IR 05000353/1986012
| ML20211F680 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/17/1986 |
| From: | Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20211F642 | List: |
| References | |
| 50-353-86-12, NUDOCS 8610310227 | |
| Download: ML20211F680 (14) | |
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U.S. NUCLEAR PEGULATORY COMMISSION
REGION I
Report No. 86-12
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Docket No. 50-353 License No. CPPR-107 Category A Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name:
Limerick Generating Station, Unit 2 Inspection Conducted: August 4 - September 28, 1986 Inspector:
R. A. Gramm, Senior Resident Inspector Approved by:
//-/7-F5 P. W. Es roth, ChieLf Oate Reactor ojects Section 2A Inspection Summary: Report for Inspection Conducted August 4 - September 28, TH6 (Report No. 50-353/86-12)
Area Inspected:
Routine inspection by the resident inspector of work activities procedures, and records relative to pipe supports, control rod drive system, reactor pressure vessel internals, diesel generators, preventive maintenance, structural steel, fire prevention and Bechtel Quality Assurance activities.
The inspector also reviewed licensee action on previously identified items and performed plant inspection tours.
The inspection involved 89 hours0.00103 days <br />0.0247 hours <br />1.471561e-4 weeks <br />3.38645e-5 months <br /> by the inspector.
Results: Two violations were identified: An as-butit pipe support configuration was inconsistent with respect to the associated engineering drawings (paragraph 4), and diesel generator vendor storage requirements for the Woodward governors were not implemented onsite (paragraph 7),
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DETAILS 1.0 Summary Work activities that were satisfactorily examined during the inspection include safety related piping, reactor pressure vessel -internals and records, diesel generator placement, preventive maintenance for Reactor Core Isolation Cooling and High Pressure Coolant Injection pumps, diesel generator structural framing steel, fire prevention activities and Bechtel Quality Assurance activities. Three previously identified inspection findings were reviewed and closed.
A violation was identified where a pipe support had been inspected and accepted by Quality Control, field enginee' ing and the craft even though r
the configuration was not in conformance with the design drawing. A second violation was identified where vendor specified storage require-ments for the diesel generator Woodward Governors was not adhered to.
The use of Visual Weld Acceptance Criteria in lieu of American Welding Standard D1.1 criteria for nuclear pipe supports is unresolved pending licensee revision of the FSAR and further NRC review. An inspector followup item was generated regarding the licensee protection of compon-ents that have been turned over.but which are physically located in the Unit 2 construction area. A second followup item was generated to provide further inspection to verify the compatibility of power strut and unistrut spring nuts. The site mechanism to ensure that concrete densities are acceptable for shielding purposes has not been defined and is considered unresolved pending further licensee review.
2.0 Plant Inspection Tours The inspector observed work activities in progress, completed work and plant status in several areas during general inspection tours. Work was examined for any obvious defects or noncompliance with regulatory requirements or license conditions. Particular note was taken of the presence of quality control inspectors and quality control evidence such as inspection records, material identification, nonconforming material identification, housekeeping and equipment preservation. The inspector interviewed craft supervision, craft and quality control personnel in the work areas. Observations are noted below: '
The inspector monitored the conduct of a training session for new site welders. An informational handout was additionally reviewed by the inspector. The training provided an adequate coverage of site welding requirements for the craft.
The inspector observed a field training session for Bechtel electrical Quality Control (QC) personnel.
The instructor covered the essential elements of electrical equipment inspection activities.
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The inspector examined HVAC duct support M-1162/H15 and M1162/H16. The associated work packages and design information was reviewed.
The inspector had no questions.
3.0 Licensee Action on Previously Identified Items a.
(Closed) Followup Item (77-13-01):
Training for fire brigade personnel.
The inspector reviewed training records associated with PEC0 Finding Report 2N-527 that documented fulfillment of the personnel training requirements. This item is closed, b.
(Closed) Unresolved (83-06-01):
Improper handling of stainless steel recirculation system pipe spools.
