ML20004D574

Responds to NRC 810430 Ltr Re Violations Noted in IE Insp Repts 50-352/81-04 & 50-353/81-04.Corrective Actions:Const Personnel Reminded to Properly Restore Covering Matls After Working on Valves

ML20004D574
Person / Time
Site:	Limerick
Issue date:	05/26/1981
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20004D565	List: ML20004D574
References
NUDOCS 8106090543
Download: ML20004D574 (4)

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• PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 1881 1981 PHILADELPHIA. PA.19101 MAY 261981 JOHN 5. KEMPER v ec t-Pe tst O E N T I s................... .

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Mr. Boyce Grier, Director  !

United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I "

631 Park Avenue King of Prussia, PA 19406  ;

Subiect: USNRC IE Region Letter dated April 30, 1981 RE: Site Inspection of March 2-27,. 1981 Inspection Report No. 50-352/81-04 & 50-353/81-04 Limerick Generating Station -

Units 1 and 2 F1.e : QUAL 1-2-2 (352/81-04 & 353/?l-04)

Dear Mr. Grier:

In response to the subject letter regarding items identified during the subject inspection of constructica activities authorized by NRC License Nos. CTPR-10 6 and - 10 7, we transmit herewith the following:

Attachment I - Response to Appendix A Also enclosed as required by the Notice of Violation, is an affidavit relating to the response.

Should you have any questions concerning these items, we would be pleased to discuss them with you.

Sincerely, C lk Chief Mechanical Engineer for J. S. Kemper JPE/gra Attachment Copy to: Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, D.C. 20555 J. P. Durr, USNRC Resident Inspector 8106090 54/3

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COMMONWEALTH OF PENNSYLVANIA  :

se.

COUN'TY OF PHILADELPHIA  :

EDWARD C. KISTNER, being first duly sworn, deposes

.and says:

That he is Chief Mechanical Engineer of Philadelphia i Electric Company, the holder of Construction Permits CPPR-106 and CPPR-107 for Limerick Generating Station Units 1 and 2; that  ;

he has read the foregoing Response to Inspection Report Nos. 50-352/81-04 and 50-353/81-04 and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.

M 2" l%

Subscribed and sworn to before me this h day of M g W w Nota y blic a , ,c iti Eh v F.

no ry Public. Pfist.? Co.

T .-m Empires Jan. 341982

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ATTACHMENT I RESPONSE TO APPENDIX A Violation -A 10CFR 50, Appendix B, Criterion V, states, in part, that, " Activities affecting quality shall be ... accomplished in accordance with these instructions, procedures, or drawings."

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

General Electric Specification 22A2724, Revision 2, Equipment Storage Requirements, Paragraph 4.1.2.1.2.a., states, in part, " Internal i cleanliness of equipment...shall be maintained by closing openings, where possible, by plugging, capping and/or sealing with tape."

Contrary to the above, on March 16, 1981, reactor coolant pressure boundary valves IF023B, 1F031A, 1F0313 and 2F023B were observed to have openings to internal parts exposed. (353/77-10-01)

This is~ a Severity Level VI Violation (Supplement II) applicable to CPPR-106 and CPPR-107.

Response to Violation-The valves noted in the violation to be totally or partially ,

uncovered were inspected and no detrimental affects were found.

These valves have now been properly covered.

To prevent recurrence, the appropriate construction personnel were reminded to properly restore covering materials after working on or around valves, and the responsible quality control personnel-were reinstructed in the requirements to assure proper storage of. equipment during installation.

I 1/2 50-352/81-04 50-353/81-04

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' Violation -B 10CFR 50, Appendix B, Criterion V, states in part: " Activities affecting quality shall be ... accomplished in accordance with these instructions, procedures, or drawings."

The Limerick PSAR, Appendix D, Paragraph 6.4, states in part:

"Bechtel Construction Department...is responsible for construction of the plant to approved engineering specifications..."

Job Rule JR-G-28, Revision 19, " Job Rule for Installation of Expansion Anchors and Grouted-In Threaded Rods," Paragraph 5.2, states in part:

"Each area (rebar cutting) drill shall be kept out of general circu-lation and shall be used only with the approval of the Lead Area Engineer." Furt. der, Job Rule JR-G-28, Revision 19, Paragraph 5.5, states in part: "When rebar is cut in a Q-listed area, a copy of the (cut Reinforcing Steel Report) form is given, on the same day, to QC to verify the hole locations."

Contrary to the above, from November 12, 1980 to January 1, 1981, forty-three core drills (rebar cutting drills) were in general circulation; in that they were issued, logged out, and never returned.

, Also, ,on or about February 10-13, 1981, reinforcing steel was cut 4

while drilling anchor bolt holes for a pipe support on the K3F-101, pipe, elevation 313', area 15. Reactor Building No. 1, and the cut Reinforcing Steel Report was not issued until February 25, 1981.

(352/81-04-01)

This is a Severity Level V Violation (Supplement II) applicable to

. CPPR-106.

Response to Violation A recall of the rebar cutting drills was issued immediately upon discovery of this condition. Any bits that were not accounted for during the recall were presumed worn-out and subsequently discarded.

Since this item of noncompliance occurred, we have taken several steps to prevent recurrence of this condition. These actions include the revision of Job Rule G-28 to more clearly describe the use and control of the rebar cutting bits. In addition, the procedure has been. changed-to revise the controls of the following activities; oxcavation review prior to drilling, the actual drilling, rebar cutting approval, documentation of cut rebar, and installation. The above changes are now implemented and their effectiveness is under ovaluation. Further changes may be needed as a result of our evaluation of these procedural changes.

We are also currently evaluating the impact of not fully controlling the rebar cutting bits and from not reporting cut rebar in a timely nanner.

Je are unable to complete our evaluation and develop conclusions on che effectiveness of the above actions at this time. A final response to-this violation will be submitted by 9/15/81.

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50-353/81-04