IR 05000352/1976008
| ML19275A883 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/07/1976 |
| From: | Heishman R, Sanders W, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19275A881 | List: |
| References | |
| 50-352-76-08, 50-352-76-8, NUDOCS 7910220144 | |
| Download: ML19275A883 (16) | |
Text
.
-
- ,.. _ ;,
.
.J.m 7 5) (r.cv /
.
U. S.1:UCLEAR RECULiTORY CC".:!ISSIO:s OFFICE OF I::S?ECTIO:: \\::D E:?FORCC!E:.T
-
REGIO:1 I
.
IE Inspection Report 1:o:
50-352/76-08
. Docket I o: 50-352 Licensce:
Philadelphia Electrid' Coc:pany License No: CPPR-106 2301 Market Street Pdorig*
-
Philadelphia, Pennsylvania 19101 A
,,
'
Safeguards
__
Limerick Uni I, Limerick, Pennsylvania Group *
Lcca tio n:
,
i Ty of Licensee.
.
Routine, Unannounced Type a:.,n::pec tio n:
a Dates of Inspection:
Au gus t 16 -19, 22, 25, 1976
,
Dates of Previ:us Inspection:
June 21-25, 1976
'
//
.
/c
.].3 7/
-
F.cperting Inspector: -
-
A.
D. Toth, Reactor inspector DATE Acco:panying Inspectors:
W[
< ~M
, /
.[//. ? /97c W. F. Sancers, Reactor Inspector
D5TE L.d %7[
9,h /76 G. Mapuda, Reactor Inspector i DtE f
.A
. se l'
rinKie,'IteaftorInspector A.
' DATE s
Other Accc=panjin;; Persennel:
A. '.'arela, R. Heishman, R. Haynes DA~E N
!
Re.Ac.ced By:
- 4
- " 'I /- / )
't>)7(
i
,.
-
R. F. Heishman, Chief, Ceastruction Projects Section DAIE
.
Reactor Construction and Engineering Support Branch
.
79.10220/
--
.
.
.
StRS.ARY OF FINDINGS
.
Enforcement Action
.
None.
Licensee Action on Previously Identified Enforcement Items
'
Reference: IE Inspection Report No. 50-352/76-07, Detail item 3 The weld, which was previously made without prior QC inspection, has been cut out and repaired.
(Details, Paragraph 5.a)
Design Changes None identified.
Unusual Occurrences The following unusual occurrences were observed and/or reported by (Details, Paragraph 3, subparagraphs as listed below.)
the licensee:
The reactor vessel transporter chain drive broke down during A.
full-load downhill tests.
Unconsolidated / honeycomb / void concrete was found in the contain-B.
ment drywell walls upon stripping of forms.
Other Significant Findings A.
Current Findings 1.
Acceotable Items The following items were inspected with respect to these No de-aspects described in the Details of this report.
partures f rom regulatory requirements or SAR commitments were identified, subject to any specific exceptions which may be noted elsewhere under Enforcement Action or Current Findings of this report.
(Details, Paragraph 6, subpara-graphs as listed below.)
.
.
.
.
-2-The quality assurance program for electrical components
-
a.
and systems consists of the Bechtel general site program.
b.
Quality assurance instructions and procedures for elec-trical co=ponents and systems handling and installation have been established or specific requirements for them defined to ass,ure availability before start of work.
Reactor vessel installation subcontractor quality assur-c.
ance programs have been established.
d.
Reactor vessel installation procedures have been estab-lished for loading and movement of the reactor vessel and associated equipment testing, Reactor vessel installation equipment tests, for transport e.
of the vessel,onsite downhill, have been conducted.
The test identified equipment problem areas which require correction, and the test will be rerun.
f.
Reactor vessel stabilizer thermal expansion effects have been considered and evaluation and corrective action have been requested of the designer / supplier (GE).
g.
General site construction activities.
2.
Unresolved Items The following items have been identified as unresolved.
Documentation of training programs for quality assurance a.
personnel of reactor vessel installation subcontractors is not yet onsite.
(Details, Paragraph 4.a)
b.
