IR 05000353/1986015

Insp Rept 50-353/86-15 on 860929-1102.Violation Noted: Failure to Properly Perform ASME Hydrotest as All Field Welds Not Visually Examined During Test for Leakage

ML20214K839
Person / Time
Site:	Limerick
Issue date:	11/19/1986
From:	Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214K807	List: IR 05000353/1986015 ML20214K805 ML20214K821
References
50-353-86-15, NUDOCS 8612020483
Download: ML20214K839 (12)

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U. S. NUCLEAR RGULATORY COMMISSION

REGION I

Report No. 86-15 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: September 29 - November 2, 1986 Inspector: R. A. Gramm, Senior Resident Inspector Approved by: 2 L ll li 8(:p Robert M. Gallo, Chief Date Reactor Projects Section 2A Inspection Summary: Report for Inspection Conducted September 29 - November 2, 1986 (Report No. 50-353/86-15)

Area Inspected: Routine inspection by the resident inspector of work activities, procedures, and records relative to reactor pressure vessel and internals, piping and pipe supports, electrical cables and raceways, HVAC duct ana supports, nondestructive weld examination, and spent fuel storage rack The inspector reviewed licensee action on previously identified items and performed plant inspection tours. The inspection involved 109 hours0.00126 days <br />0.0303 hours <br />1.802249e-4 weeks <br />4.14745e-5 months <br /> by the inspecto Results: One violation was identified: An ASME hydrotest was improperly performed as all field welds were not visually examined during the test for leakage (paragraph 6d).

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B612020483 PDR 861120 O ADOCK 05000353 PDR .

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DETAILS 1.0 Summary Work activities that were satisfactorily examined during the inspection include safety related pipe welding and supports, structural steel erection, High Pressure Coolant Injection pump assembly, reactor pressure vessel welding, core support plate installation, installed electrical raceways and control of nondestructive examination activitie A violation was identified in which an ASME hydrostatic test was improperly performed. Field engineering and quality control failed to visually examine a pipe field weldment for leakage during the inspection at design pressure as required. A deformed rod on the core support plate structure is an unresolved ite .0 Plant Inspection Tours The inspector observed work activities in progress, completed work and plant status in several areas during inspection tours. Work was examined for defects, compliance with regulatory requirements, and license condition 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 preser-vation. The inspector interviewed craft supervision, craft and quality control personnel in the work areas. The inspector met with General Electric (GE) quality control personnel and discussed the status and closure of GE Field Deviation and Disposition Requests (FDDRs) and Field Disposition Instructions (FDIs). Observations are noted below:

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A copper air line was damaged on ASCO solenoid valve M-11-3P-HV201 In Process Rework Notice P6973 was issued by Bechtel to document the conditio The High Pressure Coolant Injection (HPCI) pumps were reassembled in accordance with work package 20-S211-A. A Byron-Jackson representative was present during the reassembly of the pum Several heat exchanger fins were deformed in unit chiller 2AV-21 Bechtel issued Quality Control Inspection Report (QCIR) 2A-V210-45-1 to document the repair of the fin The diesel generator roof slab was examined before and after placement.

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The A490 anchor bolts for the drywell equipment floor drain sumps t were examine Lack of full; engagement of the locking nuts was. P questioned. The inspector was. presented Field Change Request (FCR)

M20211F.that. approved the installed configuratio i ,

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The quality. control torque verification of structural steel A325 bolting identified in work package C927-SS-23 was observe The inspector was informed that Peach Bottom Clow Corporation butterfly valves had become inoperable due to excessive pitting and corrosion between the valve shaft and bearing material. The inspector reviewed PECO Significant Deficiency Report (SDR) 177 and

. Surveillance Check Report (SCR) 2G-125. PECO QA verified that the'

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Limerick Unit 2 Clow corporation butterfly valves had not been procured. The inspector had no further questions at this tim l

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The installation of a rock bolt on a quencher' support base plate was observe No violations were identifie ;

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3.0 Licensee Action on Previously Identified Items (Closed) Unresolved Item (86-10-03): - Seismic qualification of the

