ML20107H781
| ML20107H781 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/31/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8411090267 | |
| Download: ML20107H781 (4) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 1215)841-4502 JOHN S. KEMPER VIC E#R ESID ENT guesmasnews ano masammCH g y g y l g 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
Subject:
USNRC IE Region letter dated October 4,1984 Re: Site Inspection of June 25-July 20, 1984 Inspection Report No. 50-352/84-29 Limerick Generating Station, Unit 1 File: QUAL 1-2-2 (352/84-29)
Dear Mr. Murley:
In response to the subject letter regarding items identified during
- the subject inspection of construction activities authorized by NRC License No. CPPR-106, we transmit herewith the following:
Attachment I - Response to Appendix A Attachment II - Response to Appendix B Should you have any question concerning these items, we would be pleased to discuss them with you.
Sincerely, S S, d,I-John S. Kemper RECram Encl.
Copy to:
Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, PC 20555 S. K. Chaudhary, USNRC Resident Inspector 8411090267 e41031 PDRADOCK05000g a
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' ATTACKENT I 1
TVIOLAT' ION Al 10CFR50, Appendix B,' Criterion IX, directs that-nondestructive testing be accomplished in accordance with appropriate codes. The FSAR,
' invokes the' ASME XI Code,1974 through Sunmer 1975 Addenda. The ASME XI Code directs that calibration of. ultrasonic examinations be
~ accomplished in accordance with Article I-4000 calibration, w
. Contrary to the above, an tRC review of the ultrasonic preservice
_ examination data md a' letter (Reference Ntstber 024-99) from Nuclear
- Energy
- Services,wL,talls an. unacceptable method of calibratlon which Is not in accordance with ASN Section XI I-4000. The method is currently _being.used by site POE Level-III personnel, who interpret and evaluate ASE XI code ultrasonic reflectors for acceptability.
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-RESPONSE' Nuclear' Energy Services has_ Issued Revision 7 to the " Ultrasonic Examination General Requirements", procedure 80A1565, to require all Level. III's to ' complete 'a calibration data sheet when the evaluation requires verification or additional' data. Calibrations are performed In accordance with the abnve referenced procedure and the specif.lc
. examination procedure, which conpiles with ASE Section XI.
Acceptability-of previous Level III' evaluations Is' doctsnented on Nuclear Energy ~ Services letter. 5551-898a dated August 16,-1984.g. This
- letter doctsnents a demonstration held for the Authorized Nuclear Inservice Inspector, Philado_1phia Electric % pany PIS Data Reviewers, and a representative from Bechtel M&QS.
a demonstration'showed t
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.repeataol1Ity and relIabl1Ity of previous Level III evaluations.
All Nuclear Energy Services' Level III personnel have been instructed
-to observe and comply with the revised procedure.- This Instruction has been doctsnented by NES ~on letter 024-241 dated August 15, 1984.
> Full' conpliance of_ the corrective action was achieved August 22, 1984.
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352/84-29 aco -
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ATTACHMENT I VIOLATION B-10 CFR 50, Appendix B, Criterion ~ XV, requires that nonconforming items be identified, reviewed and dispositioned in accordance with documented pro-cedures. - Site Quality Control. program for controlling and documeating
, nonconforming. items, SF/PSPG-3.1, Revision 11, dated January 13, 1984, Paragraph L3.1.5 requires that Nonconformance Reports be written when materici is believed to be nonconforming.
. Contrary.to the above, an NRC review of preservice ultrasonic examination data on July 9-20, 1984, disclosed that Pipe Weld Nos. RHB-194, HP-117, RHB-005 max,and RDB-011 were identified as containing rejectable weld
. indications but were not reported on nonconformance reports. These defects were'not dispositioned in accordance with approved procedures.
RESPONSE
Philadelphia Electric Company has issued Nonconformance Reports numbered S866M, S867M, S868M, and S869M to document the repot:ed indications on July 26, 1984 These' NCR's have subsequently been dispositioned, required action completed and closed-out.
The above violation was a direct result of PLB-15,359 dated August 23, 1983,
~
which contained guidance for writing nonconformance reports for rejectable indications found during Preservice Inspection. This letter has been withdrawn 'per the directions specified in Finding Report N-418, dated July 20,11984
'All Ultrasonic Test Data has been reviewed via the NES Supplemental '
Evaluation List of recordable indications and no additional rejectable indications exisc which were not reported on nonconformance reports.
- Full compliance was achieved on July 26, 1984.
ECG I-2/2 REC
.352/84-29 p_,
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ATTACHMENT II DEVIATION Final Safety Analysis Report (FSAR) Revision 27, dated December, 1983, Section 6, Paragraph 6.6 states, the preservice inspection program shall meet the requirements of the 1974 code,Section XI through the Summer 1975 Addenda, as modified by Appendix III of the Winter 1975 Addenda. Appendix III, Supplement 2, requires a reference system to be established to locate the weld center line for ultrasonic examinations.
Contrary to the above, there were no reference points established for the piping systems at Limerick Unit 1 to determine the weld center for the preservice ultrasonic examinations.
RESPONSE
Nuclear Energy Services procedure 80A1557, Rev. 2, " Procedure for Weld Marking Datum Points and Identification" has been issued which details a mandatury method for identifying the weld centerline. Reference marks are to be stamped or vibro-etched on each side of the weld, outside of the examination area. The marks are placed in adjacent pairs, three inches from the toe of the weld, located in four areas 90' apart, around the circumference of the component.
This method was previously an optional requirement in Revision 1 of the referenced procedure'. This method has been implemented by NES since the summer of 1983
'during system walkdowns and rescans. To date, in excess of 80% of the welds in the PSI Program Plan have been marked. The remaining welds will be marked durin,t the ISI examination. The Inservice Inspection Plan which will be issued by Occober 1,1985 will include this requirement. This commitment is being tracked by Philadelphia Electric Company's E&R QA Open Finding Report N-415.
Corrective action will be completed by October 1, 1985 with the issue of the Limerick Generating Station Inservice Inspection Program Plan.
REC 11_171 ECG' 352/84-29