IA-84-455, Forwards Evaluation of Concrete in Basemat,Waterford Unit Number 3. Despite Violations of Spec Requirements During Initial Concrete Pouring,Const Adequate to Ensure Structural Safety
| ML20128G920 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/21/1984 |
| From: | Shad L NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Crutchfield D NRC |
| Shared Package | |
| ML19263A633 | List:
|
| References | |
| FOIA-84-455, FOIA-84-A-56 NUDOCS 8505300351 | |
| Download: ML20128G920 (21) | |
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MAY 2115B4 ig 1i MEMORANDUM.TO: Dennis Crutchfield, Special Waterford Team Leader FROM: . L. C. Shao, Deputy Director DET/RES
SUBJECT:
CONSULTANT'S EVALUATION OF CONSTRUCTION ADEQUACY OF i WATERFORD BASEMAT , During the initial concrete pouring of the Waterford Basemat (especially Blocks 6,1 and 2), there were violations of specification requirements. As a part of the assignments under the Special Waterford Civil / Structure and Piping / Mechanical team. I asked Robert E. Philleo, to be our consultant to independently review how these concrete construction violations will affect the structural integrity and safety of the mat. Mr. Philleo has
- outstanding credentials and has about 40 years of experience in concrete construction, research and design. He is Past President of the American Concrete Institute and was Chief of the Structures Branch, Directorate of Civil Works, Office of Chief of Engineers U. S. Army Corps of Engineers, supervising structural design and concrete technology for the World's largest engineering organization. Enclosed is a copy of his evaluation (Enclosure 1) based on his observation of the records and physical i inspection of the concrete mat itself. It is Mr. Philleo's opinion that l in spite of the violations, the construction was adequate to ensure the ;
safety of the structures. Detailed justifications were given to support ; his conclusion. The conclusion of his evaluation is extracted from the i main report as follows:
- "The construction of the basemat was adequate to insure the safety of the structure. While there were several violations of specification requirements or missing records, none were of a nature which would impeir structural integrity. Most of the violations or omissions pertained to provisions intended to preserve the workability of the concrete such as air content, slump, temperature, age of concrete at time of discharge, and neber of revolutions of the mixer drum. Because the mat was placed during the winter and early spring when workability problems are not critical and because a large part of the concrete was passed through
- pumps, which constitute a good inspection tool for assessing workability, the lack of docuentation of some of the backup workability data is relatively unimportant. For the same reason the concrete was easy to
, consolidate, and departure from ideal placing procedures should not prove significant. Failure to doceent moist curing is not significant i because of the massiveness of the structure; and the occasional failure to maintain the required curing temperature was probably an advantage - in removing heat from the structure. Irregularities in Cadweld inspection were administrative rather than technical, and errors in handling reinforcing steel were inconsequential. Waterstop problems apparently were adequately dealt with; but in any c. vent they do not affect safety. g 8505300351 850301 e 4 hDE A-56 PDR - _ . _
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g MAY 21 BB4 { 2 f Strength of the concrete is well documented. It exceeds the design !
- strength by a, larger margin than required by American Concrete Institute standards. This fact and the fact that concrete was placed under favorable physical conditions and in favorable weather, neither of which were conducive to the develop;nent of cold joints or internal voids, testify to the safety of the structure insofar as it is affected by the construction process. Adequacy of design was not addressed in this investigation."
! Also enclosed with th'e enclosure are copies of his resumes in the brief and extended versions. (Enclosures 2 and 3). L. C. Shao, Deputy Director Division of Engineering Technology Office of Nuclear Regulatory Research
Enclosures:
1
- 1. Evaluation of Concrete Construction Adequacy in The Basemat Waterford Unit No. 3
- 2. Brief Resume
- 3. Extended Resume cc: H. Denton R. Minogue .
