IR 05000352/1978012

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IE Insp Repts 50-352/78-12 & 50-353/78-08 on 781226-129 & 790102.Noncompliance Noted:Failure to Perform Insp for Piping Installation Activities
ML19270G264
Person / Time
Site: Limerick  
Issue date: 01/30/1979
From: Mattia M, Mcbrearty R, Mcgaughy R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19270G253 List:
References
50-352-78-12, 50-353-78-08, 50-353-78-8, NUDOCS 7906050212
Download: ML19270G264 (13)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-352/78-12 Report No. 50-353/78-08 50-352 Docket No. 50-353 CPPR-106 License No.CPPR-107 Priority Category A

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Licensee:

Difladelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:

Limerick Generating Station, Units 1 and 2 Inspection at:

Limerick, Pennsylvania Inspection conducted: December 26-29, 1978 and January 2, 1979 Inspectors:

.M

/ 33 77

,

r Mattia, Reactor Inspector date signed

$6.k' f*paa$i du/n R. pcBreartp Reactor / nspector tate ' signed I

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,7 3 A. Finkel, Reactor / Inspector date signed Approved by:

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R. McGaughy# Cttief, Projects Section, g

dateA igned RC&ES Branch

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Inspection Summary Unit 1 Inspection on December 26-29, 1978 and January 2,1979 (Report No. 50-352/78-12)

Areas Inspected:

Routine, unannounced inspection by regional based inspectors of work activities and records for safety related reactor pressure vessel, electrical and instrumentation equipment, piping and pre-service inspection.

The inspectors also performed a plant tour inspection. The Unit 1 inspection involved 57 inspector hours onsite by three regional based inspectors.

Results:

Of the five areas inspected, no items of noncompliance were identified in four areas; one apparent item of noncompliance was identified in one area (Infraction - failure to Perform Inspection for Piping Installation Activities -

Paragraph 9).

Region I Form 12 7906050 $/ 2 k

(Rev. April 77)

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Inspection Summary

f.Init 2 Inspection on December 26-29, 1978 and January 2, 1979 (Report No. 50-353/78-08)

TrFs"~Iiispected:

Routine, unannounced inspection by regional based inspectors of work activities and records for preservice inspection, reactor pressure vessel and electrical equipment. The inspectors also performed a plant tour inspection. The Unit 2 inspection involved 20 inspector-hours onsite by three NRC regional based inspectors.

Results:

No items of noncompliance were identifie.

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DETAILS 1.

Persons Contacted Philadelphia Electric Company

  • D. Clohecy, QA Engineer
  • J. Corcoran, Field QA Branch Head
  • D. DiPaolo, QA Engineer
  • J. Evans, QA Engineer
  • G. Lauderback, QA Engineer
  • D. Marascio, QA Engineer
  • R. Scott, Lead Construction Engineer Bechtel Power Corporation
  • A. Arch, Laad Piping / Mechanical Engineer
  • R. Beech, Material Storage Engineer
  • J. Blevins, QA Engineer W. C. Clayton, QC Engineer
  • B. Dragon, QA Engineer
  • T. Fallon, Assistant Project Field QC Engineer
  • R. Faust, Subcontracts Engineer
  • H. Foster, Project Field QC Engineer J. Gray, QC Engineer
  • G. Kelly, QA Engineer
  • E. Klossin, Project QA Engineer-5. Shea, Large Pipe Engineer
  • D. Shaw, Lead Electrical Engineer K. Spaulding, QC Engineer
  • A. Weedman, Project Field Engineer G. Zickefoose, Lead QC Engineer Nuclear Energy Services, Inc.

E. Labey, Level II Examiner

  • denotes those present during exit meeting.

2.

Electrical Switchgear and Instrumentation Equipment (Unit 1)

The inspector examined the in-place storage of the following electrical and instrumentation equipment and the documentation records associated with the equipmen.

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a.

Receiving Documentation H12-U791-ECCS Division 1 Cabinet Floor Section - QC File

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No. 219 Unit 1 H12-U792-ECCS Division 11 Cabinet Floor Section - QC File

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No. 221, Unit 1 Quality Control Inspection Record

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Material Withdrawal Request Form No. 51338 and 51339

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Material Receiving Report - MMR Nos. 1817 and 1818

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General Electric Product Quality Certification MPL Nos.

