IR 05000353/1986020
| ML20211A805 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/29/1987 |
| From: | Kamal Manoly, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20211A731 | List: |
| References | |
| 50-353-86-20, NUDOCS 8702190237 | |
| Download: ML20211A805 (15) | |
Text
- _ _ - - _ ____
_ - __
_ _ _ _ _ _ _ - _ _ _ _ _ _ - - _ - _ _ _ _ - _ - - _ _ _ _ _ _ _.
.
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-353/86-20 Docket No.
50-353 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 and Pottstown, Pennsylvania Inspection Conducted:
December 15-22, 1986 Inspectors:
MY
//t 4///
K. A. Manoly, Lead Reactor Engineer date Approved by:
//27[#7
. Strosnider, Chief, Materials and date Processes Section, EB, DRS Inspection Summary:
Inspection Report No. 50-353/86-20 on December 15-22, 1986 Areas Inspected: A routine, unannounced inspection was conducted by a regional-based inspector of onsite design activities in the mechanical area.
The inspection covered design related activities, construction installation of piping and support systems, quality control of construction activities and contractor and licensee audits of project engineering activities.
Results: No violations were identified and two unresolved items were noted.
07021 % h $ $ $53 PDR PDR G
,
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _
=-
.
.
DETAILS 1.0 Persons Contacted Philadelphia Electric Company (PECo)
- G. Lauderback, Jr., Quality Assurance Engineer
- K. Meck, Quality Assurance Engineer T. Szonntagh, Quality Assurance Engineer Bachtel
- R. Palaniswamy, Assistant Project Engineer
- A. Sidhu, Plant Design Group Supervisor C. Haynes, Piping Stress Group Leader W. Patrick, Pipe Support Group Leader
- G. Bell, Quality Assurance Engineer Coordinator
- R. Gramm, Senior Resident Inspector
- Denotes persons present at exit meeting on December 22, 1986.
2.0 Inspection Objective and Scope The purpose of this inspection was to determine whether the licensee's Architect Engineer (A/E) onsite design activity, including controls for engineering and construction initiated field changes, was conducted in compliance with the technical and quality assurance requirements described in the facility FSAR. The inspection covered the following areas:
--
Design activities by the project engineering group in the mechanical discipline including piping and support systems
--
Design Control by the licensee and contractor.
--
Installation of onsite piping and support designs.
Quality Control and construction activities in the area of piping
--
and supports.
3.0 Onsite Engineering Organization and Status of Activities Design activities related to Unit 2 of the Limerick station are performed by the licensee's contractor Bechtel Corporation. The resident project engineering staff is located in Pottstown within few miles of the plant site and represents the majority of the project engineering t
-- - - -..
.. _ -
. - -, - -. - _ _ -. -. - -. -
.
.
organization.
The balance of the project staff remains in Bechtel's home office in San Francisco (SFHO) with an overall responsibility for coordination of mechanical, electrical and civil / structural systems activities and performance of generic and special analyses.
The resident project staff has the overall responsibility for plant physical design in the mechanical, civil / structural, and electrical
disciplines in addition to planning and control and quality assurance activities.
This inspection focused on activities performed by the plant design group which is responsible for mechanical related activities in the areas of piping layout and analysis and pipe supports design.
The inspector was informed that 90% of the overall initial design was complete.
Breakdown of completion status in various design activities, performed by the resident project engineering group, is as follows:
--
Design of all Large Bore (L/B) piping (2h" diameter and larger)
is complete Design of all computer analyzed L/B pipe supports is complete
--
All piping layout drawings are complete
--
--
Design of all pipe whip restraints is complete Design of equipment supports is complete
--
--
All computer analyzed Small Bore (S/B) piping isometrics are complete Design of approximately 10% of all S/B pipe supports is complete
--
Ongoing design activities by the plant design group include:
--
Individually designed S/B pipe supports Review of L/B piping and supports in the first phase of the
--
piping reconciliation program (Details of the program are described in the following section)
--
Snubber reduction on L/B piping systems containing a minimum of five snubbers between two design anchors Support to construction for the piping PSI program
--
The scheduled date for completion of all project engineering activities is Summer of 1990 while the target date is projected around the fall of 1989.
.
__
_
.
__
_ _ _.
.
.
4.0 Program For As-Built Verification and Stress Reconciliation of Piping Systems 4.1 Overview of the Program Activities related to the as-built verification and stress reconciliation of safety related piping systems were selected for review during this inspection.