Inspection checklists of the reactor vessel installation contractor (RCI) do not yet encompass all planned quality affecting activities.
(Details, Paragraph 4.b)
Audit scope and frequency are not fully defined in the c.
quality assurance manuals of reactor vessel installation subcontractors.
(Details, Paragraph 4.c)
.
+
_
-
.
-3-d.
Major concrete voids and honeycomb occurred in concrete which was placed subject to applicable codes, standards,
_
and quality control inspection.
(Details, Paragraph 3.b)
B.
Status of Previously Identified Unresolved Items The' following item has been resolved as noted.
(Details, Paragraph 5.b)
Reference:
IE Inspection Report No. 50-352/76-05, Detail item 4.a The licensee and subcontractor have reevaluated test prerequisites and determined that bolt tenrion limits are not required.
C.
Deviations
,
None. identified.
Managenent Int e rview At the conclusion of the inspection a meeting was held at the site with representatives of the licensec and contractor organi:atiens.
Attendees this meeting consisted of personnel whose names are highlighted (i.e.
at
- ) in paragraph 1 of the Details Section of this report. The inspector summari:ed the purpose and the scope of the inspection (Details, Para-graph 2), and the results of the inspection (as listed in the " Summary of Findings").
Additional information was provided by the licensee management repre-sentatives and/or commitments were =ade which related to the informa-tion gathered and conclusions reached as described in the Details of this report. Specifically, the licensee representative identified dates for resolution of questions regarding audit and inspection checklists and personnel training aspects of the QA program of RPV installation contractors (VSL and Reactor Controls).
,
e
_
.
DETAILS
_
l.
Persons Contacted Philadelphia Electric Cocoany
- J. M. Corcoran, Site Quality Assurance Engineer
,
- J. T. Robb, Quality Assurance Engineer
- J. J. Clarey, Resident Engineer
- R.
3. Atkinson, Quality Assurance Engineer Bechtel Corporation
- J. H. Calley, Project Construction Manager
- E. R. Klossia, Lead Site Quality Assurance Engineer
,
- A.
G. 'Jeedman, Project Field Engineer
- C. Cameron, Lead Subcontract Engineer
- M. H. Brown, Assistant Project Field Quality Control Engineer
- R.
Sevo. Quality Assurance Engineer
- R. J. Baldwin, Quality Assurance Engineer G. Zickefoose. Quality Control Engineer
.,, __,___
k'.
L. "arclay, Proj ect Field Quality Control Enzineer
- C.
R. Berezich, Subcontreet Engineer T. Redican, Senior Material Supervisor E. Strelecki, Material Storage Engineer J. Barbour, Storage Maintenance A. M. Appleford, Assistant Project Engineer (Home Office)
E. C. Soppet. Project Manager (Hece Office)
General Electric Company F. Forsythe, Project Manager J. Mays, Quality Assurance Representative 75L Corcoration J. Allen, Project Manager Reactor Controls Incoroorated S. J. Kepler, Site Manager
.
_
.
.
.
-5-2.
General A preinspection meeting was beld onsite on August 16, 1976 with
,
the senior licensee representative, to discuss the scope of the inspection, and werk progress or occurrences which may bear upon the inspection. The status of previ.ously identified unresolved items, corrective actions or other outstanding items was discussed.
The inspector stated that the scope of'the inspection would in-clude review of the general quality assurance program provisions for contractors to be involved in the move and installation of the reactor vessel, review of detailed procedures for testing rigging and transporter equipment, observation of the transporter handling and dcwnhill braking test under simulated load, and review of quality control provisions for electrical component handling and installation.
The inspection also included review of the concrete void and honeycomb proble=s experienced with one major placement of tne containment drywell walls.
During the course of the inspection, certain Region I inspection personnel visited the site in addition to the principal inspec-tion team for this inspection, to perform limited inspection activities with respect to the concrete void problem, test of the reactor vessel transporter, and to discuss the recent change in 10 CFR 50.55(e) and related guidance.
3.
Unusual Occurrences The following ite=s were observed by the inspector and/or re-ported by the licensee as unusual occurrences.
Followup and disposition of item no. 3.b. is considered to be an unresolved item.
a.
