ML20099G873

Applicant Exhibit A-98,consisting of Forwarding Response to Violation Noted in Insp Repts 50-352/78-07 & 50-353/78-04

ML20099G873
Person / Time
Site:	Limerick
Issue date:	05/07/1984
From:	Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
OL-A-098, OL-A-98, NUDOCS 8411270475
Download: ML20099G873 (5)

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Mr. Eoyce Crior, Director DEC -11978 United States Nucles: Regulatory Cor.sission Office of Inspection and Enforce =ent, Region I -

631 Pari Avenaw King of frussia, PA 19406 -

Subject:

USKRC IE,I Letter dated June 16, 1971 Rh: Si:e Inspection of l'ay 16-23, 1979 luspection Report tio. 50-352/13-07; 50-3.*3/73-04 Li arich Genorsting 5tstiurr - Units 14 2 p ile: QUAL 1-2-2 (352/78-07)

QUA1.1-2-2 -(353/73-04)

Dear r .r. Grier:

'Ov in response tu thu subject let:er regardin3 an 1:tc identifi:d darine thu 34 ject ins ction of constmetion activities autnori::.! by hkC License 14cs. tiPh-106 and -107, we transmi: herewith the following:

Attachment I - Response to Appenaix A Should you aave any questions concerning this ite=, we would be pleased to discuss :nen with you.

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A::nchment bec: R. H. Eliss, Bechtel J. 5. Ker;er

5. J. Srsdier

G. White E. C. l'istner H. R. Ws1

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• ATTACHMI::7 I

[ RIS?O::SI TO A??I:0IZ A i

Resoonse to I:en of Noncom:liance Infraction 10CPR50, Appendix 3, criterion V, sea:es in part, : hat:

'"A::ivi:1es affec:ing quali:7 shall be prescribed by documen:ed ins::ue: ions, precedures, or drawings . . . and shall be accomplished in accordance

• wi:h these instrue:icas, procedures, or drawings."

The Limerick PSAR, Appendix D, Quality Assurance Prograr, paragraph 6.4, s:a:es, in part, that: "Bechtel Construction Department. . . is responsible for construe:Lon of the plant to approved engineering speciffcations, drawings and procedures . . ."

The Peabody Testing Inc., a con:: actor to Bechtel, utili:es nondestructive examination procedure :itled " Liquid Penetrant Inspection of Walds and Components," IPPT-340-39-02 Amendment-f No. 2, which states, in part, in paragraph 6.6.3, that:

. . . final interpretation shall be made'a minimum of seven minutes and no la:e: chan thirty minutes after the developer

( is applied."

Contrary to the above, on Septa =ber 2S, 1978, during the

• liquid pene:ran: test of weld; join: H5C-182-1/0-YW50, :he licensee's contractor technician made interpretations before. ,

the seven minute developer dwell time had elapsed. *

Response

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1. Backtreund *

' Peabody performed an investigation of Peabody's Annual MDE Personnel Performance Audi:s of Peabody personnel presently and previously employed a: :he Limerick site.

This investiga: ion revealed : hat liquid pene: an:

examinations audited were performed in accordance with applicable procedures. Additionally, the investiga: ion included all previous Peabody six-(6) nonth audit reports performed on Peabody facilities at Limerick Site. These i

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'b  :, *, repor:s revealed tha: liquid penetran: examinations'wi:-

nessed durtn; :hese audits were performed in acecrdance-with applicable peccedures'. Based upon these investi-

_ ga:icas, :he-Peabody Testing Quality Control Manager -

provided assurance tha: this liquid pene:ra: ton' ens = ins-tien was an isolated incident and-: hat other liquid penetran: exa=ina:1ons performed by Peabody personnel at the Limerick Site have been performed to applicable require =en:s. , ,

2. Corrective Action Taken and Results Achieved

a. The NDE technician in question was re-qualified for b liquid pene:: ant exa=ina:1on by Peabody Testing. ,

The practical por: ion of the exanination was '

witnessed by the ASME Code Inspector and by representatives of the 3echtel-Q.C. Department.

The re-qualification certifica:1on were' approved by 3echtel on October 13, 1978.

b. Weld H3C-182-1-?U50 Gas re-examined by a qualified Peabody Technician and was found acceptable.

results of this report are documented on Peabody The )('

"esting Report PET-?;-2325.

) c.: Approxima:ely 50% of the'11guid penetrant-examinations in which the subj ect NDE technician performed or was an assistant we're re-exa=ined

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. using the liquid penetrant method. All welds were.

found acceptable except one (1) which was rejected upon re-examination by another qualified Peabody technician. Evaluation of the rejectable area of

• the one weld indicated that it was a mechanically caused lap, h" from the veld area. It was incon-clusive whether the rej ectable area was present at the time of the original liquid penetrant examina -

- tion, since cleaning operations by craftsmen pre-ceeded the re-examination. Additional evaluation also indicates that it this instance, the'inco :ect technique would not have had an effect on the outcome of the examination, since a simple wipe, without the use of solvents, would not remove a .

sufficient quantity of dye to affec: the~ appearance of an indica: ion on the developer. Based on the number of' welds re-examined and the resulting high ratio of acceptable to rejectable welde, those welds not re-examined are considered acceptable.

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e 3. Cerrective Action Tsken to ?reven: - ?. e c u r r e n c e a) The responsible 3echtel Cuality Con:rol Engineers have been instructed to increase surveillance ac:ivities with regard to liquid pene::an:

eka=ina: ion on all ?eabody Testing Personnel. This increased surveillar,.ce.will con:inue until :he Lead

-Quali:7 Control *a'elding Engineer is confiden:

cha: Peabody Testing Personnel who are performing '

Liquid Penetrant Examinations are adhering :o the app roved NDI p rocedure.

b) 3echtel Quality Con: o1 has.added,an inspec: ion activi:y to the-Quality Control Ins::uction for

- NDE Subcon:ractor Surveillance. This activity 1 requires Sechtel to witness, for compliance with the approved NDE Procedure, :he ft s: exanination by each individual :schnician for each method tha:

a technician is qualified to perform. This will' escablish initial confidence in new Peabody Testing Personnel a :iving on site.

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