IR 05000352/1979011
| ML19305E203 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/27/1979 |
| From: | Mattiga J, Mcgaughy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19305E159 | List: |
| References | |
| 50-352-79-11, 50-353-79-10, NUDOCS 8004230114 | |
| Download: ML19305E203 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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50-352/79-11 Report No. 50-353/79-10 Docket No.
CPPR-106 License No.CPPR-107 Priority
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.A Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101
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Facility Name: Limerick Generating Station, Units 1 & 2 Inspection at: Limerick, Pennsylvania Inspection conducted: October 15-31, and November 1-15, 1979
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Inspectors:
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d. G. Mattia, Keactor inspector d&te signed i
date signed
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Approved by:
Ou tul M
/A/ L7/79 R. W. McGaughy, Chief Profects a e s4gned Section, Reactor Construction and Engineering Support Branch
Inspection Summary:
Unit 1 inspection on October 15-31, and November 1-15, 1979 (Report No.
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50-352/79-11).
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Areas Inspected:
Routine inspection by the resident inspector of work activities relative to:
Installation and welding of reactor coolant pressure boundary and other piping.
Storage and installation activities for safety related items. The inspector also perfomed plant tours and reviewed licensee action on previously identified items.
The inspection involved 104 inspector hours, including 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during offshift, by the NRC Resident Inspector.
Results: Of the four areas inspected, no items of noncompliance were identified in two areas; two apparent items of noncompliance were identified L
Region I Form 12 O004g30 (k
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(Rev. April 77)
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in two areas.
(Infraction - (1) Failure to protect a safety related item from construction activities when stored in-place - Paragraph 5.b.
(2) Failure to follow weld procedure requirements to prevent excessive undercutting - Paragraph 6.).
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Unit 2 Inspection on October 15-31 and November 1-15, 1979 (Report No. 50-353/79-10).
Areas Inspected: The inspector performed plant tours and reviewed licensee action on previously identified items.
The inspection involved 8 inspector hours by the NRC Resident Inspector.
Resul ts: No items of noncompliance were identified.
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DETAILS 1.
Persons Contacted Philadelphia Electric Company Note D. Clohecy, QA Engineer
J. Corcoran, Field QA Branch Head 1, 3, 4 D. DiPaolo, QA Engineer
F. Gloeckler, QA Engineer 2, 3 W. King Jr., Construction Engineer 2, 3 G. Lauderback, Construction Engineer
D. Marascio, QA Engineer 1, 2 The inspector also interviewed other PECo employees, as well as employees of Bechtel, Peabody Testing Company, Seneider Sheet Metal Company and General Electric Canpany.
Bechtel Corporation
4 T. Altum, Lead Field Engineer
M. Baron, Field Engineer
R. Beech, Material Storage Engineer
E. Chalifoux, QC Engineer B. Dragon, QA Engineer 1,2,4 T. Fallon, Assistant Project Field QC Engineer 2,3,4 R. Faust, Subcontracts Engineer
H. Foster, Project Field QC Engineer 3, 4 H. Gilbert, QC Engineer
M. Hipple, QC Engineer R. Henry, Subcontracts Engineer
J. Horn, ARRA II Superintendent
G. Kelly, QA Engineer 3, 4 E. Klossin, Project QA Engineer 2,3,4 M. Norm, QC Engineer J. Rainey, Project Construction Manager 2, 4
R. Stevens, QA Engineer
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Bechtel Corporation Note F. Thesing, Lead Piping Superintendent
W. Ward, Procurenent Supervisor
A. Weedman, Project Field Engineer 1,2,3,4 R. Zittel, Area Superintendent
General Electric Company
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C. Clark, Project Manager (I&SE)
W. Neal, Resident Site Manager (APED)
K. Oberley, Technician (I&SE)
J. Smith, QA Engineer (I&SE)
R. Winters, QA Specialist (I&SE)
Power Cutting Inc.
A. Pisarki, Foreman T. Seibert, Technician Schneider Sheet Metal Comoany l
T. Lewis, QC Manager
Peabody Testing Company p
G. Gordon, Level II Liquid Penetrant Examiner e
C. Nice, Level II Liquid Penetrant Examiner C. Penley, Project Manager G. Spencer, Night Shift Supervisor Notes d
1 - Denotes those present at exit interview conducted on October 18, 1979 2 - Denotes those present at exit interview conducted on October 25, 1979 i
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3 - Denotes those present at exit interview conducted on November 1,1979 4 - Denotes those present at exit interview conducted on November 9,1979 l
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2.
