ML20151K684
| ML20151K684 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/15/1988 |
| From: | Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8804210380 | |
| Download: ML20151K684 (2) | |
See also: IR 05000277/1987023
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APR 151988
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Docket Nos.
50-277 & 50-278
Philadelphia Electric Company
ATTN: Mr. C. A. McNeill
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Executive Vice President
Nuclear
2301 Market Street
Philadelphia, Pennsylvania
19101
Gentlemen *
Subject:
Inspection Nos. 50-P77/87-23 and 50-278/87-23
This refers to your letter dated February 1,1988, which provided additional
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corrective measures to those described in your November 30, 1987 response to
our letter dated October 28, 1987.
Thank you for informing us of the complete corrective and preventive actions
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you have or intend to take.
These actions will be examined during a future
inspection of your licensed prograni.
Your cooperation with us it, appreciated.
Sincerely,
ROBERT M. GALLO
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Robert H. Gallo, Chief
Operations Branch
Division of Reactor Safety
cc:
John S. Kenper, Sr., Senior Vice President-Nuclear
J. W. Gallagher, Vice President, Nuclear Services
E. C. Kistner, Chairman, Nuclear Review Board
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Dickinson M. Smith, Vice President, Peach Bottom Atomic Power Station
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Jack Urban, General Manager, Fuels Department, Delmarva Power & Light Co.
John F. Franz, Plant Manager, Peach Bottom Atomic Power Station
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Troy B. Conner, Jr., Esquire
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W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric
Bryan W. Gorman, Man ri, External Affairs
Eugene J. Bradley, i quire, Assistant General Counsel (Without Report)
Raymond L. Hovis, Esquire
Thoma:: Magette, Power Plant Siting, Nuclear Evaluations
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W. M. Alden, Director, Licensing Section
Doris Poulsen, Secretary of Harford County Council
Public Document Room (PDR)
Local Public Documerit Room (LPDR)
Nucicar Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
0FFICIAL RECORD COPY
8804210380 880415
ADOCK 05000277
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Philadelphia Electric Company
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bec w/ enc 1:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section: Chief, DRP
Robert J. Bores, DRSS
Public Document Room (PDR)
Nuclear Safety Information Center (NSIC)
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0FFICIAL RECORD COPY
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PHILADELPHIA ELECTRIC COMPANY
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2301 s ARKET ST9CCT
) J. BOX 8699
PHILADELPHI A. PA.191o1
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1215) 8.*
5 001
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February 1,
1988
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Docket Nos. 50-277
50-278
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Mr. William V. Johnston, Acting Director
Division of Reactor Safety
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Region I
U.S. Nuclear Regulatory Commission
ATTN:
Document Control Desk
Washington, D.C.
20555
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SUBJECT:
Supplemental Response to Peach Bottom Inspect'on
Report No. 50-277/87-23; 50-278/87-23
Reference:
November 30, 1987 letter from J. W. Gallagher,
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(PECo) to W. V. Johnston, (USNRC)
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Dear Mr. Johnston:
This letter completes Philadelphia Electric Company's
response to your letter dated October 28, 1987 which transmitted
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a Notice of Violation and Inspeccion Report No. 50-277/87-23; 50-
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278/87-23.
The referenced letter provided the Company's initial
response, and stated that a complete response would be submitted
by Jan'tary 22, 1988.
The need for a one week delay of our
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submittal was discussed with Jacque P. Durr of your staff by W.
M. Alden, and was found acceptable.
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The initial response stated (on page 3) that a review to
identify items that had been received from the date of the
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inspection to the date of the letter would be performed by
December 8, 1987.
That review was performed and was expanded to
include all storeroom Quality coded items.
Safety-related items
procured as commercial grade without a supporting engineering
evaluation or procured from suppliers without invoking an
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approved OA program (not on Evaluated Suppliers List (ESL))
without an engineering evaluation were identified.
Approximately
1,300 such items were identified and require formal engineering
evaluation.
Approximately one-third of these items are installed
in the plant and two thirds are in the storeroom on "QA Hold".
A written corrective action program has been developed
to control the disposition of the approximate 1,300 items
requiring engineering evaluation.
The Peach Bottom Project
Manager is responsible for the overall coordination of this
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Mr. William V.
Johnston
February 1,
1988
Page 2
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corrective action ptogram.
