IR 05000353/1986018
| ML20207N152 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/06/1987 |
| From: | Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207N144 | List: |
| References | |
| 50-353-86-18, IEB-74-13, IEB-79-02, IEB-79-2, IEIN-86-094, IEIN-86-94, NUDOCS 8701140019 | |
| Download: ML20207N152 (14) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 86-18 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: November 3 - December 21, 1986 Inspector:
R. A. Gramm, Se for Resident Inspector Approved by:
MA
/!4!87 Robert M. Gallo, Chief Date Reactor Projects Section 2A Inspection Summary: Report for Inspection Conducted November 3 - December 21, 1986 (Report No. 50-353/86-18)
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, concrete expansion anchors, Bechtel quality assurance, Bechtel engineering, structural steel, instrumentation components, and welding operations.
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 i
inspector.
Results: No violations were identified.
Several new NRC open items were identified without a corresponding close out of old items, thus increasing
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8701140019 870107 PDR ADOCK 05000353 o
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DETAILS 1.0 Summary In process welding operations were observed for the. core spray header and in-core housings.
Large bore piping and pipe supports associated with the core spray system were examined. Discussions were held with Bechtel resident engineering staff on several issues involving mechanical separation and seismic design.. Follow-up inspection'on-IE Bulletins identified that the PECO Alert List, which tracks deficient components, had not been kept current. The QC surveillance of temporary support welding operations had not been performed. ' Installed concrete anchor bolts were found satisfactory; however in several cases the minimum embedment depths _had not adhered to vendor recommendations. Bechtel Quality Control and Quality Assurance activities were satisfactory. A piece of shop fabricated structural steel provided by Chicago Bridge and Iron was found slightly out of tolerance with respect to weld size and member thickness.
No concerns were identified in the area of the welder
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2.0 Plant Inspection Tours The inspector observed in progress work activities, completed work, and plant status in several areas during inspection tours. Work was examined for defects and compliance with' regulatory and license requirements. 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:
Some construction equipment was stored in a Reactor Pressure Vessel
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(RPV) nozzle located at azimuth 90 degrees and elevation 309. PEC0 Quality Assurance (QA) assured the items were removed.
-The inspector requested a copy of the project Alert List which tracks
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deficient equipment that will not be used onsite. The inspector was informed that the list was last issued in June 1984. PEC0 has issued Finding Report 2N-537. Pending licensee investigation regarding i
procurement activities during the lapse in updating the Alert List and reissuing a current list, this item is unresolved. (86-18-01)
l Core spray pump room chiller 2DV-211 was found unprotected from
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construction activities and several heat exchanger fins were damaged. The inspector reviewed previously issued Inprocess Rework Notice (IPRN) M-103 that documented the concern for resolution by
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construction.
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The HPCI turbine levelness check operation was observed by the
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inspector and the associated work Package 20-S211-A was reviewed. The cognizant field engineer and QC inspector were interviewed. The inspector had no concerns.
No violations were identified.
3.0 Licensee Action on Previously Identified Items (0 pen) Unresolved Item (86-12-06):
Equipment storage and resolution of In-Process Rework Notices. The inspector noted that Bechtel audit report PFA 757 identified similar concerns. This item remains open.
4.0 Licensee Action on IE Bulletins The inspector reviewed licensee records related to the IE Bulletin 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 Bulletin was reviewed:
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IE Bulletin 74-13:
Factory wiring on GE MCC:.
The inspector was informed that site MCCs are supplied by Cutler Hammer and that neither Vulkene "600" Type XHHW cable or General Electric type 7700 breaker-starters are specified for use on-site.
PECO had committed that a vendor drawing checklist would be used by Bechtel to assure that the deficient equipment identified by this IE Bulletin would not be incorporated in the design of safety-related equipment.
The inspector requested the drawing checklist and was informed that none was available. Bechtel QA issued Quality Assurance Request (QAR)
F-533. The inspector was subsequently informed that construction engineering performs a field check for conditions covered by the IE Bulletin.
Pending licensee clarification, this item remains open.
5.0 Reactor Pressure Vessel and Internals a.
The inspector observed in process TIG welding on the Core Spray header. The welding current was found within the Welding Procedure Specification limits. The associated traveler 2-261T was reviewed.
The welding process was performed satisfactorily and the inspector had no concerns.
I b.
The General Electric filler metal holding oven was examined. A
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calibrated thermometer was used to provide internal temperature indication. The oven holds low hydrogen coated E7018 weld rod. The temperature was found at 115 degrees F.
