ML20236X148
| ML20236X148 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/30/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8712090009 | |
| Download: ML20236X148 (4) | |
Text
o-PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 1215) 841 5001 JOsgPH W,GALLAGHER
.uT/.l"1"I,"l...
November 30, 1987 Docket Nos. 50-277
-)
50-278 i
'I William V. Johnston, Acting Director i
Division of Reactor Safety l
Region I U.' S. Nuclear Regulatory Commission l
. ATTN: Document Control Desk i
Washington, D.C.
20555
)
Subject:
Partial Response to Peach Bottom Inspection Report No.50-277/87-23; 50-278/87-23
Dear Mr. Johnston:
1 This is in response to your letter dated October. 28,-1987 transmitting Peach Bottom' Inspection Report 50-277/87-23; 50-278/87-J 23.
The purpose of this letter is to provide a partial response and inform the'NRC that additional time is1nceded to complete our-response.
Appendix A of your letter addressed an item which did cot 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 partial 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.
10 CFR 50, Appendix B, 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.
hR ADO K O
I 8
~
i fMr. W. V. Johnston November.30, 1987 j
Page 2 1
l l
i Philadelphia Electric Company Qualit'y Assurance Plan for Peach Bottom Atomic Power Station, Volume III, Section SP 3.2 requires l
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 previously reviewed for a different' application.
Such commercial-grade purchases are defined as quality assured items (procurement under the. full' auspices of a-QA Program are classified as nuclear safety-related items).
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 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.
(3)
PO #.BW 298553, PECO Code 115-20637, Muesco Air Operated 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.
This is a Severity Level IV Violation (Supplement I).
Admission or Denial of Apparent Violation PECO acknowledges that the item above is a violation of NRC and PECO QA Plan requirements as stated.
Additionally, PECO recognizes that this violation may indicate the need for improvements in the procurement process.
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.
l l
L.___
1 C
1
~
Mr'. W. V.:Johnston November 30, 1987
.Page 3 p
' 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 tra remaining three (3) items were determined to be installed in the plant. ~The eleven (11) items on "QA Hold" will.not be used in safety related applications until appropriate evaluations / inspections are performed. 'For the items installed in the plant, appropriate e*raluat' ions / inspections will be performed prior to startup from the l
current outage.
Prior to restart, appropriate corrective actions will' j
be identified and taken, regarding the missing spring.
The following actions have beea taken to prevent recurrence of this violation:
o Immediately after the. inspection, the station Quality Control (QC) Group established a policy of rejecting
- 1) purchase orders of commercial grade 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.
o From the date of this letter forward, any items received i
on-site will not be used for safety-related applications l
until appropriate evaluations / inspections have-been performed if.0C determines that.1) it was procured as q
-commercial grade without supporting documentation of an i
engineering evaluation, or 2) it was procured from a non-evaluated supplier, o
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 l
supplier.
Any items in stock determined to be in this j
category, will not be used in safety-related i
applications until appropriate evaluations / inspections are performed.
For any items installed in the plant l
determined to be in this category, appropriate 1
evaluations / inspections will be performed prior to
{
startup from the current outage.
)
i o
The PECo Nuclear Quality Assurance organization has l
initiated a study of procurement procedures / practices
)
g,',p q.;
tQ,Q o
n q..
o c p' 1.
. Novsmbar ~ 3 0', : 19 87 -
- Mr.:.W..V. Johnstonj.g;
'4
- Page.4, o...
M 7g.
f' a
gi oforTitems-.tolbe used'in; nuclear" safety-related-
! applications.i This study will identifyLany. problems
- that require; further:l investigation..and eval'uation : to -
f
- determine! the'"necessary ~ corrective l actions" to.LimproveJ 3..
.the. procurement process.
l-1
_LAn-'engineieringLprocedure'was issued on,0ctober 6,fl987.:to-
' control the. procurement..ofisafety'_related' items;from suppliersLwho do '
'notemaintain 101CFR.:50, Appendix B'QA1 Programs.
TheLprocedure(isi 4
- based.upon Regulatory Guidebl.123'and-ANSI N45.2.13,.and.o requires'an'
'J
- Engineering evaluation-to determine the critical' characteristics of.
thefitems:and:the necessary inspection requirements.
a.
PECoJwilll submit:aisupplementary.. response, outlining the.>'
4
- action plan.to improve the procurement process, by' January 22,.1987..
If you have any; quest' ions, pleaseldo'.not hesitate ~tofcontact0
~
us.
- Very_Truly,yours, Q b wg'--
m,
?
cc:
.' Addressee W. ' T.:. Russell,: Administrator, Region I,.- USNRC T. P. Johnson, USNRC Resident Site Inspector r
1.-
. f ' !-'
j, Lz L,
A-
_ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ -