IR 05000352/1978004

IE Inspec Repts 50-352/78-04 & 50-353/78-02 on 780516-23 During Which 1 Item of Noncompliance Was Noted: Failure to Follow Code Requirement for Qualification of Weld Joint & Use of Filler Plates

ML20150E343
Person / Time
Site:	Limerick
Issue date:	06/15/1978
From:	Mattia J, Mcgaughy R, Sanders W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20150E311	List: IR 05000352/1978004 ML20150E308 ML20150E324 ML20150E327 ML20150E336 ML20150E339
References
50-352-78-04, 50-352-78-4, 50-353-78-02, 50-353-78-2, NUDOCS 7812130112
Download: ML20150E343 (12)

Text

'

. . .

U.S. NUCLEAR REGULATORY COMMISSION

$ OFFICE OF INSPECTION AND ENFORCEMENT 50-352/78-04 Report No. 50-353D8-02 50-352 Docket No. 50-353 CPPR-106 i License N CPPR-107 Priority -

Category A Licer.s ee: Philadelchia Electric Comoany 2301 Market Street Philadelphia, Pennsylvania 19101

.

Facility Name: Limerick Generating Station, Units 1 & 2 Inspection at: Limerick, Pennsylvania Inspection conducted: May 16-23, 1978 Inspectors: .C. k 6!M!?7 7 C. Mattia, Reactor Inspector cate signed c c m L .! ~

RT Paolino, Reactor Idspecter sbrhe cate signec M.' V YnAW &//.W W. Sanders, o ctor Inspect 9r / cate signed Approved by: b '6 b s [ R. W. McGaughy, Chief, frofects Section 6![6

'date/signec

Reactor Construction & Engineering Support Branch Insoection Summary:

Unit #1 Inspection on May 16-23, 1978 (Report No. 50-352/78-04)

Areas Inspected: Routine, unannounced inspection of work activities and records for structural steel erection in primary containment and storage of instrumentatio The inspectors also performed a plant tour and reviewed the licensee's action on

previous inspection findings. The Unit #1 inspection involved 63 inspector-hours on site by three NRC inspector Results: Of the four areas inspected, no items of noncompliance were identified in three areas; one apparent item of noncompliance was identified in one area (infrac-tion - failure to follow code requirement for qualification of weld joint and use of filler plates - Paragraph 8).

7812130H1 Region I Form 12 ,

(Rev. April 77)

-_ _ _ _ . . _ _ . - . _ , . _ _ _ _ . _ . _ , _ _ . - . . _ _ . . . _ . _ . _ . _ _ _ _ _ . . _ _ . _ _ _ _ - _

. .

s 1

l

.

Inspection Summary 2 l l i l l

'

Unit #2 Insoection on May 16-23, 1978 (Recort No. 50-353/78-02) I Areas Insoected: Routine, unannounced inspection of work activities and records j for storage of instrumentation. The inspectors also performed a plant tour and

, reviewed the licensee's action on previous inspection findings. The Unit #2 '

, inspection involved 22 inspector-hours on site by two NRC inspector )

Resul ts: No items of noncompliance were identifie : ,

i

!

!

.

i

!

i e

i I

!

I

,

!

--

. .

l DETAILS 1. Persons Contacted Philadelphia Electric Company I *J. Clarey, Resident Construction Engineer

*D. Clohecy, QA Engineer

• J. Corcoran, Field QA Branch Head

• D. DiPaolo, QA Engineer

• D. Marascio, QA Engineer

• G. Lauderback, QA Engineer E. Sproat, Electrical Engineer (telephone)

Bechtel Power Corocration

! *T. Altum, Lead Welding Field Engineer

• K. Bishop, Lead QC Welding Engineer i *J. Blevins, QA Engineer

• H. Brown, Project Field QC Engineer i "E. Klossin, Project QA Engineer

-

J. Lucas, QC Engineer

'

• J. R4 Reiney, Project Construction Manager J. Reynolds, Materials Supervisor L. Savagee QA Engineer

'

M. H. Shanbhag, QA Engineer E. Strelecki, Maintenance Storage Engineer l C. Turley, QC Engineer

*G. Vorce, Structural Materials Supervisor

,

• A. Weedman, Project Field Engineer 2. Plant Tour - Units 1 & 2 The inspectors observed work activities in-progress, completed

,

'

work, and the plant status during general inspection of the plan The inspector examined work items for any obvious defects or noncompliance with regulatory requirements or license conditions. Where more detailed inspection of an area was conducted, the inspection scope

-

and findings are described in other paragraphs of the repor No items of noncompliance were identified.

.

.

E

__ ,, , ,- ,, ,

, _ --- - - - , - - - -

- _ _ _ _ - _ _ _

p i

4 1 i j i

l Licensee Action on Previous Insoection Findinas (Closed) Unresolved Item (352/78-01-01): Be<,htel specification 8031-C-57 conflicted with the ACI 318-71 code in allowing the grouting operations for the fuel pool girder (post-tensioning) to take place at an ambient temperature 5 F lower than the code requirement. The C-57 code was revised (addition No. 4 to revision 1 was issued on March 10,1978) to conform with the cod (Closed) Unresolved Item (352/78-03-04): A PECO Engineering Procedure addressing the requirements of 10 CFR Part 21, was not available during a previous inspection. The inspector examined the PECO Engineering Research Department Procedures (ERDP) 4.5, Rev. O and 4.4, Revision The specifying of Part 21 Provisions in Procurement Documents was a requirement in the procedur The inspector fcund that the PECO procedures pertaining to Part 21 did not specify posting requirements. Upon further review by the inspector, it was determined that this is not a requirement and is I

unnecessar NRC inspectors verified previously that the licensee

was posting in accorcance with the Part 21 requirements (reference:

Inspection Report No. 50-352/78-03).

.

l l (0 pen) Significant Deficiency - 50.55(e)(352/76-12-01): The inspector l examined the following documents associated with the deficiencies

! found in the American Bridge fabricated structural steel (Units 1 &

2):

! --

PECO Audit and Surveillance Reports related to the Structural Steel Deficiency Audit Report Nos:

AR-C-101, AR-C-107, AR-C-90 and AR-C-122.

,

Surveillance Report Nos:

SCR-C-98, SCR-C-86, SCR-C-85, SCR-C-72 and SCR-C-13 Bechtel Audit and Monitoring Activity Reports related to the structural stee Audit Report Nos:

1 PFA-138, PFA-167 and PFA-183.

! " Work Plan and Log" for period December 1,1976 - Decemoer

! 15, 1976.

l

,

" Work Plan and Log" for period May 1,1978 - May 15,

197 _ _ - _ _ _ - _ _ - _

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

I i --

Bechtel Quality Control Inspection Report Nos. C-201-C-63-aA l and associated quality records related to the repair cf defects

! in Girder G-24.

l

--

Bechtel Quality Control Inspection Report No. C-203-C-63-5A and associated quality records related to the repair of defects of Girder G-56.

l l

--

Bechtel Quality Control Inspection Report No. C-204-C-63-2D and associated quality records related to the repair of defects

,

in Girder G-89.

!

'

--

Bechtel Quality Control Inspection Report No. C-203-C-63-20 and associated quality records related to repair of defects in Girder G-4 Bechtel Nonconformance Reports (Random Sample) related to the

!

'

repair of girders NRC Nos: 2118, 2119, 2175, 2187, 2205, 2206 and 233 Bechtel Field Memorandums to Engineering (F"E) discussing repairs to girders FME Nos. 2087 and 212 Bechtel Engineering Memorandum to Field (EMF) No. 2461 discussing

repairs to girders.

l

--

Bechtel Management Corrective Action Report No. 14 issued December 1, 1976 and signed off by QA engineer on August 19, 1977, signifying that the significant deficiency was corrected and verifie Metallurgical Examination Reports of defects performed by PECO and U. S. Steel .

--

American Bridge Repair Procedure The inspector determined that the corrective actions outlined in the licensee's final report (dated, July,1977) on Structural Steel Fabrication Deficiencies had been completed. Hcwever, this item remains unresolved pending review of licensee's examination of several girders (G-37, G-83, G-84, G-86, G-13, G-14, and G-35)

discussed in Bechtel's memorandum (EMF No. 2123) to determine if these girders have weld defects (lack of fusion) in the full pene-tration shop weld (end plate to girder web weld joint).

_ _ .

,

, .

.

4 Document Control (Unit 1)

The inspector selected the following design drawings that were being used in erecting structural steel inside the primary contain-ment, to determine that they were controlled in accordance with Bechtel's Job Rule Procedure G-5:

--

Bechtel Drawing C-932, Rev. 6

--

Bechtel Drawing C-941, Rev. 5

--

Bechtel Drawing C-942, Rev. 4

--

Vendor Drawing 8031-C-72-21-4, Rev. D

--

Vendor Drawing 8031-C-72-512-1, Rev. A The drawings were checked against the Drawing Log Register to determine that the revisions were the latest. No items of noncom-pliance were identifie . Off-site Storace Facility Tour (Limerick Unit 1 & 2)

The inspector walked through the licensee's long term storage facility, located in Eddystone, Pennsylvania, with a licensee representative to observe work activities in progress and to inspect the general state of cleanliness, housekeeping and adherence to fire protection rule No items of noncompliance were identifie !

