ML20008D952

Responds to NRC 800312 Ltr Re Violations Noted in IE Insp Repts 50-352/80-12 & 50-353/80-11.Corrective Actions:Visual Insp of Installed Pipe Support Pins Will Be Extended to Areas Containing Q-listed Pipe Supports

ML20008D952
Person / Time
Site:	Limerick
Issue date:	06/10/1980
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20008D949	List: ML20008D950 ML20008D952
References
QUAL-1-2-2, NUDOCS 8010230713
Download: ML20008D952 (4)

Text

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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 JOHN 5. (EMPER JUN 101980 ,

i l Mr. Boyce Grier, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I ,

631 Park Avenue l King of Prussia, PA 19406 l

Subject:

USNRC IE Region I Letter dated March 12, 1980

! RE: a) Site and Office Inspection of November 20-30, -

and December 3-21, 1979 Inspection Report No. 50-352/79-12 and 50-353/79-11 b) Philadelphia Electric Company Letter to NRC, dated April 10, 1980 File: QUAL 1-2-2 (352/79-12 and 353/79-11)

Dear Mr. Grier:

As stated in our first response (reference b) to the Item of Noncompliance, "D" of the subj;ct inspection, we transmit herewith the complete response in Attachment I.

Should you have any questions regarding this response, we would be pleased to discuss them with you.

l Sincerely, i

l

(

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S /df i .J. S. Kemper l JMC/mmk Attachment l

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8010230f/3 y v ,

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ATTACHMENT I Response to Appendix A Item of Noncomnliance - D Infraction Appendix B, of 10 CFR 50, Criterion V, states, in part: " Activities affecting quality.. .shal' 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 Department. . . is responsible for construction and procedures. . ."

of the plant to approved engineering specifications, drawings, Bechtel Power Corporation Job Rule M-17, Section 5.5.4 states, that,

" Prior to installation vf a hanger, the area engineer or his designee verify that material to be installed is in accordance with the latest drawing revision.

Also, in Section 4.7.b it states that, "The area engineer is responsible for initiating a field change request for hangers which cannot be installed as designed or cannot be installed within specifications."

Contrary to the above, as of December 20, 1979, safety related hangers GBB-112-H20, and HBB-120-H17 were installed with pins made of materials not in accordance with the latest drawing revision, and there was no evidence that a field change request had been initiated.

Response to Infraction - D A program to identify instances where pins fabricated from A-36 material have been substituted for the specified AISI-4140 material has been developed since the original response to this infraction. The program was developed and implemented in three stages: initial investigations which included the development of inspection techniques, verification of the -

inspection techniques to be used and implementation of the inspection program.

I. Initial Investigations I

l The purpose of the initial investigation stage was to determine the  !

extent of the problem and to develop practica1 inspection techniques which would provide consistent results under field conditions.

a. In order to define the extent of the problem, laboratory testing by chemical spot checks and/or X-ray analysis was performed on 45 pipe support pins obtained from Elevation 177 of the Reactor Building Page 1

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• , '(the ares were the problem surfaced) and from the pipe support i

i racsiving/ storage area. All tests and inspections on pipe j

support pins from the site receiving / storage area indicated that

! the original pins supplied by the Vendor were fabricated from the proper material. The only samples which proved to be of l incorrect material were pins found at Elevation 177 of the l Reactor Building. Also these investigations indicated that pins fabricated in the field from A-36 material were substituted for missing or damaged' vendor supplied pins, and that field fabricated pins exhibitied dimensional and workmanship characteristics which I distingushed them- from vendor supplied pins. Additionally, it was found that most vendor supplied , pins had identification codes stamped into the pins. However, early shipments from the vendor i did not include the stamped identification because it was not a requirement of the quality control program at that time.

! b. Several inspection techniques for identifying improper pins were investigated. Eddy current tests and chemical spot testing did not produce consistent results and these testing techniques proved to be impractical under field conditions. By contrast, a I

visual examination with inspection criteria based on the dimensional and workmanship characteristics seemed to provide consistent results.

II. Verification of Inspection Techniques In order to confirm the validity of the visual inspection program a three phase inspection was performed on 100% of the pipe support pins in one area of Elevation 177 in the Reactor Building.

l a. In Phase I, the pins were inspected while instslied. The criteria i included pin diameter, edge distance from the end of the pin to l

the center of the cotter pin. hole and length, all in accordance with the approved vendor drawing. The inspection also included checks on workmanship characteristics such as cotter pin holes which were drilled askew to the pin axis and evidence of flame or sawcut which could indicate a field cut. The pins were also checked for the i vendor identification stamping, but it was rarely visible)being hidden by other components.

b. During Phase II, the same pins which had been visually inspected in Phasel were removed from the pipe support and examined for the vendor identification stamping. If the stamping was present, the pin was acceptable and was re-installed. Pins without the stamping were replaced with an acceptable pin. Phase II confirmed the validity of the visual inspection techniques in that all pins accepted by Phase I had vendor identification stampings.

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c. To further cot (firm the inspections and to identify the extent' of l

c tiv ' pin. substitution problem, a Phase III_ inspection was performed.

[~ In Phase III,"all pins rejected by the Phase I and II inspections l were sent to the PECo Metallurgy laboratory for final confirmation j

of the material . Of the 43_ pins analysed ~ by the laboratory, seven proved to be fabricated from the incorrect (A-36) material.

The visual inspection criteria are therefore conservative.

i III. Program Impleraentation

[ Visual inspection of installed pipe support pins, using the inspection cnteria fpm Phase I will be extended to areas containing Q-listed pipe j supports and will be performed in ace'ordance with a sampling plan based i on MIL STD 105D. Pins which fail the visual inspection will be removed l from the support and examined for the vendor identification stamping.

! 'If the stamiing is missing, the pin will be rejected and replaced with l an acceptable pin. Batch or lot sizes for the sampling plan will be l

i determined by the number of pipe supperts with pins in the designated areas and elevations. A rejected bate:/ lot will cause a 100% inspection of all pins within the designated area / elevation containing the rejected

, batch. Elevation 177 of the Reactor Building, the location where the l pin substitution problem surfaced will be subjected to a 100% visual inspection. The above inspections, and necessary pin replacements will be completed by December 31, 1980.

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