IR 05000277/1979013
| ML19253C561 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/07/1979 |
| From: | Jerrica Johnson, Kister H, Markowski R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19253C548 | List: |
| References | |
| 50-277-79-13, NUDOCS 7912060058 | |
| Download: ML19253C561 (22) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
277/79-13 Report No.
278/79-15 Docket No.
50-277/50-278 License No.
DPR-44/56 Priority
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Category
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Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Peach Botton Atomic Power Station, Units 2 and 3 Inspection At:
Delta, Pa. and Philadelphia, Pa.
Inspection Conducted:
June 18-21 and 25-29, 1979 f-7- M Inspectors:
-
-
G eNapuda,RaporInsp,ector,RO&NSBranch date
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E LJ.
'
D v d Keh
, React r Inspector, RO&NS Branch date
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,
9 -7-27
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x Jon Johnson, Reactor Inspeqtor, RO&NS Branch date b SM %d
% l79 R 9mond Nar sP, oaactor Jaspector, RO&NS Branch date
'7C/
Approved by:
d,(.4@
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.
H.~ B. 'Kister, Chief Nuclear Supp6rt
/ date
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5ection #2, RO&NS Branch
/
Inspection Summary:
Inspection on June 18-21 and 25-29, 1979 (Report No. 50-277/
79-13 and 50-278/79-15)
Areas Inspected:
Routine, unannounced inspection by regional based inspectors of QA Program implementation including Quality Assurance Program changes; QA/QC Organization; Receipt, Storage and Handling; procurement; records; document control, including drawings; design changes / modifications; audits; and, licens-ee action on previous inspection findings.
The inspection involved 133 inspector-hours on site by four regional based inspectors and 118 inspector-hours at the corporate office by four NRC regional base'd inspectors.
Results:
Of the nine areas inspected, no items of noncompliance were identi-fied in six areas; four items of noncompliance were identified in three areas (Infraction-Failure to identify post valve replacement test results as unaccept-able, paragraph 6.c; Infracton-Failure to accomplish timely corrective action, paragraph 10.c; Infraction-Failure to issue audit reports within the required time-frame, paragraph 10.d; Infraction-Stores Division South Warehouse Store-room not maintained in accordance with ANSI N4'.2.2 requirements, paragraph 8.d).
s Region I Form 167 (August 1979)
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,c,-n gg 7912000
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DETAILS 1.
Persons Contacted
- N. C. Birely, Licensing Engineer-Nuclear Section
- W. H. Van Buskirk, Electrical Prrject Engineer, Engineering and Research (E&R) Department
H. Conner, Superintendent Stores Division
- M. V. Cooney, Superintendent Nuclear Section J. Davenport, Engineer, QA Receipt and Inspection
- R. D. DiSandro, Research and Testing Division E&R
- C. R. Endriss, Engineer-QA EPD R. Fleishchmann, Assistant Plant Superintendent
- J. W. Gallagher, Manager-EPD
- F. C. Gloeckler, Engineer-QA E&R
- R. M. Jones, Constrtction Division ENG-QA E&R
- R. A. King, Engineer in Charge - E&R Design Division
- R. H. Logue, Engineer in Charge - Nuclear and Environmental Section
- D. L. Morad, Mechanical Project Engineer E&R S. Roberts, Results Engineer
- J. W. Siefert, Chief Design Engineer E&R D. Smith, Outage Manager
- T. Stapleford, General Superintendent, Stores Division
- W. A. Texter, Engineer-Maintenance Division EPD W. Ullrich, Plant Superintendent
- H. R. Walters, Manager-QA E&R
Present at exit held June 27, 1979
Present at exit held June 29, 1979
Present at both exits The inspectors also interviewed other licensee employees during the course of the inspection including engineering, maintenance, office, operating plant technical support, quality assurance and stores personnel.
Other Accompanying NRC Personnel J. Gilray, Nuclear Engineer, NRC:NRR (QAB)
H. B. Kister, Chief, R0&NS Section #2, NRC:RI 1509 236
2.
Status of Previous Inspection FinJings (Closed) Unresolved Item (277/78.'5-01; 278/78-19-01):
Review of QAI-18-6, Revision 0.
QAI-18-6, Revision 0 w s issued 7/10/78.
It addresses the general areas af audit preparation, performance, reporting and followup.
The inspector observed that this procedure is consistent with ANSI N45.2.12 Draft 3, Revision 4 as modified by FSAR section 17.2.B.9.
This item is resolved.
(Closed) Unresolved Item (277/7815-02; 278/78-19-02):
Establishment of the method for scheduling audits performed by E&R QA.
QAI-18-8, Revi-sion 0 was issued on March 16, 1979.
This procedure establishes the method to be used in generating an annual audit schedule for vendor and inhouse audits.
The procedure as written is consistent with FSAR section 17.2.B.9.b.
The inspector reviewed Issue 89 of the Major Activities Schedule dated June 11, 1979, and observed that it was consistent with QAI-18-8.
This item is resolved.
