IR 05000353/1987004

Insp Rept 50-353/87-04 on 870330-0510.Violation Noted: Failure to Provide Adequate Storage Measures for RHR Sys Relief Valve

ML20214P972
Person / Time
Site:	Limerick
Issue date:	05/28/1987
From:	Linville J, Scholl L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214P951	List: IR 05000353/1987004 ML20214P948 ML20214P959
References
50-353-87-04, 50-353-87-4, NUDOCS 8706040191
Download: ML20214P972 (17)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 87-04 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: March 30, 1987 to May 10, 1987 Inspectors: R. A. Gramm, Senior Resident Inspector J. E. Kaucher, Resident Inspector Reviewed by: ,4u., f.#P P7 Lar~ry L.4ch'oll, Reactor Engineer Date Reactor Projects Section 2A Approved by: m m [ --S M w 5 '

M s C. LinMfb', Chief / Dat4 actor Projects Secti A Inspection Summary: Report for Inspection Conducted March 30, 1987 to May 10, 1987 (Report No. 50-353/87-04)

Area Inspected: Routine inspection by the resident inspectors of work activities, procedures, and records relative to structural steel and structural welding, piping and pipe supports, reactor pressure vessel and internals, electrical cables and raceway, HVAC, preoperational test program meetings, mechanical omponents, and allegation The inspectors reviewed licensee action on previously identified items and performed plant inspection tours. The inspection involved 206 hours0.00238 days <br />0.0572 hours <br />3.406085e-4 weeks <br />7.8383e-5 months <br /> by the inspector Results: One violation was identified involving the failure to provide adequate storage measures for an RHR system relief valve (paragraph 10).

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8706040191 870528 PDR G ADOCK 05000353 PDR

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DETAILS 1.0 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 licensee requirement 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:

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The inspector examined the metallic expansion bellows XJ221D for the air inlet to the standby diesel generator. The shipping bars on the bellows were bent inward. Philadelphia Electric Company (PECO) QA measured the axial length of the bellows and found it consistent with the manufacturer requirement The inspector observed electrical ccble termination activity at panel 2ETBCG501. The cable termination card and connection drawing for cable scheme 2CG001F was reviewed. The cable was found properly lande Two inspectors from the NRC Vendor Inspection Branch came to examine panel closures supplied by Frank Electric Corporation. The examination was prompted by the fact that the Duane Arnold nuclear plant had found that AWS DI.1 welds performed by Frank Electric utilized a welding proceaure for which required volumetric tests had not been performed on the original test coupons. The Frank Electric panels house components associated with the Plant Monitoring System which performs an analog to digital data transfer for the Emergency Response Facility Data System. The vendor inspection personnel visually examined welding on panels 2AZ723, 2BZ724, 2CZ725, and 20Z726 and examined selected Material Receiving Reports. The following questions were raised:

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The Material Receiving Reports did not contain evidence that the panels were seismically qualifie Several welds displayed questionable workmanship attributes such as weld spatter and excessive reinforcemen A vendor deficiency report stated that weld spatter had been successfully removed and satisfactorily reinspected yet spatter remained on the weld PECO responded that while Frank Electric had provided a Certification of Conformance that the panels would be qualified in accordance with IEEE 344, the actual seismic analysis had been completed by Bechtel engineering and found satisfactory.

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The licensee further stated that the enclosure welds would be reinspected in accordance with AWS D9.1 which was the governing welding code for the enclosures. PECO further requested that Frank Electric provide the applicable weld procedures and supporting qualification records for review. Pending the completion of

, licensee investigative actions, this item is unresolve (87-04-01)

2.0 Licensee Action on Previously Identified Items (Closed) Construction Deficiency (80-00-03): Loose or Disconnected Auxiliary Switch Operator Linkages on 4KV Switchgear Breaker Units:

The inspector reviewed Gould-Brown Boveri repair procedure for replacement of the defective linkages, Bechtel Construction nonconformance Report 4143 which documents the completed rework, PECO Significant Deficiency Report 11 which documents reporting requirements of this item under the requirements of 10 CFR 50.55(e)

and PECO letter dated 8/13/81 which makes final report of closure of this item to NRC Region I. This item is close (Closed) Construction Deficiency (80-00-04): Warpage of the Colt diesel generator skid mounted heat exchanger support feet. The inspector reviewed the following documents:

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PECO Significant Deficiency Report 15