, station batteries. The inspector reviewed Bechtel drawing E-1412 and Field Change Request (FCR) E8431F which specified that Burndy

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flexible copper braids are utilized for the connection of cables

attached to the battery posts. The flexible connectors were designed to provide for isolation of the cable mass during a seismic even The inspector concluded that the flexible connection resolves the problem of not simulating the plant cable mass during the seismic qualification testing of the batteries. The inter-tier cable was examined. The slightly oversized cable relative to the C & D vendor prints will have no detrimental effects. This item is close (Closed) Followup (86-12-04): Substitution of Powerstrut and

Unistrut spring nuts. The inspector reviewed vendor documentation that specified the slip and pull out capacity of the spring nuts was

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identical. The associated strut configurations and material types

were identical. The inspector concluded that the hardware

substitution would not affect the spring nut slip or pull out

, capacity. This item is closed.

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4.0 Licensee Action on IE Bulletins The inspector reviewed licensee records related to the IE Bulletins identified below to verify that: the IE Bulletin was received and reviewed for applicability; a written response was provided if required; and the corrective action taken was adequate. The following IE Bulletins were reviewed:

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IE Bulletin 74-08, Deficiency in ITE Molded Case Circuit Breakers, t

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Type HE- Circuit breakers manufactured prior to May 1974 had

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excessively high pickup points of the instantaneous magnetic trip elements that could lead to cable damage and trip coordination-problems. The inspector was informed that Type HE-3 circuit breakers were utilized in the hydrogen recombiner panels. The licensee verified that the four breakers were manufactured after May h 1974 and therefore not susceptible to the problem identified in the IE Bulletin. This item is close O

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IE Bulletin 81-03, Flow Blockage of Cooling Water to Safety System Components by CORBICOLA SP (Asiatic Clam) and MYTILUS SP (Mussel).

This bulletin was issued in response to flow degradation in piping and heat exchangers due to a buildup of clam shells. The licensee has conducted surveys of the Schuyliill River and has not detected either Corbicula or Mytilus near the Limerick Statio The inspector reviewed a draft copy of a 1985 environmental report that found indications of the clam at a point approximately eleven (11)

miles downstream from the plant. The inspector was informed that the environmoltal monitoring will provide an ongoing assessment of the Corbicula presence in the Delaware and Schuylkill Rivers. This item is close .0 Reactor Pressure Vessel and Internals The following documents that pertain to the installation of the Reactor Pressure Vessel (RPV) internals were reviewed by the inspector:

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Final Safety Analysis Report (FSAR) section 4. Bechtel Specification M-108, " Installation of the RPV Internals

, and the Design of the Traversing Incore Probe System"

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General Electric (GE) Specification 22A2693, " Reactor Assembly"

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GE QA Manual PIA-AE-11

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GE Nuclear Production Control Manual

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GE Apparatus and Engineering Services Handbook of Procedures and Instructions The inspector found the documents to contain appropriate technical and quality assurance requirements for the RPV internals installation activities, The inspector observed the denosit of a corrosion resistant weld metal overlay on the N1 recirculation suction nozzle ID using a machine gas tungsten arc welding process. The overlay is designed to prevent the initiation of Intergranular Stress Corrosion Cracking

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(IGSCC) in the nozzle material. The associated traveler package was reviewed without any question The inspector observed the alignment of the core support plate in the RPV. The associated traveler package 2-160T was reviewe Work was proceeding in accordance with appropriate requirement In process welding of a core spray post to the RPV was observed. The welder properly cleaned the weld surface prior to depositing the next pass. Adjacent areas of the vessel wall were protected from inad-vertent arc strike The in process torquing of the core support plate bolts was observed and the presence of a GE QC inspector was noted. Use of a calibrated torque wrench and torque multiplier was observed. The craft adhered to the required bolt torque sequence. The associated traveler package and QC records were reviewed. No concerns were identifie The conduct of informational liquid penetrant examinations of the shroud to shroud support weld were observed. The indications were ground out which has necessitated the deposit of additional weld material prior to final examination of the wel The inspector noted that a stabilizer rod which is part of the core support plate bracing was deformed. Discussions with GE quality control personnel indicated that they were aware of the condition but had not previously generated a nonconformance report because the concern was under investigation. The acceptability of the deformed rod and the proper documentation of the condition is unresolved pending GE disposition of Nonconformance Report 2-26 (86-15-01).

