IR 05000277/1988038

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-277/88-38 & 50-278/88-38

ML20235M658
Person / Time
Site:	Peach Bottom
Issue date:	02/09/1989
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8902280354
Download: ML20235M658 (2)

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I FEB 0 91989 Docket Nos. 50-277 50-278 I- Philadelphia Electric Company l

ATTN: Mr. C. A. McNei'll Executive Vice President-Nuclear l Correspondence Control Desk l P. O. Box 7520 I

Philadelphia, Pennsylvania 19101 i Gentlemen:

Subject: Inspection No. 50-277/88-38 and 50-278/88-38 This refers to your letter dated December 21, 1988, in response to our letter dated November 21, 1988.

Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely, og . . . , - -

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Ja;queF. L .c Thomas T. Martin, Director Division of Reactor Safety l

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0FFICIAL RECORD COPY RL PB 88-38 - 0001.0.0 gg22eoss4890209 ,, 01/26/89 g o ADOCK osoo 7 7g,g) j

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i FEB 0 91989

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. Philadelphia Electric Company 2 cc:

John S. Kemper, Sr., Senior Vice President-Nuclear J. W. Gallagher, Vice President, Nuclear Services-E. C. Ki~tner, s Chairman, Nuclear Review Board Dickinson M. Smith, Vice President, Peach Bottom Atomic Power Station Jack Urban, General Manager, Fuels Department, Delmarva Power & Light Co.

John F. Franz, Plant Manager, Peach Bottom Atomic Power Station Troy B. Conner, Jr. , Esquire W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric Bryan W. Gorman, Manager, External Affairs Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)

Raymond L. Hovis, Esquire Thomas Magette, Power Plant Siting, Nuclear Evaluations W. M. Alden, Director, Licensing Section Doris Poulsen, Secretary of Harford County Council Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident inspector Commonwealth of Pennsylvania bcc:

Region I Docket Room (with concurrences)

Managem:nt A:sistant, DRMA (;/c encl)

Section Chief, DRP PA0 (2) SALP and All Inspection Reports Robert J. Bores, DRSS R. Martin, NRR B. Clayton, EDO O9 RI:DRSUC RI:DRS RI:DRS RIi)

Cheung/geb Anderson Durr Mar n 1/M89 1//0/89 J/[/89 0FFICIAL RECORD COPY

/ /9 RL PB 88-38 - 0002.0.0 01/26/89

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10 CFR 2.201

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PHILADELPHIA ELECTRIC COMPANY 23o1 MARKET STREET P.O. BOX 8699 PHILADELPHIA A. PA.19101.

(215) 841 4502

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S, J, KOW ALSKI V IC E-P R E SI D E NT m ... ......... . December 21, 1988 Docket Nos. 50-277 50-278 l

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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk j'

Washington, D.C. 20555 SUBJECT: Peach Bottom Atomic Power Station Units 2 and 3 Environmental Qualification  !

Response to Notice of Violation REFERENCE:-Inspection Report Nos. 50-277/88-38; 50-278/88-38

Dear Madam or Sir:

By letter dated November 21, 1988 from T. T. Martin (NRC-Region I) to C. A. McNeill, Jr. (PCCo), the referenced inspection report and a_ Notice of Violation were transmitted. The Notice of Violation identified one area which did not appear to be'in full compliance with NRC requirements. The items in this area are restated and followed by Philadelphia Electric Company's response in the attachment to this letter.

If you have any questions or require additional information, please do not hesitate to contact us.

Very trul . ours,

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Attachment cc: W. T. Russell, Administrator, Region I, USNRC W E D Marttfi7 Region I, USNRC T. P. Johnson, USNRC Senior Resident Inspector T. E. Magette, State of Maryland '

J. Urban, Delmarva Power J. T. Boettger, Public Service Electric & Gas H. C. Schwemm, Atlantic Electric d s i , d1 - '*L

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Docket Nos. 50-277 50-278 RESPONSE TO NOTICE OF VIOLATION RESTATEMENT OF VIOLATION A.1 On June 19, 1987, the inspector icentified 6 wire crimps inside 2 Limitorque Valve Actuator housings (3 in MO-2-14-005D, 3 in MO-2-14-0078), for which qualification was not demonstrated in that the test report did not provi6e evidence that the wire crimp surface was in contact with the electrical ground, while some of the 6 identified wire crimps were observed to be touching the actuator housings.

