IR 05000277/1988019
| ML20207B512 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/18/1988 |
| From: | Blumberg N, Drysdale P, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207B502 | List: |
| References | |
| 50-277-88-19, 50-278-88-19, NUDOCS 8808020356 | |
| Download: ML20207B512 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
50-277/88-19 Report Nos.
50-278/88-19 50-277 Docket Nos.
50-278 OPR-44 License Nos, DPR-56 Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, PA-19101 Facility Name:
Peach Bottom Atomic Power Station Units 2 and 3
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Inspection At:
Delta and Philadelphia, Pennsylvania
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Inspection Conducted:,1une 6-10, 1988 Inspectors:
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G. Napuda, Senior Reactor n-neer date
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,he/s v P. Drysdale, feactor Engin date
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7/#I/If E.~Blumberg, Chief,Oper)rnionsPrograms Approved by:
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Section, Operations Branch, DRS Inspection Su-sary:
Routine announced inspection en June 6-10 1938
[ReportNos.Vd-277/85I9and50-27878T~13)
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Areas inspected:
Implementation and effectiveness of corrective actions in thi QA Program for procurement of commercial grade items and the dedication of
these items for safety related applications; actions to resolve a concern
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about purchases from non-evaluated non-approved vendors; and, formalization of training for onsite records personnel (reference Report Nos. 50-277/S7-23 and t
50-278/87-23). Also, selected aspects of the consolidation of previously separate QA organizations were reviewed.
Results: The improvements to the procurement process met or exceeded the committments made by the licensee; were implemented in accordance with the stated schedule; and, have been effective The restructuring of the QA organization was well planned and inplemented. An indepth review of two ensite QA groups indicated their re-organization and staffing was carefully
planned and implemented.
8808020356 880719 PDR ADOCK 05000277
PNU
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DETAILS 1.0 Persons Contacted
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- 0. M. Sm'th, - Vice President, Peach Bottom Atomic Power Station
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'J. F. Franz, Plant Manager - Peach Bottom Atomic Power Station
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'O. G. Brown, Materials Superintendent
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- E. Bailey, Procurement Engineering
- W. L. Dobson, Nuclear Engineering
"T. E. Shannon, Project Manager - Peach Bottom Atomic Power Station
- 0. E. McGarrigan, Superintendent QA
'J. Goldman, Nuclear Engineering
- L. E. Myers, NRC Resident inspector
- 0. J. Foss, Compliance Engineer
"R. Biese, Gilbert Commonwealth (Contractor)
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"J. D. Kadingo, Nuclear Engineering
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'A. W. Grammes Nuclear Engineering - QAFM
- B. E. Raf tovich, NQA ( Audit)
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"M. L. Ewing, NQA - Main Office
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B. L. Clark, Superintendent, Plant Administration l
0. R. Helwig, General Manager QA Department
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R. H. Moore, Assistant General Manager QA Department l
J. F. O'Rourke, Quality Support Division Manager
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Interviews and discussions were held with other engineering, QA/QC and
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technical personnel.
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- T. P. Johnson, Senior Resident Inspector
- R. J. Urban, Resident inspector i
L. E. Meyers, Resident Inspector f
- Denotes attendees at the June 10, 1933 exit meeting.
2.0 Procurement 2.1 Scope of Review j
Ouring a recent NRC inspection (see combined NRC Report Nos.
- iO-277/87-23 and 50-278/87-23) it was identified that compone:its and t
spare parts were purchased as standard catalogue "off-the-shelf"
(i.e. comercial grade) items and then used in safety related
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applications without the prerequisite technical evaluation (i.e.
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dedication) to assure their suitability for the intended use.
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Philadelphia Electric Ccmpany (PECO), the licensee, sent two letters, dated November 20, 1997 and February 1, 1988 to the NRC that addressed the results of the subject inspection.
These letters described the corrective actions that were and would be taken to correct the identified deficiencies and concerns associated with their QA Program procurement process.
The detailed actions described by PECO in these letters can be sum.marized into the following broad categories.
A study by the QA organi:ation to determine the root cause of
the deficiency; define the scope of the procurecent problem; and, conclude what actions were necessary to correct procurement process weaknesses.
An immediate policy by station Quality Control to reject
purchase orders for ccmmerical grade items lacting an engineering evaluation for safety related applications or to non-approved vendors; and, the non-use of onsite cor.mercial grade items for safety related applications without an engineering evaluation or appropriate inspections.
The removal of eleven items from the warehouse for appropriate
evaluations and or inspections prior to safety related use; and, appropriate actions prior to plant startup for the three itees installed in the plant and the missing item prior to plant startup (all these items were examples identified in the inspection report).
