IR 05000353/1986007

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Insp Rept 50-353/86-07 on 860330-0509.Violation Noted: Procedural Requirements Not Followed During Reading of Radiographs & Unauthorized Tools Used on Stainless Steel Contrary to Const Procedure CP-W-1,Section 9.5
ML20210U647
Person / Time
Site: Limerick Constellation icon.png
Issue date: 05/23/1986
From: Beall J, Gallo R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20210U634 List:
References
50-353-86-07, 50-353-86-7, NUDOCS 8606030046
Download: ML20210U647 (13)


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U. S. NUCLEAR REGULATORY COMMISSION REGION 1 Report No. 86-07 Docket No. 50-353-License Nos. CPPR-107 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101

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Facility ' Name:

Limerick Generating Station, Unit 2 Inspection Conducted: March 30, 1986 - May 9, 1986 Inspector:

E. H. Gray, Lead Reactor Engineer h34 Reviewed by:

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E. Bearl, Profect Engineer Date Approved by:

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R.' C Gallo, Chief, Reactor Projects Section 2A Inspection Summary:

Report for Inspection Conducted March 30, 1986 - May 9, 1986 (Report No. 50-353/86-07)

Areas Inspected: Routine inspection by'the resident inspector consisting of follewup on outstanding items, review of procedures and observation of construction activities, resident engineering, construction engineering, Quality Assurance and Quality Control Examinations. The inspection sampled work in planning and work in progress in electrical, piping and welding, HVAC, civil / structural and reactor vessel internals installation.

Results: Two violations were identified. One violation in the area of radiography involved failure to follow procedural requirements during reading of radiographs with respect to visually confirming surface indications and documenting the acceptance of a radiograph (Section 12.0). The other violation resulted from the use of tools (grinding wheels) on stainless steel that were not specifically identified for use on stainless steel per construction procedure CP-W-1 (Section 9.5).

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DETAILS 1.0 Persons Contacted Philadelphia Electric Company J. Clarey, Construction Superintendent J. Corcoran, QA Field Section Head G. Lauderbach, Field QA Technical Branch

  • P. Naugle, Assistant Superintendent Construction
  • D. D1Paolo, QA Field Branch Head - Unit 2
  • T. Ullrich, Superintendent, Limerick 2 Project Bechtel G. Bell, QA Manager W. Mourer, Construction Manager K.-Powers, Project Field Engineer K. Stout, Project Field QC Engineer

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T. Molinaro, Project Superintendent Also, during this inspection period, the inspector discussed construction procedures and work activities with other supervisors, engineers, QC in-spectors, and craftsmen in the PECO, Bechtel and General Electric organizations.

  • Denotes those present at the exit meeting.

2.0 Followup on Outstanding Items 2.1 Unit 2 closecut of previous Unit 1 related items.

Detailed inspec-tion findings and closeout of the following items are discussed in the inspection reports noted below. The Unit 2 items listed below were.previously closed for Unit 1.

These items were re-reviewed dur-ing the 353/86-07 inspection including field observations where applicable.

(Closed) Unresolved Item (353/76-06-05). The condition of "D" mix concrete in the east wall of the reactor building not meeting strength requirements in 28 days. This item was reviewed and dis-cussed in report 353/77-02 and closed by resolution of the deviation 352/80-04-02 in Report 352/80-19. This resolution included the PSAR amendment dated September 24, 1980 describing the low test values for 5000 psi ("D"-mix) concrete and presents technical justification for 3 its acceptance.

(Closed) Unresolved Item (353/79-03-03).

Six flued head primary con-tainment penetrations from each unit with linear indications.

Closed by Report 353/79-11 for Unit 2 and Report 352/80-05 for Unit 1, indicating NRC review of repair data packages on twelve flued heads.

(Closed) Unresolved Item (353/79-09-01).

Limerick site specific

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ASME Code certifications for the General Electric Company, Installation and Service Engineering Department.