Plant Tour - Units 1 & 2 The inspector observed work activities in progress, completed work and the plant status in several areas of the plant during general inspection of the plant.
The inspector examined work for any
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obvious defects or noncompliance with regulatory requirements or license conditions.
Particular note was taken of presence of quality control, evidence such as inspection records, material
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identification, housekeeping and equipment preservation.
The
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inspector interviewed, when appropriate, craft personnel, craft supervision and QC personnel in the work areas.
No items of noncompliance were identified.
3.
Licensee Action Previous Inspection Findings (Unit 1 & 2)
a.
(Closed) Unresolved Item (352/78-06-01):
Dual unit snubber for Unit 1 core spray cooling system involving; safety locking wire, locknut thread engagement and torquing criteria.
This item was reviewed during previous inspection (352/78-10) and the remaining NRC inspector's concern is now addressed in the Bechtel's Quality Control Inspection Instruction 8031/P-2.10 Revision 8 and the job rule no. JR-M-17 Revision 2.
The inspector had no further questions on this matter at this time.
b.
(Closed) Noncompliance (352/79-05-01) Failure to record elongation
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and force used to rework slipped strands for longitudinal tendons of fuel pool girders.
The subcontractor deleted the
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requirement to record the elongation and force undersection IV E.5 of the QA Manual, since this information is not essential to the stressing operation and adequate documentation exists to verify that the strands were satisfactorily reworked.
The inspector reviewed the Bechtel approved supplier deviation disposition request (SDDR) No. L27 deleting the recording of elongation and force.
This item is resolved.
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c.
(0 pen) Unresolved Item (353/79-03-03): The required bi-monthly inspection of reactor pressure vessel flange bolt holes had not been performed as scheduled (item was listed on delinquent
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list).
The inspector reviewed maintenance records (#144070 and150089) and verified that three different stud holes were inspected.
The inspector also reviewed the delinquent maintenance
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list for all safety related equipment and noted that there was an improvement in the quantity of items not having their scheduled maintenance.
The inspector informed the licensee that the lists still indicated that some items are approximately 3 months overdue for their scheduled maintenance and that the inspector will~ review the list again.
This item is still considered unresolved.
d.
(Closed) Noncompliance (352!/79-06-01) Failure to have an approved piping spool erection sequence as required by Bechtel Specification P-322.
The piping erection sequence was submitted to Bechtel Project Engineering (Field Engineering Menorandum
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Partial approval (for spools erected to date) was received by Engineering Memorandum to field (#4728). The inspector reviewed the above memorandums and also reviewed an inter-office memo, dated June 27, 1979 instructing field personnel to follow the requirements of specification P-322.
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(Closed) Noncompliance (352/79-04-01) Failure to adequately protect mainsteam ioslation valve when welding activities were being performed above it.
The valve was cleaned, inspected and covered.
The inspector reviewed the Bechtel QC inspection report (QCIRM41-821-G001-8-3) and a Bechtel inter-office memo dated April 12, 1979 which emphasized the importance of protecting equipment during welding activities.
The inspector also verified that the valve was adequately protected from welding
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activities.
f.
(Closed) Unresolved Item (352/79-03-05) Limerick site practices for welding electrode control deviates from Bechtel Standard (WFMC-1).
Bechtel has elected not to use the portable electrode warmers to store electrodes overnight and therefore will follow the procedure in their standard (WFMC-1). The inspector verified that Bechtel is following their procedure by inspecting the weld issuing stations (turbine building and fabrication shop).
This item is considered resolved.
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g.
(Closed) Noncompliance (352/78-03-03) Previous inspection reports (352/78-05 and 352/78-07) discussed this noncompliance
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which involved improper performance of liquid penetrant examinations in accordance with procedure requirements.
The inspector reviewed the following documents relating to this noncompliance:
Bechtel Subcontractor QC Instruction QCI 8031 SW-1.01
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(Rev. 4) added an inspection activity (2.1.d) that'
required that Bechtel QC personnel witness the first liquid penetrant examination to be performed by each new Peabody Testing NDE technician arriving at the Limerick site.
Requalification documents for the NDE technician in
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question
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Peabody Testing Report PBT-PT-2325 documenting results of
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re-examination of weld joint FSK-HBC-182-IFW50 Peabody Testing letters (dated November 3, 1978, October
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26, 1978 and October 12,1978) relating to this noncompliance Bechtel Memorandum (EMF 3970) approving the re-certification
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of NDE technician in question
Peabody annual audits of NDE personnel performing NDE.