The inspector was informed that rod had been issued a short time before and GE personnel foaad the heater de-energized.
The oven was immediately turned on.
The temporary variation in even temperature was acceptable to GE supervision. No violations were identifie,
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c.
The welding operation on in-core housings was observed by the inspector. The root pass was TIG welded and the welding current and gas flow rates were within the Welding Procedure Specification limits. The inspector had no concerns.
No violations were identified.
6.0 Piping and Pipe Supports a.
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 off.
The following welds were examined:
Isometric Weld Class System Status VRR-2RD-28 WB-17 I
Recirc Root and Cover pass APE-2MS-LCC2 WC02 I
Main Steam Work Package EBB-229-1 FW6 II HPCI Intermediate pass D LA-212-3 FW6 I
RHR Intermediate pass VRR-2RD-2B B13 I
Recirc Root pass EBB-229-1 FW5 II HPCI Root pass HBB-240-1 FW16 II RHR Root pass APE-2MS-LD WD01 I
Main Steam Cover pass All observed activities were in accordance with applicable procedure ard associated documentation.
No concerns were identified.
I b.
The inspector reviewed NRC NUREG/BR-0051 that documented the failure of Bechtel designed pipe supports at Palo Verde Unit 1.
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inspector requested Bechtel to provide assurance that a similar l
design problem related to localized flange bending and eccentric j
loading due to lateral thermal motion does not exist at Limerick.
Resident Engineering personnel reviewed the Bechtel design criteria
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for Limerick and ascertained that the problem would be precluded by the site design philosophy. 'The inspector had no concerns.
c.
-The inspector examined tack welds on small bore pipe supports for line SP-DCA-298-E4 and support EBB-242-K3-8H-01. The supports are currently defined as temporary supports. The inspector was informed that the piping is run and verified acceptable by engineering then the supports can be upgraded to "Q" Category I status. When the supports are upgraded, a review will be performed to assure qualified welders and material were utilized.
The inspector was further informed that no supports have been upgraded to date and that all temporary support tack welds will be identified and not consumed in the final welds.
The inspector was informed that no Bechtel welding QC surveillances were performed on the tack weld
operations. This item is open pending future inspector review of the control of temporary supports.
(86-18-02)
d.
The inspector reviewed the following documents that pertain to piping and support installation:
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Bechtel Specifications P-300, " Piping Materials and Instrument Piping Standards" P-303, " Cleanliness Control of Piping and Equipment" P-301-2, " Field Fabrication and Installation of Piping for Nuclear Service" P-305, " Welding and Nondestructive Examination"
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Construction Procedure (CP) P-2, " Fabrication and Installation of Large Pipe (2-1/2" and Larger)
ASME Boiler and Pressure Vessel Code Section III-NB
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FSAR Section 6.3.2.2.3 figures 6.3-9 and 6.3-2 Bechtel Iscmetrics HBB-220-1/3/7, GBB-213-1/2/3/4/5/7,
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EBB-213-1
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Quality Control Instructions P-1.10, " Piping Subassembly Field Fabrication, Installation and Rework
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P-2.10, " Pipe Hanger, Support, Restraint and Shock Arrestor i
Installation"
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Bechtel P&ID, M-52, " Core Spray" Sheets 3 and 4.
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Pipe Support drawings GBB-213-H53, HBB-220-H1, HBB-220-H7,
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GBB-213-H26, GBB-213-H18, GBB-213-H17, GBB-213-H61, GBB-213-H55 and GBB-213-H5.
The piping and supports were selected from the Core Spray system.
The inspector visually examined the pipe supports for location, con-figuration, member size, weld size and quality, anchor bolts, and proper clamp and strut hardware. The following piping for loop C and loop A of the core spray system was walked down: pump 2AP206 discharge to the common header, pump 2CP206 discharge to the common header, pump 2CP206 suction from the suppression pool, pump 2CP206 minimum flow return to the suppression pool, the common discharge line to a point near the valve HV-2F004A. A portion of the redundant discharge piping from isolation valve HV208 to valve HV2F048 includ-ing the HPCI injection piping was examined. The piping configuration was satisfactory.
Field weld quality was examined and found satisfactory. The site design was found consistent with the FSAR system description. The inspector had no concerns.
No violations were identified.
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7.0 Concrete Expansion Anchors a.