V. Stello 4 R. DeYoung E. Case D. Ross D. Eisenhut J. Collins J. Gagliardo , J. Scinto : S. Turk G. Arlotto R. Vollmer J. Knight G. Lear
! R. Shewnaker D. Jeng J. Ma C. Siess ACRS J. Tapia, Region IV 9
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. g ogy 1 Is REVISION 2 6/28/84 M
g : Allegation A-107 ] l Reference No.: 4-84-A-06-02 Characterization: It is alleged that false documents were generated to replace ; I t1ssing recores related to Cadweld activities. l i Assessment of A11orlation: The NRC staff reviewed and assessed the technical aspect epations related to Cadwelding. (See A11egations A.10iP,' 3 l
% p ,s of many ah134 A-156fand A-147) Each allegation was resolved to the NRC 3
satisfaction as described in these assessments. Site personnel stated that . discrepancies in signatures and initials on the Daily Cadwald Inspection l 4 Reports were the result of reconstruction of original reports that were soiled 1 in the field, or that inspectors had to be in a physically awkward position
! during the inspection and had-a second inspector record and initial the data. i Regarding tensile test reports, the NCR addressing this issue stated that the original test records were in fact lost and that replacement records were ,
generated based on records maintained by the testing company. In addition to the review of the allegations described above, the NRC staff reviewed other records related to Cadwelds and looked for any obvious indications of falsified documents. Other technical areas were also reviewed. l The NRC staff looked for documents which appeared to be extremely new, but which had, old dates, errors in dates. duplicate originals, or other pancies. NRC staff also reviewed other Allegations (A-110, A-115, l A-146, and A-171) that were related to Cadwelds. The review led no obv ous evidence of falsified records. Thus, the NRC staff has concluded that the concern related to falsified records of Cadweld activities is not an issue. This issue has nei r safety significance nor generic tap 11 cations. - Actions Required: None. , It.IES!$$1 I 1. Assessments of Allegations A-106, A-108 A-110. A-115 A-130, A-133 A-146, A-147, A-148, A-155, A-156, and A-171.
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REVISION 1 06/26/84 SSER Task: Allegation A-116 Reference No.: 4-84-A-06-11 Characterization: It is alleged that unauthorized changes and additions have been made to J. A. Jones concrete placement records by unknown personnel. Assessment of Alleoation: Actual concrete placement records to which the unauthorized changes and additions were allegedly made were not specifically identified to the NRC staff. Thus, the NRC technical staff addressed this allegation by looking for evidence of such alterations during the review of records related to other allegations concerning concrete placement records (including Allegations A-129, A-130, A-131, A-140, A-141, A-159, and A-335, which are related to inspector qualifications, unreviewed records, poor placement practices, and records signed off by inspectors on dates when they allegedly were not on site). These allegations have been addressed by the NRC staff as described in this assessment. The NRC staff reviewed concrete placement records by looking for any evidence of unauthorized changes or additions, or falsification of documents. The staff looked for whiteouts on records, documents or portions of document packages that appeared new but that had old dates, errors in dates, duplicate originals, and other evidence indicating falsification or unauthorized alteration. The review conducted by the NRC staff revealed no obvious evidence of' unauthorized additions or modifications to J. A. Jones records, even though one apparent falsification was identified in assessing Allegation A-335, where concrete curing records were signed by inspectors on dates when they were apparently not on site. This issue was determined to have no safety significance as described in the assessment of Allegation A-335. However, the staff has referred the matter to the NRC Office of Investigations.(01). Based on the NRC staff's review of this allegation, no case of alteration or falsification of documents related to.J. A. Jones concrete placement records has been discovered, except as noted herein. This allegation has neither safety significance nor generic implications. Actions Required: None.
w ._ l References
- 1. Assessments'of Allegation: A-129, A-130, A-131, A-140, A-141, A-159, an'd A-335.
Statement Prepared By: /hha 7/c//4 y.Stro3nider y Date Reviewed By: Team Leader Date
. Reviewed By:
Site Team Leader (s) Date Approved By: Task Management Date e e 1. l . l L .
