IR 05000277/1980031
| ML19341A295 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/20/1980 |
| From: | Greenman E, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19341A291 | List: |
| References | |
| 50-277-80-31, 50-278-80-23, NUDOCS 8101220546 | |
| Download: ML19341A295 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 277/80-31 Report No.
278/80-23 50-277 Docket No.
50-278 OPR-44 C
License No. DPR-56 Priority
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Category C
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Licensee:
Philadelphia Electric Company l
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2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Peach Bottom Atomic Power Station, Units 2 and 3 Inspection at:
Delta, Pennsylvania and Philadelphia, Pennsylvania Inspection conducted:
September 30, and October 2, 3 and 6, 1980
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Inspectors:
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'G.dlapuda,ReactorInspector
/date s'igned date signed
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date signed Approved'by:
@Ob61hib n I20 / Po E. G. Greenman, Chief,' Nuclear Support date signed Section No. 2, RO&Ni Branch Inspection Summary:
Combined Inspection on September 30, October 2. 3, and 6,1980 (Report Nos. 50-277/80-31 and 50-278/80-23)
Area Inspected: Routiine, unannounced inspection by a region based inspector of i)uality Assurance Program (QAP) implementation including: Auditing, Design Changes / Modifications; and, followup on inspector identified items. The inspection involved 26 inspector-hours onsite by one region-based inspector and 18 inspector-hours at the corporate offices by one region-based inspector and a resident inspector.
Results:
Items of noncompliance - none.
Region I Form 12
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(Rev. April 77)
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l DETAILS 1.
Persons Contacted W. Baxter, Lead QA Auditor
- R. Costagliola, General Supervisor-QA (EPD)
B. Edwards, Construction Engineer
- C. Endriss, Engineer-QA (EPD)
T. Faustino, Engineer-PB Projects E. Firth, Assistant Modification Coordinator
- G. Hutt, Office Branch Head (E&R QA)
R. Lees, Group Leader-Nuclear Projects (E&R QA)
- V. Lucia, Group Leader-Audit and Administration (E&R QA)
- C. Mengers, Site Supervisor-QA (EPD)
D. Smith, Outage Manager
- S. Spitko, Engineer-QA (Station)
Other Accompanying NRC Personnel
- A. R. Blough, Resident Inspector
- C Cowgill, Senior Resident Inspector The inspector also held discussions with and interviewed other members of the Station and corporate offices administration, engineering, quality assurance and technical staff.
- denotes those present at the October 3,1980 exit interview.
- denotes those present at the October 6,1980 exit interview.
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- denotes those present at both exit interviews.
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Followup on Previously Identified Items (Closed) Unresolved Item (277/78-15-03; 278/78-19-03): Review the content of EPD QAs audit of E&R. The inspector reviewed the content of Audit 79-16
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PR, E&R Department-QA Section Activities, in order to determine if it adequately addressed the activities of the QA Section. No unacceptable conditions were identified (also reference prior Infraction 277/79-09-02;
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278/79-10-02).
(0 pen) Unresolved Item (277/78-15-06; 278/78-19-06):
Operations and Safety Review (0&SR) Connittee meeting minutes to document the safety evaluation or equivalent which was the basis for the determination made under the provisions of 10 CFR 50.59. The licensee stated that the 0&SR Committee has delegated the responsibility of reviewing safety evaluations
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that were perfonned under the provisicns of 10 CFR 50.59 to an EPD Senior Engineer. The senior engineer maintained a file of safety evalu-tions and a " status log" of this review and the status log was presented to the O&SR Committee at regular meetings subsequent to the senior engineer's reviews. The status log was incorporated into the Committee's meeting minutes if approved. A more detailed rer:ew of a modification can be initiated by any O&SR Committee member, in which case the safety evaluation, synopsis of technical presentations and Committee findings are incorporated into the minutes. The licensee believes this review system provides for a more in-depth review of significant modifications.
The inspector also reviesd a status log entitled "O&SR Review of Safety Evaluations," the file of safety evaluations maintained by the Senior Engineer-Nuclear Section and the following C&SR meeting minutes to verify this method / system of review was in effect.
