IR 05000277/1985015

Insp Rept 50-277/85-15 on 850410-19.No Violation or Deviation Noted.Major Areas Inspected:Work Performed During Extended Recirculation Piping Replacement Outage

ML20127A826
Person / Time
Site:	Peach Bottom
Issue date:	06/04/1985
From:	Beall J, Gallo R, Jerrica Johnson, Lange D, Paulitz F, Petrone C, Williams H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127A815	List: IR 05000277/1985015 ML20127A812
References
50-277-85-15, NUDOCS 8506210271
Download: ML20127A826 (25)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-15 Docket N License N DPR-44 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania Facility Name: Peach Bottom Atomic Power Station, Unit 2 Inspection At: Delta and Philadelphia, Pennsylvania Inspection Conducted: April 10-19, 1985 Inspectors: '1 b - **

, J. Yohnson,' Senior Resident Inspector, Pilgrim Date O L/1 A sA d r yWilliams,Resid(ntinspector Date OBuM Beall, Project Engineer shshr

~Dats eAL C'Pstrone, Lead Reactor Engineer gb2/er

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hF. Pa U ffam/kYoReactor Engineer Y W8W Date

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c n b 50]5'$(

Date ange, Reactf pgineer (Examiner)

Approved By:

R. GalTo, Chief, Projects Section No. 2A

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Inspection Summary (Continued) 2 Inspection Summary: Inspection on April 10-19, 1985 (Report No. 50-277/85-15)

Special announced operational readiness assessment team inspection of work per-formed during the extended recirculation piping replacement outage. The pri-mary purpose of the inspection was to verify that the licensee had established and implemented programs to restore the proper configuration of the reactor plant following extensive repairs and design changes and to revise the reactor operating information to support safe operatio Included were a review of management oversight and corrective action tracking, preoperational testing and system turnover, surveillance testing, installation of snubbers and pipe supports, recirculation and residual heat removal piping changes, electrical modifications and licensed operator requalification trainin The inspection involved 274 hours0.00317 days <br />0.0761 hours <br />4.530423e-4 weeks <br />1.04257e-4 months <br /> of inspection by two resident and four region-based inspector Results: No violations were identifie Strengths were identified in the areas of PORC involvement in the review of completed modification acceptance tests, daily outage meetings, the Major Outage Recovery Effort teams' coordi-nating activities and the licensed operator requalification lecture outlines and instructor qualification Weaknesses were identified in the areas of reviewing open problem reports prior to plant restart and ensuring that written exam administrator (s) get examined themselve t

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OPERATIONAL READINESS ASSESSMENT INSPECTION PEACH BOTTOM ATOMIC POWER STATION - UNIT 2 Table of Contents

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. Persons Contacted.............................................. 4'

~ Scope of Assessment............................................ 4 Action on Previ ous Fi ndi ngs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 4. -Management Oversight' and Corrective Action Tracking Systems. . . . 5 Modification Acceptance Tests and System....................... 7

~ Surveillance Testing........................................... 11 Snubbers, Hangers, Supports..................................... 12 . Recirculation and Residual Heat Removal Systems Piping

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Replacement.................................................. 15 El ectrical Equipment Modi fications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 1 Co re Spray Ve ri fi cati on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

' 1 Licensed-0perator Requalification and Training................. 20 1 Plant Tours.................................................... 21

- 13. Management Meetings............................................ 22 t

Attachment 1 - Persons Contacted and Documents Reviewed

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DETAILS persons Contacted Interviews and discussions were conducted with members of the licensee and contractor staff and management to obtain the necessary information per-tinent to the operational readiness assessmen Additional details are provided in Attachment . Scope of Assessment The licensee began an outage at Unit 2 in April,1984 to replace all of the recirculation system piping and residual heat removal (RHR) system piping inside the drywell and to refuel the cor The operational readiness team's purpose was to inspect Unit 2 for readi-ness to restart and resume full power operations following completion of the outage. During the inspection period the majority of equipment had been reinstalled and the reactor coolant system filled. Preparations were being made for refueling the cor The team evaluated the physical condition of systems repaired or modified as well as systems potentially affected because of proximity to the re-l paired or modified systems. Methods of review included system walkdowns, review of as-built drawings and verification of restoration and adequacy of hangers, snubbers, and support The inspection also evaluated the thoroughness of management reviews of problem reports (QA finding reports, QA noncompliance reports, and QC nonconformance reports), and the effectiveness of tracking problems to resolutio The licensee's system for post-modification inspection and testing was

, evaluated. This included a review of preoperational testing and system

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turnover. A review was also performed of routine surveillance testing i conducted and planned for safety related instrumentatio Impact of ( modifications on potential Technical Specification changes was also eval-l uate An assessment was also made of licensed operator qualifications. This included a review of the requalification program as well as training on system modifications and proposed changes to the Peach Bottom FSAR and Technical Specifications. As part of this evaluation, individual inter-l views were conducted with licensed operators, and classroom lectures were l observed.

l The inspection identified strengths, weaknesses, and additional items for which furthet followup is planned.