Unusual Cecurrences - Reactor Vessel Transporter Failure During Test During an August 22, 1976 onsite test run of the transporter to be used to =ove the reactor pressure vessel f rom the site fabrication area to the reactor building, the trans-porter rear tread drive chains broke. The transporter was carrying a 700 ton test load of concrete blocks down a 6 percent grade at the time.
The transporter coasted to a
.
.
--
..-
_
.
,6-the bottom of the grade af ter traveling several stop at hundred feet out of control. There were no collisions nor
-
injuries involved. Licensee plans include inspection of the transporter and modification of the rig and/or procedures as appropriate based on their evaluation of the problem.
A second test run is planned before the RPV is moved ; the licensee agreed to notify the inspector prior to the second test, b.
Unusual Occurrence -- Unconsolidated Concrete in Containment Drvwell Wall The concrete placement on June 23-24, 1976 in the conical section of the contain=ent drywell structure between eleva-tions 255' - 10" and 290' - 3 3/4", resulted in six areas of
=ajor defects. These defects consisted of honeycomb / voids /
unconsolidated concrete and occurred about mid-height of the placement and on the outside surface.
A preliminary investigation by the Project Field Quality Control Engineer (PFQCE) noted that the major defacts were located at the location of the CRD penetrations and over the equipment and per-sonnel access penetrations. These findings were documented in memorandums from the Project Field Quality Control Engineer (PFQCE) to the designated Project Field Engineer and were dated July 27 and August S 1976.
An inspection by IE was made of the above areas on August 17, 1976.
The defective concrete just over the the equipment access penc-tration (315' azimuth at 265' elevation) was observed to have been chipped-out over an irregular area of about 16' wide x 6' high and the =aximum probed depth was about two feet. The inspector observed that horizontal and vertical rebar were nicked and dented across deformations as well as at the nominal cross section. Diametrically opposite this (above the per-sonnel hatch), another area of irregular honeycomb /unconsoli-dated concrete was being chipped out using a three-quarter inch taper-wedge pneumatic chipping tool.
The inspector observed that some of the exposed rebar had been nicked and dented. The inspector also observed that removal of r.he one CRD penetration (230' azimuth) had defective concrete at not begun. Using a wire probe, the inspector determined that voids up to about 24 inches in depth existed in the concrete around the pipes of this penetration.
At a meeting on August 17, 1976 with licensee and contractor personnel, the inspector was informed of the following:
.
-7-(1) The investigation of the defects (and the causes),
is still in progress.
.
(2) The engineer-constructor, Bechtel, has verbally in-formed the licensee that major concrete repairs are required but that the nonconforming condition of the containment drywell concrete wall at this stage of their evaluation is not considered to be a significant deficiency reportable under 10 CFR 50.55(e).
(3) Six SCR's are in preparation which identify the six areas where major repairs may be required, i.e.,
one each over the personnel and equipment access penetra-tions and the four CRD penetrations.
(4) Project Engineers (3echtel, San Francisco) will be at
'
the site starting August 13, 1976 with concrete and structural design personnel to provide expertise for determining the scope of the investigatory work and the corrective actions to be taken.
During this meeting, the inspector discussed the folicwing items, which were acknowledged by those present:
(1) The initial approach taken by the site to not use the NCR procedure for identifying and controlling the non-conforming concrete repair work appears to bypass the quality control aspects during the repair effort in-volving concrete removal. As a result, control of the concrete removal appeared to have been relegated solely to field engineering such that no procedures (ins t ruc-tions) were ef fected t; prevent danage to rebar by chipping tools and no inspection criteria for damaged rebar had been promulgated.
(2) The heavy cencentration of rebar at the six defect locations and the use of icw slump concrete appeared to have becn f actors in the cause of the problem. A review of concrete records disclosed that 3" slump concrete with a 2" inadvertency margin was specified
_
.
-8-and that at these approximate elevations, vertical rebar with cadwelded plate anchors were required by construction drawings.
The concrete > laced between
_
about 11 p.m.,
June 23, 1976 and abou; 6 a.m.,
June 24, 1976 had slumps from 1" to 3" and was placed about 20' to 25' down in the slo, ping (conical section - dry-well) forms.
