ML20150E327
| ML20150E327 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/24/1978 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20150E311 | List: |
| References | |
| NUDOCS 7812130092 | |
| Download: ML20150E327 (3) | |
See also: IR 05000352/1978003
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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KING OF PRUSSI A, PENNSYLV ANI A 19406
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AUG 2 41973
Docket No. 50-352
Philadelphia Electric Company
Attention:
Mr. V. S. Boyer
Vice President
Engineering and Research
2301 Market Street
Philadelphia, Pennsylvania
19101
Gentlemen:
Subject:
Inspections 50-352/78-03 and 50-352/78-04
This refers to your letter dated June 12 in response to our letter
dated May 10, and your letter dated July 20 in response to our
letter dated June 16, 1978.
The information presented in your letters in response to the Notices
of Violation issued by this offica dces not fully meet the requirements
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of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10,
Code of Federal Regulations.
Pursuant to these requirements, you are
requested to submit to this office within ten (10) days of your receipt
of this notice a written explanation or statement in reply to the afore-
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mentioned Notices of Violation which includes: (1) corrective a+eps
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which have been taken by you and the results achieved; (2) cc
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steps which will be taken to avoid further items of noncompliance; and
(3) the date when full ccmpliance will be achieved,
The enclosure to this letter is provided to assist you in your under-
standing of our areas of concern.
Should you have any questions con-
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cerni.ng these items, we will be pleased to discuss them with you.
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Sincerely,
ga /[Mk
Boyce H. Grier
Director
Enclosure:
Areas of Concern
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ENCLOSURE
AREAS 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 O.
Namely, liquid penetrant ' test indica-
tions in excess of the acceptance standards were observed by subcon-
tractor test personnel when pipe weld No. HBC-183-1-FW-8 was tested
and accepted on April 2,1978; however, it was not veHfied 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 tested 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 indications did
not represent actual defects prior to acceptance of the weld on
April 2.
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PECO's response to this aoparent item of noncomoliance was
limited to actions which attested to the quality of the particular
weld.
Further corrective actions are required to assure that;
(11 subcontractor test personnel are properly implementing
the testing procedure with respect to the crocessina 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
t"e indications represented actual defects.
B.
Notice of Violation dated June 16, 1978
This item of noncompliance concerned one instance of failure to
control deviations from quality standards for Class I seismic
structures.
Namely, Bechtel Drawing No. C-875, Revision 6, was
approved and issued to implement modifications to radial beams
inside the containment structure even though this drawing contained
instructions which were contrary to requirements of the AWS Dl.1
Structural Welding Code, an applicable quality standard.
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Our bases for the above findings included the following:
(1) the aforementioned Bechtel drawing specifies the use of a
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welding procedure applicable to prequalified weld joints although
the weld joints called out on the drawing do not meet all of the
requirements of Section 2 of the AWS D1.1 code for prequalified
joints, and (2) the drawing permitted the use of fillers in a
manner contrary to requirements of Section 2 of the AWS 01.1 code.
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The designs of the weld joints were significantly different
from that specified for AWS prequalified weld joints.
Differences
included shape and type of weld joint and weld size, e.g. , weld
sizes specified for fillers for Beam Nos. 24, 25 and 29 were less
than that required for BTC-P4 welds by paragraph 2.10.3 of the
applicable AWS code.
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PECO's response to this apparent item of noncompliance indicated
that clarifying revisions had been made to drawings, but stated
that code requirements were met.
Further corrective actions are
required to assure that (1) the requirements of AWS D1.1 have been
met in the performance of the modifications, and (2) suitable
measures are provided and implemented to control deviations frem
quality standards during the design process.
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