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3. Action on Previous Inspection Findings (Closed) Inspector Follow Item (277/85-08-02) dealing with the 10 CFR Part 21 report on the washers used with recirculation pipe clamps. See discussion in Section . Management Oversight and Corrective Action Tracking Systems Scope The inspector reviewed the licensee's organizational structure and interviewed the different groups of people who were responsible for auditing, surveilling and inspecting different aspects of Unit These groups included the Engineering and Research Quality Assurance Division, the Engineering and Research Construction Division (includ-ing field construction project management), the licensee's prime contractor's (Chicago Bridge and Iron Company) Quality Assurance supervisor, and the Electric Production site Quality Assurance Audit and Quality Control groups. The effectiveness of tracking problem reports was evaluated, and open reports were reviewe The inspector reviewed these open findings with respect to impact on future operational milestones such as fuel loading and reactor start-up. A comparison of the CB&I fuel load check list and the licensee's outage planning group's fuel load check list was mad In addition, with regard to impact on operational mode changes, a

review was performed of the modifications implemented and the result-ing Technical Specification changes necessitate Findings (1) The CB&I system for tracking nonconformances was good. The system was found to be in accordance with the CB&I Nuclear QA Manual, Division 4, Section 14 with retrievable and complete records. Work packages (travelers) were not signed off as com-plete until nonconformances were resolved. The inspector noted that the CB&I group was working to a fuel load check list that had a few minor items to be completed that did not appear to be tracked on the licensee's outage planning fuel load check lis An example was work on an angle support for the Core Spray sys-te The licensee's construction division field supervisor acknowledged the inspectors comments and stated that a review would be performed to ensure that both fuel load check lists were consistent. The inspector noted that in general the check lists were consistent and had no further concerns or question The inspector noted that the licensee's plant staff was continu-ing with daily outage meetings and was actively overseeing and evaluating work items to be completed for fuel loading. This was noted to be a strength in the licensee's activitie <

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(2) Following the review of open problem reports identified by the various quality assurance and quality control groups, the inspector determined that there was a weakness in the licensee's system in that there was no planned review of these items to be conducted to ensure that there would be no adverse impact on fuel load or plant startup. The Engineering and Research Quality Assurance Division's finding reports were also not issued to the Station Sup,erintenden The open (Electric _ Production Department Quality Assurance Audit) noncompliance reports included a significant finding (AP 84-54-01) that the leakage tests required by the ASME Code,Section XI, were not completed. Also a finding (SP 83-13-01)

was still open regarding operability of the post accident samp-ling system. These findings could have some impact on plant startu The Electric Production Operations QC Group findings were being tracked in a log. The log included five ope'n findings that were not listed in the " Summary of Open Nonconformance Reports as of March 31, 1985" being prepared for distribution to plant manage-ment. The QC representatives corrected these discrepancies on the spo Some Nonconformance Reports had not been issued to the responsible station personnel because the QC group stated that the findings were being tracked via 1-) Suspected Mainten-ance Request Forms (SMRFs), or 2) the computerized history and maintenance planning system (CHAMPS). Although the inspector noted that this was authorized by the governing procedure (QADP 9.1 Rev. 0) it was not clear that all pen items would be cor-rected when they needed to be (prior to fuel load for example).

The licensee stated that if the QA findings would impact plant startup that either 1) a stop work order would have been written or 2) a Maintenance Request Form (MRF) would ensure resolutio The inspector determined that, in general, the audited or in-spected organizations appeared to be responsive to the findings and that the licensee's system was effective in ensuring resolu-tion of problems but not necessarily with respect to an opera-tional mode of the plant namely fuel load or startup. The lack of a ' systematic' effort to review these open problem reports prior to fuel load and plant startup is considered a weaknes (3) Following a review of modifications implemented it appeared that the licensee had completed processing or was adequately tracking Technical Specification changes for all but one modification, 83-93. This modification consisted of installing a drywell-to-torus differential pressure instrument. An internal PECO elec-trical engineering division memorandum dated March 5, 1985,

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stated that the purpose of the instrument was to provide assur-ance that the drywell is operating at a slightly positive differential pressure (d/p) which was the basis for the torus pool swell loading analysi The inspector questioned the licensee regarding the necessity to maintain a certain value of d/p to ensure plant safety and to provide a Technical Specification (T.S.) limiting condition for operation and associated surveillance requiremen The licensee stated that this would be reviewed and additional information provided to the NR Pending a review of the necessity of Technical Specifications for the drywell-to-torus d/p this item is unresolved (50-277/85-15-01).

5. Modification Acceptance Tests and System Turnover A review of the licensee's turnover and testing program was performed to determine if the turnover and acceptance of modified systems was conducted in a manner which would identify and resolve any remaining problems, and to verify appropriate testing was performed. The inspector discussed the turnover and testing program with cognizant licensee personnel, reviewed the administrative controls, reviewed a sample of completed Modification Acceptance Tests (MATS), and reviewed the planned test program for the Reactor Recirculation Syste Administrative Controls (1) Scope The procedure, " Major Outage Recovery Effort (MORE) Project Standards for Pre-operational /Startup Testing Phase," Revision 0, 2/1/85, describes the standards which apply to the MORE organization and controls preoperational and startup testing of the major Recirculation /RHR Piping Replacement Modification The preoperational and startup tests are performed in accordance with written procedures called Modification Acceptance Tests (MATS). The MATS are prepared by the MORE Test Engineer and approved by the Plant Operations Review Committee (PORC). MORE Discrepancy Reports are issued to document construction / design /

maintenance deficiencie The procedure A-14, Plant Modification, Revision 9, 3/28/83 describes the control mechanisms for implementing and control-ling modifications to plant systems or equipment. The procedure assigns the responsibility for ensuring compliance to a modif-ication coordinator who is required to submit the modification to the POR The Technical Engineer is responsible for pre-paration of the preoperational test ~

