IR 05000277/1987023
| ML20236H527 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/28/1987 |
| From: | Blumberg N, Dev M, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236H491 | List: |
| References | |
| 50-277-87-23, 50-278-87-23, NUDOCS 8711040181 | |
| Download: ML20236H527 (18) | |
Text
.
.
. - - _ _ _ _ _ _ _ _ _
-
i
!
U.S. NUCLEAR REGULATORY COMMISSION l
REGION I
{
j Report Nos.
50-277/87-23
!
50-278/87-23
'
50-277
Docket Nos.
50-278 l
DPR-44 l
l License Nos.
DPR-56 l
Licensee:
Philadelphia Electric Company l
<
2301 Market Street j
f Philadelphia, PA 19101 I
I Facility Name:
Peach Bottom Atomic Power Station l
Units 2 and 3 i
Inspection At: Delta and Philadelphia, Pennsylvania Inspection Conducted: August 10-14 and 17-19, 1987 Inspectors:(
R g,/
/d 2. / M h(/da ead R c Q Engineer, DRS
/ date'
.
o@
_
IO f2 S BY M. Dev, Reactor Engineer, DRS
/ dath
'
NRC Headquarters Participant:
t
R. Wharton, Quality Evaluation Engineer (NRR)
'
D Approved by:
(,
_
date N. Blumberg, Chief, Operationsf/ Programs Section, Operations Branch, DRS Inspection Summary:
Routine, unannounced inspection on August 10-14 and
.17-19, 1987 (Report Nos. 50-277/87-23 and 50-278/87-23).
Areas Inspected:
Implementation of the QA Program for Procurement, modifica-tion control, document control and records.
The ef festiveness of quality verification was also evaluated and previously identified items were reviewed.
Additionally, the status of improvements to tne Quality Assurance Program described in the licensee's Commitment to Excellence Action Plan were assessed.
Results:
One violation (failure to determine the suitability of items for safety related use, paragraph 3.3) and two unresolved items were identified.
8711040101 871022 PDR ADOCK 05000277 G
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
._ _ _ _ _ _ _
_ _ _ _ _
_ __
- -_
_
_
,
.
.
- .
DETAILS
Il.0 Persons Contacted 1 Peach Bottom Atomic Power Station (PBAPS)
.;
W. Bowers, Supervising Engineer, Electrical Engineering R. Brown, ISEG Engineer
.J. Clupp, Shift Supervisor, PBAPS Unit 2 D. Foss, Engineer, Modification Staff R. Frisby, Technical Assistant K. Hackney, Supervisor, Engineering Design Division R. Hess,. Supervising Engineer, Plant Design & Metallurgy
,
D. Honan, Engineer, Plant Design & Metallurgy i
R. King, Designer-in-change, Engineering Design Division
'
R. Lynch, Modification Coordinator, Susquehanna Test Lab F. Mascitelli, Modification Engineer
- J. McElwain, Site Supervisor, NUOPS QC
- J. Pizzola, Engineer, E&CR QA
.i S. Privitera, Elec. Design, Engineering Design Division
!
- G. Rainey,' Superintendent, Service Operations Dept.
R. Richardson, Supervisor, Document Administration Center
- D. Smith, Manager, RBAPS
'
l P. Sullivan, Engineer, Modification Staff K. Voigt, Branch Engineer, Susquehanna Test Branch F. Volz, QA Engineer, Nucleer Production
- E. Wallace, Engineer, NUOPS QC
- T.~ Wilson, General Supervisor, NUOPS QA
.
United States Nuclear Regulatory Commission (USNRC)
)
T. Johnson, Senior Resident Inspector I
- L. Myers, Resident Inspector R. Urban, Resident Inspector
- Denotes those present at the exit meeting held August 19, 1987.
j l
The inspectors also contacted other technical and administrative personnei l
during this inspection.
I 2.0 Licensee's Actions on Previously Identified NRC Concerns (Closed) Violation (S0-277/84-02-1E and 50-278/84-02-1E):
This item j
pertains to the licensee's QA records related to piant modification
<
activities.
The inspection finding item D (previously incorrectly identified as item IE) identified that the plant modification group did not incorporate records for several completed modifications in a timely
manner.
These records are required, to be transmitted to the Nuclear
)
Record Mana9 ment system for retention.
i
_
_ _ _ _ _
. _ _
_
_
--
. _ _ _.
_
_ _ _ _
_
j$'
'
-
,
!
