ML20147D395
| ML20147D395 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/11/1988 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8801200163 | |
| Download: ML20147D395 (2) | |
See also: IR 05000277/1987023
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JAN 111988
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Docket Nos.
50-277
50-278
Philadelphia Electric company
ATTN:
Mr. J. W. Gallagher
Vice President
Nuclear Operations
2301 Market Street
Philadelphia, Pennsylvania 19101
Gentlemen:
Subject:
Combined Inspection No. 50-277/87-23 and 50-278/87-23
This refers to your letter dated November 30, 1987, in response to our letter
dated October 28, 1987.
Thank you for informing us of the corrective and preventive actions documented
in your partial response to our letter.
We agree to your request for an
extension to January 22, 1988, for a full response to our letter. The actions
that have been completed as described in your letter will be examined during a
future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
grf .7
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William V. Johnston, Acting Director
Division of Reactor Safety
CC:
Dickinson M. Smith, Manager, Peach Bottom Atomic Power Station
John S. Kemper, Senior Vice President, Engineering and Production
Thomas S. Shaw, Jr. , Vice President, Production
Troy B. Conner, Jr. , Esquire
W. H. Hirst, Director, Joint Generation Projects Department,
Atlantic Electric
G. Leitch, Nuclear Generation Manager
Eugene J, Bradley, Esquire, Assistant General Counsel (Without Report)
Raymond L. Hovis, Esquire
Thomas Magette, Power Plant Siting, Nuclear Evaluations
W. M. Alden, Engineer in Charge, Lir.ensing Section
Doris Poulsen, Secretary of Harford County Council
Public Document Room (PDR)
local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
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0FFICIAL RECORD COPY
RL PB 87-23 - 0001.0.0
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8801200163 880111
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ADOCK 05000277
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Philadelphia Electric Company
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Region 1 Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
Section Chief, ORP
Robert J. Bores, DRSS
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PHILADELPHIA ELECTRIC COMPANY
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23o1 M ARKET STREET
P.O. BOX 8699
PHILADELPHI A. PA.19101
12151 841 5001
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November 30, 1987
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Docket Nos. 50-277
50-278
William V.
Johnston, Acting Director
Division of Reactor Safety
Region I
U.
S.
Nuclear Regulatory Commission
ATTN: Document Control Desk
D.C.
20555
Subject:
Partial Response to Peach Bottom Inspectior:
Report No. 50-277/87-73; 50-278/87-23
Dear Mr. Johnston:
This is in response to your letter dated October 28, 1987
transinitting Peach Bottom Inspection Report 50-277/87-23, 50-278/87-
23.
The purpose of this letter is to provide a partial response and
inform the NRC that additional time is needed to complete our
response.
Appendix A of your letter addressed an item which did not
appear to be in compliance with NRC requirements..
Your letter also
requested that we respond to two unresolved items.
The unresolved
items will be addressed in our complete response.
The apparent
violation is restated below followed by a par'.ial response.
Restatement of Apparent Violation
As a result of the inspection conducted on August 10-19, 1987, and in
accordance with the General Policy and Procedures for NRC Enforcement
Actions, (10 CFR Part 2, Appendix C), the following violation was
identified.
Criterion III requires that measures be
established for the selection and review for suitability of
application of materials, parts, equipment, and processes that are
essential to the safety-related functions of structures, systems
and components.
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November 30, 1987
Mr. W. V. Johnston
Page 2
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Philadelphia Electric Company Quality Assurance Plan for Peach
Bottom Atomic Power Station, Volume III, Section SP 3.2 requires
that an item (s) be reviewed for suitability for its intended
safety-related use prior to selection when procured as-a standard,
commercial grade (off-the-shelf) item (s) or if it.had been
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previously reviewed for a different application.
Such commercial
grade purchases are defined as quality assured items (procurements
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under the full auspices of a QA Program are classified as nuclear
safety-related items).
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Contrary to the above, the following items were procured as
quality assured (i.e., commercial grade) and identified as
acceptable for in plant safety-related use although the documented
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review did not justify the items suitability for their intended
use.
