ML20053D020
| ML20053D020 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/14/1982 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20053D019 | List: |
| References | |
| NUDOCS 8206030281 | |
| Download: ML20053D020 (4) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 1881 1981 PHILADELPHI A. PA.19101 JOHN $ MEMPER vn a entsiorest APR 141982 Mr. Ronald C.
Haynes, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region 1 631 Park Avenue King of Prussia, Pennsylvan'a 19406 i
Subject:
USNRC IE Region I Letter dated March 15, 1982 RE:
Site Inspection of February 1-28, 1982 Inspection Report No. 50-352/82-04 & 50-353/82-03 Limerick Generating Station - Units 1 and 2 File:
QUAL 1-2-2 (352/82-04 & 353/82-03)
Dear Mr. Ilayne s :
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, JPE/kk/1/2 Attachment Copy to:
Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, D.C.
20555 J.
P.
Durr, USNRC Resident Inspector 8206030281 820524 i PDR ADOCK 05000352 G
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P
-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 I
Company, the holder of Construction Permits CPPR-106 and CPPR-107 for Limerick Generating Station Units 1 and 2; that 2
he has read the foregoing Response to Inspection Report No.
50-352/82-04 and 50-353/82-03 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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o Subscribed and sworn to IN ay before me this d
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ATTACHMENT I RESPONSE TO APPENDIX A Violation During the Februar'y 1-28, 1982 inspection and in accordance with the Interim Enforcement Policy, 45FR66754 (October 7, 1980), the following violation was identified:
A.
10CFR50 Appendix B Criterion III requires that the design basis be translated into instru'ctions, procedures and drawings provid-ing appropiate quality standards and that deviations from such standards be controlled.
10CFR50 Appendix B Criterion VI requires control of the issue of documents and changes which prescribe all activities affecting quality, including review and approval by authorized persennel.and use where an activity is performed.
Contrary to the above:
(1)
On February 19, 1982, design changes were found not con-trolled by Job Rule JR-M-17, " Field Control of P?.pe Supports", Paragraph 5.6.1, which permits design changes by field engineers to remain undocumented for from three days to completion of the pipe support.
(2)
On February 9, 1982, the heating, ventilating, and air conditioning subcontractor was using uncontrolled and unreviewed " pick-off" sheets to fabricate safety-related duct work.
Response to Violation 1.
-Design changes during installation of various items at the job site are controlled by various measures, all of which, Philadelphia Electric Company believes, meet the intent of 10CFR50 Appendix B.
Although it is our opinion that Job Rule JR-M-17, " Field Control Cf Pipe Supports", provides effective control of this type of in-stallation, nevertheless, we recognize the NRC concerns and are seeking a mutually acceptable alternate procedure.
It is our understanding that our in-containment practice Of " red-lining" changes on drawings until the design is formally incorpo-rated into the drawing is acceptable to ti e NRC Resident Inspector.
Accordingly, we have extended a similar practice into other areas of the plant on a trial basis.
Details of implementation are being tested for feasibility and efficiency prior to formalization of the modified procedure.
I 1/2 50-352/82-04 50-353/82-03
)
Response to Violation - Continued 2.
Schneider, Inc. has revised their control procedure (Schneider, Inc. PPM-2.5) to include a description of the controls esta-blished for the work package " Pick-Off" sheets.
This revised procedure now requires that the " Pick-Off" sheet be reviewed by the responsible Schneider group and that each sheet be annotated l
with the work package control number and page number.
This revised procedure is.now in use by Schneider.
In addition, Schneider has performed a sample check of 70 pre-viously generated " Pick-Off" sheets to ensure that the requirements of the design documents have been correctly translated.
The sample indicated that no discrepancies were found.
Schneider, Inc. is now in full compliance with the revised pro-cedure.
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I 2/2 50-352/82-04 50-353/82-03
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