ML20033B388
| ML20033B388 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/05/1981 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20033B384 | List: |
| References | |
| NUDOCS 8112010349 | |
| Download: ML20033B388 (3) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET F'.O. BOX 8699 1881 -1981 PHILADELPHIA. PA.19101 (215)841 45o2 JOHN S KEMPER W.I lIUla"N
.e NOV 5 198)
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Mr. Ronald C.
Haynes, 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 October 8, 1981 RE:
Site Inspection of September 1-30, 1981 Inspection Report No. 50-352/81-14 & 50-353/81-12 Limerick Generating Station - Units 1 and 2 FILE:
QUAL 1-2-2 (352/81-14 & 353-81-12
Dear Mr. Haynes:
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 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,
, M 1.,
7 JPE/drd Attachment i
Copy to:
Director of Inspection and Enforcement l
United States Nuclear Regulatory Commission l
Washington, D.C.
20555 l
l J.
P.
Durr, USNRC Resident Inspector 1
1 l
8112010349 811116 PDR ADOCK 05000352 l
G PDR l
L
ATTACHMENT I Response to Appendix A Violation As a result of the inspection conducted on September 1-30,
- 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,
1980), the following violation was i
identified:
Criterion III, states, in part, that:
" Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design..."
The Limerick PSAR, Appendix D,
Paragraph 7.3, states, in part:
"...Bechtvl Engineering has an internal design control program."
Bechtel Job Rule 8031-JR-M-17, " Field Control of Pipe Supports (Hangers)," Paragraph 5.6.1, states, in part:
" Rework of a hanger to a condition other than that specified on the hanger detail drawing...may proceed if an FCR (Field Change Request) is written within three (3) days..."
Contrary to the above, on or before July, 1981, pipe support GBB-101-H3 was installed with the beam and connections (item 17) to a condition other than that specified on the hanger detail drawing GBB-101-H3.
On September 29, 1981, a Field Change Request had not been initiated for the change.
xesponse to Violation FCR Number M-8982F was initiated on September 30, 1981 to document the change in design to pipe support GBB-101-H3.
This FCR was subsequently approved on October ?6, 1981.
To prevent a recurrence, Bechtel Job Rule 8031-JR-M-17 was revised to more clearly describe the intent and timing of FCR's for pipe supports.
These clarifications are now incorporated in revision 9 of the Job Rule issued on October 30, 1981.
Also, the involved engineers and superintendents were indoc-trinated in the revised job rule requirements in a training class held on November 3, 1981.
I 1/1 50-352/81-14 50-353/81-12
l COMMONWEALTil 0F 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 foregoing Response to Inspection Report No. 50-352/81-14 and 50-353/81-12 and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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Subscribed and sworn to thisj[
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