ML20235W373

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Ack Receipt of in Response to Violations Noted in Insp Repts 50-277/87-16 & 50-278/87-16
ML20235W373
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 10/05/1987
From: Johnston W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Gallagher J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8710160187
Download: ML20235W373 (1)


See also: IR 05000277/1987016

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                                                                                                                                     SCT o 51987                  1%fi 001 11 A D 00
     Docket Nos. 50-277                                                                                                                                                              3
                                                                                      50-278
      Philadelphia Electric Company
     ATTN:                         Mr. J. W. Gallagher
                                   Vice President
                                                        Nuclear Operations
      2301 Market Street
      Philadelphia, Pennsylvania 19101
     Gentlemen:
     Subject:                                                     Comb!ned Inspection Nos.                                       50-277/87-16 and 50-278/87-16
     This refers to your letter dated September 3,1987, in response to our letter
     dated August 6, 1987.
     Thank you for informing us of the corrective and preventive actions documented
      in your letter.                                                                                       These actions will be examined during a future inspection of
     your licensed program.
     Your cooperation with us is appreciated.
                                                                                                                                     Sincerely,
                                                                                                                                         Original Signed By:
                                                                                                                               /        Cliff ord J. Anderson
                                                                                                                                     William V. Johnston, Acting Director
                                                                                                                                     Division of Reactor Safety
     cc:
      Public Document Room (PDR)
     Nuclear Safety Information Center (NSIC)
     Commonwealth of Pennsylvania
     bec:
      Region I Docket Room (w/ concurrences)
                                                                                                    {                        cfG
      RI:DRS                                                                                           ')RI:DRS           RI:DRS
     Ve         a/pk                                                                                     Strosnider       Anderson                                 l}l g
      10/ / /87                                                                                          10// /87         10/f/87
                                                                                                                    0FFICIAL RECORD COPY         RL PB 87-16 - 0001.0.0
                                                                                                                                                 09/30/87
     8710160107 871005
     gDR             ADOCK 05000277
                                                                                                            PDR
                                                                                                                                                                                     J
                                                                                                   -_____
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                                        PHILADELPHIA A ELECTRIC COM PANY
                                                  2301 MARKET STREET
                                                      P.O. BO X 8699
                                                 PHILADELPHIA A. PA.19101
                                                       (215)841 4502
           Vacs rnsstDENT
       . .... m . ... ...=aa=-                            September 3, 1987
   >
                                                          Docket Nos. 50-277
                                                                         50-278
           'Mr. William V. Johnston, Acting Director
           Division of Reactor Safety
           Region I
           U.S. Nuclear Regulatory Commission
           ATTN:       Document Control Desk
           Washington, D.C. 20555
                 ' SUBJECT:         Response to Combined Inspection Report
                                    Nos. 50-277/87-16; 50-278/87-16
                               , ..                                        .n      -
          -Dear >Mr. Johnston::             .
                                                                            ve9        -
                                                                                                          Deat Mr. 9
                                            -                              ,  . a ; r .-      -

' < , Your' letter dated August 6, -1987, : transmitted _ Combined

            Inspection Report Nos. 50-277/87-16; 50-278/87-16 concerning the
           special' safety' inspection conducted June 16-19, 1987.                         Appendix A
           of your letter identified one activity which appeared to have not
           been conducted in full compliance with NRC requirements, as well
           as one unresolved item.
                          Attachment A of this letter provides restatements of
           these items, followed by the Philadelphia Electric Company
           responses.          If you have any questions or require additional
           information, please do not hesitate to contact us.
                                                                 Very truly yours,
                                                                        /             '
                                                                   . .-
                                                                     /
                                                                                         .
           Attachments
           cci       Addressee
                     W. T. Russell, Administrator, Region I, USNRC
                     T. P. Johnson, Resident Site Inspector
                   f                      $~     ff
 ,
   .4   . Oi
                                                                                                          Attachment A
                                                                                                           Page 1 of 3
      E                                                                                             Docket Nos. 50-277*  ,
                                                                                                                50-278
             Y

.. I. Restatement of Violation .

               - As a. result of the inspection conducted on June 16-19, 1987, and

L tin accordance<with-the " General Statement of Policy and Procedure

                for NRC Enforcement Actions,"'10 CPR Part 2, Appendix C
                 (Enforcement Policy)'(1986), the following violation was
               - identified:.                                                                                                       i
                          A. .  10 CFR 50, Appendix B, Criterion V requires that
                                activities affecting quality shall be prescribed by
                                documented. instructions, procedures, or drawings and
                                                                                   .
                                that they shall include appropriate quantitative or
                                qualitative acceptance criteria for determining that
                                important activities have.been satisfactorily                                                      !
                                accomplished. The licensee's Quality Assurance Program
                                incorporated 10 CFR 50, Appendix B prior to issuance of
                                Bulletin 80-11, Masonry Wall Design.