b_._. .; 5 , , REVISION 2 08/30/84 SSER
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Task: Allegation A-129 Reference No.: 4-84-A-06/24 Characterization: It has been alleged that the installation, inspection, and acceptance of waterstop splicing activities were perfor1ned by personnel of the J. A. Jones Construction Company who were not certified for these activities. It is further alleged that the review of the waterstop quality control documentation is incomplete and that those records that were inspected showed failure to implement requirements of . specifications and procedures relative to testing frequency, recording of applicable information, and splice location. Assessment of Allegation: In assessing this allegation, the NRC staff ," - reviewed the Waterford Final Safety Analysis Report (FSAR) which states that to protect against floods all seismic Category I structures, safety . related systems, and components necessary for safe shutdown are to be located within the nuclear plant island structure (NPIS). The NPIS is a reinforced concrete structure designed to minimize water intrusion and the waterstops are one of the design features included for this purpose. l The NPIS also has a floo'r drainage system capable of disposing of water ! that mey be accumulated through leaking cracks in exterior structures, i' leaking waterstops and surface collection. In addition to the FSAR ~
*1tatements the NRC staff noted in the review that since the early stages of the Waterford project, there has been a listing of items related to the facility which undergo interdisciplinary review for safety -
classification. .This list was first issued in January 1973 and has been i under periodic review, resulting in 20 revisions up through March 1984. l , Waterstops have been noted on the list as non-safety class material. I Therefore, although it is desirable to have a high level of quality I assurance for the waterstops, a mitigative system for drainage of potential inleakage exists. Accordingly, waterstops are designated as non-safety class material, which EBASCO has confirmed, l , i The FSAR does not assign a specific safety category to the waterstop. As stated above, the Waterford QA staff considered neither waterstop material nor the installation nuclear safety-related or seismic Class I. The justification for this categorization is that there is no structural - function for the waterstop since it is provided only to reduce ground
- water inleakage to the building through construction joints so as not to
' add to the water volume to be handled by the radwaste system or present housekeeping problems. Waterstops were, however, shown on a drawing.
l ! which was designated as Seismic Category I, which apparently has led some to believe all items shown on the drawirig are Seismic Category I. This t
k _. l ../ .. . j . . ( . A-129 . was an error on the drawing. The waterstop material should have been highlighted by a special note on the drawing as not being safety-class material,then the confusion *would not have arisen during the QA review of documents. , , The NRC staff reviewed waterstop records to determine if the installati n,
. testing, and surveillance were performed in accordance with the existing specifications and procedures. In order to perform this review, LP&L was asked to provide waterstop records for the NPIS (which contains all Category I structures where waterstops were used): reactor containment building (RCB); fuel handling building (FHB); and the reactor auxiliary building (RAB). The only records they could produce were for the RAB and the portion of the common foundation mat ynder the RAB. LP&L could not locate the waterstop splicing records for the RCB, FHB, and other portions of the foundation mat. ,
The NRC staff review of the records indicated some specific problems of the installation and testing procedures. Some of these specific problems are listed below. o Some splicers made over ten splices without making a test splice, per requirements. o insomecasesafewofthetestsplices-werenotmarkedoffas acceptable. However, cross checking with the waterstop splice tensile test reports showed that these test splices did in fact meet the specifications for strength. , o One inspector who. signed off five test splices (this inspector i signed off no other test splices or production splices in the l records reviewed) was not certified on the date the test splices were signed. - o One of the splices made by a splicer for his ' certification test did not meet the required tensile properties and the records do not indicate that he was retested. Review o the certifications gY the splicers and i,nspect showed no defici cies.other than tho g noted above. l A large majority of the records the NRC requested could not be provided ! by LP&L and only the projects own internal procedures required the records since the material is not safety related. The records which were produced showed a small number of minor deficiencies with respect to LP&L's requirements. The deficiencies noted in the records reviewed are not considered significant with regard to plant safety. A review of 20 basemat preplacement concrete packages, conducted as part of the NRC staff's asssessment of allegations 104, Ill, and 190 confirmed j that the waterstops were included in the placements. l . . L
A-129 ' Actions Required: None.
References:
The following documentati~o'n waser' viewed as part of the evaluation of this allegation:
- 1. Letter from B. Grant (EBASCO) to A. Cutrona (EBASCO) dated December 13, 1983, subject: NUCLEAR SAFETY CLASSIFICATION OF WATERSTOPS(Attachment 1).
- 2. LP&L Waterford SES Unit 3 Interdisciplinary Review List (Attachment 2).
- 3. WSES-FSAR-Unit 3 Section 3.4.1, Flood Protection and Figures 3.4.1 and 3.4-2 (Attachment 3).
- 4. EBASCO Specification for polyviny1 chloride waterstops (Attachment 4).
- 5. J. A. Jones Construction Company site inspection and test procedure
. for waterstop inspection (Attachment 5).
- 6. J. A. Jones Construction Company construction work procedures for handling, installation, ar.d field repair of waterstops (Attachment 6).
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- 7. Waterstop splicing logs.
