IR 05000353/1987002

Insp Rept 50-353/87-02 on 870203-0329.Violations Noted:Four Examples of Const Activities That Did Not Adhere to Procedures,Including Unauthorized Removal of Conduit Support & Failure to Examine Closure Weld Cold Pull

ML20215K651
Person / Time
Site:	Limerick
Issue date:	04/30/1987
From:	Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215K587	List: IR 05000353/1987002 ML20215K585 ML20215K604
References
50-353-87-02, 50-353-87-2, NUDOCS 8705110283
Download: ML20215K651 (23)

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U. S. NUCLEAR REGULATORY COMMISSION REGION I'

Report No. 87-02 Docket No. 50-353 License No. CPPR-107 Category A Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility: Limerick Generating Station, Unit 2

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Dates: February 3 - March 29, 1987 Inspector: R. A. Gramm, Senior Resident Inspector J. E. Kaucher, Resident Inspector i

Approved by: </!30[/7 8d

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R ctor Projects ction 2A Inspection Summary: Report for Inspection Conducted February 3 - March 29, 1987 (Report No. 50-353/87-02)

Area Inspected: Routin 'rspection by the resident inspectors of work activities, procedures, and records relative to quality assurance and engineering deficiency report review, safety related components, electrical cable and raceway, nonriestructive examinations, piping and pipe supports, reactor pressure vessel and internals, electrical components and allegation The inspector reviewed licensee action on previously identified items and performed plant inspection tours. The inspection involved 218' hours by the inspecto Results: One violation was identified with four examples of construction

, activities that had not adhered to procedure and specification requirements:

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unauthorizec removal of a conduit support (paragraph 6b), portable rod ovens not properly energized (paragraph 9e), unapproved rigging from safety related components (paragraph 5b), and failure to examine a closure weld cold pull

(paragraph 12). At least two of the examples were performed by backshift l personnel. The construction personnel were not cognizant of applicable l construction procedure requirement i i

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8705110283 870505 i PDR ADOCK 05000353 l G PDR \

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f DETAILS 1.0 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 conditions. Particular note was taken of the presence of quality control inspectors and quality control evidence such as inspection records, material identification, nonconforming material identification, housekeeping and equipment preservatio The inspector interviewed craft supervision, craft and quality control personnel in the work area Observations are noted below:

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The inspector was informed of a problem with Agastat FGP relay seating at another nuclear facility. The inspector reviewed documentation associated with PECO Significant Deficiency Report 129 that described a generic rework program on the Limerick Agastat relay bases. The relay sockets will be tested for proper connection between the relay and the socket in accordance with procedure FE-11. The site program should ensure proper installations of the !

relay The inspector was informed that Bechtel audits for another facility had identified improper procurement practices at the General Electric (GE) Philadelphia switchgear division plant. The inspector asked the licensee if spare or replacement parts have been procured through the Philadelphia plant. (87-02-01)

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The inspector was provided GE Service Advice Letter 188.1 regarding operability of HFA auxiliary relays. Mechanical binding has prevented proper operation of the relays at other facilities. The l inspector asked the licensee whether an investigation had been

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performed of the Limerick relays to identify whether they are susceptible to a similar problem and to review licensee handling of l Service Advice Letters. (87-02-02)

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The inspector accompanied a Regional materials licensing specialist inspector during third shift tours of the Reactor Building, Primary Containment and Turbine Building. In process radiography activities were observed for adherence to radiation safety requirement Resolution of the items, such as access to high radiation areas, identified will be pursued by Region V personne Welding activities on the refueling bellows were observe The inspector reviewed Work Package 20-S201-A and the General Electric Master Parts List. The work was found in accordance with the requirements.

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2.0 Licensee Action on Previously Identified Items (Closed) Followup Item (77-99-01): Reactor pressure vessel

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internals nondestructive weld examination. The inspector reviewed l General Electric (GE) Field Disposition Instruction (FDI) 30/73030-1 l Rev. I which provided the rework and NDE instructions. The l inspector reviewed. numerous Reactor Control Inc. (RCI) weld and NDE

! data sheets that documented the performance of the required liquid penetrant examinations. This item is closed, (Closed) Construction Deficiency (79-00-01): Loose locking nuts on Limitorque valve operators. As discussed in section lib of this report, a site rework program has been implemented that assures the locknut is either staked or a set screw is used to lock it in plac All Limitorque operators are scheduled to be reworked if necessar This item is close (Closed) Construction Deficiency (80-00-05): Defective panel connector insert pins in PGCC termination modules. The inspector reviewed Field Disposition Instruction TRDC revisions 1 and 2, Field Connector Pull Test Inspection Instruction II-CA-014, GE controlled document CD046 which included: product quality certifications, receiving inspection reports, Quality Control Checklists (File

1. 9.1.15), panel connector test procedure data sheets (File #

9.1.15), NCR's for disposition of defective pins and CD046 completion checklist. A 100% inspection / rework of all insert pins 4 in PGCC termination modules has been conducted and documented. This item is close (Closed) Construction Deficiency (80-00-06): Defective SMB type control switches in GE supplied equipment The inspector reviewed Field Deviation Disposition Requests (FDDR) HH2-1049 rev. 0 & 1 and

