IR 05000271/1985035

Insp Rept 50-271/85-35 on 851104-08.No Violations or Deviations Noted.Major Areas Inspected:Design Changes & Mods & Qa/Qc Administration Program for Recirculation Sys Pipe Replacement

ML20138L783
Person / Time
Site:	Vermont Yankee
Issue date:	12/09/1985
From:	Chaudhary S, Eapen P, Hunter J, Winters R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138L772	List: IR 05000271/1985035 ML20138L769
References
50-271-85-35, NUDOCS 8512200043
Download: ML20138L783 (18)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-35 Docket N License No. DPR-28-Licensee: Vermont Yankee Nuclear Power Corporation RD #5, Box 169, Ferry Road Brattleboro, Vermont 05301

. Facility Name: Vermont Yankee Nuclear Power Station Inspection At:

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Vernon, Vermont Inspection Conducted: November 4-8, 1985 Insoectors: I[ W /v /d K. Chaudhary, Lead Regctor Engineer ' d6te

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. G. Hunter III, Reactor Engineer / d6te

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. W. Winters, Reactor En'ineer

/d/te Approyed by: ke Dr. P. K. Eapen, Chfief

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'd a't'e Quality Assurance Section, OB, DRS Inspection Summary: Routine Unannounced Inspection on November 4-8, 1985 (Inspection Report No. 50-271/85-35)

Areas Inspected: Design changes and. modifications and QA/QC administration program for the Recirculation System Pipe replacement. The inspection involved 110 inspection hours on-site and 9 inspection hours at the regional office.by three region based inspector sResults: No ' violations or deviations were identifie , PDR ADOCK050g21

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DETAILS 1.0 Persons Contacted Vermont Yankee Nuclear Power Corporation (VY)

• J. P. Pelletier, Plant Manager

• S. A. Vekasy, Project Decon and Restoration Supervisor

• W. L. Wittmer, Project Manager Yankee Atomic Electric Company (YAEC)

J. Geyster, ALARA Coordinator

• J. R. Hoffman, Project Engineering Supervisor

• R. Martin, Project QA Supervisor Morrison - Knudsen (MK)

S. Giles, QC Supervisor J. J. Hairston, Project Quality Manager F. Replogie, Quality Assurance Engineer M. Walsh, QC Inspector United States Nuclear Regulatory Commission

• W. Raymond, Senior Resident Inspector T. Silko, Resident Inspector

• Denotes those who attended exit meeting on November 8, 1985

2.0 QA Organization and Activities for the Modifications Vermont Yankee Nuclear Power Station is currently in Cold-Shutdown for major modifications. The primary modification is the redesign of the recirculation system configuration and replacement of the associated piping. The licensee has established a special project group to assure an efficient-and effective execution of this' modification projec Morrison-Knudsen has been retained by the licensee to provide erection, installation and other construction related services. Yankee Atomic of Framingham, Massachusetts, is providing the design and engineering ser-vices, and the licensee is coordinating the overall effort through an interdisciplinary project group led by a Project Manager. The project group is independent of the plant staff, and reports directly to the Manager of Operations of Vermont Yankee (VY). The Quality Assurance i functions of the effort are integrated by the QA Supervisor of VY who ;

is independent of the project group and reports directly to the Director I of QA, Yankee Nuclear Services Divisio l l

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-3-The Quality Assurance functions for construction and installation aspects of the work are provided by Morrison-Knudsen (MK) through its own QA program, which has been reviewed and accepted by the license The inspector examined the organizational structure and staffing level of the responsible QA organizations. Because this is MK's first involvement in a major safety related work with a Region I licensee, emphasis was placed on the examination and review of its QA program to determine the scope, adequacy, and effectivenes The inspector observed that currently MK's QA/QC staffing consists of twenty five (25) personnel . With a craft work force of approximately two hundred and sixty (260) in two shifts, the ratio of QA/QC to craftsmen is more than adequat The inspector also verified that at least three inspectors and three NDE technicians were always available in the vicinity of work on each shift. The QA manager of MK has sufficient independence to identify, correct, and report quality related problems to higher levels of management. The program is effective, and efficiently managed to accomplish the objectives of the program. MK-QA program is discussed in detail in paragraph 7.0 of this repor No violations were identifie .0 Design and Design Change Programs The inspector examined the licensee's programs for design and design changes to determine if the activities were conducted ir. accordance with the appropriate specifications, drawings, and approved procedures; and whether these requirements were technically adequate. The program was also reviewed to assess the adequacy of procedural controls established for the interfaces among the different organizations participating in the development of design and engineering criteria, independent technical review, technical and administrative approval, and the operational safety review of the change. The inspector reviewed the following documents:

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OQA-III-1; " Design Control", Rev. 1

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0QA-III-2; " Review of Plant Design Change Request", Rev. 2

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0QA-III-3; " Review of Engineering Design Change Request", Rev. 7

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Vermont Yankee Design Change Package, 85-1, " Reactor Recirculation System Piping Replacement".