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8 (2) Findings Based on review of these documents, and discussions with MORE team members, the inspector concluded that the turnover and testing process had been adequately and clearly define b. Sample Review of Completed MATS (1) Scope The inspector conducted a sample review of four MAT packages, which had been completed and PORC approved, to determine if:

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The procedures had been prepared, issued, performed and approved in accordance with the MORE Project Standard, Revision 0, dated 2/1/85;

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The procedures contained appropriate references, prere-quisites, precautions, step-by-step instructions, and acceptance criteria;

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All procedure steps had .been completed and signed off as required;

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All acceptance criteria had been met or a discrepancy report had been issued to document and resolve any devia-tion;

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The MAT packages contained all required material including copies of completed Surveillance Tests (STs), Rout.ine Tests (RTs), Isometric and P&ID drawings, MORE discrepancy reports, maintenance request forms (MRFs), and the MAT report;

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QC inspections were signed off as required; and,

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Post maintenance testing was performed where specifie (2) Findings The inspector verified the adequacy of the MAT packages and noted the following during his review:

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MAT 1278 PB2-48 Motor Operated Valves, Interlocks, and Position Indication (PCIS and ECCS) verified proper opera-tion of interlocks and position indications for valves M0-10-018, MO-12-015 and M0-12-018. The procedure required that a local lea rate test (LLRT) be performed following manipulation of each valve. QC verified the stroke time and motor current during stroke testing. The deficiencies identified were satisfactorfly resolve ,

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MAT 1278-PB2-23, Standby Liquid Control (SBLC), verified that the SBLC system manual isolation valve and piping inside the 6 ywell were operationally tested satisfac-toril The valve (2-11-018) position indication in the Control Room was verified correct. A walkdown by the QC inspector of the valves and piping during the systems hydrostatic testing on 4/9/85 verified there was no leakage from the syste .

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MAT 1278-PB2-06, Manual Valves with Indication, verified that the Core Spray Manual Injection Valves 2-14-14A and 2-14-148 had been inspected for physical damage, proper limit switch actuation and valve position indicatio MAT 1278-PB2-01H, All Small Piping Inside Drywell, Part H, verified that the walkdown and inspection of System 19, Bellows Drain Piping, had been completed satisfactoril This system was not modified during the outage but was inspected by the licensee because it could have been damaged by construction activitie This inspection identified two discrepancies, a broken conduit and an incorrectly installed pipe support, which were documented on MORE Discrepancy Reports forms as require Based on this review, the inspector concluded that the turnover and testing were being performed in accordance with the licen-see's administrative controls and appeared to provide adequate assurance that any remaining problems had been identified and resolve c. Recirculation System Post Modification Testing (1) Scope The inspector reviewed the licensee's planned testing of the recirculation system following the completion of the Mod 1278, Recirculation Pipe replacement. The scope of the recirculation pipe replacement was reviewed to identify those portions of the system that were affected. The post modification test program was reviewed to confirm that the modified system would perform its intended functions as described in the FSAR and Technical Specification The inspector reviewed the following MATS which implemented the preoperational and startup tests planned for the Recirculation Syste r .

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(2) Findings

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MAT PB2-13A, Recirculation Piping Replacement was issued to veri fy the functional and dynamic performance of the Recirculation system components, control switches and piping. The inspector noted that it required verification that applicable prerequisites, system flushes, and surveil-lance tests were complete. Appropriate notes and pre-cautions regarding one pump operation, excess vibration, and pump cavitation were include Detailed step-by-step instructions were provided to functionally test recircula-tion pump motor high and low oil level alarms, pump-motor temperature indication, and control logi MAT PB2-138, Recirculation Pump Vibration Monitoring MOD 925 was written to perform a functional and operational verification of the new Recirculation pump and motor vibra-tion monitoring installation (MOD 925). Detailed procedure steps are included for a functional verification of each sensor loop and the vibration alarms. Temporary vibration monitors will also be installed to provide a comparison check for the (new) permanently installed equipment during pump motor operational test MAT PB2-13C, MOD 1192, Recirculation Pump Motor 2AP34 Lower Bearing 011 Reservoir Level Switch, was written to opera-tionally verify the new lower bearing oil reservoir level switch. Appropriate prerequisites included the requirement to obtain permission from the shift supervisor and reactor operator and to perform a calibration of the new switch and its associated instrument loop. The detailed procedure required verification sign off for racking out the 13.2 KV supply breaker to the recirculation MG set to prevent an inadvertent start during the functional testing of the level switc The inspector also reviewed MAT 1278 P82-14B and the MORE Test Report for the Recirculation Pump Seal Leak Detection and Seal Purge Piping Flush which was completed on 3/11/8 This flush confirmed that the seal pressure sensing lines and the seal drain lines did not contain corrosion or debris. No flow restrictions were observed. The minor changes made to prerequisites #1 and #2 were properly made and did not change the intent of the procedur The l flushes and flow tests were verified by a QC inspector.

