IR 05000352/1979003

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IE Insp Repts 50-352/79-03 & 50-353/79-03 on 790326-30.No Noncompliance Noted.Major Areas Inspected:Activities & Records for safety-related Equipment Structures & Supports & Util Action on Previous Insp Findings
ML19247B782
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 06/20/1979
From: Cerne A, Mattia J, Mcgaughy R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19247B780 List:
References
50-352-79-03, 50-352-79-3, 50-353-79-03, 50-353-79-3, NUDOCS 7908130495
Download: ML19247B782 (15)


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U.S. NUCLEAR REGULATORY C0!O1ISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-352/79-03; 50-353/79-03 Docket No. 50-352; 50-353 License No. CPPR-106; CPPR-107 Priority Category A

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Licensee:

Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name:

Limerick Generating Station, Units 1 and 2

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Inspection At:

Limerick, Pennsylvania Inspectica Conducted: March 26-30, 1979 Inspectors: r-

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3. C. Mattia, Reactor Inspector date signed

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L Ce m r/4/n A. Cerne, Reactor Inspector date signed Approved By:

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W.McGaughgg f, Projects Section n.

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Reactor Construc n and Engineerir.g Support Branch Inspection Summary:

Unit 1 Inspection on March 26-30,1979 (Recort No. 50-352/79-03)

Areas Inspected:

Routine, unannounced inspection by regional based inspectors of work activities and records for safety related equipment, structures and supports.

The inspectors also performed a plant tour and reviewed the Jicensee's action on previous inspection findings.

The Unit 1 inspection involved 43 inspector-hours on site by two regional based inspectors.

The inspection commenced at 5:15 p.m. outside the nor'al day shift working hours at the site.

Results: Sc items of noncompliance were identified.

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Unit 2 Inspection on March 26-30, 1979 (Report No. 50-353/79-03)

Areas Inspected:

Routine, unannounced inspection by regional based inspectors of work activities and records for safety related equipment.

The inspectors also performed a plant tour and reviewed the ?icensee's action on previous inspection findings.

The Unit 2 inspection involved 20 inspector-hours on site by two regional based inspectors.

The inspection co=menced at 5:15 p.m. outside the normal day shift working hours at the site.

Resuits: No items of noncompliance were identified.

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-3-DETAILS 1.

Persons Contacted Philadelphia Electric Company J. Clarey, Resident Construction Engineer

  • J.

Corcoran, Field QA Branch Head

  • D.

DiPaolo, QA Engineer

  • J. Evans, QA Engineer
  • G. Lauderback, QA Engineer

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  • D.

Marascio, QA Engineer

  • R. Sheibley, Construction Engineer Bechtel Power Corporation T. Altum, Lead Welding Engineer R. Beech, Material Storage Engineer
  • J.

Blevins, QA Engineer

  • B. Dragon, QA Engineer
  • T. Fallon, Assistant Project Field QC Engineer H. Foster, Project Field QC Engineer J. Casparich, QC Inspector H. Gilbert, QC Engineer M. Held, QC Engineer
  • R. Henry, Subcontracts Engineer M. Jan, Civil Engineer L. Jenkins, Senior Material Supervisor W. Latawiec, Senior Field Buyer W. D. Lents, QC Inspector M. Norm, QC Engineer T. O'Connor, Rod Room Attendant L. Vernon, QC Engineer T. Waters, QC Engineer F. Webster, QC Engineer
  • A. Weedman, Project Field Engineer G. Zickefoose, Lead QC Engineer General Electric Corporation G. Wetsell, QC Engineer Schneider Sheet Mecal Company

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R. Lewis, QC Supervisor

  • Denotes those at the exit in te rview.

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RHR Pumps - Installation and Quality Records (Unit s 1 and 2)

a.

The inspector observed the condition of the Units 1 and 2 RHR pump shells and discharge heads installed, but in a storage status, at their final location within the reactor building. The pump internals and motors are presently in storage at the Adwin facility.

The inspector checked for cleanliness and protective measures consistent with the required storage clasaification and spot-checked pump loca-tion layout, assembly configuration, and installation details.

He verified that a QC inspection program for the installation of the pumps had been initiated and noted that proper torque values had been applied to the foundation bolts of the completed shells.

The application and type of corrosion inhibitor utilized on the internal surfaces of pump material were determined to be consistent with vendor data and other engineering approved recommendations.