No violations were identifie .0 Pipino and Pipe Supports _ The inspector selected safety related pipe welds for observation of welding activities and review of documents. The observation of welding consisted of examination of, when applicable, joint cleanliness; joint fitup and alignment; proper electrodes and filler materials; purge and cover gas flow rates; appearance of weld deposit; evidence of quality control inspection; and quality records. Document reviews verified: the use of proper welding procedures; required nondestructive examination was specified; proper pre and post weld heat treatments were specified; and appropriate quality control hold points were assigned and signed of . ;

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The following welds were examined:

Isometric Weld -Class System Status GBC-216-13 FW5 III MS Fit-up GBC-216-10 FW4 III MS Root repair DCA-418-1 FW1 I RHR Root pass HBB-204-1 FW6 II RHR Surface preparation DBA-206-2 FW1 I HPCI Pre-heat check APE-2MS-LAA WA01 I MS Root pass DBB-203-1 FW6 II FW Surface preparation VRR-2RD-28 FWWB-14 I Recirc Cover pass visual exam All observed activities were in accordance with applicable procedures and associated documentation. No concerns were identifie The inspector observed installation of pipo support GBC-216-H90 Work was proceeding in accordance with written instructions and design requirements. The weldments on support GBC-216-H910 were visually examined by the inspector and found satisfactory. The conduct of a Bechtel QC inspection of support GBC-201-H61 was observed. Support GBC-201-H155 was observed to have been disassembled, the inspector was informed that the QC inspection had not yet been performed on the support. No concerns were identifie The inspector observed Bechtel Quality Control (QC) personnel performing an as-built verification on sr.tIl *, ore line GBB-2DP-20 The inspector additionally observed the conduct of an as-built verification by QC on core spray line GBB-213-2. The QC personnel were knowledgeable of the installation tolerances and performed satisfactory verifications of the as-installed configuration. No concerns were identifie The following documents were reviewed by the inspector that pertain to the performance of ASME Piping hydrostatic tests:

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ASME Boiler and Pressure Vessel Code Division 1,Section III, NB-6000

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Bechtel Specification P-323

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Bechtel QA Manual section 5300

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QC Instruction T-1.00, " Hydrostatic, Pneumatic, and Preoperational In-Service Leak-Testing" The Bechtel procedures were found to incorporate the applicable code requirements regarding conduct of hydrostatic testin The inspector observed the conduct of hydrotest 2M-49A-27 on a portion of the RHR system and 2M-83A-44 on a portion of the main steam pressure relief syste The following items were reviewed:

the use of two calibrated pressure gages, use of a pressure relief device, venting of the piping, verification of test medium temperature, presence of Bechtel QC and the Authorized Nuclear Inspector, a ten minute hold for the ASME test pressure, the performance of piping walkdown at inspection pressure, and the review of the water purity test informatio During the walkdown by the Bechtel hydro engineer and QC inspector of the piping and welds on hydrotest 2M-83A-44, the inspector noted the failure of the Bechtel personnel to perform a visual examination of Field Weld 3 for leakage. The failure to perform an ASME code and procedure required examination is a Violation of 10 CFR 50, Appendix B, Criterion XI. (86-15-02)

