ML20151D125
| ML20151D125 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/08/1988 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Johnston W NRC |
| References | |
| NUDOCS 8807220369 | |
| Download: ML20151D125 (3) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 g{
g (2151841 4500
.:sion v cUn'a'sfo'sE"nuctsan
>-aa Mr. W. V. Johnston, Acting Director Division of Reactor Safety Nuclear Regulatory Conmission Attn: Docunent Control Desk Docket No. 50-353 Washington, DC 20555
Subject:
Limerick Generating Station, Unit 2 Inspectlon Report No. 50-353/88-10 Site Inspection frcm 4/11/88 to 5/22/88
Dear Mr. Johnston:
Your letter dated duie 15, 1988 forwarded Inspection Report No. 50-353/88-10 for Lirrerick Generating -Station. Appendix A of your letter addressed one item which does not appear to be in full ccnpliance with Nuclear Regulatory Conmission requirements. This item is restated in Attachnent A followed by our response.
If you have any questions or require addltlonal Informatlon, please do not hesitate to contact us.
Very truly yours,
- k b S lC' v
MKC/v1J/07058801 Attachnent cc: Addressee W. T. Russell, Administrator, Region I, USNRC R. Granm, USNRC Resident Inspector I
8807220369 880708 PDR ADOCK 05000353 Q
.<' ATTACFf4ENT A VIOLATION:
"10 CFR 50, Appendix B, Criterion X requires that inspections be performed to assure conformance of work activities with appropriate design drawings.. The Limerick Surmary Description of the Quality Assurance Program for Design and Construction Section D.S.3 states that equipment procured by General Electric, whether manufactured by General Electric or other vendors, will be subject to a quality control inspection program to assure that the design drawing requirements are fulfilled. -General Electric drawing 133D9020, Revision 7, depicts the General Electric Instrunent rack weld configuration.
Contrary to the above, on April 29, 1988, examination of safety related Instrunent rack 20C026 found that the instrunent rack did not conform to General Electric design drawing 133D9020. The required double sided square groove welds were welded to one side only en a rack reinforcement plate and one-quarter inch fillet welds were undersized at multiple locations."
This is a Severity Level IV Violation (Supplement II).
RESPONSE
Adnission or Denial of Alleged Violation:
Philadelphia Electric Conpany acknowledges the Violation as stated.
Reason for Violation:
The instrunent rack deficiencies were apparently a result of inadequate welding and inspection practices by the vendor during original fabrication of the racks. Quality control inspection perfonned by the vendor to assure that the design drawing requirements are met, in this case, failed to identify the Instrunent rack weld nonconformances.
Slanificance of Violation:
l There is no safety significance to this event. The as-built Instrunent rack wold configuration has been determined to be L
structurally adequate.
PECO Finding Report 2N-613 and GE Fleid Deviation Disposition Request (FDDR) HH2-8694 were prepared and issued to address this discrepancy. GE Nuclear Energy Systems Division (NESD), has concluded, based on analysis, that the dynamic qualification of the rack is acceptable and that the weld deviations are acceptable as is.
It is noted by GE in the FDDR that their analysis for the Unit 2 Instrunent rock used revision 6 of drawing 133D9020 whereas the fleid inspection of the weld deviations was performed to revision 7 of the drawing. GE has reviewed the drawing revisions and has concluded that there is no affwt on the dynamic qualification adequacy.
.q', /. Corrective Action Taken and Results Achieved:
No corrective action is necessary. The as-built instrunent rack weld configuration has been detonnined to be structurally acceptable by GE as docunented in IDDR HH2-8694, revision 0.
Corrective Action Taken to Avoid Future Non-Conp11ance:
GE NESD has no foreseeable orders for procuring additional local Instrunent panels.
Therefore there are no velding personnel to train or inspection procedures to revise. The panel fabrication work v'as sub-contracted.
No further action is planned.
Date When Fu11 Compliance Will Be Achieved:
Not Applicable MKC/v1J/07058801 l