ML20099G873
| ML20099G873 | |
| 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-098, OL-A-98, NUDOCS 8411270475 | |
| Download: ML20099G873 (5) | |
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e.W4 m /w s DEC -11978 Mr. Eoyce Crior, Director United States Nucles: Regulatory Cor.sission Office of Inspection and Enforce =ent, Region I 631 Pari Avenaw King of frussia, PA 19406
Subject:
USKRC IE,I Letter dated June 16, 1971 Rh:
Si:e Inspection of l'ay 16-23, 1979 luspection Report tio. 50-352/13-07; 50-3.*3/73-04 Li arich Genorsting 5tstiurr - Units 14 2 p ile:
QUAL 1-2-2 (352/78-07)
QUA1.1-2-2
-(353/73-04)
==Dear
.r. Grier:==
r
'O in response tu thu subject let:er regardin3 an 1:tc identifi:d darine v
thu 34 ject ins ction of constmetion activities autnori::.! by hkC License 14cs. tiPh-106 and -107, we transmi: herewith the following:
Attachment I - Response to Appenaix A Should you aave any questions concerning this ite=, we would be pleased to discuss :nen with you.
V L,.f. /
Sincerely, kOf g./uM l
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A::nchment bec:
R. H. Eliss, Bechtel J. 5. Ker;er
- 5. J. Srsdier G. White E. C. l'istner H. R. Ws1:ers/ Local File (3)
J. J. C11rsy
,p A. A. !lulford
,v J. M. Cercoran W. J. Johnsen/R. H.
ong 8411270475 840507
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1 ATTACHMI::7 I
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RIS?O::SI TO A??I:0IZ A i
Resoonse to I:en of Noncom:liance Infraction 10CPR50, Appendix 3, criterion V, sea:es in part, : hat:
'"A::ivi:1es affec:ing quali:7 shall be prescribed by documen:ed ins::ue: ions, precedures, or drawings and shall be accomplished in accordance wi:h these instrue:icas, procedures, or drawings."
The Limerick PSAR, Appendix D, Quality Assurance Prograr, paragraph 6.4, s:a:es, in part, that:
"Bechtel Construction is responsible for construe:Lon of the plant Department.
to approved engineering speciffcations, drawings and procedures The Peabody Testing Inc., a con:: actor to Bechtel, utili:es nondestructive examination procedure :itled " Liquid Penetrant Inspection of Walds and Components," IPPT-340-39-02 Amendment-f No. 2, which states, in part, in paragraph 6.6.3, that:
final interpretation shall be made'a minimum of seven
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minutes and no la:e: chan thirty minutes after the developer is applied."
Contrary to the above, on Septa =ber 2S, 1978, during the liquid pene:ran: test of weld; join: H5C-182-1/0-YW50, :he licensee's contractor technician made interpretations before.
the seven minute developer dwell time had elapsed.
Response
+.
1.
Backtreund Peabody performed an investigation of Peabody's Annual MDE Personnel Performance Audi:s of Peabody personnel presently and previously employed a: :he Limerick site.
This investiga: ion revealed : hat liquid pene: an:
examinations audited were performed in accordance with applicable procedures.
Additionally, the investiga: ion included all previous Peabody six-(6) nonth audit reports performed on Peabody facilities at Limerick Site.
These i
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50-352/73-07 50-352/73-04 L1
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-. Io repor:s revealed tha: liquid penetran: examinations'wi:-
'b nessed durtn; :hese audits were performed in acecrdance-with applicable peccedures'.
Based upon these investi-ga:icas, :he-Peabody Testing Quality Control Manager provided assurance tha: this liquid pene:ra: ton' ens = ins-tien was an isolated incident and-: hat other liquid penetran: exa=ina:1ons performed by Peabody personnel at the Limerick Site have been performed to applicable require =en:s.
2.
Corrective Action Taken and Results Achieved a.
The NDE technician in question was re-qualified for b
liquid pene:: ant exa=ina:1on by Peabody Testing.
The practical por: ion of the exanination was witnessed by the ASME Code Inspector and by representatives of the 3echtel-Q.C. Department.
The re-qualification certifica:1on were' approved by 3echtel on October 13, 1978.
b.
Weld H3C-182-1-?U50 Gas re-examined by a qualified Peabody Technician and was found acceptable.
The
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results of this report are documented on Peabody "esting Report PET-?;-2325.
)
c.:
Approxima:ely 50% of the'11guid penetrant-examinations in which the subj ect NDE technician performed or was an assistant we're re-exa=ined
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using the liquid penetrant method.
All welds were.
found acceptable except one (1) which was rejected upon re-examination by another qualified Peabody technician.
Evaluation of the rejectable area of the one weld indicated that it was a mechanically caused lap, h" from the veld area.
It was incon-clusive whether the rej ectable area was present at the time of the original liquid penetrant examina -
tion, since cleaning operations by craftsmen pre-ceeded the re-examination.
Additional evaluation also indicates that it this instance, the'inco :ect technique would not have had an effect on the outcome of the examination, since a simple wipe, without the use of solvents, would not remove a sufficient quantity of dye to affec: the~ appearance of an indica: ion on the developer.
Based on the number of' welds re-examined and the resulting high ratio of acceptable to rejectable welde, those welds not re-examined are considered acceptable.
O t-2/3 50-352/78-07 50-352/73-04 17
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e 3.
Cerrective Action Tsken to ?reven: - ?. e c u r r e n c e a)
The responsible 3echtel Cuality Con:rol Engineers have been instructed to increase surveillance ac:ivities with regard to liquid pene::an:
eka=ina: ion on all ?eabody Testing Personnel.
This increased surveillar,.ce.will con:inue until :he Lead
-Quali:7 Control *a'elding Engineer is confiden:
cha: Peabody Testing Personnel who are performing Liquid Penetrant Examinations are adhering :o the app roved NDI p rocedure.
b) 3echtel Quality Con: o1 has.added,an inspec: ion activi:y to the-Quality Control Ins::uction for NDE Subcon:ractor Surveillance.
This activity 1
requires Sechtel to witness, for compliance with the approved NDE Procedure, :he ft s: exanination by each individual :schnician for each method tha:
a technician is qualified to perform.
This will' escablish initial confidence in new Peabody Testing Personnel a :iving on site.
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