Hydrotest 2M-83A-44 was subsequently re performed and accepted by Bechtel hydro engineering, Bechtel QC and the Authorized Nuclear Inspector (ANI). The inspector monitored portions of the re-test and reviewed the pressure test record. Bechtel amended Construction Procedure CP-M-2 to require that leakage examinations be recorded on a checklist, drawing or piping isometric to assure all welds are examine Bechtel provided training for QC and engineering personnel regarding the use of drawings during walkdowns and the necessity to examine all piping within the pressure boundary. PECO QA has issued a directive to utilize drawings to facilitate the conduct of audits and surveillances. Based upon the above actions, Violation 86-15-02 is close .0 Electrical Cable and Raceway The inspector observed the installation of separation sleeve covers to wires within the Control Room panels. The associated GE drawing 828E38112 and construction aid document (CAD) 3 Sheet I was reviewed. The responsible field engineer was interviewed regarding the wire identification and separation requirements. Personnel were found knowledgeable and the work was satisfactorily performe The following documents were reviewed by the inspector regarding installation of electrical cables:

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NRC Safety Evaluation Report Supplement 3, Section 8

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FSAR Sections 7.1.2.2.3.2 and 8.1.6.1.14

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PEC0 letter dated August 16, 1984 - PECO design analysis for cable separation

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Bechtel Construction Procedures (cps)

E-2, " Permanent Plant Cable Installation and Termination"

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Wyle Test Report 46960-3

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Bechtel Quality Control Instructions (QCIs)

E-4.0, " Installation of Electrical Cables" E-5.0, " Cable Terminations"

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Bechtel drawing E-1412, " Wire and Cable Notes and Details" The inspector reviewed the cable separation analysis and associated NRC safety evaluation. The NRC has previously accepted the cable separation program based upon supporting licensee tests and analysis. The site installation specification was found consistent with the cable separation design analysis. Bechtel procedures were determined to contain sufficient criteria to govern the instal-lation of cables. The procedures addressed: cable marking, cable bend radius, cable pull tension, cable splicing, cable routing, QC involvement, temporary cable storage, raceway cleanliness, cable lubricants and cable code. No concerns were identifie c. The inspector examined the following documents with regards to the installation of electrical cable raceways:

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Preliminary Safety Analysis Report (PSAR) Appendix 0

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Final Safety Analysis Report (FSAR) Section 8.1 and Bechtel drawing E-1406 and E-1406-1, " Conduit and Cable Tray Notes, Symbols and Details"

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Bechtel Construction Procedure (CP)-3, " Electrical Raceway"

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Bechtel Quality Control Instruction (QCI) E-2.0, " Installation of Exposed Raceway and Seismic Bracing. Final Welding Acceptance for Electrical Raceway / Support Installations".

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Bechtel drawings E-1117, E-1175, E-1226 and E-113 Bechtel Quality Control Inspection Records (QCIRs) '

E-1500-E1134-14-1, E1500-1175-14-1 and E-1226-W-3.

The following cable trays, conduits and supports in the cable spreading room area were examined by the inspector and found in accordance with design requirements with respect to proper routing, configuration, identification, material size, welding details and spatial separation:

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Support Type C3 for tray 2DTHA F6 for tray 2CTTA section LP7 for. tray 20TBV section 05

'W4 for tray 20TBV section 08 Tray 2CTTA sections 29 to 36 2CTSA sections 29 to 36 Conduit 2AD021 2BH021 2DH009 Quality records associated with the above installations were reviewe ~

No violations were identifie .0 HVAC Duct and Supports The inspector reviewed the following documents that contain engineering and quality control criteria for the installation and acceptance of HVAC duct and supports:

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Bechtel Specification M68A-2, "HVAC Installation Class 1 Seismic"

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Bechtel Quality Control Instructions (QCIs)

M-4.10-2, " Installation of HVAC Supports" M-4.20-2, " Installation of HVAC Ductwork and Components" M-4.30-2, "On-site Fabrication of HVAC Ductwork and Supports"

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Construction Procedure (CP)-M-3, " Fabrication, Installation and Construction Testing of HVAC Ductwork and HVAC Hanger Systems".

