ML20245F593
| ML20245F593 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/24/1989 |
| From: | Kowalski S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905020436 | |
| Download: ML20245F593 (5) | |
Text
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10 CFR 2.201 a.
PHILADELPHIA ELECTRIC COMPANY h
1 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA A, PA,19101 (zis) 8414502 S. J. KOWA LSKI VIC E-P R E SID E NT Docket Nos. 50-277 m............ 278 1
License Nos. DPR-44 DPR-56 U.S. Nuclear Regulatory Commission ATTH: Document Control Desk Washington, D.C.
20555-
SUBJECT:
Peach Botton Atomic Power Station Units 2 and 3 Response to Combined Inspection Report Nos. 50-277/89-07 and 50-278/89-07
REFERENCE:
- 1) Letter from T. T. Martin (NRC) to C. A. McNeill (PECo) dated March 24, 1989
- 2) Letter from S. J. Kowalski (PECo) to U. S. Nuclear Regulatory Commission dated March 17, 1989
Dear Sir:
o This letter is in response to Reference 1 which transmitted Combined Inspection Report Nos. 50-277/89-07 and 50-278/89-07. This report concerned the Special Electrical Team Inspection which was conducted January 30 - February 10, 1989 at the Peach Bottom site and the corporate headquarters. Reference 2 provided an cdvance response to the potential restart issues identified during the inspection.
Appendix A of Reference 1 identified two items which did not appear to be in full compliance with NRC requirements. The attachment to this letter provides a
' restatement of these items along with Philadelphia Electric Company's response.
If you have any questions or require additional information, please do not hesitate to contact us.
l gg502 Sincerely
$k Y
G Attachment cc:
R. 'I. Martin, Project Manager, USNRC
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W. f. Russall, Administrator, Region I USNRC T. P. Johnson, USNRC Senior Resident Inspector T. E. Magette State of Maryland J. Urban. Delmarva Power t
J. T. Boettger, Public Service Electric & Gas
%I ll H. C. Schwemm. Atlantic Electric l.
T. E. Gerusky, Commonwealth of Pennsylvania r
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Attachment Page 1 of 4 Docket Nos. 50-277 50-278 Restatement of the Violation 1.
10 CFR 50 Appendix B Criterion V requires that activities affecting quality be prescribed by drawings and shall be accomplished in accordance with these drawings.
The Peach Bottom Atomic Power Station QA plan Revision 0. Section NE 5.1 also requires that activities affecting quality shall be prescribed by drawings and shall be accomplished in accordance with these drawings.
Drawing E26. Sheet 1 of 2 Revision 38, depicts the horsepower rating of motor operated valves M0-2-23-021, 016, 017, 57 and 58 as 6.6, 2.6, 0.65, 0.65, and 0.65 horsepower, respectively.
Contrary to the above, the installed nameplate ratings for motor operated valves M0-2-23-021, 016, 017, 57 and 58 were 6.9. 2.9, 0.722, 0.722 and 0.722 horsepower, respectively.
This is a Severity Level V violation (Supplement 1).
l Response to the Violation Admission or Denial of the Violation:
Philadelphia Electric Company acknowledges the violation.
Reason for the Violation:
The discrepancies identified are a result of drawing control and procurement 1
practices during the construction phase of the plant. The discrepancies are cases involving motor operated valves and slight differences in the fractional portion of the horsepower rating. Based on information provided by Limitorque, the motors on valve actuators are sized according to the required output torque rating; therefore, the nominal horsepower values shown on single line diagrams mAy deviate slightly from the installed nameplate rating. The minor differences in horsepower do not alter valve performance.
l Corrective Steps Which Have Been Taken and the Results Achieved:
l Walkdowns of the 480V AC safety related active MOVs and 250V DC MGVs in Unit 2 were performed to confirm the installed horsepower ratings. Discrepancies,,found were reviewed.for significance and found to have negligible impact on plantE16ading, battery sizing or protective devices of the equipment.
Attachment Page 2 of 4 Docket Nos. 50-277 50-278 Corrective Steps Which Will be Taken to Avoid Further Violations:
A review of the Unit 2 field data for MOV motor horsepower will be performed to ensure that the drawings reflect the motor nameplate within a defined tolerance of
+10%.