! HH2-383 These FDDR's implemented and documented the inspection

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and replacement of SMB control switches with specific date codes identified by GE Service Information Letter No.155. Inspection and as-required replacement of all subject switches has been conducted, and project Receiving Inspection Instruction No. R-1.00 has been revised to require receipt inspection of any new SMB type switche '

This item is close (0 pen) Construction Deficiency (80-00-10): Violations of separation criteria in the PGCC. PECO report SDR-19-1, " Final Report on Violations of Separation criteria in the PGCC," defines the corrective actions required to meet separation criteria defined in FSAR Section 8.1.6. These requirements are implemented via Section of E-1412 (wire and cable notes and details) and verified via Quality Control Instruction RW-1.10 " Internal Electrical Modifications, Disassembly and Reassembly of Q Listed Equipment".

The inspector found these instructions to be 2dequate; however, this l item will remain open until the adequacy of the implementation of j these requirements can be evaluated.

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3 (Closed) Construction Deficiency (80-00-13): Limitorque operator wiring defects. All site Limitorque operators are scheduled for rework in accordance with procedure FM-4. Vendor supplied wiring, except motor leads, are removed and replaced with qualified Rockbestos wire with new lugs. The inspector observed the replacement of wiring on "Q" operators. The site rework program has been scheduled and will rectify the vendor wiring deficiencies. This item is close (Closed) Construction (81-00-01): Grounding of PGCC flexible conduit. The inspector reviewed Field Disposition Instruction (FDI)

TREW, Revisions 0 and 1. This FDI provides field instructions for grounding of installed, unattached lengths of flexible steel conduit in PGCC insulators. Additionally, GE design specification A61-4050 and E-1404 (grounding instruction) have been revised to implement the requirements of FDI-TREW for flex grounding of ongoing and future construction activities. The inspector performed a field walkdown/ verification of installed flex conduit grounding and found installations to be in accordance with existing procedure This item is close (Closed) Construction Deficiency (81-00-03): Defective chlorine monitor pressure switche The inspector reviewed Nonconformance Report 4575 that documented the replacement of the defective pressure switches in the four chlorine monitor This item is close . (Closed) Construction Deficiency (81-00-13): Unreviewed equipment substitution. The inspector reviewed Bechtel Management Corrective Action Report (MCAR) 28 and Construction Procedure (CP) D-2,

"Proceuure for Equipment Substitutions, Transfers and Replacements."

The MCAR documented that three valves had been installed by construction personnel in system locations which exceded the valve's operating capabilities. The three valves were removed and replaced with the correct valves for the system design pressure as documented on Nonconformance Report 4994. The other equipment substitutions that had been made were reviewed by the licensee to assure functional compatibility of the equipment. The current equipment substitution procedure requires an engineering evaluation of proposed substitutions to assure that an equivalent component is being used. As discussed in section Sa. of this report several Equipment Substitution Records  !

(ESRs) were reviewed. This item is close l l (Closed) Violation (81-07-01): Recirculation gate valve storage condition. The inspector visually examined the four installed gate valves. The valves are appropriately protected. The maintenance action records were reviewed and the visual checks are performed on 28 day cycle The inspector reviewed Inprocess Rework Notices l LTM-1490, LTM-328, LTM-1358 and SS-05 On several occasions the i valve end caps dropped off and were subsequently replaced by

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construction personnel. The original PECO finding report for the discrepant conditions has been resolved. This item is closed.

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< (0 pen) Construction Deficiency (84-00-03) Defective Agastat (CR0095)

relay sockets. GE Service Information Letter (SIL) No. 384 and NRC Information Notice 82-48 identified defects in Agastat CR0095 relay 1 sockets associated with inadequate retention of the female terminal

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, in the relay socket, allowing the terminals to be pushed out of the socket. - PECO Electrical Engineering Division prepared procedure FE-11 (procecure for inspection of Agastat CR0095 relay sockets)

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which adequately addresses the requirements of SIL 384 and NRC Notice 82-48. FE-11 will not be implemented for Limerick Unit 2 '

! until " blue-tag" testing during the completion of the construction

phase of the project. Therefore, this item will remain open until

FE-11 is implemented and the results have been evaluated, i' (0 pen) Violation (84-08-01): Equipment storage and preventive maintenance. The inspector reviewed the Maintenance Action Cards and i log for fan 2AV212. The visual inspections have been performed every i two months and the motors have been ground tested every six month i The maintenance records for diesel generator transfer pump 2AP514

delineated that visual inspections were performed every three months,

and that motor ground tests and grease checks were performed every

! six months. The shaft rotation on the pump had recently been waived i since water intrusion into the pit had caused excessive corrosion.

i The inspector reviewed Nonconformance Report (NCR) 11546 that requires the pump to be rebuilt. The inspector asked PECO to provide the corrective action that will prevent further water entry into the pit j area. This item remains ope (0 pen) Unresolved (86-10-02): High strength bolting on the CRD

, restraint beam. The inspector was informed that Reactor Controls

Inc. (RCI) had installed the bolts. RCI had performed tests to correlate bolt elongation with installation preload. RCI had calculated that a bolt elongation of 0.007 inches was equivalent to a preload of 28 kips. The inspector performed the calculation utilizing bolt characteristics from 'AISC and Machinery's Handbook j and found the. elongation should have been 0.079 inche '

i L = 2.75 inches i 0 = 0.75 inches I

i n = 10 threads / inch P = 28 kips

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A = (AISC Table 1.5.2.1) tensile stress area = 0.7854 (0-0.9743/n)2=0.3344 in2

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strain = P/EA = 0.00288 in/in

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elongation = strain L = 0.0079 inches l' This item remains open pending further licensee investigatio This item has been discussed with the licensee.

