ML20205J219
| ML20205J219 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/21/1986 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8601300124 | |
| Download: ML20205J219 (10) | |
Text
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j PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 i
PHILADELPHIA. PA.19101 SHIELDS L. D ALTROFF nd%c""o"Eo=
January 21, 1986 Docket Nos. 50-277 50-278 Inspection Report Nos. 50-277/85-29 50-278/85-33 Mr. Samuel J. Collins, Chief Projects-Branch 2 Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 i
Dear Mr. Collins:
Your letter dated December 20, 1985 forwarded Combined Inspection Report Nos. 50-277/85-29;-50-278/85-33 for Peach Bottom Atomic Power Station.
Appendix A of your letter addr. esses four items which do not appear to be in full compliance with Nuclear Regulatory Commission requirements.
Tnese items are restated below followed by our responses..
i s I.
Restatement of Violation Technical Specification 6.8.1 and Regulatory Guide 1.33, November 1972, require implementation of procedures for surveillance testing.
Surveillance Test Procedure ST 4.9.B, Portal Monitor Calibration and Source Check, requires a quarterly source check and a semi-annual Jalibration of the portal monitors throughout the plant, including portal monitor number 332.
Contrary to the above from about July 7,1985 to September 25, 1985, portal monitor number 332 was-overdue for calibration and in use at the 165 foot elevation of the.
administration building bridge, ' and the semi-annual calibration had not been performed since January 7, 1985.
8601300124 860121 "O gDR ADOCK 05000277 PDR 0g
, g.
Mr. Samuel J. Collins January 21, 1986~
Page 2 This is a ' Severity Level IV Violation (Supplement 1)
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applicable to DPR-44 and DPR-56.
Admission of Alleged Violation:
Philadelphia Electric Company acknowledges the violation as stated.
Reason for Violation:
The station Instrument and Controls (I&C) Group establishes the priorities of the Instrument Lab Group in accordance with the requirements of the station and is responsible for ensuring that surveillance tests which are-assigned to the Instrument Lab and issued through the I&C-Group are completed in a timely manner, Although the subject surveillance test was issued in a timely manner, the Instrument Lab individuals responsible for performing health physics-related instrument surveillance tests were redirected by the station Health Physics Group to assist.
with other radiation monitoring instrument work associated with the Unit 2 pipe replacement outage and with preparation for the Unit 3 refueling outage which started in July, 198 5.
During this time ~ period, the station I&C Group failed to ensure that the test was completed in a timely manner.
Significance of Violation:
ST 4.9.B controls the calibration and source check of the Eberline Portal Monitors, Model PMC-4, which are used as a backup to the new and more sensitive Instrumentation Research Technology (IRT) Portal Monitors, Model PRM-110.
The subject Portal Monitor 332 is located in the-Annex Bridge connecting the Turbine Building -(Elevation 165') to the ' Administration Building.
The IRT portal monitors are the primary monitors used at the exit of the Main Guard House.
All personnel must pass through the portal monitors at the Main Guard House prior to exiting the Peach Bottom site.
The IRTs at the Main Guard House were in~ proper calibration during the period of time when the calibration of Portal Monitor 332 was past due.
Therefore, the IRTs would have prevented contamination
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from being carried off-site.
The Annex Bridge portal monitor-is used to control the potential spread of contamination to 'the Administration Building. - Use of this bridge is restricted to authorized' personnel.
Although Portal Monitor 332 had not been calibrated since January
j Mr. Scmuel J. Collins Jcnuary ~
Page 3 21, 1986 7, 1985, this monitor was source checked satisfactorily on April 2, 1985.
Corrective Actions Taken and Results Achieved:
ST-4.9.B was successfull'y performed on September 25, 1985,
.immediately after it was discovered that the semi-annual calibration of Portal Monitor 332 had-not been performed
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as required.
Corrective Actions Taken to Avoid Future Non-Compliance:
Responsibility for completion of ST-4.9.B has been transferred from the station I&C Group to the station Health Physics Group because the portal monitors are more closely related to health physics instrumentation.
The Senior Health. Physicist is now responsible for ensuring timely completi'on-of this test.
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j, Additionally, the instrument lab has established a tracking mechanism to be used for controlling tests that are not performed in a timely manner.
All instrument technicians have been instr'ucted to use this' tracking mechanism.
4 Date When Full Compliance was Achieved:
Full compliance was achieved on September 25, 1985 when ST-4.9.B was completed satisfactorily.
II.
Restatement of Violation Technical Specification 6.8.1 and Regulatory Guide 1.33, i
November 1972, require that written procedures and administrative policies be established, implemented and i
maintained.
