ML20211Q361
| ML20211Q361 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/20/1987 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| CAL-86-07, CAL-86-7, NUDOCS 8703030072 | |
| Download: ML20211Q361 (8) | |
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r FEB 2 01987 Docket Nos. 50-277 50-278 Philadelphia Electric Company ATTN: Mr. J. W. Gallagher Vice President Nuclear Operations 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:
Subject:
Status of Compliance With Appendix R at Peach Bottom Units 2 and 3 During the period March 17 through 21, 1986, the NRC conducted an inspection of Peach Bottom Units 2 and 3 to determine compliance with 10 CFR 50.48 and Appendix R, as discussed in Reference 1 (See Attachment A for references). At that time, Philadelphia Electric Company (PECo) was in the process of conducting a self-initiated review to confirm compliance with 10 CFR 50.48 and 10 CFR 50, Appendix R.
As a result, NRC Region I issued Confirmatory Action Letter (CAL) 86-07 (Reference 2) specifying that the Appendix R review be completed by September 30, 1986. The results of this review were documented in References -
3, 4 and 7 aad submitted to the NRC in accordance with Items 1-3 of the CAL.
During this review, your staff identified a number of conditions at Peach Bottom Units ? and 3 that were in violation with the requirements of 10 CFR 50.48 and Appendix R.
A summary of these conditions along with PECo's interim resolution was provided in Reference 8, Table II. This summary is repeated as Attachment B to this letter. These items are being evaluated by the NRC for appropriate enforcement action.
As a result of your identification of the violations, we met with your staff (see Reference 5) to discuss the nature of the violations; causes for the nonconforming conditions; a description and status of corrective actions and your schedule for completion; and your interim ccmpensatory measures.
- Further, we have evaluated your subsequent actions, as set forth in Reference 6, 7, 8, and 9 including (a) your interim compensatory measures consisting primarily of increased fire watch patrols, upgraded training of fire watch personnel, and improved administrative controls over combustibles; (b) your Justification for Continued Operation (JCO) while the conditions of nonconformance are being permanently corrected; with the compensatory actions in place, and (c) your schedule for full compliance with 10 CFR 50.48 and Appendix R, sections III G and J before the end of the 1987 spring refueling outage for Unit 2 except as i
identified in Reference 9, and before the end of the 1987 fall / winter outage for Unit 3, including any equipment common to both units.
l OFFICIAL RECORD COPY ANDERSON 2/3/87 - 0001.0.0 02/2W87
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8703030072 870220 PDR ADOCK 05000277 I
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Philadelphia Electric Company 2
Based on this evaluation we have concluded that, pending completion of permanent corrective actions, the compensatory measures taken and JCOs described in response to the identified violations provide adequate assurance that both Units have the ability to achieve safe shutdown following a fire.
Should your interim compensatory measures or schedule for full compliance with 10 CFR 50.48 and Appendix R sections III G and J change, please notify me or Dr. W. Johnston, Deputy Director of Reactor Safety.
Your cooperation with us in this matter is appreciated.
l Sincerely, Oricina SIC" W f,
/,hy 7v
[O U51 Stewart D. Ebnete Director
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Division of Reactor Safety Attachment A: References k
Attachment B: Table 1 Appendix R ' Condition of Non-Conformance/ Interim Resolution Summary cc w/ attachments:
R. S. Fleischmann, Manager, Peach Bottom Atomic Power Station John S. Kemper, Senior Vice President, Engineering and Production Troy B. Conner, Jr., Esquire W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric G. Leitch, Nuclear Generation Manager Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)
Raymond L. Hovis, Esquire Thomas Magette, Power Plant Siting, Nuclear Evaluations (Without Report) l W. M. Alden, Engineer in Charge, Licensing Section Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector l
Commonwealth of Pennsylvania y6 OFFICIAL RECORD COPY ANDERSON 2/3/87 - 0002.0.0 02/06/87
Philadelphia Electric Company 3
bec w/ attachments:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
Section Chief, DRP Robert J. Bores, DRSS D. Holody, E0 l
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RI:DRS RI:DRS RI:DRS RI: RP RI DRP Durr Johnston Ga)
Ka Anderson /cgiqf z/s/g;
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OFFICIAL RECORD COPY ANDERSON 2/3/87 - 0003.0.0 02/06/87 1
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ATTACHMENT A REFERENCES (1) Combined NRC Region I Inspection Report Numbers 50-277/86-08 and 50-278/86-08 of Peach Bottom Units 2 and 3 Compliance with 10 CFR 50, Appendix R, dated May 14, 1986, from S. D. Ebneter, NRC, to S. L.
