ML20138D816

Responds to NRC Re Violations Noted in Insp Rept 50-278/85-32.Corrective Actions:Fuel Reconstitution Work Halted,Two Purchase Orders Initiated & Fuel Handling Procedure Will Be Revised

ML20138D816
Person / Time
Site:	Peach Bottom
Issue date:	12/05/1985
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8512130307
Download: ML20138D816 (7)

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l l PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET

! P.O. BOX 8699 PHILADELPHIA. PA.19101 SHIELDS L D ALTROFF ELECTR C PR O C H)N December 5, 1985 Docket No. 50-278 Inspection Report No. 50-278/85-32 Mr. Stewart D. Ebneter, Director i Division of Reactor Safety U.S. Nuclear Regulatory Commission Region I 1

631 Park Avenue ,

King of Prussia, PA 19406 l

t Dear Mr. Ebneter Your letter dated November 5, 1985 forwarded Inspection

Report 50-278/85-32 for Peach Botton Atomic Power Station, Unit 3 and required a response by December 5, 1985. Appendix A of the Inspection Report letter addresses three items which do not appear to be in full compliance with NRC requirements. These

items are restated and followed by Philadelphia Electric I

Company's response.

Violation 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.

l 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.

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Mr. Stewart D. Ebneter Decembe r 5, 19 85 Page 2 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."

l Contrary to the above, on September 10, 1985, a contractor's Quality Control inspection for the fuel reconstitution ef fort was being performed by persons of the same group performing the activity. These inspection personnel were also reporting directly to the same supervision responsible for the work. i Secondly, the personnel performing the Quality Control inspection had not been qualified in accordance with company training programs and no. certification of inspector qualifications was

] being maintained.

This is a Severity Level IV Violation (Supplement 1) .

Response to Violation A Admission or Denial of Alleged Violation:

Philadelphia Electric Company (PECo) acknowledges the i violation as stated.

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J Reason for Violation:

A corporate headquarters based group, Fuel Management Section, is responsible for recommending action in the area of' fuel-related work. The Fuel Management Section Engineer-

, In-Charge informed the Reactor Engineer at the plant that the decision had been made to reconstitute fuel. Based upon this communication, qualified General Electric Company (GEco) personnel on-site were selected to reconstitute fuel as a continuation of the ongoing fuel inspection work, with one day notice. Thus, GEco personnel at Peach Bottom were authorized to begin reconstituting fuel before specific instructions had been issued identifying the necessary QC 4

requirements.  ;

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F Daceabor 5,1985 Mr. Stewart D. Ebnator Page 3 There were PECo QC personnel present on the refuel floor during the fuel reconstitution work. PECo QC personnel were assigned to . fuel movement accountability; however, no one was specifically overseeing the fuel reconstitution work involving fuel bundle assembly and disassembly. The PECo QC L personnel were aware that the GECo personnel were performing l the QC inspections; however, no one recognized that they were

not under the supervision of the on-site GEco QC Supervisor, l and thus not independent. The PECo Reactor Engineering Group, responsible for this work, did not assure that the QC requirements would be satisfied prior to authorizing the work to begin.

4 Significance or Extent of Violation 1

The significance of this event is minimal because the fuel 1

. reconstitution work was being performed by experienced

, individuals employed by GEco. The GECo pers. inel performing i the QC inspections were certified within the .iECo training i program as inspectors for fuel work. The QC inspections were being performed by these individuals who were also involved in the work. However, for each step requiring QC inspection, the individual performing the QC inspection was not the same

person who had performed the step being inspected. Thus, the

inspections were being " independently" performed, however, not by a person independent of the overall work activity.

Corrective Actions Taken and Results Achieved:

Fuel reconstitution work was immediately halted following i

notification of a potential violation. To satisfy the independence requirements of the Peach Bottom Quality

Assurance plan, two purchase orders were promptly ' initiated.

One purchase order provided GEco QC inspectors who were required to functionally report to the on-site PECo QC Supe rvisor. The other purchase order provided GECo personnel to perform the fuel reconstitution work and report to the PECo Reactor Engineer. In addition, each GECo QC inspector l was certified within the PECo QC program. They were indoctrinated to applicable procedures and this was l documented on a required reading ' list for each GECo j inspector.

PECo Quality Assurance performed an audit of the fuel reconstitution project on September 11 through September 12.