.yn, 4 > > ContrarystostheIbove,asofJuner19,h1987,awritten. c s w& vfi ? h ..ot J >

                           -
                                procedur.e cproviding the scope and zthe quantitative or: *y Mai: 3 w                             1

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                                qual,itative4 acceptance criteria was not documented for <- m i 'I m ' i
                                                                                                                              ~
                               Ethe 1980 walkdown survey of block walls performed in
                                response to NRC Bulletin 80-11.                               This lack of procedural
                                documentation prevented confirmation that all walls
                                whose failure could affect safety related equipment were
                                listed.
                                             ~
                                This is a Severity Level V violation (Supplement 1).
                                                                       Response to Violation
                Admission or Denial of Alleged Violation:
               ' Philadelphia Electric Company (PECo) acknowledges that the
                violation did occur as stated in the Notice of Violation.
                                                                                                                                   1
                Corrective Action Taken and Results Achieved:                                              .
                PECo Mechanical Engineering Division is developing a procedure
               which will provide the scope and criteria for the identification,
                survey and classification of all masonry walls. This procedure
                                 .
                                    . . . . . . . . . . . . . . . .         . .
                                                                                    . .
                                                                                          . .    ..
                                                                                                                  _.._____________j

_ - - _ _ - _ - - - _ _ - -

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                                                               -
    (,         .
                 '
                                                                                                              !
                                                                                    Attachment A-
                                                                                     Page 2 of 3
   o'                                                                        Docket Nos.-50-277*
                                                                                          50-278
'
                   will be
                        i completed by September 30, 1987 and will tua.used to
                    recheck the adequacy of all masonry walls.
  1
                    Corrective Action to be Taken to Avoid Future Non-Compliance:
                    Implementation of.the procedure discussed above will-avoid future
                    non-compliance.
                                       ~
                   1N) ensure continued compliance with' Bulletin 80-11, a procedure
                    for controlling additions or changes in'the configurations of
                    masonry walls will be approved and implemented by November 1,
                    1987.
                                                                                                              i
                    Date When Full Compliance Will be Achieved:
                    The implementation of a documented procedure which provides the
                   -scope and ' criteria cforr the didentif:icat-lonr . survey cand             -
                                                                                                    Le   "
                    classification' 'of umasonry Walls _will":assurencompliance with 10           tan
                    CPR 50, Appendix Bf' Criterion'Vras'itnappliescto. Bulletin 80-11. O'              -
                                                                                                           T
                    Full compliance will'be achieved upon implementation of this
                    procedure,: which is scheduled for September 30, 1987.
                    The identification,. classification and documentation of all walls
                    in' Unit 2 and common areas using the new procedure will be
                   -completed by November 1, 1987. In a supplementary letter to this
                    response, the NRC will be informed of the results of the Unit 2
                    and common action items upon completion.            The action items
                    affecting Unit 3 will be resolved before the Unit 3 restart.             The
                    NRC will be informed of the results of the Unit 3 action items

'

                    upon. completion.
                                                                                                              !
                    II.                    Restatement of Unresolved Item:
                   -It was found that several masonry-walls in the Reactor Building                           !
                    and the Emergency Cooling Tower had what appeared to be through                           ;
                    cracks at the boundary interface with reinforced concrete walls.                           3
                    The licensee's construction detail drawing (6280-S-246, Rev. 5)                          d
                    specified concrete expansion anchor bolts to provide a. positive                          d
                    connection at this type of boundary. The inspector was unable to
confirm the existence of positive connections through visual j

h observations or from the licensee's QC documentation. All of the l L noted crack locations were at wall boundaries where simply {

                    supported boundary conditions utilizing positive connections had                            I
                    been assumed in the reevaluation calculations. The postulated
                                                                                                               l
                                                                                                               I

c J

             .            . _ _ _         _
                                                                    _            ._   _ _ _ _                             . _ _ _ .
                                               '
        .G . ', .                  ._'           ,                                            _
                                                                                                                Attachment A
                                                                                                                 Page 3 of 3
                                                                                              Docket Nos. 50-277 *
                                                                                                                      50-278.          j
           4                                                                                                                          I
                                                                                                                                      i
                                     ' ,:                                                                                               [
                                            omission of the specified anchor bolts coupled with an apparent                         .

l through crack.would invalidate the reevaluation. calculations and ) l: raises questions regarding the licensee's conclusion that the

                                            walls are structurally adequate.
                                            The licensee was requested to provide additional information
                                            describing their. resolutions and a proposed schedule for actions.
                                            This item is unresolved pending licensee's submittal and NRC                                l
                                            review of the additional information described above (50-277/87-                            l
                                            16-02 and 50-278/87-16-02).                                                               ]
                                                                                                                                    .J
                                                                 Response to Unresolved Item:
                                                                                                                                      <
                                            PECo believes that the anchor bolts do exist, as detailed in the                           l
                                            design drawings.- In order to resolve this item, PECO will chip
                                            out the mortar joint at three of the walls inspected by.the NRC                           !
                                            and confirm that the anchors exist.     This work is scheduled to                         (
                                         ~begin October 1, 1987 and be completed by November 1, 1987.
                                                                                                                                      '
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