ML20091J416
| ML20091J416 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/06/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20091J405 | List: |
| References | |
| NUDOCS 8406050503 | |
| Download: ML20091J416 (4) | |
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.. o PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 1881 -1981 PHILADELPHIA. PA.19101 JOHN S. KEMPER hh VIC E-PR ESID E N T Owsomaa nsas ago ness ances Mr. Thomas E. Murley, Director United States Nuclear Regulatory Commission l
Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406
Subject:
USNRC IE Region I Letter dated November 22, 1983 Re: Site Inspection of September 12-16, 1983 Inspection Report No. 50-352/83-12 Limerick Generating Station, Unit. 1 Reference.
J.S. Kemper letter to T. E. Murley dated 12/22/83 File: QUAL 1-2-2 (352/83-12)
Dear Mr. Murley:
As stated in the referenced letter regarding the item identified during the subject inspection of construction activities authorized by NRC License No.
CPPR-106, we are now transmitting herewith the description of the action completed and a full response to the violation on Attachment I - Response to Appendix A.
Also enclosed is an affidavit relating to the response.
Should you have any question concerning this item, we would be pleased to discuss it with you.
Sincerely, fd TEl~
John S. Kemper GL:am Attachment Copy to:
Director of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, D.C.
20555 S. K. Chaudhary, USNRC Resident Inspector s
8406050503 840529 PDR ADOCK 05000352 PDR g
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COMMONWEALTH OF PENNSYLVANIA:
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COUNTY OF PHILADELPHIA JOHN S. KEMPER, being first duly sworn, deposes and says; That he is Vice President of Philadelphia Electric Company, the holder of Construction Permit CPPR-106'for Limerick Generating Station Unit 1; that he has read the foregoing Response to Inspection
. Report No. 50-352/83-12 and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge,.information and belief.
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Subscribed and sworn to before me'this day jof-_.
U -lf $k' cERk-PATRICIA D. SCHOLI -~
W PsMc. PhiladelpW. Philaddshla Co.
My Comassion Dpires february 10,1986 i
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. ATTACHMENT I-RESPONSE TO APPENDIX A
' VIOLATION-10CFR50,'. Appendix lB, ' Criterion IV, requires' that measures be ~ established to assure' that. applicable regulatory requirements, design bases, and other re-
- quirements which are.necessary to assure adequate quality, are ' suitably 'in-icluded orf referenced 'in the documents for procurement of materials and equipment.....Bechtel' Power. Corporation drawing E-1412.and their electrical training program," defines the accept / reject workmanship standards to be used.for wiring of safety-related electrical equipment at this site.
. Contrary to the.above, as of September.14, 1983, the MCC Powers Instrumentation
- Cabinets internal' wiring did not have adequate service loops; terminals were a.,
not installed back-to-back and terminals exceeded bend limits.
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[Bechtel's General Project Req'uirements (G-12) for Standard Instruments, Controls,fand Local Control Boards which was part of the MCC Powers Contract,.
did notf adequately specify. workmanship details.
. RESPONSE
' As stated inL the subject Notice of Violation,10CFR50, Appendix B, Criterion IV, requires that. measures be' established to assure that applicable
-regulatory requirements, design' bases,:and other requirements which are necessary to assure adequate quality are suitably' included or referenced in the documents for procurement cf materials and-equipment -(emphasis
'added).,In compliance with this requirement, Specification 8031-G-12, General-Project -Requirements for Standard Instruments, Controls', and Local
-Control Boards Supplied With Station Equipment, was invoked on purchase order 8031-M-66 with MCC Powers for HVAC local control stations. Section:
G12.11-of.this specification provides detailed requirements for the electrical-design, materials and workmanship.which are necessary to assure.the high quality
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of the panels built for the Limerick Generating Station.
The1 requirements of2Section G12.11 of; Specification 8031-G-12 were Ecompiled1 based.on'the engineering and construction experience of both
-Philadelphia Electric Company and Bechtel Power Corporation. These re-q'uirements cover such areas 'as wiring workmanship, wire. type, terminal block type and installation,l grounding, lighting, receptacles, ventilation
^
.and cooling, power supply. internal wiring separation, wire flame'retardance, wire ampacity and wire 4 identification.. These' existing requirements in Specification 8031-G-12 adequately address 1the aspects of control panel
-construction which directly affect quality.
'The subject Notice of Violation listed the following three conditions which are notLspecifically addressed in Specification 8031-G-12:
Inadequate service loops Terminals not installed back to back Terminals exceeded ~ bend limits I 1/2 352 83-12
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- These conditions are not specifically addressed in Specification 8031-G-12 because'they do not affect the quality of the panels. This
' " assertion is based on.the following:
-1..
Service loops are provided ' strictly for convenience to allow easy removal'of. panel mounted components. The presence or
- lack' of service loops has no effect on the quality or safety function of'the panel..
2.
. Specification 8031-G-12 allows a maximum of two terminal lugs to be terminated under a common screw.
It does not require
_ that the lugs be terminated back to back because this con-
-figuration-does not provide any added reliability, or circuit
. integrity over any other configuration of lug attachment to terminal blocks.
- 3.. j Maximum' bending limits of-control terminal lugs are not specified
- in' Specification 8031-G-12 because our experience has shown that lug. integrity and current carrying capability are not affected by the degree of the bend in the lug barrel.
~
. The subject. Notice of Violation states that Bechtel Power Corporation drawing 8031-E-1412,. Wire and Cable Notes. Symbols and Details defines the workmanship. standards to be used for wiring at Limerick. While this is 1 partially correct, ~ it should be noted that E-1412 applies only to the install-
'ation'and construction work that takes place at Limerick by the Bechtel crafts.
The requirements of:E-1412 which are appropriate for vendor-supplied internal panel wiring are contained in Specification 8031-G-12. As the-
-f abrication'and modification work on the HVAC control panels was performed
.underlthe 8031-M-66' purchase order, Specification 8031-G-12 governed this work and notLdrawing 8031-E-1412.
It. should be noted that drawing 8031-E-1412 does not contain any require-ments:concerning the three conditions discussed above. Confusion over this point may be attributable to Bechtel QC site personnel providing the USNRC Inspector with a Bechtel Training Manual. This manual, Training Manual TS-40, Electrical-Commodities and Inspection Guidelines, is used by the Bechtel Procurement Supplier Quality Department as an aid for training ' shop inspectors. The preface of this ennual clearly states that the material is not intended to increase the scope of inspection or supercede any specific requirements of.the procurement documents. This
- manual is not included in any of the procurement documents for the Limerick
' Project, consequently, its contents cennot be used as inspection acceptance.
"or rejection criteria.
To provide added assurance of the quality of the workmanship in the Class IE HVAC_ panels supplied by MCC Powers, we have completed a 100% inspection ofLthe panel' internals. Several minor discrepancies were found and corrected.
Philadelphia Electric has evaluated the NRC concern on this matter and
' believes the enclosed information resolves the item.
I 2/2 352 83-12