ML20004E905

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IE Safety Insp Repts 50-352/81-06 & 50-353/81-05 on 810401-30.Noncompliance Noted:Failure to Correct Identified Nonconforming Conditions & Improper Welding of Heating, Ventilation & Air Conditioning Dampers
ML20004E905
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 05/27/1981
From: Durr J, Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20004E902 List:
References
50-352-81-06, 50-352-81-6, 50-353-81-05, 50-353-81-5, NUDOCS 8106160127
Download: ML20004E905 (8)


See also: IR 05000352/1981006

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u.S. NuCt Aa accutAr0av Cax.cSSION

OFFICE OF INSPECTION AND ENFORCEMENT

Region I

50-352/ 81-06

Report No. 50-353 / 81-05

50-352

Docket No.

50-353

CPPR-106

License No.

CPPR-107

Priority

Category

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Licensee:

Philadelchia Electric Cemeany

2301 Market Street

Philadelohia, Pennsylvania 19101

Facility Name:

Limerick Generatino Station, Unit Nos. 1 and 2

Inspection at: Limerick, Pennsylvania

Inspection conducted:

April 1-30, 1981

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Inspectors:

, MJ

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F. Curr, Senior Resicent Inspector

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Approved by:

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v. ncLace, unter, neac cr

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Projects Section 29

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Ins::ection Summary: (Unit No.1) Insoecticn en Aoril 1-30, 1981 (Recort No. 50-352/81-06)

Areas Insoected: A routine inspection, including off-snift activiti.s, by the

resident inspector of piping installation, welding, IE Bulletin activities, structural

steel, safety related components, and licensee's activities en previous inspection

findings. The inspection involved 61 inspector-hours on site.

Results: Two items of noncompliance were identified in the 6 areas inspected (failure

to correct identified nonconforming ccnditions, para. 3; welding undercut in structural

steel, para. 6).

(Unit No. 2)

Insoection on Acril 1-30, 1981 (Recort No. 50-353/81-05) A routine inspec-

tion, including off-snift activities by the resident inspector of piping installation,

welding, IE Bulletin activities, and licensee's activities on previcus inspection findings.

The inspecticn involved 15 inspector-heurs en site.

Results: One item of noncompliance was identified in the 4. areas inspected (welding

uncercut in structural steel, para. 6).

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Region I Form 12

(Rev. April 77)

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8196160127

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DETAILS

1.

Persens Contacted

Philadelphia Electric Comoany

D.T. Clohecy, Quality Assurance Engineer (QAE)

J.M. Corcoran, Field QA Branch Head

F.J. Coyle, QAE

M.J. McGill, QAE

A. McLean, Engineer

G.J. Moffitt, Jr., Engineer

R. Scott, Senior Engineer

Bechtel Pcwer Corporation

A. Arch, Assistant Project Field Engineer

B. A. Dragen, QAE

H.D. Foster, Project Field Quality Centrol Engineer

J.P. Gray, Sr., Piping and Instrument QCE

L.E. Griffiths, Subcontracts Engineer

A.M. Hill, Office Engineer

E.R. Klossin, Prcject QAE

J.L. Martin, Lead Site QAE

X.L. Quinter, Assistant Project Field CCE

J.R. Reiney, Jr., Project Ccnstructicn Manager

D.C. Thanoson, Assistant Project Field CCE

A.G. Weedman, Project Field Engineer

The above listed persens attended exit interviews held en April 15, ISS1,

or on April 30, 1981. Cther engineers, craftsmen, quality centrol technicians,

or supervisors were contacted as the inspecticn interfaced with their work.

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2.

Plant Tcurs (Unit Nos.1 & 2)

Periodically during the inspection, tours were made of the Unit Nos.1 and 2

primary reactor containments, the reactor buildings, the control structure,

and surrounding yards and shops. The inspector examined canpleted work,

work in-progress, cuality control activities, and equipment storage,

handling, and maintenance.

He discussed the technical aspects of the

work with craftsmen, supervisors, and engineers to assure work was being

performed in accordance with requirenents.

