IR 05000353/1989200
| ML20247B870 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/12/1989 |
| From: | Haughney C, Imbro E, Stein S Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20247B869 | List: |
| References | |
| 50-353-89-200, NUDOCS 8905240266 | |
| Download: ML20247B870 (22) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Division of Reactor Inspection and Safeguards Report No.: 50-353/89-200 Docket No.: 50-353 Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility:
Limerick Generating Station, Unit 2 Inspection at: Limerick Generating Station, Unit 2 Inspection Conducted: March 27-31, 1989 Inspection Team Members:
- IDCA Coordinator:
E. V. Imbro, Section Chief, RSIB, NRR ICA Team Leader:
S. R. Stein, Senior Operations Engineer, RSIB, NRR ICA Assistant Team Leader:
R. A. Gramm, Senior Operations Engineer, RSIB, NRR ICA Mechanical:
R. Compton, Consultant ICA Electrical:
D. Ford, Consultant ICA Civil / Structural:
A. Unsal, Consultant ICA Nondestructive Examination:
J. J. McArdle, Consultant
- Attended inspection on March 30-31, 1989.
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5teven h. Stein, ICA Team Leader Date Signed
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Reviewed By:
A4 J 3._. * I-I T[N InteSigned
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o(Iugene V. Imbr'o, Chief Team Inspection Development Section B N
Approved By:
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C1ief [
Dat'e Signed Charles J. Haugh g,Branchv WR Special Inspections kbbbkb
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SUMMARY The team reviewed the final SWEC ICA report, including the construction (
observation reports (CORs), Bechtel and PECO's responses to the CORs, SWEC's j
acceptance of those responses, the construction action item (CAI) reports, and the licensee's responses to the CAls.
In addition, the team reviewed the CAls to determine whether SWEC escalated them to CORs when appropriate and in accordance with the overall IDCA program. The team selected a representative sample comprising 19 CORs and 8 CAls and, while on site, evaluated Bechtel's responses and corrective actions in detail.
In addition, the team reviewed the licensee's responses and corrective actions for 29 deficiencies and concerns that were identified during the NRC inspection conducted in August and September 1988 and documented in IR 50-353/88-202.
The NRC team determined, through its review of the CAls and CORs, that SWEC adhered to the IDCA program requirements for reporting ICA findines and escalating them to observation reports where warranted. The team also deter-mined through its detailed evaluation of responses to and corrective actions for the sample of CORs that, with two exceptions, the responses accepted by SWEC were appropriate. The first exception noted by the team was the response to COR-007. COR-007 reported radiographic indications for three low pressure coolant injection (LPCI) welds with no documented evaluation of the accept-ability of the indications. Bechtel's response addressed only the one weld with the potentially unacceptable indication and did not address evaluation of the other twc welds. However, the team found that the corrective actions taken by Bechtel and General Electric Company were appropriate for all three welos and evaluation of all the welds was documented in the response to
CAI-022.
l The second exception was the response to COR-34 regarding grouted-in anchors i
for pipe supports that did not meet the requirements for minimum embedment length. Bechtel's response only addressed large-bore pipe supports and did l
not explicitly address the conservatism and safety factors used as the bases
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for excluding other applications of grouted-in anchors such as those for platform steel and equipment anc.horage. The licensee has subsequently submit-ted additional infomation that is currently being reviewed by the NRR techni-cal staff.
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The team found that Bechtel's corrective actions were, in most cases, detailed,
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comprehensive, timely, and technically sound. The team was especially impressed l
with the fact that additional inspections and evaluations were almost always
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perfonned to ensure that even single discrepancies were, in fact, isolated cases or limited in scope. With a few. exceptions, the licensee's responses and cor-rective actions for the NRC-identified discrepancies and concerns also were adequate and properly implemented. One exception was the NRC concern with regard to the wire size and qualification of the motor leads for the operator on valve HV-52-2F1000. The licensee responded adequately to the concern about qualification, but did not address the concern about the wire size.
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Although the corrective actions were adequate, the team found that some
Bechtel responses to SWEC items and some PECO responses to NRC-identified concerns lacked complete descriptions of underlying causes or significance of the discrepancies. Several responses tended to ascribe the root cause of events to inadequate documents when the ultimate responsibility for the work rested with personnel. An example of this was the determination that the installation of an incorrect heating, ventilation, and air conditioning (hVAC)
hanger gusset plate was due to an engineering mistake when, in fact, the installers and inspectors had accepted an installation that clearly was not in accordance with the issued and referenced design requirements.
In another case the licensee attributed the failure to install drawing-required jam nuts on foundation bolts to unclear drawings rather than to the lack of attention to detail by installers and inspectors.
In several cases, the licensee attributed the cause to unauthorized alterations after initial installation and inspection, when it was equally likely that the original installation was improper. An example of this type of issue was the loose bolts on HVAC duct segments.
The team also found that SWEC did not fully document the basis for their acceptance of the responses the team found incomplete.
In one case (COR-007), additional infomation was found in Bechtel's response to an action item, which was not part of the SWEC ICA report, and in several other cases SWEC obtained the required information through telephone conversations. Since PEC0's IDCA program did not provide for revisions to SWEC's reports after they were issued, the licensee committed to provide any revisions or clarifications of C0R responses in its response to this inspection report.
