IR 05000353/1988010
| ML20195D285 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/10/1988 |
| From: | Linville J, Williams J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20195D265 | List: |
| References | |
| 50-353-88-10, NUDOCS 8806230087 | |
| Download: ML20195D285 (19) | |
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U. S. NUCLEAR REGULATOTY COMMISSION
REGION I
Report No. 88-10 i
Docket No. 50-353 Licensi No. CPPR-107 Category A/B t'
Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101-Facility Name: Limerick Generating Station, Unit 2 Inspection Conducted: April 11, 1988 to May 22, 1988 l
Inspectors:
R. A. Gramm, Senior Resident Inspector, Unit 2 R. L. Fuhrmeister, Resi nt Inspector, Unit 2 Reviewed by:
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J.
'Wi l l i ams,Wo'j ec t g ' n'e e r D(te '
tor Projects Secti Approved by:
_6[/P/8 J
.s C. LinviW, Chief
/ 0 ate'
ctor Projects Sectio A
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Inspection Summary: Report for Inspection Conducted April 11, 1988 to May 22, 1988 (Report No. 50-353/88-10)
Area Inspected:
Routine inspection by the resident inspector of work activities, procedures, and records relative to diesel generator bearing refurbishment, Bechtel engineering system turnover walkdowns, cable
installation activities, preoperational tost performance, reactor pressure vessel hydrostatic test results, in process welding, component technical testing, preoperational test review, water curtain design, construction deficiencies and assurance of quality.
The inspectors reviewed licensee action on previously identified items and performed plant inspection tours.
The inspection involved 257 hours0.00297 days <br />0.0714 hours <br />4.249339e-4 weeks <br />9.77885e-5 months <br /> by the inspectors.
Results: One violation was identified involving undersized welds and missing welds on instrument racks ;upplied by General Electric (details section 14).
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8906230087 880615 DR ADOCK 0500
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TABLE OF CONTENTS Page 1.0 Summary.
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2.0 Plant Inspection Tours........
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3.0 Licensee Action on Previously Identified Items
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4.0 Licensee Action on IE Bulletins and Circulars........
5.0 Preoperational Test Witnessing....
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6.0 Technical Test Program Implementation.
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7.0 Preoperational Test Procedure Review.
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8.0 System Walkdowns..
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9.0 Bechtel Quality Assurance..................
10.0 Reactor Pressure Vessel Hydrostatic Test Results.......
11.0 Diesel Generator Refurbishment Activities..........
12.0 In-Process Welding.
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13.0 Bechtel Engineering.
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14.0 Instrumentation
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15.0 Electrical Cable and Components...............
a)
'B' Diesel Generator Cable Replacement.
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b)
Cutler-Hammer MCC Conical Spring Washer Failures....
16.0 Meetings with Licensee.
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17.0 Assurance of Quality.
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DETAILS 1.0 Summary
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Eight NRC open items were reviewed and six were closed (sections 3 and 4). As discussed in section 5, preoperational testing of the Safeguard Power Supply System was witnessed.
The implementation of portions of the Technical Test Program were reviewed as discussed in section 6.
PECo reported a deficiency under 10 CFR 50.55(e) regarding
Cutler-Hammer Motor Control Centers, which is discussed in detail in section 15.0.
Replacement of diesel generator bearings and power cable were inspected, as discussed in sections 11.0 and 15.0, respectively.
One violation (88-10-01) was identified involving missing and undersized welds on instrument racks supplied by General Electric, as described in section 14.0.
Reactor Pressure Vessel Hydrostatic Test results were reviewed (section 10), as were Bechtel Engineering (section 13).and Bechtel Quality Assurance activities (section 9).
The inspectors
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participated in system turnover walkdowns, and independently verified
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installed piping system conformance with FSAR descriptions (section 8).
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2.0 Plant Inspection Tours (35060, 51063, 51053)
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 requirements.
Particular note was taken of the presence of quality control inspectors
i and quality control evidence such as inspection records, material
identification, nonconforming material identification, housekeeping and
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equipment preservation.
The inspector interviewed craf t supervision, craft and quality control personnel in the work areas. Observations are noted below:
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The inspector noted that a proposal was issued by the NRC involving
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The change would amend regulations involving the announcement of NRC inspectors onsite.
The licensee reviewed the j
proposed rule and immediately amended the construction security force post orders to end the routine notification of inplant j
personnel when an NRC inspector enters the site.
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The inspector was informed that the Test Review Board (TRB) had
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requested a QA review of TRB activities.
The review identified
several inconsistencies and questions regarding the TRB program.
The TRB Chairman indicated that procedural enhancements would be
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made ir response to the QA concerns, j
The inspector was informed that Licensee Event Report 88-000 was
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submitted for Unit I regarding a design deficiency on a water
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curtain system. The FSAR had specified the system would achieve a
0.30 gallons per minute per square-foot (gpm/f t ) at the floor level
however the systems were calculated to provide 0.13 to 0.21 gpm/ft
spray density. The inspector discussed the applicability of the i
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problem to Unit 2 with Bechtel engineering personnel.
