IR 05000353/1987016
| ML20147C906 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/07/1988 |
| From: | Linville J, Williams J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20147C887 | List: |
| References | |
| 50-353-87-16, IEB-77-05, IEB-77-5, IEB-87-002, IEB-87-2, IEC-81-08, IEC-81-8, NUDOCS 8801200012 | |
| Download: ML20147C906 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.-87-16 Docket No. 50-353 License No. CPPR-107 Category A/B Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name: Limerick Generating Station, Unit 2
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Inspection Conducted:
November 16, 1987 to December 20, 1987 Inspectors:
R. A. Gramm, Senior Resident Inspector J. E. Kaucher, Resident Inspector
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A. G. Krasopoulos, Reactor Engineer Reviewed by:
O.M.
//7/82 J. H. Williams, Project Engineer Dite'
@eactorProjectsSection2A
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Approved by:
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s C. Linv0M(, Chief
/Date actor Projects Section Inspection Summary:
Report for Inspection Conducted November 16, 1987 to December 20, 1987,(Report No. 50-353/87-16)
Area Inspected:
Routine inspection by the resider.t inspectors of work
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activities, procedures, and records relative to recirculation pump motor, preoperational test procedure review, structural concrete, turnover record review, fire protection, and assurance of quality.
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The inspectors reviewed licensee action on previously identified items and performed plant inspection tours. The inspection involved 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br /> by the inspectors.
Results:
One violation was idantified involving the failure to properly classify a design change document affecting safety related work activities for
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a welded gusset reinforcement of the recirculation motor seismic lugs.
The misclassification led to failure of quality control to perform the required inspection of the lug welding (paragraph 5b).
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8801200012 880108 I
PDR ADOCK 05000353
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DETAILS 1.0 Summary The review of NRC open items continued with the satisfactory closure of 16 items.
Two items remained open pending licensee review of design control measures regarding pin and socket type electrical connectors and completion of activitie-for fastener material testing (sections 3 and 4). A violation was issued for field lug reinforcement work on the recirculation pump motor seismic brackets that did not receive the required Quality Control inspection (section 5.0).
The initial review of preoperational test procedures found the Standby Liquid Control and 440 Motor Control Center procedures well written and in conformance with the administrative and technical requirements (section 6).
The struc-tural concrete procedures and specifications were reviewed and found to contain the proper technical information as described by FSAR commitments (section 7). The turnover records associated with a partial system turnover for the Residual Heat Removal System were reviewed (section 8).
The design of the fire protection sprinkler and penetration seal programs were found in conformance with the guiding requirements (section 9). A new report section, "Assurance of Quality," was introduced with an indepth discussion of the design control problem related to the General Electric issued field design change documentation.
2.0 Plant Inspection Tours The inspector observed in progress work activities, completed work, and
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plant status in several areas during inspection tours. Work was examined for defects and compliance with regulatory and licensee requirements.
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 l
noted below:
The inspector observed the installation of a conduit support in the
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Auxiliary Equipment Room.
The work package (R30-0176) was reviewed and the installation of the concrete expansion anchors was found acceptable.
The replacement of a Residual Heat Removal (RHR) thrust bearing oil
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cooling coil was observed.
Modification Rework package 2BE220-1 and General Electric FOI 80-73030-1 were reviewed for the increased coil size from 1/2" to 3/4" in diameter.
The inspector interviewed the QC inspector and craftsmen.
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Rework on the Main Steam Isolation Valves (MSIVs) was observed.
Work Packages M41-IP-HV-2F022B and M41-IP-HV-2F022D were reviewed.
The temporary actuator reinstallation and the lapping process were observed.
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The inspector discussed with the civil QC supervisor the current
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rejected items detected in the area of structural steel.
The QC supervisor statcd that the majority of the noted rejects were based upon work package content and not hardware deficiencies.
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The inspector observed a portion of the installation activities on a Pacific Scientific PSA 35 snubber for support GBB-218-H18 of the Residual Heat Removal System.
The inspector noted the presence of m
field engineering and quality control.
The installation activities were performed in accordance with procedure FM-10.
No violations were identified.