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H12-U791 and H12-U792 Control cnd Instrumentation Ship Short Authorization

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Product MPL #H12-U791 and H12-U792.

No items of noncompliance were identified.

b.

Installation Documentation PGCC Termination Cabinets 10C792 - Log No. 35

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PGCC Termination Cabinets 10U792 - Log No. 8

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PGCC Cabinets 10l!792 - Consist of the following equipment

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cabinets.

Refer,ince Drawing M-603

- 10C618 Log No. 9

- 10C641 Log No.10

- 10C620 Log No, 11

- 10C613 Log No 12

- 10C644 Log No 13

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PGCC Cabinets 10V791 - Consist of the following equipment

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cabinets.

Reference Drawing M-603

- 10C617

- 10C640

- 10C621

- 10C628

- 10C631 No items of noncompliance were identified.

c.

Inspection Verification Records The inspector reviewed the following Unit 1 installation records for compliance with drawings and procedures referenced in Criteria /412-3010-M-1-2, Revision 1.

Storage and Maintenance Requirements

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Location per drawings / floor locations

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Welding, anchorage and bracing

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Alignment and Orientation

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Cable ladder installation

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Area cleanliness

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Visual evidence of damage

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Signed and dated Quality Control Forms

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No items of noncompliance were identified.

d.

Storage Requirements The inspector examined the storage records and verified that the storage area is in compliance with the requirements of MRR PE 1817/1818.

The temperature and control charts are documented in file BIC265.

No items of noncompliance were identifie.

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3.

Instrumentation (Units 1 and 2)

The inspector selected the following documentation for verification with the requirements of the PSAR.

a.

Specifications Process Radiation Monitoring System for Limerick Units 1

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and 2, 8031-M-1 General Electric System Design Specification and Data

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Sheet No. 22A2940AB, Revision 2, dated April 26,1973 and Engineering Change Notice No. NE 41199, dated May 8, 1973.

Describes monitoring of radioactive liquids and gases to control the emission of radioactive materials

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into system environments.

General Electric System Design Specification No. 22A2940,

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dated May 8,1978, Revision 1, entitled, " Process Radiation Monitoring System." Defines the functional design requirements for the radiation monitoring of the process liquids and gases associated with this nuclear system.

General Electric Process Instrumentation System Design

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Specification No. 22A3732, Revision No. 1, dated October 18, 1973.

General Electric Specification No. 22A3074, Revision 1,

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dated March 18, 1976, entitled, "BWR Equipment, Environmental Interface Data." This specification defines the indoor environmental data to be used for equipment design.

General Electric Specification No. 22A1495AC, Revisior. 1,

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dated March 22, 1972, entitled, " Pressure Integrity of Pipir.g and Equipment Pressure Parts."

General Electric Specification No. 21A8690, Revision 2,

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dated May 15, 1978, entitled, " Seismic Requirements for Essential Instruments." The components that are identified by this specification are the essential instrumentation devices, sensory equipment, control equipment, power supplies, and the panels, consoles and racks.

No items of noncompliance were identifie.

b.

Testing Essential instrumentation defined in General Electric Specification No. 21A8690 shall be capable of performing all essential functions while being subjected to the following requirements:

Peak horizontial acceleration - 1.5 g's and a peak vertical

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acceleration of 0.5 g's over a frequency range of 1.0 to 30 HZ at the point of attachment to the building structure.

The equipment shall perform its essential function during and after vibration testing.

The above requirements are in accordance with the PSAR requirements for this equipment.

No items of noncompliance were identified.

4.

Electrical Audits (Units 1 and 2)

The inspector reviewed the licensee's electrical audits listed below. The audit findings and corrective action proposed or taken was also examined by the inspector.

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Electrical Audit No. E-014, dated May 9-10,1978, Units 1 and

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2, entitled, " Electrical Cable Storage."

Electrical Audit No. E-015, dated July 5-7,1978, Units 1 and

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2, entitled, "Bechtel Power Corporation - Construction",

documentation associated with permanent plant cables.

Electrical Audit No. E-017, dated October 10, 1978, Limerick

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Units 1 and 2, entitled, " Electrical Penetrations."

