ML20031H342

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IE Insp Repts 50-352/81-14 & 50-353/81-12 on 810901-30. Noncompliance Noted:Failure to Document Pipe Support Design Change for Unit 1
ML20031H342
Person / Time
Site: Limerick  
Issue date: 10/07/1981
From: Durr J, Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20031H330 List:
References
50-352-81-14, 50-353-81-12, NUDOCS 8110270384
Download: ML20031H342 (11)


See also: IR 05000352/1981014

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

Region I

50-352/ 81-14

Report No. 50-353/ R1-17

50-352f

Docket No.

50-353

CPPR-106

License No.

CPPR-107

Priority

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Category

A

Licensee:

Philadelphia Electric Comoany

2301 Market Street

Philadelphia, Pennsylvania 19101

Facility Name: Limerick Generating Station, Unit Nos.1 and 2

Inspection at: Limerick, Pennsylvania

Inspection conducted: September 1-30,1981

Inspectors:

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(A . P. Durr, Senior Resident Inspector

' date signed

date signed

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Approved by: _hk-_

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L. McLaoe, Unier, Keactor

Projects Section 2B

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Inspection Summary: (Unit No.1) Inspection on September 1 - 30, 1981 (Report No.

352/81-14) Areas Inspected: A routine, unannounced inspection by the Senior Resident

Inspector of the spray pond excavation, concrete activities, pipe and structural

steel welding, pipe supports, PGCC modifications, and licensee action on previous

inspection findings. The inspection involved 42.5 inspection-hours on site.

Results: One item of noncompliance was identified in the seven areas inspected

(Failure to document a pipe support design change, para. 4).

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(Unit No. 2)

Inspection on September 1-30, 1981 (Report No. 50-353/81-12)

Areas Inspected: A routine, unannounced inspection by the Resident Inspector of the

spray pond excavation, concrete activities, pipe and structural steel welding, and PGCC

modifications. The inspection involved 18.5 inspection-hours on site.

Results: No items of noncompliance were identified in the five areas inspected.

Region I Form 12

(Rev. April 77)

8110270394 811008-

PDR ADOCK 05000352

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DETAILS

1.

Persons Contacted

Philadelphia Electric Company

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

J. M. Corcoran, Field QA Branch Head

G. Lauderback, Jr., QAE

Bechtel Power Corporation

R. D. Bryan, Project Field Supt.

M. K. Chatterjee, Staff Conc. Engineer

B. A. Dragon, QAE

H. D. Foster, PFQCE

S. S. Godsey, Adm. Assistant

J. P. Gray, Sr. , LPQCE

M. G. Held, LC QCE

E. R. Klossin, PQAE

R. A. Lanemann, Project Electrical Supt.

J. L. Martin, LSQAE

J. B. McLaughlin, Lead Electrical Engineer

A. Molinaro, Project Superintendent

R. Newman, Lead P/M Engr. Reactor Bldg.

K. L. Quinter, Asstit.PFQCE

D. M. Shaw, APEE

R. V. Staus, Construction Engineer

W. J. Tate, Jr. , Lead Staff Civil En . ,

D. C. Thompson, Ass't. PFQCE

R. E. Weaver, LSME

A. G. Weedman, PFE

General Electric Co.

W. J. Neal, Resident Site Manager

ihe above listed personnel attended an exit interview given on September 30,

1981. Other craftsmen, engineers, quality control technicians, and

supervisors were contacted as the inspection interfaced with their work.

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2.

Plant Tours (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

completed work, work in-progress, quality 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 perfo med in accordance with requirements.

During the tour o# ti e common control room, the inspector observed the

initial portions of the work to correct flexible condait grounds in the

Power Generation Control Complex (PGCC). This deficiency was reported in

Construction Deficiency Report No. 81-00-01.

He reviewed the Field Dis-

position Instruction, FDI No. TNFV, and discussed the technical aspects

of the work with the craftsman and his supervisor. The FDI did not specifically

address which panels, circuits, or drawings were affected. The GE site

engineer had appended a list of affected panels to the FDI.

A limited

review of the drawings affected disclosed that the design infomation in the

FDI has not been translated to the drawings. When the FDI is completed,

the design infomation may be lost for future modifications or repairs.

The Engineering Change Notice (ECN) is the nomal document used to initiate

changes to the drawings, however, this was not available for review at this

time. This item is unresolved pending review of the ECN to verify FDI

design infomation (50-352/81-14-01 and 353/81-12-01).

A visual examination of the PGCC panels disclosed three questionable install-

ation practices for flexible conduit. First, a section of conduit in

panel 20C648 is not tied down adequately and can be moved to contact

surrounding terminals. Second, in panel 10C603 a 5" section of flexible

conduit is supported only by the wire it encases. Third, flexible conduit

is supported only by wire tie wraps.

