ML20065T150
| ML20065T150 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/21/1990 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9012270286 | |
| Download: ML20065T150 (44) | |
Text
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PHILADELPHI A ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955 65 CHESTERBROOK BLVD.
WAYNE, PA 19087 5691
( * " I " " "
December 21, 1990 3
Docket No.
50-35/
License No. NPF-39 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C 20555 SU8 JECT:
Limerick Generating Station, Unit 1 Response to NRC Inspection Report 50-353/88-202,
" Inspection of Independent Construction Assessment.
Limerick Generating Station, Unit 2"
REFERENCE:
Letter from J. S. Kemper to USNRC, dated March 29, 1989, " Limerick Generating Station Ur.it 2 Independent Construction Assessment. Inspection Report No. 50-353/88-202."
Gentlemen:
HRC Inspection Report (IR) 50-353/88-202 dated January 23, 1989, requested that the applicability of the findings of the Independent Construction Assessment (ICA) for Limerick Generating Station (LGS), Unit 2, and the. findings of.the NRC Inspection Team not identified by the ICA, be evaluated for LGS Unit-1.
This response provides our assessment of the applicability of these findings to Unit 1, as comitted to in the referenced letter.
We have evaluated the findings identified for LGS Unit 2 by Stone and Webster Engineering Company (SWEC) during their performance of ICA, and by the NRC, for their applicability to LGS Unit 1.
Our response addressing the applicability of the Unit 2 SWEC ICA findings to Unit 1 is provided in,.and the applicability of the NRC Unit 2 ICA inspection findings to Unit 1 is provided in Attachment 2.
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i Should you have any questions, or require additional.information, please do no hesitate to contact us.
- 6 b-G. J. Beck Manager-Licensing-Nuclear Engineering and Services _
Attachments cc:
lT.T. Martin,' Administrator.-Region-I.USNRC
'T.:J. Kenny, USNRC_ Senior Resident Inspector, LGS 4
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ATTACINENT 1 Limerick Generating Station (LGS)
Independent Construction Assessment (ICA)
Applicability of Stone & Webster Engineering Corp.
Observations to Unit 1 l
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. Applicability of: Unit.2 Independent Construction Assessment (ICA) findings to Unit'l Concern ~ COR-001 i
i Radiographs of Residual Heat Removal System Loop B. DLA-212-2. FW6 exhibit a crack-like indication that was not identified.
Supporting Information' ASME'III DIV. 1,-subsection NB 5320 Radiographic Acceptance Standard, requires that. welds that are shown by radiography to have any type of crack or: zone of incomplete fusion are unacceptable.
L Contrary'to this acceptance criteria the radiographs.of Residual Heat Removal t
System Loop B. DLA-212-2, FW6 exhibit a crack-like indication that was not identified. -The defect.is located at Station 20, views 10-20 and 20-30.
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Response
This concern is not applicable to Unit 1.
l' l-This observation was determined to be a difference 1.n radiographic interpretation between the Stone & Webster Engineering Corporation (SWEC) Radiographic L
interpreter and the Plant; Architect / Engineer,- Bechtel.-Radiographic interpreter.
-The Bechtel interpretation was accepted by various Philadelphia Electric Company
=(PECo) and Bechtel personnel. This observation was4not=the result of any.-
programmatic breakdown'in radiographic interpretation, i
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Applicability of Unit 2 Independent Construction Asset; ment (ICA) Findings to Unit 1 Concern COR-002 Documentation required on weld card (form WR-5) is missing or recorded incorrectly.
Supporting Information Specification 8031-P-301-2, Paragraph 7.6 requires identification of welder (by welder symbol) to be marked on the pipe. Appendix 3 Paragraphs 6.3 and 7.4.3 require that the Lead Welding Quality Control Engineer (LWQCE) shall enter on the weld card name(s) and symbol (s) of welder (s) who actually performed root and fill.
the welders shall be identified with the portion of the weld which they performed.
Welding filler material control procedure. WFHC-1 states in Paragraph 6.7 that a quantity of weld filler material sufficient for one shift of work shall be issued.
Unused filler material shall be returned per requirements of Table 2 or after completion of assigned welds, whichever occurs first, a.
Contrary to the above, welder G. Laurin (symbol P2W) has identification stamped on the pipe adjacent to DLA-212-2, FW-3 and was issued filler metal for root pass and hot pass only but is not listed on the weld card as performing any welding.
b.
Contrary to the above, welder D. Hedrick (Symbol P1V) was issued weld filler material on 4/30/86 and 5/1/86 for weld no. DLA-212-2, FW-1.
The weld card record shows the aforementioned welder as completing the root pass. However, the weld was not released for welding until 5/13/86. As there was no weld filler material issued to Mr. D. liedrick subsequent to 5/1/86, the time frame for welding and weld filler metal issuance should be investigated for field weld 1 on Dwg. DLA-212-2.
Response
This concern is not applicable to Unit 1.
Some weld card errors due to human error are expected and considered acceptable when considering the large population of weld cards which are manually filled out during the construction process. The Quality Assurance (QA) group conducted regularly scheduled annual audits and periodic surveillance of welding activities during the Construction phase of Unit 1 and Unit 2.
During these sur-111ance activities there has been no unusual frequency of incorrect entries in 81ock 33 of the WR-S reported. Therefore, this observation is not the result of a programatic breakdown in the recording of weld records for Unit 1 or Unit 2.
Applicability of Unit 2 Independent Construction Assessment-(ICA) Findings to Unit 1
' Concern COR-003 Performance of incorrect non-destructive examination (NDE).
Supporting Information Nonconformance Report NCR 11780 was issued to magnetic particle / liquid penetrant (MT/PT) tacking block removal areas for Field Weld 3 on DLA-212-2. The area to be examined included 1" on each side of FW-3 taken from the toe of the weld.
FW-3 is l
-a; transition weld from stainless to carbon steel. NCR 11780 (and USG-MT-9648) indi;ated that MT was performed on both the carbon and. stainless steel sides of i
l the weld.
The following additional factors should be addressed in your response:
USG-KT-9648-itself indicated.that_the magnetic particle examination was o
performed on FW-3 with no additional:information to show that the examination
~ included 1" on each side of the toes of FW-3.
The response to Construction Action Item CAI-004 did not menti.on reexamining o
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.the areas where MI was -incorrectly applied to stainless steel.
Response.
i This concern is not applicable to Unit 1.
The incorrect NDE method was chosen in this case as a result of personnel error.
On Augustil9, 1988, a review of NCRs which were written against 14 dissimilar i
L welds.was done. There were a total of nine NCRs written, with seven of them L
-dispositioned to perform PT, one not requiring HDE, and one (NCR-11780) was dispositioned to MT or.PT the area adjacent to toes of the weld (MT was done).
This is the NCR that generated'this-review. Therefore. this concern is viewed as an isolated occurrence, and is not. indicative of any programatic breakdown in non-destructive examination techniques used at Unit 1 or Unit 2.
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. Attachment;.1 Applicability'of Unit 2 Independent
. Construction Assessment-(ICA): Findings-to Unit-1:
a ConcernICOR-004-E Installation of. incorrect washer material.
Supporting Informat ion
.ShaftsealglandplatesonResidentialHeatRemoval-(RHR) pumps 2BP-202and20P-202 each have one washer on hold down studs that is carbon steel.: Manufacturers' instruction' book-(Bechtel document E11-C-002-K-2.1)-requires the washers to bu-
_A240-304 stainless steel.
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I Response-ThisconcernfisnotapplicabletoUnit.1.
The installation <of the-incorrect washers on Unit.2 equipment was the result of-
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one step..in' the: inspection / verification process ofLinstalling the mechanical seal 1 beingfmissed by Field Engineering and-Quality Control personnel.- An: inspection of-w 1
the fourL(4)' Unit '2 Core Spray Pumps, whose seal gland installation:is-similar-to
~Lthe RHR pumps, was'made and the: installation was found to beLin accordance with.
L design: documents..;This observation is the result of an isolated-case of humant errorJand,dogsinottreflect;any programmatic, breakdown:ofJthez
- inspection / verification process;which was performed on Unit 1.-
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Applicability of Unit 2 Independent ConstructionAssessment(ICA)findingstoUnit1 i
Concern COR-005 Radiographic location markers were vibro tooled on the RT film for the weld.
Supporting Information General Electric (GE) NDE Procedure No.18XA9602, Rev. 3 dated 07/11/80, titled "NDE Procedure Radiographic Examination of Welds," Para. 6.5, states that lead location markers shall be placed on the object being radiographed to provide evidence that the required coverage of the area has been obtained.
Contrary to this requirement the station markers were vibro tooled on the film for the weld:-
Low Pressure Coolant. Injection (LPCI) N178-315 - Thermal Sleeve to Safe End -
Index No. 29 Film No. N17D-315. View S-0 ASME V. Article 2 requires that location markers appear as radiographic images on the film.
Re conse Thlw ncern is not applicable to Unit 1.
This occurrence was shown to be an isolated case on Unit 2 following a review of all 24 radiographic exposures for the LPCI nozzles thermal sleeves where no other location markers were discovered to be vibro-tooled on the film. Additionally, this weld was not required to be radiographed by the ASME Code, which only rcquires surface examination..This observation was not the result of a common incorrect practice and is not indicative of a programmatic breakdown in the non-i destructive examination techniques used at Unit 1 or Unli 2.
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Applicability of Unit 2 Independent ConstructionAssessment(ICA)findingstoUnit1 i
Concern COR-006 k2diographs of welds have indications which have not been documented on the reader sheet as being evaluated.
$_upporting Information GE NDE Procedure No.- 18XA9602 Rev. 3 dated 07/11/80, 'itled "NDE Procedure Radiographic Examination of Welds," states in part L t a standard Radiographic Report form shall be prepared and as a minimum contain film interpretation noting all significant indications, their location and acceptability.
Contrary to this requirement radiographs of the following welds have significant indications, which appear to be film artifacts that have not been documented as being evaluated.
4 LPCI-N178-45 Thermal Sleeve to Safe End Index 20, film No. N178-45
-Views-0-1 thru 5-0 LPCI-N178-135 Thermal Sleeve to Safe End Index 22 Film No. N178-135 Views 1-2, 2-3, 4-5 and 5-0 LPCI-N170-225 Thermal Sleeve to Safe End Index 26. Film No. 178-225-Views 3-4 & 4-5 All films reviewed of the Reactor Pressure Vessel (RPV) Modifications, Safe Ends
- to Nozzles and'1hermal Sleeves to Safe Ends have clip holes from hand processing which scratch radiographic film during hardling. This is detrimental for film archival when handling has already initiated scratch marks on the film.
Risponse This concern is applicable to Unit 1.
-Cause:
During and prior to 1981, common industry practice was to record only the data that was noteworthy to the film reviewer on the reader's sheets.. No definition existed as to what. constituted significant indication. The reader exercised his Judgment based on his experience in complyirs with the specification.
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Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1 flims of the RPV modifications, safe ends to nozzles and thermal s1 cove to safe cnds contain hand processing clip holes because they were not procedurally required to be removed with a corner clipper.
Extent of Condition:
During and prior to 1981, cormon industry practice was to record only that data that was noteworthy to the film reviewer on the reader's sheets. This condition is assumed to be prevalent to varying degrees depending on the reader of radiographs for Unit 1 through 1981.
Hand processing clip holes in the radiographic films for Unit I can be expected to exist except where " corner clipping" occurred.
Significance:
The omission of recording certain radlographic images on the reader's sheets does not indicate the films were not properly evaluated. Our opinion is that the specific examples cited by SWEC were easily recognized as film artifacts and would not typically be recorded. We believe that all significant indications were recorded and evaluated in the context existing at the time of evaluation.
In addition, the specific examples are contractual items not required by the ASME Code.
The radiographic hand processing clip holes have no significance since they are outside the area of interest. Only mishandling of film with clip holes can cause problems.
Corrective Action:
Based on lack of significance as cited above, rm corrective action is required.
Action to Prevent Recurrence:
Present industry practice is to more extensively record data and LGS radiographs after 1981 reflect this trend.
There are no ASME Code requirements regarding clip holes.
Since the clip holes do not obstruct the area of interest, no action is planned.
Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-007 Radiographs of welds have indications that have not been documented as being evaluated.
Supporting information GE NDE Procedure No. 18XA9602, Rev. 3, dated 07/11/80, titled "NDE Procedure Radiographic Examination of Welds," Para. 7.0, states in part that a standard Radiographic Report Form shall be prepared and as a alnimum contain film interpretation noting all significant Indications, their location and acceptability.
Contrary to this requirement radiographs of the following welds have significant indications that have not been documented as being evaluated. Root condition found in radiograph of LPCI N178-225, safe end to nozzle is considered rejectable.
RPV Nozzle Modification LPCI N178-225 -
Safe end to nozzle Index No. 24 Film No. N178-225R1 Views 2-3, 3-4, 4-5, and 5-0.
Rejectable root condition with an abrupt density change at film location marker 5. Ref:
ASME111,ND4424(e)
LPCI N178-315 -
Safe end to nozzle Index No. 28. Film No. N178-315 Views 2-3, 3-4, and 4-5.
Root condition not documented as evaluated.
LPCI N17C Safe end to nozzle Index 17 Film No. N170-45 Views 1-2, 2-3, and 3-4.
Root condition and linear Indications not documented as evaluated.
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- LPCI N178-315 -
Safeendrepair(weldprep)
Index 30 Film No. IA 8 Views A-B - indication approx. 1" long.
3" from Station A not documented as evaluated.
- In addition, Film Report No. 8355 for this radiograph does not contain name of radiographic technician by Specification No. 18XA9602, Para. 7.1.1.
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Response
Applicability of Unit ? Independent Construct'lon Assessment (ICA) Findings to Unit 1 This concern is applicable to Unit 1.
Cause:
During and prior to 1981, connon industry practice was to record only the data that was noteworthy to the film reviewer on the reader's sheets. No definition existed as to what constituted a significant indication. The reader exercised his judgement based on his experience in complying with the specification.
Extent of Condition:
During and prior to 1981, conmon industry practice was to record only that data that were noteworthy to the film reviewer on the reader's sheets. This condition is assumed to be prevalent in varying degrees depending on the reader of radiographs for Unit I through 1981.
Significance:
The omission of recording certain radiographic images on the reader's sheets does not indicate the films were not properly evaluated.' Our opinion is that the specific examples cited by SWEC were easily recognized as film artifacts and would not typically be recorded. We believe that all significant indications were recorded and evaluated in the context existing at the time of evaluation and the weld quality meets ASME Code requirements. The weld quality was found acceptable based on results of an additional visual boroscope exam plus an ultrasonic Pre-
- Grvice Inspection.
Corrective Action:
Based on lack of significance as cited in Significance above, no corrective action required.
Action to Prevent Recurrence:
Present industry practice is to more extensively record data, and LGS radiographs after 1981 reflect this trend.
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Applicability of Unit 2 Independent ConstructionAssessment(ICA)findingstoUnit1 Concern COR-008 Radiographic film has chemical staining from residual thiosulfate, l
Supporting Infornation RHR system piping radiographs, DLA-212-2, fW2, GBB-201-2, FW7, and GBB-201-2, FW-9 show evidence of chemical staining from residual thiosulfate. This is indicative of film'not being processed in accordance with Part !! of Recommended Practice SE-94. BQAM-ASME 111 Paragraph 7220 describes in part that final radiographs are permanent records for items classified as ASME Section 111
-Classes 1, 2. CS or MC. The subjes; radiographs in their existing condition cannot meet permanent record requirements.
Response
This concern is not applicabic to Unit 1.
Investigation of this film with our vendor. U.S. Testing, reiterated that a problem was encountered with automatic film developing at the restart of construction of Unit 2.
The problem existed from february 7, 1986 until June 1, 1986 when U.S. Testing installed a new film processor.- This observation is therefore not applicable to Unit 1 as construction (and therefore radiography of welds) was completed in 198'.
Attechment 1 Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-009 faulty installation of spring nuts.
Supporting _Information Spring nut on Unit 2 cable tray support 13/S7.2 has a cocked spring nut in bottom angle bracket for P-5001 to vertical strut.
R_espon u 1his concern may be applicable to Unit 1.
Although a specific inspection of spring nuts was not performed on Unit 1, a small number of cases of loose spring nuts could exist on Unit 1.
The analysis performed for Unit 2 categorized 143 connections which were affected by incorrectly installed spring nuts into 12 types based on the number of spring nuts used and the configuration of the connections. An enveloping type structural analysis was performed and the results of the analysis indicate that all the computed loads in the bolts are less than the allowable loads. A minimum design safety factor of 2 is maintained for all of the inspected connections with improper installations.
Based on the analysis performed on the varied types of improper connections observed en Unit 2 we have concluded that this analysis would also demonstrate adequacy for similar deficient installations on Unit 1 should they exist.
Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-010 Motor Operated Valve Switch Compartment inadequately scaled.
Supporting Information Valve ilV51-Pf0478 - In the side of the li! alt switch compartment body is a 2" plug (threaded). There is a section of electrical cable through the center of the plug. The cable is cut off flush at both sides of the plug.
Plug is finger tight; environmental qualification (EQ) seal is inadequate.
EU.sponse lhis concern is not applicable to Unit 1.
The 2" threaded plug with cut cable was an abandoned temporary power feed used on Unit 2 for periodic meggering by the Bechtel Long Term Maintenance (LTH) Group (Reference Construction Procedures CP-G-3/CP-E-7). Since the procedure neglected to require the reinstallation of the 2" plug once meggering or permanent power was complete, reinstallation was omitted.
A walkdown was performed of all Unit 2 Motor Operated Valves, 18 additional valves were found to have a temporary connector or no plug at this location. All unacceptable conditions found were located outside the primary containment. This condition was not a concern during the construction of Unit I because of the construction sequencing during that time frame. A walkdown of Unit 1 Motor Operated Valves that have been reworked under the Unit 2 program after Unit 1 initial operations were reviewed and found acceptable, confirming that the initial FM-4 Rework Program, without LIN interface, was acceptable.
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Att achment 1 Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-011 d
Deficient instrumentation tubing installation and cicarance.
Supporting Information A.
Ref. Isometric drawing #fJ-51-04-16A. Tubing llanger #l122 has a loose tube restraint connection (1/2" hex head bolt not tightened).
This has been identified on Bechtel NCR #13838 and Start-Up NCR #5-89-J.
B.
Conduit 2A1131-to TE-49-2N022A is in contact with tubing from connection A-3 of Rack 20-C021.