3.0 Licensee Action on Previously Identified Items a.
(Closed) Construction Deficiency (81-00-04):
HVAC ductwork not installed in accordance with the design drawings.
The inspector reviewed the following documents:
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Bechtel Management Corrective Action Report (MCAR) 1-24
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PECO Audit Report 237
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PECO Surveillance Check Report M-477.
The licensee instituted the following corrective actions to address the HVAC fabrication problems:
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Schneider imposed a stop work order effective 2/24/81 for jobsite and shop fabrication activities.
Bechtel procurement quality surveillances were increased. A
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100*; inspection of all fabricated duct and hanger supports was instituted.
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Bechtel quality surveillance personnel received additional indoctrination regarding the HVAC engineering specification requirements, weld symbols and drawing details.
A root cause analysis was performed and found that Bechtel
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supplier quality inspections were performed with only Schneider Sheet Metal Drawings and not Bechtel Civil Detail Drawings.
The distribution of Bechtel Civil Detail Drawings was revised to include the Schneider procurement quality inspection
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personnel.
Schneider performed a review of all Bechtel design details for
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areas that could not be constructed, these details were presented to Bechtel for reconciliation.
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Additional Schneider training programs were conducted for AWS welding requirements and symbols.
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A 100*; inspection was performed of all previously tabricated but uninstalled material to assure compliance with the latest design documents.
The Schneider quality department was increased from six to
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eighteen personne..
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A Quality Assurance manager was assigned to manage the site
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quality program.
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PECO performed a confirmatory audit to verify that the Schneider Sheet Metal ~ quality program was being properly
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implemented.
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The licensee reinspected and reworked fabricated ducts and hangers to conform with the Bechtel' design details.
Based upon a review of the licensee actions, this item is: closed.
b.
(Closed) Construction Deficiency (81-00-07): Minimum spacing requirements for concrete anchor bolts.
Bechtel Specification C-64 was reviewed and found to contain minimum anchor bolt spacing requirements for: anchor bolt to anchor bolt, anchor bolt.to con-crete edge distance,-anchor bolt to' abandoned holes, anchor bolt to embedded unistrut and plates, and anchor bolt to grouted in anchor bolts. The licensee had performed field inspections of anchor bolts installed before the issuance of the engineering criteria' for bolt spacing.
The inspector reviewed the following documents:
Schneider in process Rework Notice 127; PECO audit findings C-289 to C-293 and M-479; Bechtel QAR F-193; Bechtel QC inspection report FIR-C-64-SI-7-8; NCRs 4731, 4712, 4517, 4732, 4752, 4795, 4819, and 4929.
The previously installed items that were nonconforming were evaluated by engineering for acceptability.
This item is closed based upon inspector review of the development of bolt spacing criteria, performance of hardware examinations and engineering evaluation of the walkdown results, c.
(Closed) Violation (82-05-01):
Safety related instruments not
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inspected and protected as required.
The inspector. verified that
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instruments in the field are properly sealed and protected. Addi-
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tionally, Bechtel has implemented a surveillance program, by area and elevation, to meet the storage maintenance requirements of GE
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specification 22A2724.
This program is controlled by input into the Maintenance Department's Computer Program (PECO Finding' Report j
N-315). The inspector verified that GE instruments,' installed in i
the plant, are included in the Storage Maintenance Program. This j
item is closed.
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d.
{ Closed)ConstructionDeficiency(83-00-03): Damage to conductor insulation during removal of exterior covering. During the-construction of HVAC control panels by MCC Powers the insulation of various separate conductors were damaged. A 10 CFR Part 21 report was made by MCC Powers and a 10 CFR Part 50.55e report was made by PECO. MCC Powers inspected all suspect panels at Limerick, prepared the appropriate nonconformance reports, and repaired or replaced wiring as necessary.
The inspector has reviewed the dis-position of all nonconforming conditions and finds the corrective action acceptable. No Limerick Unit 2 panels were involved.
This item is closed.
