IR 05000352/1979012
| ML19320D418 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/05/1980 |
| From: | Mattia J, Mcgaughy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML16341B393 | List: |
| References | |
| 50-352-79-12, 50-353-79-11, NUDOCS 8007210338 | |
| Download: ML19320D418 (15) | |
Text
.
.
.
'
.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-352/79-12 Report No.
50-353/79-11 50-352 Docket No.
50-353 CPPR-106 License No.
CPPR-107 Priority Category A
--
Licensee:
Philadelphia Electric Comoany
.2301 Market Street
__
Philadelphia, Pennsylvania 19101 Facility Name:
Limerick Generatino Station. Units 1 & 2 Inspection at:
Limerick, Pennsylvania Inspection conducted: November 20-30 and December 3-21, 1979 Inspectors:
Ck 2 !/l W C. Mattia, Reactor Inspector date signed date signed
~
date signed Approved by: M//Y,M/bru
FD R.W.McGaughy[Chf,ProjectsSection,
/ date signed RC&ES Branch Insper. tion Summary:
Unit 1 Inspection on November 20-30 and December 3-21, 1979 (Report No. 50-352/79-12)
Areas Inspected:
Routine inspection by the Resident Inspector of work activities relative to:
document control, receipt inspection, storage and maintenance of equipment, safety-related piping activities,' and electrical activities. The inspector also performed plant tours and reviewed licensee action on previously identified items.
The inspection involved ill 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: _0f the~six areas inspected, no items of noncompliance were identified in four areas; four apparent items of noncompliance were identified in two areas. (Infraction - (1) Failure to control design documents for masonry walls -
Paragraph 8a. (2) Failure to provide a QA Program for masonry walls subcontractor -
Paragraph 8b. (3) Failure to provide control of pipe hanger drawings - Paragraph 9a.-(4) Failure to following design drawing requirements for pipe hanger installa-tion - Paragraph 9b).
Region I Form 12 (Rev. April 77)
800721033%.
~
.
__
,,
-
_
--
-
.
.
.
,
- Inspection Sumary
Unit 2 Inspection on November 20-30 and December 3-21, 1979 (Report No. 50-353/79-11)
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.
-
Results: No items of noncompliance were identified.
,
t I
e
-
__
,
. -..
__
- _ - _ - -.
. _ _.
__
_ _ _
.
.
.
,
DETAILS 1.
Persons Contacted Philadelphia Electric Company Note D. Clohecy, QA Engineer 1,2,3 J. Corcoran, Field QA Branch Head
D. DiPaolo, QA Engineer 2, 3 J. Fedick, Construction Engineer
G. Lauderback, QA Engineer 2, 3 D. Marascio, QA Engineer R. T. Scott, Construction Lead Engineer
The inspector also interviewed other PEC0 employees, as well as employees of Bechtel, NULFI Co. and General Electric Co.
Bechtel Corporation _
E. Chalifoux, QC Engineer N. Confuorto, Subcontracts Engineer
J. Curci, QA Engineer 1, 2 & 3 A. DiPietro, Subcontracts Engineer 1&2
'B. Dragon, QA Engineer 1&2 T. Fallon, Assistant Project Field QC Engineer 1, 2 & 3 R. Faust, Subcontracts Engineer
H. Foster, Project Field QC Engineer 1, 2 & 3 H. Gilbert, QC Engineer J. Gray, QC Engineer
G. Kelly, QA Engineer 1,2&3 E. Klossin, Project QA Engineer
J. Gwin, Project Superintendent
M. Hipple, QC Engineer T. Hollifield, Area Engineer M. Jan, Area Engineer
R. Leingang, Assistant Project Field Engineer 2&3 J. Reiney, Project Construction Manager
D. Shaw, Staff Electrical Engineer
M. Tokolics, QA Engineer
A. Weedman, Project Engineer
.
.
.
,
4 General Electric Company
.
C. Clark, Project Manager (I&SE)
J. Smith, QA Engineer (I&SE)-
Notes 1 - Denotes those present at exit interview conducted on November 30, 1979.
2 - Denotes those present at exit interview conducted on December 6,1979.
~
3 - Denotes those peesent at exit interview conducted on December 21, 1979.
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 obvious defects or noncom-pliance with regulatory requirements or license conditions.
Particular
<
note was taken of presence of quality control inspectors and quality control evidence such as inspection records, material identification, housekeeping and equipment preservation. The inspector interviewed, when appropriate craft personnel, craft supervision and QC personnel in the work areas.
No items of noncompliance were identified.
3.
Licensee Action on Previous Inspection Findings (Units 1 & 2)
a.
