ML20207L386

Notice of Violation from Insp on 880711-22.Violations Noted: Required Preparatory Work for Hydrostatic Testing of E-2 Emergency Diesel Generator Water Jacket,Such as Removal of Heat Shields,Performed W/O Written Procedures

ML20207L386
Person / Time
Site:	Peach Bottom
Issue date:	10/11/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207L383	List: IR 05000277/1988017 ML20207L378 ML20207L386
References
50-277-88-17, 50-278-88-17, NUDOCS 8810170280
Download: ML20207L386 (2)

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APPENDI.X_A NOTICE OF VIOLATION 1

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Philidelphia Electric Company Docket Nos.

50-277 l

Philadelphia, Pennsylvania 50-278 License Nos. OPP.-44 1

As a result of the team inspection conducted on July 11 - 22, 1988, at the j

Peach Bottom Atomic Power Station, Unit 2, and in accordance with the NRC L

Enforcement Policy (10 CFR 2, Appendix C), the following violations were l

j identified:

I 1.

The PBAPS Tschnical Specification in Paragraph 6.8.1 requires that i

j written procedures be implemented in accordance with Sections 5.1 l

j and 5.3 of ANSI N18.7-1972.

Part 5.1.6.1 of ANSI N18.7 requires l

j that maintenance shall be performed in accordance with written j

procedures appropriate to the circumsta.1ces.

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Contrary to the above, the required preparatory work for hydrostatic testing of the E-2 emergency diesel generator water jacket such as I

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.

1 This is a Level V Violation (Supplement 1).

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 l

related plant instrumentation, j

Contrary to the above, the 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

.A using this gauge (PI-05678). There was no objective evidence that i

1 the gauge had been calibrated since the original installation.

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This is a level V Violation (Supplement 1),

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10 CFR 50, Appendix B, Criterton VII, as implemented by PBAPS i

Quality Assurance Plan, requires that contracted services shall

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conform to the procure tent documents.

The purchase order for j

drywell cooler maintenance required use of the MRF sytem to control work.

1 0010170200 881011 PDR ADOCK 0$000277 O

PW 0FFICIAL RECORD COPY IR PB 88 0004.0.0 3

11/29/80 l

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Appendix A.

Contrary to the above, maintenance and inspectiets were performed on all six drywell chillers for several years by a contractor, Hall-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).

4.

10 CFR 50, Appendix B, Criterion XI!!, 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 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 segregation of nonconforming stored parts and components, as indicated by the following examples:

a.

Contrary to procedure 80A-5 Revision 6 safety related and not safety related items were stored together in a stagging cage, b.

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

included, c.

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

The manufacturer's recommended storage temperature of SLCEV repair Lits is 70 1 20'F, Storage temperatures of 5 - 10'F over this range were observed, e.

For Code 115-40315, Vendor Order 320-73186-380, the vendor recommends a 2 year shelf life whereas the licensee identified the shelf itfe as 5 years.

This is a level V Violation (supplement 1).

Pursuant to the provisions of 10 CFR 20.201, Philadelphia Electric Company is hereby required to submit to this Office within 30 cays of the date of the letter transmitting this Notice, a written statement or explanation in reply including for each violation:

(1) t.he reason for the violations if aditted; (2) the corrective steps which have been taken and the results achieved; (3) the corrective steps which will be taken to avoid further violations; and, (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

OFFICIAL RECORD COPY IR PB 88 0004.1.0 11/29/80