Those it ems installed in the plant
will be dispositionec in accardance with the written program
prior to rtarting up either Peach Bottom unit.
The items not
installed kill be dispositioned in accordance with the corrective
action program prior to being teleased from OA Hold for safety-
relr*ed app)4 mtiont.
First, at evaluction of each item to
contirm that it performs a safety-rela'ed function will be
performed, either by the Nuclear Engineering Department or plant
technical staff.
Engineering evaluations will be performed for
the items verified as safety-related to determine th'ir safety
function and the characteristics which are critical to performing
the safety function,
nd identify inspection, test and
documentativn requirements, as appropriate, to assure that such
items are suitable.
The engineering evaluations will be
performed either by the Nuclear Engineering Department or plant
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technical staff, and the Nucl?ar Engineering Department will
approve all plant technictl staff evaluations.
To prevent recurrence of this violation the Peach Bottom
administrative procedu:e covering material procuremer.t, A-27,
"Procedure For Material Control System", has been extensively
revised.
Previously, A-27 permitted procurement of commercial
grade material for safety-related applications with authorization
from the Quality Assurance Division.
Prior to authorization,
either a formal engineering evaluation, a less comprehensive
engineering review or an informal Quality Assurance evaluation
was performed.
This inconsistent approach was a weasness and has
been corrected by the revision of A-27.
A-27 now requires an
evaluation and written authorization from the Nuclear Engineering
Department to procure commercial grade material for a safety-
related application.
The plant technical staff or Nuclear
Engineering Department now performs technical evaluations and
specifies the appropriate acceptance methodology to properly
dedicate commercial grade items prior to safety-related
applicaticis.
The Nuclear Engineering Department reviews plant
staff evaluations prior to giving authorization.
Unresolved item number 02 in paragraph 3.3 of the
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inspection report expressed NRC concern with the fact that
material had been procured for safety-related applications from a
non-ESL supplier.
This matter has been corrected by the revision
of A-27 which now clearly requires that safety-related items be
procured only from evaluated suppliers (on ESL).
If the selected
supplier does not maintain an acceptable Quality Assurance
Program, the Nuclear Engineering Department establishes
compensatory Quality Assurance measures to assure the quality of
the product in accordance with the Nuclear Engineering Department
procedure described in the Company's initial response letter (on
page 4).
The revision of A-27 also expanded the controls on non-
conforming items to allow "conditional release" for installation
prior to completion of the engineering evaluation.
A Maintenance
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Mr. William V. Johnston
Februnry 1,
1988
Page 3
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Request Form (MRF) specific to each of the "corditior. ally
released" non-conforming items will be issued and will not be
cloeod cut until the non-conformance is resolved.
Naclear
Engineering Department evaluation and concurrence for the
"conditional release" of those non-conforming items on hold for
engineering evalaction is now required, in adcition to Plant
Operations Review Committee approval.
Further. A-27 prohibits
the plant system in which the "conditionally released" item is
installed f rcm bei:,9 considered opet able until the nen-
conformance is resolved.
Addit ional responsibilities have also
been established to track the resolution of non-conforming items.
The Nuclear Quality Assurance organization has completed
a study of procurement procedures / practices for items to oe used
in a nuclear safety-related applications.
The study identified
weaknesses in the procurement process which require epgrading.
Corporate responsibility has been established for further
improving our nuclear plant procurement process and practiccs,
and, in particular, to address the concerns identified in the
study.
The integration of the procurement process into the
restructured plant staff organizations will be reviewed.
Unresolved item number 03 in paragraph 4.3 of the
inspection report concerned th9 lack of a formalized training
program for personnel who perform quality control activities of
reccrd management and documen'. control.
A Nuclear Services,
Nuclear Administration Division procedure will be issued by
February 29, 1988 delineating the training requirements for
nuclear records managcment personnel and the responsibilities for
the training.
This procedure will cover both corporate and
station personnel and provide a mechanism for a permanent record
of the training conducted.
As part of the transition to the
recently testructured organizations, separate, but s i.mila r
procedures may be developed specific to each station; however, in
the interim, the Nuclear Services, Nuclear Administration
Division procedure will cover all nuclear records management
personnel.
If you have any questions or require additional
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information, do not hesitate to contact us.
Very truly yours,
cc:
Addressee
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W. T. Russell, Administrator, Region I, USNRC
T.
P. Johnson, NRC Resident Inspector
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