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Audits were dated April 5,1978 and May 2,1978 Peabody reports witnessing NDE performance on a semi-
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annual basis.
Reports were dated November 3, 1978, May 22, 1979 and October 15, 1979 Bechtel inspection reports for surveillance of newly
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arrived Peabody Testing Technicians performing first examination.
The reports reviewed were:
QCRFSC-112-IPS-6(LOGS-66, 61 and 58)
The inspector also witnessed the liquid penetrant examination
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of two weld joints performed by the NDE technician in question.
The weld joints were identified as FSK-HCC-121-1/3 nos. 57 and 58
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h.
(Closed) Unresolved Item (352/78-07-02) Review of data package for the recirculation loop pipe spool B32G001 RD-2-B-12 disclosed that flattenir*: test as prescribed by ASTM-A-530 may not have been performed.
The reactor recirculation pipe has been removed and sold per Bechtel letter CFOM #2703, dated August 29, 1979 and is to be replaced with new piping.
This item is considered resolved.
1.
(Closed) Unresolved Item (352/79-06-03) Welding of a constant support hanger transverse to longitudinal axis of lower flange of boxbeam, which conflicted with Bechtel Specification C-63.
Bechtel issued a nonconformance report (#3610) for this weld configuration and Bechtel Engineering accepted it stating that it is structurally adequate.
The inspector reviewed the nonconformance report and the QC inspection report (QCIRM43-13P201-5-1) for this weld.
This item is considered resolved.
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4.
Reactor Coolant Pressure Boundary - Welding and Work Activities (Unit 1)
The following listed activities were observed to verify that the requirements of selected portions of the ASME Section III and IX codes, the applicable Bechtel procedures, drawings and specifications were adhered to:
a.
Mainsteam Weld Joint Activities During the time period of this inspection the inspector observed the following activities for mainsteam (21" dia.) weld joint
- WA4 (pipe to isolation valve)
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Observed liquid penetrant examination of weld joint end i
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preps Reviewed qualifications of NDE technician
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Observed the Fit-up of weld joint (pipe to valve)
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Examined the finished rootpass
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Reviewed weld data history card for joint
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i Reviewed QC inspection report (QCIR-M41-B21-G001-2-1) for this
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weld joint
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Verified that weldor was properly qualified Verified preheat and interpass temperatures were controlled in
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accordance with procedure (PI-AT-LH/CVN) requirements
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Verified that quality control inspection and authorized inspec-tor hold points were adhered to No items of noncompliance were identified for the above inspection.
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During the above inspection the inspector noted that the opposite weld joint end prep (WA3) had to be modified (mitered) in the field for align-ment purposes.
The inspector during his plant tour observed the final stages of machining of the weld end prep on October 16, 1979.
During the investigation of the various documents involved in this modification, the
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inspector determined that the documents were issued after the machining was practically complete.
The Bechtel re-work notice P-726 was issued on October 16, 1979.
The General Electric (supplier of pipe spool piece)
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issued the field deviation disposition request on October 16, 1979.
The inspector informed the licensee that this was contrary to the G.E. speci-fication 22A2513, which requires G.E. approval prior to re-working.
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licensee stated th'at one of their QA engineers also uncovered this and issued a PECO audit finding report (number P-285, dated October 16, 1979). The inspector informed the licensee that this item is considered unresolved pending review by an NRC. inspector of the corrective action taken to assure that the requirements of procedures, specifications and instruc-
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tions will be adhered to for safety related activities inside the contain-ment.
(352/79-11-01).
b.
Also during the above inspection the inspector noticed a non-conformance (NCR) tag (#3795) on a reactor recirculation restraint located at azimuth 90 and elevation 278'.
The tag stated that there was a crack in the fillet weld (attachment weld for restraint to biological shield).
The inspector reviewed the NCR report which was validated October 12, 1979 and held discussions with Bechtel welding engineer and the piping foreman to determine the cause for the crack.
It was both of their opinions that it was caused by improper sequencing of the weld.
The inspector reviewed the weldor's qualification and found that he was properly qualified on October 3, 1979, for this welding.
It appears that this was his first production
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weld onsite.
The inspector informed the licensee that the AWS Dl.1 Section 3.4 requires that the contractor shall develop welding sequences which control distortion and shrinkage.
It is the licensee's opinion that the cracking of weld was not due to sequencing of the weld and that they are evaluating the cause.
The licensee also stated that the engineering disposition for the NCR (sixty days from issue) will state the cause and corrective action.
