IR 05000322/1979007
| ML19257C108 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/20/1979 |
| From: | Mcgaughy R, Paolino R, Toth A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19257C104 | List: |
| References | |
| 50-322-79-07, 50-322-79-7, NUDOCS 8001240397 | |
| Download: ML19257C108 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-322/79-07 Docket No. 50-322 License No. CPPR-95 Priority:
Category: A
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Licensee: Long Island Lighting Company 175 East Old Country Road Hicksville, New York 11801 Facility Name: Shoreham Nuclear Power Station, Unit No.1 Inspection at:
Shoreham, New York Inspection conducte : May 22-25, 979 h'2 6' h Inspectors:
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A. D. Toth, Re tor nspector date signed
/lA.$
R. J. Paolino, Reac' tor Inspector
~ 9-25 99
date signed Approved by:
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N20 Yf R. W. McGaughf,Ghief, Projects date signed Section Reactor Construction &
Engineering Support branch Inspection Summary:
Inspection on May 22-25, 1979 (Report No. 50-322/79-07)
Areas Inspected:
Routine, unannounced inspection by two regional based inspectors of Quality Assurance Procedures for instrument components / systems; Work activities for structural steel welding, implementation of piping hold notices, and instrument tubing installation; Quality verficiation records for separation of race-ways, control of Engineering and Design Coordination Reports, recirculation system pipe cleanliness control, licensee action on a vendor Part 21 report. The inspectors also performed plant tour-inspectior.t, reviewed licensee action on previous inspection findings, and interviewed personnel regarding removal of a possible blockage of circulating water discharge piping.
The inspectors performed follow-up action as necesssary to resolve questions which arose 1796 036 8o01240 39}
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during the course of inspection of the above areas.
The inspection involved 53 inspector hours onsite by two NRC regional office based inspectors.
Results: Of the 11 areas inspected, no items of noncompliance were identified in 8 areas; three apparent items of noncompliance were identified in three areas.
(Infraction - weld joint fitup contrary to procedures Para. 3; Infraction - failure to promptly correct raceway separation nonconfonnance prior to installing cable - Para. 5; Infraction - design and installation of instrument tubing contrary to separation criteria - Para. 6).
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-3-DETAILS 1.
Persons Contacted Long Island Lighting Company
- J.M. Kelly, Field QA Manager
- L.C. Lilly, Site Manager W.J. Museler, Assistant Project Manager
- P. Novarro, Project Manager
- A.W. Wofford, Vice President Stone and Webster Engineering
- T.T. Arrington, Superintendent Field QC R.S. Costa, QA Program Administrator S. Crowe, Senior FQC Engineer
- C.A. Fonseca, Head, Site Engineering Office
- J. Hassett, Senior QC Inspector
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- K.A. Howe, General Superintendent Construction G. Kowtowski, Control Engineer R. Perra, Supervisor QC Inspection D. Pope, Assistant Superintendent, Yard W. Sullivan, Supervisor, Yard W. Taylor, Senior QC Inspector J. Wice, Senior QC Inspector Courter and Company
- V. Acuri, Construction Manager A. Cifarelli, Construction Supervisor
- A. Czarnowski, Project Manager C. Drebitko, Lead Inspector R. Kaer, Senior QA Representative J. Makris, Certification Coordinator
- R.C. Nayar, Project Engineer
- D.W. Papa, QA Manager
- A. Pryor, Assistant Area Supervisor
- R.E. Scott, QA Engineer D. Spence, Certification Coordinator (Acting)
Reactor Controls Incorporated K. Aspinwall, QC Supervisor 1796 038
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-4-General Electric Company
- R.M. Pulsifer, Resident Site Manager J. Cockroft, QC Representative Hartford Steam Boiler I&I
- G.F. Cocuzzo, Autnorized Inspector
- W. Meyer, Authorized Inspector In addition to the above, the inspectors interviewed various contractor supervisory, administrative and craft persolnel during the course of the inspection, relative to records retcieval, status of work, and general site activities.
- denotes those present at the exit interview.
2.
Plant Tour Shortly after arrival onsite the inspectors visited various parts of the plant to observe work activities in-progress, completed work and plant status. Observations made during this general inspection of the plant were considered,as warranted,during later inspection of the construction quality assurance program implementation in specific areas. Additional plant tour inspections were also con-ducted at other periods over the duration of the inspection.
The inspectors examined work for ary obvious defects or noncompliance with regulatory requirements.
Particular note was taken of presence and/or availability of quality control inspectors, and quality control evidence such as inspection records, material identification, nonconforming material status, inspection / process hold-point status, housekeeping and equipment preservation.