The inspector reviewed the following documents:
PECO Surveillance Check Report 2P-474
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PEC0 Finding Report N-362
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Bechtel Nonconformance Report 8373
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General Electric letters LS-6546 and LS-6450
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The inspector reviewed selected training records for craft and supervisory personnel regarding the proper rigging requirements for stainless steel piping material. General Electric (GE) evaluated the surface condition of the pipe spools and determined them acceptable.
In the event any surface rust appeared, GE directed that it be removed by buffing. The inspector examined several areas where the carbon steel slings were in contact with the pipe and no surface rust was apparent.
The inspector has no further concerns, therefore this item is considered closed, c.
(Closed) Followup Item (86-10-01).
FSAR depiction of diaphragm slab steel connection.
Licensing Document Change Notice (LDCN) FS-1035 was issued and approved by PECO to correct the FSAR figure. A safety evaluation was performed by the licensee that found no adverse consequences of the change.
The inspector has reviewed these documents and has no further concerns.
Therefore this item is closed.
4.0 Pipt.ig and Pipe Supports a.
The inspector' observed in process work activities on the following pipe installations:
Flange bolt up was observed in accordance with work package
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HBB-220-4.
The associated drawing redlines, GE Field Deviation and Disposition Requests, nonconformance reports, and weld cards were reviewed.
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Examined Field Weld 6 on Isomet-ic HBC-248-4 of the Emergency
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Service Water System. The we'.. card was reviewed and the Bechtel QC cleanliness check was observed.
i Welding was observed at recirculation system joint A8 on
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isometric VRR-2RD-2A.
Grinding on core spray system Field Weld 2 isometric EBB-231-1
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was observed. The associated planner package was reviewed.
J The inspector reviewed use weld card and found that several QC
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hold points were improperly dated. The weld card for feedwater system, field weld 1 isometric DLA-207-1/10. was corrected by the inspector that had originally performed the inspections.
The inspector additionally reviewed Quality Control Instruction P-1.10 and Specification P-301-2 that govern field fabrication and i
inspection of piping.
b.
The following documents that pertain to the installation of pipe supports were reviewed by the inspector:
FSAR sections 3.9.3.5 and 3.8.4.6.2.2
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FSAR figures 3.9-9 and 3.9-10
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Bechtel Specifications
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G-20, " Visual Examination Acceptance Criteria and Inspection Guidelines for Welded Structures" P-305, " Field Welding" P-319-2, " Field Fabrication and Installation of Q Listed and
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Seismic Category 1 Pipe Supports, Hangers and Restraints"
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P-317, " Pipe Hangers, Supports and Restraints"
Manufacturer Standardization Society (MSS)
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SP-58, " Pipe Hangers and Supports - Materials and Design" i
SP-69, " Pipe Hangers and Supports - Selection and Application" Construction Procedures
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l CP-P-3, " Field Control of Pipe Supports (Hangers)"
CP-W-1, " Welding"
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ANSI B31.7-1969 Nuclear Power Piping Code
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Quality Control Instruction 2.10
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PECO Surveillance Test ST-4-103-183-1, " Accessible Snubber
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Visual Inspection - RHR Service Water" c.
The applicable design drawings were obtained for the following i
safety related pipe supports that had been final inspected by
Bechtel QC:
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GBC-204-H5, HBB-220-H25, hBB-220-H33, HBB-220-H16, HBB-220-H29,
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HBB-220-H19 and GBB-212-H10.
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The pipe supports were associated with the Residual Heat Removal service water and core spray cooling systems. The inspector examined the installed pipe support configuration, measured weld sizes and lengths, examined weld quality, verified material sizes in accordance with bill of materials, and verified correct standard component parts.
The following concerns were identified by the inspector:
The site procedures allow for B31.7 pipe supports to have weld
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inspections performed to che Visual Weld Acceptance Criteria (VWAC). The FSAR currently invokes VWAC for' structural welding only. The inspector also asked the licensee whether VWAC or American Welding Standard criteria (AWS) 01.1 would be utilized for Section XI examination of pipe supports.