On April 16, 1981, Messrs. V. Gilinsky, Commissicner; J. Austin, Technical

Assistant; Boyce Grier, Regicn I Director; and George Snith, Divisien of

Energency Preparedness and Operational Support Director, toured the

Limerick Generating Station. The tour was preceded by a briefing at the

simulater facility cenducted by members of the Philadelphia Electric Company

staff.

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3.

Licensee's Actions on Previous Inspection Findings

(Closed) Unresolved Item (352/79-01-02) Post tensioning of the fuel , col

girders. The NRC reviewed the reports sutmitted by Philadelphia Electric

Company and found that they adequately and satisfactorily address this

unresolved item (Reference:

IE Memorandum Carlson to Reinmuth, June 7,1979,

titled, " Limerick Generating Station Unit 1 - Post Tensicning of Fuel Pool

Girders", and IE Memorandum Jordan to Martin, March 24, 1981, titled,

" Post Tensioning of Fuel

Pcol Girders").

This item is closed.

(Closed)

Infraction (352/79-07-04) Field Design Changes were not incor-

parated into completed work. The licensee's corrective actions were

inspected in IE Report 50-352/80-02, except for the implementatien of actions

to preclude recurrence. The licensee develooed a new Job Rule, JR-G-42,

" Review of Revisions to Drawings". The Job Rule designates respcnsible

discipline engineers to review all design changes. The review considers

if the changes impact on work in progress or completed work. The review

is documented in a log book and retained until ccupletion of the job.

The inspector reviewed the Job Rule, JR-G 42, and examined the log bcoks

maintained by the Area 1 Lead Electrical Engineer, the Lead Civil Engineer,

and the Lead Instrument Engineer. The review of the Area 1 Lead Electrical

Engineer's leg disclosed that Field Drawing Change Notices (FDCN's) were not

being legged alcng with the other design change documents. However, the

engineer was reviewing FDCN's as they were incorporated into the drawing

revisions. The failure to review and log FDCN's was the result of a

misinterpretatien of the Job Rule. The engineer was reviewing and logging

other design change documents. This item is unresolved pending(review 352/81-06

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and legging of FDCN's by the Area 1 Lead Electrical Engineer.

(0 pen)

Infraction (352/79-11-08)

Improper welding of heating, ventilation,

arid air cenditioning (HVAC) dampers. The inspector reviewed Bechtel

drawing C-616 Revision 15, and verified that changes have been made to

acccamodate limited access welding of hVAC fire dampers. An inspection of

fire dampers revealed that a limited number of dampers have been modified to

correct for the restricted access. The following dampers were inspected:

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Damper No.

Elevation

Remarks

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FPD-202-3

201'

approx. 1 5/8" clearance

FPD-202-13

201'

accessible

FPD-?01-13

201'

accessible, approx. 7" clearance

F90-201-40

283'

optien installed

FPD-201-31

253'

These are mounted side by side.

i!PD-202-44

253'

Approximate dimensions are 38"L x

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40"W x 42" H with 4"-5" wall

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clearance.

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The inspector questioned the licensee's ability to make meaningful inspections

of the dampers such as FFD-202-3 which is only 15/8" from the wall. The

dampers on elevation 253' are a side by side installatien which requires

the inspector to examine welds frm a distance of 38" with 4" of clearance

from the wall. The access to these damners for the original installation,

inspection and reinspection does not allow reasonable clearance for work to

be perfomed.

The licensee reopened his audit

report finding N-173 and directed further

work be perfomed to satisfy the original ncncmpliance. The failure to

assure that conditions adverse to quality are corrected is contrary to

10 CFR 50, Appendix B, Criterien XVI and an item of r.cncompliance.

(352/81-06-02)

(Closed)

Infraction (352/79-12-01) A subcentracter for masenry walls

failed to maintain currect revisiens of drawings in the work area. The

subcontracter is no lenger perfoming work en the site. The cbsolete

drawings were for the control rem area, elevatien 239'.

Cnly 3 drawings

were of seismic Category I walls. The inspecter selected drawing C-761

and reviewed the Quality Centrol Inspection Report (QCIR) No. C-761-Rx-

JL-1-8-1 and verified tnat drawings used for inspecticn are kept current.