These activities were selected as they represented a significant portion of the work currently performed by the construction group (Field engineering and QC) and the plant design staff from the project engineering organization.
The process of As-Built Reconciliation (ABR) included all ASME III and/or seismic Category I stress calculations for large and small piping and pipe supports inside and outside the containment.
Provisions for as-built reconciliation of non-ASME seismic Category II and IIA piping and support components were also provided in the specification used for the performance of this activity. The processing of the as-built information after completion of installations and prior to the issuance of the ASME N-5 date reports, varied depending upon the commodity being installed and the area of installation.
The specification addressed the processing sequence for each of the following five commodity / area processes:
--
L/B and S/B piping (inside and outside containment)
L/B pipe supports (inside containment)
--
l
--
L/B pipe supports (outside containment)
--
S/B pipe supports (inside containment)
--
S/B pipe supports (outside containment)
,
The significant feature in the ABR process was the introduction of a two phase approach in the evaluation of all as-built piping configurations and the pipe support installations outside containment. The approach
'
provides for performing the ABR of completed piping installations prior to the physical installation of all related supports.
For example, in the case of L/B piping outside containment, the first phase of reconciliation was performed for QC accepted piping and gravity support installations.
Feasible locations of seismic supports were identified by field engineering for incorporation in the first phase of piping ABR by project engineering. The two phase approach limits the piping reconciliation effort required by project engineering for as-built configurations which had been changed or where the support locations had to be altered.
It also limits the reconciliation of supports in the second phase to those installations which changed or were added after the first phase.
i h
-_
_
,,
__
_ __,
m
_ _ _ _ _ _ _. _ _ _ _ _ _,
.
.
The ABR effort for all of the above five commodity / area processes is considered complete upon evaluation of final QC accepted as-built drawing revisions and Field Change Requests (FCR's).
The QC inspection of completed piping and support installations was performed to the requirements in the field fabrication and installation procedure for these commodities. The specifications provided the acceptance criteria for erection and measurements tolerances by field engineering and QC.
The permissible deviations between as-built and as-analyzed conditions were not provided in tr.e ABR specification. However, the current evaluation of ABR packages
"
was performed to the same permissible deviations described in the specification for ABR program procedure for Unit No. 1 of Limerick Station. Documents reviewed during this inspection are listed in Attachment No. 1.
No violations were identified during this review.
4.2 Review of Design Documents Review of design documents generated by the plant design staff was performed on a sampling basis during this inspection.
The review included:
(1) governing design criteria and reconciliation specifications in the area of piping and support systems, and (2)
reconciliation packages for two piping packages and associated supports in the core spray and reactor core isolation cooling systems. The design calculation packages for the above systems were among the ABR documents completed in the first phase.
The packages were reviewed to verify that the evaluations were performed in accordance with project engineering and design procedures and that they meet the regulatory requirements.
The piping and support packages reviewed are identified in attachment 2 of this report.
No violations were identified during this review. One unresolved item was noted (section 4.5).
4.3 Interview of Project Engineering Technical Staff The inspector conducted interviews with two engineers from the plant design group. The group consists of three sections.
The first is responsible for analysis, design and reconciliation of piping systems and the second performs the same function for support systems. Design activities related to equipment supports and pipe whip restraints are performed by the civil / structural group and are not included within the scope of the pipe support section. The third section is responsible for piping layout activities.
The engineers selected for interview belonged to the piping and support sections.
The purpose of the interview was to determine the level of qualification and knowledge of technical personnel involved in the area of mechanical design.
The following topics were discussed during the interview:
. - _ _
- _.
_ - _ -
.
.
b
--
knowledge of applicable design and reconciliation procedures procedural requirements for preparation of piping stress
--
analyses and support design packaces knowledge of reconciliation criteria and permissible deviations
--
from as-analyzed conditions with regard to changes in valve weights, variations in header-to-branch stiffnesses, and support location, stiffness and orientation.
receipt and return of revised and superseded controlled
--
documents transmittal of piping restraint Toads to the support section
--
--
documentation of engineering judaements used in the reconciliation process
--
knowledge of code requirements in the design of support welds and design considerations for selection of weld configurations incorporation of structural members joint sizes and dummy
--
members in the computer analyses
--
working knowledge of requirements for design of snubbers and spring supports No violations were identified during this interview.
