IR 05000352/1980003
| ML19320D316 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/21/1980 |
| From: | Finkel A, Mattia J, Mcgaughy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19320D291 | List: |
| References | |
| 50-352-80-03, 50-352-80-3, 50-353-80-03, 50-353-80-3, NUDOCS 8007210240 | |
| Download: ML19320D316 (15) | |
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U.S. NUCLEAR REGULATORY COMMISSION-(
.0FFICE OF INSPECTION AND ENFORCEMENT Region I 50-352/80-03 Report No.50-353/80-03 50-352 Docket No.50-353 CPPR-106 License No. CPPR-107 Priority Category A
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Licensee:
Philadelphia Electric Co.
2301 Market St.
Philadelphia, Pa.19101 Facility Name:
Limerick Generating Station, Units 1 & 2 Inspection at:
Limerick, Pa.
Inspection conducted: Feb. 25 - Mar. 25, 1980
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Inspectors:
tl.L. Mattia, penior Kesidenc inspector date signed f
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A. Finkel, Realtor Inspector
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//W Approved by:
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R.W. McGaugbyy;CEjef Projects Section,
' dafe signed Reactor Construction and Engineering Support Branch Inspection Summary:
Unit 1 Inspection on Feb. 25 - Mar. 25, 1980 (Report No.
50-352/80-03)
Areas Inspected:
Routine inspection by the Resident Inspector and a regional based inspector of wc.'k activities relative to:
Installation and welding of reactor coolant pressure boundary and other piping; electrical activitica associated with pulling of cable, terminating and. storage of equipment. The inspectors also performed plant tours and reviewed licensee action on previously identified items. The inspection involved 61 inspector hours, including 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> during off-shift, by two NRC Inspectors.
Results: Of the four areas inspected, no items of noncompliance were identified in-three areas; one apparent item of noncompliance was identified in one area.
(Deficiency - Failure to preheat weld joint prior to welding - paragraph 7.)
Region I Form 12 (Rev. April 77)
8007210)/0
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Unit 2 Inspection on Feb. 25 - Mar. 25,1980 (Report No. 50-353/80-03 Areas Inspected: -The resident inspector performed plant tours and reviewed licensee action on previously identified items. The regional based inspector perfomed inspections for safety related electrical activities. The inspection involved 12 inspector hours by two NRC inspectors.
Results:
No items of noncompliance were identified.
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DETAILS 1.
Persons Contacted
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Philadelphia Electric Company Note D. Clohecy, QA Engineer J. Corcoran, Field QA Branch Head 1,2,3,4 D. Dipaolo, QA Engineer 2,4 F. Gloeckler, QA Engineer 3,4 J. Fedick, Construction Engineer
G. Lauderback, QA Engineer 1,3 D. Marascio, QA En~gineer P. Naugle, Construction Engineer
R. Scott, Lead Coristruction Engineer
H. Walters, QA Manager
R. Zong, Senior Metallurgical Engineer
Bechtel Corporation T. Altum, Lead Welding Engineer 2,4 C. Berezich, Lead Subcontracts Engineer 2,4 L. Campbell, Field Weld Engineer
R. Chmielewski, Subcontracts Engineer
J. Curci, QA Engineer 1,2,4 B. Dragon, QA Engineer 2,4 P. Dunn, QA Engineer 1,2,4 J. Fallon, Assistant Project Field QC Engineer 1,2,3 H. Foster, Project Field QC Engineer 3,4 J. Gwin, Project Superintendent 1,3 G. Kelly, QA Engineer 1,2,4 E. Klossin, Project QA Engineer 1,3,4 R. Lanemann, Lead Electrical Superintendent
R. Leingang, Assistant Project Field Engineer
J. Martin, QA Engineer
W. Nastiuk, QC Engineer
J. Ruud, QA Engineer 1,2 D. Shaw, Electrical Staff
T. Stidham, Procurement 1,2,3 M. Tokolics, QA Engineer 1,2,4 A. Weedman, Project Field Engineer 1,2,3,4
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General Electric Corporation
' Note W. N,al, Resident Site Manager
Nuclear Energy Services S. Conraa, NDT Technician
S. Dietrich, NDT Site Superintendent
Notes 1 - Denotes those present at exit interview conduct'ed on Feb. 29, 1980 2 - Denotes those present at exit interview conducted on Mar. 7,1980 3 - Denotes those present at exit interview conducted on Mar. 20, 1980 4 - Denotes those present at exit interview conducted on Mar. 27, 1980
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2.