As a result of discussions between the licensee and the team during this inspection, the licensee provided additional information innediately following the inspection regarding the original responses. This additional information and clarification of some responses indicated a better under-standing by the licensee of the team's concerns. These modified or amplified responses will be documented in PEC0's response to this report.
4.
INSPECTION DETAILS The following sections detail the results of the team's reviews end evaluations. Although the overall conclusion was that the ICA effort was adequately performed and the licensee's corrective 6ctions were appropriate and effective, full resolution of several issues requires additional infoma-tion or action by the licensee or the NRC. These issues also are identified in the following sections.
4.1 Welding and Nondestructive Examination (NDE)
With re5ard to welding and NDE, the NRC team reviewed the following SWEC CORs and CAls and NRC issues discussed in IR 50-353/88-202:
COR-003, magnetic particle examination of dissimilar metal welds; o
o 00R-007, evaluation of radiographic indications; CCR-008, chemical staining of radiographic film; o-3-
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o COR-035, density requirements for radiographic film; o
COR-052, incomplete NDE report; o
CAI-078, liquid penetrant examination of temporary attachment removal points; o
CAI-079, welding performed after final NDE; o
NRC issue, low pressure coolant injection (LPCI) nozzle-to-safe end weld radiographs; and o
NRC issue, residual heat removal (RHR) heat exchanger radiographs.
Of these, the team determined, through its review of the licensee's responses and additional data provided by site personnel, that the licensee properly resolved CAI-078, CAI-079, COR-003, COR-008, COR-035, COR-052, and the NRC issues concerning LPCI nozzle-to-safe end weld radiographs and RHR heat exchanger radiographs. The team reviewed the CAls for appropriate upgrading to observation reports and found that the licensee's treatment of CAI-078 and CAI-079 was appropriate.
The NRC team determined that SWEC's implementation of the IDCA program in the
' welding and NDE disciplines was very thorough and addressed all major areas of construction welding and nondestructive examination. The team also found that, with the exception noted in 4.1.1, below, the licensee's responses to SWEC observations and NRC issues were adequate, and that the licensee's implementation of corrective action for SWEC findings and NRC issues was timely and technically sound.
4.1.1 LPCI Nozzle-to-Safe End Welds (COR-007)
During their construction assessment, SWEC identified radiographs from three welds (LPCI-N178-45 LPCI-N17B-225, LPCI-N17B-315) that contained l
discontinuities which were not documented nr evaluated on the radiographic
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I report form. SWEC also identified one discontinuity as a root concavity in weld N17B-225 and found that it did not meet-the requirements of ASME Section III, NB4424, 1974 Edition.
Bechtel responded to the root concavity in weld N17B-225, but did not reference welds N17B-45 or N17B-315 in the response to the COR.
Further investigation
by the NRC team showed that all discontinuities were evaluated and documented for the licensee, and the results of that evaluation were documented in the response to CAI-022. Although Bechtel and the General Electric Company took
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adequate corrective action and no further action is required, Bechtel's failure to address two of the welds in the response to SWEC's COR-007 is an example of an incomplete response.
4.2 Mechanical Components and Heating, Ventilation, and Air Conditioning (HVAC) System The team evaluated the licensee's written responses and actions taken for 14 discrepancies and concerns related to mechanical equipment and HVAC systems that were identified in IR 50-353/88-202. The team also reviewed the SWEC ICA
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report and Bechtel's evaluation and final disposition of the following six-4-l
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CAls and five CORs related to mechanical equipment and HVAC systems that had been identified by SWEC during the ICA:
o CAI-001, RHR pump hold-down stud material; o
CAI-018, duct stiffener weld; o
CAI-019, RHR heat exchanger lower support foot-to-nut clearance; o
CAI-045, HVAC hanger not in accordance with drawing and undersize weld; o
CAI-046, RHR heat exchanger support steel edge distance; o
CAI-056, clearance between HVAC commodities; o
COR-004, RHR pump hold-down stud material (CAI-001);
o COR-014,improperinstallationofHVACductgasket(CAI-055);
o COR-016, improper bolting torque (CAI-072);
o COR-018, fire damper improperly identified on drawing (CAI-058); and o
COR-019, incorrect HVAC hanger material size (CAI-048).
As a result of the team's review of the CAls and CORs listed above, the team selected CORs 016, 018, and 019 and a number of related NRC-identified concerns for more in-depth evaluation at the site. The team determined, through its review of the licensee's responses and additional infomation provided by site personnel, that the following SWEC CORs and NRC-identified issues were adequately and properly resolved:
o NRC issue RHR pump plastic seal drain plugs; NRC issue, missing jam nuts on standby liquid control pump foundation o
bolting; o
NRC issue, missing jam nuts on fuel pool service water booster pump foundation bolting; NRC issue, missing washers on RHR heat exchanger support column bolting; o
NRC issue, missing washers and jam nuts, and enlarged holes on fuel pool o
cooling water heat exchanger foundation bolting; o
NRC issue, HVAC damper installed but not shown on drawing; o
NRC issue, HVAC duct instrument tap hole plugs loose; NRC issue, additional undocumented loads on RHR heat exchanger i
o foundations; and o
COR-018, fire damper improperly shown on drawing.
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The team found, however, that the responses for the remaining items either were to restrictive or inconylete, or needed further clarification. These items are discussed in the following sections. However, although the team felt that the PECO written responses for the items discussed below were inadequate, the team felt that the corrective actions taken by the licensee were adequate to resolve the SWEC or NRC concern.
