ML20235Y423
| ML20235Y423 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/20/1987 |
| From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20235Y401 | List: |
| References | |
| 50-277-87-11-EC, 50-278-87-11, GL-86-10, NUDOCS 8707250252 | |
| Download: ML20235Y423 (11) | |
See also: IR 05000277/1987011
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Combined Report No.
87-11
50-277
Docket Nos. 50-278
License Nc.
Category
C
Licensee:
Philadelphia Electric Company
2301 Market Street
Philadelphia, Pennsylvania 19101
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Facility Name:
Peach Bottom Units 2 and 3
Meeting At: NRC Region I King of Prussia, Pennsylvania
Meeting Conducted: June 3, 1987
7 /1/!/7
Inspectors:
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A.'Kraso'poulos, Reactor Engineer, DRS
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Approved by:
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. Ariderson', Chief,' Plant Systeins Section
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Division of Reactor Safety
Meeting Summary:
Enforcement Conference at NRC Region I on June 3, 1987 to
discuss the 10 CFR 50 Appendix R violations identified by the licensee in
letters dated May 22, September 17 and October 31, 1986 and verified by the
NRC in the combined inspection report 50-277/87-11 and 50-278/87-11.
The items discussed were the five examples of the violations identified in the
report.
The licensee presented their perspective on the findings, their impact on
safety and the reasons for occurrence along with their corrective actions.
8707250252 870720
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DETAILS
1.0 Meeting Participants
1.1 Philadelphia Electric Co. (PECO)
W. Birely, Licensing Engineer
G. Reid, Senior Engineer
S. Kowalski, Vice President
R. Lees, Assistant Chief Electrical Engineer
W. Boyer, Supervising Engineer
D. Spamer, Electrical Engineer
D. Smith, Manager
W. Alden, Licensing Engineer
G. Morley, Supervising Engineer
G. Swenson, Nuclear Operations
G. Leitch, Manager - Nuclear Generation
1.2
U.S. Nuclear Regulatory Commission (NRCl
J. Allan, Deputy Regional Administrator
W. Johnston, Acting Director, Division of Reactor Safety
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W. Kane, Director, Division of Reactor Projects
J. Linville, Section Chief
L. Bettenhausen, Acting Deputy Director, Division of Reactor Safety
C. Anderson, Section Chief, Plant Systems Section
D. Holody, Enforcement Officer
J. Durr, Branch Chief, Engieering Programs Branch
J. Gutierrez, Regional Counsel
R. Martin, LPM, NRR
J. Raleigh, NRR
2.0 Purpose
This Enforcement Conference was held at the request of the Region I
management to discuss the violations of the 10 CFR 50 Appendix R
requirements identified by the licensee in letters to NRC dated May 22,
September 17, and October 31, 1986.
Five examples of this violation were
subsequently verified by the NRC and documented in combined inspection
report no. 87-11,
3.0 Presentation and Discussion
Following the initial introductions and the opening remarks by the Deputy
Regional Administrator, Mr. J. Allan, and the Acting Director of the
Division of Reactor Safety, Dr. W. Johnston, the licensee was asked to
present their perspective and the reasons for the noncompliance.
The licensee, for discussion purposes, distributed the meeting's agenda,
along with a document listing the recent Appendix R chronology of events
and a chronological listing of Appendix R activities.
These documents
appear as Attachment I to this report.
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With regard to the causes of the noncompliance, the-licensee stated that
they were under the impression that NRC was aware of the Appendix R
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compliance status'since they were providing NRC with status reports of the
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Fire Protection modification work, ~These reports were submitted to NRC
every four months since May 1983.
Eleven of the noncompliance identified
by the licensee in the May:22, September 17 and October 31, 1986 letters
were identified in these status report letters.
As stated by the licensee, the reason for the noncompliance is a
combination of several factors. The licensee said that because of
changes in their initial assumptions they were late in starting the
Appenix R effort.
The licensee's initial approach to Appendix R
compliance involved a quantitative analysis which was not accepted by the-
NRC. .This is what caused the. late start of the Appendix R program,
In. addition, the licensee stated that the magnitude of the Appendix R
effort was underestimated. When the licensee began the engineering
analysis to scope-the work for Appendix R compliance, the licensee started
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using color coded drawings to identify and track safe shutdown systems.
This manual effort' proved unwieldy and mistake prone, as theLvolume of
data to be tracked increased with the progress of work.
Changes in analysis assumptions was another reason given by the licensee
for the noncompliance. These changes were caused by evolving NRC
guidance. . For instance, the guidance issued in Generic Letters 85-01 and
86-10 resulted in the invalidation of certain assumptions made in the
licensee's spurious signal and high impedance fault analysis thereby
causing some of the non-conformances.
Finally the licensee stated.that six of the noncompliance were errors
of omission.
The licensee also stated that, when it was realized that problems with
Appendix R compliance may exist and to resolve the problems caused by
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reliance on manual tracking of this effort, it was decided to perform a
confirmatory Appendix R analysis using a computer program.
It was this re-evaluation that identified the nonconformances from the
Appendix R requirements. This type of analysis aids the maintenance of
Appendix R compliance, lends itself to easy retrieval of data and
facilitates the compliance effort.
Concluding Statements
The Deputy Regional Administrator thanked the licensee for their
presentation and stated that this information would be considered in the
NRC determination of enforcement actions related to these issues.
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Attachment 1
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AGENDA
APPENDIX R ENFORCEMENT CONFERENCE
JUNE 3, 1987 - REGION I HEADQUARTERS
INTRODUCTION
R. J. LEES
CHRONOLOGY
G. M. MORLEY
W.'J.
