IR 05000346/1974007
| ML19326A102 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/29/1974 |
| From: | Hayes D, Jablonski F, Sutton J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19326A091 | List: |
| References | |
| 50-346-74-07, 50-346-74-7, NUDOCS 8001310665 | |
| Download: ML19326A102 (20) | |
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U. S. ATOMIC ENERGY C0!t1ISSION
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DIRECTORATE OF REGULATORY OPERATIONS
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REGION III
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Report of Construction Inspection
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RO Inspection Report No. 050-346/74-07
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I Licensee:
Toledo Edison Company Edison Plaza
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300 Madison Avenue Toledo, Ohio 43652 Davis-Besse, Unit 1 License No. CPPR-80 Oak Harbor, Ohio Category:
B Type of Licensee:
m Type of Inspection:
Special - Announced I'
Dates of Inspection:
October 23 - 25, 1974 Dates of Previous Inspection:
September 3 and 4,1974 (Operations)
V Principal Inspector:
. W. Sutton
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- (NJ5 Accompanying Inspectors:
F. J. 'Jablonski
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(Date)
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Other Accompanying Personnel:
. M. Hunni tt (October 23 & 24, l'974)
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Reviewed By:
D. W. Ha es,' Senior I
//[2.c/[7M Reactor Inspector (Date) '
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'(N Construction Projects COPY SENT TO: PDR LPDF NSIC
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SUMMARY OF FINDINGS
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Enforcement Action
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i A.
Violations Certain activities at the Pavis-Besse Plant appear to be in violation
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of AEC regulations, as identified below, and are considered to be of Category II severity.
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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, or drawings.
and
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shall be accomplished in accordance with these instructions, procedures, or drawings..
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Contrary to the above, electric cable tray grounding activi-ties are proceeding without approved instructions or proce-dures to verify that final inspection has been performed.
(Report Details, Paragraph 1)
2.
10 CFR Part 50, Appendix B, Criter' ion XIII, states, in part, i
that:
" Measures shall be established to control the handling, storage, shipping, cleaning, and preservation of material and Oi equipment in accordance with work and inspection instructions to prevent damage or deterioration.
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Contrary to the above:
a.
Measures were not established that could verify that the emergency diesel generators were being stored and protected
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in a manner which will prevent deterioration.
(Report
Details, Paragraph 2)
b.
Sections of safety related piping spools, valves,
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unused coated weld rods, and seismic restraints, were found scattered in debris in the auxiliary feedwater pump
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room.
(Report Details, Part II, Paragraph 1)
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B.
Safety Matters: No safet', matters were identified.
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- Licensee Action on Previously Identified Enforcement Matters 1.
~ Documented Procedures - Welding Instruction Sheet _(jU) Inspection Report No. 050-346/74-04)
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.The corrective action, for the above item, as outlined in the Toledo, Edison Company (TECO) letter of July 26, 1974, in response (~)'
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to the RO:III letter and report dated June 25, 1974, was found to
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have been satisfactorily accomplished and documented.
The approved Babcock & Wilcox Company (B&W) Field Construction Procedure Deviations No. 19-02, No. 26-03, No. 27-02, and No. 28-02 indicated that dispositions had been submitted and have been approved by Bechtel Corporation (Dechtcl).
This matter is considered closed.
2.
Licensee Action on Other Previously Identified Enforcement Matters (RO Inspection Report No. 050-346/74-05)
Correctiva action taken and planned has been outlined by TECO in a letter dated September 25, 1974, from Mr. L. E. Roe to Mr.
J. G. Keppler.
RO:III has performed a re-inspection of the apparent
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violations and determined that adequate corrective pction has been taken on six items.
A re-inspection will be conducted at a later date to verify completion of corrective action for the apparent violations under Criterion I, II, VI, and XVIII.
The corrective action taken on the remaining four items appears to meet the intent, but additional evaluation will be completed by RO:III prior to closing these items.
(Report Details, Part III)
_D_esign Changes: No new design changes were identified.
