IR 05000352/1982005
| ML20054D267 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/02/1982 |
| From: | Durr J, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054D265 | List: |
| References | |
| 50-352-82-05, 50-352-82-5, 50-353-82-04, 50-353-82-4, NUDOCS 8204220497 | |
| Download: ML20054D267 (7) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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Region I 50-352/82-05 Report No.
50-353/ 82-04
-50-352 Docket No.
50-353 CPPR-106 License No. CPPR-107 Priority
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Category A
Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generating Station, Unit Nos. 1 & 2 Inspection at: Limerick, Pennsylvania Inspection con March 1 - 30, 1982
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Inspectors:..O
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g.P.Durr,SeniorResidentInspector-Mt6 Signed (
Date Signed Date Signed Approved by:
& NC+A4 4l2l27.
E. C. McCabe, Chief, Reactor Date Signed Projects Section 2B Summary: Inspection 50-352/82-05, 50-353/82-04; March 1-30, 1982 Routine onsite resident inspection (44.5 hr., Unit 1; 9 hr., Unit 2) of structural steel supports, design document control, welding, nondestructive testing, plant tours, and action on previous findings. Two Violations were found: failure to control design changes (Detail 4) and failure to provide required cable tray edge softeners (Detail 3). Adequacy of Reactor Protection System fail-safe provisions and electrical separation was questioned (Detail 5). The six previous findings closed (Detail 2) included recirculation pipe weld alteration (LPT, training, specifier acceptance), feedwater and main steam pipe restraint weld defects (up to 1/16 inch undercut accepted, others repaired), inadequate HVAC contractor weld control (completed welds to be marked and others reinspected, containment liner weld NDE basis defined), and questionable separation for IE cable tray drop outs (installation specification revised).
I Region I Fonn 12 (Rev. April 77)
8204220497 820406 gDRADOCK 05000352 PDR
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DETAILS 1.
Persons Contacted Philadelphia Electric Company J. Brozonis, Construction Engineer D. T. Clohecy, QAE J. M. Corcoran, Field QA Branch Head J. J. Fedick, Construction Engineer J. R. Goodbred, QAE G. Lauderback, QAE P. L. Naugle, Construction Engineer P. K. Pavlides, Manager - QA Bechtel Power Corporation A. Arch, Assistant Project Field Engineer (APFE)
R. J. Bulchis, Resident PE B. A. Dragon, QAE H. D. Foster, PFQCE M. Jan, Field Mech. Engineer J. L. Martin, LSQAE K. L. Quinter, Assistant PFQCE T. F. Ritt, QAE D. C. Thompson, Assistant PFQCE D. Shaw, Assistant Project Field Engineer R. E. Weaver, LSME A. G. Weedman, PFE R. A. Weitzel, Lead Inst. Engineer E. R. Klossin, PQAE The above listed personnel attended exit interviews on March 11 and 30,1982.
Other craftsmen, engineers, quality control technicians, and supervisors were contacted and interviewed as the inspection interfaced with their work.
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2. ' Plant Tours (Unit Nos.1 & 2)
Periodically during the inspection, tours were made of the Unit Nos.1 and 2 primary reactor containments, the reactor buildings, the control structure, and surrounding yards and shops. The inspector examined completed work, work in-progress, quality control activities, and equip-ment storage, handling, and maintenance.
He discussed the technical aspects of the work with craftsmen, supervisors, and engineers to assure work was being performed in accordance with requirements.
Specific activities observed include cable pulling, cable tennination, pipe handling, pump alignment, and valve assembly.
No violations were identified.
3.
Licensee's Action on Previous Inspection Findings (Closed) Unresolved Item (352/80-02-06)
A series of welds were rejected which were made by one welder.
The licensee wrote Nonconfonnance Report 3892 which required repairs to the welds. The inspector expressed concerns that the welder may have made other rejectable welds and questioned the welder's qualification to weld.
The licensee issued Quality Action Request QAR-F145 requesting additional inspections of the welder's work. These inspections were performed and documented on Inspection Report C-72-QCG1, Control No. 7.
These documents were reviewed by the inspector.
A review of the welder's qualification record did not disclose that any additional training of the welder had been given.
