ML20084M408
| ML20084M408 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/19/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20084M400 | List: |
| References | |
| NUDOCS 8405150356 | |
| Download: ML20084M408 (4) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 1881 -1981 PHILADELPHIA. PA.19101 (215)841-4502 JOHN S. KEMPER VICE PRESIDENT EMtelseg E N6hG AND NESE ANCD8 Mr. Thomas E. Murley, Director United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Subj ect: US NRC IE Letter, dated November 10, 1976 Site Inspection of October 16, 19-22, 1976 Inspection Report No. 50-353/76-06 Limerick Generating Station, Unit 2
Reference:
V. S. Boyer letter to J. P. O'Reilly Dated December 15, 1976 J. S. Kemper Letter to T. E. Murley Dated October 11, 1983 File:
QUAL 1-2-2 (353/76-06)
Dear Mr. Murley:
In addition to the response to the subject letters regarding the items identified during the subject inspection of construe:. ion activities autho-rized by NRC License No. CPPR-107, we transmit the following supplementary information: - Second Supplementary Response to Appendix A Also enclosed is an affidavit relating to the response.
Should you have any questions concerning this item, we would be pleased to discuss them with you.
Sincerely, J. S.
r JMCram Attachments Copy to:
Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, D.C.
20555 C. K. Chaudhary, US NRC Resident Inspector 8405150356 840510 i
PDR ADOCK 05000352 g
m 5
-6 ATTACHMENT I SECOND SUPPLEMENTARY RESPONSE TO APENDIX A - ITEM A The Supplementary Response provided herein is to supply information and details equivalent to the details provided to the Atomic Safety and Licensing Board (ASLB) and to summarize Philadelphia Electric Company's evaluation of the cctivities associated with 353/76-06-01 items as well as the overall quality of welding activities.
The re-review conducted by' Philadelphia Electric Company in 1983 determined that the subject inspector had responsibility for a total of 1,235 safety-related weld inspections at the facility, of which 654 were structural welds and 581 were on components other than structural steel, such as hangers (577),
pipes (2), and electrical conduit supports (2).
It was slao determined that the Bechtel review program which was
. initiated as a result of NRC Inspection Report 76-06 and completed by the end of July,1977 had identified 426 structural welds, 423 being accessible and 3 inaccessible. The.423 accessible welds were reinspected with 6 minor deficiencies noted.
Four of these were reworked, and 2 were found acceptable by engineering analysis. The 3 innecessible welds were found by engineering analysis to be acceptable.
1 The extensive August, 1983 review identified 228 additional structural welds,16 being totally accessible and 212 partially or totally inaccessible.
The 16 totally accessible welds have now been reinspected with one minor deficiency found. This weld, together with the 212 partially or totally in-accessible welds, have been found by engineering analysis to be acceptable..
The non-structural welds, totalling 581, are all totally accessible.
Of these, 577 represent hanger welds with 534 of the 577 being welds of hangers which were completely reinspected prior to August, 1983 as part of a separate hanger inspection program.
T he remaining 43 hanger welds for which final inspections had not yet been made, together with the 4 non-hanger welds, have now been reinspected. These hangers contained 19 minor deficiencies which would have normally been dispositioned as part of the final hanger completion and inspection program. They, instead, were expeditiously dispositioned to resolve this matter.
In December,1980 a general hanger reinspection program was initiated i
due to job conditions which resulted in additional hanger work being required af ter partial inspections had 'heen performed. This reinspection program j
required a final QC inspection of all welds of all safety-related hangers re-1 gsrdless of their previous inspection status. The subject inspector had made l-
~ inspections of 534 welds on partially completed hangers which had subsequently i:
bzen subject ' to modification and completely reinspected prior to August, 1983.
I - 1/2 353/76-06
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In addition to the above described Bechtel reinspections Philadelphia Electric Company Quality Assurance performed surveillances which involved f urther physical reinspection of 67 safety-related structural welds and 60 hanger welds which were originally inspected by the subject inspector and subsequently reinspected by other Bechtel Quality Control inspectors.
These surveillances ide.itified six minor deficiencies on structural steel welds and one minor deficiency on a hanger weld.
These have been found by cngineering analysis to be acceptable for "Use-As-Is".
An engineering svaluation to determine the significance of the fuentified conditions was also performed.
This evaluation concluded that since the design of welded connections conservatively allows for minor variations, the type of deficiencies identified have no ef fect on the safety of the plant.
Philadelphia Electric Company's surveillances were audits of the Bechtel QC reinspections which were performed by a cross-section of Bechtel QC ins pectors. The results of the surveillance have demonstrated the effectiveness of the Limerick Weld Inspection Program.
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. COMMONWEALTH OF PENNSYLVANIA :
ss:
COUNTY OF PHILADELPHIA Joseph W. Gallagher, being first duly sworn, deposes and says:
That he is Manager of Engineering & Research Department of Philadelphia Electric Company, the holder of Construction Permit CPPR-107 for Limerick Generating Station - Unit 2; that he has read the foregoing Second Supplementary Response to Inspection Report No. 50-353/76-06 and knows the contents thereof; and that-
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the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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subscribed and sworn to before me this /f day tb, / f
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