The inspector re-viewed two sets of the NA and NPT ASME Certificates of Authorization dated July 18, 1980 and July 1, 1983 providing the basis for closecut of this item.

The ASME site audit providing for updating of the NA and NPT certificates for GE at Limerick past July 1986 is scheduled for May 12-14, 1986.

(Closed) Inspector Followup Item (353/76-07-01).

Minor oil spill.

The inspector as noted in Inspection Report 353/76-07 observed an oil spill of approximately 10 gallons.

The followup NRC Inspection 352/77-09, 353/77-09 of the construction phase envirormental protec-tion program included review of management controls as related to this program and implementation of the program through approved pro-cedures and controls.

This item is closed.

(Closed) Inspector Followup Item (353/76-07-04).

Calibration of me-teorological instrumentation. The NRC Inspection Report 352/77-09, 353/77-09 notes the inspection observation that meteorological in-strumentation was calibrated in accordance with written approved pro-cedures and in conformance to Regulatory Guide 1.23.

This item is closed.

(Closed) Inspector Followup Item (353/76-07-03).

Contractor Proce-dures and performance evaluations related to environmental monitoring programs.

In*the inspection 352/77-09, 353/77-09 the environmental protection program was determined to be implemented through site in-structions, procedures and a check list.

This item is closed.

In addition to the above, review of outstanding items list has iden-tified inspector followup items (IFI) and unresolved items (UNR) that are similar to other items previously followed up and resolved during the past inspections or have diminished in significance due to pro-gram improvements and core tti*e actions by the licensee since the time they were identified. Therefore, these items require no further fnspection effort and are closed.

(Closed) Unresolved Item (353/80'04-01), reference Report 352/84-10, 353/84-03.

(Closed) Unresobed Item (353/80-08-02, 352/80-09-02), reference Re-port 352/84-10, 353/84-03.

(Closed) Inspector Followup Item (353/80-00-03, 352/80-09-03), refer-ence Report 352/84-24, 353/84-08.

(Closed) Inspector Followup Item (353/80-08-04, 352/80-09-04), refer-ence Report 352/84-10, 353/84-03.

[ Closed) Inspector Followup Item (353/80-08-05, 352/80-09-05), refer-ence Report 352/84-24, 353/84-08.

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(Closed) Unresolved Item (353/80-10-01, 352/80-12-06), reference Re-port 352/84-10, 353/84-03.

3.0 Site Tour The inspector conducted frequent site tours to obsery" tasks in progress and plant status in both safety related and non-safet r related areas. The areas with safety related equipment observed include t he drywell, diesel building, wetwell, reactor building, turbine building, refuel floor, pipe fabrication shop and the common Unit 1-Unit 2 areas such as the Control Room, Auxiliary Equipment Room, Cable Spreading Room, and 4KV switchgear rooms.

The activities of Limitorque motor operated valve mechanism re-

-work, inspection and testing, and welder qualification were also observed during site tours.

No violations other than the two discussed in Sections 9.5 and 12.0 of this report were identified.

4.0 PECO Construction Division, Limerick Unit 2 The PECO Limerick QA plan in part 1.5 describes the function and responsi-bilities of the Construction Division.

The inspector reviewed the current Construction Division Limerick Unit 2 site organization chart and the work assignments of individual construction division personnel for comparison to the extent to which applicable responsibilities defined in the PEC0 QA plan are being met. The Construction Division responsibilities include reviewing a portion of specifications, drawings, procedures and other doc-uments; monitoring construction activity and providing assistance in moni-toring the PECO-Bechtel contract. The work is grouped in the following areas; drywell and elevation 253; Upper Reactor, Lower Reactor-Wetwell, turbine and auxiliary, the Turbine Building, and the Diesel Area. The Construction Division was noted to be involved in construction planning, tracking of work and in the identification and correction of problems be-fore they become significant.

The inspector concluded that the PECO Con-struction Division is meeting the responsibilities defined in part 1.5 of the PECO QA program for the work scope presently in progress.

