ML20091C412

Responds to NRC Re Violations Noted in IE Insp Repts 50-352/83-19 & 50-353/83-07.Corrective actions:post- Turnover Maint Personnel Reinstructed in Requirements of Job Rule M-21, Performing Work on Flushed Sys

ML20091C412
Person / Time
Site:	Limerick
Issue date:	02/17/1984
From:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20091C386	List: ML20091C412
References
NUDOCS 8405300558
Download: ML20091C412 (9)

Text

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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 ,

l PHILADELPHIA. PA.19101 m si e4i.4ooo FEB 171984 tuomicaina amo atsrancu nce.aratur Mr. Thomas E. Murley, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406 Subjec t: USNRC IE Region I Letter dated January 10, 1984 RE: Site Inspection of October 17-November 30, 1983 Inspection Report No. 50-352/83-19 & 50-353/83-07 Limerick Generating Station - Units 1 and 2 File: QUAL 1-2-2 (352/83-19 & 353/83-07)

Dear Mr. Murley:

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 Also enclosed is an af fidavit relating to the response.

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

Sincerely, lulenfager v JPE/drd/840130-3 Engineering & Research Department At tachment Copy to: Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, DC 20555 S. K. Chaudhary, USNRC Resident Inspector 8405300558 840521

• PDR ADOCK 05000352 O PM

.~ e Com0NWEALTH OF PENNSYLVANIA  :

ss.

COUNTY OF PHILADELPHIA  :

JOSEPH W. CALLAGHER, being first duly sworn, deposes and says:

That he is Manager, Engineering and Research Department 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 No.

50-352/83-19 and. 50-353/83-07 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.

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() V U Subscribed and sworn to before me this /) day of. l$ WY 0$22lh_1

- Notary Public PATRICIA D. SCHOLL

- Notary Pubite, Philsdelphia ' Philaddphia Co.

My Commission Expires Tebruary 10,1986

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- RESPONSETOhPPENDIXA

.VI'OLATION Is I 10 CFRL50', Appendix B, Criterion V, requires' that activities.af fecting

. quality be prescribed by a'ppropriate procedures and accomplished in accordance with these procedures.

.Bechtel Power' Corporation, Job Rule M-21 is the procedure established to provide direction ~ to construction personnel regarding cleanliness controls on systeas which have been turned-over to the licensee's Startup Organization.

Contrary to the above,' as of November 30, 1983, Job Rule M-21 had not been ef fectively implemented as evidenced by the f ailure to provide suitable cleanliness controls following disassembly of' a feedwater system contairment isolation valve IN41-1F010A. The valve body was ,

open, the internal surfaces of- the valve anJ its atuched piping were exposed to tha containment; environment, and standing water of undetermined quality had accumulated in the valve.

RESPONSE TO VIOLATION I Cleanliness controls associated with the identified valve and for

- Startup Work. Orders in progress at that time were corrected as' necessary to identify cleanliness- requirements _ to meet the. requirements 1 of Job Eule M-21.

To prevent recurrence of this condition, several! actions have been taken:

1)~ Post Turnover Maintenance field engineers, superintendents, and craf t personnel have been reinstructed in.the; requirements 3 of Job. Rule M-21 (Performing Work on Flushed Systems) .

2) Job Rules which contain references to Post Turnover -Maintenance have been revised 'to also apply to Startup Work Orders.

3) A Quality' Control Engineer hasbeen assigned full' time to -

oversee construction and housekeeping practices associated

. with the requirements' of , Job Rule M-21.~ '

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j RESPONSE TO APPENDIX A .;

VIOLATION 2

- 10 CFR 50, Appendix B, Criterion X requires the establishment of a program that assures that examinations, measurements, or tests of caterials or products processed be performed for each- work operation where necessary to assure quality. .

I Section.17.2A.10.of the Final Safety Analysis Report and Volume I, Section 10 of the Limerick Generating Station Quality Assurance Plan establish this program.