Based on this examination, and review of the programmatic controls established for the design change process, the inspector determined that the licensee has established and implemented an effective design and design change control program. This was evident in: controls requiring review and approval of change engineering analysis supporting the chang requirement for formal documentation of reviews and approval .

-4- independent technical revie . plant operational safety revie No violations were identifie .0 Recirculation System Piping Modification As a result of the occurrence of intergranular stress corrosion cracking (IGSCC) in recirculation system piping at a number of Boiling Water Reactors (BWRs), the licensee has initiated a replacement program for recirculation piping to alleviate this proble The inspector reviewed the modification plan and examined the supporting documentation to verify that the modification plan and the engineering analysis of this change were acceptable. The NRC position regarding such modification's has been published in Generic Letter 84-07, " Procedural Guidance For Pipe Replacement at BWR's". The inspector reviewed and examined the following elements of the replacement plan as detailed below: Analysis The seismic stress analysis for the modified system has been perform'ed by General Electric, and is documented in the stress report. This analysis has been reviewed by the NRC and a Safety Evaluation Report (SER) has been issue , Fabrication, Installation, Examination and Testing The original piping design of the plant is based on the standard ANSI B31.1-1977. The modified piping system has also been designed and analyzed in accordance with the same standard to provide a common basis with the existing plant design. The fabrication and installation, however, is in accordance with the requirements of ASME code,Section III, 1980 Edition through the Summer 1982 Addenda. The inspection is also in accordance with the ASME Code, and preservice examination will be performed under the existing preservice program. The inspector found these to be acceptabl Quality Assurance and Interface Control The licensee has established a separate project team to accomplish the modification in an efficient manne The Recirculation System Pipe Replacement Project consists of several organization directed by a Project Manager who reports to the Manager of Operations. This is a major construction effort and, therefore, encompasses efforts from design, fabr :ation, and installation to inspection, test, and record keepin To fulfill the need for a comprehensive QA program covering the full spectrum of the modification activities, the licensee has issued a project specific procedure establishing interface

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-5-control and quality assurance requirements. This procedure ef-fectively integrates the existing procedures and responsibili-ties in the quality program from diverse organizations partici-pating in this projec The procedure addresses all eighteen criteria of the Appendix B to 10 CFR 50. The QA program as established and implemented is adequate for the projec System Modification and 10 CFR 50.59 Review The present recirculation system design consists of a circular header that forms approximately 300 degrees of a circle. The " halves" of the circle are hydraulically separated by two loop equalizer valves that are closed during plant operation. The inspector examined the audi-fication package to determine if the proposed modification has been analyzed and evaluated for system characteristics and any unreviewed safety questions. The inspector noted that the approved modification involved a total of twelve changes to the system. The changes ranged from material, configuration and seismic analysis changes to pipe .

insulation changes. The inspector's observation regarding these changes are summarized below:

The recirculation and residual heat removal piping material has been changed from type 304 stainless steel to Type 316 nuclear grade stain-less steel. The strength properties of Type 316 nuclear grade stain-less steel are equal to or better than those for Type 30 Type 316 Nuclear Grade Stainless Steel also has better IGSCC resistance. Addi-tionally, this change does not represent any new accident or malfunc-tion as well as a reduction in the margin of safety. Therefore, this change does not constitute an unreviewed safety questio The replacement Type 316 SS material has a modified chemical require-ment as compared to " standard". The maximum allowable carbon content in the standard Type 316 SS is 0.08%, whereas the replacement material has a maximum allowable of 0.02% carbon. In addition the material also has a small amount of nitrogen added to it. The strength reduc-tion due to lower carbon content is amply compensated by the addition of nitrogen. The altered chemical composition is projected to result in improved resistance to IGSCC. The material meets the recommenda-tion of NRC NUREG-106 The recirculation system configuration has been changed to provide two independent loops; each loop supplying ten jet pump drive nozzle The modified design physically separates the two " halves" of the ori-ginal system by removing le cross tie valves. The new system config-uration does not change the' operating and/or hydraulic characteristics, because the original system was operated with the valves close .