This condition identified on Start-Up NCR d5-94-J.
C.
Ref. ISO #fJ-42-07-35-C. Sht. I and Sht. 3.
Tubing unions on adjacent lines are in contact. These unions are located between llangers fil21 and 1123. This condition has been identified on Bechtel NCR #13838 and Start-up NCR IS-93-J.
Response
- These concerns are not applicable to Unit 1.
Subsequent to final Unit 2 inspection, various construction activities occurred in the lumediate area where the cited conditions exist and we consider these cctivities to be the causal ~ factor.
Constructicn Engineering personnel performed a walkdown of 15 Unit 2 instrumentation installations consisting of 3400 feet of tubing. The results of the walkdown found that all of these installations were acceptable.
Based on walkdowns perfonned, we do not expect similar conditions to be prevelant elsewhere, and'in consideration of tne insignificance of the specific examples cited we do not consider that additional walkdowns are warranted. Therefore.
- these observations are viewed as isolated instances as a result of construction cctivities in the area and are not indicative of a programmatic breakdown in tubingLinstallation for Units 1 or 2.
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l Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-012 Steve Analysis Tests, AST., C-117, were not performed on aggregates.
S_upporting Information LGS final Safety Analysis Report (fSAR), Table 3.8-12, Page 1 of 2, states testing requirements as follows:
" Minimum Test frequency for Concrete Materials; Material finer than a 200 sieve ASTM C-Il7; once for each 5000 cubic yards of concrete production."
1he tests were not performed on fine or coarse aggregates used in the Reactor Building foundation Mat.
Response
This concern is applicable to Unit 1.
Cause:
Production Testing per ASTM-Cll7 was not required by PSAR.
Extent of Condition:
All concrete production placements performed prior to August 18, 1976 used California Sand Equivalent Test ASIM D-2419-69 versus ASTM C-117.
Significance:
Concrete mix design qualification tests were performed in accordance with ASTM C-117 as required by the FSAR and Specification C-61.
The results of these qualification tests were reported on May 3, 1974 (Ref. BLP-5894).
The results of these tests showed a small percentage of fines and demonstrated the excellent quality of the aggregate used for LGS.
As recommended by ACI 304-73, the California Sand Equivalent test (ASTM D-2419-69 Ref. ACI 304-73 Section 2.1.1) was used for production control of deleterious fine materials, as required by C-61 for every 5000 yards of concrete.
Experience from the early pours indicated that the sand washing was so effective that too many fines were washed out, and therefore Bechtel Engineering recommended less I
extensive washing.
To ensure that the percentage of fines remained within limits.
Applicability of Unit 2 Independent Constructivn Assessment (ICA) Iindings to Unit 1 the C117 test requirement was invoked in Specification 8031-C-61 Revision 5 under paragraph 5 of Section 6.3.3 via Addendum 1 on August 18. 1976. During the period from August 26. 1976 to December 26. 1978, both ASTM D-2419-69 and ASTM C-117 tests were performed.
following the issuance of Addendum #10 to Specification 8031-C-61. Revision 7. no further test per AS1H D-2419-69 was performed after December 26. 1978, and since that time only AS1H C-ll7 tests have been performed for each 5000 cubic yards of concrete.
Corrective Action:
Nonc required based on discussion under " Significance" above.
Action to Prevent Recurrence:
Nonc required.
Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-013 Missing weld on pipe support.
,$upporting Information flare bevel groove weld 11 1/2" long, near side and far side, shown on llanger Drawing GBB-217-Ill3, Rev. 3. has not been made in the field. Total length of Dissing weld is approximately 23".
Rev. 2f1 of Drawing GBB-217-Ill3 was used for the final installation inspection.
Weld documentation for GBB-217-ill3 shows no Quality Control (QC) visual acceptance of the missing flare bevel weld. Ilowever, hanger was accepted by QC as complete on 10/28/87 AHil acceptance 11/24/87, PECo review 11/9/87.
Response
This concern is not applicable to Unit 1.
This concern related to the implenentation/ inspection of as-built hardware drawing revisions to previously as-built hanger design drawings. Quality Control personnel have re-reviewed all Unit 2 large bore as-built drawing revision that have been issued to date (flR-P319-76-20) to detennine if any other inspectable attributes have been overlooked (total reviewed was 1762).
No other instances were found that affected large bore hardware installations; however, 15 software items were identified. The 15 software items were physically reinspected and all items, with the exception of two, were found to be within the installation specification tolerances. 1he remaining two instances were determined to be drafting errors or extraneous information not required by design.
Based on the total re-review of Unit 2 large bore as-built drawing revisions by QC, this finding is not indicative of a progranaatic breakdown in the construction or inspection of pipe supports installed at Unit 1 or Unit 2.
Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 i
Concern COR-014 Improper installation of gasket.
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_ Supporting Information Gasket in companion flanges between BPD-502-21A and duct work PC 498. on Drawing M-1173-1-SSM is alssing on orar corner of the flanges. This it a violation of M-68A-2.-
Response
This concern is not applicable to Unit 1.
This-Unit 2 deficiency was apparently caused by an unauthorized alteration after final installation and QC inspection. An additional 92 companion flanges were inspected on Unit 2 with no other damaged gaskets identified. Therefore, this ccncern is viewed as an isolated occurrence and not indicative of a programmatic breakdown of ductwork installation at Unit 1 or Unit ?.
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i Concern COR-015 Incorrect drawing reference for instrument installation and foreign (oily) substance on flow transmitter.
Supporting information r
A.
Isometric FJ-51-04-16A Revisio: 1 referenced installation detail P034.
instead of F034.
B.
An oily substance was found on flow transmitter FT-51-2N0528 and attached tubing and valves causing dirt and dust to stick.
. Response A.
This concern is not applicable to Unit 1.
The reference to installation detail P034 was a drafting error on an-isometric used for historical purposes only.
The correct detail was used on all installation and. inspection drawings...An additional.164 Unit 2 drawings were reviewed for errors of a similar nature. Three(3)adaitionaldrawings needed a-correction to the installation detail. As' discussed above..the correct installation detail was used in the work packages, therefore, this condition is'not a concern for Unit 1 installed equipment.
B.
This concernLis not applicabic.to Unit 1.
Surface cleanliness was inspected on 333 locally mounted Unit 2 instruments.
In areas whtie construction was complete and the equipment turned over to E
PECo. all-instruments were found to be acceptable. Therefore, this concern
<is determined to be a result of construction activities on Unit 2 only.
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i Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-016 i
Improper bolting torque Supporting Information Manufacturer's Manual for RHR pumps require discharge head flange to shell flange capscrews to be torgoed to:450-475 f t.1bs.
During torque verification of RHR pump 2CF202, the capscrews turned when a torque of-100-250 ft. Ibs. was applied. This does not meet the Manufacturer's-Manual requirements.
- Response This concert may be applicab'le to Unit 1.
- LCS has implemented a Torque and Vibration Monitoring Program for Unit 1 and Unit 2 RHR pumps to detect.and correct any torqueing problems which may develop. A recent-4. heck ons the torque of-the RHR-pump capscrews did not reveal any problems.
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Applicabi-of Unit 2 Independent Construction Assessment'(ICA) findings to Unit 1 Concern COR-017 Battery cleanliness l
Supporting Information 4
-Our' understanding is that you are using Surveillance Test. ST-6-096-902-2 and-ST-6-095-912-2 as guidelines for maintenance up until the time of fuel load.
Paragraph 4.3 in the_ aforementioned procedures require electrolyte spills to be immediately cleaned. C&D batteries Vendor Manual No. 8031-E13-28 in Section 6.10-requires the covers and containers to be clean and dry at all times.
Three (3) battery cells:had water droplets around the fill hole area and forty-three'(43) battery cells h,id a white acid residue around the_ fill holes, on the cap : along the line between the clear container and the cap and on the side rail plastic covers.
Response
.This concern is applicable to Unit-1.:
Personnel-performing hydrometer Surveillance Testt, were re-instructed regarding 1
compliance with procedure c1 caning requirements.
In addition, Routine Test RT. 095-930-0,-"VerifIcatlon of Battery Cleanliness " was written to resolve this; ccncern and requires inspection / cleaning of ' batteries and battery rooms monthly, t
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i Applicability of Unit 2 Independent ConstructionAssessment(ICA) findings >toUnit1 Concern COR-018 i
i fire dampers-improperly identified on drawing.
4 Supporting Infonnation Bechtel Drawing'N-1175 Sil.1 of 2. Rev. 25 shows fire damper. FPD-502-31 installed at the 283'. elevation and at the 253' elevation. The valve at the 283' elevation should be FPD-501-32.
Response-I This concern is not applicable to Unit 1.
i The cause of this Unit 2 observation was' a human error in draf ting. We have reviewed 46 other section views for all 119 FPD's in the Unit 2 Reactor Building and found this condition does not exist on any other drawings.. This substantiates our conclusion that this finding is not indicative of a programmatic breakdown in j
the quality of-draf ting for Unit 1 drawings.-
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Applicability of Unit ? Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-019 Incorrect material size Supporting Information Reference llanger 166 on Schneider Drawing M-1169-2 SSM.
Bechtel Drawing M-1169, Rev. 27 requires the referenced hanger to be per requirements of Drawing C-1397-2 detail 5.
This detail shows the lower gusset plate to be 3/4" thick. The installed plate is 1/2" thick.
Response
This concern is not applicable to Unit 1 The installed 1/2" plate reflects the original design drawing requirements. The actual problem was an individual mistakenly believed the as-built drawing should reflect a 3/4" plate. Therefore he changed the as-built drawing via an FCR to correct the apparent descrepancy, which was then reflected in detail 5 of drawing C-1397-2.
A review of 6 similar hanger installations and 15 associated FCR's which were written by the individual that originated FCR C-11860F, revealed no other material size discrepancies. Therefore, the observed condition is concluded not to be indicative of a programatic breakdown.
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Applicability of Unit 2 Independent Construction Assessment-(ICA) Findings to Unit I
)
Concern COR-020 Faulty installation of condult.
Supporting Information item 1A.
Conduit 200104 has a two-hole strap at Cl-1159. There is a shim positioned between top of conduit and strap. This is not shown on any detail available.
Item 18.
JB-HD78-0918 has a section of flexible metal conduit approx. two feet i
long attached only at junction box end. Other end is left hanging in the air.
t
Response
Item 1A.
This concern is not applicable te U it 1.
' Construction Engineering personnel performed a walkdown of Unit 1 and Unit 2 at conduit-bend. locations where this condition could exist. This support ctnfiguration was seldom utilized.
It was used when no other alternatives existed
'except to support the conduit at a bend. Six 6)additionalsupportswere identified as being of siellar configuration. (Only one of these supports cxhibited a shim, which was previously identified on NCR #5078.
Item 18.
This concern is not applicable to Unit 1.
This Unit 2 concern is due to construction activities in progress. Since the issuance of CAI-061 Revision 0, the abandoned flexible conduit in question aas been removed. The resulting hole in junction box JJB-llD78-0918 was plugged. This tas'not a nonconforming condition, and would have been evaluated by Construction Engineering during the facility walkdown.
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Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-021 Loose cable tray attachment hardware.
Supportirm Information Cable tray 2BCVC03 located approx. 4' west of "30.5" line is attached to the "0"
-line wall by means of bolt / spring nuts to embedded strut. The attachment at Elev.
222' (east side) has two 1/4" thick square washers between strut and siderails to act as a shim; the washers are-free to rotate about the axis of the bolt.
1
Response
This concern is not applicable to Unit 1.
The Unit 2 bolt in question was torqued to 50 ft./lbs. during installation as Lreferenced by QCIR E1261-30-4. There is no record that any rework was performed cn this bolt. The bolt on the west side of the support was checked and found fully -torquede The-condition appears to be an unauthorized bolt torque adjustment by an unknown individual.
Construction QC personnel performed a random walkdown of sixteen supports in the Unit 2 Reactor Building. A total of fifty-four bolts were. verified for torque.
No additional torque deficiencies were identified. Based on this walkdown we do not expect similar examples to be prevalent elsewhere, and do not view this concern as a programmatic breakdown in bolt torqueing during support installation for Unit-1 or Unit 2.
Applicability o' Unit.2 Independent Construction Assessment (ICA) Findings to Unit 1 Concern COR-022 Deficiencies in the Long Term Maintenance Program of permanent equipment have resulted in a lack of maintenance on equipment for approximately five years (1975 to 1981) and equipment not being placed in the Maintenance Program.
,5,3upporting Information Bechtel Construction Procedure CP-G-3, " Procedure for Long Term Storage / Maintenance / Lubrication of Permanent Plant Equipment and Materials Prior to Turnover," requires that long-term maintenance be performed on permanent plant Gquipment from the time it is released for storage or installation until turnover to the Client.
Contrary to these requirements, there are no maintenance records available for the following permanent. plant equipment:
Component' Time Period RHR Heat Exchangers'-
12/72 to 12/73 and 2AE205 and 2BE205 6/76 to 1/81 RHR Pump Shell 20P202 7/75 to 2/81 RHR Pump Shell 2DP202 2/76 to 2/81 RHR Pump Discharge Head 8/75 to 7/77; 10/78
'20P202 was the last PM Check Motor Control Center 20B212 4/78 to 4/81 (0224-R-G)
Battery Chargers 2010103 2/84 to 5/86 and 2820103 20" Valve GBC-GB-M0-51 9/75 to 10/81 2f068A & 8 RHR Suppression Pool S/83 to 9/88 Suction' Strainers 2A1F211, 281f 211, 2C1F211 201f211, 2A2F211, 282f211,
.2C2f211 and 202f211 In addition, the Suppression Pool $ trainers for the High Pressure Coolant Injection (HPCI), Reactor Core Isolation Cooling (RCIC), and Core Spray Systems were not placed in the Maintenance Program when received in May 1983.
Response
i This concern.is not applicable to Unit 1.
1
Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1 Unit 1 equipment was inspected when turned over to PECo and has been maintained in accordance with the Unit 1 Maintenance program. Therefore, we have no reason to suspect any degradation of Unit I components due to improper long term amintenance.
l Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-023 Incomplete construction action on electrical junction boxes, Supporting information Two junction boxes having 4.16 kv circuits are not closed.
2J8013 located under the ceiling and above the 4.16 kv switchgear 20A116 needs a Cover.
2JB880 in the emergency diesel generator room (cell B) needs to be enlarged and permanently enclosed.
Response
These concerns are not-applicable to Unit 1.
The two observed incompleted construction items on Unit 2 were determined to be Sunder construction" and therefore are not indicative of any prograssiatic breakdown on Unit 1 electrical equipment installations.
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Applicability of Unit ? Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-024 Deficient / damaged condition of electrical equipment.
Supporting informatlon RilR Motor "B" Electrical Box 20TB-BP-202 is mounted to motor by means of a 1 1/4" nipple and hub through back of box to motor. Also there are two bolts through back of box that act as spacers to motor surface, one is slightly bent. Box is free to rotate on axis of nipple.
Is this mounting adequate under seismic conditions?
Response
This concern is not applicable to Unit 1.
A subsequent inspection.of.all-(4) four of,the Unit 2 RilR pump motors was p3rformed with all similar installations found secure, therefore, this concern has been determined to be an isolated case of an inadequately tightened spacer bolt on Unit 2 equipment.
The junction box is supported adequately with or without the spacer bolts.
Pictoral evidence (Wyle Test Report No. 58032, July 14, 1976, GE VPF 13929-27-1 Photograph 1, Page 17, available for SWEC review at G.E. offices in San Jose) shows that the motor assembly was seismically tested with the junction box attached only by the nipple and hub; the spacer bolts were not l
installed.
This concern is not indicative of a progransnatic breakdown in the installation methods of electrical equipment for Unit 1 or Unit 2.
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j Applicability of Unit 2 independent Construction Assessment (ICA) findings-to Unit =1 Concern COR-025 I
Discrepant information on vendor drawing to the as-built condition.
Supporting Information,
. Vendor Dwg. 8031-M1-H23-P021 E-002.2-(GE rack wiring diagram) did not agree with as-built condition.
Terminal Bl_ock CC-Points 4 and 5 found Cable 221002A instead of 221C002A Terminal Block BB Points 1 and 2 FoundCable221C006C(correctedfromoriginalAction-Item) instead of 281f061A
Response
This concern is not applicable to Unit 1.
Six (6) additional CE-instrument-racks were+ selected at' random to see if similar I
discrepancies existed. None were-found. Therefore. this concern is viewed as an-isolated occurrence on Unit 2 and is'not. indicative of a programmatic breakdown in.
t GE as-built drawing continuity for. Unit 1 or Unit 2.
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At?achment 1 Applicability of Dait 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-026 Discrepant conditions in a Motor Operated Valve (MOV).
Supporting Information
_MOV-HV51-2f0048 Item 1 (cal item B) There is a loose nut / lug on terminal 10 on fingerbase.
l Item 2 (CAI Item C) Limit switch compartment cover gasket is split in half at upper right corner.
_ Response item 1 This concern is not applicable to Unit 1.
Sixteen (16) additional limit switch compartments in Unit 2 (approximately 10%)
were inspected by Construction Engineering and QC personnel for similar conditions and no discrepancies were found. Therefore. this concern is viewed as an isolated instance and is not indicative of a programmatic breakdown in MOV installations on Unit 1 or Unit 2.
Item 2 This concern is not applicable to Unit 1.
A review of Quality Control Inspection Record (QCIR) H51-7P-HV-2f0048-61-1 indicates the Unit 2 gasket was inspected and accepted with no flaws and installed in the valve limit switch cover. Prerequisite testing was performed in accordance with Inspection and Test Procedure EEll.10 which required inspection of the limit switch compartment for good workmanship (including checking the gasket) prior to reinstallation of the cover. The gasket is only.0312 thick and easily damaged during cover removal. The damage found most probably occurred as a result of the ICA inspection. Site procedures currently address gasket inspection / replacement each time a limit switch cover is removed.
(Reference Drawing 8031-fM-4 Inspection and Test Procedure EE11.10 and Preventative Maintenance Procedure PMQ-500-98).
1
Applicability of Unit 2 Independent ConstructionAssessment(ICA)findingstoUnit1 Concern COR-027 Pipe support not constructed in accordance with drawing.
Supporting Information Bill of materials requires (4) 5 1/2 x 2 7/8 x 3/8" stiffener plates. Visual inspection shows eight plates are installed.
Response
This concern is not applicable to Unit 1.
The Bill of Material quantity for item 5 was specified as (4) on Revision 2 of the Design Drawing.