BOYER, JR.
DISCUSSION OF NON-CONFORMANCES
W. J. BOYER, JR.
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CAUSE
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SIGNIFICANCE
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STATUS
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QUESTIONS
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.' APPENDIX "R" ACTIVITIES
-FEB, 1981
- APPENDIX "R" RULE PUBLISHED
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JUN,-1982
SAFE SHUTDOWN ANALYSIS. SUBMITTED
To Meet III.G. of Rule
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'JAN,'1983.
NRC' LETTER RECEIVED INDICATING:
a)
Insufficient Detail.in SSD Reporti
b)
Tolling Req'mts, per 10CFR50.48 would begin Jun, 82
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NRC PECO "SUPNIT" MEETING ON:
APR, 1983-
a)
III.F, III.G., III.M Sections of Rule
b)-
Tri-Yearly Mod Progress Reports
SEP, 1983
ALTERNATIVE SHUTDOWN PROPOSAL SUBMITTED
DEC, 1983
HVAC DAMPER PROGRAM - EXEMPTION REQUESTS-
PENETRATION SEAL PROGRAM
ENCAPSULATION & REROUTING PROGRAM
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APR,-'1984
SAFETY EVALUATION REPORT
' APPROVAL OF
ALTERNATIVE SHUTDOWN PROPOSAL
DEC, 1984
ALTERNATIVE SHUTDOWN SCHEDULE DEFINED PER
10CFR50A8 RULE:
a)
Implementation occurs before start-up after
earliest of following:
1st refueling outage
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60 day planned outage
120 day unplanne,d outage
X conmencing 180 days after conmission approval
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MAR, 1985
SER APPROVAL OF FIXED SUPPRESSION SYSTEM
Exemption - Requests associated with the Alternative
-Shutdown Submittal
kR&JUN,198
STRUCTURAL STEEL SURVIVABILITY
Analysis and Proposed " Fixes" Submitted
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MAY, 1985_
-FIRE PROTECTION. EVALUATION' REPORT-
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-Project, started
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Limerick format
b)
Confirmation of Shutdown methods
c)
Living Docunent '
DEC,.1985
' PENETRATION SEAL PROGRAM COMPLETE
6300 openings in 347 barriers
-MAR, 1986-
a)
55 dampers installed
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61 damper total exemptions requested
29. remain to be approved
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f%R, 1986
AUDIT
a)
III.G, III.d, III.L Sections of Rule
b)
Complete safe' shutdown confirmatory program
by Sept. 30, 1986-
c)
Provide copy of FPER
d)
Notify Region I immediately of violation of
Ill.G, J
e)
Complete Alternative Shutdown mods for Unit 2,
and comnon trods for Units 2 and 3 prior to
start-up from next refueling outage.
SEP, 1986
FIRE PROTECTION PROGRAM SUBMITTED
a)
Submitted on schedule
b)
Complete program provided
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OCT-DEC, 1986
ALL REQUESTED EXEMPTIONS APPROVED
a)
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b)
Penetration seals
c)
Structural steel
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RECENT APPENDIX R CHRONOLOGY
LATE, 1985
RE-REVIEW / DOCUMENTATION OF,SSD
PECO DECISION
MARCH,'1986 NRC AUDIT
DATA LOADING IN PROGRESS
FIELD WALKDOWNS
METHODOLOGY DEMONSTRATED
NRC CONCERN /PECO SCHEDULE COMMITMENT
SEPT., 1986 FPP SUBMITTED
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ON SCHEDULE
COMPREHENSIVE
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OCT., 1986
REGION I MEETING
NON-CONFORMANCES
COMPENSATORY ACTIONS
SCHEDULE DISCUSSED
NOV., 1986
JCO LETTER
COMPREHENSIVE
SCHEDULE DOCUMENTET)
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CAUSE OF NON-CONFORMANCE.
PECO IN CONCERT WITH NRC
MANNER
SCHEDULE
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PECO UNDERESTIMATED SCOPE OF WORK
EVOLVING GUIDANCE
MANUAL EFFORT-COMPLEX INTERDEPENDENCIES-
INITIAL APPROACH
NON-CONFORMANCES
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OMISSIONS
PREVIOUSLY IDENTIFIED
GENERIC LETTER 86-10
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SIGNIFICANCE OF NON-CONFORMANCES
REGULATORY NON-COMPLIANCE
"REAL" VS. APPENDIX R FIRE
CONFORMED SHUTDOWN CAPABILITY VIA TRIP'S
PUBLIC HEALTH & SAFETY NOT IN JEOPARDY
QUANTIFICATION OF NON-CONFORMANCES
NUMBER OF JCO LETTER ITEMS
SUBSTANTIAL COMPLIANCE AT AUDIT
APPROX. 90% - MONETARY BASIS
$51M - TOTAL ESTIMATED COST OF
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PROGRAM WAS CONFIRMATORY
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STATUS
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PECO WILL MEET COMMITMENTS
UNIT 2 SSD/ASD BY END OF REFUEL OUTAGE
UNIT 3 SSD/ASD BY END OF FALL, 1987
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PIPE REPLACEMENT OUTAGE - (SOME UNIT
3 WORK ALREADY COMPLETE)
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CONCLUSION
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PECO DECISION TO RE-REVIEW
PECO WORKS IN CONCERT WITH NRC
RE-REVIEW COMPREHENSIVE
NUMBER OF'JCO ITEMS MISLEADING
DEGREE OF COMPLIANCE HIGH & IMPROVING
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