- 8. Waterstop splicers training records and certifications. ,
- 9. Waterstop tensile test recor'ds.
l l Statement Prepared By: e 7/#[N ack Strosn.ider Date Team Leader Date l-Reviewed By: Site ieam Leader (s) Date l Approved By: lask Management, Date i
l ' REVIS!0N'4 08/30/84 4 SSER u - Task: Allegation A-132 i Reference No.: 4-84-A-06/27 Characterization: It is alleged that the J. A. Jones Construction Company used a form of connunication called " speed letters" to report
' information that should have been reported in deficiency notices (DNs) and possibly in nonconformance reports (NCRs).
Assessment of Allegation: The implied significance of this allegation is that " speed letters" are not quality assurance (QA) documents and do not receive an EBASCO QA review. In order to determine the validity and significance of the allegation, j' the NRC staff reviewed J. A. Jones speed letters numbered 0001 through 1122 covering the-period of November 1977 to October 1980. These speed letters had been transmitted to EBASCO engineering personnel and cone'erned J. A. Jones concrete work performed in the reactor containment
- building (RCB), reactor auxiliary building (RAB), fuel handling building (FHB), and concrete basemat. The NRC staff also interviewed EBASCO QA and engineering personnel regarding the use of speed letters.
The majority of the J. A. Jones speed letters reviewed by the NRC staff were related to the logistics of work schedules and performance; however, i the staff discovered some speed letters involving deviations from, or
- changes to, the original design specifications. Examples of deviations
! and field design changes included; a pilaster 5" too high and requiring modification, slight shifting of reinforcing steel locations, and the use of Cadwelding kits on reinforcing steel sizes other than those sizes for t which the kit was made. (See the NRC staff's assessment of Allegation A-171). i The NRC staff's interviews with EBASCO QA personnel revealed that the QA personnel were aware of potential problems regarding the misuse of speed letters, and. that QA personnel also believed that the Engineering Information Request (EIR) document was possibly being misused. EBASCO QA
- personnel informed the NRC staff that they were in the process of conducting a review to identify potential. problems regarding the use of ,
speed letters and the misuse of EIRs. In a memorandum dated February 20, 1984, tM EBASCO QA Site Supervisor requested that the ESASCO Site Support Engineering (ESSE) Supervising Engineer review the J. A. Jones speed + letters and EIRs. The results of an ESSE cursory review were themselves presented in a speed letter of January 27, 1984. Another EBASCO speed
- - letter of February 18, 1984, substantiated that design changes had been i* the subject of some of the J. A. Jones speed letters and EIRs reviewed.
Although EBASCO itself had used speed letters instead of the required QA
i, ! A-132 l l documentation to relay this information, they accurately pointed out that l a review of Field Change Requests (FCRs) and. Design Change Notifications (DCNs) would have to be performed to determine if the issues presented in the J. A. Jones speed letters were alsp, correctly addressed in the required QA documentation. The NRC staff review determined that some of the J. A. Jones speed letters and EIRs addressed areas where DNs, NCRs, or FCRs should have , been required by the existing QA program, and that EBASCO QA personnel were aware of these discreparcies in the QA practices. This allegation has' no sefety significance based on the staff's preliminary . findings; however, the generic implications involving the use of documents outside the fonnal QA program require action by LP&L. i Actions Recuired: See Item !!o.14 of the Enclosure to the letter from D. Eisenhut to J. M. Cain (LP&L), June 13, 1984. l ,
References:
! 1. EBASCO Servi:es Incorporated. Procedure for Inspection and Test Status, WQC-150, Revision 3, November 9,1983, with Amendments 1 and 2. ,
- 2. EBASCO Services Incorporated Procedure for Processing of Nonconformances, ASP-III-2, Issue J. December 9, 1983, with
~
. Amendment 1. -
- 3. EBASCO Services Incorporated Procedure for Design Change Notice and Field Change Request E-69,. February 20, 1983.
- 4. EBASCO Services Incorporated Procedure 'for Dbsign Control ASP-I-4, Issue K. June 7, 1983. -
5; J. A. Jones /EBASCO " Speed Letters" numbered 0001 through 1122 and l written during the period from November 18, 1977, to October 15, : 1980 (examples included). l 6. Letter from Mr. Sam Horton, EBASCO QA Site Supervisor, to
! Mr. Brian Grant, Civil EBASCO Site Services Engineering Supervising Engineer, February 20, 1984
Subject:
Design Review of J. A. Jones ; Construction Company's Engineering.Information Requests and Three Part Memos, 4
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A-132 .
- 7. Speed Letters from Mr. Brian Grant to Mr. Sam Horton dated February 18, 1984, and, February 27, 1984.
