IR 05000346/1974001
| ML19329B220 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/19/1974 |
| From: | Dickerson M, Sutton J, Vetter W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19329B217 | List: |
| References | |
| 50-346-74-01, 50-346-74-1, NUDOCS 8001310568 | |
| Download: ML19329B220 (17) | |
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U. S. ATOMIC ENERGY COSS!ISSION DIRECTORATE OF REGULATORY OPEPATIONS
REGION III
l Report of Construction Inspection RO Inspection Report No. 050-346/74-01 Licensce:
Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, Ohio 43652
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Davis-Besse Nuc1 car Power Station License No. CPPR-80
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f Oak Harbor, Ohio Category:
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Type of Licensee:
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Routine, Unannounced
-.Y Dates of Inspection: January 8 - 10, 1974
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Dates of Previbus Inspection:
October 16 - 18, 1973 (Construction)
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Principal Inspector:
M. W. Dickerson d ' / 7'- 7 Y (Date)
h.tu.b O w g" J. W. Sutton 2. - / 9 - 7 A Accompanying Inspector:
(Date)
)n.co.L05Mf D. W. Hayes 2-19-79 (Date)
Other Accompanying Personnel:
None M' /T' 7Y Reviewed By:
W. E. Vetter, Chief
Reactor Construction Branch (Date)
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SUMMARY OF FINDINGS Enforcement Action A.
Violations Certain of the activities at the Davis Besse site appear to be in violation of AEC regulations and in nonconformance with the Quality Assurance Program, as identified below, and are considered to be of Category II severi,ty.
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1.
10 CFR Part 50, Appendix B, Criterion V, states, in part, that:
" Activities affecting quality shall be prescribed by documented instructions, procedures,
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in accordance with those instructions, procedures, or drcwings".
Contrary to the above, support and seismic welds, associated with Class lE equipment, were being inspected without benefit of written procedures or instructions.
Moreover, there was no documentation to establish that all the subject welds were being inspected.
(Paragraph 4.d.1)
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The Fischbach and Moore, Incorporated, Quality Control Manual, Quality Assurance Procedure No.1 (QAP-1) Revision 1, dated September 27, 1972, states, in context, in Section 8.0,
" Methods of Controlling Welding Operations", that:
(1) the welding inspector must verify all fit-ups.
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qualifications prior to weld operations, and (2) ea.h veldcr is required to affix his identifying stamp to welding records for all velding operations which he performs, and the welding inspector must counterstamp the welding records, after verifying acceptability of the operation.
Contrary to the above, and 10 CFR Part 50, Appendix B, Criterion V, documentation was not available to establish that welding operations, associated with Class 1E electrical
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equipment, were being controlled in accordance with applicable procedures.
(Paragraph 4.d (2))
B.
Safety Matters d
No safety matters were identified.
Licensee Action on Previously Identified Enforcement Matters No previously identified enforcement matters were involved.
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Design Changes
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No new design changes were identified.
Unusual Occurrences A member of the public met with a representative of the Licensing Headquarters Staff on October 17, 1973, to set forth anonymous, second-party allegations regarding certain construction activities
at the Davis-Besse site.
Subsequently these allegations, requested by lleadquarters to be handled during a routine inspection, were received by RO:III.
During this inspection, these matters were given considerable attention.
The specific allegations and results of the inspector's findings on these matters are contained in Paragraph 1.a through i of this report.
Other Significant Findings A.
Current Findings The licensee indicated that, as of January 1,1974:
(1) construction was 55% complete, and (2) engineering was 88% complete.
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B.
Unresolved Matters
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1.
Westinghouse Electric Corporation (W) High Pressure Inicction Pump Motors The licensee indicated that the reported motor deficiency was under investigation by Babcock and Wilcox Company (B&W) and the results of this investigation would be available for revicu by RO:III during the next routine inspection.
2.
Weld Material Certifications The B&W weld material certification record book was found to have certifications that did not clearly establish conformance to ASME code requirements.
In addition, the legibility of the certificates was unacceptabic.
(Paragraph 2)
C.
Status of Previousiv Reported Unresolved Matters Apparent Corrosion of Stainless Steel Components and Stainless Steel Components in Contact With Carbon Steel Hangers and ('~~
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Connectors (R0 Inspection Reports No. 050-346/73-03 and !{o.