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Colt correspondence dated January 16, 1980 and June 13, 1980 to NRC - Region III

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PECO Surveillance Check Report M-355

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Nonconfo'.mance Report (NCR) 4308

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PEC0 Finding Report M-472

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Bechtel Quality Control Inspection Report (QCIR) M-71-QC-G1-6

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Bechtel Field Inspection Report M-71-QC-Gi-6

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Supplier Deviation and Disposition Report M71-38 Colt specified that tapered washers were to be inserted at the bolt locations and tack welded to the base material to achieve a bolt configuration that was consistent with the associated seismic qualification report. Colt fixed the mounting arrangement on three Unit 2 diesel units. A Colt procedure was forwarded to the site to investigate and rectify the mounting arrangement for the fourth Unit 2 diesel. The inspector reviewed QC documentation for the shim installation and bolt torquing on diesel 2AG-501. The inspector examined the heat exchanger mounting arrangements for the Unit 2 diesels. The shim installation and tack welds were in accordance with the Colt direction. This item is close J

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c. (0 pen) Unresolved Item (86-10-02): High Strength bolt application on the CRD restraint beam. The inspecter reviewed PECO Quality Assurance finding 2N-524, General Electric (GE) parts Itst 762E827, and the " Guide to Design Criterion for Bolted and Riveted Joints".

The inspector had the following concerns:

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GE did not specify the use of hardened washers for oversized hole conditions even though both AISC and the design guide specify washers should be present for the oversized hole configuratio The inspector calculated the elongation necessary for a 1 inch diameter bolt to result in a tension of 51,000 pounds. The calculated elongation was in excess of the installation criteria which could result in reduced bolt tensio The bolts were installed with the use of a calibrated wrench. To achieve uniform torque vs. tension relationships the use of hardened washers is required by AISC for bolts installed with a calibrated wrench. The sample of six bolts which established an elongation to torque relationship does not appear to provide adequate confidence that the design bolt tension was achieve This item remains open pending further licensee investigation, d. (Closed) Unresolved Item (86-18-03): Concrete expansion anchor installation requirements. Bechtel was provided correspondence from Molly and Phillips, manufacturers of expansion anchors, that stated the minimum embedment depth recommended by the vendor is measured prior to torquing the anchor bolts. The inspector reviewed Specification C-64 pre-torque embedment values and found them consistent with the vendor recommendations. Bechtel engineering evaluated that the stress cone interference for an anchor spacing of 10 diameters rather than 12 diameters would reduce the anchor capacity by 5%. The anchor ultimate capacity at the reduced spacing was found to provide the necessary factor of safety above the design capacity. This item is close e. (Open) Violation (86-21-04 and 86-21-05): In a letter dated March 17, 1987 Philadelphia Electric Company provided planned corrective and preventive action to the violations contained in NRC Inspection Report 86-21. The response has been reviewed and found acceptabl The verification of the PECO actions will be accomplished in future NRC inspection f. (Closed) Unresolved (86-21-02): Associated Circuits not identified in E-1412. Bechtel Field Engineering performed a complete review of potential " associated circuits" and has issued Drawing Change Notice (DCN) 054 to E-1412, Wire and Cable Notes and Details, revising the list of "Non-Class 1E Circuits fed from Class 1E Busses". The inspector reviewed the DCN and the current Electrical Circuit Schedules to ensure that all circuits added to the list of non-class

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1E circuits fed from Class IE busses were properly identified as safeguard and routed in dedicated safeguard raceway. This item is close (Closed) Followup Item (86-21-03): Cable Pull Calculations. The inspector performed an in-depth review of the technical requirements detailed by Bechtel drawing E-1412, Wire and Cable Notes and Details; Section 2.2, Allowable Pulling Tensions. The inspector found the requirements imposed for both tensile strength and sidewall pressure to be within acceptable design standards. Additionally, Bechtel field engineering has revised E-1406, Conduit and Cable Tray Notes, Symbols and Details to clearly reference and impose the requirements detailed in E-1412. This item is close .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: (Closed) IE Bulletin 84-02: Failure of GE type HFA Relays in use in Class 1E Safety Systems. The subject relays were installed in 12 locations throughout the plant. The inspector reviewed the work packages (FMC-E-313, FDI-LRAS, FDI-LRAR, FDI-LRGB and FDI-LRBF)