Subject:
Review of J. A. Jones Speed Letters and Review of J. A. Jones irs, respectively. ..
,. s
- 8. EBASCO Services Incorporated Procedure for Control of Information Requests Between EBASCO and Site Contractors.
Statement Prepared By: 9/#I43/
. Strosnider Date
... Reviewed By:
Team Leader Date RevTewed By: Site Team Leader (s) - Date Approved By: - Task Management Date l l l q i I ... 6 g l l i . ! e L l .
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.. . REY 1510N O 05/23/84 SSER Task: A11egation A-134 Reference No.: 4-84-A-06-29 Characterization: It has been alleged that there exists a file of letters known as " Nasty Grams" which were prepared by an individual when it was not possible or acceptable to initiate a nonconfonnance report.
Assessment.of Allegation: To r.ssess this issue, the NRC staff reviewed the QC supervisors file. The file contained letters written between the Senior Ebasco QC Supervisor and the QA Manager for J. A. Jones from July 29, 1976 to March 30, 1977. (Most letters were initiated by Ebasco.) Some letters deal with administrative espects of the QA Program, however, many letters identify problems in 'the QA Program. NRC staff evaluated those that deal almost exclusively with problems in the J. A. Jones concrete placement packages. Specific issues included are missing curing records, missing compression test results, missing Cadweld and embedment maps, and missing reinforcing bar test records. There are also a few documents related to deficiencies in QA records for Cadwelds and soils, such as missing splice numbers for Cadweld tests (these are necessary for traceability) and missing dates on backfill location logs. The existence of the file demonstrates that the QA Program was being audited by Ebasco and that efforts were being made to ensure that documentatior, of construction was being perforined in accordance with the program and procedures in effect. The important issue to be resolved is whether or not the problems identified were corrected, both for the specific items identified, and more *- generally, in the long term. , The issues of most concern are related to concrete a acements performed by J. A. Jones Construction C n .T g adequacy off.o crete placement QA records is being addresse , n r 'fregation t 39. "c ; ; ; . ' "" :-+ 4 an }4kt4
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The issues raised regarding Cadweld splicing and backfilling records that may be significant with respect to safety . and the areas of Cadweld splicing and soils are being more thoroughly assessed under other allegations. The staff has concluded, based on its review, that this file does not include any new issues not already being addressed under other allegations. Therefore, inforination obtained from the file will be included in the review 7 hjf of *"c-"- ^ 1^^ .c.ftther appropriate allegations (A-112 regarding Cadwelds, and A-145 regarding soils) and resolution of those allegations will resolve the issue of this file and any related safety issues. (
t. 5 t fN .{Y,.,hb;,*[$'l.)_j._lU..:E h Actions Required: None. L References
- 1. Memo, Documentation Control, March 1, 1977, by Ed Lemke. Attaches a list of missing documents.
- 2. Memo, Use of Form ASP-IV-17-1, by S. Gordy.
- 3. Memo, Cadweld Test Reports, LRW-T-399 to 410. S. Gordy.
- 4. Memo, Documentation on Slipforming Shield Wall, December 17, 1976.
- 5. Ltr Ebasco to J. L Jones, November 24, 1976.
- 6. Memo, Cadweld Inspections, November 17, 1976, S. Gordy.
- 7. Ltr Ebasco to J. A. Jones, November 16, 1976.
- 8. Memo, Placement Package Documentation, November 15, 1976, S. Gordy.
- 9. Memo, FHB Placement Packages, November 3, 1976, S. Gordy.
- 10. 'Ltr, J. A. Jones to Ebasco, October 28, 1976.
- 11. ' Memo, Reinforcing Steel User Tests, October 20, J976 S. Gordy.
- 12. Memo, Backfill Records, October 21, 1976, S. Gordy.
- 13. Ltr, Ebasco to J. A. Jones, October 20, 1976.
- 14. Memo, Cement Sample Tests, S. Gordy .
Statement Prepared By: f tw , 7t/N [ Jack Rtrosnider y Date Reviewed By: Team Leader Date Reviewed By: Site Team (1ader(s) Date .
