ML20041B856
| ML20041B856 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/08/1982 |
| From: | Durr J, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20041B842 | List: |
| References | |
| 50-352-82-03, 50-352-82-3, 50-353-82-02, 50-353-82-2, NUDOCS 8202250266 | |
| Download: ML20041B856 (7) | |
See also: IR 05000352/1982003
Text
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Region I
50-352/ 82-03
Report No. 50-353/ 82-02
50-352
Docket No.
50-353
CPPR-106
License No.
CPPR-107
Priority
-
Category
A
Licensee:
Philadelphia Electric Company
2301 Market Street
Philadelphia, Pennsylvania 19101
facility Name: Limerick Generating Station, Unit Nos. 1 and 2
Inspection at: Limerick, Pennsylvania
Inspection conducted:
January 11 - 29, 1982
Inspectcrs:
b ) uA4/
- /J/fil
p.P.Durr,'SeniorResidentInspector
'date signed
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date signed
date signed
Approved by: _ _ MbOeN
2 / Bl#1
t.
L. NcLaoe, Unter
Heactor
date signed
Projects Section 2B
Inspection Summary:
Report 50-352/82-03 and 50-353/82-02 perfomed January 11-29, 1982.
Areas Inspected: A routine, unannounced inspection by the Senior Resident Inspector
of Licensee's actions on Bulletins and previous inspection findings, the corporate
quality assurance program, plant tours, and piping. The inspection involved
46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> at Unit 1 and 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> at Unit 2.
Results: Two violations were identified in the five areas inspected, (violation
of valve manufacturing requirements and failure to perfom inspections, para. 3). ,
Region I Form 12
(Rev. April 77)
8202250266 820209
PDR ADOCK 05000352
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DETAILS
1.
Persons Contacted
Philadelphia Electric Company
D.T.Clohecy,QualityAssuranceEngineer(QAE)
J. M. Corcoran, Field QA Branch Head
F. J. Coyle, QAE
J. P. Evans, QAE
G. R. Hutt, Office QA Branch Head
G. Lauderback, Jr., QAE
M. J. McGill, QAE
R. A. Mulford, Project Manager
Bechtel Power Corporation
C. Berezich, Lead Cable /Tenn. Superintendent
H. D. Foster, Project Field Quality Control Engineer (QCE)
J. M. Kelleher, Electrical Engineer (Cable)
E. R. Klossin, Project QAE
J. B. McLaughlin, Lead Electrical Staff Engineer
K. L. Quinter, Assistant Project Field QCE (APFQCE)
D. Shaw, APFE
D. C. Thompson, APFQCE
M. G. Tokolics, QAE
Nuclear Regulatory Commission
J. P. Durr, Senior Resident Inspector
R. Paolino, Reactor Engineering Inspector
A. Varela, Reactor Engineering Inspector
The above listed personnel attended meetings on January 27 or 29,1982.
Other craftsmen, engineers, quality control technicians, and supervisors
were contacted and interviewed 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
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structure, and surrounding yards and shops. The inspector examined
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completd work, work in-progress, quality control activities, and equip-
ment storage, handling, and maintenance.
He discussed the technical
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aspects of the work with craftsmen, supervisors, and engineers to assure
work was being perfomed in accordance with requirements.
During a tour of the control structure, the inspector observed a
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cable tray (LAG 015), gutter (lCG002), and conduit (1CH036) installation
in the cable spreading room that may not satisfy established separation
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criteria. The cable tray and gutter will house different divisions of 1E
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cables. They are currently 1" apart vertically.
A cable exits from
the top of the gutter and enters the conduit. This will put the cable between
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enclosed raceways, the cable tray and gutter. The cable will travel
approximately 6" in air before entering the open end of the conduit.
This kind of installation does not appear to be pemitted by IEEE-384
or the licensee's specification. The licensee currently plans to verify
cable separation compliance by final inspections. This item is unresolved
pending the establishment of methods to make this and similar installa-
tions acceptable (352/82-03-01).
