ML20248E235

Forwards Summary of Issues Re Verification of Quality of Certain Types of Activities Performed for Mods at Facility. Mods Cover Automatic Depressurization Sys/Msiv Instrument Nitrogen Accumulator & Svc Water Pipe Replacement

ML20248E235
Person / Time
Site:	Peach Bottom
Issue date:	09/27/1989
From:	Butler W Office of Nuclear Reactor Regulation
To:	Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8910050112
Download: ML20248E235 (6)

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',- September 27, 1989

-Dockets-Nos.- 50-277/278 Philadelphia Electric Company

' ATTN: . Mr. C. A. McNeill Executive Vice President-Nuclear

' Correspondence. Control Desk P.O. Box 7520 n1 Philadelphia, Pennsylvania .19101 L

Dear Mr. McNeill:

RE: PEACH BOTTOM ATOMIC POWER STATION, UNIT NOS. 2 AND 3 The NRC staff has received information from several individuals t.oncerning the

verification of the-quality of.certain types of activities performed for several modifications at Peach Bottom, Unit 3. The modifications are the Emergency Service Water Pipe Replacement (Modification No. 2106) and the ADS /MSIV Instrument Nitrogen Accumulator (Modification No. 1660). The issues involved were discussed with you in our meeting of September 18,'1989 at the site and in further detail with J. Madara, M. Pratt, J. Austin and D. McGarrigan on September 18, 1989. The issues are also described in the enclosure.

We request that you provide a response to each of these issues. The response should include (a) your view on the applicability of the alleged issue to the PBAPS, (b) a discussion of the relationship of the issue to similar work completed on Unit 2 even though the concerns have been initially. identified to be specific to Unit 3, (c) a discussion of any responsive or corrective action taken by PECo, (d) a discussion of the root causes for applicable concerns.

The root cause discussion should include the programmatic-aspects of the modification and quality verification processes and the adequacy of management involvement in ensuring an effective relationship between the modification and quality verification functions. The response should reference, but need.not include, the detailed documentation which supports the response's conclusions.

We request that your response be provided in an expeditious manner but no later than thirty (30) days from your receipt of this letter.

Sincerely,

/S/

Walter R. Butler, Director Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosure:

As stated '

DISTRIBUTION:

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• September 27, 1989 F

Dockets Nos. 50-277/278 Philadelphia Electric Company ATTN: Mr. C.- A. McNeill Executive Vice President-Nuclear Correspondence Control Desk P.O. Bcx 7520 Philadelphia, Pennsylvania 19101

Dear Mr. McNeill:

RE: PEACH BOTTOM ATOMIC POWER STATION, UNIT NOS. 2 AND 3  ;

The NRC staff has received information from several individuals concerning the-verification of the quality of certain types of activities performed for several modifications at Peach Bottom,. Unit 3. The modifications are the Emergency Service Water Pipe Replacement (Modification No. 2106 and the ADS /MSIV Instrument Nitrogen Accumulator (Modification No. 1660 . -The issues involved were discussed with you in our meeting of September 18, 1989 at the site and in further detail with J. Madara, M. Pratt, J. Austin and D. McGarrigan on September 18, 1989. The issues are also described in the enclosure.

We request that you provide a response to each of these issues. The response should include (a) your view on the applicability of the alleged issue to the PBAPS, (b) a discussion of the relationship of the issue to similar work completed on Unit 2 even though the concerns have been initially identified to 3e specific to Unit 3, (c) a discussion of any responsive or corrective action taken by PEco, (d) a discussion of the root causes for applicable concerns.

The root cause discussion should include the programmatic aspects of the modification and quality verification processes and the adequacy of management involvement in ensuring an effective relationship between the modification and quality verification functions. The response should reference, but need not include, tie detailed documentation which supports the response's conclusions.

We request that your response be provided in an expeditious manner but no later than thirty (30) days from your receipt of this letter. 3 i

Sincerely,

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Walter R. Butler, Director Project Directorate I-2 l Division of Reactor Projects I/II Office of Nuclear Reactor Regulation l l

Enclosure:

As stated

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Mr. George A.. Hunger, Jr. Peach Bottom Atomic Power Station, Philadelphia Electric Company Units 2 and 3 cc:

Troy B. Conner, Jr. , Esq.

Single Point of Contact 1747 Pennsylvania Avenue, N.W. P. O. Box 11880 Washington, D.C. 20006 Harrisburg, Pennsylvania 17108-1880 Philadelphia Electric Company Mr. Thomas M. Gerusky, Director ATTN: Mr. D. M. Smith, Vice President Bureau of Radiation Protection Peach Bottom Atomic Power Station Pennsylvania Department of Route 1, Box 208 Environmental Resources Delta, Pennsylvania 17314 P. O. Box 2063 Harrisburg, Pennsylvania 17120 Philadelphia Electric Company ATTN: Regulatory Engineer, Al-25 Mr. Albert E Steel, Chairman Peach Bottom Atomic Power Station Board of Supervisors Route 1, Box 208 Peach Bottom Township Delta, Pennsylvania 17514 R. D. #1 Delta, Pennsylvania 17314 Resident Inspector U.S. Nuclear Regulatory Commission Public Service Commission of Maryland Peach Bottom Atomic Power Station Engineering Division P.O. Box 399 ATTN: Chief Engineer Delta, Pennsylvania 17314 231 E. Baltimore Street Baltimore, MD 21202-3486 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Mr. Tom Magette 475 Allendale Road Power Plant Research Program King of Prussia, Pennsylvania 19406 Department of Natural Resources B-3 .

