ML20059M656

Ack Receipt of Util Re Corrective Actions Taken in Response to Insp Repts 50-277/90-13 & 50-278/90-13

ML20059M656
Person / Time
Site:	Peach Bottom
Issue date:	09/22/1990
From:	Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 9010050152
Download: ML20059M656 (2)

See also: IR 05000277/1990013

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SEP 2 21990

Docket Nos. 50-277

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50-278

Philadelphia Electric Company

, ATTN: Mr. D. M. Smith

1 Senior Vice' President-Nuclear

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Nuclear Group Hene.uarters

Correspondence Control. Desk

P. O. Box 195

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Wayne, Pennsylvania 19087-0195

Gentlemen:

Subject: Combined Inspection No. 50-277/90-13; 50-278/90-13

This refers to your letter dated August 31, 1990, in response to our'lettert

dated July 30, 1990 regarding the Peach Bottom Atomic Power Station.

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. j

your licensed program.

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Your cooperation with us is appreciated. I

h Sincerely,

-Original Signed By: i

A. Randolph Blough, Chief .

Projects Branch No. 2 1

Division of Reactor' Project's '

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9010050152 900922 . Q i

PDR ADOCK 05000277 i

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0FFICIAL RECORD COPY RL 50-277/90-13 - 0001.0.0 .\

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09/21/90

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Philadelphia Electric Company- 2

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cc:

D. R. Helwig, Vice President, Nuclear' Engineering and' Services

R. J. Lees, . Chairman,- Nuclear. Review Board

D. B. Miller, Vice President, Peach Bottom Atomic Power Station

J . Urban, General Manager, Fuels Department, Delmarva Power & Light Co.

J. F. Franz, Plant Manager, Peach Bottom Atomic Power Station-

A. A. Fulvio, Regulatory Engineer, Peach Bottom Atomic Power Station

E. P.'Fogarty, Project-Manager, Peach Bottom Atomic Power Station ,

T. B. Conner,, Jr. , Esquire

W. H. Hirst', Director, Joint Generation Projects Department,

Atlantic Electric

B. W. Gorman, Manager, External Affairs 1

E. J. Cullen, Esquire, Assistant General Counsel (Without Report) .;

R. L. Hovis, Esquire 1

R. McLean,' Power Plant Siting, Nu'elear Evaluations

G. Hunger, Manager, Licensing Section-

D. Poulsen, Secretary of Harford-County Council j

J. H. Walter, Chief' Engineer, Public Service commission of Maryland Li

Public Document Room (PDR) (with copy of licensee's response) 1

Local Public Document Room (LPDR)(with copy of-licensee's response) .j

Nuclear Safety Information Center (NSIC)(with copy of licensee'soresponse)- i

NRC Resident Inspector (with copy of licensee's response) ,

Commonwealth of Pennsylvania (with copy of licensee's response)  !

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0FFICIAL RECORD COPY RL 50-277/90-13 - 0002.0.0

09/18/90

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Philadelphia Electric Company 3'

SEP '2 21990

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bec: (with copy of licensee's response)

Region I Docket Room (with concurrences)

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Management Assistant, DRMA-(w/o encl)

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R. Bellamy, DRSS

DRP Section Chief

R. Blough, DRP

P. Kaufman, DRP

L. - D' x ' lein, DRP

M. Coaner, SALP Reports Only

K. Abraham, PA0 (20) SALP Report and (2) All Inspection Reports

M. Miller, SLO

J. Caldwell, EDO

G. Suh,~NRR-

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W, Kane, DRP

J. Wiggins, DRP

W. Hodges, DRS

J. Durr, DRS l

R. Gallo, DRS

M. Knapp, DRSS

J. Lyash, SRI-Peach Bottom

T. Kenny, SRI-Limerick

B. Norris, PI - Shoreham

W. Butler, NRR

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RI:DRP -

RI:DRP .

ys gcb oerflein Glough ,

19/'t 90 09 4\ /90 09/)2490

0FFICIAL RECORD COPY RL 50-277/90-13 - 0003.0.0

09/18/90

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CCN 90'14163 '

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Psaca sorrou-me rowan or ascru1NCs

