IR 05000353/1987014

Insp Rept 50-353/87-14 on 871012-1115.Violations Noted. Major Areas Inspected:Work Activities,Procedures & Records Re Drywell Structural Steel,Diesel Generator Auxiliary Sys, Instrumentation & Controls & Allegations

ML20237A527
Person / Time
Site:	Limerick
Issue date:	12/04/1987
From:	Linville J, Williams J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20237A512	List: IR 05000353/1987014 IR 07100012/2011015 ML20237A511
References
50-353-87-14, NUDOCS 8712150065
Download: ML20237A527 (18)

Text

1 U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 87-14 i Docket No. 50-353 License No. CPPR-107 Category A l Licensee: Philadelphia Electric Company 2301 Market Street ~

Philadelphia, PA 19101 Facility Name: Limerick Generating Station, Unit 2 Inspection Conducted: October 12, 1987 to November 15, 1987 l Inspectors: R. A. Gramm, Senior Resident Inspector E. Kaucher, Resident Inspector Reviewed by: .

Jth /2/hd7 l H.' Williams, Project Engineer Date'

e ctor Projects Sect on 2A Approved by: pn., //4'( ? // / -

's' C. LinVf1 Te, Chieff Date actor Projects Sectio ' A Inspection Summary: Report for Inspection Conducted October 12, 1987 to November 15,1987 (Report No. 50-353/87-14)

Area Inspected: Routine inspection by the resident inspectors of work activities, procedures, and records relative to drywell structural steel, diesel generator auxiliary systems, snubber installation, PECO Engineering and Research QA, significant deficiency report review, electrical cable and raceway, instrumentation and controls and allegations.

The inspectors reviewed licensee action on previously identified items and performed plant inspection tours. The inspection involved 184 hours0.00213 days <br />0.0511 hours <br />3.042328e-4 weeks <br />7.0012e-5 months <br /> by the inspectors.

Results: One violation was identified involving the failure of engineering to properly translate supplementary material, examination and testing requirements identified in FSAR section 3.2.2.d to the applicable engineering specifications for the standby diesel generator auxiliary piping (paragraph '

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Two unresolved items were identified: NRC review of the engineering analysis for PECO Significant Deficiency Report 205-2 has resulted in concerns regarding the structural analysis of the original zinc coupling installations

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-2-in Unit 2 containment, the basis for zinc behavior at elevated accident condition temperature, and the methodology to upgrade commercial grade items for Q applications (paragraph 8); the second item concerns the potential 1 damage caused by a trash bucket impact against Class 1E cable trays in the !

Reactor Building (paragraph 9b). l

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s 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 observed the performance of a liquid penetrant weld examination on small bore pipe SP-HBB-215-E2 welds 3, 18 and 10 The penetrant examination was performed in accordance with the applicable procedure and the inspector had no concern l

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Portions of the core spray and standby liquid control piping systems were examined inside of primary containment. The core spray piping depicted on P&ID M-52 sheet 3 was examined between reactor pressure vessel nozzle N5A and containment penetration X-168. The standby liquid centrol piping depicted on P&ID M-48 sheet 2 was examined between the core spray connection and containment penetrations X-42 and X-116'. The installed system piping and equipment was found according to the associated P& id Flushing activities on the control rod drive insert and withdrawal piping were observe ,

I The inspector interviewed the QC inspector I and field engineer assigned to the task. Bechtel procedure FM-18 was reviewed without question. The system cleanliness criteria was reviewed. The inspector observed several flush cycles because excessive quantities of particles were present on the flush clot The inspector had no concern The inspector reviewed Bechtel QAR F-594 which documented a further engineering review of the nonconformance reports issued for station battery problems. Bechtel engineering and the battery manufacturer concluded that the nonconformances would not have adversely affected the battery operabilit No violations were identifie .0 Licensee Action on Previously Identified Items (Closed) Construction Deficiency (81-00-02): Failure to Properly

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l install raceway. The inspector reviewed PECO SDR 30, and Bechtel

! Quality Action Requests 177 and 181. The discrepancies involved construction installation of non-safety related raceway either near or on safety related items after Quality Control Inspection had been

