IR 05000277/1982007

IE Insp Repts 50-277/82-07 & 50-278/82-07 on 820420-21 & 26-30.No Noncompliance Noted.Major Areas Inspected:Qa/Qc Organization & Administrations & Design Change Mods

ML20054G913
Person / Time
Site:	Peach Bottom
Issue date:	05/26/1982
From:	Caphton D, Eapen P, Napuda G, Shaub E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20054G900	List: IR 05000277/1982007 ML20054G899
References
50-277-82-07, 50-277-82-7, 50-278-82-07, 50-278-82-7, NUDOCS 8206220404
Download: ML20054G913 (16)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos. 50-277/82-07 50-278/82-07 Docket Nos. 50-277 50-288 ' License Nos. DPR-44 C DPR-56 Priority - Category C License: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania Facility Name: Peach Bottom Atomic Power Station, Units 2 and 3 Inspection At: Delta and Philadelphia, Pennsylvania Inspection Conducted: April 20 - 21 and 26 - 30, 1982

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Inspectors: [I w[- & 76* } L date hG.Napuda,ReactorInspegtor 7r A 9 7G P f.K.Eapen,Ph.D.,ReactorInspector date

  ~ &RxT. Shaub, Reactor Inspector sm a date
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y . Approved by: 2ir 8[[/V)  ! I [ h D. L. Ca#htoh, Chief', Management Program (ate ' Section, OETP . Inspection Summary: ! Inspection on April 20 and 21 and 26 - 30, 198 (Combined Inspection Report No. 50-277/82-07 and 50-278/82-07).

Areas Inspected: Routine, unannounced inspection by three region-based l inspectors and a supervisor of QA Program implementation including annual , QA Program review; QA/QC organization and administration; onsite organization and administration; personnel qualifications; design change / modifications i and facility modifications; and licensee action on previous inspection findings. The inspection involved 80 inspector-hours onsite and 66 inspector-j hours at the corporate office by three region-based inspectors and one j superviso PDR ADOCK 05000277 Q PDR

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Results: No violations were identified in the six areas inspecte .

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DETAILS 1. Persons Contacted C. Andersoa, Branch Engineer, Suseughanna Test Group, Results and Test Division

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T. Baxter, QA Engineer - Engineering and Research Department (E&R) W. Bierely, Senior Licensing Engineer - Nuclear Section W. Bowers, Group Leader - Peach Bottom Control Group R. Carr, Senior Technical Assistant - Results and Test Division

* J. Castagliola, General Supervisor - QA Division, Electric Production Department (EPD)

M. Cooney, Superintendent. Nuclear Section A. Diedrich, Project Engineer - Mechanical and Electrical Division

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C. Endriss, Engineer - QA - EPD

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R. Fleishmann, Assistant Plant Superintendent L. Keenan, Engineer - Results and Test Division C. Mengers, Site Supervisor QA-EPD

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R. Moore, Superintendent QA-EPO P. Pavlides, Manager QA-E&R L. Pyrih, Supervising Engineer - Licensing E. Roth, Foreman - Training and Testing D. Smith, Modification Coordinator

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S. Spitko, Site QA Engineer S. Sykes, Lead Staff Engineer - Results and Test Division W. Texter, Engineer - Maintenance Division, EPD W. Ullrich, Plant Superintendent J. Wheeler, Acting Training Coordinator Contractors: R. Burton, Startup Engineer - Becthel USNRC

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A. Blough, Resident Inspector

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C. Cowgill, Senior Resident Inspector The inspectors also interviewed other licensee personnel during the course of the inspection including engineering, maintenance, technical support, and quality assurance personne * Denotes those present at the exit interview on April 30, 198 . .

