ML20099G854

Applicant Exhibit A-96,consisting of Util 780918 Response to NRC Re Violation Noted in Insp Rept 50-352/78-04 Concerning Failure to Fully Implement Liquid Penetrant Test Procedure IPPT-340-39-02

ML20099G854
Person / Time
Site:	Limerick
Issue date:	05/07/1984
From:	Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
OL-A-096, OL-A-96, NUDOCS 8411270464
Download: ML20099G854 (6)

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8EE 10.1373 1* . T.oyce Grier, Director United Sta:cs !*uclear Regulatory Commission '

Offics of Inspection and Enforce =en:, Region !

531 ? ark Arenue

~ King of Prussis, PA 19405 .

Subject:

US!!EC II; I letter dated August 24, 197E

!!a : Inspections t'o s . 50-352/7803 and 50-352/7804 Limerich Cencrating Station - Units 1 end 2

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Reference:

Telecon H. R. Walters (TECO) and J. !!attia

- (U S!!RC) S/31/78 File: f)UAL 1-2-2-1 (352/73-03) q OUAL 1-2-2-1 (352/73-04)

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Dear !!r. Grier:

r . . . ' during In response to the subject letter retardin's itens identified the subject inspections of construction activities authorized by lfRC License : os. CPPR-106 and -107, we trsascit .

bNE herewith the follovies: ,

gas.

A::achment I - Response to " Enclosure - Areas of Concern -

Ice: A" 8 Attacheent II'- Response to " Enc).ocurs - Areas of Concern -

I:en E" ,

rar the reference telecon, an e::: ended date of Septamher j5gc ta,197a van :ranced f or :hese responses.

j Should you have any questions concerning these responses, wp would be pleased to discuss then with you.

IV Sincerely, ll.T

• $ * .k l 'm h,,.,6

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i RJL/gra I9 g,lf A::achnent bee R. H. Elias, 3ech el J.J. Clarey

., D. Marano J. S. Kemper I, E. J. 3:adlev' K. A. Mulford G . '4 hit e s J. M. Corecran -

E. C. Kis t: ar 5. J. Johnson -

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ATTACEMINT :

Reseense to "In:lesure-Areas of'Cencern" - !:en A O' Rescrie: ton of Ceneern .

A. Nottee of Violatten dated May 10, 1973 ..

This i:em of noncompliance concerned one instar.ce of failure to fully i=plemen: the require =ents cf Liquid ,

Pene:: ant Tes: 7:ocedure IPP.T-340-39-02, Kevision O. '

Namely, liquid penetrant test indications in excess of the acceptance standards were observed by subcontractor test personnel when pipe veld No. E!C-153-1-TV-8 was tested and accepted on April 2, 1978; however, it was not verified whether c not actual defects were present.

Our bases for the above finding included the following:

(1) on April 6 an NRC inspector observed that the developing powder had not been re=oted from the weld after it was tested on April 2 and the powder revealed test indications which were in excess of the acceptance

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O standards, (2) on April 7 the weld was ratested by a qualified examiner from the licensee's constructor in

(' the presence of an NRC inspector and both observed indications in excess of the acceptance standards, and (3) recordsitorhad indicating other evidence been were verified thatnot theavailable indications did '

not represen actual defects prior to acceptance cf the weld on April 2.

PICO's response to this apparen: ite= of nonce =pliance was li=1:ed to actions which a::ssted to the quality of :h's particular veld. Further corrective actions are required l

+ :o assure that; (1) subcont:deto: test personnel are properly implementing the testing precedure wi:h respect to the processing of indications which exceed accep ance j

standards, and (2) other previous liquid pene:ran cast indications which exceeded acceptance standards were not 2

accepted w1:hout taking suitable actions to verify L

whether the indica: ions represented ac:ual defects.