This audit encompassed, in part, review of the Fuel Handling Procedures used, qualifications of the personnel involved (PECo and GECo), and documentation. The absence of a i

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Mr. Stewart D. Ebneter December 5, 1985 '

Page 4

-purchase order was the only unacceptable finding. The auditor verified by review that the PECo QC group was documenting inspection activities correctly and that the PECo 4

OC Engineer was reviewing the appropriate documents prior to

! closure. Based on review of a sample of twenty-six (26)

I reconstituted fuel bundles, out of a total of forty-eight (48) completed at the time of the audit, the lack of independence did not reduce the quality of work performed.

Corrective Actions to be Taken to Avoid Future Non-Compliance:

4 It will be made clear that the Fuel Management Section acts in an administrative capacity, making recommendations to the Station Manager for fuel-related work. The initiation of purchase orders and the identification and implementation of QC requirements are the responsibility of the station.

Date When Full Compliance Will be Achieved:

Full compliance was achieved before fuel reconstitution work was permitted to resume.

i Violation B.1 Peach Bottom Atomic Power Station, Unit 2 and 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

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ANSI N18.7-1972 and Appendix A of USAEC Regulatory Guide 1.33 (November 1972).

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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, statess' " Check to ensure that all tie rods are bottomed out in the lower tie plate ' finger tight and non-tie rods seated. Proper inspection of Ohe peripheral rod lower end plate (LEP) shall be confirmed by visual examination l

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Mr. Stswart D. Ebn1ister Decembar 5, 1985 Page 5 of all four sides of the lower tie plate." OC signature

1. 5 confirms that the tie rods are bottomed out.

1 Contrary to the above, on September 13, 1985, the Quality i Control inspector failed to perform step V-2 Section V for the reassembly of donor bundles. The bundles were reassembled correctly and all the tie rods were verified to

! be bottomed out by the operator as witnessed by the NRC l inspector.

Response to Violation B.1 4

Admission or Denial of Alleged Violation:

PECo acknowledges the violation as stated. 3

, t Reason for Violation:

Fuel Handling Procedure FH-61 does not differentiate between 1 recipient and donor bundles. It is GECo standard practice not to perform the independent OC inspection which step V-2 requires for donor bundles. The training that the GECo individuals received does not require this step. Due to administrative oversight, a temporary procedure change was not processed to clarify this point.

Significance or Extent of Violations i

The bundles were reassembled correctly and the tie rods were

. verified to be bottomed out by the operator as witnessed by

! the NRC inspector. GECo assures us that as long as the tie i rods were threaded most of the way into the lower tie plate, i the safety significance of this incident is minimal. l i

Corrective Actions to be Taken to Avoid Future Non-i compliance:

1 The Fuel Handling Procedure will be revised before it is used again to clarify the intent of step V-2 for donor bundles.

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4 Mr. Stewart D. Ebneter Decembar 5, 1985

! Page 6 Violation B.2 Peach Bottom Atomic Power Station, Unit 2 and 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).

4 Procedure HPO/CO-10a, Conduct in Controlled Areas-Minimize Exposure, requires the following:

P 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 2

taking proper precautions, such as wearing protective gloves before touching contaminated material.

Response to Violation B.2 j

Admission or Denial of Alleged Violations i

! PECo acknowledges the violation as stated. A PEco QC l

Inspector reached across the tape barrier without taking

, proper precautions.

Reason for Violation:

The QC Inspector unintentionally failed to follow Health

. Physics procedures. Health Physics training instructs 1 against such an action. At the time, the individual did not j recognize What could result from his action.

i Significance or Extent of Violation:

The potential for contamination in this situation was low.

i The individual did not become contaminated; there fore, the safety significance of this specific incident is minimal.

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Mr. Stewart D. Ebneter December 5, 1985 Page 7 Corrective Actions Taken and Results Achieved:

The individual was counselled concerning the need to be more attentive to Health Physics procedures.

Corrective Actions to be Taken to Avoid Future Non-Compliance:

All QC personnel working on the refuel floor have been reinstructed to comply with Health Physics procedures.

Date When Full Compliance Will be Achieved:

Full compliance has been achieved.

Should you have any questions or require additional in formation, please do not hesitate to contact us.

Very truly yours,

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(gm cc T. P. Johnson, Resident Site Inspector l

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