ML19350C060

Responds to NRC 810227 Ltr Re Violations Noted in IE Insp Repts 50-352/81-01 & 50-353/81-01.Corrective Actions: Nondestructive Testing Indications Documented & Open Rework Notices Reviewed

ML19350C060
Person / Time
Site:	Limerick
Issue date:	03/23/1981
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8103300305
Download: ML19350C060 (6)

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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET

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Att2 - t I - Herpense to appendix 1 Also enclosed as required by the Notice of Viciation, is an i affidarit relating to the ssponse.

l Should you have any questions conceming these items, we vould 'oe pisaaed to discuss them with you.

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Attach:sent Copy tos  :'J. rector of Inspection and Inforcement /

United States Muclear Regulatory Consnission

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COMMONWEALTH OF PENNSYLVANIA  :

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COUNTY OF PHILADELPHIA  :

1 JOHN S. KEMPER, being first duly sworn, deposes and says:

That he is Vice President of Philadelphia Electric Conpany, the holder of Construction Permits CPPR-106 and CPPR-107 for Li=erick,, Generating, Stat, ion Units 1 and 2; that he has read the foregoing Response to Inspection Report No. 50-352/81-01 and 50-353/81-01 and knows the contents thereof; and that the statements and matters set forth therein are true and correct to thefbest of his knowledge,- information and belief.

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ATTACHMENT I RESPONSE TO APPENDIX A Violation -A 10CFR50, Appendix B, Criterion XVI, states, "... conditions adverse to quality, such as...nonconformances, are promptly identified...

thet the c a t.s e of the conditions is determined and corrective action taken to preclude repetition...and the corrective action taken shall be documented and reported to appropriate levels of mana g e ne t t . .

The Limerick PSAR, Appendix D, paragraph D.4.12, states, in par.,

that: "...The program shall provide input for the initiation o' corrective action and follow-up as appropriate.".

Project Special Provisions Notice, SF/P3P G-3.1, Revision 3, paragraph 3.1.5, states, "If a deficiency to the code require =ents are identified within-the code boundary of an ASME ites, it shall be controlled by the use of nonconformance reports.".

Contrary to the foregoing, on January 15, 1981, the NRC inspector discovered through observation and document review that rejectable nondestructive testing indications were identified and dispositioned

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on In-process Rework Notices instead of Nonconformance Reports as required. Specifically, an ASME Nuclear Class I pipe weld, DLA-107-1/FW 11, was liquid penetrant tested and rejectable linear indications were identified,~"outside the areas of interest,"

(the adjacent base caterial). The indications were dispositioned on In-process Rework Notice No. W655.

This is a Severity Level V Violation (Supplement II).

Resoonse to Violation Nondestructive testing indications documented on In-process Rework Notice No. W655 was subsequently documented on a Nonconformance Report. In addition, a review of open Rework Notices was performed. Several additional instances where In-Process Rework Notices were employe~d in lieu of Nonconformance Reports were identified. These were then inc.orporated into Nonconformance

__... Reports. . _ _ .

To prevent. recurrence tne following actions were taken:

- 1. Supervision and production personnel were instructed to perform no work on ASME boundary components without proper authorization- The instructions were reiterated by the superintendent.in a subsequent memorandum to the responsible personnel.

I 1/4 50-352/81-01 50-353/81-01

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2. The Q.C. department held a training class on January 23, 1981 for the responsible personnel on the requirements for the use of Nonconformance Reports.

Full compliance was achieved on or before March 17, 1981.

In addition, the valve described in In-Process Rework Notice 90.

W6 5 2 (no t ed in the " DETAILS" section of the NRC's Inspection Report,)

was also subsequently documented on a Nonconformance Report.

The valve in In-Process Rework Notice W652 and the pipe spool in In-Process Rework Notice W655 were both fabricated in accordance with the code and received and passed the required nondestructive examinations. The code does not require penetrant examinations during the fabrication / manufacture of these components. Any removal of liquid penetri.nt indications, outside the area of interest of the liquid penetrant test performed during installation is in excess of code requirements and, therefore, the valves were acceptable for installation as received from the manufacturer.

Violation 3 10CFR50 Appendix 3,' Criterion V ', s t a~t e s , in part, that, " Activities affecting quality shall be... accomplished in accordance with these instructions, procedures, or drawings.".

The Li=erick PSAR, Appendix D, paragraph 6.4, states, in part, that, "Sechtel Construction Department...is responsible for construction of the plant to approved engineering specifications...".

Bechtel. Specification'for Forming, Placing, Finishing and Curing of Concrete, 8031-C-36, paragraph 14.0, states, in part, that,

" Imperfections in formed concrete.shall'be repaired as soon as practicable but no later than 28 days after forms removal.".