050-346/73-04)
During this inspection, it was determined that the investigation into the subject conditions, their cause, and their acceptability had been completed independently by both the Bechtel Corporation (Bechtel) and the Grinnel Company (Grinnel). The results of this investigation, which required no remedial action, was also established to have been reviewed and accepted by the Toledo Edison Company (TECO). This matter is considered closed.
(Paragraph 3)
Management Interview A.
The following persons attended the managenent interview at the conclusion of the inspection.
- Toledo Edison Company (TECO)
L. E. Roe, Vice President - Power E. C. Novak, Chief Mechanical Engineer N. L. Wadsworth, General Superintendent-Power Construction E. M. Wilcox, Field Quality Assurance Specialist
K. M. Cantrell, Field Quality Assurance Engineer Bechtel Corporation (Bechtel)
D. L. Reddick, Field Coordinator
- H. A. Ablondi, Project Quality Assurance Engineer
- Part time B.
Matters discussed and comments, on the part of management personnel, were as follows:
1.
The inspector discusced the results of the inspection relative to the allegations and stated that no confirmatory evidence for any of the allegations had been found in the records reviewed by the inspectors at the site.
However, one item, regarding CB&I NDE personnel qualifications for containment vessel fabrication, could not be completed at the site and that arrangements for access to the CBLI records at Kankakee, Illinois, was desired for January 14, 1974, to complete this review.
The licensee agreed to arrange for this access.
Subsequent to completion of the inspection at the site, a review of the CB&I records, on January 15, 1974, at Kankakee, Illinois, established that the CB&I NDE personnel had been properly qualified.
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2.
The inspector briefly reviewed the satisfactory resolution of
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the previously identified matter relative to the apparent-4-
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corrosior of stainless steel components and stainless steel components in contact with carbon steel hangers and connectors.
3.
The inspector requested that the licensee prepare information on the status of the valve wall thickness verification program for review during the acxt routine inspection.
The licensee agreed to provide this information.
4.
As a result of an inquiry by the inspector, the licensee indicated that B&W is presently evaluating the problem associated with the two W supplied motors on the high pressure injection pumps, but that resolution of the problem could not be reported at this time. The licensee was informed that this matter would remain open until it had been satisfactorily resolved.
5.
The inspector stated that, in many instances, the B&W weld material certifications were found to be illegible and that the certifications were approved for Navship and fossil construction, but not for ASME requirements. The inspector also stated that this fact was known to the B&W site QA engineer and was to be discussed with B&W corporate QA personnel during a scheduled meeting within the next week.
the licensee stated that TECO QA personnel would follow up this matter.
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6.
The inspector stated that support and seismic welds, associated s _,,
with electrical Class lE equipment, were apparently being s
inspected without benefit of written procedures or instructions.
Moreover, there was no documentation available for review that would' establish that all of the support and neismic welds were being inspected.
The licensee was informed that this appeared to be in violation of 10 CFR Part 50, Appendix B, Criterion V.
The inspector also stated that the Fischbach and Moore, Incorporated (F&M) QC manual, QA procedure No. 1 (QAP-1)
requires that:
(1) the welding inspector must verify all fit-ups, electrodes and filler materials and welder qualific-ations prior to weld operations, and (2) each welder is to affix his identife.ag stamp to welding records for all welding operations which he performs, and the welding inspector must counterstamp the welding records after verifying acceptability of the operation.
The inspector added that, contrary to the QC manual requirements, documentation was not available which would establish that welding operations associated with Class lE electrical equipment were being controlled in accordance with procedures and that this appeared to be in violation of 10 CFR Part 50, Appendix B, Criterion V.
The licensee indicated that he was aware of deficiencies in the F6M electrical program and that a stop work order had been issued on January 8, 1974, as a result of an audit by Bechtel QA/QC on
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complete by January 14, 1974.
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REPORT DETAILS Persons Contacted The following persons, in addition to individuals listed under the Management Interview Section of this report, were contacted during the inspection.