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test program for the Recirculation System appeared adequate to ensure all problems would be identified and corrected prior to plant startup.

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11 Surveillance Testing

- Scope The inspector reviewed the licensee's method of scheduling surveil-lance tests to ensure that all required surveillance tests would be completed prior to refueling and prior to restar Findinos-Based on discussions with the cognizant licensee personnel and review of selected procedures, the inspector determined that the status of all required surveillance tests was being tracked by a coordinator who maintains a computer based list of all routine scheduled surveil-lance tests and an additional manual status list of all surveillance tests required once per refueling cycle. Using the computer based list, the coordinator issues a Weekly Test Schedule which includes all shiftly, daily,. weekly, monthly, etc. surveillance tests (STs)

to be performed that week. All completed STs are routed through the ST coordinator who reviews them for completeness and updates the status list Any STs which are not completed are automatically included in the Overdue, Grace Period List which is generated from the computer based data and issued to all personnel with responsibil-ity for the overdue STs. Any STs that could not be performed during the outage were temporarily lined out by the ST coordinator, but not removed from the computer status list. These STs will be completed as the plant nears restart and will continue to appear on the Over-due, Grace Period List until they are completed. This tracking sys-te:n appears adequate to ensure that afl required STs will be complete prior to restar The use of a cen:ralized ST coordinator and a single computer based system to track all routine STs appears to lesson the possibility of a required ST being misse In preparation for fuel load, the licensee issued a procedure, SP 800, " Plant Conditions Necessary to Fuel Reload Unit 2", which pro-vides a check-off list of systems, conditions, or tests necessary before core reload could begin. The inspector (in conjunction with the resident inspector) reviewed this procedure against- the require-ments contained in Technical Specifications and did not identify any fuel load required surveillance tests or prerequisites that were not contained in Special 800 or Procedure FH-6C, Fuel Movement and Core Alteration Procedure During a Fuel Handling Outag At the time of this inspection, the licensee had completed and signed off approximately half of the'STs and MATS required by the procedure, SP 800. The inspector chose a sample of 16 STs and 13 MATS, and reviewed the completed and signed off test procedures to verify that they had been completed satisfactorily. No discrepancies were iden-tifie ____ ___ ______

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The licensee's program to assure that all required testing and pre-requisites are complete prior to fuel load appears to be effectively implemente . Snubbers. Hangers and Supports a. Scope:

The inspector reviewed plant procedures, drawings, MATS, MORE Test Reports, and other records and inspected hangers and snubbers in the Unit 2 drywell to verify that snubbers, hangers, and supports for safety related piping and equipment are in conformance with regula-tory requirements, plant drawings, and procedure The inspector reviewed the licensee's corrective actions concerning faulty pipe clamps supplied by Western Pipe and Engineering for hanger assemblies H-2, H-10 and H-11 on the recirculation system pipe. The inspector reviewed the licensee's method of controlling snubbers on safety related pipe after the implementation of Technical Specification Amendment 107 which deleted the snubber list from the Technical Specificatio b. Findings:

(1) Amendment Number 107 forwarded in NRC letter dated 3/19/85 changed the Technical Specifications associated with safety related snubbers. Amendment 107 does not include TS Table 3.11D.1 which lists the snubbers. The licensee had not incor-parated Amendment 107 into his Technical Specification at the time of this inspectio The inspector discussed with the licensee the procedures for assuring that safety related snub-bers formerly listed in TS Table 3.110.1 were properly control-led. The snubber table will be handled as a controlled drawing which can be changed by the plant modification process. Changes will require an engineering evaluation, a safety evaluation and PORC revie Modification 1278 introduced the following changes:

Six hydraulic snubbers were replaced with larger capacity mechanical snubbers (SS-1, 2, 6 A&B)

• Four hydraulic snubbers on the recirculation manifolds were deleted (SS-5A, B, C and D)

The inspector reviewed the safety evaluation for MOD 1278 and 1367, Rev. 9 and NEDC-30500, Piping Replacement to Improve Resistance to IGSCC Safety Evaluation for Peach Bottom Unit 2 associated with these changes. MOD 1278 is still in progress and the list of snubbers has not been issued as a controlled drawin _ - _ _ _ _ _ -