Administrative Procedures A-26, Rev. 24, and A-26A, Rev.
1
- :2, state that the Control. Operators shall. prepare blocking permits.
Procedure A-2 states that revised Administrative Procedures must contain equivalent, more conservative, or additional requirement's _ to be issued on an expedited
- basis, i
Contrary to the above: 1) In early September 1985, a practice was instituted allowing Plant Operators-Nuclear to. prepare blocking permits; and 2) on October ~11, 1985,
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Mr. Samuel J. Collins January 21, 1986-Page 4 1.
an -expedited change to A-26 and A-26A was made, which eliminated the requirement that Control Operators prepare blocking permits, and did not contain equivalent, more L
conservative or additional requirements.
This is a Severity L~ el IV. Violation '(Supplement 1) applicable to DPR-44 m.id DPR-56.
Admission of Alleged Violation:
{
Philadelphia Electric Company' (PECo) agrees that a practice was instituted allowing Plant Operators - Nuclear j
to prepare blocking permits and that an expedited change j
to Administrative Procedures A-26 and A-26A was made on-October 11, 1985; however, PECo coes not believe that these expedited changes were made in-a less conservative i
direction.
i I
j Reason for Violation:
i i
The practice of allowing Plant Operators' - Nuclear to prepare blocking permits was instituted in September,1985 due to the heavy workload involved with the preparation of blocking permits.
On October 11, 1985, it was realized that~ Administrative Procedures A-26 and A-26A had not been complied with because these procedures-specifically require'd that a Control Operator prepare blocking permits.
I The Plant Operations and Review Committee (PORC) met on i
October 11, 1985 to discuss and approve revision of A-26 '
l and A-26A to allow Plant Operators - Nuclearo to prepare blocking permits.
The expedited procedural changes were j
reviewed and approved by the Quality Assurance (QA)
Division that same day.
When Procedures A-26 and A-26A were originally written, rather than specify the individuals who were approved to write permits'by'name, the generic title of Control Operator was used because all
- of the individuals involved at-that time were Control Operators.
This assignment of-responsibility was not intended to limit the individuals who could write permits l
exclusively tx) those in the Control Operator. position.
In j
addition, it is our position that these. procedural changes-were not made in a less conservative direction because:
(1) Plant Operators
_ Nuclear are intimately involved with i-
.the plant equipment and have completed training programs-similar to.that of Control Room Operators in the area of plant equipment knowledge and therefore have knowledge similar to that of Control Operators (due tx) the nature of l
their day-to-day activities), -(2) Shift supervision is-I responsible for ensuring all blocking permits ~are j
adequate, regardless.of who prepares the blocking permits, l
[L
Mr. Scmuni J. Collins January 21, 1986 Page 5 i
and (3) Prior to permitting the selected Plant Operators -
Nuclear -(PO-N) to prepare blocking. permits, each - PO-N was i
given one day of individual refresher training in the use of the Blocking and Permits Handbook by a qualified
_ instructor.
This instruction is equivalent to the instruction provided to Control Operators in this subject area.
Corrective Actions Taken and Results Achieved:
i As stated previously, Procedures A-26 and A-26A were approved by the PORC on October 11, 1985'and the OA j
Division performed an expedited review of these procedures on that same date.
These changes allowed shift supervision to direct preparation of a blocking permit, as necessary, thereby satisfying QA requirements as well as j
station requirements.
Corrective Actions to be Taken to Avoid Future Non-Compliance:
The corrective actions stated above will prevent recurrence.
i Date When Full Compliance Was Achieved:
Full compliance was achieved on October 16, 1985 when QA Division completed the standard review of the changes to A-26 and A-26A.
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III.
Restatement of Violation Technical'pecification paragraph 4.6.D.4 requires that S
each main steam safety relief valve be manually opened' once per operating cycle with the reactor pressure equal j
to or greater than 100 psig to demonstrate its ability to pass steam.
Surveillance Test 10.'4,' Relief Valve Manual i
Actuation, implements this~ requirement.
i Contrary to the above, no manual test of relief valves 71 l
B, G, and K were performed on Unit 3 during.the operating cycle 6'from September, 1983 to July, 1985.
This is a Severity Level IV Violation (Supplement 1) applicable to DPR-56.
l r
Mr. Scauel J. Collins!
January 21,-1986-Page 6 i
Admission of-Alleged Violation:
i Philadelphia Electric Company acknowledges the violation as stated.
l Reason-for' Violation:
I Surveillance Test ST-10.4 (Relief. Valve Manual Actuation) was performed during Unit 3 reactor startup on September 3, 1983.