Pending further
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licensee and NRC review of the proposed weld acceptance criteria for safety related pipe supports this item is unresolved (86-12-01). The licensee presented for information ASME Code case N-430 that accepted the use of VWACS on ASME pipe supports.
Measurements of Bergen-Paterson load couplings supplied with
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variable spring hangers identified that the sight hole location would provide less than one full engagemant of the threaded stock. Bergen-Paterson provided subsequent correspondence tc Bechtel that confirmed the sight hole locations and the validity of the component load rating with less than full engagement. The inspector had no further questions on this item.
Examination of pipe support HBB-220-H16 identified that the
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location of a vertical tube steel member relative to the concrete embedment plate was not in accordance with the associated design drawing.
The failure of quality control, field engineering and the craft to properly insrect the pipe support configuration is a violation of 10 CFR EU Appendix B Criterion X (86-12-02).
The licensee issued Nonconformance Report (NOR) 11062 to document the as-built configuration. The NCR was dispositioned as acceptabic.
Bechtel QC reinspected fifteen pipe supports that the QC inspector involved with HBB-220-H16 had additionally inspected. One support configuration was found outside of tolerances and NCR 11083 was issued.
Bechtel QC performed additional training for inspectors which emphasized the necessity to verify proper support configuration and orientation. Based upon the actions implemented by the licensee, NRC Item 86-12-02 is considered to be resolved.
Support GBC-204-H5 was identified where the snubbers were not
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adequately protected from adjacent construction grinding activities.
The inspector was informed that the support had been turned over to PECO and that surveillance testing was performed on the snubber.
The fact that the snubber was not
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covered and that surveillances will be performed at 18 month intervals is a concern given the current level of construction activities.
Pending further licensee assessment of the adaquacy of protection afforded to turned-over components that are physically located in Unit 2 Construction areas this item is open (86-12-03).
d.
The inspector reviewed the following QC documents associated with the pipe supports that were examined:
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QC Inspection Reports (QCIRs)
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HBB-220-2-H019-0-70-1, LP-SRN-2-09-55-1
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M52-HEB-220-2-27-3, M52-HBB-220-3-5-1 M52-HBB-220-5-6, HBB-220-2-H29-0-70-1
M51-GBC-204-5-1, M52-HBB-220-2-27-2
M51-GBC-204-1-27-3
M51-GBC-204-1-28-5
The inspector identified no items of concern with these dccuments.
5.0 Control Rod Drive System a.
The inspector monitored in process work activity for the installation of two Hydraulic Control Units (HCus). He reviewed the associated work package 20-S224-A and found the installation activity in accordance with the engineering criteria.
The presence of QC and field engineering was noted and the Bechtel personnel were found knowledgeable of the installation criteria. No items of concern were identified.
b.
The inspector reviewed the following drawings regarding two pipe l
supports for the Control Rod Drive (CRD) Insert and withdrawal piping inside containment:
Drawings
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M-2227 CR0 Hydraulic System pipe hanger location plan
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M-2238 CRD Hydraulic System Hanger Detail IW-2010 M-2239 CRD Hydraulic System Hanger Detail IW-2011
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i Field Change Requests (FCRs)
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SP-5, SH-33 and SH-37 The hangers were examined for weld quality, weld size, member size, member configuration, bolting.naterial and shim material.
No items of concern were' identified.
c.
The inspector examined the inboard and outboard sides of the drywell control rod drive penetration assembly located at azimuth 75 degrees. The penetration configuration and acccessible welds were
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found ta accordance with Chicago Bridge and Iron Co. drawing 73 revision 6.
d.
The inspector examined the installed CRD piping under the Reactor Pressure Vessel (RPV) located at elevation 253 area 18.
The piping location and configuration were found in accordance with Bechtel drawings M-2208 and M-2214.
e.
The following drawings were examined by the inspector that depict the installation of the Hydraulic Control Units (HCUs):
Drawings
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M-2212 CRD System HCU Location Plan M-2402 CRD HCU Mounting Details GE Drwg. 9220249 HCU Outline Field Change Requests (FCRs)
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ME-71, ME-64, ME-76, ME-94 and ME-98 The inspector examined HCUs 5827, 5427 and 5027 relative to proper location and anchoring. The inspector verified the use of proper bolting, shimming, washer and nut material.