-6-The types of fittings used in the new system are different from the original syste The original system used standard component / pipe fittings such as tees, elbows, and " sweep-o-let" nozzle inserts. The new design utilizes formed pipe and integrally forged nozzles where possible. This change reduces the number of welds in the system, and therefore, potential for IGSC The seismic input (including damping values) for the recirculation and RHR system pipe stress analysis has been modified. The original design basis seismic input for the plant was based on the 1952 Taft earthquake (N69' W component) normalized to 0.079 . The analysis was based on the assumptions: 1) Two-dimensional earthquake; 2) No ver-tical amplification; and 3) 20 Hz. cut-off for amplificatio The new analysis is based on the assumptions: 1) Three-dimensional earthquake; 2) Vertical amplification; and 3) 33 Hz. cut-off amplifi-catio The analysis has been reviewed and accepted by NR Secondary thermal sleeve in the jet pump inlet nozzle safe ends has been eliminated. The original design for the safe ends utilized a secondary non-structural thermal sleev The new design has been analyzed to assure that the design requirements, as defined in the reactor pressure vessel specification, is met without the secondary thermal sleeve. The absence of the secondary sleeve does not affect the margin of safet The other five (5) relatively minor changes in the system are:

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Replacement of reflective insulation by blanket-type fiberglass insulatio Replacement of an old flow element by a new on '

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Elimination of valve body drain Rerouting of post-accident sampling lin Elimination of pressure sensing line to instruments PX-104A,

-105A, and -106 Based on the above examination, review, and evaluation, the inspector independently verified that this modification in the recirculation and RHR system does not involve: an unreviewed safety question as defined in 10 CFR 50.59; a reduction in margin of safety;

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-7- an increase in the probabilities or consequences of an accident or malfunction of system / equipment important to safety; and any substantial change in the bases of plant technical specification and/or Safety Analysis Reports (SARs).

Furthermore, the modification conformed with NRC guidance contained in Generic Letter 84-07. Also, the planning, scheduling, special project organization, and management controls especially instituted for this work was effective and efficient in assuring quality outpu No violations were identifie .0 Independent Verification The inspector reviewed drawings, specification and certified material test reports (CMTRs), and then performed a direct examination of fabricated pipe spool pieces to independently verify the spool geometry, specified attributes, and the general conditions of receipt and storage. The spool geometry was visually verified. The inspector carried-out rough measure-ments to verify spool / piping dimensions as specified on the drawing. The measurement was done by a standard commercial flexible tape measure. All dimensions were found to be acceptabl Additionally, the inspector obtained samples of Type 316 SS piping material and Type 308 welding wire for independent chemical analysis at NRC's option by an independent NRC contracto .0 Identification, Storage, and Control of Materials for Reuse The licensee's current plan calls for the reuse of some materials and equipment that have been removed from either recirculation or other systems in the drywell. Although a majority of these materials are to be scrapped, some major items such as valves, pipe and equipment supports, HVAC ducts, and shock suppressors are to be reused. These removed materials have currently been stored in the reactor buildin The-inspector examined the licensee's program to assure proper disposition of affected items and equipment. The licensee's storage, identification, segregation and control requirements were reviewed for adequacy and comple-teness. A visual examination of the stored material was performed to de-termine if sufficient identification and control measures were exercised to indicate the status of items, i.e., scrap or reuse; and if these mea-sures, as implemented, were adequate to preclude any inadvertent reuse of scrapped materia .

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To verify the effectiveness of these controls, the inspector performed a detailed inspection of-the storage area for general conformance to esta-blished requirements and environmental control, and randomly selected six items to verify traceability, disposition and status of the selected item The inspector noted: Due to contamination and radiation hazards, the materials were stored in radiation control areas in reactor buildin Except for the radiation boundary, the material within the storage area was not segregated into scrap or reusable item Of the six selected items, four were clearly tagged for status and traceability, one was not clearly identified on the outermost wrap,

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and one was found to be without any disposition or traceability that

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could be determined easily without unpackin The inspector identified items b and c above to the licensee's representa-tives. In response, the licensee informed the inspector that: the removal of the items had just begun, and due to the radiation hazard, the need to minimize the radiation exposure, and the limited indoor storage space for contaminated material, the program had not been fully implemented; the