which replaced these relays with GE Century series HFA relays for adequacy and completeness. Additionally, the inspector performed a field walkdown to verify replacement of the defective relays. This item is close .0 Structural Steel and Structural Welding The inspector reviewed sections 3.8 and 5.4 of the Limerick Final Safety Analysis Report (FSAR) and sections 3.8 and 3.9 of the Limerick Safety Evaluation Report (SER). Philadelphia Electric Company (PECO) has committed to install structural steel in accordance with the American Institute of Steel Construction (AISC)

requirements. Structural members are either A36 or A441 steel and are bolted with either A325 or A490 high strength bolts. The AISC seventh edition of the " Manual of Steel Construction" was reviewed to identify applicable installation and inspection criteria for structural stee The following Bechtel site specifications and procedures were examined by the inspector:

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Specification C-63, " Erection of Structural Steel"

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Field Change Requests (FCRs) CS-1121, CS-913, CS-868, and CS-923

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Construction Procedure CP-C-9, " Civil Work Packages"

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QC Instruction C-2.10, " Structural Steel Erection" The engineering specification provided criteria for: installation tolerances; material cleanliness at connection interfaces; exclusion of bolt threads from shear planes; bolt torquing methods including turn of the nut, calibrated wrenches or load indicating washers; QC performance of a 20% in process monitoring of bolting activities; QC torquing 10% or minimum of two bolts per connections; QC visual inspection of all connection bolts; and restrictions on reuse of A490 bolts. The associated QC inspection procedure was reviewed and found to properly incorporate the engineering requirement The following concerns were raised by the inspector during the procedure review:

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Specification C-63 allows application of localized heating up to 1200 degrees F to straighten structural member. AISC restricts the temperature to 1100 degrees F for A514 stee The inspector was informed that A514 structural steel has not been used onsit Specifications C-63 does not address AISC criteria that friction type connections are to be free of paint, oil, and other coatings. The inspector was informed that Bechtel has generically designed all connections as bearing type, and not friction typ The inspector discussed with Bechtel personnel the use of calibrated installation wrenches and QC involvement with connection inspection c. The inspector accompanied Bechtel QC personnel during bolting inspections in the suppression pool area. Four connections involving a total of 12 wetwell platform A-325 galvanized bolts were inspected that were erected in accordance with work package C-228-MS-SPPS. One of the bolts was found undertorqued, the Bechtel inspector checked all bolts on the affected connection and the craft torqued the bolt to the appropriate value. The inspector additionally witnessed QC torque checks of seven connections involving 14 downcomer bracing A-490 bolts. The following items were verified as appropriate during the QC inspections: use of calibrated wrenches; tapered washers; adequate thread engagement; threads excluded from the shear plane; proper bolt hole size; proper bolt hole edge distances; hardened washers present; and conformance of as installed conntctions with the design drawing. The inspector had no concerns.

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. The inspector reviewed the following engineering drawings that pertain to the supports for drywell unit coolers 2AV-212 and 2GV-212:

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Drwgs. C-1415, C-1416, C-1417, C-1418, and C-141 The installed supports were examined with respect to: member size; member configuration; weld size and quality; support location; high strength bolt connections; bracing configuration; and floor anchorage. The inspector identified that several bracing members were not yet installed on the supports and that one member had been removed. The associated QC Inspection Reports (C-1417-MS-24606-08-2 and C-1417-MS-24500-08-2) and Civil Work Packages (C-1417-MS-2AVI and C-1417-MS-2GV7A) were reviewed to assure that the member removal was documented and that direction has been provided to the craft to install the incomplete bracing. The inspector had no further questions. No violations were identifie The inspector reviewed the Limerick FSAR which documents that structural welding will be performed in accordance with AWS 0 and that weld inspections will be accomplished utilizing the Nuclear Construction Issues Group (NCIG) Visual Weld Acceptance Criteria (VWAC).

Bechtel Specification G-20, " Visual Examination Acceptance Criteria" was reviewed with respect to the VWAC document. The site specifi-cation acceptance criteria and inspection guidelines for weld cracks, weld size, weld fusion, weld overlap, weld profile, undercut and arc strikes were found consistent with VWAC. The inspector had no concerns, The following Bechtel procedures for structural welding were reviewed:

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General Welding Standard (GWS) - Structural

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Construction Procedure CP-W-1, " Welding"

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Structural Weld Procedures P1-A-C-LH and P1-M-PA An AWS pre qualified procedure was checked utilizing AWS D Appendix E. The following parameters were checked by the inspector:

joint details; minimum intermittent fillet weld length; minimum and maximum groove angle; beveled groove radius tolerance; root face and opening tolerance; weld position; ambient temperature and weather conditions; edge preparation; fillet weld base metal gaps; tack weld quality and qualification; weld cleaning; and filler metal contro A weld procedure that was not pre qualified was checked by the inspector in accordance with AWS D1.1 Section 5 Part B. The gas metal arc welding essential variables were found properly specifie $ .

