IR 05000277/1986011

Insp Repts 50-277/86-11 & 50-278/86-11 on 860407-11.No Violation Noted.Major Areas Inspected:Qa & QC Program Changes to QA Audit Program,Receipt,Storage & Handling of Equipment & Matls Program & Procurement Control Program

ML20205T147
Person / Time
Site:	Peach Bottom
Issue date:	05/30/1986
From:	Dev M, Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205T133	List: IR 05000277/1986011 ML20205T128
References
50-277-86-11, 50-278-86-11, NUDOCS 8606130064
Download: ML20205T147 (8)

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U.S. NUCLEAR REGULATORY COMMISSION Region I 50-277/86-11 Report No /86-11 50-277 Docket No Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station, Units 2 and 3 Inspection At: Delta, Pennsylvania Inspection Conducted: April 7-11, 1986

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Inspector: mv 52( 66>

M. Dev, Reactor Engineer / dafe App oved By: . W Dr. P. K. Eapen, Chief,' Quality Assurance Section D ~

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date Inspection Summary: Inspection conducted on April 7-11, 1986 (Combined Inspection Reports 50-277/86-11 and 50-278/86-11)

Areas Inspected: Routine, unannounced inspection by one region-based inspector of QA and QC Program Changes, QA Audit Program, Receipt, Storage and Handling of Equipment and Materials Program, and Procurement Control Progra Results: No violations were identifie $$bDO G

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DETAILS 1.0 Persons Contacted Philadelphia Electric Company J. Casey, Electric Production (EP) Quality Assurance (QA)

R. Fleischmann, Peach Bottom Atomic Power Station (PBAPS) Manager K. Mandl, Ccrporate QA Supervisor

• J. McElwain, PBAPS QC Engineer

• D. Smith, PBAPS Superintendent (Operation)

E. Trimball, PBAPS Storekeeper

• T. Wilson, PBAPS Site QA Supervisor S. Wookey, PBAPS Training Coordinator U.S. Nuclear Regulatory Commission

• P. Eapen, Chief, QA Section

• T. Johnson, Senior Resident Inspector

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• T. Silko, Reactor Engineer H. Williams, Resident Inspector

• Denotes those present at the exit meeting on April 11, 1986.

2.0 Follow-up of Previous NRC Concerns (Closed) Unresolved Item (50-277/79-09-06 and 50-278/79-10-06): Estabitsh and implement the QA program to trend defects and nonconformance The licensee has established the QA Tracking and Trending System Instruc-tion,.ESI-02. Accordingly, various groups such as Quality Assurance, the Operating Experience Assessment Committee (0EAC), the Nuclear Review Board (NRB), the Plant Operating Review Committee (PORC), Maintenance, and the Independent Safety Engineering Group (ISEG) perform statistical analysis as well as individual investigations to track significant nonconformances and dafects. The Computerized History and Maintenance Planning System (CHAMil); Minutes of Meetings of the OEAC, PORC and NRB; and investigative reports such as the Licensee's Event Reports are the basis for the genera-tion and documentation of QA Trending at PBAP Based on the review of the implementation of the licensee's Quality Assur-ance Tracking and Trending Program this item is close (Closed) Unresolved Item (50-277/83-30-01 and 50-278/83-18-01): Provide the QA coverage of contracted service _

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The licensee has revised Quality Assurance Department Procedure (QADP)-6, Quality Assurance Division Audit Program - Preoperational and Operational Phase, to require audits and surveillances of quality related activities performed by the contractor The scope of the revised program includes QA coverage of first time con-tractors performing safety-related activities described in Appendix A of the procedur Based on the review of procedure QADP-6, Rev.10, the inspector determined that the licensee has adequately resolved this ite This item is close (Closed) Inspector Followup Item (50-277/83-30-02 and 50-278/83-18-02):

This item identified that EP QA was not providing timely information to the upper management concerning the status of the open audit Noncompliance Reports (NCRs).

The licensee provided evidence that all unsatisfactory findings documented by EP QA are controlled in accordance with QADP-9, Procedure for Control of Findings. In addition, a bi-weekly Activities Report is generated and forwarded to the upper level management for review and appropriate action, as required. The inspector reviewed a bi-weekly report and noted that the status of open audit NCRs are distributed to appropriate upper level management personne Based on this review the inspector determined that the licensee's action adequately resolved this item. This item is close (Closed) Inspector Followup Item (50-277/83-30-03 and 50-278/83-18-03):