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-4-performed and underlength weld metal deposits on 62 electrical support Bechtel and PEC0 engineering evaluated the identified deficiencies and found that the conditions would not have affected the safe operation of the plant. This item is close (Closed) Construction Deficiency (81-00-10): Design of containment box beam assemblies. The licensec reanalyzed the shear stresses for the containment box beams. The reanalysis for SDR 45 found that none of the beams would fail under the postulated faulted conditions and that the resultant deflections would not impair other safety related equipment in primary containment. The reanalysis found however that several beam connections were overstressed as documented by SDR 6 Refined pipe whip loads were utilized to demonstrate the acceptability of all but the box beams at elevation 296 and one box beam at elevation 272. These box beams were modified with weld reinforcement and the addition of a structural member to redistribute the loads, The inspector reviewed the following documents with respect to the box beams:

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Bechtel Management Corrective Action Report 30

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Bechtel Quality Action Request 478

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Bechtel Field Communication F 20175 The construction drawings were revised to include the necessary l connection change Section 4.0 of this report further discusses inspection of these structural beam member installations. This item is close c. (Closed)ConstructionDeficiency(84-00-09]: Pacific Scientific snubber rear bracket gap. Specification P-319-2 was amended to require a minimum 1/4 inch gap between the snubber body and the rear bracket for PSA 50 kip snubbers. The inspector examined nonconformance report 10031 which documented the licensee review of 32 pipe supports which use the 50 kip snubbers. Four situations were repaired to provide additional clearance. This item is close d. (Closed) Construction Deficiency (84-00-13): Loose charging motor mounting bolts on the safeguards 4 KV breakers. The inspector was-informed that all of the BBC Brown Boveri Class IE support bolts were removed, cleaned, coated with locktite and retorqued to 12 foot pounds. PECO . Finding Report 2G-659 was reviewed by the inspector which documented that BBC Brown Boveri supplemental instructions to rectify the problem were added to the site vendor fil PECO Finding Report E-311 was reviewed that documented the correction of seven Unit 2 breakers. The inspector reviewed additional PECO field engineering files for Unit 2 breakers M-102738, N 101760, M-103738, N-106760 and N-108760 which included the rework documents for the bolt This item is close . .. . . . .. .. . ... . . . . . . .. ..

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-5- (Closed) Construction Deficiency (84-00-14): Design of W. Woolley Co. tornado missile door The inspector was informed that Bechtel re-analyzed the missile doors with respect to the site specific missile spectru The inspector reviewed Bechtel calculations 101.64 and 101.65. The potential tornado and railroad blast missiles were hypothesized and the missile door plastic deformation was calculated. A door jam was added on door 205 as documented on NCR 10198. The inspector reviewed pages 19 and 20 of calculation 101.65 that corrected the missile door ultimate resistance and natural frequency properties. Vendor print 8031-A-11-258-10 was modified by Bechtel to reflect the modified door jam. This item is close f. (0 pen) Unresolved Item (86-12-06): Site storage and laydown areas.

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The inspector reviewed Bechtel QA audit PFA 861 that was performed l on August 18, 1987 to September 10, 1987. An adverse finding was issued for improper storage of items that was similar to the i previous NRC unresolved ite This item remains open pending '

satisfactory resolution of the storage condition g. (Closed) Unresolved Item (86-18-02): Installation of temporary small bore pipe supports. The inspector reviewed field engineering correspondence that directed the removal of all tack welds on 10 small bore supports prior to final welding because the required weld documentation was not issued for the questionable tack welds. The small pipe work package and QC inspection record were reviewed for support SP-EBB-242-K3-H8. This item is close h. (Closed) Unresolved Item (87-02-03): Resolution of PEC0 significant deficiency report The inspector reviewed PECO Finding Report 2N-554 that documented the final Anchor Darling swing check valve l (valve M11-3P-2009) inspection. The valve hinge pin set screws were 3 found satisfactorily lock welded by Quality Control. PECO construction personnel received additional training regarding timely resolution of outstanding items. The inspector reviewed a PECO j engineering memorandum that stated no unidentified wire or J

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unqualified wire had been found in the Limitorque motor operators at i Limerick. The inspector reviewed PECO Quality Control Inspection I i Report GI-3582 that documented Rockbestos Type SIS wire was removed from operators on safety related valves M59-HV-251A and M57-2028.