Several varieties of expansion anchors are utilized to secure components to concrete surfaces. Wedge type anchors are generally used for poured concrete and sleeve type anchors are specified for block walls. The inspector reviewed the following documents that pertain to expansion anchors:
Bechtel specification C-64, " Installation of Expansion Type
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Shell, Wedge and Sleeve Anchors"
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Bechtel procedure CP-C-3, " Review and Installation of Expansion l
Anchors, Thru Bolts, Maxi Bolts, Grouted in Threaded Rods and l
Core Bores" l
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Quality Control Instruction, C-1.50, " Installation and Testing
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of Anchors" IE Bulletin 79-02, " Pipe Support Base Plate Designs Using
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l Concrete Expansion Anchor Bolts"
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PECO letters from V. S. Boyer to B. H. Grier Region I regarding IEB 79-02 L
i IE Information Notice 86-94, "Hilti Concrete Expansion Anchor
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Bolts"
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Vendor files:
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8031-C64-1-1, " Maxi-Bolt Drill Co. Devices Manual" 8031-C64-2-1, "Phillips Red Head Anchoring Systems Specification Guide for Architects and Engineers" 8031-C64-3-1, " Recommended Procedure for Installation of Drillco Maxi-Bolt Anchors" 8031-C64-4-1, " Molly Parabolt Concrete Anchors" The installation specification and Quality Control (QC) procedure contain the requisite provisions and attributes to govern the installation and inspection of the expansion anchors.
b.
The inspector was informed via IE Information Notice 86-94 that the ultimate tensile capacities for Hilti Kwik-Bolts had recently been reduced for one-half (1/2) inch diameter bolts. Bechtel Design Guide C-2.40, " Concrete Expansion Anchors" was reviewed and the design ulti;nate tensile values were more conservative than the Hilti recommendations. The inspector had no further questions.
c.
The inspector reviewed expansion anchor vendor recommendation for minimum embedment depth and minimum spacing requirements. The following inconsistencies were identified with respect to the Bechtel Specification:
Type Vendor minimum Specification C-64 minimum Phillips Red Head 1/2" hex nut 1-7/8" embedment 1-13/16 embedment 3/8" hex nut 1-1/2" embedment 1-3/8 embedment Molly Parabolt 1/2" 2-1/4" embedment 1-13/16" embedment 1"
4-1/2" embedment 3-7/A" embedment 1/2" 6" bolt to bolt 5" bolt to bolt 1"
12" bolt to bolt 10" bolt to bolt Reductions in embedment depth and bolt to bolt spacing could result in corresponding reductions in expansion anchor capacity.
Pending review of Bechtel test data and analysis to justify the identified reductions, this item is unresolved.
(86-18-03).
d.
The inspector examined the following expansion anchor installations for compliance with the Bechtel specification:
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Bolt Dia.)
No. of Installation Remarks (Inches)
Bolts 5/8 J
Tray Support-20CQB01 1/2
Conduit support-1107 20I024 1/2
Conduit support-1103 2CIO26 1/2
Instrument Support JML-56-01-17Q-A In process 1/2
Conduit support-1124 2 BID 26 The installations were in accordance with the Bechtel requirements.
No violations were identified.
8.0 Bechtel Quality Assurance The inspector reviewed the site Quality Control (QC) Administrative a.
Instructions. The instructions are used to disseminate additional guidance or instructions that is not contained within the Field Inspection Manual or the Quality Control Notices Manual. QC Instruction 2-11 provides for a QC monitoring activity to reverify, on a sample aasis, the inspections performed by QC personnel. The inspector reviewed the following QC Finld Inspection Reports that document recent monitoring activities: MT00096, MT00118, MT00105, MT00104, MT00102, MT00091, MT00100, MT00099, MT00116, MT00097, MT00035, and MT00054. The recent reports were - satisfactory. Two previous examples of improper QC inspection conduct of pipe supports had been investigated and resulted in training, reinspection and issuance of Nonconformance Reports. The inspector had no further questions.
b.
The Bechtel QC program specifies that a Corrective Action Report (CAR) be issued to document deficiencies in the conduct of QC activities that are detected internally or by audit organizations.
The CAR also documents the associated corrective actions taken to rectify the discrepant condition. The inspector reviewed CARS 97 thru 108 issued from April through October of 1986. The documented actions were appropriate, c.