4.2.1 Reactor Building Unit Cooler Foundation Bolting (NRC Issue)
This item concerned missing washers and one loose vibration pad mounting bolt on Unit Coeler 2FV211. The licensee concurred with this finding and inspected all 20 unit coolers. After identifying several additional discrepancies, the licensee corrected the discrepant installations and trained QC and construc-tion engineering personnel on the need for reviewing drawings and manuals in detail. The team considered these actions to be adequate to resolve the identified deficiencies.
However, the team found that the licensee's technical evaluation of the significance of th loose mounting bolts was not complete in that the response stated only that the existing thread engagement was adequate to transfer design tensile loads to the bolts. This evaluation did not address the potential for and ramifications of total disengagement of the loose fasteners
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from the vibrating unit.
Such disengagement would render the fasteners unavailable to accept a load. Although this is an example of an incomplete response, no additional action is required by the licensee due to the minor nature of the discrepancies and the adequacy of the licerc e's corrective actions.
4.2.2 Unit Cooler Loose Brace Bolting (NRC Issue)
This item concerned three loose fasteners connecting the f an suction bell and Unit Cooler 2FV210. The licensee concurred with this finding and reinspected all safety related unit coolers, identifying one additional unit with similar discrepancies. The licensee corrected the discrepant conditions and issued a field change request (FCR) to specify tightening requirements for these fastene'rs. The team considered these corrective ections adequate, and no further action is required of the licensee.
However, the licensee's response stated that the cause of this discrepancy l
was determined to be a lack of tightening criteria in vendor manuals and drawings and that the original installation was suitably snug. The NRC team found that this statement could not be supported and that the possibility existed that the fasteners were not tightened or were improperly tightened during initial installation. The licensee did note in the response that action to prevent recurrence included the retraining of personnel and issuance of a currective action report against the QC inspector who had performed the original acceptance inspection of these coolers. However, the licensee's failure to acknowledge specifically that the cause of this discrepancy could have been personnel error is an example of an incomplete statement of root cause.
4.2.3 Loose Bolts on HVAC Duct Segments (NRC Issue)
l This item concerned two loose bolts joining HVAC duct segments. The licensee concurred with the finding, tightened the bolts, and inspected 92 additional-6-
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joints. The team considered the corrective actions adequate, and no addi-tional action is required of the licensee.
j However, the licensee attributed the cause of the loose bolts to unauthorized alteration of the installation after final QC inspection. This statement of cause was too restrictive in that the licensee did not acknowledge that incdequate installation and inspection was an equally possible cause.
4.2.4 Improper Torque on RHR Pump Discharge Head Bolts (COR-016)
SWEC found residual torques on the RHR pump discharge head bolts that were less than the vendor specified minimum installation torque. The licensee retorqued these fasteners on all RHR pumps and on the core spray pumps, which are of the same design. Bechtel identified torque values that were below and above the specified values. The licensee established a periodic program to torque the affected bolts and monitor the torque values obtained to better assess this phenomenon.
The NRC team noted that the Bechtel response identified the probable cause of the low torque values identified by SWEC as gasket cre.ep with other contribut-ing factors that would cause the loosening of bolts. However, the Bechtel response to the C0R failed to address the fact that some residual torque values obtained during the follow-up inspections exceeded the installation torque, although the information was available in the documents accompanying the COR response. The excessive torque values would not be consistent with gasket creep or the contributing factors noted as possible causes of the cut-of-tolerance torque values. This is an example of an incomplete statement of root cause.
The NRC team reviewed the mechanical modification / rework packages (MRPs)
written to monitor and retorque the applicable bolts on the core spray pumps and the RHR pumps in accordance with requirements provided by General Electric Company (GE). The team found the MRP issued to monitor the residual torques I
on the RHR pump fasteners included, in addition to the GE requirements, a thorough and properly sequenced description of the work to be performed, and provided data sheets for recording inspection and test results.
However, Revision 1 of the MRP for the core spray pumps did not provide data sheets for recording of residual torque test results and, in the work scope section, did not require the rescribing of fastener positions after torquing and specified the step for torquin~g before the step for verification of scribe line movement, although the MRP did include the GE requirements for the work.
However, revisions to the core spray pump MRPs Bechtel issued after the NRC inspection included detailed wort descriptions and data sheets similar to those in the RHR pump MRPs.
4.2.5 Incorrect HVAC Hanger Material Size (COR-019)
This item concerned the installation of an incorrectly sized gusset plate on HVAC hanger 66. Specifically, the installed gusset plate was 1/2-inch thick, as specified on drawing M-1169-2. Accordingly to an FCR written to change the drawing and listed in inspection documents as the applicable design change document, the correct gusset plate thickness was 3/4-inch.
Bechtel concurred with the observation, perfonned calculations that indicated the existing hanger configuration was technically adequate, and revised the affected-7-
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drawings. The team considered this assessment and corrective action to be adequate, and no additional action is required of the licensee.
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However, Bechtel's response to the COR indicated that this discrepancy resulted from a mistake by the construction engineer in preparing the FCR.