(Closed) Unresolved Item (353/79-03-03)
As reported in inspection report 353/79-10, the inspector stated he would review in his next inspection the latest computer listing for delinquent safety related maintenance items. The inspector reviewed the current December 10, 1979 list and noted that there were only eight items on the list compared to 34 during the last inspection (353/79-10). The inspector informed the licensee that since the delinquent items required mostly visual inspections and the equipment were located in the warehousa that he had no further questions on this item at this time.
b.
(0 pen) Unresolved Item (352/79-03-04 & 353/79-03-03)
Only eight of the twelve repair data packages for the Sargent flued head fittings (used on the primary containment penetration) were available for review. The inspector reviewed the package for the following eight flued head fittings:
.
-
.
. - -... -.. -.
--
---
. _ _ _ - - _ _
.
.
.
,
.
' Identification No.
' Serial No.
DLA-111-01-F01-X16A 001 DLA-110-01-F01-X168 001
.DLA-212-03-F01-X45A 002-DLA-212-04-F01-X45C 002
-
DLA-212-02-F01-X458 002 DLA-212-01-F01-X45D 002 DLA-211-01-F01-X16A 002 DLA-210-01-F01-X16B 002 The data package was identified as 8031-P126AC-F-360-1 and was also reviewed and approved by Bechtel on November 26, 1979. No items of noncompliance were identified during this review by the inspector.
This item is still considered unresolved pending review by the inspector of the repair data package for the remaining four flued head fittings.
c.
(Closed) Infraction (352/78-08-01)
'The renaining item for the NRC inspectors review (as reported in the 352/79-09 inspection report) was the licensee's evaluation of the reactor girder crane internal welds. The inspector reviewed the following documents relating to this matter:
PECO Finding Report C-207 l
--
Bechtel Letter dated February 12,1979 (Code BLP-18745)
--
PECO Letter dated March 6, 1979 (Code PLB-9408)
--
Bechtel Letter dated March 21,1979 (Code BLP-19012)
--
PECO Letter dated January 9,1979 (Code PLB-9164)
--
Crane Manufacturer's Letters dated November 15, 1978 and February
--
6, 1979 t
!
-...
l>
.
.
.
.
1 PECO Surveillance Report #C-166 of internal welds
--
The licensee and manufacturer inspected (thru four cut outs at each corner of the girder) approximately 336 inches of the total internal welds. This represented about 2% of the total of the internal welds.
Based upon the defects found, the crane vendor calculated the reserve capacity of the internal welds and determined that the welds were acceptable. This was based upon the internal welds having an excessive calculated reserve capacity.
The calculations were reviewed by Bechtel and the licensee and they found them acceptable. The inspector had no further questions on this item at this time.
d.
(Closed) Infraction (352/78-12-02)
This item involved the missing of two required inspection hold points prior to the welding of two fittings (nipples) on pipe spools EBB-129-3-5 and EBB-129-3-6. The following records were reviewed by the inspector relating to this matter:
Quality Control Inspection Report M55-EBB-129-3-2-1
--
Nonconformance Report #3423 issued for lack of material identifi-
,
--
cation for fittings.
PECO Finding Report N-144
--
-
Bechtel inter-office memorandum dated January 10, 1979 which
--
iterated the discussion held with field staff engineers, super-vision QC and QA organizations on meeting procedure requirements for all inspection hold points.
e.
(Closed) Infraction 352/78-03-03)
This irfraction was closed in inspection report 352/79-11.
In addition to the information previously reported, the inspector requested the licensee to have Bechtel and Peabody review the total number of liquid penetrant examinations performed by the NDE technician in question since their total numbers do not agree. This was accomplished during this report period and Peabody issued a letter (Code No. P-283) stating
that after a review of Bechtel's summary of audit finding N-127 re-examination data and their records they have concluded that the two records are now in complete agreement.
The inspector reviewed the i.
l above documents and had no further questions.
!
,
.
.
.
,
4.
Power Operated' Relief ~ Valves It has been ascertained that inspection for binding is required for power operated relief valves manufactured by Control Component, Inc. The inspector verified that power operated relief valves from Control Component, Inc. are not used at Limerick, and that this inspection is not required.
5.
BIF Butterfly Valves BIF Corporation reported in accordance with 10 CFR Part 21 requirements, that an operational defect may exist with the Limerick BIF butterfly valves and their valve operators. The shaft keys that lock the operator to the valve stem had to be visually inspected and verified that they were staked so that they could not vibrate loose during operation.
Bechtel issued a nonconfonaance report (No. 3413) listing the Limerick valves that the BIF letter (dated October 18, 1978) applies to. The inspector reviewed NRC
- 3413 which was closed out on October 5,1979 stating that all the shaft keys were staked for the various listed valves.