The QCIR for this drawing is still open and inspecticn inccmplete at this

time.

Quality assurance program recuirements were not imposed on masenry walls

subcontractors and was cited as an item of ncncmpliance (Reference

352/79-12-02). Tae lack cf a document centrol pregram resulted fron not

imposing quality assurance requirements on this subcentractor. This was

inspected under item 352/79-12-02.

This item is closed.

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(Closed)

Infraction (352/79-12-02)

Infraction 352/79-02-02 was incorrectly

reported as closed in IE Report 50-352/81-04 when, in fact, it shculd

have been 352/79-12-02.

This item is closed.

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(Closed)

Infraction (352/79-12-03) Centrol of pipe hanger drawings. Obso-

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lete drawings were discovered in the possession of a piping foreman. The

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practice had been to issue 1 cr 2 hanger drawings and reproduce uncentrolled

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copies in the field. The licensee purged the field of all uncontrolled

drawings and established a controlled issue system.

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The inspector reviewed the Job Rule, JR-G-5, " Design Document Control", and

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verified that pipe hanger drawings are controlled in accordance with

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paragraph 4.2.5.

He examined the drawing centrols for field stick Ncs. 8 and

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18. He reviewed the Quality Centrol Record No. M52-GBB-ll2-2-5-1 for

hangers GBB-ll2-H8, H9, and H10. These were the pipe hanger drawings

detemined to be obsolete.

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This item is closed.

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(Closed)

Infraction (352/80-19-01) Failure to document a change to

the jet barrier steel. The licensee's corrective actions were:

To issue a Field Change Request No. C-7578-F

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requesting authorization to correct the minimum edge

violation. This was accomplished by plug welding the

hole.

Specification 8031-C-63, "Specificatien for the Erection

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of Structural Steel", is the controlling guidance for

erection of structural steel. Field deviation and changes

to components controlled by Specification C-63 are allowed by

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Specifications C-63, G-17, and PC.M-252. PC4-252, paragraph 10,

and Specification C-63 were modified to more clearly define

undocumented changes.

The inspector reviewed the foregoing documents and verified that corrective

actions were complete.

He also verified that quality centrol is notified

of any changes to designed installations.

This item is closed.

(Closed) Unresolved Item (352/80-21-01) Different installation criteria

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for anchor bolt thread engagement and apparent mislocatien of an electrical

function box. The licensee amended Specificatien 8031-C-64, "Specificaticn

for Installation of Expansien-Type Anchor Studs and Shells", to be censistent

with drawing E-1406 for sleeve anchor bolt thread engagements. Further,

drawing E-1406, paragraph 1(e), crovides for the location of cenduits to be

approximate and other locatiens are acceptable within specified guidelines.

This item is closed.

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IE Bulletin Review (Unit Nos.1 & 2)

(IEB-79-02) Reference:

IE Reports 50-352/81-01 and 81-04.

The inspector reviewed the licensee's test data reports for anchor bolt

torque versus tension and failure loadings for concrete anchor bolts in

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masonry block walls. He verified the acceptability of anchor bolt preload

practices at the Limerick Generating Station and the use of a safety factor

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of 3 for cyclic loads.

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This item remains open pending review of the test program for anchor bolts

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installed prior to January 17, 1980.

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5.

Observation of Welding Activities (Unit Nos.1 & 2)

Reacter coolant pressure boundary (A94E III, Class I) and other safety

related pipe welds (ASiE III, Class II and III) were selected for document

review and observation of welding activities. The document reviews verified

the welder's qualifications, proper welding procedures were enployed,

required nondestructive tests specified, appropriate quality centrol inspec-

tien points specified and signed off, and preper preheat and postweld

heat treatnents were required. The observation of welding censists of,

where applicable, examination of the cleanliness, fitup, and alignment

of the parts; preper welding equipment; purge and cever gas ficw rates;

electrodes and filler materials; appearance of the weld deposit; evidence

of quality centrol activities; and proper documentation. The following

welds were examined:

Weld No.