The stiffener plate detail (Typ. 4 places) on Sheet 2 of 2 specified 2 stiffener plates per location (total 8 required). The incorrect quantity specified in the Bill of Material was a drafting error.
The support detail was specific as to the design intent and subsequently obvious to the installer.
Construction Engineering generated field Change Request (FCR) 17781F during physical construction of the support in order to obtain Project Engineering concurrence that eight plates were required per the stiffener plate detail. The FCR was approved by Project Engineering on 2/4/84.
During the subsequent incorporation of the FCR into Revision 3 of the design drawing, a second drafting error was made in that the correction did not occur.
The correction to the Bill of Material was not made.
The incorrect quantity in the Bill of Material was a drafting error and is unique to GBB-204-H4 as this was not a standard detail. Construction Engineering and QC personnel have reviewed all Unit 2 large pipe hanger (total of 1454) PE-ABR Drawing Revisions on flR P-319-76-20 to identify any additional drafting errors; four (4) additional software errors were identified (less than 1%).
This condition, therefore, is not indicative of a programmatic breakdown in pipe support installation for Unit 1.
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Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-028 Deficiency raceway hardware installation.
Supporting Information There is a cocked spring nut at support C1-1346 for strap on conduit 20L011.
Response
This concern may be applicable to Unit 1.
Although a. specific inspection of spring nuts was not performed on Unit 1. a small number of cases of loose spring nuts could exist on Unit 1.
The analysis performed for-Unit-2 categorized 143 connections which were affected by incorrectly installed spring nuts into 12 types based on the number of spring nuts used and the configuration of the connections. An enveloping type structural analysis was performed and the results of the analysis indicate that all the computed loads in the bolts are less than the allowable loads. A minimum design safety. factor.of.two.(2),is. maintained.foralloftheinspectedconnections.with.
improper installations.
Based on the analysis perfomed on the varied types of improper connections observed on Unit 2 it has been concluded that this analysis would also demonstrate adequacy for similar deficient installations on Unit 1. should they exist.
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Applicability of Unit 2 Independent Coniu uction Assessment (ICA) findings to Unit 1 I
~ Concern COR-029 li Incomplete structural connections.
Supporting Information Two (2) joints on the platform for cooler 2AV-212 are currently connected using two bolts. The original requirement was to make the connection with four (4) bolts. Due to a misfabrication, a f<, sign Change Notice (DCN) was issued to allow
-welding of the joint. The welding was not accomplished. The platform has been final accepted and the two (2) joints are neither welded nor connected using four (4) bolts.
Response
This concern is not applicable to Unit 1.
A sample of thirty-seven (37) Unit 2 QCIRs have been reviewed for completeness of scoping and-inspection for field welding activities- (Reftrence FIR'#C-63-22-56).
The work scope on these QCIRs includes various kinds of steel construction involving field welding.
No discrepancies were found in the sample of thirty-seven(37)QCIRs. Therefore, this find ng is limited to this particular unit cooler and is not indicative of ~a prop ammatic breakdown in the structural supt et fabrication F actices employed on Unft 1 or Unit 2.
F Attadmient 1 1
3 Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1 Concern COR-030 Use of uncontrolled /uncalibrated measuring and test equipment.
i Supporting Information i
10CFR50 Appendix B, Criterion 12, identifies that " measures shall be established l
to assure that... measuring and test devices used in activities affecting quality Gre properly controlled, calibrated and adjusted at specified periods to maintain
-accuracy within' acceptable limits".
- Review of 61-WR5 reports for underground RHR Service Water piping (H8C-507 and
.HBC-509) on Drawings C1072, C1074, C1076 and C1077, shows NDE reports that identify temperature of weld surfaces being examined, but no identification of method of determining temperature, instrument used or calibration date, is shown.
-An-example is offered on NDE. Report-for weld HBC-509-C1074. FW59 that records a 42 F surface temperature. The3DEprocedurg,IPPT 340-3902 Rev. A, Amendments 1 and 2, is qualified between 40 F and 120 F.
In this instance, an uncalibrated temperature measuring instrument may not have the accuracy to allow use of the NDE procedure.
Response
This concern may be' applicable to Unit 1.
The NDE subcontractor also did not maintain the type of thermometer required to
. check temperatures for P1 exams under their calibration procedure-for measuring and test equipment during Unit 1 construction.
An in-depth review of the possibility that PT exams performed on Unit 2 were inadequate was conducted. The-results of this review were to use_the welds as-is.
l There is no: evidence that any questionable liquid penetrant examinations exist on Unit 1, however, based on the review performed on Unit 2 the expected disposition for similar-Unit 1 deficiencies would be "use-as-is".
1
' Attachment 1 Applicability of Unit 2. Independent -
Construction Assessment (ICA) findings to Unit l'
.t LConcern COR-031 Minor hardware deficiencies in a D.C. distribution panel.
Supporting'Information Minor deficiencies listed below were found in 2PPBl.(200102):
Wire to a-receptacle on the left wall was pulled out of receptacle. Two t
receptacles on the right wall have either a set screw loose or missing.
Set screws hold the receptacles.to:the housing.
Response
1-This concern.is not applicable to-Unit-1.
The' minor: Unit _2 deficiencies identified are the apparent result of unauthorized rework in Unit 2 D.C. distribution panel 200102.
The remaining Unit 2 D.C. distribution panels (2AD102, 200102 and 200102) were-L inspected by Construction Engineering for similar conditions and no deficiencies-Ewere noted.-
Therefore, deficiency is not indicative-of a programmatic breakdown in the installation-of electrical equipmentiin Unit 1 or Unit 2.
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Applicability of Unit'2 Independent I
-Construction Assessment-(ICA) findings;to Unit 1 1
Concern. COR-032 a
The compressive strength test' reports-.do not contain all-the required data.
1 Supporting 'I'nformation-s LGS FSAR, Para.-3.8.6.1.2.1,: requires that concrete properties will be verified by J
-testing. -Compressive strength shall be tested in accordance with ASTM C-39.
' Specification 8011-C-61 Paragraph 6.3.9 status,-in part, " Compressive strength
.: samples shall be-: tested in accordance with ASTM C-39."
i
. ASTM C-39,1Section 6 s+ates, in:part, "The report shall include" o-diameter;of cylinder.-in inches cross-sectionalL. areas, in square inches o
-o-umaximum loade in poundst Centrary to these stat'ements the-test reports ~for the Reactor Building Foundation
. Mat. lack this data;;
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(This concern.1s applicable to Unit 1.
Cause:i ETheicontributing cause'for the omission of tubject data.from test: reports'was'that-
--the governing Field Inspection Manualfcontained a mandatory report form which did' E
not specify inclusion!of-the subjectLdata.
u
' Extent of. Condition:'
Test reports prior to: June,1975 were prepared with _old fonns and do not include al1~..the ASTM required entries.
- Significance:-
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Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Test reports contain the calculated compressive strength derived from the measured test load and calculated cylinder area. Although test reports during the period from late 1973 to June, 1975 do not show test cylinder diameter, area, and maximum test load, these parameters were measured and recorded separately in order to calculate the cylinder compressive strength.
Rote that compressive strength of the concrete is the primary design concern. Omission of the above stated three items on the test reports has no impact on the compressive strength, it only prevents checking for any mathematical error in calculation of compressive strength. Compressive strengths are adequate and there is no safety implication.
Corrective Action:
NCR #13811 was generated and has been dispositioned by Project Engineering to "Use As Is" since the compressive strength of the concrete is the primary design criteria. All supplementary records showing diameter, area of cylinder and maximum load have been reviewed and attached to corresponding QCIRs.
fifty (50) of these supplementary records were randomly selected and checked for correctness of the recorded compressive strength on the old form. No error was found on those fifty (50) records.
Action to Prevent Recurrence:
Since all QCIRs prior to June, 1975 include the identified information on supplementary records and the strength requirements of the concrete were correctly determined even though all related variables were not initially recorded on the form no further action is. required.
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Applicability of Unit 2 Independent Construction Assessment ~(ICA) Findings to Unit 1 Concern COR-033 PGCC panel wiring & sealing deficiencies.
Supporting Information PGCC Panel 20C618
-Item 1 Cable 1801/E11A-006 at AAA6 does not have cable sheath inside clamp of plug at J-106.
Item 2 Vendor leads lifted at Points 18 and 19 at (AAA4) Section "B";
they have no tags indicating what or why lifted. Leads are insulated at ends.
Response
This concern is not applicable to Unit 1.
Inattentiveness to detail caused cable 1801/E11A-006 at AAA6 to be improperly s; cured into the plug. connector at the time the cable connector was assembled.
Items 1 & 2: 1100% of the cables in eleven (11) Unit 2 panels (200648, 20C647, 20C626, 20C610, 200669, 200644, 200646, 200619, 20C605 and 200604) were inspected by Construction Engineering Personnel for similar conditions, no deficiencies were
- noted. Therefore, Item 1 is viewed as an isolated case of inattention to detail at the time of assembly and is not indicative of a programaatic breakdown in the i-installation ~of cable connectors on Unit 1 or Unit 2.
L Item'2.was caused by wire / cable terminations which were lifted during l:
'preoperational testing on Unit 2 which were not replaced due to lack of proper tagging.. This condition would have been detected during the system checkout p
portion of the testing program.. LGS Administrative procedure A-42, " Procedure for Centrol of Temporary Circuit Alterations (TCA)," ensures that the-lifting of leads is properly controlled at LGS _ Unit 1.
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Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1 i
Concern COR-034 Grouted-in rods have not attained minimum embediment length requirements.
Supporting Information Four grouted-in rods on baseplate for GBC-204-il4 have embediment lengths of 6 3/4", 6 3/4", 6 7/8", and 6 7/8", as detennined by ultrasonic testing method.
This is contrary to the requirements of drawing C615, Sheet 2, which shows a cinimum embedment length of 7'.
Response
This concern may be applicable to Unit 1.
We are not aware of any specific cases of grouted-in rods not having attained their minimum embedment depth on Unit 1.
A sample of 15% (136) of Unit 2 grouted-in rods were examined for compliance with the minimum specifications for embedment as shown in installation drawings. Thirty-one of these rods do not meet their specification.- An engineering-evaluation of these-cases found each to be acceptable "as-is."
These results suggest that other grouted-in rod installations will, demonstrate the same factors'of safety and satisfy the design requirements of the calculations of record.
Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1
_ Concern COR-035 Code Violations on RilR' fleat Exchanger Radiographs-
-Supporting Information ASME VIII. Division 1, 1968 Edition (as referenced by ASME III Subsection C),
Paragraph UW-51 contains the following requirements:
'1.
-UW-51(c)(3): "If the film density through the weld varies more than minus 15 or plus 30 percent from the density through the penetrameter, then an additional penatrameter will be required for the exceptional area or areas."
2.
UW-51(c)(3): "The H. & D. density through acceptable weld metal shall be 1.3 minimum for single film viewing, and 1.8 minimum for composite viewing of double film exposures."
1 3.
UW-51(c)(5): "The penetrameter shall'be placed adjacent to the weld seam exceptasprovidedforinParagraph(4)."-
The radiographs of'the below: listed RHR-ileat Exchanger welds. Violate the Code for one or more of the following reasons: (a) Density deviation exceeds (minimum 15%)
Ler (plus 30%); (b) Penetrameter/ shim'in area of interest; and.(c) Density below
.l.3.
- 1) 35002T2N1-1 AD914 (a)(b)(c)
- 2) 35002T2N2-l'AD914 (a) 3)35002T2SG4'AD914-(b) t
- 4) 35002T2SG2 AD914 (b)
In addition, the following unsatisfactory practices were observed:
(1)~-
RepairTradiographs are always stapled together with originals; (2)
L Developing clip marks are on film; (3) No date included on film ID i
-(required by. procedure).
Although it may not violate the Code per se, the fact that sharp objects (staples, clip marks on film) exist is likely to degrade film quality.
L The extent of these' conditions is not known, as there were only 5 welds reviewed.
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1 Applicability of Unit 2 Independent-ConstructionAssessment.(ICA)FindingstoUnitl-
. Response This -concern nual be _ applicable for Unit 1.
cThefsubject Unit 2-welds-were determined to be acceptable.
Independent review of f
' the' radiographs in question has confirmed that the radiographs are readable and 1the welds are; acceptable, as confirmed:by ultrasonic reexamination of the suspect-welds. While current more precise radiograph examination techniques might today i
- ra se questions on the literal-Code compliance of these radiographs, the then duly Elicensed Section'III vessel Manufacturer and Authorized Inspector interpreted these radiographs tus acceptable to certify Code compliance for these vessels.
1Therefore, the identified questions on weld radiograph quality are considered insignificant. Land although no Unit I radiographs have been identified as deficient, we~ consider that should-they. exhibit the same type of deficiency an..
t ultrasonic test (UT) of the corresponding welds would yield similarly acceptable results.
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Applicability. of-Unit 2 Independent
-Construction Assessment (ICA)' findings to Unit 1 1,
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- ConcernLCOR-036
.A: structural column anchor bolt has a loose nut.
-Supporting Information A platform' column located near pipe suppcrt H88-218-il37 has a loose nut. Bechtel
-has"identif.ied this column as " column for platform No. 27, located 10'-3/8" east of 27.5 and 2'40"-south of E.at EL 177'-0".
The baseplate is anchored to the foundation slab with four (4) bolts.. Three.(3),
of these bolts are acceptable, with nuts tight and washers installed. One (1)'of s
the bolts hast a loose nut. The nut is 1/2" clear of the baseplate.
!Rasponse 1This; concern.is not applicable to Unit 1.-
' All platform < column base plates-with anchor bolts' requiring snug tight-condition"
^
in the Unit-2 Reactor and Unit 2 Diesel Generator Buildings were inspected and no
' loose nuts were found on~ any additional column base plates. JTherefore, this '
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- single 11nstance of'a loose nut is viewed-as-an isolated event and-not indicative
'of a programmatic breakdown in pipe' support installation for. Unit 1 or Unit 2.
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Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1 Concern COR-037 Incorrect nameplate Supporting Information Instrument Rack 20C021 (G.E. No. H23-P021) contains safety-related instrument 2FT-0078 (G.E. No. E11-N0078) RHR Service Water flow which is safety-related yet the nameplate is white lamicold engraved as follows:
RHR System B H23 P021 Non Safeguard The flow transmitter is safety-related (Ell-H0070) so the following must addressed:
Change nejneplate to yellow lamicoid for safety-related identification and change engraving from non-safeguard.
Response
This concern is not applicable to Unit 1.
Instr.iment rack 20C021 was upgraded as a result of the issuance of FDDR-HH1-3479 in September of 1985. The nameplate which was affixed to the rack was intentionally'left "As-Is" pending implementation of the component labeling program. This is viewed as an isolated occurrence and is not indicative of a prograianatic breakdown in the labeling for Unit 2 or Unit 1.
Applicability _.of Unit 2-Inje:,endent Construction Assessment (ICA) Findings to Unit 1 Concern COR-038--
)
Miscellaneous llouse Keeping Items Supporting Information
-Miscellaneousitems'onsafeguard4KV'switchgearD22 Bus 11600-(20A116) 1.
Considerable dirt and chunks of sealing material are scattered on top of the switchgear.
A' breaker _ hand crank and-a small metal panel (internal protection panel) are also on the top of the switchgear.
2.
Two (2). bolts in bottom cover plate of non-segregated busduct located over cubicle 111609 are loose.
13..
Removable section of the differential CT test switch is missing from front of cubicle 11607 and resulting exposed fingers are dusty.
-Response =
-1.
This. concern is not applicable lto Unit 1.-
i This concern was a--result of Unit 2 construction activity in-the area and is not indicative of condition present in Unit ~1 areas..
- 2. -
This concern is'not applicable to Unit 1.
- All--remaining: Unit 2 non-segregated busduct was inspected with no additional d ucrepancies, noted.. This deficiency is not -indicative of a progransnatic breakdown in busduct' installation on Unit.1 or Unit 2.
3.
This concern is.not applicable to Unit 1.
!This cover wasEremoved'for-Unit 2. testing purposes only. Unit 1 Administrative precedure A41.1 Troubleshooting' Safety Related/ Tech. Spec.
Equipment"whichincludesan_-IndependentVerificationofRestoration(IV0R) assures: proper. restoration ~of equipment to their. pre-work condition and would.
preclude the cover of this cubicle being left unattached on Unit 1.
1 1 Applicability of Unit 2. Independent Construction Assessment-(ICA). Findings to Unit 1-Concern COR-039 i
Potential interference between spring can and structural beam was not evaluated.
Supporting Information GBB-218 H26 spring can is.1/4"-from structural beam. Subsequent evaluation has.
i indicated that this clearance is acceptable, Response.
This concern is not applicable to Unit 1.
This potential interference on Unit 2 was discovered prior to the final pipe stress ~walkdown peing performed on the system. -Had this concern existed on Unit 1-
- during.the construction phase it would have.been detected by the Potential Interference (PI) program-and evaluated / corrected prior to turnover to PECo.
Construction Procedure CP-G-7. paragraph 5.3.1.1.e(4), states that potential
. interferences which are=obviously acceptable based on an evaluation by the
- Construction Engineer do not-require-documentation under =the-Potential Interference Notification.(P.I.N.) Program.
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Attachment l' 1
l Applicability of Unit'.2 Independent:
. Construction _ Assessment (ICA) Findings to Unitil-
~ConceeniCOR-040 !
- Incorrect fillet weld' acceptance criteria.
- Supporting Information
'(
4 a.=
When welded connections are substituted for bolted connections, the QC
. Inspectors are required.to compute the weld sizes to' develop the acceptance criteria. A review of the-calculation per.AISC Manual,. indicates that the fillet weld size should be-3/8" for welds 1A-5A_en platform No. 49A and welds i14-18 on platform No.-57J(Ref.'dwg. C-ll72).
,QCIRsLindicateJan acceptance. criteria for' weld size _of.only 5/16" for-platform _No.' 49A'and,1/4" for platform No. 57._
-b.; ; Clip to embed connection' located-l'-6" south of "II" line is not identified on
/
L QCIR' weld-map ?forf platfom No' 57; 3
/
- Responsei
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=: Acceptance of weld sizes which are less than' required by.AISC when changing
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- from:boltedito welded connections was caused:by the:use of a: conversion table ~i
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'in"a' Unit 2 procedure. which was provided Las; ExhibitLS:in _ Construction
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Procedure-CP-C-9,and a miscalculation by Construction Engineering and QC personnel.< The conversion table was utilized by Construction Engineering _ andl JQC: personnel to determine the appropriate size of-welds to~be applied as a -l' substitute for bolted type: connections. This conversion table was not-utilized onfUnit 17during construction. -
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This concern.is not ' applicable to -Unit l'.