The inspector noted that FCR ME-98 allowed the substitution of power strut # PS-10RS and unistrut # P1010 spring nuts. Other nuclear projects have experienced problems with interchanging the various strut components which can lead to degraded connection capacity.
The inspector was presented Bechtel letter LTC-10393 which addressed specific problems encountered at River Bend. The inspector will followup on the licensee's justification for the compatibility of the spring nut hardware (Inspector Follow up Item 86-12-04).
No violations were identified.
6.0 Reactor Pressure Vessel Internals a.
The inspector observed ongoing work activities on the Reactor Pressure Vessel (RPV) internals.
He examined grinding activity on
the shroud support weld in preparation for a final TIG weld overlay.
Preparatory machining activity was observed on the core spray sparger. The inspector observed General Electric (GE) QC during inspection of the core spray post installation on the inner wall of inc RPV. The inspecter identified no items of concern.
b.
The following GE documentation relative to the internals was reviewed by the inspector:
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Traveler FDDR-8113-T, Rework RPV pads
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Traveler FDDR-0799, Jet Pump riser rework
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Traveler 2-106-T, Jet Pump Riser and Brace Arm
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Traveler 2-108T, Jet Pump Instrumentation
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Traveler 2-262T, Core Spray Posts and Brackets
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The inspector reviewed the associated QC records contained in the traveler packages: joint process control sheets, welder surveillances, filler me'.al requisitions, special process control l
sheets, Nondestructive Examination (NDE) records, Authorized Nuclear Inspector (ANI) involvement, Weld Procedure Specifications (WPS) and associated Performance Qualification Records (PQRs).
No items of concern were ider.tified.
7.0 Diesel Generators a.
The four emergency diesel generator units were transported to the permanent plant locations during the report period. The inspector reviewed the following documents regarding the diesel generator
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placement:
I Specification M71, " Diesel Generators"
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Construction Procedure CP-C-8, " Rigging of Permanent Plant
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Equipment" Bechtel procedure, " Rigging, Transporting and Placement of
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Category A Equipment - Unit 2 Diesel Generators" PEC0 QA Audit 2M-530
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Bechtel QC Inspection Reports
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C-0654-EF-GENR-6-1 C-0664-EF-GENR-5-1 Colt Instructions, " Packaging, Shipping, Handling, and Storage
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Instructions" 6031-M-71-213-4 The diesel generator placement was governed by the site procedure.
All applicable vendor requirements were properly incorporated into the Bechtel procedure.
The inspector was informed that vendor representatives monitored the placement. The inspector reviewed concrete cylinder break test records that showed the diesel foundations had reached the design strength prior to placing the diesel units. The inspecter also reviewed the PECo audit that was performed on the diesel activities, b.
The inspector examined the diesel units at the field locations.
Shim plates were found at the proper locations around the unit foundations.
Temporary power was energized for several internal
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heater elements. The diesels were covered with protective forms and sheeting. The pipe flanges were found properly covered. The inspector had no questions.
c.
The following documents were reviewed by the inspector that describe the diesel preventive maintenance program:
Specification M71, " Diesel Generators"
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Colt Specification, " Packaging, Shipping, Handling and Storage
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Instructions" 8031-M-71-213-4 Woodward Governor Co. instruction, "EG-B10C Governor / Activator"
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8031-M-71-266-1 The Inspector reviewed the associated Bechtel Long Term Maintenance records and logs for the diesel units. The inspector identified that the Woodward Governor vendor requirements to fill the governor / activator with lubricating oil during storage was not incorporated into the Bechtel maintenance program. The licensee performed a subsequent field examination and found that the four governors are not properly filled.
Nonconformance Report 11211 was issued by Bechtel to resolve the problem.
This is a violation of 10 CFR 50, Appendix B Criterion XIII (86-12-05).