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Unusual Occurrences:
No unusual occurrences were identified.
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Other Significant Findings A.
Current Findings The licensee indicated that, as of September 1, 1974:
(1) construc-tion was 69% complete, and (2) engineering was 96% complete.
B.
Unresolved Matters 1.
Cooling Water Piping to Emergency Diesel Engine 2 Verification is required to establish that cooling water and compressed air piping, for Emergency Diesel Engine No. 2, routed through Emergency Diesel Engine Room No. 1 do not impair redundancy requirements.
2.
Hydraulic Snubbers The specification and purchase orders for the hydraulic snubbers and restraints did not specify the sealmaterial requirements for hydraulic snubbers and restraints to be installed in high radiation and temperature areas.
(Report Details, Part II, Paragraph 2)
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Design Drauing Change Verification
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Errors on main steam piping isometric Drawing No. PM-203A,
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Revision 1, have been carried through on current revisions without corrections.
(Report Details,-Part II,-Paragraph 3)
4.
Cable Tray Installation Procedure-Procedure No. IIP-7749-E14-7A-001, Revision 0, dated July 7, 1973, indicated (in Note No. 2) that "Firestops, separation barriers, covers, and permanent markers would be installed and-inspected at a later date".
Definition of the terms used and indication of the completion time frame was not available for theJinspector's review.
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Cable Tray Storage l
An inspection of the cable tray storage area was conducted by
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the inspector. Discrepancies relating to the identification and storage of materials were noted.
Due to an understanding by the contractor's personnel that the trays were not classed as lE (Q-listed) the trays were not being maintained in an j
approved manner. This matter was discussed with TECO QA
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personnel and revised ' procedures are to be available for review during the next. scheduled routine inspection.
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6.
Diesel Generator-Relays The Quality Control Program and' Procedures Transmittal Form
.(7749-M-180-Q-28-1) dated March 22, 1974, titled "Scismic Qualifications for the. Exciter Cubicle" had been approved without comments.
The file contained a letter dated December 19, 1972, relating to four relays. These components failed to pass certain seismic tests.
In part, the letter states:
"It
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would appear that either the relay types must be changed or that their functions in the circuit must be bypassed during a seismic event".
The corrective action taken to resolve this matter had not been documented or'noted on the transmittal-form.
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7.
Calibration Records-Stress Relieving Instrumentation and Equipment
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The inspector noted that the equipment being used for stress
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relieving of the steam piping was not' tagged with calibration stickers.
The inspector was, informed that all the equipment was newly purchased, and records pertaining to the calibration
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were stored at B&W's headquarters and would.be forwarded to
the site and made available for the inspector's review. This
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matter will be reviewed during the next scheduled inspection.
C.
Status of Previously Reported Unresolved Matters 1.
Class lE Electrical Weld Acceptability (R0 Inapection Report No. 050-346/74-04)
This matter remains open pending the inspector's review of the results of an additional review of this item by the licensee.
2.
Reactor Coolant Pumps Suction Weldment Linear Indications
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(R0 Inspection Report No. 050-346/74-04)
A final report persuant to 10 CFR Part 50.55(e) has not been submitted. Repair work to the reactor coolant pump suction welds is in progress.
3.
Incomplete We1Ain~ "ecords', Reactor Coolant Pump - Primary Piping (Rc
,_;21on Report No. 050-346/74-04)
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Weld material and weld documentation records did not reflect f 's the exact record of work in progress.
This matter will be (
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reviewed during the next scheduled inspection.
%J 4.
Class 1E Electrical Cable Trays (R0 Inspection Reports No. 050-346/74-02 and No. 050-346/74-04)
The licensee had been previously informed, by the inspector, that this matter had been referred to R0 Headquarters for resolution the matter pertained to the change by Bechtel of the classification and installation procedures of electrical cable trays for Class 1E electrical cables.