The licensee augmented full-time staffing to review and complete the backlog of modification packages. The inspector reviewed the modification packages for MODS 270 (76-14), 368 (76-71), 271 (78-02) and 437 (78-102)
r and found that the plant modification control sheets reflected the
!
completion of the work activities and the packages contained the
' supporting documentation. The engineering drawings pertaining to M00s 510 (79-29)', 21 (80-24), 655 (81-43) and 576 (81-50) were'also found to have been revised and updated to reflect as-built configuration.
'
Based on the licensee's action and enhanced emphasis to review and complete station QA records in a timely manner and maintain them in an auditable fashion, the licensee's action is considered adequate.
This item is closed.
(Closed) Unresolved Item (50-277/85-44-07):
The licensee does not require its contractors to verify education and experience for certification of QC inspectors.
Based on the discussion in paragraph 5 that Purchase Orders now.ir. pose the requirements of ANSI N 45.2.6 - 1976, Qualifications of
Inspection and Testing Personnel; and, that QA audits routinely address
this subject. This item is closed (see item below).
(Closed) Unresolved Items (50-277/86-11-01 and 50-278/86-11-01):
'
Maintaining QC personnel training and qualification records onsite.
Based on the discussion in paragraph 5 that employee records'are maintained onsite; contractor personnel certifications are maintained onsite; and, QA audits routinely address verification of documentation upon which such certification is based.
This item is closed (see item above).
,
3.0 Procurement Program
'
3.1 References / Requirements Peach Bottom Atomic Power Station Quality Assurance Plan, Volume
--
III, Revision 6.
--
ANSI N45.2.13-1977, " Quality Assurance Requirements for Control of Procurement Items and Services for kuclear Power Plants."
NRC Regulatory Guide 1.123, " Quality Assurance Requirements for
--
Control of Procurement Items and Services for Nuclear Power Plants."
A-27, Procedure for Material Control System, Revision 16.
--
--
A-27.4, Administrative Procedure for Transfer of Equipment or J
Material to Peach Bottom from Limerick, Revision 1.
]
A-27.5, Procedure for Procurement and Control of Catalog Items, I
--
Revision 0.
-
_. -
_ _ _ _
_
!
.
p (
.,
i ERDP-4.6, Procedure for. Evaluation of Nuclear Safety Related
--
Catalog-Type Items for Inclusion in the PECO " Standards Catalog of Materials and Equipment", Revision 8.
EDRP-7.1, Procedure for Receipt, Inspection, and Storage of
--
Materials and Equipment, Revision 14.
ESI-05, Instruction for QA Division Approval of Special QA
--
Requirements for Procurement, Revision 0.
,
'
3.2 Program and Implementation Review The Peach Bottom Atomic Power Station (PBAPS) procurement program involves purchases initiated either by site personnel or the responsible Philadelphia' Electric Company (PECO) engineering person-nel.
This inspection focused on procurement initiated at the site, which primarily included spare and replacement parts. Specifically, the inspe:: tor reviewed the procurement activities related to Quality Assured Materiai (commercial grade items intended for safety-related
>
s applications).
]
The procurement program was reviewed to determine its technical adequacy and if it was being properly implemented.
The inspector conducted interviews with key personnel and reviewed records and documents related to commercial grade procurement to determine if (1) evaluations for suitability of application were being conducted; (2) supporting documentation justified safety-related applications; and, (3) acceptance criteria verified critical attributes or characteristics.
The items of particular interest were those with classification changes from " QUALITY ASSURED ITEM - NUCLEAR SAFETY RELATE 0" to " QUALITY ASSURED MATERIAL".
With the exception of those items identified in the next section, the NRC inspector determined for those items reviewed that the procurement program had been adequately implemented with regard to safety-related equipment.
3.3 Findings The NRC inspector reviewed the licensee's methods and practices for procuring Q-listed (safety-related) spare and repl6 cement parts.
During the review it was noted that classification changes, from
'
Nuclear Safety-Related to Quality Assured Material, allowed commercial grade items to be purchased for safety-related applications.
The classification change forms reviewed referenced letters from the Nuclear Operations Quality Assurance Division (corporate office) as justification for the changes. However, the referenced letters did not adequately justify the use of commercial grade spare and replacement parts for safety-related use. The letters only grantcd approval of the commercial grade purchase and noted dedication would be based on an acceptable receipt inspection.
The receipt inspection reports for most of the procurement packages
>
u_______
__
_ _ _ _ _ - _
.
,
'?i
.
.
i
.
reviewed consisted of a visual insaection of packaging for shipping l
or handling damage, a verification of_the~part number, and
' identification of the certificate of conformance (C of C).
