IR 05000329/1973011
| ML19331A852 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/17/1973 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML19331A853 | List: |
| References | |
| NUDOCS 8007230887 | |
| Download: ML19331A852 (2) | |
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UNITED STATES y
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ATOMIC ENERGY COMMISSION
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DIRECTORATC OF RCGULATORY OPERATIONS j% ' \\ / /
REGION 811 (
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799 ROOSCVELT ROAD mzs'teg GLEN ELLYN. ILLINOIS 6o137 (3123 658-2500 DEC 17 1973 Consucers Tower Company Docket l'o. 50-329 ATTN Dr. Stephen II. Ilowoll Dochet l'o. 50-330 Vice President 1945 Fcrnall Road Jachaon, liichigan 49201 Gentlemen This Ictter refera to tha ir.crection of your activitics at the Midisnd sito nuthorized by MC Construction Perci' !!os. CPPR-31 cnd C2rX-82 cenducted by Meccrs. Vetter, Rohrbacher, cnd Uillirms of this offico and 11r. Witesell of our negulatory Operatiens 1*cadquartera staff on Dtcenber 6 and 7,1973.
Thio also refers to tho dir.:usolous held with you and other :2catcre of your staff at the conclusion of the int.pection on December 7, 1973.
Areas ennir.cd during the innpection arn identified in the encloced inspection O
report. Within these creas, the inspection conciated of selectivo cucirecion of procedures and records, intervicvs uith plant perso: mci, and observations by the inspectors. A copy of the encloord inspection report vau provided to l'r.11. R. Reia, Censut.:cro Power Cocpeny's concultant Icuyer, on Docenbar 14, 1973. At the sano timo, a copy of the report was mailed to Mr. Myron if. Cherry.
Uo violations of Arc regulations vero identified within the scope of this inspection.
In that tha findinga from this report reinto to the Show Caure Order icsued by l
tl.o Director of Regulation on Decc=ber 3,1973, this report has been referred to our Ec::ulatory Operations Headttuarters otaff for further revicu, evaluation, and possiblo action. You vill bo informed of the reaults of this review.
l Your ictter dated Decenber 6, 1973, stated that Consumers rover Cor.pany ve.ived tha rir,ht to nyply for uithholding proprietary infet-ation from public dis-clocure with recpect to the eccleced report. Accordins,1y, a copy of the enclosed report has been placed in the AEC's Public Docunent Roo 2.
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CEC. 7 1c13 Conoumers Power Co:pany-2-l No reply to this letter is necessary; however, should you have any questions concerning this inspection, we will be glad to discunn then with you.
Sincerely,
Ja:nen C. Keppler Regional Director Enclocura EO Inspection Ept No. 050-329/73-11 and No. 050-330/73-11 cc: Mr. A. E. Aynond, President and Chairman of tl.a Doardw/ enclosure bec: RO Chief, FS&EB w/o enclosure RO:HQ (4) w/o enclosure Licensing (4) w/o enclosure DR Central Files w/o enclosure RO Files w/o enclosure O.
PDR w/ enclosure Local PDR w/ enclosure NSIC w/ enclosure DTIE w/ enclosure OGC, Beth, P-506A w/ enclosure J. Murray, GC (2) w/ enclosure l
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I U. S. ATO::IC E::T.~.GY C0:0!ISSIO:i
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DIRECTORATE OF REGU!.ATORY OPER.iTIONS
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REGIO:I III Report of Conc ruction Inspection l
RO Inspection Report No 050-329 73-11 i
KO Incpection Report No. '** '. 0/73-11
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Liconsec:
Concu=crs Power Conpany
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1945 Parnall Reed Jackson, !!ichigan 49201
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!!idland Plant, Units 1 and 2 Licences No. C:'PR-31 l
!!idland, !!ichigan and ro. CPPR-S2 l
Category: A i
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l Type of Licensec:
EWR (SLU) - Unit 1, 650 hec
Unit 2, 818 1:ve
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Type of Inspection:
Special, Announced
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Dates of Inspection:
Decc=ber 6 - 7, 1973
Dates of Previous Inspection: Neveuber 6 - 8, 15, and 20 - 21, 1973
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Principal Incycetor:
R. A. Rehrbacher
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0 0 0!.'.5{0mm Accorpanying Inspectors:
C. C4 Willicus P - //
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E. Whitesell M */ WI Other Accenpanying Personnel:
W. E. Vetter jy fa' -
/N N' js E.Vetter, Chief [FU*[g M**/.8~~73
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Ecv$csed 3y:
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Reacter Con.itruction Branch (D:t c.)
