ML20010G958

Responds to NRC 810430 Ltr Re Violations Noted in IE Insp Repts 50-352/81-04 & 50-353/81-04.Corrective Actions:All Rebar Cutting Drills Recalled & Procedures Revised

ML20010G958
Person / Time
Site:	Limerick
Issue date:	09/14/1981
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20010G948	List: ML20010G958
References
NUDOCS 8109220713
Download: ML20010G958 (3)

Text

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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 1881 1981 PHILADELPHIA. PA.19101 (2151841-4502

._= =f1. SEP 141981 Mr. Ronald C. Haynes United States Nuclear Reg'.latory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

USNRC IE Region Letter dated April 30, 1981 RE: Site Inspectior. of March 2-27, 1981 Inspcction Report No.: 50-352/81-04 &

50-353/81-04 Limerick Generating Station - Units 1 and 2

Reference:

J. S. Kemper (PECO) to B. Grier (NRC) Letter dated May 26, 1981 File: QUAL 1-2-2 (352/81-04 & 353/81-04)

Dear Mr. Haynes:

In our initial response to the subject Inspection Report, Appendix A, regt.rding Violation B, we indicated that a final response would be submitted by September 15, 1981.

Enclosed is Attachment I, Final Response to Appendix A, Violation B, and as required by the Notice of Violation. an affidavit relating to the response.

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

Sincerely, JMC/gra Attachment Copy to: Director of Inspecticn and Enforcement United States Nuclet- Regulatory Couission Washington, D.C. 20555 J. P. Durr, USNRC Resident Inspector 8109220713, g h 2 PDR ADOCK ~ PDR G

..6 ATTACHMENT I Final Ponponse to Appendix A - Violation B I

10CFR $0, Appendix D, Criterion V, states in part: " Activities affecting quality j chall be ... accomplished in accordance with these instructions, procedures, or {

drawings." ,

The Limerick PSAR, Appendix D, Paragraph 6.h, states in part: "Bechtel Construction f Department...is responsible for construction of the plant to approved engineering l rpecifications..."

Job Rule JR-G-28, Revision 19, " Job Rule for Installation of Expansion Anchors and j Grouted-In Threaded Rods", Paragraph 5 2, states in part: "Eacharea(rebarcutting)  !

drill shall be kept out of general circulation and shall be used only with the approval of the Lead Area Engineer". Further, Job Rule JR-G-28, Revision 19, Para-graph 5 5, states in part: "When rebar is cut in a Q-listed area, a copy of the (cut Rein &rcing 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 while drilling anchor bolt holes for a pipe support on the KBF-101 pipe, olevation was 313', until not issued areaFebruary 15, Reactor Building (No.1 25, 198'. and the cut Reinforcing Steel Report 352/81-Oh-01)

This is a Severity Level V Violation (Supplement II) applicable to CPPR4 06.

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 thic item of noncompliance occurred, we have taken several steps to prevent recurrence of this condition. These actions include two revisions of Job Rulo 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; excavation review prior to drilling, the actual drilling, rebar cutting approval, documentation of cut rebar, and installation. The controls include placing a unique number on each rebar cutting drill, recording that number on the checksheet when approval to use the rebar cutting drill has been granted, and recording the bit number in the los used to control the issue and return of the bits.

The procedure for reporting reinforcing steel cut during expansion anchor installation has been simplified. One form is now used to approve the original installation, cpprove cutting specific reinfor.:ing steel, and to document the cutting of reinforcing steel. The above procedural changes have been evaluated and are considered to be effectively implemented.

We have also evalusted the impact of not fully controlling the rebar cutting bits and from not reporting cut rebar in a timely manner. Eight "as-built" sketches of heavily conjested walls / slabs with expansion anchor installations were evaluated by Bechtel Engineering assuming the worst possible number of rebars had been cut. As the result of this study, Bechtel Engineering determined that the walls / slabs are still structurally adequate. 1 g/3 50-352/81-04 50-383/81-04

~

, J " . 's

• COMMONWEALTH OF PENNSYLVANIA  :

ss.

COUNTY OF PilILADELPilIA  :

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 Lisarick 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.

El -

Subscribed and sworn to before me this j day of b-I

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ary Pu'bl ic/\

ELtZA ETH H. BOY R Notary Pub ic. Phila., Phi

.Commi n Expires Jan. 30,1982