IR 05000352/1982003
| ML20042C593 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/24/1982 |
| From: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8203310554 | |
| Download: ML20042C593 (1) | |
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MAR 2 4 saz Docket Nos. 50-352
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50-353 e
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Philadelphia Electric Company
ATIN: Mr. John S. Kemper
gECEIVED Vice President L
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M4R3g I 02' S Engineering and Research t
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b 88cze seu 2301 Market Street
% anex7j,ct p Philadelphia, Pennsylvania 19101
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Gentlemen:
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s Subject: Combined Inspection 50-352/82-03 and 50-353/82-02 This refers to your March 11, 1982 letter replying to our February 9,1982 letter.
Thank you for informing us of your corrective and preventive actions. Those actions will be examined during future NRC inspections.
Regarding your response to Violation A. Radiography Before Tempering, the inspection mference was 10 CFR 50 and your comitments of July 15, 1975 (FSARTable3.2-1, Note 7). Since later code editions permit radiography before heat treatment, we accept your corrective action of updating the FSAR to reflect that practice in this case. We note, however, that selective partial substitution of later code editions must be supported by an engineering review to verify compatibility.
Your cooperation is appreciated.
Sincerely
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/ Richard W. Starostecki, Director
[/ f Division of Project and Resident f
Programs
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o om V. S. Boyer Senior Vice President, Nuclear Power
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8 8 Local Public Document Room (LPDR)
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o NRC Resident Inspector
Comonwealth of Pennsylvania 00-200 bec:
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699
- 1981 PHILADELPHIA. PA.19101 k
JO H N S M F. M P E,,
VIC E. PR E SIDE N f osse.ss s e seesee Asen es a ss ase< >e Mr. Ronald C. Hages, Director United States Nuclear Regulatory e mmission Office of Inspection and Enforce,.
Region I 631 Park Avenue 19106 King of Prussia, PA
Subject:
USNRC IE Region Letter dated February 9, 1982 RE:
Inspection of January 11-29, 1982 Inspection Report No. 50-352/82-03&$0-353/82-02 Limerick Generating Station - Units 1 and 2 File:
QUAL 1-2-2 (352/82-03 & 353/82-02)
Dear Mr. Haynes 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 Appendix A Also enclosed as required by the Notice of Violation, is an affidavit relating to the response.
Should you have any questions concerning these items, we would be pleased to discuss them with you.
Sincerely,
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Attachment Copy to:
Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, D.C.
20555 J. P. Durr, USNRC Resident Inspector
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ATTACHMENT I RESPONSE TO APPE91X A VIOLATION -A 10CFR 50.55a requires that Class 1 valves comply with the ASME Draft Code for Pumps and Valves (DCPV), which specifies in Section 314.1.6 that repair welding procedures be qualified in accordance with ASME Code Section IX.
ASME Code Section IX, Paragraph V-6 requires welding procedure requalification if there is a change in the heat treating temperature.
The repair welding procedure, QAP-49D, dated May 7, 1971, and Procedure Qualification Record QAP-49D, dated October 26, 1971, limit post-weld heat treatment temperatures to 1100 degree-1300 degree (Fahrenheit).
Further, DCPV Section 314 specifies that nondestructive tests must be performed after any heat treatment.
Contrary to the above, from December 20, 1971 to February 12, 1972, Class 1 Main Steam Isolation Valve B21F022D, Serial No.
3-683, was repair welded, radiographed, and post-weld heat t rea ted/ tempe red.. at 13h0 degree F.
RESPONSE TO VIOLATION The response to this violation is addressed in two s,eparate parts:
1.
Radiography Before Tempering:
The valve supplier's and licensee's interpretation of the code requirement for the timing of radiography is:
The March 1970 Addendum of the-Draft Pump and Valve Code allows radiog-raphy to be performed at any time.
Paragraph 615.3(b) states:
" Radiographic, ultrasonic and eddy current examinations may be performed before or after any forming or heat treatment."
Also, Section 314 of the 1968 Draft ASME Code for Pumps and Valves for Nuclear Power requires that "non-destructive examinations for materials shall be performed after any heat treatments required by the. Material Specification".
The Material Specification for the MSIV's (ASTM A216-69) requires that the materials be either normalized or normalized and tempered.
Thus, the Draft Pump and Valve Code is interpreted for ASTM A216-69 to mean:
"non-destructive' examinations for materials shall be performed after normalizing or normalizing and tempering."