Bechtel stated that the system had been redesigned on Unit 2 to provide the requisite spray density.
The original calculations had been
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performed by a subcontractor, Viking, and the problem had been
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i originally identified by PECo.
There are only three water curtains
in Unit 2 and the inspector was informed the installations were
redesigned as necessary.
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The Bechtel Reportability Review log was reviewed by the inspector.
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Bechtel Nonconformance Reports are examined by Bechtel and PECo to determine whether the deficiency is potentially reportable under 10 CFR 50.55(e).
Several of the Bechtel NCRs had been translated to
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PECo Significant Reports and some items had been reported to the
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NRC. The inspector noted that the majority of the NCRs were found
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acceptable based upon further engineering analysis.
The inspector
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The inspector reviewed Region I Temporary Instruction 87-06
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regarding lubrication of General Motors Electro-Motive Division diesel generators with Ingersoll Rand air start motors.
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Limerick Unit 2 diesel generators are manufactured by Colt-Fairbanks
Morse and do not utilize Ingersoll Rand air start motors.
Rather, j
an air distributor delivers starting air to the engine cylinders in j
the firing order. Tnis Temporary Instruction is not applicable.
The inspector observed the installation of fire stops in conduits
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in the diesel generator building.
The inspector reviewed Procedure
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CP-E-4, Procedure for the installation of Internal Raceway and a
Equipment Seals and Electrical Raceway. Fireproofing, and the vendor instructions for the foam material used.
The inspector verified that sampling and density calculations were performed in accordance with vendor recommendations, and that instellation was in accordance with procedural requirements.
The inspector also verified that
appropriate safety precautions were being taken.
i No violations were identified.
i 3.0 Licensee Action on Previously Identified Items (92701, 92702]
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a.
(Closed) Construction Deficiency Report (82-00-02):
NSSS Local Rack Installation.
This deficiency was first reported to NRC in November
1982 by GE-NEB 0 and involved incorrect instrument connection identi-
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fication on the drawings for four local instrument racks for Unit 1
and Unit 2 (same four rackr in each plant).
It was noted at that
time that incorrect connection of the instruments could compromise
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the Emergency Core Cooling System design basis. GE issued Field
Deviation Disposition Requests to PECo to identify and-authorize appropriate corrective action for the Unit I racks in 1982.
In addition, during 1986, 1987 and 1988 additional action was identi-
fled and completed to make the configuration of the Unit 2 racks l
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conform with the actual installed configuration of the corresponding racks in Unit 1.
This item is closed.
b.
(Closed) Unresolved Item (87-04-02): HVAC ductwork installation welding and marking requirements. Bechtel engineering analyzed the dif ferences between Specification G-20 and weld inspection criteria in relation to the 1976 seismic duct testing in response to PECo Finding Report 2N-561.
The original duct testing was performed with butt welds that had a lack of penetration of up to 70% which represents a weld size reduction far in excess of that allowed by specification G-20.
The actual welding is still performed in accordance with the requirements of AWS D1.1, which exceeds the tested configuration.
Site procedure CP-G-9, "Plant Component labeling" has been issued to control the labeling of HVAC duct and other components. Quality control inspection will be performed on Q-listed, fire protection and radioactive waste component labeling.
This item is closed.
c.
(0 pen) Unresolved Item (88-01-Oll:
Diesel generator heater energization.
The inspector examined the portable heaters provided for the four generator units.
Two heaters were on and two had cycled off in response to a thermostatic control unit.
In response to PECo Finding Report 2N-591, Bechtel had previously stated that the firewatch personnel would verify the generator heaters were energized continuously.
The inspector was informed that the firewatch verification was terminated on April 15, 1988.
PECo has issued Finding Report 2N-616 and this item remains open.
d.
(Closed) Violation (88-01-02):
Need for controls to prevent damage to electrical cable while handling at low temperatures.
This issue was first identified in inspection 50-353/87-06 wherein it was determined that there were no procedural controls in place to preclude degradation of electrical cable due to handling at low temperatures.
In response to the unresolved item, Construction
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Procedures CP-F-2, "Receipt Inspection, Storage and Withdrawal of Materials and Equipment", and CP-E-2, "Permanent Plant Cable Installation and Termination", were revised to include requirements to assure that the temperature of the cable was above 10 degrees F prior to uncoiling, handling a.J pulling.
During inspection 50-353/88-01, personnel in the outside cable stoiage yard were observed uncoiling cable from reels, in order to pre-cut pull lengths, without regard for cable temperature. When questioned by the inspector, members of the cable cut crew stated that they were not aware of any temperature controls. At that time, the item was upgraded to a violation.
