ML20059F054

Responds to NRC Re Violations Noted in Safety Insp Repts 50-277/90-13 & 50-278/90-13.Corrective Actions: Training Will Be Provided for Personnel Re Requirements of Drawing E1317 & Administrative Procedures A-2 & A-6

ML20059F054
Person / Time
Site:	Peach Bottom
Issue date:	08/31/1990
From:	Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9009110076
Download: ML20059F054 (5)

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'CCN 90-14163"

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' PHILADELPHIA ELECTRIC COMPANY PEACil BOT 1DM A1DMIC POWER STATION : .i R. D.1, imx 208 Delta, Itnnsylvania 17314 {

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~peacu sorrues :na powan or excrutmca (717) 456-7014 j' ." D. B. Miller, Jri Vice President -

5- August 31, 1990 o Docket Nos 50-277 l r 50-278 i'

n U.. S. ' Nuclear Regulatory Comission.

,  ; ATTN:. Document Control Desk' Washington, DC. 20555' -;

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SUBJECT:

' Peach Bottom Atomic Power Station -. Units 2 & 3 Response to Notice of Violation .

(Combined: Inspection Report Nos. 50-277/90-13; 50-278/90-13)

Dear Sir:

.In! response to your letter dated' July 30, 1990 which transmitted the-subject Inspection Report land Notice of Violation,~we: submit the attached

,: response. The subject-Inspection Report concerns a routine resident. safety ~

inspection 1during the period May'16 through Jul.y 2,l1990. .

. :If you have any. questions or require additional information. please do not .

( hesitate to contact us. i i

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Sincerely, A r

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l Attachment- j icc: ,RL A. Burricelli, Public Service Electric & Gas T. M. Gerusky, Comonwealth.of Pennsylvania

-J. J. Lyash, USNRC Senior Resident Inspector E T..T. Martin, Administrator, Region I, USNRC H. C. Schwe m. Atlantic Electric R. I. McLean, State of Maryland-

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X Urban, Delmarva Power-y ~0'ohf[1OO76'900831 9 7 \ l 4

PDR ADOCK 0500 j v ,,

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a T 'YbeciJ.iA.Basilio 52A-5, Chesterbrook:

'J. A. Bernstein- 51A-13, Chesterbrook-R.-N. Charlest 51A-1 Chesterbrook; .;

Commitment Coordinator 52A-5, Chesterbrooki i

-A . Correspondence Control Desk 61B-3, Chesterbrook a l:

h E. J.:Cullen: S23-1, Main Office-A. D. Dycus' A3-15, Peach Bottom E. P. Fogarty .A4-4N.. Peach Bottom J. F. Franz A4-1S, Peach Bottom- ,

A. A. Fulvio'. A4-1S, Peach Bottom - I D. R. Helwig 51A-11 Chesterbrook G. A. Hunger '

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• 52A-5 Chesterbrook. t 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 A4-2S,' Peach Bottom J. M. Pratt, B-2-S., Peach Bottom.

L. B. Pyrih- 638-5,'Chesterbrook'.

-J. T. Robb 51A-13, Chesterbrook+

r D. M. Smith 52C-7, Chesterbrook-F

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. .d. Attachment t

Response to Notice of Violation 90-13-02 Restatement of Violation 10 CFR 50, Appendix B, Criterion III, Design Control,_ requires that measures be established to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are; '

controlled. Criterion VI,-Document Control, requires that measures be established to control the issuance of drawings and to assure that they are used at the location where the prescribed activity is~ performed.

The Philadelphia Electric Company Nuclear Quality Assurance Plan (QAP),

documents the 1.icensee's Appendix B program. QAP Section MEM 2.2.3, states. .j maintenance that may affect functioning of-safety-related systems or- l componen+s shall be performed in a manner to assure compliance with specified design requirements. Section MEM 6.2 states that personnel participating in the maintenance activity shall_use current drawings for performing:the  ;

activity.

Design drawing E1317, Revision 54, " Wire & Cable - Notes & Details. Power.

Control & Instrumentation " establishes the acceptable cable splice configurations for use at Peach Bottom.