Piant Tour - Units 1 & 2
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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 noncompliance with regulatory requir ments or license conditions.
Particular note was taken of presence of 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.
Electrical Switchgear (Units 1 & 2)
a.
Installation The inspector examined the installation and documentation for the following listed equipment:
D13 Safeguard Bus 10All7 4160 volts
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D134 Safeguard MCC 10B223ZC 440 volts
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D14 Safeguard Bus 10All8 4160 volts
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D144 Safeguard MCC 10B224ZC
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D114 Safeguard Load Center 10B201 and transformer 10X201
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D124 Safeguard Load Center 108202 and transformer 10X202
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With the exception of Dll4 and D124, the above equipme.it was welded in place, equipment heaters operating and cove.ed with a fire retardent material. During this inspection the D114 and D124 equipment was being welded in place.
The inspector verified that the above equipment was in the desig-
nated location and separated as required by the PSAR and engineering drawing (E1406).
b.
Documentation
The listed documentation was reviewed and examined by the inspector to ascertain whether requirements of applicable specifications, work procedures, job rules and inspection procedures are being or have been accomplished in the following areas for the electrical equipment identified above.
Storage control, equipment location, and missile protectic,n
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and separation
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Protection aid cleanliness preservation during and after
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installation Work and inspection procedure revision control.
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The inspector examined the following documentation associated with
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the above listed areas:
Job Rule (JR)-G-7 Storage Maintenance of In Plant Maintenance
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. of Installed Equipment Revision 17, dated March 21, 1979, i
Job Rule (JR)-G-ll Jobsite Housekeeping and Cleanliness Control,
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Revision 9, dated September 18, 1979,
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Quality Control Inspection Records (QCIR) M-121-10B202-1,
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M-121-10B201-1, M-ll7-108217-1, M-119-10B224-1 and M-119-108223-1 The electrical equipment such as feed oceakers, supply breakers, motor starters, etc. are stored at the licenseets warehouse. The switchgear is stored in place and protected,.but without the components and cables connected at this time.
The inspector determined that the quality control personnel associ-
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ated with the inspection of the electrical equipment were adequately trained for the activities assigned to them.
No items of noncompliance were identified.
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4.
Electrical Components and Systems Quality Records a.
Receipt and Installation (Units 1 & 2)
The inspector reviewed the quality control instructions (QCI's)
which reference the requirements of E1406 entitled " Conduit and Cable Tray Notes, Symbols and Details" for installation of electrical cables and installation of raceway.
The inspector ascertai -d that QCI E-4D entitled " Installation of Electrical Cables,, _ted February 19, 1980, Revision 5 and QCI E-20 entitled
" Installation of Exposed Raceway", dated February 19, 1980, Revision 5 reflected the engineering requirements of E1406.
The inspector verified that the 4160 volt switchgear, 440 volt motor control centers and load centers complied with the QCIR requirements and the engineering requirement of E1406.
See paragraph 3 above. As identified in paragraph 3 above, the breakers and other related electrical components for these switchgear are in warehouse storage.
b.
QA Audits and Nonconformance Records The inspector randomly selected the following electrical equipment audits performed by the licensee during the 1979 year for Units 1 & 2.
Audit Report E-025 entitled " Safeguard 4KV Switchgear", dated
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April 6,1979. This audit was performed to determine that adequate stcrage and maintenance requirements were being complied with on Safeguard 4KV Switchgear.
Audit Report E-018, entitled " Power Generation Control
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Complex", dated August 14, 1978 through February 12, 1979.
This audit covered the receiving, installation and maintenance of the equipment.