Immediate corrective actions included contacting the cabic manufacturer to obtain recommendations for handling cable at low temperature, revising CP-F-2 to remove temperature limits on cable handling based upon site meteorological data, and conducting training for electrical personnel to emphasize procedural requirements.
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Construction Procedure CP-G-2, "Reading Assignments ana Orientation and Training of Non-Manual Personnel", in Appendix 1,. requires each supervisor on the jobsite to monitor construction procedures, among other source documents, to identify training requirements, and to ensure compliance with those requirements. The PECo Quality-Assurance Audit Program has been modified by the addition of an audit of Personnel Training, to verify the effectiveness of training, and that appropriate training is being conducted when revisions to Construction Procedures are issued.
This ' item is closed, e.
(Closed)UnresolvedItem(88-05-Ol}:
Inaccuracies in FSAR figures.
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This iten was opened based on a discrepancy between an Emergency Service Water system logic diagram and the associated FSAR figure.
It appeared that there were not clearly defined requirements to update FSAR figures when the associated design drawings were revised.
The inspector reviewed Engineering Department Project Instruction (EDPI) 4.21.1, Rev. 3, "Preparation, Control and
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Revision of Safety Analysis Reports and Environmental Reports".
EDPI 4.21.1 was revised as part of the corrective actions for this item. The revised EDPI 4.21.1 requires that FSAR unique figures (ones that do not exist as separate design drawings outside the FS/.R) be revised by a Licensing Document Change Notice (LDCN)
prepared for each specific design change. All other FSAR figures are to be updated on a four or eight month cycle, depending upon the type of source document from which they are derived. A single LDCN will be generated to incorporate all of the revised figures for a specific FSAR revision.
It is noted in EDPI 4.21,1 that figure revisions to support changes to text may need to be made more frequently.
Figure 7.3-21, which was originally found inaccurate, was revised in FSAR revision 51, issued in February 1988.
4.0 Licensee Action on IE Bulletins and Circulars (92701, 92703)
i 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:
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a.
(Closed) Circular (81-03):
Inoperable Seismic Monitoring Instru-mentation.
The licensee evaluated the locations of accelerometers and accelerographs and found the locations were based upon Regulatory Guide 1.12 recommendations.
Unit 1 Technical Specification Section 4.3.7.2 defines the surveillance requirements for seismic monitoring instrumentation.
The inspector reviewed the surveillance test l
frequency computer report which documents the instrumentation test
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intervals.
The instrument failure trend data was analyzed by PECo
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and the test intervals were found adequate based on lack of repeti-tive instrument failures.
The surveillance test data and operating experience of the seismic instrumentation system was reviewed by y
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PECo engineering.
Engineering found that background vibrations have not posed a problem. One sensor had alarmed when impacted by plant personnel and a cage was put around the sensor to preclude future accidental impacts.
This item is closed.
b.
(Closed) Bulletin 88-01:
Defects in Westinghouse circuit breakers.
This bulletin was issued in February 1988, and identified a number of failures of Westinghouse Series DS circuit breakers.
Licensees were requested to perform inspections of welds on pole shafts and closing mechanism alignment.
PECo Nuclear Engineering Disision reviewed the design documents for Limerick Unit 2 and determined that Westinghouse Series D3.ircuit breakers are not used at Limerick Generating Station.
The negative response was forwarded to NRC within the required 60 days.
These breakers will be added to the ' Alert' list maintained by Quality Assurance to preclude their purchase at some future date.
This item is closed.
5.0 Preoperational Test Witnessing (70441, 71302)
The inspector witnessed portions of the following preoperational a.
tests:
2P4.1, 4 KV Safeguard Power System
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2P5.1, Safeguard 440 V Load Centers
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2P17.1, Instrument AC Power As appropriate, the inspector verified that the testing was performed in accordance with the approved procedure; that calibrated test equipment was utilized; that Shift Startup Enginece concurrence and Shift Superintendent approval were obtained to initiate the l
test; that a test briefing was performed for test personnel; and that initial breaker alignment was accomplished.
b.
The inspector was present at the D21 safeguard switchgear for test steps 6.4.1 through 6.5 of test 2P5.1. A PECo QA auditor was present in the control room for the testing.
The inspector was present at the D23 safeguard switchgear for test steps 8.4.3.1 to 8.4.3.11.
A PECo QA auditor was also present.
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The inspector witnessed portions of test 2P4.1 which were performed to demonstrate the capability of the Safeguard Bus Feeder Breakers to transfer load from the initial source cf offsite power to the alternate source of offsite power when voltage on the initial source
falls below a preset level.
During the test, the inspector noted that two identical digital voltmeters had different calibration recall frequencies.
Licensee personnel were unable to explain the apparent discrepancy at that time, but later determined that this is permissible under the PECo portable test equipment calibration program.