(0 pen) Unresolved Item (277/78-15-03; 278/78-19-03):
Review the content of EPD's audit of E&R organizational units.
The inspector noted that this audit was sti11 in the preparational stage.
This item remains open pending further review.
(Closed) Unresolved item (277/78-15-05; 278/78-19-05):
Revise A-14 to clarify "in certain cases" as it relates to electric production perform-ing major mods.
A-14, Plant Modifications, Revision 6 specifiecs that electric production shall be assigned major modifications in certain cases when performed by a vendor under their QA program.
This item is resolved.
(0 pen) Unresolved item (277/78-15-06; 278/78-19-06):
Operations and Safety Review (0&SR) Committee meeting minutes to document the safety evaluation or equivalent which constituted the basis of the review associated with changes to equipment or systems conducted under the provisions of 10 CFR 50.59.
The inspector reviewed the most recent 0&SR (offsite) Committee meeting minutes (draft) No. 90 and noted that it contained a safety evalua-tion associated with the containment purge valve (I.A. 29-06-T.S.-79-4 modification.
The licensee representative stated these minutes were the first to specifically reflect the basis upon which the tc.mmittee deter-mined that an unreviewed safety question was not involved with a given modification and that this practice will be continued.
This item remains unresolved pending further review of future meeting minutes during a sub-sequent inspection (s).
(0 pen) Unresolved item (277/78-15-07; 277/78-19-07):
Process jumpers and lifted leads which have been installed for long time periods.
The inspec-tor verified that the plant operations review committee had reviewed the jumper and lifted leads log and had determined which jumpers and lifted leads were to be permanent modifications.
The inspector further verified 1509 237
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that the majority of those jumpers and lifted leads which were to remain temporary have been removed from the plant.
The inspector identified that the processing of the jumpers and lifted leads to permanent modifi-cations was just commencing and that no modifications had been issued for this purpose at the time of this inspection.
This item is to remain open pending verification by NRC:RI that the desig'ated lifted leads / jumpers are being processed into permanent modificatius.
(Closed) Unresolved item (277/78-15-08; 278/78-19-08):
Procedure R2-00006 to include requirement that procurenent of components which are not a replacement in kind be in accordance with A-14, plant modifications.
A review of R2-00006 verified that the above requirement was delineated in the procedure.
This item is resolved.
(0 pen) Unresolved item (277/78-15-09; 278/78-19-09):
The inspector veri-fied that procedure A-27 had been revised to clarify the method of material control but noted that procedure 50-1 had not been revised.
The licensee stated that SD-1 would be revised to be consistent with A-27 by July 27, 1979.
(Closed) Infraction (277/78-15-10; 278/78-19-10):
The inspector verified the steps the licensee has taken to improve storage conditions in the Con-structior. Division Warehouse - Mechanical and found conditions acceptable.
However, a similar item of noncompliance is discussed in paragraph 8.d.
(Closed) Infraction (277/78-25-02; 278/78-30-02):
Failure of the OS&R Committee to perform audits of actions taken to correct deficiencies which affect nuclear safety at least once per six months.
The inspector noted that the OS&R Committee delegated the responsibility of conducting this audit to the Quality Assurance Department and documented this action in Meeting No. 82 minutes (Iten 7305).
The inspector also reviewed QAD Audit Report 79-1-PR.
Corrective Action (OS&R), which documented an audit of the subject area.
The inspector determined that the foregoing was consis-tent with the licensee's statement in their letter to NRC:RI, dated Decembcr 5, 1978.
The inspector stated this area would be reviewed during subsequent routine inspections.
This item is closed.
(Closed) Ceficiency (277/77-31-01):
Procedure for performing audits lack-ing.
The inspector noted that Procedure 18-6, Procedure for Performing Quality Assurance Audits, Revision 0, was issued January 4, 1978.
The inspector determined that this was consistent with the licensee's state-ment in their lettei m NRC:RI, dated October 26, 1977.
This item is closed.
3.
Quality Assurance Program Review a.
Implementing Procedures The inspectors reviewed the changes m 9e to the quality assurance proceduressubsequenttothelastNRCQ,.inspectionconductedduri,&o
\\509
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June, 1978.
These procedures are listed in other paragraphs of this report and are identified by an asterisk.
The revisions were reviewed to determine if they were consistent with the licensee's accepted Quality Assurance Prcgram (FSAR).
No items of noncampliance were identified, however, two unresolved items are discussed below.
b.
Quality Assurance Division Organi7.ation The inspector noted that a recent reorganization invalidated the Quality Assurance Plan description of the Quality Assurance Division and the assigned responsibilities of the General Supervisor and QA Engineer in particular.
The licensee representative stated that the QA Plan will be revised to reflect the current organization and assigned responsibilities by January 15, 1980.
This item is unresolved pending NRC review of licensee action during a subsequent inspection (s).
(277/79-13-01; 278 '79-15-01)
c.
0&SR Committee Program Review Section 17.2.2.2 of the FSAR states that the Operations and Safety Review Committee will review the QA Program annually to determine its adequacy and status.
