IR 05000346/1975003
| ML19319B587 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/01/1975 |
| From: | Hayes D, Jablons F, Sutton J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19319B585 | List: |
| References | |
| 50-346-75-03, 50-346-75-3, NUDOCS 8001270110 | |
| Download: ML19319B587 (19) | |
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O U. S. NUCLEAR REGULATORY C0:0!ISS:0N OFFICE OF INSPECTION AND ENF NCEMENT
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REGION III
Report of Construction Inspection
IE Inspection Report No. 050-346/75-03 Licensee:
Toledo Edison Company 300 Madison Avenue Toledo, Ohio 43652 Davis-Besse, Unit 1 License No. CPPR-80 Oak liarbor, Ohio Category:
B Type of Licensce:
PWR (B&W) - 872 MWe Type of Inspection:
Routine, Unannounced Dates of Inspection:
March 5-7, 1975 Dates of Previous Incpection:
January 22-24, 1975 (Construction)
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Principal Inspector:
J. 'W. Sutton -
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J.fJablonski 3-28 75 Accompanying Inspectors:
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K. R. Naidu
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Other Accompanying Personnel:
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D. W. Ilayes, Senior Icactor Inspector l[/!/f
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Construction Projects
'(Date)
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SUMMARY OF FINDINGS Enforcement Action A.
Violations None B.
Safety Matters None Licensee Action on Previously Identified Enforcement Matters 1.
Use of approved instrumentation installation / fabrication planner (IE Inspection Report No. 050-346/75-01)
2.
Failure to provide and use approved instructions, procedures, and drawings during installation and fabrication of safety related components (IE Inspection Report No. 050-346/75-01)
3.
Failure to have documentary evidence of material conformance to procurement requirements prior to installation of components and structures (12 Inspection Report No. 050-346/75-01)
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4.
Failure to establish and control use of inspection stamps during
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construction (IE Inspection Report No. 050-346/75-01)
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5.
Failure to control tools used in quality related activities (IE Inspection Report No. 050-346/75-01)
6.
Failure to control the handling, storage, and preservation of quality related materials and components (IE Inspection Report No. 050-346/75-01)
7.
Failure to issue a stop-work order relative to the installation of safety related instrumentation components found to be improperly controlled (IE Inspection Report No. 050-346/75-01)
Although it was apparent that the licensee had taken action relative to these matters, an answer to the notice of violation had not been completed at the time of the current inspection.
These matters remain open pending receipt of an acceptable response from the licensee.
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Design Changes No new design changes were identified.
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Unusual Occurrences N__/
No unusual occurrences were identified.
Other Significant Findings A.
Current Findings 1.
Current Status The licensee indicated that, as of January 31, 1975: (1) construction was 80.2% complete, and (2) engineering was 98.7% complete.
2.
Personnel Changes Johnson Cc ntrols Company (Johnson) is currently recruiting for a new quality assurance representative.
At present, the Corporate Director of quality assurance is responsible for QA matters.
B.
Unresolved Matters 1.
Documentation on Paint Documentation is required that spproved the use of high zine content primer for the fabricat.on or repair of the ventilation f"'x duct.
(Report Details, Part III, Paragraph 3.d)
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2.
Inappropriate Closure of Nonconformance Reports (NCR's)
NCR's No. 376 and No. 399 were found to be closed, even though the deficiencies mentioned therein were not satisfactorily resolved.
(Report Details, Part III, Paragraph 3.c)
3.
Incomplete Test Data Verification is required whether additional test data is required to meet the requirements of Technical Specification No.
7749-M-404, Air Filteration System.
(Report Details, Part III, Paragraph 3.g)
4.
Clarification in Technical Specification Verification is required whether Technical Specification No.
7749-M-404, Section 8.1.1.n.3 should read:
"The minimum tensile strength shall be 1.25 pounds per inch
' width'", instead of
' water', as mentioned in Revison 4, dated October 31, 1974.
s (Report Details, Part III, Paragraph 3.h)
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5.
Evaluation of Test Requirements on Filters td Evaluation is required to determine whether the charcoal and HEPA filter elements, manufactured, tested, and delivered during 1973, meet the requirements of Technical Specification No.