Findings identified in the above referenced Audits were documented with resolution and corrective action taken.

It appeared that the findings were not generic, but rather to this specific installation.

No items of noncompliance were identifie.

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5.

Electrical / Instrumentation Field Modifications (Units 1 and 2)

The inspector reviewed Procedure Ell-35, Revision 2, dated September 8,1978, entitled, " Limerick Generating Station, Units 1 and 2 Field Modification Control." The procedure Ell-35 describes the method to be used by the licensee to coordinate, identify and control Field Modifications to delivered equipment or to completed installations of Limerick Generating Station prior to turnover to startup.

The inspector reviewed the GE product quality certifications (PQC)

for the power generation control complex / advanced control room (PGCC/ACR) equipment received at the site. The PQC identified various items not incorporated in the PGCC/ACR equipment received.

In reviewing the receiving package dated October 1975 for the PGCC/ACR equipment, the inspector observed that the H12-U791 and H12-U792 equipment racks were shipped with outstanding Enginering Change Nctices (ECN's) identified on the PQC fonn, but these items were not listed in the General Electric Field Outstanding Item listing as of this inspection period.

It appears that the outstanding items listed by General Electric on their PQC form are not verified by the licensee as being identified and listed in the General Electric field listing.

This matter is considered to be unresolved and will be examined by an NRC inspector during a subsequent inspection.

(352/78-12-01)

6.

Plant Tour (Units 1 and 2)

The inspectors observed work activities in progress, completed work and plant status in several areas of the plants.

The inspectors examined work items for any obvious defects or noncompliance with regulatory requirements.

No items of noncompliance were identified.

During this tour the inspectors also observed that the reodor recirculation piping stored in-place in the primary containment, had been removed. The licensee stated that they are replacing the original piping which was fabricated with type 304 stainless steel

piping with type 316L stainless steel.

The type 316L material will be selected with the lowest possible carbon content and still meet the material properties of the ASTM standards.

The purchase order for the 316L piping is to be issued some time in January, 1979.

The installation of horizontal tendons for the fuel pool girders was also observed during the plant tour.

No items of noncompliance were identified during this tour.

7.

Reactor Pressure Vessel (RPV) Storage (Units 1 and 2)

a.

Vessel Inspection The inspector inspected sections of the surface of the interior of the reactor vessel to ascertain that the requirements of the Bechtel RPV Storage Procedure (Revision 3, dated November 18,1977) are being implemented. The inspector also inspected the temperature and dewpoint recorders monitoring the environment inside the vessels. A pertenent log book is being maintained at each entry to the vesse's.

The log book is used to control the entry in and out of the vessel.

The inspector noted that the storage procedure did not address the maintaining of a permanent log book. The licensee revised the procedure (Re-vision 4, dated December 29, 1976) to reflect the use of the log book.

No items of noncompliance were identified.

b.

Record Review The inspector reviewed the completed RPV maintenance action cards for the months of October, November and December, 1978, to ascertain that the required inspections are being performed, and at the required frequency.

No items of noncompliance were identifie.

Licensee Action on Previous Inspection Findings (Closedi 'Jnresolved (352/78-03-05):

Bechtel Job Rule JR-E-1 was complet.f revised (Revision 9, issued July 26, 1978) based upon IEEE Standard 43-1974 requirements. A memo was issued by Bechtel, dated August 7, 1978, listing motors that are to be meggered in accordance with the Job Rule (E-1, Revision 9), in lieu of the vendors instructions. The GE supplied motors for the core spray, RHR and reactor recirculation pumps were on this list. This item is considered resolved.

(Closed) Unresolved (352/78-02-02):

Bechtel Drawing C-637 was revised (Revision 8) to state which " Guides" listed on the drawing are mandatory and will require prior engineering approval for deviation.

Bechtel issued a checklist (No.15) which lists the C-637 Drawing mandatory inspection criteria. The project QC instruc-tions for concrete preplacement (8031/C-1.20, Revision 10) were revised to incorporate checklist No.15.

The inspector reviewed PECO Surveillance Report No. G-19 which detailed the search that PEC0 had performed to ascertain that for the Limerick Units no other design " Guideline" document existed.

This item is considered resolved.

9.

