ML20206E385

Responds to NRC Re Violations Noted in Insp Repts 50-277/88-17 & 50-278/88-17.Corrective Actions:Work Instructions Revised to Include Removal of Heat Shields & Exhaust Manifolds

ML20206E385
Person / Time
Site:	Peach Bottom
Issue date:	11/10/1988
From:	Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8811180066
Download: ML20206E385 (9)

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' D. M. Smith PHILADELPHIA ELECTRIC COMPANY PEACl! BOTIDM ATOMIC PO4TR STATION R. D.1, Box 208 Delta, Pennsyhania 17314 (717)456 7014 Vice President November 10, 1988 Docktt Nos. 50-277

. 50-278 Mr. Thomas T. Martin, Director Division of Reactor Safety Region I U.S. Nuclear Regulatory Commission ATTH: Document Control Desk Washington, D.C. 20555

SUBJECT:

Peach Bottom Atomic Power Station Response to Combined Inspection Report Hos. 50-277/88-17; 50-278/88-17

Dear Mr. Martin:

This is in response to your letter dated October 11, 1988 which transmitted Peach Bottom Inspection Report Hos. 50-277/88-17; 50-278/88-17.

This report concerned the special maintenance team inspection of July 11 - 22, 1988. Appendix A of your letter described four items which did not appear to be in compliance with NRC requirements. The attachment to this letter provides a restatement of these items, and provides Philadelphia Electric Company's respor,se.

If you have any questions or require additional information, please do not hesitate to contact us.

Very truly yours.

Attachment cc: Addressee W. T. Russell, Administrator, Region I. USNRC T. P. Johnson, USNRC Senior Resident inspector T. E. Hagette, State of Maryland J. Urban, Delmarva Power J. T. Boettger, Public Service Electric & Gas H. C. Schwemm Atlantic Electric ggol seii180066 881110 7 ADOCK 05CC 1 g

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TO: Mr. Thomas T. Martin Page 2 bec: C. A. McNeill, Jr. - S26-1 S. J. Kowdiski - S25-1 J. W. Gallagher - S25-1 E. P. Fogarty - S7-1 E. J. Bradley - 523-1

0. R. Helwig - S7-1 J. F. Franz - PB C. J. McDermott - S13-1 G. F. Daebeler - PB T. E. Cribbe - PB A. R. Marie - N2-1 G. A. Zaimis - N4-1 W. M. Alden/FDL - S7-1 J. T. Robh/ISEO 1 J. A. Basilio - S10-1 Commitment Coordinator DAC L

- Attachment Page 1 of 7 ,

, , Docket Noso 50-277 50-278 RESPONSE TO NOTICE OF VIOLATION RESTATEMENT OF VIOLATION 1 ,

The PBAPS Technical Specification in Paragraph 6.8.1 requires that written procedures be implemented in accordance with Section 5.1 and 5.3 of ANSI N18.7-1972. Part 5.1.6.1 of ANSI N18.7 requires that maintenance shall be performed in accordance with written procedures appropriate to the circumstances.

Contrary to the above, the required preparatory work for hydrostatic testing of the E-2 emergency diesel generator water jacket such as removal of heat shields and exhaust manifolds was performed without written procedures.

Although a procedure did exist for this work, it was not referenced in the work package and it was not being used.

This is a level V Violation (Supplement 1).

RESPONSE TO VI0I.ATION 1 Admission or Denial of the Allened Violation:

Philadelphia Electric Company acknowledges the violation.

Reason for the Violation:

The work instructions which were specified on the Maintenance Request Forn, t (MRF) for the leak test were a more detailed version of the leak test portion of M52.2, "Diesel Engine Maintenance". The cause for M52.2 not being referenced on the MRF is believed to be an isolated case due to personnel error. The M52.2 was referenced on the overall Annual Diesel Maintenance MRF which was subsequently issued and performed. {

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Corrective Steps Which Have Been Taken and the Results Achieved: >

l The work instructions were revised to mclude the removal of the heat shields and exhaust manifolds which avoids confusion in referencing both M52.2 and the work instruction on fJture leak test specific MRFs. The responsible maintenance engineer was counseled on the importance of including required

• references to procedures in the MRF. Maintenance procedure M52.2 was revised to include the leak test detailed instructions so that maintenance on the Diesel Generators during annual inspections will be performed using one procedure.

Corrective Steps Which will be Taken to Avoid further Violations:

]

No additional corrective actions are required.

L 1 l~ Attachment

, , Page 2 of 7

- Docket Nos. 50-277 50-278 Date When Full Compliance will be Achieved:

Full compliance was achieved on 07/28/88 with the revision to the work instructions. ,

RESTATEMENT Of V10LAT101 2 The PBAPS Technical Specification in Paragraph 6.8.1 requires that written procedures be established and implemented in accordance with Section 5.3 of ANSI N18.7-1972. Part 5.3.6 of ANSI N18.7 requires that procedures be provided for' periodic calibration of safety related plant instrumentation.

