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)

Text

-

www*' m=.aw- - , . . .

D

~-

.(s. ,

S

? 5? ".

d'*

.J PHII.ADELPHIA ELECTRIC COMPANY

', f.'- .

2301 MARKET STREET ',.-.m -g.-

+

PHILADELPHIA. PA.19101 3, 7:

(2151841-4500 g w. .

V.C.BOYER LW9 vies enssinant , ,

W8 DEC -4 E73 EG 5.q Mr. Boyce Grier, Director United States Nuclear Regulatory Commission ?g Office of Inspection and Enforcement, Region I yp

%g 631 Park Avenue King of Prussia, PA 19406 , k[ki USNRC IE;I Letter dated June 16, 1978

~

P,

Subject:

RE: Site Inspection of.May 16-23, 1978 W ,.

Inspection Report No. 50-352/78-07; 50-353/78-04 h,R Limeri.ck Generating Station - Units 1 6 2 2' k File: QUAL 1-2-2 (352/78-07) DYM QUAL 1-2-2 (353/78-04) #sys G A.

i in:;\

~ ~l car Mr. Grier: hdN ~. .a l% .

>1

' In response to the subject letter regarding an item identified during the subject inspection of construction activities authori::ed by NRC License I)(  :. ...

Nos. CPPR-106 and -107, we transmit herewith the following: 0;C cir.w Attachment I - Response to Appendix A , 9,,.?

xcA:.  ;.

Should you have any questions concerning this item, we would be pleased 74 c::Q; to discuss them with you. f(Nyy s4q Sincerely, s.;. . .

hT5 M

,  ; 'l JMC/mmk gib2

2N

..yg

..w . , .

Attachment

???J RL 50 fh;t. ,

2, . ..

4 v

.J. >

MQ y

r90L o ol a

yyg

^~~5- -- _ _ _ .r... , , . . _

{ *%

, . x,8.v; . 3 .w__ .. _.:.e. _,.;, g R ,;ggg. y .5 m m p g y z y p 3 I$h

. '. . (i 9

j Ed. "-

" 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: 1

" 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 Department. . . is responsible for construction of the plant ,.

to approved engineering specifications, drawings and procedures . . ." -

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

wC Inspection of Welds and Components," IPPT-340-39-02,' Amendment #

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

~

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

@% ,l the seven minute developer ' dwell time had elapsed. k.f ww Responsa.

f

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

- presently and previously employed at.the Limerick Site. Jgg s,.

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

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

performed on Peabody facilities;at. Limerick Site. These F h[7

'g n

s

.[

l, ng ;

n;. s QM.L -

l MSc.

i I-1/3

\ hhh m

50-352/78-07 !V j 3 --

_,3 ;  ? o

. ~ x m ., 3 7. .-- %_n_-qs,oj y i. - - ...

• W

- - - . _ m . . . . ., _

a .

,,<., - m , .

, .g,  ; ,.

.y l. c

,h ,.2 ; L 3.j${} reports. revealed that liquid penetrant examinations wit- d.h u nessed during these audits were performed in accordance with applicable procedures. Based upon these investi- . 'f'...

gations, the. Peabody Testing Quality Control Manager provided assurance that this liquid penetration examina- i, ;

S 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. -

. W h

2. Corrective Action Taken and Results Achieved

a. The NDE technician'in question was re-qualified for N 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.

phw

.m m

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

Peabody Technician and was found acceptable.

results of this report are documented on Peabody The Q$ s Testing Report PBT-PT-2325. ggn$ 'fi p$$

Q.

c. Approximately 50% of the liquid penetrant &g Ay

~

examinations in which the subj ect NDE technician ELV

. performed or was an assistant were re-examined using the liquid penetrant method. All welds were .*; u ;

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 the one veld indicated that it was a mechanically

. caused lap, "

from the veld area. It was incon~

clusive whether the rejectable area was present at (M d.

4.93j the time of the orig 1ual liquid penetrant examina- 4.fgj rion, since cleaning operations by craftsmen pre- gg caeded the re-examination. additional evaluation gg.. . .

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 without the use of solvents, would not remove a MM 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 ratio of acceptable .to rej ectable welds, those Sk-welds not re-examined are considered acceptable. sj-e +

h@

g

.s.

es;z

'W\ ,

@:y r.

I I-2/.3 ,'

yNjl@.:

50-352/78-07 r.43W t

. 50-352/78-04 FEM R;s.L c

__- - - _ . --,.,..-.-m-,,,

..y.,,.,..-,, L e-r

~

r s a

.__..1- . E..:. - - - s,. . , . g, , ; 7,7, gg ,

.W:.

y cu r

.p, ,.s

,Q, -

SW.W,Y

@&#L

3. Corrective Action Taken to Prevent Recurrence L.yMX -m

t. .

7A w2.e.; s, a) The responsible. Bechtel Quality Control Engineers have been instructed to increase surveillance

['7; ,-

activities with regard to liquid penetrant g examination on all Peabody Testing Personnel. This g:ll s 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.

~

Bechtel Quality Control has added an inspection A b) 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 '

!m _

by each individual technician for each method that .f.

a technician is qualified to perform. This will establish initial confidence in new Peabody Testing ,

g -. . ;..

Personnel arriving on site. bf 6 e is ww gps a

c, ::c

${$(

'>xk Qsy p g- .

gyp C Js, k

& a-

-Me..i '.

. g .s x- .

4%

rh.:'(&

ap c.%p .:f Wkhi

%.~.y ,.

O S ,

%o .

p..

, .g3 l I-3/3 fy.

50-352/78-07. , Qd 50-352/78-04 s rg.m g.;4??

. gy. . -

W ?:

3e: wry ~~---, vrw* ~ - --- yq -~v--

~73.,-- -- n.-,. .

7v. ~ ?, ;. . --

..