ML19331B706

Responds to NRC 800604 Ltr Re Violations Noted in IE Insp Repts 50-352/80-02 & 50-353/80-02.Corrective Actions: Obsolete Drawings Were Discarded,Hanger GBB-112-H-10 Will Be Reworked & Base Plate Replaced

ML19331B706
Person / Time
Site:	Limerick
Issue date:	07/03/1980
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19331B704	List: ML19331B706
References
NUDOCS 8008120628
Download: ML19331B706 (3)

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O ewi'^oe'esi^ s'EcTaic coMe^NY 23O1 MARKET STREET P.O. BOX 8699

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PHILADELPHIA. PA.19101 (2151841-4502 VIC E-PR ESID E NT ENGeseEE menG ANO RESE ARC 04 JUL -31980 Mr. Boyce Grier, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

USNRC IE Region I Letter dated June 4,1980 RE: Site and Office Inspection of January 22-31, 1980 and February 1-22, 1980 Inspection Report No. 50-352/80-02 6 50-353/80-02 Limerick Generating Station - Units 1 and 2 File: QUAL 1-2-2 (352/80-02 and 353/80-02)

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Dear Mr. Grier:

In response to the subject letter regarding items identified during the

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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 Should you have any questions concerning these items, we would be pleased to discuss them with you.

Sincerely,

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J.-S. Kemper JMC/mmk Attachment

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8008120 b N

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ATTACHMENT I RESPONSE TO APPENDIX A Item of Noncompliance -A Infraction Appendix B, of 10CFR50, Criterfon V, states in part: " Activities affecting quality....shall be a :complished in accordance with these instructions, procedures or drawings...."

The Limerick PSAR, Appendix D, Quality Assurance Program, Paragraph D.6.4 states, in part, that: "Bechtel Construction Department....

is responsible for construction of the plant to approved engineer-ing specifications, drawings, and procedures...."

The Bechtel Power Corporation Job Rule G-5 in section 4.2.3, states in part: "... personnel or field stick coordinators receiving updated working copies are responsible for destroying or marking all copies previously issued to them " VOID"..."

Contrary to the above, as of January 29, 1980, two obsolete drawings, C-1182 Revision 5, and C-1183, Revision 10, were in a work area where safety-related platform was being erected in the ,

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Unit i reactor enclosure. These drawings were not marked " VOID" to indicate they were obsolete.

Response to Infraction A

1. Corrective Action Taken to Resolve Finding:

a. The obsolete drawings were discarded.

b. Bechtel QC has performed a complete inspection of the work covered by drawing C-1182, Revision 5 and C-1183, Revision 10 and found no deficiencies.

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2. Corrective Action Taken to Prevent Recurrence:

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a. A complete audit of all drawings possessed by craftsmen was performed by the responsible superintendents and they documented the results on Inspection / Review forms.

This review has assured that the drawings are current or l are marked " VOID".

i 1 1/2 352 6353 80/02

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b. In addition, we have reviewed the repetitive nature of our drawing control problems and have taken an additional step to assure that correct drawing revisions are in use.

The Job Rule 8031-G-5 document control transmittal sheet has been revised to require a signature by the responsible superintendent to concur that all revised drawings have been marked " VOID" or " Reference" or that they have been destroyed.

Item of Noncompliance - B Infraction Appendix B, of 10CFR50, Criterion V, states in part: " Activities affecting quality....shall be accomplished in accordance with these instructions, procedures, or drawings..."

The Limerick PSAR, Appendix D. Quality Assurance Program, Paragraph D.6.4 states, in part, that: "Bechtel Corporation Department...

is responsible for construction of the plant to approved engineering specifications, drawings, and procedures...."

Bechtel Power Corporation Design Specification P-319, Section 4.5.3, states in part:...."that for pipe supports, in order to account for misalignment of installed anchors, predrilled holes in support plates may be enlarged provided that the minimum edge thickness "b" is satisfied. When this action is initiated, a reinforcing plate covers the enlarged hole. These plates shall be installed and welded as shown in Figure 14...."

Contrary to the above, as of January 28, 1980, a pipe support (GBB-112-H10) with a predrilled base plate had one of its four holes plug welded to account for the misalignment of an installed anchor. The base plate was then drilled to accomodate this misaligned anchor.

Response to Infraction B

1. Corrective Action Taken to Resolve Finding:

a. Hanger GBB-112-H-10 will be reworked in accordance with the disposition of NCR-3979 dated 4/1/80. The base plate will be scrapped and a new plate provided by September 1, 1980.

2. Corrective Action Taken to Prevent Recurrence:

a. The installer has been instructed regarding related site procedures.

b. Specification P-319 has been revised to include plug welding as an approved repair procedure.

I 2/2 352 & 353 80/02 ,