The inspector informed TECO management that it is R0 Headquarters' position-that receipt inspection, storage, and installation of Class 1E cable support systems, including trays as well as seismic supports, should lui included in the licensee's QA program and
should address matters as straightness and crueness of sections and installed runs, freedom from sharp corners, or projections which might damage cable insulation, electrical bonding, etc.
This matter will be further reviewed for inclusion in the licensee's QA/QC programs during the next scheduled inspection.
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Uestinghouse Electric Corporation (W) High Pressure Injection ~
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Pump Motors (R0 Inspection Reports No. 050-346/74-01, No.
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050-346/74-02,'and No. 050-346/74-04-)
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The inspector was informed that the subject motors have been modified and raturned to the site.
Documentation pertaining to the final resolution will be reviewed during the next scheduled inspection.
Management Interview A.
.The follouing persons attended the management interviews at the conclusion of the inspection.
A separate management interview was held on October 24, 1974, to discuss violations identified during a previous inspection relative to protec'tive coatings installed by
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Bagwell Coatings, Incorporated (Bagwell).
Toledo Edison Company (TECO)
L. E. Roe,.Vice President - Power (October 24 and 25, 1974)
J. D. Lenardson, Quality Assurance Engineer (October 24 and 25, 1974)
G. W. Eichenauer, Quality Assurance Ficid Representative (October 25, 1974)
E. C. Novak, Project Engineer (October 25, 1974)
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j Bechtel Corporation (Bechtel)
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11. A. Ablondi, Project Quality Assurance Engineer (October 24 and 25, 1974)
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j C. L. Huston, Field Construction Manager (October 25, 1974)
Bagwell Coatings, Incorporated (Bagwell)
T. D. Cohen, Vice Presidant (October 24, 1974)
C'. H. Ridgdell, Project Manager (October 24, 1974)
B.
Exit Interview Conducted on October 24, 1974 An exit interview was held on October 24, 1974, to discuss the results of the re-inspection of apparent violations reported in RO Inspection Report No. 050-346/74-05. The inspection results were discussed in.a point-by-point discussion of each of the ten apparent violations answered in a letter dated September 25, 1974, from Mr.
L. E. Roe to Mr. J. G. Keppler.
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1.
The inspcctor stated that Bagwell's recently prepared QA i
Manual and commitment to establish a direct line of communica-
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tions between the QA/QC Engineer at the site and the Bagwell
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- corporate office appears to have been met.
RO:III will review the QA Manual prior to closing this item.
2.-
The inspector. stated that a review of the May 21, 1974, audit-performed by TECO-indicated that four_ outstanding items were identified. One of these items had been resolved and three i
were unresolved. A commitment to purchase fire resistant file-cabinets had been made by the Vic?e President, Bagwell.
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results of an Internal Audit had not been documented but vould L
be completed and on file.in the near future. No audit of the
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l paint suppliers was available. The inspector stated that
these-three items would be carried as "open" and re-inspected
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during a subsequent inspection.
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3.
The. inspector stated that the appropriate procedures had been made=available for review and that these procedures and-instruc-
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tions were adequate.
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The inspector stated that a cursory review of the Bagwell QA
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. Manual indicates that-it contained instruction to maintain and-
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control appropriate documents. The. licensee committed to
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verify thatLthe'Bagwell QA Manual is implemented.
~5.
The inspector stated that documentation and physical possession
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of the samples required by Specification 7749-A-24 was made available for inspection.
6.
The. inspector stated that the purchase of new, calibration
. thermometers and' verification that thermometers used during the coating of the containment vessel liner plating were
.within acceptable tolerances resolved this item.
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The inspector stated that corrective action for use of NCR's l-
-appears to be adequate.
The licensee had no comment.
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8.
The; inspector stated that appropriated documentation related to completion of corrective action on NCR's was available for
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review and the item is considered closed.