A' review of this test indicates that not all of the safety relief valves were tested at - that time.
There' 5
f appears to have been an oversight on the part of the-personnel' who performed and reviewed -the test because, if all the relief valves were not tested, the test should i
have been treated as a " partial-test" under the:
i requirements of Administrative Procedure A-3 (Procedure.
for Temporary Changes to Approved Procedures).
If the l
test had been marked up as a " partial. test" as required by
'l A-3, the Surveillance Test Coordinator would have known to reissue ST-10.4 to check the relief valves that were not j
previously tested.
However, because the test was not.
properly marked up as be.ag a " partial test", ST-10.4 was not reissued.. The reason for the violation was failure to j
properly follow Administrative Procedure A-3'.
l Corrective Actions-Taken and Results' Achieved I
The personnel responsible for performing and reviewing -the j
subject surveillance test have been ccanseled on the I
proper method of handling " partial tests" in accordance l
with Administrative Procedure A-3.
t 1
Corrective Actions to be Taken to Avoid'_ Future Non-Compliance:
The Operations Engineer has issued a memo to shift operating personnel concerning the proper. method'of handling " partial tests" in accordance with' Administrative 1
i P rocedure A-3.
In addition, the duties of'the Surveillance Test Coordinator will be reviewed in. light of i
this violation with the intent of strengthening this function to prevent recurrences of this type.
I r
i Date When Full Compliance Will Be' Achieved:
l Unit 3 is currently in a refueling and maintenance -outage.
ST-10.4 is. scheduled to be performed during. Unit.3 startup which is currently scheduled for January 27, 1986.
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Mr. Scmuel J. Collin3 Jcnuary 21, 1986 Page 7 Satisfactory performance of ST-10.4 will satisfy Technical Specification 4.6.D.4.
IV.
Restatement of ' Violation 10 CFR 50.72 requires that the licensee notify the NRC Operations Center via the Emergency Notification System within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 10 CFR 50.73 requires the preparation of a Licensee Event Report of any event or condition that recults in manual or_ automatic actuation of any engineered safety feature, including the reactor protection system.
Contrary to the above, eight reactor protection system actuations occurred between August 29 and October 10, 1985 and, as of October 25, 1985, no reports were made to the NRC.
This is a Severity Level IV Violation (Supplement 1) applicable to DPR-56.
Admission of Alleged Violation:
Philadelphia Electric Company agrees that eight actuations of the Reactor Protection System (RPS) occurred between.
August 29, 1985 and October 10, 1985 at Peach Bottom Unit 3 and that none of these actuations were reported under the requirements of 10. CFR 50.72 and 10 CPR 50.73.
Reason for Violation:
The cause of the late reporting of these events was due to an interpretation of 10 CFR 50.72 and 10 CPR 50.73 reporting requirements.
Seven of the eight RPS actuations involved initiation of full scram signals due to false Intermediate Range Monitor (IRM) high flux signals.
The remaining.RPS actuation involved a false scram discharge volume high level signal.
The eight actuations occurred with Unit 3 shutdown for refueling and no. fuel in the reactor vessel.
At the time of the events, it was believed that RPS actuations, which occurred when the fuel was completely removed f rom the reactor vessel, and whose l
initiating signals were caused by other than the flux sensing detectors, were not reportable.
NUREG-1022, titled, " Licensee Event Report System - Description of
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System and Guidelines for Reporting", the guidelines which were published with'10 CFR 50.72 and 10 CFR 50.73 in the Federal Register, the PBAPS Technical Specifications, and
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' Mr. Scnuel J. Collins January 21,.1986 ~
Page 8 1
I.
plant design analyses support this interpretation of the reporting requirements of 10 CFR 50.72 and 10 CFR 50.73.
1 i
Section V of NUREG-1022, which provides a paragraph-by-paragraph explanation of the LER Rule, contains guidance for Paragraph 10 CFR 50.73 (a) (2) (iv) concerning reportability of actuations of any engineered safety feature, including RPS.
Section V of NUREG-1022 states, "Actuations~ that need not be reported 'are those initiated i,
for reasons other than to mitigate the consequences of an i
event".
The actuations discussed in this violation i
occurred while there~ was noLfuel in.the reactor vessel.
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.These actuations had been evaluated as actuations which were not initiated to mitigate the consequences of'an event.
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Technical Specification Bases 3.1, concerning the Reactor Protection System, states that "When there is no fuel in i
the reactor, the scram serves no function; therefore, the l
Reactor Protection System is not required to be operable".
l The Updated Final Safety Analysis Report (Section 7.2.1) l states that "The safety objective of the RPS is.to provide timely protection against the onset and consequences of conditions that threaten the integrities of the fuel j
barrier and the nuclear system process barrier.....