O&SR Meeting Number Date 102 May 13,1980 103 May 14,1980 106 September 12, 1980 The inspector ncted that this method / system of review provides for an indirect review of safety evaluations except for those that were selected for direct review. The inspector stated that the manner in which the T.S.
required reviews of safety evaluations were being performed will be referred to NRC management for a determination on the acceptability of this method /
system employed by the 0&SR Committee. The licensee acknowledged the inspector's statement.
(Closed) Unresolved Item (277/78-15-07; 278/78-19-07):
Process jumpers and lifted leads that have been installed for extended time intervals. Tne inspector reviewed PORC meeting minutes 78-68 and noted that the remaining (see IE Inspection Report 277/79-13; 278/79-15, Paragraph 2) lifted leads /
jumpers had been evaluated, and the disposition of each had been determined.
The inspector selected jumpers #2-32-3 through 6 and #3-32-1 through 4 in order to confirm the designated action (in this case, plant modification)
was initiated / completed. The inspector reviewed a letter from the QA Engineer-Construction Division /Ganeral Superintendent-Construction Divi-sion, dated February 22, 1980 which discussed Modifications MOD 21 C and D for the applicable valves, MO 89 A and D, and the work order numbers involved. Review of this documentation showed that required actions are/
have been taken.
(Closed) Unresolved Item (277/78-15-09; 278/78-19-09):
Revision of Procedure A-27 to clarify method of material control. As a result of a reorganization which established a Stores Division the licensee has revised the system of implementing procedures for this functional activity. The inspector veri-fled that A-27, Material Control System, Revision 10 and SDA-6, Material Control, Revision 0 described the use of an " orange" and a " pink" tag and
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their use to establish positive control over acceptable and "on hold" items. The inspector verified that both procedures were consistent, in context, with each other. Additionally, the inspector toured the Stores Division's storage locations and verified proper tag usage and practices.
-(Closed) Deviation (277/79-09-01; 278/79-10-01)*:
Inspection personnel not qualified to ANSI N45.2.6-1973. The licensee's response to this item stated that a procedure would be written establishing requirements for inspection personnel and that applicable employees would be so qualified.
The inspector revfewed AP-55, General Requirements for QA Procurement and Receipt Inspectors, Revision 0 and the employee records of three randomly selected inspection personnel requiring qualification to ANSI N45.2.6-1973.
No unacceptable conditions were identified.
(Closed) Infraction (277/79-09-07.; 278/79-10-02)*:
Failure to conduct an audit of E&R QA within the required time frame. The licensee's response to this item stated that such an aJdit Would be Conducted and repeated biennially.
The inspector reviewed the audit (see item 277/78-15-03: 278/78-19-03 above) and verified that the audit is scheduled to be conducted biennailly under the cognizance of the O&SR Committee.
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(Closed) Deficiency (277/79-09-03; 278/79-10-03)*:
Failure to followup overdue responses for E&R nA audit findings.
The inspector reviewed QAI
18-6, Performing Quality Assurance Audits, Revision 1 and verified that Paragraph 6.9 was revised to detail the responsibilities and actions required to followup late responses to audit findings. The inspector also verified that QAI 17-3, Preparation and Transmittal of QA Data for Computer Input and Issuance of Computer Logs, Revision 2 described the computer followup system for audit findings. The inspector further determined that:
the computer printout to responsible QA Engineers has been implemented; memos were issued and meetings held to emphasize importance of timely followup of open items; and licensee action was consistent with the licensee's statements in their response to this item (also see items 277/79-13-11 and 12; 79-15-11 and 12 below).
(Closed) Unresolved Item (277/79-09-02; 278/79-10-02)*: Safety Evaluation for Q-List changes. The inspector verified that ERDP 3.2, Handling Q-
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Listed Modifications, Revision 4, Paragraph 6.1.6.1 requires that a safety I
evaluation be prepared and reviewed and concurred in by QA and other applicable engineering groups. The inspector also reviewed various docu-ments including letters Project Engineer / Chief Engineer-Mechanical Division (dated June 11, 1979) and Electrical Project Engineer / Project Engineer
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(dated June 1,1979) that verified safety evaluations were performed for
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the 24 ftems that predated the above requirement.