This was anJisolated case of a missed QC inspection on;a Unit.2 weld and is; not indicative: off a: progranniatic breakdown in--structural. installation at Unit ~
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. Applicability of Unit 2 Independent ConstructionAssessment(ICA)findingstoUnitl' Concern COR-041 Incomplete hardware installation Supporting Information Cable 28821232C in Panel OBC 667 is not adequately secured in the area where it terminates to terminal block 00.
Risponse l
This concern is not applicable to Unit 1.
The unsecured cable was,the result of the failure of Unit 2 testing personnel to replace.ty-wrap. removed during Unit 2 preoperational testing. Unit I requires i
that any configuration changes be performed in accordance with procedure A-41.1 t
' Troubleshooting. Safety Related/ Tech Spec Equipment." This procedure includes a-IV0R which assures proper restoration of equipment to their pre-work condition.
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Applicability of Unit 2 Independent Construction Assessment (ICA) findings to Unit 1 Concern COR-042 An incorrect drawing reference
~ Supporting information Drawing No.- C-1136 references various drawings for cross-sectional views of slabs and walls. One cross-section makes reference to a detail as being "Section
. A/ Drawing C-1130 similar" Drawing C-1130 does not exist.
. Response
- This concern is_not applicable to Unit 1.
An' inspection of 200 other Unit'2 drawing revisions revealed no other errors.
.This error and other drafting errors like it are not viewed as indicative of any-programmatic breakdown in the quality of drawings on Unit 1 or Unit 2.
In addition. the impact of = such errors =1s insignificant and thus does not warrant a program of. drawing review.
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Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1 Concern COR-043 Erroneous nameplate data Supporting Information MOV HV51-2F0148 motor nameplate indicates the motor insulation as "(Radiation Ins.
- R")" while the Valve Data Sheet (Attachment 1 to Design Specification P102. Sheet
- 20) indicates it to be Class H.
Response
.This concern is not applicable to Unit 1.
This concern was deemed not valid for Unit 2 therefore it was not inspected for Unit 1.
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l Applicability of Unit ? Independent Construction Assessment (ICA) Findings to Unit 1 Concern COR-044 Unauthorized cable tray attachments Supporting Information In tray 2BCUA25 at EL.-242' there is a cable tray roller attached to the side rail near the point where the tray turns from the vertical to the horizontal.
Response
This concern is not applicable to Unit 1.
The cable tray " roller / clamp" was left in place by Construction Cable Pulling Crews. This type of device is utilized to facilitate bulk cable pulling efforts throughout the plant during construction. The facility walkdown which would have identified this particular item for removal had not yet been performed at the time of its identification.
Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1 Concern COR-045 liardware and housekeeping deficiencies in electrical panels.
Supporting Information CAI Item 1 The unistrut required to brace the 4.16 KV field cables have not been installed in 2BG-502 as shown on Drawing 8031-M-71-249(2). These cables are currently not braced.
CAI' Item 3 Dust is starting to accumulate in the bottom of the back of each section of panel 2BC-514. Also electrical cable measuring tape requires dressing. These panels need cleaning.
Response
CAI Item.1 This concern is not applicable to Unit 1.
An FCR.was generated on 2/15/83 to install the unistrut cross member in Unit I cabinet 1BG-502 only, to address a unique installation difficulty. This FCR was then incorrectly incorporated into the reference drawing and shows these supports required for both Unit 1 and Unit 2 equipment, 18G-502 and 2BG-502, respectively.
Additional unistrut bracing is not required for the support of the ri id #750 MCM cables which terminate inside the reactor cubicles. The G
cables enter through floor penetrations and are supported, as required, to side wall unistrut supports provided within the panel. The cables are formed to the exact position at their termination points to assure that no weight will be realized there. This was not the case with panel 1BG-502 which necessitated the addition of cross member supports.
CAI Item 3 This concern is not applicable to Unit 1.
This condition is a result of ongoing construction-activities on Unit 2 and is not indicative of the cleanliness of Unit 1 equipment.
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Applicability of_ Unit 2 Independent Construction Assessment.(ICA) Findings to Unit 1 Concern COR-046 Hardware and cable deficiencies in electrical panel Suppe ting Information CAI Ite Cable 22KGAlQ was wrapped to another cable for support where it exits the bottom of the panel, not to the panel itself.
(Bay 6)
CAI Item 3-There is a loose cable support bar resting against the left wall positioned diagonal to the floor (Bay 6)
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CAI Item 4-Cable 2BSP0007A with a plug connector is coiled and hung near the top
-of the panel. This cable is believed to be spare.
Leaving this cable in this configuration permits it to sw mg into other panel equipment
-during a seismic disturbance.
(Bay 6)
'CAIItem5finBays1through5several-deviceenclosurebackcovershavebeen removed and left lying at the bottom of the under panel trough.
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Response
- CAI Item 2-This concern is not applicable to Unit 1.
CA1 Item 3-This concern is not applicable to Unit 1.
CAI Item 4-This concern is not applicable to Unit 1.
1 Any work:such as that identified.in CAI Items 1, 2 and 3 performed on Unit 1 will-be controlled by procedure A41.1, " Troubleshooting Safety Related/ Tech. Spec.
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- Equipment" which includes an IV0R to assure proper restoration of equipment to their pre-work condition.
1 CAlfItem'5ThisconcernisnotapplicabletoUit1 n
-The back covers to these devices were removed as a part of the Unit 2-preoperational-testing program.
h Applicability of Unit 2 Independent-Construction-Assessment-(ICA) Findings to Unit 1
-Concern COR-047-Missing nameplate
. Supporting'Information Transformer.20X107 does.not have a yellow lamicold nameplate to signify its
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Response-
-This' concern is not' applicable to Unit 1 I
The Unit 1. equivalent transformers were inspected and found to be properly-Elabeled.
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Applicability of Unit 2-Independent Construction Assessment (ICA) Findings to Unit 1 Concern -COR-048 Obstruction within 2T + 2 distance of PSI /ISI weld.
Supporting-Information Specification 8031-P-319-2 requires that there be no obstructions for a distance cfL2T + 2 inches from Preservice Inspection / Inservice Inspection (PSI /ISI) weld.
Contrary to the above, double U-bolt pipe clamp for snubber DCA-418-H3 is resting partially on FW7 (DLA-212-02).
~ Response This concern is applicable'to Unit 1.
The specification addresses ~ clearance requirements and documentation of pipe support obstructions !n relation to PSI /I5I welds. The-intent of the specif f' cation is' to establish a method of compiling access information for the owner for performing, inservice = inspection.= The information is used in determining which welds will txt examined (in systems where only a-percentage of the total population requires: examination). or in the case'where 100% examination is required, what the scope of work is to remove obstructions. There is no code violation when a part of a pipe support has been installed adjacent to or on top
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l Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1 Concern COR-049 Potential thermal interferences between snubber and various commodities were not evaluated.
Supporting Information GBB-201-H32 snubber is located 3/4" from an instrumentation flex hose.
Instrument tubing is located 3/8" from structural portion of snubber GBB-201-H32.
Instrument tubing support is located 5/8" from structural portion of snubber GBB-201-H32.
Subsequent evaluation has indicated that these interferences are acceptable.
Response
This concern is not applicable to Unit 1.
This potential interference on Unit 2 was discovered prio* to the final pipe stress walkdown being performed on the system. Had this cancern existed on Unit I during the construction phase it would have been detected by the Potential Interference (PI) program and evaluated / corrected prior to turncver to PECo.
Construction Procedure CP-G-7, paragraph 5.3.1.1.e(4), states that potential interferences which are obviously acceptable based on an evaluation by the Construction Engineer do not require documentation under the Potential Interference Notification (P.I.H.) Program. This judgement is confirmed by Project Engineering during the P403 Section 10 seismic walkdown.
Applicability of Unit 2 Independent Construction Assessment (ICA) findings to. Unit 1
. Concern COR-050 Inspection records incomplete.
Supporting Information Inspection records for pipe spools HBC-509-C1074-1 thru 4 have no calibration due date: listed for the P-201 " holiday" tester used. These completed records have been reviewed and accepted by QC.
Response
-This' concern is not applicable to Unit 1.
- The omission of the' calibration expiration date is viewed as an administrative 1Grror in completion'of a Unit.2= form for the following reasons.
- 1. _
-The calibration due dates of measuring and test equipment are retrievable from permanent quality control records.
2.
-These, records also include measuring and test equipment numbers, and-date~of use.
3.
Permanent QA records provided the missing information for the 1
referenced spools 4.
lQC-personnel are trained to verify that measuring and test equipment-used' for acceptance have tui active calibration sticker prior to use..-
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Measuring and test equipment are recalled for recalibration prior: to their expiration date as detailed in QC guidance.
Therefore, this finding is not indicative of a programmatic breakdown in pipe spool testing on Unit'1.or Unit 2.
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Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1 Concern COR-051 Deficiencies with the battery racks installation for batteries 2B10101 & 2820101.
Supporting Information Item 1A.
Para. 3.2.3, Line 10 of Manufacturer's Installation Book for Batteries states, in part, "should only be tightened enough to ensure that they will not work loose - approx. 10-15 ft./lbs, torque." Nut was found loose on the rod at Cell 40-41 (2810101).
Item 4.
Drawings 8031-E-13-17-4 & E-13-18-4 denote dimensions for overhang of bottom rails 0 6.00" and 7.50" respectively. Actual overhang on both battery racks at this end varies between 7.50" and 9.00".
Consequently, the other end overhangs approx. 4.50."
This is addressed on NCR S-73-E.
Response
This concern is not applicable to Unit 1.
Item 1A and 4: All Unit 1 and Unit 2 battery racks have been inspected by Construction Engineering personnel for similar conditions; no deficiencies were noted.
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Applicability of Unit 2 Independent Construction Assessment (ICA) findings to-Unit 1
' Concern COR-052 Inspection records incomplete f
Supporting Information NDE report 1(or HBC-509-C1076-FW1.has no batch number recorded for the developer used.
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Response
- This. concern is applicable to Unit 1.
QC performed:a random sample review of 200 similar reports for proper I
documentation of the batch number. 0nly one-additional report was found to not'
'have the batch number recorded. The isolated omission of batch numbers does not-affcetL the. quality of either the weld or~ associated NDE, and 1s not viewed as' a
-programmatic breakdown in the performance of NDE-reports for Unit 1 or Unit 2.
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Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1 Concern COR-053 Missing component identification Supporting Information In MCC 208218 cubicle 19 for MOV 2f0688, terminals 1, 2 and 3 have no identification as rcquired by Bechtel drawing 8031-E-1412, Sheet 1.4.2, Paragraph 1.21.
Response
This concern is applicable to Unit 1.
The Unit 1 component labeling program-is replacing labeling methods which are easily susceptible to damage with more durable equipment identification methods.
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1 Applicability of Unit 2 Independent Construction Assessment (ICA) Findings to Unit 1 Concern COR-054 Incorrect hardware installed Supporting Information Shunt Trip Device Motor Control Center 20B224 The Shunt' Trip Device in Cubicle 7A wer mounted on the right pole of the circuit breaker contrary to the-information or.
awing E-68, Sheet 2 Rev. 12. Cubicles 7A and 78 should be identical per the dr wing but they are not. Also note.the following:
'The adhesive-sticker attached to the breaker in cubicle 7A contains the following information:
Attachment Ril:
Shunt-Trip
-Style 260904264
-Voltage 12Sv dc-Current.975 amps The: adhesive sticker attached to the breaker in cubicle 78 contains the following information:
- Attachment Lil Shunt Trip Style 2609042G10-Voltage 125v dc
Response
.This concern is not' applicable to Unit 1.
- This condition occurred as a result of an isolated case of repurchasing Shunt Trip davices incorrectly for Unit 2.
No Shunt Trip devices have been repurchased for Unit-1.
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Applicability of Unit 2 Irdependent ConstructionAssessment(ICA)findingstoUnitl' Concern COR-055 t
' Insufficient equipment protection.
Supportinnintornation Some form of-protection (grating suggested) should he put over the duplex-strainer.
- and instrument tubing. located..in' pit in front of terminal box 2ATB-BG501. The strainer and tubing-are subjected to persons stepping on them every. time entrance is made to terminal box 2ATB-BG501.
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Response
'1'his concern'is not applicable to Unit 1.
- The duplex: stainer and instrument pit in question is covered by a pemanent-
'grcting fo. Unit:1 and Unit 2 during normal operatlon. This concern is of a etnstruction nature:only, t
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Applicability of Unit 2 Independent ConstructionAssessment(ICA)findingstoUnit1 Concer,r
.56 l
Equipment n..ot adequately controlled after QC acceptance to protect it from construction damage and to restore and maintain it in the design condition after post acceptance testing.
Supporting Informition The informatioa contained in this observation report is indicative of a potential 1
trend that has been evaluated through a review of the ICA observation reports issued to date.
During our review of the observation reports, the ICA Trending Group has determined that the following OR's represent a concern that care and control of equipment after QC acceptance may not be adequate.
The following items identified on CORs were accepted by QC and subsequently found d3ficient.
It appears that these would have remained undetected or would not have been routinely corrected.
COR-09 Cocked spring nut on tray support COR-10 Improper conduit plug in MOV COR-21 Loose shims cable tray support COR-24 RilR pump motor Jb, bent stand off bolt, box free to rotate COR-26 MOV loose wire lug, daraged gasket
-COR-28 Cocked spring nut conduit support COR-31 Pulled out wire and missing mounting set screws DC Panei 280102 COR-33 Cable not secured in cable clamp COR-51 Loose nut on tic rod on battery re.ck COR-54 Incorrect shunt trip device in mater control center The following items were accepted by QC and subuquently found deficient.
The response to the ors indicates that they would have been routinely corrected by an existing program.
COR-17 Battery cell cleanliness COR-33 Conductors lifted and spared COR-38 Dirt / dust / debris on 4 Ky switchgear, missing bolts.
-missing CT test switch cover
.COR Dirt / dust in Panel 2BG-502/2BC-514 l-COR-46 Loose cable support bar, instrument covers removed, spare cable coiled and hung from panel, one cable tywrapped i
l to another rather than to the panel COR-47 Transformer yellow nameplate fell off I
COR-53 lerminal marking strip torn off
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. Applicability of Unit 2 Independent i
ConstructionAssessment(ICA)findingstoUnit1 i
Response
This concern is not applicable to Unit 1.
The Unit 2 COR.. response is applicable to this ites.
Equipment controls after QC acceptance' arc detailed in the. Unit 2 response to COR 056. -The disposition of the cited items and their significance is also provided
-in that response..The response provides the following conclusion:
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conclude that two relatively aln;e3 unrelated concerns cannot be considered a j
trend..."
Based on our. analysis of the results of your review, the system is working..The system used on Unit 2 is patterned after the Unit 1 program. Unit I has been successfully preoperational, startup, surveillance tested and has.
operated succest'ul'y.for several years and demonstrated-that the developed programs are adequate.
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ATTACIMENT 2 Limerick Generating Station Applicability of Unit 2 Independent Construction Assessment (ICA)
HRC Inspection findings to Unit 1 l
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Applicability of Unit 2 Independent Constructinn Assessment (ICA) HRC Inspection findings to Unit 1 NRC Inspection Report Section 4.2.2.2 Concern The NRC team reviewed the radiographs for Low Pressure Coolant Injection (LPCI)
N17B-225 and LPCI N178-315, nozzle-to-safe-end welds. The team verified root concavity indications un these radiographs that Stone & Webster Engineering Corporation (SWEC) identified during their Construction Assessment. SWEC documented their findings in cal-022. General Electric (GE) responc'ed that the root concavity was four.d acceptable af ter a boroscope inspection, llowever, ASME Code Section 111, HB-4000, required that root concavity be evaluated by film density comparison with the base material.
G.E. should review the subject radiographs and evaluate the root concavity in accordance with the ASME Section III requirements.
Response
This concern is applicable to Unit 1.
Cause:
During and prior to 1981, comon industry practice was to record only that data that were noteworthy to the film reviewer on the reader's sheets. No definition existed as to what constituted a significant indication. The reader exercised his judgement based on his experience in complying with the specification.
Extent of Condition:
As a rtsult of this comon industry practice, this condition is assumed to be prevalent in varying degrees depending on the reader of radiographs for Unit 2 thru 1981.
Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit 1 Significance:
The omission of recording certain radiographic images on the reader's sheets does not indicate the films were not properly evaluated. As stated previously, the root condition of LPC N178-225 was determined acceptable based on a boroscopic examination.
In addition, a preservice UT examination was conducted on the weld and revealed no flaws.
Finally, although radiography of the thermal sleeve to safe end welds were required by contract, we do not consider that they are required by the ASME code.
In the time frame of 1981, our opinion is that the specific exampics cited by SWEC were easily recognized as film artifacts.and would not typically be recorded.
We believe all significantcindications were-recorded and evaluated in the context existing at the time of evaluation and the weld quality meets code requirements.
Corrective Action:
Based on lack of significance as cited above, no corrective action required.
i Action to Prevent Recurrence:
Present industry practice is to more extensively record data, and LGS
- radiographs af ter 1981 reflect this trend.
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Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit 1 NRC Inspection Repoit Section 4.2.2.3
_ Concern SWEC assessed the radiographs of the nozzle-to-shell welds for the "B" loop Residual lleat Removal (RHR) heat exchanger. They identified film densities that did not comply with the density requirements set forth in ASME Section VIII. UW-
- 51. The density requirements stated in part that the density in the area of interest (i.e., the weld) shall be within -15 percent to +30 percent of the density through the penetrameter. The NRC team reviewed the radiographs of the nozzle-to-shell welds for both RilR heat-exchangers. welds 35002TINI and.H2, and 35002T2H1 and N2. The team verlfled SWEC's finding and identified the same-condition with the "A" RilR heat exchanger radiographs.
Failurc to use adequate shim thickness under the pentrameter or to use more than one shinned penetrameter was the root cause of the problem. A secondary contributing factor was the low density in the weld area caused by the weld reinforcement.
Because of the large variation in density between the welds and the penetrameter, it was impossible to assess the quality of the welds.
Response
This concern may be applicable for Unit 1.
The subject Unit 2 welds were detennined to be acceptable by re-evaluation of the radiographs and a follow-up Uf inspect *~m.
