ML20206R400
| ML20206R400 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/25/1986 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8607070133 | |
| Download: ML20206R400 (3) | |
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2868103910 PHILADELPHIA ELECTRIC COMPANY 23O1 MARKET STREET P.O. BOX 8699 PHILADELPHI A PA.19101 (215)841-4502 vict#ntsIDENT June 25, 1986 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 Subj ect: USNRC IE Region I Letter Dated May 27, 1986 RE:
Site Inspection of March 30 - May 9,1986 Inspection Report No. 50-353/86-07 Limerick Generating Station, Unit 2 File: QUAL 1-2-2 (353/86-07)
Dear Mr. Murley:
In response to the subject letter regarding the item identified during the subject inspection of construction activities authorized by NRC License No. CPPR-107, we transmit herewith the following:
Attachment I - Response to Appendix A Should you have any questions concerning these items, we would be pleased to discuss them with you.
Sincerely, J. S. Kemper JMC/pc Attachment Copy to:
Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, DC 20555 H. Gray, assigned USNRC Resident Inspector 8607070133 860625 l
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28 8103910 ATTACHMENT I RESPONSE TO APPENDIX A - Item 2 VIOLATION 10CFR50, Appendix B Criterion V requires that activities af fecting quality be prescribed and accomplished in accordance with documented procedures.
The radiography procedure RT-XG-2 requires, in paragraph 5.1.5.2, that an indication determined acceptable, through other means (e.g. visual examina-tion) be recorded on the radiographic review form. Paragraph 8.2 requires interpretation of each radiograph and disposition of the material examined.
Contrary to the above as of April 7, 1986 the conditions existed:
One area of a radiograph, 52-56, for weld HBB-218-2, FW52 contained an indication, which was determined to be acceptable, where visual examination of the weld had not been performed.
One radiographic review form, applicable to EBB-203-1, FW5, did not indicate the disposition of the radiograph.
RESPONSE _
The areas of radiography, 52-56 for weld HBB-218-2, FW52 have been visually inspected and confirmed as an acceptable surface condition of grinding marks.
The surface indication has now been so noted on the Radiography Review Report.
Additionally, the Radiography Review Report for weld EBB-203-1, FW5 has now been properly signed off.
A further review of these conditions concluded that this concern was limited to the initial film interpretation by two interpreters. The films that were read by these interpreters have been re-read by a Bechtel Level III Radio-graphic Film Reviewer and appropriately documented. The re-reading revealed no rejectable indications that required repair, other than those which the original interpreters rejected. However, several of the welds did require additional radiography in order to obtain acceptable radiographs.
To prevent recurrence of these conditions, a training session was held for the Bechtel Level II Radiographic Film Reviewers. The training class included a review of the proper methods for film interpretations and in particular, documentation of such.
To further prevent the recurrence of this condition several process improvements have been implemented:
1.
The requirement for surface conditioning has been strengthened to require " flat top" grinding of selected weld configurations to minimize the difficulty in achieving acceptable radiographs.
2.
A new film processing machine has been installed by the radiographic subcontractor to improve the film quality.
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2868103910 3.
An additional level III has been added to the subcontractor's radiographic staff to ensure that satisfactory radiographs are provided to Bechtel.
4.
Philadelphia Electric Company Quality Assurance will review a sample of the initial film interpretations made during the first week of assignment of any future Bechtel Quality Control personnel assigned to the Limerick project.
5.
Philadelphia Electric Company Quality Assurance has increased their audit frequency of radiography interpretations from annually to semi-annually.
6.
Bechtel Quality Assurance has increased their audit program of radiography interpretations to quarterly for the next 12 months as a minimum, and longer if audit results are not satisfactory.
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