ML20247D184
| ML20247D184 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/19/1989 |
| From: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8907250072 | |
| Download: ML20247D184 (4) | |
Text
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.g PHILADELPHIA ELECTRIC COMPANY PEACII BOTTOM ATOMIC POWER STATION R. D.1, Box 208 Delta, Pennsylvania 17314 PEACH B0f'KW :fME POWER Of EXCNLLENcm (717) 456-7014
' D. M. Smith Vice President.
. July 19,1989 Docket Nos. 50-277 50-278 a ::
Document Control Desk U. S. Nuclear. Regulatory Commission Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station - Units 2 and 3 Response to Combined Inspection. Report Nos. 50-277/89-16;50-278/89-16
Dear Sir:
_.This is in response to your letter dated June 26, 1989, which transmitted
. Peach Bottom Inspection Report Nos. 50-277/89-16;50-278/89-16. This report.
concerned the special restart safety inspection conducted May 7 through June
- 17. 1989. Appendix A of your. letter describes an item which did not appear to be in compliance with NRC requirements. The attachment to this letter provides a restatement of this item, and provides Philadelphia Electric Company's response.
If you have any questions or require additional information, please do not hesitate to contact us.
Sincerely.
cc: -T. P. Johnson, USNRC Senior Resident Inspector W. T. Russell, USNRC, Region I l
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s 89'07250072 890719 PDR ADOCK 05000277 l
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R. A. Burricelli,~Public Service Electric & Gas
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.T. M. Gerusky, Commonwealth of. Pennsylvania T. E.~Magette, State of Maryland L
H. C. Schwemm, Atlantic Electric J. Urban.Delmarva Power bec: J. A. Basilio 52A-5, Chesterbrook Commitment Coordinator 52A-5, Chesterbrook Correspondence Control Desk NS-5, Main Office T. E. Cribbe Al-2S, Peach Bottom E. J. Cullen-S23-1, Main Office G. F. Daebeler A4-15, Peach Bottom E. P. Fogarty-51A-1,'Chesterbrook J. F. Franz A4-1S, Peach Bottom K. R. Graff 52A-5, Chesterbrook D. R. Helwig 51A-11. Chesterbrook G. A. Hunger 52A-5, Chesterbrook S. J. Kowalski S25-1, Main Office J. M. Madara 53A-1, Chesterbrook
'A. J. Marie N2-1, Main Office C. J. McDermott S13-1, Main Office C. A. McNeill, Jr..
S26-1, Main Office PB Nuclear Records A4-2S, Peach Bottom D. M.. Smith SM0-1. Peach Bottom
___lL__----
Page 1 of 2 Docket Nos. 50-277/278 RESPONSE TO NOTICE OF VIOLATION RESTATEMENT OF VIOLATION PBAPS Technical Specification section 6.8.1 requires that written procedures be established, implemented and maintained that meet the requirements of sections 5.1 and 5.3 of ANSI N18.7-1972, and Appendix A of Regulatory Guide 1.33 (November 1972).
ANSI N18.7-1972, section 5.1.6.4 requires procedures for modification installation, inspection and testing. Regulatory Guide 1.33 (November 1972)
Appendix A, section I, requires procedures for maintenance and modification work.
Contrary to the above, on May 5, 1989, Modification No. 5061 for installation of an analog isolator on the Unit 2 High Pressure Coolant Injection system flow controller was not installed in accordance with construction installation procedure CD 5.3; furthermore, quality control inspection checklist procedure CD 5.3 and post maintenance modification acceptance test (MAT) procedure MAT 5061 failed to detect the installation error.
This is a Severity Level IV violation (Supplement I).
RESPONSE TO VIOLATION Admission or Denial of the Alleged Violation:
Philadelphia Electric Company acknowledges the violation.
Reason for the Violation:
Investigation determined that the root cause of this event was failure of craft electricians to follow installation instructions during the implementation of Modification 5061.
It was also determined that the following three additional factors contributed to the event:
Inadequate Inspection - post installation inspection was inadequate due to the failure of the Quality Control (QC) inspector to verify that the wiring installation was in accordance with the work instructions per Construction Division (CD) Procedure CD 5.3 and installation drawing.
- Inadequate Field Wiring Check - The Field Installation Engineer used color coding to perform the point to point wiring check and therefore, failed to identify the installation errors.
Communications used during the check were not specific with regard to wire number, cable number, or terminal point.
Inadequate Modification Acceptance Test (MAT) Procedure - MAT 5061 utilized Surveillance Procedure SI-2F-23-82-XXC0 " Calibration Check of High Pressure Coolant Injection (HPCI) Flow Instruments" to verify the instrument loop from flow controller to ramp generator and signal converter. The SI procedure did not provide sufficient overlap of tested components to assure the required portions of the loop were tested.
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Page 2 of 2 Docket Nos. 50-277/278 Corrective Steps Which Have Been Taken and the Results Achieved:
HPCI was declared inoperable, redundant systems (Reactor Core Isolation Cooling, Low Pressure Coolant injection and Automatic Depressurization) were satisfactorily tested, the wiring error was corrected, and HPCI was retested satisfactorily.
Supervisory personnel associated with implementation of modifications were briefed on this event.
The' specific individuals involved in the installation, inspection, and testing of the isolator have been counseled on this event and the significance of the errors committed.
Installation Checklists for open electrical modifications have b'een changed to require the first line supervisor or the Site Lead Man (Job Foreman) to verify correct installation of the work prior to QC
- inspection.
The event has been reviewed with construction, inspection, test, and other site personnel associated with the implementation of modifications and MATS.
Areas discussed included; adherence to procedures / instructions, wiring color standards, use of wire tags as a construction aide only, and attention to detail regardless of apparent simplicity of the installation.
The modification process has been enhanced to ensure that when a standard test.
(e.g., Surveillance Procedure) is used to functionally test an electrical installation, the test encompasses the components required to be tested.
These enhancements include: 1) cognizant personnel have been added to distribution for MATS to allow time for review prior to performance of the test, and 2) the responsible Field Engineers Modification Checklist has been revised to require verification that the test encompasses the components required to be tested.
Personnel performing wiring checks have been instructed in use of proper communications practices when performing wire checks or other similar tasks.
Corrective Steps Which will be Taken to Avoid Further Violations:
Construction Division Procedure, CD 5.3, " Procedure for the Installation of Electrical Equipment" is being revised to require the Site Lead Man to verify the correct installation of the work prior to Quality Control inspection. A planned issue date of July 31, 1989 has been assigned.
It should be noted
.that this requirement has been put into practice since the time of the event.
Date When Full Compliance will be Achieved:
Philadelphia Electric Company is in full compliance with respect to this violation.
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