Bechtel stated that, to detcrmine the extent of this discrepancy, six similar hanger installations and 15 FCRs prepared by that construction engineer were reviewed, and no further discrepancies were noted. The response also indi-cated that the action to prevent recurrence was to emphasize to the responsi-ble construction, engineer the need to pay mere attention to detail. Although the field engineer mai have erred in specifying the plate size on the FCR, Bechtel's response did not acknowledge that the support was not constructed in accordance with the spr.cified design and was accepted in error by the QC inspector.
Because RcChtel did not P operly identify inadequate installation and inspection as a cause of this discrepancy, its corrective actions were not properly focused. However, due to the minor nature of the installation discrepancy and lack of similar deficiencies identified by SWEC and the NRC, no further action is reqLired of the licensee.
4.2.6 Lack of Installation and Inspection Criteria for RHR Heat Exchanger Lower Supports (NRC Issue)
The design specification and the vendor technical manual for the RHR heat exchangers.7dicated that installation requirements should include clearance requirements for the lower support bolts to allow for thermal expansion.
The team was concerned that the installation documents for the RHR heat exchangers did not specify any required clearance, and thus, the existence or amount of any clearance in the as-built condition was unknown. Although the licensee stated in the response that it did not concur with this concern, the l
licensee conducted inspections to verify the radial clearances for the RHR f
heat exchanger lower supports and performed calculations to determine that j
thermal growth would not cause unacceptable loads to the heat exchanger or l
supports.
The team still considered this a failure to incorporate design criteria into installation documents.
In fact, the licensee's subsequent inspections and reviews also identified the existing clearance between the support feet and adjacent bumpers as being outside the range used in the design analysis.
The team considered this another example of improper incorporation of design criteria.
Bechtel performed stress calculations using combined seismic and thermal loads and found that FSAR-allowable values would be exceeded, although en analysis indicated the support steel would remain functional. To comply i
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with the FSAR commitments, the licensee installed shims where required on the lower support bumpers.
In addition, the NRC inspection team noted that the licensee's response to IR 50-353/88-202 did not indicate that FSAR commitments would have been exceeded without installation of the shims. Although this is an example of an incomN ete response, the licensee's corrective actions were adequate, and no additional action is required.
l 4.2.7 Missing Jam Nuts on Equipment Foundation Bolts (NRC Issue)
l This concern related to the licensee's failure to install jam nuts on
foundation bolts for various pumps and unit coolers in the reactor building, as required by the general foundstion drawing. The licensee concurred with this finding and performed an inspection of all mechanical equipment-8-l
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foundations in the reactor and diesel generator buildings. After identifying additional cases of required jam nuts and washers that had not been installed, the licensee corrected the discrepant conditions or deemed them as acceptable on a case-by-case basis. The team considered the licensee's actions to be adequate.
However, the licensee indicated in the response that the basic cause of these discrepancies were inexplicit and inconsistent equipment foundation drawing details. The last sentence of the paragraph indicated that, "In addition,
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an adequate drawing review was not performed in all cases...".
The team noted that the same drawing. requiring jam nuts applied to all of these founda-tions. The licensee's response directed attention to poor documents, rather than to the fact that the installers and inspectors tailed to comply with existing, referenced design drawings. Although no additional action is required of the licensee, this response was another example of an incomplete root cause determination.
4.2.8 Discrepancies in the Control of Work Packages (NRC Issue)
During its inspection, the NRC team noted numerous discrepancies in the documentation related to work packages for mechanical equipment installation and modification. The team was also concerned with the complexity and clarity of inspection documents and considered these factors possible contributors to some of the discrepancies noted on mechanical equipment installations. The licensee stated in its response to this issue that it did not concur with this concern, indicating that the work packages are neither quality documents nor permanent records. The response further stated that all QC-required data and inspection attributes had been accounted for, and numerous audits had deter-mined these programs to be adequate.
The team identified this concern to the licensee as an observation of apparent program weaknesses that have also been identified at other nuclear plants where they have directly contributed to installation deficiencies. The team reviewed two Bechtel audits and nine PECO audits provided by the licensee in support of the response. The team noted that discrepancies similar to those addressed in the NRC report, such as missing or imoroperly referenced accep-tance criteria and other inspection and installation documents and improper inclusion of installation details in work packages, were identified in four of the audit reports provided by the licensee. Several cases of performance and QC acceptance of out-of-tolerance shaft alignments were also identified.
In addition, the team noted that the poor quality of the recently issued MRP for the core spray pump discharge head bolting program, discussed in Section 4.2.4 above, was a current example of this concern. Although no additional action is required of the licensee, the licensee indicated following the inspection that they recognized the NRC's concern regarding adequately documented work packages.
4.3 Civil / Structural and Piping and Supports The inspection team examined the resolution of selected SWEC ICA and NRC issues from IR 50-353/88-202 to asce:tain if SWEC adhered to the ICA program for control of identified issues, if SWEC's bases for accepting the Bechtel responses to the findings were adequate, and if the licensee responses to the NRC findings were adequate with respect to scope and corrective actions.
Additionally, the NRC inspection team reviewed a number of construction action-9-
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items (CAls) that were generated by SWEC.
The team determined that the CAls had been escalated properly to observation reports where appropriate. The following construction observation reports (CORs) and issues were reviewed by the inspection team:
o COR-029, missing connection welds on a structural platform;
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o COR-034, embedment length of grouted-in rods; o
COR-036, loose nut on platform anchorage; o
COR-040, erroneous acceptance criteria for welded connections substituted for. bolted connections; o
NRC issue, cadweld sister splice testing; o
NRC issue, structural bolts with threads located in shcar plane; and o
NRC issue, potential interference between pipe support clamp and structural column.