Establish a consistent format for the presentation of recommendations in EP QA Audit Report The licensee has revised QADP-5, " Procedure for Performance of QA Division Audit", Revision 11 to add a " Recommendation" section. This section esta-blishes a consistent format for the presentation of recommendations in EPQA audit report Based on the review of QADP-5, Rev. 11 and selected EP QA Audits, the inspector determined that the licensee's action is adequate to resolve this item. This item is close (Closed) Deviation (50-277/83-32-01): This item pertains to the licensee's failure to implement records management in accordance with ANSI N45. The licensee's corrective actiun program was to increase the work force to expeditiously reduce the document backlog. This action assured that the documents were reviewed, dispositioned and retained as required by the Station Administrative Procedure A-46.1, which implements the requirements of ANSI N45.2.9. Exhibit A-46.1-1 to this Administrative Procedure has

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been revised which delineated PBAPS document responsibilities by Work Group and indicated maximum retention time for related documents by the cognizant group prior to their transmittal to the Nuclear Records Management Syste Based on the review of the licensee's action, the inspector determined that the licensee met the intent of ANSI N45.2.9. This item is close (Closed) Noncompliance (50-277/84-22-07): This item pertains to the licensee's failure to provide annual recertification of two QC inspector The licensee has revised the Procedure for Certification of QC ' Inspectors, CD-1 This revision establishes the medical recertification of QC in-spectors by a medical professional. In addition, the Supervisor's Evalua-tion Form (Exhibit CD-10.1-III) documents the recertification and requali-fication of the QC inspectors based on their job related competenc Based on the review of the licensee's implemented actions, the inspector determined that the licensee's recertification program for the QC inspec-tors is adequate. This item is close .

3.0 Licensee's Annual Quality Assurance Program Review 3.1 Audits Program The Peach Bottom Atomic Power Station (PBAPS) QA Program, Revision 5, and the Final Safety Analysis Report (FSAR) Appendix 0, Section 0.11, Revision 3, establish the responsibilities for the conduct of QA audits and surveillances during the operations phase. The prerequisites associated with qualification of auditors are delineated in QADP-1 The auditors are required to prepare an audit checklist in accoroance with QADP-8 to insure depth and continuity of audits and inclusion of verification of corrective action for previously identified deficien-cies, nonconformances and observations in accordance with QADP-1 Subsequent to the conclusion of the audit, an audit report is gener-ated and any noncompliance is documented in the Finding Control Form in accordance with QADP-9. Upon approval of the audit reports by the Superintendent, QA Division, the reports are distributed to the Vice President, Electric Production; Manager, Nuclear Production; Station Manager of the audited station; QA Division site offices; responsible management of the audited organization; Vice Presidents of Audited Organizations outside of the Electric Production Department; and the Nuclear Review Boar The inspector reviewed the following selected EP QA audits for their program compliance. The audit reports included acceptable findings, acceptable reaudit findings, unacceptable reaudit findings, observa-tions and recommendations. The audit findings were properly documented and the responses thereto included corrective actions, statements of cause, corrective actions to prevent recurrence, and a scheduled date

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of compliance. The inspector noted that the EP QA auditors had re-viewed and verified the implementation of the corrective action. The audit noncompliances were properly dispositioned and accepted by the Audit QA Supervisor. The QA Division publishes biweekly status re-ports of the non conformances identified during EP QA audits and sur-veillances. This status report is transmitted to the upper level management in accordance with QADP-9 for information and appropriate actio The inspector reviewed the following EP QA Audits:

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AP 85-82-TR, Non-Licensed Operator Training /Requalification

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AP 85-83-TR, General Employee Training / General Respiratory Training

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AP 85-101-TR, Training and Qualifications of PBAPS Technicians, Maintenance Craftsmen and Quality Control Personnel

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AC 85-113-PR, Calibration and Control of Measuring and Test Equipment

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AP 85-33-PR, Record Management

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AP 85-93-MEM, Corrective Maintenance Program

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AP 85-91-PR, Corrective Action Program

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AP 85-02-SP, Material Procurement and Storage The inspector reviewed the deficiencies and observations identified in these audits and four.d that the related licensee's dispositions were adequate and timely. For example, EP QA in Audit AP 85-93-MEM identified that PBAPS was using Equipment Trouble Tags (ETT) to ini-tiate corrective maintenance without any administrative controls. As a corrective action the licensee developed an Instruction for Com-pleting the Peach Bottom Equipment Trouble Tag to Initiate Corrective Maintenance, an appendix to the Station Administrative Procedure A-2 This Administrative procedure is presently in the station review pro-cess. The effectiveness of the implementation of this instruction will be reviewed in a future NRC inspectio .2 Receipt, Storage and Handling of Equipment and Material The licensee has developed and implemented the Station Administrative Procedure A-27, Procedure for Material Control System for procurement, receipt and issuance of spares and replacement parts, materials and services for safety-related equipment. The procedure delineates the methodology for initiation of procurement orders, technical require-ments, environmental qualification, codes and standards requirements, f