Items of measuring and test equipment found to be within
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tolerance during recalibration may have their recall period extended each time, up to a maximum of four times the base recall interval.
During conduct of the test it was determined that relay 162-11509 was not energizing as expected, and required by the procedure. A review of the termination drawings revealed a note specifying that the wires for energizing the coil of this relay were not to be terminated until Unit 2 is ready for operation.
This action was required during the Unit 1 operation-Unit 2 construction period in order to prevent starting Unit 2 diesel generators before they were fully tested and operable. A test exception was properly documented
&nd the test was continued.
The inspector had no further questions.
d.
The inspector witnessed portions of test 2P17.1 which were conducted to demonstrate the ability to supply design power to eight Class 1E and 10 non-class 1E instrument distribution panels, and to demon-strate load shedding, on a LOCA signal, of the two non-class 1E instrument panels fed from Class 1E power supplies.
Several of the Class 1E instrument distribution panels were found to have damaged circuit breakers by the QC organization while performing their installation inspections.
These breakers are functional but will be replaced with new ones when they are received from the manufacturer.
Since these circuit breakers are on the incoming feeds at the panels, it was determined that their replacement would not affect those portions of the test which verify the separation of the power supply feeds, and the load shedding for non-class 1E panels feu from class 1E Motor Control Centers (MCC)s.
The procedure steps for verifying the separate and independent feeds to the instrument j
distribution panels were successfully completed. When attempting to j
verify load shedding (in section 6.4.16) contactor 42-22322 closed when it should have remained open (step 4).
At this point the test was terminated and the syste n lineup returned to normal. A Startup Non-conformance Report (NCR), 217A-187/S-2-E, was written to document this condition.
Discussions with the Test Director and PECo Quality Assurance personnel indicated that this function had been success-fully demonstrated several times during component (blue tag) testing.
A Startup Work Order (SWO) was written to troubleshoot the circuit and determine the cause of the failure.
During troubleshooting, it was determined that relay labels had been misapplied in the 4KV switchgear cubicle, so that when the lead was lifted to simulate a
loss of coolant accident signal, it was lifted on the wrong relay, and the signal was not generated.
The relay labeling was corrected, the SWO and NCR were closed, and the test procedure steps were i
successfully completed.
Quality Assurance personnel have notified the inspector that a design change is under consideration for the control circuits for the non-class 1E instrument AC panels powered from Class 1E sources.
The design change involves replacing the existing AC control circuit for the Motor Control Center cubicle with a DC control circuit.
If and when this design change is implemented, the preoperational test will be reviewed by the licensee for any
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required changes and retest requirements.
No violations were identified 6.0 Technical Test Program Implementation (52051, 52053, 52055)
The inspector accompanied PECo instrument technicians during Blue Tag test and calibration activities on the following item:
valve HV-11-224 stroke test
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standby diesel day tank temperature switches TISH-20-221A and
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TISH-20-221C standby diesel day tank level switch LSHL-20-221C
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The inspector verified use of current test procedures, methodology of QC verification for safety related component restoration, correction of lifted vendor wires identified on equipment problem report 2-23B-1, proper water bath calibration of the temperature switch setpoint, and use of a water column for the calibration of the level switch.
The inspector noted that the presence of Bechtel boundary tags on valve HV-11-224 and the air supply valve precluded the performance of the valve stroke test.
No violations were identified.
7.0 Preoperational Test Procedure Review (70354)
2P-78.1 Startup range neutron monitoring system (70354).
The inspector reviewed the procedure for conformance with the requirements of the startup administrative manual and for technical content. The inspector questioned the mixing of intermediate range monitor (IRM) channels fed by different Reactor Protection Systems (RPS) channels in the range switch rod block logic.
It was determined that this is in accordance with the GE design, and has no effect on the separation of the trip unit feeds to the RPS logic.
The inspector also questioned reading the 0-40 scale on the IRMs with the mode switch in the 125 (calibrate) position.
It was explained that the two calibrate positions, 40 and 126 were intended to give readings of 40 on the 0-125 and 0-40 scales respectively. The differ < ace between the two positions being amplif' cation which should exactly campensate for the attenuation difference between the two ranges.
The inspector also noted numerous typographical errors, which should not affect the outcome or performability of the test. During the review of procedure references, it was noted that the FSAR text, on page 7.2-4, referred to the wrong table for the IRM trips. This was identified to PECo Quality Assurance personnel who initiated a LDCN to correct the FSAR.
Thsre were no
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further questions.
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8.0 System Walkdowns (37301)
a.
The inspector examined portions of the Emergency Service Water System depicted on Piping and Instrument Diagram (P&ID) M-11 Sheet 4.
Valves HV224, HV228, HV227, HV76, HV46, HV221, HV223 and 2010 were examined.
The intermediate piping runs were examined.