2. Previously Identified Items (Closed) Deficiency (278/77-16-04). The inspector reviewed surveillance test ST12.5-1, Integrated Leak Rate Test, Revision 2, and discussed the procedure with cognizant Results Engineers. The subject root valve and its position for various test phases has been incorporated into Appendix D of the procedure. The inspector had no further questions with respect to the licensee's corrective action as stated in their letter of May 12, 1977, in response to the NRC's letter of April 21, 1977, or the procedure's descrip-tion of the test methodolog (Closed) Unresolved Item (278/79-07-01): Review the vendor's evaluatien and licensee's acceptance of defective welds. The inspector reviewed the vendor's " Summary Report of resolution and corrective actions for Philadelphia Electric Company Audit Finding OPS 2 - 4." The report detailed the testing of seam weld samples; the analyses of stress loads; and the results of actual weight loadings simulating stress loading. The conclusions were that the poison cans as welded were acceptable, based on overall analyses and results such as: the welds had no structural, only a leak tight function; the cans could more than withstand inservice pressure / stress conditions; the vacuum and pressure leak test used for acceptance purposes exceeded inservice adverse conditions; and overall analyses / test results qualified the welds for their intended purpose. The vendor also detailed actions taken to prevent recurrences such as: weld insnector training; inspections; and, qualification of a new weld procedure. The licensee's audit findings were closed, based on acceptable followu Based on the above this item is close (Closed) Unresolved Item (278/79-07-02): Verification of traceability of boral on a sample basis during receipt inspection The inspector reviewed documentation of licensee action with respect to onsite verification of boral traceability. Licensee engineering reviews of documentation for racks A-22565-52-E, A-22565-51-E, A-22565-50-E, and A-22565-28-E, -31-E,

-32-E, -35-E, -40-E, and -45- The inspector also reviewed the installa-tion records for Rack A-22565-19-E (an installation record package exists for each individual rack) which included an Installation Report, installation checkoff sheets, receipt inspection and storage reports, point of origin inspection reports, a shipping release form, boral presence graph tracings, and instrument calibration records. Based on objective evidence of licensee

verification activities and the content of the reviewed record package, this item is resolve (Closed) Unresolved Item (278/79-07-03)

Review vendor documentation verifying fuel racks can withstand 4000 pounds uplift pressure. The inspector reviewed the " Fuel Rack Storage System Design Report . . . High Density Spent Fuel Racks", January 1980. Section 4.6 presents the static load for a jammed fuel bundle as 4.0 kips (limited to crane capacity) and an 18 inch middle

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drop as 49.20 kips and that the stresses of the former condition are 8.13 percent of the latter condition. Section 4.15 presents the actual peak load of a simulated dropped fuel bundle as 25,000 pounds, which is less than the calculated load. Comparison of the calculated jammed fuel bundle (uplift) load to the calculated and simulated test loads of the dropped fuel bundle indicates that the rack can withstand an uplift pressure of 4000 pound This item is unresolve (Closed) Unresolved Item (278/79-07-04): Modify receipt inspection procedure to conform to ANSI N18.7. Licensee Audit Finding Report OP-62-06 identified that procedure 273C did not fully comply with the licensee procedure ERDP-5.1 and, hence, ANSI 18.7. Corrective action and acceptability thereof was verified by the licensee in September 1979. The inspector also selectively reviewed Special Procedures 273C, Removal of Existing Spent Fuel and Control Rod Storage Racks and the Installation of New High Density Racks, Rev. 2 (one procedure for each Unit). These procedures detailed the work steps involved in removing the existing racks and installing the new ones, including such steps as necessary authorization / permits, inspections, sketches, prerequisites, and the use of the Boral Presence Testing Device. The completed working procedures were selectively reviewed for content and required signoffs. The inspector identified no violations or concern Based on the foregoing this item is resolve (Closed) Unresolved Item (278/79-07-05): Verification by licensee of correct rack installation fi Based on the discussions in items 79-07-01, 02 and 03 above and inspection records that accepted the as installed condition This item is resolve (Closed) Unresolved Item (278/79-07-06): Decision on corrosion test specimen installatio Based on the discussions in items 79-07-01, 02, 03 and 05 above; the contents of the report mentioned in item 79-07-01 above; and, discussion with the then cognizant engineer about all these items, the inspector had no further questions. This item is resolve (Closed) Unresolved Item (278/79-13-01): Tube serial numbers verification for boral traceability purpose The inspector reviewed nonconformance report (NCR) CD-1 This NCR and attachments documented the resolution of individual discrepancies associated with fuel racks, including racks A-22565-48-E and -49- The identified discrepancies were corrected or resolved, and the fuel racks were then found acceptable by the license Based on the foregoing and the discussions in items 79-07-01, 02, 03, 05 and 06 above, this item is resolve . _ _4 m . . _ _ - _ ... _ _ _ _ _