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SU D!ARY OF F1NDI!;GS
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Enforcement Action
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A.
Violations
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No, violations of AEC requirements were identified dur1ng the
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inspection.
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B.
Safety Matters No safety matters were identified during the inspection.
Licensee Action on Previously Identified Enforconent !!atters This inspection report covers a special inspection to deterrine the
status of the licensee's corrective action relative to 0A/0C program deficiencies and specific, apparent violations identified in conjunc-tion with site Cadwalding activitics.
These matters are identified in RO Inspection Report No. 050-329/73-10 and No. 050-330/73 10 and are discussed in Paragraph 2 of this report.
's Design Changes Uo design changes were identified during the inspection.
Unusual-Occurrences No unusual occurrences ware identified during the inspection.
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A.
Current Findings
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1.
Facility Status The engineering and constructio,n status remains eccent' 11y unchanged since the previous inspection on November 2(
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Cadvolding activitics remain suspended pending m
'arther order and determination by the Director of Regulation.
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2.
Current Construction Activities a.
Class I Construction The following Class I construction activitics were in-progress during the inspection.
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< (j (1) Activitics associated with the field welding of
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containment liner plate asseab~ics.
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(2) Installation of rchar support brachets for base slab upper robar layers.
(3) Forming for the Unit No. 2 base slab concrete pour.
(4) Upgrading and expansion of Cadweld material storage
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area.
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Other Construction Activities
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Except for a small amount of sito earthwork, construction activitics (other than discussed in 2.a., above) were observed to be minimal.
According to the licensee, the construction force at the site is approximately 200 i
workers in all categories.
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3.
Personnel Channes i
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.Significant personnel changes have bcon made and are discussed in the Management Interview Section of this report.
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B.
Unresolved Matters
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During routine site construction activity surveillance by Consumers Power Company (CP) a procedural discrepancy, relative to approval
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of work procedurcs, nas identified.
The licensee was in the process of investigating this =atter at the time of the incpection.
(Details, Paragraph 3.a(4))
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C.
Status of previcusiv Identified Unresolved Matters
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Cadweld Personnel Oualifications (R0 Insecction Report No.
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050-329/73-10 and :o. 050-330/73-10, Saction B.1)
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As previously reported, personnel qualification measures for
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l Cadwolders were incomplete in that these =cacuros did not
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specify conditions and requirements for Cadwelder requalifica-i tion in the event that un:cceptable work was demonstrated.
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During this inspection, the licensce's representatives provided evidence of adequate, corrective action in that Bechtel
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Corporation (Bechto',) Specification No. C-231 had been revised
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to ref1cet requalification requirencats.
The specification
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[~ j ravisions were determined to be in general accord uith AEC
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Regulatory Guide 1.10 and are contained within Dechtel Specification C-231, Paragraphs 10.8.1 and 10.8.2, nevision 4.
This matter is considered to have been resolved.
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2.
Inconsistencies Ectween Decicn Docunents and the PSAR (R0 InspectionMeort to. %C.CO/ 7 3-lO and No. 050-330/73-10
$cction B.2)
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A portion of the problem, associated with site Cadgciding activitics, involved certain circunstances wherein the Cadweld-ing procedures ucre inconsistent with the PSAR and/or the Cadueld manufacturer's recommendations.
During the current inspection, it was determined that the licensee had taken steps to assure that recurrent like situations do not occur.
Specifically:
(1) the licensee had rcquested that Bechtel develop instructions requiring that work specifications be j
revicued for this possibility prior to the conduct of Class I l
work, (2) the licensee had established provisiens for CP QA review of work procedures which is to include attention to this
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matter, and (3) the licensee had established procedures for attention to this matter in the form of audit of Class I work i
on an intensified scale.
