ML20080N891
| ML20080N891 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/19/1984 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20080N851 | List: |
| References | |
| NUDOCS 8402220374 | |
| Download: ML20080N891 (7) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 23ol MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. DALTROFF ELactnic pn non January 19, 1984 Docket Nos. 50-277 50-278 Inspection No. 50-277/83-34 50-278/83-32 1
Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory. Commission Region I 631 Park Avenue King of Prossia, PA 19406
Dear Mr. Starostecki:
Your letter of December 22, 1983, forwarded Combined Inspection Report 50-277/83-34 and 50-278/83-32.
The report cited two apparent violations of NRC requirement.
This letter will restate the violations and provide our responses.
1.
Technical Specification 6.8 and Regulatory Guide 1.33 (November 1972)-require implementation of procedures for fire protection and for general control of modification, maintenance, and repair.
Administrative Procedure A-30, Revision 4, June 10, 1981, Plant Housekeeping Controls, states that trash shall not be allowed to accumulate and create conditions that will adversely affect quality.
Contrary to the above, from 8:00 a.m.
to 1:20 p.m.,
November 22, 1983, combustible trash was allowed to accumulate in the Turbine Building near the elevator at the 135-foot elevation, creating a condition that adversely affected quality, in that it created a fire hazard for unprotected safety-related cabling in this area.
B402220374 840209 PDR ADOCK 05000277 G
PDR j
g Mr. Ric.hard W. Starostechi Page 2 I
Response
This' violation resulted from a communications breakdown between the groups responsible for removing debris from the _ plant.
The Philadelphia Electric Company has committed to I
upgrade plant penetration seals to meet the requirements of 10CFR50, Appendix R.
This project is the responsibility of the Philadelphia Electric Company's Construction Division and has been contracted to Brand Industrial Services, Inc. (BISCO).
BISCO has generated a_ considerable amount of debris in identifying and installing these penetration seals.
The Construction Division has recognized this problem and has taken the responsibility-for the removal of the debris generated by BISCO.
The removal of any debris within the plant, not associated with the BISCO project, is the i
responsibility of the station janitors, i
When the inspector' notified shift supervision of the debris in the turbine building, the Shift Supervisor informed the station-janitors.
Since a large BISCO work force had been sealing penetrations in the area, he also informed Construction Division.
Each group thought the other would remove the debris; and because of the misinterpretation of information, the removal was
' delayed.
The debris was being removed when the inspector made this second tour of the area.
A single conduit containing safety-related cable passes L through thislarea of the plant.
In the unlikely event
- of-fire damaging the enclosed cable, the automatic condensate storate tank low level suction' transfer of the High Pressure Coolant Injection System (HPCI) could be affected.
The HPCI turbine would still remain manually available.
The administrative controls designed to preclude the presence of transient combustibles will be continued.
These controls include ST_16.27 which requires an inspection of the area once per day to confirm the absence of transient combustibles.
Additionally, the site janitors and Construction Division have been instructed to be more attentive to plant requirements regarding housekeeping and of their responsibility to keep' these areas clear of combustibles.
Mr'. Richard W.
Starostecki Page 3 2.
10CFR50 Appendix B Criterion XII, Control of Measuring and Test Equipment (M&TE), requires measures to assure that measuring and testing devices are properly controlled, calibrated, and adjusted.
The licensee's approved Quality Assurance Plan, Revision 5, March 1983, Sections 3-MEM-12.1 and 2.12.3, as well as Maintenance Division Administrative Procedure MA-6, Revision 3, September 16, 1981, Procedure for Calibration and Control of Maintenance Division Measuring and Test Equipment (M&TE), requires that when M&TE are found to be out-of-calibration, an evaluation shall be made and
-documented of the. validity of previous inspection test results andLof the acceptability of items previously inspected or tested with the equipment.
Contrary to the above, between September 16, 1981, and December 8, 1983, in at least eighteen cases when torque wrenches and dial indicators were found to be out-of-l calibration, evaluations were not made of the validity of previous inspection test results and of the acceptability of'the items previously inspected or
. tested with the equipment.
I
Response
The cause of the violation was identified as individual.
L personnel' error.
The individual responsible has been counselled in the importance of doing a documented evaluation when a tooliis found to be out of calibration.
All-the calibration records have been reviewed for unacceptable "as found" calibration results.
The available measuring and test equipment usage reports for these tools have been collected and corrective action for each is being identified and recorded on calibration record sheets in accordance with procedures.
-The Maintenance Division Administrative Procedure MA-6 will be' revised to assure that usage reports for unacceptable "as found" calibrated tools will be kept for a period of five years.
Maintenance Division will be in_ full compliance with 10CFR50 Appendix B Criterion XII by July 1, 1984.
Mr. Richard W. Starostecki Page 4 Additional Concerns:
Beyond the specifics of this violation, the inspector requested the licensee to address three additional concerns: first, retention of Maintenance Division M&TE Usage Forms for audit purposes; second, adequate work group retraining programs dealing with revised procedures; and third, evaluation of inspection findings for applicability to work groups other than ones specifically cited.
1)
Measuring and Test Equipment (M&TE) Usage Forms utilized by the Maintenance Division presently are not required by procedure to be kept after a calibration cycle.