The inspectors interviewed craft personnel, supervision and quality inspection personnel as such personnel were available in the work areas.
During the plant tour, en inspector observed a questionable presence of some weld rod (discussed in detail paragraph 4) and questionable weld joint gaps in CRD support brackets (discussed in detail paragraph 3). Other than the item in paragraph 3, no items of noncompliance were identified during the plant tour.
3.
Control Rod Drive Beam Support Bracket Welds During the plant tour inspection an inspector observed that a titup gap exists between the wall and the support bracket in at least 4 of 20 locations.
The inspector requested the Reactor 1796 039
-5-Controls Incorporated personnel to assess the extent of the gap, and he reviewed governing RCI weld procedures and inspection criteria. The inspector examined the following documents:
RCI Drawing 11600.02-5.04-40A
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RCI Detailed Welding Specification WS-104 Revision 0
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RCI Detail "C.R.D. Beam Support Bracket to R.P.V. Pedestal
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Weld Identification - Ref. WS-104 9-22-75" RCI Welding Data Sheet #29 - for welds #17 and 17A
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The RCI site manager and quality control supervisor inspected the questionable weld joints and ascertained that gaps up M 3/16" wide exist 9d, of variable length due to non-uniformity of fitup.
The NRC inspector determined that the applicable RCI welding data sheet #29 did not provide for fitup gaps and showed contact fitup of the weld joints for the fillet welds.
The RCI personnel could identify na design change or other document which provides fitup criteria r.ther than contact fitup.
The RCI quality control acceptance of the joint which does not conform to the contact fitup, or the absence of criteria for accep-tance of other than the contact fitup shown in the governing weld procedure, represents a noncompliance with Criterion V of Appendix B of 10 CFR 50.
(322/79-07-01)
4.
Licensee Action On Previous Inspection Findings (Closed) Unresolved Item (322/78-16-03):
Inspection criteria for instrumentation tubing.
Stone and Webster procedure QAP-10.13 has been issued, including criteria on pitch and radius.
This item is resolved.
(Closed) Unresolved Item (322/79-06-04):
Updating hydrostatic testing composite diagrams.
The inspector was shown a file of composite drawings marked in red, and a file drawer of hydrotest files for tests conducted to date on portions of various piping systems. The inspector selected file #C11-4 for a portion of the RHR system and checked it against drawing FM-208-11 to ascertain proper identification of the test boundaries.
The Courter ASME III hydrotest certification coordinator demonstrated a similar check of Core Spray System test E21-16 against drawing M-10118-11.
A new coordinator has been assigned by Courter and he declared his intention to maintain the records on the basis now established.
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-6-(0 pen) Noncompliance (322/78-02-01):
Failure to control weld material in accordance with procedures. This item was previously addressed in reports Nos. 50-322/78-06, 78-12, and 79-06.
During the current inspection the inspector observed the equivalent of the contents of one portable electrode oven lying loose in a group on a ledge of the reactor shield.
The inspector observed no welders working with the material, and the accompanying licensee site QA auditor could not identify the source of the material.
The site manager issued a May 24, 1978 instruction to all contractors, department heads and engineers requiring all contractors on site to require all used and unused electrode to be returned at the end of each shift, and UNIC0 Supervision sampling of returned electrode quantities (one contractor per week). Three offenses of discrepan-cies are to result in withdrawal of all qualifications for the welder involved.
Failure to take disciplinary actions will be treated as a security matter and treated accordingly.
This item remains unresolved pending completion of licensee analysis and reviews.
(Report 50-322/79-04):
Training of electrical field QC inspectors.
The inspector examined training / certification files of two individuals. Appropriate certifications were included and graded-evaluated written quizes included for initial training and a recent training session, as indicated by the inspection supervisor during inspection 79-04.
(0 pen) Unresolved Item (322/79-04-04):
Discrepancy between S&W and Cives structural steel drawings.
The inspector reviewed current status of this item. A QC inspection rtoort indicates that FQC has examined some of their inspection records and found that they had accepted a weld in accordance with a Cives drawing which was not in agreement with the S&W drawing.
The field QC supervisor has requested the group which approved the Cives drawing to re-review all such _ drawings to verify proper incorporation of inspection parameters.
This action appears apt m riate to prevent recurrence and to correct any existing discrepi es.
The item is unresolved pending completion of FQC action.
5.
Separation of Raceways The inspector examined an Engineering Design and Coordination Report (E&DCR) number F-19039 dated March 14, 1979.