6. Storace of Instrumentation, Electrical Eouipment and Control Comconents (Limerick Units 1 and 2) During the inspection of the long term storage facility, the inspector examined safety relate: components, panels, racks and enclosures for these componen':c to ascertain whether ,

storage, handling and cleanliness requirements conform with l established licensee procedure identified as Job Rule N j 8031-JR-G-7, Revision 1 '

l

'

l

. _ . _ _ . . _ _ _ _ _ _ _ _ _ _ .

_ _ _ _ _ _

'

.' . .

-

Items examined for compliance include:

(1) Explosive valves per specification No. M-1 General Elec-tric Co. (GE) MPL No. C41-F004 Serial No. (S/N) 123 and 126. (Limerick Unit 1)

(2) Control test cabinet per specification No. M-40, . S/N 2040 (Limerick Unit 2) S/N 204A (Limerick Unit 1). Material Receiving Report (MRR) No. SF-222 (3) Electric Heat Trace System per specification E-3 Tag No. 00C182 (common to Limerick Unit 1 & 2)

Tag No.10C183 (Limerick Unit 1)

Tag No. 20C183 (Limerick Unit 2)

(4) SRM/IRM Control Cabinet per specification No. M-1, GE Requisition No. 320-68726, Cat. Mo. H-23-PC09 (Limerick Unit 2)

(5) Flow Indicator, GE MPL No. B32-N002B, MRR No. PE-1145 (Limerick Unit 1 & 2)

(6) Pressure Indicator, GE No. C11-R015, MRR No. PE-1569

, (Limerick Unit 1 & 2)

l No items of noncoroliance were identifie The inspector examined receipt inspection records for the following items to ascertain whether the required materials, component characteristics, performance tests and qualification tests meet the specified requirements of the purchase orde Items examined for compliance include:

(1) Control Rod Drive Position (Indication) Assembly (CRD)

Tag No.10JX104A & B (Limerick Unit 1)

(2) Control Rod Drive Position (Indication) Assembly (CRD)

Tag No. 20JX104A (Limerick Unit 2)

.

.__m__m__ . _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ .

.-.... .

' *

. .

(3) CR0 - Signal Transmitter, Tag No. Cll-N052 (Limerick Unit 2)

(4) Hydrogen (H2) Recombiner, Tag No. 185403 (Limerick Unit j 1)

i'

(5) Auxiliary Transformer, Tag No. 20X102 (Limerick Unit 2)

i (6) Auxiliary Transformer, Tag No.10X102 (Limerick Unit 1)

l

No items of noncompliance were identified.

!

! The inspector examined storage maintenance data and records i (computerized Maintenance Action Cards) listing inspection j parameters and inspection due dates for the Control Rod Drive Position Assembly Nos.10JX104A&B and 20JX104 Documents were examined for verification of licensee compliance with storage / maintenance program as follows:

(1) Surveillance Records for period, January 23, 1978, through May 18, 1978 (2) Insulation resistance test reports for above items dated, 4 December 13, 1977 i .

(3) Storage Maintenance data listing initial megger test, daily gage reading, monthly visual check for condensation J and damag No items of noncompliance were identified.

8 Instrument Cable / Termination - Quality Records (Limerick Unit 1 i and 2)

!

i Cables i The inspector examined receipt inspection records for select ,

cable reels to ascertain whether materials, size, type and '

i qualification tests meet the specified requirements of the

purchase order (P.O.) and specification No. E-28, Revision 4.

!

! >

a

"

.

l

,

b

~ . . . _ _ _ , , _ - - . . - - _ _ _ , . _ .

- _ _ _ _ _ - _ - - - . .

!

. . ,

l

-

9 l

!

