IR 05000352/1980004
| ML19337A189 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/06/1980 |
| From: | Chaudhary S, Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19337A186 | List: |
| References | |
| 50-352-80-04, 50-352-80-4, 50-353-80-04, 50-353-80-4, NUDOCS 8009090232 | |
| Download: ML19337A189 (7) | |
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_-U.S.~ NUCLEAR REGULATORY COMMISSION
,0FFICE OF INSPECTION-AND ENFORCEMENT-
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Region I
'50-352/80-04.
Report No.- 50-353/80-04 50-352 Docket No.- 50-353
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-CPPR-106-Category A'
- License No. CPPR-107 Priority
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Licensee:
Philadelphia Electric Company 2301 Market-Street-
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Philadelphia, PA.
19101 Facility Name:
Limerick Generating St'ation, Units 1 and 2 Inspection ~at:
Limerick, PA.'
Inspection conducted:
March 19-21, 1980 April 2-4, 1980 Inspectors: NaSikvW 5/22/8o S. - K.; Chaudhary,' Rea~ctor Inspector
'date signed S. D. Ebneter. Chief. Engineering Support Section No. 2 date signed date signed Approved by:
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'[M[80-Support Section No. _2,. RC&ES Branch
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date signed-S. D. Ebneter, Chief, Engineering
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Inspectica Summary:
Units 1 and-2, Inspection on March 19, 20, 21, April 2, 3, 4,-1980 (Combined Inspection Report-Nos. 50-352/80-04 and 50-353/80-04)
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Areas-Inspected: _ Routine unannounced -inspection by a regional based -inspector
.ofswork activity and records associated with Nonconformance trend, control of-Nonconformances, and control of Field-Change Requests.
The inspection involved 48 inspector-hours onsite_by one regional based inspector and 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />s-by one supervisor.-
Results: No. item of noncompliance was11dentified.
However, one item of apparent-deviation'was identified-failure to meet the PSAR commitment for concrete strength in
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28 day tempression tests;- paragraph 5.
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P 3 Region)It Form -12'
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(Rev. AprilL77)
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8,009 0' 9 0 2.32 <
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DETAILS i
1.
Persons Contacted Philaoelphia Electric Company (PECO)
- G. Lauderback, QA Engineer
- A. McLean, Construction Engineer H. Walters, QA Manager
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Bechtel Corporation (Bechtel)
- H. Foster, Project Field QC Engineer
- J. Fallon, Asst. Project Field QC Engineer
- E. Klossin, Project QA Engin(er.
- A. Leingang, Asst. Project Field ingineer
- T. Stidham, Procurement
- W. Tate, Lead Civil Staff Engineer
- P. Dunn, QA Engineer
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- M. Tokolics, QA Engineer
- J. Curci, QA Engineer
- G. Kelly, QA Engineer
- H. Weednam, Project Field Engineer B. Pandit, Civil Engineer M. Iyer, Resident Engineer U.S. Nuclear Regulatory Commission (NRC)
- J. Mattia, Res'ident Reactor Inspector
- Denotes. personnel attending exit interview.
2.
Review of Quality Assurance Reports (OARS)
l The inspector reviewed the system of QARs as used by Bechtel site QA organization. The following documents were reviewed by the inspector:
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Quality Assurance Activity Report No.193, for the month of February 1980, issued on 3/10/80.
QA Master _ Audit Plan, Rev. 13.
QAR-63, Covering nonconformances in concrete, issued 7/16/76 - closed
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6/9/77.
QAR-128, for Welding nonconformances.
QAR-143, for Material Traceability.
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Based on the review of above documents, the' inspector's observations
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'are as follows:
QAR-143 was issued in Decemoer, 1979, requiring a response in 60 days.
However, there was no response received from the Project. Construction Manager by March 20, 1980.. Bechtel's Project QA Engineer informed the
' inspector that the response was-in typing, and would be received in a
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day or two. A response to.QAR-143 was received by Bechtel QA while the inspector was on site, and was verified by the inspector on March 21, 1980.:
The inspector.also verified that the constructor's QA department.