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The necessary mechanical bend tests had been documente The inspector had no concern No violations were identifie .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 DCA-201-1 FW6 1 RWCU Weld prep SP-HBD-465-E14 FW6 B3 "Q" weld Socket Weld All observed activities were in accordance with applicable procedure requirements. No concerns were identifie .0 Reactor Pressure Vessel and Internals The inspector observed in process automatic machine welding on Control Rod Drive (CRD) housing 02-43 to the associated Reactor Pressure Vessel (RPV) stub tube. The traveler package, special process control sheet, joint process control sheet and filler metal requisition doc *.ents were reviewed. The appropriate QC hold points had been satisfactorily inspected for cleanliness, flange elevation, fitup, preheat and root pass examination. The inspector had no concerns, In process work activities on the core spray post modifications were observed by the inspector. Traveler package 2-262T and Field Disposition Instruction 52/73030-1 were reviewed for details regard-ing the support bracket modifications. The inspector observed trial fitup of the bracket over the core spray lin The inspector had no concern The inspector observed fabrication activities on the feedwater sparger to thermal sleeve welding. The performance of the final liquid penetrant examination on weld 10 for the sparger located at 30 degree azimuth was observed. The inspector verified penetrant

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dwell time, excess penetrant removal, developer application, final interpretation and developer removal. The associated joint process control sheet and filler metal requisition for joint 10 were reviewe The middle thermal sleeve was positioned 3/8 inch from the feedwater sparger sleeve. The inspector observed the installation of tack welds on the middle thermal sleeve. The tack weld wire, clamp on meter amperage, wire diameter, and polarity were found consistent with the associated weld procedure. The inspector additionally observed the initial stages of the liquid penetrant examination of the feedwater sparger weld preparation for sparger serial number The inspector had no concern No violations were identifie .0 Electrical Cables Raceway and Components The inspector observed a power cable pull between Motor Control Center (MCC) MCC 20B221 to MCC 20B217 for Cable 2CB21704A-143. The cable was made up of three single conductor wires. The head of the cable had exited the conduit and a winch was used to continue the power pull. The allowable tension had been calculated as 1500 pounds and the inspector reviewed the associated QC documentation which recorded a maximum pull tension of 1480 pounds. A QC inspector and electrical field engineer were present during the power pull operation. While a tensiometer had been used for the portion of the pull when the head of the cable was within the conduit, the tensiometer was not utilized during the stages of the power pull after the cable head had exited the end of the condui The inspector was informed that craft supervision had independently chosen to continue the pull without tension monitoring. The QC inspector subsequently documented the improperly pulled cable on Non-conformance Report 11829 and cable 2CB21704A was pulled out and scrapped. Additionally, training classes were held for construction personnel regarding the necessity to perform tension monitoring throughout the duration of power pull The inspector had no further concerns on this issu The inspector observed electrical continuity checks at a Conax Control Rod Drive electrical penetration for cables J1-5-4, J2-5-1 and J2-5-2 at feedthrough 2. The inspector reviewed drawing 7514-10004 and the connector location legend from work package EI-0014-0043. Bechtel QC personnel were present to monitor the work activities. The inspector had no concern The inspector reviewed work package R30-0007 for a Class 1E gutter installation in the cable spreading room. The installed portions of gutter 2WG012 were examined. The gutter was found pronerly routed and supported. The inspector had no concerns.

