ML20096E330
| ML20096E330 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/08/1984 |
| From: | Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8409070016 | |
| Download: ML20096E330 (5) | |
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PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 (2:5) sat sozo "i*$.."."
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August 8, 1984 Docket Nos. 50-277 50-278 Inspection Report Nos. 50-277/84-17 50-278/84-15
- Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Starostecki:
Your letter of July 10, 1984, forwarded combined Inspection Report 50-277/84-17 and 50-278/84-15.
Appendix A of your letter addresses two activities which do not appear to be in full compliance ~with Nuclear Regulatory Commission requirements.
These items are restated below along with our response.
1.
10 CFR 50, Appendix B, Criterion XVI, " Corrective Action" requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected and in the case of significant conditions adverse to quality, the measures are required to assure that the corrective action precludes repetition.
Peach Bottom Quality Assurance Plan, Volume III, Program Section, Paragraph 16.1, " Corrective Action" states, in part, that " measures bq established to assure that conditions adverse to quality are promptly identified and corrected."
PECO defines conditions adverse to quality as "...nonconformances to specified requirements."
Contrary to the ahove, as of May 18, 1984, nonconformances had not been corrected that had been identified in Quality Assurance Audit Report AP83-40PR Yoh&7 PDR
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[Mr. Richard W. Starostecki August 8,_1984 Page 2 dated January 26, 1984,.and previously in nonconformance report NCR A82-37-01 dated December 15, 1982, regarding failure 1to - review maintenance f administrative : procedures at-the _ prescribed periodicity.
- This lis a Severity Level'V violation (Supplement I).
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" Response The noncompliance identified in our Electric Production'
. Quality _ Assurance. Division Audit Report AP83-40PR dated i
fJanuary 26, 1984, and in Noncompliance Report (NCR) A82--
37-01 issued February 9,-1982, was that several Maintenance Division maintenance administrative (704) procedures had not been reviewed within the required two
_(2) year period.
4 The corrective action taken by our Maintenance Division
.in response to Quality Assurance Audit Report.AP83-40PR, specifically NCR AP83-40-03 was the commitment by the-Maintenance Division to review, approve, and submit l
these outstanding MA procedures to the Electric Production Quality Assurance' Division (Quality Assurance Division) for review ~ by September 1, _1984.
In addition, as~_a corrective' action to prevent recurrence,
-Maintenance _ Division had committed to generate, on a
_ quarterly basis, an internal letter outlining the-status
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of the MA procedure review and approvals for submission to the Maintenance' Division's Nucl~ ear Branch Senior Engineer,. Engineer-In-Charge (this position has now been incorporated into the job of Nuclear' Branch Senior Engineer), and Superintendent of Maintenance to provide improved: tracking of the MA procedures.
Both the corrective action and the action to prevent recurrence was accepted by-the Electric Production Quality i.
Assurance Division on_ April-25, 1984.
In order to'
.further-improve the tracking of the MA procedures, the quarterly letter has been replaced by a report which p
specifically describes the status of each MA procedure.
Beginning' April 24, 1984,~ this report has been issued on a biweekly basis to the Maintenance Division's Superintendent of Maintenance and Nuclear Branch Senior Engineer.
b Your inspection report of July 10, 1984, refers to five administrative procedures MA-4, MA-8, MA-11, MA-15, and MA-17.
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l e v-a iMr. Richnid WJ Starostacki August 8, 1994 g
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Page 3 In accordance with the daintenance Division's' February.
18,-1984. response to~ Quality Assurance Division NCR 2AP83-40-03, all of these maintenance procedures will be submitted'to the Electric Production Quality-Assurance-
= Division by September 1, 1984.
The status of our Maintenance Division's review of these
. specific MA~ procedures as of August 8, 1984, are as follows:
.s 1)
MA-4, Revision 6, was reviewed and approved by the Maintenance Division on July 17, 1984 and approved by the Quality Assurance Division on July 25, 1984.
2)
MA-8, Revision-3, is-under review-by the Maintenance Division and will be submitted to the
-Quality Assurance Division by September 1, _1984.
3) l MA-ll, Revision 2, was reviewed and approved by the Maintenance Division on May 8, 1984, approved by the Quality Assurance Division on June 4, 1984, and distributed,on June-13, 1984.
4)
MA-15, Revision 1, is under review by the Maintenance Division and will be submitted to the Quality Assurance Division by September 1,1984.
'5)
MA-17, Revision 1, was reviewed and approved by the' Maintenance Division on May 8, 1984, approved by.
L' the Quality Assurance Division on May 29, 1984, and distributed on June 8,'1984.
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. Philadelphia Electric Company believes ' that the corrective action initiated by the: Maintenance Division in response to the Quality Assurance Division NCR AP83-40-03 has produced a mechanism to prevent recurrence of the. audited item AP83-40-03.
This mechanism,'a biweekly report' describing the status of each maintenance
' administrative' procedure, provides the improved tracking necessary to avoid further violation.
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2.
10 CFR 50, Appendix B,_ Criterion XI, " Test Control",
requires that measures be established to assure that testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is' performed in accordance with written test
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August'8,.1984-Page 4 s
-procedurestwhich incorporate the requirements.and Lacceptance limits..
Peach Botton QualityLAssurance Plan, Volume III, Program Section,. Paragraph ll.l. states, in part, that-testing.
shall be performed in accordance with written? test
. procedures which incorporate or. reference acceptance
, limits contained in design documents.
The. Activities Section of that Plan, Paragraph 11.4 states that procedures shall' be designed to permit ~ evaluation of the system's or' component's performance.
Contrarynto the above, Surveillance-Test Procedures ST-12.15.1-3, ST'12.15.3-3 and ST 12.15.4-3 which partially
. implement Technical Specification 6.14, which requires a program to reduce leakage of potentially highly radioactive fluids from systems outside containment, contain neither acceptance criteria nor the data on
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which.the' evaluation of the system's or component's performance can be evaluated.
' This is a -Severity Level V violation (Supplement I).
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Response
Technical Specification 6.14, ' Integrity of systems outside Containment', requires a' periodic visual inspection' program to reduce the leakage to as low as practical ~1evels from systems outside' containment that would or could carry radioactive fluids during:a_ serious
' transient or accident.'.A leakage identification program was, initiated and has been implemented to satisfy this requirement.- Visual inspection tests _are routinely performedLto identify and initiate the repair of sources of leakage.-
The acceptance criteria (limits) intended in these tests is "any leakage".
This pass / fail criteria provides=a very conservative approach in defining.an action
- threshold snd meets the. intent and criteria' requirements of Technical Specification 6.14,10 CFR 50 Appendix B, Criterion XI, and PBAPS Quality Assurance Plan Volume III. Paragraph 11.1 and 11.4.
6-Although these test procedures currently satisfy the criteria requirements of the above mentioned' documents, additional procedural detail would enhance evaluations.
A revision has been initiated to better indicate the Technical Specification intent within the procedure and
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7 Mr., Richard W. Starc'stecki August 8, 1984 0
Page 5 to require a more detailed description of the source, nature, and probable cause of the leakage as well as a
' leakage rate appraisal.
The conservative acceptance criteria, as well as the more detailed leakage descriptior> requirements off these tests, will permit adequate esaluation of the urgency of repair of leaking components thi'ch are identified during.these surveys.
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. The revision will be completed by October 31, 1984.
A Should you require additional information, please do not hesitate to contact us.
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Very truly yours,
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A. R. Blough
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