.. tracks the open QARs, and this information.is transmitted to construction and project management on a monthly schedule via Quality Assurance Activity reports.
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The inspector' observed that th'e QARs were initiated to fla'g any noncon-foming trend in the-QA program.
No item of noncompliance was identified.
3.
Nonconformance Trends
.The inspector reviewed the nonconformance trends.as developed and analyzed by the constructor's QA organization.
The areas of activity
=for trending was selected by the Project QA Engineer.
The inspector examined and reviewed the'following doc 0ments:
The procedure for NCR trend analysis--no unique identification number was' assigned to.this procedure.
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Compilation.of NRC trends in the areas of:
Welding Materia 1' Traceability Nonconformances in D-Mix of Concrete'
Based on the review of above documents the inspector observed the
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following:
The _ procedure for NCR trending was not uniquely identified, and there l
was no evidence showing the'date of approval and/or implementation of-this: procedure. The inspector was informed that the procedure was in-effect'from 1976.
j, The NCRs in different areas of activity had been tabulated for any indication'of trend from the' year 1976.
!QARs had been initiated to inform management of NRC trends.
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'No item of noncompliance was identified -in this area.
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4.
Review of NCRs The inspector' initiated a review of NCRs which had been dispositioned and closed. The NCRs spanned a period of approximately fifty months, from June 1975 to August 1979. -The NCRs were examined and reviewed for procedural conformance, and relevancy and technical adequacy of disposition.
l The inspector observed that approximately seventy four NCRs were initiated for failure to attain specified strength in twenty eight days. However, in most cases, additional comparison test specimens were tested at a later date to determine the strength (56 to 90 days),
generally at ninety. days. The test specimens exhibited a strength of five thousand psi or more, and were considered acceptable by the project engineering.
In some cases where the additional test did not show that the concrete had attained 5000 psi strength, the matter was properly evaluated by project engineering-against the criteria of actual strength. requirement of the structure.
However, the inspector noticed that two NCRs (Nos. 1482 and 1533) per-taining to a wall in control building showed two different strength requirements for the same wall. The design calculations referenced in the NCR dispositions were not available on site.
The inspector requested more information to resolve this apparent disparity of strength requirements of the wall in question. The licensee obtained the requested information from his A/E and presented this information to the inspector for review. After review of additional information and discussions with licensee and his A/E personnel the strength requirement disparity was still unresolved. At this point the licensee indicated that there was a possibility of incorrect disposition on one or the other NCR, and the licensee will try to resolve this matter by further information and discussions with his A/E, and inform the inspector of his effort.
In a subsequent telephone call.to the inspector a licensee engineer notified the inspector that the disparity of requirement has been resolved. The additional information developed and analyzed by licensee will be reviewed by the inspector in a subsequent. inspection to resolve this matter.
(80-04-01)
This item is unresolved.
5.
Compressive Strength of D-Mix Concrete in 28 Days During the review of NCR trends,: the inspector noted a compilation of NCRs initiated for D-Mix concrete for failure to meet the specified strength criterion in 28 days. There were seventeen (17) NCRs initiated within a period of August 4,1978 to January 3,1979.
Following this trend the inspector initiated a review of records for D-Mix of concrete.
The following records were reviewed by the inspector:
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Philadelphia Electric Company letter to Mr. Edson G. Case, Acting Director, Office of Nuclear Reactor Regulation, dated April 19, 1977 with attachment A.
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U.S. Nuclear Regulatory Commission letter to Philadelphia Electric Company to the attention.of Mr. Edward G. Bauer, Jr., Vice President and. General Counsel, dated August 5, 1977.
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Bechtel Power Corporation, Inter 0ffice Memorandum FME-2941, dated July 25, 1978.