The-RPS limits the uncontrolled release of radioactive i
material from.the fuel and the nuclear system process l
barrier by terminating excessive temperature and pressure t
increases through the initiation of an automatic scram".
j These design objectives clearly indicate that an RPS actuation ~which occurs when no fuel 'is in the. vessel I
serves no safety function.
In NUREG-1022, Supplement No. 1, in the " Questions and Answers from LER Workshops" section, additional information supporting this interpretation.is provided in I
the answer to question 6.9 which states that reporting is l
not. required if "the system is not required to be operable and it has been properly removed from service-such 'that it cannot' perform its intended function".
Concerning these i
specific events, all fuel was removed from the reactor.
j vessel.
This condition-meets the specific intent of.the NRC answer,.in-that the system was r.ot required to be operable nor could it perform its intended function.of~
controlling reactivity, i
i Additionally, NUREG-1022 states tnat "' Actuation' of multi-channel ECF actuation systems is defined as j
actuation of enough channels to' complete the minimum i
actuation logic..
1Therefore, single. channel actuations, whether' caused by failures or'otherwise, are not
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reportable ~if they do not complete the minimum actuation t
_ _. _., ~,
i.,._
~.r.-.
Mr. Stmuel J. Collins Jcnucry 21, 1986 Page 9' logic."
Seven of the eight events occurred as a result-of single channel actuations because a preplanned trip of the alternate channel, to support outage-related work, was already in place prior to each event due.
Therefore, because seven of the eight events only produced a single i
channel actuation, they were not, in.themselves, sufficient to. complete the minimum actuation logic.
Using NRC guidance and plant design analyses,. these actuations were not viewed as being significant or useful to identify and resolve threats to public safety.
3 Significance of Violation:
I The RPS actuations for each of the eight events identified above occurred while the unit was in the refuel mode with no fuel in the reactor vessel.
These actuations were not significant and they were not necessary "to mitigate the consequences of an event" because of the plant configuration.
Additionally, seven of these events would not have occurred during power operation because the work circumstances which caused the single channel actuations cannot exist at that time.
Therefore, the root cause would not develop.
Corrective Actions Taken and Results _ Achieved:
Peach Bottom Atomic Power Station Licensee Event Reports j
3-85-21 and 3-85-22 were submitted to NRC on December 18, 1985 and December 20, 1985, respectively.
LER 3-85-21 concerned the f alse IRM signals and LER 3-85-22 concerned the false scram discharge volume high level signal.
All i
.of the events identified in this violation were reported I
to NRC in these two LERs.
l Corrective Actions Taken to Avoid Future Non-Compliance On October 11, 1985, a memorandum was issued by the Operations Engineer stating that all Engineered Safety Feature actuations, including RPS actuations occurring while the reactor is defueled, will be reported to the NRC as a Licensee Event Report.
Date When Full _ Compliance Was Achieved Full compliance was achieved on December 20, 1985 with l
submittal of Peach Bottom Atomic Power Station Licensee Event : Report 3-85-22.
i k
Mr. Samuel J. Collins Jcnuary 21, 1986 Page 10 The cover letter which transmitted this Inspection Report requested that PECo discuss the management controls used to ensure that PORC-approved procedures are not revised in a less conservative direction via the issuance of non-PORC rev_iewed guidance.
Although not specifically tied. to a violation, we assume this request refers to a letter from the Operations Engineer to the Operating Shif t dated August 29,-1985.
This
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letter provided interpretation guidance based on engineering judgment for the ESF actuation portion of Administrative Procedure A-31 (Procedure for Notification of the NRC).
The intent of this letter was to provide specific guidance on a subset of events which are not addressed by the A-31 procedure.
There was no intent to revise in a less conservative manner or otherwise circumvent the Administrative Procedure.
Licensee representatives from all utilites who are familiar with NUREG-1022 and have attended the various NRC LER Workshops clearly understand, as stated in-the various NRC documents, that engineering judgment must be used in determining the reportability of events.
This was the case in these instances.
The purpose of the letter was to document the rationale'of the engineering judgment employed and provide consistency with regard to the reportability of the specific events' under ' the specific conditions sta'ted in the letter.
In response to the concern raised in your cover-letter, the Plant Manager has directed all of the Senior Staff at Peach Bottom that this form of guidance must be PORC approved prior to issuance.
Should you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours,
)
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cc:
T. P. Johnson, Resident Site Inspector
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