The remote shutdown panel 10C201 has an open bottom which provides
comunication between panel sections and divisions. This does not appear
to satisfy IEEE-384, paragraph 5.6.6 and 10CFR50, Appendicies A and R,
for fire separation. This item is unresolved pending verification that
the appropriate fire protection design criteria have been satisfied.
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(352/82-03-02)
3.
Previous Inspection Findings
(0 pen) Noncompliance (81-16-01)
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Reference:
Inspection Reports 81-16 and 81-17
The main steam isolation valve body castings do not appear to satisfy
the ASME Draft Code for Pumps and Valves (DCPV). The issues involved
and updated information are as follows:
(1) The welding procedure was not qualified for the post weld heat
treatment (PWHT) temperature range used. The DCPV, Section 314.1.6(c)-
requires that repair welding procedures be qualified in accordance
with the ASME IX Code. The ASME IX Code, Section Q-11,
paragraph V-6, requires that the welding procedure be regaalified if
there is, "a change in the heat treating temperature..." The
Quaker Alloy Procedure, QAP-490, for repair welding was qualified
for a minimum PWHT temperature of 11000F, That procedure also limits
PWHT temperature to a maximum of 13000F. The valve casting repair
welds were PWHT/ tempered at 13400F.
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(2) Nondestructive testing was perfomed before heat treatment.
The DCPV, Section 314, requires, "Non-destructive examinations...
shall be perfomed after any heat treatments required by the
material specification." The valve was nomalized on 12/20/71,
radiographed on 1/18/72, and tempered on 2/12/72.
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The foregoing items are contrary to 10 CFR 50.55a and a violation.
(3) Repairs and heat treatments were not perfomed sequentially in
accordance with the procedure.
The licensee produced an Audit
Finding Sheet, AF No. 13, dated March 21, 1973, which shows that
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the licensee's audit program identified that Quaker Alloy
Casting Company's repair welding procedure was not qualified for
the thickness range for which it was being used.
Based on this
finding and subsequent to fabrication, the casting manufacturer
appended a Procedure Qualification Record (PQR) to " Repair
Welding Procedure for Carbon Steel Castings", QAP 49D. This
would mean that the May 7,1971, revision was in effect at the time
of manufacture. The sequential requirements were not imposed
in this revision. This matter is resolved.
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(4) Because of the number and apparent severity of the unresolved
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items associated with this finding, it appeared that there was a
significant breakdown in the licensee's quality assurance program.
It does not appear now that this is the case with the satisfactory
resolution of all but two items. This matter is resolved.
(0 pen) Noncompliance (352/81-17-02)
The review of Quality Control Inspection Record C-1415-W-1 disclosed that
hold point inspections of full penetration groove weld preheat and interpass
tenperature, paragraph 2.4.a had not been perfomed for welds FPGW 17,18,
19, 32, 33, 36, 37, 38, 43, 44, 45, 46, and 47.
Project Special Provision
Notice PSP G-6.1, Revision 3, " Quality Control Inspection Plans",
paragraph 3.1.5, states that inspection hold points are mandatory and work
shall not proceed beyond where the designated activity is no longer
inspectable. This is a violation.
4.
Licensee's Action on IE Bulletins
The inspector reviewed the licensee's program for processing IE Bulletins.
He examined the documentation supporting the status and/or completion by
Philadelphia Electric Company of actions to satisfy the NRC requirements.
He sampled various documents to verify compliance with the licensee's
procedure for processing IE Bulletins, Appendix X of the Ouality
Assurance Plan.
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The following table lists the IE Bulletins reviewed and the current
status:
IEB
STATUS
REMARKS
74-08
open
The licensee committed to not
using ITE HE-3 molded case
circuit breakers. Subsequent
to his commitment, ITE HE-3's
were received in the hydrogen
recombiner panels.
Licensee will
verify date codes to assure no
defective breakers used.
78-12
closed
Licensee's action complete.