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(Closed) Construction Deficiency (83-00-07):
Cracked unistrut connection clips. The inspettor reviewed the following documents:
Bechtel Management Corrective Action Report (MCAR) 1-33
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Nonconformance Report 8147
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Quality Action Request 474
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Schneider Nonconformance and Disposition Report 1634 Bechtel Instrument Rack drawing M-830-G040 sheet 5
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Bechtel HVAC support drawings C-1390, C-1390-2, C-1366, C-1362
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and C-1366-2 The site installation documents were revised to utilize ungalvanized field fabricated plates with larger bend radii or welded connections in lieu of the unistrut clip angles.
The licensee determined these controls would preclude the recurrence of the observed cracks when the original galvanized strut clips were reverse bent or opened to match the installed strut connection angle. The licensee performed static and fatigue testing to determine the structural capacity of the bent unistrut fittings installed in the plant.
Installed plant system supports were reworked to assure the support integrity for
the installed applications.
This item is closed.
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(Closed) Construction Deficiency (83-00-10):
Defective HVAC damper actuators manufactured by Paul Monroe Hydraulics Inc.
The licensee subsequently removed the hydraulic actuators from the Unit 2 applications. The inspector reviewed NCR 6866 and PEC0 Finding Reports M-600 and 2M-656 that documented the replacement of the Unit 2 Paul Monroe Hydraulic actuators with Limitorque operators.
The inspector reviewed the PECO Alert List and found the subject actuators identified to preclude future use.
This item is closed.
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(Closed) Construction Deficiency (84-00-01):
Potentially defective Limitorque operators.
Because of improper torque switch settings,
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affected valves would travel to the full open or closed position and the motors would trip on thermal overload rather than'high torque. A generic test program has been instituted which utilizes the MOVATS system to verify the torque switch settings of all Unit 2 safety related operators.
This item is closed.
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(Closed) Construction Deficiency (84-00-06):
Defective Capstan spring tangs on Pacific Scientific shock arrestors model PSA-1 and PSA-3.
The inspector reviewed the following documents:
NCRs 8603, 11872 and 10396; Bechtel Shipping Notices J-23315, J0-24144, J0-3273 and J0-24326. All of the suspect shock arrestors were returned to Pacific Scientific for inspection and repair as necessary.
This item is closed.
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(Closed) Construction Deficiency (84-00-11):
Possible insulation damage to Rockbestos cable which may be a concern during a LOCA.
Spot defects in cable jacket material is repaired by Rockbestos at i
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the factory by removal of the defective jacket, trimming of.the exposed jacket edges, and molding a replacement section of identical Jacket material in place.
It was discovered that rework performed by a certain individual had, in some cases, resulted in damage to
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conductor insulation under the area of jacket rework.
Rockbestos made a 10 CFR Part 21 report and PEC0 made'a 10 CFR 50.55e report
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on this matter.
Rockbestos identified to PECO the potentially defective cable reels and location on the reels where jacket. spot defects had been repaired.
The <.pector reviewed Bechtel Noncon-formance Report 10153 and the engineering evaluation performed by Bechtel on the potentially defective cable which had been installed.
Bechtel identified 19.potentially defective cables which had been installed, of these none were inside containment and only five were subject to High Energy Line Break (HEL8) conditions.
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Rockbestos evaluated the HELB conditions and determined that the
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HELB conditions were not severe enough to affect the functional characteristics of the cable. Bechtel additionally determined that potential failure of the five cables subject to the HELB environment would have no affect on the ability of the plant systems to perform their safety functions. The remainder of the cable not used was returned to Rockbestos. This item is closed.
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[ Closed) Construction Deficiency Report (84-00-18):
Swollen ethy-lene propylene seals in G. H. Bettes Co. actuators. The inspector reviewed Plant Change Request (PCR) 1056 and Nonconformance Report
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(NCR) 10076.
The lubricant in the Unit 2 actuators was replaced
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with Molykote 44 silicone as recommended by the manufacturer. The
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associated actuator seals were also replaced.
This item is closed.
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(Closed) Violation (86-21-04):
The use of unverified and unapproved documents containing design and vendor data.
The inspector has verified that both construction engineers and QC engineers have been formally instructed that only source of design and vendor data is contained in approved, controlled project documents.