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Accrecate Storoce (RO Insecction Reoort Mo. 050-329/73-10 EJ N$. 050-330-73-10)
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As previously reported, the concrete aggregate pile (3/4 inch)
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vas observed to be questicnably consistent with,/CI-304
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requirements.
This conditica was reported to be centrolled and tc=porary, due to rework of the aggregate storage facility.
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This matter is now documented in accordance with the site QA program and proper steps have been taken to preclude use of l
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nonstandard aggregate.
k'e will review this matter during the
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next RO inspection.
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Other previously unresolved matters, not applicable to this special inspection, will be examined during the next routine
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inspection.
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Mannecment Interview t
Two management intervicus were held at the conclusion of the inspection and are discussed under A and B, below.
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A.
The first managccent interview vas conducted just prior to the
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l conclusion of'the inspection to discuss the status of-corrective p)
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action on the part of CP corporate manancment to identify and deal vith gencric quality assurance program deficiencies, which appeared to be instrumentally related to the violations associated with Cad-welding.
CP personnel in attendance were ac follows:
Mr. S. !!. Ilovell, Vice President Mr. W. E. Ecssicr, Project Manager Mr. G. S. Koc1cy, Director of Quality Ascurance Services'
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Mr. T. C. Cooke, Project Superintendent
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The meeting ecmbers were inforned that a revicu of CP'c internal correspondence had Icd to a conclusion, on the part of the inspectors, that CP management personnel had adequately analyzed the circumstances associated with the violations and discrepancies identified during the RO:III revicu of site Cadwelding activitics, and had prescribed
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corrective action measures which, if properly implemented, provido adequate assurance that future prob 1 cms of a similar nature should not occur.
Mr. Ilowell commented that the program of corrective action, reviewed during the inspection by the inspectors, reflected a "long, hard, looh" at the events and circumstances asscciated with site cadwelding I
and that this kind of canagement involvement was to continue and, if
necessary, be expanded.
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s Mr. Howell added that, in addition to the corrective action measuree l
juat discussed, _ further aceps had been taken to assure that impic-
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montation of the Midland site quality assurance / quality control program was consistent with AEC requirements and good practice.
He explained that:
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Management, at his level and above, had concluded that nothing short of full dedication to quality assurance / quality control programs, on their part, was accept.able in the interest of proper construction of the Midland Plant.
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2.
Tuo additional personnel, considered to be very highly quali-
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fled, have been assigned from current ducios in the corporate
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officca to full time QA duties at the Midland site.
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3.
Im=ediate steps are to be taken to procure outside services,
from organications providing QA/QC services, to provide help, as needed, to assure that a proper QA/QC program was maintained
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at the Midland site.
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4.
Certain steps have been taken in the way of personnel action,
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relative to existing personnel, to ascure that a strong QA/QC
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5.
A meeting was scheduled to occur during the' afternoon of December'7, 1973 (the last day of the current inspection)
with the Architect-Engineer (A-E) for the purpose of esta-blishing a " clear, unmistakable" position that construction activitics at the Midland site are not to be conducted without full attention.to all quality assurance / quality control
program requirements, and that it=cdiate steps must be taken by the A-E to assure that this issue is properly acco:modated.
Mr. Ilowell added that four, top-ranking members of the A-E
corporate structure had traveled from the west coast for the specific purpose of participating in the subject meeting.
As a final item of discussion during the f,irst management
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meeting,1:cssrs. Kessler and Keeley identified a need for further involvement, on their part, in the area of fully
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understanding the AEC inspection program and suggested that,
perhaps, a more " forceful" approach on tha part of RO:III was l
needed, i.e., greater emphasis on the part of inspectors in
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the area of "cust performance." The inspectors stated that they were in general agreement'with com: cats by Messrs. Kessler and Kccley and said that every effort 5.ould be cado to be as clear
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and precise as possible and suggested that increased communication (!,
between CP personnel and the inspcctors, initiated by CP whenever
questionabic situations arise, might be helpful.