The inspector determined that the program is being reviewed for ade-quacy and status on an ongoing basis, e.g., biweekly status reports and management meetings.
However, the inspector noted that this review method is not clearly described in any procedure.
The licensee representative stated that the QA Flar. ar.d any necessary implementing procedure (s) will be revised by Jr.auary 15, 1980, to clearly describe the manner in which this required management review is accomplished.
This item is unresolved pending review by the NRC of the licensee's action during a subsequent inspection.
(277/79-13-02; 278/79-15-02)
4.
Document / Record Control a.
References
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A-2, Control of Procedures, Revision 14*
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A-46, Mainte7ance of Records During Commercial Operation, Revision 4 1509 239
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b.
Documents During the course of this inspection the inspectors requested and received the various documents and records listed in other paragraphs of this report.
The inspectors verified that those documents such as procedures were controlled as required ind of current revision.
The inspectors also verified those records requested were retrievable and maintained as required.
No items of noncompliance were identified.
c.
Records The inspector reviewed the licensee's records management effort.
The licensee representatives stated that the feasibility study was completed the latter part of 1978, implementing procedures are being developed and hardware for the system is being purchased.
The repre-sentatives further stated that present planning estimates current records will be in the system by mid 1980 and backlog records will be incorporated by early 1981.
The inspector stated that he had no further questions and that this area would be reviewed during a subsequent routine inspection (s).
5.
Drawing Control a.
References:
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A-6, Procedure for Control of Drawings and Drawings Logs, Revision 6; b.
Program Review The inspector reviewed the procedure referenced above and noted that it defined administrative controls for the control of drawings which provided:
a list of Piping and 11strument Diagrams (P&ID) and Electrical
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One Line Diagrams which were to be controlled; and, indicated the revision status of these drawings (referred to as the Draw-irg Control Log);
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the requirement that those drawings identified on the Drawing Control Log were to be used for plant operations (i.e., trouble-shooting and for blocking);
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the requirement that differences oetween the as built configura-tion of the plant and that indicited on a controlled drawing would be corrected utilizing a " Request for Drawing Change";
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the requirement for manual updating of controlled drawings at
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the site as an interim method of reflecting the "as built" con-figuration prior to formal revision subsequent to both major and minor modifications; and, the assignment of responsibility for the maintenance and issu-
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arne of controlled drawing at the site.
No items of noncompliance were identified.
c.
Implementation The inspector selected a sample of drawings (i.e., P&ID's and E-diagrans) and using the Drawing Control Log, dated June 1, 1979, verified that those copies retained in the Shift Supervisor's Office, the control room and the controlled aperture card deck in the admi-nistration building were the current revision (s).
The drawings selected were:
M-301, Rev. 5; M-307, Rev. 15; M-308, Rev. 16; M-351, Rev. 18; E-28, Sheet 1, Rev. 24; E-28, Sheet 2, Rev. 20; E-29, Rev. 17; E-1615, Rev. 18; and E-1616, Rev. 20.
No items of noncompliance were identified.
6.
Modifications a.
References A-2, Procedure for the Control of Procedures, Revision 14*
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A-14, Plant Modifications, Revisions 3 thru 6*
A-26, Procedure for Corrective Maintenance, Revision 19*
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A-27, Material Control System, Revision 10*
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ERDP-3.1, Handling Q-listed Modifications, Revision 0*
ERDP-3.3, Procedure for the Performance of Safety Evaluations
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and Applications for Facility Operating Licenses
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ERDP 14.1, Procedure for Use of Maintenance Requests Forms and Modification Status Reports b.
The inspector selected the following modifications to determine if 10 CFR 50.59 safety evaluations, design basis verifications, and quality control and post Inodification followup in the areas of pro-cedure and drawing updates are being accomplished in accordance with the applicable administrative controls.
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Modification Number Title
- 77-27 Replacement of Snubbers in the Control Rod Drive Hydraulic System 77-42 Emergency Diesel Generator Minor Mods
- 78-031 Recirculation Pump "A" Trip Delay 78-032 Control Rod Drive System Suction Line Reroute 78-046 HPCI, RCIC Hydraulic Control System
- 78-121 Remove Bleeder Orifices from 2 1/2 Inch Snubbers No items of noncompliance were identified, however two unresolved items are discussed below.
(1) The inspector identified that one procedure change and one new procedure were required as a result of modification 77-27.
The
" plant modification control sheet," a document used to identify when new procedures and changes are needed, stated no changes were required.
Although an individual had been delegated the responsibility of idenfitying changes /new procedures needed as a result of a modification, no formal method is described for accomplishing this task.
The licensee acknowledged the inspec-tor's comments and stated that the new procedure change that was required had been completed and that the new procedure which was required did not impact on plant operations at this time.
The licensee further stated that a formal method for identify-ing new procedures and/or procedure changes needed as a result of a plant modification would be incorporated during the next revision to A-14, Plant Modifications, and that this revision would be issued by August 31, 1979.