No violations were identified.

5.0 Civil 5.1 Diesel Generator Building Foundation, and Related Work The inspector made periodic observations of work in progress on the Diesel Generator Building Area including the following:

Foundation Excavation per DWG C656, Sheet 2 Shoring Progress on East Wall Side per DWG C656, Sheet 2 Reinforcing Steel (Rebar) Splicing-(Cadwelding)

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Placement of Center Wall Foundation at Line 27

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Placement of Mud Mat Concrete on Bed Rock Y

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Installation of Reinforcing Steel Fillcrete backfill between foundation walls--two west sections Systematic excavation to bedrock hf the Diesel' Building Site and in-stallation of shoring on the East Wall side of the Diesel per drawing C656, sheets 1 and 2 were noted.

The inspector. observed the preparation of a Tensile Test Cadweld Splice required for one splicing crew prior to production splicing in accordance with the Specification 8031-C-34.

Production splices performed in the disposition of'NCR 10698 were examined.

Observations made included the technique of rebar end preparation, preheating, hrndling of the splice sleeve and material identifications.

The QC instruction (QCI-C600) and Quality Control Inspection Record (QCIR-C656 WL 194-11-1) applicable to the test splice and production Cad-welding in progress were reviewed. The inspector noted the work observed to be consistent with specification 8031-C-34.

The yard fabricated rebar assemblies for the Die.sel Building listed below were examined.

Each section was identified by a tag.

The following individual rebarr, were noted to be marked as BV9N60 or BV11N60 as appropriate:

Wall Line AA, 1st Section Near Face (NF),

2nd Section NF and Far Face (FF),

3rd Section NF and FF,

- 4th Section FF, Section DW FH-14, West Face.

The rebar assemblies were found to be tied securely per specification 8031-C-36, paragraph 6.1.2 with number 16 or number 14 gauge black annealed wire and cross braced.

  • Prior to the placement of concrete in the line 27 (Center of Diesel Building) foundation, the inspector observed the formwork and rebar placement including adequacy of rebar ties for comparison to the C36

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of concrete.

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The inspector noted the involvement of QC inspectors prior to and during concrete placement and reviewed the QC IR C656-FD-192A-5-1, the QC record of preplacement and placement attributes.

During con-crete placement QC inspectors and the QC Laboratory personnel were taking required data and conducting tests per Specification 8031-C-114. The tests include temperature det.ermination, slump test, den-sity, measurement and casting of compression test specimens.

Prior to placement of the last conrete pour (musmat) on the bedrock L-

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below the Diesel Building Foundation Elevation, the inspector noted the total excavation of overburden to bedrock.

No violations were identified.

5.2 Reinforced Concrete Wall Placement (RW-HL-107)

In the Reactor Building, the concrete form work and rebar arrangement for the wall'RW-HL-107 above the 217' elevation were observed. Our-ing the concrete placement the inspector examined portions of the work r

including QC testing, concrete free fall distance, vibration of con-crete and visual examination of the concrete by QC inspectors and supervision.

Concrete-Ticket Number 217194 was selected for detailed review of-QC Laboratory Records, batch plant records and independent calculations by the inspector to establish conformance to the requirements of the Specification C-114 and QCIR-C720-WL-107-5-1.

In calculation of the 217194 batch mix for comparison to the OC-1 type concrete, the air entrainment additive (AEA) was noted to be 60 when the C114 required amount adjusted for batch size was 28.5.

Review of the Field Change Request, FCR C12105, determined that AEA may be field adjusted to obtain the appropriate air entrainment. The inspector had no further question in this area and concluded that the requirements of C114, associated QC tests and QCIR checks were made for the RW-HL-107 concrete placement.

No violations were identified.

6.0 Control of Measuring and Test Equipment The QC Lab has the primary responsibility for control of measuring and test equipment (M&TE), including calibration. The inspector examined a sample of measuring and test equipment records of calibration, observed the tool issue and cor. trol stations and discussed the program with the QC supervisor and others. The obrervations made were compared to the appli-cable procedural requirements of the following:

Job Rule 8031-JR-G-23 Rev. 8 - Control of all measuring and test equipment subject to calibration verification.

