ML20138Q222
| ML20138Q222 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/20/1985 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8512270100 | |
| Download: ML20138Q222 (2) | |
See also: IR 05000278/1985032
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DEC 2 01985
Docket No.
50-278
Philadelphia Electric Company
ATTN: Mr. S. L. Daltroff
Vice President
Electric Production
2301 Market Street
Philadelphia, Pennsylvania 19101
Gentlemen:
Subject:
Inspection Report No. 50-278/85-32
This refers to your letter dated December 5,1985, in response to our letter
dated November 5, 1985.
Thank you for informing us of the corrective and preventive actions documented
in your letter.
These actions will be examined during a future inspection of
your licensed program.
.Your cooperation with us is appreciated.
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Sincerely,
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Division of Reactor Safety
cc w/ enc 1:
R. S. Fleischmann, Station Superintendent
John S. Kemper, Vice President, Engineering and Research
Troy B. Conner, Jr. , Esquire
W. 'H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric
Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)
Raymond L. Hovis, Esquire
Thomas Magette, Power Plant Siting, Nuclear Evaluations (Without Report)
W. M. Alden, Engineer in Charge, Licensing Section
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
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PHILADELPHIA ELECTRIC COMPANY
2301 M ARKET STREET
P.O. BOX 8699
PHILADELPHI A. PA.19101
GHIE LDS L. D ALTROF F
ELectnic Pn
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December 5,
1985
Docket No. 50-278
Inspection Report No. 50-278/85-32
Mr. Stewart D.
Ebneter, Director
Division of Reactor Sa fety
U.S. Nuclear Regulatory Commission
Region I
631 Park Avenue
King of Prussia, PA
19406
Dear Mr. Ebneter:
Your letter dated November 5,
1985 forwarded Inspection
Report 50-278/85-32 for Peach Bottom Atomic Power Station, Unit 3
and required a response by December 5,
1985.
Appendix A of the
Inspection Report letter addresses three items which do not
appear to be in full compliance with NRC requirements.
These
items are restated and followed by Philadelphia Electric
.
Company's response.
Violation A
Criterion II, requires a quality assurance
program to be documented by written policies, procedures, or
instructions and carried out in accordance with this.
Criterion
X further requires that inspection be performed by individuals
other than those who performed the activity being inspected.
Section 2,
Paragraph 10, of the Peach Bottom Atomic Power Station
Quality Assurance plan requires the following:
" Inspection activities to verify the quality of work shall be
performed by persons other than those who performed the
activity.
Such persons shall not report directly to the
immediate supervisors who are responsible for the work being
inspected.
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Decembe r 5, 19 85
Page 2
The inspection program for modifications and non-routine or
major maintenance work is accomplished by personnel
independent of the group or individual performing the work."
" Personnel performing Quality Control inspection a re
qualified in accordance with applicable industry standards
and Company training programs.
Certifications of inspector
qualifications are maintained in accordance with
Administrative Procedures."
Contrary to the above, on September 10, 1985, a contractor's
Quality Control inspection for the fuel reconstitution ef fort was
being performed by persons of the same group performing the
activity.
These inspection personnel were also reporting
directly to the same supervision responsible for the work.
Secondly, the personnel performing the Ouality Control inspection
had not been qualified in accordance with company training
programs and no certification of inspector qualifications was
being maintained.
This is a Severity Level IV Violation (Supplement 1) .
Response to Violation A
Admission or Denial of Alleged Violation:
Philadelphia Elem: ric Company (PECo) acknowledges the
violation as stated.
Reason for Violation:
A corporate headquarters based group, Fuel Management
Section, is responsible for recommending action in the area
of fuel-related work.
The Fuel Management Section Engineer-
In-Charge informed the Reactor Engineer at the plant that the
decision had been made to reconstitute fuel.
Based upon this
communication, qualified General Electric Company (GECo)
personnel on-site were selected to reconsti tute fuel as a
continuation of the ongoing; fuel inspection work, with one
day notice.
Thus, GECo personnel at Peach Bottom were
authorized to begin reconstituting fuel before specific
instructions had been issued identifying the necessary OC
requirements.
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' Mr. Stsw2rt D. Ebnator
December 5,
1985
Page 3
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There were PECo QC personnel present on the refuel floor
during the fuel reconstitution work.
PECo QC personnel were
assigned to fuel movement accountability; however, no one was
specifically overseeing the fuel reconstitution work
involving fuel bundle assembly and disassembly.
The PECo QC
personnel were aware that the GECo personnel were performing
the QC inspections; however, no one recognized that they were
not under the supervision of the on-site GECo QC Supervisor,
and thus not indepe ndent.
The PECo Reactor Engineering
Group, responsible for this work, did not. assure that the QC
requirements would be satisfied prior to authorizing the work
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to begin.
Signi ficance or Extent of Violation
The signi ficance of this event is minimal because the fuel
reconstitution work was being performed by experienced
individuals employed by GECo.
The GECo personnel performing
the QC inspections were certified within the GECo training
program as inspectors for fue1~ work.
The QC inspections were
,
being performed by these individuals who were also involved
in the work.
However, for each step requiring QC inspection,
the individual performing the OC inspection was not the same .
person who had performed the step being inspected.
Thus, the
inspections were being
independently" pe rformed, however,
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not by a person independent of the overall work activity.
Corrective Actions Taken and Results Achieved:
Fuel reconstitution work was immediately halted following
notification of a potential violation.
To satis fy the
independence requirements of the Peach Bottom Quality
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Assurance plan, two purchase orders were promptly initiated.
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One purchase order provided GECo OC inspectors who were
required to functionally report to the on-site PEco QC
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Supervisor.