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This item is close i. (Closed) Violation 87-02-05: Unauthorized removal of a raceway support by construction personnel. The required Raceway / Support Rework Notice has been issued to control the reinstallation of raceway support 2A-14-277-C1-1000. Additionally, construction personnel have been re-instructed on the requirements of Construction Procedure CP-E-3 regarding removal of electrical raceway support This item is close )

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-6- (Closed) Violation 87-04-03: Protection of relief valve blowdown ring adjustment lock wire Bechtel Construction has issued

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maintenance action cords which require periodic checking of the condition of the relief valves and additionally has modified Construction Procedure CP-M-4 tc require a formal program of protecting safety relief valves from physical damage during construction. The inspector performed a field walkdown of safety-related relief valves to ensure that adequate physical protection has been provided and that periodic checking is being performed. No new items of concern were identified and this item is close (0 pen) Violation (87-13-01): Wiring errors within the ' Power Generation Control Complex panels. The inspector observed selected panel wiring checks performed in accordance with General Electric connection diagram 807E560TR. The drawing was marked up to reflect the satisfactory and unsatisfactory as-built conditions. The reinspection was performed in accordance with FDDR HH2-20619 This item remains open pending the completion of the wiring verification effort; corrective action implementation; and engineering analysis of the significance of the wiring deficiencie .0 Licensee Action on IE Bulletins and Circulars The inspector reviewed licensee records related to the IE Bulletins and Circulars identified below to verify that: the IE Bulletin or Circular was received and reviewed for applicability; a written response was provided if required; and the corrective action taken was adequate. The following IE Bulletins and Circulars were reviewed: (Closed) IE Bulletin 74-9: Deficiency in General Electric Model 4KV MAGNA-BLAST Breaker Various hardware problems associated with these breakers were identified, causing the breakers to trip open or causing auxiliary contacts to malfunctio The licensee determined the subject breakers are not used at the Limerick project and the defective circuit breakers are listed on the Alert List to prevent future use, (Closed) IE Bulletin 74-12: Incorrect coils in Westinghouse Type SG Relays at Trojan. The licensee determined that no Westinghouse Type 8G293-8255A20 relays would be used in Limerick safety related system The inspector found the PECO Alert List to include the subject relay This item is close (Closed) IE Bulletin 74-15: Misapplication of Cutlerhammer Three Position Maintained Switch, Model No.1-250T. It was determined I that the subject switch could be positioned so that it appeared to be in "AUT0", but was actually in a position between "AUT0" and

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"0FF" in a dead area of the swi tch. PECO reported to Region I, in a letter dated January 23, 1975, that-the subject switches are not used, nor are they planned to be used, on the Limerick project. The

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-7-model No.10250T switches are carried on the project Alert List for products supplied by evaluated vendors to prevent future use of these defective switches on the Limerick projec d. {_Open) IE Circular 77-09: Improper Fuse Coordination in BWR Standby Liquid Control (SLC) System Control Circuits. The inspector was 1 presented General Electric SIL 186 dated July 30, 1976 and the !

licensee actions to modify the SLC control circui The Cooper event occurred on October 9, 1976 and involved different GE l recommendations to replace certain fuses in the control circuit l The licensee was asked to re-review their corrective actions to the l circula This item is open, e. (Closed) IE Bulletin 78-06: Defective Cutlerhammer Type M Relays i with DC Coil The licensee conducted an inspection of all l

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safety-related motor control centers and identified one type M relay (#21150-12) in motor control center 108211. The subject relay was identified on NCR 3369 and replaced by the manufacturer as documented by NCR 348 PEC0 QA performed an audit (E-021) on the replacement of the defective relay. The Type M relays are carried on the project Alert List for products supplied by evaluated vendors to prevent the future use of the defective relays on the Limerick Projec f. (Closed) IE Bulletin 79-11: Faulty Overcurrent Trip Device in Circuit Breakers for Engineered Safety Systems. The licensee determined that Westinghouse Type DB-50 or 08-75 circuit breakers would not be used in Limerick safety related systems. The inspector i found the PECO Alert List to include the subject breakers. This l item is close '

g. { Closed) IE Circular 80-01: Service Advice for General Electric Induction Disc Relays. Induction disc type protective relays using petroleum jelly lubricant were found to become " sticky" thus causing the actual pickup values to be higher than the setpoint value Correction of the condition requires cleaning in accordance with GE ,

Service Advice Letter 721-162.2. A total of 446 subject relays were ;

identified at Limerick and have been cleaned in accordance with SA I l

721-162.2. The Relay Test Procedures at Limerick have been revised

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to require induction disc relays to be checked for date codes upon receipt. Any that fall into the category identified by IE Circular 80-01 are cleaned in accordance with GE SAL 721-16 h. _(Closed) IE Circular 80-02: Nuclear Power Plant Staff Work Hour l This circular was closed for Unit 1 in NRC Inspection Report 84-3 l The inspector reviewed PECO Administrative Procedure A-4 '