The change in quality classification of material represents a design control measure requiring selection and review of_ suitability of-application.
The PBAPS Quality Assurance Plan, Volume III, Section SP 3.2 requires that standard, commercial (off-the-shelf) procure-
)
ments, or those which have been previously approved for a_different application to be reviewed for suitability prior to selection.
(
During the inspection', the NRC inspector identified the following instances where commercial grade "off-the-shelf" materials, parts and equipment were not reviewed for suitability of application:
(1) PO # BW 218026, PECO Code 115-92145, ASCO Solenoid Valve (2) P0 # BW 2!0672, PECO Code-115-73852, Crosby Relief Valve I
'
>
(4) P0 # BW 215582, PECO Code 115-07408, Muesco Valve Operator Spring (5) PO # S0 126022, PECO Code 115-88873, Ahomatic Valve Insert.
(6) P0 # SO 126022, PECO Code 115-94187, Aktomatic Solenoid Valve.
Failure to review the suitability of application for commercial grade items intended for safety-related use are in violation of 10 CFR 50, Appendix B, Criterion III.
(50-277/87-23-01; 50-278/87-23-01).
l The NRC inspector also noted that Aktomatic Valve Co., Inc., a j
non-ESL (Evaluated Supplier List) vendor, had been supplying PBAPS with Nuclear. Safety-Related and Quality Assured spare and replacement valve parts. This practice had occurred consistently during the six year period since 'their removal from the ESL.
Typically, quality items are not procured from non-evaluated suppliers, especially when receipt is based on the C of C.
The validity of the C of C is normally substantiated by audits, source inspection., or some other quality verification activity.
The PBAPS Quality Assurance Plan, Section SP 2.7, reflects this practice by requiring that procuremen^.
of items or services from other than " Evaluated Supplier" be control-led for the establishment of procurement requirements to assure the quality of the product.
It was not apparent to the NRC inspector that any attempt had been uade to assure the quality of Aktomatic products since their removal from the ESL.
Pending further review to determine the bases for such continued procurement, this matter is considered unresolved.
(50-277/87-23-02; 50-278/87-23-02).
_ _ _ _ _ _ _ _.
___ :
~r -
= -
-
'
f
,
,
i t, g,,.
'm
?
A<+
{
s,
-,
- g'\\,j k p
i e
,
[ [
b
'(
l c r
'
im"
'
,y, Yk
4.0 Records Management and Oocument-Control Py,og am l
f The_ basic requirements and guidelines for collection, storage and
W ' maintenatice of Quality Assurance Records,'and' Design and Procurement
,,^ :3,,
Documentation are described in:
,
T
,
,
-Technical Specifications, Paragraph 6.8 and 6.10.
l
,
-Final Safety Analysis ReportM FSAR), Appendix 0, Sections 17.2.17, j
a
'
17.2.5, 17.2.6 and 17.2.3.
!'
-ANSI N45.2-1977, Quality' Assurance.Prooram Requirercants.
t,
-ANSI N18.7-1976, Adminigrative Concrol's and Operational Quality Assuranct or the Operat'lonap ' Phase of Nuclear Power f
i Plants,
'
-ANSI h45.2.9-74, Collection,'* Storage andiMaintenance of Nuclear Power Plant Quality Assurance Resords.
-ANSI N45.2.11-73, Quality Assurance @equhp.ments for the Design of Nuclear Power Plants.
-Regulatory Guides 1.28,1 1.33, 1.64 and 1.88.
]
-Philadelphia Electric Company PBAPS QA Plan.
'
,
p 4.1 Program Review s
,
A review of the Peach Bottom Atomic Power Stetion (PBAPS) Record Management and the Document Canbrol Program was conducted to verify
that the licensee has established ar.d implemented:
Requirements 1hnd provisions to maintain stations QA records,
-
--
Responsibilities and controls for'tra6sfer, storage, maintenance j
--
/ and disposal of records, K
h V,
Administrative cuatrols to resolve discrepancies between as-built 3:f-
--
r and the design change documentation, complete the as-built je drawings in a timely manner, and assure availability of current D"
and updated design' doc 9dantation for the use_of the cognizant
.
'
functional group, and Administrative control for review, approval and update of
--
vendors information and manuals.
{
>
The licensee's procedures governing the Records Management Program
.
v
'
and the Documents Contral Program are listed ?n Attachment 1.
