ML19269D064

Responds to NRC 790103 Ltr Re Violation Noted in IE Insp Rept 50-277/78-32.Corrective Actions:Addl Training Has Been Provided to Engineering Personnel Re Surveillance Tests

ML19269D064
Person / Time
Site:	Peach Bottom
Issue date:	01/19/1979
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19269D060	List: ML19269D064
References
NUDOCS 7902270097
Download: ML19269D064 (3)

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PHILADELPHI A ELECTRIC COM PANY 2301 M A RK ET STR EET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. DALTROFF ELECTRec Pn Ctions January 19, 1979 Re: Docket Nos.. 50-277 Inspection No.: 50-277/73-32 Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Brunner:

Your letter of January 3, 1979 forwarded Inspection Report 50-277/73-32. Appendix A to your letter addresses an activity which did not appear to be in compliance with Nuclear Regulatory Commission Requirements. The examples cited and categorized as a Deficiency are restated below with our response.

Technical Specification 6.8.1 states, in part: "dritten procedures and administrative" policies shall be established, implemented, and naintained. .

Peach Bottom Atonic Power Station, Quality Assurance Plan, Volume III, Operations Phase (Rev. 3) states, in part:

"17.3 Applicable... test procedures, operational procedures or other documents shall specify the quality records to be generated. All such records shall be legible, completely filled out, and adequately identifiable to the time involved." (p. 2-33)

"ST 10.3 Review and monitoring of surveillance tests shall be made and initiated by Shift Supervision, and the appropriate staff engineer to verify conforaance with documented instructions, procedures, and drawings, as part of their quality function. " (p. ST-7) 7902270 @

Mr. Eldon J. Brunner Page 2 Contrary to the above, the following exaapies of nonconformance to quality record-keeping and review were identified during this inspection:

(1) ST 3.4.1 Local Power Range Monitor (LPRM) Gain Calibration completed and reviewed on October 26, 1978, did not have attached an OD-13 LPRM Sensitivity computer printout prior to LPRM calibration, as required by Step 30 of the procedure.

(ii) ST 3.3.2 Calibration of the Average Power Range Monitoring (APRM) System to Core Thermal Power performed October 22, 1973, 1045, had a review signature, but no date of review.

(iii) ST 3.3.2 performed October 27, 1978, 0850, and reviewed Hovember 7, 1973, did not have Channels D, E, and F checked as properly adjusted.

(iv) ST 3.3.2 performed November 15, 1978, 0654, and reviewed Deceaber 5, 1973, did not contain the required entry for P-1 Periodic Core Evaluation date and time.

Response

The examples of deficiency identified as a result of JHC Inspection 50-277/73-32 have been closely examined.

ST 3.4.1 LPRM Gain Calioration completed and reviewed on October 26, 1973 did not have attached a copy of computer printout OD-13 prior to calibration. However, a copy of OD-10 OPT 7 was attached prior to the calibration. CD-10 OPT 7 also provides the LPRM Gain Adjustuent Factors which are necessary for calibration. The calibration was performed properly but through a personnel error the 00-13 attachment was omitted.

A review of the APRM calibrations referenced in conjunction with ST 3.3.2 indicates that although there were record keeping inadequacies, all calibrations were performed properly.

To avoid future iteas of non-coapliance, the following steps have been taken:

1. Additional training has been provided to the engineering personnel involved in the perforuance of surveillance tests to reinforce the necessity for completion of all documentation to provide conformance with quality record keeping and review.

Mr. Eldon J. Brunner Page 3

2. ST 3.3.2, which was part of the annual requalification oral examination recently conducted, was discussed with all licensed operators and licensed engineers.

3. Discussions were held with the personnel in the Reactor Engineering Group who are responsible for the completion and review of ST's. Emphasis was placed on the importance of a review which insures that all entries on ST's are completely and correctly logged.

We believe the above corrective actions will climinate the recurrence of this type of deficiency in the future.

Very truly yours, s _

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