_T_oledo Edison Company (TECO)
M. D. Colcamuggioi, Power Plant Electrical Engineer
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Bechtel Corporation (Bechtel)
J. J. Ford, Quality Assurance Engineer T. B. Fyock, Field Lead Civil Engineer W. B. Daly, Lead Welding Engineer L. M. Ruggieri, Lead Civil Quality Control Engineer R, L. Lewis, Project Field Quality Control Engineer R. L. Lykens, Contract Administrator W. C. Lowery, Quality Control Engineer (Electrical)
Babcock and Wilcox Company (B&W)
J. W. Marshall, Field Quality Control Supervisor A. Bently and Sons Company (Bently)
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R. G. Sanders, Quality Assurance / Quality Control Engineer Michigan Testing Engineers, Incorporated (MTE)
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L. (NMI) Ponke, Quality Control Supervisor Chicago Bridge and Iron Cocoany (CB&I)
V. M. Yarbrough, Area Quality Assurance Manager W. R. Wagner, Area Quality Assurance Supervisor l
Fischbach and Moore, Incorporated (F&M)
D. M. Moeller, Quality Control Manager
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J. D. Binford, Chief Supervising Inspector
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Q. L. Waite, Welding Inspector Results of Inspection 1.
Allegations g
As stated previously, a member of the public met with a representative
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anonymous, second-party allegations regarding certain contruction activities at the Davis-Besse site.
As a result of this meeting, RO:III was requested to handle this matter during the next routine site inspection.
The allegations specified were as follows:
Integrity of the reactor ring girder foundation (concrete).
t Reinforcing steel placed in concrete before testing, steel which failed tests for noncritical buildings used in reactor building, and records destroyed.
(This steel was described as spiral steel.)
Water-cenent ratios of concrete were ignored, and changes from one type of concrete to another were made without prior approval.
Concrete was placed and poured before tests were performed, in order to minimize overtime work.
Michigan Testing Company (assumed to be MTE) personnel were unqualified for testing.
Foundation fill for the cooling tower, which came from an onsite quarry, failed to meet specification.
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Employees were asked to do things that were not in conformance
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Testers on the containment vessel were not qualified, and even laborers were used to perform tests.
Selective rather than random, sampling was done for testing.
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Onsite quality control was weak link.
Records were destroyed.
Each of the above allegations were reviewed extensively during the inspection conducted on January 8 - 10, 1974, and included a review of
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of records and interviews with personnel.
Although the inspection did
not establish any evidence to support the allegations, it did estab-lish that certain of the activities did occur, i.e.:
blasting following completion of the final ring girder pour.
The allegations and results of the inspection regarding each allegation is discussed in the following i
paragraphs.
a.
Integrity of the Reactor Ring Girder Foundation
(1) Concrete
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The allegation specified that, during construction of the reactor building ring girder foundation, a concrete pour of 680 yards of concrete was poured starting at 7:00 a.m. and completed at 4:40 p.m.
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that same day, and that at 4:50 p.m. that day, a contractor's
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office trailer, located near the concrete batch plant, was rocked by an explosion of sufficient intensity to knock items off shelves, etc.
According to the allegations, the explosion was the result of blasting authorized by Bechtel and could have been in a quarry about 100 feet from the freshly poured foundation.
Concern about the integrity of the pour was alledged to have been contained in letters to Pittsburgh Testing, Bechtel, and TECO. The allegation also asserted that the letters and copies later(disappeared.
In addition, four men from Bechtel reportedly checked the concrete pour visually, after the forms were removed, and found that the blasting had not been detrimental to the foundatien pour.
It was also reported that ultrasonic tests had been completed to check the pour.
To evaluate the allegations, the inspector reviewed the records for the two pours which comprised the concrete reactor ring girder foundation.
Records revicued consisted of those for, (1) the batch plant operator, Nicholson Concrete and Supply Company (Nicholson);
(2) the placement contractor (Bently); (3) the inspection contractor (MTE); (4) the concrete testing contractor, Pittsburgh Testing Laboratory (PTL); and (5) the mix design testing contractor, Toledo Testing Laboratory (TTL).
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The first pour, designated as CB-FR-P No. 1 (S-14) poured on October 12, 1970, was con: prised of 322 cubic yards of design mix C-2 and the second, designated as CB-FR-P No. 2 (S-22) was poured on October 27, 1970, and comprised of 655 cubic yards, was also design mix C-2.
The second pour is apparently that referred to in the allegation, since the delivery starting time of 6:40 a.m.,
ending delivery time of 3:24 p.m., and the total number of yards delivered, plus two loads rejected for slump, closely approximate those stated.
