IR 05000353/1986019

Insp Rept 50-353/86-19 on 861117-21.No Violations Noted. Major Areas Inspected:Hvac Duct Work Fabrication & Support Const

ML20212J131
Person / Time
Site:	Limerick
Issue date:	01/12/1987
From:	Strosnider J, Varela A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20212J101	List: IR 05000353/1986019 ML20212J097
References
50-353-86-19, NUDOCS 8701280092
Download: ML20212J131 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-353/86-19 Docket N License No. CPPR-107 Priority --

Category A Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name: Limerick Nuclear Generating Station, Unit 2 Inspection At: Limerick, Pennsylvania Inspection Conduct : November 11 ,21, 1986 Inspector: . , lh b dd/I I, lf 87 A. A. Varelad Lead Reactor Engineer

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. Strosnider, Chief, Materials and date rocess Section, EB, DRS Inspection Summary: Inspection Report No. 50-353/86-19 on November 17 - 21, 198 Areas Inspected: A routine unannounced inspection was conducted by one regional-based inspector of Licensee, A-E and contractor activities relating to HVAC duct work fabrication and support construction. Corrective actions resulting from non-conformance reports in HVAC fabrication and quality control of installation were verifie Results: No violations were identifie '

8701200092 870115 PDR ADOCK 05000353 G PDR

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DETAILS Persons Contacted Philadelphia Electric Company (PECo)

• D. Clohecy, Construction Engineer

• D. A. DiPaolo, QA Branch Head

• L. C. Dyer, QA Engineer-HVAC

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K. W. Meck, QA Engineer Bechtel A. Quaou, Lead Civil Resident Engineer

• V. Aggarwal, Resident Engineer-Civi'

• C. Bell, Project QA Engineer

• A. Drucker, Lead QA Engineer

• H. F. Greenawalt, QA Engineer

• G. Gallandorm, Construction Engineer D. Harder, Quality Engineer G. C. Kelly, Lead Site QA Engineer S. J. Loofbourrow, Lead Civil Quality Engineer G. D. Morgan, HVAC Coordination Engineer L. Pons, Resident Engineer-Civil J. E. Russell, Q. C. HVAC-Mechanical Supervisor W. J. Tate, Lead Construction Engineer-HVAC J. Zierle, Sub contracts Engineer

• Denotes attendees at exit meeting conducted on November 21, 198 . Inspection Purpose and Scope The purpose of this inspection was to review with cognizant and respon-sible licensee, A-E and contractor representatives the ongoing corrective actions required to disposition the following HVAC installation and fabrication problem .1 Non-Conformance Report 11009 An apparent design control / coordination problem resulted in conflict-ing installation design information for HVAC construction of duct hangers and supports. Bechtel design change notices (DCNs) issued against the Schneider Power Corporation (SPC) construction drawings /

sketches were not incorporated, referenced or attached to Bechtel design drawings. Bechtel QA identified that the field changes made to the SPC construction drawings had not been incorporated in the original Bechtel design drawings. Additionally, field change requests (FCRs) and field change notices (FCNs) issued against SPC drawings were not necessarily referenced, attached or incorporated against Bechtel design drawings. Non-conformance report number

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11009 dated July 15, 1986, which reported the above problem resulted in quality action requests (QARs) by Bechtel QA. A summary report dated October 9, 1986 was developed by Bechtel QA to assure Bechtel Management and PECo that the HVAC problems and quality concerns were being addressed in a timely and professional manne Corrective actions taken as a result of NCR 11009 included: Craft support engineers were instructed to ensure that Schneider hanger sketches were in compliance with the Bechtel generic standard details. If there were deviations, FCRs were generated to document the difference . Resident Engineering performed a review of the Schneider hanger drawings that were previously approved in variance to the Bechtel Civil Standards. Numerous DCNs were issued to-the appropriate Bechtel drawings for those Schneider sketches differing from the Bechtel detail . Field Engineering instituted a re-inspection effort of all previously accepted Q Listed hangers (all hangers accepted prior to July 17, 1986 were re-inspected). QC instituted a re-inspection effort of all previously accepted Q listed hangers installed prior to July 17, 198 . Training was conducted and is continuing to inform HVAC engineer and craft people of recurring problems identified in the re-inspection .2 Non-Conformance Report 11270 Bechtel's engineering design drawing number C-1329 applies to rectan-gular duct fabrication for HVAC inside the drywell containment. The specific requirement for duct stiffener spacing of 24" identified by this drawing, in the notes and referenced tables, was incorrectly interpreted as not applying to all duct pieces fabricated by SPC in Pittsburgh. Consequently, duct pieces not conforming to the 24" stiffener spacing were shipped to the site, installed and accepted by Bechtel field and QC engineering. This continued up until October 3, 1986 when the non-conforming condition was recognize Non-conformance report number 11270 reported Octcber 3, 1986 on the above problem, was closed-out, "Use as is," November 26, 1986.

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3. Inspection Coverage The inspection effort associated with the above non-conformance reports consisted of the following.