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- .J 5 7 (0 pen) Unresolved Item (86-21-01)

Drawing errors introduced during '

the translation utilizing the Computer Aided Drafting System. A meeting was held on March 12, 1987 between Region 1, PECO and Bechtel

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personnel to discuss the drawing error problems and implemented corrective actions. The inspector was informed that PEC0 QA is reviewing recently released P& ids. A summary list has been developed by engineering that identified the Quality Assurance Diagram dis--

crepancies for QA investigation. The use of informal construction documents to identify drawing errors in lieu of the Field Change Notice or Field Change Requests has been documented on Bechtel

Quality Action Request F-562. The inspector will follow up on the

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resolution of this QAR. This item remains ope ' 3.0 Licensee Action on IE Bulletins and IE Circulars The inspector reviewed licensee records related to the IE Bulletins and

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IE Circulars identified below to verify that: the IE Bulletin or IE i Circular was received and reviewed for applicability; a written response

was provided if required; and the corrective action taken was adequat '

] The following IE Bulletins and IE Circulars were reviewed:

j (Closed) IE Bulletin 74-16: Improper Machining of Pistons in Colt 4 Industries (Fairbanks-Morse) Diesel-Generators. The design and j fabrication activities on the Limerick diesel generators had not i been initiated when the IE Bulletin was issued. The inspector

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reviewed PECO audit report 151 that covered the Colt Industries Quality Assurance (QA) program. The audit found that specification and QA program requirements were implemented. This item is close .

' (0 pen) IE Bulletin 76-02: Relay Coil Failures GE Type HFA, HGA,

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HKA, HMA Relays. The inspector asked PEC0 for additional documents-which would verify relays had been properly upgraded. This item

remains ope (Closed) IE Circular 79-02

Failure of 120 Volt Vital AC Power Supplies. The inspector reviewed FSAR section 8.3.1.1.1 and other

licensee correspondence. The Limerick inverters are supplied by I

Exide and do not incorporate time delay circuitry. The inverters are non-Q equipment. The inverter power supplies are DC batteries so e i that high AC input voltage transients are not of concern. This item j is closed based upon the design differences of the Limerick uninter-ruptible power supply (UPS) system design which precludes a similar voltage transient problem from occurin < (Closed) IE Circular 79-04: Loose Locking Nut on Limitorque Valve Operators. The inspector reviewed procedure FM-4, "Limitorque '

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Rework Program and Supplemental Technical and Maintenance

Instructions for all Limitorque Operators at Limerick."- The procedure requires that Limitorque operator stem nuts are retained

by a locknut that is held in place. The locknut is either staked or a set screw is used. The inspector examined several operators in i

{ the rework shop and verified the presence of locknut staking. All

site Limitorque operators will be reworked under the control of the

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FM-4 procedure, and the locknuts will be secured if necessary. This

has been scheduled in the licensees tracking program and the inspector

considers this item close (Closed) IE Bulletin 79-04: Incorract weights for swing check valves manufactured by Velan Engineering Corporation. The subject check valves are installed in numerous plant systems. Velan verified that the valve weights indicated on their design drawings

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were accurat The licensee reviewed the piping stress analysis and found the proper valve weights were used. The inspector reviewed Bechtel. letter 59809 which documented a site verification of several

actual weights and found them less than the drawing weights. A decrease in actual valve weight will reduce the stress levels in the i piping analysis. This item is close :

' (Closed) IE Circular 79-25: Shock Arrestor Strut Assembly Int 9rference. The inspector reviewed the following Bechtel j documents:

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.Nonconformance Report 5305

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Field Inspection Reports P-101-QCG1-1, P-101-QCG1-2, 1 P319-QCG1-8, P319-QCG1-9, P319-QCG1-11, P319-QCG1-14, and P101-AC-QCG1-20.

l Bechtel identified thirty-five (35) hangers that included Pacific

] Scientific size 50 and 120 snubbers used with Bergen-Patterson part i 2540 rear brackets. Twenty three (23) supports were reworked to

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incorporate a redesigned part 2540 that would preclude snubber damage. Quality Control personnel inspected the remainder of the hangers and found no damage to the dust covers. The snubbers were j satisfactorily stroke The inspector. reviewed Bergen-Patterson letter dated January 20, 1982 that concluded the-dust cover damage

had been erroneously attributed to part 2540 interference. Bechtel reviewed hanger design calculations and determined the size 120 snubbers carry loads less than 112 kips. This item is close P