Bechtel Quality Assurance (QA) audits are performed by site and San Francisco personnel. The inspector reviewed the following Bechtel home office audit reports:
Audit Date Area Audited PASF-386 7/7 - 7/11/86 Control of design calculations (
PASF-387 7/16 - 7/24/86 Project material requisitions PASF-389 9/8 - 9/12,86 Project engineering drawings and drawing change notices
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PASF-393 9/18 - 9/22/86 Fire Protection QA program PASF-395 10/14 - 10/20/86 Off project design review PASF-397 10/30/86 Project Q-List control The inspector also reviewed the following site audits including the audit checklists, audit findings, data collection sheets, and audit reports:
Audit Date Area Audited PFA-786 10/10 - 11/3/86 Welding and NDE PFA-785 10/6 - 10/10/86 Off project design review PFA-757 9/30 - 10/16/86 Material storage and maintenance No violations were identified.
I 9.0 Bechtel Engineering a.
The inspector examined the configuration of piping in the primary containment wetwell.
Several pump suction openings were observed to be in close proximity to Main Steam Relief Valve (MSRV) quenchers.
t Bechtel Resident Engineering provided the following documents that
had previously analyzed the potential effects of air ingestion on the pumps:
General Electric Field Deviation Disposition Request HH1-8078
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GE letters GLB-3351 dated June 25, 1984, and GLB-3037 dated
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l March 19, 1981 Bechtel letter BLG-4458 dated November 3, 1980
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The potential for air ingestion has been evaluated by Bechtel, GE and the pump vendor and found that no deleterious effects will result. The inspector had no concerns.
b.
The inspector reviewed Bechtel Specification G-23, " Separation Program" and the " Separation Review Report for LGS #2."
The plant layout was reviewed by Project Engineering for hazards associated i
with pipe breaks and internal missiles.
Some items had to be rerouted and shield plates were required to prevent equipment damage. The inspector reviewed the following installation drawing
changes:
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Drawing Remarks
E-1257
. Conduits rerouted
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M-1173 DCN 12 issued to revise barrier location
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E-1260 Conduits rerouted The inspector discussed the effect'of field tolerances upon the assumptions of.the separation review.
Resident Engineering requires-Field Change Requests _for field installations which exceed
predetermined tolerances. Additional field walkdowns are scheduled
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by engineering to-verify the separation requirements. The inspector
had no concerns.
c.
The inspector reviewed the following documents that relate to seismic IIA structures:
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FSAR section 3.2.1 and 1.8 Regulatory Guide 1.29, " Seismic Design Classification" i
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Bechtel Specification M-400, " Safety Impact Review"-
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Bechtel QA Manual Section 0 Number 8, "Special Class II Seismic l
(IIA) Quality Assurance Program"
PECO QA Manual Appendix J, " Quality Contro1LProgram for "R" and
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"S" Listed Items"
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PECO R/S Checklist P-6, " Installed Pipe Support"
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Bechtel Drawings M-109 Sheets 1 to 9
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-The Seismic IIA items are examined by Bechtel Construction
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engineering and PECO to verify cerformance with design requirements.
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For Seismic IIA items that are nonseismically designed, Bechtel
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intends to perform a plant walkdown to review the potential for
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i impact upon safety related items. The inspector was informed that
Specification M-400 is under revision and that a field implementing
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safety impact review procedure had not been written. The inspector
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i-will review the revised specification, the implementing procedure,-
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and the analysis of nonseismic piping located in Category 1 areas during a future inspection.
(86-18-04)
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l-1110.0 Structural Steel a.
The inspector reviewed the following documents that pertain to the
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seismic truss and stabilizer assemblies that are located at the top l
of the bio-shield wall:
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FSAR sections 3.8.3.1.6 and 3.8.3.6.3 and figures 3.8-26 and 3.8-43
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Bechtel drawings C-286 and C-936 The truss installed at Azimuth 180 degrees was examined for conformance with the design drawings. The inspector checked member size, configuration, weld size and weld quality. The following concerns were identified:
Two dimension details were inconsistent between the FSAR
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figures and the design drawings.
Two welds appeared to have slightly undersized vertical leg
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lengths.
The builtup member width was 11-1/4" in lieu of 11".
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One side piece was 1-11/16 thick in lieu of 1-1/2".
PECO QA examined the installation and confirmed the inspector's observations. PECO issued Finding Reports N-539, N-540 and N-541.
The inspector was informed that a Licensing Document Change Notice will be issued to correct the FSAR and that engineering will disposition the nonconforming conditions. The inspector was further informed that structural steel originally received through Chicago Bridge and Iron Co. will be reexamined by Bechtel QC.
The above concerns are unresolved pending completion of licensee investigations, and engineering actions.
(86-18-05)
b.