This document permits installation of cable into raceways which are known to 1796 041
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-7-violate the separation criteria defined in Shoreham FSAR sections 3.12.3.5.2.c and 3.12.3.5.2.d.
Stone and Webster Field Quality Control Procedure 12.1 Revision C requires that field QC inspectors verify that raceway ' separation criteria'are adhered to prior to the installation of cable.
The E&DCR eliminated the work hold established by this requirement, by keying to a specification provision which permits deviation from quantitative ' separation criteria' for raceways, as long as each case of deviation is documented in an E&DCR.
The ' separation criteria' thus became simply a matter of verifying existence of an E&DCR. The responsible site personnel stated that this aporoach results in the Field Quality Control Procedure 12.1 not having been changed. Accordingly, E&DCR F-190';9 had not been submitted for review or approval by divisions of Stone and Webster responsible for QCP-12.1, such as the field Quality Control Division, Chief Engineer of Quality Systems Division, Project QA Manager, or Construction Manager.
When questioned regarding the individual E&DCR's which identify
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deviations from the separation criteria in the FSAR, the Stone and Webster representatives stated that resolution of these E&DCR's would be defined in conjunction with a study which would investigate the safety implications for hypothesizing destruction of various zones of the facility. As a result of that study, some of the E&DCR's may be accepted as is, while others would require removal of the cables and rework, or other actions.
The inspector stated that the FSAR appeared to commit to specific minimum separation criteria without recognition of such a study, and that the basis for classifying E&DCR-F-19039 as "FSAR Change - No" was not clear.
The inspector stated that the current activity is unacceptable from the viewpoint of 1) continued building and development of conditions contrary to the FSAR criteria, 2) handling of the E&DCR by absence of referral to concerned branches of the S&W organization and 3)
absence of FSAR impact identification.
The inspector stated that the continued development upon non-conforming conditions appeared to be contrary to a control principle inherent in the objectives of the QA program, and the E&DCR-19039 involves aspects of Criteria III, VI, X, XV and XVI of 10 CFR 50 Appendix B.
The provisions, which undermine the measures established to assure that nonconforming conditions are promptly identified and corrected, particularly appear contrary to Criterien XVI.
(322/79-07-02)
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-8-Relative to ':he above matter, the inspector had examined the following specific documents and interviewed r.sponsible QA, QC, and Site Engineering personnel.
E&DCR's:
F-19039, 20359, 19726, 18416, 18178-18182, 17355,
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17091, 17471, 17571, 17833-34, 17968, 17861-62, 9467-69, 10160-E.
QC Procedures 12.1 fievision C and 4.1 Revision C
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Engineering Assurance Procedure EAP-6.3 Revision 3
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6.
Instrumentation Components / Systems - Observation of Work Activities a.
By direct observation, and independent evaluation of work performance, the inspector verified that work activities relative to instrument components 1E51*PT001 and 1E51*PIO11 are being accomplished in accordance with NRC requirements and SAR commitments.
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For this determination the inspector reviewed:
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Component check list dated June 7, 1978 Instrument check list dated February 1, 1979
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Instrument Control drawing no.100bI CN9-2 revision 0
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Rod Requisition Nos. 14912, 14913 and 14914 Field Weld sheets dated December 21, 1978 and December 29,
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1978
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Material Requisitions and Control Form Serial Nos.
C-00643, C-6835 and C-6753 Welder Certification list - Memo of April 13, 1979
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No items of noncompliance were identified.
b.
The inspector performed a line walk inspection of:
(1) The instrument tubing installation from the Main Steam Instrument Rack B, panel no. H21*PNL-015, Recirculating Pump Systems Rack A, panel no. H21*PNL-006 and Main Steam Instrument Rack D, panel no. H21*PNL-015 located in the Reactor Building, plan el. 40'-0".
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(2) The instrument tubing installation from the RCIC Instrument Rack A, panel no. H21*PNL-017 and the RCIC Leak Detection Rack B, panel no. H21*PNL-037, located in the Reactor Building, plan el. 8'-0".
The inspector noted that the tubing separation was not in accordance with specification no. SH1-343 revision 1, dated August 11, 1978. Section 2, line 28.8, pg. 1-26 of the specification states "In areas where no physical barriers are provided to protect instruments and lines from damage by a credible common cause....shall be separated by a great a distance as practical.
In no case shall there be less than a minimum distance of 4 ft. in all directions and barriers shall be routed so as to decrease the possibility of crossing impulse lines of different redundant channels."
