ML20100P935

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Responds to Violations Noted in Insp Repts 50-352/91-23 & 50-353/91-24.Corrective Actions:Use of Nonevaluated Vendor to Prepare Test Samples Eliminated & All Vendors Used in Welding Qualification on Evaluated Vendor List
ML20100P935
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 01/31/1992
From: Leitch G
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9202040168
Download: ML20100P935 (3)


Text

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o l'IIILADELl'IIIA ELECTRIC COMI%NY LIMERICK GENERATING YTATION P. O. BOX 2300 IWrSIOVN, PA 19464 0920 (215) )27 12(0, INT.XKo January 31, 1992 GyQL[jcH Docket Hos.

50-352 uuurs atnowm sww 50-353 License Nos. NPP-39 NPP-85 U.S. Nuclear Regulatory Ccu.-tss. a Attn Document Cont rol Det k Washington, DC 20555

SUBJECT:

Limerick ben-ating Station, Units 1 and 2 Reply to a Notice of Violation NRC Inspection Report Nes. 50-352/91-23 and 50-353/91-24 Attached is Philadelphia Electric Company's reply to a Nctice of Violation for Limerick Generating Station (LGS) Units 1 and 2, which was contained in the NRC Inspection Report Nos 50-352/91-23 and 30-353/91-24 dated January 2, 1992.

The Notice of Violation involves use of a non-evaluated vendor to machine bend test samples for qualification of welders by the Barbadoes Training Facility without making provisions for source or receipt inspection.

The attachment to this letter provides a restatement of the violation identified during an NRC inspection conducted between October 29, 1991, through November 4, 1991, at LGS, Barbadoes Training Center, and Chesterbrook Nuclear Maintenance Division, followed by our response.

If you have any questions or require additional information, please contact us.

g Very truly yours,

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T. Martin, Administrator, Region I, USNRC o n.o T. J. Kenny, USNRC Senior Resident Inspector, LCS

o Attachment Page 3 of 2 Docket No. 50-353 r

Mply_to a Notice of Violation Restatement of the Violation During an NRC inspection conducted on October 29, through November 4, 1991, a violation of NRC requirements was identified.

In accordanne with the " General Statement of Policy and Procedure fer NRC Enf orcement Actions, 10CPR Part 2, Appendix C (1991),

the violation is listed belows i

10CTR50, Appendix D, Criterion VII, requires that a licensee previde for vendor evaluation and selection, objective evidence of quality of goods and services, soutce inspection, and examination at delivery.

Chapter 17.2.7.1-of-the Updated Pinal Safety Analyses Report states that vendors will be evaluated and approved by the Nuclear i

Quality Assurance Department.

Contrary to the above, a non evaluated vendor was i ed to machine bend test samples for-qualification of welders by

  • Darbadoes Training racility without making provisions for st.n_0 or receipt

-inspection.

This is a Severity Level IV Violation (Supplement I).

RESPONSE

l Ad...ission of Violation Philadelphia Clectric Company (FECo) acknowledges the violation.

Reason for the Violatlory-i L

Prior to your inspection PCCo recognized applicability of 10CFR50, Appendix B, Criterion IX, and the Nuclear Quality Assurance (NOA) plan, Criterion 9, to qualification of welders.

PEco di 3. not - realize t hat 10CFR50 Appendix B, Criterion VII, appl a to a vendor used to-prepare test samples for weld certification testing.'

l Corrective Action and Results Achieved

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l Attachment Page 2 of 2 Docket No. 50-353 Ur,e of the non-evaluated vendor to prepare test samples wan eliminated on !)ovember 14, 1991, after ensuring that no test samples were at the vendor.

A review wan performed to ensure i

that all vendor services-used in the welding qualification program are on the Evaluated Vendor List (UVL).

All test cample preparation formerly performed by the non-evaluated vendor was i

assumed by the Barbadoes Training Center in compliance with the NQA plan effective November 14, 1991.

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Corrective _ Action M a38n to Avoid Future Non-Compliance i

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PECo will perform test sample preparation in-house in accordance with-the NOA plan and Section IX of the ASME code.

In the future, the use of a vendor for test sample-preparation in the welding qualification program will comply with_10CPH50, Appendix B, Criterion VII and Criterion 7 of the HQA plan.

Prior to use j

of a vendor on the CVL to prepare test samples, procedures would be developed for Barbadoes Training Center personnel to perform receipt inspection on the tent samples.

Date When l'ull Compliance was Achieved Pull compliance was achieved on November 14, 1991, when use of l

the non-evaluated vendor was eliminated and test sample preparation was assumed by the Barbadoes Training Center.

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