" Procedure for Working Hour Restrictions." The procedure defines the site personnel overtime limits and management review processes for extenuating circumstances. This item is close _

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-8- (0 pen) IE Circular 80-11: Emergency Diesel Generator Lube Oil Cooler Failures. The licensee determined that soldered joints were !

not present in the Limerick oil coolers. The inspector asked the licensee to identify if any corrosion inhibitor is used, to provide the procedure for monitoring the parameters such as Ph and to verify the chemical compatibility of any corrosion inhibitor with the materials in the system. This item remains ope J. (Closed) IE Circular 80-15: Loss of Reactor Coolant Pump Cooling and Natural Circulation Cooldown. The licensee reviewed the design of the recirculation pumps and the Reactor Enclosure Cooling Water (RECW) System that serves the pump seals and motor oil coolers. The l potential loss of the RECW system, due to a single failure, was evaluated and found acceptabl The operability of the ;

recirculation pumps is not a safety related functio This item is

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close k. (0 pen) IE Circular 80-21: Regulation of Refueling Activities. The inspector reviewed plant administrative procedures regarding the training and licensing of personnel involved with refueling activitie The inspector asked the licensee to provide the administrative procedure that addresses communication between the refueling personnel and control room personnel that observe the reactivity monitor This item remains ope . [ Closed) IE Bulletin 81-02: Failure of Gate Valves to Close against Differential Pressure. The licensee found the Limerick design did not include any Westinghouse Electro-Mechanical Division Motor operated gate valves, Borg-Warner three-inch motor operated gate valves, or Anchor Darling three-inch double disc valves. The inspector found the PECO Alert List to include the subject valve This item is closed, m. (Closed) IE Circular 81-06: Potential Deficiencies affecting Certain Foxboro 10 to 50 Milliampere Transmitters. The licensee 1 reviewed the Limerick safety related plant systems and found that no Foxboro transmitters were used. The inspector found the PECO Alert List to include the subject transmitter This item is closed, n. (Closed) IE Bulletin 83-08: Electrical Circuit Breakers with an Undervoltage Trip Feature in use in Safety-related Applications other than the Reactor Trip System. The licensee determined that Westinghouse type DB or type DS and General Electric type AK-2 circuit breakers with undervoltage trip features are not used in Limerick safety related systems. The licensee evaluated the two ITE type K-600 circuit breakers that supply power to the safety related reactor building recirculation fan The licensee determined that the ITE undervoltage trip device is not susceptible to the failure mechanism of the Westinghouse or General Electric relays. PEC0 found that as of September 25, 1987 there had been no inservice

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-9-I failures of the maintenance free K-600 circuit breakers. This item I is close (0 pen) IE Bulletin 84-03: Refueling Cavity Water Seal. The inspector asked the licensee to provide design drawings for the i refueling bellows and inflatable ring seals and to provide '

information regarding the preoperational testing of the seal syste This item remains ope l 4.0 Drywell Structural Steel The following design documents were reviewed regarding the j installation of drywell structural steel:

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Bechtel drawings C-927 C-286 C-929 C-276 ,

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C-941 C-935 C-976 C-977 The design drawings included the box beams and connections associated with Construction Deficiency Report 81-00-10 discussed in section 3b of this repor The inspector performed a field examination of structural beams located at elevations 253, 272 and 296. In particular the following i'

beam members and associated connections were examined: 8, 88, 8A, 23A, 27, 35, 28, 31, 32, 34, 34A, 74, 75, 63, 64, 65 and 66. The following aspects were examined during the inspection: member location, member size, weld size and quality, bolt size and location, connection details, and material markin The inspector found that the connections for beams 63 and 64 to the biological shield wall were in variance to the drawing. The l

licensee presented NCR 11,948 which had been previously issued and ,

determined acceptable by engineering. A six inch end return weld I was missing at two connections on beam 8. The licensee issued Field '

Change Request CS-1939 which corrected a drafting error in the drawing and clarified that the end return welds were not necessar The inspector later accompanied Bechtel QA auditors during audit l PFA-883 that covered drawing incorporation. A random review of 97 i change documents identified an additional six drafting errors. The inspector was informed that an audit finding would be issued by Bechtel and that immediate personnel training was performed to I enhance the drawing review proces The following quality records were reviewed by the inspector that

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pertain to the high strength pins depicted on drawing C-977 detail 4:

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- QCIR C43-MRR 126256 The Industrial Mechanics supplier documentation included material physical properties and results of nondestructive testing to verify conformance with the design requirements for the 2 1/2 inch diameter beam pin The inspector selected two beam members and asked the licensee to provide the associated material receiving report. The Mississippi ;

Valley Structural Steel Company records for beams A-204L and A-205L '

were reviewed in report QCIR-C72AC-SF2810. In particular the inspector examined: surface preparation and painting records, A-36 certified mill test reports for chemical and physical properties, SFA5.1 mild steel covered arc welding electrodes certified material ,

test report, A325 bolt material reports, nondestructive examination i records and Supplier Deviation Disposition Requests. The inspector had no concern .0 Diesel Generator Auxiliary Systems The following documents were reviewed by the inspector that pertain to the standby diesel generator air intake and exhaust systems:

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Safety Evaluation Report Section 9. FSAR sections 9. .2. figures 9.5-12 tables 9.5-10 3.2-1

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Piping and Instrument Diagram (P&ID) M-81 and M-20

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Bechtel Specifications P-300, P-301-2, P-305 and P-323

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Quality Assurance Diagram (QAD) M-81 sheet 3 The FSAR invoked supplementary material, examination and test requirements for the B31.1 designed auxiliary diese3 generator piping. In particular ASME materials with Certified Material Test I Reports (CMTRs) were to be used, piping was to be seismic Category 1 with ASME III Class 3 minimum wall thickness, all pipe was to be pneumatically tested to 1.25 times desfqn pressure, and piping greater than two inches was to be examined by radiograph The systems were designated as seismic Category 1 and safety related. The intake air system is comprised of sheet metal duct from the air intake to the filter and is 26 inch diameter carbon steel pipe fr= the filter to the expansion bellows adjacent to the engine. The exhaust piping is carbon steel pipe designated as B3 pipin The air intake duct work and the compartment exhaust system for engines 2B and 2D were examined by the inspector. The duct support location, configuration, member siz", weld size and weld quality,

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-11-I support anchorage, duct size, duct flange connections, duct stiffener location and size, equipment location, and duct configuration were examined and found acccptable. The following design documents were utilized during the hardware examination:

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Bechtel calculation M81-31

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Bechtel drawings M-1319 M-1001 M-1356-2 M-1320 i M-1321 1 l M-1393 detail 108 and 169 l l l The inspector noted that a 70 inch length of unstiffened round duct was immediately adjacent to the air filter assembl Drawing C-1356-2 did not provide a maximum stiffener spacing for this situatio Bechtel QC investigated the situation and found that no stiffeners are required in accordance with drawing C-1329- c. The inspector examined the air intake piping between the filter and the diesel air inlet nozzl The following documents were reviewed:

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isometric .1BD-461-2

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QC Inspection Records JBD-461-2-63-1 JBD-461-2-55-1

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Vendor package JBD-461-2-1 (8031-P100BC-F-1949-1)

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ANSI B31.1 American National Standard for Power Piping The inspector found that neither shop or field circumferential welds had been radiographer, that ASME materials were not procurred and that the intake piping had not been pneumatically tested. The failure of engineering to properly translate the FSAR requirements into the appropriate design and fabrication specifications is a l violation of 10 CFR 50, Appendix B, Criterion III (87-14-01). '

d. The licensee quality assurance organization immediately began an investigation to determine the scope of this problem. PECO issued Finding Report 2N-586 to document that the supplementary requirements were not fulfilled and recommended that other: off skid piping be reviewed, that the FSAR and design documents be

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reconciled, that other FSAR supplementary requirements be verified present in the site design documents and that personnel be trained to assure future FSAR commitments are incorporated into the field implementing requirements. The licensee identified that FCR M16.,

634 had been issued on 10/24/83 to invoke the supplementary requirements, however the FCR was incomplete and ambiguously written and the site drawings and specifications were not revised properl The licensee found that the diesel exhaust piping was similarly deficient in that the requisite radiographic examinations were not performe ;

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-12-e. The inspector reviewed the following FSAR sections and the Fairbanks Morse quality assurance records for standby diesel 2AG501:

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FSAR sections 9.5.4, 9.5.5, 9.5.6, 9.5~7 and 9. tables 9.5-3, 9.5-5, 9.5-7, 9.5-9 and 9.5-10

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Vol. I to 4, Fairbanks Morse Quality Assurance Records M71-F-9-1 (engine 2AG501)

The inspector reviewed the engine contract witness test documentation for the overspeed test, lube oil pump performance, air compressor test, five start test, load acceptance test, load rejection test and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> tes The inspector. verified that maximum exhaust temperatures were less than 750 degrees farenheit, and reviewed certificates of compliance, main frame inspection records, material certificates of conformance, nondestructive examination records, ASME data reports, and hydrostatic test report Various auxiliary system design pressures were verified to be consistent with FSAR dat The inspector had no concerns, Snubber Installation I The inspector reviewed the following documents that pertain to I the installation of mechanical snubbers: )

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Bechtel Specifications P-317, " Pipe Hang 2rs, Supports and Restraints" P-319-2, " Field Fabrication and Installation of Q Listed and Seismic Category 1 Pipe Supports, Hangers and Restraints" .

