ML20198C264
| ML20198C264 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/05/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198C255 | List: |
| References | |
| 50-278-85-32, NUDOCS 8511120035 | |
| Download: ML20198C264 (2) | |
Text
F i.,
APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company Docket No. 50-278 Peach Bottom Atomic Power Station, Unit 3 License No. OPR-56 During an inspection from September 9-13, 1985, and in accordance with the NRC i
Enforcement Policy (10 CFR 2, Appendix C), the following violations were identified:
l A.
10 CFR 50, Appendix B, 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.
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 are 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 Con-trol inspection for the fuel reconstitution effort was being performed by persons of the same group performing the activity. These inspection per-sonnel were also reporting directly to the same supervision responsible for the work.
Secondly the personnel performing the Quality Control in-spection had not been qualified in accordance with company training pro-grams and no certification of inspector qualifications was being maintained.
This is a Severity Level IV Violation (Supplement 1).
8 51112g ag$
2 s
B.
Peach Bottom Atomic Power Station, Unit 2 & 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).
1.
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 inspec-tion of the peripheral rod lower end plate (LEP) shall be con-firmed by visual examination of all four sides of the lower tie plate." QC signature #5 confirms that the tie rods are bottomed l
out.
Contrary to the above, on September 13, 1985, the Quality Control inspector failed to perform step V-2 of Section V for the reassembly l
of donor bundles. The bundles were reassembled correctly and all the tie rods were verified to be bottomed out by the operator as I
witnessed by the NRC inspector.
2.
Procedure HP0/CO-10a, Conduct in Controlled Areas-Minimize Exposure requires the following:
Radiation rope or tape is a barrier. When it is necessary to reach across a tape or rope barrier, proper precautions have to be taken.
Contrary to the above, on September 13, 1985, a PECO employee who was observed reaching across the tape barrier without taking proper pre-cautions, such as wearing protective gloves before touching contami-nated material.
These two examples are a Severity Level V Violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to this office within thirty days of the date of the letter which transmitted thi., Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be cchieved. Where good cause is shown, consideration will be given to extending this response time.