. (Closed) 1E Circular 81-05: Self-Aligning Rod End Bushings for Pipe i

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Supports. The inspector reviewed the following procedures:

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Startup procedure TT1.30-2

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Quality Control Instruction P-2.10

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Field Mechanical procedure FM-10 l Bechtel QC performs inspections to assure that snubber and sway strut ball bushings are properly engaged, and the appropriate spacer i

washers are installed. The inspector reviewed the procedure,

spot checked inspection and considers this item close i (0 pen) IE Bulletin 84-02: Failures of General Electrical Type HFA j Relays in use in Class IE Safety Systems. The PECO correspondence

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. 7 dated July 10, 1987 to the NRC identified that twelve safety related HFA relays were installed in Unit The inspector reviewed PECO correspondence, PLB-4391E, that stated four HFA relays were replaced with century series HFA relays that would preclude further failures of the Lexan coil spools. The inspector asked for clarification of the total number of HFA relays onsite and how the relays were fixe This item remains ope (Closed) Information Notice 87-08: Degraded Motor Leads in Limitorque DC Operators. The inspector reviewed Bechtel Quality Actior. Request F-555 and PECO Surveillance Check Report ILC-05 The licensee investigated twenty-two potentially affected operators and found one installed at Unit 1 that utilized the nomex-kapton insulated leads. The operator was subsequently removed from servic .0 Deficiency Report Review Nonconforming conditions that are identified during construction are documented on either a Bechtel Nonconformance Report (NCR) or Inprocess Rework Notice (IPRN). The NCR is utilized for nonconformances identified after final QC inspection; ASME deficiencies which are dispositioned " accept-as-is" by project engineering; or a repair disposition outside the scope of pre-approved repair procedures. The inspector reviewed the following documents related to the Bechtel nonconformance program:

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Preliminary Safety Analysis Report (PSAR) Appendix 0

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Project Special Provisions Notice G-3.1, " Control of Nonconforming Items"

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Construction Procedure CP-D-1, " Processing of Nonconformance Reports (NCRs)"

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PECO QA Plan Volume 1, Appendix Q The NCRs listed in attachment I of this report were reviewed by the inspector to: verify cortpleteness of documentation; assure satis-factory technical disposition; verify the adequacy of the Bechtel pending program; assure PECO receipt and review of the NCRs; verify

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evaluation of significant deficiencies; verify involvement of ANI for ASME code items, and review documentation of QC verification of corrective actions.

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'. 8 The inspector found the nonconformances properly documented and reviewed. The nonconformances associated with ASME code items were reviewed by the Authorized Nuclear Inspector. The nonconformances had been reviewed for 10 CFR 50.55e reportability. The inspector

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i verified that PECO received copies of use as is and repair '

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nonconformances for a quality assurance and engineering overvie '

No violations were identifie i Volume I,-Appendix Z of the PEC0 QA Plan for Design and Construction,

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Procedure for Reporting Significant Deficiencies, Defects and ,

Noncompliances to the USNRC was reviewed by the inspector. The procedure provides for onsite and corporate evaluations of 't significant problems. The reportability criteria was found g consistent with 10 CFR 50.55e. (These SDR's listed in Attachment 2 of this report.)

The SDRs were found controlled in accordance with the QA procedur The items had received reviews by the appropriate personnel. The following concerns are unresolved (87-02-03) pending licensee investigation:

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SDR 174 identified the potential that lock welds were missing from the Anchor Darling swing check valves. In Juiy 1985 Anchor Darling recommended that the valves be inspected to assure the hinge pin set screw was lock welded. As of March 1987, one valve has not received an inspectio SDR 189 documented that limitorque operator jumper wires were not addressed by the environmental qualification report. This problem was reported under 10 CFR 21 for Unit 1. The Unit 2, 10 CFR 50.55e analyses for reportability determined that the site FM-4 rework program would rectify all wiring concerns. The inspector asked the licensee to consider the operators that are currently not reworked under the provision of 10 CFR 50.55e reportabilit ,

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5.0 Safety Related Compenents Site equipment substitutions are controlled in accordance with Construction Procedure (CP) D-2, " Procedure for Equipment l

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'. 9 Substitutions, Transfers and Replacements". The program allows for temporary and permanent substitution of Unit 2 equipment for other Unit 2 equipment. Reassignment of Unit 2 equipment to Unit 1 is similarly controlled under procedure CP-0-2. The inspector reviewed the following Equipment Substitution Records (ESRs):

348, 349, 350, 351, 355, 356, 363, 368 The ESRs were examined for completeness, QC notification and engineering review. The inspector had no concern During a plant tour, the inspector examined the inboard Main Steam Isolation Valves (MSIV). A section of pipe whip restraint 938-PR-202 was found attached to a MSIV eyebolt with a come alon Construction engineering indicated that the piece of steel weighed 730 pound Construction Procedure CP-C-8 requires engineering review and approval prior to rigging off other than building steel and prohibits rigging off piping. There was no apparent engineering approval for the case in question. The failure to adhere to the rigging controls of procedure CP-C-8 is a Violation of 10 CFR 50 Appendix B Criterion V (87-02-04).

