ML20095A153
| ML20095A153 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/20/1984 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20095A053 | List: |
| References | |
| NUDOCS 8408210394 | |
| Download: ML20095A153 (5) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHIL ADELPHI A, PA.19101
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JUN 201984
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.. m-m MANAGER EN T.tME R RING AND RESE ARCH Mr. Thomas E. Murley, Director United States Nuclear Regulatory Consission Office of Inspection and Enforcement, Region I 631 Park Avenue-King of Prussia, PA 19406
Subject:
USNRC IE Region I Letter dated March 21, 1984
Reference:
Site Inspection of April 1-30, 1984 Inspection Report No. 50-352/84-19 and 353/84-06 File: QUAL 1-2-2 (352/84-19 and 353/84-06)
Dear Mr. Marley:
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.?.ppendix A Also enclosed is an affidavit relating to the response.
Should you have any question concerning these items, we would be pleased to discuss them with you.
Sincerely, Obk d
JMC/drd/840615-1 l
Copy to: Director of Inspection and Enf orcement United States Nuclear Regulatory Commission l
Washington, DC 20555 S. K. Chaudhary, USNRC Resident Inspector l
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8408210394 840002 PDR ADOCK 05000352 O
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.'e-ATTACHMENT I s.
6 RESPONSE TO APPENDIX A 28407'3750 A.
VIOLATION 10 CFR 50, Appendix B, Criterion III requires the establishment of measures to assure that applicable design basis for systems and m
components are correctly translated into drawings.
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Section 3 of Volume 1 of the Limerick Generating Station Quality Assurance Plan implements these requirements of Criterion III.
Contrary to the above, as of April 24, 1984, the measures established to incorporate implemented design changes into applicable drawings failed to assure that all changes made to the high pressure coolant injection system by Design Change Package-232 were reflected in Piping and Instrumentation Diagram M42.
RESPONSE
An IDCN has now been issued to include the appropriate.information on P&ID M-42.
This condition appears to be unique in that this GB initiated change was made in an advance drawing revision and hence Bechtel did not
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recognize the need to revise their P&ID when this design change was proce,ssed, llowever, several other DCP's were reviewed to verify satisfactory engineering, inter-disciplinary coordination and no other problems were identified.
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I 1/3 352/84-19 and 353/84-06 L
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ATTACHMENT I
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RESPONSE TO APPENDIX A t
B.
VIOLATION 1-10 CFR 50, Appendix H, Criterion V requires that activities af fecting quality shall be prescribed by appropriate procedures and these pro-cedures shall be followed during performance of these activities.
Stactup Adminsitrative Procedure AD 1.2-2 and Appendix % to Volume 1 of the Limerick Cenerating Station Quality Assurance (QA) Plan require that Startup Nonconformance Reports be reviewed by the licensco's Quality Control and Quality' Assurance organizations to determine if conditions exist which requirq reporting to the NRC per 10 CFR 50.55e.
Contrary to the above, AD 1.2-2 and Appendix Z to tho QA Plan were not of factively followed in that the review provided for Sturtup Nonconformance Reports S-346-M, S-347-M, and S-414-M, involving f ailures to elect rohydraulic operators for ventilation system dampers, failed to identify that these failures constituted a condition which warranted reporting,
RESPONSE
The condition of failures of electrohydraulic operators for the ven-tilation system dampers identified on the Startup Nonconformance Reports has now been evaluated for reportability per 10 CFR 50.55e throu6h the Startup nonconformance trend analysia proceso and was reported to the NRC on May 25, 1984
'i To prevent a recurrer.ce of this condition, Procedure QADP-27 1 - Procedure for Performance of Startup Nonconfonnance Report Trend Analysis has been revised to address evaluation for reportability per 10 CFR 50 55e.
I 2/3 352/84-19 and 353/84-06 e
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Lj 4 ATTACHMENT I.
'O RESPONSE-TO APPENDIX A 23407:3750:
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C.! VIOLATION 10 CFR 50,; Appendix' b, Criterion V requires that activities affecting -
quality shall be prescribed by appropriate procedurus.
Section 16 of the Startup Activity Section of.the Limerick Generating Station Quality Assurance Plan _ requires that measures shall be es-tablished to assure conditions adverse to quality are promptly identified, reported and corrected.
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Contrary to the above, the measures-necessary to promptly identify, report and correct those conditions adverse to quality which were associated with facility buildings, areas and rooms were not prescribed by appropriate Startup Administrative procedures as required by the Limerick Quality Assurance Plan.
RESPONSE
The need for construction to complete the diesel generator building roofing, including finish roofing and flashing, was on the construction work list prior to Startup personnel noticing the condition.
With regard 'to the apparent confusion regarding which of the corrective action systems applied to facilities, the following steps have been taken to prevent such a recurrence.
- 1) Startup revised Administrative Procedure AD 1.2, Startup Nonconformance Report (NCR) to address nonconformance reporting on facilities.
- 2) Startup issued a Training Bulletin discussing how Startup abould report deficiencies identified on facilities.
- 3) Construction Division procedure CPL-9 Procedure for Facility Turnover and Facility Post Turnover Activities has been issued defining responsibilities for facility controls after turnover.
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1 3/3 352/84-19 and 353/84-06
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. o-224070750 CON 00NWEALTa OF PEIDiSYLVANIA :
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COUNTY OF PHILADELPHIA J
JOSEPH W. GALLAGHER, being first duly sworn, deposes and says:
That he is Manager, Engineering and Research Department 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. 50-352/8h-19 and 50-353/8h-06 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
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'before me this %
d l9 b og Wa^Al Notary Public PATRICIA D. SCHOLL Netwy Pubic, PfubMfhlt Philadelphis Co.
My Commissja hptgg I,eb,ryary 10.12 u-la - : s
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