ML20212H720

Responds to NRC Re Violations Noted in Insp Rept 50-277/85-40.Corrective Actions:Licensed Operators Involved, Including Control Room Supervisor,Disciplined by Superintendent for Operations

ML20212H720
Person / Time
Site:	Peach Bottom
Issue date:	03/13/1986
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8701270547
Download: ML20212H720 (4)

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r PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. D A LTROFF n5%I"//SEo- March 13, 1986 Docket No. 50-277 Inspection Report No. 50-277/85-40 Mr. Samuel J. Collins, Chief Projects Branch No. 2 Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Collins:

Your letter dated February 11, 1986 forwarded Inspection Report No. 50-277/85-40 for Peach Bottom Atomic Power Station, Unit 2. Appendix A of your letter addresses an item which does not appear to be in full compliance with NRC requirements. The apparent violation concerns improper blocking of a control rod in the fully withdrawn position. Your letter also expressed a concern about "the ability of Unit 2 to meet Technical -

Specification shutdown margin requirements with a control rod blocked (tagged out) in the fully withdrawn position as was identified in this inspection. " This concern is addressed in the

" Extent or Significance of Violation" section of this letter.

The apparent violation is restated below and followed by Philadelphia Electric Company's response.

Restatement of Violation:

As a result of the inspection conducted on October 26, 1985 -

December 31, 1985, and in accordance with the revised NRC Enforcement Policy (10 CFR 2, Appendix C) published in the Federal Reaister on March 8, 1984 (49 FR 8583), the following violation was identified:

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.- Mr. Sncu 1 J. Collins March 13, 1986 Page 2 Technical Specification 6.8.1 and Appendix A to Regulatory Guide 1.33, November 1972, require implementation of procedures for operation of safety-related BWR systems including the control rod drive system.

Control rod drive system operating procedure S.4.2.C,

" Removing a Control Rod and Its Hydraulic Control Unit from Service During Reactor Operation", Revision 0, December 15, 1972, requires that a control rod be placed in a full-in position prior to removing it from service.

Contrary to the above, with Unit 2 at 44% reactor power from 12:05 a.m. to 1:45 p.m. on December 26,' 1985, control rod

1. 22-11 was full out at position 48 and blocked out of service per blocking permit #2-3-M85-09148.

This is a Severity Level IV Violation (Supplement 1) applicable to DPR-44.

Response

Admission or Denial of Alleged Violation:

Philadelphia Electric Company acknowledges the violation as stated above.

Reason for Violation:

The licensed operators (both R.O. and S.R.O.) who authorized the blocking committed a fundamental error by not assuring that the rod was moved to the fully inserted position.

Extent or Significance of Violation:

During the entire period that control rod 22-11 was fully withdrawn and blocked (from 1205 to 1355 hours0.0157 days <br />0.376 hours <br />0.00224 weeks <br />5.155775e-4 months <br />), Unit 2 was at power and moderator temperature was approximately 540 degrees Fahrenheit. If a scram had occurred and all control rods moved to the fully inserted position except rod 22-11, the core would have been made subcritical. The core would have remained subcritical even with ambient moderator temperature (68 degrees Fahrenheit) .

hr. Sasual J. Collino March 13, 1986 g Pago 3 If a scram had occurred while control rod 22-11 was fully withdrawn and blocked, and.the strongest control rod (ro'd 26-

11) remained in the fully withdrawn position, the reactor would have been made subcritical because moderator temperature'was approximately $40 degrees Fahrenheit. The core would not have remained subcritical if the moderator temperature had decreased to below 168 degrees Fahrenheit.

However, several hours would have been available to remove the block on control rod 22-11 and insert it before the moderator temperature decreased to~168 degrees Fahrenheit.

Because post-scram procedures require the operators to promptly verify that all control rods are in the fully-inserted postion, steps would have been immediately taken to insert the blocked rod before moderator temperature decreased below 168 degrees Fahrenheit.

Technical Specification Shutdown Margin Concern:

1 Technical Specification Limiting Condition for Operation-3.3.A.1 requires that "A sufficient number of control rods shall be operable so that the core could be made subcritical in the most reactive condition during the operating cycle with the strongest control rod fully withdrawn and all other operable control reds fully inserted." Assuming the "most reactive condition" to be ambient moderator temperature and most reactive cycle f core exposure, this requirement was not satisfied.

However, Unit 2 was maintained at power (540 degrees Fahrenheit) during the entire period that control rod 22-11 was blocked in the fully withdrawn position.

Corrective Actions Taken to Avoid Future Non-Complinace and Results Achieved:

The licensed operators involved, including the Control Room Supervisor, have been disciplined by the Superintendent-Operations. The operators were advised that blocking a control rod in a withdrawn position is considered an error striking to the fundamentals of reactor operations. During counseling, the Superintendent emphasized the importance of constant attention to operational details in reactor operations. The Superintendent advised that errors of this nature will not be tolerated by management and, therefore, repeat of such operator failings will lead to elevated discipline and more severe corrective actions.

During our investigation, it was noted that the Standard Blocking Sequence for control rod drives does not provide direction to the operators concerning the position the rod 1

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• Sr..Sanusl'J. Collins March 13,.1986

- Paga 4 should be'in prior to blocking. The permit for blocking control rod 22-11 was- written based on the Standard Blocking Sequence. A cautionary note is being added to the Standard Blocking Sequence to alert the operators to the fact that the rod should be fully inserted prior.to blocking. It is believed that this will further aid in preventing recurrence of this incident. The Standard. Blocking Sequence will be revised by April- 30, 1986.

Date When Full Compliance Will Be Achieved:

Full compliance has been achieved.

l If you have any questions or require additional

information, please do not hesitate to contact us.

1 l-l Very truly yours,

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Jcc: T. P. Johnson, Resident Site Inspector I

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