- licensee was in the process of acquiring more outside shielded space for contaminated material storage for better segregation and control of scrap-ped materials; and if any item that was not fully traceable and identifi-able would be scrapped and not reused in any safety related applicatio , The inspector acknowledged the licensee's statement. This item will be followed up by NRC in. subsequent inspection for full implementation and

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effectiveness. (50-271/85-35-01)

7.0 Morrison-Knudsen Quality Assurance Program The inspector examined documentation and reviewed the program with cogni-zant licensee and contractor personnel to assess the adequacy of the con-tractor quality assurance plan and the control that the licensee exercises over the plan. To verify the adequacy of the Quality Assurance program and the control that the licensee exercises, the inspector examined the following documents:

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MK QA Program - 10 CFR 50 Appendix B, 4th Edition, 11/8/82

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MK Site Quality Procedure for VY Nuclear Power Station, Vol 1

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MK Field Quality Procedures for VY Nuclear Power Station, Vol 2

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MK Field Welding Procedures for VY Nuclear Power Station, Vol 3

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VY Vendor Surveillance Reports 84-69(7/31/84),84-69-1(10/17/84),

84-69-2(10/16/85)

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AP 6965.1, Rev 0, 9/21/85, VY Recirc Project Interface Procedure"

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SQP 5.1, Re'v o, 5/1/85, " Preparation, Revision, and Approval of Field Procedure SQP 2.1, Rev 2, 9/17/85, " Quality Program Description" Based on the above review, discussions _with cognizant personnel, and personal observations, the inspector determined the following:

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The QA program and the plan are patterned to assure compliance with 10 CFR 50 Appendix B criteria and implemented in the field

, through procedures. Each procedure is numbered to reflect the criteria it was written to addres Site Quality Procedures are issued to assure quality related duties performed by multiple site organizations are coordinate Field Quality procedures are issued to direct the work of the i contractor's Quality Group on site. Field Welding Procedures are issued to assure the contractor's welding program is being implemented. The QA plan adequately defines the scope of the QA program and the details of applicability and implementation are presented in the contractor's procedures.

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The contractor's QA program was reviewed by the licensee and documented in Vendor Surveillance Reports 84-69, 84-69-1 and 84-69-2. The licensee reviewed the QA plan and determined that it satisfied the applicable criteria of 10 CFR 50 Appendix The licensee also reviewed the corporate implementation of the QA plan and the site implementation of the program and determined that they were in compliance with the program. The contractor was included in'the licensee's Approved Vendors List for oper-ating plants following the closure of Vendor Surveillance Report 84-69-0 The licensee reviews and approves the contractor's procedures as stated in the contractor's procedure SQP 5.1 and the licen-see's interface procedure AP6965.1 before implementation. Each

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procedure's cover sheet must have the licensee's signature of approval which insures that the licensee reviews and accepts the procedur No Violations were identified.

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The details'of the inspector's review of the above QA program are given below: Instructions, Procedures, and Drawings The inspectors reviewed Site Quality Procedures (SQP) 5.1 "Prepara-tion, Revision and Approval of Field Procedures" to determine the method and adequacy of procedure preparation. This procedure re-quires preparation by the section within the contractor's organiza-tion that will either be the user of the document or is best quali-fled to write the procedure. After it is written it is reviewed and approved by the Project Engineering Manager (PEM), the Project Qua-

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lity Manager (PQM), the Project General Superintendent (PGS), and the Project Manager (PM). When these reviews and approvals by the con-tractor have been completed the procedure is transmitted by the PEM to the licensee for review and approva The licensee may disposition this procedure in one of three ways, namely, " Approve", " Disapprove", or " Approve with Comments". Proce-dures " Approved with Comments" must be revised to incorporate the licensee's comments prior to use. The originating section is respon-sible for resolving licensee comments. When the licensee has approv-ed the procedure, the PEM approves and obtains approval from the PQM, PGS, and PM. Approved procedures are issued in accordance with SQP 6.1 " Document Control".

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The inspectors also reviewed SQP 5.2 " Preparation, Control and Issue of Controlled Work Packages".