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inspector has verified that cable pull tension calculations that were prepared using the unapproved, unverified documents were
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reviewed and revised as required. The cable. pulls associated with the revised calculations had not been made.
This item is closed.
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(Closed) Unresolved Item (87-04-01): Welding of Plant Monitoring system enclosure panels.
PECO and Bechtel reviewed the Frank Electric Corporation Welding Procedure Specifications (WPSs)
and Procedure Qualification Test Records (PQRs) for the welding
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processes that were utilized on the Limerick Panels. The licensee found that all code requirements had been fulfilled by Frank Electric for the procedure qualifications. The inspector reviewed PEC0 Finding Report 2N-559 and NCR 12297. The enclosure panel welds were examined by PECO and Bechtel quality' personnel in accordance with AWS 09.1 criteria.
Indications were identified that included:
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extra weld length deposited, lack of fusion, all around fillet-welds not completed, and excessive undercut.
Engineering personnel
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examined and evaluated the as-built panel weld conditions'and found the non-conforming items acceptable. 'This item is closed, m.
(Closed) Unresolved Item (87-08-02):
Licensee QA organization.
description in the Preliminary Safety Analysis Report.
The-licensee updated the QA program for design and construction in a letter dated July 9, 1987 to Region 1.
By NRC Region 1 letter dated November 6, 1987 the QA program was found acceptable. This item is closed.
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(Closed) Violation (87-11-06):
Design documents. issued without design verification.
Numerous design documents for NSSS supplied equipment, including instrument' data sheets, parts lists, assembly drawings and connection diagrams were issued without design verification.
These include the drawing number 169C8370TR for the HPCI leak detection,. instrument. data sheet number 234A9312TR for the reactor water cleanup system and' instrument data sheet number
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234A9310TR for the reactor core isolation cooling. The inspector has performed a sample review of the completed design verification of all GE drawings. Any changes required have been documented on
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the appropriate design cbAnge documents.. Where field changes were required, Field Deviation Disposition Requests have been issued and their c'iosure verified after work completion.
To prevent-this problem from recurring, General Electric has developed a project procedure to process documents that have not been design verified.
The p"ocedure requires that an identification be added to the drawing indicating that it has not been design verified.
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addition, a similar note will be added to the transmittal letter
This' item is closed.
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(Closed) Unresolved Item (87-11-08): Errors in Instrument Data Sheets (IDS) which had been design verified. The inspector reviewed the corrections to the IDSs to' ensure that-the errors did not adversely affect the original design intent (Field Devi-ation Disposition Reouest HH2-6128).
The source of the errors l
was that not all of the design specification data sheets had 'oeen updated to reflect the "as-built" configuration of Limerick Unit 1 J
subsequent to the conttruction restart at Limerick Unit 2.
An additional sample of five IDSs was reviewed and no errors were
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found (PECO Finding Report 2N-579). This item is closed.
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4.0 Licensee Action on IE Sulletins and Circulars l
The inspector reviewed licensee records related to the IE Bulletins and
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Circulars identified below to verify that: -the IE Bulletin or Circular i
was received and reviewed for applicability; a written response was v
provided if required; and the corrective action taken was adequate.
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The following IE Bulletins and Circulars were revieted:
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(0 pen) IE Bulletin 77-05:
Electrical connector assemblies.
The licensee reviewed the plant design in 1977 and identified the locction of pin and socket type connectors.
The connectors were evaluated with respect to Loss of Coolant Accident (LOCA) and High Energy Line Break (HELB) conditions and found acceptable. The inspector asked the licensee to provide the design control measures that would preclude the potential use of these connectors in othe*
plant areas during the intervening timeframe.
This item remains open.
b.
(Closed) IE Circular 81-08:
Foundation materials.
The licensee and architect engineer reviewed the design of Category 1 structures.
No structural foundations were located on compacted soil.
The foundations are situated on rock or backfill concrete and therefore soil backfill settlement problems are not applicable.
This item is closed.
c.
(0 pen) IE Bulletin 87-02:
Fastener testing to determine conformance with applicable material specifications. The licensee was directed to obtain a sample of ten safety related and ten non-safety related fasteners and associated nuts for testing of physical and chemical parameters. The licensee established a committee of PECO and Bechtel personnel to coordinate the site response to the bulletin.