1 P-130, " Design Specification for Mechanical Shock Suppressors and Compensating Struts"

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Bechtel procedure FM-10, " Installation and Inspection of l Mechanical Snubbers"

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Bechtel QC Instruction P-2.10, " Pipe Hanger, Support, Restraint and Shock Arrestor Installation" The procedures address the following aspects of the snubber installation activities: personnel training; installation precautions to avoid snubber damage; snubber assembly; snubber torquing; and snubber stroke test. The installation procedure references vendor manual information details and gives complete instructicas for the assembly of various snubber component The QC instruction references applicable specification' elements that require QC verification. The inspector had no concern i

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1 The installation and inspection activities for snubbers VRR-2VM-H5 and H6 were observed. The PSA 100 kip snubbers are located between the biological shield wall and the recirculation pump motor casing. A Bechtel QC inspector and a field engineer were present throughout the installation process. The inspector observed the forward end torquing, rear end cap adjustment, end cap nut retorque and snubber strokin The following documents were examined by the inspector:

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work package VRR-2RMLB-HS VRR-2RMLB-H6

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QC Inspection Reports VRR-2RM-LB-H6-0-70-1

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Bechtel hanger drawing VRR-2RM-H6

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NCR 12659

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QCIR P130-AL-MRR-104632

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PSA drawing 1801601 for the Clevis Assembly

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Material Receiving Report 104632

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GE drawing 127D1127

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PSA Rear Bracket drawing 18016008-03

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During the installation of snubber H6, the telescoping cylinder rotated relative to the support cylinder and the snubber was determined unacceptable for installatio Nonconformance Report 12659 was issued to return the snubber to the vendo The receiving documentation for the special clevis assembly was reviewed. The retainer pin hard marking was verified by the inspecto The inspector discussed with engineering the spherical bushing minimum angular movement tolerances and had no question No violations were identifie I 7.0 PECO Engineering and Research QA l The inspector reviewed the following QA Instructions that provide implementing direction for QA activities: l

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QAI 2-2, " Procedure for Training and Qualification of Quality Assurance Personnel"

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QAI 2-6, " Procedure for Training of Quality Control Inspectors"

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QAI 2-7, " Procedure for Qualification of Quality Control Inspectors"

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QAI 2-9, " Procedure for Trend Analysis" The inspector reviewed PECO Trend Analysis report 86-04 that covered the period from January 1, 1986 to December 31, 1986. PECO Audit findings were categorized by trend codes and deficient organization. The trend analysis found the majority of findings were attributable to a failure to follow procedure _ - _ _ _ _ - - - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ -

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-14-The inspector reviewed QA qualification records for several audit and ;

inspection personnel. Indoctrination records, qualification records and l vision examination records were reviewed for selected QC inspection I personnel. The inspector noted that one eye test would not extend to the certification expiration date for a PECO insp~ector. The individual was immediately retested and PECO reviewed the vision examinations of other inspectors to assure that the tests would be valid to the expiration date of the inspector certifications. The inspector had no further concerns as the identified vision test was still valid and no questionable inspection activity had been performe .0 Significant Deficiency Report Review The inspector reviewed PECO Significant Deficiency Report (SDR) 205-2 which evaluated the use of zinc three piece coupling fittings for conduit installation In June 1987, PECO engineering determined the condition was not a significant deficiency because no tests results existed which demonstrate a problem with the coupling Engineering further determined that even if the coupling would fail, that the cable is qualified for (

exposed installation, that the support system would constrain conduit movement, and the the potential hydrogen generation icnrease would be negligibl The documentation associated with a purchase order for the three piece couplings was reviewe Bechtel Purchase Order 18240-F2-008691 was for