Procedure CP-F-2, receipt inspection, storage and withdrawal of materials / equipment.

PSP-G-4.1 Rev. 5.

Project special provisions for control of measuring and-test equipment for Job 8031.

Controls on M&TE include a master computer list of items requiring cali-bration with the calibration due date, approximately 42 specific proce-dures for_ calibration of various types of M&TE, the preparation of a f~

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calibrationreportforeachcalibrationperformedandtheuseofanaccu-

racy" certification label on equipment to attest that an item has been cal-

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ibrated to,a specific procedura.

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No~ violations were'identif ed.

7.0 Electrical - Maintenance of Installed Equipment

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' :The inspector toured the. plant and examined the application of Construb-tion, Procedure CP-G-3 for the sttribytes of internal heating to pre, vent condensation, protective co'tering and monitoring of inplace long term

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storage of motor control centers (MCC).

The following: motor control cen-

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ters and two transformer cabinets were observed:

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20D201 20B218 20D203

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20B216 208224ZC 20B217 208202 (Transformer Cabinets)

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. 20B201 (Transformer Cabinets)

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The inspector also reviewed the PEC0 QA Finding Report Number 2E-394 dated-

4/3/86 wnich documents and provides recommended corrective action to the L'problsm of MCC-20B224 not being tracked op the maiqtpaance log. The prop-er application of internal heating and protective cove: ring was noted to be in place on this MCC during the above observations by the.inspecto,r.

No violations were identified,

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8.0 HVAC.- Heating Ventilation and Air Conditioning Theinspecto'rreviewedtheNuclearSafetyRelatehHVACProgramandexam-ined selected components for comparison to the Specification 8031-M-68A Rev. 2 and the AWS D1.1 and AWS D9.1 code requirements. Construction pro-cedure CP-M-3 is the procedure for fabrication, installation and construc-tion testing of HVAC ductwork and HVAC hangen systems.

The specification 8031-G-20 contains the visual inspection criteria applic ble to'HVAC Welding.

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HVAC, duct pieces visually examined.by the inspector included M1168 piece

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0094A, M1177 piece 319 and M1177 piece 320. The applicable work packages including drawings were reviewed.

The inspector noted the involvement of

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QC inspection in the HVAC 'and the appropriate use of both QC instruction:

and QC inspection reports (QCIR),

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No violations were identified.

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9.0 Piping and Welding 9.1 Welding in Progress During plant tours, the inspector observed work in progress including weld joint fitup and welding of the following pipe hanger, pipe or pipe to valve components.

The observations were compared to con-struction procedure and code requirements as applicable to the work in progress. Observations were made on the following:

LOCATION ISO WELD (s)

SYSTEM Turbine Building EBB-202-1 FW6 Main Steam (MS)

Turbine Building EBB-201-1 FW7 Main Steam (MS)

RHR Room GBB-201-1 FW1 RHR RHR Room GBA-213-2 FW4 RHR 217' ELV GBB-218-1 FW7 RHR Drywell-250' ELV DBA-206-1 FW6 HPCI Drywell Boundary APE-2MS-LC-C18 WC18 Flued Head / Containment Penetration Turbine Building EBB-204-1 FWS Main Steam 238' ELV DCA-204-1 FW7 RHR Turbine Building EBB-204-1 FW6 Main Steam Reactor Building GBB 218-1 FW5

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Drywell Boundary APE-2MS Wb18 Flued Head /Containtment Penetration Drywell APE-2MS-LA WA05 MSIV to MS Pipe 271' ELV C0-976-MS-RHGR --

Recirc Pump HGR Steel Wetwell HBB-242 H9, H10

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GBC-201 H79

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Steam Chase C835 Splice MS pipe support plate to beam

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Drywell 238' ELV VRR-2RS HHA6

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315 degrees Drywell 238' ELV VRR-2RS HHA5

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315 degrees HBB-218-1 FW6

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GBB-209-2 FW 13 and 14

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SP HBC-241-ES Sockets ESW

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Drywell Boundary APE-2MS-LD WD-18 Flued Head / Cont.