D. B. Miller, Jr.

PHILADELPHIA ELECTRIC COMPANY

PEACH BOrlDM ATOMIC POWER STATION

R. D. '1, Box 208 ~

Delta, Pennsyhania 17314

(717) 456-7014

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l Vice President

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August 31, 1990 i

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Docket Nos. 50-277 1

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50-278- l

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U. S. Nuclear Regulatory Commission

ATTH: . Document ~ Control Desk

Washington, DC 20555i

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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)

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Dear Sir:

l In response to your letter dated July 30; 1990 which transmitted the

subject. Inspection Report and Notice of Violation, we submit the. attached.-

response. The subject Inspection Report concerns.a routine resident safety

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inspection during'the period May 16 through July 2, 1990. ,

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If you have any questions or require additional information, please'do not. 'i

hesitate to contact us.

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Sincerely, j

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Attachment

cc: R. A. Burricelli,-Public Service Electric & Gas'  !

T. M. Gerusky, Comonwealth of Pennsylvania

J. J. Lyash, USNRC Senior Resident Inspector

T. T. Martin, Administrator, Region I USNRC

H. C. Schwemm Atlantic Electric

R. I. McLean, State of Maryland  ;

J. Urban, Delmarva Power i

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Attachment ,

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Response to Notice of Violation 90-13-02- t

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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 tc 'issure that they are

used at the location where the prescribed activity lIs jerformed. >

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

documents the licensee's Appendix B program. QAP Section MEM 2.2.3, states  ;

maintenance that may affect functioning of safety-related systems or

components shall be performed in a manner to assure compliance with specified

design requirements. Section HEM 6.2 states.that personnel. participating in

the maintenance activity shall use current drawings for performing the

activity.

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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 revisicn.  ;

This is a Severity Level IV violation-(Supplement I).

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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.

l and 72 of E1317 " Wire & Cable - Notes & Details, Power, Control &

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 s'rk package was changed by the maintenance planner without

engineering review or approval to allow use of a non-Class IE splice design

for Class IE application. Upon further review the craftsman requested an

additional change, which the planner agreed to oecause 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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That afternoon an NRC Inspector identified discrepancies during the splice

installation concerning use of E1317, Sheet 6E. Nuclear Quality Assurance

Technical Monitoring personnel at the job scene also initiated an immediate.

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-investigation into the deficiencies. This situation was communicated to,

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

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the splice was completed that day.

Corrective Actions Taken and Results Achieved I

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

l- 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

splice on the E3 DG standby lube oil circulation pump motor was discovered, i

and was properly re-installed during the E3 Diesel Outage.

y An investigation was also performed evaluating the proper usage of E1317 in

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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 consisted of

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

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investigation identified no similar problems with the usage of. specification

E1317.

A training session on Administrative procedure A-2, " Procedure and Technical

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Specification Control," Administrative procedure A-6,.'" Drawing Control," and  ;

l specification E1317 was given to appropriate Maintenance / Instrumentation &

i Control foremen and planners. This.information was then provided to

l 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.

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Corrective Steps That Will Be Taken To Avoid Further Violations

Training will be provided for Maintenance /l&C, Nuclear Maintenance Division

and Planning personnel in the requirements of E1317, A-6 and A-2.

Furthermore, this training module will be incorporated into the' continuing

training cycle. The initial training will be completed by December 31 1990.

An evaluation will be performed on splice installation and the use of

controlled procedures and drawings after the initial procedure training has -l

been completed. This evaluation will be performed by Maintenance /I&C with the'

assistance of Nuclear Quality Assurance.

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

600 Volt Caole Splices on Nuclear Safety Related Systems, Class IE and Non-

Class IE" and IC-11-00341, " Removal and Reinstallation of Plant Equipment"

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will be made to fully address the splicing options within the E1317

specification. This will be completed by October 31, 1990.

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Date When Full Compliance Will Be Achieved- '

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,. iFull compliance was. achieved ontJune 29 1990 when electrical splices on the- '

E3 emergency diesel generator air start solenoid valves were completed-for .

Class IE application per specification'E1317, Sheets 82 and 84, Revision 54. '

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