This item is unresolved pending issuance of the next revision to procedure A-14 and sub-sequent review by NRC:RI (277/79-13-03; 278/79-15-03)
(2) Modification 77-27 removed 16 safety related hydraulic snubbers from Unit #2 and Unit #3 and replaced them with mechanical snub-bers which, according to the licensee, are equal to or better than the hydraulic snubbers previously installed.
Technical specification section 3.11.0 provides operability requirements for the snubbers included in Table 3.11.D.1.
The replaced snub-bers were included in Table 3.11.D.1.
Technical Specification A
Major modifications performed by Engineering and Research/ Construction Divisions.
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Section 4.11.D contains the surveillance requirements for verifying.
Operability of the hydraulic snubbers included in Table 3.11.D.1.
Orginally the table listed only hudraulic snubbers, however, due to the modification, mechanical snubbers are now included to Table 3.11.D.1, but the technical specification surveillance requirements do not specifically address mechanical snubbers.
The licensee acknowledged the inspectors coments and stated that a technical specification change will be issued by December 1,1979, clarifying the applicability of technical specification 3.11.0 to mechanical snubbers.
This item is unresolved pending further review by NRC:RI (277/79-13-04; 278/79-15-04)
c.
Relief Valve Replacement The inspector reviewed the maintenance request form, the maintenance procedure and acceptance tett procedure associated with the replacement of the target rock relief valve which had failed one week prior to this inspection.
Surveillance test (ST) 10.4, Relief Valve Manual Actuation, dated June 16, 1979, was the acceptance test for the target rock relief valve.
The acceptance criteria required the relief value to pass a flow equivalent to two (plus or minus one quarter) turbine bypass valves.
The data recorded on the table indicated that a flow equivalent of only one and a half bypass valves was actually
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achieved.
The subject test was signed off as being completed satisfactorily by the operator who performed the test and the shift supervisor.
Immediate notification of shift supervision and the plant superintendent or alternate was required by this step if the test could not be completed satisfactorily.
Since the review by the operator who perfomed the test and the shift supervisor did not identify the unsatisfactory test results the required notifications therefore were not made.
The licensee acknowledged the unsatisfactory test results and agreed to retest the relief valve immediately.
The inspector reviewed the retest documentation, ST 10.4 dated June 21, 1979, and noted that the data associated with the relief valve capacity check was not intelligible.
The inspector also noted that the data recorded on Table 2, which is required to be recorded prior to and after the capacity check, was only prior to the capacity check data.
The licensee acknowledged the inspector's comments and corrected the data sheets immediately.
The inspector also reviewed ST 10.4, dated May 19, 1978, perfomed subsequent to the previous outage and noted that the Table 2 data was only prior to and not post test data as required by the procedure.
The failure of the operator and shift supervisor to identify the unsatisfactory test results during their test data review, the failure 1509 243
to notify required supervision / management of unsatisfactory test results, and, the failure to identify unintelligible and incomplete data with respect to the performance of ST 10.4 is considered to be an item of noncompliance at the infraction level (277/79-13-05; 278/79-15-05).
7.
Procurement Control a.
References PBAPS QAP, Volume I, Appendix L, Procedure for Preparation and
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Maintenance of the Approved Suppliers List for Q-Listed Products, Rev. 0*
QAI 18-5, Procedure for QA Supplier Evaluation, Rev. 0
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ERDP 3.2, Procedure for Maintenance and Revision of the Project Q-List, Rev. 1
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ERDP 4.4, Procedure for Procurement of Equipment, Materials, Services, or Combination Thereof of Q-Listed Installations, Rev. 1 ERDP 4.5, Procedure for Procurement of Materials and Equipment
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Listed by Engineering Design Division, Rev. 1.
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Systems Division Procedure 7-30(39), Requisitioning Quality Assured Materials and Services December 19, 1975
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A-27, Procedure for Material Control System, Rev. 10*
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SD-1, Procurement of Nuclear Safety Related Parts, Material, and Services, Rev. 3*
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PBAPS Evaluated Suppliers List, Rev. 3
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PBAPS Project Q-List, Rev. 14 b.
Program Review The documents referenced above were reviewed to verify chat adminis-trative controls for procurement have incorporated the requirements as described in the FSAR, Section 17 amendment.
This review deter-mined that administrative controls have been established for:
The identification of items purchased; identification of tests
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and/or special instructians, technical requirements and docu-mentation to certify the item; assuring that the contractor /sup-plier has implemented a QA program consistent with Appendix B 1509 244
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to 10 CFR 50, and, when deemed appropriate by the licensee, access to the supplier's plant or records for purposes of audit.
The assignment of responsibilities for:
initiation of procure-
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ment documents; review and approval of specifications differing from the original design documents; review and approval of procurement documents, including changes thereto; and, the designation of quality classification of procurred items.
The evaluation and approval of bidders / suppliers including the
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assignment of responsibilities for the following functions:
review / update of the " Approved Suppliers List"; providing for right of access to supplier's facilities and records; and, main-tenance of records of suppliers qualification and audit.