'
4.2 Details of Inspection
'
'
'
The inspector reviewed the records pertaining to the licensee's i
respoase to 'the previously NRC identifit.d concerns (See paragraph
'
2.0). l In addition, the licensee's docutientation for an'.or going
!
plant' modification, M00-1457 was reviewed. This modifkation
perta' ins'th the licensee's TMI Action Plan discussed in NUREG 0737, j
Item II.F.2, "Ir, adequate Core Cooling Instrumentation" and the
l
'
l Generic Letter PA-23, " Reactor Vessel Water Level Instrumentation i.
BWRs".
The licensea's compliance to rtg statory requirements related m,
i
.
t S
!,
L.
,.
- - - - - -
.
,r
-
c7 u p f
-
Q
/, j tr!
i'
'
f(
<
,
,
i:
b y
/
.
(
j 9 f \\,,1
'
)
<
, 6
< t: 3 y
<'
- \\.$
,-
-
{
t
.
l K
to QA Record Management and Dccument Control Program was verified as discusscJinthefollowingparagraphs.
signCtfc 4.2.1 n Modifications Documentation
)
,
L(
The licensbe had reviewed Generic Letter (GL) 84-23 and
'
established
{p1 and schedule to implement a modification to reduce let yl'qdication errors caused by high drywell i
,
water level "!r@ansmitters with analog transmitters.tM replace th temperature, a Accordingly, 100 1457 removed the Yarway temperature.
\\i'
q compensated reference column; rerouted the associated b <'
(
reactor level measurement instrument lines through
'
different drywel} penetrations; installed two new non-temperature cor@ensated condensing chambers; and added
,(
!
.
reactor pressure compensation to the reactor water level
<'
'
measurement.
The scope of the modification was established in the Engineering and Research Department " Design Input" for M00,1457.
'
Theinspectorreviewedthelicensee'sSafetyEvaluationforI[
this modification.
This modification improves the reactor
,
'
water level measurement for both the wide range and the
'
fuel-zone ranges.
The pressure compensation equipment replaces the Rosemount trip units with Foxboro equipment that enhances system reliability.
The pressure compensa-
,
tion increases the accuracy of the reactor water level
,
indication in the control room for pressure less than the normal 1000 psig and reduces the operators' errors in interpreting the level indication at lower reactor pr'ssure.
The new equipment prc/ ides the same actuation e
(dnctio n at the same level as the previous equipment configurat Sn.
Thus, the reliability of the new l
}
.
instrut...c _
is compatible with the Technical Specifications i
laals. Tne licensca C :: evaluated this modification against the significant hazard considerations of 10 CFR 50.92 concerning the license amendment.
The licensee determined that the repair or replacement of component or system does not result in a significant change in its safety function or significant reduction in any safety limit or limiting ( ndition for operation associated with
'
the component or system.
However, the licensee proposed a change to Table 3.2.F of the Technical Specifications,
'
increasing thereby the range of the reactor water level recorder.
The measurement errors associated with the increased range of the recorder and recorder signal are determined to be compatible with the required accuracy for the ECCS initiations. The safety evaluation concluded that this modification does not involve any unresolved safety issue of l0 CFR 50.59 or significar; hazard considerations j
,
l-t n
'
f l l
/
i
.
_ _ _ _
-.
__
_ _
-_-
__
__.
__ _______ - ___
~
.f
'
.
.
,
associated with the license amendment required by 10 CFR 50.92.
The inspector did not observe any deficiency in the licensee safety evaluation.
The licensee installed a Foxboro microprocessor for the reactor water level measurement pressure compensation ane ECCS initiation.
Electrical engineering has reviewed revised s
and approved vendor initiated configurations' software and E
configuration data base disks and developed three :ets of
)
two controlled disketts for configuration and data base for l
use by the Susquehanna test laboratory, the document
,
administration library and the electrical engineering.
The
'
licensee has also established implementing Administrative Procedure TL-05-50026, " Control and Use of all Quality Controlled and Special Quality Controlled Master Diskettes at'PBAPS".
The storage and access to these diskettos meet the requirements of ANSI N45.2.9-1979.
The inspector reviewed the licensee's nonconformance report pertaining to the installation of 1" schedule 40 pipe instead of schedule 80 pipe for this modification.
The licensee had properly dispositioned it..
Accordingly, the support system was modified and evaluated to meet the loading requirements.
Selected engineering drawings were also reviewed for as-built configuration and proper revision, and found acceptable (see Attachment 1).
The inspector also noted that the operational acceptance test for the Foxboro type S200 microprocessor was incomplete as minor hardware modifications were still in progress.