This interpretation is considered as good engineering practice because tempering would not cause any change or growth of indications or defects.
I 1/3 352/82-03
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The March 1970 Addenda was issued to make editorial and othe'r essential changes to the November 1968 draft of the ASME Code for Pumps and Valves for Nuc1 car Power and was invoked in the purchase order to the valve body manufacturer.
Philadelphia Electric intends to note the use of this Addenda in the FSAR.
This interpretation is consistent with current editions of Section III of the ASME B&PV Code which allows radiography to be performed in any heat treated condition and does not state:
"after material properties are established".
2.
Post Weld Heat Treatment At 1340 degree F:
Weld Procedure QAP-49D, dated May 7, 1971 was used for repair welds on MSIV B22F022D.
However, in March of 1973, Phila-delphia Electric Company identified a noncompliance to this procedure during a source audit:
weld repairs in excess of the qualified size range were made.
C rrective action t.o this finding was to modify the procedure.
Previous to this finding, a qualification of this procedure was performed and a PQR existed for the larger welds.
The modified procedure was back dated October 26, 1971 to match the date of the PQR.
The October 26, 1971 procedure was submitted as part of the final documentation package for the valve and therefore this was the procedure used in reviewing the final records.
QAP-49D dated October 26, 1971 did not limit post weld heat treatment temperatures.
In addition, the DCPV did not limit the temperatures as do more current editions of the Code.
(Section III started in 1973 to lim i. t PWHT temperatures to 1250 degree F for carbon steel).
Also,Section IX of the Code was ambiguous in regard to what change in heat treatment temperatures constituted the need for procedure requalification.
However, recent editions of Section IX have cleared the ambiguity.
In view'of the current interpretation, we are in the process of qualifying the weld procedure for the post weld heat treatment temperatures used.
We expect to have the qualification tests completed and evaluated by May 31, 1982.
We have reviewed the documentation of'several other items supplied by the same foundry and samples of other suppliers and have determined that the high post weld heat treatment temperatures are isolated to the MSIV's.
Also, since 1973 the Code has limited post veld heat treatment temperatures.
Therefore, other than the above described actions, no additional action to prevent recurrence is needed.
I 2/3 352/82-03 353/82-02
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Violation - B 10CFR 50 Appendix B Criterion V requires that activities affecting quality be performed in accordance with procedures.
Project Special Provision Notice PSP G-6.1, Revison 3, Paragraph 3.1.5, specifies that inspection hold points are mandatory and work shall not proceed to a point where work is no longer inspectable.
Quality Control Instruction W-2.00, Paragraph 2.4.a.1, requires that minimum preheat and interpass temperatures be verified for full penetration groove welds as a hold point inspection.
Contrary to the above, reviews on January 21, 1982, disclosed that the preheat and interpass temperature hold point inspections for full penetration groove welds listed on Quality Control Inspection Record C-1415-W-1 had not been performed, and the welds had been completed without them.
Response to Violation Bechtel Power Corporation NCR 5353 was written reporting that the preheat had not been verified on Quality Control Inspection Record C-1415-W-1.
The NCR has been dispositioned by Bechtel design engineers to "use-as-is".
The rationale for this decision is that the preheat requirements for these welds are to preheat to 70 degree F if the ambient temperature is below 32 degree F.
The subject welds were performed during May and June of 1979, when the ambient temperature was above 32 degree F.
The subject Quality Control Inspection Record C-1415-W-1 did not require interpass temperature inspection.
In an effort to determine if this inspector had missed other preheat hold point inspections, twelve (12) other inspection records com-pleted by him were reviewed for similar discrepancies.
No other discrepancies or missing sign-offs were found on these records.
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open Civil Quality Control Inspection Records were reviewed for preheat requirements and sign-offs.
All were found in conformance with the applicable procedures.
A training session was held on January 13, 1982 for Quality Control Welding Inspectors emphasizing the proper preheat requirements.
I 3/3 352/82-03 353/82-02
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COMMONWEALTH OF PENNSYLVANIA :
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- COUNTY OF ?HILADELPHIA JOHN S. KEMPER, being first duly swcrn deposes and says:
That he is Vice President 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.50-352/82-03and50-353/82-02 and knows the contents thereof; and that the statements and matters set forth therein are true
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and correct to the best of his knowledge, information and belief.
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Subscribed and sworn to before me this Il'" day of MrWCA, H9E
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Notaty Public Notary Putdic,l'hibdelphb, Phibddphia Co My Commission Expins Jtt/ 28, 199.3