Safety Related Piping Installation (Unit 1)

a.

The inspector observed welding of safety related piping at various stages of weld completion to determine if regulatory requirements and PSAR committments are adhered to.

The following weld joints in various stages of completion wer2 inspected.

HBB-127-1/7-M57 FSK-EBB-129-3/9-No. 51 No items of noncompliance were identified.

b.

The inspector reviewed the weld history cards and quality control inspection reports for the above weld joints.

For weld joint FSK-EBB-129-3/9-No. 51 (the welding of a two inch

nipple to the pipe spool) the inspector observed that there were three (prior to welding) inspection hold points listed on Quality Control Inspection Report No. M55 which were not signed off as acceptable.

These inspection hold points were as follows:

(1) Activity #2.2 - verification of materials (2) Activity #2.3 - inspection for cleanliness and surface defects, and (3) The authorized code inspe tor's hold point for activity 2.3.

Further investigation indicated that neither the authorized code inspector nor the Bechtel QC engineer were notified prior to the welding of the 2" nipple to pipe spool that construction was ready for them to perform their respective inspections.

The work had proceeded beyond the point where it was not feasible to adaquately perform the cleanliness and surface defect inspections (activity 2.3) as described in QC inspec-tion (No. 8031/0-1.10). The licensee was informed that this was ccatrary to the requirements of the Project Special Pro-vh1ons Procedure G-6.1, Revision 1, and Appendix B, Criterion V of 10 CFR 50.

This is considered to be an item of noncompliance.

(352/78-12-02)

10.

Preservice Inspection (PSI) Activities (Unit 1)

The licensee has contracted Nuclear Energy Services, Inc. (NES) to perform the PSI examinations required by Section XI of the ASME Boiler and Pressure Vessel Code.

The ultrasonic examination of piping welds is governed by Appendix III of Section XI,1974 Edition, Winter 1975 Addenda as modified by Paragraph lWA-2232 of the Sumer 1976 Addenda.

The inspector observed NDE in progress, reviewed NDE data and interviewed personnel with respect to the data and observation.

a.

Observation of NDE in Progress The inspector witnessed the ultrasonic examination of RHR System weld number RHD-047, an 18 inch diameter pipe to elbow weld, in order to ascertain that the examination was done in compliance with the applicable code and procedural requirements.

The inspector found that the longitudinal beam and angle beam examination of weld RHD-047 was done using equipment, beam angles, calibration techniques and test frequencies specified by NES procedure number 80A1566, Revision 0, entitled, " Ultra-sonic Examination Procedure for Piping Welds."

The inspector noted that the longitudinal beam examination frequency used to perform the examination of RHD-047 differed from the nominal frequency specified by Section XI of the ASME Code.

The apparent discrepancy was discussed with licensee contractor representatives who provided documented technical justification for the examination frequency which was employed.

The inspector had no further questions at this time concerning this matter.

b.

NDE Data Review The inspector reviewed data sheet 1566-1, dated November 27, 1978, for weld number RHD-069, sheet 1566-29 and 30, dated December 20, 1978, for Weld RHD-050 and sheet number 1566-38, dated December 27, 1978 for weld RHD-047.

The review was done in order to ascertain compliance with code and procedural recording requirements and to ascertain that required evaluations were done.

The inspector found that the reviewed material identified beam angles, extent of examination, examination equipment, including instrument, transducers, couplant, search cable, calibration block and also identified the examination personnel and their level of qualificatio Indications detected by angle beam in weld RHD-047 were ecorded on data sheet 1566-38. The sheet contained a notation b" the level II examiner that the indications were evaluated mised on a comparison of the ultrasonic data to radiographic data for the weld.

A plot of the location of the indications with respect to the wald was not made and the basis for comparison of ultrasonic and radiographic data was not clear.

The inspector stated that this item is considered unresolved pending NRC review of the data evaluation subsequent to licensee review and approval, and further review of the NES evaluation process.

(352/78-12-03)

11. Unresolved Items Unresolved items are matters about which more information is re-quired in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Two unresolved items disclosed during this inspection are discussed in Paragraphs 5 and 10.

12.

Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on December 29, 1978, and January 2,1979.

The inspector summarized the purpose and the scope of the inspection and the findings.