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Second Managee.ent Interview
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A second management interview was held at the conclusion of the
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inspection.
Personnel in attendance were as follous:
i Consumers Power Company (CP)
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f S. H. I!owell, Vice President
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W. E. Kessler, Proj ect Manager - Midland l
G.'S. Eccley, Director of Quality Assurance Services j
T. C. Cooke, Construction Suparintendent - Midland j
H. W. Slager, Quality Assurance Supervisor - Midland'
i Bachtel Corporation (Bechtcl)
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M. M. Krout, Project Manager - Midland D. R. Johnson, Chief - Field Quality Centrol Engineer
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(San Francisco)
l E. E. Felton, Project Superintendent - Midland A
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P. A. Martinen, Project Engineer - Ann Arbor
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T. C. Valenzano, project Field Engineer-During this managoucnt interview, the inspectors identified areas of inspection ecverage and con =ented, in detail, with respect to the scope of inspection coverage.
In response to questions on the part of both CP and Ecchtel personnel, with respect to the
" success or failure" of the current inspection effort, the inspectors explained that the inspection had involved a team effort and that
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the results of the inspection would require further review in order to provide meaningful answers.
As a final item of discussion, the inspectors pointed out that the circumstances related to what appears to be a procedural discccpancy associated with centainment liner plate wcld repair activitics, called to the inspectors' attention by CP personnel during the inspection, tud been reviewed and tha't a violation of Part 50, Appendix B, ray be involved.
However', the inspectors added, in view of the fact that CP personnel were in the process of completing an investigation at the time of the inspection, this matter would be classified as " unresolved" and would be fully reviewed during the next reutine site inspection.
At the conclusion of the meeting, Mr. Howell questioned the results
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of the current inspection in terms of whether or not the results were such as to allow continuation of site Cadwelding activities.
s_,j By way of rcsponse, Mr. Ecwell was infer:cd that the results of the inspection would be thoroughly reviewed.and made available to_the
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Director of Regulatory Operations en an c::pedited ' schedule, and that an authorication to continue Cadwelding activities can caly be initiated by the Director of Regulation in keeping with the provisions of the " Order to Show Cause" dated December 3, 1973, signed by the Director of Reg,ulation.-
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REPORT DETAILS
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Persons Contacted
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The following persons, in addition to individuals listed under the Management Intervicu Section of this report, were contacted during the inspection.
Concuncrs Power Company (CP)
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R. E. Whitaker, Quality Assurance Engineer J. L. Coricy, Field Supervisor 3. H. Peck, Field Supervisor Bechtel Pouer Corporation (Ecchtc1)
C. E. Kinney, Project Field Quality Control Engineer J. I. Dotson, Project Quality Assurance Enginc.er C. F. Clark, Field Engineer - Welding
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J. T. Stochs, Uciding Engineer i
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R. A. Crote, Civil Engineer-i P.
(NMI) Hendrick, Quality Control Engineer
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K. Puleto, Mechanical Engineer
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J. P. Connolly, Prcject Field Quality Assurance Engineer
e~'s L. R. Albert, Quality Control Engineer (
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j Results of Inspection This inspection was a special inspection to determine the adequacy of the liconeca's overall effort to correct quality assurance / quality control program
.shortconings identified during inspections conducted'on November 6 - 8, and 20 - 21, 1973.
The results of the inspection are as follows:
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}bnaccrent Analvsis of QA/QC Program Deficiencies and Corrective Action At the conclusion of the inspection on ".'ovember 20 - 21, 1973, the licensce'
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was informed that, in addition to certain, specific, corrective action shortcomings, discussed later in this report, (relative to the issue of Cadwelding violations and deficiencies) adequate, corrective action could not be descastrated in the areas of:
(1) canagement analysis-of QA/QC program shortcomings which appear to have led to tha Cadwelding activity
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problems, and (2) management respense to such an analycis to assure that future, similar problems in other areas of Class 1 construction would not i
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During the current inspection,-the licensec provided docurented results
. of an overall QA/qC program analysis, based on violaticas and discrepancies encountered relative to Cadwelding, and identified a program of corrective action.