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(Closed) Unresolved Item (277/79-13-03; 278/79-15-03):
Revision of A-14 to describe a formal method for identifying new procedures / procedure changes needed as a result of a modification. The inspector verified that:
A-14, Plant Modifications, Revision 7 was issued August 29, 1979 and Section IV.C addressed this concern; Revision 8 to the procedure was a general re-write that detailed the step by step responsibilities / requirements and the phases
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that are now assigned to the processing of a modification. Additionally
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expanded checksheets are now provided for this activity.
(0 pen) Unresolved Item (277/79-13-04; 278/79-15-04):
T.S. 3.11.0 to be revised clarifying T.S. applicability to mechanical snubbers.
The inspector discussed the surveillance requirements for snubbers with the licensee and the Licensing Program Manager-NRR and the latter stated that surveillance requirements for mechanical snubbers are under development by NRR and inservice inspection requirements are to remain in effect during the interim.
The licensee stated that the designating of which snubbers in T.S. Table 3.11.D.1 are mechanical will be discussed with NRR.
The inspector will review any resulting T.S. changes in this area.
(Closed) Infraction (277/79-13-05; 278/79-15-05):
Failure of operator and shift supervisor to identify unsatisfactory results test, notify management of same and allow unintelligible data to go unchallenged. The inspector reviewed ST 10.4 performed November 5,1979 for all 11 valves and December 11, 1979 testing for valve RV-71L. No unacceptable conditions were identified.
The inspector noted that ST 10.4, Relief Valve Manual Actuation, Revision 13, in addition to the recording of parameters formerly required, now contains a matrix which requires that 5 quantitative data points be recorded and 13 qualitative parameters be checked.
The inspector verified that this is consistent with the licensee's response to this item.
(Closed) Unresolved Item (277/79-13-06; 278/79-15-06):
Procedure issuance for receipt inspector qualification requirements.
The inspector verified that A-55, General Requirements for QA Procurement and Receipt Inspectors, Revision 0 details the manner in which the licensee intends to implement the requirements of ANSI N45.2.6 (Reference item 277/79-09-01; 278/79-10-01 above).
(Closed) Infraction (277/79-13-07; 278/79-15-07; 278/79-15-07):
Failure to control storage of items in Stores Division storage area in South Warehouse-Recurrent item. The inspector toured the various storage areas and stated that:
the previously unacceptable area was significantly improved; the crowded North Warehouse met minimum storage requirements; other areas were impoved since the previous inspection; and, the foregoing was consistent with the licensee's response to this item.
The licensee acknowledged the
inspector's comrmients and stated that various offices on the first floor of the South Warehouse / Administration Building are to be vacated so that the South Warehouse can be expanded, thus relieving the crowding of the North
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(Closed) Unresolved Item (277/79-09-03; 278/79-10-03)*: Safety Evaluation for Engineering Review Requests (ERRF).
The inspector verified that:
ERDP 3.4, Procedure for Design Control, Revision 2, Paragraph 6.2.1 specifically requires that a detennination be made if the original safety evaluation is/is not affected; ERDP 3.8, Processing Engineering Review Requests, Revision 3 Paragraph 6.2.1.1 requires the responsible engineer to include this determination when processing the ERRF. A letter Project Engineer /Resoon-sible Engineers (no date) identified 15 ERRFs that involved safety related modifications and directed that safety evaluations be performed.
The inspector verified that safety evaluations were performed for the 15 identified ERRFs.
(Closed) Unresolved Item (277/79-09-10; 278/79-10-10):
Untagged Items in storage areas.
The inspector noted that SDA-6, Revision 0 allows ~one tag for bulk type items. The inspector toured the storage areas and identified no untagged items (Reference item 277/78-15-09; 278/78-19-09 above).
(Closed) Unresolved Item (277/79-09-11; 278/79-10-11): Temporary use of a non-Q motor. The temporary use of an onsite non-Q motor for one of the four Diesel Fuel Transfer Pumps was evaluated prior to its use by engineering and a PORC member as required by Procedure A-27.
This evaluation determined that the system is so designed that any one of the other three pumps could be used by way of crossover / interconnecting piping if the subject pump / motor failed. The licensee is in the process of revising the system for the procurement of catalog items with respect to 10 CFR 21 mquirements.
