ML20050A753
| ML20050A753 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/04/1982 |
| From: | Durr J, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050A741 | List: |
| References | |
| 50-352-82-04, 50-352-82-4, 50-353-82-03, 50-353-82-3, NUDOCS 8204020234 | |
| Download: ML20050A753 (8) | |
See also: IR 05000352/1982004
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U. S. NUCLEAR REGULATORY COMMISSION
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50-352/82:.04
Report No.
50-353/82-03
50-352
Docket No.
50-353
CPPR-106
License No. CPPR-107
Priority
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Category
A
Licensee: Philadelphia Electric Company
2301 Market Street
Philadelphia, Pennsylvania 19101
Facility Name: Limerick Generating Station, Unit Nos. 1 & 2
Inspection at: Limerick, Pennsylvania
Inspection cond cted:
February 1 - 28, 1982
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Inspectors: ]< ,/
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J. P. Durr,~' Senior Resident Inspector-
/ Dite Signed
Date Signed
Date Signed
Approved by:
&bM
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E. C. McCabe, Chief, Reactor
Date Signed
Projects Section 2B
Inspection Summary: Report 50-352/82-04 and 50-353/82-03 perfomed February
i - zu, 1962.
Areas Inspected: A routine, unannounced inspection by the Senior Resident
Inspector of the HVAC subcontractor's quality assurance program , plant tours,
licensee action on previous inspection findings, and 10 CFR 21 reports. The
inspection involved 77.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> at Unit 1 and 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> at Unit 2.
Results:
One violation was identified in the 4 areas inspected, (Failure to
adequately control design changes, para. 3 and 4).
Region I Fonn 12
(Rev. April 77)
8204020234 020315
gDRADOCK 05000352
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DETAILS
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1.
Persons Contacted
Philadelphia Electric Canpany
J. M. Corcoran, Field QA Branch Head
M.J. McGill, QAE
G. J. Moffitt, Engineer - Construction
P. L. Naugle, Engineer
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P. K. Pavlides, Manager - QA
Bechtel Power Corporation
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G. D. Abbey, Subcontrects Engineer (SCE)
T. Altum, Assistant Project Field Engineer (APFE)
A. Arch, APFE
M. J. Baron, Lead Field Welding Engineer
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G. Cerrix, Instrument Superintendent
B. Dragon, QAE
H. D. Foster, PFQCE
H. F. Greenawalt, QAE
J. Honer, Sr. Lead S/C Engineer
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G. C. Kelly, QAE
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E. R. Klossin, PQAE
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J. L. Martin, QAE
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K. L. Quinter, Assistant PFQCE
D. Smolinsky, Lead Pipe Engineer
D. C. Thompson, Assistant PFQCE
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R. E. Weaver, LSME
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A. G. Weednan, PFE
Schneider, Inc.
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T. M. Carroll, Project Manager
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G. A. Heinrichs, QC Manager
The above listed personnel attended exit interviews on February 11 or 25,1982.
Other craftsmen, engineers, quality control technicians, and supervisors were
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contacted and interviewed as the inspection interfaced with their work.
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2.
Licensee's Actions on Previous Inspection Findings
(Closed) Violation (353/78-07-01)
(Closed) Violation
(352/78-11-01) The licensee was discharging
water from construction activities with turbidity levels in excess of
Construction Pemit allowed levels. The licensee analyzed the rate at
discharge and the turbidity level relative to the Schuylkill River fiow
and determined that there was no adverse environmental impact.
In
addition, he eliminated the direct discharge of water to the Schuylkill
River and instructed the responsiMa superintendent in the proper
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disposal of dewatering operatior.
The subcontractor responsible for this violation has completed his work
at the site and no further dewatering operations will be perfomed by him.
The inspector toured the site on February 17, 1982, and verified that
settling basins are functional and dewatering appears to be controlled.
He also verified that the licensee had performed a follow-up audit, N-142,
and surveillance, C-172, and corrected all violations.
This item
is closed.
(Closed) Violation (352/79-11-08)
(Closed) Violation (352/81-06-02)
Inspection finding (352/79-11-08)
identified improper welding of heating, ventilating, and air conditioning
An attempt to close this finding disclosed that inadequate
corrective actions were taken. The limited access to the welds in question
precluded meaningful inspections from being performed. The design remedy
was to provide an alternate weld inside the damper.
A verification
inspection by the NRC revealed that where welds were inaccessible for
inspection, the alternate weld had not been deposited. This resulted k the
finding (352/81-06-02).
To preclude recurrence of incomplete corrective actions, the licensee has
changed his system so that findings will no longer be closed out before
committed actions are completed. This will be verified by the NRC as future
violations are resolved.
In addition, the licensee took the following actions to correct the
(1) Reinspected all dampers for weld accessibility.