M7749-M-404, Revision 4, dated October 31, 1974.
(Report Details, Part III, Paragraph 3.k)
6.
Procedure on the Quantity of Zinc Inside the Containment A procedure is required to collect information to verify that installed duct work surfaces do not exceed the estimated area value as indicated in the FSAR. (Report Details, Part III, Paragraph 3.1)
7.
Audit on the Installed Restraints An in-depth audit of the seismic and thermal restraints is required to identify location changes made without engineering approval, and to verify whether the altered positions meet the seismic qualification criteria.
(Report Details, Part III, Paragraph 4)
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8.
Emergency Diesel Cencrator Storage During a review of surveillance records, it was determined
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that the licensee has not satisfactorily implemented corrective k_,/
action relative to the preservation of the emergency diesel generator.
This matter will be reviewed during a cubsequent inspection.
(Report Details, Par't II, Paragraph 1.a)
9.
Design Changes to Seismic Class I Tubing Protection Revision No. 1 to Bechtel Drawing No. J-G16-4 appears to remove any protection afforded to safety related instrument tubing, as required by Appendix A, Criterion 4.
This matter was discussed with the licensee and Bechtel engineering personnel.
IE:III followup review will be made during a subsequent inspection.
C.
Status of Previously Reported Unresolved Matters 1.
Cooling Water Piping to Emergency Diesel Engine No. 2 (R0 Inspection Report No. 050-346/74-07 and IE Inspection Report No. 050-346/75-01)
The inspector observed the cooling water piping to emergency diesel engine No. 2 being dismantled.
This item remains open pending review of revised drawings showing rerouting.
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2.
Hydraulic Snubbers (R0 Inspection Report No. 050-346/74-07 and IE Inspection Report No. 050-346/74-01)
-The inspector reviewed available information on the seal material
j and oil used in the hydraulic snubbers and determined that no test data was available to indicate that the material used to i
manufacture the seal was tested and found to s.atisfactorily withstand high temperature and radiation without deleterious effects.
This item remains open.
3.
Design Drawing Change Verification (R0 Inspection Report No.
050-346/74-07 and IE Inspection Report No. 050-346/75-01)
The inspector verified the records at ITT Grinnell Corporation
I (Grinnell) pertaining to drawing transmittals.
He also reviewed the revised drawing verification system and determined that the implementation was in order.
This item is considered closed.
4.
Cable Tray Installation Procedure (R0 Inspection Report No.
050-346/74-07)
This matter remains open pending the inspector's review of the licensee's procedure that would verify that these items are
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included as part of the inspection program.
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5.
Cable Tray Storage (R0 Inspection Report No. 050-346/74-07)
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i This item remains open pending the inspector's review of procedures and observation of the storage area.
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6.
Calibration Records - Stress-Relieving Instrumentation and Equipment (R0 Inspection Report No. 050-346/74-07)
Implementation of revised calibration procedure No. 9T101, Revision 4, will be verified during a subsequent inspection.
This item remains open.
7.
Diesel Generator-Relays (R0 Inspection Reports No. 050-346/74-07 and No. 050-346/74-10)
l The 1E:III inspector reviewed documentation which verified that
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the four (4) relays, which failed to meet seismic qualification, I
were not actually a part of the equipment to be used at the
Davis-Besse site.
However, other records indicated that tests i
performed on Davis-Besse related equipment were not complete.
This matter remains open and will receive follow-up review during a subsequent inspection.
(Report Details, Part 11, Paragraph 1.b)
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Reactor Coolant Pumps Suction Weldment Linear Indications (RO ('~'j Inspection Reports No. 050-346/74-04, No. 050-346/74-07, No.
050-346/74-10, and IE Inspection Report No. 050-346/75-01)
The inspector was informed that repair work for reactor coolant pump weld No. WJ-2-1 has been completed, and final acceptance of weld radiographs is in progress.
In addition, the licensee informed the inspector that the weld repair procedures have been revised for the remaining three pump welds.
A final report, pursuant to the requirements of 10 CFR Part 50.55(e) for this matter has not been submitted.
