ML20127L814

Forwards Insp Rept 50-277/92-82 & 50-278/92-82 on 921019-23 & 921103 & Notice of Violation

ML20127L814
Person / Time
Site:	Peach Bottom
Issue date:	01/21/1993
From:	Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20127L818	List: IR 05000277/1992082 ML20127L814 ML20127L822
References
GL-89-10, NUDOCS 9301280018
Download: ML20127L814 (4)

See also: IR 05000277/1992082

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JAN 211993

Docket Nos. 50-277

50-278

Mr. D. M. Smith

Senior Vice President-Nuclear ;E

Philadelphia Electric Company

Nuclear Group Headquarters

Correspondence Control Desk

P. O. Box 195 -

Wayne, Pennsylvania 19087-0195

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Dear Mr. Smith:

SUBJECT: MOTOR-OPERATED VALVE (MOV) INSPECTION AT PEACH BOTTOM

ATOMIC POWER STATION (NRC INSPECTION REPORT NO.

50-277/92-82; 50-278/92-82)

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This letter refers to the NRC team inspection conducted on October 19-23 and 5

November 3,1992, at the Peach Bottom Atomic Powe. Station, to evaluate the adequacy of i

your actions developed in response to NRC Generic Letter 89-10, " Safety-Related  ;

Motor-Operated Valve Testing and Surveillance." This Generic Letter and its Supplements ,

provided recommendations to licensees to ensure operability of safety-related MOVs that i

perform vital functions in protecting public health and safety during postulated design-basis _

accidents. L

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Our inspectors observed that the implementation of your MOV program is progressing i

towards its scheduled completion by November 30,1994, for Unit 2 and November 30,

1995, for Unit 3 in accordance with the recommendations of Generic Letter 89-10. 3

However, the level of management control necessary to assure the proper disposition of 1

nonconforming conditions was not evident in some areas of the MOV program at Peach  ;

Bottom,

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Our inspectors identified multiple examples of nonconforming conditions in MOVs that were y

not documented and examples of nonconformance reports that were inadequately  ;

dispositioned involving over-th ust, over-torque, and under-thrust conditions in safety-related

MOVs. In addition, informal communications between site maintenance and nuclear  :

engineering groups allowed your established mechanism for documenting and maintaining 7

correct MOV switch settings to become out of date and not reliable for valid design-basis [

information. Several MOVs had questionable switch settings that were not appropriate for  ;

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9301280018 930121  ;

PDR ADOCK 05000277 i

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Mr. D. M. Smith 2

design-basis conditions. Consequently, several switch settings required resolution prior to

startup of Units 2 and 3. Our review concluded that your organization took appropriate and

prudent measures to .tssure that specific concerns identified during this inspection were

resolved prior to the startup of both units.

Based upon this inspection, it appears that several of your activities were not conducted in

full compliance with NRC requirement 1, as set forth in the Notice of Violation, enclosed ,

herewith as Appendix A.- Spaifically, this Notice of Violation addresses the fact that you

1) did not document nonconforming conditions,2) did not properly disposition existing

nonconforming conditions, and 3) did not take timely corrective actions to evaluate and

resolve nonconforming conditions in MOVs in your Generic Letter 89-10 program. Your

response to this notice should follow the instructions in Appendix A. In your response, we i

also request that you address the administrative controls within the corrective actions process

at Peach Bottom that were not effective in these cases and your proposed corrective measures

to prevent recurrences. The NRC is concerned about these conditions because multiple

examples may indicate programmatic deficiencies and because the lack of appropriate ,

corrective actions for nonconforming conditions in safety-related plant equipment can

potentially affect public health and safety.

We also request your attention to a concern related to your current GL 89-10 program

schedule which calls for completion of all testing in November 1994 for Unit 2 and

November 1995 for Unit 3. In light of the MOV family groupings proposed in your

program plan, some groups may not be justified after actual dynamic test results are

reviewed. If the test population must be significantly expanded, waiting until the fall of 1993

to start Unit 3 dynamic testing could jeopardize completion within the GL 89-10 schedule.

Although your GL 89-10 program test schedule was based on proposed test groups,

expansion of the test population is likely once actual dynamic test results are reviewed and

evaluated. We expect that your MOV testing will remain ahead of the planned schedule to

- ensure that all required testing is satisfactorily concluded within the scheduled program

completion dates.

The results of this inspection, as detailed in the enclosed report, were discussed during the

exit meeting held at the Peach Bottom Station on October 23,1992. At the exit meeting,

your staff acknowledged the inspection findings that three Unit 2 and two Unit 3 MOVs were

potentially inoperable and agreed to review the areas requiring clarification or improvement

to assure MOV operability before Units 2 and 3 returned to power operations. On

November 3 and 6,' 1992, your staff further clarified several of your intended actions and

commitments prior to Unit 3 startup. -On November 20,1992, the status of your objectives

and commitments were reviewed as summarized in Table I_of the enclosed report. The

overall inspection effort concluded on November 30,1992, in a telephone conference

between Mr. J. Durr of the Region I staff and Mr. D. Miller of PECo.

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JAN 211993

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Mr. D. M. Smith 3

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If your understanding of the actions to enhance the MOV program is different than

summarized in Table I, please notify me in writing as soon as possible.

Your cooperation with us in this matter is appreciated.

Sincerely,

Cridr.al Tcm Cy:

Marvin W. McJgs

Marvin W. Hodges, Director

Division of Reactor Safety

Enclosures:

1. Appendix A, Notice of Violation

2. Inspection Report No. 50-277/92-82; 50-278/92-82

cc w/ encl:

R. N. Charles, Chairman, Nuclear Review Board

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

G. Rainey, Vice President, Nuclear Services Department

G. Cranston, General Manager, Nuclear Engineering Division

C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.

K. P. Powers, Plant Manager, Peach Bottom Atomic Power Station

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

G. J. Beck, Jr., Manager, Licensing Section

J. W. Durham, Sr., Senior Vice President and General Counsel

J. A. Isabella, Director, Generation Projects Department,

, Atlantic Electric

B. W. Gorman, Manager, External Affairs

R. McLean, Power Plant Siting, Nuclear Evaluations

D. Poulsen, Secretary of Harford County Council

R. Ochs, Maryland Safe Energy Coalition

J. H. Walter, Chief Engineer, Public Service Commission of Maryland

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

K. Abraham, PAO (2)

NRC Resident Inspector

Commonwealth of Pennsylvania

TMI - Alert (TMIA)

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JAN 211993

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Mr. D. M. Smith 4

bec w/ encl:

Region I Docket Room (with concurrences and IFS Forms)

T. Martin, RA

M. Hodges, DRS

E. Wenzinger, DRP

C. Anderson, DRP

DRS/EB SALP Coordinator

V. McCree, OEDO

J. Shea, NRR

T. Scarborough, NRR

A. Gibson, Region II

T. Martin, Region III

S. Collins, Region IV

K. Perldns, Region V

bec w/ Letter and Executive Summary Only (and Enclosure 1 - to be used with an NOV)

C. Hehl, DRP

W. Lanning, DRS

C. Miller, PDI-2, NRR-

T. Kenny, SRI-Limerick

B. Norris, DRP

D. Holody, EO

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I:DRS RI:DRS RI:DRS

Drysdale Eapen

1:DQ

Durr ' Hod

1/ll/93 1/11/ 9 3

1//093 l#l/93

OFFICIAL RECORD COPY

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