Audit Report E-34 entitled " Safeguard L.C. Transformers",
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dated August 28, 1979 to September 12, 1979. This audit was performed to detennine that adequate storage and maintenance requirements were being complied with on Safeguard Load Center transformer stored at the Limerick site; and Audit Report E-037 entitled " Motor Control Centers", dated
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November 1,1979 to December 15, 1979. This audit was performed to determine compliance of the quality control records with the requirements of Specification 8031-E-ll for Class lE Motor Control Centers.
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The audits were in accordance with the licensee's audit procedure, the audit reports were sent to management and the identified nonconformances were recorded and ciosed in a timely manner.
The inspector randomly selected 10 Finding Reports to verify completeness of finding, recommendation and close.out action.
The ten selected Finding Reports identified the finding, listed the recommended action and were verified by quality assurance.
No items of noncompliance were identified.
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Electrical Cables ard Termination Procedures Procedure Review (Units 1 & 2)
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The inspector reviewed the following cable, raceway and termination procedures to assure that the activities of receipt, handling and installation, identification, inspection and testing, separation, protection, raceway loading and redundancy and separation are identi-fied and performed according to the licensee's engineering require-ments.
Job Rule (JR)-E-2 entitled " Electrical Field Raceway
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Reporting System", Revision 3, dated August 31, 1979; Job Rule (JR)-E-10 entitled, " Permanent Plant Cable
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Installation and Termination", Revision 1, dated February 4, 1980;
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Engineering Drawing E-1406 entitled " Conduit and Cable
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Tray Notes, Symbols and Details";
Quality Control Instruction (QCI) E-2.0 entitled, " Installation
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of Exposed Raceway", dated February 19, 1980, Revision 5 and, Quality Control Instruction (QCI) E-4.0 entitled " Installation
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of Electrical Cables", dated February 19, 1980, Revision 5.
The inspector verified that the PSAR requirements are reflected in the engineering drawing E-1406 and the referenced Job Rules and QCI's.
It was noted that the quality control inspector will verify the procedures beirig used and the revision number.
In discussions with the quality control personnel, the inspector verified that they were inspecting to the latest issued revision of the document.
No items of noacompliance were identified.
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Installation of Electrical Cables (Unit 1)
-The inspector obser'
-he installation of the safety-related power cables from the Dl,
. 014 Safeguard Switchgear to the 1A and IB Drywell Chillers. The inspector verified that the conduits were inspected prior to the cable pull and that the seismic supports on the raceways were verified and torqued to specification requirements.
The torque requirements and the tool number used by QC inspection to verify the values were recorded in the Tool Check-Out Logbook maintained in the quality control files.
During the cable pull the inspector verified that the quality control personnel were knowledgeable of the requirements specified in E-1406 and QCI's E-4.0 and E-2.0.
The inspector verified that the latest revision of E-1406 was reflected in the QCI's E-4.0 and E-2.0.
At the completion of the cable pulls, the cable 1DA118080 (lB Drywell Chiller 1BKil) and cable ICAll708A (lA Drywell Chiller lAKil)
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were sealed and supported off the ground.
The inspector verified that one end of the cable was terminated to D13 Safeguard Switchgear in accordance with E-1406 requirements.
No items of noncompliance were identified.
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d 7.. Reactor Coolant Pressure Boundary (RCPB) Work Activities (Unit 1)
The inspector observed the following work activities being performed inside the containment to verify compliance with regulatory, code, standards and applicable design documents:
a.
Reactor Pressure Vessel Safe End Replacement Observed the liquid penetrant examination of feedwater
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safe end weld joint at azimuth 3300 verified that NDT technician was qualified in accordance with GE procedure.
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Observed the machining of feedwater nozzle of weld
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0 and 210.
preparations located at azimuths 30 Observed the grinding of an indication in the safe end weld
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joint located at azimuth 90.
The indication was found during ultrasonic examination. The prior radiography did not reveal this unacceptable indication.