Although no Unit I radiographs have been identified as deficient, we consider that if a similar deficiency exists, a UT would verify the welds as acceptable.
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I Applicability of Unit 2 Independent Construction Assessment (ICA)NRCInspectionfindingstoUnit1
>. g NRC Inspectinn Report Section 4.3.2.1 Concern
.(1)
- Three of.four anchor bolts for the lower support columns on RHR heat exchanger J
2A did not have washers as shown on anchor bolt Drawing C-615.
Response
This concern 11s not applicable to Unit 1.
r Clarif,1 cation of.this issue.has been.provided_through.the. issuance of.. Field, 4,.
ChangeRequest(FCR).CC-1561-Awhichmakestheuseofwashersforanchorbolts.
AB-93Cl optional.
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pppilcability of Unft 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit 1 NRC Inspection Report Section 4.3.2.1 Concern (2)'
Paragraph. 4.4.7.1.1 of GE Design Specification 21A9227AT for the RHR heat exchanger stated that installation requirements shall include the following requirements for-bolts:
" Clearance... to allow for radial thermal expansion of the heat exchanger".. Note (1) of Tigure 1 in the vendor (Delta Southern Company) technical manual indicated that the difference between support and mating structure bolt circles was to allow clearance for thermal expansion.
However, GE and Bechtel design-drawings-for the lower support-and Bechtel installation work plans did not-specify any required clearance.
Consequently, the existence or amount of any cicarance_in the installed position was unknown.
f Zero clearance could result in overstress or failure of support structure 4
components during heatup. 'This concern must also be addressed for Unit 1 installations.
= Response
- This concern is not applicable to Unit 1.
An analysis of-the as-built gaps of-the' Unit 1 RHR Heat Exchange Supports has been completed and no shims are required on the support bumpers, p
Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit 1 NRC Inspection Report Section 4.3.2.1 Concern (3)
Additional loads from attached pipe supports and electrical equipment were not reflected on the design drawings for the lower support structure for either R}lR heat exchanger. The NRC inspection team inquired about the existence of an alternate method for assuring that designers would be aware of all loading on these structures for future calculations.
The licensee indicated that no such methods were in use.
Response
This concern is not applicable to Unit 1.
Generally, in the early stages of the structural design of power plants, principal loads for major equipment and structures are reasonably well defined.
Other loads, such as pipe supports, are not known with any degree of accuracy.
Therefore, the design process generally allows for these loads eit.her by conservatively estimating for various additional loads or by selecting members l
sized slightly larger than that required for the known loads. This approach is necessary since final locations and exact design loads are unknown for the pipe suppurt loads until their detailed analyses are performed in later st ges of design. Sheets 16 and 38 of Calculation 101.73, Revision 1, show that l
significantly larger steel sections were used to allow a margin for additional i
j pipe supports and other loads.
l Limerick Project Specification 8031-P-401, " Design Criteria for Design and Documentation of Pipe Supports and Restraints for Pipe 2-1/2 inches and larger"
Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection findings to Unit 1 and 8031-P-366-2, " Specification for As-Built Reconcillation," address the coordination of pipe support loads with the civil engineering discipline.
Specification P-410, Section 4.2.4.2, states that all large pipe hangers shall MY be coordinated with the civil group via a coordination print. Specification P-
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366 addresses the procedure for coordination of small pipe hangers with the civil group. Section 5.4 of Specification P-366-2 states that small pipe supports need to be coordinated only when the attachments are to the structural members W10 or smaller, including channel sections. However, it further states L
that the pipe support group shall exercise good engineering judgement to coordinate other attachments when it appears that there may be some impact to the civil structure. Methods do exist for the coordination of multiple consnodity supports as discussed in Project Specifications 8031-G-21 and 8031-G-28.
In addition, a comparison of heat exchanger reactions and existing pipe attachment loads clearly indicate that the design engineers exercised sound engineering judgement because the incremental load in terms of pcreentage of the
- original load is about 1%. We note that in cases of significant pipe support loads, civil calculations were made to investigate their effects on the structure. Another key consideration is to view the impact of small p:.g support or conduit support reactions in their true relative importance. ThefHR heat exchanger supports are no,t specifically shown to be designed for these small attachment loads, but the calculations do not ignore them; they are implicitly considered in the design process.
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Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection findings to Unit 1 NRC Inspection Report Sectinn 4.3.2.1 Concern (4)
Piping and arrangement design drawings for the RHR pump shaft seal assemblies indicated that the drain port was to be plugged with a steel plug. However, the NRC inspection team found that plastic shipping plugs were actually installed in pumps 2A, 20, PC, and 20. Subsequent discussions between Bechtel Engineering and GE indicated that in addition to removing the shipping plugs, drain lines should have been piped to radwaste drains.
t, field Deviation Disposition Request (FDDR) was generated to request. design. details for this piping and for approval to continue startup testing with-the:present drain port configuration.
This concern must be addressed for Unit 1 installations also.
The licensee initiated NCR 13878 and FDDR M1102 in response to the teams finding.
Response
This concern is not applicable to Unit 1.
The condition is limited to the four (4) Unit 2 RHR pumps. The Unit 1 RHR pump shaft seal assembly drain ports contain steel plugs per current design requirements. The Core Spray (CS) pump's seal is similar in design to the RHR pump and both were manufactured by Ingersoll Rand and supplied by General Electric. The Unit 1 and Unit 2 CS pump seal drain connections are piped to a floor drain in accordance with Bechtel design documents.
Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection findings to Unit 1 NRC Inspection Report Section 4.3.2.1 Concern (5)
Bechtel Design Drawing C-631
" Equipment foundations," specifies the use of Jam nuts or staked threads on the foundation bolts for the standby liquid control (SLC) pumps. Jam nuts were not installed, nor were threads staked on any of the foundation bolts on SLC pumps 2A, 28. and 2C. The licensee initiated NCR-13877 based on this HRC finding.
Response
This concern is applicable to Unit 1.
A Unit I walkdown was performed to verify design basis specifications for anchor bolts on various Reactor and Diesel Building equipment. The following generic disposition was developed for discrepancies found with foundation bolts.
Maintenance to " Rework" all items, including those identified as "to be determined" in attachment 2 of Unit 2 Nonconformance Report (NCR) 13877, as follows.
1)
Add washers whenever hole size is 1/16" greater than bolt size. Whenever washers cannot be added, such as when washer affects thread engagement, resubmit for case-by-case review.
2)
Add additional jam nut or second standard nut for all vibrating equipment and the sliding end of heat exchangers. Whenever nuts cannot be added due to inadequate thread engagement, threads may be staked in accordance with l
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Spec 8031-p-401. Jam nuts need not be added for tanks or other non-vibrating equitwnt.
3)
The as-built condition after ' rework' shall be provided to Nuclear f.ngineering for incorporation into Design Drawings. These details should be provided at one time after maintenance personnel have signed Section 5 of NCR 13877.
4)
NCR L89112-312 (Unit 1) identifies discrepancies in the installation of 1
equipment anchor-bolts, wherein washers and/or jam nuts have been provided
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as required by-the design drawings. Related discrepancies in the installation of Unit 2 equipment.have been identified in PECo audit finding 2N-638.
The significance of the discrepancies identified in-NCR 13877-is suianarized as follows.
I A)
Washers play only a minor role in distributing the pressure due to i
l bolt tension, except where oversized or short-slotted holes are used.
llowever, since we have metal-to-metal contact between the foundation nuts and the associated equipment, there is no concern about equipment operability.
B)
Jam nuts are used to ensure that standard nuts do not becone loose during constant and p olonged vibration.
1)
The lack of jam nuts on heat exchanger is not considered significant since the anchor bolts are not subject to vibration. Jam nuts are provided on the sliding end to maintain a relatively-fixed clearance. Although failure to
Attactment 2 Applicability of Unit 2 Independent Construction Assessment (ICA)HRCInspectionfindingstoUnit1 provide jam nuts could lead to contact, the friction from such contact would be negligible and would not affect the function of the sliding end.
11)
The lack of jam nuts on unit coolers is not considered significant since the equipment has vibration isolators.
The vibration at the anchor bolts is therefore negligible.
iii)
The lack of Jam nuts on pumps was determined to be not significant for the following reasons.
a).
In general.. pumps.nced-to operate.for-only short periods of time in comparison to the plant life, b)
Vibration of pumps are of relatively small amplitude.
Bolt pretension caused by the snug-tightness is considered to exceed the bolt loads due to vibrations, which precludes the loosening of the standard nut.
iv)
The lack of Jam nuts on equipment not addressed above is acceptable either in comparison to the above equipment, e.g.,
turbines, recombiner, etc.), or because the equipment is not subject to vibration, (e.g., tanks).
Based on the above rationale, we have concluded that the failure to provide jam nuts for the Unit 1 equipment installations identified in NCR13877 would not affect equipment operability. This is particularly true due to the fact that there is metal-to-metal contact between the foundation nuts and the associated equipment e identified in NCR 13877.
Nevertheless, the original design required a locking mechanism for the subject nuts, so for Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit 1 enhancement purposes the NCR shall be dispositioned to " rework" the installatic'-
This disposition is consistent with the disposition for the Unit 2 equipment. Since the affected existing installations have already been reviewed for both Units 1 and 2, this concern is satisfied for Unit 1.
Applicability of linit 2 Independent Construction
[
Assessment (ICA) NRC Inspection findings to Unit 1
_ N_B linspection Report'Section 4.3.P.1 s
Cp ern Washers were not installed on any of the eight attachment bolts for unit cooler 2FV211--as-shown on the American Air filter final-Assembly Design Drawing 1070-153890-G.
In addition, two of the angle clips through which these bolts were mounted had been enlarged, as authorized by a FCR. Standard structural practice as detailed -in the American Institute of Steel Construction (AISC) Manual dictated that washers' be used under nuts wherever holes are exposed. Also, one of-the vibration absorber. pad mounting bolts for the fan unit was not fully engagedn NCR 13906 was' initiated by the: licensee to document and resolve this-
' discrepancy..
Response.
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This concern-is applicable to Unit.1.
l The dispositten for the previous-finding (5th concern in 4,3.2.1) also applies
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Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection findings to Unit 1 NRC Ins 9ection_ Report Section 4.3.?.1
_Cuncern Three (3) of four (4) bolts attaching the horizontal brace between the fan suction bell and unit cooler 2fV210 were loose.
This unit cooler was part of the SWEC ICA sample.
Response
This concern is act ap911 cable to l.imerick Unit 1.
A visual inspection was performed on nine (9) Unit 1 unit cooler horizontal braces. All braces inspected appeared tightly bolted and the original paint was undisturbed.
- - - - - - - - - ' ~ - ' - ' - ^ - ^ -
J Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection findings to Unit I NRC Inspection Report Section 4.3.2.1 Concern Washers shown on the foundation anchor bolt design drawing were not installed on the fixed end of fuel pool cooling water heat exchanger 2A and on the sliding ends of fuel pool cooling water heat exchangers 2A, 20 and 2C.
In another example, heat exchanger PC bolt holes had beer. significantly enlarged and were visible around the perimeter of the nut. Jam nuts shown on Bechtel Equipment Foundation Design Drawing C-631 were not installed on the fixed ends of any of
- these heat exchangers.= Balance of-Plant Condition Report M3144 was written by the licensee to document this NRC finding.
Response
This concern is applicable to Unit 1.
The disposition for the 5th concern in section 4.3.2.1 4/ 0 applies to this 3
item.
l i
Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit I r
NRC Inspection Report Section 4.3.2.1 Concern i
Jen nuts on Bechtel Foundation Design Drawing C-631 were not installed on any of 4
- the anchor bolts for the fuel pool service water booster pumps. This condition was also recorded by the licensee on Balance of Plant Condition Report M3144.
Response
This concern is applicable to Unit 1.
' The dispostion for' the 5th concern in section 4.3.2.1 also applies.to this item.-
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Applicability of linit 2 Irulependent Construction Assessment (ICA) NRC' Inspection findings to Unit 1 JiRCInspectionReportSection4.3.2.1 Concern E
-Various pumps and unit coolers did.not have jam nuts installed on the fo I
bolts.
General Note S on Bechtel Design Drawing C-626, " Reactor Building i Equipment Foundations." specified that two nuts were required for anchor b securing vibrating' equipment.-
r
- Response This concern is applicable to Unit 1.
The disposition for the 5th concern in section'4.3.2.1 also applies to this 1
. finding.
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l Applicability of Unit 2 Independent Construction Assessment (ICA)NRCInspectionfindingstoUnit1 NRC Inspection Report Section 4.3.2.1 Concern
.The NRC inspection team reviewed Work Packages (WPs) for the Unit 2 RHR pumps and heht exchangers. Dusing this limited review, the team identified several discrepancies in the documentatiLn and some apparent weaknesses in the control t
and execution of WPs. These observations may point out contributory causes of the hardware discrepancies previsasly detailed.
N
.This inspection primarily focused on-the hardware installation. However, the NRC inspection team was concerned,about-the. condition.of. mechanical-equipment.
WPs and the separete and confusing QC inspection documents. The licensee should review the existing documentation to assure that all aspects of installation and modification of mechanical equipment at Limerick have been completed and that the required documentation exists.
The NRC team also concluded that the policy of considering the WPs as j
nonpermanent QA records creates a potential information gap in the machinery history of the plant's mechanical equipment.
The lack of a clear and detailed machinery history could. hamper long term corrective efforts and does not provide L
an auditable record.
Response
This concern is not applicabic to Unit 1.
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Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection findings to Unit 1 I
1he WP program was not used during construction of Unit 1.
The WP program was instituted in early 1986 about the time of Unit 2 construction was resuted.
All Unit 1 equipment was installed prior to that time.
_. _ _. _ _ _ _ _... ~. _ _ _ _ _ - _... _ _ _ _ _ _ _ _.. _ _ _ _.
h Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit 1 NRC Inspection Report Section 4.3.2.2 Concern s
Two (2) bolts joining the companion angles of duct segments 73A and 80 were loose.
Response
This concern is'not applicable to Unit 1.
An additional 92 companion fl ages were inspected for loose bolts-on-Unit-2 and no' discrepancies were found.:'3herefore,"this< finding is viewed as an-isolated' case and is.not indicative-of a programatic breakdown in the construction of ductwork on Unit 1 or 2.
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Applicability of Unit 2 Independent Construction 4
Assessment (ICA)NRCInspectionFindingstoUnit1 NRC Inspection Report Section 4.3.2.2 Concern A splitter damper was installed at segment 73, but no damper was shown installed at that location on the Bechtel Design Drawing or the Schneider Construction Drawing.
Response
5 This concern is not applicabic to Unit 1.
During the construction phase of Unit 1 various problems were identified with Schneider work practices. As a result of these problems, all'HVAC work was stopped for a' period of time in 1981. Corrective actions were instituted including an aggressive inspection program which was instituted for all completed HVAC work. This inspection program included a three part independent
, inspection by Schneider, Bechtel and PECo personnel. Therefore, we are confident that the above Unit 2 concern is an isolated occurrence and that the above described inspection program assures accuracy of the Heating Ventilacing and Air-Conditioning (HVAC) drawings for Unit'I and Unit 2.
Applicability of Unit 2 Independent Construct lon Assessment (ICA)NRCInspectionfindingstoUnit1 J
NRC Inspection Report Section 4.3.2.2 Concern Tapered washers were not installed between the fasteners and the channel iron frame of a splitter damper, segment 73, as specified in the AISC Manual of Steel Construction. Paragraph 3.2.1 of HVAC Specification 8031-M-68-2 stated that equipment and components shall confom to this standard
Response
This-concern is not applicable to Unit 1.
A review of the cited Unit 2 condition concludes that it conforms to Specification M-68A requirements.~*Per the AISC Manual'of Steel Construction, 7th Edition..Page 5-196 requirement, the use of bevelled washers is to compensate for the lack'of parallelism between mating surfaces. The subject bolt heads and nuts have been verified as achieving sufficient bearing of mating surfaces,- therefore eliminating the need for washers.
. ~ _
Attachment'2
' Applicability of Unit 2 Independent Construction Assessment (ICA)NRCInspectionfindingstoUnit1
.NRC-Inspection Report Sectton 4.3.2.2 Concern 1
-Three(3)tapholesusedforcheckingpressuresandflowsduringsystem balancing.were not: properly sealed after the balancing work. Plugs consisting of bolts with gasket washers were not fully engaged. This situation provided
. potential leakage paths and the possibility that the bolts could back out completely due to vibration during system operation.
Response
i
.This concern is not applicable to Unit'1.
The cited condition is attributable to ongoing Unit-2 Construction Activities:in thatbalancingofthesubjectsystemhadnotstartedatthetimeofthis
[
t inspection. 'The inspector misunderstood ~the Start-up Engineer to say all testing had been completed. Startup Technical fest TTI.10, Appendix A. verifies
- by notation ~ that the. static and; traverse bolts are wrench tight upon completion
~
.of final balancing.-
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Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection findings to Unit 1 NRC Inspection Report Section 4.4.2.1 Concern The NRC team had one concern relating to sister splices made for cadweld testing. Contrary to the requirements of Section 3.8.6.2.2.2 of the FSAR, sister splices were not tested prior to the start of production splices made by cadweld operator 93 for splice numbers 38271 and 41851. A similar concern was also raised by the SWEC reviewer for a different cadweld crew.
Response
This concern is not applicable to Unit 1.
Cause:
The cited Unit 2 condition is attributable to an oversight by Construction Engineering and Quality Control personnel to ensure that sister splices were made prior to production splices when the three (3) day limit was exceeded after the welder requalified.
I Extent of Condition:
A review of 120 records was performed on Unit 2 to inspect for similar conditions; 10 additional discrepancies were noted. We consider that this ratio l
of error is representative of the entire records population.
Significance:
This issue has been evaluated and the conclusion is that it is not significant for the following reasons which are valid for Unit I and Unit 2.
4 nep.' 1bility of Unit 2 Independent Construction Assessment (ICA)NRCInspectionFindingstoUnit1 All welders were prequalified and every 25th splice was pull-tested.
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All-splices were. visually examined.
- Corrective Action
1
-The deficiencies were. documented on tl nit 2 NCR-14244 which has been
' dispositiotied to "Use-As-Is". Therefore, this concern is not indicative of a programatic-breakdown in cadweld activities for Units 1 and 2.
Accordingly, no further actions are needed for Unit 1.