A revicu of ' the subject docunents and discussion with manage:cnt personnel provided the following inforeation.
a.
The licensco has concluded that the Cadweld problem materialized as a result of:
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(1) Unclear inspection procedures leading to confusion on thc part of.
personnel responsible for determining the quality of Cadueldinp.
(2) Inconsistent work requirements for Caduciding with respect to tae PSAR, Bechtel specifications, and the Cadweld manufacturer's
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(3) A lack of. review of Bechtel Master Inspection Plans prior to tha initiation of Class I work.
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j (4) A lack of audit depth on the part of CP QA personnel and the lack of an in-depth, formal site QA audit plan.
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(5) Inadequate training of QA audit personnel.
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b.
Corrcetive action relative to Items a(1) through a(5) above, was
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determined to be as follows:
(1) Ecchtel had been requested to review all procedures prior to the start of each specific Class I work activity, to assure that the r
procedures are written in a manner such as to avoid confusion.
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(2) Ecchtel had been requested.to devise a system to assure that work procedures are reviewed to detect situatiens wherein other docu-ments (such as the PSAR and manufacturer's specifications) contain quality information inconsistent with procedures being used to j
perform work.
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(3) CP procedures now include a requirement that CP QA personnel review l
Bechtcl Master Inspection Plans covering Class I work and discuss-i the results of this review, with Bechtcl, prior to the initL7 tion i
of work.
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(4) Three additional CP persons had been assigned to the construction f
site to prcvide for in-depth audit of Class I work activitics.
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to be conducted in a formal manner and are to be based on 10 CFR
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Part 50, appandix 3.
In cddition to the foregoing, the CP quality assurance services director now requires that the corporate office quality assurance services supervisor spend a nininum of one day
cvery two wechs at the construction site.
(5) The CP quality assurance services director had advised corporate canagement, in writing, that a need for training QA personnc1 cxists
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and has stated that training pr'ograms will be initiated in cl;2 near future, c.
The information contained in Itc=s a and b, above, reflect internal CP correspondence from the Quality Assurance Services Director, G.
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Keeley, to Mr. S. H. Howell, Vice President, CP.
In response to Mr. Kecicy's correspondence, Mr. Howell stated, in a letter to Mr.
Eccicy, that he concurred uith Mr. Kecicy's analysis and recommenda: lons and requested that any action not already taken should be taken immediately.
Mr. Howell~also stated that:
"Although, in this case, the specific problem has appeared in the performance of Cadwelds, a; we have discussed and as is indicated by your analysis and recommenda-tions, the probl'em has broader sympteratic aspects to our total qut.lity assurance progran and the remainder of the project.
I wish to stress this fact, to ensure that everyone has full recognition of it, and that our whole pregran is critically studied for problems or weaknesses."
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d.
In a letter to Bechtcl, dated December 4,1973, Mr. Keeley made a number of "suggestiens" designed to require action of a nature such as to assure that QA/QC program weaknesses, identified as a result of the Cadwelding problen, will be corrected. These suggestions are discussed below.
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(1) Bechtel should provide a method for critically relating inspection procedures to acceptance criteria.
(2) Master Inspection Plans, generated by Bechtel, are to be sent to
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CP's quality assurance services personnel for review and co==ent prior to the start of Class I work activities.
(3) Whenever inspection plans require inspection of individual items, records cust be maintained to the extent necessary to provide
" visibility" that such individual inspection items have been accommodated.
(4) CP feels that Bechtel relics too heavily on one er two general documents to cover specific work procedures and believes, in most cases, icpictenting procedures should stand on their own with a minicum of cross reference.
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According to Mr. Keeley, all of the applicablu Scchtel personnel (at both Ann Arbor.and San Francisco) had reviewed the subject letter, agreed with Mr. Keeley's suggestions, and Bechtel was preparing a
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rcply to this effect.
The Ecchtel project canager for the Midland Plant confirmed the substance of Mr. Keeley's statc=ent.
2.
Corrective Action Relative to Socciffc Violations nud Deficiencies
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a.