This item remains open.
(Report Details, Part II, Paragraph 1)
9.
Class lE Electrical Cable Trays (R0 Inspection Reports No.
050-346/74-02, No. 050-346/74-04, No. 050-346/74-07, and No.
050-346/74-10)
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The licensee is reviewing procedures submitted by Fischbach &
tioo re, Incorporated (F651) and approved with comments by Bechtel Corporation (Bechtel).
These procedures deal with the entire area of cable trays and include grounding, receiving, storage, installation, and inspection.
This matter remains unresolved pending Toledo Edison Company's (TECO's) approval and implementation of the procedures.
IE:III follow-up review will be made during a subsequent inspection,
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Westinghouse Electric Corpjlgation (W) 11igh Prensure Injection m
P mp Motors (R0 Inspection Reports No. 050-346/74-01, No.
O,0-346/74-02, No. 050-346/74-04, No. 050-346/74-07, No.
0. 1-346/74-10, and IE Inspection Report No. 050-346/75-01)
A final report, as required by'the requirements of 10 CFR Part 50.55(e) was received by IE:III office.
The report was dated February 20, 1975, and was reviewed and found to be acceptable.
This matter is considered closed.
11.
Review of Bagwell Coatings, Incorporated (Bagwell) Quality Assurance Manual (R0 Inspection Reports No. 050-346/74-07, No. 050-346/74-10, and IE Inspection Report No. 050-346/75-01)
The inspector was informed by the licensee that they have just received Bagwell's Revised QA manual for review and approval.
This item remains open pending final review and acceptance at the hagwell's QA manual.
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12.
Review of Bagwell's Closcout of Outstanding Items as Listed
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in the TECO Audit of May 21, 1974 (R0 Inspection Reports No.
050-346/74-07 ano No. 050-346/74-10)
This matter remains open pending the inspector's review of Bagwell's corrective action pertaining to these items.
13.
Instrumentation for Handling Piping, Components, Etc., Purchased by Grinnell (R0 Inspection Reports No. 050-346/74-10 and IE Inspection Report No. 050-346/75-01)
The inspector reviewed Grinnell's procedure No. SS1201, Revision E, and found it satisfa-tory.
Ilowever, the instruction to use Form QC FF105A, Field Planner, in conjunction with the above procedure, did not indicate it would be used for piping and piping subassemblies and equipment.
This item remains open.
14.
Incomplete Installed Equipment Reports (IE Inspection Report No. 050-346/75-01)
The inspector reviewed correspondence between Grinnel and the Bechtel Construction Manager (BCM) relative to the use of
" Installed Equipment Reports." The inspector was not furnished a copy of a reply from the BCM answering Crinnell's letter dated March 13, 1973, and approving the use of the referenced "InstalJation
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h Equipment Report Form."
This item remains open.
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15, List of Safety Related Items (IE, Inspection Report No.
050-346/75-01)
The inspector was informed by the licen.:ee that the matter is being reviewed by TECO project management personnel.
This item remains cpen.
16.
Johnson Controls Company - Installation / Fabrication I/F Planner System (IE Inspection Report No. 050-346/75-01)
The licensee informed the IE inspector that, as a result of stop-work order No. 9, issued to Johnson, Bechtel Specifications No. 7749-M-328 and No. 7749-M-329, are being revised.
Subsequently, the Johnson QA manual will include the requirement that Bechtel approve all of Johnson's I/F planners prior to the installation of each Class 1 tubing system.
Pertinent revisions to both the specification and the QA manual will be reviewed during a subsequent inspection.
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Management Interview l
A.
The following persons attended the management interviews at the conclusion of the inspection.
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Toledo Edison Company (TECO)
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E. C. Novak, Cencral Superintendent - Power Engineering and Construction J. D. Lenardson, Quality Assurance Manager
G. W. Eichenauer, Quality Assurance Field Representative E. A. Wilcox, Field Quality Assurance Specialist C. T. Daf t, Quality Assurance Engineer J. Greer, Quality Assurance Engineer Bechtel Corporation (Bechtel)
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H. A. Ablondi, Project Quality Assurance Engineer
C. L. Huston, Field Construction Manager J. D. Heaton, Project Field Quality Control Engineer i
B.