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- Applicability of Unit 2 Independent Construction Assessment (ICA)NRCInspectionFindingstoUnit1
' NRC Insbection Report Section 4.4.2.2 Concern On platform 55,- the'NRC team noted that one bolt might not have enough projection to exclude the threads from the shear plane, as required by Bechtel.
Design Drawing C-1184 Revision 31. PECo should confirm whether this. bolt meets
-the requirements of. the -above mentioned design drcwing.
Response!
- This! concern is not applicable to Unit 1.
An additional 2500 bolts:on Unit 2 were-inspected for similar conditions; 35-i discrepancies were noted. This low percentage of discrepanciestis not
' indicative.ofsa programatic breakdown in structural connections on platforms at
. UnitDl or.E Additionally, these deficiencies identified foi-Unit 2 have been-determined to.be insignificant through engineering avsluation and-have been dispositioned Use-As-Is.
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' Applicability of Unit 2 Independent Construction i
Assessment (ICA) NRC Inspection findings to Unit 1
-NRC Inspection Report Section 4.4.3 Concern-i i
The NRC and SWEC reviews showed that the structural steel platform samples selected conformed to the design requirements shown on the appropriate drawings, except for the missing -connection welds on platform 2AV-212.
However,. the NRC
> team believed that-PECo should perform additional field irspections.to determine whether a generic' problem exists regarding missing connection welds on Limerick
. Unit 2. Structural Steel-connections, i
- Responsef 7This< concern is-not applicable to' Unit.1.
i
.A sample _of thirty-seven (37) Quality Control Inspection. Records (QCIRs) have been reviewed for completeness of scoping and inspection for field welding
-activities (
Reference:
FIR #C-63-22-56)..-Thework-scope.ontheseQCIRsincludes
--variouskinds-ofsteel. construction' involving ~fieldwel' ling.. No discrepancies ^
-were found in the sample of thirty-seven.QCIRs. 'Therefore this finding is a-
. limited to this particular unit cooler and is not indicative of a programmatic i
1 breakdown in the' structural support fabrication practices employed on Unit 2:or
- Unit:1.
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p Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection Findings to Unit 1 NRC Inspection Report Section 4.4.3 Concern The SWEC ICA review for the block walls was comprehensive and adhered to their review plan LK-C-1903. The NRC team believed that from the independent review performed on block wall 104, construction was in accordance with the FSAR
. requirements and is consistent with SWEC findings, liowever, the concerns raised by SWEC regarding construction documentation should be resolved by PECo before a conclusion can be reached on the adequacy of all masonry construction at Unit 2.
Response
This concern is not applicable to Unit 1.
The cittJ Unit 2 condition regarding construction documentation has been resolved in accordance with Stone & Webster Construction Action Item CAI-82
'which stated that all of the records for block wall 104 are in the QC vault and available for review.
l t
1
Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection Findings to Unit 1 NRC Inspection Report Section 4.5.2.1 Concern Vendor installed cabling in several Class IE motor co t
-deficiencies in the bend radius.
n rol centers exhibited The team's examination of motor control centers 2AC224 and 2BC224 (Control panels for the unit hyd
-disclosed wiring between the heater breaker and the motor starte rogenrecombiners) significantly less radius than that required by industry and sit r that exhibited The wires in question were number 4 AWG bunerican Wi e standards.
installed with a radius of approximately one-(l) i re Gage) in size and were L
nch.
the insulation of these wires had buckled and pulled The~ team also noted 1. hat away from the individual conductors because of their excessive. bending.. Similar defi i observed in cubicle 08 of motor centrol center c encies-were 208212 was formed with a radius of approximately 1/2 inch
, in which vendor wiring In response tn this observation, the licensee issued NCR 13 910 to docunent and evaluate the impact of the deficiencies on component and syst Ilowever, based upon the frequency of this observati em operation.
on from a relatively small sample, it-appeared that the licensee should consider conducti vendor wiring in Class IE motor control centers to determi ng a review of significance of bend radius deficiencies.
ne the scope and
' Response The concern identifies two (2) conditions that are u addressed individually.
nrelated and must be As a means of differentiation, they are referred to a concern il and concern #2.
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-Attachment 2'
. Applicability of Unit. 2Lindependent Construction-
~
Assessment-(ICA) HRC Inspection Findings to Unit'1 Response'to Concern il sThis concern is:not applicable to Unit 1.
E
~All. Unit ~1 control panels.provided by-'the vendor in question.were examined.
These panels were found to be free of this condition..
4 Response to Concern'f2 1
-3
'This-concern is not applicable ~to Unit 1.
?The cite (' Unit 2 condition relative to the bend radius' deficiency identified in motor etc rol center'20B212 -is attributable to the.as supplied condition of the
- .venoort: supplied equipment'..
1 UThewirein' question.was'af4;SISwirewithabendradiusofapproximately1/2 Linch.- l The vendor-(Cutler,-llanener) has advised-us that their. standard wire.
bending policy is that the:Inside bend radius is to be no smaller than the-1 outskediameterof-the:cablebeing' bent.:.The f.4: SIS wire har an outside, o
. diameter of:.360 inch and therefore, a.5; inch'inside bend radius is acceptable.
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.Applicabi11ty of Unit 2: Independent Construction-i 7
Assessment'(ICA)NRCInspectionFindingstoUnit1 1
NRC Inspection = Report Section 4.5.2.1 Concern 3
During the examination of motor control center (NCC) n
. 200217, the NRC inspector noted:that cable 2CB21703A in cubicle 03 was improperly terminated., This three-
-. conductor cable was the power feed for the 2A reactor enclosure cooling water
. pump andLwas teminated by. bolted connection to' the breaker teminal bars. The Y
Linspector noted that'the phase 'B lug had been bent-by construction activity 3
~
1 1
Tresulting'in:a;1/2 to 3/4 inch gap between the' lug'and the' terminal bar.
Although circuit continuity! had' been maintained,'this configuration:resulted in la contact "hotispot" which may: lead-to operational problems..The licensee.
Asho'uldi--have reteminated;this cable replacing-or repairing the lugiin question.
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Response-e+,
7Thisiconcern is not: applicable to Unit 1.
,y The? cited. Unit 2 condition has been evaluated;as acceptable. With input from.
- the:BurndbCorporated, the manufacturer of-the lug-in question, Design Change
+
- Notice,iDCH #70, to Drawing.E-1412.has been issued to clarify the criteria-for I
Lbe'nding ofLlugs.
7 It'.is:permissiblefto bend the-Burndy3 type YA. lug up to g
f30,ithe:luglin ~ question was observed to.be bent approximately= 10 and, 0
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0 otherefore 'is acceptable.. Therefore, this concern 1s not indicative of any problems regarding Unit'l-electrical terminations.-
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-Applicability of Unit 2 Independent Construction Assessment _-(ICA)NRCInspectionFindingstoUnit1 r
~NRC: Inspection Report Section -4,5.2.1-a r
Concern
- Duringkheexamination,the-inspectors.notedthatseveralClassIEpenetrations-contained circuits that ' ed both engineered safety features (ESF) and reactor l
protection system (RPS) functions. Additicnally.-the inspectors noted that-several. penetrations contained both Class it and Non Class 1E circuits.
[TheLLGSFinalSafety,AnalysisReport(FSAR)prvvidedrequirementsforthe t
/
.-physical independence or dundant's.ystr in hecuan 8.1.6.1.14.
This section detailed specific physici
' system circuits. These requirements reflected'those specified in Regulatory Guide 1;75 and:Institur f Electrical and Electronics Engineers (IEEE) Standard 4
184-1947, with stated exceptions.-
With regard to. electrical penetrations, the FSAR made, provision for the routing
?
- of Class IE and Non-Class lE circuits through a common penetration. However,.no t
provision was made.for the routing of ESF and RPS circuits or multiple division-
. of ? RPS-circuits through: a commion. penetration.- Consequently, the routing'of both' o
l
'ESF and RPS circuitsJin this.. manner did not appear to meet the intent of the-regulteor 1uide or the FSAR for the-station.
Additionally, Section 5.5-of(IEEE' Standard'384.to which the station is cosmiitted. required that Hon-Class'1E circuits < routed in penetrations containing ClassilE: circuits be treated as associated circuits in accordance with the l-requirements.ofLSection 4.5.. Section 4.5 stated-that associated circuits shall
- comply with one of'the following:
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.Applicabilityof, Unit'2._IndependentConstruction Assessment (ICA) NRC Inspection Findings-to Unit 1 5^
i
-- l.
They shall be uniquely. identified as such and shall' remain with, or be
~
separated the.same as, those Class IE circuits with which they are 7-associated.
2.'
iThey shall be in:accordance'with;(1)'above from.the Class 1E. equipment to
,3
- and --including the. isolation device. Beyond the isolation device, a circuit-is not subject to the requirements of this document provided it-does-not u
again become associated with a Class IE system.
i L 3..- cThey shall be analyzed critested to demonstrate the Class IE circuits are.
E not-degraded below an acceptable level.
4 Y:
The LGS FSAR stated that, associated circuits were not-uniquely identified as-such and were treated and identifiedias* Class-1E"upfto an-. isolation-device.
E. Contrary'toltheseirequirements, the Non-Class lE circuits routed with Class 1E'
- circuits-through common penetrations have not been identried or routed as Class 11E once theysexit;the: penetration.-
8 In-response [tothese= concerns,BechtelProjectEngineering. stated.thatthe-
~
~
cexistingidesign conformed to.the requirements of-the FSAR for,the-. station.
Thei (NRC inspectors believed that: additional evaluation, clarification, >or analysis y+
. W Lwould.be required-before-this-: issue could be closed.-
i e
- Response
-This concern isLnot applicable to Unit 1.
We:have analyzed the cited UnitL2 conditions.and have. concluded'the followina.
l Penetration 20JX1000 y
' Attachment 2 Applicability of Unit 2 Independent Construction Assessment'(ICA) HRC Inspection Findings to Unit 1
-This penetration contains RPS Channel 'Z' cables only, therefore, electrical separation is maintained by redundant RPS, Class IE or Non-Class IE cables routed through different penetration assemblics dispersed around the circumference of the contairment.
Penetration 20JX1038
'This penetration contains:
1-
-Class 1E Divisions B&D instrumentation Cables, and 2.
-Non-Class IE Instrumentation Cable The following conditions apply:
a.
Inside the Penetration Assembly The redundant Class 1E'and Non-Class 1E instrumentation cables are not-routed through comon feed-throughs. The feed-tnrough steel casing forms the j
separation-barriers between redundant Class 1E and Non-Class 1E feed-throughs, iThe size of-'the cables is #16 AWG. Electrical separation is maintained between redundant Class 1E and Non-Class IE cables per E-1406, Section 2.1.2.3, L
" Enclosed: Raceways'and Cable Trays", paragraph a.1.
'b.
Inside the Penetration Box p-l The redundant Class-1E cables are enclosed in stainless steel flexible conduits from the point they leave the feed-throughs up to a connector-inside the Conax isol'ation junction box; Therefore, these are treated as enclosed raceways. The Non-Class 1E-cables are considered dropout cables inside the Conax isolation junction box per E-1406, Section 2.2.
In addition, all the cables in the c
m
Applicability of Unit 2 Independent Construction l
l Assessment (ICA) HRC Inspection Findings to Unit 1 isolation box are #16 AWG. Therefore, separation is maintained between redundant Class 1E and Non-class 1E cables per E-1406, Section 2.2.3, Paragraph
- 1. " Separation Between Dropout Cables and Enclosed Raceway".
Although no RPS cables have been found mixed with ESF or Non-Class 1E cables in the subject penetrations, please be informed that, per E-1406, Section 2.1, Raceway Separation parhgraph 2.1.1.a. Class 1E raceway is defined as ESF and RPS raceways. Therefore, RPS cables are treated as Class 1E and, as such, are separated from Hon-Class 1E and ESF cables per E-1406, Sections 2.1.2.3 and 2.2.3 which is consistent with the FSAR, Section 6.1.6.1.14.a.1.
In addition, a review of the rest of the penetration assemblies for separation has been performed and our findings are similar to those described above.
We conclude that there is continuity between IEEE 304-1974, the L.GS FSAR Section 8.1.6.1.14, paragraph b.8, and E-1406, and proper electrical separation has been maintained. Consequently, there is no indication of a programatic breakdown in physical separation of Class 1E and non-Class 1E cables for Units 1 or 2.
l
n 4
Applicability of Unit 2 Independent Construction t
Assessment (ICA)NRCInspectionFindingstoUnit1 NRC=Inspectlon Report Section 4.5.2.1
' Concern
'The haphazard routing of-cables and conductors in the main control boards made the boards congested and did not reflect the workmanship observed in other plant control panels. This condition appeared to be the result of the large number of
?
GE design changes. issued for these panels. The NRC did not inspect _the panels in detall, and therefore did not identify specific construction deficiencies.-
I
. However.. che: inspectors believed that the. condition of these panels merits-
. s
. additional: attention by'the.llconsee...In-particular,-the. licensee-should assure that cable ~ installation requirements such as bend radius, separatlon -fire stops.;and absence of cable damage, have been. maintained.
n
' Response i
IThis concern is not. applicable to Unit 1.
The cited condition is programmatically addressed as part of the final separation and' color _ coding inspectton of electrical equipment perforneo-by f
Quality Co'ntrol (Q'C) personnel on Unit 1-and Unit 2 in accordence with the-
~
__ requirements of Specification'.E-1412. These inspection attributes include, but l
u
'are.-not: limited to the following.
L Replacement equipment is the correct type and installed in the proper
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-location with no damage.
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--. Consponents_rtmoved to provide access for modification work are properly n
reinstalled.
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Applicability of Unit 2 Independent Construction Assessment (ICA)NRCInspectionFindings-toUnit1 o
Debris-removed.-
Work activities.have been performed without damaga to adjacent components o,.
or material.
0:
Separation of components is adatained.
0:
-Permanent wire I.D. is installed.
o.
Cable / wire-size, type and dressing is correct.
o-
- Correct ~ lugs-or pins are installed.
i
~
.o' 6 nductors are terminated at correct tenninal point and are tight; soldering has been properly performed.
0; Wires are properly _ color coded.
o-
-Separation of wires'and raceways-is correct.
4 L-This.clnspection has been satisfactorily completed on all Unit 1 and Unit 2 Main p
l
- Control' Boards.
i :.
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l 1
l Applicability of Unit 2 Independent Construction Assessment (ICA)NRCInspectionfindingstoUnit1 HRC-Inspection Report Section 4.5.2.1 Concern Valve HV-52-2f001C contained vendor supplied motor leads that appeared to be undersized for the application.
Leads T1, 12. and T3 were number 18 AWG wire supplied by Belden Wire Company and provided interface between the actuator motor and the field-power cable. Additionally, the use of Belden J. Type AWM crosslinkwireinanenvironmentallyqualified(EQ)valvewasquestionedbythe HRC team.
To ascertain whether the identified wire was of the type and size re'211 red for this application, the NRC inspectors requested copies of environme nal reports for this valve. Discussions with PECo and Bechtel personnel indicated that EQ packages had not been completed for the Unit 2 vab<e operators. The inspectors then attempted to revicw EQ packages for Unit i valve operators on the basis of similarity of-design and purchase requirements, llowever, although it was initially indicated that these documents were on site, it was determined that all of the EQ packages were kept in the Philadelphia Office and thus were not
~
nade available to the inspectors.
On the. basis of this lack of information and the questionable type and size of installed wire, the HRC inspectors considered the quality n.J the environmental qualification of valve operator llV-52-F001C to be indeterminate.
Response
This concern'is not applicable to Unit 1.
Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection findings to Unit 1 Limitnrque has informed us that the Peerless AC Motor, (Serial Number UA54184WM) and the Belden motor leads are qualified in accordance with their Qualification Report B0003. Therefore, this concern is not indicative of any problems regarding Unit 1 motor leads.
Applicability of Unit 2 Independent Construction Assessment (ICA) NRC-Inspection findings to Unit 1 NRC Inspection Report Section 4.5.2]
Concern Examination of. valve operator HV-55-2F002 disclosed a discrepancy in the
,t
- termination of cable PDB224188. This cabic was the power feed for the actuator
- motor and was terminated in accordance with the Bechtel connection list.
Functionally the termindclon was correct and reflected the coreductor-to-terminal poirit configuration specified on the connection list. However, the phase-identf ficationidid not match connection list' details'in that Phase ' A'~ and -'B'~
t "had -been reversed =
i, Discussions with' Bechtel personnel ' indicated that phase conductors may be reversed in accordance' with Specification E-1412. Section 4.22 of the specification stated that "for 480V, 3 phase motors the; field may reverse two of
. the 3 phase-conductors'of the motor feeder cable at the MCC'in order to obtain proper rotation of the motor. ' Revision-of the connection list for this change -
3
, is-not required."
- Reversing: feeder cableiconductors to achieve proper motor rotation is a common ;
industry practice. iiowever, such actions should be reflected in design documentsito ensure accurate representation of existing field conditions.
. Without formal-updating of the Bechtel connection lists and wiring dMgrams future system and coraponent modifications may be adversely uffecteo. The licensee:shculd ensure that a'll conductor phase rotations are noted and inccrporated into plant design documents.
Response
u...
Applicability of Unit 2 Independent Construction
- Assessment (ICA) NRC Inspection findings to Unit 1 This concern is not applicable to Unit 1.
The motor leads for Unit 1 equipment have not been color coded in accordance
- with Field Change Request EL-2557-E. However,.it was a common practice durine Unit l' construction to swap-labels on motor leads when they were reversed, thus, maintaining correct phase identification to the motor leads.
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^' plicability of Unit 2 Independent Construction 2.Aent (ICA) HRC Inspection findings to Unit 1 HRC Inspection Report Section 4.5.2.P.
Concern In general, the installation of Class 1E cables was found to be in accordance with specified criteria. The routing of examined cables accurately followed the path shown on engineering documents and QC inspection records. Attributes such as cable size, type, and identification were also specified on design documents.
Ilowever, several cable installations were identified that did not meet the LGS FSAR requirements for electrical separation. The examples observed involved Class 1E' cables that lef t design designated raceways and ran'" free-air" through walls or into electrical equipment.
The inspectors noted that in many instances these cables did not maintain the required physical separation from redundant Class 1E cables and raceways and had not been protected throtgh the use of fire barriers or cable wrap as required.
This issue was discussed with Bechtel personnel to determine the status of the cables in question.
