ML19261A586

Responds to NRC 781121 Ltr Re Violations Noted in IE Insp Repts 50-352/78-09 & 50-353/78-05.Corrective Actions: Protection & Storage of Equipment;Qc Documentation Implemented Re Verification of Concrete Strengths

ML19261A586
Person / Time
Site:	Limerick
Issue date:	12/27/1978
From:	Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19261A584	List: ML19261A586
References
NUDOCS 7902050078
Download: ML19261A586 (5)

Text

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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET PHILADELPHI A. PA.19101 1215)841-4500 V.S.BOYER

" " ~ " " ' ~

I)ecember 27, 1978 bir. Boyce Grier, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406 Subj ect: USNRC IE;I Letter dated November 21, 1978 RE: Site Inspection of October 17-19, 1978 Inspection Report No. 50-352/73-09 5 50-353/78-05 Limerick Generating Station - Units 1 5 2 File: QUAL 1-2-2 (352/78-09 and 353/78-05)

Dear Str. Grier:

In response to the subj ect letter regarding an item identified during the subj ect inspection of construction activities authori::ed 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 this item, we would be pleased to discuss them with you.

Sincerely,

^

1 .

V. S. Boyer Jh!C/mak Attachment 990z050 'T

ATTACEMENT I Resuonse to Annendix A Item of Noncomuliance - I 3 & D I. 10CFR50, Appendix 3, Criterion V, states, in part, that: " Activities affecting quality shall be prescribed by documented instractions, procedures, or drawings .. . and shall be accomplished in accordance with these instructions, drawings and procedures ...."

Section D.6.1.2 of Appendix D of the PS/R states, in part, "Bechtel Project Managecent is responsible for monitoring to assure that the quality control requirements for the storage of cc=ponents .... are effectively implemented."

Section D.h.9 1 of Appendix D of the PSAR states, in part, "

.... equip-ment vendors shall have written instr 2ctions to gove:n the ... storage

... and presertation of the itecs ... to prevent degradation . . ."

Bechtel Job Rule No. 8031-JR-G-7, Rev. 1h, states that equipcent should be stored and maintained in accordance with vendor instractions unless modifications to vendor instractions are approved by Project Field Engineer.

Contrary to the above, as of October 18, 1978:

3. Terry Turbine Procedure SP-11 was implecented in 1972 and was still in use, although its use was limited to a duration of three years.

D. Electrical equipcent on the HPCI turbine was not protectively wrapped in accordance with vendor require =ents.

Resuense to Iten of Noncomuliance 13 Job Rule G-7 has been revised to provide for storage that exceeds specified vendor tine periods.

Resnonse to Iten of Noncomeliance 1D The Unit #1 EPCI turbine was examined and a Long Te m Maintenance Rework Notice was issued for inadequate protection of equipment. The corrective maintenance was co=pleted on November 8, 1978.

Additionally, the Unit #1 RCIC, Unit #2 RCIC and Unit #2 EPCI turbine units were examined. A Long Tem Maintenance Rework Notice was issued for inade-quate protection on the Unit #1 RCIC. Corrective maintenance was completed on November 13, 1973. The Unit #2 RCIC and EPCIwere found satisfactory.

I-1/h 50 352/78-09 50 353/78-05

The Maintenance action activity task 01-09 was inadvertently deleted from the long Tem Maintenance Program, resulting in the missed main-tenance activities. The maintenance activity task has been re-instated in the cceputer program. This action will prevent recurrence.

Item of Nonconnliance II II. Criterion V of 10CFR$0, Appendix B, requires, in part, that, " Activities affectbag quality shall be prescribed by Documented instructions, procedures, or drawings, of a type appropriate to the circunstances and shall be accom-plished in accordance with these instructions, procedures, or drawin6s "

The quality Assurance Progran implementation described in the Limerick Generating Station Units 1 and 2 PSAR . . Appendix D, states in paragraph D.6.h, in part, that "(Bechtel) Quality Control Engineers . . . are respon-sible for preparing Inspection Plans in accordance with the Field Inspect-ion Manual, (and) performing Quality Control inspections ..."