8.0 Preventive Maintenance a.
The inspector reviewed the following procedures that govern site preventive maintenance activities:
Construction Procedures
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CP-G-3, "Long Term Storage / Maintenance / Lubrication of Permanent Plant Equipment and Materials Prior to Turnover" CP-F-2, " Receipt Inspection Storage and Withdrawal of Materials / Equipment" CP-C-4, "Jobsite Housekeeping Cleanliness Control" Bechtel Quality Control Instruction
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S-1.00, " Storage Facilities" S-3.00, " Pipe /HVAC Ductwork/ Hanger Components /Small Manual Valve Storage Maintenance" Bechtel provides equipment preventive maintenance coverage until the items are turned over to PECO.
Bechtel mechanical engineering reviews vendor instruct!ons, PEC0 directives, and Bechtel San Francisco Home Office (SFHO) engineering instructions to derive the applicable equipment maintenance requirements. Maintenance Action Cards (MACS) are developed from the review of all equipment
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maintenance requirements. The MACS are distributed and serve to
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coordinate craft and QC involvement in the various maintenance activities.
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b.
The inspector accompanied Bechtel QC during the performance of the warehouse instrument room visual walkthrough.
The inspector found the instrument components properly maintained. The inspector additionally accompanied Bechtel QC during a walkthrough of the Bechtel main warehouse area. The access to the storage areas was appropriately controlled. Safety related items and weld filler material were found properly segregated. The enclosure was generally weathertight with the exception of the electrical storage annex structure which was currently under repair. Materials were found properly stored.
During the walkdown of the field laydown storage areas the inspector observed several items of concern:
some structural steel and electrical raceway had fallen off the dunnage onto the ground, there was debris in some pipe spools which had no end caps, debris was noted in the laydown area, and no offsite access control was established for a laydown area adjacent to the North gate. The inspector was presented Inprocess Rework Notices (IPRNs) LTM-1406 and LTM-1408 which had been generated in mid August which described similar concerns. The control of the laydown areas and the timeliness of the IPRN responses is in unresolved item (86-12-06).
c.
The inspector interviewed the lead Long Term Maintenance (LTM)
engineer. The current equipment maintenance requirements are loaded onto a computer database. The inspector reviewed the September 12, 1986 bulk listing for the Instorage Maintenance System. The maintenance action required list which defines the previously missed maintenance actions was reviewed with LTM personnel. The inspector was informed that missed maintenance activities are assessed on a case by case basis and prioritized where necessary to ensure completion in a timely manner. The inspector discussed the requirement to decrease mainten6nce intervals when an unsatisfactory finding is issued for particular equipment. A case was reviewed where the time interval was decreased accordingly, d.
The inspector reviewed the following vendor instructions and the associated portions of the Bechtel maintenance log:
Equipment Document HPCI Pump 8031-M-1-E41-C001-K-1.1T RCIC Pump Procedure D51.3 RCIC Turbine Specification SP-11 The site program adequately incorporated the vendor storage and maintenance requirements.
No violations were identifie _
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9.0 Structural Steel and Concrete a.
The inspector witnessed concrete pour DW-HK-47, 48 for the diesel generator building. He observed slump, air content, unit weight tests, temperature and preparation of test cylinders.
The inspector noted that the measured concrete unit weight was 144.47 lbs.
FSAR section 12.3.2.2 states the minimum bulk density of concrete is 145 lb. per cubic foot.
Pending resolution of PECO Finding Report 2N-531, this item is unresolved (86-12-07).
b.
The inspector reviewed the following documents regarding the erection of structural steel:
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FSAR Sections 3.8.4.6.2
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AISC Steel Construction Manual
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Specification C-63, " Erection of Structural Steel"
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Quality Control Instruction (QCI) 2.10, " Structural Steel Erection"
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Quality Control Inspection Reports (QCIRs)
C672-MS-315A-8-1 C668-MS-315A-8-1 C672-MS-315A-8-1
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Drawing C-672 Diesel Generator (DG) Baffle Plate C-667 DG Roof Framing Plan C-668 DG Crane Girder Plan Bethlehem Steel Drawing 8031-C-41C-24-4
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Field Change Request CS-634
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The inspector examined selected bolted connections, welded connections, and member configuration in the diesel generator building area. The steel composed portions of the roof frame and the crane girder system. Welded connection details were confirmed to comply with AISC criteria.