During the LOCA test, the wire crimp surface should be touching the electrical ground in order tc aetect any insulation resistance degradation during the LOCA conditions.

This is a Severity Level IV, riupplement I.

RESPONSE TO VIOLATION A.1 Admission or Denial of the Alleaed Violation:

Philadelphia Electric Company acknowledges the violation.

Reason for the Violation:

Prior to November 30, 1985 (the environmental qualification compliance deadline) PECo had established environmental qualification (EO) for the Limitorque valve actuators discussed in the Notice of Violation.

However, at that time the need to question if the crimps were touching a ground plane during the qualification testing was not recognized.

These crimps were subsequently den.onstrated to be qualifiable based on Limitorque Test Report No. B0119 and an' April 1986 document prepared by the Nuclear Utility Group on Environmental Qualification. This qualification was found acceptable by the NRC as documented in Inspection Report No. 50-277/87-18; 50-278/87-18 (hereafter referred to as 87-18).

Corrective Steps Which Have Been Taken and the Results Achieved:

I The EQ file has been updated to address this issue; however, these wire crimps were replaced with splices for which more conclusive qualification evidence exists. This replacement is complete at both Units 2 and 3, (Modification 2231).

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Paga 2 of 6

. Docket Nos. 50-277 50-278 Corrective Steps Wnich Will Be Taken to1 Avoid Further Violations:

The' Company does not consider additional corrective acti'ons to be cnecessary. Limitorque has discontinued- use of these wire crimps.

Date When Full Compliance Will Be Achievedi Pull compliance was achieved in July 1987 as. acknowledged in Inspection Report No. 87-38.

RESTATEMENT OF VIOLATION A.2 During the 1987 and 1988 period, when Peach Bottom Units 2 and 3 were snutdown, the licensee identified numerous Raychem splices which did not. meet the Raychem qualification criteria (sealing length too short, bending radius too small). Qualification of these splices was not established at the time they were identified.

This is a Severity Level IV, Supplement I.

RCSPONSE TO VIOLATION A.2 Admission or Denial of the alleced Violation:

Philadelphia Electric Company acknowledges this violation. The Company identified these deficiencies during a sample inspection i

program initiated to address a concern identified during Inspection l No. 87-18 concerning Raychem heat shrink tubing over braided wire.

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Reason for Violation:

The installation deficiencies vere determined to be due to insufficient training for the personnel who install such splices and j the inspectors who check such installations. These splices were found l to be qualifiable based on a March 1987 test report; however, because

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the splices did not conform to current Raychem installation J j procedures, the Company did not have positive qualification )

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justification'for the configurations found. l L _ -__ ___-

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. Attachment Page 3 of 6

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Docket Nos. 50-277 50-278 Corrective Steps Which Have been Taken and the Results Achieved:

These splices have been replaced with splices prepared in accordance with Raychem installation procedures as part of Modification 2355.

Tnis modification consists of inspection and replacement, as necessary, of pigtail splices on environmentally qualified devices.

Training sessions have been conducted by Raychem Corp. at Peach Bottom. These sessions were attended by installation, field engineering, maintenance, and quality assurance personnel. In addition to the Raychem training, the installation details (as shown on drawing E-1317) were revised to include the exact Raychem installation procedures.

Corrective Steps Which Will Be Taken to Avoid Further Violations:

The Company considers the corrective steps taken sufficient to prevent further violations in the near term; however, the Company, as part of its long term program, has objectives which are particularly germane to preventing future violations of this type. These objectives are to control maintenance program activities which could affect plant configuration and provide training programs in support of this ob 3 ective.