The above items were evaluated against criteria established in Bechtel Job Rule 8031-JR-G-7 (Revision 17), GE Inutallation Instruction 22A2537 (Revision 1), Ingersoll-Rand Vende*

Data and Procedure CQCP-1088 (Revision 2), and the Lim rick PSAR.

The following documents were examined:

--Bechtel QCIR 2A-P202-7-1, completed May 19, 1976.

--Bechtel QCIR P-202-7-1 (in process).

--GE Letter, Novembei 12, 1975, modifying the Ingersoll-Rand Data for foundation bolt torque requirements.

--GE Field Deviation Disposition Request FDDR HH1-116, April 17, 1978.

--Bechtel Drawings M-51 (Revision 10), M-ll6 (Revision 6),

HBB-ll8-4 (Revision 9), HBB-118-5 (Revision 8),

HBB-ll8-6 (Revision 9), and RBB-118-7 (Revision 9).

No items of noncompliance were identified; however, one item remains unresolved as discussed below.

The inspector noted that the field length of straight-run piping to the RHR pump suction nozzle, while consistent with the above referenced HEB piping isometric drawings, c16051

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-5-did not conform to Note 19 of Figure 4.8.lb of the Limerick PSAR (January, 1976), which calls for'a straight run of upstream piping for a minimum of six pipe diameters.

Subsequent com=unication between the licensee's engineering staff and site QA staff revealed that Note 19 was no longer an applicable requirement for the type of pump being installed.

However, the licensee did issue a EECO Finding Report (N156) on March 29, 1976, and an SAR Deviation and Change Control Form 4-56 on March 27, 1979, to follew up on this apparent discrepancy.

Pending resolution of this di.screpancy and documentation of the justification for eliminating Note 19, this item is unresolved.

(352 and 353/

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79-03-01)

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The inspecrsr verified the existence of both an in-place maintenar.ce system for the RRR pump shells ana discharge heads and an in-storage maintenance system foc those parts of 'ne RHR pumps located at the Adwin facility.

He checked che In-storage Maintenance System March 16, 1979, computer listing for the Unit 1 RHR pump "D" scheduled maintenance activities against the vendor's recommendad long and short term storage procedures.

He also spot-checked official

" Maintenance Action Cards" to determine that the scheduled maintenance activities and inspections had taken place. The

"In-place Maintenance Log" and the " Maintenance Action Required List" were examined to verify their use and confor-mance to the requirements of Bechtel Job Rule JR-G-7 (Revision 17) as part of the overall maiatenance program.

No items of noncompliance were identified.

The inspector reviewed the material receiving report packages c.

for two each of the RHR pumps in Units 1 and 2.

He spot-checked material certifications, test report data, and traceability of component items with regard to the require-ments established in the 'iollowing documents:

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--GE Documents 21A924 3, Revision 0, July 23,1970, and 21A9243BV, Revision 4, May 2, 1973.

--GE Purchase Order 205-AC751, Revisions 0-14.

--GE Deviation Dispositi an Requests 7970, 9674, and 9675.

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-6-Generally included in the review for the Unit 1 Pumps "A" and "D" and Unit 2 Pumps "C" and "D" were the Material and Charpy Test Results and chemical composition data for the discharge heads and pump shells and the Material Test Results and tracebility to heat numbers of the stainless steel impellers and shafts.

Nonconformance Report (NCR)

1346, October 27, 1975, was also examined for proper control and disposition.

Specifically included in the review were the following documents listed for each pump.

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Unit 1, Pump A

--Bechtel MRR's PE-1044, October 20, 1975; PE-1434, April 6,1977; PE-1434 (Revision 1), April 27, 1977; and PE-659, June 24, 1975.

--Bechtel QCIRs M1-21307, completed December 15, 1975, and M1-16963, completed October 27, 1975.

--GE Product Quality Certification F180, June 13, 1975.

Unit 1, Pump D

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--Bechtel MRRs PE-1044, October 20, 1975, and PE-664, July 1, 1975.

--Bechtel QCIRs M1-21307, completed December 15, 1975, and M1-16963, completed October 27, 1975.

--GE Product Quality Cerfitication F176, June 24, 1975.

Unit 2, Pumo_C

--Bechtel >EUt PE-693, August 8, 1975.

--Bechtel QCIR's M1-31533, completed September 29, 1978, and M1-21319, completed April 26, 1976.

--GE Produc t Quality Certification C436, July 31,1975.