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The inspector 1 stated that a re-inspection indicates that
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-available' documentation appears to be adequate when included with other information covered in all other phases of this
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inspection. -The, inspector-recognized that lost documentation
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could not be replaced, but the reasonable attempts had been
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made to' consolidate available information and piece the record l
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together as'far as possible. The lack of signatures or
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initials and dates on hand corrections to typed information on BC-4 forms could not be retro-fitted, but has been' 6crrelated as far as practical by the licensee, the contractor and the sub-contractor. The inspector stated that the item is closed.
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The licensee had'no questions on comments on the items discussed except as noted.
C.
Matters discussed and comments, on the part of management personnel,
.during the October 25, 1974 management interview, were as follows:
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1.
The inspector stated that records and procedures which were reviewed indicated that cable tray grounding activitics were
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proceeding without approved inspection instructions or pro-cedures to verify that final inspection has been performed.
This was considered an apparent violation of 10 CFR Part 50, Appendix B, Criterion V.
(Report Details, Paragraph 1)
2.
The inspector stated that records and procedures which were reviewed indicated that measures were not established which would verify that the emergency diesel generators are being
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stored and protected in a manner which will prevent deterior-ation. This was considered an apparent violation of 10 CFR Part 50, Appendix B, Criterion XIII.
(Report Details, Paragraph 2)
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The inspector stated that conditions observed during the inspection of the feedwater pump room area indicated that precautions to protect sections of safety related material had not been taken.
Appropriate measures to prevent a recurrence had not been initiated.
This was considered an apparent violation of 10 CFR Part 50, Appendix B, Criterion XIII, requirements.
(Report Details, Part II, Paragraph 1)
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4.
The inspector stated that a review of Procedure No. IIP-7749-
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E14-7a.001, titled " Inspection of Electrical Installation Hangers and Supports" contained sections which could not be clearly defined for the inspector.
The l'icensee indicated that this matter would be reviewed.
5.
The inspector stated that conditions observed during the inspection of the cable tray storage. area indicated that certain irregularities existed. The licensee stated that-these irregularities ' would be corrected.
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The inspector stated that, during revieu of the emergency.
-diesel engine records,-it appeared that followup corrective action relative to failure of certain relays for the diesel-generators to pass scismic qualification testa had not been
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~ initiated. The inspector added that the quality control
package for the dicsc1 generators, including the defective-relays, had apparently been approved.
The licensee-stated that this matter would be investigated.
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7.
The inspector. stated that it was'the Commission's position that thefelectrical cable trays for Class 1E electrical cables should be included in the licensee's QA program and that this-
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item would be reviewed during subsequent inspections.
The i
licenseo stated that this matter is being reviewed by TECO and
'Bechtel management.
l 8.
The inspector discussed the TECO QA audit programs that have
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been conducted and indicated that independent TECO audits of
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the A-E and constructor would be advisable, and that the,
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action taken relative to this matter would be reviewed during a subsequent inspection.
The licensee stated that this item t
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would be discussed with TECO management personnel.
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The inspector _ stated that the present routing of cooling water j
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and compressed air piping for Emergency Diesel Engine No. 2, through Emergency Diesel Engine No.1 room, may -impair the redundancy requirenents.' The licensee stated that this matter
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would be reviewed by the A-E.
10.
The inspector stated that seal material for hydraulic snubbers used in high radiation or temperature areas should be specified both in component Specification 7749-M1-90 and in purchase orders to alert the manufacturer to select the appropriate
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radiation and temperature resistant materials. The licensee stated that this matter would be discussed with the A-8.
t 11.,The inspector stated that, during the review of the main steam
' piping drawings, it appeared that errors were not being detected
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promptly and corrected.
Records available at the site indicated
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that the design changes being made were not being documented.
-The licensee stated that this matter would be corre ted.
(Report Details, Part II, Paragraph 3)
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REPORT DETAILS
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Part !
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/['27'79 Prepared By:
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F.'3.(Jablonski (Date)
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Reviewed By:
D. M. Hdanf6utti (Date)
Persons Contacted The following persons, in addition to individuals listed under the Management Interview Section of this report, were contacted during the inspection.
