ML20108B439
| ML20108B439 | |
| Person / Time | |
|---|---|
| Site: | Limerick, 05000356  |
| Issue date: | 02/26/1985 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| CON-#185-866 OL, QUAL-1-2-2, NUDOCS 8503070212 | |
| Download: ML20108B439 (3) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 23O1 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 JOHN S. KEMPER VICEPR ESID E NT February 26, 1985
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Mr. Thomas E. Murley, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406 Subj ect: USNRC IE Region I Letter dated January 25, 1985 RE:
Site Inspection of September 17 - 21, 1985 Inspection Report No. 50-352/84-53 Limerick Generating Station - Unit 1 File: QUAL l-2-2 (352/84-53)
Dear Mr. Murley:
In response to the subject letter regarding items identified during the subject inspection of construction activities authorized by NRC License No. CPPR-106, we transmit herewith the following:
Attachment I - Response to Appendix A Should you have any questions concerning these items, we would be pleased to discuss them with you.
Sincerely, JPE/drd/840621/2 Attachment Copy to: Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, DC 20555 J. Wiggins, USNRC Resident Inspector 8503070212 B50226
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RESPONSE 'IO APPENDIX A VIOIATICN As a result of the inspection conducted on Sept aber 17-21, 1984, and in accordance with the NBC Enforcement Policy (10 CFR 2, Appendix C), the following violation was identified (three examples):
I f
A.
10 CFR 50, Appendix B, Criterion V states, in part, that:
" Activities affecting quality shall be prescribed by documented instruction...and shall be accmplished in accordance with these instructions."
I 1)
Section 6.3, 3rd paragraph, Wire and Cable Notes and l
Details, No. E-1412, sheet 6.5, revision 9, states, in part, that:
"A minimum separation distance of 6 inches shall be maintained between class IE wiring.
Contrary to the above on Septmber 18, 1984, safety class IE, Divsiion I (Red) and Division III (blue) cables entering the bottcra of control panel 10C601 were identified as not meeting the separation requirments of E-1412.
2)
Section 5.13 of Conduct and Cable Tray Notes Symbols and Details, No.E-1406, sheet 5.2.1, revision 3, states, in part, that:
" Entrances for cable into the top of equiprnent frm cable trays shall be sealed for dust and debris.
Contrary to the above on September 18, 1984, cable entry ports in top of panel 10C601 were not sealed as required by E-1406.
3)
Section 5.3 of Administrative Procedure No. AD6.8.4 requires that an orange tag be used for field identification of t mporary modifications and that the tag contain necessary information to ensure verification and inspection of rm oval and restoration is controlled.
Contrary to the above, on Septmber 20, 1984 tm porary tags used to identify field wiring used for ccrmunication during testing did not contain necessary information to ensure verification or re aval and restoration of original configuration.
RESPONSE
The following corrective actions have been empleted.
1)
The wiring entering control rom panel 10C601 has been properly spaced and protected to meet the separation requirements. Also, the wiring entering through the floor openings of each of the other Unit 1 and ccmnon panels were inspected frcm both the top (control rom side) and the botta (cable spreading rom side) and reworked as necessary. It appears that the cause of the inadequate separation was the installation of the fire barrier sealing material. The fire seal installation took place after the inspections of the cable separation and the installation of the "daming" for the floor seals. The actual sealing activity was the cause of these cables moving slightly thereby violating the separation criteria.
For Unit 2,
another separation inspection 3521 8h-53 Page 1 of 2
3350538380 after the installation of the fire barrier sealing material will be added to prevent further occurances of this condition.
Provision for this inspection shall be established prior to the initiation of the penetration sealing program.
2.
It was the interpretation of dust seal requirement that the alarm cabinets mounted on top of the control rom cabinets served the purpose of preventing dust and debris frmt entering. However, it is agreed that a sepacate dust cover is a good. idea and the drawing E-1406 has been revised to show this cover.
Dust barriers have been installed on panel 10C601 and on the tops of the other Unit 1 and corrman control rom panels.
As a result of the cover now being a requirement on drawing E-1406 these same barriers will be installed on Unit 2 to prevent a recurrence of this.
3.
'Ihe tmporary ccumunication wiring identified and the balance of the temporary cormunication wiring used during the pre-operational testing has been removed.
'Ib prevent a recurrence,the individuals in the organization responsible for this temporary wiring have been trained in the controls for t mporary installations.
In addition to the temporary canunication wiring, other tenporary wiring has been installed to support the startup testing phase. An inspection and identification, rework or removal of this cable is expected to be cmpleted by June 1, 1985. Additional training has been accenplished to re-enforce the existing procedural and design requirements. 'Ibe need for a revision to the existing controls is being evaluated and will be cmpleted and inplemented sinultaneously with the empletion of the field work, June 1, 1985.
JK:/EFS 3521 84-53 Page 2 of 2
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