A Work Package is a multi part document used to provide detailed scope, instructions and control of a specific work task in the fiel This multi part document provides sufficient information to assure that the required quality levels of the work are met. The Work Package consists of a Work Package Cover Sheet, Site Work Instruction (SWI), and necessary attachment A Site Work Instruction is that portion of a Work Package which spe-cifies the work requirements, work sequence, and inspection Hold Points required for a given Work Package. The SWI is a Quality As-surance record and shall be afforded care and mcintenance to the ex-tent required to preclude loss and damag The Discipline Engineer (DE) is responsible for preparing work packages and writing the SWI. Work packages are reviewed, applicable hold points determined, and approved by the PEM, PGS, Health Physics Manager g (HPM) and PQM prior to transmittal for licensee approval. Approved work packages are held by document control until neede . _ , _

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-11-When needed, document control issues one controlled " Master" copy and other controlled copies as required. The " Master" copy is the work controlling, signature, and record copy. Currently 54 work packages are planned for completion of the installation of replacement recirculation and RHR system Individual work packages reviewed by the inspectors are listed in the appropriate sections of this repor Review and approval of field welding procedures is the responsibility of the welding engineer. The NDE level III is responsible for review and approval of NDE procedures. In addition the NDE Level III is responsible for demonstrating the adequacy of NDE procedures to satisfy the intended purpos . Control of Special Processes The contractor is conducting extensive qualification and training for machine operators and welders / welding operators under conditions simulating those to be found in the plant. The inspectors witnessed a welder qualification in progress and welding of a simulated 28" valve to pipe machine weld. Welders / welding operators are being qualified for both manual and machine welding. In addition to assur-ing the ability of the individuals this has the advantage of having the welding operator qualified to make manual repairs if require To reduce radiation exposure the welding is remotely controlled using video equi pent and one welder / observer at the weld. The welder /ob-server is in audio communication with the operator. The video pic-ture was acceptable but the resolution was not good enough to elimi-nate the observe A full scale mock up of the N1A nozzle was being used to train opera-tors in actual field conditions. This mock up was complete with ra-diation protection in place, restricted access for the set up and operation, simulated step off pads, radiation work permit and a health physics technician in attendance. The mock up training has provisions to conduct simulated training with personnel wearing anticipated pro-tective clothin Another task on this project is to replace the vessel drain lin The contractor has built a mock up of the conditions around this drain line including simulated control rod drive housings to assure this task can be performe There was no ongoing activity at the time of the inspectors visi .-. . .. . -- .-. . . - . . .

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There were approximately eleven machines available for end prepara-1 tion of the pipes. These were set up for various types of conditions ranging from no restrictions to those found at the NIA nozzle mock u The contractor plans to plug nozzles from the inside of the vessel to prevent machine chips from enterin These mock-up operations were either being controlled by existing

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procedures or being used to develop procedures. Quality control inspectors were being used to monitor the processes and were being trained for the conditions expected during installatio The control of special processes was adequate and no violations were identifie . Receipt Inspection The inspector examined documentation and reviewed receipt inspection reports with cognizant contractor personnel to assess the adequacy of the centractor's receipt inspection program. To verify the effectiveness of the implemented procedures, the inspector examined the following documents-

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FQP 7.1, Rev 1, 9/11/85, " Receipt Inspection"

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SQP 7.1, Rev 2, 9/25/85, " Material Control and Identification"

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Receipt Inspection Reports (Table-1)

, Based on the above review, discussions with cognizant contractor personnel, and personal observations, the inspector determined the following:

The reports examined by the inspector were in various stages of completion and pertained to both the licensee's and the contractor's material. The inspection process consists of a visual inspection and dimension verification followed by a documentation review. The accept / reject criteria are based on the contractor's procedures and the licensee's specifications. Licensee owned material, such as the recirculation pipe, is inspected by the contractor and the license The contractor performs the initial visual inspection and dimensional verification and then the licensee verifies the results through their own inspection and performs a dccumentation review. The contractor verifies the documentation review performed by the licensee and if

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accepted, the quality assurance engineer authorizes the release of the material. Material which is rejected requires a nonconformance report. Of the reports examined only three pertained to licensee

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-13-material, two of which involved spare pipe spools, were complete, and authorized for release. The remaining pipe spools were in the process of documentation review by the licensee. No pipe, to be permanently installed, has gone through the complete receipt inspection process and been released for use at the time of this inspection. The receipt inspection process was adequate with sufficient control being applied to assure procedures are followe No violations were identifie . Control of Measuring and Test Equipment (M&TE)