Based on these observations the

inspector asked,if the seismic qualification of the PGCC panels was made

with the flexible conduit installed, what was the anchoring criteria for

flexible conduit, and do tie wraps meet the criteria? This item is unresolved

pending replies to these questions.

(352/81-04-02and353/81-12-02)

On September 10, 1981, Messrs. J. R. Pearring, of the Hydrologic and

Geotechnical Engineering Branch, and R. B. McMallen, of the Geosciences

Branch, visited the site to observe the spray pond excavation. The spray

pond tour was preceded by a meeting with licensee's technical personnel

to discuss NRC concerns relating to the South slopes ability to retain

water, the North slopes potential for liquifaction, and the rock structure

pemeability.

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3.

Previous Inspection Findings

(Closed) Unresolved Item (352/80-16-01) Welding filler rod transferred

to the Susquehanna Steam Generating Station (SSES) from Limerick was

identified by the NRC as not meeting ASME III requirements. The NRC

issued noncompliances 387/80-04-01 and 388/80-02-01 to the SSES. The

closeout of this noncompliance at SSES is applicable to this item at

Limerick and is reproduced below:

-(Closed)

Infraction (387/80-04-01; 388/80-02-01): Failure

to document chemical analysis of weld. filler metal. The

subject infraction involved the utilization of E309L-16 and ER 309

austenitic SMAW and GTAW filler metals which met ASME Section II

SFA-5.4 and SFA 5.9 filler metal requirements, but failed to

be tested for residual elements requir'ed by ASME Section III

(1974) Table 2432.1. The filler, received before January 1972

by the Limerick site and transferred to Susquehanna, did not require

analysis for these elements. The 1974 Edition of Section III

requires that these elements be analyzed for infonnation only

rather than indicating a specific range or maximum for each

element. The filler metals meet all other requirements for Section III

and are considered by the inspector to be metallurgically acceptable.

The actions taken by the licensee including residual analyses for

three heats and weld joint deposit analyses for two welds was

reviewed by the inspector and found acceptable. The inspector had

no further questions concerning this item.

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4.

Pipe hangers

The below listed pipe supports, hangers, and snubbers were selected for

visual examination. The examination verified selected attributes of the

design drawing were correct and that the drawing accurately reflected

the installation. The inspection consisted of dimensional measurements

of parts, visual and dimensional weld examinations, correct materials

used and proper documentation. The following supports were examined:

Support or Hanger

Finding

GBB-118-H12

Fillet weld between item #3 & #4 not

full throat; item #4 not identified

on drawing.

GBB-113-HG

Item #8 and #9 rotated 900

HBB-118-H3

Dimension on item 11 is 5/8" versus ";

lug orientation shows 1200 spacing, should

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be 90 ; pipe clamp does not have outside

bolts as shown, beam cope has notch at-

radius.

GBB-101-H3

Behm end connections for item 17 not

consistent with drawing, beam copes appear

to be less than h" radius.

GBB-ll7-H4

No nonconformances.

GBB-101-H15

No nonconformances.

GBB-ll7-Hil

No nonconformances.

GBC-101-H48

No nonconformances.

The supports were in various stages of completion and rework.

It was

verified that final inspections had not been perfonned by the licensee's

quality control group. The licensee issued In-Process Rework Notices for

the deficiencies noted.

The beam end connections for item 17 of support GBB-101-H3 were not installed

in accordance with the drawing. Significant changes in configuration were

made. A discussion with field personnel disclosed that the hanger was last

worked on circa July,1981. A check of document centrol records shows

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that no Field Change Requests have been issued for that support. The

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1.imerick Job Rules M-17, paragraph 5.6.1 and G-5, paragraph 5.3 require

the initiation of a Field Change Request for Alteration of design config-

uration. The failure to issue a Field Change Request in accordance with

established Job Rules is an item of noncompliance.

(352/81-14-03)

The inspector noted that the copes and cutouts of structural shapes do not

appear to meet.the AISC b" radius requirement.

Specifically, the notched

condition on HBB-ll8-H3 and the radii on GBB-101-H3 beam copes. Further

inspection revealed that the Specification for Installation of Critical

Pipe Supports, Hangers, and Restraints, P-319, does not address the use

of the AISC. However, the Specification for Pipe Hangers, Supports, and

Restraints for a Nuclear Power Plant (procurement), P-317, and Design

Criteria for Design and Documentation of Pipe Supac.-ts, Hangers, t.nd

Restraints, P-401, both invoke AISC requirements. This item is tmeesolved

per. ding verification that AISC requirements are applicable to pipe

support structural elements and are implemented for installation

activities.

(352/81-14-04)

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5.

