ML20099H454

Applicant Exhibit A-113,consisting of Forwarding Response to Noncompliance Noted in Insp Repts 50-352/80-12 & 50-353/80-10.Corrective Actions:Schneider,Inc Revised Project Procedure PPM 5.1

ML20099H454
Person / Time
Site:	Limerick
Issue date:	05/07/1984
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
OL-A-113, NUDOCS 8411280151
Download: ML20099H454 (7)

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.tle. Scyce Grier, DLec:or

• SEP 2G 1980 United Sta:cs Nucicar Reguls: cry Co::.issien .

Office of Inspec.icn nd Enforeccent, Rc; ion I 631 Park Avenuc King of Prussin, PA 19406

Subject:

US::RC I2 Ro; ion I Lettor, dn:cd August 27, 1930 IC!: Jito and Office Inspection of June 16-27, 1900 Inspection Repor: No. 50-332/30-12 5 50-333/0c-10 L1= crick Cencrating S:stion - Units I sad 2

?ile: QUAL 1-2-2 (252/30-12 sud 353/00-10)

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Cear J!r. Cricr:

{p In responso to the subjec: Ic :er r:2nrding i:c= identified du:ing the V s C c"ubject n-1* inspection

=a -=, - of ==se: construe:icn ac=c t=aactivitics eo feI-in authori:cd

by NRC Licenso ;;os.

A:::ch=nt I - Response to Appendix A Should you have say c.ucstions cenecrning these 1:c=s, we vould be pleased to discuss then with you.

Sincerely, ,

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2 C. er (hi*, J) C/=k A::sch=ent bec: R. li. Elins, Bechtel

• E. R. Klossin, Bech:ci E. J. Drndicy G. White E. C. Yis:ne::

11. R. Walters/ Loc 1 File (2) .

' J. J. C1::cy ,

R. A. l'ulford l W . M. Corcor:n Project File (2) f.

M 8411280151 840507 i

n PDR ADOCK 05000352 Q PDR 1

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ATTACEMENT'I '. ,

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n RES?CNSE TO A??IND!I A ff'_

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s Ita= of None==cliance -A Deficionev -

Appendix 3 of 10C7350, criterion V, s:ates in part: "Ac:1v1:1es

-affec':ing quality shall be prese 1 bed by docu=ented ins: uctions, procedures, c -drawings and shall.be ac'co=plished in accordance wi:h these ina::ue: ions, procedures or drawings.

The L1=erick PSAR, Appendix D,' Quality Assurance ?:ogra=, paragraph D.4.3.2 s:a:es in part: "The subcontractor shall have v iccan procedures for control of the. required testing and inspection progra=s on.che ite= under contract. These procedures shall cover all nondestructive tes:ing...;".

Schneider Inc'. procedure ??M 5.1 Revision 0 requires tha Quality Con:rol inspection personnel have experience and traising and be certified as qualified prior to performing inspecticus.

Con::ary.to the above, on June'IS, 1980 an individual who worked for Schneider Inc. as a QC inspector perfor=ed receip inspections r' without beint. properly certified as a qualified inspector, g r

\- Resoonse to Deficiencv Echneider Inc. upon iden:ification of this-deficiency i==ediately hal:ed perfor=ance of inspections by this individual. All ite=s '

previon 17 in:spected by this individual were re-inspected by a properly certified inspector. This re-inspec:ien activity was reviewed-and found Oc be co=ple:e on 8/19/80.

Schneider Inc. has revised thei Pro j ec: ?;ocedure.??M 5.1, Cer:1ficacion and Training of QC Inspec:Lon Personnel, to include provisions :e allow certification of Level I inspec: ors co three ,

separate' inspection categories after required ::aining is acco=plished. .

I:e= of Nonco=eliance -3 Defteienev Appendix 3 of 10C7R50, Crite:1o= V, states in part: "Ac:1vieles affecting quality shall be prescribed by documented instrue: ions, procedures, or drawings...and shall be acco=plished in at ordance with these ins::uctions, procedures, or drawings." ,

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50-3.5 /80-12 50-353/a0-10 6

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The L1=eri$k ?SAR, Appendin D, Quali:7 Assurance ?:ogran, paragraph D.4.8-s:a:es, in.part: "The'. subcontractor shall have instructions

' f's> '] . gove: ing :he con:rol of =easure=ents. -These ins: ue:1ons shall include, as appropria:e, calibration to standards and accuracy

, .aquire=ents...". -

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Schneider Enc. procedure ??M 3.3, Revision 5. states in part:

"Lov hydrogen.:ype. coa:ed elec: odes and' stain 14ss steel. covered

~ electrodes shall be s:ored in vented ovens a: 25007 to 350 07.

