ML20214U099
| ML20214U099 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/04/1987 |
| From: | Kowalski S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8706110048 | |
| Download: ML20214U099 (3) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 S. J. KOW ALSKI f
VICE PRESIDENT anomaseme ano esemascu United States Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Subject:
USNRC Region 1 Letter Dated May 5, 1987 Re:
Site Inspection of February 3 to March 29, 1987 Inspection Report No. 50-353/87-02 Limerick Generating Station, Unit 2 File:
QUAL l-2-2 (353/87-02)
Gentlemen:
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 this item, we would be pleased to discuss them with you.
Sincereldy,
/
fl/m dS.J.Kowalsi JMC/mep Attachment Copy to:
United States Nuclear Regulatory Commission Office of Inspection & Enforcement, Region 1 631 Park Avenue King of Prussia, PA 19406 R. Gramm, USNRC Resident Inspector 6110048 870604 G
ADOCK 05000353 PDR g
n n
t Attachment I Response to Appendix A - Item A Violation 10 CFR 50, Appendix B Criterion V and the Limerick Preliminary Safety Analysis Report Appendix D.6.4 require that activities af fecting quality shall be accomplished in accordance with appropriate specifications or procedures.
Cintrary to the above, on March 27, 1987, the following examples of cc astruction activities not performed in accordance with the applicable requirements which were:
A.
Bechtel ASME Quality Assurance Manual Welding Standard WFMC-1 requires that portable rod ovens be energized at the work location. However, Weld ovens W-91 and W-774 were de-energized on February 20 and oven 246 was de-energized on February 23.
B.
Construction Procedure CP-C-8 requires that engineering review 4 r necessary prior to rigging from plant components other tha" strur' re.
steel. However, a section of Pipe Whip Restraint 938-PR-202 was q3ed from a Main Steam Isolation Valve without prior approval.
C.
Bechtel Specification P-301-2 requires quality control and field engineering documentation for ASME Class I closure welds. However, Field Weld 201 on isometric SP-DCA-213-E-3 was not properly examined prior to completing the closure weld.
D.
Construction Procedure CP-E-3 requites that a Raceway Support Rework Notice be issued prior to removing a support that has been completed.
However, conduit support 2A-14-277-Cl-1000 was removed without authorization after Field Engineering acceptance.
RESPONSE
A.
The use of weld rod from unheated portable rod ovens, as noted in inspection report 353/87-02, has been documented on Nonconformance Report 11738. Bechtel reviewed the items that were being welded and concluded that the filler material could have actually been issued in non-heated l
containers. To ensure the portable ovens are energized, the involved welders and their supervisors were reinstructed on the requirements for filler metal handling and controls. A site wide training bulletin was issued to reinstruct welding personnel that rod ovens must be energized and checked at frequent intervals.
B.
Discussions with the personnel involved indicated that the Main Steam Isolation Valve (MSIV) eyes were not used for lifing but only lateral restraint. Engineering reviewed the situation and determined that even if the full weight of the 3 foot piece of structural steel was rigged from the MSIV eye bolts there would be no adverse effects on the l
MSIV. To ensure future rigging is properly accomplished, construction
(
tool box training sessions were held to reiterate the provisions of the rigging control procedure.
I 1/2 JMC/mep 353/87-02 6/1/87 T
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C'.
As a result of the lack of proper closure weld controls on Field Weld 201 on class I, 2" small piping isometric SP-DCA-213-E-3, an Inprocess Rework Notice P-7147 was issued to cut out the root pass. The weld was removed and the piping closure mismatch was 4
measured and reported to engineering for review.
The engineering disposition of the closure condition determined that the piping closure shou?d be made at another location along the piping system to facilitate a proper closure. This work has now been satisfactorily.
completed. The closure had originally been identified on the appropriate work package cover sheet, however, the weld was subsequently relocated but the closure was inadvertently omitted from the work package at the new closure location. A full review of other class I small pipe greater than 1" was performed. Several other instances of improper closures were identified. These were documented on Nonconformance Report 11737 and were dispositioned by Bechtel Engineering based on additional field verification and closure data. To prevent recurrences of this condition, the appropriate personnel have been re-instructed in piping closure requirements.
D.
Regarding the removal of the electrical raceway support (i.e. the strap only) it was determined that this was removed by craft personnel without Construction Engineering knowledge or authorization.
The removal occurred prior to Quality Control inspection of the hanger. A Raceway Rework Notice E-0008 has been issued, as procedurally required to re-install the hanger. To prevent recurrence, a training notice was issued to remind craft personnel of the procedural requirements regarding removal of electrical raceway hangers.
In addition to the corrective action stated above, we have reviewed the conditions to determine if any common causes or generic conditions could be identified. We have determined that human error or lack of recall of the procedural requirements were the basic causes for the four above noted conditions. However, both the personnel and procedures were so diverse that there appear to be no generic implications. We determined, based on our reviews,that further action was necessary in two of the cases; items A & B.
In each of these cases, additional procedural changes have been made to effectively implement the requirements.
The rigging control procedure was reworded regarding the use of supports.
In the area of piping closures,the installation specification was revised adding separate instructions for small pipe socket weld closures and quality control inspections were added for small piping closures.
I 2/2 6/1/87 353/87-02