ML20235K600

Notice of Violation from Insp on 870622-0702.Violation Noted:Design Documents for Nss Supplied Equipment Issued W/O Design Verification,Fillet Weld Did Not Meet Aws d.1.1 Requirements & Maint Action Cards Temps Not Recorded

ML20235K600
Person / Time
Site:	Limerick
Issue date:	09/24/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235K584	List: ML20235K581 ML20235K600 ML20235K631
References
50-353-87-11, NUDOCS 8710050161
Download: ML20235K600 (2)

Text

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e

. i APPENDIX A NOTICE OF VIOLATION l

Philadelphia Electric Company Docket No. 50-353 Limerick Generating Station (Unit 2) License No. CPPR-107 As a result of the inspection conducted on June 22 to July 2, 1987, and in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy 1987), the following violations were identified:

A. 10 CFR 50, Appendix B Criterion VI requires that documents, including changes, be reviewed for adequacy and approved for release by authorized personnel.

Additionally, t'e quality assurance program, Appendix 0, Section 7.2 to the Limerick PSAR, requires that General Electric - NEB 0 independently review to verify the adequacy of the design of equipment and systems provided by General Electric - NEB 0 through review of drawings and specifications.

Contrary to the above:

Numerous design documents for NSS supplied equipment, including instrument data sheets, parts lists, assembly drawings and connection diagrams were issued without design verification. These include the construction drawing Number 169C8370TR for the HPCI leak detection, instrument data sheet Number 234A9312TR for the reactor water cleanup system and instrument data sheet Number 234A9310TR for the reactor core isolation cooling.

This is a Severity Level IV Violation. (Supplement II)

B. Criterion X of Appendix B to 10 CFR 50 requires that a program for inspection of activities affecting quality be established and executed to verify conformance with documented instructions for accomplishing the activity. Quality control project instruction No. 8031/W2.00 for Welding and Non-Destructive Examination for Structural and Electrical Component Installations requires in section 2.3 the performance of surveillance to verify fit-up for fillet welding separation and maximum gap requirements to section 3.3 of AWS D1.1, 1972. It also requires in section 3.0 the performance of final inspection to verify weld sizes to the applicable drawing.

Section 3.3 of D1.1 requires that parts joined by a fillet weld be brought into contact as close as practicable. It also requires that the leg size of the fillet weld be increased by the amount of separation if the separation is 1/16" or greater.

OFFICIAL RECORD COPY IR LIM 2 87 0003.0.0 09/24/87 8710050161 PDR ADOCK h fooPDR 53 G

c.

Appendix A 2 Contrary to the above, on conduit and gutter multiple support No. CBL-G474 for the fillet weld connecting the top end of the diagonal brace to the vertical member the fit-up gap exceeded the 1/16" requirement of AWS D.1.1 and the weld size was smaller than the minimum required 3/16" required by the support detail drawing and specification E-1406-1. The weld had received final QC inspection and was found to be acceptable in QCIR No. E1175-W-124 when it did not meet AWS D1.1 requirements.

This is a Severity Level IV Violation. (Supplement II)

C. 10 CFR Part 50, Appendix B, Criterion V states in part that " activities affecting quality shall be prescribed by procedures and shall be accomplished in accordance with these procedures."

The procedure " Project Special Provisions to Field Inspection Procedure" G-5.1, Material, Receiving, and Storage Control, Revision 6, requires that the licensee maintenance activities be performed in accordance with construction procedure "Long Term Storage / Maintenance / Lubrication of Permanent Plant Equipment and Materials Prior to Turnover," Number CP-G-3, Revision 4.

Procedure CP-G-3 instruction requires that the special instruction of the equipment manufacturer be shown on the Maintenance Action Cards (MAC).

The MAC cards showed the requirements of General Electric Company document 22A2724 in that the Core Spray Pump Motors temperature and ambient temperature were to be recorded.

Contrary to the above: MAC card 370395 Core Spray Pump A dated June 1, 1987, MAC card 370273 Core Spray Pump B dated May 29, 1987, MAC card 356530 Core Spray Pump C dated June 15, 1987, and MAC card 356531 Core Spray Pump D dated June 16, 1987 did not have all the required temperatures recorded.

This is a Severity Level V Violation. (Supplement II)

Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time.

This written response is required for Violations A and B but not for Violation C which was corrected during the course of the inspection.

l OFFICIAL RECORD COPY IR LIM 2 87 0004.0.0 l 09/24/87

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