Matters discussed and comments, on the part of management personnel, l
were as follows:
1.
The inspector stated that, since the curreat inspection was being conducted prior to receipt of the licensee's reply ta j
the infractions resulting from the January 23-24, 1975, inspection, j
these items would remain open.
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2.
The inspector stated that many of the outstanding open unrc.;olved
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items could not be closed during the inspection, as corrective action
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had not been taken and additional unresolved items were being generated as a result of the current inspection.
The licensee stated that unresolved items would be given priority attention.
3.
The inspector stated that, during the inspectica, it was noted that Nonconforming Notices and QC P & P packages had been closed out and placed in the storage vault, even though open items were still to be resolved.
He also stated that in-dpeth audit of these packages should be performed to determine the accuracy of the
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contents of the closed packages.
The licensee stated that this matter would be reviewed.
(Report Details, Part Ill, Paragraphs j
3.e and f)
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The inspector stated that, during the previous inspection, the
inspectors had discussed the placement of pipe hangers and i
restraints.
it was established during a TECO audit conducted during February 1975, that hangers had been changed without j
engineering approval.
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The inspector stated that an in-depth aud!t of installed quality g'
related hangers and seismic restraints should be conducted to determine the exact number of hangers that have been changed without engineering approval.
The licensee stated that this would be further discussed with Bechtel engineering personnel.
(Report Details, Part III, Paragraph 4)
5.
The inspector stated that he had reviewed documentation relating to the lif ting of the QA stop-work order for electrical work (terminations).
The documentation reviewed appeared to satisfy the QA requirements needed to be corrected prior to the start of any electrical work.
The stop-work order for instrumentation is still in effect.
(Report Details, Part I, Paragraph 2)
6.
The inspector stated that a review of Drawing J-G16-4, Revision 1, indicated the possible removal of protection from safety related tubing.
This item had been brought to the attention of Bechtel, Gaithersburg, personnel.
The licensee stated that this item would be reviewed with Bechtel engineering.
7.
The inspector stated that it would be appropriate for the licensee to distribute and to explain to all contractors and subcontractors Part 19 of Title 10, Chapter 1, Rules and Regulations.
The licensee indicated that this would be done.
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8.
The inspector requested that the Ecchtel QA representative s_,/
discuss the manner in which the Johnson QA manual would be reviewed before safety related work could be resumed by Johnsen.
The Bechtel QA representative replied that, in reference to Part IV, Section B, of the PQA Interim Report, the Johnson manual would be reviewed in a manner similar to that described in the minutes of meeting, dated February 22, 1975, subject, MCAR and Stop-Work Order No. 9.
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REPORT DETAILS
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Results of Inspection 1.
Reactor Coolant Pumps Suction Weldment Linear Indications lhe inspector reviewed Babcock & Wilcox Company's (B&W) revised Field Construction Procedures, Deviations No. 26-02-27-01 and No. 28-01, i
ton 2.
These procedures are to be used for welding of the remaining three ccolant pump weldments.
The main change from the previous procedures is that, instead of welding in quadrants, the entire weld is to be removed and rewelded as a whole.
The piping is to be held rigid by use of lugs being welded to the ID, The lugs are to be of stainless steel (SS) or buttered with SS, to prevent contamination of the SS cladding.
During the current inspection, work on the three remaining pump welds is being limited until acceptance of WJ-2-1 by TECO.
The inspector raised the question as to the method to be used to record and control interpass temperatures.
He was informed that " Temp Stiks" would be used for controlling interpass temperatures.
The use of recording pyrometers for this item should be considered.
Further review of the weld repair will be conducted during subsequent inspections.
2.
Quality Assurance Audit (TECO)
/j The inspector reviewed a TECO audit of Bechtel site QA/QC activities.
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The audit was performed during the week of February 4-11, 1975.
The audit was conducted to verify the corrective action taken by Bechtel as a result of previous audit conducted during November 1974.
The current audit also covered design document control and additional quality items.
The audit was conducted using TECO's Audit Checklist Form 2181-D.