Witnessed etching of area on reactor pressure vessel nozzle
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(N2A) in accordance with GE Field Deviation Disposition Request HH1-297. The etching was done to determine that the heat affected zone caused by arc strikes were totally removed by the grine:ng.
Witnessed ultrasonic testing of completed reactor recirculation
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safe end weld located at azimuth 2700 in accordance with GE Procedure SRSEl-10. Reviewed calibration data prior to testing. Verified calibration of equipment (Branson 303-Serial #1176203) and reviewed qualifications of Level I and II examiners.
No items of noncompliance were identified for the above activities.
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RCP8 Pipe Restraint ~ Work Activities
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Observed the welding activities for pipe restraint (PR-239) which was about to be welded this particular morning in accordance with'.the requirements of weld procedure PI-A-LH(STR)/2 and drawing C-940.
The inspector questioned the weldor if he preheated the weld joint
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prior to welding. The, ins'pector was_ informed that he did not, nor was there any evidence in the immediate area of heating equipment (burnerandgashoses). The requirement for this weld joint (thickness 1 ") is a minimum preheat of 700 Temperature in contain-ment. ranged between 60-630F. The inspector informed the licensee that this failure to maintain the minimum preheat in accordance with
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. the welding procedure was an item of noncompliance (352/80-03-01),
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Reictor Recirculation Work Activities
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Observed the cleaning of reactor recirculation pump l
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bowl using acetone as the cleaning agent.
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Observed the preparing of two reactor recirculation weld
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ends on a pipe spool prior to welding. Also verified that the files being used were stainless steel.
Inspected final weld on reactor recirculation pump
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discharge, 28" diameter,1.285" wall thickness.
Weld joint identification is BWRPD-lREC-k.
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~ flo items of noncompliance were identified for the above activities.
d.
Liquid Penetrant Examination Observed the liquid penetrant (LP) examination of penetratica X -40C instrument lines (FJ-DCA-303-I9/3) after hydrostatic testing. The connections'were examined in accordance with LP procedure PT-SR-l.
The inspector also examined the qualifications of the Level II examiner..No items of no'icompliance were identified.
8.
Qualification of Preservice Inspection Subcontractors NDE Examiners (Unit 1&2)
During an inspection of another nuclear construction site, it was determined that the same subcontractor that was performing preservice examination of ~ safety-related piping at Limerick in accordance with the ASME Section XI' code had inadvertently let their Level III examiner 3s certification expire on 10/24/79. The NRC inspector examined the qualification records of-all the subcontractor's' examiners who performed examinations after 10/24/79 to determine that _they were properly certified by a Level III examiner with an appropriate certification. Currently there are only two i
.NDE examiners, a Level I and II on site. They were both certified by
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the Level III examiner prior to his expiration date.
The inspector also verified that they met all the SNT-TC-1A requirements for certification.
No items of noncompliance were identified.
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Cracking of Welds in Reactor Recirculation Pipe Restraints (Unit 1)
The inspector reviewed nonconformance report (NCR) No. 4018 which involved the cracking of weld joints during the welding of a reactor recirculation pipe restraint, located at azimuth 00 and elevation 278.
This restraint was being welded to an embed in the biological shield and this is the second restraint that has cracked during welding (see unresolved item in inspection Report 352/79-11). The licensee was informed that the NCR did not evaluate the possible cause for the cracking and that the NRC inspector is corcerned that the final welds on these particular type of restraints uo not receive a non-
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destructive examination (liquid penetrant or magnetic particle exam-ination). This item is considered unresolved pending review of licensee's evaluation as to the cause of cracking and their decision on performing NDE other than visual for these restraints (352/80-03-02)..
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10. Licensee Action on Previous Inspection Findings j
i (0 pen) unresolved item (352/79-11-02):
the inspector reviewed the status of the licensee's evaluation of the cause as of the cracking of pipe restra' int weld.
The following memoranda or letters were viewed:
Licensee QA organization's memo dated Oct. 22, 1979 to their
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engineering division requesting they evaluate that liquid penetrant
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(LP) or magnetic particle (MP) examination be performed on reactor recirculation restraint based upon the complex welding and cracking of welds.