Unit 2, Pump D

--Bechtel MRR PE-695, August 8, 1975.

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--Bechtel QCIRs M1-31533, completed September 29, 1978, and M1-21320, completed April 26, 1976.

--GE Product Quality Certification G435, August 8, 1975.

No items of noncompliance were identified.

3.

R2 actor Pressure Vessel Protectien (Units 1 and 2)

The inspector visually examined the interior of Units 1 and 2 reactor pressure vessels (RPV) which are in storage status.

He noted that a controlled access program had been established to permit entry only through a normally locked penetration with a permanent log book be.ng maintained to record the names and dates of personnel access.

Heaters hcd 'aeen installed to control moisture within the RPV and temperature recorders are used to monitor that acceptable temperatures are maintained.

The

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inspector verified that an adhesive tape being used on the interior stainless steel surfaces of the RPV was an acceptable and approved brand.

The inspector examined " Field Inspection Reports," "In Process Rework Notices," " Maintenance Action Cards," and temperatu*e recorder charts on a sample basis to determine if the RPV main-tenance and inspection program was being properly implemented.

The above items were evaluated against criteria established in the following documents:

--Bechtel Job Rule 3031-JR-G-7 (Revisicn 17).

- Bechtel Procedure for Cleaning, Preparations, and Storage Activities for Units 1 and 2 RPV and Accessories, Revision 4, December 18, 1978.

--GE Specifications 22A2517, Revision 0; 22A2724, Revision 3; 21A9340, Revision 1; and 21A9340AF, Revision 10.

--GE Installation Instruction 22A2537, Revision 1.

No items of noncompliance were identified; however, the following items require further action by the licensee and verification of such action on a programmatic basis by the NRC on some future inspection:

618054

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- The inspector noted a discrepancy between the Bechtel program of weekly temperature checks within the RP7 and the CE requirement for daily temperature inspecti::..s (Specification 22A2517, Revision 0). Although approval te implement weekly inspections had been obtained from the GE Eite Manager by letter on Feb uary 22, 1978, this apprcval was conditional upon the proper operation of a warning system which is not currently available.

The licensee issued a Field Inspection Report (BK 307) and a Supplement Sheet to the maintenance activity instructions which reinstated the daily temperature inspection program effectlye i=nediately.

Interviews with. responsible QC personnel indicate that this daily insp2ction a~ctivity will be integrated into the computer listed "In-storage Maintenance System" after an approximate one wees process time. (352/79-03-02; 353/79 03-02

- The inspector also noted that a required bimonthly inspection of the Unit 1 RPV flange bolt holes had not been performed as scheduled in Jaunary 1979 The system for identifying such delinquent activites did properly nore this activity in the " Maintenance Action Required List,' but as of March 30, 1979, the required inspection had not yet been performed.

The licensee inicisted a PECO Finding Report N158 to track down the delay in ef fecting corrective action.

The inspector's concern f or any possible programmatic problem in the effective use of the 'Siaintenance Action Required Lis*

to initiate corrective action on delinquent maintenance and inspection activities will be pursued on a future inspeciton.

(353/79-03-03; 4.

Fuel Pool Girder Concrete Placement (Unit 2)

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The inspector witnessuu portion of the "E" lift concrete a

placement for the Unit 2 Souuh Fuel Pool Girder (Pour RW-TU-43, 71, 55, 41, 42).

He observed pump placement and consolidation techniques and inter i.ewed available QC inspectors.

The QC preplacement and placement inspection reports and one concrete batch plant delivery ticket were examined.

The inspector noted the conduct of required in-process QC testing activities near the final placement location.

No items of noncompliance were identified.

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5.

Plant Tour

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The inspectors observed work activities in-progress, completed

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work and plant status in several areas during inspection of the plant. The inspectors also examined work items for any obvious defects or noncompliance with regulatory requirements.

During this tour, the inspectors noted that holes had been burned in the Reactor Building superstructure steel columns above the refueling floor to permit the continuous passage of reinforcing bars through the structural steel.

These columns will be embedded in concrete walls to be placed at some future time.

A review of Bechtel Field Change Request (FCR) C5313F, January 31, 1979, indicated engineering approval for the addition of new holes and the method of obtaining them through the burning process.

The inspector also interviewed a responsible field civil engineer to discuss the burning of these holes witn regard to Bechtel Specifi-cation 8031-C-62 and AISC Steel Manual. requirements.