The deficiencies found were discusscu at an exit interview with Bechtel's management.
Action completion dates for reported audit findings have been assigned.
Further review of TECO's QA/QC audits are to be made during subsequent inspections.
3.
Quality Assurance Stop-Work Order (IE Inspection Report No.
050-346/75-01)
The inspector reviewed the QA requirements that were imposed on Johnson prior to a partial lifting of the stop-work order for electrical work only (terminations) SWO No. 9.
Two areas were required to be corrected prior to work being performed:
Approval of QA manual revisions for the electrical work.
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b.
All AFR's and FIR's, directly affecting the electrical portion of the Johnson QA program, would be resolved.
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The inspecter reviewed the documentation pertaining to the above
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and found it to be in order and properly reviewed and approved.
The
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b REPORT DETAILS Part II I.
.ared By:
F. J. Jablonski 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)
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S. M. Cantor, Engineering Specialist - Gaithersburg J. O. Gray, Lead Instrument Quality Control Engineer G. K. Grover, Senior Electrical Quality Control Engineer V. W. Howard, Instrument Engineering Group Supervisor - Gaithersburg W. C. Lowery, Electriccl Quality. Assurance Engineer S. N. Saba, Electrical Supervisor - Davis-Besse Design - Gaithersburg Fischbach & Moore, Incorporated (F&M)
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s D. M. Moeller, Quality Control Manager
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Johnson Controls Company (Johnson)
C. M. Egasti, Lead Mechanical Engineer W.
S. Morrow, Project Engineer Results of Inspection 1.
Diesel Generators a.
The IE:III inspector reviewed surveillance records regarding the licensee's response to an enforcement matter identified in RO Inspection Report No. 050-346/74-07.
The cover sheet of each Bechtel Field Inspection Report (FIR)
was stamped "salinfactory" and signed by the appropriate Bechtel j
representative.
However, attached data sheets contained j
inconsistent information and were not appropriately signed
and dated.
Also reviewed was the generator manufacturer's generator preservation procedure.
The inspector concluded that, as stated the procedure lacked direction and format.
The licensee does notl have a formal generator storage procedure.
The i
licensee indicated that this m:stter would be reviewed and (,/
compared with motor storage procedures.
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Documents reviewed included:
(1)
Field Inspector's Repcrts dated:
(a) January 15, 1975 (b) February 12, 1975 (c) March 5, 1975 (2)
Bechtel File No. 7749-M-180Q-37-1, Bruce G. M. Diesel, Incorporated, Generator Preservation.
b.
The inspector further reviewed the QC program and procedures verifying that the relays which failed to meet seismic qualifications were not actually a part of the equipment to be used at the Davis-Besse site.
The actual static exciter and associated protective devices were seismically tested and the data documented.
The test results reviewed by the inspector were as follows:
On page 41, Appendix 1, Item 5, in part states that: "up to ten separate electrical contacts within the assembly will be menitored.
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r~'s On page 12 of the report, paragraph one, states, in part that: "All fv')
electrical circuits that were monitored in each unit gave no (
indication of malfunction during the tests.
It is concluded from this that the units would have remained functionally operative if power had been applied.
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The inspector questioned which contacts were monitored and how it was concluded that the equipment would function as designed if, in fact, actual power had not been applied.
These questions were discussed, via telephone, with cognizant Bechtel personnel.
The resui;s of their findings will be reviewed during a subsequent inspection.
Documents reviewed include:
(1)
Transmittal Form 7749-M-180Q-28-1, Section Ill
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Transmittal Form 7749-M-180Q-29-1 i
(3) Tert Report tio. 83 of Job No. 976.00-71, MTS Systems
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Ccrporation Test Research Laboratory l
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The inspector reviewed seismic vibration tests of the emergency c.
('j diesel generator electrical control and relay boards.
The tests performed indicated that three design features were not satisfactory:
the base mounting'was not stiff enough; certain
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relays experienced high acceleration input; and the cabinet doors induced shock to the cabinet itself.