Licensee's memo dated Jan. 23, 1980 concluded that LP or MP is not
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required due to cracking caused by improper weld sequencing.
On Feb. 19, 1980 the licensee's QA organization issued a memo to
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their engineering division to re-evaluate the need for LP or MP of the completed restraint weld joints due to another reactor recirculation restraint cracking, whereby the proper weld sequence was used.
Bechtel letter dated Nov. 8,1979 evaluating the cause of cracking;
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The conclusion drawn was improper weld sequencing.
Bechtel field memo, dated 10/29/79 was an evaluation as to cause
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of weld cracking. The conclusion drawn was improper weld sequencing was used by the weldor.
This item is considered still open pending review of the licensee's engineering reply to their QA organization's memo dated Feb. 19, 1980.
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(Closed) unresolved item (352/78-06-02):
the inspector reviewed the revised Job Rule M-17 (Revision 2) to verify that an acceptance criteria for rusting of hanger was delineated.
The inspector also verified that the hanger vendor's storage criteria for acceptable rusting was incorporated in the job rule. The inspector verified that the revised maintenance requirements were incorporated on the periodic maintenance cards for the hangers. The rusting pipe support HBB-118-H53 found during inspection 352/78-06 was inspected by Bechtel to the acceptance criteria in the Job Rule M-17 and was found to be acceptable.
This item is considered resolved.
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(Closed) noncompliance (352/78-11-03 and 353/78-07-01):
The untreated
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(undecanted) waste waters were pumped from within the coffer dam surrounding the intake structure and also from the cooling tower blowdown water diffuser trench into the Schuylkill River. The inspector visited both these areas and found that the activities that caused the pumping of waste water no longer exist and there was no waste water being pumped at either location.
The PEC0 finding report N-142 was reviewed to verify that immediate corrective action was taken and also verified by the licensee QA organization.
This item is considered closed.
(Closed) unresolved item (35-2/78-11-02 & 353/78-07-02): The inspector verified that excavated material from the cooling tower blowdown pipe trench was removed from the banks of Possum lMllow Run and that the bales of hay were placed on the bank of Possum Hollow Run to prevent erosion and minimize run off.
This item is considered resolved.
(0 pen) inspector followup item (352/78-11-03 & 353/78-07-03):
The inspector examined the areas east and west of Long View Road and noted that some areas were graded and seeded. There are still some active areas for depositing spoils adjacent to east and west of Long View Road.
This item will be re-examined at a subsequent inspection.
(Closed) unresolved item (352/79-11-01):
The antractor had mitered an end of a GE supplied pipe without prior approval from GE.
The inspector reviewed the following documents relative to this item:
PEC0 finding Report P-285 concerning this matter and the
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acceptable resolution of this item.
Bechtel Inprocess Rework Notice No. P-726 for mitering of weld joint.
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Documentation for rework in accordance with GE field deviation dispo-
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sition Request HHI-219.
This item is considered resolved.
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(Closed) unresolved item (352/78-05-01). NRC (Office of Inspection and Enforcement and Office of Nuclear Reactor Regulation) reviewed the-licensee's final report and supplementary data for the repor+ad deficiency of the seismic gap between the containment and the re tor enclosure being less than the PSAR commitment.
The NRC review found it to be acceptable. This item is considared resolved.
(Closed)
item of noncompliance (352/79-11-06). The corrective action taken for the improper storage of the 4kv switchgear #10All7 during the erection of block walls was reviewed.
The inspector had difficulty finding any objective evidence in the form of a Bechtel or PECO inspec-tion, auditor surveillance report that the inside of switchgear was inspected for detrimental cement dust in switches, relays or contacts.
The cognizant licensee QA engineer and the NRC inspector inspected the inside of the cabinet and also the various components inside switchgear 10All7, and found it to be clean and satisfactory.
(Closed) unresolved item (352/80-02-09):
the inspector witnessed the ultrasonic measuring of the gouged area located inside reactor recircu-lation valve M0-F031-8. The UT measurement was performed by a General Electric Level III NDE technician.