The inspector informed the licensee that this was en item of noncompliance and an infraction of Criterion V of 10 CFR 50, Appendix B.
(50-322/79-07-03)
7.
Instrument Components / Systems - Review of Quality Records The inspector reviewed pertinent work and quality records for instrument components associated with process variables of systems required for safe shutdown to ascertain whether the records meet established procedures and whether the records reflect work accomplishments consistent with NRC requirements and SAR commit-ments in the area of instrument component installation and qualification records for QA and Inspection (QC) personnel.
Documents examined for this determination include:
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Surveillance Inspection Report No. VS-56 per QC-20.2, QAP-1.1 and QAP-1.2 dated January 22, 1979 Surveillance Inspection Report No. VS-55 per QC-20.2 and
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QAP-14.2 dated December 14, 1978
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Instrument Tubing Run Drawing M-10062-6 (FK-1C-6) for Main Steam System B.
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Documentation package for panel nos. H21*PNL-019 and H21*PNL-014 1796 044
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Installation Records for instrument nos. E21*PT-0018 rack A-1,
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hanger nos. 2 and 5; E21*PDS 038B(LP) rack A-7, hanger nos.
19, 22 and 27; E41*PS026A rack A10, hanger no. 2 and E41*PISO98 rack A-5, hanger nos. 2, 16 and 20 C.I.P.-6.8 dated June 30, 1978 entitled " Qualification of
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Pressure Test Supervisor" QAP-10.13 dated March 20, 1979 entitled " Final Installation
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Inspection of Instrumentation" QC-12.2 dated February 16, 1979 entitled " Instrumentation
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Control Program" Field Audit Record Nos. FA-826, FA-880, FA-920 and FA-934
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In addition, the inspector reviewed the qualification records of two QA/QC personnel.
The records appear to be complete and current.
Records confirm that personnel are adequately qualified for their assigned duties.
No items of noncompliance were identified.
8.
Review of Engineering and Design Coordination Reports The inspector examined a March 1979 LILC0 site QA audit nf the E&DCR control program, to ascertain the adequacy of controls to assure incorporation of design changes into the physical plant.
The audit encompassed the more than fifteen on-site locations where copies of various E&DCR's would be sent, and it included each on-site contractor and the field quality control organization.
It considered presence of E&DCR and references to the E&DCR on drawings /
specifications at the various stations.
Where deficiencies were identified, requests for corrective action had been issued.
The inspector considered the audit and its results relative to the QA program requirements of Section 17 of the Shoreham FSAR.
The inspector interviewed the auditor and his supervisor regarding the sample size selection criteria, the type of the deficiencies noted, and the general statistics of the study.
The audit report did not address document control specific discrepancies comon to inspection and construction groups, but it did include data to permit such assessment (such discrepancies were not apparent in the audit data).
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As a result of the NRC inspector's questions, the licensee project manager convened a 5/24/79 meeting of all UNICO discipline super-intendents, S&W quality control, S&W field engineering, LILC0 site QA, and senior site management to assess duplicate systems of control of changes. A presentation was made to the NRC inspector regarding types of E&DCR's, and various control systems to provide confidence that changes would in fact be incorporated into the plant.
Categories discussed included:
a.
Interferences - where obviously work cannot proceed until the interference is resolved.
b.
Hangers - where there are a computerized hanger status log, an individual drawing for each hanger, field drawing revisions occurring at the time an E&DCR is dispositioned.
c.
Cable pull routing - where changes are not controlled by E&DCR's but rather by pull ticket changes.
d.
Piping nonconformance reports by the piping contractor -
where tracking of the resolution is controlled by the piping contractor's NR control, with the E&DCR being the S&W redundant in-house control.
e.
Piping as-built program for stress analysis verification -
where a separate set of isometric drawings, with E&DCR's, is used for system walk down by two separate groups.
f.
E&DCR verification program - where the sita engineering office specifically reviews those E&DCR's which can affect operations (marked " verification required") on the E&DCR.
Each of these is identified in a master log.
g.
System operation verification - where the construction discipline (electrical) assistant supervisor is required to verify completion of E&DCR's prior to system turnover.
The inspector was familiar with these controls as a result of previous NRC inspection activities, and concluded that the verifications described above provide confidence that an E&DCR misplaced at one location would be identified and incorporated into the physical plant as intended by the designers.
The inspector identified no items of noncomplisnce.
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9.
Structural Steel Welding Work Activities The inspector observed welding in-progress on a single'-vee joint,
- FW-99-1 (FS-23AZ) of a horizontal gusset plate in the containment building. The inspector interviewed the Dravo welder, the area foreman, a LILC0 auditor and a LILC0 welding engineer regarding conduct of the specific work, and welding in general.
