ML19350D405

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Notice of Violation from Insp on 801204-31
ML19350D405
Person / Time
Site: Limerick  
Issue date: 01/20/1981
From: Robert Carlson
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19350D392 List:
References
50-352-80-21, 50-353-80-19, NUDOCS 8104150439
Download: ML19350D405 (2)


Text

l APPENDIX A

, g NOTICE OF VIOLATION Philadelphia Electric Company Docket Nos. 50-352 Limerick Unit No. 1 and No. 2 50-353 t

License Nos. CPPR-106 CPPR-107 As a result of the inspection conducted on December 4-31, 1980, and in accord-ance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violations were identified:

A.

10 CFR 50, Appendix B, Criterion V, states, in part:

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances... Instructions, procedures, or drawings shall include appropriate quantitative and qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

The Limerick PSAR, Appendix D.4, states, in part:

..Bechtel Construction will have a Quality Control Program.

These programs shall cover the necessary quality control requirements... including appropriate elements of the following items:

D.4.3, Control of Special Processes, Test and Inspection 1.

The vendor shall operate under a controlled manufacturing system and shall have written procedures or instructions for control of special fabrication and construction processes such as welding.

2.

...shall have written procedures for control of the required testing and inspection programs...These programs shall cover all... weld fitup inspections...".

l Contrary to the above, the Bechtel Quality Assurance Manual - ASME Section III, Division 1, Document No. WD-1, paragraph 7.4, provides for sampling inspections (surveillance) without specifying a sampling plan. There are no quantitative or qualitative criteria for sampling rates, acceptance levels, or increased inspection frequencies set forth.

Records are not maintained to support a sampling inspection plan such as rejection rates.

This item applies to Unit No.1 and Unit No. 2.

This is a Severity Level V Violation (Supplement II).

B.

10 CFR 50, Appendix B, Criterion IX, states, in part:

"..special processes, including welding...are controlled and accomplished...in accordance with...speci-fications, criteria, and other special requirements.,,

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kppendixA 2

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...".

The " Installation and Maintenance Manual for Electrical Penetration Assemblies,"

8031-E-40-36-2, paragraph 5.2.4, states, in part, that: " Temperature resulting from welding, in excess of 3000F may damage parts of penetration assemblies...".

Contrary to the foregoing, about December 4,1980, containment electrical penetration 10Jx101B was welded utilizing welding procedure specification P8,P1-AT-Ag(CVN)1, which limits interpass temperatures to 3500F. This item applies to Unit No. 1 only.

This is a Severity Level V Violation (Supplement II).

Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to this office within twenty-five days of the date of this Notice, a written statement or explanation in reply, including:

(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.

Dated 28 8 /

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Robert T. Carlson, Chief l

Reactor Construction and Engineering Support Branch i

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