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Quality Assurance requirements, equipment safety class designation, supplier selection, shipping and packaging, receipt inspection, and resolution of nonconforming items. The PBAPS Quality Control Instruc-tion (QCI)-020, provides instruction for the establishment of QA requirements in the procurement document The vendors are selected from the licensee's Evaluated Suppliers List. Any revision to a pur-chase order is reviewed for the original requirements of the specifi-cation along with other requirements such as safety evaluations, en-vironmental qualification reviews, equipment history files, plant modifications, and review of the previous order In addition, PBAPS QCI-017 provides for the quality review of the requisition and pur-chase order and generation of the receiving inspection checklist to verify that the equipment complies with the requirements established in the purchase documents. The receipt inspection and the review of procurement documentation for items classified as quality assured nuclear safety-related and quality assured materials or catalog items are conducted in accordance with the Station Instruction PBAPS QCI-01 The inspector reviewed the procurement and receiving inspection docu-

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mentation for the following selected stored items and found them in complianc Impeller Hub, SO 120671

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Socket-Agastat, BW 213077

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Transformer-Cutler & Hammer, GS 392204/50 120690

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Wedge, BW 369062, Code 11573062

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Solenoid Valve-ASCO, BW 298170, Code 11573062

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Gasket, BW 299106, Code 11594395

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0-Ring, GS 388896/S0 120660

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Gasket, BW 298656, Code 11532938

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0-Ring., BW 213257, Code 11587681 The inspector also reviewed the documentation of the following Mea-suring and Test Equipment utilized by the QC Inspection personnel and found the equipment calibration and issuance in orde Hartsonic Gage, 36-0055

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Torque Meter, 54-0197

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Torque Meter, 54-0190

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Torque Meter, 54-0192

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Torque Wrench, 54-0181 The inspector randomly selected qualification and certification docu-mentation for five QC inspectors / engineers. The licensee conducts training, qualification and certification of all EP QC personnel in accordance with QA0P-100. The QC inspectors were provided basic training and job specific classroom training related to electrical and mechanical disciplines. Also, on-the-job training was instituted

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to reinforce formal class room trainin Based on their qualification, experience, education, training, medical examination, and performance evaluation, the QC inspectors were certified as Level I, Level II or Level III. The QC inspectors (PECo employees as well as contract personnel) were adequately qualified and trained for their respective certification level to conduct assigned quality control activities at PBAPS. However, the training completed by two QC inspectors was not adequately documented. The licensee representatives indicated that the relevant training documents were available in the corporate ar-chive This item is unresolved pending licensee action to update site QC personnel training and qualification records (50-277/86-11-01 and 50-278/86-11-01).

4.0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, or violations. An unresolved item identified during this inspection is discussed in Para-

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I 5.0 Exit Meeting The inspector met with licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on April 11, 1986 to summarize the scope and findings of the inspection as described in this repor At no time during the inspection was written material provided to the licensee by the inspecto I A _ _ _ _ _ _ _ _______ _

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REFERENCES Peach Bottom Atomic Power Station (PBAPS) Final Safety Analysis Report (FSAR), Section 17.2, Operational Quality Assurance, Revision 3 QA Program Manual, Revision 5 QADP-5, Procedure for Performance of QA Division Audits, Revision 13 QADP-6, Quality Assurance Division Audit Program - Preoperational and Operational Phase, Revision 10 QADP-8, Procedure for Preparation and Use of Audit Checklist, Revision 7 QADP-9, Procedure for Control of Findings, Revision 12 QADP-19, Procedure for the Identification and Closure of QA Open Items for PBAPS & LGS QADP-29, Procedure for Written Evaluations of Changes Made to the QA Program Described in the LGS and PBAPS FSAR PBAPS Administrative Procedure A-26, Procedure for Corrective Maintenance, Revision 1 10. PBAPS Administrative Procedure A-27, Procedure for Material Control System, Revision 14 11. ESI-02, Instruction for Data Input to Quality Assurance Tracking and Trending System, Revision 0 1 PBAPS QCI-010, Instruction for Determining the Environmental Qualification Requirements of Materials, Revision 1 1 PBAPS QCI-017, Instruction for QC Review of Purchase Orders / Requisitions and Generation of Receiving Inspection Checklists and/or Instructions, Revision 0 1 PBAPS QCI-018, Instruction for Receiving Inspection and Vendor Document Package Review, Revision 0 1 PBAPS QCI-020, Instruction for the Establishment of QA Requirements in Procurement Documents, Revision 1 l