The location of Unit 1 to Unit 2 tie-ins was noted, valve 2006 was found properly locked closed, and the air operators on valves HV46 and HV76 were properly rcmoved.
The piping configuration was according to the P&lD.
b.
The inspector accompanied licensee personnel during a system walkdown on the Turbine Lube Oil System.
The Electrohydraulic Control (EHC) power unit, lube oil reservoir, and lube oil centrifuge were examined, c.
The inspector accompanied licensee personnel during a system walkdown on Standby Diesel Generator A.
The walkdown team was composed of PECo Startup, PECo Field Engineering, PECo Construction, Bechtel System Completion, Bechtel Engineering, Bechtel QC and Bechtel QA.
The walkdown covered the diesel and associated auxiliary systems.
The inspector noted temporary construction coveiing on the diesel air inlet / exhaust expansion bellows and a broken air compressor pressure gage window.
The items were added to the system punchlist for correction prior to system turnover to the licensee.
d.
The inspector examined piping, valves and instruments depicted on P&ID M-55 Sheet 2 for the High Pressure Coolant Injection system.
In particular the following flow paths were examined:
pump dischargs to the core spray and feedwater lines; pump suction from condensate storage tank between line 34-HCB-205 and the pump; pump suction from the suppression pool; and pump discharge test return lines to the suppression pool.
The installed equipment configuration was found consistent with the P&lD.
l The inspector accompanied licensee personnel during a system e.
walkdown on the Primary Containment Instrument Gas system depicted on P&ID M-59 Sheet 3 and 4.
The walkdown team was composed of startup, engineering and quality control / assurance personnel.
Several containment isolation valves and the safety related pipe associated with the seismic air bottle storage for the automatic depressurization system relief valves were examined.
The QC inspectors performed a very thorough examination of the system components.
f.
The inspector examined portions of the Core Spray system depicted on P&ID M-52, sheets 3 and 4.
Large bore piping and valves were verified to be as shown on the P&ID.
It was noted that some instruments and relief valves were removed for talibration and system flushing.
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The inspector examined portions of the Residual Heat Removal System shown on P&ID M-51, sheets 5, 6, 7 and 8.
Configuration of large bore piping and valves was verified to be as depicted on the drawings.
It was noted that system relief valves were removed, with temporary flushing connections installed in their place, and that the temporary strainers and associated spoolpieces at the pump suctions were removed with blank flanges installed on the piping.
h.
The inspector accompanied licensee personnel during a system walkdown of the safeguard piping fill system shown on P&ID M52, sheet 4.
The walkdown team was composed of personnel from the PECo Startup, PECo Field Engineering, PECo Construction, Bechtel System Completion, Bechtel Quality Control and Bechtel Quality Assurance organizations.
Proper system configuration and equipment installation were verified, i.
The inspector accompanied licensee personnel during a system walkdown of the Recirculation System Motor-Generator Set Lubricating Oil System, shown on P&lD, M-19, sheet 6.
The walkdown team was composed of representatives of the PECo Startup, PECo Field Engineering, PECo Construction, Bechtel System Completion, Bechtel Quality Control, Bechtel Quality Assurance and PECo Quality Assurance organizations.
It was stated by startup group personnel that testing of the lube oil system would need to be completed prior to commencing testing of the motors, scheduled for late June.
Several current problems and the actions for resolution were discussed, including relief valve code requirements, DC motor brush retaining springs, and control cabinet wiring.
Field engineering personnel also noted that the size of overload heaters for the DC motors were not specified on the design drawings, that two different drawings showed conflicting capacities for the same fuse, and that they were investigating the discrepancies.
No violations were identified.
9.0 Bechtel Quality Assurance (35060)
a.
The inspector reviewed the following Bechtel Management Corrective Action Requests (MCARs):
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(1-39) Mechanical screw type fuse clip termination lugs supplied by B. K. Electric on DC Distribution panels do not make a tight connection with field wires.
All 12 affected panels were examined and the loose connections were identified.
The mechanical screw type lugs will be replaced with compression type lugs.
This item has been reported to the NRC as a potential 10 CFR 50.55(e) item.
(140) Drywsil sump flow detection system not properly
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configured to monitor leakage rate.
LER 88-05 was issued for Unit 1 a'id TCA 1276 was initiated to restore the system to an operable configuration. The problem was related to the opening of the sump drain valves which would drain the tank to a low
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level and reinitiate a new measurement period for the leakage flow rate.
The leakage, as recorded by this system, could have exceeded Technical Specification limits unknowingly.
This problem was identified during a review of the Unit 2 preoperational test procedure, b.
The following Quality Action Requests (QARs) were reviewed:
(F-613) Attachment of Q items to non-Q supports.
The
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pre-engineered items were identified and documented on nonconformance reports. All situations were found
"accept-as-is" by Bechtel engineering.
The installation criteria were revised to restrict future attachments of this type.
Training was performed for Bechtel personnel on the revised attachment criteria.