(3) The inspector inquired as to what assurance the ricensee had that no voids / honeycomb / unconsolidated concrete exists at the liner plate and the rebar anchor plates which is not visible.
The inspector was informed that the investigation would include steps to deter =ine the soundness of the concrete in these areas.
This item is considered to be unresolved pending the review of the results of the licensee's investigation of this
'
problem.
4.
Unresolved Items The folicwing items were icentified by the inspector as unresolved
,
items, subject to future inspection and verification of supplecental information:
a.
Reactor Vessel Installation Subcontractor - OA Personnel Training Criterion II of Appendix 3 of 10 CFR 50 requires that the quality assurance program "shall provide for indoctrination and training of personnel performing activities af fecting quality as necessary to assure that suitable proficiency is achieved and maintained." Criterion II also requires docu-mentation of the quality assurance program through written policies, procedures or instructions.
The quality assurance manuals of VSL Corporation, and Reactor Controls Incorporated (RCl) do not provide description of the training program for quality assurance and quality control personnel.
The licensee representative stated that approved training criteria, and training records, exist for RCI and VSL, and will be available onsite in 3 weeks.
Also, an RCI quality assurance manual revisicu, to include definition of auditor training requirements, will be avail-able within 3 months.
The licensee representative stated that ne:cssary trainf ng will have been accomplished prior to performance of related work by QC persennel.
-
-
.
_g.
b.
Reactor Vessel Installation Subcentractor - Insoection Scone Criterion X of Appendix B of 10 CFR 50 requires that "Examina-
-
tions, =easurements, or tests of material or products pro-cessed shall be performed for each work operation where necessary to assure quality."
The inspection checklist contained in the RCI quality assur-ance canual does not enecmpass all quality af fecting uork
~
activities planned to be conducted by RCI. Such RCI work activities had not yet cor=enced.
The licensee representative stated that the checklists shown in the QA =anual are only examples which are typical of de-tailed inspection checklists to be developed for specific work activities. He stated that work / inspection procedures
'
are currently available and appropriate inspection checklists will be available within 3 weeks prior to star.: of the re-lated RCI work activities. An RCI quality assurance manual revision, to include clarification of inspection che:klist generation /use, will be available onsite within 3 =enths.
c.
Reactor Vessel Installatien Subcentractor - Audit Scoce Criterion XVIII of Appendix 3 of 10 CFR 50 requires "A co=-
prehensive system of planned and periodic audits shall be carried out to verify ecepliance with all aspects of the quality assurance progra=...," and "The audits shall be performed in accordance with the written procedures or checklists...."
The audit checklists contained in the VSL quality assurance manual do not cover all the elements of the VSL scope of quality affecting activities. The RCI quality assurance =anual does not define the frequency of audits.
The licensee representative stated that the VSL quality assur-ance manual will be revised within 3 weeks to provide for a comprehensive audit scope, and.the RCI =anual revision to include audit frequency will be available within 3 months.
_
.-
-
.
-10-5.
Resolv d Items The following items were reviewed by the inspector and the correc-
-
tive abtions ef fected by the licensee are considered adequate to resolva the previously identified questions regarding these ite=s:
I a.
Inscection of Welding - Infraction
'
T7e inspector verified the licensee's action to correct the epforcement action identified in item number 3 of the Details s)ction of IE Inspection Report No. 50-352/76-07, as described in the licensee's August 10, 1976 response to the notice of violation. This item is resolved.
i The inspector examined records which shew that weld no. G3C-102-1/7 was removed and a weld repair made and inspected in a:cordance with quality assurance program provisions. The rpdiograph review form for the reweld shcus the veld accep-tsble.
The following specific documents were examined:
In-process Rework Notice. U-24 (#34), dated June 25, 1976.
--
Weld Card for repair R2, dated June 25, 1976.
--
Radiograph Review Form CSC-102-1/7, FW-7R2, dated July
--
14, 1976.
b.
Containment Ecuipment Hater Test Procedure The licensee and subcontractor have reevaluated test pre-requisites and determined that bolt tension limits are not a critical parameter requiring verification prior to the pressure test.