Date When Full Compliance Will Be Achieved:

Tne inspection and necessary replacement of splices (Modification 2355) is complete on Unit 2 and will be complete on Unit 3 prior to restart of Unit 3. Therefore, Unit. 2 is in full compliance and Unit 3 will be in full compliance prior to restart.

RESTATEMENT OF VIOLATION A.3 During the 1987 and 1988 period, the licensee identified in Unit 2 that Ideal wire nuts were used to connect Atkomatic solenoid valves to the field wire in the Containment Atmosphere Dilution Analyzer racks.

The qualification for these wire nuts was not established in that there was no EQ file or qualification data for these wire nuts and they were not on the EQ Master List.

This is a Severity Level IV, Supplement I.

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Attachmnnt'

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Docket Nos. 50-277 50-278

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' RESPONSE TO VIOLATION A.3 L ,

Adinission or' Denial of the Alleged Violation:

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^l Philadelphia Electric Company acknowledges this violation. l

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Reason for the~ Violation:

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Environmentalfqualification of the Containment Atmosphere Dilution (CAD) Analyzers was established based,.in.part, on the review of purch6se specifications. The specifications required compression-type ,

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connections. However, wire nuts are not compression-type connectors.

Because wire nuts-have not been permitted for use at the station, it is1be]ieved that the CAD analyzers were supplied with the wire nuts contrary to the' purchase specification. As a result, there was no.

justification for wire nuts in the EQ files.

Cortective Steps Which Have Been Taken and the Results Achieved:

These wire nuts have been (or are being)'relaced with' splices prepared in accords.nce with Raychem installation procedures as part of Modification 2355 (Unit 2 is complete, Unit 3.in progress).

'Correc'tive Steps Which Will Be'Taken to Avoid Further Violations:

This is considered to be an isoluted case; therefore, no additional corrective steps are planned.

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Date When Full Compliance Will Be Achieved:

Unit-2 is in full compliance, and Unit 3 uill be in full compliance prior to restart of Unit 3.

RESTATEMENT OF VIOLATION A.4 ,

i c During the 1987 and 1988 period, the licensee identified in Unit 2 that AMP butt splices were used in 8 solenoid valve circuits, 2 pressure switch circuits and 1 level transmitter. The qualification for these butt splices was not established in that there was no EQ

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,. Docket Nos. 50-277 50-278 fi3e or qualification data for these splices and they were not on the EQ Master List.

This is a Severity Level IV, Supplement I.

RESPONSE TO VIOLATION A.4 Admission or Denial of the Alleged Violation:

The Philadelphia Electric Company disagrees that there was no EQ file for these splices and that these splices were not on the EQ Master List. Philadelphia Electric Company acknowledges a deficiency in that the EQ file for these splices did not adequately address test anomolies identified in AMP Test Report No. 110-11004.

Reason for the Violation:

The reason for this deficiency was that the AMP butt splice (EQ package No. 36) did not address the insulation resistance capabilities during the LOCA portion of the test due to test anomolies.

Specifically, the test specimens were not in contact with the ground plane, and shortly after the start of the LOCA test, the 600V potential was removed. The package did not adequately address these anomolies. However, prior to this inspection PECo evaluated these anomolies and concluded that tne post-LOCA tests included in the EQ file qualified the connectors.

Corrective Actions Which Have Been Taken and the Results Achieved:

Prior to the inspection, PECO obtained and reviewed additional supplementary test data on these splices from another nuclear utility.

The EQ file was reviewed and revised to demonstrate qualification of the AMP outt splices. However, these splices have been (or are being)

replaced with splices prepared in accordance with Raychem installation procedures as part of Modification 2355 (Unit 2 is complete, Unit 3 in progress).

Corrective Steps Which Will Be Taken to Avoid Further Violations:

The appropriate installation procedures have been revised to require, for additional assurance, that Raychem heat shrink tubing be installed in accordance with Raychem installation procedures over all AMP splices installed in the future.

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