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. In process work activities on the Class IE battery rack installations were monitored. The associated work package EI-30-0027 was examine The work package included the appropriate manufacturer instruction regarding seismic anchorage and bolting hardware. The C & D Battery rack installation drawings were reviewed. Documentation for the battery rack grouting and concrete anchors were reviewed. The rack installation was found in accordance with the work package require-ments and the inspector had no concern No violations were identifie .0 He-ting, Ventilation and Air Conditioning - The inspector reviewed the following documents that pertain to the design and installation of the Heating, Ventilation and Air Conditioning (HVAC) system:

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FSAR Table 9.4-4 Section 9.4. Figure 9.4-7

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Bechtel Specification M-68A-2, "HVAC Installation, Class I and Class IIA Seismic"

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

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Quality Control Instructions:

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

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M-00 Legend M-77 Drywell HVAC

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Quality Assurance Diagram (QAD) M-77 Drywell HVAC

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Field Change Requests (FCRs) MV-853, MV-809, MV-777, MV-743, MV-521, MV-421, MV-514, MV-454, MV-427, MV-338, and MV-30 Specification G-20, " Visual Examination Acceptance Criteria for Welded Structures" The FSAR states that safety related ductwork has been shown to meet seismic Category 1 standards through analysis or test. The ductwork is supported by seismic duct supports. After construction, leakage tests are to be performed on the duc _ _-__ -

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The inspector reviewed the FSAR description of the drywell HVAC system. The' system function is to circulate, but.not cool, air C

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after an accident. The ductwork design incorporates relief valves -

to prevent transient differential pressures from exceeding the component design rating. The site layout drawings were compared to

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the FSAR system configuration. The system layout and safety related boundaries were found consistent.

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Specification M-68A-2 requires that- ductwork markir.gs be placed

, at intervals not to exceed. twenty-five feet and at points where

, the duct. enters and exits from rooms. The current QC instruc-

. tions do not-include an associated inspection attribute however QC personnel were developi.ng an HVAC turnover instruction that

would provide the necessary marking. inspectio q\

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The FSAR states that seismic ductwork was seismically designed-

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based upon Bechtel tests and analysis perfbrmed in 1976. The current weld inspection criteria for duct was found less L stringent than AWS D9.1 criteria for sheet metal welding. The

. following inconsitencies were identified: .

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l AWS D9.1 Criteria Bechtel Spec G-20 App. A Crite ia

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- No cracks permitted Crater cracks allowed

. - Undercut less than 0.15t Undercut less than 0.25t . ?

for t less than 0.187 inches- 'a

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- Limit on porosity per Perosity not a criteria for l inch of weld rejection

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reinforcement without limit i .

.. The above issues are unresolved (87-04-02) pending licensee-I development of the HVAC turnover QC instruction and providing an engineering justification of equivalence between the current weld e inspection criteria and the weld acceptance criteria that was ,#

assumed during the 1976 seismic testing.

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b. The inspector reviewed recent Bechtel audits for on and offsite i fabrication of HVAC components. The following audits and associated j QA findings, checklists and data collection sheets were examined:

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PFA 781 9/22 - 10/6/86 Procedures, welder 2 document control certification findings records, inprocess welding, field rod a

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n PFA 745 4/10 - 6/12/86 6 inprocess and 9 Work package draw-completed work ings not updated, packages HVAC inspection Reports not properly signed *

PFA 788 11/5 - 11/7/86 Schneider Pitts- Companion flanges'

burgh facility, made from 10 G material certifi- Sheet in lieu of cations, welder structural shapes; qualification some material icss records, inspec- than 36 KSI yield'

tion records, shop strength fabrication acti-vities on 7 duct pieces s

The audits were found to address hardware and software-related aspects of the HVAC subcontractor activities. The identified c deficiencies were appropriately documented on finding reports. 'The .

audit checklists were developed from engineering specification requirement The Bechtel finding report log was reviewed to identify QA deficiencies associated with Schneider work activities on HVAC-systems. The following reports were examined: ,

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Quality Action Request (QAR) F-531, current Bechtel design , t drawing not forwarded to offsite fabrication she ,

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QAR F-535, attachments to bioshield 1,nspected to' incorrect specification, NCR 11560 issue ,

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QAR F-703, welding of unistrut support materia QAR F-536, fabrication cencerns on duct connection detail Three NCRs issue The available responses to the QA deficiencies were reviewed and found technically adequat The inspector reviewed PECO audit reports performed in the HVAC area. The associated audit checklists were examined. The following audits were reviewed:

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Li Audit N Audit Date Areas Audited Remarks 2G-206 5/20 - 6/6/86 HVAC work package 2 findings issued control 2M-537 111/26 - 12/23/86 HVAC duct & sup-

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No findings

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port installation, bolting, welding, hanger confirgura-tion f 2M-521 2/25 - 3/11/86 Reactor building Four findings 4 HVAC, welder issued; work pack-

qualification, age drawing, weld filler mater- Schneider welding

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ial control, duct qualification