Fernal engineering evaluations for all items that were coded
for safety related application that had been purchased as ccmmercial grade or from unapproved vendors prior to their use if in the warehouse and appropriate evaluations and or inspections for those items installed in the plant prior to startup. A written corrective action program would be developed for this category.
Each of the above cerrective action areas were evaluated by conducting interviews with cognizant engireering and management personnel; technical review of the evaluation docueentation that dedicated com.mercial grade items for safety related application (see Attachment A); examination sad review of activities, organizations and procedures; and a tour of the onsite warehouse that included esamination of items and observation of ongoing inspections and testing.
2.2 Observation and Findings Tne Nuclear QA Cepartetet (tG;O) concucted e ecmprehensive study to determine the tyca a.-J ei,$nt cf z eat icms in SFe precurement
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process. A corrective action program that detailed specific actions to upgrade.the procurement process was developed and provided to senior management. A major recommendation in this report was to integrate the procurement process 1.9to the plant organization. A direct result of this recommendation was the establishment of an onsite engineering group during February 1988 that reviews all new Purchase Orders (PO) and is also participating in the ongoing evaluations and reviews of previously purchased commercial grade items and procurements from unapproved vendors. Because of the large volume of work ano the need to complete needed evaluations and reviews in a reasonable time frame the group is now staffed almost exclusively by contractec engineers from an established enginearing services company.
PECO representatives stated that this group will become a permanent organizstion in the PO review process and that the intent is to have it staffed by their own employees.
The onsite Quality Control 5ection (QCS) of the NQAD issued a stop work order November 7, 1937 ?. hat prohibited the acceptance of P0s to unapproved vendors or for commerical grade items coded for safety related applications that lacted supporting documentatto^. (e.g.
evaluations, dedications). This stop work order also prohibited the release (QC Hold) of previously purchased items from the warehouse for safety related use unless such evaluations or inspections supported the item's intended use.
Ten items (see Attachment A)
originally on such QC Hold were relected for in-depth review to determine the effectiveness of tht hold strategy and adequacy of actions discussed in previous and later paragraphs.
The documentation supporting the final dispositions of the fifteen examples (see Attachment A) Itsted in inspection report 50-277/87-23 and 50-278/87-23 were reviewed and discussed with PECO representatives. Also, as applicable. the physical location of items were observed during the warehouse tour and respective hold status' were verified.
There were approximately 615 items from the total suspect population of 1300 items purcha wd prior to the subjact NRC inspection that were determined to require ev41uations and or inspections to dedicate them for safety related application.
The dedicatica process has been completed for all but about 40 items and the evaluations were ongoing.
Ten items (see Atuchment A) were selected so as to verify the adequacy of the evaluations dedicating them for safety related applications.
Document package,t were technically reviewed and discussed with cognizant pECO and contracted engineers; the physical location and hold status was observed as applicable; ongoing inspections and testing of these items was observed and discussed with *.he QC inspector and engineer on lccation; and, the validity of the hold / release status of the items were verifie _
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Procedures A-27, "Procurement Control", and EROP 4.8. "Engineering Evaluations" were reviewed and discussed with cognizant PECO personnel, who stated that additional refinement of procedures was planned to further enhance the procurement process.
The observations and findings discussed abovt; indicated that these existing procedures were being followed.
In addition to the evaluation and verification of PECO corrective actions discussed above the following effvrts were also noted, Correction and improvement of the procurement process was by a a
Nonconforming Material Project group that included the onsite Project Division, QC Section, Nuclear Engineering and Stores.
A list of suspect items was developed by QA and provided to
project management at the beginning of the corrective action e f fort.
The dedication of commercial grade items followed the
guidelines established recently by the Electric Power Research Institute (EPRI).
The status of thi: corrective action program is reviewed during
a monthly onsite meeting with the Executive Vice President Nuclear.
Based on the results of the evaluation discussed above where PECO ret or exceeded their committeents to the NRC and the acceptability of those corrective actions, (Violation (50-277/87-23-01 and 50-273/87-23-01), Failure to evaluate the suitability of commercial grade items for safety related application; and Unresolved Item (50-277/87-23-02 and 50-278/87-23-02):
Procurements from non approved vendors, are closed.
2.3 Conclusions The commissioning of the procurement study to the QA Department and the resources com.mitted to its recommendations indicate management involvement and commiteent to the improvement of the procurement process.
The study and associated report reflects a positive trend in the performance of the QA Department.
The step work actions by
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the QC Section and their continued involvement in corrective actions including the inspection and testing of suspect items display decisiveness and technical competence.