The inspector was presented site procedure 18240-2-FG-002, Rev. O,
"Review and Implementation of all Activities Requested by NRC Compliance Bulletin No. 87-02."
The licensee committee developed the bolting material types and grades sample based upon information in the bulletin, material purchased for the Unit 2 warehouse, material currently in the warehouse and an engineering evaluation of material actually installed in the plant.
The proposed sampling plan was reviewed by the inspector.
The inspector accompanied Bechtel material control and quality control personnel during the actual selection of sampled material.
The inspector verified the selected sample conformed with the proposed sample.
Several items were independently selected by the NRC inspector and added to the sample to be tested.
All of the fastener pieces were assigned a
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sample ID number and tagged with the following information:
stock
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code, size, material and grade, heat number, color code, head marking, bin location, quantity on hand and sample ID. The
fasteners were bagged with associated stud and nut material in the same bag.
The inspector monitored the material selection and identification process. This item remains open pending review of site material control procedures for receipt inspection and storage, review of instructions to the testing laboratorf, and review of the licensee response to this bulletin.
The inspector was additionally informed that the licensee has randomly sampled fastener material for chemical and physical characteristics since approximately 1978.
The licensee data on the program of periodic material sampling will be reviewed in the future.
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5.0 Recirculation Pump Motor a.
The inspector witnessed the ins'tallation of snubber VRR-2RM-H6 that'
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is attached between the biological shield wall and the recirculation pump motor casing.
The snubber was classified as a safety related Class 1 item. A Bechtel quality control inspector was present during the installation.
The inspector verified that the snubber was torqued and stroked in accordance-with procedure FM-10 for installation of mechanical snubbers.
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The inspector identified through discussions with site quality and engineering personnel that the recirculation pump motor has been treated as a non-Q item.
The inspector reviewed the following documents regarding the motor:
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GE purchase specification 21A9344 for the recirculation pump.
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Bechtel receiving inspection reports M-F43691-MRR82500 j
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FSAR Table 3.2-1
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Quality Assurance Diagram M-43
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GE Master Parts List 236X350AD and 238X115AD
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GE Field Disposition Instruction 96-73030-1
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Bechtel QCIR MI-B32-C001-6-1
The recirculation pump motors had been classified by General l
Electric engineering as passive safety related items. The function
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of the motor is non-safety related however the structural integrity of the motor is of concern to preclude potential overstresses of the recirculation piping pressure boundary. General Electric had redesigned the motor seismic lugs by the addition of reinforcing
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gussets to increase the load capability of.the lugs. The Field l
Disposition Instruction was erroneously classified by GE to not
involve any safety related activities and the gussets were not l
inspected on the Unit 2 motor seismic lugs.
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Appendix B, Criterion III of 10 CFR 50 requires that quality
standards be specified in design documents.
Section D.5.2 of the Limerick construction QA program states that General Electric (GE) is responsible to incorporate quality control' provisions into drawings for equipment within the GE scope of supply.
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GE master parts list (238X115AD) identifies the recirculation
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pump motor as a passive safety related item that requires quality
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control inspection. GE Field Disposition Instruction 96-73030-1 was issued for the installation of the motor seismic lug gusset reinforcement as non-safety related work and no quality control inspection was performed for the gusset installation. The failure of GE engineering to provide the proper quality classification for
the lug reinforcement is a violation of 10 CFR 50, Appendix B, Criterion III.
(87-16-01)
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.The licensee subsequently issued QA Finding Reports 2N-588 and 2N-570.
Bechtel'was requested to review this and other passive Q installations.to assure that the appropriate inspections had been performed.
Bechtel was requested further to issue nonconformance documents as necessary and to perform the requisite reinspections.
General Electric was requested to review other issued design change documents to assure that the proper safety relatedLclassification had been assigned.
