ML20010D038

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Responds to NRC 810715 Ltr Re Violations Noted in IE Insp Repts 50-352/81-10 & 50-353/81-08.Corrective Actions: Drawing for Hanger HBC-182-H1 to Be Revised & Hanger Reworked to Provide Stiffener
ML20010D038
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 08/05/1981
From: Kemper J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20010D030 List:
References
NUDOCS 8108210395
Download: ML20010D038 (3)


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PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8609

' IOO PHILADELPHIA. PA.19101 JOHNS.KEMPER vicE PRESIDENT AUG 5 - 1981 Mr. Boyce Grier, D ir e :: t o r United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

USNRC IE Region Letter dated . July 15, 1981 RE: Site Inspection of June 15-30, 1981 Inspection Report Nos. 50-352/81-10 & 50-353/81-08 Limerick Generating Station - Units 1 and 2 File: QUAL 1-2-2 (352/81-10 & 353/81-08)

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

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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, 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

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8108210395 810817 -

PDR ADOCK 05000352 PDR O

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ATTACHMENT I Response to Appendix A Violation 10CFR50, Appendix B, Criterion III, states, in part: " Measures shall be established to assure that applicable regulatory requirements and design basis...for those structures, systems, and components to which this appendix applies are currently translated

into specifications, drawings, procedures, and instructions."

The Limerick PSAR, Appendix A.3.1, states, in part: "The equipment and piping considered as Class I Seismic...is as follows:

q...RHR Service Water System...Clpss I Seismic equipment is examined to assure its ability to withstand seismic requirements..."

Specification P-300, " Specification for Piping Materials and Instrument Piping Standards," and P-401, " Design Criteria for l Design and Documentation of Pipe Supports, Hangers, and restraints for Piping 2 " and Larger," require that the RHR Service Water Pipe Support HBC-182-H1 be d signed and installed as Seismic Category I.

l Contrary to the above, on June 25, 1981, Item 7, a 3/4" x 5-3/4" l x l' 8" stiffener plate on Drawing HBC-182-H1, in the RHR Service l Water System, was identified as being attached for support to a ledge angle, defined as not safety related by the Project Q-list, Page C-2, Item 6.

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! Response to Violation The drawing for hanger HBC-182-H1 will be revised and the hanger reworked to provide a stiffener which does not require the use of the ledge angle for a structural connection.

A review is being conducted on all other similar pipe hangers to determine if a similar situation exists. This review will be completed by 10/1/81 and any rework which is necessary will be completed by 3/30/82.

The other hanger configurations which use stiffeners installed perpendicular to the web, (not parallel as in the instance of the i

stiffener for hanger HBC-182-H1), appear to be acceptable with or without the welded connection to the ledge angle. The reviev and evaluation remains to be completed on each hanger to be sure this is the case on all hangers.

l To prevent recurrence of this on future hanger design and redesign, l a memorandum has been issued to designers to be aware of avoiding the use of non-seismically designed supports for connections o?

seismically design equipment.

l I 1/1 50-352/81-10 50-353/81-08 s-

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COUNTY OF PilILADELPHIA .

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

That he is Vice President of Philadelphia 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. 50-352/81-10 and 50-353/81-08 and knows the contents thereof; and that the statements and matters set forth therein are true and s 'rrect to the best of his knowledge, information and belief.

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t Subscribed and sworn to before me this b day of M -

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Notar y 1(b'11c

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. EUZABETH H. BOVEA N PubHe, PNia; Co.

p mmbs4on Empires Jan. 30,1982 1

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