The licensee subsequently issued Finding Report 2N-551 and determined that the rigging was for lateral stability onl Engineering review of the situation determined that there were no adverse effects on the MSIV. Construction tool box training sessions were held to reiterate the provisions of the rigging controls procedur .0 Electrical Cable and Raceway The inspector toured the spray pond pumphouse. A visual examination was performed of the shared Emergency Service Water (ESW) and Residual Heat Removal Service Water system components. The inspector examined the sluice gate instrumentation and verified the gates were 100% open. An unlabled rigid conduit was identified for the power

.,, cable to an ESW pum PECO QA examined all conduits associated with the ESW pumps and generated Apparent Discrepancy L-019 for the two missing tags. The tags were installed as documented on Maintenance

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Request Form 8701623 and PEC0 QC Inspection Report PJA-87-056 The following documents were reviewed by the inspector regarding electrical raceway design and installation:

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Electrical Raceway Work Package (ERWP) R-14-0002

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Computer listing of Raceway Supports by work Package (report #

MLR2BLS025, run date 87/02/05)

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Raceway Layout Drawing, Containment Unit 2, Drywell Section Az 0 degrees to Az 90 degrees, E-1286 sheet 1 of 4

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Liner Plate Attachment Request (LPAR) E-065

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Weld Request Form (WRF) 26455 The inspector reviewed work package R-14-0002 for completeness, accuracy, correlation with E-1286 sheet 1 of 4 and consistency with the computer listing of raceway supports. The inspector then performed a walkdown of conduits 2XZ106 and 2XZ016 to verify installation in accordance with the requirements of ERWP R-14-0002, LPAR E-065 and WRF 26455. During the walkdown the inspector noted that conduit support 2A-14-277-Cl-1000, which was listed as installed and accepted in the computer listing of raceway supports, was not installed in the field. The inspector was informed that the support i had been installed and had been removed by construction. PECO QA issued a finding report (2N-553) to investigate the reason for the -

unauthorized removal of the support. Failure to issue a Raceway Support Rework Notice as required by CP-E-3 is a Violation of 10 CFR

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50 Appendix B Criterion 5. (87-02-05) No other areas of concern

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were identifie c. The inspector witnessed eight Q listed cable pulls associated with r pull package SE00554 for the Unit Cooler Controller. The cables s were pulled from the 201 elevation to the 269 elevation, area 18, inside the reactor enclosure. The inspector verified that: the cable reel was recorded on the pull card, the cable ends were properly marked with the scheme number, the proper cable type was used, the cable bitter ends were protected, the proper cable routing was followed, the cable was properly tied down, edge protection was used where required, OC coverage was adequate, separation markings and requirements were met, trays were clean and inspection records were properly documented. The inspector additionally witnessed cable pull operations for cable 2CCTA09. The inspector identified no items of concer d. The inspector reviewed the following documents associated with cable terminations:

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E-1412, Wire and Cable Notes and Details, Section Cable connection list

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Schematic E471

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Connection drawing E-8348

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powers Drawing 2741-WD-2AC208 The inspector witnessed cable terminations being made in the Reactor Enclosure Unit Cooler control panel 2AC208. The inspector verified that cables were landed in accordance with the termination package, that proper terminal lugs were used, that terminations were made in accordance with E-1412 and that termination tools were properly calibrated. The inspector noted that the terminal block labeling on terminal point 3, terminal board 8 was inconsistent with the numbering on E-8348. Further investigation showed that field modification FMC-E5251 had been written to correct this i

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. 11 inconsistency, but had not yet been implemented in the fiel The inspector noted no other items of concer The inspector also observed cable terminations in the control room panels. Cables 2AIC41A03A and 2BIC4A03A were found terminated in accordance with work package ECR-CABLE-020. The inspector witnessed installation of a replacement transformer and wire terminations in accordance with work package E29-004 The crimps were satisfactory and the terminations were made at the pr" Or points in both case .0 Non-Destructive Examination The inspector interviewed several personnel from the Bechtel Welding QC department, including the Lead Welding QC engineer. The present NDE schedule was discussed, as well as the QC coverage of NDE methods and personnel. The inspector witnessed the performance of dye penetrant testing on 10 field welds on the control rod drive hydraulic control unit headers and vertical drops. The following documents were reviewed:

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Bechtel Procedure PT-BPC-4, Procedure Specification, " Liquid Penetrant Examination" -

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BPC NDE Standard, Procedure Specification PT-SR-1,2, Rev. 1,

" Liquid Penetrant Examination, Solvent Removable Method"

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Bechtel Construction Inc., Nondestructive Examination Standard,

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

Rev. 5 The documents reviewed were found to be in compliance with the requirements of Article 6 of ASME Section V, 1974. The inspector verified that the surfaces to be tested were properly cleaned, penetrant was applied as required, dwell time was satisfied, excess penetrant removed as required by procedure, developer was correctly applied and chemicals were properly identified. All chemicals were from the same manufacturer and of the types specified in the proced-ure, and tests were properly interpreted. The inspector also reviewed the certification records for the person performing the NDE. The inspector identified no areas of concer The inspector reviewed the following radiographs to determine their i acceptability and to evaluate the BPC QC radiograph interpretation  !

process. The inspector evaluated film density, calibration of the  ;

densitometer, visibility of the 4T hole, use of proper densitometer, the procedure used, unsharpness calculation, weld data sheets and the completeness of the NDE report. Radiographs for the following welds were reviewed:

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Report No. USG-RT-16139, Piece EBB-229-1/7, FW3 i

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Report No. USG-RT-16761, Piece DCA-201-3/9, FW21  !