Violations (RO Inspection Report No. 050-239/73-10 and No. 050-330/73-10)
(1) As previously reported:
(1) procedures for Cadwelding and Cadvold incpection vere unavailable or inadequate, (2) instructicas and
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procedures for preheating were not properly implemented, and
_(3) inspection personnel did not demonstrate knowledge and proper implemcatation of Cadweld acceptance-criteria, leading to the acceptance of twelve splices which ucre either questioned'or
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rejected upon subsequent reexamination.
With respect to the above, the following corrective action had been taken.
(a) The licensee has now produced approved procedures for Caduelding
. and Cadweld inspection activities, uhich ccmprehensively relate to all requirenants of the specifications, the site QA progrs=,
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and the manufacturer's instructions and reconnendations.
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procedures are titled as follows:
(1) " Quality Centrol Procedure No. C-231-1, Inspection of Cadwcld Mechanical Splicing of
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Concrete Reinforcing Steel," dated December 5, 1973, and (2) "Rebar Splicing Instructions for the Operator - Vertical Position and hori::cntal Position," dated Dece=ber 4,1973.
(b) Included in the above procedures are specific instructions
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regarding all Cadwelding preheat requirements and the ccans for verifying that these requirements have been met.
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(c) All C_adweld inspcerion, personnel have been appropriately
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retrained.
The method of i=plc=cnting the Cadweld void evaluation criteria has been refined to more accurately relate
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to actual void di=cnsions.
The licensee had previously com-
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mitted to a continuous training and evaluation program for all
Cadueld inspection personnel.
This program is identified as Project Special Provisions (SF/ PSP) No. 2, Revision 0, Project
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No. 7220. A training session for Cadwelding, dated Movember-14,
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1973, covering all arcas, was documented. A training session,
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titled, " Training on How to Measure Voids," dated November 9,
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1973, was also documented.
The results of this training for i.
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cach participant.is documented on the " Reinspection Proficiency Exam - Cadwelding of. Reinforcement Stoci," taken by each participant in the retraining program.
This proficiency examination was determined to be couprehensive and'representa-
.tive of work requirements.
In addition to the above, a "Cadweld Reinspection Checklist,"
providing specific and appropriate instructions to. inspectors relative to the Cadweld reinspection activity, was reviewed and determined to be adequately comprehensive.
The status of the twelve Cadwclds, either rejected or' identified cs questionable through the site Cadweld reinspection effort, is currently documented in Bechtel Nonconforming Reports.(NCR's).
The disposition of these Cadwelds, which were rejected and/or questioned by the Ecchtel site QC personnel, has been reevaluated by the Ecchtel Engineering Department.
The Engineering Department
_
ordered additional inspection of these Caducids, using a "more accurate" method of void determination.
The results of this further examination are docunented on Bechtel NCR No. C-13.
The "nore accurate" examination involved-the use of a " planimeter.
The results of this examination established that nine Cadwelds, previously rejected for excessive metal void areas, i.e.,
greater than three equare inches, actually contain void areas less than three square inches, and these nine Cadwalds have now been
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(U)
accepted.
With respect to one Cadweld previously identified as having excessive porosity, and two Cadwalds previously identified as having no evidence of position reference lines, the Cadweld having porosity has been rejected and is to be repli.ced while the two Cadwelds with no evidence of reference lines have been accepted through engineering evaluation.
-(2) As previously reported, docu=ented procedures to demonst' rate specifically that measures had been established to control handling and issuance of Cadweld splicing material, including the return of unused material, were inadequate or unavailabic for review.
(3) Procedures were not made available for review, relative to control of nonconforming Cadweld material, nor were records available to establish that nonecnforming material was properly controlled.
The following corrective action has been taken relative to
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items (2) and-(3) above:
The licensco has included instructions and procedures for the
" storage and handling" of Cadweld materials in the Cadwelding-s (v>
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production and inspection procedures, identified in a(1)(a), above.
These instructions include specific reference to Ecchtel Procedurc e'
No. C-3.-
This procedure adequately provides instructions and pro-cedures for the identification, handling, controlling, and segregation of ncnconforming materials.
Further, the Cadweld production and Cadweld inspection procedurcs, identified in a(1)(a), above, provide specific instructions and procedures and
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provide for delegation of authority and responsibility regarding the return of unused Cadweld material to storage.