6.0 Preoperational Test Procedure Review
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The following documents were reviewed with respect to generation of preoperational test procedures:
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FSAR Section 14.2
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Startup Administrative Manual AD8.1P "Preoperational Test Procedure Format and Content" i
Preoperational test procedures are generated to verify dynamic system response and to document test results which are compared with
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both FSAR and engineering system acceptance criteria. The procedure specifies:
procedural approval by engineering, General Electric, PEC0 QA, the Test Review Board (TRB) Chairman, and the PECO Limerick Generating Station Manager; development of non quantitative items to j
be verified in the test objectives section; specification of accept-i ance criteria and associated reference document and procedure step
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that accomplishes verification; documentation of references such as the FSAR, single line diagrams, piping and. instrument diagrams, vendor data, surveillance tests and specifications; precaution and notes that forewarn the test engineer of hazardous conditions and equipment operating limitations; system test prerequisites; temporary installations; review of component technical tests; test instructions which are detailed step-by step instructions to demonstrate test acceptance criteria was satisfied; and system restoration directions. The administrative procedure guidelines were found satisfactory, b.
The inspector reviewed the following documents that pertain to the standby liquid control system preoperational test procedure:
Preoperational Test Procedure 2P-53.1 Revision 0, "Standby
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Liquid Control System (SLCS) Startup Subsystem 53A" I
Limerick FSAR sections 15.8.3.5, 3.9.3.1.12, 9.3.5, 7.4.1.2,
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7.6.1.8.3.4; figures 9.3-5, 9.3-6, 9.3-7, 7.4-2; and tables 9.3-6, 14.2-4 Limerick SER sections 9.3.5, 7.4.1.2, 3.9.3.1
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Limerick Technical Specification section 3/4.1.5
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and table 3.6.3-1
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Piping and Instrument Diagram M-48 sheet 2 and M-52
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sheet 3
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General Electric documents Standby Liquid Control-Data Sheet 22A6246AA Standby Liquid Control-Design Specification 22A6246 Preoperational Test Specification 22A2271AY, Appendix B, GE-3 Redundant Reactivity Control-Design Specification 22A7477 Redundant Reactivity Control-Data Sheet 22A7477AE
Field Deviation Disposition Requests (FDDRs)
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HH2-6043 HH1-0978 HH2-6134 HH2-9012
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Flush procedure 2F53.1 Technical Test Procedure TTI.1
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The system preoperational test procedure was reviewed with respect to the administrative requirements contained in the Startup Admin-istrative Manual.
The test procedure was found complete. The procedure acceptance criteria for-pump operation, Reactor Water Cleanup system isolation, firing of SLC explosive valves, minimum pump capacity, maintenance of SLC tank temperature, verification of
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system alarms, boron solution transport time, operability of squib
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valves and other valve characteristics enveloped both the FSAR and GE test procedure acceptance criteria.
The inspector met with PEC0 Quality Assurance personnel and startup test engineers cognizant of the SLC preoperational tests.
The inspector discussed the isolation valve closure stroke time and found it conservative with respect to the Technical Specifica-tion limits. The minimum net weight of sodium pentaborate added to the SLC tank was found consistent with General Electric design assumptions. The FSAR described the ability of the SLC system to inject the boron solution into the Reactor Pressure Vessel (RPV) in about 40 seconds. -The acceptance criteria and GE analysis has been amended to an injection time of 53 seconds. The inspector was informed that a Licensing Document Change Notice (LDCN) has been issued to correct the FSAR.
Several GE precautions on the system operation were found within associated component test procedures.
The inspector reviewed GE documents NEDE-24222 and NEDE-22042.
The basis for the SLC boron transport times were reviewed. The
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inspector found the 53 second transport time to the core spray j
junction to be the critical value of interest.
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The procedure test sequences for tank heater operation, two pump
. automatic initiation and motor operated valve stroking were reviewed.
b.
