ML20081D106
| ML20081D106 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/16/1995 |
| From: | Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9503200130 | |
| Download: ML20081D106 (4) | |
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Gerald R. Reiney Vice Presidrnt g
f Peach Bottom Atomic Power Station
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PECO ENERGY ggeg,ce-a ">
Delta, PA 17314-9739 717 456 7014 March 16. 1995 t
Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission
' Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station Units 2 & 3 Response to Notice of Violation (Combined Inspection Report No. 50-277
& 50-278/95-01)
Gentlemen:
In response to your letter dated February 14, 1995, which transmitted the Notice _of Violation concerning the referenced inspection report, we submit the attached response.
The subject report concerned a Routine Resident Safety inspection that was conducted January 1 through February 4,1995.
If you have any questions or desire additional information, do not hesitate to contact us.
Gerald R. Rain 6y Vice President Peach Bottom Atomic Power Station Attachment cc:
R. A. Burricelli, Public Service Electric & Gas R. R. Janati, Commonwealth of Pennsylania T. T. Martin, US NRC, Administrator, Region l W. L. Schmidt, US NRC, Senior Resident Inspector H. C. Schwemm, VP - Atlantic Electric R.1. McLean, State of Maryland A. F. Kirby 111, DelMarVa Power dNlY 200053 l}
CCN-95-14026 9503200130 950316 PDR ADDCK 0500o277 Q
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l RESPONSE TO NOTICE OF VIOLATION Restatement of Violation 10 CFR Part 50.59 (b)(1) states, in part, that "The licensee shall maintain records of changes in the facility made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the safety analysis report. These records must include a written safety evaluation which provides the bases for the' determination that the change does not involve an unreviewed safety question.
Contrary to the above, during outages in 1993, PECO modified the reactor building structure at Unit 2 and Unit 3 through the installation of temporary shielding structures (four in total) above the seismic Category 1, hydraulic control units, and left these structures in place during power operations without performing a written safety evaluation as required by 10 CFR Part 50.59.
This is a Severity Level IV violation (Supplement 1).
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a Reason for the Violation i
i On October 1,1992., an Engineering Work Request (EWR) was initiated that requested i
Engineering to evaluate the temporary use of scaffold planking to support shielding lead blankets over the hydraulic control units (HCUs). This shielding was requested to reduce
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radiation dose rates in areas where maintenance outage work was being performed. A structural load analysis was performed by Engineering to support the EWR and the installation of the sheilding was approved prior to the unit outages. The shielding was categorized as temporary and was to be removed at the end of the outages. Following
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completion of the outages and the return of the units to power, however, a decision was made to leave the shielding in-place to continue the reduction in general area dose rates. Since the installation of the shielding above the HCUs was originally designed to reduce area dose rates for personnel only during outage conditions, a 10CFR50.59 review and seismic analysis were not performed. The EWR did not address ownership or delineate the appropriate control or resposibilities associated with the installation, l
inspection, and removal of the shielding. As a result, shielding originally classified as temporary was allowed to remain installed in the plant during operation without a completed safety evaluation o'r seismic analysis.
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Guidance for temporary shielding was provided in Engineering Specification NE-048, "The Use of Temporary Shielding at PECO Energy Company Nuclear Facilities" and Health Physics procedure HP-C-313," Temporary Shielding Program". Specification NE-048 provide the technical requirements for the temporary shielding. The specification noted that shielding evaluated, installed, and controlled in accordance with the requirements of NE-048 did not require an individual 10CFR50.59 review, but would be j
included under the 10CFR50.59 evaluation for the specification. The specification also stated that temporary shielding was intended to be in use for one year or less. Shielding applications required to be in place longer than one year were recommended to be implemented with a plant modification. In contrast to the specification when the shielding was originally installed, the HP procedure did not specify a time limit that the shielding could be left in place. In a later revision, however, the procedure was revised to define temporary shielding as shielding to be in use for six months or less. Although the specification and procedure provided some guidance concerning temporary shielding, the overall process to request design, installation and control of temporary shielding was not clearly defined. The inappropriate application and control of the HCU shielding was a result of conflicting procedural guidance, non-compliance with the existing specification and procedure, and a lack of program ownership which prevented resolution to process weaknesses and the subsequent violation of 10CFR50.59 requirements.
The Corrective Steps That Have Been Taken and the Results Achieved The lead shielding blankets were reconfigured so that they were contained within the toeboards and additional supports were provided to secure the scaffold planks in place at each location where the planks cross an I-beam.
A Performance Enhancement Program (PEP) issue was initiated January 25,1995, to determine causal factors of this event and the activities associated with it and to develop appropriate corrective actions to prevent recurrance.
Engineering in conjunction with HP personnel performed a walkdown of ait accessible shielding installations to determine the status of existing configurations. In addition, Engineet.g performed a review of 163 previously approved shielding requests. Upon completici of these reviews, it was determined that five shielding installations required further evaluation to be in full compliance with 10CFR50.59, Specification NE-048, and HP-C-313. An EWR was issued to Engineering to perform the required analysis and appropriate actions were completed February 17,1995.
y Non-comphance reports (NCRs) were issued to Engineering to address structural integrity, impact on the control rod drive system and issues related to the long term use of pla'nks as permanent structures. To address the as-left condition, as previously approved under the initial EWR, a seismic analysis and 10CFR50.59 safety evaluation was performed.
Engineering Specification NE-048 was revised March 3,1995, to clearly define the shielding requirements and provide the proper controls for the installation of temporary versus permanent shielding. In addition, Engineering will control the installation of shielding, whether temporary or permanent, via the Engineering Change Request (ECR) process under a Minor Physical Change ECR, the Small Modification ECR or a Major Modification. In all cases, a 10CFR50.59 review or evaluation will be required to fully evaluate Category I and ll components and structures.
Health Physics procedure HP-C-313 was revised and made effective March 2,1995, to de.ine all shielding as permanent and designed for the purpose of reducing radiation levels, unless specifically identified as temporary. Temporary shielding is still required to be in use no longer than six months, but the revised HP-C-313 now provides the appropriate control, program ownership and consistency with the requirements with Engineering Specification NE-048.
The Corrective Steps that Will Be Taken to Avoid Further Violations The corrective steps that have been initiated as a result this event will serve to avoid further violations.
Date When Full Compliance Was Achieved Full compliance with 10CFR50.59 requirements was achieved March 13,1995,when safety evaluations for shielding above the Unit 2 and Unit 3 HCU banks were approved by the Plant Operating Review Commitee.
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