; Approved By:
L - _ _ _ _ _ _ _ _ _ - - - - - --- -- _
REVISION 3 ,
. - 07/11/84 SSER i
i h sk: Allegation A-258 ; Reference No.: 4-84-A-06-142(1) , Characterization: It is alleged that Chicago Bridge and Iron Company (CB&I) did not maintain material traceability on certain seismic Category I structural components in the containment vessel that were fabricated from Class D materials. Assessment of Allegation: Chicago Bridge and Iron Company (CB&I), fabricator of the containment vessel, used material they had categorized as Class D to fabricate certain nonpressure retaining structural components in the containment vessel. These structural components include seismic clips that support safety-grade class piping systems, parts of the equipment hatch handling device, parts of the personnel and escape locks, crane rails and girders, stairs, ladders, and some temporary attachments and components. EBASCO ca'tegorized these components as seismic Category I, a category requiring material traceability. But, according to CB&I quality assurance , j procedures, material traceability was not required for Class D material and thus was not maintained. Nonconformance R~eport (NCR) No. W36224, issued by EBASCO Quality Assurance Group on May 13, 1983, addressed this issue. To resolve .the material treceability problem, EBASCO con'tacted CB&I and requested that_ they conduct a search of their in-house records to establish
. traceability of these. materials where possible. CB&I was able to provide Certificates of Compliance or Certified Material Test Reports which established material traceability for a large portion of the components. A listing of those components, which could not be identified as temporary, or for which. '. material traceability could not be established through CB&I records, was forwarded to EBASCO Site Support Engineering (ESSE) for engineering evaluation. - . Based on their review, ESSE concluded that material traceability was not c42nf@n1 fe Oshe mfo Gmration_ of the components, including bolting and angle
a ,- - Allegation A-258 l l ESSE pointed out that in the CB&I design of the containment vessel, the structural members were categorized in material Classes A through D reflecting their order of importance Class A being the most important and Class D the least important. Thus, there was a conscious decision by CB81 regarding the materials classification of components. ESSE indicated that they had reviewed and concurred with the CB&I materials classification system. ; l The NRC staff reviewed the ESSE evaluation, including in the resolution of : I NCR W36224, and performed an independent assessment of the components with potential safety significance, specifically the equipment hatch handling device and the personnel and escape locks. The equipment hatch handling device is
~
used for opening, closing, and storing the 14 foot diameter equipment hatch during maintenance operations but is not relied upon to maintain containment integrity during nonnal or postulated accident conditions. The NRC staff concurred with the ESSE conclusion that material traceability is not essential for this component. The personnel and escape locks each have two gasketed doors in series with valve and interlock mechanisms so that containment l integrity can be maintained during entry and exit. The NRC sta'ff review of the bill of materials and drawings for the personnel and escape locks showed that the Class'D materials in these components were used primarily in the fabrication of actuating mechanisms for valves and interlocks, and for miscellaneous items such as valve handles, bolting, and indicator plates for which material traceability is not critical. The main concern regarding these components is operability and LP&L is required by the final safety analysis report and in their Technical Specifications to perform operability testing of the personnel and escape locks each time they are opened and at periodic intervals. This surve111ance testing should provide adequate assurance that i these components will perform satisfactorily. l i BasedonthereviewoftheESSEeva~1uationofthisissueandonit(own ' ' independent review and and evaluation, the NRC staff concluded that 3 traceabili issue for Class D material used in the containment vessel as addressed in NCR W3-6224 has been satisfactorily resolvid through the actions taken in the [
Allegation A-258 - 3-One issue with possible generic implications is that EBASCO did not perfonn a comprehensive, initial review of the contractor's (CB&I) procedures to detennine that they were consistent with EBASCO specifications. Vendor and contractor QA procedures should have been reviewed to ensure that they were l consistent with the prime contractor's specifications and quality assurance program. Although a failure in the quality assurance program in effect initially 1 did occur because of inconsistency between documents was not identified, the ! same program through internal review identified the material traceability issue. NCR 6224 was written and no violation of NRC regulations was identified. l This allegation has neither safety significance nor generic implications. s l ~~*.5]9
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s ..-.,< .u . .. . 3 A Actions Required: None. References
- 1. NCR W3-6224 issued May 13, 1983.
- 2. CB&I Nuclear Quality Assurance Manual for ASME Section III Products; Section 4.0, Procurement and Material Control; Revision 6; April 3,1975.
- 3. Material Requirements Table for Contract No. 71-2426.
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Allegation A-258 4. EBASCO Internal memorandum from B. Grant, to L. A. Stinson;
Subject:
Relocation; dated July 19, 1983. 5.- Waterford Steam Electric Station Final Safety Analysis Report. Section 3.8.
