IR 05000277/1999005

Insp Repts 50-277/99-05 & 50-278/99-05 on 990518-0628. Non-cited Violations Noted.Major Areas Inspected:Operations, Surveillances & Maintenance,Engineering & Technical Support & Plant Support Areas

ML20210H549
Person / Time
Site:	Peach Bottom
Issue date:	07/27/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20210H537	List: IR 05000277/1999005 ML20210H534
References
50-277-99-05, 50-278-99-05, NUDOCS 9908040035
Download: ML20210H549 (28)

Text

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

License No DPR-44 DPR-56 Report No Docket No Licensee: PECO Energy Company Correspondence Control Desk P.O. Box 195 Wayne, PA 19087-0195 Facility: Peach Bottom Atomic Power Station Units 2 and 3 Inspection Period: May 18,1999 through June 28,1999 Inspectors: A. McMurtray, Senior Resident inspector M. Buckley, Resident inspector B. Welling, Resident inspector J R. Nimitz, Senior Radiation Specialist Approved by: Curtis J. Cowgill, Chief Projects Branch 4 Division of Reactor Projects l

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9908040035 990727 PDR ADOCK 05000277 O PDR

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., i l EXECUTIVE SUMMARY Peach Bottom Atomic Power Station NRC Inspection Report 50-277/99-05, 50-278/99-05 This inspection report included aspects of licensee operations; surveillances and maintenance; engineering and technical support; and plant support area ' Operations:

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e Unplanned engineered safety feature actuations occurred on both units due to the de-i energization of the Unit 3 emergency auxiliary transformer during restoration of the 343

! startup bus to the normal offsite power supply. The investigation for this event was excellent and provided detailed insights into its causes. The root cause of this event was unclear management expectations for controlling equipment configuration status. The lack of adequate written instructions for equipment status control resulted in a Severity Level IV violation that was treated as a Non-Cited Violation consistent with Appendix C of the NRC Enforcement Policy. (Section 01.2)

, e Operators took prompt and effective actions in response to three off-normal conditions

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during the period: 1) a loss of power to the Unit 3 primary feedwater control computer,2)

a Unit 2 plant monitoring system computer interruption, and 3) a Unit 3 reactor core

! isolation cooling system high suction pressure alarm. Appropriate follow-up actions were completed or planned by station personnel. (Section O4.1)

e During March through April 1999, Nuclear Quality Assurance (NQA) performed a thorough assessment of Plant Operations Activities. The assessment was comprehensive and provided severalinsights into current operations performance. The most significant NQA assessment finding was the identification of an adverse trend in the

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effectiveness of corrective actions to preclude repetition of some deficiencies. (Section 07.1)

Maintenance:

• During post maintenance testing, Instrumentation and Controls (l&C) technicians identified that they had not properly restored a core spray system flow transmitter to service following maintenance. Overall, the PECO investigation and corrective actions for this event were appropriate and identified that incorrect assumptions were made regarding restoration instructions and some actions stated in the clearance and tagging manual were not performed. (Section M1.2)

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l e Required station emergency lighting units were tested and inspected according to plant l procedures and consistent with Appendix R requirements. Corrective maintenance was performed promptly. Maintenance action requests were not being reviewed for maintenance rule implications due to an action request database error that indicated the lighting units were not within the scope of the rule. This deficiency was entered into the ;

corrective action program and corrected. (Section M2.1) i Enaineerina:

e During the past nine months, PECO engineering personnel have identified several

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subtle, historical non-conformances to the Peach Bottom Fire Protection Plan during their reviews of the fire protection program. These reviews have been notably comprehensive with appropriate corrective actions taken for deficiencies identified. The non-conformances with the Fire Protection Plan constituted a Severity Level IV violation that was treated as a Non-Cited Violation consistent with Appendix C of the NRC Enforcement Policy. (Section E2.1)

Plant Support l e PECO implemented effective programs in the areas of radioactive waste source evaluation, processing and handling, determination of radionuclide scaling factors, waste classification, and volume reduction efforts. PECO developed appropriate scaling factors for hard to detect radionuclides, performed appropriate radionuclide concentration averaging, and implemented waste volume reductions efforts. (Section R1.1)

e PECO implemented an effective radioactive waste and radioactive material packaging and shipping program and successfully shipped irradiated hardware and clean-up filters from its Unit 3 spent fuel storage pool. (Section R1.2)

e PECO thoroughly planned for the personnel diving in the Unit 2 spent fuel pool. The diving evolutions were carefully monitored by health physics personnel. PECO's excellent dose reduction efforts resulted in significantly lower than expected overall dose l to the divers. (Section R4.1)  !

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TABLE OF CONTENTS EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l . Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 General Comments (71707) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

01.2 De-energization of the 343 Start-Up (SU) Bus During Restoration and (Closed) Licensee Event Report (LER) 50-277(278)/2-99-004 . . . . . . 2 04 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 04.1 Operator Response to Off-Normal Conditions . . . . . . . . . . . . . . . . . . . 4 07 Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 07.1 Nuclear Quality Assurance Assessment of Plant Operation Activities (71707) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 l l . M aintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 M1.1 General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 M1.2 Equipment Status Control lasue Associated with Instrumentation &

Controls Work .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 M2 Maintenance and Material Condition of Facilities and Equipment . . . . . . . . . . 8 M2.1 Safe Shutdown Emergency Lighting Review . . . . . . . . . . . . . . . . . . . . 8 {

M2.2 On-line Maintenance of the 2B Core Spray System . . . . . . . . . . . . . . . 9 Ill . Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 E2 Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . 10 E Fire Protection Plan Non-Conformances (Units 2 and 3) and (Closed) eel 50-277(278)/98-10-03 and LER 50-277(278)/2-99-003 . . . . . . . . . . . 10 )

IV. Plant Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . . 13 R1.1 Radioactive Waste Sources and Processing Systems, Radionuclide Scaling Factors, Waste Classification, and Volume Reduction Efforts. 13 R1.2 Radioactive Material Transportation Activities . . . . . . . . . . . . . . . . . . 14 i R2 Status of RP&C Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 l R3 RP&C Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 R4 Staff Knowledge and Performance in RP&C . . . . . . . . . . . . . . . . . . . . . . . . . . 17 R4.1 Personnel Diving in Unit 2 Spent Fuel Pool . . . . . . . . . . . . . . . . . . . . 17 l R5 Staff Training and Qualification in RP&C. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 R8 RP&C Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 R7 Quality Assurance in RP&C Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 iv f j i

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V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . ........................... .21 l X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 i