The Quality Control Inspection Report (QCIR) form used to 12ple=ent 3echtel Quality Control Instruction 8031-C-1.h0, " Post-Placement inspection of Concrete" provides in paragraph 2.2d for inspection of the following activity:

"For forms that support concrete members, concrete cylinder test report reviewed to verify that concrete has attained the specified strength prior to fom renoval."

Bechtel Drawing 8031-C-637 (Rev. 7) states, in part, regarding the recoval of te=porary supports for the fuel pool girder beans, in Section 3 5.2.7 that, "The posts at or near lines 1k.1, 15.5, and 21.5, shall be removed after the girder concrete is placed to a ci"4 un of EL. 326'-0", and reaches a co=pressive strength of 5,000 psi ...

Contrary to the above on October 17, 1978, 3echtel QCIR C-1226-RW-ST-13-h for the post-placement inspection of the East Puel Pool Girder concrete to elevation 326'-0" indicated, with a "N/A" comment placed next to the requirements of paragraph 2.2d, that no quality control inspection had been performed to verify concrete strength had attained the 5,000 psi required prior to support renoval.

Response

Corrective action was performed on October 23, 1978 when 3echtel QC attached a Field Inspection Repcrt (QC-G1-1)to QCIR C-1226-RW'-ST-13-h. The QC-GI 1 states that, based on concrete cylinder reports and craftscen time cards, concrete below elevation 326'-0" met the compressive strength requirements of Secticn 3 5.2.7 of Drawing 8031-C-637 prior to removal of posts at or near column lines 1h.1, 15 5, and 21.5 I-2/h 50 352/78-09 50 353/78-05

Corrective steps being taken to avoid further items of noncompliance a.re :

o Identification by Project Engineering of the notes on Drawing C-637 which are safety related.

o Writing a QC check list to define the unique inspection activities required by Drawings C-637, C-771, and C-772.

o Revising Quality Control Instructions C-1.20 and C-1.h0 to require use of the check list to supplement the present QCIR's for concrete placements related to the fuel pool system.

o Revising QCI's C-1.20 and C-1.h0 to identify generically the concrete placements which are related to the fuel pool systems.

Full co=pliance will be achieved by December 29, 1978.

Item of Noneceuliance IV IV. Criterion X7II of 10CFR50, Appendix 3, requires in part, that " sufficient records shall be maintained to furnish evidence of activities affecting quality."

The Quality Assurance Program implementation described in the Limerick Generating Station Units 1 and 2 PSAR. Appendix D, indicates in paragraph D.6.h. in part, that " Procedures (are) used to control and perfom inspections by (Bechtel) Quality Control Engineers ..."

Bechtel Job Rule 8031-JR-C-2, Revision 1h, states, in part, in paragraph 3.h that, "The Project Field Quality Control Engineer is responsible for surveillance and documentation of excavation to assure compliance with the referenced criteria and this instruction."

Contrary to the above, no documentation could be produced to indicate that Bechtel Quality Control had perfo=ed any inspection activity for the design change chipping work accomplished on the Unic 2 containment concrete and governed by the restrictions and requirements of approved Field Change Request (FCR) C-1933F.

Resnonse Corrective action was initiated on October 20, 1978 by QC inspection of the chipping work on Unit #2 containment in accordance with the requirements of Field Change Requests (FCR's) C-1933F and C-5111F, Results of the inspection are being documented on Field Inspection Report Number C-199-C-63-L.

I-3/h 50 352/78-09 50 353/78-05

Corrective steps being taken to avoid further items of nonco pliance are:

1. Clarifying Job Rule 8031-JR-C-2 for excavation review by incorporating chippin6 of concrete in its scope.

2. Revising Job Rule 8031-G-5 for design document centrol to describe a better procedure for routing of Field Change Requests.

Also, the QC group is reviewing a representative sa=ple (250-300) of FCR's for modifications to completed work to assure that the codifications were inspected by QC.

Full compliance will be achieved with the Jcb Rule revisions before January 1, 1979 The FCR review will be cocpleted before June o, 1979 I-h/h 90 352/78-09 50 353/78-05