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Penetration

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Work packages and required documentation were noted to be in the work area during fitup or welding, as applicable.

The handling and rig-ging to position piping in the reactor building and drywell was ob-

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served for comparison to procedural requirements.

No violations were identifie f

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  • 9.2 Reactor Recirculation Piping The GE specification number 22A2284 was reviewed as the basis for reference during inspection of field installation of the reactor re-circulation piping. This specification and the ASME Code Section III (to 1974 Winter Addenda) and Section IX contains the specific in-structions and code requirements for erection of the GE supplied re-actor recirculation piping system.

The Bechtel Specification 8031-P-305, attachment 2 sheet 18 of 25 indicates the applicable welding procedures for recirculation loop field welds. These weld procedure designations are in agreement with 22A2284 in that they indicate the use of the Gas Tungsten Arc Process (GTAW) for use in root passes for both butt welds and socket welds of single side welds where the weld root on stainless steel is in contact with water. The inspector examined the weld fitup and portions of the machine welding of weld WB48/0 of Spool VRR-2RD-28, the first recirculation piping system field weld.

The work package and applicable documentation including QC inspections were reviewed. The presence of construction supervision and field weld engineering and the use of qualified welders was evident.

No violations were identified.

9.3 Mild Steel (E7018) Low Hydrogen Weld Electrode The procedure for welding at Limerick Unit 2, CP-W-1.in paragraph 5.3.4.5 requires that unused E7018 that was issued in an unheated container be returned to the rod room after 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> for reissue of unexposed electrodes. The inspector, in observation of the issue and use of E7018 for welding of mild steel noted that this requirement of CP-W-1 was being followed.

The inspector revieweo the laboratory test data and engineering justification for use of E7018 issued in unheat-ed electrode cans during the ten hour time period after issue. The basis is the March 15, 1978 report, including attachments titled

" Qualification of an Alternative Electrode Control Program for AWS D1.1".

This _ report which verifies the presence of acceptable mois-ture contents in the coating of E7018 exposed to high humidity for time periods over 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> was reviewed by the NRC in 1978. The NRC letter dated April 24, 1978 on Docket 50-528 indicates concurrence with the electrode handling method of using E7018 issued in unheated cans within twelve hours.

The inspector also reviewed letters be-tween Bechtel and PECO dated September 25, 1978 and November 13, 1978 providing for changes to procedures including the Welding Filler Met-al Control Procedure (WFMP-1) to implement the issue of E7018 in un-heated cans for use within the maximum specified time, for welding of mild steel.

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The inspector concluded that an adequate basis had been established

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for the present practice of issue and control of E7018 weld elec-trodes in accordance with procedure CP-W-1 and WFMP-1 Revision 2.

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The practice as defined in these procedures was observed to be in effect in the fleid.

No violations were identified.

9.4 Main Steam Quencher Lines, Steam Relief to Wetwell The inspector observed fitup, welding, NDE and PWHT in progress typi-cal of GBC-216-12/11 FW20, and GBC-216-4/9, FW 11 and FW 12. The pressure joint is a type 515 Grade 70,1-1/2" thick plate full fusion welded as a corner joint to 1.4" thick ASME P1 pipe material.

Although the piping is designated GBC (ASME Class 3), the installa-tion ~ drawing requires that these welds be examined per GBB (ASME Class 2) requirements, that is, radiographic examination of pressure welds and ultrasonic examination (UT) of the plate for laminations per the ASME Code NC 5253(b)(1). During review of the initial radio-graphs for this weld joint type, the inspector saw that the edge of the weld and heat affected zone of the weld in the plate material

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were not included in the radiograph due to the geometry of the weld, pipe and plate.