Contrary to the above, tne E-2 emergency diesel generator water jacket discharge pressure gauge was found to not be calibrated. Furthermore, hydro testing of the E-2 water jacket was performed using this gauge (PI-05678).

There was no objective evidence that the gauge had been calibrated since the original installation.

This is a Level V Violation (Supplemcnt 1)

RESPONSE TO VIOLATION 2 Admission or Denial of the Alleged Violation:

Philadelphia Electric Company acknowledges the violation.

Reason for the Violation:

In the PBAPS Unit 2 and Unit 3 Q list, PI-0567B is listed as "Q" passive. The Pressure Indicator is passively "Q" because it is a system pressure boundary.

The pressure indication function of PI-05678 is listed as Non-Q (not safety related). Because the indication function of the Pressure Indicator is not safety-related, periodic calibration required by ANSI 18.7 section 5.3.6 does not apply to this instrument. However, since the guage was being used as a piece of test equipment it should have been calibrated. The E-2 water jacket testing was performed without a calibrated gauge because the work instructions preparer erroneously assumed that PI-05678 was a calibrated gauge. It is

, believed that the omission of PI-0567A-D from the routine calibration list, while other Diesel-Generator instruments are on the routine calibration list, is the root cause of the error.

Corrective Steps Which Have Been Taken and the Results Achieved:

Following the jacket coolant system leak test, PI-05678 was calibrated and found to be within its calibration tolerance. This confirms that the test was performed at the proper pressure. PI-0567A-D were added to the routine calibration list with the other diesel generator instruments. Also, PI-0567A, C and 0 were calibrated. The jacket coolant pressure test instructions have been revised to include use of PI-0567A-D and another calibrated pressure

Attachment

, , Page.3 of 7 Docket Nos. 50-277 50-279 t

gauge to accurately verity the test pressure. ..This will ensure the adequacy f of the leak test 1 pressure.

Corrective' Steps Which 'lli be Taken to Avoid Further Violations:

. No additional corrective actions are required. ,

h- Date When Full Compliance will be Achieved:

Full compliance was achieved on 07/21/88 with the calibration of PI-05678 verifying the leak test was valid.  ;

3 RESTATEMENT OF VIOLATION 3 10 CFR 50, Appendix 8 Criterion VII, as implemented by PBAPS Quality Assurance Plan, requires that contracted services shall conform to the procurement documents. The purchase order for drywell cooler maintenance J required use of the MRF system to control work.

Contrary to the above, maintenance and inspections were performed on all six drywell chillers for several years by a contractor, Hull-Trane Company,  !

Harrisburg, PA, without use of the site work control process and without ,

direct knowledge of the maintenance department.

This is a Level V Violation (Supplement 1).

RESPONSE TO VIOLATION 3 Admission or Denial of the Alleged Violation:

Philadelphia Electric Company acknowledges the violation.

Reason for the 91olation:

The Hull-Trane Company was contracted to perform maintenance on the non-safety related drywell chillers. Although the contract stated that the Hull-Trane representative report to the maintenance field representative, this did not occur for work not requiring a blocking permit. The cause was that the i representative did not clearly understand that all work performed required a l Maintenance Request Form (MRF). In addition, the cognizant plant staff was  ;

not fully aware of all the details of the contract concerning work control and i allowed this condition to continue. The work control requirement was originally generated in 1975. Btcause cf the age of the original work control i requirement and the misunderstanjing of the contract by the contractor, this  ;

is not felt to be a generic proSitm.

Corrective Steps Which Have Been Ttken end the Results Achieved:

The Hull-Trane representative has been counseled that he shall report to the '

Maintenance Shift Assistant Foreman orior to beginning work per the revised contract. The Maintenance Shift Ass'stant Foreman is now responsible per the i i

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Attachment Page 4 of 7 Docket Nos. 50-277 50-278 revised contract to issue the work control documents to the representative for work performed by Hull-Trane.

The Maintenance cognizant staff and Hull-Trane are now aware of the work control requirements for Hull-Trane. ,

Corrective Steps Which will be Taken to Avoid Further Violations:

No additional corrective actions are necessary.  ;

Date When Full Compliance will be Achieved:

, Full compliance was achieved with the counseling of the Hull-Trane representative on PBAPS requirements for peiJarming work.

l RESTATEMENT OF VIOLATION 4 10 CFR 50, Appendix B, Criterion Xill, requires storage measures which prevent deterioration of materials and equipment. 10 CFR 50, Appendix B, Criterion XV, requires measures, such as identification, documentation, segregation and disposition, to prevent the inadvertent use of nonconforming materials, parts t and components. ~

Contrary to the above, certain measures utilized by the licensee did not  !

assure storage of equipment to prevent deterioration; and did not assure  !

proper identification, documentation and segregatior of nonconforming stored '

parts and components, as indicated by the following uamples:

a. Contrary to procedure 80A-5 (sic) Revision 6, safety related and not safety related items were stored together in a staging cage.

b. The shelf life log used to identify items with expiring shelf lives was incomplete in that certain safety related items including codes, 115-73900, 115-40315 and 116-01282 were not included.  ;

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c. A Standby Liquid Control Explosive Valve (SLCEV) with an expired shelf l life had not been replaced or identified for proper disposition.  ;

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d. The manufacturer's recommended storage temperature of SLCEV repair kits is i 70 +/- 20 F. Storage temperatures of 5-10 F over this range were observed. ,

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e. For Code 115-40315 Vendor Order 320-73186-380, the vendor recommends a 2  !