No items of noncompliance were ider.tified.
c.
Implementation Review The inspector selected a sample of Purchase Orders / Purchased Items and reviewed each to determine that:
documentary evidence is available onsite to support conformance
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to procurement requirements; documents were prepared in accordance with the appropriate
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procedures; items were purchased from qualified vendors or appropriate
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additional procedural controls were applied; procurement documents contained requirements to supply appro-
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priate documentation; and, feed back from experience with suppliers is provided to those
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maintaining the " Approved Suppliers List."
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The Purchase Orders / Purchased Items reviewed were:
BW377249, Motor Frame 286U
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BW325898, HEPA Filters
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S0185670, Solenoid Valve for Fuel Support
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S0118085, Double Torque Switch Assembly
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BW299333, 18 inch Vacuum Relief Valve
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S0154857, Pressure Switch (RCIC Pump)
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BW383368, Seal for CRD Assembly
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S0144354, Plunger for Target Rock Relief Valve
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BW372671, 0 Ring (CVIC Pump)
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BW388037, Speed Switch for Auxiliary Diesel
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BW332179, Trigger Assembly Kits (SLC System)
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50183267, 0 Ring (Recipe Pump)
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BW397417, Nupro Check Valves
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BW397415, Swagelock Tees
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BW388550, Nupro Check Valves, 0 Rings
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M243BC, Valve Operator, HPCI Steam Line Heat Up Valve
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M415AL, Piping Spool Pieces (Core Spray System)
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BW372102, Electrical Relays
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EC323982, Pipe Thread Sealer
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Electrical Circuit Breaker
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No items of noncompliance were identified.
However, the inspector noted the lack of documentation for two items stored in the Construc-tion Division (Electrical) Storeroom.
ERDP 7.1, Procedure for Receipt, Inspection, and Storage of Materials and Equipment, Rev. 1, requires that quality assured material received by the Electrical Construction Engineer and found acceptable be placed in a segregated storage area for acceptable Q-listed material only.
During a tour of the Electrical Construction Division storeroom on June 20, 1979, the inspector requested documentation (purchase order and receipt inspection) for an electric circuit breaker and several bottles of pipe thread lubricant / sealer which were stored in the segregated storeroom.
The Electrical Construction Engineer stated to the inspector that he did not have nor could he locate the required documentation to certify the circuit breaker and immediately removed the circuit breaker from the storeroom.
The Construction Engineer also stated that the thread lubricant / sealer was not requested on the purchase order but was sent with a shipment of connectors (P.O.
EC323982).
He further stated that the thread lubricant was not required for the electrical connectors ordered and that he would remove the lubricant from the Q-listed storeroom.
The inspector had no further questions.
8.
Receipt, Storage and Handling a.
References
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A-27, Procedure for Material Control System, Rev. 10*
A-13, Procedure for Reporting Defects and Non-compliances, Rev. 2
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A-30, Plant Housekeeping Controls, Rev. 0
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MA-8, Control of Purchased Material and Services, Rev. 1
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SD-1, Procurement of Nuclear Safety Related Parts, Materials, and Services, Rev. 3*
SD-2, Supervising Storekeeper Monthly Audit, Rev. 3*
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SD-3, Annual Review of Stores Division Program by General Suner-
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intendent July 24, 1974 EROP 7.1, Procedure for Receipt, Inspection, and Storage of
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Materials and Equipment, Rev. 1 ERDP 15.1, Procedure for Handling Nonconfomance, Rev. 0
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CD 10.1, Procedure for Certification of QC Inspectors, Rev. 0
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CD 10.2, Procedure for Certification of Inspectors of Handling
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Equipment and Rigging, Rev. 0 CD 13.1, Procedure for Handling Q-Listed Items
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SD-5, Storage and Handling of Material for Nuclear Power Plants,
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March 29, 1979*
b.
Program Review The documents referenced above were reviewed to determine that administrative controls for receipt, storage, and handling of safety related items have incorporated the requirements as described in the FSAR, Section 17 amendment.
This review determined that administrative controls include:
receipt and inspection of safety-related items including docu-
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mentation thereof; dispositioning acceptable, nonconforming, and conditional release
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items; maintenance and care of items in storage including appropriate
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environmental conditions, control of access to, and periodic inspections of storage areas; qualification requirements for personnel performing receipt
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inspections; and, qualification requirements for inspection and use of handling
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equipment and rigging.
No items of noncompliance were identified.
However, the inspector reviewed actions that the licensee has taken in response to a recent NRC Performance Appraisal Team (PAT) finding that receipt inspectors are not qualified in accordance with ANSI N45.2.6 as described in the licersee's QA Plan.
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An EPD administrative procedure has been written, approved by the on site review committee, and forwarded for further review and approval.
This procedure, A-55, General Requirements for QA Receipt Inspectors (DRAFT), is intended to implement the requirements of ANSI N45.2.6 for Quality Receipt Inspectors.