Spray Pond (Ultimate Heat Sink)

The spray pond preparation was selected for observation of rock preparation,

concrete fill, and soil backfill. The inspector reviewed the following

documents:

-- C94, Specification for Spray Pond Earthwork

-- C61, Specification for Furnishing and Delivery of On-Site Concrete

-- Cll, Specification for Placing Unreinforced Concrete

-- LGS, FSAR Sections 2.5, 3.8, and 9.2

-- Drawings C-1102, 1105, 1128, 1129, and M-384

Portions of the spray pond excavation were examined by members of the

NRC-NRR Geosciences Branch (see paragraph 2) for acceptability. Areas

beneath the spray pining were excavated down to cmpetent rock and backfilled

with Class "A" concrete. The NRC inspector observed portions of the

concrete backfilling. He eitnessed slump and air entrainment tests

verifying that they were perfomed in accordance with ASTM test methods

and the values met specification li; nits.

He observed concrete batching, transporting and placing activities.

It

was noted that concrete trucks were being driven on relatively fresh

concrete. The inspector detemined, from conversations with licensee

personnel, that sme of the concrete was only 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> old. The inspector

brought this to the attention of the licensee, who issued a "Stop Work"

notice to prevent further construction loads on fresh concrete. A review

of specification C-ll disclosed that the specification does not provide

for protection of concrete fr m construction loads as required by ACI-301.

This item is unresolved pending verification that the concrete was not

damaged and revision of Specification C-11 (352/81-14-05 and 353/81 12-03).

A review of the soil backfill records for areas adjacent to the overflow

structure identified inconsistencies in the ASTM test documentation. The

specification C-94 requires that Moisture-Density curves be made in

accordance with ASTM-D698, Method "D".

The curves reviewed by the inspector

were made by Method "C".

The ASTM-0698, Method "D" states, "This method

shall not be used unless the amount of material retained on the 3/4" sieve

is 10% or greater." The licensee has not retained the sieve analysis

records to support method "C" use.

It appears that, frm soil stock pile

sieve analyses, that the "C" method is warranted. However, the method of

sampling and record correlation are not clearly defined. This item is

unresolved pending clarification of procedures and confimation of test

acceptability.

(352/81-14-06 and 353/81-12-04)

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The licensee has a "Q-List" wnich identifies structures and components

that are nuclear safety related and subject to 10CFR50, Appendix B,

requirements. The "Q-List" exempts the spray pond unreinforced concrete,

concrete backfill, soil-bentonite lining, soil cover, riprap, and shot .

crete from the list. A preliminary ' review by the NRC considers these items

to be under the purview of 10CFR50, Appendix B.

This item is unresolved .

ending review of the licensee's rationale for exenpting the above items

352/81-14-07 and 353/81-12-05).

6.

Concrete Activities

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The inspector observed the placement of concrete in the following ; locations:

Diesel Generator roof slab, Drawing C-660-DS-K-6-3

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-- Spray pond fill and pipe supports (see para. 5)

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-- Suppressica pool base plate grouting, Drawing C-263

He verified that the required tests were performed, the concrete mix met

specifications, and that placement practices were in accordance with codes

and specifications.

No items of noncompliance were identified.

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7.

Observation of Pipe Welding Activities

Reactor-coolant pressure boundary (ASME III, Class. I) and other safety

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

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review and observation of welding activities. The document reviews

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verified the welder's qualifications, proper welding procedures were employed,

required nondestructive tests specified, appropriate quality control

inspection points specified and signed off, and proper preheat and postweld

heat treatments were required. The observation of welding consists of, where

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

parts; proper welding equipment; purge and cover gas flow rates; electrodes

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

control activities; and proper documentation. The following welds were

examined:

Unit

Weld No.

Class

System

Status

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DCA-318-3-W6

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RHR

Fitup, Alignment,

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Rootpass

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DLA-206-1-W2

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Feedwater

Fitup, Alignment,

(PENE)

Rootpass

2

GBC-201-8-FW51

III

Main Steam Fitup and Alignment

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No items of noncompliance were identified.

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Containment Structural Steel

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Containment structural steel was selected for observation of welding and

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installation activities. Welding of a built-up box beam, Unit I, elevation

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253', Drawings C-949 and C-926, W14X370, and of a box beam seat, Unit II,

elevation 272', Drawings C-929 and C-942 were observed. .The inspector

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verified welding preheat, welder qualification, welding technique, weld

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bead appearanbe, and confomance to drawing configuration.

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Measurements of the Unit II beam end clearances detemined that they

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exceeded drawing limits.

It was verified that the licensee had identifi 4

this condition and was issuing a Field Change Request.

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No items of noncompliance were identified,

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9.

Unresolved Items

Unresolved itr' are matters about which more infonnation is needed to

determine if they are acceptable, deviations, or nc :ompliances.

Unresolved items are discussed in paragraphs 2, 4 and 5.

10.

Exit Interview

The inspector held an exit interview with representatives of the licensee

(denoted in paragraph 1) on September 30, 1981, to discuss the scope

and findings of the inspection.

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