Class

System

Status

DCA-319-1/9 FW l

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Ccre Spray

Root and Intermediate

Passes

BWR PD-1 REC-1/WA16

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Recire.

Foot and Intennediate

Passes

GBC-201-1/0 FW56

III

Main Steam

Final pass and rect I.D.

10JX1C6A

MC

Elect. Pene-

Fitup,

cot pass, &

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traticn

intee.2diate

The inspector noted that the feedwater piping closure spool fitups to the

reactor pressure vessel nozzles do not meet ASME III Ccde alignment

tolerances. This was previcusly identified and dccumented on NCR 4699 by

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the licensee. The misalignments of the 6 closure spools were as great as

5/8" in sane instances. The inspector verified that activities to

correct this misalignment were being carried out within the requirements

of the ASME III Code.

Four heats of weld filler metal were selected for a review of quality

documentation. The review verified that the materials meet ASME II C

and III Code requirements. The review consisted of confirmation of

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chemical and physical test data.

No items of noncompliance were identified.

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6.

Observation of Structural Steel (Unit Nos.1 and 2)

The reactor building North exhaust stack structural steel erection was

selected for observation of work activities. Selected attributes on

drawings C-845 and C-846 were selected for examination and verification

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that they confom to drawing, specification, and applicable code require-

ments. The examinations censisted of verification of weld size and

appearance, bolted connecticns for proper size and type, confonnance of

the configuration to the drawings, proper size and weight of structural

shapes, and properly shaped copes.

The inspector observed welding undercut en the- welded connecticn for beams

2202 and 2404R. The welding undercut exceeded the 1/32" specified in

the AWS Code D 1.1.

This is contrary to specificaticn 8031-C-41A,

" Specification for Furnishing, Detailing, Fabricatien, and Delivery of

Structural Steel for the Reacter Building and Centrol Cceplex

Superstructure and Radwaste Building", and 10 CFR 50, Appendix B,

Criterien V.

This is an itan of ncnccepliance (352/91-06-03, 353/81-05-01).

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It was noted that the holes for the precast cencrete panel attachment

clips were being oxy-acetylene cut into the support beams. Cne of the

holes was cut osersized and failed to " clean up" when reamed. This was

brought to the attention of the foreman and workm'en, who repaired the hole.

Due to the inspector's concern for a general ccndition of oversized holes,

two additicnal clips were removed.

All holes examined appeared to be

completely reamed, however, due to the restricted access, the reamed

holes are serrated. The applicable codes are not definitive en the

acceptability of this condition. The licensee is evaluating this

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ccndition.

This item is unresolved pending ccrnpletien of the licensee's evaluatien

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and review by the NRC.

(352/81-06-04)

7.

Safety Related Components (Unit No.1)

The reactor recirculation discharge gate valve, 832-F031, SN:71-GE-49327-32,

and the main steam isolation valve, 821-F022, P.O. 205-AB319, were

selected for a quality documentation review. The review was to verify

compliance with applicable codes, ASME Ccde for Pumps and Valves (draft)

and ASME III Code. The review consisted of minimum wall calculations for

the valve bodies and chemical / physical properties checks.

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The chenical analysis review of the welding filler metals used for the

valve B32-F031 disclosed that the nickel requirements for Stoody

supplied material is low for Product Certifications Nos. 1825-71,

1770-71, 1087-71, and 235-72. The applicable ASME IIC Code specifica-

tiens require 11-14% nickel, while the Product Certifications record

less than 11% nickel. Also, the material certificatien for Murex

supplied filler material has recorded a manganese centent of .66%,

while the specification requires 1.0 - 2.5%.

This item is unresolved pending justificatien for these chemistry

deviatiens and review by the NRC.

(352/81-06-05)

8.

Unresolved Items

Unresolved items are matters abcut which more infonnation is required

to detennine if they are acceptable, noncompliances, or deviatiens.

Unresolved items are discussed in paragraphs 3, 6 and 7.

9.

Exit Interview

On April 15 and 30,1981, exit interviews were held with members of the

licensee's staff listed in paragraph 1.

The inspector discussed the

inspecticn scope and the findings.

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