This resolves item number 4.a of the Details section of IE Inspection Report No. 50-352/76-06.
The inspector examined PECo Finding Report N-076, which in-cludes a formal respense by the subcontractor, Chicago Bridge and Iron Company (CB&I). The C3&I resolution defines that only hand tightening of bolts is required, and that this will not damage the bolts.
Casket design is such that gasket damage cannot occur. The 4.nspector stated that he had no further questions on this item.
.
-
-
-11-6.
Acceotable Items The following ite=s were examined by the inspector to ascertain
_
implementation of the quality assurance program with respect to these items. The inspectors did not identify any departures from regulatory requirements or PSAR commitments, except as may be specifically described in other paragraphs of this report and referenced in subparagraphs below.
,
a.
Quality Assurance Program for Electrical Cocoonents and Systems The inspector examined the quality assurance program pro-visions for electrical components and systems, and determined that this work is scheduled to be performed by Bechtel and will be inspected by Bechtel quality control inspectors and audited by Bechtel onsite audit staff. The provisions of
,
the Bechtel Nuclear Quality Ansurance Manual, Limerick site (NQAM) will be applicable to these activities. The SQAM has previously been approved by the licensee for Bechtel activities, and was examined by IE inspectors in connection with other site activities (e.g., lE Inspection Report No.
50-353/75-05).
b.
Quality Assurance Instruction and Procedures for Electrical Cccoonents and Svstems The inspector interviewed personnel and reviewed Bechtel's quality assurance procedures and field instruction manuals for the receipt / handling / storage / installation / material and component identification and verified applicability to electrical compenents and systems as follows:
(1) Quality Control Instruction 8031/R-100, Revision 4, dated February 19, 1976 titled " Receiving Inspection,"
delineates the inspection requirements for site re-ceiving and storage of materials and components.
(2) Job Work Rule titled, " Rigging of Permanent Plant Equip-ment," S031-JR-G-10, Revision 0, dated June 29, 1972, delineates the requirements for installation, protection and special instructions for clectrical components and systems.
.
-12-(3)
Job Work Rule titled " Storage Maintenance of Installed Equipment," 8031-JR-C-7, Revision 12, dated August 2, 1976, delineates the requirements for the maintenance
,
of installed equipment and equipment in storage, both on and off site, after being received by Bechtel.
(4)
Field Inspection Procedure G-3 titled, " Processing of Nonconforming Items," Revision 6, dated June 4, 1974, delineates the requirements for validating a noncon-forming item, defines segregated storage areas and details the methods for separating nonconfor=ing items from conforming items.
(5)
Inspection and construction testing instructicns have not been prepared at this time.
The job rules (noted above) contain requirements for preparation of inspec-
,
tion plans. The licensee representative s:ated that these plans would be available before performance of installation work as required by the job rules.
(6)
Relav Coordination Studv The licensee stated that the relay coordination study, which is approxi=ately 907. cceplete, is located at the San Francisco Power Division Of fice of Bechtel.
The results of this study, which define such areas as transformer loading, fault protection, setpoint informa-tion, etc. will be supplied to the site through engin-eering drawings and specification requirements.
c.
Reactor Vessel Installation - Subcontractor Quality Assur-ance Plans The inspector interviewed personnel and examined the quality assurance =anuals of the subcontractors responsible for in-stallation of the reactor vessel. This included examination of the "VSL Corporation Heavy Rigging Quality Assurance Pro-gram for Power Industry Projects" which manual is applicable to (1) the loading of the vessel into the transporter at the vessel field erection point, (2) transport of the vessel to the vicinity of the reactor building, and (3) lif ting the vessel over the building and containment wall, and lowering it into place on the reactor vessel pedestal. The exanina-tien also included the " Reactor Controls Incorporated (RCI)
_
_.