The inspector also stated that he is concerned, that since the welds for attaching restraints to the biological shield wall do not receive any non-destructive examinations other than a visual (no magnification) that there may be other cracks not detectable by the naked eye.
This item is unresolved pending review by the NRC inspector the licensee's corrective actions (352/79-11-02).
c.
Observed postweld heat treatment (PWHT) of feedwater weld joint (DLA-107-1-7 to OLA-107-1-1 at FW #50), to determine that require-ments of Bechtel Job Rule G-33 Revision 6 and ASME Code are adhered to.
The following activities were inspected:
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Verified recorder (W361) was in calibration Observed placing of thermocouples, installation of heaters and
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wrapping of insulation blankets Observed portions of heat up rates holding temperatures and
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cooldown rates
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Reviewed various types of documentation (workorder, QC records, recorder chart etc.) associated with this PWHT No items of noncompliance were identified.
d.
The inspector reviewed welder training records for the past three months and complied a list of weldors who are welding safety related items where only a visual examination is required.
Two reactor recirculation restraints were randomly selected where the welds attaching the restraints to shield wall were made in accordance with Bechtel drawing C-956 Revision 2 requirements and accepted by quality control. The restraints were at location azimuth 105 and 135 on the shield wall and welds were accepted by QC on October 17, 1979 and November 1, 1979, respectively.
No weld defects were noted (inspector used 5x magnification), however, the inspector noted that the restraint at the 135 azimuth the vertical welds were ground while at 105 it was not.
The inspector questioned the Bechtel QC engineer what was the maximum reinforcement allowed by AWSDl.1 code and used for acceptance.
He replied that one-eighth was the require-ment.
The code appears to be unclear and the licensee and Bechtel are to evaluate what maximum reinforcement is allowed for this particular joint configuration.
This item is unresolved pending review of code and design requirements (352/79-11-03).
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e.
The inspector observed and inspected the following activities related to the reactor pressure vessel recirculation nozzle safe end modifications:
Observed and verified that the nozzle layout and cutoff of
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recirculation safe end at 300* azimuth location was in accordance with G.E. procedure SRSE l-7 Reviewed qualifications of subcontractor crafts performing.
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machining operations
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Reviewed various G.E. documents related to safe end modi-fications.
The inspector informed the licensee that there is a G.E. letter (October 17,1979) which allows the site project manager to approve changes to G.E. documents and release docu-ments if the G.E. Technical Support Manager is not available (located in Philadelphia office).
A revised letter issued by the G.E. Technical Support Service Manager (dated November 1, 1979 outlines five required steps that the site project manager must take prior to releasing documents for production.
The NRC inspector had no further questions on this matter at this time.
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During an inspection of the G.E. weld storage area the inspector found inconel electrodes in a portable rod warmer.
It was determined that they had been there approximately one week and uncontrolled.
The inspector informed the licensee that this was contrary to G.E. specification no. SRSE l-7 Revision 6 which states the weldor shall return all unused welding material upon completion of the shift.
The licensee stated that on October 29, 1979 (one day before NRC finding)
they had a similar finding and that corrective action was being initiated.
This item is considered unresolved pending review by inspector of the corrective action taken by G.E. and licensee.
(352/79-11-04)
f.
During offshift inspection the inspector observed welding activities (weld buildup on recirculation base plates at azimuth 105* and 135 )
in accordance with approved field change request FCR-C-6055.
The inspector also reviewed the following documents relating to this activity:
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Quality Control Inspection Report #C-956W-10
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Weld Procedure PI-F (c 2)I Qualifications of QC engineer and welders.
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s Preheat of weld joint
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No items of noncompliance were identified.
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5.
Electrical (Components and Systems) Unit 1 a.
Observe the receipt inspection of two standby diesel generators (Purchase Order LX239585).
The diesel generators were stored in a weatherproof enclosure.
The inspector reviewed the suppliers storage instructions (8031-M-71-213-4) and noticed that the energi-zing of the alternator space heaters (460 volts - 2750 watts) was not addressed.
The inspector informed the licensee that on other construction sites he had visited with the same diesel generator manufacturer the space heaters were energized.
Bechtel called the manufacturer and was informed by them that it was an oversight on their part and the space heaters should be energized.
The inspector also stated that there was not a periodic test (Meggering) of alter-nator windings to determine any deterioration due to long term storage.
This item is considered unresolved pending review of licensee's actions concerning this matter.
(352/79-11-05).
b.
The inspector randomly selected installed safety related electrical items (Motor Control Center and switchgear) to verify that location and anchorage were in accordance with the drawing (C-603) require-ments.