The inspector also reviewed the licensee's surveillance report (#P-254) of this activity.
6.
Reactor Coolant Pressure Boundary - Welding and Work Activities (Unit 1)
The following listed activities were observed to verify that the require-ments of selected portions of the ASME Section III and IX codes, the applicable construction procedures, drawings and specifications were adhered to:
a.
Reactor Recirculation Safe End Replacement Activities
,
The inspector observed the following activities relating to the replacement of reactor pressure vessel nozzels safe ends:
inspected second weld pass of replaced reactor recirculation safe
--
end at azimuth 3000 inspected fitup (tackwelded in place) of reactor recirculation
--
safe end at azimuth 3360 reviewed qualifications of welders who perfonned welds at azimuth
--
3000 and 3360 to verify that they were qualified in accordance with GE procedures LR 179-1-7W and LR 179-1-2W.
observed welding activities of welder qualifications using in-
--
conel mockups in accordance with procedure LRI 79-1-7D using automatic welding machine (Dimetrics model A power supply and model F welding head).
No items of noncompliance were identified.
f
<
.n-
-
-w,-
- -.
.,, ~ -.., -, - - -
,
,--
.
.
,
b.
Reactor Recirculation Restraint Welding Activities During an offshift inspection, the inspector observed various welding activities for reactor recirculation and main steam restraints located in containment to verify compliance with weld procedure PI-A-LH (Struc-tural). The following areas were inspected:
Observed horizontal welding being performed on restraint located
--
at azimuth 2700 and elevation 244'.
~
Observed weld buildup (shim) on restraint located at azimuth 900
--
and elevation 254'.
Observed welding of main steam restraint at elevation 272'
--
No items of noncompliance were iden',1fied.
7.
Receipt Inspection (Units 1 & 2)
The inspector witnessed the receipt inspection activities of various safety related equipment to verify that the following requirements were being met:
Handling and identification
--
Adherence to receipt inspection procedures
--
Documentation of inspection
--
The receipt inspection of the following items were observed by the NRC inspector:
Stainless steel plug valve (#HCC-PC-D-AO) purchase order 8031-P-ll2-
--
AC, Revision 20.
Pipe' fittings, purchase order 831-F-20400, Revision 6.
--
Diesel generator (No. 1BG501), purchase order LX-239585.
--
.
No items of noncompliance were identified.
8.
Storage, Handling'and Protection (Units 1 ~& 2)
The inspector observed the onsite warehouse storage
'eas to determine that safety related equipment (mechanical and electrical) is being st.ored, handled and protected in accordance with the applicable portions of Job Rules G-7, G-8, M-5 and M-6.
The types of equipment inspectcl fere as follows:
.
.
.
,
Piping fittings
--
Valves (various sizes and types)
--
Electrical raceway - supports and fittings
--
Electrical connectors
--
Electrical and mechanical hardware
--
The inspector noticed that on a shelf in the warehouse there was Raychem heat shrink tubing for electrical connections that was Peach Bottom A+omic Power Station's surplus material which was sent to Limerick Generating Station for their use. The inspector reviewed the following documentation to verify that the Raychem heat shrink tubing met the drawing requirements (E-1412, Rev. 7 Section 1.15.
PEC0 memorandum (CF0M-2502, dated May 2,1979) asking Bechtel if they
--
can use Peach Bottom surplus material.
Bechtel letter (LTC-6999, dated May 7,1979) stating that it could be
--
used, provided it met their requirements (drawing E-1412).
Reviewed various Raychem's certificate of compliances for the following
--
Raychem purchase orders:
BW-383184, BW-371994, BW-372299, BW-382787, BW-383291.
Reviewed the material receiving report #64419 which received the Peach
--
Bottom material.
.
No items of noncompliance were identified.
9.
Reactor Vessel Protection (Units 1 & 2)
The inspector reviewed the Unit 1 & 2 reactor vessel (RV) maintenance action cards for the month of November and December,1979 to verify that they are being stored in accordance with the approved NSSS Instructions.
For the Unit 2 RV the inspector noted in the maintenance records that Becthel found during an inspection (see long term maintenance action reports #973 and #1022) that some moisture and light rusting was found inside of the vessel at the bottom center. The chloride content at this location was found to be 140 parts per million.
GE issued instructions (October 18, 1979) requiring Bechtel to perform a neutralizing operation of wiping the interior of the vessel with a solution of trisodium phosphate and demineralized water. This neutralizing action was currently being i
!
l
.
. - - - -
m
.
..
.