The ovens shall be checked _ quar:erly using a calibraced ther=o=eter...". ,

Contrary to the.above, on June 20, 1980 oven nu=ber 1, which .

contained 17013 covered. electrodes, was at a ta=perature in excess of the 35007. Calibra:ed ther=o=eters used for =easuring oven

e=perature were apparently in error.

Resoonse to Deficiency Schneider'Inc. issued Corrective Action Report #43.on 6/23/80 directing che defec:ive ther=o=eter to be re=oved fro = service and destroyed. Corrective Action vam verified on CAR #43 and was closed on June 25, 1980.

New thermometers have been purchased, calibrated, and placed in service and the electrode oven's te=perature'has been reduced to

-within the, acceptable range. Corrective actions xere verified as being accouplished on 8/5/80.

O Q,j x_ The veld rod and velds =ade with this rod are acceptable and no t

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( ..  ? effect on the-safety and reliability of the velds is possible because the 40007 rod storage oven ta=perature (which was 5007 I over the specified range of 25007 to 35007).vas not sufficient l to break down the coating on the veld rod. This was confirmed .

l during the NRC exit =seting for'this inspection where the inspec:or l stated, after consulting with veld rod =anufacturers, tha.c a 40007 L s torage ta=perature was not detri= ental to the rod.

Ite= of Nonco=o11ance -C ,, ,

, Deficionev' l

Appendix 3, of 10C7E50, Criterica V, states in,part: "Ac:1vities '

affec:ing quality shall be prescribed by docu=ented ins uctions, or drawings... and shall be seco=plished in accordance vi:h these instrue:1ons, procedures or drawings".

I. The Li=arihk ?SAR, Appendix D. Quality Assurance Progra=, paragraph D.6.4 sca:es in part.: "Bechtel Construction Depart =en:...is responsible for construction of the plant to approved engineering specifica: ions, drawings, and procedures...."

3echtel D sving C-602, Revision 21 in. note 4, s:a:es in part: -

" construction join:s shown on this drawing do no: represent actual location. For actual construction j oin: loca:1uns, see CC drawings".

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50-353/30-13 -

3ech:e1 Job Rule JR-G 30-requires.  : hah each C drawing shall con:si:

. '\ - a-noce specifying :he_ul:i= ace use of the drawing. If :he drawing

-isn't to show :he-as-buil: conditioss, then a note, "Installa:Los

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shown en cha. drawing is no:L equired to reflec: the as-buil:

condition"'mus: he placed near the ti:le block of the drawing.

Con::ary to :he above, as of June 13, 1930, drawing :C-456, Revision _l, does_nce reflect che as-built' location of :he cons tru'c:Lon j oint in the vall, no does 1: have :he required ul i= ate ute note.

Reseense-to Deficienev .

C series drawings are used as "construccics aid" drawings. They are not design drawings and do not show ac:ual cons: ue: ion join:

loca: ion.

Note'4 on drawing C-602 has been revised and now sta:es:

" Construe:1on. join:s shown on this drawi=g do no: represent actual location. Construction joints may be located as required by the Field, unless noted otherwise on the design drawings".

As required by Job Rule G-30, by Dece=ber 31, 1930 a note will be placed on C drawings indicating that the drawing does so: reflect the as-bui.'t condition.

Item of Noncomeliance -D

' - Infraction

{ "Activi:ies Appendix B, of 10C7R50, Criterion V, states in par::

affecting quality shall be prese 1 bed by docu=ented ins:: ctions, procedures, or. drawings...and shall be acco=plished in accordance with these instruction, procedures, or drawings."

The Limerick ?SAR, Appendix D. Qualit7 Assurance ?;ogras,-paragraph D.6.3 statas in part: "Bechtel Power Corporation shall perform the c

i quality assurance surveillance functie: to assure tha: equip ====

! manufacture is in compliance wi:h,the applicable" specifica:1on.

l 3echtel inspection carries out the surveillance function utill:ing.

established guidelines and procedures..."