The inspector verified that these discrepancies had been corrected per the recommendations which were included as part of the test report and included:
(1)
Relocation of the protective relays to a lower portion of the panel (2)
Addition of horizontal and vertical panel stiffeners (3)
Installation of additional base mounting hold-down bolts (4)
Installation of additional door latches (5) Modifications to the lockout relay operating circuitry to preclude spurious tripping during emergency operation of the diesel generator.
Documents reviewed included:
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(1) Techanical Specification 7749-E-19Q-3-4 s_
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Drawing 7749-E-39-3-5 (3)
Drawing E-64B-SillC, Revision 2
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REPORT DETAILS Part III
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Prepared By:
K.
R. Naidu i
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Persons Contacted
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The following persons, in addition to individuals listed under the
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Management Interview Section of this report, were contacted during
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I this inspection.
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Bechtel Corporation (Bechtel)
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J. J. Ford, Quality Assurance Engineer R. D. Reineck, Mechanical Field Engineer l
ITT Grinnell Corporation (Grinnell)
J. Duderstadt, Chief, Engineer D. Giguere, Quality Control Manager
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j Lumm-Irsay
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j P. Cameron, Project Superintendent I
D. Steinam, Quality Control Technician Results of Inspection
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General - Emergency Ventilation System, Containment Air Recirculation
System, and Containment Air Cooling Units Lumm-Irsay has been awarded the contract to fabricate and to install
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the ventilation duct work, including the supports for the above
systems.
Bechtel Specification 7749-M-410 covers the scope of this
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contract.
Electric switchgear, including motors and mechanical j
equipment, such as filter units and filter elements associated l
with the above systems, were purchased from other suppliers.
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2.
QA Program Review Selected portions of Lumm-Irsay's QA manual, cc'ering handling and storage, incoming inspection, drawing control, and drawing revision control, were reviewed and were considered to be in order.
3.
Implementation of the QA Program During the inrpection, the inspector verified the implementation i
of the QA program in the following selective areas.
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a.
Welding v
Welding procedures were being used for field welding.'
Welds were visually checked for acceptance by the quality control technician.
b.
Weld Rod Control A procedure was not available for weld rod control.
The inspector was informed that a procedure for weld rod control would be prepared for use.
c.
Drawings Drawings prepared by the contractor relative to layout were submitted to Bechtel for approval.
The contractor enlisted the consulting services of Fluor-Pioneer to design the seismic supports for the duct work.
The inspector was inforned that, whenever field changes were involved, the changes were transmitted to Fluor-Pioneer for re. ew and approval.
Documentation on transmittals were reviewed and found to be in order.
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d.
Painting Specification Technical Specification 7749-M-410, Subsection B, page 3 of
/"'N paragraph 4.1, states, in part:
' The high zine content priner
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shall be approved by the Construction Manager," This requirement
appears to meet the intent of Chaper 6 of the FSAR which commits to the type of zine primers to be used (Table 6-10A, page 6-59a) to restrict the generation of combustible gases and corrosion rate following a LOCA.
An approval by the construction manager or any documentation on the type or zinc primer actually used was not available.
The
'censee stated that he would investigate this matter further and provide necessary documentation.
Followup on this will be conducted during a subsequent inspection.
e.
Review of Noncomformance Reports (NCR's)
The inspector reviewed the quality assurance records on the filter elements which were compiled in "Redoc 357", and it was determined that two NCR's were prematurely closed and that the test data was incomplete.
The package contained NCR No. 376, dated July 17, 1973, for incomplete test reports on charcoal filter elements.
This NCR was closed on July 26, 1973, prior to the receipt of the necessary documentation.
The package also contained NCR No. 399, dated October 3, 1973, for a deficiency in documentation
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for the HEPA filter units and was reported closet' an April 24,
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1973, prior to the receipt of any documentation.
he inspector will review corrective action taken to resolve these two NCR's during a subsequent inspection.
f.
In-depth Audit of Closed QA Records As a result of the above disclosures, the inspector expressed concern that the closed QA records, known as "Redoc" packages, have been considered closed and stored in the vault, under the assumption that they contain NCR's which have been satisfactorily resolved may, in fact, contain unsatisfactorily closed NCR's.
This matter will be reviewed during a subsequent inspection.
g.