This item is unresolved pending review of NDE requirements, evalua-tion of the significance of not having UT performed on the plate pri-or to welding, determination of expected loads on the plate and possible use of ultrasonic testing to demonstrate soundness of the weld including heat affected zone in the plate.

(353/86-07-03)

9.5 Metal Removal Tools for Use on Stainless Steel A basic requirement in-fabricating and installing stainless steel piping is to avoid contact of the stainless steel with low carbon steel to prevent surface contamination by iron on the stainless steel. Construction procedure CP-W-1 in paragraph 5.18 addresses this issue'by stating that metal removal tools used on carbon steel shall not be subsequently used on stainless steel and that metal re-moving tools used on stainless steel be color coded red.

On April 10, 1986, the inspector observed stainless steel weld joint

. preparation by grinding in progress where non color coded metal re-moval tools were in use. This is a violation as noted in Appendix A of this report. (353/86-07-01)

As background to this finding, the inspector determined that the grinding tools in use were new when obtained from the Tool Room Issue Station and had not been previously used on carbon steel. Metal re-moval tools could be issued from any of three tool room counters.

The inspector found two of these tool rooms to have no color coded metal removing tools (Grinding wheels, files, brushes, etc.) or means to color code new tools for use on stainless steel. The inspector concluded that the requirement to color code metal removal tools for

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use on stsialets steel had not been full.y innlemehted. Within hours of this fieding, the licensee and contractor initiatesi corrective Prior to the conslusi n of thi-s intpettion period corrective action.

actions, steps to prevent recutrence and plans for monitoring by Q/.

through se'neduled audits were comple ted. Corrective acticns included training of pipe fitters and tool room attendants in the CP-M-I re-quirement for tbe use of color coding on : stainless steel metal remov-ing tools, the use of tools on stainless cteel so marked and provision by QA to audit this and otner attributes nf procedure CP-W-1 to document continued uSt of properly marked tools on stain-

.lets steel.

The inspector had no further questions on -thit anatttr.

9.6 Welder Qualification During observation of weldirig and eeview of weld tiocupertatf ort the inspector selected welder symocls to verify qualification fer weld tasks performetl. The inspector determined that the following weld-ers, by weld symbol, where cualified for the welding they performed on the work sampled.

P84 P66 P2W PJK PGY PJ2 P7B PT7 P2 BH4 PE6 PSA BT2 PSU P02 No violations were identified.

9.7. GTK4 Welding Machine Calibration The GTAW machine welding program,orov(des for periodic check and cal -

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ibration of the machine power source.ar.d contrch that affect veldits variables. The inspector observed a portion of the calibtation check in process on one weld machine. This electronic calibration provides assurance that the actual values fcr welding variables match the ma-chine settings fbr.these variables. Subsequent to the electrontc check, the varia' les such as amperage, voltage, wire feed rate, cat-o riage travel speed and oscillation rate are confirmed durf ag test

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welding.

No violations were identified.

10.0 Pipe Supports and Pipe Hangers The inspector reviewed NCP.10718 which idsntifies a problem with Bergan Patterson (BP) Part #113' Hanger' Beam Attachments with cracks near the Send Radius Corners. Dispo.sition'of the NCR 10715 included 100% inspoetion of this type attachment in sizes 3 to 14. Approximately 5000 : pieces ware inspected with 66 cracked ' items identified; tost (49) of the cracks were

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in the size 7 item. The cracked items were identified as rejected compo-nents and scrapped or used in material testing for evaluation of the ef-fect of the cracks on load carrying capacity of the parts involved. The test report (TRNHTL-1086-092A) on part #113 load rating dated March 31, 1986 demonstrated that the cracked components would achieve loading beyond design requirements.

No violations were identified.