(2) Welds which were determined to be inaccessible were modified
in accordance with the alternate design.
(3) Retrained the HVAC quality control inspectors regarding procedures
for inaccessible equipment.
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(4) Revised the site inspection procedure, PPM-5.3, to include a re-
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quirement in the in-process inspection procedure to check for
accessibility.
The NRC inspector verified that the above corrective actions were completed.
These items are closed.
(Closed) Unresolved Item (352/80-02-03)
The practice of welding galvanize-
coated shapes to the containment liner was questioned.
A review of the
February 14, 1980 letter disclosed that the licensee perfonned welding tests
of electro-galvanized and hot-dipped galvanized shapes.
No adverse
reactions were noted because of the coating.
The AWS Welding Handbook, 72.13-
72.21, and the AWS Structural Welding Code, 3.2, discuss welding through
galvanized coatings without detrimental effects on the weld deposit. This
item is closed.
(Closed) Unresolved Item (352/80-02-04)
The inspector was concerned
that licensee Audit Finding Reports, Fonn QAF-8, were not routinely reviewed
for reportability under 10 CFR 50.55(e). A review of the licensee's
Quality Assurance Plan, Appendix Z and Exhibit XXXIII, verified that
procedures have been implemented which assure the review of audit findings
for reportability. The Finding Report is required to be reviewed for
reportability and this review documented in block 21 of the report. This
item is closed.
(Closed) Violation (353/80-08-01)
(Closed) Violation (352/80-09-01)
The licensee failed to prevent the
discharge of raw sewage to the Schuylkill River. The licensee determined
that the spillage was caused by an open vent associated with the main
tank inlet pipe. An abnonnally large
flow of sewage escaped from this
vent. The licensee capped this vent to preclude recurrence. The inspector
verified that the vent was capped and discussed the sewage system operation
with the pollution control engineer and plant operators. This item
is closed.
(Closed) Violation (352/80-17-01)
(Closed) Violation (352/81-04-01)
Violation (352/80-17-01) identified
uncontrolled cutting of reinforcing bars (rebar) in a concrete block wall.
Violation (352/81-04-01) identified uncontrolled issue of rebar cutting
drills and improper documentation of cut rebar. The licensee recalled all
rebar cutting drills, and implemented new procedures to control the cutting
of rebar, and performed an analysis of " worst case" walls to assure
structural soundness.
The inspector reviewed the revised Job Rule, JR-G-28, for the committed
program changes and controls.
He verified that the procedure for control
was implemented by examining selected attributes from the Job Rule.
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interviewed the personnel responsible for Job Rule implementation and
confimed that they were knowledgeable of their duties and that appro-
priate reccrds were being kept. During previous plant tour inspections,
the inspector examined several Excavation Check Sheets and verified that
rebar drilling was properly authorized. These items are closed.
3.
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
cmpleted 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 perfomed in accordance with requirements.
During the tours and over a period of several days, welders complained
to the inspector that they were having difficulty with weld porosity
during the first half inch of weld deposit.
Further inquiries by the
inspector revealed that other welders were also experiencing difficulty
with porosity in the initial weld deposits. This was brought to the
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attention of the licensee who acknowledged that similar complaints had
been made to him and that some infomal tests had been perfomed in order
to substantiate the complaint. The tests apparently were satisfactory and
the issue closed.
Based on the welders' statements, the inspector requested further steps
be taken to resolve the issue. The licensee believes that the problem
may be limited to welder technique and will provide additional instruction
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to those encountering difficulty.
This item is unresolved pending
resolution of the problem (352/82-04-03).
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Safety related welds (ASME 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
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were e ployed, required nnndestnictive tests specified, appropriate
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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,
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fitup, and alignment of the parts; proper welding equipnent; purge and
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cover gas flow rates; electrodes and filler materials; appearance of the
weld deposit; evidence of quality control activities; and proper documen-
tation. The following welds were examined:
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Weld No.
Class
System
Status
GBB-111-1/6 FW55
II
Root Pass
Pipe Weld
HBC-182-H901
III
RHR Serv.
Intemediate
water
Weld Passes
In an attempt to close an open item concerning pipe hangers, the inspector
reviewed the Job Rule M-17, " Field Control of Pipe Supports". The Job
Rule, paragraph 5.6.1, pemits the field engineer to deviate from the
hanger detail drawing or the installation specifications during fabrication,
installation, and rework.
In the case of fabrication and installation, the
engineer has 3 days within which to document the change on a Field Change
Request (FCR). For partially installed hangers and hanger rework, he is
not required to document changes u til the completed hanger is submitted
for acceptance to quality control. This practice allows undocumented
design changes to be made and installation to proceed without approved
drawings or procedures. This is contrary to 10 CFR 50, Appendix B,
Criteria III and VI in that:
Criterion III requires the design basis be translated
into drawings and that field changes to these drawings
be controlled.
