ML20031C007
| ML20031C007 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/18/1981 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20031C000 | List: |
| References | |
| 50-277-81-12, 50-278-81-13, NUDOCS 8110060423 | |
| Download: ML20031C007 (3) | |
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APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company Docket Nos. 50-277 Peach Bottom Atomic Power Station, Units 2 and 3 50-278 License Nos. DPR-44 DPR-56 l
As a result of the inspection conducted on May 4-8, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), it was identified in the following areas that corrective actions and management controls to ensure proper corrective actions concerning a previously ideatified Notice of Violation was inadequate; and that Technical Specification and Station Administrative Controls were not followed. The following items are separate examples which are considered collectively to be a single violation:
10 CFR 50, Appendix B, Criterion XVI, states, in part, " Measures shall be established to assure that conditions adverse to quality, such as... deficiencies, deviations
.. and nonconformances are promptly identified and corrected... The measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition... the cause of the conditien, and corrective action shall be documented and reported to the appropriate levels of management."
Contrary to the above, management controls to ensure corrective action and the corrective action taken for a previously identified item of noncompliance was inadequate, in that, the following item of noncompliance identified in our letter dated August 27, 1979 (NRC Combined Inspection 50-277/79-12 and 50-278/79-14 conducted May 21-24, 1979), Notice of Violation Item C, still existed.
Several Maintenance Request Forms (MRF's) used to document the performance of plant maintenance during the period April 29, 1978 through October 27, 1978, identified as open in the MRF Log Book on May 22, 1979 could not be located. This was contrary to the MRF flowpath established in Administrative Procedure A-26.
Continued inadequate corrective action concerning this item is evidenced by the following noncompliance:
a.
Technical Specification 6.10.1 states, in part,
"...b.
Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety (shall be retained for at least five years)..."
Contrary to the above, records of the following maintenance activities which were identified by your staff as having been completed, could not be located during the inspection and appear not to have been retained:
L OFFICIAL RECCR0 COPY 8110060423 810918 PDR ADOCK 05000277 0
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Appendix A 2
MRF 2-19-L-0-18, Fuel Pool. Cooling High Temperature Alarm Change to-100 F, shown as completed April 18, 1980 by Instrument Shop logs; MRF 2-19-M-0-3, Repair "B" Pefuel Pump Seal Leakage, shown as completed September 22, 1980 by Maintenance Shop logs; MRF 2-19-M-0-4, Repair "A" Refuel Pump Seal Leakage, shown as completed September 22, 1980 by Maintenance Shop logs; MRF 2-52L-0-33, E-401 Fuel Tank Hi/Lo level alarm will not clear, completica date could not be determined but shown as completed by Instrument Shop logs; Procedure M-10.24, RHR Pump Motor Maintenance, used for performance of MRF 2-10-M-0-65, Install New Motor on RHR Pump 2B, completed July 10, 1980; Procedure M-4.12, SRM/IRM Detector Drive Maintenance, used for performanc of MRF 3-60-M-0-53, Repair of 3D SRM Drive Unit, completed October 23, 1980; and, Procedure M-23.11, High Pressure Coolant Injection (HPCI)
Turbine Stop Valve / Hydraulic Cylinder Mainte::ance, used for performance of MRF 3-23-M-0-18, Disassembly HPCI Turbine Stop Hydraulic Cylinder, completed May 5, 1980.
In addition to the lost records noted above, the fol'.owing violations were identified concerning the administration of maintenance records:
b.
Technical Specfication 6.8.1 states, in part, " Written procedures and administrative policies shall be established (and) maintained..."
(1) Administrative Procedure A-26, Procedure for Corrective Maintenance, paragraph 3.M states, in part, "Following (its)... completion... shift supervision shall close out the MRF in the MRF log...
Placement (of completed MRF's) in the appropriate equipment history file is the responsi-bility of the staff supervisor.
This equipment history file, containing completed original MRF's associated Quality Control Conformance Data Tag, completed maintenance procedures, and A-12 forms shall become part of the permanent station records."
OFFICIAL RECORD COPY i
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Appendix A 3
Contrary to the above, the MRF's identified in item "a '
above, although identified as completed by your staff, were not being retained in equipment history file, nor were the MRF's closed out ir, the MRF log. Additionally, the completed maintenance procedures identified-in item-
"a" above were not being retained in the equipment history file.
(2)
A-26, paragraph 3, specifies the flow path for the original of a MRF from its initiation to final disposition.
Contrary to the above specified flow path, MRF 2-52-L-0-11, E-4 Diesel Generator cylinder Exhaust Temperature for No.
9 and No. 10 Cylinder-No Readings, initiated January 16, 1980, could not be located and the status of this mainten-ance could not be determined.
This is a Severity Level V Violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to this offi:e within thirty days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps'which will be taken to avoid further violations; and (3) the date when full compliance will tu achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Where good cause is shown, consideration will be given to extending your response time. The responses directed by this Notice are not subject to the clearance proceaures of the ~)ffice of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
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' &AhtX/ 6'1 Dated.
iimas T. Martin, Acting Director, Division of Engineering and Technical Inspection OFFICIAL RECORD COPY
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