Contrary to the above, the progra n establishe.d for engineering and quality inspection of pipe support hangers failed to assure the quality of two -saf ety-related hangers in- that, _as of Novenber 7,1983, hangers VRR-IRS-HHA-1 and HHB-1, for ths reactor recirculation sys tem suction piping were inadequately designad and installed and the inadequacies were not . identified during the engineering and quality inspections which

, had been completed.

RESPONSE'TO VIOLATION 2 The interferences identified by the Inspector did not develop until' af ter Field Engineering and QC acceptance of HHB-1 and Field Engineering release for pre-ops of HHA-1. These interferences developed as a result of the vibration caused by the recire pump operation. . However, . subsequent

- to the interferences developing, Field Engineering performed rework on '

hanger .HHB-1 which QC inspected. The rework was limited- and did not

involve the interfering members of .the support. The interferences were .

not identified because of the apparently limited inspection of the-reworked hanger.. '

s .

The Inspector identified interferences have been resolved by implementing l

p tan option which was included in an FDDR prior to the interference- being; -

L Identified. The option was not used durit.g initial installation because i the. Field Engineers did not foresee the developement of the interferences.

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i. To determine the ~ extent of' this condition QC completed inspectbns of the:

24 GE designed recirculation and unin steam hangers. These inspections '

U identified several nonconf ormances, the majority of which result from the lack of installation tolerances. Investigation into the-cause of -

these nonconf ormances - is..'not complete.: Theref ore, a follow-up response 4 to this violation will be.made by;3/31/84. ,

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. RESPONSE TO APPENDIX A VIOLATION 3' 10 CFR 50, Appendix B, Criterion <V requires .that activities affecting quality be prescribed by documented procedures and accomplished in accordance with the established procedures.

' Project procedure PSP-G-3.1 specifies nonconformance reporting requirements

.and permits oniv one nonconforming condition to be reported in each noncon-formance report (NCR).-

Contrary to the above, the project nrocedure for NCR reporting was not followed in that. as of November ~ 30, 1983, NCR 6507 was revised to include additional nonconformances.

RESPONSE ~TO VIOLATION 3 j

The additions made to Nonconformance Report (NCR) No. 6507, although admittedly not provided for in the existing procedure, did document the nonconforming conditions and associated dispositions to adequately meet the requirements -

of 10 CFR 50, Appendix'B, Criterion XV.

To prevent recurrence and to provide for the.various situations encountered during the processing of Nonconformance Reports.(NCR's), Project Procedure 3

PSP-G-3.1.was revised to provide for reprocessing the original NCR if the existing condition was not resolved or if a new condition was created by the disposition. .The PSP was also revised-to require a.new NCR be gen-l' erated when additional nonconforming items are' discovered. The exact i instructions in the PSP are:

- "If ~" Rework" or " Repair" performed to .the original disposition did not satisfactorily resolve the existing condition

or created a' new condition, the Construction Quality Control Engin4er per-forming _ the reinspection shall document the results as a revision l to block 19 of the NCR form, and reprocess the NCR for additional disposition.

i If ' additional nonconforming items are discovered as a result of ~

the reinspection, a new Nonconformance Report shall-be initiated.

The Quality Control Engineer performing the reinspection shall ,

use discretion in determining which of the 'above conditions applies. -

. Any question shall be resolved -by the responsible lead discipline-

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-Quality Control Engineer."

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. Additional training has been given on1the above matter.

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i FEB 171984 Mr. Thonna E. Murley, Director United States Nuclear ReLulatory Commisujon Office of Inspection and 1:nforcantient, Region I 631 Park Avenue King of Pruccia, PA 19406 Subj ec t: USNRC 11:, Ret,1un I Letter dated January 10, 1934 RE: Site lucpection of October 17-Novetaber 10, 1983

. Inspection Report No. 50 ')S2/83-19 & 50-353/if'J-07 Limerick Generating Station - Unita 1 and 2 File: QUAL 1-2-2 (352/83-19 f. '151/83-07)

Dear Mr. Murley:

In response to the nubject letter regardin;>. itetau identified during the subject inupoction of cunutruction netivities authorize.1 by MRC License Nos. CPPR-106 and 107, to transmit herewith the followine,:

A ttachinent I ilesponnu to Appoiuli:: A Also enclos,ed is an affidavit relating to the response.

