ML20077R479
| ML20077R479 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/21/1991 |
| From: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20077R476 | List: |
| References | |
| NUDOCS 9108230074 | |
| Download: ML20077R479 (4) | |
Text
{{#Wiki_filter:_ -. - _ e CCN 91-14095 @~~M1W PilILADEll' Illa ELECTRIC COMi%NY PEACll BOITONI ATON1lC POWl'R STATION / R D 1. Ikn 20M Delta, lYnnsy lvania l*31e rucu nornm-int ros r a or tuittsv i ('l")i Mi-UI4 D. B. Miller, Jr. June 21, 1991 %ce Preudent Docket Nos. 50-277 50-278 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 91-14-01/01 (Combined Inspection Report Nos. 50-277/91-14:50-578/91-14)
Dear Sir:
In response to your letter dated May 23, 1991, which transmitted the Notice of Violation in the referenced inspection report, we submit the attached response. The subjcct inspection report concerns an inspection on environmental qualification conducted April 1-5, 1991. If you have any questions or require additional information please do not hesitate to contact us. Sincerely 0 ( 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, Region I, USNRC H. C. Schwemm, Atlantic Electric R. 1. McLean, State of Maryland J. Urban, Delmarva Power 9108230074 910008 PDR ADOCK 05000277 O PDR
..~ -. - l j -Document Control Desk Page 2 i bcc: J. W. Austin A4-4N, Peach Bottom J. A. Basilio 52A-5, Chesterbrook -G. J.' Beck 52A-5, Chesterbrook J. A. Bernstein SlA-13, Chesterbrock-3 R. N. Charles SIA-1, Chesterbrook Commitment Coordinator 52A-5, Chesterbrook Correspondence Control Program 618-3, Chesterbrook J. B. Cotton 53A'1, Chesterbrook G. V. Cranston 63B-5, Chesterbrook E..L Cullen 523-1, Main Office A. D. Dycus A3-lS, Peach Bottom J. f.-Franz A4-lS, Peach Bottom A. A. Fulvio A4-lS, Peach Bottom l
- 0. R. Helwig SlA-ll, Chesterbrook R. J. Lees NRB 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 8-2-S, Peach Bottom J. T. Robb 51A-13, Chesterbrook D. M. Smith 52C-7, Chesterbrook i l I [ } t i h F I i ? l T e I ? I [ h I i I
. ~ -.-..~ -- Q Occtiment' Control Desk- -Page, AllACHMENT _ Response to Notice of Violation 91-14-01/01 Restatement of the Violation '10CFR 50, Appendix B, Criterion V, states,.in part, that: " Activities affecting quality shall be prescribed by documented instructions, . proc.edur.es... and shall be accomplished _in accPdance with these instruct;ons, procedures..." Material Specification M-38A provided for fiberglass piping insulation for the modification package no. 5046. Licensee Procedure No. HEDP 3.8, Section 2.1.1, states, in part, that: " Requests for authorization to depart from referenced specifications during the installation of a modification shall be processed as an Engineering Review Request (ERR) using the Engineering Review Request Form (ERRF)." During the facility walkdown on April 3, 1991, the NRC inspector identified the' installation of combustible anti-sweat insulation on the emergency service water piping system. Contrary to the above procedures, the licensee failed to complete the required'ERRF, resu' ting in the use of materials that were not specified in the modification package (5046). .This is a Level.IV Violation (Supplement I). Reason for the Violation During performance of modification (mod) work on the Unit 2 Emergency Service Water (ESW) system, unapproved insulation (Rubatex) was installed on.small piping appendages such as clean-outs, caps, and plugs without prior engineering approval as required by procedure. The plant specifications called for these small appendages to remain uninsulated. Because of possible pipe-sweating that could create a housekeeping concern, the lead installation. engineer approved installation of Rubatex to minimize pipe sweat-as well as to prevent potential head-knocking injuries.-- The reason to install Rubatex was due to the assumption that Rubatex was an insulating material approved for plant use. Rubatex existed throughout the plant and was available in the storeroom, Corrective Steps Taken and Results Achieved A non-conformance report was generated on 4/5/91 to document the unapproved Rubatex insulation installation. It was determined that the ~ advantage of installing ani.i-sweat insulation was not significant and the l insulation installed during the modification was removed by 4/8/91. i A corrective action report was also initiated on 4/5/91 to investigate and 1 l i p. 4 y ,m.__. y y...,, +
...v Document Control Desk
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1 prevent recurrence of installing material without engineering evaluation and approval, On 4/5/91 a plant walkdown confirmed that Rubatex and other similar insulation was used throughout the plant. l The installations personnel involved in the event were informed of the -{ significance of the event and counselled not to deviate from approved mod installation specifications without prior review and approval. ~i 9 .Corredtiv'e Steps Which Will be Taken to Avoid Fu__r_ther Violations ~ Appropriate installations personne! were informed of this event including the need to thoroughly understand the scope and applicability of design specifications and the requirement to obtain engineering approval prior to deviating from-installation instructions. An engineering review is in progress to determine the extent and possible effects of installed Rubatex insulation. Preliminarily, there appears to be no. fire protection concerns in respect to 10 CFR 50 Appendix R or combustible loading requirements. The review will also consider electrical separation concerns regarding combustible material between j safety related cable trays and will determine the acceptability of using i _Rubatex,-including properties of its. adhesive. This review will be completed by 9/91. Date When Full Compliance Will Be Achieved j Compliance with the insulation specification for the subject mod work was l achieved on 4/8/91 with the removallof the Rubatex insulation. The engineering review of accessible areas to be completed by 9/91 will determine if further corrective actions _are required. Inaccessible areas -will also be evaluated with appropriate corrective action being taken when access is permitted. l l l l l l D i-L i .}}