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. 50-332/7803

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-The chronology of events per:aining 'to. :he liquid penetran:

nondestrue:1ve-tes:s perfor:ed on veld H3C-IS3-1-?'l-8 is <

de scribed 'below. This provides background infer =ation and rationale used::o: determine the acceptability of the qualified examiner's evalus:ica el any indiaations revealed during the liquid penetrar.: test performed en Ap:11.2, 1978:

o On March 17, 1978 a liquid penetran:-:est was performed and evaluated by a qualified subcon:: actor examinar in accordance with the subcontractor's a;;;:ved liquid penetran:

procedure I??T-340-39-02, Revision 0. The field weld was determined to be acceptable and the tes: was documented as required.

o on April 2, 1978 the liquid penetrant cas: was again

. performed and evaluated by the same subcontractor exaeiner.

This test was performed to accomodate the Authori=ed Nuclear Inspector's request to witness the liquid penetran: test of

-this weld. The liquid penetrant-test or April 2 again determined the veld to be acceptable. This test was documented as required.

j([ After the April 2, 1978 liquid penetrant test was performed the liquid penetran: test materials were not' removed fo:

cleanliness purposes as required. This was a failure to fully.

-(' imple=ent the. requirements of procedurc IPPT-340-39-02, P.evision 0, but appears to have been an isolated case. Corrective actions have been taken to remind the subcontractor personnel of the procedure requirements. ,

o On Apr11.6, 1978, during an NRC inspection the NRC

• inspector reported observing indications in the liquid penetran:

test materials that had been left on the veld.

On April 7, at the request of',' and in the presence of the NRC inspector, a liquid penetrant ' test was again perictmed.

-this time by Philadelphia Electric Company's Constructors personnel. The records of this test show apparent relevan:

indications. Since relevant indications could not be reproduced by a subsequent liquid penetran: test performed after the NRC inspection, the April 7 indications mus have been false indications. PECO cencludes that these false indications were the result of the difficulty in completely renovir.g liquid penetrant materials from the April 2 test which had dried up and ,se: for several days, o On April 11, subsequent to the NRC inspection, another liquid penetrant test, described in our June -12, 1978 response, O. demonstrated that the evaluation conducted on 1978 was accurate and that any indications observed were April 2, evaluated to have been nonrelevant.

I/2 50-352/7802 .:.

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1 I: is the ?ICC posi:1cn tha: the indications revealed by :he-April 2 tes:, and 12:e: ebserved by the NRC Inspector on April 6,; vere evalua:ed as par: cf the April 2 :ss: and that ne relevan: ' indications were presen:. There is no requirenen:

to docu=en: .in the tes rece:d any indications which are evalua:ed' and deter =ined to be nonrelevan:,- ner 1: is the pelicy of

_ P.E C O , our cess::ue:o or subcon:: actors to do so. The existence of liquid penetrant tes docu=entation indicating an accep:able .

weld is censidered to be evidence that any indications requiring evaluation-vere, in-fact, evalua:ed and found to be nenreleven:.

in accordance with the.:est p;ccedure.

Philadelphia Electric Co=pany is satisfied tha: the particular, veld under question is acceptable and that any indications revealed by the April 2, 1978 liquid penetrant test were properly evaluated. Tur: hor, Philadelphia Electric Co=pany-is assured that the Subcontractors are properly perforning liquid penetrant tests th:ough the surveillance performed by the Constructor's Quality Control Personnel and by periodic Audits conducted by the PECO site Quali > Assurance Personnel.-

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These docu=ented surveillances and audits assure that (1) subcontractor test persennel are properly inplementing the testing procedure with respect to the processing of indications which exceed acceptance standards and (2) other previous r- liquid penetran test indications which exceeded acceptance

(_. standards were not accepted without taking suitable actions to verify whether the indications represented actual defects.

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50-352/7802 .

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S.*ith te welds f:r tes.: :.:s . Za, 25, and 2f. q- =* *'ied b;* the abeve L tes and stress cal:.*.1 :.::s : nit:s.:ing -;.s present weld si:es s.re capable :f a ::=:da.tng r.e desi!; . .: ads , : change in .ield *.hi:kness is e:c;t: ed to be necessar;- (?aragra;h 2.6.2, A*43 21.1).

_ (2) 0:rree-tre A : ten t: Assu-e -ha' S.:1 atie;;2;t- veasures are Previded a.d

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- (3) C : ;1etien of Cor- e -ive A::1:ns .

Ite=s (1) and (2) above v.11 de ::=;1e:ed by Ja=2.a f 5, 197f.

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