Procedures SQP 12.1 Rev. I "Use of Measuring and Test Equipment" and FQP-12.1 Rev. 3 " Control of Measuring and Test Equipment" describe how the contractor controls the calibration, issue, use, and recall of M&T The p0M is responsible for controlling M&TE. The inspectors visited the M&TE storage area, examined the method of storage, and the record The calibrated devices are stored in a lockable cabinet in the quality assurance office. When devices are issued they are each logged out on a_ separate log sheet that has the users name and date ou Upon return the date in is noted with the users comments if any. A review of the calibrated tool _ log showed seven clerical errors in approxi-mately 900 entries. None of these errors indicated the program was out of contro Several dial indicators had been removed from the calibration program and were in use in the training of machinists. Such use in training has no effect on safety and would have the effect (if any) of making the machinists task more difficult since the principal use observed was in centering mandrels for tool mounting. During installation only calibrated devices will be use Tool numbers are recorded on data sheets as data is recorded. This information together with the sign out log allow traceability if a tool is found out of tolerance during calibratio No violations were observe . Nonconformance Reporting / Corrective Action The inspector examined documentation and reviewed nonconformance reports with cognizant contractor and licensee personnel to assess the adequacy of the contractor's nonconformance control and correc-tive action measures. To verify effectiveness of the implemented procedures, the inspector examined the following documents:

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SQP 5.2, Rev. O, 5/1/85, " Preparation, Control and Issue of Work Packages"

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SQP 15.1, Rev. 2, 9/17/85, " Control of Nonconformance"

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Nonconformance Reports (Table 2)

Based on the above review, discussions with cognizant contractor and licensee personnel, and personal observations, the inspector deter-mined the following:

.The nonconformance reports (NCRs) examined were the result of poor identification of materials, material damage, out of specification material, unapproved vendors, and the mistreatment of hold point Nanconformance-reports are issued by the contractor's Quality Control Supervision and hold tags ar- issued to identify the nonconformance in the field. The contracto 's engineering group is responsible for evaluating the condition and proposing corrective action. The pro-posed corrective action is approved by the contractor's Project Engineering Manager and Project Quality Manage Proposed corrective action for nonconformances classified as " scrap", "use-as-is" or "re-pair" and pertaining to licensee furnished material must be approved by the licensee. SQP 15.1, Rev 2, does not clearly define the licen-see's responsibility to inform the contractor in writing of their own proposed corrective action or any changes or additions to the contrac-tors proposed corrective actio After licensee approval, the contractor's engineering group reviews the disposition of the NCR to assure compliance with all applicable requirements and the action party is issued the authority to implement the approved disposition. The contractor's quality control supervisor assigns an inspector to reinspect the corrected condition and to re-move hold tags, if acceptable. The quality control supervisor reviews and closes the nonconformance repor The contractor's nonconformance reporting system is adequate and sufficiently controlle Nonconformance report No. 007 is an example of the contractor not receiving formal approval from the. licensee. The contractor proposed to use out of specification cation resin as is but made'no:Justifi-cation because the licensee would generate their own nonconformance report. The licensee accepted the resin for use but never informed the contractor of the reasons. To insure that all pertinent informa-tion is transmitted in the future, the contractor has proposed a re-vision to SQP 15.1, Rev. 2. This revision would require the licensee to attach or reference the generated nonconformance report to the original contractor report before returning the contractor's report to the contractor. The inspector reviewed a draft of the required procedure change and found it acceptabl .

, -15-As of November 4, 1985, three of the twelve nonconformance reports (NCR009, NCR010, NCR012) involved the mistreatment of hold points in work packages. This repetitive nonconformance was identified by the licensee and contractor. The corrective action taken was to hold a contractor training session to refamiliarize craft and management with SQP 5.2, Rev. O. The inspectors attended this training sessio During this training session, recurring problems and the steps taken to correct these problems were discussed. Special emphasis was placed on the importance of hold points in work packages. Detailed examples were used to point out the correct use and sign off of the work pack-age The contractor's management also established a method of fami-liarizing those involved with hold points through preconstruction meetings. Also discussed were the disciplinary actions that may be taken if the work packages were not properly processed and signe There were no written corrective action requests issued as of November 4, 198 However, the contractor management agreed to issue written corrective action requests for such instanes in the future. The inspectors found the licensee / contractor actions in this regard to be acceptabl No violations were identifie . Audits and Surveillances The inspectors reviewed the licensee's surveillance reports on the contractor, and reports of the contractor's internal audits. Contrac-tor audits are required by FQP 18.1 Rev. 2, " Audits." Qualification of auditors is established in FQP 2.3 Rev. O, " Qualification and Certification of Audit Personnel."