The records for both pours reviewed consisted of:
(a) Trip tickets (issued by Nicholson)
(b) Installed inspection reports (ABS Form No.13)
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(c) Reinforcing steel placement report (ABS Form No. 5)
(d) Form work construction report (AES Form No. 9)
(e) Concrete placement checklist (ABS Form No.10)
(f) Concrete curing and form removal (ABS Form No. 12)
(g) Report of batch plant operations (PTL)
(h) Field inspection reports (ABS Form No. 11)
(1) Field data on concrete compression tests (PTL)
(j) Report of concrete mixture design (ITL mix design test of C-2 dated October 3, 1970)
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All records were established as complete acceptable, including (,/
those for slump tests (except for the two truck loads which were rejected) and break cylinder tests, all of which, exceeded-8-
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the required 28-day strength of 4,000 psi.
G No additional records of a special visual inspection or of an ultransonic test of the ring girder foundation were cvailable for review as alleged. Moreover, no basis was established which would indicate that records (or letters) had been destroyed or changed. Records for the particular reinforcing steel placed in the ring girder foundation were also reviewed, and all steel place-ment was determined to have been accepted by means of a certified user's test report prior to placement of the steel.
Section 1.b of this report further describes inspection results regarding reinforcing steel.
Additional detailed information of an inspection of concrete ring girder foundation is included in RO Inspection Report No.
050-346/70-04.
(2) Blasting A review of blasting records maintained at the site established that a blast by Great Lakes Construction Company did occur on October 27, 1970, and was located at the intake structure area approximately 500 feet east of the reactor ring girder founda-tion.
No records of blasting in the quarry area were available for review, although it was established that the quarry area is-s s
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located approximately 1/2 mile from the reactor ring girder and g\\~s'
300 feet from the concrete batch plant area. The blasting records indientc that 1,150 pounds of 60% nitro starch was placed in 240 holes at depths ranging from 10 to 15 feet, with center-line dis'tances of 7 feet. The distance, cppro::imately 500 feet from the blast area to the ring girder foundation, is well above the minimum distance required by Bechtel Specification No. 7749-C-1, dated and approved April 14, 1970. This specification is titled
" Toledo Edison Company and Cleveland Illuminating Company, Unit No. 1 Construction, Bavis-Besse Nuclear Power Station",Section XI, Subsection 4.3.2, titled " Blasting" states, in paragraph 3, that
" Blasting is not permitted with 100 feet of concrete or grout that has been in place less than seven days".
b.
Reinforcing Steel The allegation stated that:
(1) reinforcing steel was placed in concrete before testing, (2) steel which failed tests for non-critical buildings was used in the reactor building, and (3) records were destroyed.
(This steel was described as spiral steel)
Records pertaining to receipt, testing, storage, nonconformance, and placing of reinforcement steel used in the containment, auxiliary, and turbine buildings were exanined and reviewed by the inspector. Particular attention was placed on the acceptance s
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of the steel by means of a certified user's test report. The material and testing of the steel was found to be in accordance with the engineering specifications and ASTM requirements.
One instance of reinforcing steel (two bars) being placed, prior to receipt of a user's tests report, was found by the inspector.
The bars were cut out of the auxiliary turbine building wall prior to the concrete pour, and the conditions found were noted.
The reinforcement steel was found to be traceable to use and placement area by means of heat numbers.
Receiving and shipping records were reviewed indicating that rejected steel was shipped offsite, as soon as it was known that the steel failed the user's test.
Records were available that substantiated disposition of the steel.
The records of concrete pours sampled indicated that all reinforcement steel was acceptable for use prior to pouring of the concrete.
Spiral steel was approved for used on the Davis-Besse project in the auxiliary and turbine buildings columns accordin to engineering design and specifications.
The spiral steel used was manufactured to A 615-60 ASTM Standards.
The steel rods were classed as No. 4 and No. 5.
Three-eighths-inch diameter rods, with a two-inch pitch, were specified.
The rods were required to be tested in accordance with Bechtel Specification No. 7749-C-29A, Technical Specifications for the Furnishing, Detailing, Fabricating, Delivering, and Placing Reinforcing Steel".
A review of receiving, test, and placement
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of the auxiliary and turbine buildings was tested prior. to use and was not rejected rods.
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Based on the continuity and completeness of the records revieued.
it appeared that no records were destroyed, and this allegation could not be substantiated.
Additional information on rebar is also contained in RO:III Inspection Reports No. 050-346/70-04, No. 050-346/71-02, and No. 050-346/71-03.
c.
Water-Cement Ratios The allegation specified that water-cement ratios were ignored, and changes from one type of concrete to another were made without prior approval.
The records for several concrete pours, spanning the period from October 7, 1970, to December 22, 1971, were reviewed to assess the validity of the allegation.
