IR 05000353/1987011

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-353/87-11

ML20236U851
Person / Time
Site:	Limerick
Issue date:	11/25/1987
From:	Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8712030413
Download: ML20236U851 (2)

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o Nov 251997 Docket N Philadelphia Electric Company ATTN: Mr. John S. Kemper Senior Vice President Engineering and Production 2301 Market Street Philadelphia, PA 19101 Gentlemen:

Subject: Inspection No. 50-353/87-11 This refers to the letter from S. J. Kowalski dated October 28, 1987, in response to our letter dated September 28, 198 Thank you for informing us of the corrective and preventive actions concerning violations identified during inspection 50-353/87-11 documented by the October 28, 1987 lette These actions will be examined during a future inspection of your licensed progra Your cooperation with us is appreciate

Sincerely, 0ci .,inc ; n;.:.;; 77:

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1111am V. Johnston, Acting Director

'. [DivisionofReactorSafety cc:

S. J. Kowalski, Vice President, Engineering and Research W. T. Ullrich, Superintendent, Limerick 2 Project J. M. Corcoran, Quality Assurance Manager Troy B. Conner, Jr. , Esquire Eugene J. Bradley, Esquire, Assistant General Counsel Public Document Room (PDR)

1.ocal Public Document Room (LPDR)

lluclear Safety Information Center (NSIC)

1RC Resident Inspector Commonwealth of Pennsylvania f' --

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8712030413 871125 PDR ADOCK 05000353 } l G PDR OFFICIAL RECORD COPY RL LIM 2 87-11 - 0001. /23/87

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l . Philadelphia Electric Company 2 bcc:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section Chief, DRP Robert J. Bores, DRSS

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. PHILADELPHIA A ELECTRIC COM PANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA A, PA.19101 ta t si e414 so 2 OCT 281987 S. J. KOWA LSKl ~~

VIC E PR E51 DENT anemsansmo Amo assaancM United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 SUBJECT: USNRC Region I Letter Dated September 28, 1987 l

l l RE: Site Inspection of June 22, 1987 to July 2,1987 l Inspection Report No. 50-353/87-11 Limerick Generating Station, Unit 2 FILE: QUAL l-2-2 (353/87-11)

Gentlemen:

In response to the subject letter regarding the items identified during the subject inspection of construction activities authorized by NRC License N CPPR-107, we transmit herewith the following:

Attachment I - Response to Appendix A - Item A Attachment II - Response to Appendix A - Item B In response to the apparent violation of NRC reporting requirements under 10CFR 50.55e, in the October 22, 1987 enforcement conference Philadelphia Electric Company addressed the issue and described the corrective action for consideration by the Na Should you have any questions concerning these items, we would be pleased to discuss them with yo

Sincerely,

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JMC/pc:mes Attachments Copy to: United States Nuclear Regulatory Coimnission Region I 631 Park Avenue King of Prussia, PA 19406 R. Gramm, USNRC Resident Inspector 4 7 LL30VrA -

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Attachment I Response to Appendix A - Item A 10 CFR 50, Appendix B Criterion VI requires that documents, including changes, be reviewed for adequacy and approved for release by authorized ~~

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

Response:

In order tc correct the identified problems, the following actions have been complete . The drawings that were issued without having design verification performed were identified and a listing provided to PECO by General Electric - NEB . General Electric - NEB 0 has completed the design verification for these drawings . Changes were documented on the appropriate design change document If field changes were required, General Electric Field Deviation Disposition Requests (FDDRs) were issued. The FDDRs are processed in such a manner that their closure is verified af ter work completio 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 vill be added to the transmittal lette J DAD I 1/1 353/87-11

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Attachment II Response to Appendix A - Item 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 the performance of surveillance to verify fit-up for fillet welding separation and maximum gap requirements to Section 3.3 of AWS Dl.1,197 It also requires in Section 3.0 the performance of final inspection to verify weld sizes to the applicable drawin 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 fillet weld be increased by the amount of separation if the separation is 1/16" or greate 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 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 Dl.1 r equir ement This is a Severity Level IV Violatio (Supplement II)

Response:

Bechtel Engineering analyzed the as-built hanger and determined the condition to be acceptable as is. An inspection was performed of one hundred and eighty-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 undersized. Engineering analysis determined that these also were acceptable to use-as-is,

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Direction was then focused on skewed angle fillet welds. A list of Unit 1 and l Common W-2.00 electrical support weld inspection records was used to select approximately four hundred 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 angle fillet welds on electrical suppor t 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 wel When this study has been completed, an inspection will be made to verify the minimum weld size exist DAD II 1/2 353/87-11

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l We expect the engineering study will be finished by January 15, 1988 and the

! field inspection completed by January 31, 198 The Unit 2 electrical support details are different in that an additional weld

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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 ide..tified 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 measurement of skewed angle weld DAD II 2/2 353/87-11 i

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