_
__
,
-13-Quality Assurance Manual," which manual is applicable to the alignment and final setting of the vessel onto the vessel pedestal within the containment drywell. The
-
inspector's examination included assigned scope of work and delegation of responsibilities in the following areas:
(1) Organizational structure and quality control / audit personnel; (2) Document control and review; (3) Quality requirements, definitions, documentation, and incorporation in procedure documents; (4)
Control of =aterials; (5) Control of processes and qualification of personnel and
>
procedures; (6) Test control and control of test equipment; (7)
Corrective action and nonconfornance controls; (8) Quality record identification, review and disposition; (9) Inspection procedures and docu=entation; and (10) Audits.
The exa=ined QC =anuals were consistent with the...ensee's overall QA program and related PSAR commitments, with the exception of ite=s listed as " Unresolved" in paragraph 4 of this report, in the following areas:
(1) VSL and RCI programs for training of QA personnel; (2) RCI quality control checklists for inspection activities; and (3) VSL audits scope and RCl audit frequency.
_
e
--
-.
..
..
.
-14-d.
Reactor Vessel Installation Procedures The inspector examined twenty (20) VSL Corporation procedures
_
and verified that the activities of reactor vessel lifting, moving and installation are governed by quality control pro-visions to assure conformance with applicable requirements.
Specifically, the procedures require the follcwing:
(1) Crane and rigging testing prior to lif ting the vessel,.
and detailed instructions for the lift.
(2) Leading and transporting equipment testing, to verify capability of transporting the RPV in a vertical posi-tien over a 61 grade.
(3) Preparation and inspection of the road bed.
(4) Braking and holding tests of the transporting and lifting equipment.
(5) Records of inspection and test results, Reactor Vessel Installation jcuipment Tests - Transoorter e.
The inspector observed the following activities to ascertain compliance with approved procedures:
(1) Assembly of the transporter consisting of two box beans, car bcdy, final drive sprockets, chains, motor assembly and caterpillar tracks.
(2) Prepartion of haul road by leveling, with granular material to within 1" side to side and a 6% max grade.
(3) Loading of 700 tons of test blocks onto the transporter, and transport of the test lead from the assembly area (adjacent to the RPV) approximately 100 yards to the starting point of the 6% grade. At this point the chain on the left front drive broke. Af ter the chain repair the events felleving
~
are described in " Unusual Occurrences" in this report (Paragrapa 3.a).
Within the scope of this inspection no df.screpancies were observed.
.
e
_
.
-15-f.
Reactor Vessel Stabilf ers The inspector interviewed the licensee senior quality assurance
'
representative onsite with regard to provisions for thermal expansion effcces, for reactor vessel stabilizer assemblies.
The inspector also examined a related July 26, 1976 letter from PECo to GE.
The letter requests GE to review the design parameters, including anticipated operating tenperature that
'
may be encountered, and any changes or modifications that are deemed necessary to be made to the stabilizer assemblies pro-posed for Limerick. The licensee stated that this action was intended to recogni:e the stabilizer deformation experience the PECo Peach 3otton 2/3 Facility this year, and to pre-at clude such occurrence at Limerick.
g.
General Site Construction Activities
,
The inspector examined the in place storage of High Pressure Coolant Injection (HPCI) Pump (S/N 10 P204) and Turbine (S/N 10 S211) and Reactor Core Isolation Cooling (RCIC) Pu=p (S/N 10 P203) and Turbine (S/N 10S212). This equipment was separ-accly enclosed in heated shelters that controlled unauthorized access.
The inspector observed that the humidity indicater strips signalled that the dessicant should be replaced in the HPCI turbine control bcx.
The constructor's representative initiated immediate corrective action by way of "In Process Work Notice LTM 141" and Work Order #73."
The inspector reviewed the " Main Pump Maintera.nce Log" and
" Maintenance Action Cards" for the above equipment. These records show that the humidity indicators were checked by the constructor in June 1976, in accordance with a three month inspection frequency. The fact that the dessicant had become saturated within two =enths af ter the last check did not appear consistent with the inspection frequency.
The constructor's representative agreed and initiated i=me-diate corrective action via preparation of a " Supplement Sheet" to the maintenance / inspection requirements for the HPCI and RCIC Pumps and Turbines. The supplement sheet increases the humidity check to a weekly status until an eff ective f requency interval is deter =ined.
The inspector stated that he has no further questions at this time.
_
m