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Bechtel Power Corporation memorandum EMF-3739, dated August 9, 1978.
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SAR change notice, Bechtel Serial No. 5-86, dated February 16, 1979.
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Bechtel Specification for Concrete, 8031-C-61, Furnishing and Delivery of On-Site Concrete.
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Chronological Sequence of D-1 concrete mix design and related data covering a period of 3-4-74 to 6-4-76 (not dated).
The inspector's; observations as a result of the above records review are as follows:
The licensee submitted to the NRC a proposed change in its SAR comitment as Amendment No. 22.
In the proposed amendment the licensee indicated that in the production of high strength concrete, the licensee had not always been able to attain the specified compressive strengh in twenty eight (28) days. Therefore, it was proposed the criterion of acceptance for such concrete be changed to meet.the specific strength in ninety days instead of the twenty eight (28) days as required by ACI 318-71.
The response from NRC dated August 5, 1977 to the licensee stated that the proposed change in acceptance criterion for concrete strength was not acceptable to NRC.
It was NRC's position that the twenty eight
day strength should be used because it is a conservative estimate of the ultimate concrete strength.
i The licensee did not take any further action to obtain relief from the
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28 day requirement.
In July,.1978 Bechtel field engineering sent a memorandum (FME-2941)
to project engineering expressing concern over the adequacy of concrete mix design D-1H and D-2G.
The memo requested immediate action to alleviate this recurring problem.
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l In August,1978 the project engineering response (EMF-3789) to field
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engineering regarding the problem with D-Mixes acknowledged that the problem of D-Mixes attaining required compressive strength in twenty eight days. The project engineering did not intend to initiate any corrective action but advised the field engineering to transmit NCRs to project engineering for resolution.
The SAR change notice issued by Bechtel on February 16, 1979, and approved by PECO on March 8,1979 stated that exceptions taken to ACI 318-71 (PSAR Amendment No. 22) were not approved by the NRC, therefore, Section 5.2.5.2.1(b), items 6 and 7, on page 5.2-16 of PSAR required deletion.
It also stated that it was not necessary to notify the NRC.
The applicable specification for concrete 8031-C-61" indicated that the acceptance criteria for concrete strength to be in accordance with ACI 214, and ACI 318-71, and any deviation from these criteria to be
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reported on NCR.
It also required that two additional compressive streng' h test cylinders be made from D-Mixes for testing at ninety t
days.
The inspector observed that seventeen NCRs had been initiated between August 4,1978 and January 3,1979, and two NCRs were initiated in June 1979 for failure of D-Mix to attain the required strength.
All of these NCRs were resolved by the project engineering (October 10, 1978-August 24,1979) to accept "as-is" on the basis of fifty six and ninety day strength of the additional cylinders.
Based on the abovE 3bservation the inspector concluded that the licensee is still committed to design D-Mixes of concrete to attain five thousand (5000) psi in twenty eight days. The licensee, however, has not fulfilled his commitment described in Section 5.2.5.2.1(b) of the Preliminary Safety _ Analysis Report for Limerick Generating Station by accepting D-Mix concrete on the basis of fifty six and ninety day strengths. (80-04-02).
This is a deviation.
6.
Field Change Request (FCR) Control System The inspector reviewed the FCR system as implemented for pipe supports and hangers. The inspector reviewed the following documents:
FCRs M-4707F to M-4790F, covering the period of March 5. 1980 through March 17, 1980.
Following FCRs were reviewed in detail because of disapproval by A/E project engineering.
M-4712F, M4717F M-4755F, M-4795F QCIR-Mll-138-1-5-1
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The inspector also reviewed several Hanger Rework Notices.
.No item of noncompliance was identified.
7.
Unresolved-Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. The unresolved item in this report is discussed.in Paragraph 4.
8.
Exit Interview The inspector met with the licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection. The inspector summarized the purpose and scope, and the findings.
His findings were acknowledged.
by the licensee.
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