Bechtel Corporation (Bechtel)
W. B. Barry, Lead Quality Control Documentation G. K. Grover, Senior Electrical Quality Control Engineer R. T. Hayes, Mechanical Field Engineer f'~',
R. L. Lewis, Project Quality Assurance Engineer (
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W. C. Lowery, Electrical Quality Assurance Engineer w/
Fischbach & Moore, Incorporated (FSM)
H. J. Harris, Quality Control Coordinator
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D. M. Moeller, Quality Control Manager
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Toledo Edison Company (TECO)
K. M. Cantrell, Field Quality Assurance Engineer Results of Inspection 1.
Cable Tray Grounding The inspector observed that cable tray grounding activities had been performed. As a result, the inspector reviewed Procedure No. IIP-7749-E14-7a.001, Revision 0, dated July 17, 1973, titled
"The Inspection of Electrical Installation Hangers and Supports".
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" Grounding. - visually check for proper grounding (tightness of hardware and exothermic welds, etc.).
(See note number one.)....".
Note one states" " Design of tray grounding not available at this writing".
The inspector questioned the licensee how grounding activities could be in progress if there was not an approved method of grounding. The licensee supplied the inspector with Bechtel' Drawing No. 301A, dated and approved in July 1974.
This drawing was reviewed and was found to contain cable tray grounding
. details.
Six cable tray installation cards were also reviewed.
These cards have an installation inspection checklist on the reverse side.
Every card had inspection point "G", cable tray ground, marked
"N/A".
j Drawing No. 301A clearly supplies the licensee with a cable tray
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installation procedure. The issuance of this drawing voids Procedure IIP-7749-E14-7a.001, Revision 0.
- Based upon review of these procedures, documents, and drawings, it is apparent that the licensee does not have instructions or procedures which will provide for the inspection of previously installed or subsequent cable tray grounding installations.
The licensees representative was notified'that this was an apparent violation of gss i
AEC requirements and would be brought to the attention of TECO i
management.
2.
Diesel Generators The inspector observed that electrical conductors were installed in
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the vicinity of the diesel generator space heaters.
The licensee
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was not able to provide evidence of the date on which these heaters were energized, nor that a routine inspection had ever been made to verify that the heaters continued to remain energized.
The licensee also was not able to provide evidence that the generator had ever been meggered, nor that any tests of this type would be made.
Discussions with site personnel indicated that surveillance responsi-bility was not clearly defined.
The inspector reviewed Purchase Order No. 1542, Emergency Diesel Generator, dated April 5, 1974.
Under the heading of "Special Storage" was a requirement to energize the generator space heaters.
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Also reviewed was a documented telephone conversation dated November 7, 1973, between Bechtel and Bruce GM Diesel.
The message was relative to the energizing of space heaters and the meggering of the generators
- "on a regular basis to verify no moisture buildup".
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'These. documents indicate that there are special storage requirements for.the emergency diesel generators.
l Based upon these facts,'it is apparent that the licensee has failed to establish measures to meet the supplier's requirements to store and protect this equipment in a controlled manner.
This is an apparent violation of Criterion XIII of Appendix B, to 10 CFR Part 50.
3.
' Audits
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The inspector reviewed Audit Report No. 132, dated March 19, 1974.
The licensee's agent performed an audit of installation and inspection
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of Class 1E cables.
All deficiencies found during the audit were corrected, and the audit was closed out on August 28, 1974.
This audit appears to have been performed in a manner which meets requirements.
4.
Battery Installation The inspector reviewed the installation procedure for station
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batteries numbered IP7749-E14-6h.001 dated March 14, 1974.
Also reviewed was Specification No. 7749-E-18 and REDOC 53.
Based on
'~N this review and observations by the inspector, the two station
,. location, and batteries appear to meet installation, inspection
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seismic requirements.