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The inspector reviewed ST 15.9-2, Revision 16, Seismic Hydraulic and Mechanical Snubber Inspection Unit 2 Only, dated 4/10/84 and compared the listed snubbers with those in Technical Specifica-tion Table 3.11.D.I. All snubbers listed in Table 3.11.D.1 were included in ST 15.9-2. ST 15.9-2 was being revised to identify accessible and non-accessible snubbers. The inspector attended the PORC meeting where this revision was discusse Based upon this review, the inspector finds that the licensee's controls are adequate for the safety related snubbers that were listed in the Technical Specificatio (2) The inspector reviewed MATS P82-11A, B and C and the associated MORE test reports. P82-11A, " Snubber Inspection", was partially completed on 4/22/85 to allow fuel load to commenc Several discrepancies were noted in that certain cold piston settings were out of tolerance. An engineering evaluation concluded that the cold piston settings were a restraint on heatup but not fuel loa The inspector accompanied the test engineer on an inspection of two of these snubbers (SS 3A, 4A) and discussed the problem with the test engineer. Snubbers (SS 3A, 4A) were repaired and reinspected by the test engineer subsequent to this inspectio PB2-118 "Large Pipe Support Inspections" and PB2-11C, "Small Pipe Support Inspection" were also partially completed to allow fuel load to commence. These reports as well as the MORE test reports were reviewed. No unacceptable conditions were noted in these documents anJ the licensee's system for documenting, correcting and reinspecting discrepancies appeared to be working wel The inspector reviewed ST/ISI-5, " Inservice Inspection - Visual Examination of Spring Hangers, Rigid Supports and Anchors", and the associated documentation. Forty-three hangers were examined as part of the ISI baseline inspection and the inspector re-viewed the data sheets for all 43 hangers and supports. Dis-crepancies on hangers H-4, H-5, H-14. H-15, H-16, and H-17 on the recirculation system had been noted by the licensee and had been corrected and reinspected. At the time of the inspection the following supports were still being worked on by the licensee:

RWCU 12 DCN-H-152 RHR 10 DE-H-130A RHR S-80 RHR 10 DCN-S-66 RHR 10 DE-H-132A Recirc-B H-9

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, Based upon a review of the data sheets and the licensee's system for correcting and reinspection of hanger discrepancies, the inspector concluded that the hangers and supports will be ready i for plant operatio (3) The inspector examined a sampling of snubbers and hangers in the Unit 2 drywell. Snubbers were examined for freedom of motion, installation of cotter pins, fluid leaks, fluid level, and general condition of the snubber Hangers were examined for general conditions. Snubber 1-GG-S-7 was found to be tight and would not move freely. The inspector discussed this problem with the licensee and determined that the licensee was already aware of the problem. The snubber had not been turned over to

, operations. Snubber 1-GG-S-3 was noted to have a low fluid level in the reservoi The licensee's records listed the reservoir as 45% full, which was lower than normal but accept- ,

able. These two snubbers were on Main Steam Relief Valve blow-

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down lines. Except for the conditions noted, all snubbers and l hangers examined were satisfactor NRC Inspection Report 277/85-08 described a problem with pipe clamps supplied by Western Pipe and Engineers which was reported as a Part 21 repor The inspector reviewed the Part 21 report

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and discussed the problem with the licensee and his contracto The faulty clamps were part of pipe hanger assemblies for H-2,

, H-10, and H-11 on the recirculation piping system. The design report for the clamps specify use of two spring disc washers between the clamp beam and the load nut to compensate for the differerre in the rate of thermal expansion between the stain-less steal piping and the low-alloy U-bolt. The hangers had one flat washer installed as reported in Inspection Report 85-0 After analyzing the operability of the hangers it was determined that the spring discs were critical to the integrity of the

clamp. Western Piping and Engineering made the Part 21 Report on 3/4/85. The inspector reviewed the licensee's corrective action, including the travellers and associated drawings for the recirculation loops A and The flat washers were replaced +

with two spring washers. The inspector examined two hangers in

, the drywell to verify the washers had been changed. Based upon discussions with the licensee, review of the documentation and i inspection of the hangers the inspector concludes that the corrective action was adequat This item (277/85-08-02) is

, close Within the scope of this inspection of snubbers and hangers the r inspector found that approved procedures were being followed, and ;

that identified deficiencies were documented, reviewed and correcte No unacceptable conditions were observe _ _ _ _ -_ _ _ _ _ - _ _ . _ _ - _ _ _ _

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8. Recirculation and Residual Heat Removal Systems Piping Replacement Scope The inspector reviewed Modification Package 1278 (MOD 1278) which involved the replacement of the piping for the Recirculation System and the in-drywell portion of the Residual Heat Removal (RHR) Syste Most of the work performed in the Peach Bottom Unit 2 drywell during this outage was under MOD 1278. The licensee's safety evaluation and its subsequent revisions were reviewed for completeness in addressing potential safety question The inspector examined the process in place for identifying changes required to update design and licensing documents to reflect known modifications. Selected design documents supporting modifications made under MOD 1278 were reviewed for technical adequacy including the large bore piping stress analysis and the documents associated with the replacement of the ECCS suction strainers in the toru Findings (1) The safety evaluations associated with MOD 1278 had all received the appropriate level of review and had been approved by the PORC. Safety concerns had been adequately addressed and changes had been identified for the Technical Specifications and the FSAR. The process for identifying and incorporating changes to design documents include the following Engineering and Research Department (ERDP) procedures:

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ERDP 3.1, Procedure for Handling Q-Listed Modifications

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ERDP 3.3, Procedure for Performance of Safety Evaluations, Applications for Amendments to Facility Operating Licenses, and Changes to the Updated Final Safety Analysis Report

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ERDP 3.4, Procedure for Design Control

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ERDP 3.6, Procedure for Preparation and Review of Engineer-ing Drawings for Nuclear Plant Modifications The inspector reviewed the licensee's procedures and found them to be adequate. The inspector independently identified several changes caused by MOD 1278 which could require revisions to the Technical Specifications, the FSAR and design drawings. Exam-ples of these items include:

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Elimination of recirculation cross tie valves and piping (TS 4.6.E.2 and FSAR Figure 4.3.2A)