Incomplete Test Data During the review of test data documents, the inspector did not find evidence that the " minimum elongation before rupture" test requirements were satisfactorily met, as per Technical Specification 7749-M-404, Section 8.1.1.a.2.
The FSAR, on page 6-41, paragraph 6.2.3.4, Subsection a.3, implies that the filters would meet this requirement.
The licensee stated that he would inquire why data on this requirement was not furnished.
h.
Review of Specification 7749-M-404, Revision _4, During the review of the above specification for test and inspection criteria, the inspector noticed that Section 8.1.1.a.3 stes, in part: "Tha =4"imum tensile strength.
1.25 pounds per
...
inch of water" The inspector requested verification
....
whether the requirement should read " width" instead of " water".
i.
Discrepant Tensile Strength Values (HEPA Filters)
The FSAR, page 6-41, Section 6.2.3.4, Subsection a.2, stipulates that a sample of the filter element would yield a minimum tensile strength of 1.5 pounds per inch of width.
This value is slightly higher than
.25 pounds per width requi cd in the above technical specification.
The licensee's QA engineer stated that he would obtain an evaluation on this matter.
The inspector will review, during a subsequent inspection, the results to determine whether the reduction in the value of tensile strength will degrade the quality of the fi1ters.
j.
Evaluation of Test Data on Filter Elements During the review of the test certificates on the filter elementn, the inspector noted that these elements were tested during 1973.
Ilowever,)several revisions were made to Specification 7749-M-404
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Revison 4, is dated October 31, 1974.
Since the filters were manufactured, tested, and delivered a year earlier than the current revision, the inspector requested that an engineering evaluation be made to determine that the filters would meet the acceptance criteria of current Revision 4.
k.
Quantity of Zinc Within the Containment The inspector determined that there was neither a prccedure nor a requirement in Specification 7/49-M-404 that addressed itself to the final computation of the total installed zinc surface area and volume within containment.
The inspector stated that this computation may be necessary to compare these va]ues and determine whether these data indicate that the quantity may exceed the estimated value of the hydrogen generation rate as detailed on page 6-59, of the FSAR.
4.
Approval on Seismic and Thermal Restraint field Changes During a previous it.apection, conducted on November 20, 21, and 22, 1974, the inspector prepared an "ltem To Be Checked" (ITBC)
on the following snubbers that had been installed.
a.
Snubber 33B-GCB1-H18, Serial No. 836!
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This snubbers was installed according to Sketch 8-132, Revision 1.
gO b.
Snubber 33B-GCB1-H33, Serial No. 8362 This snubber was installed according to Sketch 8-117, Revision 1.
The inspector noted that hangers were beirg installed at 1ccations other than those specified in the sketches, and the sketches were being revised in the field without prior engineering (Bechtcl)
approval.
The inspector requested the licensee to pursue this matter further and to confirm the following:
a.
That sketches were revised in the field to reflect field changes necessitated by obstructions.
b.
Whether these were design changes for which prior engineering approval should have been obtained.
c.
That these installation changes do not invalidate prior seismic calculations.
As a followup on this matter during the current inspection, the inspector reviewed the information obtained by the licensee.
The licensce's OA engineer conducted an in-depth audit on the ins t. illa t i on Oi
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of the above hangers and reported his findings in Audit Finding j
Report 326-5-6, dated February 6, 1975.
According to this report,
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the location of the hanger should not have been changed without prior Bechtel (A-E) engineering approval and is based on a Bechtal
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Interoffice Memoranda (IDM) dated Septembe-3, 1972, f rom 11. W.
- Mable to S. R. Stephens.
Corrective ae.61on recommended was to review
the hanger revision program and to 1. corporate the substance of the i
above mentioned memo in the Engineecing Procedures Manual.
The inspector expressed concern that, during installation of the hangers to date, the location of seismic and thermal restraints
may have been changed without prior engineering approval, especially
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in the absence of a specific procedure.
The inspector stated that
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an in-depth audit of the entire hanger installation program will be required to determine whether the location of any additional seismic and thermal restraints have been changed without prior engineering approval and report changes made, if any, to engineering, to enable seismic qualification verifications.
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