ML20099H621

Applicant Exhibit A-122,consisting of Forwarding Attachment I to Response to App a of Insp Repts 50-352/81-01 & 50-353/81-01.Personnel Reinstructed & Training Class Held 810317

ML20099H621
Person / Time
Site:	Limerick
Issue date:	05/07/1984
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
OL-A-122, NUDOCS 8411280221
Download: ML20099H621 (6)

Text

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. Appt. Ex . 112.

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MAR 23 G81 y

.w. ser . G:le=, hreeto United States Ihacles: Esp.lato:y Cc=nission ,

Office of hspection and Inforcement, 2sgion I '

631 Pa=n Avenue Ii=g of P=ussia, PA. 19146 M: UEH2C I2 Region Letter dated.Teb:um=y 27,1931

• IIs Site Inspection of Janz.a / 5 -o,1981  ;

Inspection Report so. 50 352/31-o1 & 50-353/31-01 Limerick Generating Station - U=1ts 1 s=d 2

• g zggi cu n 1-2-2 (352/31-o1 & 353/at-o1l

. Iear Mr. Grier:

In =esycase to the sub*ect letter regarding itens idsntifisi du=in.3 the subject Espection of conct:r.tetion actirities act.::1:sd

~ by H2O License 3os. wuu-106 and -107, ve t:--e 't herewith the ,

fallsv1=gs

, it*-- " t I - Eesper.=e to i;;endiz A .

Also enclosed as =wquired 1ry the Not'=e of Tielati=n. is an affidavit = elating to the =esponse. **

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2:culd you have any questia=s con =a-*-- these items, we e d se ,le-ed = disc . e e.n wi e - .

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Co;7 tot 21=ector of hapection and Inf==: ament United States Ihaclear segulato:/ Commission

. WashLagten, D.C. 20555 )

, J. P. h==, umC Essident hapec .o= -

bce: 1. E. I11as, 2echtel ' 2. 2. Valters/Ic a1 ?ile

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I. R. II:ssin, 2echtel J. J. Clarey

3. J. 2:ailey G. White 3,A,gulfe;g(:])

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I CCMMO:t*JIALTH 07 ?IN:*STL*'ANIA  :

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CCC::!T 07 ?HILADCL?RIA  :

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JOEN.S. KIM?I?., being first duly sworn, deposes and'says:

That he is Vice President of Philadelphia Electric Cospany, the holder of Construction Permits C??R-106 and C??R-107 for L1=erick_ Generating. Stat. ion Units 1 and 2.; that he has read the foregoing Response to Inspection Report No. 50-352/81-01 and 50-353/31-01 and knows the contents thereof; and that.the statements and matters set forth therein are true w l.- and correct to the best of his knowledge, information and belief.

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ATTACMMINT :

v~S~ KIS?CNSI TO A??!M3II A N_A' Is 71-la:i - - A

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'10CT7.5 0, IAp p endix 3, Cri:erion X7I, sta:es, "...condi:1ons adverse to quali:y, such'as...nonconformances, are prosp:17 iden:1fied...

tha: the cause of :he condi:1ons-is determined sad cc:: active ac: ton taken to preclude repeti: ton...and :he corree:ive action

aken-shall be docu=ented and reported to. appropriate levels of -

sanagenent.".

The Linarick ?SAR, Appendix 0, paragraph D.4.12, states, in par:, *

ha:: ". ..The progra:'shall provide inpu: for the initta: ion of -

. .co::ective ac:1on and_ follow-up as appropriate.".

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Project Special Provisions Ho: ice, ST/ PSP C-3.1, Revistor. 3, paragraph 3.1.5, states, "If a deficiency to the code requirements are idencified within-the code beundary of an ASMI ices, it shall be controlled by the use of nonconformance reports.".

Contrary to the foregoing, on January 15,.1981, the NRC inspecto:

discovered through observation and document reviev : hat rejectable nondestructive testir.3 indications were identified and dispositioned on In-process Rework. Notices instead of Nonconfor=ance Reports as required. Specifically, an ASME Nuclear Class I pipe veld, DLA-107-1/7*4 11, was liquid penetran: ces ed.and rejectable linear

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(, indications.were identified, "outside the areas of interest,"

(the adjacan: base mate, rial). The indica:1cas were dispositioned on In-process Rework Notice No. W655.