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'N../ -J-REPORT DETAILS
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Prepared By:
K. R. Naidu
'(Date)
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Reviewed Dy:
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// - 7.17Y D. M. Il6nni' cutt (Date)'
Persons Contacted The following persons, in addition to individuals listed under the
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Manageraent Interview Section of this report, were contacted during
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'the inspection.
Toledo Edison Company (TECO)
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E. A. Wilcox, Field Quality Assurance Specialist C. T. Daft, Quality Assurance Engineer ITT Grinnell Corporation (ITT)
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D. Giguere, Quality Control Manager b
L. A. McGuire, Project Manager
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F. Magner, Job Superintendent J. Uuderstadt, Site Chief Engineer C. Keller, Incoming Receipt Inspection
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Bechtel Corporation (Bechtel)
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R. Kies, Piping Field Engineer Babcox and Wilcox (B&W)
W. R. Klingler, Project Manager
.J. W. Marshall, Q.
C.' Supervisor
C. R. Hilling, Q. C.
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i 1.
Storage Conditions in the Auxiliary Feedwater Pump Area
i During inspection of. safety related piping, it was observed and brought to the attention of.tlus licensee that the handling and storage of safety.related ("Q" listed) items, such as pipes, spools, scismic restraints, and unused weld rods,_ appeared to be below acceptable standards..The ends of pipe sect'ons were not covered i
as. required by Bechtel's Specification No. ~ 7749-M-453, Paragraph
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15.1.3.. Unused weld rods were found scattered on the floor, and restraints were found lying in debris.
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The inspector reviewed a report on an exit interview held on
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September 27, 1974, by a representative of Bechtel's San. Francisco office.
In addition to other deficiencies, the report identified storage deficiencies of:
(1) unaccounted, unused weld rods, and (2) storage of "Q" listed piping and restraints.
The report stated that corrective action was taken by removing unused weld rods and assigning the ITT QA manager to clear the debris and to store the pipes and restraints according to Bechtel's Specifica-tions No. 7749-M-453 and No. 7749-M-453 in 30 days.
However, during an interview with management personnel of IIT, the inspector established that it appeared corrective action had not been initiated, and procedures to prevent recurrence were not prepared.
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2.
Hydraulic Snubbers
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The inspector reviewed Bechtel's Design Specification, Part II, No.
7749-M1-90, on hangers and TECO's P0 No. Q1734 to ITT, Warren Ohio,
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for snubbers, and found no special requirements on the seals.
From available literture, it appeared that "Hi-Seal Imperial" seals, manufactured by the Eastman Corporation Chicago, Illinois, would be used.
Information was not available that these seals had been tested and found to successfully withstand high radiation and temperature conditions over extended periods, without permanent deformation and damage. The licensee stated that he will review
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this matter with the vendor.
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3.
Design Drawing Change Verification During the review of Main Steam Piping Isometric Drawing No. PM203A, Revision 12, to select welds for a record review, two errors were found and were traced to have occurred while modifying Revision 10 of the drawing to Revision 11, and it was determined that the errors went uncorrected.
Procedures for design verification process were not available.
During interviews with the site design personnel, it was established that only some of the design changes, initiated through telephone conversations, were documented, and such informa-tion was not made available to the personnel assigned to verify the accuracy of design changes.
Followup is planned during subsequent inspections.
4.
Main Steam Piping Inside Containment (B&W)
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Implementation of Quality Assurance Progr'am a.
A review of the TECO, Bechtel, and B&W organizations and *. heir
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functional relationships indicated that applicable quality requirements were being met relative to main steam piping inside containment.
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welding' appeared to'be acceptable by selective record review
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of:
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Isometric drawings i
(3). Material certifications for pipe, spools, and weld
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(4) Material and shop NDE reports
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'(5) Welder, inspector, and NDE personnel identification
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i (7) Furnace load sheets and heat treatment records
(8) Deviation. reports Welding _ Record Review j
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An.cnamination of the weld records of five' welds, No. 3A, No.
4A, No. 6A, No.12B, and No. 9B, where all welding and inspection
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of applicable codes, QA, and work ~ performance procedures were satisfactorily met.