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400 Efcor manufactured #170 rigid steel coupling of malleable iron. The fittings were procurred from a distributor, Franklin Electric Company, that provided an associated certificate of conformanc The inspector was informed that all 400 inner pieces were found to be zinc and that the outer coupling pieces were manufactured by Producto in lieu of Efco The items were procurred as 10 CFR21 not applicable and as commercial grade item During installation of the coupling, the zinc inner pieces cracked because of thread incompatibility. Bechtel issued Quality Action Request F-569 to document the use of the zinc fittings which was not allowed by Bechtel specification E-1406 for primary containment raceway applications. The following corrective actions were implemented by Bechtel:

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Field Engineering and Quality Control personnel performed a 100%

inspection of Ericson 3 piece couplings in the Unit 2 primary containment and replaced them with malleable iron. NCR 11,904 documents the locations where zinc fittings were replace On July 6,1987, a 100% receipt inspection of all conduit couplings was instituted to preclude inadvertent supply of zinc fitting Specification E-1406 was revised to preclude the use of zinc conduit couplings in all plant area ._ _

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Balance of Plant Condition Report (BOPCR) E-1197 directed the craft l to inspect and remove from the field and warehouse stores all  !

Ericson couplings. They were inspected for zinc components and '

approved fittings were marked accordingl BOPCR E-1196 assured that all non-Q zinc fittings in the Unit 2 primary containment were replace l

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Procurement documents were revised effective July 7,1987 to explicitly prohibit supply of zinc conduit fitting PECO Finding Report ILF-014 documents the engineering review of the zinc fittings at Unit '

.1kdown was performed of Unit 1 containment and nc zinc outer fittint ce found. Engineering conservatively assumed the inner pieces w' P c and found that the conduit installations were structurally adequ. a e i that the cable within would not be damage Negligible increase r hydrogen were found and a ground fault current path would remain. vechtel letters BLP-40747 and BLP-41149 further discuss the review of Unit 1 area The inspector reviewed Bechtel letter BLP-41228 which summarized the use of zinc fittings outside of the Unit 2 containment. Based upon extensive walkdowns and accompanying engineering analysis, the presence of zinc l fittings was found to not impair the structural adequacy of the conduit j installations. In 192 of 830 couplings, either one or two of the l coupling pieces were found to be zin The inspector additionally reviewed the following documents: '

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Bechtel Specification E-1406, " Conduit and Cable Tray Notes and Details" section 4.6 and Construction Procedure CP-F-1 Bechtel Calculations 99.24.9, 99.24.10, 99.24.11 and 99.24.13 ,

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MIL-STD-105D, Sampling Procedures and Tables for Inspection by  !

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I The inspector held several technical meetings with Bechtel and PECO personnel to discuss this issue. The following concerns remain unresolved:

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Assurance that all cases of zinc used in Unit 2 primary containment as documented by NCR 11904 would be structurally adequate under elevated temperature accident condition l

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Reconciliation of the Bechtel assumption of zinc behavior at elevated temperatures with PECO data from Franklin Research Center that showed zinc fittings disintegrate une r simulated accident conditions and validity of allowable stress equation extrapolation beyond 212 degrees farenhei ,

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Provide assurance that other commercial grade items procured are suitable for upgrade to Q installatio The above concerns are unresolved pending licensee response (87-14-02).

9.0 Electrical Cable and Raceway During a routine inspection tour the inspector noted that cables dropping out of adjacent IE wireways (2DG043 and 20G34S5) into adjacent IE and non-1E cable trays (2DCQA21 and 20C7821) did not conform to the separation requirements specified in E-1406, Conduit j

and Cable Tray Notes. The inspector determined that final ~

acceptance of separation will be performed as part of Construction l Procedure CP-T-2, " Facility Turnover to PECO Construction". This procedure requires that a detailed inspection of all raceway be conducted to assure compliance with project design document It further requires that 16 weeks prior to turnover a punch list be generated to track any required rewor Final acceptance of the facility is contingent upon completion of all required inspections, resolution of all punch list items and final QC inspections performed after resolution of punch list item The inspector finds this approach acceptable and will closely monitor the facility turnover proces As part of the review of the above process the inspector questioned why the separation issue on the cable dropout had not been identified during the conduct of Quality Control Instruction (QCI)

E-4.0 as step 2.7 of QCI E-4.0 requires that separation be verified in accordance with project engineering drawing requirements. The inspector was informed that the intent of QCI E-4.0, step 2.7 was to verify only that IE and non-1E cables were not intermixed. QCI E-4.0 has been modified to define the scope of inspection performed in step 2.7 and to identify that final, detailed separation QC inspection will be performed at the time of facility turnover as discussed abov While performing a routine plant inspection, the inspector witnessed a trash collection pan weighing several hundred pounds striking the supports of Q-listed cable tray The incident occurred while the trash collection pan was being lowered in area 17 of the reactor building. The tag lines attached to the trash collection pan were not being properly used by the laborers to direct the horizontal motion of the pan. The licensee QA division has issued Finding Report 2N-585 which required that classroom training be conducted to instruct laborers in the correct use of tag lines, and also required that all "Q" cable trays and supports at all elevations in area 17 be inspected to insure that no damage has occurred by this or similar incidents. These corrective actions have not been completed, and this item is considered unresolved (87-14-03).