X2 Review of Year 2000 Readiness of Computer Systems . . . . . . . . . . . . . . . . . 21 INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 ITEM S OPEN ED AN D CLOS ED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 LIST OF ACRONYM S USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

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Report Details l

Summary of Plant Status PECO operated both units safely over the period of this repor Unit 2 began this inspection period at 100% power. On June 4,1999, Unit 2 load was reduced to about 65% power for main condenser waterbox cleaning and various maintenance activitie Unit 2 was retumed to full power on June 6 and remained at 100% for the rest of the perio Unit 3 began this inspection period at 100% power. On June 11,1999, Unit 3 load was reduced to about 65% power for scram time testing and other maintenance activities. Unit 3 was retumed to full power on June 13. On June 25,1999, Unit 3 load as reduced to about 85%

power for a rod pattem adjustment and was retumed to full power on June 26. Unit 3 remained at 100% for the rest of the perio l. Operations 01 Conduct of Operations'

01.1 General Comments (71707)

Load Droo Observations Unit 2 The inspectors observed operator performance during the Unit 2 load drop activities on June 4 - 6,1999. Operators demonstrated good use of procedures and awareness of plant conditions. Very good peer checking and self-checking were observed during reactivity manipulations and performance of various system testing. Critical oversight af control room activities by supervision and management was evident when shift supervision identifi6d that communications for some control room evolutions did not  !

always meet expectations. The shift manager held discussions on this issue with the l operators involve '

Load Droo Observations Unit 3 l l

On June 26,1999, the inspectors observed control room operators raduce Unit 3 load to ,

85% in order to per'orm a rod pattem adjustment. The operators performed reactivity  !

manipulations in a deliberate, well-controlled manner. Procedure usage, peer checking,  !

coordination with reactor engineering, and supervisory oversight were good. The l Inspectors also observed portions of the power ascension to 100% power and identified  !

no concem ,

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I To'sical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report outEie. Individual reports are not expected to address all outline topic I

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01.2 De-eneraization of the 343 Start-Up (SU) Bus Durina Restoration and (Closed) Licensee Eygnt Reoort (LER) 50-277(278)/2-99-004 Inspection Scoos (71707)

During restoration of the 343 SU electrical bus to the normal offsite power source on May 21,1999, the bus was inadvertentif de-energized due to an open disconnect switc Loss of this bus caused the automatic transfer of two Unit 2 and two Unit 3 4kV ,

emergency buses to alternate power supplies and multiple engineered safety feature I (ESF) actuations. The inspectors reviewed station log entries, operating procedures, and discussed this event with operations personnel and management. The inspectors also reviewed the Performance Enhancement Program (PEP) document and root cause investigation for this even Observations and Findings During planned maintenance on the 343 SU bus, debris was observed in the circuit switcher located in the line from the normal 220 kV offsite power source to the 343 SU ,

bus. Following completion of the plan 7ed maintenance, the system restoration activities l were completed with the exception of the circuit switcher and a disconnect switch in the l line, which were left open to allow removal of the debri i The planned maintenance work clearance was closed but no equipment status tags were l hung on the circuit switcher or the disconnect switch because operations personnel ;

acsumed that a new switchyard clearance would control their status and restoration during the debris removal. As an interim measure, an administrative clearance was hung to address the circuit switcher position until the new switchyard clearance was issued. The administrative clearance did not address the disconnect switc A new switchyard clearance was not prepared and other controls were used during the removal of the debris which did not specifically address the disconnect switch. The operations coordinator, who had written the administrative clearance, thought the disconnect switch would be placed in the normal closed position using a particular station procedure to energize the electrical bus. However, the operations coordinator did not communicate this information to the operations crew that would be restoring the 343 SU bus to normal offsite power. The procedure used by the operations crew to energize the bus was different than that assumed by the operations coordinator and did not ;

contain specific instructions to verify that the disconnect switch was close Just prior to energizing the electrical bus, an equipment operator was sent out to inspect a breaker between the circuit switcher and the disconnect switch. The equipment operator noticed that the disconnect switch was open but he did not report this condition because he believed that the control room was just going to cycle the breaker and not energize the normal offsite power line. He had not been included in the pre-job brie The licensee's root cause for this event was unclear management expectations for l control of equipment configuration status. Also, lack of documentation of equipment l l

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status changes, poor shift tumover, failure to include the equipment operator in the

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system restoration pre-job brief, and an ambiguous operations procedure used for restoring the 343 SU source contributed to this even The inspectors noted during interviews of operations personnel that expectations for the control of the status of the disconnect switch were unclear. Some operations personnel i stated that an equipment status tag should have been placed on the disconnect switch l while it was open, while others stated that the disconnect switch position would be l controlled by the switchyard clearance or procedures. The inspectors reviewed the I procedures that controlled equipment status tags and administrative clearances and noted they were unclear as to exactly how equipment status was to be controlled when equipment is left in an off-normal position following system restoration. Operations management was aggressively implementing changes to clarify expectations for

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equipment status contro The inspectors independently concluded that the licensee's root cause analysis was thorough. The inspectors noted that an event and causal factor flowchart was developed and an in-depth root cause analysis was performed. The corrective actions developed l from this analysis were comprehensive. The inspectors performed an in-plant review of j the LER. No additional concoms were identifie Peach Bottom Units 2 and 3 Technical Specification 5.4.1 requires that written procedures be established, implemented and maintained for the activities listed in Regulatory Guide 1.33, which includes Equipment Control. Peach Bottom Operations Manual Section OM-C-10.6, " Equipment Status Tags," Revision 3, provided inadequate written instructions for administrative control of equipment out of its normal position i following a system restoration. Consequently, operators did not maintain control of the !

off-normal position of the 3433 disconnect switch during restoration of the 343 SU bus to the normal offsite power supply. ' This led to the de-energization of the 3 EA transformer and subsequent multiple ESF actuations. This Severity Level IV violation is being .

treated as a Non-Cited Violation (NCV) consistent with Appendix C of the NRC l Enforcement Policy. This violation is in the licensee's corrective action program as PEP 10009864. (NCV 50-277(278)/99-05 01)

c. Conclusions Unplanned engineered safety feature actuations occurred on both units due to the de-energization of the Unit 3 emergency auxiliary transformer during restoration of the 343 startup bus to the normal offsite power supply. The investigation for this event was excellent and provided detailed insights into its causes. The root cause of this event was unclear management expectations for controlling equipment configuration status. The ,

lack of adequate written instructions for equipment status control resulted in a Severity l Level IV violation that was treated as a Non-Cited Violation consistent with Appendix C of the NRC Enforcement Polic ,