Criterion VI requires that measures shall assure that changes
to these drawings are reviewed for adequacy, approved for
release, and are distributed to and used at the location
where the activity is perfomed.
The stated and implied requirements are that field design changes must be
documented and controlled before the work proceeds so that the workmen
have clear drawings and instructions to perfom the work with.
This is a violation (352/82-04-04).
The inspector became aware of an excessive rejection rate for pipe hangers
while pursuing the foregoing violation. The licensee is currently exper-
iencing a 50% rejection rate for hangers inspected by quality control.
Discussions with the licensee's staff verified that they were aware of the
problem and taking steps to improve the acceptance rate. The inspector
infomed the licensee that he strongly suspected that the failure to
provide positive controls on the field originated design changes, identifled
above, have contributed to the problem.
The licensee's efforts to improve
the hanger rejection rate will be reviewed in conjunction with the violation.
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4.
Heating, Ventilating, and Air Conditioning (HVAC)
Subcontractor Audit
The NRC SALP Report for the period of October,1979 to September,1980,
identified the subcontractor quality assurance program functional area
as below average.
The HVAC subcontractor's perfomance was the basis for
this finding. Further, the licensee reported a Construction Deficiency
relating to the fabrication and installation of HVAC duct work which
did not meet design drawings.
Based on these findings, an audit of the
HVAC subcontractor's program was perfomed to assess the adequacy of
corrective actions taken by the licensee.
The audit consisted of
selected attributes from the HVAC subcontractor's " Field Nuclear
Quality Assurance Manual" and " Project Procedures Manual".
The audit
verified the implementation of design roviews, organization, welding pro-
cedures, document control, inspection, nonconformance reporting and duct
work installation.
The review of the drawing control process revealed that when design
changes are received from the architect-e: gineer (AE) they are redrawn
in the HVAC subcontractor's fomat. This requires that the redrawn
documents receive another design review by the AE. To expedite the work,
" pick off" sheets are drawn from the design change drawings. The
" pick off" sheets are details of the fabrication which permits work to progress
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while the base document is approved.
There are no provisions in the
program to provide review and control of these " pick off" sheets. This
means that equipment is being fabricated, for a period of time, to
unreviewed and uncontrolled documents. This is contrary to 10 CFR 50,
Appendix B, Criterion VI and a violation (352/82-04-01).
The review of the Nonconfomance and Corrective Action control systems
disclosed that 4 Nonconfomance and Dispor1 tion Reports from 1978 were not
closed. Further, the Corrective Action Report (CAR) log shows 11 CAR's
open from November, 1979 to September, 1981.
The quality assurance manual
does not impose any time restraints for initiating follow-up action by
the responsible parties. The licensee stated that the quality assurance
manual was currently being revised and that a time restraint would be
imposed on CAR follow-up.
The quality assurance manual also states that a " Shop Standard Book" is
prepared by the Lead Draftsman.
This has not been done, however, the
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infomation covered by the Shop Standard is covered by the AE, C-1350
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drawings. These are in use by the field personnel.
The " Shop Quality
Assurance Manual" has recently deleted the Shop Standard requirement. The
licensee stated that the Field Quality Assurance Manual will be revised
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to accurately reflect current practice. These items are unresolved pending
revision of the manual (352/82-04-02).
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5.
IE Circular Review
80-22 Investigation report 352/82-01 identified concerns with the
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licensee's personnel qualification verification program.
The need to perform personnel qualification verification was the
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result of IE Circular 80-22. The inspector verified that the
licensee initiated actions to satisfy the Circular concerns within
PEC0 and its contractors. The licensee, independent of the NRC
investigation, identified problems with a quality control
inspector's credentials and has taken steps to correct the matter.
This item is closed.
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Closecut of 10 CFR 21 Reports _
The inspector verified that the licensee is aware of the following listed
10 CFR 21 items and has initiated corrective action:
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Part 21 No.
Subject
AITS No.80-190
American Warming and
H06000527
80-195
Ventilating Actuator Defects80-333
Colt Industries Emergency
H06000539
Diesel Generator
80-215
American Warming and
H06000614
Ventilation Wiring Defects80-259
MCA Scientific Pressure
H06000671
Switches79-159
GE Connector Crimping
H06000500
80-331
PGCC Flexible Conduit
H070003086
Grounding
H070003087
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Bergen Paterson Snubbers
H06000516
The above items are closed.
7.
Unresolved Items
Unresolved items are matters about which more infonnation is required in
order to ascertain if it is acceptable, a deviation, or a violation.
Unresolved items are discussed in paragraphs 3 and 4.
8.
Exit Interviews
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Exit Interviews were held on February 11 and 25,1982, with members of the
licensee's staff. The inspector discussed the scope and findings of
the inspection.
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