This is a Severity Level 7 Violation (Supplement II).

Resoonse et violation

. Nondes::uctive testing indica:1cas. documented on In-process Rework

-Notice No. W655 was subsequently (ocumen:ed on a Nonconic mance Report. In addition. a review of open Rework Notices was performed. Several addi:Lonal instances where In-?;ocess Rework Notices were employed in lieu of Monconformance Reports were ,

identified. These were then incorporated into Nonconformance Reports.

To preven: recurrence the following ac:1ons were :aken

-1. Supervision and production personnel were ins :ucted to perform no work on ASME boundary ce=ponents withou: prope; au:horization. The instructions were reiterated by the superintendent in a subsequen: se=orandum to the responsible personnel. '

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, ,2 . - The Q.C._depar:sen: held a ::aining-class'en January 23, 1981 'l

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for the responsibia personnel on the requirements for :he use of . Nonconf ormance F.apo r:s . t

(, full cos;11ance was achtsved on or before Mar:h'17, 1981.

I , In addi:Lon ':he valva-described in_In-process Rework Notice No. U W432 (noted in the "DITAILS" section of ' :he 3RC's Inspection Report. )

. was also subsequently documented on.a Nonconformance Report.

The1 valve-in In-process Rework Natice W632 and the pipe spool in

'In-process Rework Notice W433 were both fabricated in accordance with the code and received _and passed the required nondestructive .,

examinations. The code does not require penetran: examinations

.during the fabrication / manufacture of these components. Any removal of liquid penetran: indica:1cas, cu: side the area of' .

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interest.of the. liquid penetran: test performed during installation- '

, is in excess of code requirements and, therefe.re, the valves were acceptable for installation as received from the manufacturer.  ;

violation - B ,

10CTR30,, Appendix 3.' Criterion V, s:stes, in part, that, " Activities' '

, affecting quality shall be... accomplish.ed in accordance with these i L, instructions, procedures, or drawings.". '

i The Limerick PSAR, Appendix D, paragraph 6.1, states, in part, .

i that, "Bechtel Construction Department. . .is responsible f or  !

construction of the plant to approved engineering specifications...". !

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lechtel Sptcification for forsins, placing, finishing and Curing

- (. of Concrete, 8031-C-34, paragraph 14.0, states, in part, that,

" Imperfections in formed concrete shall be repaired as'soon as practicable but no later than 28 days after forms removal.", ,-

l Contrary to the above, on January 13, 1981, a concrete imperfettien was observed on approminate elevation 279', in Reactor lu11 ding i No. 1, in the West slab construction 15-p-1-4, measuring approzinately2"deepby1"highby1 join: in length.- The quality '

Control. Inspection Record No. C-110-RS-p-1-4, executed on October o

10, 1977, did not record this conkition. .

L This is a Sevarity Level V Violation (Supplement II).

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Rassonse to violation NCR 43!1~was issued t,o identify that the concrete wall i= perfection. l g, had not been repaired within 28 days after form renoval. The NCR-was dispositioned "use as is" because the structural integrity -!

of the wall will not be adversely affected by failure to make I

'. repairs within 28 days.

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1 Inspection Record 4C-140-F.5-7-1-a3 for inspection of the subject ~ area and issued In-process

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f' Reverk Notice C-2229 which identifies that repair is required at

. (l* the loca:1:n described by the Viola:1er.. The repair location has been chipped to sound concrete and dispositioned "niner" per the requirements of Section 14.0 of Specification C-36. The repair

.6 will ie cespleted before March 31, 1981.

.QC reinspected approximately 108 ether concrete placements originally'inspested by the personnel who inspected the placement

• in question. The reinspection documented en QC-C-1-C-34-SI-1-1, 1 identified 3 siner defects which have been repaired.