4.4 Verification of As-Built Piping, Components and Support Installations The objective of this inspection was to verify, by sampling examination, that the selected systems were fabricated and erected in accordance witf design drawings and installation specifications (attachment 1). The inspection included the same piping and support commodities in the syrtems addressed in section 4.2 (i.e., core spray and reactor core isolation cooling).
The inspected portion of the system was located outside the containment, thus only gravity or combined gravity / seismic supports were installed and QC inspected within the scope of first phase.
The verification of as-built installations was performed either by visual inspection or by independent measurements of accessible components and supports.
The criteria used for the assessment of piping component and supports were those described in the installation specifications and the quality control instructions.
The inspection attributes for piping components typically included selective verification of the following:
E
.
.
--
pipe configuration and outside diameter;
--
branch connection types and locations; piping bend and elbow radii;
--
proper flow direction marks on valves;
--
--
correct sequential location of valves on piping runs; welder's inscription for piping field welds;
--
--
proper identification and orientation of valves and operators; and, spool piece and heat numbers
--
The inspection attributes for pipe supports typically included selective verification _ of the following:
--
support location along the piping run; support orientation, function and location in relation to the
--
building;
--
connection to the proper structure; as-built configuration including dimensions of structural
--
members;
--
size and general condition of welds on hangers, including welded attachments to piping; baseplate dimensions and location of structural attachment to
--
baseplates; baseplate concrete expansion anchor tightness, edge distance
--
and bolt identification for anchor type; restraint bleed holes open and free of foreign material;
--
--
pin-to pin dimensions of sway struts;
grouting of floor mounted baseplates and gap sizes for wall
--
i
'
mounted plates; and,
--
pipe routing and support locations such that movements of j
piping due to vibration, thermal expansion, etc., would not l
cause interference with other pipes, supports, equipment or components.
'
!
Piping and support installations examined during this inspection are identified by the sarae piping isometrics listed in attachment 2 for the design packages reviewed, and by hanger numbers in attachment 3 for QCIR's reviewed.
No violations were identified and one unresolved item was noted (sectica 4.5).
l l
l
.
~
.
.
4.5 Fjndings and Conclusion The inspector concluded, based on sampling review of design activities in the plant system group, that the governing design criteria and procedures were established and utilized by the
,
technical staff performing the design function. The design packages reviewed were found to be complete and technically adequate.
Examination of piping components and support installations indicated an overall good quality of workmanship and compliance to design
drawing requirements. Regarding the as-built reconciliation process, the inspector noted that the approach selected for accomplishing this activity would ultimately result in a more efficient walkdown effort for as-built verification of completed piping and support installations, and reduce the number of design iterations and as-built reconciliation evaluations. Two unresolved items were noted during the review of ABR design documents and examination of piping and support installations.
1.
The design requirements for piping supports are based on USAS B31.7 code for class 1, 2 and 3 piping systems.
The allowable design limits for non-standard catalog support components
(structural steel) within the B31.7 boundary are specified in the project plant design instruction (SFPSM-1) as 1.8S and 0.9S for the emergency and faulted loading conditions y
respectively (where S and S are, respectively, the material y
allowable and yield stresses par ANSI B31.1 at maximum design temperature).
The basis for specifying these allowables was not apparent since they exceeded the AISC code limits specified for the design of the same structural elements used in the supplementary steel portion of the pipe supports. This item is considered unresolved pending licensee justification of these allowables and NRC review (353/86-20-01).
2.
During examination of the multiple pipe support frame for gravity hangers No. HBB-245-H3 and H4, the inspector observed gaps under the horizontal piping run No. HBB-245-1-2 at both support locations.
The gaps were measured by Bechtel's field engineering as approximately.04 and 0.06".
To address this finding and other conditions which could potentially exist, the licensee initiated a non-conformance report against the above identified support hangers and proposed the inclusion of a requirement for inspection of gaps between piping and supports during the final pipe support installation inspection by QC.
The requirement is to be incorporated as a revision to tha QC Instruction Procedure No. 8031/P-2.00 for final review of pipe hanger, support and restraint installation. This item is considered unresolved pending implementation of the licensee's corrective action and NRC review (353/86-20-02).
t
-.. -. _, -, -,...,, -
,
- - -
--
, - -, -,
, -.. - -, - - - --- --
,..
e
5.0 Review of QA/QC Interface During the course of the inspection, the inspector reviewed various QA/QC related activities pertaining to the design and installation of piping and support systems. The activities reviewed are addressed below.
