ML19350B191
| ML19350B191 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/20/1981 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19350B183 | List: |
| References | |
| NUDOCS 8103200065 | |
| Download: ML19350B191 (3) | |
Text
.
O PHILADELPHIA ELECTRIC COMPANY l
2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 JAN 2 01"1 20- -- -
VfCE PRESIDENT tseossesancese mano nasEAnces 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 December 17, 1980 RE: Site Inspection of November 2-28, 1980 Inspection Report No. 50-352/80-20 and 50-353/80-18 Limerick Generating Station - Units 1 and 2 File: QUAL 1-2-2 (352/80-20 and 353/80-18)
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,
-MdL.E. C,'.
JMC/mmk
-Attachment l
cc:
J.
P.
Durr, Resident NRC Inspector
. 48103 2 0 0 O(oi n
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9 ATTACHMENT I RESPONSE TO APPENDIX A Item of Noncompliance -A Infraction 10CFR50, Appendix B, Criterion IX, states, in part:
"... welding...
(is) controlled and accomplished... in accordance with applicable codes, standards, specifications...".
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 er_gineering specifications, drawings and procedures...".
General Electric Specification 22A2284, Revision 2
" Field Erection of' Reactor Recirculation Piping", paragraph 4.7.1.
Piping Butt Joint End Preparation, requires that, "... existing piping butt
. joint-end preparation shall not be remachined, filed, ground or otherwise changed without prior approval of General Electric."
Contrary to the foregoing, on November 6, 1980 reactor recirculatton
' pipe = spool RS-N-A2, pipe weld preparation-BWRPD-lREC-1/4 WA3, was ground approximately 3/16" into'the base metal and approximately 49" around the circumference.
There was no apparent authorization from Geueral Electric to do this alteration.
Response
The item of noncompliance was documented on Bechtel Nonconformance
- Report 4408.. General Electric disposition and authorization for reworking the weld preparation was obtained on GE Field Deviation Disposition Request FRI-424.
Additionally, a training session for Engineering, Supervision,: Quality Control and Craft personnel was held on: November _7, 1980 in.which the specification requirements were explained and emphasized.
Full compliance was achieved on November 17, 1980.
.9 f
Sheet 1 of 2
Item of Nonconpliance
-B Infraction Appendix B, of 10CFR50, Criterion V, states in part:
" Activities affecting quality...shall be accomplished in accordance sich 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 engineering specifications, drawings and procedures...".
Limerick Project Standard for Visual Examination Acceptance Criteria for Welded strucenres, 8031-G-20, paragraph 4.1.6.1 states, in part, "... undercut'not exceeding 1/32" may oe accepted...".
Contrary to the foregoing, on November 14, 1980, 10 areas of undercut exceeding 1/32" in depth were observed on the feedwater pipe restraint depicted on drawing C-836, Revision 5.
Response
The subject feedwater pipe restaint was inspected by Bechtel Power Corporation inspectors subsequent to the NRC. identification of the deficiencies.
Additional deficiencies identified were recorded on a Bechtel Power. Corporation Nonconformance Report for engineering evaluation.
As a result of this inspection, further inspections are required in order to perform an engineering evaluation of the conditions.
The additional inspections and engineering evaluation will be completed by May 1981 and rework, if required, will be completed by July;1, 1981.
To prevent recurrence, the manufacturer sent a representative to the site to ^bserve the conditions first hand.
In addition to this, o
a Philadelphia Electric Company audit of the vendor involved to check on the effectiveness of his welding ::nspection program vill be conducted during the 3rd week of January 1981.
Sheet 2 of 2
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