Should you have any questionu concerning these item 1, t.e t,ould be pleased to diucous them with you.

Sineercly,

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Qp Q 4# fodineering IV Research Department

!!-" JPE/drd/840130-3 Manager p' Attachinent

,b p Copy to: Director of Inspection and rnforcetaent ,

United States Mucionr Regulatory Coccission Washington, DC  ?.0555 S. K. Chaudhary, USURC Resident luspector

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RESPONSE TO APPENI)lX A ,

i E VIOLATION I 10 CFR 50, Appendix B, Criterion V, requires that ac tivities afl ecting in quality be prescribed by appropriate proceduren and accomplishe,)

accordance with these procedures.

Bechtel Power Corporation, Job Rule M-21 in the procedure estabt ished to provide direction to construct ion personnel rey,ardt oiny, cleanl t he i ne"8 fleennee' controlu un .systemn whicli luive been turned-over Startup Organization.

Contrary to the above, as of November 10, l *RI's , Job Hol etoM-71 failure prwind ids-not been uf fec tively Lmplemented an ev idenced by I he suitable cleanliness controls f ollowing dianssemblyThe of avalve f eedwa bodyt was er system containment isolation valve llV41-lF010A.i t s a ttached piping were open, the internal surfacen of the valve nial exposed to the containment unvironment, and nLanding wa ter of.

undetermined quality had neeumulated in the vn Ive.

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Cleanliness controls associated with thatthe identifled t ime valve andasf or were corrected necessary Startup Work Orders in progress a t to identi f y cleanliness requ irements to meet I he requ irement n cf .lub Rulu M-21.

To prevent recurrence of .this condition, several actions have Icen taken:

1)

Pos t Turnover Maintenance fluid engineern, 'superintendente, alKI craf t person.nel have been reinstructed in the /equiremente of Job Itulo M-21 (Perf orming Work on Flunbed Systeme) .

nance

2) Job Rules which contain ref erences to Pout Turnover Mainte have been revised to also apply to Startup Work Orders.

3) - A Quality Control. Engineer has been assigned full time to oversee construction and housekeeping practices associated with the requirements of Job Rule M-21.

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RESPONSE TO APPEND 1X A l i

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VIOLATION 2 i j

10 CFR 50, Appendix B, Criterion X requires the establishment of' a d program that assures that examinations, measu rements , or testn of materials or products processed be performed for each work operation where necessary to assure quality.

Sec tion 17.2A.10 of the l'inal Safet y Analynin Report and Volume I, Section 10 of the Limerick Cunerating Station Quality Assurance Plan ectablish this program.

Contrary to the above, the progmm established for engineering and assure the quality quality inspec tion of pipe sup.iort hangers f ailed tu of two saf ety-related hangers in that, as of Novanber 7,1983, hangers VRR-IRS-IlllA-1 and lillB-1, fur the reae tor reeI reulatIon synien sue tlun piping were inadequately designed and installed und the inadequ.seles were not identified during the engineering and quality inspections which had Seen completed.

HMSPONSM TO VIOI.ATJON 2 The interferences identified by the Inspector did not develop until af ter Field Engineering and QC aeceptance of 111lll-1 and Field Hngineering release for pre-ups of IlllA-1. These interf erences developed as a result

' of the vibration caused by the recire pump operation, llowever , subsequent to the interferences developing, Field Mngineering performed rework on innger 11118 - 1 which QC Inspected. The rework was limited and did not.

Involve the interfering members of the suppor't. '?he interferences were not identified .because of the apparently limited :41spection of the reworked hr.nger.

The Inspector identified interferences have been resuived by implementing an option which una included in an FDDR prior to the interference being identified. The option was not used during initial installation because

- the Field Engineers did not focusee the developement of the interferences.

