ML20236G960
| ML20236G960 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/28/1987 |
| From: | Kowalski S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8711030362 | |
| Download: ML20236G960 (4) | |
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United h/jates Nuclear Regulat y, Commission l'}
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SUBJECT:
USNRC Region I Letter. Dated eptember 28, 1987, RE: pite Inspection of June 22,1987 to. July 2,.1987 ;
t IMpection Report No. 50-34/87-11
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'I'imerick Generating Station, Ur.it 2-p<
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(Ihionse'tothesybjectletterregardingtheitetMidentifiedduringthe.
su6 ec inspection of construction activities.authori
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NAtQchment I - Response. to Appendix A - Item A Atuachment II - Response to Appendix A - 7t7m B ge/
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, 9,qn response to the apparent violation,of NRC reporting requirements under g9CFR 50.55e, in the October 22, 1987 4 enforcement conference Philadelphia j
$ k.itric Company addressed the issue rad described the corrective' action for i
cMsL% ration by thNRC.
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Shoi ld' y,s ii ;$v have any questions concerning these items, we would be pleased to discugs Ahem with you.
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Attachment I Response to Appendix A - Item A 1
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10 CFR 50, Appendix B Criterion VI requires that documents, including changes, be reviewed for adequacy and approved for release by authorized.
personnel.
Additionally, the quality assurance program, Appendix D, 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 l
instrument data sheets, parts lists, assembly drawings and connection -
l 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 j
system and instrument data sheet Number 234A9310TR for the reactor 4
core isolation cooling.
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This is a Severity Level IV Violation.
(Supplement II) i l
Response
In order to correct the identified problems, the following actions have been completed.
1.
The drawings that were issued without having. design verification performed were identified and a listing.provided to PECO by General Electric - NEBO.
2.
General Electric - NEB 0 has completed the design verification for these l
drawings.
3.
Changes were documented on the appropriate design change documents.
If field changes were required, General Electric Field Deviation l
Disposition Requests (FDDRs) were issued. The.FDDRs are processed in such a manner that their closure is verified af ter work completion.
To prevent this problem from recurring, General Electric has developed a project procedure to process documents that have not been design verified. The procedure requires that an identification be added to the drawing identifying it has not been design verified.
In addition, a similar note will be added to the transmittal letter.
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Attachment II j
1 Response to Appendix A - Item B l
l 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 l
project instruction No. 8031-W2.00 for Welding and Non-Destructive Examination.
j 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 Dl.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 Dl.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 l
fillet weld be increased by the amount of separation if the separation is 1/16" l
or greater.
Contrary to the above, on conduit and gutter multip e support No. CBL-G474 for the fillet weld connecting the top end of the diagonal brace to the vertical.
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member the fit-up gap exceeded the 1/16" requirement of AWS Dl.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. Ell 75-W-124 when it did not meet AWS l
Dl.1 requirements.
J This is a Severity Level IV Violation.
(supplement II)
Responses j
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l Bechtel Engineering analyzed the as-built hanger and determined the condition 'to
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be acceptable as is.
An inspection was performed of one hundred and eighty-I l
eight (188) welds on electrical supports in the cable spreading room with the result that three (3) additional skewed angle fillet welds were found to be j
undersized. Engineering analysis determined that these also were acceptable to use-as-is.
Direction was then focused on skewed angle fillet welds. ' A list of ' Unit 1 and Common W-2.00 electrical support weld inspection records was used to select -
l approximately four hundt ed and eighty_ (480) records to be reviewed for inclusion of skewed angle fillet welds. Approximately one hundred and twenty (120) skewed angle fillet welds were identified in this manner.and a walkdown undertaken to inspect them. Three (3) more welds were found undersized, however, engineering disposition was to use-as-is.
This walkdown inspection has been suspended pending the results of an ongoing engineering generic study to address skewed
'I angle fillet welds on electrical supports. Each electrical. support detail-having skewed angle welds has been identified. A sample of calculations that used these details is being analyzed to determine the minimum required. weld.
when this study has been completed, an inspection will be made to verify the minimum weld size exists.
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j We expect the engineering study will be finished by January'15,1988 and the-field inspection completed by January 31, 1988.
The Unit 2 electrical support details are different in that an additional weld
- is required to be placed on each side of diagonal connections. A separate engineering study determined that this additional weld was sufficient to carry the design loading without the skewed angle weld. Two unique hangers were i
identified that did not have this additional weld, however, inspection'of them revealed one undersized weld which has been dispositioned use-as-is by'engi-neering. Training has since been given to electrical QCE's to stress proper I
measurement of skewed angle welds.
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