,
performed. The inspector examined the interior of Unit 1 and 2 vessels and also observed the humidity and temperature recorder, which were monitoring the environment inside the reactor vessels.
~
No items of noncompliance were identified.
10. Masonry Walls (Unit 1)
a.
Document Control During an inspection of conduits and cable trays, the inspector noticed several loose civil drawings on a work table belonging to the masonry wall subcontractor.
The drawings were located at elevation 244 near column line 26.
A check of the nine drawings with the current Bechtel revision listing (register) revealed the following:
DWG. No. and Revision Current Revision
- C-761, Rev. 7 Rev. 8
- C-762, Rev.11 & 12 Rev. 13 C-608, Rev. 6 Rev. 8 C-756, Rev. 11 Rey, 12 C-761, Rev. 8 Rev. 8 C-1241, Rev.1 Rev. 1
- C-426, Rev.10 Rev. 12 C-1240, Rev. 1 Rev. 1 Note: Drawing C-756 which is identified as the key plan for the Limerick Plant masonry walls delineates what walls (drawings) are Seismic I and II. Those above marked with an asterisk are Seismic Class I.
The above drawings were assigned to the subcontractor who is erecting the masonry walls.
The inspector after discussing the lack of control of drawings by the subcontractor asked Bechtel for the subcontractor's document control procedures. He was informed by the licensee that the subcontractor was not required to have any since they were covered by Bechtel's Job Rule G-5 (entitled, " Design Document Control"). The l-
'
L
- _ _ _ _ _ _ _ _ _ _
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
.
inspector could not find in the subcontract document 8031-A-2A nor could the licensee provide documented evidence that the subcontractor was governed by Bechtel's Job Rule G-5.
The inspector informed the licensee that this lack of document control was contrary to Criterion VI of 10 CFR 50 Appendix B.
(352/79-12-01)
b.
QA Program A review of documentation related to the subcontractor for the erection of Seismic Class I masonry walls did not indicate what applicable portions of 10 CFR 50 Appendix B criteria were invoked on the subcon-tractor.
The only objective evidence that indicated that any Quality Assurance Criteria were applied to this subcontract was two Bechtel Quality Control Inspection Documents (PQCI #8031/SC-1.09, Revision
" Installation of Masonry Walls" and PQCI #8031/R-1.40, Rev. 2 -
" Receiving and Testing Concrete Masonry Materials").
Bechtel was performing the inspection function for this subcontractor.
The inspector spent several hours with the Bechtel QC Engineer witnessing the inspec-tions he performed on various masonry walls being erected, in accordance with the Bechtel Inspection Procedure PQCI #8031/SC-1.09.
No items of noncompliance were identified during the witnessing of Bechtel's performance of these inspections.
In other safety related type of work accomplished by subcontractors such as vessel internals, control rod drive installations, erection of fuel pools, erection of heating and ventilation system, etc.
Bechtel invoked in the subcontract their " General Project Requirements for Supplier QA" (8031-G-13) which addresses all 18 criteria of 10 CFR 50 Appendix B.
The inspector informed the licensee that the failure to invoke a documented QA program for the subcontractor performing work under subcontract 8031-A-2A entitled " Masonry for the Limerick Generating Station" was contrary to Criterion I of Appendix B of 10 CFR 50.
(352/79-12-02).
11. Safety Related Pipe Hanger Installation (Unit 1)
a.
Installation Activities The inspector witnessed the installation of hanger GBB-ll2-H10 (core spray) to verify installation per-drawing requirements.
During this inspection, the inspector noticed that a blue colored loose leaf book which had several hanger drawings (81s x 11" size) was being used by
,
l the crafts for this hanger installation.
The inspector then selected i
several drawings from the book including the one being used (GBB-ll2-
'
H10, Rev. 2), to verify if they were current with Bechtel's register of drawings. The following are the results of this verificatio.
.
.
,
' Book Drawing and Revision Current Revision Per Register GBB-ll2-H10, Rev. 2*
Rev. 3
,
GBB-ll2-H17, Rev. 4 Rev. 4 HCD-107-H12, Rev. 1 Rev. 1 HCD-107-H13, Rev. 4 Rev. 4 HCD-107-H14, Rev. 1 Rev. 1 HCD-107-H15, Rev.1 Rev. 1 HCD-107-H35, Rev. O Rev. O GBB-112-H9, Rev. 4*
Rev. 5 GBB-112-H8, Rev. 3*
Rev. 4 HBB-120-H13, Rev. 4 Rev. 4 HBB-120-H16, Rev. 2 Rev. 2 HBB-120-H29, Rev. O Rev. O I
HBB-118-H71, Rev. O Rev. 0
- 0bsolete Drawing in Book.