The first procedure in this ongoing effort is ERDP 4.6, Procurement of Catalog Items to be Maintained as Storeroom Stock, Revision 0 which details the manner in which the engineering ev::luation and procurement is accomplished.
The licensee stated that applic?. ole procedures are/will be reviewed / revised to be consistent with ERDP 4.'.
No unacceptable conditions were identified.
(Closed) Unresolved Item (277/79-09-12; 278/79-10-12): Proper Care of Items in Storage.
The inspector toured the storage areas and identified no unacceptableconditions(seeitem 277//9-13-07; 278/79-15-07 below).
(Closed) Unresolved Item (277/79-13-91; 278/79-15-01):
Revise OA Plan to reflect QA Division reorganization and new internal responsibilities.
The inspector verified that the QA Pira, Volume III, Revision 4, Section 1.2.2 describes the current QA Divisica organization and delineates the responsi-bilities of assigned personnel.
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Unresolved Item (277/79-13-02; 278/79-15-02): 0A Plan to be revised to clearly describe how 0&SR Committee accomplishes annual program review. The inspector verified that:
the QA Plan, Volume III, Revision 4,
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Section 1.2.2 describes the method of review of the QA Program by the Superintendent-QA, Station Superintendent, 0&SR Committee and the Vice t
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President and Manager of Electric Production; QADP-11, OA Division Activities
Report, Revision 8 describes the content of a bi-weekly report and its
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distribution; and, Activity Reports 80-10 through 18 were written and I
distributed as required.
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(Closed) Unresolved Item (277/79-13-08; 278/79-15-08): Review procedure detailing maintenance of electric motors in storage and implementation of the procedure. The inspector verified that: SWI-2, Periodic Testing of Stored Quality Assurance Motors, Revision 0 detailed how to do the required preventive traintenance of electric motors; the required storekeepers list of motors for 1979 was sent to the Susquehanna Areas Electric Fore-man and records indicated the work was done; and, the 1980 list was forwarded for action.
(Closed) Unresolved Item (277/79-13-09; 278/79-15-09): Review procedure for shelf life control and implementation. The inspector verified that SDA-7, Procurement, Storage and Control of Shelf Life Items, Revision 0 addresses pertinent points of shelf life for items procured after the effective date of the procedure (April 1,1980). The inspector also toured the various storage areas and verified that the procedure had been implemented. This item is closed for record purposes.
However, the inspector identified that items subject to deterioration, pro-cured and stored prior to the issuance of the above procedure, were not included in the shelf life controls, The licensee stated that all such safety related items would receive an evaiuation, their shelf life deter-mined and controls established. This item is unresolved pending review of the stated licensee actions during a subsequent inspection (277/80-31-01; 278/80-23-01).
(Closed) Unresolved Item (277/79-13-10; 278/79-15-10): Make the defini-tion of " Surveillance" consistent between the QA Program and QA Division.
The inspector verified that the QAP Glossary, Revision 4 and QAPD-12, Performance of QA Division Surveillance, Revision 7 definitions of the term were consistent with one another. The inspector also reviewed records of QA/QC Surveillance activities (see Paragraph 3 ).
(Closed) Infraction (277/79-13-11; 278/79-15-11):
Failure to take prompt corrective action with respect to adverse audit findings. The inspector reviewed audits for timely issuance of the report; required responses received; corrective action initiated / completed; and, necessary followup performance (see Paragraph 3). The inspector determined that the correc-tive actions discussed in items 277/79-09-03; 278/79-10-03 above and 277/
79-13-12; 278/79-15-12 below and the inspection results discussed in Para-
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graph 3 were consistent with the licensee's September 17, 1979 respop.a to this items (Closed) Infraction (277/79-13-12; 278/79-15-12):
Failure to issue audit reports and associated findings within the required time limit. Based on the inspection results discussed in Paragraph 3 and items 277/79-09-03; 278/79-10-03 and 277/79-13-11 ; 278/79-15-11 above, the inspector determined
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that the licensee's corrective action was consistent with their response to this item.
- These items are identified as recorded in IE Inspection Report 277/79-09; 278/
79-10 (e.g., Infraction -02, Unresolved Item -02, etc.).
3.
Audits a.