(4) As'previously reported, records were not maintained to' furnish evidence of conformance to' quality requircuents, identified in the Cadwelding specification, No. C-231 (Inspection Plan Form No.
QAG6-2A and Material Issuance Control).
The licensee has taken the following corrective action:
(a) As stated elseuhere in this report, all Cadwelds at the site have been reinspected at least twice, once by Ecchtel field engineers and, finally, by the Ecchtel QC engineers, for conformance to quality requirements.
Corrective action, as appropriate, relative to the results of these reinspections,
, has been taken as discussed earlier in this section of this
,O report.
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yj During the current inspection, RO:III inspectors personally evaluated a total of 4'i Caducids in Units 1 and 2 reactor base slabs and found them to be conforming, in all recpects,
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to the requirements.
In addition, the inspectors witnessed,
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durin3 the above activity, a demonstration of the current methods of Cadweld inspection by Bechtel QC inspectors. This-
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demonstration was conducted on Cadwelds randomly selected by
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the RO inspectors and provided evidence that the QC inspectors were properly qualified.
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(b) The licensee has generated a comprehensive procedure for-Cadueld inspection (idhntified in a(1)(a) above).
Further Cadweld inspection report form, QA-06-2A, is now supported by " Form QC-Cadwelds," Revisien 1, dated November 29, 1973.
Collectively, these forms include all quality requirements identified in the governing specification and inspection plan, plus instructions specifying that conformance to these quality clements must be verified and documented at a time
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appropriate to the fabrication status of a Cadweld joint.
Tbc instructions for the use of the QC Cadwald form are on the back of the form.
The records of the reinspection efforts,
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implenentation of the new record form (RC-Cadwalds) and proper impicacutation of the neu Ccdveld production and inspection procedures have adequately resolved RO:III concerns relative
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to this matter, b.
Deficiencies (R0 Inspection Report No. 050-329/73-10 and No.
050-330/73-10)
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The Caduciding deficiencies identified in the above inspection report involved:
(1) Inadequate provisions for maintaining continued acceptable Cadwelder performance qualifications.
(2) Inconsistencies between design documents (Bechtel specifications, Manufacturer's instructions, and the PSAR) relative to Cadwelding
activities.
,
Item b(1), above, is discussed in Section C.1 of this inspection'
report and item b(2), above, is discussed in Section C.2 of this inspection report (both of these deficiencies have been resolved),.
3.
Identification and Exanination of Other C19.ss I Construction Activities at the Site w,-
A tour of the constructicn site was made by the inspectors to observe Class I construction activities in progress and, subsequently, to rceicw applicable work precedures.
The results of this effort arc discussed as follows:
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Field Ucidine of Containnent Building Liner Plate Activities associated with the field welding of centain=cnt liner plate, including valding activitics in progress, were observed.
A pair of liner plate assamblics, cach approximately 80 x 10 feet, were observed on a jig to have been partially velded together (Two of these assemblics arc welded together to form an 80 x 20 feet liner sheet).
The licenseo stated that five pairs of asseublics have been joined by welding, and that tuo assemblics are partially ecided.
(Each
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completed containnent building liner is to consist of approximately 75 liner sheets.)
Two temporary construction buildings are being used
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for fit-up, welding, welding inspection, and leak checking.
Another
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, construction building is to be used for sand blasting, painting, and additional inspection.
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In conjunction with inspection of the containment building liner plate
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activitics, the control and issuance of wcld rod was examined.
Observa-tion of wcld work in progress and inspecticn of facilitics for storage
'7 and issuance of wcld rod established that applicable quality critoria were being accoumadated. Ucid rod was properly protected in the field through the use of portable ovens, and a thorough systou for storage, identification, and issue of wcld rod was being implemented in a central area.
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A review of wcld rod control records established that wcld -rod issuance -
was' properly accounted for and that the records.were sufficient to
" trace" welds, ucid rod, and welders to specific areas of liner plate velding.
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Vork and QC procedures, relative to field welding of containment building liner plate, were reviewed.
