IR 05000353/1987008

Insp Rept 50-353/87-08 on 870526-0605.No Violations or Deviations Noted.Major Areas Inspected:Qa Effectiveness in Const Activities

ML20235N486
Person / Time
Site:	Limerick
Issue date:	07/01/1987
From:	Eapen P, Winters R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235N468	List: IR 05000353/1987008 ML20235N465
References
50-353-87-08, 50-353-87-8, NUDOCS 8707200090
Download: ML20235N486 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

- REGION I Report N /87-08 Docket N License N CPPR-107 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generating Station', Unit 2 Inspection At: Limerick, Pennsylvania Inspection Dates: May 26 - June 5, 1987 Inspector: 3I R. W. Winters, Reactor Engineer date Quality Assurance Section, 08, DRS, RI Approved by: @ N- b Dr. P. K. Eapen, Chlief -

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Quality Assurance Section, Operations Branch Division of Reactor Safety, RI Inspection Summary: Routine unannounced inspection on May 26 - June 5, 1987 (Report No. 50-353/87-08)

Areas Inspected: Quality Assurance effectiveness in construction activitie Results: No violations or deviations were identifie PDR ADOCK 0500

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DETAILS 1.0 Persons Contacted Philadelphia Electric Company

• J. Corcorr.n, Manager, Quality Assurance 3 * D. DiPac~o, Quality Assurance t'ngineer L. Dyer, Quality Assurance D. Marascio, Quality Assurance

• P. Pay 11 des, Director, Quality Assurance Bechtel Construction Incorporated

• G. Bell, Project Quality Assurance Engineer G. Kelly, Quality Assurance Engineer L. Reyes, Quality Control Inspector General Electric Company

• C. Brinson, Quality Assurance Manager United States Nuclear Regulatory Commission

• P. Eapen, Chief, Quality Assurance Section

• R. Gramm, Senior Resident Inspector

• J. Kaucher, Resident Inspector

• H. Kaplan, Lead Reactor Engineer

• J. Linville, Chief, Projects Section

• Denotes those present at the exit meeting held June 5, 198 The inspector also contacted other administrative and technical personnel during this inspectio .0 Implementation of Construction Quality Assurance Program The purpose of this inspection was to determine whether: Site work was being performed in accordance with NRC requirements, SAR commitments and implementing procedure . The OA/QC program was functioning in a manner that ensures require-ments and commitments were being me . Prompt and effective action was being taken to achieve permanent corrective action on significant discrepancie . _ _ _ _ _ _ _ _ _ _ _ . -_

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2.1 Details of the Inspection The inspector selected piping and structural general construction activities to determine the effectiveness of the quality program in the following areas:

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Field Drawings and Work Procedures

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Field Inspection

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Quality Control

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Nonconforming Items

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Materials and Equipment

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Audits l

1 Residual Heat Removal System Review The inspector reviewed portions of the RHR system piping depicted on drawings 8031 M-51 Sheet 6 of 8. This included portions of the 18" diameter piping between the RHR pump 2BP202 and the heat exchanger 2BE205. For this system the'most recent revision of field drawings, instructions and work procedures were in agreement with the Final Safety Analysis Report (FSAR).

Deviations of the as built configuration from the P& ids were properly controlled and dispositioned. For example, Field

) Change Request ME-375 was originated on February 9,1987, to i' relocate flow orifices F0-220B and F0-2218. This Field Change

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Request is required to be incorporated into sheet 5 of P&ID M-5 The inspector reviewed installation procedures as shown in Attachment A and noted that weld preparation, alignment and fit up were designated and verified by Quality Control hold point inspection The inspector physically walked down the above portion of the RHR system and verified pipe diameter, support locations, and instrument penetration locations. He also visually inspected selected weld !