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i 04 Operator Knc;;'d-p and Performance '

04.1 Ooerator Response in Off-Normal Conditions

, Insoection Scooe (71707)

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The inspectors assessed operator response to three off-normal conditions. These i conditions were: 1) a loss of power to the Unit 3 primary feedwater control computer, and j 2) a Unit 2 plant monitoring system (PMS) computer interruption, and 3) a Unit 3 reactor core isolation cooling (RCIC) system high suction pressure alarm. The inspectors also reviewed the planned and completed follow-up actions and discussed them with station personne ,

i Observations and Findinas On May 25,1999, the Unit 3 reactor operator received a reactor low level alarm and noted that level was trending downward. The operator took prompt actions in accordance with plant procedures to reduce reactor power and to manually control

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reactor feed pumps until level had stabilize i instrumentation and Controls (l&C) and engineering follow-up was thorough. I&C personnel determined that power to the primary feedwater control computer had been lost due to a blown fuse. Further inspection of the fuse by the PECO laboratory revealed that it failed due to a mechanical defect rather than due to a high current or ground condition. Engineering personnel analyzed the automatic swap-over from the primary ,

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computer to the backup and initiated actions to enhance the tuning of the feedwater control program and thereby reduce the magnitude of a reactor level transient for this type of even i On June 10,1999, operators experienced a temporary loss of the Unit 2 plant monitoring system (PMS) computer. They reduced power slightly to ensure average power limits were not exceeded, since the average power monitoring function of PMS was no longer available. Operations personnel also made an event notification to the NRC per 10 CFR 50.72, because the computer problem resulted in a loss of the safety parameter display system, which is used for emergency assessmen This event was entered into the corrective action system as Performance Enhancement Program (PEP) 10009936, and information systems personnel planned to perform a full root cause analysis. Preliminary investigation indicated that the computer interruption was caused by a hardware failure. This problem was not related to testing errors that caused a similar computer failure earlier this yea On June 24,1999, operators and control room supervisors responded effectively to a Unit 3 RCIC high suction pressure alarm. After the high pressure condition was corrected throLGh u'e of the alarm response card, shift personnel continued to monitor the RCIC system for abnorrr, parameter . ,

Engineering determined that the condition was caused by leakage through the RCIC discharge valve (MO-3-13-21). The inspdors noted that the leakage did not create a high/ low pressure interface issue or a c'ialienge to system operability. Repair of the RCIC discharge valve was scheduled f or the 3R12 outage in October 199 Conclusions Operators took prompt and effective actions in response to three off-normal conditions during the period: 1) a loss of power to the Unit 3 primary feedwater control computer, 2)

a Unit 2 plant monitoring system computer interruption, and 3) a Unit 3 reactor core isolation cooling system high suction pressure alarm. Appropriate follow-up actions were completed or planned by station personne : Quality Assurance in Operations 07.1 Nuclear Quality Assurance Assessment of Plant Ooeration Activities (71707)

During March through April 1999, Nuclear Quality Assurance performed a thorough assessment of Plant Operations Activities. Performance improvements were noted in the areas of narrative log keeping, communications, annunciator response, and operator rounds especially by equipment operators. NQA identified six Performance Enhancement Program (PEP) issues. The most significant PEP documented an adverse ;

trend in the effectiveness of corrective actions to preclude repetition of deficiencies with !

the fuse control program, the operator aid program, shift turnover checklists, and the adequacy of operability determinations for penetration seals. The potential for the !

operations department to identify these issues was diminished since no self assessment was performed in 1998. Plant operations planned to perform a self assessment in 199 !

The inspectors reviewed the assessment and concluded that it was comprehensive and provided several excellent insights into current operations performanc . Maintenance i i

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M1 Conduct of Maintenance M1.1 General Comments NRC Inspection Procedures 62707 and 61726 were used in the inspection of plant maintenance and surveillance activities. The inspectors observed and reviewed selected portions of the following maintenance and surveillance test activities:

Maintenance Observations: Observed On:

R0629084 MO-3-14-005D Motor Operator PM June 2,1999 R0741329 E1 Emergency Diesel Generator (EDG) June 7 - 9,1999 PM inspection

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l L - M-003-215 Hydraulic Control Unit (HCU) On-line June 14 - 15,1999

Maintenance M-056-001 480 Volt Motor Control Center Circuit June 22,1999 Breaker Assembly and Cubicle Terminal Maintenance Surveillance Observations: Observed On:

Sl2K-54-E33-XXFM Functional Te of E33 4kV June 04,1999 Undervoltage relays Sl2K-54-E43-XXFM Functional Test of E43 4kV June 04,1999 Undervoltage relays ST-l-07G-101-2_ Primary Containment isolation June 05,1999 System (PCIS) Group i Logic

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ST-t-052-251-2 ' E1 EDG Post-Maintenance June 11,1999 i instrumentation and Logic Test

. Sl2K-60F-757-XXCS Calibration / Functional check of June 22,1999 RPS Altemate Feed Relays Sl3A-2-MSL-A1FQ Functional Test Main Steam Line June 26,1999 High Flow Instruments of RPS "A" Card File Sl3A-2-MSL-C1FQ Functional Test Main Steam Line June 26,1999 High Flow Instruments of RPS "C" i Card File l The work and testing performed during these activities was professional and thoroug Technicians were experienced and knowledgeable of their assigned tasks. The work and testing procedures were present at the job site and were generally effectively use Good pre-job briefs were observed prior to the performance of the surveillance activities observe M1.2 Eauioment Status Control lasue Associated with Instrumentation & Controls Work l Inspection Scope (62707)

, The inspectors reviewed an event in which Instrumentation and Controls (l&C) personnel did not return a core spray system flow transmitter to service following maintenanc l-l

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The inspectors also reviewed maintenance records and discussed the event with l&C managemen Observations and Findinos On June 3,1999, during post-maintenance testing, operators noted that the 3B core i

! spray system flow indicator was reading zero flow with the pump running. l&C technicians checked the valve lineup and found the flow transmitter had been improperly left isolated following l&C maintenance the previous da l&C personnel investigated the event (PEP 10009906) and identified that a number of problems contributed to the improper restoration problems. Specifically, they determined that: 1) technicians incorrectly assumed that a clearance would restore the instrument to service, 2) l&C planners provided incomplete instructions for restoration, and 3) the ,

clearance instructions did not isolate the instrument prior to closing the root va!ve j i

A member of the work control center reviewed the investigetion and identified additional I problems. He found that non-compliances with the clearance and tagging manual also l contributed to this event. Specifically, technicians did not enter required comments in the !

clearance, and clearance writers did not add appropriate information tags as directed by l the manua I The inspectors noted that this equipment status control event was identified during post-maintenance testing and did not result in any challenge to equipment operability. Thus, the inspectors concluded that the clearance and tagging manual non-compliances constituted minor violations not subject to formal enforcement actio The inspectors noted that while the overall investigation of the event was adequate, the review by l&C personnel did not reveal some key issues. Corrective actions for this !

event were adequate and included discussions with l&C and Planning staff. In addition, I&C management planned to include this issue in the station's equipment status control initiativ !