Except as noted under~the Unresolved Matters Section of this report, and discussed in Paragraph (4) below, in regard to a procedural discrepancy, no inadequacies or
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discrepancies were identified during the review of records.
The review included the following:
(1) Ecchtel Specification No. C-111, Revision 1, and as atended.
This specification includes welding standards and procedures, NDE standards, and welder qualif1 cations for field welding of contain-
,_s i (D ment building liner plate.
(2) 3cchtcl Mastcr' Plan No. C-L-1 (a to h). and Ecchtel Inspection Plan.
No. C-111.
The detailed inspection plan for occh containment building liner plate consists of a package of cight 'pages, along with pertinent data sheets.
This inspection plan refercnces applicable codes, standards and specifications, and includes inspection criteria for cach activity listed.
Separate NDE reports and weld status forms are used for cach liner plate.
(3) Eccht'el Welding Filler Metal Control (UFMC-1, Revision 0, May 1973).
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i This procedure specification includes adequate receiving, storage,
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and dispersal of wcld rod relative to liner plate welding.
(4) At the beginning of the inspection, the CP Director of QA Services provided the inspectors a copy of a letter to him from the CP project superintendent dealing with an apparent procedural dis-crepancy concerning the issue of a procedure to cover containment building liner plate work activitics.
A review of this letter, and discussion with the CP field supervisor involved, established that, during work surveillance by the field supervisor on November 13,
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1973, a Ecchtel work =an was observed to be in the process of l'
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repairing liner plate surface defects resulting from the removal
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of fit-up and plate li' ting attachments. According to the'CP field supervisor, in respo-to questioning, the Bechtel workman stated
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that he cas performing the subject work in accordance with Appendix B of Ecchtel Procedure No. C-lll..Further investigation by the CP field supervisor disclosed that Appendix B of Procedure No. C-lli, had not been approved.
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Appendix B to Procedure No. C-lll was approved on November 29,.1973, and a review by the. inspectors disclosed that the approved procedure was an exact duplicate, in terms of work procedure requirements, of the unapproved procedure in use on November 13, 1973.
Discussions with C?;and Bechtel personnel at the conclusion of the inspection indicated that some confusion existed with respect to whether or not the work involved required the use of Appendix B, since the parent procedure included instr.uctions with respect to the specific work in progress observed by the CP field supervicor on November 13.
In any event, the licensec vas in the process of completing a full investigation and fact finding effort at the conclusion of the inspection and is to provide the results of this effort to facilitate further review of this matter by RO:III during the,next routine inspection.
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/~'h b.
Renctor Base Slab Concrete Ferns U
About 15% of the enisting ccncrcte forms for the Unit 1 base slab, installed during 1970, have been replaced with new concrete forms.
Forms for the' Unit 2 base slab are about 75% in place. No forms were
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being placed during the tour of the site.
Overall forming work for the base slabs is estimated to be about 50% complete.
Bechtel Specification No. C-321(Q), Revision 0, uas reviewed for requirements of erectin3 forms, placing, finishing, and curing concrete. The specified work is to be verified and documented on Ecchtel Form QC-C5.
The specification was determined to be adequate for concrete form placement for Class I concrete structures.
No
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Class I concrete activity was observed by the inspector to be in j
progress during a tour of ?.he construction site.
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Installation of Rebar Supports I
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Support brackets for the base slab upper rebar layers are being installed.
Brackets were observed being welded into place in Unit 1.
The licensec stated that this work was nearing completion for Unit 1 l
and that it is essentially completed for Unit 2.
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A large, enclosed trailer is being used to store Cadweld materials
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and accessories at the site.
It was observed that all Cadweld.
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i natorials and accessories were stored ou shelves.
The enclosed
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trailer provided for heated and dry storage. A'second trailer, presently cepty, was nearby.
A representative'of the-liccusec stated
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Gang boxes, with heaters, to contain'Cadwald caterials that this second trailer vould provide additional storage space, when
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i ree.oved from the trailers, are to be used in the ficid.
They'are
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'o Caduc1d materials, such as sleeves and powder, l-tiere observed at the site outside. of the storage trailer.
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