The inspectors reviewed the contractor internal audit schedule toge-ther with audit reports covering the period from the project mobili-zation to present. The schedule calls for all criteria of the pro-gram to be audited during the scheduled life of the project. Also each Work Package will be i.. sted to insure proper completion. A review of audit reports 85-02 (8/12-16/85) covering procurement acti-vities and audit report 85-06 (10/28-11/1/85) covering nonconforming materials and quality assurance records, indicated one deficiency, namely, the document distribution list was not approved by the PEM and PQM. This deficiency has been correcte The inspectors' reviews of the licensee surveillance reports are summarized below: Licensee Surveillance of General Electric Company (GE)

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-16-The inspector examined audit and surveillance reports of engi-neering, analysis, and other technical services provided to the licensee by GE. These surveillances assessed the adequacy-of GE's administrative controls over its activities in these areas, and the effectiveness of these controls in assuring quality outpu The inspector reviewed the following documents:

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VY Purchase Order 22959

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Surveillances: VSR 84-58; VSR 84-58-1 VSR 84-58-2; VSR 84-58-3

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PSSA Report 23A4591, Rev. 0

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Memorandum 003658 MEM-PT-PT, 8/13/85 Based on the above examination, the inspector determined that GE's administrative controls were adequate and effective. Two items identified by these audits /surveillances were promptly resolved and closed in a subsequent audit. A concern regarding the control of interfaces was also identified by the license The audit report, however, recommended additional audits and/or

. surveillances to evaluate this are No violations were identifie B. Licensee's Surveillances on MK Activities To assess the adequacy of MK's administrative controls in this area, the inspector examined Surveillances VSR 85-47, VSR 85-51, VSR 85-51-1 and VSR 85-51- The above audit /surveillances covered activities in the area of

. NDE, material control and identification, and training and indoctrination of personne Following items of concern were identified in these surveillances:

(1) Te s t. pieces used for NDE certifications were not properly identified and did not have maps of known defect (2) One radiograph had a linear indication, but was not identifie (3) Tests following indoctrination had no pass / fail criteri (4) Material Receiving Notices (MRNs) were not properly filled ou (5) A lack of proper ventilation in warehouse / storage roo . . .. =. - . . . - _ - . .

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. -17-The inspector. verified that the above concerns were adequately addressed by MK management, and were either resolved or were in the process of resolution. The licensee's surveillance program in this area is effectiv No violations were identifie ,

8.0~ Exit Interview

At the conclusion of the inspection, the inspectors met with the licensee management on November 8, 1985. (See paragraph 1 for attendees). The

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inspectors presented their findings to the licensee representatives at this meeting. The licensee did not indicate that there was any proprie-tary material involved in the inspection.

. At no time during this inspection was written material provided to the licensee.

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-18-e TABLE 1 Morrison-Knudsen Receipt Inspection Reports R-0096-MK Weld Prep Gage (open for documantation review)

R-0108-MK Lead Blankets (authorized for release 10/8/85)

R-0109-MK Chain Holst (authorized for release 10/11/85)

R-0111-MK Abrasive Wheels (authorized for release 10/11/85)

R-0034-VY Recirculation Pipe Spools (open for documentation review by licensee)

R-0045-VY Recirculation & Residual Heat Pipe Spools (authorized for release 9/4/85)

R-0046-VY Pipe Spools-Spares (authorized for release 9/4/85)

TABLE 2 Morrison-Knudsen Nonconformance Reports NCR 001 Poor Identification on welding wire spools NCR 002 Broken seals on weld R00 containers NCR 003 Poor Identification on bare wire NCR 004 PN_ Services not on M-K approved vendors list

.NCR 005 No ASME specification or manufactures name on consumable insert 10 TAG NCR 006_ Welding material used before receipt inspection NCR 007 Cation resin out of specification NCR 008 No ASME specification or manufactures name on consumable insert I.D. TAG NCR.009 Bypass of VY hold point - step 630, work package 5030 NCR 010 No signatures for hold point-step 100, work package 5030 l

NCR 011 No ASME specification on consumable insert NCR 012 By passed VY QA hold point-step 580, work package 5040 l