The 3echtel Nuclear Quali:y Assurance Manual Seccion III, procedurc

nu=ber 4, paragraph 3.1.7 states in part: "a release for ship =en:

shall not be gran:ed until all identified deficier.cf es and non-conformances are resolved, i.e. disposition verifiad or provisions made for subsequen: resolution such as documented on a =onconfor:ance; report." .

l Con::ary to the above, as of June 17, 1930, a weld repair had been

=ade to the coped area of a safety related s::ue ural beam which l

l had been delivered to the site. The weld did not mee: the AWS -

D.1.1 accep ance cri:eria. The suppliers quali:y docu=en:a:1on for :his s::ue: ural bea= did to: indicate that any weld repairs I

(. y had bee =ade.

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50-352/80-12 ~-

50-353/50-10

[m Resoonse te Infraction 3echtel QC visually inspected the nonconfor=ing hea= and all other coped bea=s for platfor=s shown on drawing C-671 for elevations 225'-8 and 233'-10. Coped areas of eight of the bea=s including the N?.C identified beam. vere nical etched to deter =ine if repair velds-had been =ada. . Radiographs taken~whern seching indicated

< veld repairs determined that_several of the repairs-including the repair identified by the NP.C confained unacceptable veld defects.

The inspection results are documented on NCR 4260 which was dispositioned use-as-is on September 3, 1980.

To. prevent. recurrence, the supplier was requested to i= prove the quality of' weld repairs and has revised his In-Process Inspection Report to include a hold point inspection of beam cope repairs.

Corrective actions have been completed on or before September 26, 1980'.

i Ite= of Noncomoliance -E Infraction Appendix 3 of 10CFR50, Criterion V, states in part: " Activities affecting quality shall be prescribed by documented instructions, l procedures, or drawings...and shall be accomplished in accordance

( -with these. instructions,. procedure or drawings".

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k- The Limerick PSAR,. Appendix D, Quality Assurance Program, paragraph D.6.4 states, in part: "Bechtel Construction Department...is responsible for construction of the plant to approved engineering specifications, drawings and procedures...". -

3echtel Job Rule M-3, Revision 5, in paragraph 4.0a states in part:

"All (electrical and mechanica10 equipment shall be installed in accordance with the j ob rule, the proj ect specifications, the p roj ect engineering drawings,.and-engineering approved vendor drawings and installation instructions."

Contrary to the above, as of June 20, 1980, EVAC duct support No.

11 had been tack welded to the primary containenne floor 11=er y place, although the 3echtel design drawing C-1411 did not specify welding to the liner place. -

Resconse to Infraction The unauthorised tack welds on the diaphragm slab of the containmeng

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liner were removed. After removal of the tack welds the affected l area was examined, us,ing non-destructive testing procedures, to assure that no unsatisfactory. condition exists. Four of these tack welds existed on a single member.

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50-353/80-10 [~~

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. .' I The balance of the Uni: 1 containment was visually inspec:ed by,bo:

'('~ Schneider and 3echtel to ensure that no c: hor.un' authorized welds exist. This correceive ac:1on was comple:ed on 8/27/80.

Schneider has instrue:ed their foremen and welders that only ASMI qualified welders are to work on the containmen: liner. This will preclude any unauthorised Schneider welding on the containment -

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Item of Nonconcliance -7 .

Deficionev Appendix 3 of 10CFR50, Criterion V, "Activitiac

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states in part:

affecting quality shall be prescribed by documented instructions, procedures., or drawings...and shall be accomplished in accordance with these instructions,, procedures or drawings.".

- The Limerick PSAR, Appendix D. Quality Assurance Program, paragraph D.4.1, states in part "...Bechtel si:e subcontractors shall have  ;

a quality. Control organization which has the authority and l' responsibility for seeing'that the quality control progra= is es tab 11she:1, planned and implemented. . .". l Paragraph 18.3.1.1 of Schneider's Quality Assurance Manual requiresi A{.{.} that each area of the QA Manual be-audited once each year.

Contrary to the above, as of June 27, 1980, document control

- activicius performed at the site vere not audited during 1979.

- l Resoonse to reficiency SchneiderInc. conducted a co=plete audit of the site documen:

control activities (Section 6, "Docu=ent Control" of the Field QA Manual) on August 13,.1980.

l l-To prevent recurrence of this situation, Schneider Inc.'s corporate l l office has established a formal audit schedule. Audi:s are scheduled several months prior to the required dates of the various QA Manual sections to ensure timely completion and maintain the specified audi: frequency.

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