Actions taken to pretent recurrente were 1) t class held.en 2/17/81' I '

t.fter the violation was identifindi and 2) reissue of PCM-487, l dated 6/16/80 (project Construction Manager name) to all reopensible ,

personnel to re-esphasise the. requirement that eescrete' repairs ,

are to be made within 28 days of fers resevaal.

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Violation - C 10CFR50, Appendix 3, Criterien IX, states, is part, that. [

" ... Welding... (is) sentre11ed...in asserdasse with applicable ,

sedes, attadards, spesifications...". , c The Limerisk pSAK, Appendix D, paragraph D.4.4, states, in part, that, "Beshtel Construation Department...is responsible for asastruction of the plant to approved engineering spesi!1sations...".  ;

{ i Welding procedure $pesification p1-A-LX (Sheet), Revision 0, '

requires that welding be performed in asserdamse with the General Velding Standard, G*a*S-Structural. The GV8, in paragraph 3.1 and ' e Table.GSW - Structural - 1, requires that f or 'E7018 electrodes ,

and saterial thisksess in essess of 1%" through 24", the welding preheat be saissained at 130 F.

- Contrary to the above, en January *21, 1981, the welding en the ,

safety-related electrisat supporth, Wald Mo. 1-431-4, sensisting  !

of a 3/8" plate welded to a structural )ess flange greater thaa ,

1%" thick, did not have preheat applied to a temperature of 130 7. . ,

j This is a severity Level Y violation (Supplement II). ,

1assesse to Violation ,

We have determined that veld K-431-4 performed without preheating l to 130' is asseptable based on tests performed for certain Veldias l l precedure Qualificaties Reports. The applicable pqR's are 404, 488, 649, 490, 491, 703, 704, and 707. These tests were performed I i

=using 16010 ,and E7018 weld electrodes and they desenstrate that '

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'satisf actory welds -can be dor.e on 1 *g using signift:an:17 Less preheat :han :he 130'T required by :he o 2 in:h base sa:erial

- General 'a'elding $pecification. The prehea: tempera:ure for :he

.I above tests were either 30*p or 60'T,t indicating tha: no preheat.

was performed and that the ambient temperature was recorded during the test. The 30'~:o 6007 ambient-is approximately what exis:s

i throughou: the heated plant, therefore, veld 1-431-4 was perfor=ed

1. ' under essentially the same condi: ions as the above pq1's. -

Turthermore, sedesa:horthanA*[3basapreheat requirements or, weldysise, using the throat-thickness of a' fillet veld as asasure-mentEinstead of thiakness of the Sase metal.- Tor-example in regard ,

to preheat, ANSI 3'31.1 states "The thicknes's of socket.-fille:

and seal welds is defined as thros: thickness for pressure'non-

. pressure velds". (See ANSI- 3 31.1 - 73 / tf 7 4, table 131, ha te 4.)

Stailarly,-where the/ASME code offers-guidelines for preheat ~ of p1~ steel, the sede states that the guidelines de met apply to

"...Tillet Welds 1/2 inch and under in size that are used to attack insulation slips and other parts not carrying leadings due-se internal pressure." ($ee.ASME III - Div. 1, 1974, Subsection WA, Append'iz'd, paragYaph'b-1210.2). The position that the fillet weld throat thiskness should be used to determine preheat requirements instead of base metal thiekness is supported by the PQR's seted above.

Cur position is that staisus preheat requirements should be 3 determined as outlined above, however, the actual. work practice in the future will aset the preheat requirements in the General' Weldtag Spesifications which are mere conservative.

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To prevent a resurresse the following actions were taken

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• a) A training session was held on January 21, 1931-for a11

. elastrital welders, foresen,' general foresen,'and electrical superintendents to dissues preheat requirements in AWS;eedes.

, b) _On the same date, a training session was held for lashtel weldias Quality control Engia'eers on.the same subjest.

a) The Job Rule for Welding, Job Rule.C-16, was revised on

. Marsh 20, 1941 to clarify and emphasise structural preheat '

requirements.

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Full Ceap 11anse was achieved en or before 3/20/41. . - - - . .

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