However, an interview of the Lead Field Welding Engineer and the Welding and Qualification Training Supervisor revealed that addi-tional training had been given to the welder.
It was not the policy at that time to document retraining of welders as it is now.
This item is closed.
(0 pen) Violation (352/80-17-03)
The violation deals with the failure to install cable tray edge softeners in accordance with the Bechtel Specification 8031-E1412. The licensee issued Finding Report N-213 which was closed based on correction of the identified condition, reinspection, retraining of the Q.C. inspectors, and i licensee surveillance audit.
The inspector reviewed the above documentation and performed a visual inspection to verify corrective action. The visual inspection consisted of cable trays in the cable spreading room, the PGCC, and several elevations in the reactor building.
He identified the following cable trays with nonconfonning edge softener conditions:
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Cable Tray Location Condition-1BTLA99 EL 259 Softener only on one edge.
Cable Spread 1ATXA99 EL 260 Softener only on one edge.
Cable Spread 1ACZA04 EL 296 No edge softener installed.
PGCC 1ACYC01 EL 296 No edge softeners installed, PGCC against sharp edges of tray clip angle.
The failure to install cable tray edge softeners in accordance with the requirements of Drawing E1412 is a violation (352/82-05-01).
This is a recurring violation.
Because of the recurring nature of the above violation, the inspector reviewed the licensee's quality assurance program to verify that measures have been established to prevent recurrence of nonconforming conditions.
The Bechtel audit program requires auditors to review previous audit findings, nonconformance reports, and licensee findings for inclusion in their audit attributes. The cable tray softeners were audited, PAF-355, after the first violation.
(Closed) Violation (352/80-20-01)
The welders altered the weld preparation on the 28" diameter recirculation pipe spool joint BWRPD-lREC-1/4 WA 3.
The weld preparation was altered to provide weld bead drawing of the pipe spool to facilitate alignment. The General Electric specification >equired their approval of any alteration to the weld joint.
The licensee issued Finding Report N-223 which documented the following corrective actions:
o Nonconfomance Report 4408 was issued. The disposition required a liquid penetrant test of the ground area.
o A training session was held on November 10,1980 to re-emphasize the specification requirements.
o Field Deviation Disposition Request HH1-424 was processed to obtain General Electric approval for the welding deviation.
In addition to verifying the foregoing, the inspector reviewed the radiographs for weld joint WA 3.
This item is closed.
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(Closed) Violation (352/80-20-03)
The feedwater and main steam pipe restraints were found to have unacceptable welding defects. -The licensee issued Finding Report No. N-224 which
. directed that further inspections be perfomed on equipment supplied by the same vendor. The inspections resulted in the identification of other welding defects and the issuance of Nonconfomance Report Nos. 4500, 4521, 4564 and 4565.
The inspector reviewed.the above documents and verified that appropriate corrective actions were implemented. The design engineers dispositioned welding undercut less than 1/16" as acceptable based on the fact that the structures involved are not cyclically loaded.
A reinspection of the pipe restraints verified that repairs were made to the structures and no defects were noted, based on the revised acceptance criteria. This item is closed.
(Closed) Unresolved Item (352/81-02-01)
The heating, ventilating, and air conditioning (HVAC) contractor's weld status quality control program did not provide a positive method for deter-mining weld status. The HVAC contractor revised the Project Procedure Manual 5.3 to include a requirement to mark all completed welds. Any welds not marked must be reinspected.
He also has more clearly defined the basis of the 10% nondestructive test requirement for welds to the containment liner.
The inspector reviewed the report file established to track these welds.
This item is closed.
(Closed) Unresolved Item (352/82-03-01)
The facility has lE cable tray drop outs that will pass in proximity
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to other 1E and non-lE cables which will violate the separation criteria.
The current revision of the cable installation specification does not provide for this condition. The licensee issued Drawing Change Notice No.149 to Drawing E-1406 which provides instructions for separation of cable tray drop outs. This item is closed.
(Closed) Unresolved Item (352/82-03-06)
The licensee was late in issuing the annual quality assurance report to the Vice-President, Engineering and Research. The licensee issue the report covering the period July 1,1980 to December 31, 1981.
One of the reasons-for the extended report period was to shift the report ending date to coincide with the fiscal year.