Daltroff, PECo.
(2) Confirmatory Action Letter 86-07, dated April 11, 1986, from S. D.
Ebneter, NRC, to S. L. Daltroff PECo.
(3) Special Report: Conditions of Non-Conformance with 10 CFR 50, Appendix R of Peach Bottom Atomic Power Station, dated May 22, 1986, from G. M.
Leitch, PECo, to T. E. Murley, NRC.
(4) Special Report: Conditions of Non-Conformance with 10CFR50, Appendix R of Peach Bottom Atomic Power Station, dated September 17, 1986, from Mr.
J. Conney, PECo, to T. E. Murley, NRC.
(5) Details of October 16, 1986 Management Meeting CAL 86-07, dated November 14, 1986, from S. D. Ebneter, NRC to S. L. Daltroff, PECo.
(6) Compensatory Measures for Conditions of Non-Compliance with 10 CFR50, Appendix R of Peach Bottom Atomic Power Station, dated October 24, 1986, from S. L. Daltroff, PECo, to W. F. Kane, NRC.
(7) Special Report: Conditions of Non-Conformance with 10 CFR 50, Appendix R of Peach Bottom Atomic Power Station, dated October 31, 1986 from J. S.
Kemper, PECo, to T. E. Murley, NRC.
(8) Justification for Continued Operation of Peach Bottom Units 2 and 3 with Conditions of Non-Conformance with 10 CFR 50, Appendix R, dated November 28, 1986, from S. J. Kowlaski, PECo to W. F. Kane, NRC.
(9) 10 CFR 50, Appendix R, Fire Protection Program Peach Bottom Atomic Power Station, dated January 8, 1987, from J. W. Gallagher, PEco to W. F. Kane, NRC.
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ATTACHMENT B Table I Anoendiv R Condition of Non-Conformance/ Interim Resolution Summarv C:ndition Fire Interim Humber Condition Description Area Resolution I
CHANGES IN PREVIOUS ASSUMPTIONS I.A Assoelated DC Loads /Hiah Imoedance Fault I.A.1 Loss of Process and Diagnostic Monitoring 13H Required instrumentation Instrumentation is available I.A.2 Loss of DG Exciter Control 2
Hot shutdown repair to provide alternate power feed I.A.3 Loss of Process and Diagnostic Monitoring 2
Required instrumentation Instrumentation is available I.B Grounds on Unarounded DC Svstems I.B.1 Blown Control Power Fuse for ESW 43, 44, Hot shutdown repair to 45, 46 isolate fault I.B.2 Blown Control Power Fuse for ESW/ Breaker 37, 35, Hot shutdown repair to Lockup 39, 45, isolate fault 50 I.B.3 Tripping of RHR Pump Breaker 35, 36. Hot shutdown repair to 37 isolate fault I.B.4 Tripping of HPCI Turbine 6S Hot shutdown repair to override HPCI trip I.B.5 Blown Logic Power Fuse for Core Spray 2
Hot shutdown repair to obtain manual control of Core Spray I.C Control of Svstems to Prevent Vessel Overfill
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Candition Fire Interim Humber Condition Description Area Resolution I.C.1 Inability to Isolate HPCI 13N Manuel operation at local control station I.C.2 Inability to Isolate RCIC 25 Menual operation at local control station I.D Seoarat ion Between Manholes for Imbedded Conduits a
I.D.I Inadequate Separation 'bstween Redundant 50, Fire watch HPSW/ESW pumps Yard I.D.2 Inadequate Separation between Redundant Yard Fire watch DG cables I.E Damaae to Parallel Al-Headers for SRV 135 Hot shutdown repair to restore Ocaration air supply I.F Sourious Ooonina_of Head Vent - Hi/Lo 2, 25, Resolved by interim modification Pressure Boundarv 6H. 6S, 18, 135, 21 II.