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Information radiograph for Piece URR-2RD-2A, FWA13 )

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Information radiograph for Piece EBB-229-2/4, FWX35

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Information radiograph for Piece VRR-2RD-2A, FWA16 The inspector identified no areas of concer .0 Piping 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 The following welds were examined:  ;

Isometric Weld Class System Status l HBB-210-1 FW6 2 HPCI Surface preparation DCB-I30-35K-1 FW1 2 CRD Socket weld l DCB-I54-35K-1 FW1 2 CRD Socket weld DCB-I58-35K-1 FW1 2 CRD Socket weld SP-DCB-209-K56 FW1 2 CRD Fit-up i DCA-201-1 FW13 1 RWCU Inprocess l VRR-2RD-2A FW-Wall 1 Recirc Inprocess  :

DCA-419-1 FW1 1 Core Spray Inprocess I l

All observed activities were in accordance with applicable procedure and associated documentation. No concerns were identifie The inspector observed the performance of a QC final inspection on l pipe support GBB-212-H8. The QC inspector documented discrepancies between the as-built hanger and the as-built drawings regarding a gap between the support and adjacent pipe lug The inspector witnessed a hydrostatic test on portions of the .

Residual Heat Removal system piping as shown on isometrics HBB-l 240-1 and GBB-202-1. The Pressure Test Record, inspection lists, QC l Inspection Report 2M-49A-21-62-1 and water quality test records were l reviewed. The test was witnessed by Bechtel QC, the Authorized Nuclear Inspector (ANI), and PEC0 QA. The pressure test hold durations and walkdown examinations were properly performed. The inspector had no concern l

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". 13 The inspector reviewed the precautions for welding to valve Vendor precautions for valve position during welding were examined and found consistent with site procedures. Site engineering personnel were knowledgeable of the requirements and field control through work packages. The inspector had no concern Field issued coated electrodes are disbursed per WFMC-1 in portable

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rod ovens to minimize moisture absorption that can lead to potential weld discontinuities. The inspector toured the Reactor Building and primary containment to monitor inprocess control of the low hydrogen electrodes. On February 20 portable ovens W-91 and W-774 were discovered de-energized in the field. The electrodes had been issued by the rod room as requiring the use of the ovens. On February 23, oven 246 was found in a cold condition. The Bechtel ASME QA manual Welding Standard WFMC-1 requires that portable rod ovens shall be continuously heated except during transit tim Failure to adhere to the quality requirements constitutes a violation of 10 CFR 50 Appendix B Criterion (87-02-06)

The licensee subsequently issued Finding Report 2N-552 and Nonconformance Report 11738 to document the noted concerns. Bechtel reviewed the items that were being welded and concluded that the filler material could actually be issued in non-heated container The involved welders and their supervisors were reinstructed on the requirements for filler metal handling and controls. A site wide training bulletin was issued to reinstruct welding personnel that rod ovens must be energized and checkr.d at frequent intervals, The inspector reviewed the following documents that pertain to the drywell spray system piping:

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FSAR Table 3.2-1

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Becntel Specification P-305

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Piping Isometrics GBC-214-1, GBC-214-2, GBC-211-1, and GBC-211-2

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Material Receiving Package 8031-P100A-F-472-1

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Southwest Fabrication, Welding and Radiographic records The inspector verified that the shop welds had been radiographically examined in accordance with the FSAR commitments. The installation of the spray rings and associated piping to the containment penetration was vibJally examined. The piping was found installed in the engineering specified configuration. Most of the supports were only temporarily installed at this time. The inspector had no conc,rn .0 Reactor Pressure Vessel and Internals The inspector reviewed General Electric (GE) specification 22A4111,

" General Instructions for Reactor Assembly". The use of hardened washers at the end of each Reactor Pressure Vessel (RPV) stabilizer

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. 14 i

spring pack assembly was verified. An inspection of the RPV interior identified that the tops of the Control Rod Drive (CRD) housings were protected with plastic cap The specification recommended that the tops of the CRD housings should be 0.060 inches high prior to welding to accomodate expected shrinkage. Discussions with GE personnel identified that engineering has approved setting the tops of the

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housings higher to accomodate actual shrinkage of up to 0.140 inches. The inspector had no concern The inspector reviewed GE traveler packages 2-282T, "Feedwater Sparger Fitup" and 2-220T, "SBLC and Differential Pressure Line Installation". The packages had not received a final QC revie The data sheets were found properly completed. The inspector had no concerns, The inspector observed automatic machine welding operations in CRD stub tube housing 6041. Traveler package w-200T and Special process control sheet Z-200S-1 were reviewed for the weld. The root had been penetrant tested and appropriate alignment checks had been per-formed. The inspector had no concerns on the groove wel No violations were identifie .0 Electrical Components The inspector conducted an inspection of motor operated valves which have been installed in the plan The following documents were reviewed by the inspector:

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Limitorque Rework Program Procedure 8031-FM-4

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Construction Procedure for Storage Maintenance, 8031-CP-G-3

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Construction Procedure for Non-NSSS Electrical Equipment, 8031-CP-E-6 The following motor operated valves were inspected:  !