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Change in insulation type from mirror to fiberglass blanket (FSAR Section 4.3.4)

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Changes in snubber type and numbers (Drawing 730 E 116 and FSAR Section C.5.3.6)

In each of the above cases, the licensee was incorporating the required changes in revisions being prepared to the design docu-ments. The proposed revisions were reviewed and were found to be acceptable. In the casa of the new insulation type, the licensee had determined that no change was necessary since the type of insulation had not been previously identified and the properties of the two types were not sufficiently different as to invalidate the original descriptio (2) The inspector rtviewa the stress analysis for the new Recircu-lation and RHR system pipin Loading combinations, moments and service level val.as were compared to allcwed values. The maximum allowable loads for the new mechanical snubbers vary for the service condition being analyzed as described in the GE safety evaluatio The values used were compared to ASME Sec-tion III limits and were confirmed to be acceptabl The licensee and GE safety evaluations concerning the replace-ment of the mirror type insulation on the Recirculation and RHR Shutdown Cooling lines with a fiberglass blanket typ' were examined. One effect of the new insulation is to increase the potential quantity of debris in the torus following a hypothet-ical LOCA which could be entrained by ECCS pump The results of the analyses called for larger strainers on the ECCS inlets in the torus. The necessary increase was calculated to be 19 square feet for the RHR suctions and 8.4 square feet for the Core Spray suctions. The strainers were modified during the outage to attain the needed surface area. No deficiencies were identifie (3) The inspector compared the small bore piping drawings listed in MOD 1278 as being affected by modification work with the draw-ings identified by the corresponding MAT, PB2-18, as needing field verificatio No drawings were found to be omitte Portions of the MAT walkdown were selected and performed by the inspector on a sampling basis to verify that piping modifica-tions had been installed as shown oc that deficiencies had been identified for correction.

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, 17 The inspector compared approved drawings to as-built hardware including hangers, snubbers, guides, couplings, caps and valve orientation. Small bore piping, electrical conduit and cables were examined for signs of damage or excessive wear. The large bore recirculation piping was walked down and several- connec-tions by smaller piping were traced to verify that small bore restraints had not been located in such close proximately to the connection that thermal growth by the recirculation piping could cause excessive stresse During the physical walkdown, the inspector noted that one small bore pipe section had not been reinstalled, two hangers were located differently than shown, and other minor discrepancie A review of the MORE team records showed that all the items had been identified by the licensee and were being tracked er had been determined to be acceptable as i No violations were identifie . Electrical Equipment Modificatien Scope This inspection was conducted to determine the licensee compliance with the NRC requirements for the electrical system modification The areas inspected were as follows:

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Modification control

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Design change

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Component, procurement, receipt, inspection and storage

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Installation, including quality control hold points and verif-ication

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Testing after modification

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Technical specification changes

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Maintenance procedure changes Particular attention was given to the above areas during the inspection and review of the following modifications:

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MOD 1048, Class 1E batteries (4) which were replaced along with the racks

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M00 825, Safety related motor operated valve (20) environmen-tally qualified (EQ) brake replacement

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MOD 1473, Agastat CR 0097 relay socket (128) replacement with type ECR 0095

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MOD 1565, Agastat GP series relay (46) replacement with type EGP

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MOD 514N, Instrument splice (37) replaced with EQ material

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MOD 84-033, RHR containment spray flow transmitter (2) replace-ment b. Findings (1) The inspector observed that 37 of the 128 battery rack cell spacer rods for the four batteries were not installed as re-quired by the battery vendo The vendor required that the first nut on each rod end be finger tight. The second backup nut should be torqued to 30 foot-pounds. Some of the rods could be moved 1/8 inch, indicating that the first nut was not finger tigh The second jam nut could be moved, when touched, on other rods. A sample check, of other rack nuts and bolts, was made by construction personnel using a torque wrench. A number of those nuts and bolts did not have torque settings of 30 foot-pound The licensee agreed to reverify all rack nut-bolt torque setting A silicone compound, General Electric type G 623, was used on the bottom of the battery cells during the installation of bat-tery A and C. Although the battery vendor did recommend a sil-icone compound, to clean the battery tops, the code number differed from that silicone compound use The licensee agreed j

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to check with the battery vendor to verify that the silicone used on the battery cell bottom would not adversely affect the battery cell Both the battery rack torque setting and the use of GE type G 623 silicone compound is considered an unresolved item (277/

85-15-02).

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(2) During the review of MOD 514N, Instrument Splice Replacement, the inspector observed that the Plant Operations Review Committee (PORC) signoff required by Modification Control Procedure A-14 had not been made. The licensee agreed to review the minutes of previous PORC meetings to determine of the modification had been reviewed and the signoff missed, or if the modification had not been reviewed at all by PORC. This item is considered unresolved pending this review and followup on a subsequent inspection (277/85-15-03).