Bechtel's responses indicated that electrical separation would be addressed at the time of facility turnover through the use of Quality Control Instruction (QCI) E-3.0, " Raceway Barriers and Seals." This instruction provided for the inspection of cable and raceway installations to ensure compliance with all attributes of electrical separation.
Specific guidance was provided for inspection of " free-air" cables and the application of approved fire barriers. While the content of this document appeared thorough, the inspectors noted tnat aggressive implementation would be required in order to assure that Class 1E cable ir.stallations met FSAR separation criteria.
l Rosponse
Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Inspection Findings to Unit 1 This concern is not applicable to Unit 1.
The cited Unit 2 condition is programmatically addressed as part of the final facility electrical separation walkdown which aggressively assures cabic separation in accordance with QCI E-3.0.
These inspection attributes include, but are not limited to the following.
o Verify the methods used to meet minimum separation between redundant Class 1E raceway, or~ Class 1E and Non-Class 1E raceway are acceptable.
Verify the methods used.to meet minimum separation between exposed cables-
-o or exposed cable and raceway.
o VerifyLthat dropout cable wrapping has been properly installed where required by design _ drawings.
Verify that the proper type of raceway covers have been correctly installed o
at the required locations.
Verify covers of proper typed are installed on conduit fittings, panels-and o
. boxes.
W. here gaskets are required, verify they haye been provided.
Therefore, this' condition is a result of ongoing Construction Activities prior to final walkdown and is not of concern:for !fnit 1.
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Applicability of Unit 2 Independent Construction
' Assessment (ICA)_NRCInspectionfindingstoUnit1 NRC Inspection Report Section 4.6.2 Concern In the case of pipe support DCA-418-il8, the NRC team measured less than a 1/2 inch gap in the east-west direction between the 3-bolt pipe clamp (part number 6), which moves with the pipe, and the east-side flange of a W6-20 column (part number 8).Thepotentialinterferencewaspreviouslyidentifiedbythelicensee via a Potential Interference Notification (PIN) and Disposition Form (PIN No.
12328,. dated November 21. 1987).
Ilowever,'the PIN cited a gap of 3 5/8 inches versus the 1/2 inch' measured by the NRC team:~Bechtel Project' Engineering had reviewed the PIN and determined that the reported gap was acceptable in view of:
analyzed piping = displacements being less-than the existing gap. The NRC inspector's review of the as-analyzed pipe displacements, however, revealed-that
-seismic displacements as well as thermal pipe displacements exceeded the gap observed during the NRC inspection.
The single finding related to potential piping and pipe support interferences suggested the need for greater emphasis on interference checks in the final stress walkdown inspections-of-piping systems.
-Response
'This concern is not applicable to Unit 1.
The cited Unit 2 condition-is attributable to the fact that Construction Engineering personnel mistakenly transposed dimensions and supplied erroneous
.information to Project Engineering for evaluation on PIN Humber 2328.
-Applicability-of-Unit 2 Independent Construction Assessment (ICA) NRC. Inspection Findings to Unit _1 The existing gap between the pipe clamp and-the east side flange of the W6x20
- column exceeds 1/2. inch.:_ This'was documented on PIN Number 4331 which supersedes PIN number 2328 and was submitted to Project Engineering for evaluation. Project-Engineering has concluded that the 1/2 inch clearance satisfies design requirements.
-This condition would have been identified in the course of the final stress
.walkdown. _ Specification P-403, Section 10.1, indicates'that the purpose of this walkdown Is to review,:by means of a visual inspection of the installation:
a)-
The capability-of the. piping system to perform its design function,-
and b)
Interferences which would prevent free thermal. expansion of the
' piping system.
Inspection attributes of this walkdown include, bu are not limited to the i
'following.-
o.
Piping layout configuration consistent.with that used in the stress analysis.
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io Free-thermal expansion:of the. piping system not blocked by interferences with other commodities, i.e: HVAC,. cable trays, other pipe supports, floor or wall-penetrations, grouted-in penetrations, etc.
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= Existing branch lines have been considered in the stress analysis and l;
are shown on-the walkdown isometric drawings.
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Appl icab 111 ty ' of Uni t ' 2. Independent Construct i on Assessment (ICA)NRCInspectionFindingstoUnit1
-Pipe support type, line of action or location correct with respect to 0-
-.the-stress analysis, o'
'Additten or missing pipe support (s).with respect to the stress analysis.
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' Emphasis has'been placed on the interference checks and formal training sessions have-been conducted to assure program compliance.
- This concern is not indicative of a programmatic breakdown in pipe support Linstallation'on' Unit 1 or Unit 2.
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l Applicability of Unit 2 Independent Construction I
Assessment (ICA) HRC Inspection Findings to Unit 1 HRC Inspection Report Section 4.7.2.1 Concern The team conducted a review of selected Long Term Maintenance (LIM) requirerents as established under Bechtel Procedure CP-G-3, " Storage / Maintenance / Lubrication Requirements for Long Term Storage of Installed Equipment Prior to Turnover.d Revision 8, dated August 23, 1988. This procedure required that, as a minimum, the vendor recommended maintenance would be performed at the required interval.
Deviations from the vendor recommendations were allowed, if supporting documentation was provided to justify the change.
CP-G-3 required, in part, that deviations noted during the performance of LTM activities be documented on either an In-Process Rework Notice (IPRH) or if of a more significant nature, on a Honconformance Report (NCR). This procedure also required that steps be taken to correct the deficiency and that action be taken to prevent-its recurrence.
The team reviewed the list of outstanding preventative maintenance actions for the week of September 23, 1988. One safety-related maintenance action had not been performed within the required time interval.
In reviewing the background of this delinquent maintenance action, the team noted that the pressure in the Hydraulic Control Unit (HCU) accumulators was required to be checked, on a sampling basis, one a month. The total number of HCU's installed in the plant was 185, and the LTM program required checking 4 HCU accumulators each month.
During the review of the maintenance records, the team noted the following facts.
l Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit 1 DATE CONDITION ACTION TAKEN 6/10/88 llCUs-30-19 and 38-47 nitrogen Accumulators recharged pressyr. below minimum acceptable to 25 psig value 7/7/88 flCU's.30-19 and 38-47 nitrogen Accumulators recharged pressure below minimum acceptable to 25 psig valve l
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'8/2/88 lICus' 30-19 and/38-47 nitrei;cn" - " Accumulators recharged-
. pressure below minimum. acceptable. to 25 psig. IPRN 2417-value issued to investigate
. leakage problem
'8/19/88' ilCU's 30-19 and 38-47. nitrogen Accumulators recharged pressure below minimum acceptable to 25 psig. IlCU 38-47 1
g value leak checked with liquid-l soap solution
.8/24/88' ilCUs 30-19 and 38-47 inspected by IPRN 2417 closed out QC. Pressure was within the acceptable range (10-25 psig)
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Applicability of Unit 2 Independent Construction E
W l
Assessment (ICA) NRC Inspection Findings to Unit 1 i
lj
' ill DATE CONDITION ACTION TAKEN r
9/29/88 ilCUs 30-19 and 38-47 checked NCR 13908 issued y
in response to and NRC request.
Pressure in the accumulator W
3 units was 8.2 psig and 0.4 psig
- g muust a respectively e
Vendor Manual C11-0001-K001 required maintaining a nitrogen purge pressure k
between 10-25 psig to prevent corrosion of the llCU accumulator internals. The NRC team noted that no record of the as-found or the as-left pressure was recorded on the Maintenance Action Card-(MAC) for the accumulators in question.
=
with th0 exception of the pressure check performed on 8/19/88. Additionally.
4ypf ep the corrective actici, 'c'cen to correct the leakage problem and prevent its
}gg recurrence was not documented when IPRN 2417 was closed out.
MrWMI Vendor Manual C11-D001-K001, Section 4-19, authorized the use of only two I
approved' leak detection 1lquids. The vendor manual also required rinsing the
~
fittings with demineralized water after the leak check was completed to prevent corrosion of accumulator metals. Ilowever, because no work instructions were used to conduct the leak check, it could not be detemined if either of the g [
f approved leak detection fluids was used. As documented in NCR 13908 a demineralized water rinse was not performed following the leak check made on
[
August 19, 1988.
)
J Vendor Manual C11-D001-K001, Section 3/27,F, specified a torque value of 150 to y
200. inch-pounds for the nitrogen charging connector cap. Ilowever, the MAC card.
j whIch was routinely used to check the accumulator pressure and recharge it
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Attachnent 2 Applicability of Unit 2 Independent Construction Assessment (ICA)HRCInspectionFindingstoUnit1 accordingly, did not specify any tyque values. Additionally, the NRC inspector
-noted that a torque wrench was not used in reinstalling the connector cap on September 29, 1988.
-The team deterutned that the Bechtel Quality Control department failed to identify the llCU leakage problem as a nonconforming condition. The Bechtel QC Department closed out the lower tiered correction document, IPRN 2417, without taking appropriate measures to prevent its rec.urrex e.
It was not until the NRC inspector requested Bechtel to recheck the pressure in the HCOs in questlon that an NCR was issued to resolve the nitrogen leakage problem.
The NRd team reviewed the results of the SWEC ICA effort in the LTM and Procurement areas.
SWEC found some problems in the maintenance records for major RHR components. On the basis of a. review of the LTM program for llCRs and the findings of the SWEC ICA review, the team was concerned about Bechtel's attention to, detail in maintaining the material condition of safety-related components. The attention given the maintenance of-these components was not 4
- consistent with the operational safety importance of the licus.
Response
=This concern is not applicable to Unit 1.
- Unit'1 has been in speration since February 1986. No abnormal problems have developed during the operational phase of the llCus which would indicate any deficiencies in their Long Term Storage prior to Unit 1 operation.
l
l Applicability of Unit 2-Independent Construction Assessment.(ICA)HRCInspectionfindingstoUnit1 NRC Inspection, Report Section 4.9.2.4 Conca-n The NRC inspector reviewed and compared a sample of. hydrostatic and pneumatic pressure tests to the requirements of-the pressure testing procedure CP-M-2 and the ASME code requirements. Documentation for hydrostatic tests 2M-49A-12, 2M-45A-16, 2M-448-10, 2M-45A-59, 2M-45A-10, and 2M-52A-06 was reviewed.
Pneumatic test 2M-83-75 for ilCC-234-E24 and ilCC-234-E25 at 240 psi was observed in progress. During these reviews and observation, two potential problems were identified with the pneumatic test process. First, although the pneumatic test was conducted in accordance with the CP-M-2 procedure and Section 111 of the ASME Code, the leak detection fluid was applied to the pipe welds just before
'the examination for leaks rather than during the examination. This practice reduced the sensitivity for leak detection such that there was a slight possibility that a leak, if present, might not be observed. Second, the leak
' detection fluid (Snoop) was not removed from the stainless steel piping of HCC-234-E24 after completion of the examination. This omission was in conflict with page 1.4-1 of Boiling Water Reactor (BWR) Operations Manual NEDE 20583A, dated November 1978 which reconnends complete removal of Snoop from stainless steel after use.
Response
This concern is applicable to Unit 1.
The inspection using Snoop are conducted in accordance with procedures for l
pneumatic testing which meet the requirements of IsSME 111 NB/NC/ND-6000. Snoop solution is applied to the joints just prior to or at the time of inspection.
The inspectors reapply the fluid if they feel it is warranted.
l Applicability of Unit 2 Independent Construction Assessment (ICA)NRCInspectionfindingstoUnit1.
Snoop is comprised primarily of deionized water containing a surfacant of the alkyl aromatic class. Snoop has less than (1) ppm total: halogens. The total content of the low melting point metals mercury and lead is less than (2) ppe.
' Snoop contains none of the low melting point metals bismuth antimony, tin or zinc. The ' vendor has concurred that Snoop is not deleterious to stainless steel.
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Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection Findings to Unit 1 NRC Inspection Report Section 4.9.2.1 Concern RilR pump differential pressure transmitter PDT-51-2N0588: The team found one of four Unistrut nuts securing the transmitter to the Unistrut channel in rack 20C027 was not fully engaged with the Unistrut track. The bolt was snug and appeared to have been tightened with the Unistrut nut misaligned. Bechtel prepared a work package to correct the discrepancy during this inspection.
The team. identified 11 instruments with at least one loose or misaligned Unistrut mounting nut. These-QC accepted installations did not meet.the requirements of Bechtel Specification M-830-G0000, paragraph 8.7.
On the basis of this NRC finding, Bechtel instrument engineers performed a walkdown inspection of all. Instrument racks in Unit 2 to determine the extent of the deficiency and to identify additional misaligned Unistrut spring nuts.
Bechtel wrote Startup Nonconformance Reports 283C-385/S-132-J and 2SlA-673/S-133-J to document and resolve the discrepancies. The NRC inspector reviewed the Startup Nonconformance Reports and determined that they adequately resolved the technical issue, llowever, the team believes that the root cause determination for such a large number of deficiencies in installations that were inspected and accepted by QC should be evaluated, and measures should be taken to prevent recurrence.
Response
This concern is applicable to Unit 1.
I Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection Findings to Unit 1 l
Spring Nuts on seven (7) Unit 1 GE instrument racks were inspected and identified as deficient. An evaluation of the significance of the cited condition is documented in the response to COR-09 and COR-28. This evaluation shows that the cited conditions are acceptable "as-is."
Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit 1 i
NRC Inspection Report-Section 4.9.2.1 i
.Concerni EmergencyServiceWater(ESW)pumppressureswitchPSL-12-001D: The team found two anchor bolts for the baseplate of hanger ill were missing flat washers unoer
-the nuts. Washers were recommended by Section 3.3 of Specification M-8031-C-64 and were present on other installations.
The washers were also reconnended by vendor manuals.
The panel nuts securing the two drain valves to their respectii.e valve brackets were-loose. preventing the brackets-from holding the valves mecurely.
tThe external cover protecting the pressure switch adjustment mechanism was loose.
The level instrument was QC accepted and in service supporting LGS Unit 1
-operation. --TheLlicensee issued Apparent Discrepancy Notification (ADN) Form L-
- 72 to identify and document the discrepancies of this instrument installation.-
Response-The concern identifies two conditions that are unrelated and must be addressed indikidually. As a means of differentiation, they;are referred to as Concern #1 and Concern #2.
Response to Concern #1~
This concern is applicable but not a problem on Unit 1.
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Applicability of Unit 2 Independent Construction Assessment-(ICA) HRC Inspection Findings to Unit 1-Specification M-8031-C-64, paragraph 3.3, states that, " washers may be omitted when... hole size is rio larger than the bolt diameter plus 3/16 inch," and paragraph 3.5 requires bolt holes to be nominal anchor / bolt diameter plus 1/8 inch.
Response to Concern f2 This concern is not applicable to Unit 1.
A suosequent. inspection has been performed of an additional 30 Unit 2 instruments involving-71 valves for loose " Dragon"- drain valve panel nuts at bracket' attachments and pressure switch adjustment mechanism external covers; one isolation valve panel nut was found loose. Therefore. this concern is viewed as an isolated; instance and not indicative of programatic-breakdown in the installation practices of instrumentation on' Unit 1 or 2.
i Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit 1
.NRC Inspection Report Section 4.9.2.1 Concerrl RHR 'B' loop flow transmitter FT-51-2N0158: The teani found one of three support bolts holding the " Dragon 3" valve manifold to the instrument support was loose.
Section 8.19.9 of Construction Specification M-830-0000, Sheet 14, required bolt torque to be in accordance with the manufacturer's specifications.
In the a
absence of specific vendor recoumendations, M-830-G000 provided general
. specifications for various bolt sizes. Birchtel instrument engineers prepared
'Startup;Nonconformance Report 249A-2065/S-129M which documented the discrepancy and approved the corrective action of tightening the bolt to design requirements.-
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Response
- This-concern is not applicable to Unit 1.
A' subsequent inspection of an-additional 24 Unit 2 instrument installations with-valve manifolds installed (a total of 72 bolts) was completed with no
~
discrepancies found. Therefore, this condition is considered isolated and not-indicative of a programatic breakdown in the installation of valve manifold-supports on Unit 1 or Unit 2.
1
Applicability of Unit 2 Independent Construction Assessment (ICA) HRC Inspection Findings to Unit 1 NRC Inspection Report Section 4.9.2.1 Concern TE-76-2238 for unit cooler 2BV210: The field lead terminal lugs at the temperature element had insulation damage on the terminal lug barrels crused by inadequate clearance between the inside of the threaded cover and the wiring and terminal lugs. Three other air cooler temperature detectors had similar or more severe damage on the field wires, detector wire, or terminal lugs and are
' discussed in Section 4.9.2.2.
Response
This concern is applicabic to Unit 1.
This concern is addressed in our response to the first concern discussed in Section 4.9.2.2.
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Applicability ~of. Unit 2 Independent Construction Assessment (ICA): NRCl:-inspection findings to Unit.1
- NRC
- Inspection Report'Sectton 4.9.2.1 4
-Conc'rnL e
l
' Local control'paneltfor unit cooler.2BV210: Thewhiteconductor(wire 388)on point 10Tof terminal board TB-1 was bent excessively. The bend radius of the wire was only 1.5 to 2 times the wire's outside diameter. The NRC inspector was-
' informed by Bechtel and PEco Staff that the-Limerick Station did not have a
= ccrsi;ruction' requirement for the bend. radius of single conductors. The s
inspector was concerned that without a standard, no assurance could be provided-i that vendorarecommendations~and requirements for safety-related wire-bend radli would be maintained'in future modifications and installations.
- L esponse R
This concern is not applicable to Unit 1.
- The cited condition has been evaluated by Project Engineering for acceptability.
-The criteria for: minimum' bending radius _(4 x 0.D.'of conductor) is contained in
'ICEA Standard S19-81 under Ozone Resistance Test. LThis;is.a generic criteria and.it stipulatesithe usefor conductors under worst. case service conditions.
Based upon specific usage, the'following observations have been made, The.ICEA minimum bending radius criteria is based on cables' carrying o
rated current while the conductors in question"are for.
instrumentation circuits and carry only a small fraction of rated current.
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'l Applicability of Unit 2 Independent Construction I
Assessment (ICA)NRCInspectionFindingstoUnit1 o
-The ozone resistance properties of the conductor insulation-used at
' LGS (Ethylene-PropyleneRubber) reduces-theprobabilityofinsulation degradation as does the inherent conductor protection provided by the n
equipment enclosure.
i for these reasons, the installed radius of the subject wires are considered acceptable. Thewiremanufacturer(Fluorocarbon)hasalsogiventheir
-- concurrence in this matter.