However, the licensee has divided the MOD 1457 acceptance tests into 15 phases and certain tests have been completed and accepted. -The inspector reviewed selected Technical Specifications related Modification Acceptance Tests.
Test data recording for Surveillance Test ST 2.11.08B, calibration check of PT/ PISH /PSL 2-2-3-558 was found to be questionable.
The licensee representative stated this to be a recording error made by the technician.
The calibration check was retested and rendered acceptable.
4.2.2 Audits The Nuclear Operations QA Division conducted an audit, AP87-29PR, during February 15 to April 14, 1987, to review
,
control, distribution and maintenance of PBAPS procedures, drawings and vendor manuals. The audit enumerated certain recommendations for the proper implementation of PBAPS Administrative procedures A-2, " Administrative Procedure for control and u;e of Documents", A-6, " Procedure for control of Drawings and Drawing Logs", and A-92, " Control of Vendor Manuals".
The audit concluded that the adminis-trative controls established at PBAPS for convolling
- _
_ _ _ _ _ _ - _ _ _ _ _
r m',-
,
. ;
-
p
,
,o s
m m
-
,
,
,
.
-j
.
- ,
D
'
,
!*,
,
- documents, precedures,- and drawings were adequate and
,
effectively implemented.
'
The inspector ' verified the effectiveness.of the licensee's document-administration by reviewing, records of selected'
- engineering drawings, surveillance, test reports,.special-test reports, vendor manuals,Jdetails of which are-givenLin-
~
the paragraphs that follow.
4.2.3 Vendor Documents and Procurement Records j
The inspector.. verified that the licensee document administration
~
.. library and the control room have identical control copies
'
of updated vendor manuals.
Their proper-update.and-revision were verified through the Nuclear-Record-l Management's system. computer.
Currently, the licensee is I
'
.in the process.of updating PBAPS vendor documents. A master vendor document list has been generated'and.being
reviewed;by the cognizant station discipline for its
.
accuracy, adequacy and completeness.
Following vendor-
!
manuals were reviewed.
'
a
'M-14-138-2, Modular Compressor - Gardner Denver
--
M-14-139-1, Operating Instructions, Condensate Polisher
--
M-117-7-1, Composite Instruction Book, Foxboro Company -~
'
--
Safety Grade Air Supply.
The' inspector also reviewed the procurement documentation for
Rosemount transmitters used for MODS 1419 and 1457. The i
equipment was properly receipt inspected and met the-acceptance requirements. All vendor supplied documents including acceptance test results, environmental qualification test reports, certificate of conformance and other QA records, all of which were readily retrievable.
No violations were identified.
4.2.4 Operating and Surveillance Test Records The inspector reviewed the licensee's Nuclear Record Management System (NRMS) program and verified the I
maintenance and availability of the following records at PBAPS Document Administration Center.
The completed ree rds were microfilmed and traceable through the NRMS.
No violations were identified.
ST 8.2, Station Battery Check (Weekly).
ST 17.1, MSA Filter Expiration (Monthly).
RT 8.4, Emergency Lighting Automatic Transfer Switch Test (Monthly).
SP-1021, Plant Conditions Necessary to Reload Fuel - Unit 2.
l 4-
-- _ _ _. - _ - -
--
--
f l
'
!
.l V
.
g
- SP-1015, Administrative Control for Refueling Unit 2 CR0 HCU to service after Flushing Scram Discharge Riser.
SP-1004, Setup Procedure for Uncoupling Multiple CRDs.
LER, 3-86-023, Full Scram During Turbine Shell Warming.
LER, 3-87-005, Full Scram During Turbine Shell Warming.
4.3 Document Administration Center and Plant Tours The inspector toured the licensee's Document Administration Center and Vault area and discussed the licensee's Nuclear Record Management System at PBAPS with the cognizant personnel.
The licensee prepares microfilms of all safety-related QA station records.
Duplicate copies of these records are properly identified, stored and easily retriev-able at a remote underground facility.
The vault area's temperature and humidity are properly maintained and controlled.
It utilizes Cardox System for Fire Protection. All radiographs and light sensi-tive, and safeguard information are kept in the vault.
The area is access controlled and the access list is updated periodically.
The inspector toured the reactor building, Elevation 165'-0" near panel 2AC65, and witnessed the recalibration check of PT/ PISH /PSL 2"2-3-558.
A tour of the Cable Spreading room was conducted to witness Foxboro S200 Microprocessor installation.
The test technicians were found to be experienced and trained.
The area around the equipment panel was clean and properly roped out to
<
control radioactivity contamination.
