ML20127L822

Notice of Violation from Insp on 921019-23 & 921130. Violation Noted:Licensee Measures Established for Assurance of Quality Inadequate or Untimely as Evidenced by Listed Examples

ML20127L822
Person / Time
Site:	Peach Bottom
Issue date:	01/21/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127L818	List: IR 05000277/1992082 ML20127L814 ML20127L822
References
50-277-92-82, 50-278-92-82, NUDOCS 9301280019
Download: ML20127L822 (3)

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APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company Docket Nos, 50-277, 50-278 Peach Bottom Atomic Power Station License No. DPR-44, DPR-56 As a result of the inspection conducted from October 19 through November 30,1992, and in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the following violations were identified:

10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions," states, in part, that ...

" Measures shall be established to assure that conditions adverse to quality, such as ...

nonconformances ... are promptly identified and corrected."

The Philadelphia Electric Company Nuclear Quality Assurance Plan, General Program-section PR 16.0, Corrective Action, requires, in part, that measures be established to assure that conditions adverse to quality are promptly corrected and that ... safety-related equipment nonconformances are controlled.

Contrary to the above, as of October 23,1992, the licensee's measures established for the assurance of quality were inadequate or untimely as evidenced by the following examples.

1. The following represent examples where no documentation of nonconforming conditions was recorded:

a. Reactor water cleanup (RWCU) loop isolation valve 2-12-018 experienced an over-thrust condition at 286% in March 1992. The actuator was replaced and the new actuator's as-left thrust also exceeded the vendor's nominal thrust rating by 150%. Neither the original nor the as-left over-thrust conditions were documented or evaluated through a formal nonconformance report (NCR). _ Also, no documentation or evaluation was performed to consider if the original over-thrust condition exceeded the rating of other related compo-nents (such as valve internals). The licensee did not establish a basis for accepting the replacement actuator in the as-left over-thrust condition,

b. Reactor core isolation cooling (RCIC) system minimum flow valve 3-13-027 was left in an over-thrust condition at 161% on October 17,1991. The licensee did not initiate an NCR to document and evaluate the nonconforming condition.

9301280019 930121 PDR G ADOCK 05000277 PDR

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! Appendix A 2 II. The following represent examples where documented nonconforming conditions were inappropriately resolved:

a. The as-found under-thrust condition and the as-left over-torque condition for MOV 3-12-015 (documented in NCR 92-00001) was not properly resolved because: 1) The torque switch was set at approximately 116% of the actuator torque rating without an engineering evaluation as specified by the manufacturer; and 2) The licensee relied on a commercial actuator rating instead of the manufacturer's published nuclear actuator rating to disposition this concern without an engineering evaluation.

b. An over-thrust condition experienced by MOV 2-12-015 (documented in NCR 92-00111) was not properly resolved because: 1) The licensee considered 200% of the actuator's thrust rating acceptable based on a study by a contractor on the capability of MOV actuators to withstand thrust greater than the manufacturer's published ratings. The actuator thrust of 200% exceeded the maximum thrust allowable specified by the manufacturer (162%). The licensee did not perform an internal engineering evaluation when 162% of the actuator's rated thrust was exceeded; and 2) the NCR did not identify if the actuator torque ratings was also exceeded.

c. An under-thrust condition in MOV 3-23-015 in the closing direction (documented in NCR 92-00582) was not properly resolved. The resolution of this NCR did not incorporate conditions from the manufacturer when planning to raise the allowable thrust,

d. NCRs 92-00353 and 92-000395 provided final dispositions of over-thrust conditions where the actuators for MOVs 2-13-027 and 3-13-025 had potentially been subjected to 210% and 162% of their rated thrust respectively.

The licensee justified the acceptability of these over-thrust conditions without fully implementing vendor recommendations such as evaluating the actuator for potential over-torque problems.

III. The following represents an example of untimely corrective action:

a. On April 29,1992, torus cooling loop injection valve 2-10-34B failed to function properly. Subsequently, a surface crack was discovered and repaired in the valve yoke. After the companion RHR valves were inspected on August 7,1992, surface cracks were also found in the yoke of MOV 2-10-34A. The approximate five months taken to inspect valve 2-10-34A subsequent to identifying cracks in the 2-10-34B valve was untimely corrective action.

This is a Severity Level IV Violation (Supplement I).

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Appendix A 3 Pursuant to the provisions of 10 CFR 2.201, the Philadelphia Electric Company is hereby

' required to submit a written statement or explanation to the U.S. Nuclear Regulatory i Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the

< Regional Administrator, Region I, and a copy to the NRC Resident Inspector within 30 days of receipt of the letter transmitting this Notice of Violation. This reply should include:

(1) the reason for the violation, if admitted, or contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the

corrective steps that will be taken to avoid further violation, and (4) the date when full compliance will be achieved.

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