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- Although formal bend radius criteria are not provided as a requirement, wires
+
are always trained 4in a craftsman.like manner to avoid' extreme bends which would-cause sharp points.
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4 Applicability of Unit 2 Independent Construction
' Assessment (ICA) NRC_ Inspection Findings to Unit 1 NRC Inspection Report Section 4.9.2.2, Concern The team found wire damage in all four (4) Unit 2 compartment air cooler i
resistance temperature detectors (RTDs): TE-76-223F, 223H, 224F, and 224B. The damage was due to abrasion from the RTD threaded cover that was supposed to protect the wiring and-terminal board. The configuration of the connections 1
' caused the lugs and wires to protrude and come in contact with the cover whenever the cover was installed or removed.'~Although the team found wires or terminal lugs showing evidence of abrasiori from the cover in all four (4) RTDs,
=the most severe damage was noted in TE-76-223F. The insulation of field. wire number 2 in this RTD was worn-to the point of exposing bare conductor. A bare wire _in contact with the terminal board screw and the cover could short circuit the RID and make the air cooler fan control circuit inoperable.
The:NRC-team: identified the problem to PECo and Bechtel staff, along with the concern that the problem may be generic to all air coolers in both Limerick units and RTDs of that type and manufacture. Bechtel issued NCR 13911 to idocument.and correct _the air cooler RTDs with the damaged cables in Unit 2, and ADN Form D-50 to evaluate the air coolers.in Unit 1.
The NRC' inspector reviewed
.the:nonconformance report and the ADN. The NCR, although addressing the specific RTDs, did not address the probable generic nature of the-problem for all similar installations in Unit 2.
The generic nature of_this issue should be addressed for all safety-related RTDs of this type.
Response
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' Attachment 2
.. Applicability of Unit 2 independent Construction Assessment (ICA)'NRCInspectionfindingstoUnit1 This concern is ret ~ applicable to Unit 1.
RTD Connection Loads, terninal blocks and wiring are inspected every 18 months.
-During.these inspections any deficiencies are corrected using the Maintenance Request form (MRF) process. Therefore, any deficiencies on Unit.1 RTDs would have already been corrected.
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Applicability of Unit 2 IWependent. Construction Assessment (ICA) HRC Inspection findings to Unit 1
~NRC' Inspection Report Section 4.9.2.2 Concern
- The team found-that the-instrument tubing supports for drywell pressure transmitters PT-42-2N0918, PT-42-2N094F, and PT-42-2N0508 in rack 20C027
. exceeded the maximum allowable span. Construction Specification M-830-G038..
Note.1, specified a maximum span of five feet (60 inches) for 3/8 inch diameter-tubing. ~The team found that the tubing for these -instruments.had an unsupported span ^of"about 80 inches. - Bechtel instrument engineers confirmed the overspan condition with the NRC-inspector. Since the instruments weru in a rack supplied by G;E., Bechtel staff told the: inspector that the installation would be--
- evaluated in conjunction with G.E.
.l Response.
i This concern;is not applicable to Unit 1.
j
- The Unit 12
- investigation subsequently discovered that only one of the subject
-tubing runs exceeded the ' allowable span. Following additional' analysis this-
- tubing run was detemined to 'be a'dequately supported._ All thirty (30)-Unit 2.GE instrument racks-(approximately 160 bulkhead connections) were reinspected for-
-~'overspan conditions with none identified. Therefore, this concern is viewed as
~an isolated occurrence and is not-indicative of a programmatic breakdown in the installation of instrument tubing on Unit 1 or Unit 2.
Applicability of. Unit 2 Independent Construction Assessment (ICA) NRC Inspection Findings to Unit 1 NRC Inspection Report _Section 4.9.2.2 Concern The NRC inspector found a loose support strap on the instrument tubing bulk-head j
connector for pressure transmitter PT-40-2N055 in rack 20-0073. The inspector also noted that the instrument tubing contacted-safety-related conduit 201059.
Construction Specification M-830-G000, Sheet 14, required torquing of clamp bolts and specified the torque requirements. Section 5.11 of M-830-G000, Sheet
- 7. required instrument'11nes be protected from mechanical loads and wear.
Bechtel prepared;FDDR-J-196 in response to the NRC inspector's finding. The FDDR identified the discrepancy and proposed torquing the clamp to the required
- 72. inch pounds.
Securing the clamp properly should eliminate the contact between the tubing and conduit. The inspector reviewed the FDDR and concluded that the; proposed action was adequate to address the technical issue.
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Response
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This concern is not applicable to Unit 1.
The cause of-this Unit 2 condition was determined to be unauthorized alteration which occurred during the construction phase. The support straps did not work themselves loose and the Unit 2 problem is viewed as construction related and is not. Indicative of a programiatic breakdown in the installation of instrument tubing.
U Applicability of Unit 2 Independent Construction Assessment (ICA)NRCInspectionfindingstoUnit1 NRC~ Inspection Report Section 4.9.2.2 Concern During field inspections of instrument tubing and supports, the NRC inspector noted that galvanized materials welded or cut in the field were left untreated.
Construction Specification M-830-G038, Sheet 1. Note 8 required that " field cut or welded surfaces of galvanized materials shall be treated with galvanizing spray to protect the surfaces".
Bechtel responded to the NRC inspector's finding by initiating Balance of Plant Condition Report J400. The condition report identified and documented the discrepant condition for future correction.
Response
This concern-is applicable to-Unit 1.
-Cause:
LThe cited Unit 2 condition is attributable to a misunderstanding on the part of L
l Construction Engineering of the requirements in M-830-G038 to coat the ends of.
cut-off galvanized material.. The general notes of M-830. Paragraph 8.4. state that for painting and welding._ refer to project requirements. Ccistruction Engineering understood this to mean that general project painting requirements
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should apply to cut or welded Unistrut.
Extent of Condition:
Not applicable cased upon action taken to prevent recurrence.
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' Attachment 2' Applicability of Unit 2 Independent. Construction Assessment (ICA)NRCInspectionFindingstoUnit1 Significance:
- This condition has been evaluated and we have determined that non-treated field cut or welded surfaces of galvanized materials are not detrimental to the plant, Corrective Action:
i Balance of Plant Condition Report J-400 was issued and has been dispositioned by Project Engineering to "Use-As-Is." This disposition applies to both Units 1
- and 2.
Action to Prevent Recurrence:
FCR MI-758-J removed this requirement from Specification M-830-G038.
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-Attachment 2-Applicability of Unit'2 Independent Construction Assessment (ICA)-NRC Inspection findings to Unit'l
-Section 4.9.2.2
_ Concern r
1 The NRC'h inspection also identified a number of fastener discrepancies that consisted of missing _flht w'ashers on base plates anchor bolts and missing lock washers'on instrument attachment bolts.
-IlangerH2forESWpressureswitchPSi.-12-001Btubing: missing flat o
washer on one baseplate anchor-bolt attachment.
I of ESW pressure : transmitter PSH-12-004B: missing-lock washer on one' support bracket bolt.
o ESW pressure' transmitter PSH-12-0040: missing lock washers on two support bracket bolts.
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. Conduit hanger CI-1485: missing' flat washers under all four anchor bolt nuts for the hanger baseplate.
~ Bechtel! prepared-ADN Fem L-72 to document the NRC observations for the transmitters and tubing support. The'NRC inspectors-discussed baseplate anchor flat washer discrepancies with the Bechtel Lead and Assistant Electrical Lead w
. Engineers and was presented with Information from Specification 8031-C-64.for anchor installations. The specification-recossended the use of washers.for all expansion anchor' installations and that washers could be omitted when the plates-
. hole size -is no_ greater than-the bolt diameter plus 3/16 inch.
It further=
x.. stated;that all bearing surfaces-shall be plane surfaces to ensure that
_ tightening of-the _ nut has the desired seating effect on the anchor. The NRC=
Applicability of Unit 2 Independent Construction Assessment'(ICA)NRCInspectionfindingstoUnit1 inspectors had the following concerns regarding this portion of the specification.
o Since omission of-flat washers for expansion anchors was allowable, then the expansion bolt. hole size for those baseplates should be a quality attribute that should be QC inspected and recorded during assembly.
o The specification did not provide criteria to determine if surfaces were plane and, therefore, that deterr.ination was left to the judgement of the installation craftsmen.
The specification's exception for the use of washers was independent o
of the anchor's use and expected load. The exception was also-inconsistent with vendor recommendations, drawings, and qualification testing for specific anchors.
The NRC inspectors noted that most baseplate anchor bolts had flat ' washers installed and it-appeared-that a few isolated electrical conduit supports were missing washers. The team also noted that the-intent in constructing the plant was to install. washers under nuts on all anchor bolts. The NRC team recommended
=that-PECo and Bechtel evaluate the appropriateness'of Specification C-64 requirements for expansion anchors.
Response
This concern is applicable but not a problem on Unit 1.
Applicability of Unit 2l Independent Construction i
Assessment (ICA)NRCInspectionFindingstoUnit1-The cited condition has'been evaluated and our conclusions with respect to Unit l
1 are as follcus.
Expansion anchor allowable loads contained in Specification C-64 are independent of the anchor's use. Omission of washers, as permitted by the specification, is similarly independent of.the anchor's use and expected load. Washer omission at anchors installed to' achieve specified torques'does not have significant affect on-anchor capacities. This has also been confirmed by the anchor manufacturer.
' Anchor qualification testing and vendor recommendations do not identify washers as a significant parameter. Drawings for commodity support connections using expansion anchors do not specifically_ require washers. Expansion anchor hole sizes in baseplates-are inspected as required by Section 3.6 of Project Quality
'ControltInstruction (PQCI) 18240/C-1.50. Criteria to determine if bearing
-< : surfaces 'are plane is given in Section ;3.3.of Specification C-64 by the requirementLthat the minimum allowable-angle between the. axis of the anchor and 3 the-bearing surface shall be 85 degrees.. This criteria is addressed in Section
- 2.1.B.1(b) of ~ tiu.- PQCI. The PQCI, in Section 3.5, also requires that proper nut contact with the bearing surface-be verified in accordance with Section 3.3 of i
-Soec'fication C-64.- Therefore,-we conclude that Specification C-64, for use of k
expansion anchors, is adequate-and appropriate.
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Applicability'of Unit 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit 1 i
NRC Inspection Report Section 4.9.2.2 Concern i
The NRC inspector noted an apparent interaction violation between an uninsulated
-steam pipe and a safeguards junction box and safety-related conduit 2AJ',70.
The uninsulated pipe. EBO-205-E3, with a design surface temperature of 550 degrees Fahrenheit, was routed within 2 inches of the face of the junction box.
Construction Specification M-830-E1406 Section 2.9 required that uninsulated.
pipe with surface temperatures-above 200 degrees Fahrenhelt be evaluated by
' Project Engineering for adequate clearance from electrical raceways.
The NRC' inspector discussed the installatlon'with Bechtelistaff who provided NCR 13913 and PIN 369 dated August 11, 1987. The irspector had the following
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concerns after reviewing the NCR and PIN.-
PIN 369 stated that conduit 2AJ170 was reworked to achieve 3-1/4 o-inches-separation between the bare pipe and the junction box. The PIN also required two (2) inches of insulation on the pipe..The NRC.'
ileid inspection.of the installation found the pipe uninsulated and only 2 inches of clearance between the pipe and the junction box.
The PIN did not indicate any QC or QA action or acceptance.
o o'
The PIN was signed off as being " closed out" with "N/A" indicated in the " Action Completed By" block.
The NRC inspectors concluded that the installation was not in accordance with requirements or the PIN, and had not been reworked as stated in the PIN.
Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Ir.spection Findings to Unit 1
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~ Additional = review and evaluation of-corrective action for this deficiency were warranted.
Response-This concern _is'not applicable to Unit 1.
The PIN-program was not '.n use on Unit 1.
However, any Unit 1 interaction violations would have been: identified in the course of the final stress
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reconciliation walkdown-perfonned by Project Engineering. Therefore, this Unit 2-concern is not elndicative of:a_ programmatic breakdo; in the installation of-Uutt 1 piping or_ equipment; h
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-Attachment 2' L
Agiplicability of. Unit 2 Independent Construction Assessment-(ICA),NRC Inspection findings to Unit 1 NRC Inspection-Report Section 4.9.2.2 Concern
-)
-The team found all four (4) mounting bolts for pressure transmitter PT-11-0038-loose. The transmitter measured the unit common emergency service water D loop
-f discharge header pressure. The bolts did not appear to have been tightened.
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The NRC inspector reviewed ADN Fom L-73 which the licensee prepared in response
-to the teams-finding. -The team noted that the form identified and documented the discrepancy but had not yet been evaluated for appropriate action by PECo
-QA.:"The NRC team: recommended that the root cause of the oiscrepancy be-determined and that1 measures be taken to prevent its recurrence.
Response-
- This concern was--identified on a Unit 1 instrument.
g Anlinspection of = all! pressure switches and transmitters in the spray and-pump 4
house was completed. No additional-cases of loose mounting bolts were-discovered.-
$ Thef fact that all four (4) of the mounting bolts' were' discovered on the one
- pressure transeltteriPT-11-0038.and not one (1) mounting-bolt was found loose on the ' additional: instruments inspected indicates that the most probable cause of this event was! unauthorized reworked to the common pressure transmitter during
-Unit 2 construction. AsLno other similar occurrences were discovered this condition is viewed as an isolated occurrence and is not indicative of a
. programmatic breakdown in the installation of Unit 1 or Unit 2 instrumentation.
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~ Attachment _2 o
Applicability of Unit 2. Independent Construction 1
Assessment (ICA):NRCInspectionfindingstoUnit1
]
I NRC Inspection Report'Section~4.9.2.2 f
l The NRC inspection identified loose flexible conduit fittings in the j
l installationsofseven(7) instruments. Bechtel Instrument Engineers prepared a j
l FDDR that documented the deficiencies identified by the_ team. -The NRC inspector reviewed the F00R and concluded that it adequately addressed the problem.
Response
This concern may be applicable to Unit 1 but is not a problem.
G.E. has evaluated this condition and considers it to be insignificant since the
- flex connector cannot unscrew from the device with conduit attached to it.
There11s no impact to plant safety or-system function as a result of.this condition nor does it affect the qualification of the instrument rack.
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/,tachment 2 -
Applicability of Unit 2 Independent Construction-Assessment (ICA) NRC Inspection findings to Unit 1 J NRC Inspectien Report Section 4.9.3 Concern
<The inspector gained additional insight (4 the involvement of site QC inspection
. personnel-in the construction process during review of completed work packages i
and QCIRs.- The NRC inspector noted that QC personnel were involved in the work activities from work planning to final inspection of the activities. However, the. deficiencies = identified by the NRC team in the mechanical, HVAC, and instrumentation areas, particularly the equipment mounting discrepancies.
_ indicated that QC activities were not completely effective in all cases.
The number-of discrepancies found during NRC' field inspections of instruments t
-both~within End outside the SWEC sample generally indicette *; hat the quality of work-by craftsmen were above average. The. type of discrepancies found on QC-
, accepted installations would suggest weaknesses in attention to detail in acceptance of completed installations or lack of detailed checklists for final 1
verification.
-Response-
_This concerniis not applicable to Unit 1.
I We have reviewed the cited conditions and conclude that the vast-majority of the valid concerns were noted to be isolated cases which were assessed by PECo to be minor in nature, and can'be categorized as follows.
Deficiencies-associated with QC acceptance of conmiodities.
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Attactment '2 Applicability of Unit 2 Independent-Construction Assessment (ICA)NRC;InspectionfindingstoUnit1 Deficiencies associatei with the degradation of commodities:after QC o
acceptance, of Specification interpretation.
-The only discrepancies attributable to the first category are those. identified in the area of mechanical equipment mounting. As discussed _in the response to each of the_ specific hardware concerns related.to this suiiect, conflicting / confusing design' requirements and lack of attent'on __to detail during drawing review were the root causes of the problem. We have 2etermined that-this condition-is-isolated to this issue as has been demonstrated by the SWEC
. IDCA-and this NRC Inspection Report. - We provide a graduated program-of assurances,that atlevel of qualityLis maintained on safety related equipment;
}
sufficient to assure its function. Each program provides controls to ensure
- that the work-receives that anpropriate inspection. The controls for Bechtel Constructionare'providedintheConstruction~ Procedures (cps)._Thesecontrols
- ensure the work package is routed _ through QC for the; preparation of; their:
O inspection-documentation.--When blue tag testing is-in progress, the controls-c
'are established'in PECo Electrical Engineering Procedures =(EEs).
These--
procedures ~ require the rework notice to be routed through QC for inspection-
- documentation. Startup Work Orders (SW0s) are'used by the Startup organization-
~to authorized all work. Their controls.are. notal in the Startup Administrativet Procedures and:they include provisions for QC inspection. 'These control-a functions e'nsure that all work on systems _and facilities are carefully controlled under our quality program.
The1 discrepancies attributable to the'second category are also discussed in the
~. responses to each of the specific concerns.
In addition, our quality program q'
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. Attachment 2 Applicability of Unit 2 Independent Construction Assessment (ICA) NRC Inspection findings to Unit I recognized the possibility of inadvertent damage af ter QC inspection. Two programs have been developed to ensure that the damage does not go undetected.
The first is a system turnover program. Prior to system turnover to Startup, a walkdown is performed by a multidiscipline team of Construction Engineers, QC Engineers and Startup personnel. This walkdown is done to ensure that all construction is complete or noted as an exception and that any damage is documented.
In conjunction with the walkdown, a QC records review is performed to ensure all inspections are completed and all open items are entered on the punchlist. Once turned over to Startup, the system is tagged to clearly identify that the system is under Startup control.
1 The second-system developed is the facility turnover process.
Again, a walkdown is performed by a multidiscipline team. This team ensures that the facility and its components are damage free and note that all construction is complete or documented as an exception. These areas are then locked-down to the extent
- possible to prevent unauthorized entry.
The two'(2) walkdown programs are described in Bechtel Construction Procedures CP-T-1 and CP-T-2.
Assurance that the design is maintained af ter post acceptance testing is recognized as an important element of our Startup Administrative Procedures.
i These documents assure that all design changes are properly controlled.
In addition, these controls include provision for QC inspection and retest af ter work completion.
Attachrwnt 2 Applicability of Unit ? Independent Construction Assessment (ICA)HRCInspectionfindingstoUnit1 Although concern was expressed regarding the acceptability of interpretations of some specifications, analysis has shown these specification interpretations to be acceptable to meet requirements and therefore "use-as-is."
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