ML19305E165
| ML19305E165 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/14/1980 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19305E159 | List: |
| References | |
| NUDOCS 8004230071 | |
| Download: ML19305E165 (3) | |
Text
'
O' PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (21518414000 p": a 4lu
., n 10 %
Mr. Boyce Grier, Director United States Nuc1 car Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406
Subject:
USNRC IE Region I Letter dated January 11, 1980 RE: Site and Office Inspection of October 15 thru November 15, 1979 Inspection Report No. 50-352/79-11 and 50-353/10 Limerick Generating Station - Units 1 6 2 File: QUAL 1-2-2 (352/79-11 and 353/79-10)
Dear Mr. Grier:
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 Should you have any questions concerning these items, we would be pleased to discuss them with you.
Sincerely,
- f g
%)
J. S. Kemper JMC/mmk Vice President Attachment Engineering & Research Dept.
g 0 042,3 0
Attachment I Response to Appendix A Item o f Noncompliance - A Appendix B, of 10 CFR 50, Criterion V, states in part:
"Activitics 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 s ta tes, in part, that:
Bechtel Construction Department...is responsibic for construction df the plant to approved engineering specifications, dra' wings, and procedures...".
Bechtel Power Cor'poration Job Rule G-7 Revision
, states in Section 2.2, "in-place" is the location of equipment placed in the plant...because of surrounding construction work, it is during this period that the equipment is often Icast protected from dust, dirt and moisture.
Temporary coverings, heating facilities and routine inspection shall be employed as specified on the maintenance action card. Careful planning and surveillance is required to ensure the equipment fs adequately protected.".
Contrary to the above, as of October 24, 1979 one end of the 4KV switchgear no.10A117 was not adequately protected from adjacent construction activities. There was raceway material, cahic reels, empty soda cans and cement dust either next to or on the 'switchgear.
The scheduled surveillance activity for visual inspection was once per year which is inadequate to ensure' protection with the amount of construction activity present in the area.
Response to Item of Noncompliance - A The subject switchgcar was protected by plywood and polyethylene while other adjacent construction activitics continued.
All equipment was rechecked after this occurrence and found to be acceptable.
Subsequently all switchgcar was cleaned to remove dust and dirt upon comt,letion of adjacent blockwork and fireproofing and then recovered with polyethylene.
.The contractor's Superintendents have been instructed to keep all equipment covered and protected from damage and dirt.
I - 1/2
- '353/79-11 353/79-10
,5-d.
[
- 8 tem of Noncompliance - B i,
Appendix B, of 10 CFR 50, Critorion V, states in part:
"Activitics
'i affecting quality...shall be accomplished in accordance with these 1
instructions, procedures or drawings...".
The Limerick PSAR, Appendix D, Quality Assurance Program, Paragraph D.6.4. states, in part, that: Bechtel Construction Department...is responsibic for construction of the plant to approved engineering specifications, drawings,.and procedures...".
The heating, air conditioning and ventilation subcontractor's wcld
' j procedure SSM-502, Revision 3, states..."the weldirg current and a
manner of depositing the wcld metal shall be such that.there will be practically no undercutting into the base metal.".
i Contrary to the above, as of November 1,1979 excessive undercutting y
into the base metal resulted from the manner in which the welder deposited weld..for the damper flange joint (FPD-202-4 7).
The undercut j
exceeded 1/32 inch.
d Response to Item of Noncompliance - B The noncompliance was resolved by a design change which provides an alternate installation detail to be utili:cd when spacial limitations preclude perfoming a satisfactory external perimeter weld. The alternate installation allows welding the damper to the penetration on the internal i
surface in those areas where the external we'Id is impractical.
3' Previously existing installations will be inspected by August 31, 1980, and reworked if necessary.
Should a similar damper positioning condition reoccur the alternate installation detail allowing the structural and seal wcld in the internal surface will be utili:cd.
I 1
l b
S a
I - 2/2 352/79-11 353/79-10 e ee6* me e a