The licensee has complied with the requirements and commitments concerning the modifications identified in the scope of this inspec-tion, with the exception of those unresolved items listed abov No violations were identifie . Core Spray Verification Scope:

The Core Spray System was inspected for operability. The status and impacts of core spray modifications on operability were also examine The inspector reviewed equipment conditions and items that might degrade performance of the Core Spray system. The inspector inter-viewed operators to veri fy that they were knowledgeable of plant conditions. The status and impacts of core spray modifications on operability were also examined, Findings:

The Core Spray system (loops A and B) was out of service during this inspection period, but the licensee was preparing to make the system available before loading fuel into the reactor vessel as required by Technical Specification 3.5.F. The inspector reviewed all modif-ications (MOD's 1516, 430, 1390, 1293, 936, and 421) to the Core Spray system for the current outage to determine any impacts on core spray operability. No impacts were identifie The inspector walked down large diameter core spray pipe in the dry-well using P&IO M-362, Sheet 1 of 2 and drawings H150-1405 and H150-1406. No unusual conditions were observed. MORE team Modification Acceptance Test on core spray small bore pipe (MAT-PB2-IL) and the MORE test report dated 4/14/85 were reviewed. A problem with two missing pipe supports was identified in the MORE reports. The prob-lem was corrected with Maintenance Request Form (MRF) number 8502510 which resulted in fabrication and installation of the supports. The

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supports were inspected by the MORE team on 4/17/85 and found accept-able. The inspector discussed the missing pipe supports with the licensee. It could not be determined whether the supports were removed when a short run of pipe was relocated because of interfer-ence problems, or if the supports were missing from the original as-built pipe. Licensee walkdowns of other small bore pipe lines have not identified any similar problem, therefore the two missing sup-considered by the licensee to be an isolated problem. No ports wag"ble conditions were identified by the inspecto unaccepta The inspector walked down portions of the Core Spray system on eleva-tions 91'6" and 116' in the Unit 2 reactor building, however, on-going work prevented verifying operational readiness. Valve lineups and instrument operability were reviewed in the control room. The inspector discussed Core Spray readiness with the reactor operator The operators were knowledgeable of Core Spray status. Blocking permit 2-10C8501904 was reviewed for repair of electrical conduit on valve #AO-14-158 and the inspector verified the valve was properly tagged on the control panel. No unacceptable conditions were note The inspector concluded that the licensee was following approved procedures, operators were knowWgeable of system status, and the licensee should be able to return the Core Spray system to opera-tional statu . Licensed Operator Requalification and Training Scope The inspector reviewed the Peach Bottoa Requalification Training Program including training department records, lesson plans, required reading lists, required lecture attendance and results of the 1983 and 1984 annual requalification exam. Interviews were conducted with on-shift licensed personnel and licensed personnel enrolled in the requalification training program. The interviews evaluated' the technical adequacy and overall results of the training received by licensed operator The inspector reviewed the licensee's activities in the area of training which were related to the June 18,1984 Order. In response to the Order, the licensee committed to include training on system modifications and FSAR revisions in the requalification progra Findings The inspector found the licensee's requalification training program to be generally acceptable but some weaknesses were note ..

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The licensee's requalification program does not ensure that those staff members involved in the preparation of the annual written requalification exam are periodically administered an exam themselve The inspector noted that one staff member has not taken a written exam for four year The omission of written examination requirements from the licensed operator requalification program is considered to be a weaknes The inspector confirmed that the licensee was conducting training on plant modifications. The licensee had identified 38 modifications on which training was required; 21 were covered during training sessions in November,1984 and the remaining 17 will be covered and the earlier training reviewed prior to Unit 2 restart. Modification training had also been incorporated into the oral walkthrough exam-ination guid: and FSAR revisions had been added to the required read-ing list. The inspector found the lesson plans to be well written and the oral walkthrough examination guide to be of high qualit These aspects of the licensed operator requalification program were noted to be a strength in the licensee's activitie No violations were identtiie . Plant Tours Scope During the course of this inspection tours of the plant were made including the turbine building, reactor building (including the re-fueling floor and the drywell), dieml generator rooms, and the con-trol room. Items reviewed included equipment condition, housekeep-ing, radiological controls and securit Findings (1) A worker had left his securf ty badge on his personal clothing at a anticontamination clothing change area on the turbine dec The area was being observed by a HP technician at the time and there was no breach of security. The licensee security organ-ization responded to take control of the badge. The inspector had no further concerns. Additional findings, related to badge control are the subject of a separate NRC Region I specialist

, inspection. (Inspection Report No. 50-277/85-16, 50-278/85-13)

(2) During a tour of the drywell, the main steam safety-relief valves were installed and several had the air operator tubing bent by construction activities in the are The licensee's MORE team had already identified this (and other) discrepancies during a drywell walkdown and were tracking the equipment prob-lems to resolution. The inspector had no further question _

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(3) 'The licensee uses clear plastic bags for collecting radioactive and non-radioactive trash and protective . clothing as well as transporting equipment throughout the station. The inspector noted that this practice resulted in widespread use of clear plastic bags on the refueling floor including about four bags on the refueling bridge which was in use over the open reactor vessel and the spent fuel pool. The inspector questioned the i licensee regarding the affect on safety-related equipment if the bags were dropped into the reactor cavity and were not noticed nor recovered. The licensee's position was that the bags would float and that no safety problem would result from the use of clear plastic but did acknowledge the concern and stated that the matter would be reviewe The inspector had no further questions at this time. No viola-tions were identifie . Management Meetings During the inspection, licensee management was periodically informed of preliminary findings. In addition, the findings were presented to licen-see management at an exit meeting held on April 19, 198 No written material concerning inspection results was provided to the licensee during this inspection.