5.1 Quality Control Instructions Quality Control Instructions (QCI's) were written to provide inspection checklists consisting of surveillance and mandatory holdpoints.
The QCI's document inspection attributes contained within the engineering and installation specifications.
The QCI's included generic QCIR forms that capture the requisite inspection attributes.
,
The inspector reviewed QCI's associated with the following activities:
field fabrication, installation and rework of piping
--
sub-assembly
--
installation of pipe hangers, supports, restraints and shock arrestors final review of the pipe support installaticr.: aba,e.
--
'
The QCI's contained appropriate inspection criteria f o+ t he associated activities. However, a revision of the QCI ur final review of piping support installations is planned to L'earporate inspection requirements for gaps (Item 2 of section 4 5).
l The inspector had no further questions.
5.2 Quality Control Inspection Records
-
The inspector examined QC inspection reports associated with piping components and support installations verified during the NRC's walkdown verification (attachment 3).
The records were found to specify the requisite information regarding the item inspected, reference documents utilized during the inspection, quality control inspect' ion report number, inspector identification, accept / reject notation ~and report review.
The QCIR's reviewed during this inspection are listed in attachment 3.
5.4 Review of Non-conformance and Design Change Documents The inspector reviewed three non-conformance reports and one field change request pertaining to piping and support installations examined during this inspection. The review also included a random
!
.
. -
. - - -... - -
- _. -
-.
..
- _.
~
.
sample of several non-conformance reports generated by QC during inspection of other piping and support installations. The review was performed to ascertain: ' compliance with procedural controls; proper review and approval; retrievability and clarity; the technical adequacy of the non-conformance dispositions and design changes; and the adequacy and completeness of the information included to ensure adequate implementation of the disposition or change.
The non-conformance and change documents reviewed are listed in attachment 4.
No discrepancies were identified as a result of this review.
5.5 Review of Audit Reports The inspector reviewed programmatic audit and monitoring reports by
,
Bechtel's QA group as well as audit reports by the licensee QA department of activities performed by project engineering. The review was performed to verify:
(1) functional area and extent of the audit; (2) audited organization received a copy of the audit report; (3)
appropriate ttandards were referenced for measuring performance; and (4) records of corrective action taken when recommended by the audit report.
Records examined by the inspector in this area included:
(1) Audit No. PFA 784 (30.29 B-1) by Bechtel's QA on 9/22-26/86 of as-built reconciliation design activities (2) Audit No. PFA (3-4 B-1) by Bechtel's QA on 8/4-15/86 for evaluation of project engineering's compliance with requirements for identification of external / internal design interfaces (3) Monitoring report No. 30.298 on 10/17/86 by Bechtel's QA group of plant design group in hanger as-built reconciliation (4) Monitoring report No. 30.30 B on 11/19/86 by Bechtel's QA group of plant design group activities in preparation and maintenance of preliminary stress report.
(5) Audit report No. 2M-524 by PECO's QA on 4/30-5/14/86 of project engineering calculations in the mechanical / piping area (6) Audit report No. 2P-481 by PECO's QA on 6/2-23/86 of plant design group calculations in pipe hanger design.
No violations were noted during this review.
i i
v
- -.
,,,, - -
-. - -
.
m
6.0 Definition of Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, violations, or deviations.
Unresolved items identified during this inspection are discussed in paragraph 4.5.
7.0 Exit Meeting The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on December 22, 1986. The inspector summarized the purpose and the scope of the inspection and the findings.
At no time during this inspection was written material provided by the inspector to the licensee.
!
!
i
I i
s
- _ - _ - _ _ _ _ - _ _ _ - _ _ _ _ - _ _ _ - _ _ _ _ _
.
ATTACHMENT 1 DESIGN SPECIFICATIONS AND PROCEDURES REVIEWED The following design documents were reviewed, in part, during the course of the inspection:
Specification No. 8031-P-319-2 For Field Fabrication and Installation of
--
Q-Listed and Seismic Category 1 Pipe Supports, Hangers and Restraints Specification No. 3031-P-301-2 For Field Fabrication and Installation of f
--
Piping For Nuclear Service Specification No. 3031-P-403 For Stress Group Design Criteria For Piping
--
Stress Analysis Design Criteria 8031-P-401 for Design and Documentation of Pipe Supports,
-
--
Hangers, and Restraints for Pipe 21s Inches and Larger
[
--
Project-SFPSM:
Pipe Support Design Manual for Limerick Generating Station Specification No. 8031-P-366 and P-366-2 As-Built P,econciliation for the
--
Limerick Generating Station Units 1 and 2.