] year shelf life whereas the licensee identified the shelf life as 5 years.

j This is a level V Violation (Supplement 1).  !

c

Attachment Page 5 of 7 Docket Nos. 50-277 50-278 RESPONSE TO ITEM A 0F VIOLATICH 4 Admission or Ocnial of the Alleged-Violation:

Philadelphia Electric Company denies item a of the violation for the following reason:

Violation 4a of the referenced NRC Inspection Report states that safety related and non-safety related items were stored together in a maintenance staging cage contrary to SDA-5, Revision 6 "Stores Division Administrative Procedure for Storage Packaging and Shipping of Items for Nuclear Power Plants". The referenced procedure SDA-5 Revision 6 applies only to items i stored in the storeroom prior to being issued to Maintenance. The "Q" components in this locked cage had been issued to Maintenance and identified  !

with orange Quality Control tags in accordance with A-27, "Procedure for Material Control-System".

10 CFR 50, Appendix 8, Criterion XV applies to components which do not conform to requirements. The stored components were not non-conforming components as defined in 10 CFR 50, Appendix B, Criterion XV.

RESPONSE TO ITEM B, C AND E OF VIOLATION 4 Admission or Denial of the Alleged Violation: i Philadelphia Electric Company acknowledges items b, c and e of the violation, ,

Reason for the Violation:

1. Shelf life items were not dispositioned when shelf lives became overdue because the shelf life log was incomplete due to a breakdown in  !

communication between the warehouse rece'.ver and the office shelf life log keeper. The cause of this was due to a lack of strict programmatic control of the form. The required shelf life form was not fully tracked for entry into the shelf life log.

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2. The shelf life for Code 115-40315 was inadvertently indicated as 5 years i on the Quality Control Tag due to a personnel error when transcribing i information from the manufacturers requisition to the PEC0 Quality Control Tag. The error resulted in two different shelf life dates on the Quality Control Tag and there was no entry into the shelf life log.

, Corrective Steps Which Have Been Taken and the Results Achieved:

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1. The corrective action to properly disposition shelf life items omitted from the log was already underway. The following corrective steps have been taken:

a. Warehouse employees were given counseling and additional training on the use of the shelf life form.

Attachment Page 6 of 7 Docket Nos. 50-277 50-278 l

b. A physical verification of shelf life items were performed to verify the shelf life log against storeroom material. Discrepancies were identified and added to-the log. Items with expired shelf lives were removed.

c. Non-conforming code item 115-40315 was removed from stock and the individual who erroneously entered the wrong shelf lifa date on the '

Quality Control Tag was counseled.

d. The Personal Computer Trar. king process used by the storeroom has been revisad to identify items with a she'If life that expires within 90 f days to fccilitate restocking of items prior to shelf life expiration.

Corrective Steps Which will be Taken to Avoid Further Violations:

a. Programmatic controls will be implemented on the corporate co:nputer system by July 1989 to control the receipt process to ensure shelf l life requirements are met. Shelf life information will be entered into the data base at the time of receipt. This will eliminate the  ;

need for control of the shelf life form.

Date When Full Compliance will be Achieved:  !

Full compliance was achieved 8/16/88, with removal of items from stock with expired shelf lives. .

i RESPONSE TO ITEM 0 0F VIOLATION 4 Admission or Denial of the Alleged Violation:

i

! Philadelphia Electric Company acknowledges item d of the violation.  !

Reason for the Violation: i Storage temperatures out of the recommended range were caused by the failure of the air conditioning system and lack of appropriate Pnvironmental

, verification.  ;

Corrective Steps Which Have Been Taken and the Results Achieved:

Corrective action for exceeding the allowable storage temperate e was to expedite repair and service of the air conditioner. The unit was repaired and placed back in service the first week in August. The affected SLCEV repair kits have been removed from stock.

Corrective Steps Which will be Taken to Avoid further Violations:

The Materials / Warehouse Procedures will be revised by 12/31/88 to include verifying the Environmental Area is monitored at least once per day. An assessment will be perforr..td on a sampling basis of potential impact on other 2

environmentally susceptible components. This will be completed by 12/02/88.  ;

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• '3 Attachment Page 7 of 7 Docket Nos. 50-277 50-278 Date When Full Compliance will be Achieved:

Full compliance was achieved 7/21/88 when the SLCEV repair kits were removed from stock.