The inspector identified several loose high strength bolts at structural steel connections located in the primary containment at elevation 277 azimuth 75 degrees. The licensee provided drawing C-931 which authorized the slip connections. The inspector had no concerns.
c.
The inspector examined the installation of rigid conduit 2BI144 at elevation 294 in the Reactor Building. The conduit was mounted on the exterior of Primary containment and was separated by less than l
one (1) inch from an adjacent structural steel member. Work Package R-9-0004 was reviewed which documented the completion of the conduit in question. The structural steel platform had not yet been inspec-ted by Bechtel QC.
PECO determined that drawing E-1406 would be revised to add criteria for this configuration. The revised criteria will result in backfit QC inspections of previously accepted items.
The framing steel was notched around conduit 2BI144.
Pending licen-see completion of the drawing revision and field walkdowns this item is unresolved.
(86-18-06)
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11.0 Instrumentation Components a.
The inspector examined instrument tubing support 3 on run JTR-51-05-22A-A and observed that the tubing was attached with mixed friction clamps type 2D and 3D. The support had not been accepted by field engineering or QC. The clamp was reworked so both halves were 20 type. The inspector had no concerns.
b.
The inspector monitored in process installation of instrument supports. The following documents were reviewed in the work area:
Work Package JML-52-01-16Q-A and JML-52-01-12Q-A
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The supports were examined for anchorage, welding, equipment identification, location and member size.
The inspector had no concerns.
c.
The inspector observed the in process cable termination of cable 8909-R350-001 in the PGCC panel 609 F-11.
The inspector had no concerns. The inspector examined two terminal lugs in panel 611 terminal block KKK1 point 35 and 43 that were installed upside down.
The lugs had not been inspected and were subsequently corrected by Bechtel construction.
d.
The installation of under vessel flexible conduits for LPRM/IRM/CRD/
and SRM wires was examined.
The inspector reviewed the associated documentation:
Work Package R14-079
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Field Change Requests (FCR) ME-100 and ME-85
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Teledyne Engineering Services Drwg. E-7201: file 8031-M-164-TSA-142-1 and Drwg. E-7200: file 8031-M-167-TSA-141-1 The conduits were installed with appropriate overhang, sag and on the correct side of the supports. The support hardware was examined for bolt size, welding, jam nuts and stop plates.
The inspector had no concerns.
No violations were identified.
12.0 Welding and Welder Qualification a.
The inspector accompanied a Bechtel QC weld inspector during a surveillance of AWS welding activities.
The wetwell activities on pipe supports and downcomer bracing welding was monitored.
In accordance with QC Instruction W-1.60, "In-Process Welding Inspection" the following attributes were checked: associated work packages, welder qualification, proper filler metal, adherence to
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welding procedure specification, proper preheat, and weld quality.
The inspector had no concerns.
b.
The inspector reviewed the following documents that pertain to the welder qualification program:
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Bechtel Welder Qualification Listing dated October 17, 1986
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Bechtel Accounting Procedure 8031-TK-4, " Hiring of Manual Employees:
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ASME Section IX, " Welding and Brazing Qualifications"
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Bechtel ASME Section III QA Manual Section 5000 WD-1, " Welding Standard"
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WQ-1, " Welding Standard Performance Specification Construction Procedure CP-W-1, " Welding"
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PECO Surveillance Audits 2M0492 (86) and 2C0287 (86)
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Bechtel Audit PFA-786.
The recent licensee and Bechtel audits of the welder qualification program were reviewed. The only finding related to the timeliness of updating the qualified welder listing.. The Bechtel specifica-tions incorporated the necessary elements of the ASME qualification requirements. The inspector was informed that welders are uniformly qualified under Section IX which is then extended to cover AWS welding. The inspector observed ongoing welder qualification tests and confirmed.the identities of the welder'. The test booths and several weld coupons were examined.
The welders were qualifying with 10-inch pipe in the 2G and SG positions.
The test booth weld supervisors were interviewed. The inspector held discussions with Bechtel supervision regarding issuance of site photo ID badges. The prospective welders must show a Social Security card plus two other forms of identification with their signatures.
Records of several welders that had terminated and were rehired were reviewed.
Several in process welding operations were cbserved and the associated welders were checked against the qualified welder list.
The inspector nad no concerns.
No violations were identified.
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. Unresolved Items were discussed in paragraphs 2, 7c, 10a., and 10.-
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14.0 Exit Meeting Ti.e 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 December 19, 1986. Based on discussions held with licensee representatives on December 19, 1986, it was determined that this report does not contain information' subject to 10 CFR 2.790 restrictions.