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79-03
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79-04
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79-05
No response required.79-05A
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79-06
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79-09
Licensee's action complete.
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79-11
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79-13
No response required.
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79-15
Licensee's action complete.
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79-17
No response required.
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79-24
Licensee's action complete.
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79-25
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79-26
Open
Although this was for information
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only, it does not appear that the
licensee performed the correlation
of destructive data to the lifetime
calculations as suggested by their
review.
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IEB
STATUS
REMARKS
79-28
Closed
Licensee action complete.
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80-02
80-03
Open
The licensee committed to perfom
inspections upon receipt of the
equipment. There is no evidence
that this commitment was kept.
There does not appear to be a systematic method for assuring that future
comitments to the NRC are kept for Bulletin responser. Further, from
the review of Bulletin 74-08, it also appears that no system exists to
preclude identified defective equipment from being purchased subsequent
to Bulletin issues being fomally closed. This item is unresolved
ending the licensee's review and corrective action implementation.
p(352/82-03-03)
5.
Licensee's Quality Assurance Program (QAP) Audit
The licensee's QAP was audited for compliance with regulatory requirements and
commitments. The audit consisted of a review of the Limerick Quality
Assurance Plan and the Quality Assurance Instruction::.
Specific requirements
and commitments were selected and their implementation verified by
interviews and records review. The audit encompassed the field and main
office branch activities. The audit findings are as follows:
(1) PECO Audit Report No. 240 identified concerns with Bechtel's
Significant Deficiency Report (Construction Deficiency
Reports) procedures. A letter, PECO PLB-12, 409, was generated
in lieu of an audit finding report. The letter requested
corrections to the Bechtel procedures to align the Bechtel/
PECO reporting time frames. The letter requested resolution by
September 1, 1981. There has been no action to date. This item
is unresolved pending completion of actions (352/82-03-04).
(2)
tudit Finding Report No. 213-01 found that the design report
documents supplied by General Electric did not provide objective
evidence that environmental conditions were considered in equipment
design. The NSSS contractor's response was that this infomation
was not required to be supplied in the documentation reviewed. The
licensee closed this finding based on the above response.
The response never adequately answered the question as to whether
the environmental design factors were incorporated into the design
for the equipment. This item is unresolved pending an adequate
response from the NSSS contractor.
(352/82-03-05)
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(3) Quality Assurance Plan, paragraph 1.1.2.3 states that, on an
approximately annual basis, a report will be submitted to the
Vice-President, Engineering and Research for review of
the status and adequacy of the QAP. The last report was issued on
October 31, 1980. The licensee issued a letter, dated January 11,
1982, requesting input from the various QA branches. This item
is unresolved pending issue of the report.
(352/82-03-06)
Except as noted above, it appears that the licensee is executing the
QAP in accordance with regulatory requirements and commitments.
6.
Reactor Coolant Pressure Boundary and Safety-Related Piping
The inspector reviewed portions of the Job Rule JR-M-12, " Fabrication and
Installation of Small Pipe". He observed the partial installation of pipe
SP-HBC-323-E2 and SP-HBB-143-E8.
It was noted that for some of the small pipe drawings inside of containment
that the design pressures and temperatures are less than the values associated
with the design basis accident. For example, HCB-106 and 107 are drains
from tanks designed for 55 PSIG and 300 F while all other piping is
designed for 55 PSIG and 340 F.
This item is unresolved pending further
review by the NRC (352/82-03-07).
7.
Unresolved Items
Unresolved items are matters about which more infonnation is needed to
detennine if they are acceptable, violations, or deviations. Unresolved
items are discussed in paragraphs 2, 5, and 6.
8.
Exit interviews and Meeting
An exit interview was held on January 27 and 29,1982, with members of the
licensee's staff denoted in paragraph 1.
The inspector discussed the
scope and findings of the inspection.
A meeting was held on January 14, 1982 with members of the licensee's staff
and General Electric Company to discuss the technical aspects of the main
steam isolation valve findings, paragraph 3.