The required minimum wall thickness for this area is 2 inches.
The gouged area measured between 3.4 - 3.6 inches. The details of this wall thickness measurement is documented in licensee's QA surveillance check Report M-279.
This item is considered res61ved.
11.
Power Generation Control Complex (PGCC) Units 1 & 2 The ins,,ector reviewed the results of sample testing (approximately 8%
of total) of the PGCC connectors which were tested in accordance with GE. procedure #TNDS (revision 0). The total number of connectors in Unit 1 are 2023 and 1901 in Unit 2.
The amount of connectors tested in Unit 1 were 224 and 217 in Unit 2.
The Unit 1 failure rate was 0.255%
and 0.860% for Unit 2.
The acceptable failure rate (0.65%) was exceeded in Unit 2 and therefor all the connectors (1901) for the Unit 2 PGCC will have to be tested.
During the review of the test data sheets the inspector observed that there were several " observed condition notices" (0CN) referenced. These documents (OCN) are issued for non-confc ming conditions found during testing or inspections in ~ac'ordance wich GE Procedure #LNS-3, Revision 1.
A review of the log being kept by GE on OCNS issued the inspector noted that to date (3/17/80) 190 have been issued (note:
not all are safety related items) and only 16 have been dispositioned.
Some of these OCNS were issued as far back as Aug. 22, 1979. The licensee was informed that this backlog of OCN without dispositions can be detrimental to the proper functioning of the QA program and that this item will be inspected during a subsequent inspection.
(352/80-03-03 and 353/80-03-01)
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12.
Preservice Inspection (Unit -1)
a.
The inspector observed ultrasonic calibration and examination being
. performed by the subcontractor in accordance with his procedures
. 80A1565, Rev. 4 and 80A1566, Rev. 2 for a primary steam joint (MSA-015). This UT examination is to be used for the ASME Section XI baseline for piping welds.
During this calibration and UT examination two discrepancies were noted with the subcontractors Procedure #80A1566, which are as follows:
i 1) Section 6.2.3 states in part tbt the examiner shall refer to the individual "T" map for each weld when scanning.
There are no "T" maps for each Limerick weld to be inspected for the baseline. The subcontractor stated this procedure is their generic procedure with modifications made to suit the Limerick plant.
It appears that this item was missed during
the review and the subcontractor stated it will be revised.
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2) Table I and Figure I doesn't list the calibration standard (identified as LIM 26-1.013CS) used by the subcontractor for the primary steam weld Joints. The subcontractor stated that the procedure will be revised to add this calibration standard.
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The above items are considered unresolved pending review by the inspector of the changes to the procedure (352/80-03-04).
b.
The licensee is providing the second level of review for monitoring the subcontractor's implementation of his QA program.
Bechtel only j
provides the administration of the subcontractor's contract. The
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inspector reviewed a sample of licensee's past audits or surveillances performed'in 1979 (there were none for 1980).
(Surveillance M-233, Audit M-181 and Audit M-182). The inspector informed the licensee that a review of. subcontractor's records indicated that 127 ultrasonic examinations were performed in 1980 (1/2 - 3/26/80) and that PECO
had not performed'any surveillances or audits, nor were there any scheduled in the near future (coggizant QA engineer schedule was up to week ending April 18,1980). The licensee stated that the PECO has met their comitments and the Site Audit Program schedule (current issue was dated 3/26/80) will be revised to inc. ease surveillance or audits based upon sut, contractor's activities. This item is consid-ered unresolved pending review of revised schedule (352/80-03-05).
13. Meeting Between Local Officials and U.S. Nuclear Regulatory Commission A meeting was held on March 18, 1980 between US NRC personnel and local
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officials representing the Boroughs of Phoenixville, Boyertown and Spring City to introduce the NRC senior resident inspector for construction at the Limerick facility,' describe the NRC organization and its inspection program. Also a question and answer session was held during this meeting.
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14. Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items. ite s of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in paragraphs 9,11,12,..
15.
Exit Interviews
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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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