To determine the extent of this condition QC completed inspections of the 4

24 GE designed recirculation and unin steam hangers. These inspections identified several. nonconf ormances, the majority of which result from the lack of installation tolerances. Investigation into the cause of these nonconformances is not complete. Therefore, a follow-up response -

to this violation will be made by 3/31/84.

I 2/3 352/83-19 353/83-07

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RMSPONSE TO APPHNDIX_A_

VIOLATION 3 l 10 CFR 50, Appendix II, Critorion V requires that activities af fecting

. quality be prescribed by ' documented procedures and accomplished in accordance with the established procedures.

- Project procedure PSP-C '3. I specif f us nonconformance report i ng requirements and permits only one nonconforming condition to be reported in each noncon-Lformance report (NCR).

Contrary to the above, the oro.iees orncedure lor NCR r..nortion wau not followed in that. as of November 30, 1983, NCR bS07 was revised to include additional nonconformances.

RESPONSE TO VIOLATION 3 The additions made to Nonconformance Report (f;CR) No. 6507, although admittedly not provided for in the existing procedure, did document the n'onconforming conditions and associated dispos Ltions to adequately meet the requirements of 10 CFR 50, Appendix 11, Criterion XV.

To prevent recurrence und to providu Lbrthe va r i ous u1Luationu encountered during the processing of Nonconformance Reportu (NCR's), Project Procedure PSP-C-3.1 was revised to provide for reprocessing the originai NCR ii the existing condition was not renol ved 'or if a new condit ion wan created by the disposition. The PSP wau also revised to require a new NCR be gun-3 erated when additional nonconforming itemn are discovered. The exact instructions in the PSP are:

"if " Rework" or " Repair" performed to. the origingt disposition '

did not satisfootorily resolve' the existing condition or created a new condition, the Countruct ion Quali ty cont rol Munineer pi r-forming the reinnpcetion'nhall document the renullu an a revision to block 19 of the NCR form, and reprocess the NCR for additional disposition.

If additional nonconforming items are diseuvered as a result of the reinspection, a new Nonconformance Report shall be initiated.

The-Quality Control Engineer performing the reinspection shall use discretion in determining which of the above conditicieapplies..

Any question shall be- resolved by the responnible lead discipline Quality Control Engineer." .

Additional training has been given on the ahuve matter.

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.h e 9 PHil sADELPHlA ELECTRIC COMPANY s 2301 MANKET STREET

, P.O. BOX 8699 PH:LADELPHIA. PA.19101 1215[041 4000

" orch 26, 18s?.4

'r. da.rus f'. "ut ley, Director l' . i u s' fit a n . 2- ..uclear Keaulatory Conr,f rnion office of li.op etion ari d Enforcerent, Per f on 1 63] fark ? venue l i t.;' of I rur.c i a , Pn. 19406 Subj e ct : US .AC IF Re.gion 1 Letter deted Jr.ccory 10, 19b4 Re: Site Ins pection of October 17-fovember 3D, l'B'3 Inspection Peport Fo. 50-352/U3-10 and 50-353/U3-07 Feference: J. S. 5'e r pe r Le t t er to T. F. . urley, dated 2/17/H4 Iile: QUAL 1-2-2 (352/03-19) over r. ;urjev:

In m:r reenense to Violsrion 2 nf Insm'etion Penort W . 5t'-3 5?/:' 3-19 cc ev oitted to a follen. up rm ponse by 3/31/t4. I!our- ve r, tbc correcti're cetjon Jteted in our previous responre bar, not yet been ccro!cto .. 1( 1 e' ' e '+ c e t to coirnlete prorrear tie corrective 1 r t i n'19 'y f./ ~10/'a and vill inter- y: of eer

4. r thit tire.

f.1ould you have any ruestions concerning this itee, i e 1o013 be p l e t's ed t o dis. cut s t her vi th you.

M nce rcl:',

C J. 5. Peeper F A:.ir cc: S. F. Chaudhary, SRC Re:;ident luspector (Lir.erick)

J . *i . 'i n : ins , $7kC 1:esident Inspector (Litrerick)

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