IR 05000277/1981023
| ML20038B834 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/19/1981 |
| From: | Caphton D, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20038B827 | List: |
| References | |
| 50-277-81-23, 50-278-81-25, NUDOCS 8112090140 | |
| Download: ML20038B834 (5) | |
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U. S. NUCLEAR REGULATORY QMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
50-277/81-23 Report No.
50-278/81-25 50-277 Docket No.
50-278 DPR-44 C
License No.
DPR-56 Priority
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Category C
Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia PA 19101 Facility Name:
Peach Ecctom Atomic Power Station, Units 2 and 3 Inspection At:
Delta, Pennsylvania Inspection Conducted:
October 5-9, 1981
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Inspectors:
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G. Napudi,' Reactor Inspector dats date h e-p
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Approved by:
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D. Caphton/ Chief, Management Programs date~
Section, Division of Engineering and Technical Inspection Inspection Summary:
Inspection on October 5-9, 1981 (Combined Report Nos. 50-277/81-23)
and 50-278/81-25
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Areas Inspection: Routine, unannounced inspectfon by ora region based inspector of the Quality Assurance Program (QAP) implementation.ncluding; design changes /
modifications; design change / modification controls; audits; and follow-up on previously identified items. The inspection involved 47 inspector hours onsite.
Results: Of the three areas ir +pected no items of noncompliance were identified.
Region I Form 12 (Rev. April 1977)
8112090140 811123'
PDR ADOCK 05000277 G
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DETAILS 1.
Persons Contacted
- R. Costagliola, General Supervisor - QAD J. Davenport, Engineer-Maintenance C. Endriss, Scpervisor - QAD D. Fiorello, Engineer - Stores
- E.
Firth, Assistant Mofifications Coordinator
- R. Fleischmann, Assistant Station Superintendent G. Jackman, Technical Assistant
- C. Mengers, QA Site Supervisor
- R. Moore, Superintendent - QAD W. Ullrich, Station Superintendent Other NRC Personnel
- C. Cowgill, Senior Resident Reactor Inspector The inspector also held discussions with and interviewed other administrative and technical personnel.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (0 pen) Unresolved Item (277/80-31-01; 278/80-23-01):
Evaluate all safety related items with no designation as to shelf life in order to determine shelf life requirements and establish controls for same.
Licensse representatives stated that various manuf acturers were soliciteu for recommendations and a general review of industry practices was conducted.
Based on these the Electric Production Department (EPD) has decided to follow the guidelines of publication " Materials with Limited Shelf Life",
by Garlock Corporation.
Implementing procedures for EPD and the Stores Department, applicable to both the Limerick and Peach Bottom Stations, are in preparation.
This item remains open pending further review of licensee actions as to adequacy and timeliness.
(Closed) Unresolved Item (277/80-31-02; 278/80-23-02):
Complete review of Modifications Package Material Requisition Forms and other documents associated with modificiation 79-104 that were not readily available during a previous inspection.
The inspector reviewed the modification package to the criteria specified in paragraph 4.c.
No unacceptable conditions were identified.
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3.
QA Program Review a.
References ERDP 3.6, Preparation and Review of Engineering Drawings for
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Nuclear Modifications, revision 3 b.
Review The inspector reviewed the changes made to the quality assurance procedures subsequent to the last NRC QA inspection conducted during October, 1980. These procedures are listed above and asterisked in other paragraphs of this report. The revisicr.s were reviewed to determine if they were consistent with the licensee's accepted Quality Assurance Program (FSAR Section '17.2).
No items of noncompliance were identified, however an unresolved item is discussed in Paragraph 4.d.
4.
Design Changes / Modifications Control a.
References
- -- A-14, Plant Modificiations, revision 8
-- A-26, Corrective Maintenance, revision 23
-- ERDP 3.1, Handling Q-Listed Modifications, revision 1
-- ERDP 3.3, Performance of Safety Evaluations and Applications for Amendments to Facility Operating Licenses, revision 3
-- ERDP 3.4, Design Control, revision 2
-- ERDP 6.3, Processing Documents, revision 2
-- ERDP 14.1, Use of MRF's and Modification Status Report, revision 2 b.
