their restart plans.
In particular, 'he status of Section II of the "Plan. for Restart of Peach Bottom Atomic Power Station" was discussed.
The licensee gave an overview of this pla-includino corrective' actions to address root causes, and, the link among the shutdown issues,-root causes, and proposed corrective actions.
(The licensee subsequently submitted the plan on February 12,1988).
The inspector attended the meeting..The NRC will continue to follow this area including a detailed review and evaluation of this plan.
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