ML19320D393
| ML19320D393 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/26/1980 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML16341B393 | List: |
| References | |
| NUDOCS 8007210312 | |
| Download: ML19320D393 (2) | |
See also: IR 05000352/1979012
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Docket Nos. 50-352
50-353
Philadelphia Electric Company
ATTN: Mr. John S. Kemper
Vice President
Engineering and Research
2301 Market Street
Philadelphia, Pennsylvania 19101
Gentlemen:
Subject:
Combined Inspection 50-352/79-12 and 50-353/79-11
This refers to your letter dated April 10, 1980, in response to our letter
dated March 12, 1980.
Your response to Infraction B of the " Notice of Violation" states that PECO
does not believe the situation described represents a noncompliance and
suggests that NRC may have misinterpreted the Limerick PSAR, Appendix D,
Paragraph D.4.1.
You also stated that it is PEC0's position that it is not
required that every subcontractor establish and implement his own quality
control program.
We concur that every subcontractor is not necessarily required to establish
and implement his own quality control program.
It is required that an
appropriate quality control program be applied to all safety related work.
As stated in 10 CFR 50 Appendix B Criterion I and in item B of Appendix A
to our lett6r of March 12, 1980, the authority and duties of persons and
organizations performing activities affecting the safety-related functions
of structures, systems and components shall be clearly established and
delineated in writing. Your PSAR paragraph D.4.1 basically endorses this
regulatory requirement.
Subcontractors can be under a documented contractors
QA program; however, we require that QA requirements applicable to the
subcontractor's work be clearly delineated in writing.
For the work by the block wall subcontractor this was not done.
For example,
as described in item A of Appendix A to our letter of March 12, 1980 and
your reply thereto, it appears that no procedures for control of documents
used in performing the work were required.
It also appears that a verbal
agreement was made that Bechtel would do all the inspections for the erection
of the block walls and the materials that went into the walls. The NRC
Inspector requested objective evidence from PECO in an effort to determine
what QA program was established for this subcontractor.
No such evidence
was provided.
It appears that the QA program for the work perfonned by
this subcontractor was principally a verbal one.
Reclassification of the
item of noncompliance is not appropriate.
800721039
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Philadelphia' Electric Company
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Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of
Federal Regulations requires that your reply include, among other things,
the date when full compliance will be achieved.
Your letter of April 10,
1980 did not include a specific statement in that regard concerning items A
through C,-although in some cases a date could be inferred.
In order to
preclude misinterpretation and to comply with regulatory requirements, we
request that you provide that information.
We note that further reports
are planned by you concerning item D.
In as much as your letter did not clearly indicate the causes of these
items of noncompliance, the recognition of whian is necessary for fully
effective. corrective action, our inspectors will be alert for recurrence of
similar problems in the same or other areas of construction.
Thank you for informing us of the corrective and preventive actions documented
in your letter. These actions will be examined during a subsequent inspection
of your licensed program.
Sincerely,
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Boyce H. Grier
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Director
cc:
V. S. Boyer, Senior Vice President, Nuclear Power
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