I c. Conclusions During post maintenance testing, instrumentation and Controls (l&C) technicians idenMed that they had not properly restored a core spray system flow transmitter to service following maintenance. Overall, the PECO investigation and corrective actions for this event were appropriate and identified that incorrect assumptions were made regarding restoration instructions and some actions stated in the clearance and tagging manual were not performed.

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M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Safe Shutdown Emeroency Liahtina Review Insoection Scope (62707)

The inspectors reviewed testing and maintenance for Appendix R battery-powered emergency lighting unit '

! Observations and Findinos Instrumentation and Controls (l&C) personnel functionally tested emergency lighting units (ELUs) on an annual basis. The testing procedures check the function of the test button and verify that the emergency lights remain lit for at least eight hours, as required by Appendix R, while maintaining a minimum specified battery voltage. Plant personnel also performed routine inspections of ths ELUs on a monthly basis. The inspectors observed a portion of an annual functional test and identified no concem The inspectors reviewed several corrective maintenance action requests (ARs) that were j written for deficiencies found during testing in May and June 1999. The inspectors noted that corrective maintenance was performed promptly, consistent with the requirements of

. the Peach Bottom Fire Protection Progra .

The inspectors identified a deficiency in the implementation of the maintenance rule for j the ELUs. Specifically, the inspectors noted that while the ELUs were considered to be within the scope of the maintenance rule, ARs were not being reviewed fc. meintenance

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rule implications. This occurred because ELUs were assigned an incorrect code in the ;

AR database indicating that they were not in the scope of the maintenance rul Engineering personnel corrected this condition, documented it in PEP 10009938, and reviewed other systems for generic implications. The inspectors determined that this maintenance rule implementation deficiency constituted a minor violation not subject to l formal enforcement actio I

' Conclusions Required station emergency lighting units were tested and inspected according to plant procedures and consistent with Appendix R requirements. Corrective maintenance was performed promptly. Maintenance action requests were not being reviewed for maintenance rule implications due to an action request database error that indicated the lighting units were not within the scope of the rule. This deficiency was entered into the corrective action program and corrected .

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l M2.2 On-line Maintenance of the 2B Core Sorav System Insoection Scope (62707)

i During post-maintenance testing of the 2B core spray system, the inboard discharge l valve failed to close. The inspectors observed the corrective actions to restore valve l ' operation and discussed generic issues of this failure with engineering personnel.

l Observations and Findinas

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During the 2B core spray system maintenance outage, PECO experienced a one-day

delay in restoring the system due to the inboard discharge valve failing to stroke closed l

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during post-maintenance testing. Troubleshooting activities by maintenance technicians revealed that a breaker auxiliary contact failed to reposition. During the system l maintenance outage, preventive maintenance for the breaker was performed, and the

! auxiliary contact had initially performed satisfactorily.

l Engineering's response to the contact failure was comprehensive and included sending l l

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the breaker assembly to a testing laboratory for evaluation. The laboratory results !

indicated the probable cause of the failure was binding of the double-stack auxiliary contac The procedure used for retesting the breaker did not provide clear guidance to account i for multiple starts of the motor-operated valve. Consequently, when the valve motor was !

started multiple times within a short period, the valve motor overheated, which resulted in tripping of the thermal overload relay. Subsequent checks verifiexf no damage to the valve motor. Engineering planned to clarify the procedure to include the limits for stroking of this valvc during testing so that the thermal overloads are not challenge Conclusions l

Maintenance and engineering actions in response to the failure of the 2B core spray system inboard valve to stroke closed were acceptable. However, operations and engineering did not account for the thermal effects of multiple cycles of the discharge valve motor operator during testing, which resulted in the motor tripping on thermal overload I

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111. Engineerina E2- Engineering Support of Facilities and Equipment E2.1 Fire Prei dica Plan Non-Conformances (Units 2 and 3) and (Closed) eel 50-277(278)/98-10-03 and LER 50-277(278)/2-99-003 a. Inspection Scope (37551)

The inspectors reviewed four issues that were non-conformances with the Peach Bottom Fira Protection Plan. These issues were identified by PECO engineering personnel during a Fire Safe Shutdown (FSSD) review being performed in conjunction with Thermo-lag remediation work. The inspectors also discussed these non-conformances with engineering personne b. Observations and Findinos Fire Detection Systems Not installed as Reauired in Several Unit 2 and 3 Areas Between March and October 1998, PECO engineering personnel identified five fire areas, containing cables for safety-related or safe shutdown equipment that did not have automatic fire detection systems as required by 10 CFR 50, Appendix R and the Updated Final Safety Analysis Report (UFSAR). Details of this issue are contained in NRC Inspection Report 50-277(278)/98-10, Section E2.1. The licensee submitted an exemption request to the Appendix R requirements for automatic fire detection in these areas in November 199 Engineering personnel determined that the Reactor Protection System (RPS)

instrumentation in many of these areas could be totally lost due to a fire. Per the licensee's Fire Protection Plan, any fire affecting the RPS system will not prevent the reactnr from being scrammed. The inspectors noted that the operability determination only addressed the loss of RPS cabling and did not address the impact of losing safe j shutdown cables that were in these areas. However, many of the rooms in these areas I contained automatic fire suppression systems that would alarm in the control room upon actuation. The inspectors determined that fires in any of the areas without any automatic l fire suppression would not disable safe shutdown equipment necessary to place the units in hot or cold shutdow Failure to Properly Address the Effects of Potential Floodina Caused by Fire-Induced Mis-Operation of Hioh/ Low Pressure Interfaces in Low Pressure Emeroency Core Coolina Systems (ECCSs)

On March 18,1999, PECO engineering concluded that certain fires could result in spurious operation of High/ Low pressure interface valves in the residual heat removal (RHR) or core spray (CS) systems. The sustained opening of these valves could result in flooding of the Unit 2 or Unit 3 sump pump rooms through low pressure system (s)