The team found, through its review and on-site evaluation, that the licensee properly resolved COR-029, COR-036, COR-040, and the NRC issues concerning instances of. bolt threads located in shear planes, and the reduced gap between a pipe support clamp ar.d structural member.
The team found, however, that the response for one SWEC COR was incomplete, and that full resolution of one NRC-identified issue required additional action by the licensee. These two items are discussed in the following paragraphs.
4.3.1 Embedment Length of Grouted-In Rods (COR-034)
SWEC determined that the embedment lengths for grouted-in rods on baseplate GBC-204-H4 were less than the design requirements. The discrepancies in length were due to the fact that no inspection requirement existed in the quality control or field engineering inspection programs to verify that minimum embedment requirements were met.
Bechtel examined the length of 136 additional grouted-in rods installed on seismic Category 1 large-bore pipe supports and found that approximately 20 percent failed to meet the minimum embedment requirements. The inspection team reviewed the Bechtel calculations used to demonstrate adequacy of the installations with less than full embedment depth, and found the calculations adequate. However, the NRC team had the following concerns regarding the corrective actions for this COR.
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Grouted-in rods for equipment anchorages and platform steel supports were not evaluated to quantify the actual safety factors that would exist with the reduced embedment depth.
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Only the grouted-in rod capacities for large bore supports were reduced for future calculational purposes in association with the reduced embedment depth where the capacities for other uses such as equipment anchorages were not adjusted accordingly.
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Bechtel utilized a factor of 1.0 times the peak seismic acceleration of the applicable floor response spectrum to calculate equivalent static loads for design of steel platforms under seismic conditions, in lieu of
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the factor of 1.5 specified by the NRC Standard Review Plan Section 3.7.2.II.b.
The licensee provided the team with additional information regarding these concerns immediately after the inspection. These additional documents are being reviewed by the Mechanical Engineering Branch of the NRC's Office of Nuclear Reactor Regulation.
4.3.2 Sister Splices for Cadweld Testing (NRC Issue)
Bechtel performed an investigation in response to the NRC concern, and found that in approximately 10 percent of the production splices the appropriate sister splice cadweld testing had not been done in advance.
Bechtel concluded that the cadweld operations were satisfactory since the welders were prequali-fied, every twenty-fifth splice was tested, and all splices were examined visually in accordance with the engineering specification. However, based upon the high rate of discrepancies, the licensee was requested to amend the FSAR to reflect actual cadweld test practices. This change was considered by the team to be editorial in natme.
ChangeNotice(LDCN)gtheinspection,thelicenseeapprovedLicensingDe Immediately followin FS-1695 to make the appropriate changes to the FSAR.
Based on PEC0's proposed FSAR change, this item is fully resolved.
4.4.
Electrical and Instrumentation The NRC team reviewed in detail 13 issues in the electrical and instrumentation areas. This review consisted of an evaluation of pertinent documentation, plant personnel interviews, and physical inspection of affected systems and components.
Of the following 13 issues examined, 8 were responses to NRC-identified concerns from IR 50-353/88-E02 and 5 were construction observation reports (CORs) detailed in the SWEC ICA report:
o COR-010, sealing of motor-operated valve compartments; o
COR-017, vital battery maintenance; o
COR-026 motor-operated valve HV51-2F004B; o
COR-031, deficiencies in de distribution panel; o
COR-051, station battery rack configuration; NRC issue, cable separation in penetrations; o
o NRC issue, cable bend radius in control panels; NRC issue, RHR pressure transmitter mounting deficiency;
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NRC issue, general cable separation; NRC issue, qualification of motor-operated valve internals; o
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NRC issue, pipe to junction box interaction;
o NRC issue, general wiring practices; and o
NRC issue, damege to temperature detector wiring.
In general, the NRC team's inspection of corrective actions indicated that the SWEC ICA effort had been implemented as required by the IDCA program proce-j dures.
In most cases, the NRC inspectors found that identified deficiencies
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had been appropriately evaluated and corrected by the licensee.
The team determined, through its review of the licensee's responses and additional backup data provided by site personnel, that the SWEC CORs and NRC-identified issues were adequately and properly resolved, with the excep-tion of the NRC issues concerning cable separation in penetrations and quali-fication of motor-operated valve internals, Full resolution of these issues
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required additional clarification or corrective action by the licensee in response to the concerns discussed in the following paragraphs.
4.4.1 Cable Separation in Penetrations (NRC Issuel The NRC team documented in IR 50-353/88-202 two concerns regarding the routing of safety class cable through comon penetrations.
The first concern regarded the routing of Class IE and non-Class 1E cable through a common penetration.
In response, Bechtel provided an analysis which adequately demonstrated the use of Conax feedthrough tubes as a separation barrier, thus eliminating any potential detrimental affects of the non-Class 1E circuits on the Class 1E circuits.
The second concern regarded the routing of engineered safeguard system (ESS)
and reactor protection system (RPS) circuits within a comon electrical penetration. The concern was that the FSAR required separation of ESS circuits from RPS circuits but did not provide specific requirements for routing ESS and RPS circuits through a comon penetration, as it did for Class 1E and non-Class IE circuits sharing a comon penetration.