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(F-604) Lack of T-drain for Limitorque motor operated valves.
Walkdowns were performed by Bechtel which identified the scope of the problem. A supplemental Limitorque qualification report to Bechtel demonstrated the acceptability of the operators outside primary containment.
Nonconformance Reports have been issued for operators inside primary containment and this issue remains under investigation by Bechtel.
The following audits and associated checklists, findings and data c.
collection sheets were reviewed by the inspector:
Audit Area Audited PFA 896 Fire protection sprinkler subcontractor PFA 903 Design interface control PFA 892 Radiography PFA 899 Electrical Equipment PFA 898 Design Calculations PFA 896 Schneider power - HVAC i
The inspector noted that hardware and software were reviewed, a Level
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III technical person supplemented the auditor for the radiograph audit, and corrective actions taken to resolve the noted audit findings appeared appropriate.
d.
The inspector attended the exit for Bechtel management audit numbers 88-06, 07 and 08.
The audit team was comprised of off project auditors.
The audit scope included construction, turnover, quality control, design and preventive maintenance activities.
The audit covered Limerick Units 1 and 2 as well as Bechtel work for Peach
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Bottom generating station.
Five draft quality assurance findings were issued that dealt with procedural and software concerns.
No violations were identified.
10.0 Reactor Pressure Vessel Hydrostatic Test Results (70562)
a.
The inspector reviewed the Bechtel QC inspection report (2M-RPV-01-62-1) and the test procedure (2FM-19) for the Reactor
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Pressure Vessel (RPV) hydrostatic test.
The QC report addresses:
test pressure and test hold times; the conduct of the leakage walkdown; system restoration; accuracy of test gages; system drainage; and included walkdown team signoffs for various activities.
Several nonconformance reports were issued as a result of problems that occurred during the test.
The following aspects of the test procedure were reviewed:
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demineralized water analysis report proper signoffs for test procedure steps (by QC, ANI,
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ANII, Test Director, General Electric-Bechtel Engineering as appropriate)
test pre-requisite signoffs
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intermediate system pressurization signoffs for walkdowns and system venting test pressure hold documentation (1610 + 31 - 0 psig)
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inspection pressure hold documentation (1353 + 25 - O psig)
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system depressurization
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RPV surface temperature control test pressure gage and temperature reading data sheets
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post test pressure gage calibration sheets pressure test release documentation
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pre-test briefing documentation
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pressure test record (2M-RPV-01)
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valve line up check list
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drawing and inspection list pressure test work data sheet
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leak collection data sheets walkdown team data sheets
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signature identification list test instrument calibration signoff sheet
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Section III and XI Inspection Record Sheet
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test change log
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The inspector had no concerns regarding the test records for the RPV
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hydrostatic test conduct.
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11.0 Diesei Generator Refurbishment Activities (51053, 51055)
a.
The following correspondence was reviewed by the inspector:
Colt /Fairbanks Morse letter dated February 16, 1988
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PECo construction division letter CFOM 2-7322
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PECo Nuclear Engineering letter dated March 28, 1988
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Based upon the extensive storage period of the four standb/ diesel generator units, Colt recommended several actions be taker, prior to engine startup.
The recommended actions include:
replace main and connecting rod bearings
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flush and hydrostatic test jacket water system
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remove and test all fuel injection nozzles
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check engine alignment
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Bechtel construction was directed to implement most of these and startup assumed responsibility for the others.
The bearing replacement was necessitated by the analysis of multiple bearing failures at another nuclear facility which in part was attributed to a galvanic reaction between the aluminum bearings and the iron crankshaft when an insufficient oil film thickness was present.
The need to replace the generator end bearing was evaluated by PECo and the generator manufacturer, and both concurred that it was not
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necessary.
Vibration testing is planned during diesel testing which would detect potential bearing problems.
PECo engineering recommended that Colt Service Letter SIL-A-9 be implemented for examination of the vertical drive thrust bearings, however the bearing material was subsequently determined by r lt to not require o
inspection.
b.
The inspector observed various phases of the bearing replacement activities.
The presence of Bechtel QC, Colt vendor representatives and PECo QA personnel were noted.
The associated Modification / Rework Package (MRP) 2AG501-16 was reviewed.
Extracts from the Colt vennor manual and full time overview by the Colt representatives provided technical direction for the bearing replacement. The QC Inspection Report QCIR-2AG501-48-8 was reviewed.
During an inspection performed by a Region I specialist, it was noted that lapping compound had contaminated the replacement bearing components.
The presence of the lapping compound was also suspected to have contributed to previous engine bearing failures at cther facilities.
This issue involving failure to have proper work instructions to prevent the intrusion of the lapping compound into the bearings will be addressed in NRC inspection report 50-353/8E. 12.
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The licensee determined which bearings had been contaminated. Those bearings were removed and cleaned.