The housekeeping was adequate.
The inspector determined that the licensee's record management program was adequately organized and effectively functioning. The plants documents and data are easily retrievable. Jiowever, the inspector identified that the licensee has not established a formalized training program for the personnel performing quality control activities of record management and document control, as required by ANSI N45.2-1971, nor was there any training records to support indoctrination and training of these personnel.
Following discussion, the licensee representative stated that an informal training and indoctrination was imparted to the personnel assigned to the Station Document Administration Center.
A new employee works closely under the guidance of an experienced document control personnel to familiarize himself (herself) with the associated procedural requirements.
The licensee is currently reorganizing the PBAPS document administration management, and expressed that the training and indoctrination program would be formalized, updated and implemented once the reorganization was complete.
The individual training documentation will be accordingly updated and maintained to comply with the requirements of ANSI N45.2-1971.
Pending review of the effectiveness of the licensee's training program, this is an unresolved item (50-277/87-23-03 and 50-278/87-23-03),
i l
i
_ _ - _
.
.
5.0 Commitment to Excellence Action Plan (CTEP)
=The licensee has developed the CTEP to assure safe restart and continued operation _of Peach Bottom' Atomic Power Station.
Discussions with licensee management and technical personnel about the status of CTEP Program Elements 5.3.9.1 through 5.3.9.13 (Quality Assurance Program); review of
,
pertinent documents; and, the findings and observations discussed in other paragraphs of this report determined the s-tatus of licensee efforts which.is depicted below.
Priority Element Category *
Description Status 5.3.9.1
Establish an expanded Procedures Quality Control Opera-approximately tions Monitoring 50% complete Program for all shifts (reference paragraph 6.0)
)
5.3.9.2
Establish and implement Initial process to further conceptual integrate the QA stage functions into plant operations.
5.3.9.3
Assess the adequacy of Presently existing quality writing the deficiency reporting specification program; improve as for consultant required who will do assessment.
5.3.9.4
Review open Engineering Complete and and Research (E&R) QA corrective findings tc determine action ongoing actions needed for closecut and assign
!
responsibility for implementation
!
5.3.9.5
Review open Nuclear Developing a
.
Operations (NO) QA system to
)
findings to determine integrate i
actions needed for Category 1 closeout and assign findings into i
responsibility for CTEP with one implementation finding open 5.3.9.6
Closecut open Category In process, 1 E&R QA findings see 5.3.9.4
,
I
.
.
- _ _ _ - _ _ _
_ _ _ _ _
_ _ _ _ - _ _ _ _ _ _ _
i
.
.
Priority Element Category Description Status i
5.3.9.7
Reduce backlog of open No action yet
Category 2 E&R QA findings 5.3.9.8
Assess the processes by No action which E&R QA findings taken yet are tracked and reviewed, and appropriate actions in response are decided upon, monitored and closed out.
Identi fy improvement opportu-nities and implement appropriate improvements.
-
5.3.9.9 1 ^
Closecut open Category One remains
-
1 NO QA findings open.
Combined with 5.3.9.5 5.3.9.10
Reduce current backlog Not formally of open Category 2 No started, but QA findings eudits continue to address appropriate open items 5.3.9.11
Assess the processes by Initial which.N0 QA findings conceptual are tracked and re stage viewed, and appropriate actions in response are decided upon, monitored and closed out.
Identi-fy improvement opportu-nities and implement appropriate improvements 5.3.9.12
Expand the role of NO Now using QA in audits of technical j
Technical and perfor-specialists l
..
mance based activities to assist on
.l
'
l audits, obtaining
]
Nuclear Review i
Board (NRB) member approval of audit i
i (
,.
!
-
- - - _ _ _ - - - _ _
_ _ _ _ _ - _
_
,
.
Priority Element Category Description Status plan, observing work including backshifts during audits, and providing additional training to auditors in activities audited 5.3.9.13
Assess the need to Initial Change the existing conceptual scope of QA to stage encompass non-safety related equipment, systems and operations
- Category 1 - Activities which must be completed prior to restart.
- Category 2 - Activities which must start prior to restart (with planning and resources defined for completion of activities) but may not be. completed until after restart.
- Category 3 - Activities which require long-term implementation, may or may not be started prior to restart and will not be completed until after restart.
The conclusions of the assessment are that licensee actions are pro-gressing in an orderly fashion consistent with established priorities.
No violations or deviations were identified.
6.0 QA/QC Overview and Quality Verification An assessment of the QA/QC organizations and their activities was performed with respect to the enhancements and improvements the licensee described in their Committment to Excellence Plan (see Paragraph 5) and is discussed below.