In response to this concern, the licensee's Project Engineering Department perfortned a review of regulatory requirements and the Limerick FSAR. Additionally, the licensee performed an evaluation of existing field installations to determine con:pliance with design requirements.
In sumary, the response concluded "that
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there is a continuity between IEEE 384-1974, the Project FSAR Section 8.1.6.1.14, paragraph b.8 and [ Specification] E-1406 and proper electrical separation has been maintained." The NRC team was satisfied with the technical adequacy of the response, but found that it did not adequately address the lack of provisions in the FSAR for the routing of ESS and RPS
,
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circuits in a common electrical penetration.
This issue was further discussed with the licensee and Bechtel engineering in order to clarify the team's concern. The NRC inspectors noted that FSAR Section 8.1.6.1.14.b.8 provided for the routing of Class IE and non-Class IE circuits within a common penetration and also allowed the routing of two divisions of Class 1E circuits through the suppression pool penetration.
These specific provisions were addressed in the FSAR as exceptions to the general separation criteria provided in preceeding sections of the FSAR and were based on an analysis which demonstrated that affected circuits would not be degraded by internal faults which initiate in circuits of another division. However, I
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the FSAR was silent on the routing of ESS and RPS circuits in this manner.
Consequently, the NRC team again concluded that cable installations which route ESS and RPS circuits through a common electrical penetration were not specifically addressed in the FSAR.
This conclusion was discussed with the licensee and Bechtel engineering.
As a result of these discussions, the licensee approved Licensing Design Change Notice (LDCN)-FS-1692 shortly after the inspection. This LDCN will revise the FSAR so that it will accurately reflect existing field cable configurations.
This proposed change to the FSAR is considered by the team to be editorial in nature and adequately resolved the concern.
4.4.2.
Qualification of Motor-0perated Valve Internals (NRC Issue)
The NRC team identified concerns regarding the use of Belden J type AWM crosslink wire in valve actuator HV-52-2F001C.
Specifically, the motor leads appeared to be undersized for the application, and evidence of their environ-mental qualification could not be provided by the licensee.
In response to this issue the licensee provided the NRC inspectors with a copy of Limitorque Qualification Report B0003.
This report detailed the environ-mental qualification of both the Belden motor leads and the Peerless AC motor to which they are connected. However, the licensee provided no engineering justification or analysis to demonstrate that the small size of the motor leads in question (18 AWG) was adequate for the application.
Immediately following the inspection, the licensee provided information that the wire's continuous current rating (18 amperes) was greater than the motor's locked-rotor rating (15.8 amperes).
However, the wire rating was based on an ambient temperature of 30* Celsius, and the wire's rating at a more realistic ambient temperat.re of 40 C would only be 16 amperes. To resolve this concern u
fully, the NRC team requires additional information regarding the Belden wire's fire retardency, its short-term current rating, and the relationship of the wire's ratings to the design requirements of the motor-operated valve.
4.5 Procurement, Receiving and Storage, and QA and QC The NRC inspection team evaluated the SWEC ICA findings to ensure that the construction action items (CAls) were properly escalated to construction observation reports (CORs) when necessary and that SWEC had an adequate basis for acceptance of Bechtel's responses.
Further, the team reviewed the responses to the findings from the previous NRC inspection documented in IR 50-353/88-202 to ensure their technical adequacy and completeness, the appropriateness of corrective actions, and the proper scope of corrective actions. Specifically, the team reviewed the following items in detail:
o CAI-016, valve fastener material; CAI-021, vendor certification for pump cleaning and coating; o
o CAI-035, supplier quality assurance program; o
CAI-036, long-tenn preventive maintenance records; CAI-038, receiving records for reinforcing bar material; o
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o-CAI-102, conduct of' preventive maintenance for suppression pool suction strainers;.
o COR-22, missing preventive maintenance records and lack of suction strainer preventive maintenance; o
NRC issue, conduct of pneumatic leak testing; and o
NRC issue, hydraulic control unit preventive maintenance.
The NRC team determined that CAI-036 and CAI-102 were properly escalated to observation report status in COR-022, and found all of the Bechtel responses to the CAls were technically satisfactory. The team reviewed the single observation report, COR-022, that was issued in this area and the associated site nonconformance documentation. Bechtel's actions included a visual examination by QC personnel of all affected suppression pool strainers, and a review of prior storage conditions. The strainers were found satisfactory by Bechtel and were entered appropriately into the preventive maintenance program. Based upon evidence of preventive maintenance program implementa-tion, equipment installation verification, and coraponent testing, Bechtel had demonstrated the acceptability of the equipment for which certain preventive maintenance records had been lost.
The licensee's resolutions of NRC concerns from IR 50-353/88-202, Sections 4.7.2.1 and 4.8.2.4, were reviewed by the NRC team. This review indicated that the licensee's conduct of pneumatic leak detection testing was properly controlled. The leakage from the hydraulic control units was ultimately diagnosed by the licensee, and an accumulator and valve were reworked to prevent further nitrogen leakage. Associated corrective actions included personnel training, torquing of nitrogen fill caps, ar,d using demineralized water to rinse a unit to which a leak detection fluid had erroneously been applied.
The team concluded that the SWEC and NRC findings had been satisfactorily addressed by the licensee and that no outstanding concerns remained in this area.