The inspector observed six butt welds. The welds were visually acceptable, with no evidence of unacceptable undercut, porosity or arc strike These welds were prepared for preservice and  ;

inservice inspections. The inspector verified the dimensions and configuration of welds on accessible portions of five pipe support In all cases the fillet welds met or exceeded the drawing requirement ,

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The inspector verified'that the markings on the piping and components.were consistent with the specifications.- In one instance, the marking appeared'to be different (CC vs. GG) due to the curvature of the pipe. The licensee agreed to reidentify this:section of the pip I The inspector witnessed the~ final inspection of pipe support GBB-201-H4. During the inspection the architect engineer's (AE)

QC inspector.de'monstrated'a thorough knowledge of the associated inspection technioues. The Quality Control Inspection Record for.this hanger was' complete and signed off as required for all activities performed on this hanger. As' acceptance criteria .the AE's inspector used.the' installation drawing for this suppor The NRC inspector independently . reviewed this support- and found '

it acceptabl Nonconforming Items The inspector reviewed nonconformance reports listed'in Attach -

ment A.' The identified nonconformances were discussed with cognizant field engineers to unde'rstand and assess the root causes. In.all cases reviewed the nonconformances were dispo-sitioned in a technically competent and timely manner. This was especially true in dispositioning NCR.11366 for a bent mounting i bracket on RHR pump cooler Processing of this NCR included disposition by the NSSS supplier. The inspector verified the bent bracket was replace The inspector reviewed the trend analysis program and the anal-ysis performed on selected NCRs and Inprocess Rework Notices (IPRN). The program requires all NCRs and IPRN for safety related components to be coded by source, type and activity by theLAE's Quality Engineering group. The code reviewed was for large piping (over 2-1/2 inch outside diameter) minimum wall-violations. The AE's analysis indicated that there was no meaningful trend for either the NCRs or IPRNs in this classi-

'ficatio The NRC inspector independently reviewed this analysis and found it acceptabl Materials and Equipment The inspector reviewed preventive maintenance records of compo-nents in storage. From this review the inspector concluded that preventive maintenance is performed in accordance with the manufacturers recommended practice or as modified by the AE's engineering department. In one case the inert gas protective atmosphere was removed for installation of the RHR heat exchangers. The removal was done with the approval from the heat exchanger supplier. Originally this inert gas removal was i allowed for one year to allow for installation of the heat

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exchange However, as a result of an audit, prior to the expiration of the year's relief, the requirement for inert gas protection was deleted based on the current installation requirement for the heat exchange The inspector reviewed the data packages provided by the vendor for the RHR heat exchangers and discussed their contents with the cognizant licensee personnel. The packages included all of the required.information including the ASME Code data sheet properly signed by the Authorized Nuclear Inspector. However, the NRC inspector noted that the procedure qualification records PQR 103 and PQR 106' contained apparent errors in the calculation of the tensile strength data. In both cases, the data indicated that the qualification was acceptable in accordance with the ASME Code Section IX, 1968 Edition. Also, Welding Procedure 9008, although properly qualified, used non-ASME Code termin-ology in specifying the base material to be welded. The errors noted above in the welding procedure qualifications and the welding procedure specification, collectively constitue an unresolved item pending licensee actions to correct these errors (50-353/87-08-01). Audits The inspector reviewed the audit reports and checklists shown in Attachment A for the audits performed by the licensee and the AE. Topics covered by the audits reviewed included installation of rotating equipment, control of work packages, QA program administration, Inspectors training and qualification, NCRs and IPRNs, installation of large and small pipe and supports, storage of equipment, records, receiving inspection, and welding procedures. Audits were comprehensive and often extended over several weeks in order to allow observation of work in progres Audit deficiencies were promptly reported and response by the audited organization was timely and thorough. As stated above, the maintenance of the inert gas atmosphere on the RHR heat exchangers was identified and corrected prior to its removal becoming a nonconformanc .2 Conclusions Changes to the FSAR P&ID drawings were adequately controlled and reviewed by the appropriate engineering organizations. At the time of this inspection all changes had not been incorporated into the FSAR but these changes were identified and available for revie However, during discussions with the licene'e's management personnel concerning the licensee's Quclity Assurance organization, the inspector noted that the organization chart shown in the Preliminary Safety Analysis Report (PSAR) was not revised to reflect the latest licensee organizational changes. This is an unresolved item (b0-353/87-08-02) pending the licensee's revision of the PSA .n >