11.0 Work Packages (WP)

Procedure CP-P-2, part 5.5 outlines the preparation, use, and control of work packages for large bore pipe (2-1/2" and larger). The installa-tion, rework, modification or repair of Unit 2, large bore pipe is intend-ed to be implemented through the use of work packages. During inspection of pipe fitup and welding activities the presence of work packages in the work area was noted, with the following exception. Welding on GBB-201-1/11 FW 1 was being completed in the RHR Room, ELV 177' while the work package was in the pipe fabrication shop in use for work in progress on another portion of the line. The welding documentation (WR5) and weld wire issue slip (WR6) were both in the FW1 weld area. The inspector re-viewed the procedure CP-P-2, Rev. O and found no clear definition of how work in progress at the same time in two significantly distant areas of the plant could be properly implemented through the use of a single work package.

In followup of this concern, procedure CP-P-2 Rev. O was reviewed and revised by Bechtel Construction Engineering with appropriate approvals to implement the use of multiple work packages when required to control separate work activities.

The inspector had no further concern in this area.

Nc violations were identified.

12.0 Non Destructive Examination (NDE)

The insp ctor observed the performance of NDE by QC inspectors and re-viewed documentation of NDE results for comparison to the applicable NDE procedure requirements.

Radiography (RT), magnetic particle examination (MT), penetrant testing (PT), and ultrasonic examination (UT) for material,,

thickness checks were observed as indicated below.

ISO WELD NDE H8B-218-3 FW X50 (NCR 10672)

MT&UT APE-2MS-LAA1B Weld WA18 PT Final EBB-203-1 FW5 RT GBB-201-4 FW9 RT HBB 218-2 FW52 RT

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DBA 206-2 FW4 RT The PT dye container in use on WA18 above was observed by the inspector to have the correct lot number but the dye identification on this container

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was SKC-NF/ZC-78 rather than the SKL-HF/S required by procedure PT (SR)

ASME III/XI Rev. 3.

In investigation of this discrepancy the inspector determined the source of the dye ~ was a correctly marked container and the dye required by the procedure was actually in use. The PT dye container in use was remarked to indicate the correct dye type.

The contractor located and corrected the dye type designation on two other dye containers. A review of 43 PT reports revealed two where a number dis-crepancy in dye identification was present on the PT reports.

These were revised to show the dye type used and the inspector had no further ques-tion in this area.

Radiographs and related documentation were reviewed for conformance to procedure RT-XG-2 Revision 1 as applicable to ASME Code Section III, Class 1 and 2 piping.

The radiography procedure RT-XG-2 requires in paragraph 5.1.5.2 that an indication determined acceptable through other means (e.g. visual examina-tion) be recorded on the radiographic review form.

Paragraph 8.2 requires interpretation of each radiograph and disposition of the material examined.

The inspector observed that procedure RT-XG-2 was not being fully imple-mented in the following respects. One area, 52-56, on HBB-218-2, P452 contained an indication identified as undercut where visual examination of the weld had not been performed by the film reader. The subject pipe weld area was examined by the NRC inspector and noted to be slightly underground but not undercut. The radiographic review form had no reference to the film reader having performed a visual examination of this area. One radio-graphic review form applicable to EBB-203-1, FW5 did not indicate the disposition of the radiograph by the film reader. These conditions are a violation as noted in Appendix A of this report.

(353/86-07-02).

The licensee in followup to the findings of the inspector initiated a thorough radiographic film and documentation review and based on the find-ings provided for appropriate corrective actions.

The radiographic film, documentation review results and corrective actions will be reviewed fol-lowing licensee reply to this report.

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13.0 Unresolved Items Unresolved items are matters about which more information is required to ascertain if it is acceptable, a violation, or a deviation. An unresolyed item is-discussed in paragraph 9.4.

14.0 Exit Meeting

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The NRC resident inspector discussed the issues and findings in this re-port with Mr. J. Corcoran on a weekly basis and others throughout the inspection period and at an exit meeting held on May 9,1986. At the exit meeting, the licensee's representatives indicated that the items discussed in this report did not involve proprietary information.

No written mate-rial was provided to the licensee during the inspection period.

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