The inspector examined the weld for removal of slag between passes, uniformity of-bead, side wall fusion, and preheat.
He examined the drawings and weld procedure for correlation with the weld joint location, con-figuration, materials and preheat.
He examined the welder's qualification card for correlation with the procedures.
He examined the Magnetic Particle Examination Sheet for evidence of QC magnetic particle examination of the root and 50% thickness material. The inspector considered the above relative to AWSDI.1, and quality program requirements of Section 17 of the Shoreham FSAR.
He examined the following specific documents, as stated above:
Drawing #FS-23AZ (Cives)
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Magnetic Particle Examination Sheet - W70H Rev. I for FW-99-1
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Welder Qualification Identification Card - #N33 Welding Procedure W70H
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No items of noncompliance were identified.
10.
Implementation of Piping Hold Notices During his plant tour-inspection, one inspector selected four typical Courter Company " hold" tags on piping in the reactor containment building.
He reviewed the associated nonconformance reports (NR #468 and #517) or deficiency correction orders (DC0 #1139,
- 737,#738,#759) associated with these to ascertain that work had not progressed beyond the intended holdpoints.
He interviewed a deputy foreman responsible for piping in this area, and examined his recr ds of work-in-progress to correct items on three DC0's (#?37, #
'8, #759). He ascertained that quality control inspection was invo!ved in the final disposition.
The subjects of these NR's and DCO's included repair of arc strikes and nicks on piping, relocation of a piping tap (sockolet), repair of overgrinding and related check of pipe minimum wall, and repair of a valve linear indication and subsequent nondestructive test and wall thickness check.
The inspector ascertained that the deputy foreman was familiar with the selected hold points and was aware of quality control documentation and inspection hold points.
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No items of noncompliance were identified.
11. Recirculating System Piping Cleanness The inspector interviewed the GE site QC representative regarding crawl through and associated visual inspection of the reactor recirculating water system inlet header.
The GE representative stated that he had personally performed the crawl through inspection required by GE specification #22A2537 Revision 1 part 7-2.2.1 (j).
The inspector also reviewed the cleanliness check records for pre-welding inspection of welds #FW-B31-NS006-BW-10, 12 and 13 of recirculating water risers from the header.
No items of noncompliance were identified.
12.
Licensee Followup on a Part 21 Report The inspector reviewed licer.see action relative to reported defects in Farr Company carbon cells and test canisters.
Licensee notification, evaluation, and corrective action is reflected in the following documents reviewed by the inspector:
Letter, Farr Company /NRC dated 10-19-78
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Letter, Farr Company /LILC0 dated 11-1-78
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LILC0 Reportable Deficiency Followup Report dated 11-1-78
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Memo LILC0/S&W Project Engineer dated 3-2-79
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Memo S&W Project Manager /LILC0 dated 4-19-79
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No items of noncompliance were identified.
13. Reactor Vessel Feedwater Nozzle Examination The inspector interviewed LILC0 and GE site personnel regarding in-progress investigation of marginal linear indications at the root of the nozzle / pipe weld of RPV nozzle N4B (azimuth 135g).
These nozzles had been bored for installation of piston-type thermal sleeves, such that the indications are not attributed to geometric discontinuities. Original radiographs and current investigatory radiographs show no lack of fusion or linear indications.
This item is unresolved pending completion of the licensee investigation and review of the results.
(322/79-07-04)
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14. Circulating Water Discharge Pipe Blockage A Long Island citizen contacted the NRC regional office to comment on the existence of an nluminum boat in the circulating water discharge pipe. The citizen was concerned that the boat may not have been removed.
The boat was used during construction for inspection in the pipe.
Discharge to this pipe is through standpipes which can overflow if the downstream piping is blocked, and the matter is not a safety related concern.
However, the inspector interviewed two responsible personnel on-site who witnessed cutting and removal of the boat in late 1978. The inspector had no further question on this matter.
No items of noncompliance were identified.
15. Unresolved Itemt Unresolved items are matters about which more information is required by the inspector in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
An unresolved item disclosed during the inspection is discussed in paragraph 13.
16. Management Interview At the conclusion of the inspection on May 25, 1979 a meeting was held at the Shoreham site with representatives of the licensee and contractor organizations. Attendees at this meeting included personnel whose names are indicated by notatioc: (*) in paragraph 1.
The inspectors summarized the results of the inspection as described in this report.
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