ML20084J318
| ML20084J318 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/10/1984 |
| From: | Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20084J313 | List: |
| References | |
| NUDOCS 8405090073 | |
| Download: ML20084J318 (4) | |
Text
m PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (215)841 4000 February 10, 1984 Docket Nos. 50-277 50-278 Insocction Nos. 50-277/83-30 50-278/83-18 Mr. Thomas T. Martin, Director Division of Enqineerina and Technical Programs US Muclear Regulatory Comission Reqion I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
Your letter of January 13, 1984 forwarded C7nbined Insnection Renort 50-277/83-30 and 50-278/83-18. The report requested that we resnond to Unresolved Item 277/83-30-01 and 278/83-18-01. This letter will restate the Unresolved Item and provide our response.
INR9SOINED ITFN 1.0 The Insoector concluded that auditinq by the Electric Production m of contracted services is inconsistent. The Insooctor reviewed the m coveraqe of General Electric - A&SE (weld overlay work) and Vikem Industries, Inc. (radiological waste processing) and found the m Division identified unaccentable contractor work durinq audits and corrected the problems via manacement meetinas and stoo work orders. However, the m coverage of NPS Energy Services durinq their control rod drive mechanism changeout work was noor. The only m coverage of NPS Energy Services was that their emoliance with AIAPA orocedures was reviewed as part of an ATARA audit at the site. The Insoector concluded that a more thorough review of NPS Energy Services should have been narformed based on the following:
.. This was tha first work narformed by NPS Energy Services for the licensee.
.. The removal, refurbishment, and renlacement of the control roi drive machanisms is very significant wrk with resnect to reactor safety.
8405090073 840502 PDR ADOCK 05000277 G
PDR 1
Mr. Thcmas T. Martin Page 2
.. During the only @ review of NPS Energy Services, i.e., the AEARA audit, NDS Energy Services was found not to be in comoliance with the AIARA crocedures and work was stopped.
.. Quality control review of NPS Enerqy Services work was performed by Inspectors contracted from NPS Enercy Services.
.. There were numerous delavs and interruotions of the work, includina the inadvertent overfilling of the reactor cavity with water.
Further, during a cursory review of purchase order pamrwork, the Insmetor noted that althouqh Purchase Order PB 332061 reauired "All personnel must be minimtrn of Level II as defined in ANSI 45.2.6", one of the three Insoectors was cualified to Level I only.
RESTATPMRI' OF INSPECIOR'S OnNGRNS The following are PECo resconses that address the Insoector's soe-ific concerns.
Concern:
.. This was the first work nerformed hv NPS Enerov Services for the licensee.
Resnonse:
While it is true that the Unit 3 CRD Maintenance was the first work performed by NPS Enerqv Services for Philadelohia Electric Comoany, NPS Energy Services had exoerience in CRD maintenance services at other utilities. In addition, the NPS Enerqy Services Job Suoervisor was a former General Electric Conoany emnloyee with considerable exoerience in control rod drive design and maintenance. NPS Enerqv Services performed CRD Maintenance durina the Unit 3 Fif th Refuelinq Outage under the direction of PECo v intenance Suoervision using a
PECo anoroved imolementinq orocedures which have proven accentable when innlementnd by PEco and vendors in cast outages. Based on our evaluation of NPS Energy Services control rod drive exnerience, their leadershin and the fact that our proven procedures would be utilized with our Maintenance Suoervision, our m Division Suoervision decided that a formal audit was not as beneficial as the allocation of OA forces to audit other safety-relatnd outaqe activities.
Concern:
.. The removal, refurbishment, and replacement oL the control rod drive machanisms is very significant verk with resocct to reactor safety.
Resnonse:
PECo aqrees that the remrwal, refurbishment and renlacemont of the control rod drive mechanisms is very sionificant wrk with resoect to reactor safety.
An such, PEco has defined CRD Maintenance as a safety-related activity which is recuired to be atylited at least once per tw (2) year audit cycle.
In fact, the m Division has performed audits or surveillances of the CRD Maintenance Activity at least once oer year durinq the cast three (3) years (1490,1981, and 1982) with no unaccentable findings identified during the last two (?) years.