During subsequent activities, the inspector noted that difficulty was encountered while attempting to assemble a lower connecting rod bearing (#9) on the 'B' engine.
It was determined that one of the bearing halves had been reversed during assembly, and the alignment pins were preventing the bearing from aligning properly.
The Colt representative examined the two halves and determined that the slight indentations in the edges did not cause any metal to be displaced at the bearing surface and that they could be used as-is.
The inspector had no additional concerns.
12.0 In-Process Welding (55150)
a.
The following documents were reviewed by the inspector:
Bechtel QC Instruction W-1.60, "In process Weld Inspection"
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The instruction provides guidance for in process weld inspection of Q-listed welding activities.
The inspector discussed the implementation of the instruction with QC personnel.
Bechtel QC performs a sampling review to assure that the in process weld activities are in accordance with th2 applicable requirements, b.
The inspector accompanied Bechtel QC personnel during the in process weld inspection.
The Q-listed filler metal withdrawal forms were obtained from the rod issue station. Welding was reviewed at the following areas:
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Weld Request Item
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45424 Reactor building door drawing C-133 34980 Hanger GBC-201-H27 32752 Pipe restraint PR-1000 57275 Pipe hanger SP-DCB-WO6-47-H1 The following attributes were checked as applicable:
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welder qualified for the weld procedure specification and base metal thickness range
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correct filler material used, properly marked and handled base metal surfaces properly prepared
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proper joint fitup
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proper joint pre-heat application
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proper weld machine polarity, voltage, and current range
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observed amperage check with clamp on meter The QC inspection report WIP-82-0889 was reviewed.
No concerns were identified by the inspecto.
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13.0 Bechtel Engineering (37055)
l a.
The inspector interviewed Bechtel engineering regarding the actions taken as part of the Systematic Assessment of Licensee Performance (SALP) action plan.
The action plan addresses design interface control as well as FSAR accuracy.
Numeroes actions have been initiated which include: designation of discipline licensing coordinators; expeditious processing of Licensing Document Change Notice backlog; defined FSAR drawing update policy; review of FSAR code compliance; development of integrated commitment tracking system; performance of off project design change interface reviews; meetings between General Electric and Bechtel engineering to develop new design interface control document; and vendor survey on adequacy of Bechtel issued design documentation. As discussed below, the inspector reviewed certain elements of the engineering action plan in greater details, b.
The following documents were reviewed by the inspector that relate to the Becatel engineering SALP improvement items:
Document Review Item Covered BLP-43627 Of f project interdisciplinary review of four Project Change Notices.
These were found very thorough with recommendations to enhance the project activities.
BWPC IOM 227587 Solicited engineering document end user survey and BLP-43622 information from PECo, San Francisco groups and field groups.
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Meeting Minutes Bi-monthly problem identification and resolution feedback meetings which address audit findings and administrative processing problems.
BLG-5700 Generation of GENE /Bechtel design interface document.
EDPI 4.21.1 Clarified update cycle for FSAR figures.
FSAR impact blocks added to change authorization documents.
Draft Program for discipline licensing coordinators.
EDPI 4.21.2 BWPC 10M-227929 Disseminated draft ECPI 4.25.3 to control the impact of change authorizing documents on FSAR, plant differences and other licensing reports.
BLP-43470, Summary of code compliance review of FSAR table BLP-43010, 3.2-1 and associated design or purchase BLP-42014 specifications.
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Chief Engineer proposed schedule for conduct of Review Schedule interdisciplinary reviews of project change notices, selected specifications, as built reconciliation packages and GE technical interface.
The inspector noted very thorough chief engineer design reviews were performed that addressed design interface areas.
The inspector will continue to review the Bechtel improvement program activities as further elements of the program are implemented.
c.
The inspector met with Resident Engineering personnel and discussed the Unit 2 equipment qualification program.
The Unit 1 Equipment Qualification packages will be extended to address Unit 2 installations. An Equipment Qualification walkdown of General Electric and Bechtel scope of supply components will be performed at a later date by project engineering personnel.
The inspector was informed that no Unit 2 specific qualification testing has been performed.
The inspector had no questions at this time.
No violations were identified.
14.0 Instrumentation (52053, 52055)
The inspector reviewed the following documents associated with instrument rack 20C026:
Work Package QCIR Work Activity JMR-42-07-34Q-A FJ-42-07-340-58-1 Set instrument rack JFR-00-07-01Q-A FJ-42-07-34Q-58-4 Test tee installation JFR-42-07-34Q-0 FJ-42-07-34Q-58-3 Remove pressure transmitter JFR-42-07-34Q-A FJ-42-07-340-58-2 Rearrange tubing / transmitter location within rack The associated General Electric drawings and Field Deviation Disposition i
Requests were reviewed.