The weld records reviewed for each weld selected included.the following:
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QC inspector records covering visual and dimensional
inspection.
-(2) Weld history records.
Furnace -load sheets and heat treatment records (3).
I (4). Records covering evaluation radiographs of welds.
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(5)
Deviation Reports No. 71-08, No. 71-06, No. 71-07, and No. 71-02, all dated September'11, 1974, for field welds
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No. 3A, No. 4A, No. 6A, and No. 9B, respectively, which
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were forwarded to Bechtel for cicarance, since the heat
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F treat temperature was exceeded by'approfimately 50 F.
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Ilowever, the inspector.noted no indicatioa.to check the
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calibration of the heat treat recorder,.since all the deviations were-based on the high temperature indicated.
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(6) Welding material control recor'ds, covering receipt verifi-cation of.the identity and conformance with specifications, control of preissue storage condition, identification and issue control.
(7) Welder qualification records.
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Observation of Work Welding activities on the main steam piping were not being performed on the days of inspection.
5.
Main Steam Piping Outside the Centainment (ITT)
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a.
Implementation of Quality Assurance Program A review of the TECO, Bechtel, and ITT organizations and their functional relati*onships indicated that applicable quality requirements were being met relative to welding activities on
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main steam piping outside the containment.
b.
Review of Quality Control System
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The ITT QC s', stem for main steam piping, related to field (
welding, w.s determined to be acceptable by selective record
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review of:
(1)
Receiving inspection reports (spool pieces are fabricated at ITT, Kernersville).
(2)
Isometric. drawings.
(3)
Material certifications for pipe, spools, and weld electrodes.
(4)
Material and shop NDE reports.
(5) Walder, inspector, and NDE personnel identification.
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Welding Record Review An examination of the weld records of five welds, No. FWil, No. FW12, No. FW 13, No. FW14, and No. FW18, where all welding
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and inspection activities were completed, established that the requirements of applicable codes, QC, and work performance
procedures.were satisfactorily met.
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(2) Weld history records.
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NDE records covering evaluation of welds.
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'(5) Heat treatment records covering preheat and interpass temperature stress relief heat treatment was not specified j
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i (6) The records did not show any deviation reports or weld i-repairs.
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Observation of Work Welding activities on the main steam piping outside containment were not in progress during the current inspection.
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REPORT DETAILS v
Part III
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Prepared By:
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D. M. Hunnicutt (Date)
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//- 29 - 7 V Reviewed By:
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D. W.' Hayed (Date)
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Re-inspection of Items Listed in RO Inspection Report No. 050-346/74-05 A discussion with cognizant Toledo Edison and Bechtel personnel was held on October 24, 1974, to discuss each of the apparent violations listed in R0 Inspection Report No. 050-346/74-05 and the Toledo Edison answers to each of these apparent violations.
The answers and a general dis-cussion of the Containment Vessel Liner painting are documented in a letter to Mr. J. G. Keppler, Regional Director from Mr. L. E. Roe, Vice President, TECO dated September 25, 1974.
The results of this discussion and re-inspection of these apparent violations were as follows:
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T A.1 Criterion I
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The Baguell Coating, Inc., (Bagwell) organization had been further strengthened by a direct line of communication between the Bagwell QA/QC Engineer in the filed and the Bagwell corporate office.
In addition, Bagwell has prepared a Quality Assurance Manual for the Installation of Protective Coatings in Class I Areas at Davis-Desse Nuclear Power Station. This Manual is under review by RO:III.
This item remains open pending RO:III completion of the manual review and subsequent verification that the proposed organization functions as described.
A.2 Criterion II & XVIII The results of the second audit (dated May 21, 1974) conducted by TECO were made available for RO:III inspection. This audit indicated that three minor items remained unresolved.
During the inspection one of these three items was resolved when the Lagwell Vice President committed to purchase fire resistant file cabinets as an additional precaution against loss of records by a posttlated fire in the file storage area.
