ML20079C884
| ML20079C884 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/11/1991 |
| From: | Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CCN-91-14095, NUDOCS 9106260260 | |
| Download: ML20079C884 (4) | |
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9-IdCN'91-14D95-PIIILADELPHIA ELECTRIC COMPANY n
- PEACll 11Ur10M A1DMIC PO4TR 51ATION N
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R. D.1, Box 208 Win t Delta, Itnrnylvania 17314
- esacu mornw-ties you aa or asutarNo (717) 4 6-7014 D, B. Miller, Jr.
June 21, 1991
- Vice President Docket Nos. 50-277 50-278 U. S.JNuclear 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 (CombinedInspectionRepo't-Nos. 50-2791-14;50-578/91-14) r Ocar Sir:
In response to your letter dated May 23, 1991, which transmitted the" Notice of. Violation in the referenced inspection report, we submit the o'
attached response. The subject 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, S
Jcc:
R. A. Burricelli..Public Service Electric & Gas
-T.'M.LGerusky, Commonwealth of Pennsylvania J. J. Lyash, USNRC Senion Resident ~lnspector
-T. T.. Martin,-Administrator, Region I, USNRC H. C. Schwemm,. Atlantic Electric R. I. McLean, State of Maryland J. Urban Delmarva Power-9106260260 910611
.PDR ADOCK 05000277
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Document Control Desk l
Page 2 bcc. J. W. Austin A4-4N, Peach Bottom J. A. Basilio 52A-5, Chesterbrook G. J. Beck 52A-5, Chesterbrook J. A. Bernstein SIA-13, Chesterbrook R. N. Charles SlA-1, Chesterbrook Commitment Coordinator 52A-5, Chesterbrook Correspondence Control Progrom 61B-3, Chesterbrook J. B. Cotton 53A-1, Chesterbrook G. V. Cranston 638-5, Chesterbrook E. J. Cullen S23-1, Main Office A. D. Dycus A3-IS, Peach Bottom J. F. Franz A4-IS, Peach Bottom A. A. Fulvio A4-lS, Peach Bottom D. R. Helwig 51A-ll, Chesterbrook R. J. Lees, NRB 53A-1, Chesterbrook C. J. McDermott S13-1, Main Office D. B. 'Allier, Jr.
SMO-1, Peach Bottom PB Nuclear Records A4-25, Peach Bottom J. M. Pratt B-2-S, Peach Bottom J. 1. Robb SlA-13, Chesterbrook D. M. Smith 52C-7, Chesterbrook
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Document Control Desk Page 3-1 AllACHMEN1 Response ~to Notice of Violation 91-14-01/01 Restatement of the Violation 10CFR 50, Appendix 0. Criterion V, states, in part, that:
" Activities affecting quality shall be prescribed by documented instructions, procedures... and shall be accomplished in accordance with these instructions, procedures..."
Material Specification M-38A provided for. fiberglass piping insulation for the modification package no. 5046.
Licensee Procedure No. NEDP 3.8, Section 2.1.1, states, in part, that:
" Requests for authorization-to depart from referenced specifications l_
during the installation of a mod.fication 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, resulting in the use of materials that were not'specified in the modification package (5046).
This is a Level IV Violation (Supplement 1).
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.
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. 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 l
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.
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-Corrective Steps Taken and Results Achieved
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.A non-conformance report was generated on 4/5/91 to document the unapproved Rubatex insulation installation.
It was determined that the i
advantage of installing anti-sweat insulation was not significant and the insulation installed during the modification was removed by 4/8/91._ A corrective action report was also initiated on 4/5/91 to investigate and l
Document Control Desk Vane A prevent recurrence of installing material without engineering evaluation and approval.
On 4/b/91 a plant welkdown conf irmed that Rubatex and other similar insulation was used throughout the plant.
1he installations personnel involved in the event were informed of the significance of the event and (ounselled not to deviate from approved mod installation specifications without prior review and approval.
Corrective Steps Which Will be Token to_ Avoid f urther Violations Appropriate installations personnel were informed of this event including the need to thoroughly understand the scope and applicability of design specificatior',c.J (5e requirement to obtain engineering approval prior to deviating t u in', tali tion instructions.
s An engineering review is in progres to determine the extent and possible effects of installed Rubatex i t.sa :
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preliminarily, there appears to be no fire protection concerns ".. c.pect to 10 Cf R $0 Appendix R or combustible loading requiremenu.
The review will also consider electricel separation concerns rega' ding combustible material between safety related cable-trays and will determine the acceptabilits of using Rubatex,. including properties of its idhesive.
This review will be completed by 9/91.
Date When full Compliance Will Be Achieved Complience with the insulation specification for the subject mod work was achieved on 4/8/91 with the removal of the Rubatex insulation.
1he 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.
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