All records examined established that the mixes for each pour conformed to the specification requirements and to the ACI requirements for the cement, aggregate, fly ash and water. Water-ccment ratios, slump tests, strength tests, and inspection requirements for pre-and-post placement were established as conforming to requirements.
Where slump did not meet requirements, rejection of the material was properly documented.
[' 'T Records for pours examined (in addition to the ring girder founda-()
tion) were:
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Date
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Pour No.
Poured Concrete Req.
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M-9, M-10 & M-11 Membrane 10/07/70 C-1 1" to 4h" 4000-(24 cubic yds)
Protection P-10 Foundation 2/11/71 C-1 1" to 4h" 4000 (448 cubic yds)
Mac C-2 1" to 4" 4000 153 Auxiliary 7/06/71 C-2 1" to 4" 4000 (205 cubic yds)
Bldg. Wall.
541 Containment 12/22/71 D-1-3-A 1" to 4h" 5000 (197 cubic yds)
Building
- Bechtel Specification No. 25, Central Mix Plant, Section 3.5 (Mix Design) Revision 0, dated July 31, 1970, and Revision 1, dated October 23, 1970, (no change in mix design requirement from Revision 0 to Revision 1.)
The records reviewed during this inspection did not indicate that pours had been switched from one type of another.
However, at least on incidence of misplaced concrete is kncun to have taken place.
The incident and its resolution (placement of nine cubic yards of concrete designed for the reactor shield building into
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the spent fuel pit floor slab) is documented in RO:III Inspection s_ /
Report No. 050-346/71-02.
Additional documentation of RO:III l
inspection activities related to concrete are contained in RO:III
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Inspection Reports No. 050-346/71-01, No. 050-346/71-03, No.
050-346/72-01, No. 050-346/72-02, and No. 050-346/72-03.
d.
Concrete Placed Before Tests Performed The allegation stated that: " Concrete was placed and poured before tests were performed in order to minimize overtime work."
The exact nature of this allegation could not be determined, since required tests on concrete are difficult or impossible to perform after it has been poured.
Records reviewed during the inspection were Bently and Bechtel field inspection reports for the period September 30, 1970, to March 10, 1971.
Problems associated with preparation for pouring of concrete and two instances of reinforcing steel quaratine were noted with appropriate documentation of the resolutions.
Included were inspection reports of batch plant operations for conformance with ASTM and Bechtel Specifications.
The reports also included inspection results of PTL activities regarding tests of caterials cement, aggregate, water, fly ash and Curing Tank temperatures for conformance to ASTM and Bechtel specifications. No deficiencies were noted.
As indicated by the f-g records examined above and in Sections 1.a and 1.c of this report, no
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evidence was established which would substantiate this allegation.
e.
Michigan Testing Engineers, Incorporated - NDE Personnel The allegation specified that MTE personnel were unqualified for testing. A review of records of }EE indicated that the personnel assigned to the Davis-Besse project did not, except in one area (Cadwelding) perform any NDE work. MTE quality control efforts were limited to visual inspections of rebar and concrete work.
All NDE work was performed by PTL.
PTL verified all required strength tests for Cadwelding, concrete, and rebar.
MTE Personnel were qualified and tested for Cadwelding inspections of rebar.
The records reviewed indicated that the personnel of MTE, involved in Cadwelding inspections, were qualified to perform the job according to specifications.
No requirements or qualifications were necessary for visual inspections of rebar and concrete slump tests.
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Cooling Tower - Foundation Fill The allegation stated that foundation fill for the cooling tower, which came from an onsite quarry, failed to ccet specifications.
Since this subject was extensively covered in the environmental hearings and is not considered to be Class I, this matter uas not
"'g examined by the RO:III inspectors.
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Employees Asked to Do Thines Not in Conformance Uith ASTM and ACI Standards
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During all of the reviews conducted by the inspectors during this inspection, no evidence was found which would substantiate the subject allegation.
h.
NDE Personnel Used on Containment Vessel Fabrication The allegation stated that testers on the containment vessel were not qualified and that even laborers were used to perform tests.
The inspector reviewed all available personnel records to determine if the personnel periorming NDE work on the containment vessel were qualified to perform the required tests.
The records indicated t
that personnel involved in NDE work uere qualified to perform the required tests.
Tests performed on the vessel included Magnetic Particle, Radiography, and halide leak testing.
All test personnel signed the as-built drawings made of the containment vessel.