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-17- The inspector toured a 125 volt battery room and observed the installation of insulation barriers in the main bus compartmen Work Packages 2CD105 and 200105 were reviewe The appropriate control room notification form and field change request EL-1169 were included in the work packages. The 1/4 inch thick Brown Boveri electrical grade polyester glass laminate insulation material was examine The inspector later verified that electrical QC had received Rework Notice 7489 since previously inspected cables were disconnected in the bus compartment. The inspector had no concern An in process cable pull was observed by the inspector in the cable spreading room. The pull ticket for cable 2BLE2362A143 was examined and the QC inspector was interviewed with respect to his inspection dutie No concerns were identifie No violations were identifie .0 Instrumentation and Controls The following documents were reviewed by the inspector regarding instruments and tubing associated with work on instruments FT-51-2N0520, FT-51-2N0150, FT-51-2N015A, FT-51-2N052A and FT-51-2N001:

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QAD-M-51, sheet 7, Residual Heat Removal

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Instrument Index, run date 87/08/02

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Work Packages JML-51-06-16Q-A and JML-51-06-37Q-A

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Piping Isometrics FJ-51-06-16A and FJ-51-06-37A Layout Drawing - M1552, Rev. 10, Instrument Location Reactor Building Unit 2, Pian at elevator 217, Area 18

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Drawing M830, Instrument Installation Details

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Drawing 8031-M-251-59-1, Allowable Installation Configuration for Hose Assemblies - Flexible Metal

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Quality Control Instruction I-10, Installation of Instrumentation ~

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Construction Procedure CP-J-1, " Fabrication and Installation of Instrumentation"

The inspector verified that the design of the instrument installation for the above listed safety related RHR pump discharge flow transmitters met the requirements of M-830 including:

materials, valving, layout, orientation to process line, proper fittings and specific vendor requirement The inspector performed a walkdown of the completed instrument installation for the RHR pump discharge flow transmitter FT-51-2N001 and verified the following attributes: tubing bend radii, ovality requirements, torquing of all support bolts, instrument model numbers, instrument ID tags, traceability of root valves and flex hose, instrument location, instrument clearance, proper supports and p tubing slope, tightness of compression fittings, installation

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-18-dimensions, current calibration of torque wrenches and proper documentation by QC inspector During the conduct of the inspection several items of non-conformance were properly identified by the QC inspector These items of non-conformance were: several sections of tubing violated minimum slope requirements, flex hose was touching and a tubing hanger was missing. The non-conforming items were documented and rework notices were issued. As a followup to this observation, the inspector reviewed final acceptance data for instrument installations and found the reject rate higher than anticipate A large number of the rejectable items appear to be due to construction damage occurring between work completion and final QC inspection, Field engineering is providing additional training for crafts to emphasize precautions that are necessary to avoid damage to the instruments and tubing. The inspector will closely monitor future instrument installation rejection rate .0 Allegation 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 are noted below:

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(RI-87-4-0118) The NRC received'an anonymous allegation on October 5,1987 that a Bechtel construction employee had used a controlled substance. The licensee's security personnel interviewed the Bechtel employee, a lead superintendent, on October 6, 1987. The inspector was informed that the Bechtel employee admitted to previous drug use and declined testing under the licensee Fitness for Duty program. The Bechtel employee was terminated on October 6, 1987. This allegation is considered closed based upon the licensee actions and the fact that any safety related work activities under l the direction of the Bechtel employee would be inspected by QC as required.

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12.0 Unresolved Items Unresolved items are matters about which more information is required to ascertain if it is acceptable, a violation or deviatio Unresolved items were discussed in paragraph 8 and .0 Exit Meeting 4 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 November 16, 1987. Based on discussions held with licensee representatives on November 16, 1987, it was determined that this report does not contain information subject to 10 CFR 2.790 l restrictions.

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