- 6. Waterford Steam Electric Station; Technical Specifications Section 3/4, Containment Airlocks. .
Statement Prepared By: J . 7 t//# b.Str'osnider (( Date Reviewed By: Team Leader Date Reviewed By: Site Team Leader (s) Date Approved By: Task Management Date 1 I
l b - REVISION 1 07/01/84 SSER , Task: Allegation A-259 - Reference No.: 4-84-A-06/142(3) Characterization: It is alleged that " Class D" material used by Chicago Bridge and Iron (CB&I) in the fabrication of certain non-pressure bearing structural components inside the containment building was not welded with traceable weld rod and that the welds are not traceable to a specific welder. Assessment of Allegation: This allegation is related to Allegation A-258 regarding the traceability of materials categorized by CB&I as Class D that were used in the fabrication of certain non-pressure bearing structural com-ponents in the containment vessel. As described in the assessment of Allegation A-258, these structural components included seismic clips that support safety-class piping systems, parts of the equipment hatch handling device, parts of the personnel and escape locks, crane rails and girders, stairs, ladders, and some temporary attachments and components. EBASCO cat-egorized these components, with the exception of temporary items, as seismic Category I. As such, they required material traceability. But, according to CB&I quality assurance procedures, material traceability was not required for what they categorized as Class D material and thus was not maintained. As stated in the assessment of Allegation A-258, the traceability of the Class .D structural steel was satisfactorily resolveqi by Nonconforinance Report (NCR) W3-6224 . Even so, this NCR did not address the traceability of the weld material. To assess this ' issue, the NRC staff reviewed the structures in which the
" Class D" material was used and requested LP&L to provide the quality assurance (QA) documentation for welds in several of-the structural components considered to have the greatest safety significance. These components were the containment spray system pipe supports (seismic clips), crane girders, and equipment hatch handling device. The staff also requested QA documentation for such items as welding procedures, welder identification and qualifications, weld rod identi-fication, and the inspection results for certain welds in these components.
This QA inforzation is required for welds in safety-related structures. LP&L was unable to produce the records requested by the NRC staff. The inability to produce the appropriate QA records makes the quality of these safety-related structures indeterminable and the NRC staff has concluded that LP&L must take additional actions, as described below, to resolve this issue. l
. . i y
y Allegation A-259 , t l } Actions Recuired: See Item No.15 in the enclosure to the letter from l D Eisenhut (NRC) to J. M. Cain (LP&L), June 13, 1984
References:
f ! 1. Assessment of Allegation A-258 l 2. Nonconformance Report W3-6224 issued May 13, 1983
- 3. Code of Federal Regulations, Title 10, Part 50, Appendix B.
Statement Prepared By: s. 7[t[W
. Strosnider y Date 2
i
- Reviewed Sy
Team Leader Date
~
Reviewed By:
- Site Team Leader (s) Date i
i Approved By: Task Management Date i 1 i _, _ - . _ _ . , _ _ _ . . _ _ _/
REVISION 2
.',, , , 06/21/84 SSER l Task: Allegation A-260 t
L Reference No.: 4-84-A-06-142(3)
' Characterization: It is alleged that there is a lack of traceability of certain materials used in non-pressure retaining components in the containment vessel such as equipment door handling device, personnel and escape lock hardware, and miscellaneous structures. This allegation is related to Allegation A-258.
Assessment of Allegation: The alleger suggested that in order to resolve the issue of lack of traceability, samples of the materials in question should be ) taken and mechanical and chemical analyses performed to determine if the materials were acceptable. The alleger's suggestion is a plausible solution to the issue of traceability of materials. However, the NRC staff detennined as a result of its inspections that this concern was satisfactorily resolved with regard to the base metal as described in the NRC staff's assessment of Allegation A-258. However, the issue of traceability of the weld material, process and personnel used in l welding the Class D materials inside the containment has not been satisfactorily ' resolved. The allegers suggestion has been identified as an option in resolving l the issue in Allegation A-259. l 7 This allegation has neither safety significance nor generic implications. Actions Recuired: None. References -
- 1. A11egat. ion A-258 and A-259.
Statement Prepared By: _
. 7 //#
. Stro5nider Date
(/ l Reviewed By: Team Leader Date l Reviewed By: Site Team Leader (s) Date '. Approved By: Task Management Date
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