The records indicated that the personnel were qualified to SMT-TC-1A, Levels I, II, and III.
The only area that unqualified workers
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would have been used during tests was during the halide leak test of the containment vessel welds.
Helpers were needed to hold the test channel over the weld while the qualified tester performed the test ('~'}
from the opposite side.
No requirements or qualifications were (v/
needed for the helpers used for this test.
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Additional information on the qualification of personnel, relative x,,/
to the containment vessel, is contained in R0:III Inspection Reports No. 050-346/70-04, No. 050-346/71-02, No. 050-346/71-03, No.
050-346/72-01, and No. 050-346/72-03.
1.
Other Allegations The specified allegations were:
(1) selective rcther than random sampling done for testing, (2) onsite quality control was a weak link, and (3) records were destroyed.
During the reviews conducted by the inspectors during this inspection, no evidence was found which would substantiate the allegations enumerated above.
2.
Primary Piping During the inspector's review of the B&W weld material certification records, it was noted that, in many instances, the certifications were copies of the original, but the legibility was unacceptable in that it was impossible to determine the certification figures.
It was also noted that some certifications were approved for Navship and fossil use, but not for ASME rcquirements.
The B&W representative stated that he had recognized this fact and that he had it on his agenda for discussion with B&W QA management.
The inspector informed
[g the licensee that this matter would be reviewed during the next scheduled
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inspection.
(O a.
Follow-up Welding Record Revieu Examination of the welding (procedures) and weld rod issue control records on file for the primary piping indicated that they were completed satisfactorily for those areas completed to date.
A total of twenty-eight field welds comprise the primary system uelding schedule.
Seven welds have been partially completed.
Final grinding and radiographic examination his not been performed.
Records reviewed for veld procedures No. 26 and No. 30 included welds No. B-61-1, No WJ-2-2, No. WJ-31-2, and No. WJ-5-2.
The areas covered were:
(1) visual inspection of joint preparation, environmental control, root gap alignment, root pass, and completed weld; (2) preheat temperature, interpass temperature, weld quality, correlation of records to welds, defect removal, and acceptance of repair (final NDE has not been completed); (3) weld rod control thrcugh material receipt verificaticn, preissue storage condition and issue control; (4) disposition of unused material, and heat treat records; (5)
repair records (for welds No. WJ-5-2 and No. WJ-31-2); and (6) material control.
b.
Welding Follow-up Observation of Work
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Visual examination of welds No. WJ-2-2 and No. UJ-5-2 was made
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by the inspector.
Areas checked were:
(1) use of welding
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weld, welder, and inspector (the welds are not stamped; control of identification is being maintained on the weld record sheets);
(4) appearance of partially completed weld; and (5) control of weld material.
c.
Piping - Follow-up Records P.eview The quality records for piping examined during the inspection were reviewed. The primary piping is received onsite and installed using the material certification system as a prercquisite for receipt and
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installation. Records were examined for (1) receipt inspection; (2)
installation NDT (were required); and (3) QC inspection of installations.
The records were found to have been completed and signed satisfactorily.
Hydrostatic testing and cleanliness of the piping is to be reviewed during future inspections.
3.
Apparent Corrosion of Stainless Steel Connonents and Stainless Steel
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Components in Contact With Carbon Steel Hnnecrs and Connectors (no Inspection Reports No. 050-346/73-03 and No. 050-346/73-04)
A detailed investigation of the subject conditions was conducted by both Bechtel and ITT Grinnel.
Ecchtel's findings were transmitted by letter ET-3225, dated August 24, 1973, and the Grinnel reports were 7 ~sg
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transmitted on July 27, 1973, and Novc=ber 12, 1973.
The investigations
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. conclude that such rusting, or-discoloration, does not affect the metal-(
lurgical structure or quality of the underlying metal, nor is there evident of a decrease in the integrity of the stainless steel due to this condition.
Additionally, project specifications allow the use of carbon steel components on Class 3 systems and Class 2 systems of a 300 pound ratian, or less. A review of this practice indicated that no galvanic action would be anticipated and the stainless steel would not be affected.
Therefore, based on the conclusion of these reports and acceptance of these findings by TECO in memorandums dated January 10, 1974, from the chief mechanical engineer to the Vice President, Power Group, and from the Vice l' resident, Power Group, to_the Chief Mechanical engineer and the Davis-Besse quality assurance engineer, this matter is considered closed.