The item will be reviewed by NRC during a subsequent inspection (s)
(277/79-13-06; 278/79-15-06).
c.
Implementation Review The inspector toured the on-site storeroom and off-site warehouses and selected items (listed below) received to determine if receint inspecticn, disposition, storage controls, traceability, maintenance of items in storage, and control of non-conforming items were in accordance with the governing instructions.
(1) South Warehouse (Stores Division)
50173759, GL Gear Box Assembly
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S0166567, 3" Valve Manifold
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BW320206, Four Electrical Motors (Limitorque)
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S0127721, Electrical Motor (Reliance)
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BW377249, Motor Frame 286U (on ' hold')
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BW325898, HEPA Filters
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(2) North Warehouse (Stores Division)
50185670, Solenoid Valve for Fuel Support (on ' hold')
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50118085, Double Torque Switch Assembly (on ' hold')
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BW298637, 1 1/2" 200 psi Globe Valve BW299333, 18" Vacuum Relief Valve
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(3) Administration Building Storeroom (Stores Division)
50154857, Pressure Switch (RCIC Pump)
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BW383368, Seal (CRD Assembly)
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50144354, Plunger - Target Rock Relief Valve
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BW372671, O Ring - CVIC Pump
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BW388037, Speed Switet. - Auxiliary Diesel
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BW3882179, Trigger Assembly Kits (SLC System)
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50183267, 50127893, S0167900, 50108970, BW388574, Various 0 Rings
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for Recirc System Centrifugal Pump (4) Construction Division Warehouse (Mechanical-Construction Division)
BW397417, Nupro Check Valves (on ' hold')
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BW397415, Swagelock Tees (on ' hold')
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BW388550, Nupro Check Valves, 0 Rings (on ' hold')
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M243BC, Valve Operator - HPCI Steam Line Heat Up Vaive
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M415AL, Spool Pieces for Core Spray System, (on 'hald')
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(5) Construction Division Warehouse (Electrical-Construction Division)
Electrical Circuit Breaker
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EC323982, Electrical Connectors, Thread Lubricant
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SW372102, Electrical Relays
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The inspector also reviewed the following:
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Supervising Storekeeper Monthly QA Audit Reports June 23, 1978 through May 25, 1979
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General Superintendent of Stores Division Annual Review Reports March 30, 1978, September 28, 1978, and May 25, 1979
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Shelf Life Diary for 1979
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QAD Audit Report 78-22, Stores and Purchasing dated December 5, 1978 One item of noncompliance, two unresolved items and an item that required consultation with NRC:NRR offices were identified and are discussed below.
d.
Stores Division Storeroom The inspector identified that contrary to 10 CFR 50, Appendix B, Criterion XIII, and FSAR Fection 17, the Stores Division Storeroom in the South Warehouse did not comply with the requirements of ANSI N45.2.2 in the following major areas:
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Avoidance of accumulation of trash and discarded packing material Storage of hazardous material
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Care of items in storage to minimize damage
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This failure to control the storage of items is an Infraction level item of noncompliance.
This is a recurrent item (277/79-13-07; 278/79-15-07).
The licensee stated that the accepted, Q-listed material in the storeroom in question was stored in a manner not to be re-issued from stores division as a stock item without having been reinspected.
The inspector acknowledged the licensee's statement.
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The inspector also noted that the flammable material had been removed from the storeroom, cleaning of the streroom commenced, and reinspec-tion of all Q-listed material initiation prior to the completion of this inspection.
e.
Maintenance of Electrical Motors in Storage ANSI N45.2.2 Section 6.4.2 requires that rotating "ectrical equip-ment in storage be given insulation resistance tes a on a scheduled basis and that the shafts be rotated on a periodir basis.
The inspec-tor noted that there was no documentation availab'e to demonstrate that the required maintenance had been performed for the electrical motors in the Stores Division Storeroom in the South Warehouse.
The lack of a maintenance program for elect ical motors in storage was identified by the General Superintendent of Stores as described in a letter to the Superintendent of QA Division, the Plant Superin-tendent, and the Storekeeper dated March 30, 1978.
Audit Report 78-22 SP, dated January 12, 1979, identified a lack of corrective action in this area and QAD issued Nonconformance Report 78-68 on March 29, 1979 SD-5, Storage and Handling of Material for Nuclear Power Plants was approved.
Section 4.6 of SD-5 contains the require-ments for the performance and documentation of maintenance of elec-trical motors in storage.
The response to NCR 78-68, dated May 22, 1979, frcin the Ge u ral Superintendent of Stores Division states that "the Maintenance Division expects to have a procedure approved by August 1, 1979 detailing the maintenance procedure for electrical motors in storage."
This item is unresolved pending review by NRC:RI of the approved procedure for maintenance of electrical motors in storage and imple-mentation of this program (277/79-13-08; 278/79-15-08).
f.
Shelf-Life of Quality Assured Items Procedure A-27, Section D.8 requires that the " Shelf Life Expiration Date" be placed on the Quality Control Conformance Tag (orange accept tag) after receipt inspection acceptance of the item.
Procedure SD-1, Section 4.0 also requires that the " Shelf Life Expi-ration Date" be placed on the Acceptance Tag.
Section 4.1 of SD-1 further states in part that "if an item has a shelf life then this information is to be entered on the ' Shelf Life Following Diary'...
This diary shall be reviewed each day....The material will be physically denroyed to prevent further use."
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.
.
The inspector identified that administrative controls do not specify how to determine " Shelf Life" or how to determine " Shelf Life Expi-ration Date."
The licensee stated that current policy was to take the Shelf Life from the stock card description and add that length of time to the date the item was received and the resulting date would be the
" Shelf Life Expiration Date" to be entered on the Acceptance Tag.
The inspector identified the following discrepancies with this policy.
All items involved were 0 Rings for Recirculating Pumps and were located in storage bins in the Administrative Building Storeroom.
Shelf Life P.O. Number Shelf Life Date Received Expiration Date (Not listed in 50183267 3 yrs.
1976 Dairy) 9/25/78 S0127893
--
--
Blank 50167900 3 yrs.
9/78 2/81 BW357110
'4Q76 SHELF 4Q79'
8/80
--
S0108970
'3Q75' or '4Q75'
2/78 2/81 BW388574
'4Q775HELF4Q80 5/79 4Q80 The licensee stated that a review would be performed by August 1, 1979, to ensure that no items are in stock with expired shelf life expiration dates and that all items in stock with shelf lives are entered in the Shelf Life Followup Diary.
The licensee further stated that a complete review of the Shelf Life Program would be performed and that a procedure would be submitted for approval by December 31, 1979, which would provide guidance on how to determine Shelf Life and Shelf Life Expiration Dates.
This item is unresolved pending review of the revised / issued proce-dure and implementation thereof by NRC:RI inspectors (277/79-13-09; 278/79-15-09).
g.
SLC System Trigger Assembly / Primer Charge Replacement
.
PBAPS Technical Specifications, Amendment 47, Surveillance Require-ment 4.4.A.2.b states in part:
"the replacement charges to be installed will be selected from the same manufactured batch as the tested charge."
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.
.
A review of completed maintenance request foms and maintenance procedures indicated that on March 8, 1977 Unit 3 tested the SLC System explosive squibb valve 14B with primer charge from batch
" HEP 14-1".
Replacement primer charges from batch "CX1-1" were then placed in valves 148 and 14A.
The licensee's interpretation of the above referenced Surveillance Requirement was that the primer charge replacements could be from a batch that had been tested at a previous time and at the other unit.
The inspection verified that completed maintenance records for Unit 2 indicated that on June 1, 1976, SLC system explosive squibb value 14A with primer charge from batch "CX1-1" had been test fired.
The inspector verified via telephone conversations between NRC:IE, Region I and NRC:NRR personnel subsequent to this inspection that the licensee's interpretation was acceptable.
9.
Surveillance Program The inspector reviewed the implementation of the Quality Assurance Divi-sion (QAD) Surveillance Program described in the Peach Bottom Quality Assurance Program (PBQAP).
The inspector noted that the surveillance program as implemented by the QAD was not consistent oith the definition of surveillance in the PBQAP glossary in that physical observation was not always performed.
The licensee acknowledged the inspector's comment and stated that the surveillance program was intended to be supplementary to the audit program when there was insufficient preparatory time for an audit.
The licensee further stated that the PBQAP would be changed to make the definition of surveillance consistent with the QAD surveillance program, and this change would be made by January 15, 1980.
The inspector stated that this item was unresolved pending further review of this area during a subsequent inspection (277/79-13-10; 278/79-15-10).
10.
Audits The inspectors reviewed the audits listed below that were conducted since the previous NRC Quality Assurance Inspection (June 1978).
These audits were reviewed to verify that they were conducted as follows:
in accor-dance with written checklists / procedures; by trained personnel not having direct responsibilities in the area (s) audited; with findings documented and reviewed; with followup actions completed / initiated / closed out; and, with audit frequencies and general audit conduct in accordance with estab-lished standards.
--
QAI 18-6, Procedure for Performing Quality Assurance Audits, Revision 0; 1509 252
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.
QAI 18-8, Procedure for Formulation of Peach Bottom Annual Audit
--
Plan, Revision 0; QAI 18-9, Procedure for Preparation of QA Major Activities Schedule,
--
Revision 0; QAI 18-10, Procedure for Preparation of Audit Reports, Revision 0
--
QADP-5, Procedure for the Performance of QA Division Audits,
--
Revision 8*
QADP-9, Procedure for Reporting Apparent Deficiencies, Revision 6*
--
QADP-19, Procedure for the Identification and Closure of Open QA
--
Items, Revision 3*
b.