The inspector had no further questions on this matter.

6.

Licensee Followuo Activities Relative to Items Reported to NRC Under 10 CFR 50.55(e)

Cold Formed Back-to-Back Channel Shop Welding Deficiency a.

(PECO S.D. Reoort No. 5)

The inspector examined records and held discussions with various personnel regarding the corrective actions described in the licensee's April 5, 1978, letter to NRC.

A prelim-inary inspection was performed in July of 1978 and was documented in inspection reports 50-352/78-06 and 50-353/

78-03, Paragraph 7.

The following documentation related to this cable tray support deficiency was reviewed:

--Bechtel's interim precedure listing the acceptance criteria for replacement material.

This document was issued March 17, 1978, and was used prior to a revision to the governing specification E-1406.

--Vendor's (Superstrut) Test Procedure No. 10-T2 (revision dated June 5, 1978) for testing the multiple channels.

--Bechtel's audit survey report conductem vendor on February 22-23, 1978.

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--Bechtel's Management Corrective Action Report No.

1-18, date of issue March 16, 1978.

This report was closed by Bechtel on January 22, 1979, indicating that all corrective actions have been satisfactorily completed.

--Bechtel's revised sheets (10.2 Rev. 12, 10.3 Rev. 14 and 10.4 Rev. 1) to Technical Specification E-1406.

These sheets detail the new procurement requirements such as production test requirements and vendor surveillance.

--Nonconformance Reports (NCR) 3055 and 3064 associated with this deficiency.

--Bechtel's approval of Unistrut's procedure No.

20-01-015, revision date February 10, 1978.

--Licensee's Audit Report No. E-016 of an audit conducted during the period August 24, 1978 through March 7, 1979, of activities associated with this deficiency.

--Bechtel's Quality Control Inspection Report Nos.

E1183-W6, E1183-W7, E1127-W4, E1111-W1 and E1154-W3.

--Bechtel Purchase Orders 8031-F-27113 and 8031-F-28962 which order new material from different vendor (Unitstrut).

--Material Receiving Reports 58365 and 60848 for material supplied by Unistrut.

--Unistrut certificates of compliance dated September 22, 1978, and January 4, 1979.

--Unistrut production test reports of channel spot welds report Nos. 261, 297, 257, 254 and 285.

The inspector also observed in the site laydown area, whera many of the rejected charuels were tagged and segregated.

The licensee at this time oaes not plan to repair these channels.

The inspector inspected a random sample of repaired back-to-back channels in the cable spreading room.

No items of noncompliance were identified during the above inspection.

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Cold Formed Composite Channel P1004A Welding Deficiency (PECO S.D. Report No. 6)

The inspector examined records and held discussions with various personnel regarding the corrective actions described in the licensee' August 23, 1978, letter to NRC.

This weld deficiency occurred on fabricated channels identified as Unistrut (vendor) P1004A channels which are used for the heating, ventilation and air conditioning seismic Class I duct supports.

The inspector reviewed the following documentation:

--Schneider Sheet Metal (SSM) letter dated Sky 22, 1978.

This letter reported the results of a acunding test to determine defective spot welds.

--SSM Nonconformance and Disposition Report No. 19 for nonconforming channels.

--SSM QC inspection reports Nos. 53 and 54 listing results of inspection of channels.

--SSM repair procedure of channel using a "TEK" (self-tapping) screw.

This procedure was developed for repairing channels when welding was not feasible.

(Note:

The "TEK" screws were never needed.

All repairs were accomplished by welding.)

--Report of cension-shear tests of 1/4" by 3/4" "TEK" screws.

Report dated August 29, 1978.

--PECO Audit Report No. M-161 for audit conducted on December 27-28, 1978, of SSM activities associated with this deficiency.

The inspector selected a random sample of repaired seismic Class I HVAC supports that have been repaired in reaccor building (elevation 217 feet) and control building (eleva-tion 289 feet) to inspect.

No items of noncompliance were identified during the above inspection.

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Sargent Industries Flued Head Fittings Used for Primary Containment Penetrations (PECO S.D. Report No. 7)

The inspector examined records and beld discussions with various personnel regarding the corrective actions described in the licensee's November 22, 1978, letter to NRC.

The following documents were reviewed:

--Nonconformance Reports (NCR) Nos. 3310, 3242, 3299 and 3288.

These NCRs covered the twelve penetrations

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manufactured by Sargent Industries that contained unacceptable linear indications.

