ML20151T708
| ML20151T708 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/04/1988 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8808170151 | |
| Download: ML20151T708 (2) | |
See also: IR 05000277/1988008
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AUB "41988
1,
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Docket No. 50-277
Philadelphia Electric Company
ATTN: Mr. C. A. McNeill
Executive Vice President
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Nuclear
2301 Market Street
Philadelphia, Pennsylvania 19101
Gentlemen:
Subject:
Inspection No. 50-277/88-08
This refers to your letter dated May 25, 1988, in response to the violation
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identified in our letter dated April 28, 1988. The violation involved the use
of uncontrolled drawings for the. fabrication of emergency service water piping.
Thank you for informing us of the corrective and preventive actions documented
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in your letter. These actions appear to appropriately address the violation
and will be examined during a future inspection of your licensed program.
However, we note that in your response the significance of the violation is
minimized on the basis that post fabrication inspections would have identified
discrepancies from the design drawings.
(As noted in the Inspection Report
50-277/88-08, errors were identified on the sketch.s that require correction.)
The significance of the violatien is the application of the principle that work
must be done properly such that post fabrication inspections will generally
verify the work is in accordance with the design documents.
Quality should ba
achieved during initial fabrication not through reliance on post trodification
inspection.
Your cooperation with us is appreciated.
Sincerely,
Original Signed 37 f
JacqueP.Durr
Jacque P. Durr, Chief,
Engineering Branch
Division or Reactor Safety
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OFFICIAL RECORD COPY
RL PB 88-08 - 0001.0.0
08/03/88
8808170151 880s04
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ADOCK 05000277
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Philadelphia Electric Company
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cc w/er,cl:
John S. Kemper, Sr., Senior Vice President-Nuclear
J. W. Gallagher, Vice President, Nuclear Services
E. C. Kistner, Chairman, Nuclear Review Board
Dickinson M. Smith, Vice President, Peach Bottom Atomic Power Station
Jack Urban, General Manager, Fuels Department, Delmarva Power & Light Co.
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John F. Franz, Plant Manager, Peach Bottom Atomic Power Station
Troy B. Conner, Jr. , Esquire
W. H. Hirst, Director, Joint Generation Projects Department,
Atlantic Electric
Bryan W. Gorman, Manager, External Affairs
Eugene J. Bradley, Esquire, Assistant General Counsel (Without Report)
Raymond L. Hovis, Esquire
Thomas Magette, Power Plant Siting, Nuclear Evaluations
W. M. Alden, Director, Licensing Section
Doris Poulsen, Secretary of Harford County Council
Public Document Room (POR)
local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
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Commonwealth of Pennsylvania
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Region 1 Docket Room (with concurrences)
Management Assistant, ORMA (w/o enc 1';
Section Chief, ORP
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PA0 (2) SALP and All Inspection Reports
Robert J. Bores, DRSS
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R. Martin, NRR
B. Clayton, E00
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PHILADELPHIA ELECTRIC COMPANY
2301 MARKET STREET
P.O. BOX 8699
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PHILADELPHI A. PA 19101
(ris) sai. soot
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JOSEPH W. G ALL AGHER
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May 25, 1988
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Docket Nos. 50-277
50-278
Mr. William F. Kane, Director
Division of Reactor Projects
Region I
.U.S. Nuclear Regulatory Commission
ATTN:
Document Control Desk
Washington, D.C.
20555
SUBJECT:
Peach Bottom Atomic Power Station Units 2 & 3
Response to Combined Inspection Report
Nos. 50-277/88-08; 50-278/88-08
Dear Mr. Kalte:
Your letter dated April 28, 1988 transmitted Combined
Inspection Report Nos. 50-277/88-08; 50-278/88-08 concerning the
routine safety inspection conducted at Peach Bottom on March 14-
18, 1988.
Appendix A of your letter identified one activity
which appeared not to have been condocted in full compliance with
NRC requirements.
The Attachment to this letter provides a restatement of
this item followed by the Philadelphia Electric Company's
response.
If you have any questions or require additional
information, please do not hesitate to contact us.
Very truly yours,
Attachment
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Addressee
W. T. Russell, Administrator, Region I, USNRC
T. P. Johnson, USNRC Senior Resident Inspector
T. E, Magette, State of Maryland
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Attachment
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Pago 1 of 2
Docket Nos. 50-277
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50-278
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Restatement of Violation
10 CFR 50, Appendix B, C.r.iterion VI, requires that measures
be established to control the issuance of drawings and that
drawings be reviewed for adequacy and approved for release
for distribution and use at the location where the work will
be performed.
Contrary to the above, on March 16, 1988 the inspector
identified Emergency Service Water piping being fabricated to
sketches that were not in the drawing control system, and
showed no indication of approval prior to release.
This is a Severity Level IV violation (Supplement II).
Response to the Violation
Admission or Denial of Alleged Violation:
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Philadelphia Electric Company admits that the violation did
occur, as described.
Reason for the Violation:
The violation is attributed to weaknesses in the level of
understanding of the proper use of fabrication aids and the
application of the Quality Assurance Plan by the installation
engineers and supervisors.
This lack of understanding extended
to the craftsmen, resulting in this violation.
The complexity of the design drawings recessitates the use of the
simplified sketches in the fabrication process.
The Modification
Section at Peach Bottom has permitted and encouraged the use of
fabrication aids in the shop.
These aids have included sketches
made by a worker, foreman or installation engineer from the
controlled design drawing.
These aids facilitate and improve the
quality of the fabrication process.
A set of controlled design
drawings are kept in the shop and are available to the craftsmen
at all times.
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Attachmant
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Page 2 of 2
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Docket Nos. 50-277
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50-278
Extent or Significance:
PECo believes the significance of this violation to be minimal.
.The extent of the use of uncontrolled drawings was limited to
their use as fabrication aids.
Direct use of the design drawings
.in post-fabrication inspections, installation, as well as OA/QC-
activities was required, therefore, discrepancies would be
identified prior to any use of the modification.
Corrective Actions Taken and Results Achieved:
The sketches which were used for this modification were reviewed
against the design drawings,~ verified to be correct and signed by
the responsible design engineer and formally issued.
The "Procedure for Control of Drawings (Procedure for Control of
Modification Documents)", CD 6.2 was revised and issued on May
20, 1988 to require approval and control of fabrication aids.
The engineers, modification / construction supervisors and foremen
were instructed in the use of the revised procedures, as well as
on the circumstances of this violation.
The supervisors in the
Modification Section have also received additional training
regarding quality assurance and the use of fabrication aids.
Training sessions were also conducted to emphasize this to the
craftsmen.
Corrective Steps to be Taken to Avoid Future Violations:
The actions which have been taken will avoid future
noncompliance.
Date When Full Compliance will be Achieved:
The implementation of the revised procedure and formal personnel
instruction were completed on May 23, 1988.
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