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The results of an Internal Audit will be documented and made available for RO:III review. An audit of Suppliers will be made available for RO:III review during a subsequent inspection.
Furthermore, results of additional audits by both Bechtel and TECO that are committed to be performed prior to the performance of any containment vessel liner plate coating and will be reviewed during a subsequent inspection RO:III.
This item remains open.
A.3 Criterion V The sub-contractor made appropriate procedures available for review.
RO:III review verified that procedures and manufacturer's instructions were adequate to meet the requirements of Specification No. 7749-A-24, Revision 4.
This item is closed.
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A.4~
Criterion VI The Bagwell Quality Assurance Manual includes instructions to maintain appropriate documents and that these documents will be
,
made a part of the permanent job files.
The licensee and contractor will verify that the Bagwell quality assurance program is implemented.
This item is closed, but is subject to re-inspection during a subsequent inspection.
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A.5 criterion VII g/
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The subcontractor produced a letter from Bagwell to Ameron dated May 19, 1972, requesting five (5) sample panels of concrete and five sample panels of steel onto which the primer and surface coatings had been applied.
The completed panels were available for inspection. The subcontractor stated that the panels had been stored in a vault at the construction site since about July 1972.
A letter of transmittal for the five (5) approved samples from Ameron and five (5) approved samples form Carboline was forwarded from Bagwell to Bechtel on September 10, 1974.
The Bechtel represent-ative stated that the samples would be stored in the QC vault.
Bagwell has received Manufacturer's Product Identity Certifications from the paint supplier for each batch received. These certifi-cations state that the formulation and manufacturing of the paint batches are "resasonably identical".
These certifications from Carboline were dated October 9, 1974, and were forwarded to Bagwell subsequent to a letter dated August 13, 1974, that stated that the company'could not certify that the various-paint batches were
" precisely identical", but that the company could certify that the various paint batches were "rcasonably identical".
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j Documentation indicated that independent laboratory testing was
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fac'complished on June 5, 1973. The testing included adhesion testing at random within the containment vessel,' infrared spectrograph analysis of Amercoat 66 and design basis accident (DBA) testing of
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carbo-zinc 11 topcoated with Amercoat 66.
The results were sent to Bagwell'on July 12, 1973.
Results of the testing are referenced by P. 0. No. 2098-8437 dated August 30, 1974. The reported results indicate that the adherence qualities are adequate to meet postulated DBA requirements. The documentation and corrective action appear to be adequate. This item is closed.
A.6 ' Criterion XII Documentation indicates that the surface thermometers used during the time period when coatings were being applied to the containment
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e vessel liner plating had sufficient accuracy. These thermometers were Model 309F and had a maximum deviation of 4 F.
Recently accquired Model 312 F thermometers were shipped to the construction site on August 19, 1974.
The accuracy of these Model 312 F thermo-meters is a deviation of 4 F.
Verification that the thermometers were within specified limits and purchase of calibrated thermometers
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This item is closed.
A.7 Criterion XV g
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Adequate corrective action has been taken by the licensee. This
['~'s item is considered closed.
v A.8 Criterion XVI
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Documentation indicates that a total of 112 pails (5 gallons each)
and 50 cartons of paint were returned to the manufacturer on October 6, 1972. This documentation and NCR Nos. 8172-1-QC and 8172-2-QC are considered adequate to close this item.
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A.9 Criterion XVII The licensee has conducted a detailed review of records and document-ation of inspections for work related to the coating application to
,
-the containment vessel liner plating. A re-inspection by RO:III indicates that available-documentation appears to be adequate when included with information covered in items discussed above.
The lack of initials or signatures and date verification on hand correc-tions to various BC-4 forms was included in the review conducted by the licensee.-
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The review and corrective action taken by the licensee appears to be ade.quate. This item it closed.
E A.10 Criterion XVIII
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j-This item is discussed in A.2 and is considered adequate.
The item
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is closed.
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