Mr. Roland Fletcher Tawes State Office Building Department of Environment Annapolis, Maryland 21401 201 West Preston Street Baltimore, Maryland 21201 1

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ENCLOSURE' '

SUMMARY

OF ISSUES Item A

'During the Mod 2106 Instrument Tubing Modification the QCI was requested to do a final inspection. NCRs on the mod were not made available to the QCI and some NCRs were known not to have yet been dispositioned. Some ERRF's had not been concurred in.

This was said to be raised during mid-June to early July by the QCI to two levels of supervision, the QC Lead and the Superintendent of QC. Discussions also involved the Mechanical Engineer. The response to these issues, as understood by the QCI, reflected only a scheduler need to complete the modification and was not responsive to the need for adequate documentation to support QC activities.

' Item B During Mod 2106 Instrument Tubing Installation a final QC inspection was called for on a portion of tubing that was missing the tubing fittings, i.e. the installation was incomplete. Fittings were added later but were not present when this final QC inspection was requested.

Item C CAR PC 89027412 on Mod 2106 concerns was initiated on July 5, 1989. The CAR was said to be voided on July 7,1989 within a short time of departure from the site of its originator.

Item D As of July 24, 1989 a QCI stated that certain mod 2106 instrumentation documentation packages were under the control of the QCI within the plant for periods of several days or more.

Item E l

For Mod 2106 valve installation reports; the Internal Defects / Conditions was said to be marked as N/A for all valves in Mod 2106. The QCI was not aware of any basis for this especially considering that this represents bypassing of a QC hold point.

Item F Mod 1660 accumulators in the drywell are said to have no documented clean checks. QCI was asked to sign off that these clean checks had been done on the basis that associated actions required by specification 301 and CD 5.2 had been accounted for as complete. QCI's position was that positive, discrete i evidence of successful performance of the clean checks, such as a marked up '

drawing showing a signoff for these clean checks, was required as a basis for the QCI's signoff.

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G It was said that the Mechanical Engineer agreed to process an NCR on this issue and that therefore it may have been dealt with.

Item G It is said that for Mod 2106 instrument tubing supports in RHR rooms A, B, C, '

D the holes in the walls were drilled deeper than the specified 2 inch depth and that an NCR was. originated for this condition. ,

i Item H Mod 2106 instrumentation tubing in D RHR room was the subject of CAR PC 89027412. Shortly after issuance of the CAR, and while action on its resolution was still pending, the involved QCI was said to be directed by the involved Mechanical Site Lead Man to resume inspections. This is said to have occurred in a fashion that reflected conflict and potentially an attempt to intimidate the QC personnel involved.

Item I Concerning the Mod 2106 Instrument Tubing walkdown in early July 1989, it is said that a QCI's explanation to the Site Lead Man of the items required to be in the tubing package to support the QCI's inspection was met with the response that provision of these items was a courtesy.

Another occasion prior to early in July is said to have called for a verification by the Site Lead Man of material heat numbers. Upon arrival the Site Lead Man is said to have exclaimed that his verification was not a necessary step in a fashion which could have b'een interpreted as intimidating by the QCI.

In late June 1989 it is said that the QCI was requested to verify clean checks 4 and fit-ups on several welds but could not do so because no drawing documenting that these activities had been done was available. This is said to have been followed by an exchange between the Site Lead Man and the QCI that overtly  ;

. reflected conflict and potentially an attempt to intimidate the QCI. '

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ENCLOSURE List of Documents

1. NRC Integrated Assessment Team Inspection, Report No. 50-277/89-81; 50-278/89-81 dated March 6, 1989 reporting on inspection conducted during February 3-17, 1989.

2. LER  ;

Inspection Report 50-277/89-16; 50-278/89-16 dated June 26, 1989 and the licensee's response dated July 19, 1989 concerning Mod 5061.

3. Documents from July 25, 1989 visit to plant (a) File Copies of Corrective Action Requests (CAR) PA 88-513-01, 02, 03, 04, 05, 06, 07, 08, 09 and 10.

(b) Memorandum of D.R. Helwig and F.J. Coyle, PBAPS Modification Program Evaluation, March 27, 1989 (c) Memorandum of D. E. McGarrigan to J.M. Madara, " Action Plan for Modifications Quality Control Inspection Guidelines," April 6, 1989, (d) Memorandum of D.R. Helwig, " Limerick and Peach Bottom Review of QA/QC Program Adequacy for Modifications," January 13, 1989.

(e) Memorandum, S.J. Kowalski to J.M. Madera, " Quality Issues Identified by Root Cause Analyses of the Peach Bottom Modification Process and Control of Design Interface Audits," with 7 attachments, June 14, 1989.

(f Procedure A-14, Plant Modifications, Rev.16.

(g NA-03N001, Control of Hardware Nonconformances, Rev. 0 (h Computer printout of nonconformances on mods 1457, 1660, 2106, 5051 i for Unit 3, July 26, 1989. '

(i) NQA-25, Corrective Action, Rev. 1 (j) 'G 3.8-7/NEDP 3.8, Procedure for Processing Engineering Review Requests, Rev. 12.

(k) NEDP 3.11, Procedure for Processing Engineering Work Requests, Rev.

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(1) CD 5.2, Procedure for Installation of Piping Systems at Peach Bottom, Rev. 5 (m) Safety Evaluation for Mod 2106, Rev.1 (n) Desk Top Procedure for Mod 2106 Composite Document Package Review, August 4, 1989 (o) CAR PC 89024411 to Supt. Modifications on Mod 2106 on June 23, 1989.

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