References QADP-5, Performance of QA Division Audits, Revision 9
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QADP-6, Quali'; Assurance Division Audit Plan-Operations,. Revi-
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sion 5 QADP-8, Preparation and Use of Audit Checklists, Revision 4
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QADP-12, Performance of QA Division Surveillance, Revision 5
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QAI 18-6, Performing Quality Assurance Audits, Revision 1
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b.
Audit Review The inspector reviewed the long range audit schedules to verify that the areas to be audited and the audit frequencies are consistent with Technical Specifications requirements and FSAR commitments. The listed audits were reviewed to determine that:
Written procedures or checklists were utilized during the audit.
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Audits were conducted by trained personnel not having direct
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responsibility in the areas being audited.
Audit reports were documented and reviewed by management having
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responsibility in the audited areas and by corporate management.
Appropriate followup actions, including reaudit if necessary, had
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been taken, were in progress, or were being initiated.
Frequency of the audits was in conformance with T.S. and the QA
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Program.
The audited organization responded in writing to the adverse
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audit findings.
The audits and schedules reviewed were:
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E&R QA AR-0P-109, Vendor Audit of Limitorque Corp., Lynchburg, Va. '
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OP-86, PECO Mechanical Engineering, Research and Testing and
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Construction Division CP-92, E.E. Division-Field Engineering Section
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OP.105, CB&I Activities Associated with CSC Mods 537, 538 and 529
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S-79-01, Surveillance of Concrete Expansion Bolt Inspection and
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Test Program In-house Audit Plans for PB Mods 1978-79
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In-house Audit Plans for PB Mods 1980-81
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Mod / Audit Status Log for 1980-81
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E&R QA Vendor Audit Plans for 1980
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EPD OAD 79-16-PR, E&R Department-nA Section Activities
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80-18, MOD, Minor Modifications and Interface on Major Mods
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QA Division Audit Schedule January 1980-December 1980
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QA Division Audit Plan Audit / Surveillance Coverage from November 1977-December 1979 QA Division Program Summary November 1977-December 1979
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No unacceptable conditions were identified.
4.
Design Changes / Modifications a.
References ERDP 3.1, Handling Q-Listed Modifications, Revision 1
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ERDP 3.3, Performance of Safety Evaluations and Applications for
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Amendments to Facility Operating Licenses, Revision 3 ERDP 3.4, Design Control, Revision 2
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EROP 3.6, Preparation and Control of Deisgn Calculations, Revi-
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sion 1 ERDP 3.8, Processing Engineering Review Requests, Revision 3
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ERDP 14.1, Use of MRFs and Modification Status Reports, Revision
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Implementation Review The in',pector reviewed modification package 79-104, NMS Bypass Switch Replacement for a recently completed modification to verify that:
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10 CFR 50.59 raviews were performed and documented.
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Design changes / modifications were accomplished in accordance
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with written procedures.
Acceptance testing was accomplished and deemed satisfactory.
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Procedures and drawings required to be changed as a result of
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the design change / modification were updated or generated.
The Maintenance Work Orders (MRFs) under which the work was done could not be located prior to the conclusion of the inspection. Subsequent to the inspection the subject MRFs were located in the records section where they had been sent for processing and presented to the resident inspector. The licensee also stated at tha.t. time that the records were available for the inspector's review at any mutually agreeable location. Pending the review of the subject MRFs and any other applicable documents this item is unre-solved (277/80-31-02; 278/80-23-02).
5.
Unresolved Items Unresolved items are matters about which more information is required to clarify whether they are acceptable, items of noncompliance or deviations.
Unresolved items are discussed in Paragraphs 2 and 4.
6.
Entrance and Exit Interviews Licensee management was informed of the purpose and scope of the inspec-t tion at the entrance interview, and the findings of the inspection were periodically discussed with the licensee representatives as indicated in the following summary.
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Date Reportable Details Covered September 30, 1980 Entrance Interview, 2 October 2, 1980 2, 4 October 3, 1980 2, 4, Exit Interview October 6, 1980 2, 3, Exit Interview The inspector conducted exit interviews with licensee representatives
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(denoted in Paragraph 1) where the findings of the inspection were presented and acknowledged by the licensee.
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