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relief valves. Water damage to the instruments in these rooms could result in isolation of '

the HPCI or RCIC systems which were protected for FSS The licensee determined that this deficiency was caused by inadequate engineering analysis of the FSSD program during High/ Low interface over-pressurization reviews in 1986. The licensee also determined that this placed the plant outside the design basis due to the failure to maintain the provisions of the Fire Protection Program for High/ Low pressure interface The licensee immediately established hourly roving fire watch inspections for the identified areas. Temporary plant alterations were subsequently installed on both units to remove power from one of the valves in each of the impacted High/ Low pressure interfaces to isolate the water flow paths. The licensee planned to make a permanent I physical change to the plant to correct this deficiency. In addition, PECO engineering l reviewed four additional High/ Low pressure interfaces at Peach Bottom that could be l affected by potential flooding due to a fire. No concems were identified with these interface The inspectors performed an on-site review of LER 2-99-003 and identified no additional concem Lack of Analysis to Assure the Operability of Main Control Room Ventilation Durina All booendix R Scenarios On April 22,1999, PECO engineering determined that there was no analysis to show that the main control room emergency ventilation (MCREV) supply fans would remain operable during an Appendix R fire. The FSSD analysis took cret ' for operation of one l of the two supply fans during an Appendix R fire. However, subsequent to 1988-1989, ;

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the MCREV system was not included in the Appendix R analysis as protected equipmen Elimination of outside air to the main control room during an Appendix R fire would allow

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the main control room temperature to exceed 114*F in approximately seven hours unless the operators took action and provided portable ventilation to the control room. At this point in the FSSD scenario, the unit (s) would at least be in hot shutdown and alignments to bring the unit (s) to cold shutdown would be completed. Existing PECO calculations and procedures relied on the operation of one of the main control room ventilation supply fans to keep the control room below 114*F. No procedures existed that directed operations personnel to take actions to alleviate the increasing temperature condition in the control room if the supply fans were inoperable. Also, portable ventilation and fans were not staged for the control roo The licensee issued a Shift Update Notice to inform operations personnel of this condition and the actions that were necessary if the MCREV supply fans were inoperable during a fire. Portable ventilation and fans were also provided. The licensee planned to make formal procedural revisions to provide additional guidance for the loss of the

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12 supply fans and Action Request A1205843 was generated to provide final disposition for this conditio Fire-induced Closure of a Vacuum Breaker Isolation Valve Could Affect HPCI Operability in Certain Anoendix R Scenarios On June 16,1999, PECO engineering determined that fire-induced damage to a motor control center sub-panel couki cause the spurious closure of the Unit 2 HPCI vacuum breaker isolation valve. This may preclude the ability to cycle HPCI on and off remotely during the Appendix R fire scenario that damages this sub-panel. Closure of this valve could cause Water from the torus to be drawn into the HPCI turbine exhaust line due to condensation of steam present when the system is cycled off. This may result in water entering the HPCl turt;ine and/or a waterhammer event upon HPCI re-start. This fire scenario required HPCl for reactor vessel level control in hot shutdow Engineering personnel concluded that this condition had the potential to cause a failure of the HPCI system to operate post-fire and constituted a non-compliance with Appendix R separation requirements. The licensee determined that this deficiency was caused by inadequate engineering analysis of the FSSD program during the 1986 review. The licensee also determined that this placed the plant outside the design basis since closure of the vacuum breaker could prevent multiple starts of HPCI as required by this Appendix R scenari Operations and engineering personnel determined that the HPCI system remained operable for all other required fire scenarios and design basis plant transients. They noted that this condition does not affect the initial HPCI injection function, but may preclude system restar As an immediate corrective action, PECO established hourly roving fire watch inspections for the affected fire area. Engineering personnel were evaluating follow-up actions, including options for a permanent modification to correct this deficienc {

Summary The inspectors verified that all initial corrective actions for these deficiencies were properly implemented. The inspectors noted that each of these non-conformances resulted from inadequate engineering analysis of Fire Protection Plan issues. The original analyses for these issues occurred at least nine years ago. The inspectors noted that the current reviews of the Fire Protection Plan ensured that appropriate levels of engineering expedise were applied to Appendix R and FSSD reanalyses. The ,

inspectors determined that these reviews provided very good examination of the Peach Bottom Fire Protection Program, including the FSS l

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Peach Bottom Atomic Power Station Units 2 and 3 Facility Operating Licenses (DPR-44 j and DPR-56) require that the licensee implement and maintain in effect all provisions of

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the Fire Protection Plan as described in the UFSAR. Contrary to this requirement, j PECO engineers identified four non-conformances to the Fire Protection Plan. These '

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non-conformances included fire detection systems not being installed, failing to properly address the effects of flooding caused by fire induced mis-operation of High/ Low interfaces in low pressure ECCSs, potential inoperability of MCREV supply fans during a fire, and potential inoperability of Unit 2 HPCI due to fire-induced damage affecting power to a vacuum breaker isolation valve. The NRC determined that these non-conformances constituted a Severity Level IV violation of the Units 2 and 3 Facility Operating Licenses. The NRC concluded that these issues were of low risk significance and that station personnel took prompt and effective corrective actions as described above and in NRC Inspection Repo,150-277(278)/98-10, Section E2.1. This Severity Level IV violation is being treated as a Non-Cited Violation (NCV) consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as PEPS 10009023,10009584,10009737, and 10009946. (NCV 50- .

277(278)/99-05 4 2) Conclusions During the past nine months, PECO engineering personnel have identified several subtle, historical non-conformances to the Peach Bottom Fire Protection Plan during their reviews of the fire protection program. These reviews have been notably comprehensive with appropriate corrective actions taken for deficiencies identified. The non-conformances with the Fire Protection Plan constituted a Severity Level IV violation that was treated as a Non-Cited Violation consistent with Appendix C of the NRC Enforcement Polic IV. Plant Suonort

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R1 Radiological Protection and Chemistry (RP&C) Controls

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R1.1 Radioactive Waste Sources and Processina Systems. Radionuclide Scalina Factor Waste Classification. and Volume Reduction Efforts Inspection Scope (86750)

The inspectors reviewed and discussed the following matters:

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sources of radioactive waste at the station, current waste generation rates, and volume reduction efforts

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processing (as appropriate) and handling of the waste

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the development of scaling factors for difficult to detect and measure radionuclides

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the classification and packaging of radioactive waste

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processing of non-radioactive /non-contaminated trash shipped for disposal

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implementation of applicable NRC Branch Technical Positions (BTPs) on waste classification, concentration averaging, waste stream determination, and sampling frequency,

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current waste streams and their processing relative to descriptions contained in the UFSAR and the station's approved Process Control Program (PCP)