Documents and reels examined for conformance a- follows:

(1) Reel Nos. 6A909, 6A242, 60103 and C03AA (2) QC file W. IPC-2E-28-4, IPC-2E-28-1 (3) MRR Nos. PE-1316, PE-1226 (4) P.O. No. LX-239581, Rev. No items of noncompliance were identifie b. Solices The inspector examined receipt inspection data for shrink tubing used in safety related class IE cable splices to ascertain whether material, size, type and qualification testing meet the requirements of the purchase specification E-40, Rev. 4, dated September 21, 197 Section 6.2.5 of Specification E-40 established the IEEE Standard 383-1974 requirement for class IE cables, splices ...

and flame tests per IPCEA S-19-81, S-61-402, S-66-524, S-68-516 and IEEE-38 Qualification test data per the acove referenced documents for shrink tubing purchased against No. 8031-E40-AC; MRR No. 2285 and referenced as Vendor part No. N-45023-05 for electrical penetration assemblies was not available for review by the inspector during this inspectio The licensee did provide Vendor Bulletin G-503, listing product number, type and conformece with ASTM D635-72, UL-224(FR-1 rating) and VL-8 This same information is also referenced in the Conax Qualifi-cation Report No. IPS-269 for Electrical Penetrations, as qualifying data for shrink tubing. (reference IPS-269 para-graph 5, Section 4.8) The inspector stated that this data cannot be substituted for the required IEEE and IPCEA qualifi-cation requirements noted in the purchase specificatio The licensee has agreed to review the specification require-ments and to obtain the necessary qualification data. This item is unresolved pending NRC review of dat (353/78-02-01); (352/78-04-01)

_ _ _ _ - _ _ _ _ _ _ _ _ _

.

..

- Connectors In reviewing the Conax Electrical Penetration Qualification Report IPS-269, the inspector noted that the only reference to '

connector qualification is made in Section 4.9 of the repor Paragraph 1 states, in part, that: "ccnnectors used on the Limerick penetration are standard connectors, certified by the vendors to meet pull requirements and not contain mercur ...." It does not appear that the external connectors have been geslified for the LOCA environmen .

Discussions with site licensee QA personnel and licensee HQ engineering indicates the licensee is aware of this and that '

-

engineering has already contacted the vendor who is performing additional qualification testing of conr ctor ~*?

This item is unresolved pending NPL ' v of test dat g (352/78-04-02) (353/78-02-02)  %

%

8. Modification of Containment Structural aueel Box Beams 1 ..

? :

An inspection was performed of the activities related to the modifi- k cation of structural steel box beams located inside the drvwel %

These modifications corrected beam width fabrication error's at the $

beam ends connecting to the containment clevis imbed . 'g

?

The inspector found that Bechtel drawing C-875, Revision 6, provides the design details of the change to correct the width of the beam {g Detail 4.a 3 hows a weld which joins two plates at an unspecified l

angle. No cimensions were shown on the drawing for the angle of

! fit-up or weld grooveopening for the specified fillet wel The inspector was informed that the contractor considers this to be a l prequalified weld joint design. However, AWS 0.1.1 Section 2.7,

" Details of Fillet Welds" show fillet welds to be lapped plates with metal-to-metal contact. A compar son of the designed weld to the code descriptive and ref erenced weld sketches of Figure 2.7 in the AWS Code shows that these welds do not meet the criteria for a \

prequalified weld joint and would require rework or qualificatio ?

As stated in caragraph 2.6.2 of the AWS Code, " Joint details may depart from details prescribed in 2.9 through 2.14 and 10.13 only if the proposed joints and joint welding procedures demonstrate ,

their adequacy with the requirements of 5.2 of this code and their ,

conformance with the applicable provisions of Sections 3 and 4."

This demonstration had not been performe l

-

l

'

i f

. .

_ _ _ _ - _ _ _ - _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ .

-

.

• *

. .

Detail 9 of the same drawing, Bechtel C-875, Revision 6, shows the use of filler bars to take uo space for large weld gap The AWS Code specifies certain rules in the use of fillers as described in para.B 2.4.3 and Figure 2. The fillers as designed do not meet i

the requirements described in the AWS Cod The two items described above appear to be an item of noncompliance

'

concerning control of design deviations fromquality standard . Review of Quality Records Two drywell box beams Nos. 40 and 41 were randomly selected for a review of the Quality related records for conformance to specifica-tions 8031-C-72 and 8031-C-63 and AWS D1.1 welding cod The records reviewed are listed belo Statement of conformance by the fabricator

-- Certified Mill test report for (8) heats of ASTM 441 material

-- Certified Mill test report for weld filler material

--

Magnetic particle inspection reports

-- Ultrasenic test reports

-- Surface preparation and painting reports

-- Vendor Quality Control Inspection Record No items of noncompliance were identifie . Un~asolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviation Unresolved items disclosed during this inspectionare discussed in paragraph _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ - - _ _ _ _ _ _ _ _ - _ _ - - _

. . , -

, , .

i

l 11. Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on May 23, 197 The inspector summarized the purpose and the scope of the inspec-tion and the finding i 6