' installation tests, and duct f protection from work activitie The audits were satisfactorily accomplished and had focused on hardware aspects. The concerns identified during the audit were appropriately documented on QA finding reports. The inspector had no Concern The inspector performed a walkdown examination of portions of the drywell HVAC system. The following engineering documents were reviewed and utilized during the field inspection in addition to the documents identified in section 9.1 of this report:

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Bechtel drawings: M-1001, M-1184, C-1400, C-1400-2, C-1401-2, C-1329-2, C-1381, C-1350-2, C-1351-2, C-1352-2, C-1353-2, C-1354-2, C-1355-2, C-1356-2, C-1362-2, C-1363-2, C-1364-2, C-1365-2, C-1366-2, C-1367-2, C-1368-2, and M-1190

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Schneider sheet metal drawings: M-1184-1-SSM and M-1184-2-SS Schneider duct support drawings: M-1184-1-H-26, M-1184-1-H-27, M-1184-2-H-1, M-1184-2-H-2, and M-1184-2-H- American Warming and Ventilating drawings 13509 (8031-M-113-42-6) and 10151 (8031-M-113-70-6)

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Pressure Relief Valve drawing 8031-M-123-290-78R The inspector examined the following HVAC Components:

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Unit coolers cooling core and axial flow fans - 2AV-212 and 2GV-21 , _ _ _ _ _ _

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Balance and backdraft dampers - BDD-77-207A, BDD-77-208A, 80-516-2, BD-508-2, BD-508-3, BDD-77-207G, BDD-77-208 Duct supports - M-1184-1 hangers 13 and 14, M-1184-2 hangers 1 and Duct pieces - M-1184-1 pcs 26, 27, 22, 28, 30, 33, 27, and 2 M-1184-2 pcs 44, 45, and 4 Duct relief valve collars - PRV-A-2-13 and PRV-A-2-14

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Transition pieces - M-1184-1 pcs. 19, 20, 21A, 24, 31, and 3 M-1184-2 pcs 42, 41, 39 and 4 The components were checked for proper location and connection to the associated duct or supports. The dampers were checked for proper flow direction and potential operability interferences. The use of silicone rubber gaskets and proper bolting hardware was verified for flanged duct connections. The duct supports were checked for member size; member configuration; location; weld size and weld qualit The duct size; duct weld quality; companion flange members; inter-mediate duct stiffener size and location were examined. The duct instrumentation and pressure relief valves have not been installed dee to potential for damage from ongoing construction activitie The inspector reviewed work package documentation for assurance that the components not yet installed were being tracked by field engineering. The duct expansion bellows were covered for protectio The inspector identified a dent in the companion flange at duct pieces 1184-01-028, 030 and 033. Bechtel issued Nonconformance

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Report 11885 and found that the condition was acceptable based upon a structural evaluation of the flange connection and that the joint integrity was maintained. The intermittent fillet weld of a companion angle to a balancing damper was reviewed and found in accordance with Bechtel design criteria for weld size and spacin Three Bechtel QC inspection reports were additionally reviewed that were associated with duct or supports that the inspector examine The records were properly filled out and reflected the field condition with the exception of the dent discussed abov The inspector toured the Schneider Power site fabrication sho Various duct components were examined. The fabrication processes were discussed with the fabrication shop foreman.

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The inspector accompanied a Bechtel QA auditor during the conduct of a field monitoring of HVAC welding. The auditor was found knowledgeable of the HVAC design requirements. The auditor checked the control of welding processes and materials. The inspector had no concern .