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M49-1P-HV-2F010 l

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M51-1P-HV-2F0070 l

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M51-IP-HV-2F007B l

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M51-1P-HVC-254B

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.M51-1P-HV-2F011B The inspector found the valves and operators properly protected from the effects of adjacent construction activities. Visual inspection of the valves and motors showed no apparent physical damage. The inspector has been unable to determine how the thermal overloads are selected to protect the valve motors. The inspector will followup on the method used to select the thermal overload (87-02-07)

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I ", 15 The inspector reviewed the following documents that relate to the Limitorque operator rework program:

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Procedure FE-16, " Procedure to Evaluate As Found Limitorque Valve Stem Thrust"

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Procedure FE-14, " Procedure to Adjust and Set Limitorque Stem Thrust"

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Procedure FM-4, "Limitorque Rework Program" The inspector observed rework activity and associated QC inspection activity for several "Q" operators in the rework sho Personnel training records were examined that documented the crafts had received special training regarding the operator rework activities. The use of Mobil 28 and Exxon EP-0 grease was noted, vendor supplied non-qualified parts were removed from the operator, vendor supplied wires and lugs were removed and replaced with Rockbestos wire, the proper gasket material for the operator reassembly was used, heat shrink tubing was provided for motor leads entering the switch compartment, and locknuts or staking were provided where necessary. The inspector additionally observed the adjustment of a torque switch by PEC0 field j engineerin The inspector reviewed IE Information Notice 87-08 " Degraded Motor Leads in Limitorque DC Operators", Bechtel Quality Action Request 1 F-555 and PECO Surveillance Check Report ILC-053. The licensee investigated twenty-two potentially affected limitorque operators and I found one installed at Unit 1 that utilizied the nomex-kapton l insulated leads. The limitorque operator was subsequently removed I from service.

I 12.0 Allegations

During the inspection period, the inspector conducted inspections and i interviews in response to an allegation received _by the NRC. The

inspector and licensee actions resulting from the allegation is noted

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below:

(RI-87A-0012) The NRC received an anonymous allegation of improper fitup activities in the drywel Investigation of the welding activities found a come-along attached to an ASME Class 1 Reactor Pressure Vessel drain line. The root pass had been made at Field Weld 201 which had been designated as a closure weld. Review of the weld documentation identified that the cold pull deflections had not been verified by field engineering

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in accordance with specification P301-2 prior to welding the root pass.

l Failure to properly control the closure weld is a violation of 10 CFR 50 Appendix B Criterion (87-02-08)

l The licensee has subsequently issued the following documents and performed the noted corrective actions:

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Inprocess Rework Notice P-7147 Cut out FW201 and performed

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[ *. ' 16 l

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l engineering verification of cold ,

pull dimensions '

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Small pipe Redline to DCA-213-E3 Designated FW201 as engineering l verified closure weld

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PECO Finding Report 2N-550 Document that closure requirements not' satisfied an directed Bechtel to investigate other pipe systems

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PECO Finding Report 2P-767 Requires that Bechtel perform enhanced QC verification of closure weld activities

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Nonconformance Report 11737 Documents seven cases of Class 1 pipe closures without apparent QC verification 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. An unresolved Item was discussed in paragraph 4 .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 March 27, 1987. Based on discussions held with licensee representatives on March 27, 1987, it was determined that this report does not contain information subject to 10 CFR 2.790 restriction v U

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y 1*.

ATTACHMENT 1 Further Bechtel Review for 50.55e

'NCR Disposition * ASME Reportability Remarks 6799 rew/rej/ rep Yes No Peeling of epoxy phenolic from DG fuel oil tank interio PEC0 reported as 50.55(e) to NR rew/u-a-1 No No Cables encased in grout 11231 rep Yes No Crack in pipe elbow-11249 rep No No Pipe sleeve misaligned 11386 rep /u-a-i No No Base material indication 11428 u-a-i No No MT exam of full penetration welds 11461 u-a-1 No No Transverse welds to beam flange 11462 u-a-1 No No Root gap dimension 11468 u-a-1 No No Out of calibration tools 11469 u-a-1 No No Material documentation 11502 u-a-i Yes No Pipe Minimum wall 11508 u-a-1 No No Structural connections 11517 rep No No Vendor welding 11522 u-a-1 No No HVAC duct stiffeners 11554 u-a-i No No Out of calibration equipment 11555 rep /u-a-i No No HCU mounting hole l'

location I

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11564 u-a-i No Ye . seismic stabilizer welds 11582 rep Yes No~ . pipe minimum wall 3703 rew/ rep No ' --

Anchor Darling limit switch

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11278 rep No' No PVC conduit damage 11305- rew Yes' No Punch indentation 11328 rew/u-a-1 Yes No Liner plate seam weld

