ML20072F965
| ML20072F965 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/21/1982 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20072F947 | List: |
| References | |
| NUDOCS 8303240477 | |
| Download: ML20072F965 (3) | |
Text
PHILADELPHIA ELECTRIC COMPANY
{
2301 MARKET STREET P.O. BOX 8699 1881 1981 0EC 21 19b2 PHILADELPHIA PA.19101 (2151841 4502
.~ C'.T::::lL.e 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; US NRC IE Region Letter dated November 23, 1982 RE: Site Inspection of October 4 - November 14, 1982 Inspection Report No. 50-352/82-13 File: QUAL l-2-2 (352/82-13)
Dear Mr. Haynes:
In response to the subject letter regarding items identified during the subject inspection of construction activities authorized by License Nos. 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 l
relating to the response.
Should you have any questions concerning these items, we would be i
pleased to discuss them with you.
j Sincerely, Sf5f
/
JMC/mmk Attachment Copy to:
Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, DC 20555 l
l S. K. Chaudhary, US NRC Resident Inspector r303240477 830316
{DRADOCK05000g u
r ATTACHMENT I RESPONSE TO APPENDIX A Violation 10CFR50, Appendix B, Criterion V requires that activities affecting quality be accomplished in accordance with prescribed instructions, procedures, or drawings.
Bechtel Procedure EDPI-4.47.0, Paragraph 2.1.d, directs that any Field Change Request (FCR) received 15 days prior to issue of a drawing revision shall be incorporated in that drawing revision.
Contrary to the above, FCR's M-11, 559F and M-11, 939F to drawing No. GBB-102-H1, issued on or before June 1 and June 25, 1982 respectively, were not incorporated into a September 30, 1982 revision to that drawing.
Response to Violation During this Inspection, Philadelphia Electric Company presented an open Quality Assurance Finding, No. G-160, which previously identified the generic problem of incorporating drawing change notices including revising drawings without incorporating open drawing changes. Although our finding did not specifically identify Drawing GBB-102-H1, it clearly identified the generic condition.
Philadelphia Electric requests that this item be changed from a Violation to an Unresolved Item.
Whether the item remains as a Violation or an Unresolved Item, the action taken is as follows:
f The FCR's M-11, 559F and M-11, 939F were not incorporated in the drawing, since they were cancelled as noted in your Inspection Report 50-352/82-13, paragraph 4.a.
Hence, no further action'is required on the specific items.
With regard to preventing recurrence, it was determined that the two FCR's in question were reviewed prior to revising Drawing GBB-102-H1.
However, the approvals of the rejected FCR's took longer than the l
approval of the revised drawing.
This was due to the critical management scrutiny given when San Francisco Project Engineering rejects field change requests.
1 To prevent recurrences of this, the responsible individuals were re-instructed in the procedural requirements.
In addition, we will continue to pursue resolution of Finding l
Report G-160.
l l
COMMONWEALTH OF PENNSYLVANIA ss.
J COUNTY OF PHILADELPHIA f
JOHN S. KEMPER, being first duly sworn, desposes and says:
That he is Vice President of Philadelphia Electric i
Company, the holder of Construction Permit CPPR-106 for Limerick Generating Station Unit 1; that he has the foregoing Response to Inspection Report No. 50-352/82-13 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.
i i
4 GL rr L
/
1 Subscribed and sworn to before me this dl day of cEsM32d. t q $Y CLCude N-Notary Public PATRICIA D. SC 10LL Ncia4 Putic, Phila M hia. P%&lpMa Co.
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M/ Commicien Dputs Febrearf 10, 1966