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The inspector interviewed Schneider Power site management personnel, Bechtel field HVAC engineering personnel and Bechtel HVAC Quality Control personnel during this inspectio No violations were identifie .0 Preoperational Test Program A meeting was held on April 21 between Region 1 and PEC0 personnel to discuss various aspects of the preoperational test program. The inter-relationship of the Blue-Tag testing and preoperational testing were discussed. Blue-Tag testing will be conducted as part of post construction verification and will include such items as equipment calibration, circuit logic testing and equipment operability testin Portions of the Blue-Tag tests are to be taken credit for in the preoperational test program to eliminate the need to retest certain equipment and sub-systems. Additional topics of discussion included plant staffing levels for operations personnel, the role of QA/QC during the test program, the role of the Test Review Board, equipment turnover process, and the test procedure review cycles. Region 1 indicated that there would be closer scrutiny of the Blue-Tag testing because of the increased reliance upon it during the preoperational test phas Further discussions were held between NRC inspection personnel and PECO startup test personnel regarding the inter-relationship of Blue Tag test-ing and the preoperational system tests. Portions of the draft Core Spray and Reactor Enclosure Cooling Water system preoperational tests and asso-ciated Field Engineering tests were reviewed. The proposed methodology to correlate acceptance critera and Blue Tag tests was presente .0 Mechanical Components During routine inspection of installed equipment the inspector identified a broken lock wire on valve PSV-51-2F055A in the RHR system. The lock wire prevents the removal of two plugs which provide access to adjustment rings for the valve blowdown. The missing lock wire rendered the blowdown adjustment indeterminate and dictates that the valve be retested. During the walkdown the inspector noted that the lockwire on valve PSV-51-2F055B (RHR train B) was properly installed and adequately protected to prevent damage or removal. At the present time no formal program has been insti-tuted to have relief valve seal wires protected from construction activitie PECO QA has initiated Finding Report 2N-557 to Bechtel Construction Inc. requiring modification of the Long Term Maintenance program to include actions to protect and periodically check lock wires on safety related relief valves. The lack of such a program is a violation of 10 CFR 50 Appendix B - Criterion XIII, in that no measures have been established to prevent damage or deterioration of material and equipment. (87-04-03) .

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. The inspector monitored the replenishment of oil for the core spray pump motor 2AP-206 upper reservoir. The oil reservoir was filled as the motor had been drained prior to moving it to the field locatio The oil replenishment was performed by Bechtel millwrights and directed by a Long Term Maintenance (LTM) engineer. A OC inspector monitored the operation. The inspector reviewed Maintenance Action Item (MAI) 3306 which specified Mobil oil for the motor. The inspector had no concern The Quality Control (QC) records and copies of work packages were reviewed for the installation of core spray pumps and motors for 28P-206 and 2DP-20 Quality Control Inspection Report (QCIR)

P206-46-1 was reviewed for pump 2DP-206. The foundation bolt torque records and motor flange bolt installation records were examined. The temporary foundation anchor nuts were replaced with hardened washers and A307 nuts. The associated pump and motor installations were visually examined. No violation were identifie .0 Allegations During the inspection period, the inspector conducted inspections and interviews in response to an allegation received by the NRC. The inspector and licensee actions resulting from the allegation is noted below:

(RI-87 A-0041) The NRC received an anonymous allegation that a field weld engineer had issued pre-approved weld requisition forms for construction use. _The inspector performed a field inspection and confirmed that three Bechtel weld metal requisition forms had been pre-approved. Two forms were subsequently destroyed and the inspector retained one forin. Site procedures require the weld engineer to review the qualification of the assigned welder, applicable weld procedure and filler metal compatibility prior to signing the form to authorize filler metal withdrawal. The licensee was informed of the problem and the following steps were taken:

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The field weld engineer that had pre-approved the forms was interviewed and he admitted to filling several forms out in advance for construction use. The engineer was informed of the procedural requirements for weld metal documentation and was suspended for five day A field examination was performed by Bechtel of other work package areas to identify whether other pre-approved forms existed. None were foun All field weld engineers were re-trained or proper methods to fill out the filler metal requisition form All rod room attendents were interviewed by Bechtel regarding previous instances where weld requisition forms had been filled out in error. Bechtel ascertained that on three occasions, temporary

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e foremen had improperly filled the forms out. The inspector was informed that the foremen were reindoctrinated on the proper method to generate the filler metal requisition form The inspector has found that Bechtel QC reviews all safety related "Q" weld requisition forms, after the rod is drawn, to assure use of qualified personnel and materials. Prior to issuing weld rod, the rod room attendents indicated that the qualification of the welder is checked in relationship to the applicable weld procedur These additional reviews of the weld requisition forms would detect the use of unqualified welders or materials. While the practice of pre-approved requisitions is not authorized by site procedures, no impact upon safety related welding was identified and the licensee's corrective action should prevent recurrence. This allegation is close .0 Unresolved Items Unresolved items are matters about which more information is required to ascertain if it is acceptable, a violation, or a deviatio Unresolved items were discussed in paragraphs 2 and .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 May 8, 1987. Based on discussions held with licensee representatives on May 8, 1987, it was determined that this report does not contain information subject to 10 CFR 2.790 restrictions.