. 11429 u-a-i N No Divider plate

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1144 rep No_ No Structural steel gaps

'11474 u-a-i No No Concrete curing I

- 11477 rep No No Structural steel gap 11478 rew/u-a-1 No No Torque wrench calibration 11525 u-a-i Yes 'No Welding procedure adherence 11579 u-a-1 No No Platform weld connection-

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11580 u-a-1 No No- Torque _ wrench-calibration 11603 u-a-i No No - Duct work relocated

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11604 _u-a-i No No Washer hardness

11623 u-a-1 No No Pipe support material 11626 u-a-1 No No Pipe support material 4199 rew Yes No Weld Indication 11276 rep /u-a-1 No No - Full penetration weld NDE >

11385 -rew/u-a-1 Yes No Globe valve

~ identification

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-,.e ,r-w - - m,---*- +m+--,e- , ,

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Attachmerst 1

11419 rew/u a-1 No 11452 No rep No No Arc strikes 11467 rew/u a-i Plate gouged 11504 Yes No u a-i Pipe rust No No 11528 u a-i Yes No Expansion joint 11538 u a-i No No Drawing consistency 11539 u a-i Concrete test cylinder curing No No

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11548 u a-i Concrete test cylinder curing No No 11551

\ rep No 11552 u a-f No Air meter calibration 11557 u a-1 Yes No Embedment installation E 11593 No No Excessive grinding u a-1 11608 No No Concrete cure rew/u a-f 11615 No No Holdpoints bypassed u a-i 11619 Yes No Rebar nicked g

u a-i

\ 11628 No No Missing code data plate

\ u a-i No No Concrete curing k

10870 Torque wrench rew/ rep

{ 11003 rep Yes No calibration

{ 11303 No No Grinding on weld ID u a-i

\ 11514 rep Yes No ease plate mistocated 11566 u a-i Yes No Electrical Penetration

\ 11594 Yes No Flange bore diameter rep /u a-i

{ 11612 No No FE holdpoints bypassed u a-1 1 No Gusset plate No

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, stirrener plates

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l Attachment 1 3 l

11419 rew/u-a-i No No Arc strikes I i

11452 rep No No Plate gouged 11467 rew/u-a-i Yes No Pipe rust 11504 u-a-i No No Expansion joint l 11528 u-a-i Yes No Drawing consistency 11538 u-a-1 No No Concrete test cylinder curing 11539 u-a-1 No No Concrete test cylinder ,

curing i 11548 u-a-i No No Air meter calibration 11551 rep No No Embedment installation 11552 u-a-i Yes No Excessive grinding ,

11557 u-a-1 No No Concrete cure l 11593 u-a-1 No No Holdpoints bypassed 11608 rew/u-a-i No No Rebar nicked 11615 u-a-i Yes No Missing code data plate 11619 u-a-1 No No Concrete curing

)

11628 u-a-i No No Torque wrench calibration 10870 rew/ rep Yes No Grinding on weld ID l 11003 rep No No Base plate mislocated 11303 u-a-i Yes No Electrical Penetration 11514 rep Yes No Flange bore diameter 11566 u-a-i Yes No FE holdpoints bypassed 11594 rep /u-a-1 No No Gusset plate 11612 u-a-1 No No Stiffener plates

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". Attachment 1 4 11618 u-a-1 No No Full penetration weld NDE 11642 u-a-i No No HVAC duct hanger 8473 rew Yes No Rust on pipe 11387 rep No No Piping minimum wall 11395 u-a-i No No QC inspection of weld

• disposition codes rew - rework res reject rep repair u-a-i-use-as-is

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ATTACHMENT 2

.50.55e SDR Description Report to NRC Remark

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174- Lock weld on Anchor No Single Valve not Darling set screw yet inspected 175 Containment penetration seal No voids (Unit 1)

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i 176 Limitorque wormshaft gear Yes CDR #85-00-01 failures t

177 Clow valve corrosion No Valves.not procurred

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178 Cracks in Bergen Patterson No Reviewed load fittings test reports

179 Failure of Westinghouse molded Yes CDR #86-00-01 i case circuit breaker-

180 Supplier QA Program No . Suspect nuts removed,.QA program approved 182 ITT Barton switch malfunction No EQ results satis-factory for Limerick appli-

, cations

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183 Solitech SBGT heater controller No Reported for Unit I since common j equipment MSIV springs quench cracks

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184 No MT exams underway

! for springs 185 K line circuit breaker gear Yes Reported 1981 teeth

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186 HVAC air balance damper No Unit 1 problem 187 FSAR commitments on drywell No License verified piping commitment'

implementation

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v -, y,_!, ,----,m.m_, --~m r_ -. . ., .__e-,, , , , # ,m.. . , -, , , . - , ,n ,, , m.b r y . ,, .% , ,.--.-,,.,..e,

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Attachment 2 2 189 Limitorque jumper wire EQ No Reported under Part 21 for Unit FM-4 program to rework all Unit 2 operators 190 HVAC duct branch stiffeners No Engineering confir-mation on duct adequacy 191 Fan olade failure No Non-Q fan 192 Bolt edge distance requirements No Engineering acceptable