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location, anchor details, f rame configuration, welding size and quality, tubing configuration, instrument location and labeling, instrument mounting hardware, instrument protection from construction activities, instrument type, and valve identification.
Contrary to General Electric rack drawing 13309020 (Bechtel file M-1-H23-P001-C-3.1) the inspector observed several fillet welds less than the specified 1/4 inch size and double sided square groove welds are welded on one side only to the gusset plates welded to the frame angle iron.
PECo QA issued Finding Report 2N-613 and General Electric has initiated an examination of all Unit 2 instrument racks. The failure of the General Electric (GE) supplied instrument racks to conform with the
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GE design drawing 13309020 is a
';n of 10 CFR 50, Appendix B,
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Criterion X (88-10-01).
15.0 Electrical Cable and Components (51063, 51053, 51055)
a.
The inspector monitored activities associated with the
'B' Diesel Generator power cable replacement.
The cable was being replaced because it failed insulation resistance testing.
The inspector verified that the line tension gages in use were within calibration.
During the course of the cable installation, a decision was made to bypass one pull point since the next portion was a vertical drop.
Activities were suspended while engineering personnel performed calculations to determine whether the pull could be made in that configuration without exceeding the maximum allowable tension on the cable. After determining that the pull was feasible, installation activities were resumed. After initial attempts at near maximum tensions resulted in little covement of the cable, the licensee decided to pull from an intermediate location, simultaneously, to relieve tension in a series of sharp bends.
This resulted in working tensions less than ane-half of the allowable tensions.
During subsequent installation activities, it was determined that i
the cable jacket had sustained some minor damage (several cuts and gouges in the Jacket of two of the conductors).
The damaged areas were taped-over to protect them and pulled through to a junction box in the diesel generator room where they would be more readily accessible for inspection and repair.
The condition was documented on NCR 13366, and dispositioned to repair in accordance with Okonite (cable vendor) instructions.
The inspector monitored the repair activities to verify that work was conducted in accordance with Okonite drawing 0-5731 as prescribed. The inspector also monitored the cable termination activities and verified the use of correct crimping dies for the lugs and the number of crimps.
The repaired conductors were identified as being phases A and B.
The inspector had no further questions, b.
PECo reported to the NRC, under the provisions of 10 CFR 50.55 (e)
the failure of conical spring washers used in Cutler-Hartner Motor Control Centers.
This was first reported to NRC by telephone on April 15, 1988, with a followup report by letter dated May 13, 1988.
Metallurgical analysis of failed washers showed that the failure was due to hydrogen embrittlement of the high carbon spring steel used to make the washers. All the failed washers were found in non-Class IE MCCs.
Class-1E MCCs were inspected with no abnormalities identified. Metallurgical tests were performed on the spring f
washers supplied by Cutler-Hammer for replacement purposes.
These were found to be suitable for use, and not to exhibit hydrogen j
related embrittlement.
PECo is evaluating the magnitude of the problem, and this item will be reviewed later as a followup to Construction Deficiency Report 88-00-04.
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16.0 Meetings with Licensee
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On May 13, 1988, the inspector attended a meeting held at the licensee's request which involved both Region I and Office of Nuclear Reactor Regulation (NRR) personnel.
The PEco Readiness Verification Program
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(RVP) was discussed. The RVP scope includes both an Operational Readiness Verification and a Design and Construction Verification. The selection of a contractor to perform the verification efforts, the focus of the design review and matters of protocol were discussed. A followup meeting was held on May 24, 1988 to further discuss the Design Verification activities.
The inspector attended a meeting with senior personnel of the recently reorganized Quality Assurance organization, wherein they briefed regional management on the changes. Changes in personnel and reporting chains within the organization, and the response by senior corporate management were discussed The NRC resident inspector discussed the issues and findings in this report with members of the licensee's staff on a weekly basis, and at an exit meeting held on May 20, 1988.
Based on discussions held with licensee representatives on May 20, 1988, it was determined that this report does not contain information subject to 10 CFR 2.790 restrictions.
17.0 Assurance of Quality Work relating to the replacement of the 'B' diesel generator a.
power cable (described in section 15a) demonstrated significant pre planning and coordination. All personnel involved were knowledgeable of the work scope, procedures, precautions, and quality criteria.
Changes to the installation method were not implemented until engineering evaluation was complete and had determined them to be acceptable. When minor damage was identified, work was stopped and measures taken to prevent further damage.
Those damaged sections were then pulled through to an area of better accessibility for inspection and repair activities. All facets of the work were carefully supervised and personnel from the quality
organizations closely monitored all activities.
Safety personnel were on-hand during repair activities with Material Safety Data Sheets for the cement used.
They also had appropriate equipment for monitoring for hazardous conditions caused by the solvents used, and provided respiratory protection for personnel involved in the work, i
b.
The Test Review Board showed good initiative in requesting a review of its activities by Quality Assurance, and by initiating changes in response to the concerns identified.
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