After review of this apparent violation, MA-6 will be revised to have the unacceptable "as found" calibration results evaluated by a member of the Maintenance Division Engineering Section.
As previously stated, MA-6 will also be revised to assure usage reports for unacceptable "as found" calibrated tools will be kept for a period of five (5) years.
2)
Philadelphia Electric Company work-group training and retraining has always been viewed as an item essential to efficient work practices.
During the Winter of 1982-83, approximately 120 Maintenance Division personnel received training / retraining in OA/QC, Maintenance Division - Control of Procedures, Maintenance / Plant Interface, Maintenance Division - Training and Certification of Personnel, and Maintenance Division - Conduct of Work.
A review of MA-6, Control of Measuring and Test Equipment, was included in all classes.
The MA-6 review included:
Purpose and Intent, Responsibility, Program, and Documentation and Records.
Maintenance Supervision, Engineers, NDE and QC Personnel, Foremen, Assistant Foremen, Sub-Foremen, and Upgrade 1st Class Personnel were included in the Training / Retraining Clasces.
The next training class, planned to start before July 31, 1984, will highlight changes made to procedures as a result of identified deficiencies.
Mr. Richard W. Starostecki Page 5 3)
The following paragraphs address the inspector's last additional concern dealing with the evaluation of-inspection findings for applicability to work
. groups other than ones specifically cited.
A.
. Copies of all NRC IE Inspection Reports that are sent to the Vice President of Electric Production are forwarded, for information and evaluation purposes, to the Senior Vice President of Nuclear Power, the Vice President of Engineering and.Research, the Manager of Electric Production, the Superintendent of the Nuclear Generation Division of the Electric Production Department, and the Superintendent of the Quality Assurance Division of the Electric Production. Department.
Electric Production QA Division Audits go to all members of the Nuclear Review Board (NRB) and affected supervision.
All completed non-compliance reports' fro'm these audits with Correctivo Action, Statement'of Cause, and Correction Action Taken to Prevent Recurrence-are sent< to all members of the NRB and affected supervision.
Audits are discussed at the NRB, meetings and included in the NRB minutes.
All EPOA Audit NCR's and Corrective Actions are listed in the QA Division, Activity Report and distributed to the Vice President of
' Electric Production's staf f twenty-four times
- a. year.
Significant items from this report are discussed at the Vice Presient of Electric Production'E twice-monthly staff meetings.
B.
'A review of the Construction Division, and Research and Testing Division procedures and practices was performed.
Construction Division procedures at Peach Bottom comply with the approved Quality Assarance Plan, Volume 1, Revision 7, Paragraph:12.2.l(i), which' requires that an investigation be performed upon notification to the'using organization that "as found" conditions do not' meet _the required accuracy of the measuring or test equipment.
Construction Division procedure CD 12.1, s'
s
Mr. Richard W. Starostecki Page 6 Rev.ision 1 - Procedure for Calibration and Control of Construction Division Test Equipment - requires that all test equipment returned from calibration be placed on " HOLD" until examined by a construction Division OC Inspection.
If a Test Data Sheet indicating that the test equipment was found out of calibration is supplied with the returned test equipment, the Construction Divison OC Inspector is required to review the Test Equipment Usage Report to determine the need for tests.
When the error of the test equipment exceeds the allowable tolerance of a particular test, retests are to be performed.
If ratests are not practical, then a Nonconformance Report (NCR) is to be initiated in accordance with procedure ERDP 15.1, Revision 3 - Procedure for handling Nonconformances.. Engineers in the Mechanical or Electrical Engineering Division are responsible for dispositioning these NCR's.
Presently, the Test Equipment Usage Report may be destroyed only after the Construction Divison QC Inspector has notified the Site Lead Man that the test equipment is acceptable
.for.use.
However, after review of this violation, the Construction Division procedures will be changed to retain the Usage
. Report Form for five years.
C.
The Research and Testing Division has been adhering to the procedures regarding out-of-tolerance measuring and test equipment in procedures RT-12-50007 and RT-12-50008.
Procedure RT-12-50007, Rev. O, Control of Calibration of Primary, Secondary and Tertiary Standard Instruments, requires that an investigation be performed to determine the acceptability of items inspected with a standard which, subsequent to the use of the standard, is found to be out-of-tolerance.
Proocedure RT-12-50008, Rev. 2, Control of Calibration of Portable Test Equipment, requires the user group be notified by the end of the following working day when "As Found" conditions are not within the prescribed tolerance.
Research and Testing Division Instrument Calibration Records are kept for the life of the plant.
e O
Mr. Richard W. Starostecki Page 7 Within the E&R Department, the R&T Division retains responsbility for calibration of measuring and test equipment itsed by tne E&R Department and for the calibration of standards used to calibrate such equipment.
The most recent audit of this activity performed by the E&R Department QA Section, dated 8/23/83, established that documented investigations were performed for standards found to be out-of-tclerance to determine the acceptability of items tested or inspected with such standards.
If there are any further questions, please do not hesitate to contact us.
l Very truly yours, 7
A)
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R. Blough, Site Inpsector s
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