The inspector reviewed the report and had no further questions concerning the matter. This item is closed.
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4.
Structural Supports The reactor pressure vessel pedestal embeds for the recirculation pumps were selected for observation of work activities. This included a review of the design drawings and specifications, visual and dimensional examination of parts and components, observation of installation activities, and review of quality control data.
The inspector noted that extensive work had been perfomed such as excavation of concrete, location and core boring of holes, and pemission to move bolt holes from design locations on Engineering Memoranda to Field (EMF's) Nos.
6798, 6945, 7086 and 7151.
EMF's are not described by the quality assurance program for design control. The formal document for design change control is the Drawing Change Notice which is described by the Nuclear Quality Assurance Manual, Section 3.2 and EIPIOM-6, paragraph 4.1.
The failure to process design changes as required by the Quality Assurance Manual and EIPIOM-6 is a violation (352/82-05-02).
The inspector observed the modifications to the box beam depicted on drawings C-932 and C-966 (detail E).
He verified that the welder was qualified and that selected details and dimensions were as specified on the drawings.
No violations were identified.
5.
Review of Engineering Memoranda to Field (EMF's) and Resident Engineer's Memoranda (REM's)
The inspector perfomed a review of EMF's and REM's to detemine if design changes were being handled outside of the established system. The basis for this review is the violation described in paragraph 4.
The inspector reviewed the computer listing of EMF subjects and selected 12 EMF's for examination. EMF 6306 gives pemission to the field to deviate from separation criteria provided by Specification M-830 (Ref. IEEE-279)
for the pemissive scram by-pass sensing lines for PT-01-1N052A, B, C, & D.
These pressure transmitters allow the anticipatory turbine stop and contro.
valve scrams to be by-passed below 30% power.
Based on available infomation, it appears that any failure involving both sensing lines would cause the by-pass of the anticipatory scrams. These scram by-passes are discussed in the FSAR Sections 7.2.1.1.4.4.1 and 15.2. The FSAR Section 7.2.1.1.4.4.1 states that the pressure transmitter sensing taps are " physically separated".
Further, 10 CFR 50 Appendix A Criterion 23 requires the reactor protection system (RPS) be designed to fail into a safe state.
It appears that any failure in the sensing mechanism of the scram by-pass sensors would cause them to by-pass the scrams, thus not failing into a safe stat,.
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The following items are unresolved pending review by the NRC:
The justification for deviating from the separation requirements
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of IEEE-279 and FSAR Section 7.2 commitments for the sensing lines.
The apparent deviation from 10 CFR 50 Appendix A Criterion 23
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for this part of the reactor protection system in that it does not " fail safe".
(352/82-05-03)
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Observation of Welding Activities Other safety related pipe welds (ASME III, Class II and III) were selected for document review and observation of welding activities. The document reviews verified the welder's qualifications, proper welding procedures were snployed, required nondestructive tests specified, appropriate quality control inspection points specified and signed off, and proper preheat and postweld heat treatments were required. The observation of welding consists of, where applicable, examination of the cleanliness, fitup, and alignment of the parts; proper welding equipment, purge and cover gas flow rates; electrodes and filler materials; appearance of the weld deposit; evidence of quality control activities; and proper documentation. The following welds were examined:
Weld No.
Class System Status GBB-101-2/3 FW57 II RHR Fitup and root pass GBC-ll6-2/1 FW51 III SRV Intemediate passes The inspector also observed various phases of liquid penetrant tests being perfomed on field welds EBB-141-E2 W-13, W-16, and W-23 and GBC-116-2/1 FW51.
Weld GBC-ll6-2/1 FW51 is a pipe to flued head penetration connection at the containment diaphragm floor. The material certifications for flued head, PN7-050511-1 (P.0 No. 57764-7), were reviewed and verified to comply with the applicable code and specification.
No violations were identified.
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Unresolved Items Unresolved items are matters about which further infomation is required to determine if they are acceptable, deviations, or violations. An unresolved item is discussed in paragraph 5.
8.
Exit Interviews Exit interviews were held on March 11 and 30, 1982 with members of the licensee's staff listed in paragraph 1.
The inspector discussed the scope and findings of the inspection.