I a) In plant inspection of twelve areas where duct installation was in progres b) Review of: (1) HVAC duct work and HVAC hanger system installation procedure CP-M-3, Revision 6; (2) QC instruction M-4.10-2 for instal-lation of HVAC supports, Revision 2; (3) QC instruction M-4.20-2 for installation, of HVAC ductwork and components, Revision 1; (4) QC instruction M-4.30.2 of on-site fabrication of HVAC ductwork and supports, Revision 1; (5) Procedure CP-M-3, Revision 6, for fabrica-tion, installation and construction testing of HVAC ductwork and HVAC hanger system c) Review of licensee and Bechtel quality assurance audits and surveil-lance activities relating to HVAC on-site construction and offsite fabricatio d) Review of reverification inspections of installed drywell contain-ment ducts for field disposition of NCR number 11270, and engineering calculations which formed the basis to " Accept-as-is" the as-fabri-cated stiffener spacings that do not conform to specified 24 inch stiffener spacing.

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e) Review of reverification inspections of other installed and previ-ously accepted safety related ducts for field disposition of NCR number 11270 and justification to " Accept-as-is."

f) Review of reverification inspections of previously installed and accepted duct supports and hangers for field / engineering disposition and corrective actions affected by NCR number 1100 g) Review of Bechtel quality action requests (QAR), numbers F-520 and 531, associated with disposition of NCRs resulting from reinspection Review of the licensee quality concerns and the reportability evalua-tion per 10 CFR 50.55e resulting from NCR number 1100 h) Review of Bechtel engineering design procedure EPD number 4.58, Supplying and Reviewing Supplier Engineering and Quality Verification Documentation which formed the basis for NCR number 1100 ) Review of on going HVAC Training Classes for HVAC craft support engineers and QC engineers. These classes were initiated to review and transfer field experience relating to HVAC generic details thst are confusing and could lead to misinterpretation as identified in NCR number 11009. The NRC inspector attended the eighth (of twelve scheduled) training session for about 30 engineering personnel of

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Bechtel, Schneider and PECo. This session dealt with stiffener requirements at Elbows and Branches, and emphasized the applicability of DCNs attached to design drawings and how to apply various notes and table value j) Review of Bechtel and PECo QA procedures, respectively; Project QA audits, Revision of July 22, 1986; and Disposition of Contractor Approved Use-As-Is Non-conformance Reports, Revision k) Review of HVAC Hanger Productivity Improvement Program dated November 6, 1986. The improvement program encompasses Bechtel Field Engineering /SPC joint walkdown prior to HVAC duct installatio This coordination effort is intended to correct the difficulties identified in NCR 11270. It will also provide Bechtel engineering with agreed-upon changes in SPC construction drawings / sketche Quality Control engineers will thereby save time by not having to research Bechtel details and note These NRC inspection efforts were augmented by interviews with licensee and Bechtel QA engineers and physical observations in association with PECo and Bechtel field engineers. The inspector performed independent verification of craft workmenship in duct fabrication and installation of supports for three separate areas. They consisted of: (1) Inspection of QC checks and sign offs for a completed HVAC duct support installation in Reactor Building area number 17, elevation 331 (rectangular duct 72" x 120", Standby Exhaust Air for Refueling, hanger number M-1181-01/

H002); (2) observation of Bechtel QA/QC and field engineering As-Built verification inspection of Reactor Building area 14, elevation 201 (rectangular duct 8" x 12" hanger number M 1158/H-15, Exhaust Air Supply);

and (3) observation of SPC site fabrication shop Welder qualification /

proficiency test for AWS D1.1-85/ Shielded Metal Arc Welding with a three foot extension type electrode holder in a restricted conditio . Review of Licensee Administrative Controls and Quality Assurance In determining the adequacy of PECo's administrative controls in assuring quality in installation of HVAC duct work and support construction by SPC crafts and QC inspection by Bechtel, two audit reports (numbers 2M 521 and 2M 525) were reviewed. These reports demonstrate responsible licensee involvement in assuring quality of HVAC duct fabrication and installatio PECo QA and construction engineers participated in Bechtel meetings relating to corrective actions imposed for close out of NCRs Nos. 11009 and 11270. They also conducted surveillance - monitoring inspections of HVAC construction and its quality control. In conclusion, PECo's adminis-trative controls were observed to fulfill responsibilities in compliance to 10 CFR 50 Appendix B Criterion XVII _ - .- .

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6 Summary Based on the information examined during this inspection and the results of observations made during field walkdowns, the corrective actions taken for disposition of nonconformances documented in NCR numbers 11009 and 11270 provide consistent evidence of quality fabrication and installation of HVAC ductwork and hanger systems at Limerick Unit . Exit-Meeting The NRC inspector conducted on exit meeting with licensee and Bechtel representatives (denoted in paragraph 1). The NRC inspector summarized the inspection findings and the licensee licensee acknowledged these comments. No written material was provided to licensee personnel.

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