6.1 Quality Assurance Division - Nuclear Operations The Nuclear Operations Quality Assurance Division (N0QAD) inspects, monitors (QA/QC Surveillance), and audits those activities affecting I
the quality of items and or work important to safety.
The division is composed of a QA Training Section, Quality Control Section, QA Engineering Section and QA Audit Section.
An onsite QC Monitoring Group is currently in the planning stag _ _ _ _ _ _ - _ _ _ _ - - _ - _-_- --________ - ____
._
_ _
_
- -__
_.
-
.
...
6.1.1 Quality Control Section The Quality Control Section is composed of two groups, one each located at the Limerick Power Station and the Peach Bottom Power Station (PBPS).
The 23 inspection personnel located at P8PS are nearly evenly divided between licensee employees and contractors.
The site QC supervisor and QC Engineering Staff are licensee employees. A random sampling of onsite empi 9es background documentation and interviews with selected idividuals indicated them to be well qualified for their a signed duties.
Inspection personnel provided by contracted vendors are certified to be qualified by the vendor and audits are conducted on this aspect of the vendors QA Program.
Inspection points are established in appropriate procedures or maintenance work requests by engineering personnel and concurrence and or revision to these inspection points are made during review by QC Engineers. A second level of overview, " monitoring",
is performed over the same functional areas as those that are inspected.
It was noted that monitoring of HP/Radwaste activities was done by Senior HP Technicians who are rotated into QC for nine month assignments. Also, the monitoring of operations activities (e.g. blocking permits, Limiting Conditions of Operations) is performed by loaned plant operators who are in the final stage of training as candidates for NRC licenses.
The accomplishment of inspections was verified during the review of other functional areas as discussed in paragraph 5.0.
6.1.2 Quality Assurance Audit Section The Audit Section is composed of three groups, one at each of the power stations and one located at the licensee's of fsite corporate offices.
The supervisor and five of the onsite PBPS QA Audit Group are licensee employees while two are contractors.
This group conducts audits and monitoring of onsite activities otner than those associated with modifications.
This group also has cognizance of the computerized corrective action system that tracks all items requiring action such as adverse audit and mcnitoring findings and recommendations; NRC bulletins, letters and reports; INPO findings; and Licensee Event Reports. The voluminous printout of open items was reviewed and selected items were evaluated in depth to determine the adequacy and timeliness of the corrective actions.
It was noted that there has been recent improvement in all aspects of the corrective action systems, including reducing the backlog cf open items, and this is consistent with the stated intent of the licensee to improve their performance.
_ _ - -__ _ _
_
_ _ -
_ _ _ _ _ - _ _ _ _
,
.
Another program improvement is that the status of open
.
'
items is periodically checked and corrective action is physically verified. Audits were being generally conducted in accordance with the established schedule and in accordance with established requirements (checklists, report issuance, etc.).
6.1.3 Quality Control Monitoring Group The status of the effort to establish an onsite QC-Monitoring grcup that would be dedicated to only overview of operations activities was reviewed.
The method of i
monitoring (e.g. checklists, procedures) is under development and 14 functional areas have been identified for this overview. Job descriptions have been developed and the group is.to consist of an onsite supervisor and five individuals who will report directly to the Superintendent of N0QAD.
Twelve subtasks and their milestones necessary to complete this effort have been established and are being tracked with an anticipated completion date of October 1987.
Currently, an Operations Monitoring team has been formed and the control room is under observation at all times by one or another member of the team.
6.2 Quality Assurance Division - Engineering and Research Department The Quality Assurance Division (QAD) of the Engineering and Research Department (E&RD) is comprised of a Field Section and an Office Section.
The Field Section is located at the Limerick Station.
The Office Section consists of a Project Branch with a onsite PBAPS Group and an offsite Office Group; and a Technical Services Branch located offsite (i.e., corporate offices). This division performs audit and monitoring overview of all activities associated with design changes / modifications including vendor control.
6.2.1 Peach Bottom Group The Peach Bottom Group was established onsite approximately l
one year ago and now consists of a supervisor and eight i
engineers.
The supervisor had recently requested l
management to approve an additional position and
anticipates a complement of ten prior to the end of this year.
These engineers conduct audits and monitoring of 21 l
specific areas that coincide with a like number of established procedures. Matrices of these areas and number of weeks in a year are used for scheduling purposes.
This is permissible since the 21 procedures were developed to address specific functions (e.g., valve installations, l
l.