Audits Reviewed (1) Engineering and Research Department Audits OP-26, Unit Nos. 2 and 3 Modification No. 886, June 24, 1977
--
-
OP-34, Unit No. 3 Modification No. 305, June 6, 1978
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OP-35, PECO Purchasing Division; August 1, 1978
--
--
OP-36, Unit No. 3 Modification No. 20A, June 2,1978 OP-31, Spare and Renewal Parts Subsection GE San Jose -
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December 29, 1977 OP-39, PECO Construction Division, May 3, 1978
--
--
OP-45, Electrical Engineering Division November 4, 1978 OP-46, Unit No. 2 Modification No. 433, November 20, 1978
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OP-47, Electrical Engineering Division, September 27, 1978
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OP-48, Unit No. 2 Modification No. 375, October 10, 1978
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OP-49, Franklin Institute Research Laboratories, March 12, 1979
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OP-50, PECO Construction Division, October 4, 1978
--
,
OP-53, Bechtel P.ower Corporation, January'3, 1979
--
.
--
OP-54, Unit No. 2 Modification No. 478, February 27, 1979
--
OP-55, Engineering Design Division, February 8, 1979 1509 253
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OP-56, ITT Geinnell - Pipe Hanger Division, February 6,1979
--
OP-57, Mechar.f cal Engineering Division, February 14, 1979
--
OP-58, Walworth Co. - Value Division, May 1,1979
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OP-60, Construction, Electrical Engineering, Mechanical
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Engineering, Research and Testing, and Electric Production Maintenance Corrective Action, April 6,1979 OP-61, McJunkin Corporation-Chester Branch, April 3,1979
--
--
OP-62, PECO Construction Division /Research and Testing, June 14, 1979
..
(2)
Electric Production Department - Ouality Assurance Division Audits 78-07, Corrective Actions (0&SR)
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78-08, Permits and Blocking
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78-22, Semi-Annual Storeroom
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78-24,' Verification of Use of Pennit and Blocking Forms
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78-28, Unit No. 2 Reactor Head Heating
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--
78-29, ISI-Pumps and Valves (0perability Testing)
78-33, ISI
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79-02, Unit No. 2 Snubber Repair
--
--
79-03, Surveillance Test System 79-06, Shift Operations Log
--
Two apparent items of ry:ompliance are discussed below.
d.
Corrective Action Associated with Audit Findings FSAR Section 17.2.B.9.d which is part of the NRR accepted Quality Assurance Program description states that the audited organization is required to report corrective action taken within 45 days of the date of the audit transmittal letter.
E&R QA Procedure r 18-6, Revision 0, requires that the transmittal letter include the number of days within which corrective action taken must be reported and stipulates a " normal" time frame of 30 days (Section 6.8.5.6).
QAI 18-6 further states that the corrective action response can be extended if requested by the audited organization (Section 6.9.3).
QAI 18-6 also requires that when a response becomes 30 days overdue a letter shall be prepared requesting an immediate report of corrective action taken (Section 6.9.5).
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.
.
The inspectors further noted that any followup actions (such as telecons or discussions) associated with the followup to audit findings were required to be documented (QAI-18-6, Section 6.9.1).
During the review of the below listed audits the inspe:: tors specifically requested documentation of any such telecons or discussions.
During further discussions with the Peach Bottom Audit Co-ordinator and the Manager, E&R OA it was determined that as of June 29, 1979 no such documentation was available.
It appears that the audited organization and E&R QA had not taken required action within the specified time frames.
The subject audits were:
Audit No.
Transmittal Response Response Request for Day Requested by Date Immediate (Days)
Reoort
- 0P-26 6-30-77 745 11-17-78 No 0P-34 6-27-78 Not Indicated 11-20-78 No O P-36 6-2-78
11-17-78 No 4-12-79 OP-50 2-14-79
5-17-79 No OP-53 1-3-79
3-23-79 No 0 P-57 2-14-79
Not Received No This failure to take prompt corrective action is an item of noncompliance at the infraction level (277/79-13-11; 278/79-5-11).
e.
Timeliness of Audit Reports Section 17.2.B.9 which is part of the NRR accepted quality assurance program description states that the licensee shall follow the
-
guidance of ANSI N45.2.12, Quality Assurance Program Auditing Requirements for Nuclear Power Plants, Draft 3, Revision 4.
ANSI N45.2.12 states that audit reports shall be issued witnin 30 days of the end of the audit.
The Engineering and Research Quality Assurance audit reports listed on the following table were issued in excess of 30 working days from the end of the respective audit.
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.
Audit Report No.
Audit Ended Report Issued OP-35 6-6-78 8-1-78
- 0P-54 11-29-78 2-27-79 OP-58 2-7-79 5-1-79 This failure to issue audit reports and associated findings is an item of noncompliance at the infraction level (277/79-13-12; 278/79-15-12).
11.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncom-pliance, or deviations.
Unresolved items identified during this inspec-tion are discussed in Paragraphs 3.b and c, 6.b, 8.b, e and f, and 9.
12.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)
on June 27 and at the conclusion of the inspection on June 29, 1979.
The scope and findings of the inspection as stated in this report were pre-sented.
The licensee verified the target dates for unresolved items as they appear in applicable paragraphs.
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