ML20003A729

Responds to NRC 801020 Ltr Re Violations Noted in IE Insp Repts 50-352/80-17 & 50-353/80-15.Corrective Actions:Bechtel Identified Cutting of Rebar as Nonconformance W/Drawing & Reinstructed Personnel

ML20003A729
Person / Time
Site:	Limerick
Issue date:	11/17/1980
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20003A730	List: ML20003A729
References
QUAL-1-2-2, NUDOCS 8102050793
Download: ML20003A729 (3)

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O PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101

,_ g (2151841 4502

. ...=::=:1.. N0V 171980 Mr. Boyce Grier, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcenent, Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

USNRC IE Region I Letter dated October.20, 1980 RE: Rite Inspection of September 2-5 & 15-30, 1980 Inspe tion Report No. 50-3',2/80-17 and 50-353/80-15 Limerick Generating Statio1 -

Units 1 and 2 File: QUAL 1-2-2.(352/80-17 and 353/80-15)

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, SWr&

JMC/mmk Attachment O E O /{ Q h -

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ATTACHMENT I RESPONSE TO APPANDIX A Item of Noncompliance -A Infraction Appendix B, of 10CFR50, Criterion V, states in part: " Activities 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 states, in part, that: "Bechtel Construction Departmunt...

is responsible for construction of the plant to approved engineering specifications, drawings, and procedures...".

The Bechtel Job Rule G-28, Revision 18 in Section 5.2 states, in part, that: "The lead area engineer is responsible for issuing the Rebar cutting tool. Each area's drill shall be kept out of general circulation and shall be used only with the approval of the lead area engineer."

Contrary to the above the Crafts were drilling into a seismic Class I block wall No. 62 (Ref. Drawing C-762) without the required written appruvaL oC the lead area engineer.

Response to Infraction Bechtel Power Corporation QC has issued Nonconformance Report NCR-4378 on October 10, 1980 to identify the cutting of rebar in wall 62 as a nonconformance with drawing C-603. Bechtel Project Engineering will evaluate the noncsnformance by the end of 1981 to detarmine if corrective action is required for the wall. This evaluation will be coordinated with their review of the masonry block wall adequacy required by NRC Bulletin 80-11.

To prevent recurrence, Bechtel Proj ect Field Engineering Memorandum PFEM-1724 was issued on October 9, 1980 requesting Area 2 to instruct appropriate personnel on the requirements of Job Rule G-28, Section 5.0, concerning rebar interference.

Item of Noncompliance -B Infraction Appendix B, of 10CFR50, Criterion V, states in part: " Activities affecting quality...shall be accomplished in accordance with these instructions, procedures or' drawings...".

I 1/2 50-352/80-17 50-353/80-15 9

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The Limerick PSAR, Appendix D, Quality Assurance Program, paragraph D.6.4 states, in part, that: "Bechtel Construction Department...

I is responsible for construction of the plant to approved engineer-ing specifications, drawings, and procedures...".

The Bechtel design specification E-1412, sheet 1.3.1 entitled

" Wire and cable notes and details" depicts typical (two) methods for protecting cables from sharp edges of the cable trays (side rails and ends). The two methods consist of the use of adhesive backed nooprenc gasket material or slit air hose.

4 Contrary to the above, as of September 18, there were five cable trays (Nos. 1ATX01, IATXA32, ICTTA24, ICTSA06 and 1BTVA05) that -

had cables coming out of the trays which were not protected from j the cdges of the trays.

Response ta Infraction

, Proper cable protection has now been installed on cable trays 1ATXA01, IATXA32, 1CTTA24, ICTSA07, and IBTUA05. Cable tray numbers 1ATX01 and ICTSA06 noted in the infraction were erroneous ,

and should have been LATXA01 and ICTSA07, respectively. Buchtel QC inspected the above tray sections by November 6, 1980 to assure compliance to Field Design Change Notice FDCN No. 18 of. drawing  ;

E-1412. Bechtel QC performed additional inspections for cable '

protectLon in the cable spreading room and 4kv switchgear rooms a

and those areas were found to meet the requirements of FDCN No. 18.

To prevent recurrence, Bechtel issued FDCN No. 18 on October 31 j 1980 to clarify requirements for cable protection. Bechtel QC i held a training session on October 31, 1980 explaining the implementation of FDCN No. 18. Also, Quality Control Instruction E-4.0, Act/ Task 3.3 was revised on November 6, 1980 to require inspection for cable protection for each safety related cable.

I. 2/2 50-352/80-17 50-353/80-15 l

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