ML20147D395

Ack Receipt of 871130 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-277/87-23 & 50-278/87-23.Request for Extension Until 880122 Agreed

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,

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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 ,pk

0FFICIAL RECORD COPY RL PB 87-23 - 0001.0.0 p

01/07/88 I

8801200163 880111 I

PDR ADOCK 05000277 I 5

O PDR I

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Philadelphia Electric Company 2

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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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1/7/88 1/f/88 1/ /88  :

OFFICIAL RECORD COPY RL PB 87-23 - 0002.0.0 1

01/07/88

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PHILADELPHIA ELECTRIC COMPANY

23o1 M ARKET STREET

P.O. BOX 8699

PHILADELPHI A. PA.19101

12151 841 5001

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November 30, 1987

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

Washington, 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.

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.

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Mr. W. V. Johnston November 30, 1987 ;

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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 '

previously reviewed for a different application. Such commercial

grade purchases are defined as quality assured items (procurements ,

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.

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(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).

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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 i

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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November 30, 1987 i

Mr. W. V. Johnston 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:

o 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,

o 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.

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

supplier. Any items in stock determined to be in this ,

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,

o 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 I

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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. .

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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