--Bechtel Shipping Notice No. 6416, dated March 13, 1979, which returned all twelve penetrations to vendor for repair.

--Bechtel Drawing M-391, Revision 13.

This revision depicts the rework of penetration.

--Bechtel Material Request No. P-126, Revision 11.

This revision ou-lines the repair requirements for the defective penetrations.

--Peabody Liquid Penetrant (LP) Report Nos. 2201, 2124. 2260, 2198, 2203, 2121, 2200, 2259, 2199 and 2202.

These reports indicate the LP results of the defective penetrations.

--Bechtel Purchase Order 8031-P-126-AC, Revision 12, dated January 24, 1979, listing requirements of repair.

--PECO Surveillance Report P-260.

This report covered the activities associated with the removal and pack-aging of the installed penetrations (X-45A and X-45C).

The inspector inspected the condition of the weld prep where penetrations X-45A and X-45C were removed.

No items of noncompliance were identified during the above inspection, however, this item is considered unresolved pending NRC review of vendor's repair data package after penetrations have been repaired and returned to the site.

(352/79-03-04 and 353/79-03-03)

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7.

Structural Support Steel Welding Inside Containment

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The inspector observed welding activities associated with structural support box beams to determine that welding was performed in accordance with design Drawing C-942, Revision 6 aad we.1i proce-dure Pl-A-LH/ Structural Requirements.

The following ateributes were observed for weld joints 20A and 21BA at elevation 272 feet in containment:

--Weld identification and location.

--Use of specified weld procedures.

--Welders (IA4 and IK3) qualified in accordance with AWS requirements.

--Correct weld material (E7018) used.

--Unused weld =aterial properly kept in portable rod warmers.

--Verified that QC inspector observed welding activities (QCLR No. C928-W-14).

--Physical appearance of weld.

The inspector also performed an inspection of the weld issuing station (turbine building) which supplied materials for this welding to determine compliance with Bechtel's Welding Standard WFMC-1, Revision 6.

No items of noncompliance were identified during the above inspection, however, the welding standato (WFMC-1) does not reflect what is being done at Limerick site.

Th' following are differencec found between the standard and Limerick site practices:

Bechtel Standard Requirements Limerick Practices Electrodes out of holding oven Unused electrodes are kept in less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shall be welder's portable rod oven at placed in holding oven for minimum temperature of 250 F minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at minimum for minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

temperature of 200 F.

Portable rod warmers shall be Portable rod warmers are cali-checked semi-annually to brated every 3 months to insure insure that temperature of minimum temperature of 250 F 125 F is maintained.

is maintained.

This item is considered unresolved pending NRC review of revision to standard to agree with current site practices.

(352/79-03-05).

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8.

Structural Support Steel Welding Outside Containment

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The inspector observed welding activities associated with structural support beams to determine that welding was performed in accordance with design drawing C-1164, Revision 8, approved Field Change Requests (FCR) C-5447F and C-5487F, and welding procedure Pl-A-LH/ Structural Requirements.

The following attri-butes were observed for two weld joints associated with FCR C-5447F and C -5487F in the reactor building at elevation 182 feet (Area 16):

--Weld identification and location.

--Joint preparation and alignment.

--Evidence of QCIR verification (QCIR No. Cll64-W'-1)

--Use of applicable weld procedure.

--Qualified weldor (I.C.).

--Correct weld material (E7018).

--Physical appearance of weld.

No items of noncompliance were identified during the above inspection, however, the inspector observed that some areas of weld joint at the flanges of beam splice appeared to be over ground which created some questionable shallow areas.

Bechtel =easured these areas and found them to be undersize (less than minimum flange thickness). A Nonconformance Report No. 3503 was issued for this condition.

This item is considered unresolved pending NRC review of repair and close out of NCR 3503.

(352/79-03-06)

9.

Licensee Action on Previous Inspection Finding (Closed) Unresolved Item (352/78-10-06):

Job Rule R-10, Revision 12 was not specific in requiring that when NSSS equipment is withdrawn from storage for installation, it is to be inspected (final) as required.

The Job Rule R-10 was revised (Revision 13)

dated March 9,1979, and is now specific in requiring a final inspection.

This item is considered resolved.

10.

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items,

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items of noncompliance or deviations.

Six unresolved items disclosed during this inspection are discussed in Paragraphs 2, 6, 7, and 8.

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11.

Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 30, 1979.

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

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