Contrary to the above, on January 15, 1981, a concrete imperfection was observed 'on approxi= ate elevation 279', in Reactor Building No. 1, in the West slab construction joint RS-P-1-4, measuring approximately 2" deep by_.1" high by l' in length. The Quality Control. Inspection. Record No. C-140-RS-P-1-4, executed on October 10, 1977, did not record this condition.

This'is a ' Severity Level V Violation. (Supplement II).

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Response to Violation -

NCR 4551 was issued t,o identify that the concrete wall imperfection had not been repaired within 25 days after form removal. The NCR was dispositioned "use as is"1because e' e structural integrity

- of the wall.will not.be adversely affected by failure to make repairs within 28 days.

I 2/4 50-352/31-01 50-353/31-01 P

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Bechtel QC implemented Quality Control Inspection Record VC-140-RS-P-1-4B for inspeccion of the subject area and issued In-Process Rework Notice C-2229 which identifies that repair is required at the locatior. described by the Violation. The repair location has been chippud to sound concrete and dispositioned " minor" per the r e q u i r eme r.t s of Section 14.0 of Specification C-36. The repair will be completed before March 31, 1981.

QC reinspected approximately 100 other concrete placements originally inspected ' sersonnel who inspected the placement t in question. The rein, n documented on QC-C-1-C-36-SI-1-1, identified 5 minor def. dch have been repaired.

Actions taken to prevent u.currence were 1) a class held on 2/17/81 after the Violation was identified; and 2) reissue of PCM-487, dated 6/16/80 (Project construction Manager memo) to all responsible personnel to re-emphasize the requirement that concrete repairs are to be made within 28 days of form removaal.

Violation - C '

10CFR50, Appendix B, Criterion IX, states, in part, that,

"... Welding... (is) controlled...in accordance with applicable codes, standards, specifications...".

The Limerick PSAR, Appendix D, paragraph D.6.4, states, in part, that, "Bechtel Construction Department...is responsible for construction of the plant to approved engineering specifications...".

Welding Procedure Specification F1-A-LF. (Sheet), Revision 0, requires that welding be performed in accordance with the General-Welding Standard, GWS-Structural. The GWS, in paragraph 5.1 and Table GSW - Structura. - 1, requires that for E7018 electrodes and material thickness in excess of 1" through 2 ", the welding preheat be maintained at 150 F.

[ Contrary co the above, on Janua ry 21, 1981, the welding on the safety-related electrical supports, Weld No. R-431-4, consisting of a 5/8" place welded to a structural beam flange greater - than 1\" thick, did not have preheat cpplied to a temperature of 150 F.

This-is a Severity Level V Violation (Supplement II).

Response to Violation

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We have determined that. weld R-431-4 performed without preheating to 1500 is acceptable based on tests performed for certain Welding l Procedure Qualification Reports. .The applicable PQR's are 606, L 688,1689, 690, 691, 705, 706, and 707. These tests were performed l .using E6010,and E7018 veld electrodes and they demonstrate that I' 3/4

. 50-352/81-01 50-353/81-01

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, satisfactory welds can be done on 1- to 2 inch base material using significantly less preheat than the 1500? required by the General Welding Specification. The preheat temperature for the above tests were either 50 0 F or 60cF, indicating that no preheat was performed and that the ambient te=perature vaa recorded during the test. The 500 to 600 F ambient is approximately what exists throughout the heated plant, therefore, weld R-431-4 was perfor=ed

under essentially the same conditions as the above PQR's. l Furthermore, codes other than AWS base preheat requirements on weld size, using the throat thickness of a fillet weld as measure-ment instead of thickness of the base metal. For example in regard

to preheat, ANSI B 31.1 states, "The thickness of socket, fillet and seal welds is defined as throat thickness for pressure non-

. pressure welds". (See ANSI 3 31.1 - 73/U74, table 131, note 4.)

Similarly, where.the ASME code offers guidelines for preheat of

• P1 steel,' the code states that the guidelines do not apply to

"... Fillet Welds 1/2 inch and under in sire that are used ::

attach insulation clips and other parts not carrying loadings 3[ due to internal pressure."- (See ASME,III - Div. 1, 1974,

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Subsection NA, Appendix 0, paragraph D-1210.2). The position that the fillet weld throat thickness should be used to determine '

. preheat requirements instead of base metal thickness is supported 3

by the PQR's noted above. '

cur-position is that minimum preheat requirements should be determined as outlined above, however, the actual work practice in the future will meet the preheat requirements in the General t

Welding Specifications which are more conservative.

To prevent a recurrence the following actions were taken:

a) A training session was held on January 22,.1981 for all electrical welders, foremen, general foremen, and electrical superintendants to discuss preheat requirements in AWS codes.

-b) i0 n the same date, a training session was held for Bechtel welding. Quality Control Engineers on the same subject.

c) :The Job Rule for Welding, Job Rule _G-16,-was revised on March 23,~19811 to-clarify and emphasize structural preheat requirements.

J Full c:mpliance was achieved on or before 3/20/81. -- -

I . 4/4 50-352/81-01

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