The documented evaluations and dispositions by Nuclear Engineering and Procurement Engineering personnel showed concientious application of engineering skills. Also, the dedication evaluations, inspections and or tests were documented in a clear and understandable fashion that was easily amenable to review or audit.
Overall, senior management support by allocation of resources and involvement through meetings supports PECO statements that their proposed improvements are being made to the QA Program, its implementation and personnel performance.
3.0 QA Consolidation and Interfaces 3.1 Scope of Review The basis for the new organizational configuration and assignments of responsibilities were discussed with the General Manager of the Nuclear Quality Assurance Department and several of his division managers and section superintendents.
The rationale for personnel reassignments and staff allocations were also discussed.
Particular review was directed at the Quality Control Section as it became apparent that this group was most affected by the recent consolida-tion of the previously separate QA/QC groups, Additionally, the involvement of the Technical Reviews Branch, the Technical Services Branch, and the Quality Inspection Branch with the procurement process and the dedication of commercial grade items was reviewed.
3.2 Findings and Conclusions The transition to the consolidated QA Department was well planned so as to factittate interdepartmental cooperation and communication.
Reassignments were based on specific abilities and experience.
Staffing allocations were decided on past experience and additional personnel have been requested where deemed necessary.
The certification of inspector qualifications to particular disciplines in the new Inspections Branch is ongoing.
The Quality Control Section Superintendent stated that those individuals not yet certified under the new organization are restricted to inspections they previously performed (i.e. work associated with modifications or work activities by plant maintenance personnel). The qualifications of fifteen inspectors were reviewed and discussed with the superintendent and they were found to exceed the requirements for their respective discipline (s) certificatio _ - - _ - _ _ _ _ _ _ _ _ _ _..
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,.ngoing involvement in the procurement corrective actions, of these branches reviewed, was extensive. The planned continuing and future involvement of those tranches in the procurement process was deemed to be well above a minimum level.
Overall., the current involvement and performance of the new QA Departri.ent has been improving and should continue this positive trend with continued management support.
4.0 Sy tus of Previously Identified Items f.:losed) Unresolved Item (50-277/87-23-03 and 50-278/87-23-03): Provide
'ormalized training to the onsite records personnel.
Procedure NRSI-12, iraining of Nuclear Records / Administrative Services Clerical Personnel, has been developed and issued.
It describes the minium and types of training to be given to the subject personnel.
It was verified that the procedure has been implemented.
Based on the foregning, this item is clcsed.
5.0 Management Meetings The licensee management was inforeed of the scope and purpose of this inspection at an entrance meeting conducted on June 6,1983.
The findings of the inspection were discussed with the licensee representatives during the course of this inspection. An exit meeting was conducted on June 10,1988 (see pa agraph 1.0 for attendees) at which time the findings of the inspection were presented.
At no time during this inspection was written r'aterial concerning inspection findings provided to the licensee.
The licensee did not indicate thht any proprietary information was involved within the scope of this inspection,
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ATTACHMENT A
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l 1.0 NRC Combined Inspections Report Nos. 50-277/87-23 and 50-278/37-23 Examples of Purchased Items i
Solenoid Valves, 115-92154 (previously identified incorrectly as
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115-92145)
Reitef Valves, 115-73852 Valve Operator Sprirg, 115-07408 Air Operated Valve Diaphragm, 115-20637 Valve Insert, 115-88273 Solenoid Valves, 115-94187 i
2.0 Sample to Verify Corrective Actions Piston Rod Link, 115-93715 Piston Ring Part, 115-93716 i
Lubricant, 119-14420 Heater Coil Overload Relay, 115-46418 i
0-Ring, 115-89559 o
Circuit Breaker, 115-11157 Micro Switch, 115-91841 l
Pump Parts, 115-42650, 59205 and 63825
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3.0 Documents and Procedures Reviewed i
Engineering and Research Department I
Procedure (EROP) 3.2, Maintaining, Axending and Revising the Project
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l Q-List, RV.8 and Interim Guidance 3.2.1 (3/83)
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EROP 3.4, Design Control RV.11
EROP 4.2, Processing Revisions to the Evaluated Supplies List, RV.6
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EROP 4.6, Evaluation of Nuclear Safety Relattd Catalofue Type Items for Inclusion in PECO Standard Catalogue of Materials and Equipment, RV.8
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EROP 4.8, Evaluations of Safety Related Items for Procurement From Supplies Without Approveo Quality Assurance Programs, RV 0
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Interim Guidance 4.10, Oedication of Comserctal Grade Items for Use in i
Safety Related Application (3/63)
i Procedure A-27, Material Control System, RV.20 l
Material Corrective Action Program, RV.1 i
Quality Assurance Manual, Volume !!!, RV.7
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