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(Closed) Unresolved Item (278/79-13-02): Correction and validation of records for Tube serial numbers and weld procedure identification. Based on the discussions in items 278-07-01, 02, 03, 05 and 06, and 79-13-01 above the inspector had no further questions. This item is resolve (Closed) Unresolved Item (278/79-15-04; 277/79-13-04): T.S. 3.11.0 to be revised clarifying applicability of mechanical snubbers. The inspector verified that T.S. 4.11.0 was clarified (Amendment 71) to address only hydraulic snubbers. The surveillance of mechanical snubbers is currently being addressed by NRR and any requirements that may be established will be inspected during the NRC routine inspector's program. Based on the above this item is resolved.

l (Closed) Unresolved Item (278/80-23-01; 277/80-31-01): Instock items subject to deterioration to be included in shelf life control. The inspector reviewed letter Plant Superintendent / Manager-Stores Division, March 1, 1982, wherein was transmitted a " Materials '. tith Limited Shelf Life" guide developed by the licensee's Technical Staff. The inspector verified the guidance is in the process of being implemente The inspector had no further questions and this item is resolve l 3. Design Change / Modification Control '

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_ 3.1 References

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NUREG 0737

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ANSI N45.2 - 1977

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ANSI N45-2.11 - 1974

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Procedure No. ERDP 3.4, Rev. 2

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Procedure No. ERDP 3.6, Rev. 3

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FSAR, Section 1 PBQAP - Modifications, Rev. 4

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Procedure No. A-14, Rev. 8

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Letter from S. L. Daltroff to D. G. Eisenhut, dated April 15, 1982

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Letter from S. L. Daltroff to D. G. Eisenhut, dated Februa ry 19, 1982

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Letter from S. L. Daltroff to J. F. Stolz, dated August 7, 1981

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3.2 Review The design change packages listed in 3.3 below were reviewed on a sampling basis to verify that the following requirements have been met, as applicable:

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Design Input Requirements such as design bases, regulatory require-ments, codes, and standards were identified, documented, and their selection reviewed and approve Design activities shall be prescribed and accomplished in accord-ance with procedures that would assure the applicable design inputs are correctly translated into specifications, drawings, procedures, or instruction Interface controls were established to identify, control, and maintain responsibilities, lines of communications, and documenta-tion requirements for internal and external interface Design verification was established to determine the adequacy of the design to meet the requirements specified in design input Document control procedures were established to control the issuance of design documents and their change Design change control procedures were established to control design change ~

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Design documentation and records were maintaine Audits were conducted to verify compliance with all aspects of QA programs for design and design change New or modified systems were installed in accordance with the approved desig New or revised procedures relating to the modified system were completed and approved for technical specification As built drawings were revised to reflect modification The operators were trained to use the modified syste .3 Document / Record Packages Reviewed The inspector reviewed the following design modification packages: i l

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MOD No. 389 - Core Spray Piping Replacement

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MOD No. 532 - New power and control cables for safety-related valves

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MOD No. 536 - Additional vacuum relief on Mainstream Relief Valve discharge lines

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MOD 575 - Direct Position Indication for Safety Relief Valve

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MOD 576 - Reactor Water Level Recorders

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MOD 580 - Post-accident Sampling System