Electrical - Record Review - Welding I
a.
General Records associated with support and seismic welding for Class 1E electrical equipment, excluding penetrations, were reviewed.
The subject welding, which primarily involves supports for cabic trays and conduit, was estimated to be 60% complete at the time
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of the inspection.
Activities in two areas involving weld inspection j
for acceptability and control of welding operations appeared to be in
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nonconformance with applicable specifications or procedures and in v
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U violation of AEC criteria and are discussed in Paragraph 4.d, below.
A "stop work" order for Class IE (Q-listed) electrical welding was issued by Bechtel, approved by the licensee, and placed into effect on January 8, 1974. A subsequent phone call to the licensee established that the "stop work" order was still in affect as of January 31 1974.
Documents, procedures, and specifications examined during this inspection included:
(1) Bechtel Specification No. 7749-E-14, Revision 3, dated October 15, 1973.
(2) F-M, Quality Assurance Procedure (QAP) No. 1,." Welding Procedure",
Revision 0, dated Septecher 27, 1972.
(3) F-M, QAP-2, " Receiving and Receiving Inspection", Revision 0, dated September 27, 1972.
(4) F-M, QAP-6, " Processing of Nonconforming Items", Revision 0, dated September 27, 1972.
(5) F-M, QAP-1, Appendi:: A, " Welding Procedure Specification for the Welding of Carbon Steel".
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(6) F-M,. Quality Control Instruction (QCI) No.1, "Relding Procedure s_/
for Welding of Carbon Steel Structures per AWS D1.0-69", Revision s
1,. dated October 15, 1973.
(7) Weid Procedure Test Reports, Pittsburgh Testing Labcratory.
(8) Bechtel reports of audits and inspections of F-M activities.
(9) Bechtel and F-M Nonconformance Reports (NCR's) related to electrical welding activities.
(10) Bechtel "Stop Work Record" No. 5, dated January 8, 1974.
(11) American Welding Society (AWS) Standard Dl.0-69.
b.
Qualifications Qualification records for welders and weld procedures were reviewed and found to be properly documented and approved in conformance with applicable specifications.
Support and seismic welds for Class IE electrical equipment are specified to be in accordance with AWS Standard D1.0-69.
Electrical penetration welding is to be in accord-ance with ASME Sections III and IX.
(No electrical penetrations have been installed to date.)
The F-M welding engineer checks, at 7 ~~g least monthly, to verify the current qualification of each welder and records were available to establish this fact.
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c.
Weld Materials Receiving and material certification records for Type E-7018 welding electrodes were reviewed for shipments received January 18, May 4, and October 2, 1973.
No discrepancies were identified.
No inspection, relative to storage and issue con'.rol of welding materials, was performed since no Class IE electrical velding was in progress at the time of the inspection.
d.
Control of Welding Operations (1) Inspections Nonconformance reports and repair records for electrical welds were reviewed and considered to be in conformance with requirements.
';owever, procedures for inspection of Class IE support and seismic welds were not available, nor was documentation available to estab-lish that all electric.al Q-listed welds were inspected.
The F-M Quality Control Manual, in Section No. 9, states, in context, that " inspections necessary to assure compliance with the centract requirements will be performed and that detailed inspection procedures will be prepared and shall include accept-reject criteria, validation
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sheets, or check-off lists".
/N (2) Other Controls
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F-M, QAP-1, in parabraphs 8.1 and 8.2, states, in part, that:
"The welding inspector is responsibic for maintcining surveillance of all welding operations.
he must verify all fit-ups, electrodes, and filler materials.
. prior to the weld operation:, and (2) "Each velder is
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issued an identifying stamp.
IIe is required to affix the stamp tc welding records for all welding operations which he performs.
The welding inspector must counter staep the welding records af ter verifying acceptability of the operation".
Contrary to this, there was no documentation available to establish that requirements of the pro-cedure were being followed.
A representative of F-M stated that the procedure provisions referenced were intended to apply only to welding performed to ASME Section III requirements and not to welding performed in accordance with AWS Standard Dl.0.
i These same findings were-identified by Bechtel in audits performed on September 21, 1973, and on January 7, 1974, and, as a result, a "stop work" order for cicctrical Q-listed welding was issued on January 8, 1974.
The licensee was informed that, although corrective action had been initiated, these matters were considered to be in violation of AEC a
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regulations and would be brought to the attention of corporate l
management by a copy of our report summarizing the results of the inspection.
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