ML20030C211
| ML20030C211 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/07/1981 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20030C205 | List: |
| References | |
| NUDOCS 8108250519 | |
| Download: ML20030C211 (4) | |
Text
h PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 1881 -1981 PHILADELPHIA. PA.19101 1215) 841 4 5 o 2 JOHN S KEMPER
... = ::: =..
AUG 7 - 1981 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 Letter dated July 17, 1981 RE: Site Inspection of May 5-8, 1981 Inspection Report No. 50-352/81-07 Limerick Generating Station, Unit 1 File:
QUAL 1-2-2 (352/81-07)
Dear Mr. Grier:
In response to the subject letter regarding items identified during the subject inspection of construction activities authorized by NRC License No. CPPR-106, 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, EU JPE/gra l
Attachment l
Copy to:
Director of Inspection and Enforcement United States Nucle-r Regulatory Commission Washington, D.C.
20555 J.
P.
Durr, USNRC Resident Inspector l
l l
r nicensos19 slos19 PDR ADOCK 05000352 PDR O
t n__
COMMONWEALTH 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 Permit CPPR-106 for Limerick Generating Station Unit 1,
that he has read the foregoing Response to Inspection Report No. 50-352/81-07 and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best af his knowledge, information and j
belief.
i W S.W,L Subscribed and sw n to before me this day of b
\\
4(A s tary Pub l
EUZA ETH H. BOYE4 ary J,C. Phila., Phila. Co' l
My Commemon Empires Jan. 34 tgeg i
e k
ATTACHMENT I RESPONSE TO APPENDIX A Violation j
10CFR50, 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 and...shall include appropriate quantitative or qualitative acceptance criteria..."
Limerick Gcnerating Station, Quality Assurance Plan, Section 5.4, states, " Quality related activities performed by PECO personnel are required to be accomplished in accordance with the appendices procedures..."
of this plan and/or written instructions or 1.
Quality Assurance Instruction, QAI-10-1, Revision 6, Section 7.4, states, "The records described in Section 7.1, 7.2, and 7.3 are filed and maintained in the site QA file."
Contrary to the above, Project Special Provisions Notice G-5.1, Revision 3 was reviewed, the approval letter transmitted, however, a signed copy of the comment letter was not in the site QA records file, as required by procedure.
2.
Quality Assurance Instruction, QAl-10-1, Revision 6, Section 6.1.6, states, "The Field QA Branch Head or the assigned
{
member of the Field QA Branch shall compare the final PSP to the proposed draft previously reviewed, complete the checklist as follows:
Block No.
9.
Final PSP - check off YES or NO as appropriatc if the final PSP agrees with the draft previously reviewed or has been revised to resolve PECO comments on the draft.
10.
Reviewed by - enter signature and date of reviewer."
l Contrary to the above, Project Special Provisions Notice, G-8.1, Revision I was reviewed, the approval letter was transmitted, however, the checklist in QAI-10-1 was not signed by the reviewer as required by the procedure.
3.
Quality Assurance Instruction, QAI-5-8, Revision 4, Section 4.2, states, "The members of the Field QA Branch are responsible f or reviewing job rules in accordance with this procedure."
Contrary to the above, Job Rule, JR-G-25, Revision 16 was placed in the QA record file although it had not been reviewed.
l I
1/2 l
50-352/81-07
Response to Violation 1.
A copy of the signed letter was obtained and is now in the site QA records file.
To prevent a recurrence of this item the Quality Assurance Instruction 10-1 is in the process of being revised to indicate that copies of the signed approval letters are j
maintained in the Project Files.
The rationale for this l
change is that the approval letters are prepared at Limerick Site and forwarded to the Corporate Office in Philadelphio for issuance.
The reviseu procedure will be issued by 9 /1- / 81.
2.
The checklists involved have been signed off.
The Quality Assurance Engineer did review these procedures, however, neglected to sign-off the checklists.
To assure there was no other instances, the other current revisions of the PSP's were reviewed and all checklists are now signed-off.
In addition, the individual responsible was reinstructed in the Quality Assurance Instruction, QAI-10-1 requirements.
3.
Job Rule G-25, Revision 16, has now been reviewed.
It was I
determined that the revision was routed in error to the file, rather than the individual identified for review i
responsibility.
To prevent recurrence of this situation, personnel responsible for filing were remind,ed of the filing practices.
In additior., all other current revisions of safety related Job Rules were checked to assure that they have been reviewed by Philadelphia Electric Company Quality Assurance, i
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I 2/2 50-352/81-07 I