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ATTACHMENT 1 The following information includes a list of persons contacted and documents reviewed during inspection No. 50-277/85-1 Persons Contacted G. Czapnik, Welding and QA Supervisor, CB&I K. Schoenleber, Site Manager, CB&I A. Donell, QC Site Supervisor, PECO T. Wilson, QA Site Supervisor, PECO

.R. Fleischmann, Peach Bottom Station Superintendent, PECO B. Clark, MORE Project Manager, PEC0 F. Hoelzle, Project Engineer - Construction, PECO J. Pizzola, QA Engineer, PECO F. Mascitelli, Assistant Modification Coordinator, PECO Modification Packages (MOD)

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MOD 1516, Grafoil Packing of Valves

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MOD 430, Core Spray Test Return Line Flow Orifice

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Mod 1390, Core Spray Pump Miniflow Differential Pressure Switches

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MOD 1293, Core Spray Loop Flow Indicators

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MOD 936, DPIS-2-14-43A and B Core Spray Pipe Break Detection

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MOD 421, Relief Valves 2-14-20A and B

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MOD 1048, 125 Volt DC Battery Replacement

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MOD 825, Motor Operated Valve Brake Replacement

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MOD 1473, Test and Replace Agastat CR0097 Relay Socket

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MOD 1565, Agastat Relay Replacement

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MOD 514N, Instrument Cable Splices

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MOD 84-033, RHR Containment Spray Flow Transmitter Modification Acceptance Test (MATS)

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MAT 1278 PB2-18, All Small Piping Inside Drywell, Part B

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MAT 1278 PB2-1C, All Small Piping Inside Drywell, Part C

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MAT 1278 PB2-1H, All Small Piping Inside Drywell, Part H

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MAT 1278 PB2-IL, All Small Piping Inside Drywell, Part L

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MAT 1278 PB2-48, Motor Operated Valves, Interlocks and Position Indication (PCIS and ECCS)

-- MAT 1278 PB2-6, Manual Valves with Indication

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MAT 1278 PB2-11A, Snubber Inspection

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MAT 1278 PB2-118, Large Pipe Support Inspection

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MAT 1278 PB2-11C, Small Pipe Support Inspection

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MAT 1278 PB2-13A, Recircolation Piping Replacement for System 2

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Attachment 2

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MAT 1278 PB2-138, Recirculation Pump Vibration Monitoring MOD 925

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MAT 1278 PB2-13C, MOD 1192, Recirculation Pump Motor 2AP34 Lower Bearing 011 Reservoir Level Switch

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MAT 1278 PB2-148, Recirculation Pump Seal Leak Detection and Seal Piping Flush

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MAT 1278 PB2-23, Standby Liquid Control (SBLC)

MORE Team Test Reports

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MORE Test Report, MAT 1278 PB2-11B

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MORE Test Report, MAT 1278 PB2-1L

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MORE Test Report, MAT 1278 PB2-11A

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MORE Test Report, MAT 1278 PB2-118

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MORE Test Report, MAT 1278 PB2-11C

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MORE Test Report, MAT 1278 PB2-148 Surveillance Tests (STs)

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ST/ISI-5, Inservice Inspection - Visual Examination of Spring Hangers, Rigid Hangers, Rigid Supports and Anchors

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ST 9.15-2, Seismic Hydraulic and Mechanical Snubber Inspection, Unit 2 Only

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ST 8.4.2, 125/250 Volt Battery Discharge Performance Test, Revision 0

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ST 13.31, Hydraulic Snubbers Function Test, Revision 2 Procedures

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ERDP 3.1, Procedure for Handling Q-Listed Modifications

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ERDP 3.3, Procedure for Performance of Safety Evaluations, Applications for Amendments to Facility Operating Licenses, and Changes to the Updated Final Safety Analysis Report

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ERDP 3.4, Procedure for Desig, Control

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ERDP 3.6, Procedure for Preparation and Review of Engineering Drawings for Nuclear Plant Podifications

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A-14, Plant Modification

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A-30, Plant Housekeepr1 Controls

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QADP 9.1, QC Procedure 'or the Control of Non Conformance

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Procedure SPECIAL 800, 'lant Conditions Necessary to Fuel Reload Unit 2 Other Documents Reviewed

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Unit 2 Drywell Deficiency List dated March 2,1985

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Outage Planning Core Reload Check List dated April 11, 1985

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CB&I Fuel Load Check List dated April 9, 1985

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EP QA Division Activities Report as of April 4, 1985

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EP QC Summary of Open Non Conformance Reports as of March 31, 1985

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E&R QA Audit Report Distribution List, and Open Unit 2 Finding Reports

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-e Attachment 3

Other Documents Reviewed (Continued)

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CB&I Nonconformance Report Records

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EP QA Open Unit 2 Noncompliance Reports

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NEDC-30500, Piping Replacement to Improve Resistance to Intergranular Stress Corrosion Cracking (IGSCC) Safety Evaluation for Peach Bottom, Unit 2, April 1984

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Major Outage Recovery Effort (MORE) Project Standards for Preoperational/

Startup Testing Phase

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Type Design Report, Piping; Recirculation Piping and Equipment Loads, 23A4086

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