The other purchase order provided GECo personnel
to pe r form the fuel reconstitution work and report to the
PECo Reactor Engineer.
In addition, each GECo QC inspector
was certified within the PECo QC program.
They were
indoctrinated to applicable procedures and this was
documented on a required reading list for each GEco
,
inspector.
PECo Quality Assurance performed an audit of the fuel
reconstitution project on September 11 through September 12.
This audit encompassed, in part, review of the Fuel Handling .
Procedures used, qualifications of the personnel involved
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(PECo and GECo), and documentation.
The absence of a
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Mr. Stewart D. Ebneter
December 5,
1985
Page 4
purchase order was the only unacceptable finding.
The
auditor verified by review that the PECo OC group was
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documenting inspection activities correctly and tha t the PECo
OC Engineer was reviewing the appropriate documents prior to
closure.
Based on review of a sample of twenty-six (26)
reconstituted fuel bundles, out of a total of for ty-eight
(4 8) completed at the time of the audit, the lack of
independence did not reduce th e qual i ty of wo rk pe r fo r med.
Corrective Actions to be Taken to Avoid Future Non-
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Complia nce:
It will be made clear that the Fuel Management Section acts
in an administrative capacity, making recommendations to the
Station Manager for fuel-related work.
The initiation of
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purchase orders and the identification and implementation of
OC requirements are the responsibility of the station.
Date When Full Compliance Will be Achieved:
Full compliance was achieved before fuel reconstitution work
was permitted to resume.
Violation B.1
Peach Bottom Atomic Power Station, Unit 2 and 3 Technical Specification 6.8, " Procedures", requires that written procedures
and administrative policies shall be established, implemented and
maintained that meet the requirement of Section 5.1 and 5.3 of
ANSI N18.7-1972 and Appendix A of USAEC Regulatory Guide 1.33
(November 1972 ).
Procedure FH-61, Fuel Bundle Upper Tie Plate
Removal / Replacement and Individual Rod Handling, Revision 0,
requires the following:
Section V, Upper Tie Plate Installation, Step V-2,
states:
" Check to ensure that all tie rods are bottomed
out in the lower tie plate finger tight and non-tie rods
seated.
Proper inspection of the peripheral rod lower
end plate (LEP) shall be confirmed by visual examination
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Mr. CtGwnrt D. Ebn2 tor
December 5,
1985
Page 5
of all four sides of the lower tie plate."
Oc signature
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Contrary to the above, on September 13, 1985, the Quality
Control inspector failed to perform step V-2 Section V for
the reassembly of donor bundles.
The bundles were
reassembled correctly and all the tie rods we re ve ri f ied to
be . bottomed out by the operator as witnessed by the NRC
inspector.
Response to Violation B.1
Admission or Denial of Alleged Violation:
PECo acknowledges the violation as stated.
Reason for Violation:
Fuel Handling Procedure FH-61 does not dif ferentiate between
recipient and donor bundles.
It is GECo standard practice
not to perform the independent OC inspection which step V-2
requires for donor bundles.
The training that the GEco
individuals received does not require this step.
Due to
administrative oversight, a temporary procedure change was
not processed to clarify this point.
Signi ficance or Extent of Violation:
The bundles were reassembled correctly and the tie rods were
verified to be bottomed out by the operator as witnessed by
the NRC inspector.
GECo assures us that as long as the tie
rods were threaded most of the way into the lower tie plate,
the safety significance of this incident is minimal.
Corrective Actions to be Taken to Avoid Future Non-
Compliance:
The Fuel Handling Procedure will be revised before it is used
again to clarify the int'ent of step V-2 for donor bundles,
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Mr. Stcw3rt D. Ebnator
December 5,
1985
Page 6
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Violation B.2
Peach Bottom Atomic Power Station, Unit 2 and 3 Technical Specification 6.8,
" Procedures", requires that written procedures
and administrative policies shall be established, implemented and
ma in ta ined that meet the requirement of Section 5.1 and 5.3 of
ANSI N18.7-1972 and Appendix A of USAEC Regulatory Guide 1.33
(November 1972 ).
Procedure HPO/CO-10a, Conduct in Controlled Areas-Minimize
Exposure, requires the following:
Radiation rope or tape is a ba rrie r.
When it is
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necessary to reach across a tape or rope barrier,
proper precautions have to be tak e n.
Contrary to the above, on September 13, 19 85, a PECo employee
who was observed reaching across the tape barrier without
taking proper precautions, nuch as wearing protective gloves
before touching contaminated material.
Response to Violation B.2
Admission or Denial of Alleged Violation:
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PECo acknowledges the violation as stated.
A PECo QC
Inspector reached across the tape barrier without taking
proper precautions.
Reason for Violation:
The OC Inspec or unintentionally failed to follow Health
Physics procedures.
Health Physics training instructs
against such an action.
At the time, the individual did not
recognize what could result from his action.
Significance or Extent of Violation:
The potential for contamination in this situation was low.
The individual did not become contaminated; the re fore, the
safety signi ficance of this speci fic incident is minima
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Mr. Stewart D. Ebneter
December 5, 1985
Page 7
Corrective Actions Taken and Results Achieved:
The individual was counselled concerning the need to be more
a t ten tive to Health Physics procedures.
Corrective Actions to be Taken to Avoid Future Non-
Compliance:
All QC personnel working on the refuel floor .have been
reinstructed to comply with Health Physics procedures.
Date When Full Compliance Will be Achieved:
Full compliance has been achieved.
Should you have any questions or require additional
in forma tion, please do not h esitate to contact us.
Ve ry t ruly yours,
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P. Johnson, Resident Site Inspector