The installed high strength bolts were found satisfactory.
No violations were identified.
10.0 Fire Prevention a.
The licensee has established procedures that pertain to fire prevention, detection and suppression.
The inspector reviewed the following documents:
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Construction Procedures CP-S-2, " Control and Disposal of Hazardous / Controlled Substances" CP-S-3, " Fire Protection and Emergencies" CP-C-4, "Jobsite Housekeeping and Cleanliness Control" Field Safety Procedures
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FSP-1, "The Reporting and Handling of Medical, Fire and Safety Emergencies" FSP-2, " Fire Brigade / Fire Watch Organization and Training" FSP-3, " Fire Equipment Maintenance and Inspection" FSP-4, " Fire Impairment Procedure" FSP-5, " Fire Brigade Action Plan" PECO Finding Reports 2G-496 and 2G-495
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The Bechtel procedures contain provisions regarding:
The control of welding and burning activities
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The use of fire retardant lumber
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The control of combustible material
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The maintenance and inspection of fire fighting equipment
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The training of fire fighting personnel
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The notification of operations personnel regarding damaged equipment The inspector found the Bechtel procedures to provide an adequate framework for fire prevention and mitigation.
b.
The inspector performed a plant tour of the reactor building elevation 201 ft and found the fire extinguisher equipment and hose stations properly maintained.
During plant tours the inspector observed the use of fire retardant lumber in the primary containment. The inspector noted a segregated storage area for combustible liquids. The use of fire retardant sheets was observed in the vicinity of welding operations.
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No items of concern were identified.
11.0 Bechtel Quality Assurance a.
The inspector reviewed Quality Assurance (QA) activities related to audits and surveillances of engineering activities. The following l
audits were reviewed:
Audit
' Description of Area Audited PFA 725 Calculations and change notices PFA 775 NCR dispositions PFA 754 Project administrative instructions
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PFA 726 Supplier surveys PFA 771 Design interface controls PFA 774 Fire protection design PFA 761 Material requisition The scope of weekly monitoring activities was reviewed which includea electrical separation criteria, engineering personnel training, seismic IIA program, NCR closure, control of vendor documentation and GE interface activities. The inspector additionally reviewed several audit finding reports covering engineering activities.
No items of concern were identified.
b.
The Bechtel quality assurance program requires that implementing procedures be issued to control engineering and design activities.
The inspector reviewed selected Engineering Department Procedures (EDPs), Engineering Department Project Instructions (EDPIs) and associated directives. The procedures govern activities associated with design control, design review, design interfaces, nonconformance resolution, 50.55e evaluation, calculations, design changes and engineering records.
No items of concern were identified.
c.
The following documents were reveiwed by the inspector regarding Inprocess Rework Notices (IPRNs):
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PSAR Appendix D Bechtel Nuclear Quality Assurance Manual Section N No. 7
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Quality Control Notices Manual PSP-G-3.1
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The Bechtel procedures allow for inprocess deficiencies that can be corrected by adjustment, reassembly, or other rework actions to be documented on an IPRN in lieu of a Nonconformance Report (NCR).
Both IPRNs and NCRs are trended by Bechtel QA. The inspector reviewed the following IPRNs and associated records for adherence to the Bechtel procedure:
M-89, M-85, P-6940, P-6933, P-6930, and P-6928. The inspector identified no items of concern and had no further questions.
No violations were identified.
12.0 Unresolved Items Unresolved items are matters about which more information is required to ascertain if it is acceptable, a violation, or a deviation. Unresolved Items are discussed in paragraph 4c, 8b, and 9a.
13.0 Exit Meeting The NRC resident inspector discussed the issues and findings in this report with members of the licensee's staff on a weekly basis, and at an exit meeting held on September 26, 1986. Based on the Region I review of
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1 this report and discussions held with licensee representatives on August 1,1986, it was determined that this report does not contain information subject to 10CFR2.790 restrictions.
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