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MOD 584 - Containment Pressure Indication

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MOD 584B - Torus Water Level Indication

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MOD 587 - Containment High Range Radiation Monitors

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MOD 649 - Modification of Torus Internal Structures

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MOD 686 - RWCV Suction Line Replacement

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MOD 843 - Upgrading of Fan Systems

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MOD 859 - Replacement of Reactor Recirculation Pump No. 3B

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MOD 581 - Noble Gas Effluent Monitor 3.4 Findings No violations were identified, however the following items will be reviewed furthe . The inspector observed that a design input (all material TP 316 water quenched with .02% max. carbon) was incorrectly transcribed onto the construction drawings (11187-022-M-415 Series) for MOD 389. The Mill Certification for the installed piping indicated that the carbon content was acceptable (less than .02%). The inspector identified this concern to the licensec, and the licensee agreed to review this matte The progress and completion of this review will be followed in future NRC inspections (IFI - 277/82-07-01 and 278/82-07-01).

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3.4.2. The inspector reviewed the post-accident Sampling System for the facility installed under MOD 580. This System was designed by General Electric Company, and l NRR is currently reviewing the adequacy of this desig The inspector advised the licensee that the acceptance of the post-accident Sampling System would be subject to NRR's approval of the design. This item will be followed in future NRC inspection (IFI - 277/82-07-02 and 278/82-07-02).

3.4.3. The inspector noted that the Plant Modification Coordinator also has responsibilities as the Outage Manager. The inspector held discussions with the Modification Coordinator on the following concerns:

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The Assistant Modification Coordinator did not meet the qualification and experience requirements for the Modification Coordinator;

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No formal training in the area of design modifications was provided to the Assistant Modification Coordinator; and,

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There was no formal interface between the Modifications Coordinator and the Engineering and Research Department to obtain the necessary assistance in work classification and safety evaluation preparatio The inspector advised the licensee representatives that the adequacy of the training and other assistance for the Assistant Modification Coordinator would be followed in future NRC inspections to assure that the Assistant Modification Coordinator was qualified to assume the Modification Coordinator's position when that individual assumed the duties of Outage Manage (IFI - 277/82-07-03 and 278/82-07-03).

3. The inspector noted that the corrective actions implemented in response to Inspector Follow Item (IFI) No. 278/79-13-03 were not incorporated into the design modification procedures for the Engineering and Research Divisio The licensee informed the inspector that the required corrective actions would be incorporated in the Engineering and Research Design Modification procedures. The inspector advised the licensee that the above procedure revisions would be followed in future NRC inspection (IFI - 277/82-07-04 and 278/82-07-04).

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3. The licensee has not completed the geometry calibration for the effluent noble gas monitor (NUREG 0737, Item II.F.1, Attachment 1). From discussions with the licensee representatives, the inspector learned that the required geonatry calibration was in progress. The inspector advised the licensee representatives that the timely completion of the geometry calibration would be followed in future NRC inspections. (IFI - 277/82-07-05 and 278/82-07-05).

3. The inspector observed that the preoperational testing for MOD 584A did not include channel response time verificatio This verification is required (reference 10 CFR 50, Appendix B, Criterion X) to demonstrate the channel's adequacy to meet the requirements of the design input document and the response time requirements of NUREG 0737, Item II. F.1, Attachment A. Completion of the preoperational test to measure channel response time is unresolved (277/82-07-06 and 278/82-07-06). Personnel Qualification Program 4.1 References

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Peach Bottom Atomic Power Station (PBAPS) Final Safety Analysis Report (FSAR), Section 13.2, Conduct of Operation PBAPS Quality Assurance Plan, Volume III, Operational Phase, Section 2, "QA Program".

-- PBAPS Quality Assurance Plan, Volume I, Design and Construction Phase, Section 2, "QA Program".