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The inspector noted that field inspection was adequately controlled by;the AE with adequate. licensee surveillance of the installation activities. 'All nonconforming items were identified by Nonconfor-t'

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mance Reports or Inprocess Rework Notices (IPRNs) and corrective-action were' implemented in a timely manner. The program.for trend

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analysis of both NCRs and IPRNs was performed by the AE. The program for. sorting'by deficiency categories was adequate to provide meaningful grouping:for analysis. The analysis performed'by qualit engineering was also adequate.

L Material'and equipment were controlled and preventive maintenance was performed both during storage and after installation, as required, i

Audits were' comprehensive and, as appropriate included observation of installation practices. The audit schedule was generally followe .0- Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or violation Two Unresolved items are discussed in paragraph .0 Management Meetings I

Plant management was informed of the scope and purpose of the inspection [

at an entrance interview conducted on May 26, 1987. The findings of the inspection were periodically discussed with plant representatives during the course of the' inspection. The exit interview was conducted on June 5, 1987, at which' time the findingslof the inspection were presente The . licensee did not indicate that any proprietary information was contained within the scope of this inspectio At no time during this inspection was written material provided to the licensee by the inspecto ,

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ATTACHMENT A i Procedures Philadelphia Electric Company Number Revisien Title

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QAI-18-4 4 Procedure for Formulation of PECO Audit Plans QAI-18-9 4 Procedure for Preparation of QA Major Activity Schedule QAI-18-22 4 Procedure for Preparation and Control of Site Audit Program Bechtel Construction Incorporated QADP-C-19 1 .Nonconformance Report (NCR) Trend Analysis i

Delta Southern Company (RHR Heat Exchanger Vendor)

i Welding Procedure Specification

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103 2 103H 5 Welding Procedura Specification 110H 3 Welding Procedure Specification 113H 9 Welding Procedure Specification 9009 2 Welding Procedure Specification 103 0 Welding Test Record Procedure Qualification 103 O Welding Test Record Procedure Qualification 106 0 Welding Tent Record Procedure Qualification 110H 0 Welding Test Record Procedure Qualification 113H 0 Welding Test Record Procedure Qualification Audits Philadelphia Electric Company Number Date Subject 2M-544 12/22/86-3/17/87 Installation of Rotating Mechanical Equipment 2G-206 5/20-6/6/86 Control of Work Packages 2G-204 5/27-6/16/86 QA Program Administration 2G-210 7/14-16/86 Inspectors Training and Certification 2G-227 12/15/86-1/12/87 Control and Documenting of Nonconforming Items 2G-240 3/5-11/87 Nonconformance Logs 2G-207 6/2-10/86 In-Process Rework Notices 4 2E-244 12/3-5/86 BCI Maintenance of PGCC Panels i 2G-217 11/11-14/86 .Welders Qualification 2G-215 8/19-9/23/86 Site Receiving Inspection

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Attachment A 2

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I Audit Checklists j I

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i 2G-192 Long Term Maintenance 2C-207 .In-Process Rework Notices 2G-206 Control of Work Packages 2M-544 Installation of Rotating Equipment ] ,

2G-215 Site Receiving Inspection 1 2G-227 Control and Documenting of NCR Items Bechtel Construction Incorporated Audits i

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I 761 7/21-25/86 Project Material Requisitions '

767 8/19-9/9/86 Inspection Plans and Records 775 8/25-27/86 Dispositioning of Nonconformance Reports l 757 9/30-10/16/86 Material Storage and Maintenance l 758 6/23-7/15/86 Material Issue 752 6/23-7/7/87 Field Procurement Control l 749- 5/7-6/13/86 Processing of Nonconforming Items

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