ML19260B127

Responds to NRC 790927 Ltr Re Violations Noted in IE Insp Repts 50-352/79-07 & 50-353/79-07.Corrective Actions: Specified Repair Procedure to Meet Pipe Restraint Spec & Structural Design Requirements

ML19260B127
Person / Time
Site:	Limerick
Issue date:	10/31/1979
From:	Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19260B125	List: ML19260B127
References
NUDOCS 7912070151
Download: ML19260B127 (3)

Text

<

e e PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET PHILADELPHI A PA.19101 (215)841 4500 vics.cassion=t Mr. Boyce Grier, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

USNRC IE Region I Letter dated September 27, 1979 RE: Site Inspections of July 5, 6 and 9, 1979 Inspection Report No. 50-352/79-07 & 353/79-07 Limerick Generating Station - Units 1 and 2 File: QUAL l-2-2-1 (352/79-07)

OUAL l-2-2-2 (353/79-07)

Dear Mr. Grier:

In response to the subject letter regarding items identified during the subject inspection of construction activities authorized by NRC License Nos. CPPR-106 and -107, we transmit herewith the following:

Attachment I - Response to Appendix A Should you have any questions concerning these items, we would be pleased to discuss them with you.

Sincerely,

/

N V 1517 213 79120

. . Attachment I

.

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

" Activities affecting quality... shall be accomplished in accordence with these instructions, procedures or drawings."

The Limerick PSAR, Appendix D, Quality Assurance Program, Paragraph D.6.4, states, in part, that: "Bechtel Construction Department... is responsible for construction of the plant to approved engineering specifications, drawings, and procedures..."

Bechtel Power Corporation Project Special Provision Procedure G-6.1, Revision 2, states in Section 4.4,

" Engineering changes which effect conpleted work that requires further construction, shall have a new inspection record initiated by construction QC. The new inspection record is developed to cover the inspection of the work required to accomplish the engineering change."

Contrary to the above, as of July 6, 1979, a Field Design Change Notice No. 5 to Design Drawing C-292 effected the completed and QC accepted weld j oint on a pipe restraint, identified as PR-9. A new inspection record was not developed to cover the inspection of the work required to accomplish the engineering change. As a result, the work required by the engineering change was not accomplished on PR-9.

Response to Infraction A Bechtel Quality Control in s p e c te d PR-9 and the nonconforming conditions were documented for Engineering disposition.

Project Engineering dispositioned the nonconforming conditions by specifying a repair procedure thr : will meet specification and structural design requriements.

Subsequently, Quality Control re-inspected all restraints affected by Field Design Change Notice No. 5 to Dwg. C-292 and identified similar conditions on pipe restraint PR-45.

The same repair procedure as above was specified by Project Engineering.

Repair :Crk for both pipe restraints will.be completed by November 16, 1979.

Development of corrective action to preclude recurrence is in progress and will be fully implemented by January 1, 1980.

I 1/2

. 50-352/79-07 1517 214 50-353/79-07

- .

. . .

Item of Noncompliance P Infraction Appendix B of 10CFR50, Cciterion V, states, in part:

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

The Limerick PSAR, Appendix D, Quality Assurance Program, Paragraph D.6.4, states, in part, that: "Bechtel Construction Department... is responsible for construction of th1 plant to approved engineering specifications, drawings, and procedures.. "

Bechtel Primary Containmen* Soecification C2 (Revision 9),

Section 10.1.14, applies te amporary brackets among other things, and states that: "L.2 heat at 2000 F minimum shall be applied to all carbon steel seams whose thickness exceeds 1-1/4" regardless of ambient temperature."

Contrary to the above, as of July 6, 1979, temporary brackets were welded at several locations on the liner plate, where the plate thickness was 1-1/2 inches, and no preheat was applied.

Response to Infraction B Weld documentation (WR-NC-1 Forms) has been reconstructed from existing Quality Control records of the subject welds to the containment liner plate. The documentation and control forms (WR-NC-1) have been fastened to the temporary attachments. For these temporary attachments WR-NC-1 requires a visual examination and a dye penetrant test of the affected base metal after the removal of the temporary attachments. This dye penetrant test will assure that any indications resulting from the lack of preheat will be discovered and dispositioned.

As a matter of interest, Weld Requect (WR) Forms and Weld Filler Metal Authorization (WR-NC-2) Forms existed for the subject welds and show that the welding was performed by qualified welders.

Additionally, a letter of instruction was issued to require Quality Control Inspection / Records to be i.. sued prior to performing temporary attachment welding to the containment liner. This will insure compliance with specified requirements such as preheat prior to welding.

I 2/2 50-352/79-07 50-353/79-07 iSi7 213

' , _ 'I , . O

.

f

'

UNITED STATES

'"

nao NUCLEAR REGULATORY COMMisslON y n REGION 1

$ $ 831 PARK AVENUE

• 1" KING Ofr PRUSSIA. PENN5Yt. VAN!A 19406

%,*****/

Docket Nos. 50-352 50-353 JEP 27 Im Philadelphia Electric Company ATTN: Mr. V. S. Boyer Vice President Engineering and Research 2301 Market Street Philadelphia, PA 19101 Gentlemen: ,,

Subject:

Combined Inspection 50-352/79-07 and 50-353/79-07 This refers to the inspection concucted by Mr. J. Mattia of this office on July 5, 6, and 9,1979 at the Limerick Generating Station, Units 1 and 2, Limerick, Pennsylvania of activities authorized by NRC License Nos. CPPR-106 and 107 and to the discussions of our findings held by Mr. Mattia with Mr. J. Corcoran of your staff at the conclusion of the inspeccion.

Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this letter. Within these areas, the inspec+ ion consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

Based on the results of this inspec:. ion, it appears that certain of your activi-ties were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. These items of noncompliance have been categorized into the levels as described in our corres-pondence to you dated December 31, 1974. This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code cf Federal Regulations. Section 2.201 requires you to submit to this office, within thirty (30) days of your receipt of this notice, a written state-(1) corrective steps which have been ment taken or by explanation in replyachieved; you and the results including:(2) corrective steps which will be taken to avoid furtner items of noncompliance; and (3) the date when full compliance will be achieved.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room. If this report contains any infor-mation that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered b he k 1517 216 q;6 qqll

. .

,

,-

~,

'

Philadelphia Electric Company 2 Commission as listed in subparagraph (b) (4) of Section 2.790. The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Documer.t Room.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

_N f kYf t Robert T. Carlson, Chief x -

Reactor Construction and Engineering Support Branch

Enclosures:

1. Appendix A, Notice of Violation

2. Office of Inspection and Enforcement Combined Inspection Report Numbers 50-352/79-07 and 50-353/79-07

.

\s\1 2\i

~

.

-

,

,

.

_ (m

.

%

APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company Docket No. 50-352 This refers to the inspection conducted by a representative of the Region I (Philadelphia) office at the Limerick Generating Station, Unit 1, Limerick, Pennsylvania, of activities authorized by NRC License No. CPPR-106.

During this inspection, conducted on July 5, 6, and 9,1979, the following apparent items of noncompliance were identified:

A. Appendix B of 10 CFR 50, Criterion V, states, in part: " Activities affecting quality... shall be accomplished in accordance with these instructions, proceoures or drawings."

The Limerick PSAR, Appendix D, Quality Assurance Program, Paragraph D.6.4, states, in part, that: "Bechtel Construction Department... is responsible for construction of the plant to approved engineering specifications, drawings, and procedures..."

Bechtel Power Corporation Project Special Provision Procedure G-6.1, Revicion 2, states in Section 4.4, " Engineering changes which effect completed work that requires further construction, shall have a new inspection record initiated by construction QC. The new inspection record is developed to cover the inspection of the work required to accomplish the engineering change."

Contrary to the above, as of July 6,1979, a Field Design Change Notice No.

5 to Design Drawing C-292 effected the completed and QC accepted weld joint on a pipe restraint, identified as PR-9. A new inspection record was not developed to cover the inspection of the work required to accomplish the engineering change. As a result, the work required by the engineering change was not accomplished on PR-9.

This item is an infraction.

B. Appendix B of 10 CFR 50, Criterion V, states, in part: " Activities affecting quality... shall be accomplished in accordance with these instructions, procedures or drawings."

The Limerick PSAR, Appendix D, Quality Assurance Program, Paragraph D.6.4, states, in part, that: "Bechtel Construction Department... is responsible for construction of the plant to approved engineering specifications, drawings, and procedures..."

1517 218 q)L N

fib 14I

- *. .

,.

APPEllDIX A 2

.

Bechtel Primary Containment Specification C2 (Revision 9), Section 10.1.14, applies to temporary brackets among other things, and states that: " Preheat at 2000F minimum shall be applied to all carbon steel seams whose thickness exceeds 1-1/4" regardless of ambient temperature."

Contrary to the above, as of July 6,1979, temporary brackets were welded at several locations on the liner plate, where the plate thickness was 1-1/2 inches, and no preheat was applied.

This item is an infraction.

.

15i7 2l9

'

<

(

. U.S. NUCLE /R REGULATORY COMMISSION OFFICE OF IhSPECTION AND ENFORCEMENT

.

'

Region I 50-352/79-07 Report No. _50-353n9-07 50-352 Docket No. 50-353 CPPR-106 License No. CPPR-107

.

Priority -- Category A Licensee: Philadelphia Electric Comoany 2301 Market Street Philadelphia, Pennsylvania ~ 19101 Facility Name: Limerick Gneration Station, Units 1 and 2 Inspection at: Limerick, Pennsylvanie Inspection co ducted: July 5, 6, and 9,1979 Inspectors: e A 9[r7 7 M Mattia, Reactor Inspector date signed cate signed date signed Approved by: [//// ////h4W f D 76 R. McGau'ghyI, Chief,d/ojects Section, / cat 6 signed RC&ES Branch Inspection Summary:

Unit 1 Inspection on July 5, 6, and 9,1979 (Report No. 50-352/79-07)

Areas Inspected: Routine, unannounced inspection by regional based inspector of work activities and records associated with safety related piping. The inspector also performed a plant tour inspection. The Unit 1 inspection involved 23 inspector-hours on site by one regional based inspector.

Resul ts : Of the two areas inspected, no items of noncompliance were identified in one area, two apparent items of noncompliance were identified in one area (Infractions - (1) Failure to follow desi related pipe restraint, Paragraph 4; (2) Fai

,

gn requirement for welding of safety

• ** -

requirement for the welding of temporary att

" ^ "

un t 2 ns tion on Jul 5 6 and 9,1979 ne, unannounce inspe Entire document previously The inspector performed a plant tour, inspect entered into system under:

2 inspector-hours on site by one regional ba Results: No items of noncompliance were ide ANO ggr is v Region I Form 12 (Rev. April 77) ,-., -

a No. of pages: h