The inspector reviewed preoperational test procedure 2P-6.1,
"Safeguard 440V Motor Control Centers." The following related documents were additionally reviewed:
FSAR sections 8.3.1.1.2, 14.2 and
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table 14.2-4
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Startup Administrative Procedures AD2.4, Rev. O, "Test Review Board" ADS.1P, Rev. 3, "Preoperational Test Procedure Format 'and Content" AD8.2P, Rev. 2, "Preoperational Test Procedure Control" Limerick Preoperational Test Procedure Writers Guide
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Limerick Test Review Board Manual, Rev. 0
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Electrical Single Line Diagrams and Schematics
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The inspector reviewed the preoperational test procedure and found the test format and content in accordance with the guiding requirements. The test acceptance criteria were properly trans-
lated primarily from the FSAR to the test procedure and the test-instructions were found satisfactory.
The. test prerequisites and associated documentation for recording acceptance data were reviewed. The inspector reviewed PECO Testing and Laboratories procedures to ensure that appropriate testing performed during the Blue Tag testing phase would receive the necessary quality control inspection.
The inspector reviewed the system voltage acceptance criteria in relationship to the electrical equipment
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design.
No violations were identified.
7.0 Structural Concrete a.
The fa lowing documents were reviewed by the inspector that
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perta 1 to the installation of structural concrete:
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Limerick Final Safety Analysis Report
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section 3.8.1, 3.8.6, and 1.8 tables 3.8-1, 3.8-2, and 3.8-12 Bechtel Specification
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C-62, "Testing of Concrete, Soils-and Reinforcing Steel" C-61, "Furnishing and Delivery of On-site Concrete" C-114, "Purchase of Off-site Supplied Concrete" C-39, "Furnishing, Detailing, Fabricating and Delivering Reinforcing Steel" C-36, "Forming, Placing, Finishing and Curing of Concrete"
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NRC Regulatory Guides
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1.15, "Testing of Reinforcing Bars for Category 1 Concrete Structures" 1.55, "Concrete Placement in Category l. Structures" 1.94, "Quality Assurance Requirements for Installation, Inspection and Testing of. Structural Concrete and Structural
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Steel during the Construction Phase of Nuclear Power Plants"
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Bechtel Quality Control Instructions C-1.20, "Preplacement Inspection of Concrete"
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C-1.30, "Concrete Placement Inspection" C-1.40, "Post Placement Inspection of Concrete"
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Bechtel Construction Procedure CP-2, "Concrete Construction" The inspector verified that the site specifications,' procedures'
.l and instructions were consistent with the FSAR descr'iption for
structural concrete materials, workmanship and inspections.
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particular the following site process. descriptions were reviewed:
i controls for hot and cold weather concrete placement, preparation
of construction joints, repair of concrete surface defects, limita-
tion of concrete layer thickness, concrete curing methods, leak
testing of embedded pip:ng systems, limits on concrete horizontal
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flow distance, sample points for concrete cylinder strength tests,
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concrete material qualification tests, consolidation of. concrete,
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minimum reinforcing bar bend diameters and bending operation
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restrictions, testing frequencies for concrete and concrete
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materials, and reinforcing bar bend and tension test requirements, f
e The associated Quality Control instruction provisions were found adequate.
No violations were identified.
8.0 Turnover Record Review i
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The inspector reviewed the following procedures that describe the
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facility and system turnover process:
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CP-T-1, "System / Partial Turnover"
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CP-T-2, "Facility Turnover to PELO Construction
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Bechtel Project Special Provision PSPG10.1, "Component / System
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Turnover"
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The Limerick structures and systems are divided.into. discrete turnover elements. The appropriate drawings are annotated to define the scope
I of the turnover package.
During the-turnover process numerous system-walkdowns are performed to identify incomplete work items. Quality
Control personnel review inspection records associated with the turnover-
to assure that all necessary inspections have been completed. Exception l
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punchlists are' maintained and upon turnover the open items are incorpo-rated into the Startup Work List (SWL) with the. concurrence of startup
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personnel.
The inspector reviewed Turnov'r Package 2-49A-1p for
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portions of the Residual Heat Removal system. The following. items were found properly complete within the package:
system completion review :
sheet, system turnover form, turnover package content checklist, system cescription, hanger indices; mechanical and electrical equipment indices, valve indices, data confirmation checklist, omission / turnover exceptions list, punchlist/ exception form, permanent equipment boundary tag log, turnover package comment sheet, and scoped piping and instrument diagrams.