(1)
PO # BW 218026, PECO Code 115-92145, ASCO Solenoid Valve.
(2)
PO # BW 210672, PECO Code 115-73852, Crosby Relief Valve.
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(3)
PO # BW 298553, PECO Code 115-20637, Muesco Air Operated
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Valve Diaphragm.
(4)
PO # BW 215582, PECO Code 115-07408, Muesco Valve Operator
Spring.
(5)
PO # SO 126096, PECO Code 115-88273, Aktomatic Valve Insert.
(6)
PO # SO 126022, PECO Code 115-94107, Aktomatic Solenoid
Valve.
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This is a Severity Level IV Violation (Supplement I).
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Admission or Denial of Apparent Violation
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PECO acknowledges that the item above is a violation of NRC and PECO
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QA Plan requirements as stated.
Additionally, PECO recognizes that
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this violation may indicate the need for improvements in the
procurement process.
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Reason For Violation
A formal engineering evaluation was not performed to verify the
suitability of these commercial grade components for safety-related
application.
A study is in progress to determine the root cause of
this violation and to accurately define the scope of the problems in
our procurement process.
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Mr. W. V. Johnston
November 30, 1987
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Page 3
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Corrective Actions Taken and Results Achieved:
Fifteen (15) items were procured by the seven (7) purchase orders
identified in the Notice of Violation.
Of those fifteen (15) items,
eleven (11) items have been removed from the storeroom and placed on
"QA Hold", one (1) item (a spring) has not been located, and the
remaining three (3) items were determined to be installed in the
plant.
The eleven (11) items on "OA Hold" will not be used in safety
related applications until appropriate evaluations / inspections are
performed.
For the items installed in the plant, appropriate
evaluations / inspections will be performed prior to startup from the
current outage.
Prior to restart, appropriate corrective actions will
be identified and taken, regarding the missing spring.
The following actions have been taken to prevent recurrence of this
violation:
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Immediately after the inspection, the station Quality
Control (OC) Group established a polic:' of rejecting
1) purchase orders of commercial gradr items for safety-
related applications without supporting documentation of
an engineering evaluation, or 2) Nuclear Safety-Related
purchase orders from a non-evaluated supplier for the
order.
Rejected purchase orders are returned to the
initiator to obtain an engineering evaluation from
qualified personnel or identify an evaluated supplier
for the order,
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Prom the date of this letter forward, any items received
on-site will not be used for safety-related applications
until appropriate evaluations / inspections have been
performed if Oc determines that 1) it was procured as
commercial grade without supporting documentation of an
engineering evaluation, or 2) it was procured from a
non-evaluated supplier.
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A documentation review of items that have been received
from the time of the inspection to the date of this
letter, will be performed by December 8,
1987 to
determine if 1) any were procured as commercial grade
without supporting documentation of an engineering
evaluation, or 2) any were procured from a non-evaluated
supplier.
Any items in stock determined to be in this
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category, will not be used in safety-related
applications until appropriate evaluations / inspections
are performed.
For any items installed in the plant
determined to be in this category, appropriate
evaluations / inspections will be performed prior to
startup from the current outage,
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The PECo Nuclear Quality Assurance organi ation has
initiated a study of procurement procedures / practices
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Mr. W. V.
Johnston
November 30, 1987
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Page 4
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for items to be used in nuclear safety-related
applications.
This study will identify any problems
that require further investigation and evaluation to
determine the necessary corrective actions to improve
the procurement process.
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An engineering procedure was issued on Octclu
6,
1987 to
control the procurement of safety related items from suppliers who do
not maintain 10 CFR 50, Appendix B OA Programs.
The procedure is
based upon Regulatory Guide 1.123 and ANSI N45.2.13, and requires an
engineering evaluation to determine the critical characteristics of
the items and the necessary inspection requirements.
PCCo will submit a supplementary response, outlining the
action plan to improve the procurement process, by January 22, 1987.
If you have any questions, please do not hesitate to contact
us.
Very Truly yours,
wJ b%b
cc:
Addressee
W. T. Russell, Adminstrator, Region I, USNRC
T.
P. Johnson, USNRC Resident Site Inspector
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