SPURIOUS OPERATIONS II.A Sourtous Ooorations at Inconortune Times II.A.1 RHR Pump Breaker Logic Trip / Lock-Up 34 Hot shutdown repair to isolate fault II.A.2 Ho RHR pump Minimum flow Protection 6S, 13H Fire watch II.B Sourious Ooerations that Defeat Svstem Function II.B.1 Spurious CO2 Injection in DG 44, 45, Analysis Compartments 46, 54 II.B.2 Closure of ESW Sluico Gates 39, 50, Resolved by permanent modification 25
C:ndition Fire Interim Number Condition Deteription Area Resolution II.B.3 Closure of ESW Discharge Valve 2, 25.
Resolved by interim modification 34, 36, 43 II.B.4 HPCI Spurious Isolation Signal 13S Hot shutdown repair to override HPCI trip II.B.5 Operation of Bus Differential Relay 34, 35, Hot shutdown repair to I'
36, 37 isolate fault II.B.6 Feedwater Block Valve' Closure 25 Manual operation at MCC II.B.7 RCIC Isolation Valve Closure 6H Hot shutdown repair to RHR logic; use method C III.
OTHER ITEMS III.A Loss of Core Sorav Flow Indication 2
Required instrumentation is available i
III.B Loss of RHR/HPSW Flow Indication 30 Required instrumentation is available III.C Emeraenev Llahtina 2, 5.
Use available portable 10, 6S, emergency light ing 6H, 135, 13H, 12, 25, 45, 46, 50, Yard III.D Loss of Power to DG Auxiliarv MCC 6H Hot shutdown repair to maintain DG 40 Resolved by permanent modification III.E Incorrect Circuit Breaker Coordinat ion -
50 Resolved by permanent modification Hlah Innedence Fault III.F Loss of HPCI - Associated Circuit 6S Fire Watch III.G Loss of Torus Temoerature Indication 13H Indication not needed
C:ndition Fire Interim Humber Condition Description Area Resolution IV PREVIOUSLY IDENTIFIED ITEMS IV.A Unit 2 Process..Monitorina and Dimanostic Instrumentation IV.A.i Loss of Process and Diagnostic 2
Required instrumentation Instrumentation is available
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IV.A.2 Loss of RHR Flow Indicatlon 4
Required Instrumentation is available IV.A 3 Loss of Process Indication 6N Required instrumentation is available
- V.A.4 Loss of Process and 6S Required instrumentation is Diagnostic Indication available IV.A.5 Loss of CST Water Level 50 Indication not required Indicatlon (V.B Thermal Maanetic Breakers - Associated Analysis Circuits IV.C Sourtous Closure of HPCI and RCIC Steam 6S, 13H Fire watch Valves IV.D toss of Unit 2 Rollef Valve Ooorabilliv 6S Hot shutdown repair to restore air supply, fire watch 6H Fire watch Resolved by analysis V.E Testable Check Eauelizer Valves on RHR and CS I
V.F Unit 2 and Common A lternat ive Shut down 25 Hot applicable
.V. 0 Alternative Power Suoolv for HPCI Steam 25 Analysis Suoolv Valves On schedule, awaiting SER IV.H Structural Steel 1
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