ML19351D358
| ML19351D358 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/15/1980 |
| From: | Robert Carlson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8010100024 | |
| Download: ML19351D358 (2) | |
See also: IR 05000352/1980012
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 1
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KING OF PRUSSI4 PENNSYLVANIA 19406
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Docket Nos. 50-352
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50-353
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Philadelphia Electric Company
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ATTN: Mr. John S. Kemper
Vice President
Engineering ar.d Research
2301 Market Street
Philadelphia, Pennsylvania 19101
Gentlemen:
Subject: Combined Inspection 50-352/80-12; 50-353/80-10
Some copies of the subject inspection report may have been distributed without
page 11. A copy of that page is enclosed with this letter.
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Sincerely,
Robert T. Carlson, Chief
,
Reactor Construction and
Engineering Support Branch
Enclosure: As stated
cc w/ encl:
V. S. Boyer, Senior Vice President, Nuclear' Power
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8010100 024
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11
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1) The FCR's were complete and confomed to the required
fomat.
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2) The FCR's were adequately controlled in distribution,
fili.ng and retrievability.
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3) All FCR's were approved by project and/or field engineering
and contained adequate technical description of requested
changes..
However, the inspector noticed that a substantial number of these
documents contained corrections by "Wite-out" correcting fluid
obliterating the previous information; also the new infomation
entered onto them was not initia11ed and dated by the individual
entering such infomation. A few FCR's also contained cut-outs
from drawing's, pasted on them showing changes and other information.
The inspector questioned the propriety of such practices on controlled
pemanent records.
In response to the inspector's question, the
licensee and the A/E's Resident Engineer replied that there are no
provisions or rules on the project which specifically prohibit these
practices; and they have been using 'these practices extensively
on this project for a number of years. This item is unresolved
pending further review.
(352/80-12-06;353/80-10-01)
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b.
The inspector noticed that a substantial number of FCR's
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had been issued for only one specific condition. These FCR's had
a note from design engineering indicating that the affected drawings
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would not be changed or revised to shcw the requested change.
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The- inspector determined that it is currently not required that the
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approved FCR's be even referenced on the affected drawings.
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response to.the inspector's concern in this regard, the licensee and
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the A/E's Resident Engineer indicat;ed that they have initiated a
program in April 1980 which 'will reference all approved FCR's on
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the affected drawings. Therefore, any changes not incorporated in
design will be readily traceable and retrievable for review and
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inspection during the plant life. However, the licensee's Quality
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Assurance Plan, Appendix W does.not designate FCR's to be a
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life-time record. The FCR's are designated as a one-year record
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by the licensee. Therefore, the inspector detennined that referencing
of FCR's on affected drawings does not adequately satisfy the irspec-
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tor's concern. A reference of an FCR on any drawing is of no value
if the FCR itself will not be available for the life of the plant.
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This item is considered unresolved pending review of licensee's evalu-
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ation.
(352/80-12- 07)
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