ML20058A253
| ML20058A253 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/17/1990 |
| From: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9010250356 | |
| Download: ML20058A253 (4) | |
Text
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004 90-14190 e
eP PillLADEI.PillA El.ECTRIC COMPANY
\\ (hjF l't.ACilIKWIDM AlOMIC POWIR STATK)N R. D 1. Inox 20M Niwp WM Delta. Itnm)lvania 17314 p u n n a m -e m n.ein ors u stti m e
(?!7) 4W7014 D. B. Miller, Jr.
V6ce Preudent Octator 17, 1990 Docket Nos. 50-277 50-278 U. S. Nuclear Regulatory Commission ATTH:
Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station - Units 2 & 3 Response to Notice of Violation (CombinedInspectionReportHos. 50-277/90-15; 50-278/90-15)
Dear Sir,
in response to your [[letter::05000278/LER-1990-010-03, :on 900804,HPCI Declared Inoperable Due to Failure of Manual & Overspeed Trip Tappet Assembly.Caused by Design Problem Re Tappet Swelling.New Design Being Provided by GE Will Replace Tappet Assembly|letter dated September 6, 1990]], which transmitted the subject inspection Report and Notice of Violation, we submit the attached response. The subject inspection Reptrt concerns a routine inspection of maintenance activities on the emeraency diesel generators during the period July 23-27. 1990.
The date of re.sponse to the Notice of Violation was changed to allow thirty days after rcceipt of the transmitted notice, which arrived September 17, 1990. This agreement was made between Jacque Durr of your staff and Al fulvio, Regulatory Engineer on September 24. 1990.
If you have any questions or require additional ir./ormation, please do not hesitate to contact us.
Sincerely, cc:
R. A. Burricelli, Public Service Electric & Gas T. M. Gerusky. Commonwealth of Pennsylvania J. J. Lyash USNRC Senior Resident inspector T. T. Martin, Administrator Ragion 1. USNRC H. C. Schwemm. Atlantic Electric R. 1. McLean, State of Maryland J. Urban. Delmarva Power i
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Document C;ntrol Desk October 17, 1990 Page 2 bec: J. A. Basilio 52A-5, Chesterbrook J. A. Bernstein 51A-13. Chesterbrook R. N. Charles 51A-1. Chesterbrook Commitment Coordinator 52A-5, Chesterbrook Correspondence Control Desk 618-3 Chesterbrook E. J. Cullen S23-1 Main Office i
A. D. Dycus A3-15, Peach Bottom E. P. Fogarty A4-4N, Peach Bottom J. F. Franz A4-15 Peach Bottom A. A. Fulvio A4-15 Peach Bottom D. R. Helwig 51A-11. Chesterbrook G. A. Hunger 52A-5, Chesterbrook R. J. Lees, NRB 53A-1. Chesterbrook J. M. Madara 53A-1 Chesterbrook C. J. McDermott S13-1. Main Office D. B. Miller, Jr.
SMO-1. Peach Bottom PB Nuclear Records A4-25, Peach Bottom J. M. Pratt B-2-S, Peach Bottom L. B. Pyrih 638-5, Chesterbrook J. T. Robb 51A-13 Chesterbrook D. M. Smith 52C-7 Chesterbrook 1
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Document Control Desk
- 6ctober 17, 1990 Page 3 o
ATTACHMENT Response to Notice of Violation 90-15-01 Restatement of Violation 10 CFR 50. Appendix B, Criterion V, requires in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures.
PBAPS QA Plan PR 5.0, " Instructions Procedures, and Drawings" delineates this requirement by requiring that activities be accomplished in accordance with procedures prescribed by procedure manuals or test procedures. Quantitative criteria, such as dimensions or tolerances, shall be specified for determining satisfactory work performance.
Contrary to the above, on July 27, 1990, work activities were not accomplished in accordance with established procedure MP-052-001
" Diesel Generator Maintenance", in that as-left tolerance limits for EDG brush forces were exceeded and this condition did not receive an adequate, independent review as required by the procedure.
This is a Severity level IV Violation.
(Supplement 1).
Cause of Violation The craftsman that adjusted the spring pressure on the brushes misinterpreted the fractional values on the spring scale and incorrectly applied those values to the as-left limits of the procedure. The procedure listed decimal values from 1.75 lbs. to 2.25 lbs. as acceptable for the as-left brush force.
The craftsman however transcribed readings of 2 1/2 lbs. from the spring scale and thought they were equal to 2.25 lbs. as found in the procedure.
The craftsman then signed off the procedure as acceptable.
The craftsman then informed the individual performing the independent review that he was to look for a maximum value of 2 1/2 lbs for the as-left value.
The independent reviewer neither questioned or verified this instruction.
Noting that all the as-left values were 2 1/2 lbs. or less, the independent reviewer also signed off the procedure as acceptable.
A final review of the procedure and work package was performed by Maintenance Supervision, but did not identify the out of tolerance values.
Corrective Actions Taken and Results Achieved An acceptability evaluation was initiated promptly after the as-left brush force values were found to have exceeded the maximum limit. This evaluation determined that the as-left values would have no detrimental effects on the diesel generator. Based on this evaluation it was determined to leave the brush force values at the current setting.
.o Document Control Desk October 17, 1990 Page 4 This incident was discussed with the individuals involved as well as other team members that perform this task during diesel outages. Attention to detail and procedural compliance were stressed.
The responsibilities of an independent reviewer and supervision review of completed work packages were discussed during a team quality awareness meeting held on September 20, 1990. This incident was discussed as well as the process of independent verification.
A review of three other diesel generator maintenance procedures was conducted to determine if there were any prior discrepancies with as-found or as-left brush force values. The previous brush forces values were all found to be within the specified tolerance range of the procedure.
Corrective Steps Taken That Will Avoid future Violations The process of independent verification will be discussed in future maintenance team meetings. This will be completed by December 31, 1990.
Maintenance Procedure M-052-001
" Diesel Generator Maintenance", will be revised so that the as-left brush force values will be indicated in both their decimal and fractional values.
1his revision will eliminate the need for scale conversions in the field while performing the procedure.
Additionally, a more accurate spring scale will be purchased to minimize personnel and measurement error. The new spring scale will be more reliable and will display a digital decimal readout.
This will reduce discrepancies in recording field values and transferring them to the procedure. A training session will be conducted with the appropriate craft before the use of this instrument. The responsibilities of reviewing data and independent verification will be re-emphasized during this training as well.
These actions will be completed prior to the next diesel outage, scheduled for June 1991.
Date full Compliance Was Achieved Full compliance was achieved July 26, 1990 when the as-left brush force values were evaluated and found to be acceptable by the manufacturer and maintenance engineering.
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