ML20150E324
| ML20150E324 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/18/1978 |
| From: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20150E311 | List: |
| References | |
| NUDOCS 7812130083 | |
| Download: ML20150E324 (6) | |
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e PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET PHILADELPHI A. PA.19101 V..S.BOYER vtCE*$5SiD(Mt a
Mr. Boyce Grier, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406
Subject:
USNRC IE; I Letter dated August 24, 1978 Re: Inspections Nos. 50-352/7803 and 50-352/7804 Limerick Generating Station - Units 1 and 2
Reference:
Telecon H. R. Walters (PECO) and J. Mattia (USNRC) 8/31/78 File: QUAL 1-2-2-1 (352/78-03)
QUAL 1-2-2-1 (352/78-04)
Dear Mr. Grier:
In response to the subject letter regarding items identified during the subject inspections of construction activities authorized by NRC License Nos. CPPR-106 and -107, we transmit herewith the following:
Attachment I - Response to " Enclosure - Areas of Concern -
Item A" Attachment II - Response to " Enclosure - Areas of Concern Item B" Per the reference telecon, an extended date of September 18, 1978 was granted for these responses.
Should you have any questions concerning these responses, we would be pleased to discuss them with you.
Sincerely, j
- %) *m V.' S.
Boyer
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781213062Y'
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ATTACHMENT I Response to " Enclosure-Areas of Concern" Item A Description of Concern A.
Notice of Violation dated May 10, 1978 This item of noncompliance concerned one instance of failure to fully implement the requirements of Liquid Penetrant Test Procedure IPPT-340-39-02, Revision 0.
Namely, liquid penetrant test indications in excess of the acceptance standards were observed by subcontractor test personnel when pipe weld No. H3C-183-1-FW-8 was tested and accepted on April 2, 1978; however, it was not verified whether or 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 removed from the weld after it was tasted on April 2 and the powder revealed test indications which were in excess of the acceptance standards, (2) on April 7 the weld was retested 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) records or other evidence were not available indicating it had been verified that the indicatione did not represent actual defects prior to acceptance of the weld on April 2.
PECO's response to this apparent item of noncompliance was limited to actions which attested to the quality of the particular veld.
Further corrective actions are required to assure that; (1) subcontractor test personnel are properly implementing the testing procedure with respect to the processing of indications which exceed acceptance standards, and (2) other previous liquid penetrant test indications which exceeded acceptance standards were not accepted without taking suitable actions to verify whether the indications represented actual defects.
I/1 50-352/7803
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esponse The chronology of events pertaining to the liquid penetrant nondestructive tests performed on veld H3C-183-1-FW-8 is described below.
This provides background information and rationale used to deter =ine the acceptability of the qualified examiner's evaluation of any indications revealed during the liquid penetrant test performed on April 2, 1978:
o On March 17, 1978 a liquid penetrant test was performed and evaluated by a qualified subcontractor examiner in accordance with the subcontractor's approvcd liquid penetrant procedure I?PT-340-39-02, Revision O.
The field weld was determined to be acceptable and the test was documented as required.
o On April 2, 1978 the liquid penetrant test was again performed and evaluated by the same subcontractor examiner.
This test was performed to accomodate the Authorized Nuclear Inspector's request to witness the liquid penetrant test of this weld.
The liquid penetrant test on April 2 again determined the weld to be acceptable.
This test was documented as required.
After the April 2, 1978 liquid penetrant test was performed the liquid penetrant test mat 2 rials were not removed for cleanliness purposes as required.
This was a failure to fully implement the requirements of procedure I??T-340-39-02, Revision 0,
but appears to have been an isolated case.
Corrective actions have been taken to re=ind the subcontractor personnel of the procedure requirements, o
On April 6, 1978, during an NRC inspection the MRC inspector reported observing indications in the liquid penetrant test caterials 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 performed, this time by Philadelphia Electric Company's Constructors personnel.
The records of this test show apparent relevant 1
. indications.
Since relevant indications could not be reproduced by a subsequent liquid penetrant test performed after the NRC inspection, the April 7 indications must have been false indications.
PECO concludes that these false indications were the result of the difficulty in completely re=oving liquid penetrant materials from the April 2 test which had dried up and set for several days.
o On April 11, subsequent to the NRC inspection, another liquid penetrant test, described in our June 12, 1978 response, 1
1 demonstrated that the evaluation conducted on April 2, 1978 was accurate and that any indications observed were evaluated to have been nonrelevant.