The HVAC duct and supports are fabricated by Schneider Power Corporatio Bechtel Quality Control inspects the the duct and associated support The inspector accompanied Bechtel QC personnel during an inspection of hanger 10 on duct run M1152. The hanger was found satisfactory relative

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to: member configuration, weld size and quality, bolt torque, member size and location. The inspector additionally observed a QC inspection of duct piece 63 on run M1152. The duct was properly installe The inspector was informed that several problems had been identified regarding the stiffening of HVAC duct. The problems included stiffener spacing for duct located in the drywell, stiffeners for drop collars and return line stiffeners. Analysis and field investigations are underway to determine the extent of the problems. The inspector reviewed Field

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Change Request M369 and PECO reportability evaluation forms associated with the proble No violations were identifie .0 Nondestructive Weld Examination Bechtel has subcontracted the performance of Nondestructive Examination (NDE) of weldments to Unitech. The inspector reviewed the following documents:

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Preliminary Safety Analysis Report (PSAR), Appendix D. ASME Boiler and Pressure Vessel Code, Division 1,Section V, Articles 1, 6 and ASME Section III, NB-500 ASTM SE-165, " Standard Methods for Liquid Penetrant Examination".

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ASNT-TC-1A, " Recommended Practice for-NDE Personnel Qualification, Certification, and Training" 1980 editio Bechtel Quality Assurance Manual Section 500 Bechtel Specifications P-301, " Field Fabrication and Installation of Piping" P-304, " Nondestructive Examination of Field Walded Pressure Vessels and Piping" P-305, " Field Welding"

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Constructive Procedure (CP) W-1, " Welding"

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Unitech Quality Assurance Plan

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NDE procedures:

PT(SR)ASME III, " Liquid Penetrant (Solvent Removable)"

MT-Dry-ASME III, " Magnetic Particle Examination" Certification and qualification records for six personnel were reviewe All records were found in accordance with applicable requirements and procedure NDE procedures for surface examinations were found consistent with the ASME code requirements. The procedures included provisions regarding surface preparation, application of penetrant and powder, control of test equipment, base material temperature restrictions, dwell and dry time, surface illumination and accept and reject criteria. The procedure allows the liquid penetrant test to be performed at 40 degrees F. The inspector reviewed Procedure Qualification Record NDE-PQR-001 that demonstrated the acceptability of the low temperature test results through testing with a comparator bloc _ --

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-The inspector accompanied Unitech quality control personnel during performance of liquid penetrant tests on line HBB-218-5E field welds 3, 103, 104 and 105. .The inspector additionally observed performance of a magnetic particle examination on downcomer bracing for line 6-270-MS-DCC2-8-1. The tests were satisfactorily performe No violations were identifie .0 Spent Fuel Storage Racks The following documents were reviewed by the inspector relative to the design and quality assurance program applicable to the spent fuel storage racks:

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Final Safety Analysis Report (FSAR) sections 9.1 and figures 9.1-21 and 9.1- Preliminary Safety Analysis Report (PSAR). Appendix D.2.2. PEC0 QA Plan Section 2.12

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PECO Specification MP-7613, "High Density Spent Fuel Storage Racks"

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PECO Audit Reports AR-229, M-356 and M-38 Bechtel receiving inspection reports for the racks

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PAR Systems Corp. fabrication and inspection records, welding records, NDE records, boral maps, nonconformances, certification of conformance, certified material test reports and rack drawing The PECO specification invoked the necessary quality assurance requirements upon the supplier, PAR Systems Corporation. The specification requirements regarding applicable codes and standards, applicable NRC Regulatory Guides, and rack design bases were found consistent with the FSA The inspector reviewed the PEC0 quality assurance audit report that was

, performed at PAR Systems Corporation during the fabrication of the Limerick racks. The audit covered the following activities: control of design documents, review of procurement documents, conduct of PAR audits and vendor audits, rack material identification, control of weld wire, and weldor qualification, examination of fabricated racks, and control of calibrated equipment.

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The racks were receipt inspected by Bechtel and some racks were returned to PAR to clean as they had not been properly covered during shipment. The inspector was informed that PECO performed additional boral mapping to ensure the shielding material was properly installe s

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The inspector was informed that the racks are currently stored at an offsite warehous No violations were identifie .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 Item was discussed in paragraph 5 '12.0 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 October 31, 1986. Based on discussions held with

' licensee representatives on October 31, 1986, it was determined that this report does not contain information subject to 10CFR2.790 restrictions.

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