The turnover package was found. complete and properly approved by the applicable site groups.
The inspector additionally examined the follow -
ing Quality Control Inspection Reports (QCIRs) that document the QC review of inspection records covering the turnover package:
QCIRs SU-249A-0lP-274-1, SU-249A-01P-758-1, SU-249A-01P-159-1 All records reviewed were found in order and no violations were identified.
9.0 Fire Protection
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The inspector reviewed the following documents to verify that field activities pertaining to the installation of fire protection systems are
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properly controlled in accordance with applicable licensee commitments, codes and standards:
Specification M-40, "Fire Protection Systems"
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' Miscellaneous sprinkler installation drawings
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Miscellaneous hydraulic calculations related to the sprinkler system
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design
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Specification A-40, "Design and Installation of Penetration Seals" The inspector verified that the sprinkler system design complies with the National Fire Protection Association (NRPA) guidance; that the sprinkler
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system design includes critical dimensions such as size and location of water supplier and sprinkler piping; that the design.and fabrication codes have been specified within applicable procurement documents; and
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that the penetration seal program for fire barriers has properly.iden-
'tified the appropriate design, procurement, installation, inspection and tests for assurance that the penetration seals will perform their intended function.
No violations were identified.
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10.0 Assurance of Quality t.
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Control of Design Change Processes The quality assurance program includes two categories of safety related equipment.
Equipment that performs a safety related func-tion is explicitly identified on the project Q-List and associated Quality Assurance Diagrams (QADs).
Equipment that is considered as passive safety related, must provide pressure boundary, provide structural integrity, or maintain the integrity of a safety related electrical circuit.
Passive safety related items are differentiated on QADs by having their outline highlighted with a phantom identi-fication number.
As identified in paragraph 5b, the recirculation pump motor is considered pasr.ve safety related and is properly depicted on QAD M-43 and within'the General Electric Master Parts List.
GE issued a field design change document (FDI 96-73030-1) in 1984 to rein-force the motor seismic lugs.
The FDI was. improperly classified by GE as not involving safety related equipment or function. The field work was properly inspected by Bechtel QC for the Unit 1 motor reinforcement.
However, the Unit 2 work that was performed in 1987 did not receive the commensurate QC inspection because of the erroneous GE classification on the FDI.
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When contacted by 6he inspector, Bechtel Resident Engineering rapidly ascertained that the design intent was tnat the motor integrity is essential to assure the integrity of the recircula-tion piping pressure boundary.
This requires QC inspection of-the structural elements of the motor.
However, Field Engineering and Bechtel QC had r.ot realized that the reinforcement would be treated under the quality program as Q work.
The situation was apparently not fully reviewed in relationship to the QAD requirement when the associated work package was issued.
Had Field Engineering or QC properly checked the QAD, the work would have been designated as Q.
This error is attributable to an inadequate review by GE engineering of the field design change document and to the failure of Bechtel site personnel to verify the application of the QAD requirements to the field work.
PECO Quality Assurance responded promptly to the NRC concern. An investigation was done to confirm that the work should be cate-gorized as passive Q.
Two Finding Reports were issued (2N-570 and 2N-598) by QA. The recommended corrective actions were for Bechtel to review passive Q installations and assure that the necessary inspections had been performed. Bechtel was also directed to reinspect the seismic lugs and issue a Nonconformance
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Report for the situation. ' General Electric was directed to review all_F01s for q passive equipment and to assure that the FDIs were properly categorized as safety related work items.
The licensee response to'the NRC violation' associated with,the improperly issued FDI will be reviewed to assure appropriate preventive actions are specified to preclude recurrence of this problem, b.
Quality Records As documented in paragraph 9, the records for a partial system turnover were reviewed.
The documentation was extremely detailed and complete with respect to the scope of the turnover. The QC review of quality records within the scope of.the turnover was found thorough and well documented.
The turnover process proce-dures and. records were found well defined and controlled.
No violations were identified.
I 11.0 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 December 18,.1987.
Based on discussions _ held with licensee representatives on December-18, 1987, it was determined that this report does not :ontain informat'on subject to 10 CFR 2.790 restrictions.
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