ML20030A851
| ML20030A851 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/10/1981 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20030A846 | List: |
| References | |
| NUDOCS 8107290089 | |
| Download: ML20030A851 (4) | |
Text
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PHILADELPHI A ELECTRIC COM PANY 2301 M ARKET STREET P.O. BOX 8699 1881 -1981 PHILADELPHI A. PA.19101 (215) 841-4 5o 2 JOHN 5 KEMPER VIC E PRES 4DE NT JUL 101981 Mr. Boyce Grier, Director United States buclear Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406
Subject:
USNRC IE Region Letter dated June 26, 1981 RE: Site Inspection of May 1-29, 1981 Inspection Report No. 50-352/81-08 & 50-353/81-06 Limerick Generating Station - Units 1 and 2 File:
QUAL 1-2-2 (352/81-08 & 353/81-06)
Dear Mr. Grier:
In response to the subject letter regarding items identified during the subject 1-apection of construction activities authorized by NRC License Nos. CPPR-106 and -107, we transmit herewith the following:
Attachment I - Response to Appendix A Also enclosed as required by the Notice of Violation, is an affidavit relating to the response.
Should you have any questions concerning these items, we would be pleased to discuss them with you.
Sincerely, IU JPE/gra Attachment Copy ;o:
Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, D.C.
20555 J.
P.
Durr, USNRC Resident Inspector 81072900P9 810722 PDR ADOCK 05000352 G
~.
C0l?MONWEALTH OF PENNSYLVANIA ss.
COUNTY OF PHILADELPHIA JOHN S.
KEMPER, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the holder of Construction Permits CPPR-106 and CPPR-107 for Limerick Generating Station Units 1 and 2; that he has read the foregaing Response to Inspection Report Nos. 50-352/81-08 and 50-353/81-06 and knows the contents thereof; 1
I and tr tements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
hd,. S. W.,lu_t Subscribed and sworn to before me this lC day
, lh of W2n_/
t Notary P b E 'ADETH H.D Notary wje m,3 b W A3 ion Exp,res Jan. 30, hay
ATTACHMENT I RESPONSE TO APPENDIX A Violatien
-A 10CFR50, Appendix B, Criterion XV, states in part:
" Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures".
The Limerick PSAR, Appendix D.4.10, states in part:
"The vendor shall have critten procedures governing the identification, control and disposition of materials, parts, or equipment that do not meet specification requirements".
The Bechtel Nuclear Quality Assurance Manual,Section IV, Number 7,
paragraph 3.1, states in part:
" Construction quality control procedures for processing nonconforming items shall provide for:..."
g.
Obtaining approval signatures of authorized personnel for conditional release of nonconforming materials."
The Project Special Provision G-3.1, paragraph 3.3, states in part:
" Nonconforming items documented on a Nonconformance Report may be released for installation or further work subject to the following conditions:
(1)
The installation and further work is approved by the Froject Field Engineer with the concurrence of the Project Field Quality Control Engineer.
Concurrence of the Lead Site Quality Assurance Engineer and/or the Project Quality Assurance Engineer is required for "Q" listed and ASME Section III code items; and the Authorized Inspector for all ASME Section III code items.
Approval and concurrence is documented by signature and date on the conditional release form...
(3)
The conditional release shall be attached to the nonconformance report and applicable restrictions, if any, on use or further work to the nonconforming item, shall be no ed on the conditional release.
Contrary to the above, Nonconformance Report No. 3979 was issued against pipe support CBB-ll2-1110 on January 28, 1980, and Field Change Request M-7240F, providing for plug welds of the anchor bolt studs to the base plate, was approved on March 3,
- 1981, and implerented thereafter without the issuance of a conditional release.
I 1/2 50-352/81-08 50-353/81-06
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Response to Violation A conditional release was issued on Nonconformance Report (NCR) 3979 upon notification of this situation by the NRC Inspector in order to perform the work needed to determine if the NCR disposition had been completed.
It was determined that the disposition on NCR 3979 had been implemented in March 1980.
It appears that the work was performed, the material was rejected, and the tags were discarded, but the NCR inadvertantly was not signed off.
NCR 3979 is now signed off and closed.
To assure there were no other instances of this, a sample of 30 NCR's that had been open for some time were checked and it was found that work had not proceeded without conditional release.
To prevent recurrence, a training class was held for QC personnel, Field Engineers, and Field Superintendents on the subject of conditional releases.
I 2/2 50-352/81-08 50-353/81-06
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