Mr. Thomas T. Martin Page 3 Concern:
.. During the only QA review of NPS Energy Services, i.e., the AIARA audit, NPS Energy Services was found not to be in compliance with the PIARA procedures and work was stopped.
Resoonse:
During the period when the CDD Maintenance was being performed, several audits were conducted by the QA Division in areas whidi interfaced with the CRD Maintenance project, for example: Fire Protection, llousekeeping, Ilealth Physics aM AIARA. As the Inspector has indicated in his concern, NPS Energy Services was founr1 not to be in conpliance with the PBAPS AIARA Procedure. Work was stopped and NPS Energy Services emloyees were reinstructed in the AIARA Procedures.
Concern:
.. Quality control review of NPS Energy Services work was performed by Insnectors contracted from NPS Energy Services.
Recnonse As indicated in the Insocctor's concern, Quality Control Services for CHD Maintenance were contracted to NPS Energy Services. NPS Energy Services Quality Control Activities are described in the NPS Quality Assurance Manual. The NPS Quality Assurance Manual was reviewed aM aanroved by PECo in 1982, and NPS was subsequently placed on PECo's Evaluated Suopliers List as an acceptable supplier for safety-related services. Additionally, NPS Energy Services QC personnel received CBD exchanqe aM rebuild training at Peach Bottom prior to imlementation of this work.
Concern:
.. There were numerous delays and interruptions of the work, including the inadvertent overfilling of the reactor cavity with water.
Resnonse:
Although the Inspector has expressed a concern that there were delays and interruntions of the CRD work, we request that the Insnector reconsider this concern since NPS Energy Services had no resoonsiblity in overfilling the reactor cavity. The overfilling of the reactor cavity resulted from a false instrument signal generated while calibration was in progress. In fact, NPS Energy Services emloyees were helnful in assisting plant personnel in resnanding to this event.
concern:
.. Further, during a cursory review of purchase order panerwork, the Insnector noted that although Purchase Order 332061 required "All personnel must be minimum of Level II as defined in ANSI 45.2.6", one of the threa Insnectors was qualified to I,evel I only.
l
w. c -,
.j Mr. Thomas T. Martin Page 4 y
Resnonse:
We agree that NPS Energy Services did not ccnoletely cmoly with all the purchase order recuirements, in that, a Level I Insoector was sunolied when the s
ourchase order recuired that all QC nersonnel be at least Level II Inscectors as defined in MSI N45.2.6.
The OA Division will issue a Noncomoliance Recort
?
(NCR) to NPS Energy Services for failure to aihere to Purchise Order Recuirements which will recuire a written response by NDS Energy Services.
A criticue of the performance of NPS Enerqv Services was held at Peach Bottom at the conclunion of the control rod drive maintenance activity, with NPS
!!anagement and Suoervision, Plant Staff and Maintenance Sunervision. This criticue concluded that NPS Energy Services had performed the control rod drive maintenance nroject in an efficient, professional manner. The NPS final report thoroughly documented this activity and NPS Energy Services remains on the Philadelphia Electric Ccmnany Evaluated Sucoliers List for this activity.
PECo is cortnitted to audit in accordance with ANSI N18.7 - 1972, Paragraoh 4.4, which states, "... Audits of selected asoects of plant coeration shall ba nerformed with a frecuency comensurate with their safety significance and in such a manner as to assure that an audit of safety-related activities is comoleted within a period of two years..." The PEco QA Division will continue to schedule and oerform audits of selected aspects of plant operation and maintenance in such a manner as to assure that an audit of significant safety-related activities is completed within an audit cycle of two (2) years.
Further, siqnificant safety-related activities performed at Peach Bottom by "first time" contractors will now be considered as a criterion for selection for a OA Division Audit or Surveillance.
Quality Assurance Division Procedure OhDo-G, Quality Assurance Division Atriit Program - Onerations, Rev. 7, will be revised by May 1,1984 to add the "first time" contractor criterion to that list of criteria to be considered when selectinq those activities which rule the formally audited.
9 If there are any further nuestions, please do not hesitate to contact us.
Very truly yours,
?
ey i.ager uclear Production cc:
S. L. Daltroff A. R. Blouqh, Site Incpoctor
- _ - - _ _ _ _ _