I/2 50-352/7802
It is the PECO position that the indications revealed by the April 2 t e s t,- and later observed by the NRC Inspector en April 5, were evalunted as part of the April 2 test and that no relevant indications were present.
There 1s no requirement to document in the test record any indications which are evaluated and determined.co be nonrelevant, nor it is the policy of PECO, our constructor or subcontractors to do so.
The existence of liquid penetrant test documentation indicating.an acceptable weld is considered to be evidence that any indications requiring evaluation were, in fact, evaluated and found to be nonrelevent in accordance with the test procedure.
Philadelphia Electric Company is satisfied that the particular weld under question is acceptable and that any indications revealed by the April 2, 1978 liquid penetrant test were properly evaluated.
Further, Philadelphia Electric Co=pany is assured that the Subcontractors are properly performing liquid penetrant tests through the surveillance performed by the Constructor's Quality Control Personnel and by periodic Audits conducted by the PECO site Quality Assurance Personnel.
These documented surveillances and audits assure that (1) subcontractor test personnel are properly inplenenting the testing procedure with respect to the processing of indications which exceed acceptance standards and (2) other previous 11guld penetrant 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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t ATTACBEC II 4
l Response to Encicsure - Areas of Ccncern - Item 3 2
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Notice of Violation dated June 15, 1:79 4
This item of nonce =pliance concerned ene instance of failure to control deviations frc= quality standards for Class I seis=le structures.
Namely, Bechtel Drawing No. C-575, Revision 6, was approved and issued to implement modifications to radial beams inside the containment structure even though his drawir4 centained instructions which were contrary to requirenents of the 243 D1.1 Structural '4eldir4 Code, an j
applicable quality standard.
Our bases for the above findir4s included de follevirg:
j (1) te afore=entioned Sechtel drawir4 specifies the use of a weldir4 procedure applicable to prequalified weld joints al icush te weld Joints called out en -he drawir4 do not meet all of te require =ents cf Section 2 of te f43 D1.1 code for prequalified joints, and (2) l the drawir4 permitted the use of fillers in a -ener centrary to
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requirements of Section 2 of the X43 D'.1 code.
The designs of te weld joints were sig.ificantly d.fferent frc= 2at specified for E5 prequalified weld joints. Differences included shape and type of weld Joint and weld sice, e.g., weld sices specified for fillers for Beam Nos. 2h, 25, and 29 were less -'
" at required for ETC-Ph welas by paragraph 2.10 3 cf the applicable N43 code.
1 PECO's respense to dis apparent item of ncncc=pliance indicated tnat clarifyire revisions had been cade to drawirgs, but stated tat code requirements were =et.
Furcer corrective actiene are required tc 4
assure 2at (1) the require =ents of 24S D1.1 have been met in 2e l
perfoncance of the =cdifications, and (2) suitable measures are pronded anc. i=plemented to centrol deviatiens frc= quality standards i
during the design precess.
4 Rescenses to Ite= 3 (1) Cor ective Action to Assure tha*, the Recuirements of NJS Di.1 have
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been =et in the Perferra'.e of the LIedifications To answer the questionable interpretation of t".o prequalification of
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te weld joints shown in details ha and 9 cn Drawir4 SC31-C-375, j
Rev 7, a post qualificatien of this type of weld joint htich includes filler plate will be perfonced in accordance with Section 3 of N43 D1.1.
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'412 the welds for beas Nos. 24, 25, and 29 qualified by the above
- est and stress :alculations indicati 4 te present weld sizes are capable of accc=nocating te design 1: ads, no charge in weld th:.:kness is expected to be necessar/ (?aragraph 2.6.2, 243 D1.1).
(2) Corrective Action to Assure dat Str table Measu es are Prov ded and Implemented to Centrol Deviatiens frc= Qaality Standards curirg the Design Process 2
The appropriate draw _rgs will be reviewed for Ocepliance with X45 D1.1 where sinilar field nodifications to design have Occurred. In addition, 2e Engineers and related staff in the Civil / Structural discipline will be reinstructed to review welf14 configurati:ns for conforance with K45 D1.1.
1 (3) Ceccletion of Co rective Acticns Items (1) and (2) above will be conpleted by Januar/ 5,19'79
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