An investigation by the inspector found that the book belonged to the hanger foreman and it was uncontrolled, that is, Bechtel's document control group was unaware of its existance. The inspector informed the licensee that this was contrary to Criterion V of 10 CFR 50 Appendix B and Bechtel's Job Rule G-5 requirements.
(352/79-12-03)
b.
Completed Work
.
The inspector randomly selected four completed safety related pipe supports to determine that they were installed per drawing requirements.
The following are the hangers selected and the results of the inspection:
,
___
s
,
,
.
,
f (1) Hanger HBB-120-H17
In one of the connector pin (Bergen-Paterson Drawing 64161) the cotter pin holes which are located at ',he ends of connector pins
were not in accordance with the drawing requirements. The edge
+
distance did not meet the minimum dimension as specified on the drawing #64161.
(2) Hanger GBB-112-H2O A similar condition as hanger HBB-120-H17 above.
(3) Hanger GBB-ll2-H2 The connector p.n adjacent to the pipe clamp was not long enough.
The pin was installed with only one cotter pin.
The other end of the pin did not protrude beyond the mating clevis support, therefore, a cotter pin could not be installed to lock the connector pin in place.
(4) Har.ger GBB-ll2-H24 One of the lock nuts on the pipe clamp had insufficient thread engagement. Approximately two full threads of nuts were engaged.
When the licensee was informed of this, an in process rework
notice No. P-791 dated November 16, 1979 was presented to the inspector which indicated that the Bechtel QC inspector had reported this condition prior to the NRC inspector's finding.
Corrective action has been initiated by the use of the "in process rework notice" as described in Bechtel's Job Rule Procedure.
,
During the above inspection, the inspector also noticed a pipe support connector pin Jn a tool box. The connector had an abnorral appearance.
'
There were hand file marks, the cotter pin holes were not drilled properly and the edge distance was not per Bergen-Paterson Drawing 64161. This particular pin was not identified for any particular hanger. The inspector took the pin to a licensee representative and infomed him that he suspected that some hanger connector pins were being fabricated at the site and that the pins suppliad by the hanger
'
vender were not being used. The licensee took this sample pin and had it metallurgically examined to determine the type of material. The results of the test indicated that the material was ASTM A36 (Note: A minimum yield strength of 36,000 psi is required by the ASTM Standard).
,
The Bergen-Paterson drawing specifies that the material shall be ASTM 193 Grade B7.
(Note: A minimum yield strength of 105,000 psi is
.
-
__
.
.
.
,
required by the ASTM Standard). The licensee subsequently obtained connector pins from 4 more hangers (HBB-119-H12, HBB-120-H17, GBB-112-H2O and GBB-112-H2) to test. The results of this examination are as follows:
Hanger HBB-119-H12 - All pin materials (per Drawing) ASTM 193
--
Hanger HBB-112-H2O - Two pins were ASTM 36 material
--
Two pins wcre ASTM 193 Hanger GBB-112-H2 - All pin materials (per Drawing) ASTM 193
--
Hanger GBB-112-H17 - All pin (two) ran:*ials not per drawing
--
(ASTM A36)
In accordance with Bechtel Job Rule #M17, Sections 4.7 and 5.5.4, the area engineer is responsible to inspect hanger prior to and after installation to verify installation was per design requirements and if not, a field change request shall be initiated. There was no objec-tive evidence that a field change request had been initiated as would be required by the Job Rule. Although a subsequent inspection of these hangers by QC was required, that inspection was not required to identify the materials of the pins.
The licensee was informed that this is contrary to Criterion V of 10 CFR 50 Appendix B and that their response to the item of noncompliance should address what their actions will be to assure that all safety related hangers have the proper pin material and that they meet the dimension requirements as delineated in vendor's hanger drawings.
(352/79-12-04)
12. Raceway Installation (Unit 1)
Tre inspector selected the following raceways and supports to determine that the applicable drawing and specification requirements were being met:
Applicable Raceway Identified Location Drawing and Spec IACMA08 (cable tray)
EL244 & E21 E-1117 & E-1406 & E-49 IAD006 (conduit)
EL244 & E21 E-1117 & E-1406 i
IAD003(conduit)
EL244 & E21 E-1117 & E-1406
i
1
.
-. - -
- -,
s
O
During the above inspection, the inspector noted that the drawing called for conduit IAD006 to be 4" rigid steel, however, what was installed was 5" rigid steel. Bechtel issued _a field change request No. E-3379F to revise the drawing to agree with installation.
'
No items of noncompliance were identified.
13.
Exit Interview 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.