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reporting of changes to the PCP, and updating of the UFSAR to reflect changes (as appropriate)

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injection of noble metals into the Unit 2 reactor coolant and its impact on the 10 CFR Part 61 waste classification analyse The review was against criteria contained in 10 CFR 20,10 CFR 61,10 CFR 71, the UFSAR, the PCP, and applicable NRC Branch Technical Positions. The inspector interviewed various waste processing personnel including waste system managers and reviewed applicable documentation. The inspector also met with cognizant chemistry personnel to discuss impact of noble metals addition on reactor coolant radionuclide concentration Observations and Findinas There were no significant changes in PECO's waste streams or processing methodology. PECO was processing its waste consistent with information contained within its UFSAR, PCP and applicable procedures. The UFSAR and PCP were updated as appropriate with changes properly reported. PECO performed sampling and analysis of the various waste streams (as appropriate); developed radionuclide scaling factors consistent with NRC Branch Technical Positions; and implemented applicable NRC BTPs on waste classification, concentration averaging, waste stream determination and sampling frequenc Radioactive waste shipped for disposal was properly classified and packaged consistent with 10 CFR 61.55 and 10 CFR 61.5 Current waste generation rates and volume reduction efforts were similar to the previous inspection but a slight increase in volume of buried waste was noted due to modification of processing for economic issue Conclusions No violations or safety concerns were identified. PECO implemented effective programs in the areas of radioactive waste source evaluation, processing and handling, determination of radionuclide scaling factors, waste classification, and volume reduction j efforts. PECO developed appropriate scaling factors for hard to detect radionuclides, '

performed appropriate radionuclide concentration averaging, and implemented waste volume reduction effort i R1.2 Radioactive Material Transoortation Activities Inspection Scope (86750)

The inspectors selectively reviewed the following aspects of PECO's radioactive waste and radioactive material pcci: aging and shipping activities;

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radioactive waste shipping records for shipments made since the previous inspection

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implementation of applicable shipping requirsments, including completion of

! waste manifests

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implementation of the Certificates of Compliance for NRC approved shipping

! casks including limiting package contents consistent with C of C requirements and leak testing of packsoing l -

use of NRC approved snipping casks l

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- implementation of recent NRC and DOT shipping rule changes.

l The review was against criteria contained in 10 CFR 61,10 CFR 71,49 CFR 100-199, disposal facility licenses, and applicable Certificates of Compliance for shipping cask The inspector performed selected hand calculations to verify waste classification.

l The inspectors reviewed shipments of low specific activity (LSA) material, small quantities of material, general radioactive material shipments and shipments of irradiated metals for disposal. The inspectors observed and reviewed surveys performed on an LSA shipment in preparation and verified training and qualification of personnel involved '

as well as the calibration of survey instruments used to perform the surveys. The inspectors also verified completion of training and qualification of personnel handling, processing, and shipping radioactive materials relative to NRC Bulletin 79-19 and applicable DOT Hazmat training requirements.

l l Observations and Findinas PECO implemented an effective radioactive waste packaging and shipping progra Individuals involved in shipping activities were knowledgeable of applicable requirements and used up-to-date regulations and licenses for verification of compliance. PECO was aware of recent NRC and DOT rule changes and implemented them, as appropriat Of particular note was PECO's efforts during the period November 1998 through January 1999 to clean-out its Unit 3 spent fuel pool of irradiated metals. Numerous QA surveillances were performed during the activity to monitor the adequacy of controls and ,

implementation of procedures. PECO implemented good radiological controls for this I activity and packaged and shipped approximately 50,000 curies of highly radioactive irradiated metals including clean-up filters. PECO used appropriate shipping casks and implemented shipping requirements. PECO maintained an ongoing written narrative of l this activity and held a post-Job critique, including a post-job ALARA review, to identify areas for improvement. One individual involved in the waste packaging activities on January 5,1999, had not attended the required NRC Bulletin 79-19 training before performing work. This matter is discussed in Section R5 of this report.

l l Packaged radioactive material shipped to offsite vendors for processing or burial were 1 - properly packaged and shipped. Survey documentation for the shipments was clear and clearly indicated conformance with applicable requirements. Program procedures required verification of Certificate of Compliance requirements for radioactive waste shipping casks, radioactive waste shipment driver instructions provided for maintenance of exclusive use shipments, and emergency notification information was properly included with advance notifications properly made.

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16 Conclusions No violations or safety concems were identified. PECO implemented an effective radioactive waste and radioactive material packaging and shipping program and successfully shipped irradiated hardware and clean-up filters from its Unit 3 spent fuel storage poo R2 Status of RP&C Facilities and Equipment Insoection Scope (86750)

The inspectors viewed accessible portions of the station's radioactive liquid and radioactive solid waste collection, processing, and storage systems / locations (e.g., Radwaste Building, Low Level Waste Storage Facility and storage areas exterior to the station). The inspectors reviewed storage and handling practices, reviewed general condition of facilities and equipment, and interviewed personnel involved with various ;

waste handling and processing activities. The inspectors reviewed control and storage of radioactive material relative to 10 CFR 20.2006, Control and Storage of Radioactive Material, and general storage practices relative to NRC Bulletin 81-38. The inspectors performed selected radiation surveys at packaged radioactive material and waste storage area Observations and Findinos The locations toured were generally clean and well maintained. Tanks were periodically inspected, station leaks were aggressively pursued for repair and shielding and decontamination (as appropriate) was performed to minimize ambient radiation dose rates. Storaga locations for radioactive materials were properly posted, barricaded, and

, secured (as appropriate).

PECO collected and processed various liquid waste in drums (e.g., mop water) to preclude unnecessary impact on plant waste processing systems. Liquid and wet wastes were processed using small filter demineralizer units and various drying techniques. The activities were conducted on the 165' elevation of the Radwaste Building and were performed in accordance with procedures. Two drums of debris / dirt were observed to be stored in the area of liquid drummed waste processing. Although properly marked and labeled the drums were not included in PECO's computerized waste tracking programs and had apparently remained in the area for approximately two years unknown to supervisory personnel. The drums and there contents were subsequently incorporated into the tracking programs for review of disposal option PECO reviews did not identify any additional drum PECO established designated waste collection points at various areas of the station for specified waste types, including a new waste collection point (116' Turbine Building)

known as the Radwaste Enclosure for collection and sorting of waste. Drums of radioactive material and waste were stored in the area for subsequent processing. A drum of no longer used radioactive sources was observed stored in the area. Although the dose rates were low (less than 10 millirem /hr at the waste storage barricade line), the drum had been in the area for some time under evaluation for disposal options and was

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creating elevated dose rates for workers in the area and personnel traversing the are PECO concurred in this observation and initiated reviews of tho matte Conclusions No violations or safety concerns were identified. PECO's waste processing, handling, and storage areas were generally clean and well maintained. Waste storage areas were property posted, barricaded and secured.'