I
,
_
_ _ _. _ _. _--_-___ _ _
- '
.
cable installation, core boring / drilling, temporary penetration sealing, field welding).
Checklists are used for both audits and monitoring with the latter overview accomplished on a monthly basis for all active areas. When a hardware type oi deficiency is identified the work organization, issues a Nonconformance Report (NCR) while an audit / monitoring finding is issued by the Peach Bottom
Group for procedure / program problems.
Either type of corrective action is tracked and verified as being accomplished. This onsite group has developed an internal'
trending program that has all indications of being a i
valuable tool in anticipating potential problem areas and affording a logical basis to adjust overview efforts.
However, it could benefit by incorporating a weighting factor as to the safety. significance of an adverse finding.
The Office Group and Technical Services Branch overview efforts are discussed in paragraphs 6.3 and 6.4.
6.3 Construction Quality Control Group The Construction QC Group, within the Construction Division is responsible for inspections of items and work associated with onsite-modification activities. The supervisor is a licensee employee, while the eight inspectors are contractors.
Certifications of
'
individual inspectors are maintained onsite.
Purchase Orders for j
inspector services contain provisions for adherance to ANSI N45.2.6-1976, Qualification of Inspection and Test Personnel.
The
'
vendors are surveyed, approved and periodically audited for compliance to requirements. Audit checklists for several vendors were reviewed and all contained attributes addressing the verification of personnel certifications.
It was noted that the corrective action-system contained a number of items related to the
)
qualification of inspectors by audited vendors.
6.4 Findings Conclusions of this assessment were that:
i
-- the onsite presence of QA/QC personnel has been significantly increased.
-- the observation of ongoing activities has been emphasized in both auditing and monitoring by the two QA organizations.
-- the backlog of open corrective action items is being reduced and followup is becoming more aggressive.
-- the status of the QC Monitoring effort is consistent with the expected completion date.
-- the effectiveness of the quality verification effort is improving.
No violations or deviations were identified.
i
- - _ _ _ _ _ _ -
_ - _ _ -
!
f
[-
q l-l
I
!
i I
..
I
!
l
.7.0 Unresolved Items l
Unresolved items are matters about which more information is required in j
order to ascertain whether they are acceptable, deviations or
{
l violations. Unresolved items were identified and discussed in l
l paragraph 3.3 and 4.3.
l 8.0. Management Meetings The plant management was informed of the scope and purpose of this
inspection at an entrance. interview conducted on August 10, 1987.
The.
<
findings of the inspection-were periodically discussed with the licensee's cognizant representatives during the course of this inspection.
The exit 1nterview wer conducted on August 19, 1987, at which time the findings of the inspection were presented (reference Paragraph 1 for attendees). The licensee did not indicate that any proprietary information was contained within the scope of this inspection.
At no time during this inspection was written' material provided to the
'I licensee by the inspectors.
,
v._.______.___.__
._. _ _.. _. _. _. _
. _ - _ _ _
..
.
ATTACHMENT 1 i
Documents Reviewed TL-05-50026, Control and Use of All Quality Controlled and Special Quality Controlled Master Diskettes at Peach Bottom A.P.S., Rev. O,
A-92, Control of Vendor Manuals, Rev. 1 Safety Evaluation for Modification 1457, Rev. 3, Reactor Water Level Instrument Line Reroute and Pressure compensation,
!
'
Audit Report AP87-29PR, Document / Draw.r.g Control & Vendor Manuals Control, April 14, 1987 Engineering Drawings:
.
i 6280-M-1-EE-461-2, Functional Diagram, Reactor Water Level - Fuel Zone (Pressure Compensation Cabinets) Sheet 7, Rev. 2, August 6, 1987 6280-M-353-S, Shee: 2 Nuclear Boiler Vessel Instrumentation, Rev. 5, July 1, 1987 6280-M-352 Sheet 1, Nuclear Boiler Vessel Instrumentation, Rev. 21,
!
April 16, 1986 6280-M-367, Containment Atmospheric Control System, Rev. 28, December 16, 1986 6280-M-356, Control 90d Drive Hydraulic System, Rev. 31, August 9, 1986 i
6280-M-361, Residual Heat Removal System, Rev. 29, October 29, 1986 6280-M-295, Sheets 52, 56 and 58, Critical Small Piping Isometric Inside Drywell Unit 2 11187-M-295, Sheets 49, 50, 55 and 83, Critical Small Piping Isometric Inside Drywell Unit 2
,
d
--___ _ _ _ _ _ _ _ _ - - _ _