ML20042A314
| ML20042A314 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/05/1982 |
| From: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20042A307 | List: |
| References | |
| NUDOCS 8203230319 | |
| Download: ML20042A314 (4) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 s2isi 041 4 500
- v. s. no v a sH. vec t Purstot N T NUCLE AH POWE H Mr. Ronald C.
Ila yn e s United States Nucicar Reguintory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue i
King of Prussia, PA 19406
Subject:
USNRC IE Region Letter dared February 4, 1982 RE:
Site Inspection of December 1,
1981 January 8, 1982.
1 Inspection Report No. 50-352/81-17 6 50-353/81-15.
Limerick Generating Station - Units 1 and 2 File:
QUAL 1-2-2 (352/81-17 6 353/81-15)
Dear Mr. Ilayne s :
In response to the aubject 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 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.
t Sincerely, j
i t
JPE/kk Attachment Copy to:
Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, D.C.
20555 J.
P.
Durr, USNRC Resident Inspector O$foffy 5
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COMMONWEALTil 0F PENNSYLVANI A sS.
COUNTY OF PilILADELPilIA V.
S.
BOYER, being first duly sworn, deposes and says:
That he is Senior Vice President, Nuclear Power, of Philadelphia Electric Company, the holder of Construction Permits CPPR-106 and CPPR-107 for Limerick Cenerating Station Units 1 and 2; that he has read the foregoing Response to Inspection Report No. 50-352/81-17 and 50-353/81-15 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, s
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Subscribed and sworn to 1
d" before ne this day o f H i s. c,s. F i c. s 1
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' )n. (L't i. (/ //k. ~ w '
Notary Public Ymy u.:i. rw "
,w-l My Cc.r u a L%m jds L.13 E3
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I ATTACllMENT I Response to Appendix A 4
Violation During inspection on December 1,
1981 - January 8, 1982, and in accordence with the' Interim Enforcement Policy, 45FR66754 (October 7,
1980), the following violation was identified.
4 10CFR 50. 55a (d) (2) requires that Class I piping meet ASME Boiler and Pressure Vessel Code Section III (B&PV-III), which requires in Paragraph NB-2121 that materials used in Class 1 piping conform to the material specification.
Bechtel Specification P-312 for Shop Fabricated NucJear Service Piping, Paragraph 5.2 states that materials shall be-in accordance with the ASME B&PV-III.
Bechtel Pipe Specification P-300 for Class "DBA" d
10-inch diamter pipe requires that Specification SA-106 Gr.
B, Schedule 80 pipe be used.
ASME II Material Specification SA-106 i
Paragraph 18.3 and Table A2 limit the minimum wall thickness at any point on Schedule 80 pipe to 0.519 inches.
Contrary to the above, on December 9, 1981, Nuclear Class 1 pipe spool DBA-106-1 was 0.500 inches thick in a ground out area.
Response to Violation t
The area ground down on the subject pipe spool below minimum wall l
requirements has been reported on Bechtel Power Corporation NCR-5281.
l The NCR has been dispositioned by Bechtel design engineers as requir-ing nondestructive examination of the subject ground areas, removal of any indications found, and repair by addition of weld metal to any areas less than a minimum required thickness.
In an effort to determine if any similar condition exists, the-subject spool was completely inspected as were six other pipe spools with the same heat number and the remainder of the pipe spools shown on Isometric Drawing DBA-106-1.
The deviation from minimum wall thickness identified by the Resident NRC Inspector occurred on pipe spool DBA-106-1-2A which was cut from pipe spool DBA-106-1-2 to permit installation of a flow element.
Another ground area with a pipe wall thickness less than 0.519 inch was identified during the inspections on the original pipe spool DBA-106-1-2.
The ground area on DBA-106-1-2 was also reported on NCR 5281 and the engineering disposition is the same as for the first ground area.
No other ground areas or deviations from the minimum pipe wall thickness were identified on the other pipe j
spools inspected, llowever, several minor surfaca discontinuities which are of an indeterminate nature were observed on other pipe spools I
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1/2 50-352/81-17 50-353/81-15 I
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r inspected and were reported on NCR 5281 to obtain engineering direction for further examination.
The engineering disposition for these minor surface discontinuities requires removal by grinding, nondestructive 4
examination to verify removal of all indications, and measurement of the remaining wall thickness to verify conformance to pipe wall thickness requirements.
The grinding reported on NCR 5281 appears to have occurred during fabrication, since the ground area is under paint.
A letter dated February 5, 1982, was sent to Texas Pipe Bending Company, the fabricator, identifying Texas Pipe's responsibility for nonconforming ground areas, reminding Texas Pipe to comply with the specification requirements and requesting more effective inspection in order to preclude recurrence of discrepancies of this type.
Corrective Actions required by the disposition of Bechtel NCR 5281 will be completed by May 28, 1982.
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2/2 50-352/81-17 50-353/81-15
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