Contrary to the above on June 27, 1990, electrical splices performed under Maintenance Request Form 9061705 on the E3 emergency diesel generator air start solenoid valves were of a' configuration not approved for Class IE applications, per E1317. In addition, copies of drawing E1317 obtained for use by the craft personnel, Revision 52, were not the most recent revision. 1 This is a Severity Level IV violation-(Supplement ~I)._

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s Background ,

On June 26, 1990, the craftsman. responsible for performing electrical splices on the E3 Diesel Generator (DG) determined that the splice specified in ,

maintenance procedure M521.202 of the work package could not-be performed within.the space limitations of the conduit. The craftsman suggested to the >

maintenance planner that an alternative splice method detailed on Sheets 71 j and 721 of E1317. " Wire'& Cable - Notes & Details, Power, Control & 1 Instrumentation" be performed. The planner agreed with this suggestion

although the method.was approved only for non-Class IE application. 'The splice on the air start solenoid valve of the-diesel' generator required Class

. IE~ detail. The work package was changed by the maintenance planner without engineering review or approval to allow use of a non-Class IE splice design 3 ifor Class IE application. Upon further review the craftsman requested an "

additional change, which the planner agreed to because the splice technique of Sheets 71 and 72 was not the craft's preferred method. The craftsman then

-selected Sheet 6E of.E1317. Rev. 52 which was an uncontrolled and outdated revision that was limited to non-Class IE application. Work began on June 27, 1990, using the incorrect print and improper splice application.

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• OThat afternoon an NRC Inspector identified discrepancies during the splice l installation concerning use of E1317, Sheet 6E. Nuclear Quality Assurance a Technical Monitoring personnel at the job scene also initiated an immediate investigai. ion into the deficiencies. This situation was communicated tn '

Supervision and Maintenance Engineering. On June 29, 1990 Maintenance  :

-Engineering and the craftsman involved reviewed alternative splice methods. I that could be used on the air start solenoid valve. An appropriate _ splice. kit detailed on Sheet 82 and 84 of E1317. Revision 54, was found acceptable and 1 the splice was completed that day. J Corrective Actions Taken and Results Achieved

The' incident was discussed with the individuals involved and a letter re-  !

emphasizing the verification of the correct drawing revision prior to use was ^

distributed to maintenance foremen. A review of other diesel generator work packages was. initiated to verify proper splicing techniques. An improper l splice on the E3 DG standby-lube oil circulation pump motor was discovered,- i and was properly re-installed during the E3 Diesel Outage.-

An investigation was also performed evaluating the proper usage of E1317'in other work applications. Approximately 100 work packages that had the

• potential of containing splicing requirements were investigated. The work packages contained a variety of components and equipment that consisteo of-  ;

both Class IE and non-Class IE detail requirements. The result of this  ;

investigation identified no similar problems with the usage of specification 1 E1317.

A training session on Administrative procedure A-2, " Procedure and Technical Specification Control," Administrative procedure A-6, " Drawing Control," and specification E1317 was given to appropriate Maintenance / Instrumentation &

Control foremen and planners. This information was then provided to individuals of each maintenance team to heighten their awareness in the proper ,

l use of controlled prints and requirements of using only approved splicing; techniques; Corrective Steps That Will Be Taken To Avoid Further Violations Training will be provided for Maintenance /I&C, Nuclear Maintenance Division 1 t' 'and Planning _ personnel in the requirements of E1317. A-6 and A-2. i l- Furthermore, this training module will be incorporated into the continuing _ -l L ~ training' cycle. The initial training will be completed by December 31. 1990. 'l An evaluation will be performed on splice installation and the use of _

i controlled procedures and drawings after the initial procedure training has s been; completed. This evaluation will be performed by Maintenance /I&C with the I assistance of. Nuclear Quality Assurance. l

, ' Revisions to M521.202, " Procedures for Insulating and Environmentally Sealing '

H 600 Volt Cable Splices on Nuclear Safety Related Systems Class IE and Non-Class _IE"-and IC-11-00341, " Removal and Reinstallation of Plant-Equipment" L^ will.be made to fully address the splicing options within the E1317 L

' .[ specification. This will be completed by October 31, 1990. 1 L

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-. .i:M Sit'e When Full'Compiiance Will Be Achieved.- l u

.t Full compliance was achieved on' June 29,' 1990 when electrical' splices on'the "

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E3 emergency diesel generator air. start solenoid = valves were completed lfor'

.- Class'IEiapplication per specification E1317.-Sheets 82:and 84, Revision 54. j .

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