ML20083K177

Responds to NRC Re Violations Noted in Insp Repts 50-352/78-07 & 50-353/78-04.Corrective actions:re- Qualification of technician,re-examination of Weld & re- Examination of Liquid Pentration Test

ML20083K177
Person / Time
Site:	Limerick
Issue date:	12/04/1978
From:	Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20083K167	List: ML20083K177
References
NUDOCS 7901110017
Download: ML20083K177 (4)

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.J PHII.ADELPHIA ELECTRIC COMPANY

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LW9 V.C.BOYER vies enssinant W8 DEC -4 E73 EG Mr. Boyce Grier, Director 5.q United States Nuclear Regulatory Commission

?g Office of Inspection and Enforcement, Region I yp 631 Park Avenue

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Subject:

USNRC IE;I Letter dated June 16, 1978 RE:

Site Inspection of.May 16-23, 1978 W

Inspection Report No. 50-352/78-07; 50-353/78-04 h,R 2' k Limeri.ck Generating Station - Units 1 6 2 File:

QUAL 1-2-2 (352/78-07)

DYM QUAL 1-2-2 (353/78-04)

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' In response to the subject letter regarding an item identified during I)(

the subject inspection of construction activities authori::ed by NRC License Nos. CPPR-106 and -107, we transmit herewith the following:

0;C cir.w Attachment I - Response to Appendix A

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Should you have any questions concerning this item, we would be pleased 7

to discuss them with you.

f(Nyy s4q Sincerely, s.;..

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j ATTACHMENT I a

RESPONSE TO APPENDIX A Ed d

u Response to Item of Noncompliance Infraction 10CFR50, Appendix B, Criterion V, states in part, that:

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" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings."

The Limerick PSAR, Appendix D, Quality Assurance Program, paragraph 6.4, states, in part, that:

"Bechtel Construction is responsible for construction of the plant Department.

to approved engineering specifications, drawings and procedures

y The Peabody Testing Inc., a contractor to Bechtel, utilizes nondestructive examination procedure titled " Liquid Penetrant y/-

Inspection of Welds and Components," IPPT-340-39-02,' Amendment wC No. 2,.which states, 1n part, in paragraph 6.6.3,,that:

final interpretation shall be made a minimum.of seven minutes and no later than thirty minutes after the developer gM' is applied."

g g,E 32 Cor!.tra ry to t.h a above, en September 28, 1978,'during the l.3 liquid penetrant! test of wcld j oinr EBC-182-1/O-FW50, the

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licensee's contracrcr technician maf.e-interpretations before.

the seven minute developer ' dwell time had elapsed.

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Responsa.

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Background, Peabody performed an investigation of Peabody's Annual NDE Personnel Performance Audits of Peabody personnel

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presently and previously employed at.the Limerick Site.

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This investigation revealed that liquid penetrant WW examinations audited were performed in accordance with QW applicable procedures.

Additionally, the investigation included all previous Pasbody six (6) month audit reports h.%

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performed on Peabody facilities;at. Limerick Site.

These

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reports. revealed that liquid penetrant examinations wit-u nessed during these audits were performed in accordance with applicable procedures.

Based upon these investi-

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gations, the. Peabody Testing Quality Control Manager S

provided assurance that this liquid penetration examina-i, ;

tion was an isolated incident'and that other liquid

.i penetrant examinations performed by Peabody personnel i

at the Limerick Site have been performed to applicable g$.

requirements.

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Corrective Action Taken and Results Achieved N

a.

The NDE technician'in question was re-qualified for liquid penetrant examination by Peabody Testing.

g The practical portion of the examination was witnessed by the ASME Code Inspector and by representatives of.the Bechtel Q.C. Department.

The re-qualification certification vere approved by Bechtel on Octo.ber 13, 1978.

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Weld HBC-182-1-FW50 was re-examined by a qualified st$

Peabody Technician and was found acceptable.

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results of this report are documented on Peabody s

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'fi Testing Report PBT-PT-2325.

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Approximately 50% of the liquid penetrant Ay examinations in which the subj ect NDE technician ELV

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performed or was an assistant were re-examined using the liquid penetrant method.

All welds were

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found acceptable e.xcept one (1) which was rej seted upon re-a:camination by another qualified Peebody

$8 technician.

Evaluation of the rejectable area of MEA (M

the one veld indicated that it was a mechanically d.

caused lap, from the veld area.

It was incon~

4.93j clusive whether the rejectable area was present at the time of the orig 1ual liquid penetrant examina-4.fgj rion, since cleaning operations by craftsmen pre-gg caeded the re-examination.

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also indicates that in this instance the incorrect s

technique would not have had an effect on the 6$$

outcome of the-examination, since a simple wipe, nW MM without the use of solvents, would not remove a

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sufficient quantity..of dye to affect the appearance of an indication on the developer.

Based on.the number of welds re-examined and the resulting high W

Sk-ratio of acceptable.to rej ectable welds, those h@

welds not re-examined are considered acceptable.

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Corrective Action Taken to Prevent Recurrence w2.e.;

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The responsible. Bechtel Quality Control Engineers

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have been instructed to increase surveillance activities with regard to liquid penetrant gg:ll examination on all Peabody Testing Personnel.

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increased surveillance will continue until the Lead

@JS Quality Control Welding Engineer is confident that Peabody Testing Personnel who are performing 9,3;p,[

Liquid Penetrant Examinations are adhering to the 5-W approved NDE procedure.

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Bechtel Quality Control has added an inspection A

activity to the Quality Control Instruction for NDE Subcontractor Surveillance.

This activity requires Bechtel to witness, for compliance with 3

the approved NDE Procedure, the first examination

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by each individual technician for each method that g

a technician is qualified to perform.

This will establish initial confidence in new Peabody Testing Personnel arriving on site.

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