The following are the items inspected:
(1) MCC #108216 located in area 16 elevation 217.
The inspector verified the dimensional location and inspected the welding of the MCC to the floor embedment.
The inspector also reviewed QC inspection report (M-ll8-18216-1).
No iters of noncompliance were identified.
(2) In an attempt to inspect the switchgear in the reactor enclosure at the 239' elevation.
The inspector found that concrete block walls were being installed near various switch-gear equipment and they were protected with plywood and plastic.
The inspector noted that one end of 4KV switchgear
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The inspector informed the licensee that this was contrary to the 8echtel Job Rule G-7, Section 2.2 and 4.2.2 for in place storage.
In addition, the inspector stated that the required frequency of visual inspection for this item is once a year and that it is not adequate for in place storage, where
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the construction activities are detrimental to the equipment.
The inspector informed the licensee that this is an item of noncompliance (352/79-11-06).
The inspector selected the Power Generation Control Complex (PGCC)
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Terminal Cabinets (10C787, 10C792 and 10C794) to verify that the
location and anchorage is in accordance with the drawing require-ments.
The following are the results of this inspection:
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The location was as specified per drawing
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The anchorage of the cabinets to the floor was by welding.
The drawing configuration of the weld joint varied, either a fillet or plug welds was allowed.
The inspector found various combinations of weld configurations.
In some areas shims were used for leveling and the shim was then welded to imbed with either a fillet weld or plug wel d.
Some terminal cabinets have very thin shims, therefore were difficult to fillet weld.
The inspector had difficulty in determining what the actual welding requirements were. A Bechtel field change request M2999F was issued to revise G.E. installation requirements as outlined in VP8031-MI-H12-3010-M2.1.
There were four G.E. field deviation disposition requests (FDDR) nos.
HHI-172, HH2-173, HHI-1000 and HH2-1001 issued for this welding but G.E. cancelled all of them.
The inspector informed the licensee that this item is unresolved pending review by the inspector. The G.E. and Bechtel approved welding requirements for anchoring PGCC cabinets.
(352/79-11-07).
6.
Seismic Class 2 Heating and Ventilation System When the inspector was witnessing a liquid penetrant examination being performed on a pipe weld joint he noticed that nearby a weldor for the heating and ventilation subcontractor had approximately a 21/2 foot extension taped to his electrode holder and was trying to weld a damper flange where one edge was located adjacent to a concrete wall (about 4" away). The inspector returned later to inspect this weld joint, after it was inspected by the subcontractor's QC inspector. The damper is a safety related item and is identified as FPD-202-47 and it is located at elevation 283' and at the 23 line.
The subcontractor's QC inspector accepted the weld on October 31, 1979. The inspector informed the licensee that the weld did not meet the acceptance criteria of subcontractor's weld procedure SSM-502 Revision 3 which states "that appearance of weld shall be such that there will be practically no undercutting into the base me tal ". Also the applicable standard AWS.D.l.1 Section 3.6 weld profile requirements were not adhered to.
Undercutting in excess of 1/32 inch into the base metal was present. The AWSD.l.1 Section 4.5 also states that slag shall be removed prior to depositing the next pass.
Since this weld joint is not very accessible it is difficult to determine if slag was properly removed.
This inaccessibility condition for welding of safety related ventilation system exists also at other locations in the plant and the corrective action for all areas will be addressed by the licensee in his response to this item of noncompliance (352/79-11-08).
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7.
In-Place Storage of Electrical Equipment In an attempt to inspect maintenance storage records for load center
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switchgear 10B201 and 108202 which have been installed in place for
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approximately two months, the inspector found that a maintenance log was not initiated by the Bechtel storage group.
The reason for this was that the storage group never received a copy of the material withdrawal requests (mechanism for initiating action when an item is removed from warehouse storage to in place storage).
The licensee stated that they uncovered a similar problem during their audit no. E-052 (dated October 23,1979).
Corrective action has been initiated by Bechtel and improvment in the control of material withdrawal requests has been noted by the licensee.
The inspector informed the licensee that this item is considered unresolved pending review of the corrective action in a sub-sequent inspection by an NRC inspector.
(352/79-11-09)
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8.
Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Unresolved items disclosed during the inspection are dis-cussed in paragraphs 4, 5 and 7.
9.
Exit Interviews At periodic intervals during the course of this inspection, meetings were held with the facility management (dates and attendees are denoted in detail 1) to discuss inspection scope and findings.
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