R3 RP&C Procedures and Documentation Inspection Scooe (86750)

The inspectors reviewed and discussed changes in radioactive waste processing, handling, storage, and transportation procedures and programs since the previous inspection in this area (NRC Combined Inspection Nos. 50-277;278/98-08). The l inspectors compared as found processes and methods to that described within the PCP and UFSA Observations and Findinas There were no significant program changes identified in the area of waste processing, storage, handling, and shipping. PECO updated its UFSAR and PCP to reflect recent organizational changes and areas of responsibility and authority as well as reportin PECO also updated its procedures to reflect changes in DOT and NRC waste shipping requirements. PECO was processing, handling, and storing radioactive waste consistent with UFSAR; v1 PCP descriptions, Conclusions No violations or safety concems were identified. PECO maintained its radioactive waste processing, handling, storage and transportation program descriptions current. As-found processes, pactices, and methodology were consistent with program descriptions and i updated as appropriat R4 Staff Knowledge and Performance in RP&C R4.1 Personnel Divina in Unit 2 Soent Fuel Pool Inspection Scooe (71750)

The inspectors reviewed PECO's preparations and observed personnel diving in the Unit 2 spent fuel storage pool. Personnel were required to dive in the pool to modify structural braces in the cask storage area to facilitate placement of the TN-68 dry cas The inspectors also disLssed the diving evolutions with cognizant licensee personnel and reviewed applicable documentatio l

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1 b. Observations and Findinas i

PECO thoroughly planned and prepared for the diving in the Unit 2 spent fuel poo l PECO used a dedicated day shift work crew, vacuum-cleaned the dive area, used high resolution cameras for monitoring the activity, implemented live-time monitoring of the i diver, and implemented High Radiation Controls consistent with guidance contained in NRC Regulatory Guide 8.38, Appendix A (e.g., use of physical barriers and limit length of diver tethers). PECO also collected and reviewed all applicable NRC Information Notices associated with diving activities or applicable unplanned exposure potentials. Of particular note was the efficient coordination of activities due to PECO's inter-departmental planning efforts. PECO used a special procedure and developed action, communication, and job-abort matrice The inspectors observed close monitoring of the diver both visually and through live-time ,

electronic dosimetry. Detailed surveys were performed of the dive area following a '

thorough clean-out and frequently throughout the approximately week-long effort. The inspectors noted that PECO's excellent dose reduction efforts resulted in significantly lower than expected overall dose to the diver c. Conclusions PECO performed thorough planning for personnel diving in the Unit 2 spent fuel poo The diving evolutions were carefully monitored by health physics personnel. PECO's excellent dose reduction efforts resulted in significantly lower than expected overall dose to the diver R5 Staff Training and Qualification in RP&C a. Inspection Scope (867501 The inspectors reviewed initial and continuing training provided personnel involved in radioactive waste generating, processing, and handling activities. This includeo ;

personnel who receive, handle, generate, process, or ship radioactive materials. The l inspectors also reviewed the training of personnel handling mixed waste. The review was against criteria contained in NRC Bulletin 79-19, Packaging of Low Level Radioactive Waste for Transport and Burial and 49 CFR 172, Subpart H training. The inspectors reviewed training records, lesson plans and discussed training with cognizant PECO personnel. Specific aspects reviewed included identification and testing of hazmat employees covered under 49 CFR 172.702(a), requalification training, and documentation of training completion. The inspectors discussed waste processing and shipping activities with cognizant personnel and evaluated personnel knowledge and areas of responsbilit The evaluation of licensee performance was based on review of training materials, discussions with personnel and review of applicable record . ,

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b. Observations and Findinas PECO continued to provide annual training to personnel in accordance with NRC Bulletin 79-19 guidance. The training specified in 49 CFR 172, Subpart H was also provided to these individuals and records of training were maintained. Personnelinvolved with radioactive waste activities were interviewed and were knowledgeable of procedure requirements applicable to their assigned areas of responsibilit During a previous inspection (50-277;278/98-08), a worker performing cask loading operations as a crane operator was identified that had not attended PECO's a-priori specified NRC Bulletin 79-19 training. PECO placed this matter in its corrective action ]l program and took actions to identify all workers needing specific NRC Bulletin 79-19 l training and included the training expectations in affected groups' training matrice On January 5,1999, a worker from the maintenance group assisted in packaging a cask i of irradiated metals for disposal. The worker performed double verification of the torque value of radioactive waste shipping cask head bolts. The worker had not received the NRC Bulletin 79-19 training listed in his training matrix. PECO had provided this individual the 49 CFR 172, Subpart H hazmat training and the individual was under direct oversight by personnel who had received the training. PECO was reviewing the effectiveness of its corrective actions at the time of the pool cleanout. This matter had minor safety significance. However, the failure to ensure that the worker had received proper training prior to performing work associated with packaging and shipping radioactive material is a minor violation of procedure AC-CG-26.4, Revision 7, which requires that supervisors assure that assigned work is performed by trained and qualified staff. Technical Specification 5.4.1 requires establishment and implementation of procedures. PECO included this matter into its correctw w on process with other items !

for improvement identified during its corrective action effectiveness review (PEP N , dated May 28,1999). This minor violation is not subject to formal enforcement actio c. Conclusions Personnel involved in waste activities received training as specified in NRC Bulletin 79-19 and 49 CFR 172, Subpart H and exhibited good knowledge of procedure requirements. A minor violation associated with one individualinvolved in waste packaging activities, who had not received applicable training, was identified and included in PECO's corrective action syste R6 RP&C Organization and Administration a. Inspection Scope (86750)

l The inspectors reviewed the current radioactive waste processing organization, its staffing and its responsibilities and authorities against criteria contained in UFSAR Chapter 13, and applicable PECO procedures. The inspectors evaluated PECO's performance in this area by discussion with cognizant personnel and review of documents.