-- Technical Specifications Section 6.3, Facility Staff Qualifica-tion ANSI N18.1 - 1971, Standard for Selection and Training of Personnel for Nuclear Power Plant ANSI N18.7 - 1972, Quality Assurance for the Operational Phase of Nuclear Power Plant ANSI N45.2.6 - 1973, Qualification of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plant Quality Assurance Department Procedure (QADP)-13, QA Training Program, QA Division Personnel, Revision 5, March 198 . _

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QADP-14, QA Division Personnel Qualification Program, Revision 7,

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March 198 Engineering and Research Department (E&R) Quality Assurance Instruction (QAI) 2-2, Procedure for Training and Qualification of Quality Assurance Project Personnel, Revision 1, October 197 E&R QAI 2-3, Procedure for Quality Assurance Training Course, Revision 1, June 197 t

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Administrative Procedure (A)-7, Shift operations and Appendices ! I, II, and III, Duties and Responsibilities of Shift Superintendent, Shift Supervisor, and Shift Technical Advisors, Revision 17, May ' 1981.

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A-50, Training Procedure, Revision 7, June 198 A-55, General Requirements for QA Procurement and Receipt Inspectors, ! Revision 0, August 197 Maintenance Administrative Procedure (MA)-9, Training of Maintenance Division Personnel, Revision 2, October 198 MA-12, General Requirements for Quality Control Inspectors, Revision 1, July 198 Research and Testing Procedure (RT)-02-5002, Procedure for Qualifi-cation and Training of Research and Testing Division Personnel,

Revision 0, September 198 RT-10-50003, Procedure for Qualification of Quality Control Inspectors and performing Quality Control Inspections, Revision 0, July 197 RT-09-50010, Procedure for Training and Certification of Non-destructive Training Personnel, Revision 0, October 197 .2 Program Review l The inspectors reviewed the plans and procedures referenced above to verify that:

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Minimum education, experience, and/or qualification requirements have been established; and,

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Position descriptions including responsibilities have been i assigned in writin ___ . - _ __ __ - .

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The inspectors determined that formal job description, including qualification and responsibilities, did not exist for all plant and technical support (craftsmen and technicians) personnel. The inspector discussed the status of licensee action as a result of a similar-INPO (June 1981) inspection finding with licensee managemen The licensee representative stated that job descriptionsand responsi-bilities for the site staff engineers have.been completed and are currently being developed for plant technical support personnel (crafts-men and technicians) in an expeditious manner. The inspectors had no further question .3 Implementation Review The inspector reviewed resumes and training files for selected personnel in the following positions to verify qualifications and experience as required by the PBAPS, FSAR, ANSI N18.1-1971 and ANSI N18.7-197 Senior Plant Staff Engineer Technical Engineering Support Staf First level supervisors, including reactor operations and craft foreme Plant craftsme Plant operator QA/QC inspectors.

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QA supervisory staf Members and alternate members of the offsite safety committe No violations were identifie . QA/QC Administration 5.1 References

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PBAPS, Quality Assurance Plan Volume I, Design and Construction Phas PBAPS, Quality Assurance Plan, Volume III, Operational Phas FSAR, Appendix 17.2A, Operational Phase, Quality Assurance.

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FSAR, Appendix 17.28, Design and Construction Phase, Quality Assuranc Annual Review of PBAPS QA Program, February 16, 198 Joint Utility Management Audit of Electric Production - QA Division Activities June 1981; October 19, 198 QADP-1, Procedure for Control of QA division Procedures and Instructions Manual and PBAPS QA Plan'Vol. III Revision 5, March 198 QADP-2, Procedures for Control, Generation, and Revision of QA Division Procedures and Forms, Revision 7, June 198 ERDP 3.1, Handling Q-List Modifications, Revision 7, June 197 ERDP 3.2, Procedure for maintaining, amending, and revising the Project Q-List, Revision 4, March 198 ERDP 6.1, Procedure for Control of Engineering and Research Department Procedure',, Revision 3, April 198 Quality Insurance Instruction (QAI) 3-1, Procedure for Quality Assurance Review of Project Q-List Revisions, Requests, and l Changes, Revision 1, August 1979.

