ML19347B222
| ML19347B222 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/26/1980 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19347B215 | List: |
| References | |
| NUDOCS 8010140054 | |
| Download: ML19347B222 (4) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 (215]841 45o2 JOHN S. KEMPER v ec E#st ESID E NT gassesessnesse aseo assaances
- AUG 261980 Mr. Boyce Grier, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406
Subject:
USNRC IE Region I Letter dated July 24, 1980 RE: Site and Office Inspection of May 1-30, 1980 Inspection Report No. 50-352/80-08 and 50-353/80-07 Limerick Generating Station - Units 1 6 2 File: QUAL 1-2-2 (3S2/80-08 and 353/80-07)
Dear Mr. Grier:
In response to the subject letter regarding items identified during the subject inspection of construction activities authorized by NRC License Nos.
CPPR-106 and -107, we transmit herewith the following:
Attachment I - Response to Appendix A t
Should you have any questions concerning these items, we would be pleased to discuss them with you.
Sincerely,
$ $=j!-
J. S. Kemper Vice President Engineering 4 Research Dept.
Attachment i
8010149 c$y 4
ATTACHMENT I RESPONSE TO APPENDIX A Infraction A Appendix B, of 10CFR50, Criterion V, states in part:
" Activities affecting quality...shall be accomplished in accordance with these instructions, procedures or drawings...".
The Limerick PSAR, Appendix D, Quality Assurance Program, Paragraph D.4.6 states in part, that:
"...the vendor shall i
establish an inspection and testing plan to assure that the required inspection and tests are performed and to provide records of their performance...".
l The Reactor Controls, Inc. QA document L !i-1, Revision 6, in Paragraph 13.1 states that quality control shall inspect 10%
(minimum) of all non full penetration welds on a daily basis for pre-weld cleanliness, fit-up, pre-heat and welder identification.
Contrary to the above, on May 13 and 14, 1980, welding had been performed on the control rod multi-functional supports and the Reactor Controls quality control organization had not inspected the required 10% daily minimum of the fillet welds being deposited
]
for pre-weld cleanliness, fit-up, pre-heat and welder identification.
i 1
Response to Infraction A Partial penetration welding performed on days in which the Reactor j
Controls quality control organization did not perform the required 10% in-process inspection has been, subsequently inspected and
- accepted, i
Reactor Controls resumed daily in-process inspections in accordance
)
with Addendum LM-1, Paragraph 13 of the RCI Quality Assurance Manual on May 16, 1980.
In order to prevent recurrence, Reactor Controls, Inc. reviewed l
the subject inspection requirements with their jobsite personnel and conducted a quality assurance training program for their j
personnel on May 20, 1980.
Full compliance was achieved on May 20, 1980.
I 1/3 50-352/80-08 50-353/80-07
j Infraction B Appendix B, of 10CFR50, Criterion V, states in part:
" Activities affecting quality...shall be accomplished in accordance with these instructions, procedures or drawings...".
The Limerick PSAR, Appendix D, Quality Assurance Program, Paragraph D.6.4 states in part, that:
Bechtel Construction Department...is responsible for construction of the plant to approved engineering specifications, drawings, and procedures...".
Bechtel Job Rule G-39, Revision 1, states in part that Field i
Deviation Disposition Requests (FDDR's) are controlled as technical documents and distributed to concerned parties and that changes to G.E.
equipment are authorized by G.E.
approved FDDR's.
Contrary to the above, on May 20, 1980, welding to the G.E.
supplied consoles (10C681, 10C665 and 10C602) had commenced with FDDR #HHI-1000 (Revision 0), which had been superceded.
The i
current revision was Number 2.
Response to Infraction B GE has issued revision 3 to FDDR #HH1-1000 for welding consoles 10C681, 10C655, and 10C602.
Revision 3 does not supercede revision 2.
Revisions 2 and 3 approve additional weld details and do not 4
require rework resulting from the welding done to revision 0.
Revisions 2 and 3 were processed in accordance with job rule G-39.
The welding was completed on 8/8/80 on the above panels.
All weld request forms were rechecked by the area superintendents to assure that attachments had the latest re' vision number.
Bechtel QC has corrected inspection report QCIR M-602-W-1, which covers welding of the above panels, to reference the proper revisions of the inspection criteria.
Because the attachments to the weld request forms are design documents, they should be controlled in accordance with job rule G-5.
To prevent recurrence of the problem, Bechtel construction had a training session with area electrical superintendents, area electrical enginecring, and electrical foremen on 6/12/80 to reinstruct them on the necessity of having the proper revision of working documents in the possession of the workmen.
The above actions were completed on or before August 18, 1980.
Actions taken by Bechtel QC to prevent recurrence are addressed in the response to Infraction C.
I 2/3 50-352/80-08 50-353/80-07
_g.
Infraction C Appendix B of 10CFR50, Criterion X, states in part: "... inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instruction.s, procedures and drawing for accomplishing the activity...".
The Limerick PSAR, Appendix D, Quality Assurance Program, Paragraph D.6.4 states in part:
"...the quality control engineers are responsible for preparing inspection plans, performing QC inspections, including final acceptance of the work...".
The Bechtel Proj ect Special Provision Notice SF-PSP-G-6.1, Revision 2,
states in part:
"...the documentation coordinator shall inform the responsible construction QC engineer implementing an inspection record if an inspection criteria referenced on that inspection l
record is revised.
It is the construction QC engineer's responsibility to revise the inspection record to reflect
' applicable revisions' to' inspection criteria...".
Contrary to the above, as of May 30, the inspection criteria for two quality control inspection records (QCIR-E-1193-W-1 and l
QCIR-E-1163-W-2) were revised and the QC engineer failed to revise the inspection. record to reflect the applicable revisions to the l
inspection criteria.
i Response to Infraction C l
Bechtel QC has corrected inspection reports QCIR-E-1193-W-1 and QCIR-E-1163-W-2 to reference the proper revisions of the inspection criteria.
Work completed in the scope of these inspection plans was reviewed and it was determined that neither the welds nor the quality control inspection thereof were adversely affected.
1 To prevent recurrence, the Project Field Quality Control Engineer for Bechtel has issued Administrative Instruction #156 on August 25, 1980 providing direction for entries of inspection criteria revisions and review of all continuation sheets for legibility of data entries.
In addition, a training class was held on June 12, 1980 for all discipline Quality Control Engineers stressing the proper review of inspection criteria.
PECO has performed a follow up audit as a result of this infraction, The results are available fcr the NRC inspector's review of corrective action associated with this item.
The above actions were complete on or before August 25, 1980.
I 3/3 t
50-352/80-08 50-353/80-07
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