4.6 ICA Trend Analysis The inspection team reviewed COR-56 which related to a SWEC-identified trend involving alteration of electrical equipment after initial installation and quality control inspection. The Bechtel investigation in response to the COR found, however, that the equipment problems were generally due to incomplete performance of the initial installation quality verifications. The NRC team reviewed the CORs related to COR-56 and the Bechtel analysis of the perceived trend. Based upon the review, the team concurred with the Bechtel response that the discrepancies were generally not caused by post-inspection work activities.
The team, however, was concerned about the characterization of the site's QA program in the response to the COR. The response stated, in part, that the QA program did "not provide zero defect hardware", but was "a graduated program of assurance that a level of quality is maintained on safety related equipment sufficient to assure its function." The team found this description of the
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licensee's nuclear quality assurance program to be narrow and inconsistent with the rules and policies of the NRC.
The goal of a QA program should be to strive for excellence in all areas of
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plant operation that affect plant safety and not just the sufficiency of function for safety-related equipment.
Subsequent discussions between.the team and PECO and Bechtel quality representatives indicated that the state-ments made in the COR response did not reflect the overall QA philosophy of i
the licensee. The licensee needs to clarify the meaning of the statements in the COR response with regard to its description of its QA program.
Based upon a review of concerns identified by both SWEC and the NRC, the team
detected a trend associated with improperly performed quality control inspec-
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tions (89-200-01). This trend includes the following problems, o
Foundation bolts for the standby liquid control pumps 2A, 2B, and 2C lacked the requisite jam nuts or staked thr M s, and unit cooler 2FV211 attachment bolts lacked washers.
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The anchor bolts for residual heat removal heat exchanger 2A were not provided with washers.
o The plastic shipping plugs for the residual heat removal pumps 2A, 28, 2C, and 2D shaft seal drain port assemblies were not replaced with a steel plug, nor were the radwaste drains provided.
o Five structural connections where welds were substituted.for bolting were not inspected, and the QC inspection criteria for such substitutions were incorrect, resulting in 52 installations that did not meet the appro-priate criteria.
o Structural steel connection bolt threads were not always excluded from the shear plane.
No quality control inspection attributes were provided for grouted-in o
anchor bolt embedment length.
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o Unistrut spring-nuts were improperly installed.
Although the individual deficiencies would not have adversely affected the safe operation of the plant, and although the corrective actions implemented by the licensee have generally resolved the concerns, these issues are still indicative that the installation quality verification process failed to ensure fully that, in these instances, equipment was installed in accordance with l
design requirements. Based upon the scope of the SWEC and NRC inspections, the team concluded that these concerns did not constitute a programmatic breakdown since the majority of equipment was properly installed.
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MANAGEMENT EXIT MEETING I
The NRC team held an exit meeting with PECO and Bechtel management on March 31 1989.
Individuals who attended the meeting are identified in Appendix B, Key Personnel Contacted. At the exit meeting, the team discussed its conclusions I
with regard to SWEC's implementation of the ICA process and the adequacy of
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the licensee's responses, those issues requiring additional information or action by the licensee, and those issues which had a potential for enforcement action.
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APPENDIX A
LIST OF DOCUMENTS REVIEWED Number Rev.
Title Date ADN-D-077
Apparent Discrepancy Notice 03/01/89 CAR 145
QC Corrective Action Report 09/28/88 DCA-418-H8
Pipe Support Containment Enclosure 01/20/89 RHR Unit 2 FCR 013504
Field Change Request 09/29/88 E0P-4.37
Design Calculations 12/18/87~
EWR 1-00150
Engineering Work Request 01/23/89 NCR 13908 Hydraulic Control Unit Nitrogen Purge Leak 10/04/88 NCR 1321 Bechtel Nonconfomance Report on 09/09/88 Chemical Staining of Radiographs NCR 13985 Suppression Pool Strainers PM 09/22/88 NCR 13871-Preventive Maintenance Records Lost 09/23/88 NCR 14028 Nonconformance Report 11/18/88 NCR 13842 Nonconformance Report 10/11/88 NCR 13953 Nonconformance Report 11/09/88 NCR 14244 Nonconformance Report 03/03/89 NCR 14136 Nonconformance Report 01/11/89 GE-UT-1
GE NDE Procedure Ultrasonic Examination 10/04/88 of Welds GEK-39469E Hydraulic Control Unit Part Nos. 761E500 10/85 Groups 1 Through 9 18XA9602
GE NDE Procedure Radiographic Examination 07/11/80 of Welds 18240-2-FW-001 1 Bechtel Procedure Determination of Life-12/13/88 of-Plant Film Quality Nupro Letter SN0OP Liquid Leak Detector 10/25/88 to Bechtel
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Title Date Swagelok letter-SNOOP Leak Detector 06/04/87 to Bechtel FDDR HH2-8803'
Nitrogen Fill Cap Torque 10/31/88 FDDR HH2-9045 Hydraulic Control Unit Nitrogen Purge 10/17/88 IPRN LTM-2417 Hydraulic Control. Unit Nitrogen Purge 08/02/88 E.3-0.
Raceway Barriers and Seals N/A B0003
Limitorque Qualification Report N/A CP-E-4
Installation of Internal Raceway and N/A Raceway and Equipment Seal and Electrical Raceway Fire-Proofing-101.8.10
Bechtel Calculation, Limerick Reactor 09/29/88 Building Drywell Unit Cooler Supp.