Drawing revisions will be made to reflect the notation on MOV horsepower tolerance and numerical changes, as appropriate. Similar walkdowns of Unit 3 MOVs and any resJlting drawing revisions Will be completed prior to restart of Unit 3.
i Our preliminary review of the potential impact of the changes on engineering calculations reveals that the effects are insignificant. However, a formal review of the impact will be documented for calculations which use MOV horsepower data.
The current procedures governing modifications, procurement, and drawing control are sufficient to ensure that minor discrepancies such as these are identified and resolved.
l Date When Full Compliance Will be Achieved:
Necessary drawing changes resulting from the Unit 2 and Unit 3 walkdowns will be made prior to restart of Unit 3.
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'i Attachment L'
Page 3 of 4 Docket Nos. 50-277 50-278 3
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Restatement of the Violation l
2.
10 CFR 50 Appendix B Criterion XVI requires that measures shall be established to assure that conditions adverse tu quality such as deficiencies are promptly identified and corrected.
l The Peach Bottom Atomic Power Station QA plan Revision 0. Section NE 16;l requires that measures shall be established to assure that deficiencies are l
promptly identified and corrected.
Contrary to the above, on February 3, 1989, for Motor Control Center 20011, circuit 29-1100, the deficiency identified in calculation 18247-008-EG, Attachment D, dated July 10, 1986 was not corrected in that a 100 Amp, 200V DC rated fuse was utilized for a 250V DC application.
This is a Severity Level IV violation (Supplement I).
Response to the Violation Admission or Denial of the Violation:
4 Philadelphia Electric Company acknowledges the violation.
Reason for the Violation:
The primary purpose of calculation 18247-008-E6 was Appendix R coordination. The fuse application issue was identified in the calculation, but categorized as a " plant betterment item", and not required for completion of the Appendix R review. Prompt corrective actions were not taken in response to the fuse application issue because the safety significance of the issue was not properly communicated.
The reason that the fuse misapplication occuried, when initially addressed in response to NRC Information Notice 84-65, is that the installed 100 Amp, 200VDC rated fuses (Gould-Shawmut TR-R100) were specified based on a misinterpretation of the available manufacturer's data related to voltage rating of fuses, and an isolated l
error in the implementation of the information presented in the NRC Information Notice.
j Corrective Steps Which Have Been Taken and the Results Achieved:
In response to the installation of TR-R100 fuses in safety related 250VDC applications, Non Conformance Reports (NCRs) P89050-216 and P89111-216 were generated to resolve this issue at PBAPS Units 2 & 3.
These NCRs have been dispositioned to y
replace the TR-R100 Gould-Shawmut fuses with TR-S100 Gould-Shawmut fuses. The j
application of the TR-S100 fuse will provide a 600VDC rating while maintaining l
coordination with the upstream protective device. Calculation EE-7 Section E6 has been revised to document circuit coordination with the new TR-S100 fuse.
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Pige 4 of 4 l
1 Docket Nos. 50-277 50-278 i
A design review of the 125/250VDC power etem for Units 2 and 3 was performed to
- confirm that the ratings of the remainii
.uses are appropriate for the design application. A walkdown of the subject tuses in Uritt 2 has confirmed that the l
installed fuses match the design drawings.
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Corrective Steps Which Will be Taken to Avoid Further Violations:
l Recurrence of the lack of prompt corrective actions in response to an identified deficiency will be prevented by implementation of Nuclear Group Administrative Procedure (NGAP) NA-03N001, " Control of Hardware Nonconformances" (effective date l
March 1, 1989). This procedure requires that any person who identifies a hardware deficiency must report it to appropriate supervision for dispositioning.
Dispositioning includes an assessment of the safety significance and the specification of any corrective actions.
To prevent recurrence of the misapplication of a fuse, an engineering memorandum dated March 29, 1989 was issued to engineering and design personnel to clarify the significance of AC and DC voltage ratings of DC components. Special consideration for the voltage rating of fuses was highlighted.
Date When Full Compliance Will be Achieved:
The installation of the safety related TR-S100 fuses in Unit 2 MCC 20011 to replace the existing TR-R100 fuses was completed on March 31, 1989.
The installation of the safety related TR-S100 fuses in the Unit 3 MCC 30D11 to replace the existing TR-R100 fuses will be completed prior to restart of Unit 3.
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