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, o 20 Observations and Findinas PECO reorganized its chemistry and radioactive waste groups to combine these organizations and also incorporated non-radioactive waste handling and monitoring activities into the organization. PECO created and staffed the position of Chemistry /Radwaste Manager. The individual assigned to this position did not fully meet the qualifications of Chemistry Manager. PECO established a transition plan for this individual in accordance with administrative procedures and designated a fully qualified individual to act as Chemistry Manager. PECO performed a 10 CFR 50.59 evaluation to change the organization and updated applicable procedures and the UFSA Conclusions No violations or safety concems were noted. PECO updated its administrative documents to reflect recent organization changes in its chemistry /radwaste organizatio PECO also implemented its administrative controls to designate an acting Chemistry

' Manager pending full qualification of the Chemistry /Radwaste Manage R7 Quality Assurance in RP&C Activities insoection Scope (86750)

The inspectors reviewed audits, assessments, and surveillances of the radioactive waste handling, processing, storage, and transportation programs as well as audits of the Process Control Program. The inspectors also reviewed audits of the training and qualification of personnelinvolved in radwaste processing, handling, storage and shipping activities. Further, the inspectors reviewed audits of the adequacy and effectiveness of the corrective action program in the area of radwaste processing, l handling, storage, and transportation activitie The inspectors reviewed selected completed audit checklists and final audit results. The review was against criteria contained in UFSAR Appendix D, Quality Assurance j Program, and applicable station audit and surveillance procedure ; Observations and Findinas PECO performed audits consist with guidance contained in UFSAR, Appendix D. The audit scope was reviewed and commented on by Nuclear Review Board members who were determined to have expertise in the area audited. Technical specialists were used to perform audits and surveillances. The audit activities were performance based and areas for improvement and correction were entered into PECO's corrective action programs. PECO performed self-assessments of radioactive waste shipments. PECO also provided documented audits of the training and qualification of personnel performing radioactive waste processing, handling, or shipping activitie Assessment LAR 99-001, conducted early 1999, evaluated health physics, chemistry, radiochemistry and radwaste personnel training. The results of the assessment were

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combined with other station training audits. Although the completed audit checklist contained areas for improvement, the audit summary did not provided a clear and j

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comprehensive summary of the areas for improvement. The areas for improvement associated with personnel involved in radwaste activities were, however, included in a management performance enhancement program (MPEP) report as part of a corrective action review proces i A Quality Assurance (QA) surveillance of liquid effluent sampling (PSR 98-120, dated !

August 12,1998), identified a concern in the technique for compositing samples for offsite radionuclide analysis. A liquid sample was not shaken and sediment was observed to have settled in the composite sample possibly resulting in underestimating the insoluble radioactivity released. This matter was isolated to one technician who independently composited liquid samples during the period March - July 1998. This l

matter had minor safety significance in that tank activities were low, affected chemistry technicians were re-instructed, and a procedure revision was made to ensure proper sample mixing. At the time of the inspection, PECO had not reevaluated previous releases for potential error attributable to the sampling practice associated with the one technician. PECO subsequently completed the review and concluded that liquid releases were well within limits; there was no potential for significant release of unquantified radioactivity and that given the low concentration of radioactivity in liquid t releases, the likelihood of exceeding liquid release limits was negligible in that tanks sampled by the technician exhibited trace radioactivity. This was identified and properly evaluated by the licensee and appropriate remedial actions were taken. The NRC concluded that no violation of regulatory requirements resulte a c. Conclusions  ;

l PECO audits of radwaste activities were consistent with UFSAR requirements and were l generally performance based. Corrective actions were incorporated into PECO's j corrective action syste V. Manaaement Meetinas I X1 Exit Meeting Summary The inspectors presented the results of the inspection to members of licensee management on July 7,1999. The licensee acknowledged the findings presented. No ,

proprietary information was identified by PEC l l

X2 Review of Year 2000 Readiness of Computer Systems l The staff conducted a review of Y2K activities and documentation using Temporary Instruction (TI) 2515/141, " Review of Year 2000 (Y2K) Readiness of Computer Systems at Nuclear Power Plants." The review addressed aspects of Y2K management planning, documentation, implementation planning, initial assessment, detailed assessment, remediation activities, Y2K testing and validation, notification activities, and contingency planning. The reviewers used NEl/NUSMG 97-07, " Nuclear Utility Year 2000 Readiness," and NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning," as the basis for this review. The results of this review will be comt:ined with the results of other reviews in a summary report to be issued by July 31,199 .. . . 1

l lNSPECTION PROCEDURES USED

!P 37551 Onsite Engineering Observations IP 61726 Surveillance Observations IP 62707 Maintenance Observations IP 71707 Plant Operation IP 71750 Plant Support Activities IP B6750 Solid Radioactive Waste Management and Transportation of Radioactive Waste ITEMS OPENED AND CLOSED Opened / Closed 50-277(278)/99-05-01 NCV Inadvertent Lass of the 3 Ernergency Auxiliary (EA)

Transformer During 343 Start-Up (SU) Bus Restoration 50-277(278)/99-05-02 NCV Fire Protection and Fire Safe Shutdown Plan Non-Conformances (Units 2 and 3)

Closed 50-277(278)/2-99-003 LER Failure to Maintain the Provisions of the Fire l Protection Program to Properly Address the Effects I of Flooding Caused by Fire Induced Mis-Operation of High/ Low Pressure Interfaces in Low Pressure Emergency Core Cooling Systems 50-277(278)/2-99-004 LER Multiple Unplanned Engineered Safety Feature (ESF) Actuations During A Planned Electrical Bus Restoration Following Maintenance Activities 50-277(278)/98-10-03 eel Fire Detection System Non-Conformances (Units 2 and 3)

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LIST OF ACRONYMS USED l AR action request ARC alarm response card ALARA as low as is reasonably achievable BTP branch technical position CFR code of federal regulations CS core spray DOT Department of Transportation EA emergency auxiliary ECCS emergency core cooling system EDG emergency diesel generator eel escalated enforcement issue i ELU emergency lighting unit i ESF engineered safety feature FSSD fire safe shutdown- t HAZMAT hazardous materials HCU hydraulic control unit HPCI high pressure coclant injection l&C instrumentation and controls LER licensee event report LSA low specific activity MCREV main control room emergency ventilation MPEP- management performance enhancement program

NCV non-cited violation NRC Nuclear Regulatory Commission NQA nuclear quality assurance

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ODCM offsite dose calculation manual PBAPS Peach Bottom Atomic Power Station l PCIS primary containment isolation system l PCP process control program PDR public document room PECO- PECO Nuclear PEP performance enhancement program l PMS plant monitoring system l QA quality assurance

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RADWASTE radioactive wasted l RCIC reactor core isolation cooling ]

l RHR residual heat removal l RP&C radiological protection and chemistry RPS reactor protection system SO system operating SU start-up TEDE . total effective dose equivalent TLD thermoluminescent dosimeter TS technical specifications UFSAR updated final safety analysis report VIO violation Y2K Year 2000