Program Review The documents listed above were reviewed to verify that the admin-istrative controls for modifications incorporated selected basic requirements as described in the accepted FSAR, Section 17.2.
This review, except as discussed in subparagraph d. below, verified that basic administrative controls have been established for:
-- design and modification requests;
-- design document / records control; and,
- post modification testing.
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c.
Implementation
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The inspector reviewed modification packages 80-11 (389), Replace-Core Spray Piping with Another Type of Stainless Steel; and, 81-46 (610), Replace Time Delay Relays in Control Circuits of 4 KV Busses, Diesel Generators, and Recirculating MG Sets to verify that:
-- 10 CFR 50.59 reviews were performed and documented;
-- Design changes / modifications were accomplished in accordance with the procedures;
-- the design change /modificaticn package contained the necessary
~ instructions / records with respect to the work;
-- Acceptance te: ting was accomplished and deemed satisfactory; and,
-- Procedures and drawings required to be changed as a result of the design change /medification were updated or generated (a sample).
d.
Findings A number of Maintenance Work Orders (MRFs) under which the work.was done were located by the licensee with some difficulty.
Post modifi-cation testing records for the E4 Diesel Generator and E43 4KV Bus were not located until after the conclusion of the inspection, at which time they were reviewed by the Senior Resident Inspector. The above procedures.and applicable procedures in paragraph 4.a. did not clearly describe what documents / records are to be provided with or remain in a modification package (s).
Further, the flow of documents, their identity and retention location (s) were not addressed.
IE combined Inspection Report 50-277/81-12; 50-278/81-13 identified concerns in the document / records area to which the licensee must respond.
Licensee auditors (see paragraph 5) had previously identified extensive problems corporate wide in the records system and applicable procedures.
Licensee auditors also identified incorrect execution and completion of MRFs, and corrective action is being followed up.
Discussions with licensee representatives indicated that an extensive effort has been mounted to rectify the records problem since it was identified by the QAD audit.
These examples of previously identified unacceptable conditions were discussed with the licensee. The following points were specifically discussed with the licensee.
-- written controls detailing the contant of the modification package at critical stages
-- written controls describing the flow of the modification package after it arrives onsite
-- written controls addressing documents associated with modification work and their flowpath/ retention
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A licensee. representative stated that the inspector's comments would be considered during the. revision.of procedure A-14 whict. is in an initial stage of revision.
Pending review of licensee action with respect to clarifying modification document / record control, this item is unresolved (277/81-23-01; 278/81-25-01).
No items of noncompliance were identified.
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Audits a.
References
-- QADP-5, Performance.of QA Division Audits, revision 9
- -- QADP-6, Quality Assurance Division Audit Plan-Operations, revision 6
-- QADP-8, Preparation and Use of Audit Checklists, revision 4
-- QADP-9, Control of Apparent Deficiencies, revision 7
- -- QADP-12, Performance of QA Division Surveillances, revision 7 b.
Implementation The inspector reviewed Audits A81-01PR, Post Maintainance and Modifi-cation Testing; and A81-04PR, Records Managemant; conducted by the Quality Assurance Division of plant testing activities and corporate wide records function.
The inspector verified that these audits were conducted in accordance with written procedures and checklists; with audit findings documented and reviewed; with followup action completed / initiated / closed out; and general audit conduct in accordance with established schedules and procedures.
The inspector noted that the audits identified a number of deficiencies that were of concern to the inspector during the conduct of his inspection.
This is discussed further in Paragraph 4.d.
Ne items of noncompliance were identified.
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Unresolved Items Unresolved items are matters about which more information is required to clarify whether they are acceptable, items of noncompliance or deviations.
An unresolved item is discussed in Paragraph 4.
7.
Entrance and Exit Interviews Licensee management was informed of the purpose and scope of the inspe,-tion at the entrance interview, and the findings of the inspection were period-ically discussed with licensee representatives during the inspection and with licensee management (denoted in paragraph 1) at the conclusion of the inspection on October 9, 1981.