Fixes 2AW212 114.4.64
Bechtel Calculation, Limerick Generating 01/20/89-Station NCR #14136
.114.4.61.
O Bechtel Calculation, Limerick Generating 11/01/88 Station Unit II NCR #13953 Welded Connections 114.4.62
Bechtel Calculation, Limerick Generating 01/20/89-Station II NCR #14028 Platform Beam End Connections 114.6.6.(426)
Bechtel Calculation:
Civil FCRs, NCRs 06/22/88 and BP0CRs
Bechtel Stress Calculation 2-10-06 12/16/b7 Attachment A
Bechtel Stress Calculation 2-10-06 02/10/89 o
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Attachment H 114.11.13
Bechtel Calculation: Grouted-in 03/07/89 Rod with Reduced Embedment Detail 2/C-615,3/6-615 l
8031-E-1406
Conduit and Cable Troy Notes, Symbols, N/A and Details 8031-E-1412
Wire and Cable Notes and Details 10/05/88 l
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Number Rev.
Title Date 8031-E-1410
Teminal Box, Junction Box, Option Box, N/A Wireway, Local Control Station Box, Notes, Table and Figures 8031-G-21
Specification for General Project 08/04/88 Requirements for Mixing of Supports
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Specification for Multi-Comodity 01/20/89-Supports 2M-529
PECO Audit Report 10/02/86 2M-530
PECO Audit Report 09/26/86 2M-544
PECO Audit Report 04/03/87
PECO Audit Report 12/15/87 2M-562
PECO Audit Report 01/08/88 2M-566
PECO Audit Report 02/18/88 2M-572 0-PECO Audit Report 05/18/88 2M-576
PECO Audit Report 05/18/88 2M-577
PECO Audit Report 08/09/88 C-63-22-51 Field Inspection Report 10/18/88 C-63-22-56 Field Inspection Report 10/27/88
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C-64-22-4 Field Inspection Report 10/26/88 PFA 952
Bechtel Project Field Audit Report 10/07/87 (21.1-23)
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PFA 952
Bechtel Project Field Audit Report 10/27/88 (21.1-24)
Modification and Rework Package for Core 03/13/89 Spray Unit Cooler 2FV211
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PMQ-500-063
Preventative Maintenance Procedure for DRAFT Operational Analysis of Motors P-202, P-206, P-506, and P-548 for Maintenance Recommendations A-3 a
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e APPENDIX B KEY PERSONNEL CONTACTED Name Organization G. Lauderback*
Startup Quality Control (QC) Supervisor, PEC0 G. Kelly *
Quality Assurance (QA) Engineer, Bechtel R. Brown *
Nuclear Quality Assurance, PECO E. Fleming *
Chief Engineer, SWEC D. Helwig*
Assistant to Vice President Nuclear, PECO P. Werts*
Construction Engineer, Bechtel-
l E. Grant *
Licensing Engineer, NED W. Bugher*
Construction Engineer, Bechtel J. Patrick *
Quality Engineer, Bechtel D. Moyer*
Mechanical Engineer, Bechtel S. Harvey*
Construction Engineer, Bechtel W. Ross*
Welding Engineer, Bechtel K. Humma*
Asst. Project Construction Engineer, Bechtel V. Aggarwal*
Civil Engineer, Bechtel J. Fedick*
Mechanical Supervising Engineer, PEC0 J. Delaney*
Lead HVAC Engineer, Bechtel K. Heck *
Assistant Superintendent Nuclear QA, PECO D. DiPaolo*
Superintendent Unit 2 QA, PECO D. Daniels*
Project Construction QA Engineer, Bechtel J. Corcoran*
Startup Superintendent Unit 2, PECO R. Stipcivich*
Project Engineer Unit 2, PEC0 W. Mourer*
Project Manager, Bechtel D. Snyaer*
IDCA Coordinator, PEC0 M. Teller *
Construction, PECO P. Naugle*
Limerick Unit 2 Manager, PECO S. Blubaugh*
Instrumentation Engineer, Bechtel J. Luhring*
Electrical Engineer, Bechtel l
J. Wirbicki*
Assistant Lead Electrical, Bechtel l
C. Brinson Quality Assurance, General Electric Company K. Quinter Quality Control Supervisor, Bechtel P. Hudson Piping Field Engineering Supervisor, Bechtel J. Schwamb Mechanical QC Supervisor, Bechtel R. Phelps QC Inspector, Bechtel T. Roosa Electrical Engineer, Bechtel H. Schifferer Electrical QC, Bechtel C. Haynes Design Engineer, Bechtel L. Yates Supervising Maintenance Engineer, PEC0 J. O'Mara Maintenance Engineer, PEC0 J. Base Maintenance Engineer, PEC0 D. Neff Regulatory Engineer, PECO D. Le Stress Engineer, Bechtel A. Herzog Stress Engineer, Bechtel D. Kaas Civil Engineer Bechtel J. Bhatt Civil Engineer, Bechtel
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D. Reading Hanger Engineer, Bechtel l
T. Kenny *
Senior Resident Inspector, NRC R. Fuhrmeister*
Resident Inspector, NRC
- - Attended managemcnt exit meeting on March 31, 1989
l B-1
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