,,
.
.
.
.
_ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
_
.
.
ATTACHMENT 2
'
DESIGN CALCULATION PACKAGES REVIEWED The following design documents were reviewed, in part, during the course of the inspection:
Piping Stress As-Built Reconciliation Package No. 2-22-58 (revision 2)
--
For Isometric No. HBB-245-1 Piping Stress As-Built Reconciliation Package No. 2-20-68 (revision 2)
--
For Isometrics No. GBB-213-1, 4, 5 and 7 Pipe Support Calculations No. HBB-245-C2, C3, C4 and C5
--
--
Pipe Support Calculations No. GBB-213-C57, C61, C26, C18, C55 and C17 t
i i
I
j i
-
r wm- - -., - --
r-,
.--,
a-n.,,r,-
w.--_,,,,-,
,-..cn,--
,,
r-e,---,---..,m-,.,,,,,,
r
+ - -,,. -, -,, -, - - - -. - - - - -
-n,-,,,------
,,.-n, - -, -,
---n-,
,~-.,
-,w
e
.
.
ATTACHMENT 3 QUALITY CONTROL INSPECTION RECORDS REVIEWED
--
QC Inspection Record No. HBB-245-1.55-1 For Piping No. HBB-245-1 (Area 18, EL. 201'-0")
QC Inspection Record For No. HBB-245-1-56-1 Valves No. HV-M49-2F084,
--
HV-M49-2F080, M49-2017, M49-2018, M49-2F068 In Process Rework Notice No. P6914 For Valve No. M0-2F084
--
QC Inspection Record No. GBB-213-4-55-1 for piping No GBB-213-4
--
(Area 13, EL 184'-0")
--
QC Inspection Record No GBB-213-4-56-1 For Valve No. M52-4P-2F010A QC Inspection Record No. GBB-213-5-55-1 For Piping No. GBB-213-5
--
QC Inspection Record No. GBB-213-5-56-1 For Valves No. M52-2F 010C and
--
M-52-2F-036C QC Inspection Record No. GBB-213-7-55-1 For Piping No. GBB-213-7
--
QC Inspection Record No. GBB-213-7-56-1 For Valve No. M52-M0-2F031A
--
--
QCIR No. HBB-245-1-H1-0-70-1 (Hanger H1)
QCIR No. HBB-245-1-H2-0-70-1 (Hanger H2)
--
QCIR No. iBB-245-1-H3-0-70-1 (Hanger H3)
--
QCIR No. HBB-245-1-H4-0-70-1 (Hanger H4)
--
QCIR No. HBB-245-1-H5-0-70-1 (Hanger H5)
--
QCIR No. GBB-213-4-H17-0-70-1 (Hanger H17)
--
QCIR No. GBB-213-4-H18-0-70-1 (Hanger H18)
--
--
QCIR No. GBB-213-5-H26-0-70-1 (Hanger H26)
QCIR No. GBB-213-7-H55-0-70-1 (Hanger H55)
--
QCIR No. GBB-213-7-H57-0-70-1 (Hanger H57)
--
QCIR No. GBB-213-5-H58-0-70-1 (Hanger H58)
--
QCIR No. GBB-213-7-H61-0-70-1 (Hanger H61)
--
-
_
___
.._
..
- -.
_.
A
.
r
'
ATTACHMENT 4 NON-CONFORMANCE AND CHANGE DOCUMENTS REVIEWED i
'
Non-Conformance Report No. 11125
--
Field Change Request No. LH-85
--
Non-Conformance Report No. 10704
--
Non-Conformance Report No. 9133
--
.
Non-Conformance Report No. 11248
--
Non-Conformance Report No. 5004
--
Non-Conformance Report No. 5670
--
Non-Conformance Report No. 10772
--
Non-Conformance Report No. 10804
<
--
Non-Conformance Report No. 11083
--
i
e i
!
!
t e
!
i
,- - - - - -, - -
-. -.,,
.,. - -
-,., -,-.-- -.-....,,. _ -,.-,_---.... -
- --..,._ -._ - - -._, -,,,