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QAI 5-1, Procedure for Preparation of Quality Assurance Instructions (QAI's), Revision 4, August 198 QAI 6-1, Procedure for Control of Quality Assurance Instructions (QAI's), Revision 1, March 197 QAI's, Appendix A, Procedure for Control and Revision of the PBAPS Units 2 and 3, QA Plan Volume I, Revision A-1, Administrative Procedure for Preparation and Approval of Administrative Procedures, Revision 4, October 1981.

l 5.2 Program Review The inspectors conducted discussions with licensee personnel and reviewed the plans and procedures referenced above to verify .that:

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The QA Program clearly defines or identifies these structures, systems, components, document, and activities to which the QA , Program applies;

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Procedures and responsibilities have been established for making changes to the QA program documents; j,

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Administrative controls for QA/QC Department procedures have been established to require review and approval prior to implementation, control of changes and revisions to procedures, and control of distribution; and, i,

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Responsibilities and methods have been established to assure overall review of effectiveness of the QA progra No violations were identifie .3 Implementation The inspector selected a sample of drawing (i.e., P&ID's and QAD drawings) and controlled manuals to verify:

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current revision to drawing and procedures were available or posted in controlled manuals;

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Systems, structures, and components identified as safety-related on the QAD drawings were consistent with the approved Project Q-List; 2nd,

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QA Program procedures were reviewed and approved at the proper , level, prior to issuanc The following dr' awing and manuals were selecte M-851, Rev. 10, Expansion Joint, Containment Penetratio M-864, Revision 2, Filter Demineralizer Syste M-865, Revision 10, HPC M-892, Revision 6, Standby Diesel Generato M-897, Revision 7, Gas Treatment Control Diagra Engineering and Research Department, QA Sections QAI ERDP, and Project Q-Lis Corporate QA Department manuals, including Administrative Procedures, QADP's, and Maintenance Administrative Procedure _

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Site QA Audit Group man'uals, including Administrative Procedures, QADP's, Maintenance Administrative Procedures, Project Q-List and ERDP' ' No violations were identifie _ 6'. Onsite Organization and Administration /

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L 6.1 References ,

 ;s PBAPS FSAR Section 13.2, Conduct of Operation '
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Technical Specifications, Section 6.3. Facility Staff Qualifi-cations.

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ANSI N18.1-1971, Standard for Selection and Training of Personnel for Nuclear Power Plant Technical Specifications, Figure 6.2-2 Facility Organization Char .2 Program Review The inspector conducted a discussion with the plant superintendent and reviewed the documents referenced above to verify that:

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The onsite organization structure is as described in the Facility Technical Specification;

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Personnel qualification levels are in conformance with codes and standards as described in Technical Specifications;

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Lines of authority and responsibility are in conformance with Technical Specifications; and,

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Changes, if any, in the organizational structure have been reported to the Commission as required by Technical Specificatio No violations were identifie .3 Findings The licensee is planning to reorganize the station organizatio This reorganization will have the Health Physics and Chemistry ~ sections report to the Plant Superintendent rather than to the Technical Enginee ___ _ - - . _ __ __ . - . - - - - . .. . - _ _ J

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-No violations were identifie . QA Program Review The inspectors reviewed the changes to the procedures referenced in preceding paragraphs to verify their consistency with the licensee's accepted Quality Assurance Program (FSAR, Section 17.2).

No violations were idantifie . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item is discussed in paragraph 3. . Management Meetings Licensee management was informed of the scope and purpose of the inspection at entrance interviews conducted at the Peach Bottom Atomic Power Station site on April 20, 1982 and the Philadelphia Electric corporate offices on April 28, 1982. The findings of the inspection were discussed with licensee representatives periodically during the inspectio An exit interview was conduc'.ed at the site on April 30, 1982, at which time the findings of the inspection were presented to licensee management (see paragraph 1 for attendees).

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