IR 05000352/1980012
| ML19339C756 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/26/1980 |
| From: | Chaudhary S, Jernigan E, Mattia J, Mccabe E, Mcgaughy R, Reynolds S, Walton G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19339C741 | List: |
| References | |
| 50-352-80-12, 50-353-80-10, NUDOCS 8011190329 | |
| Download: ML19339C756 (22) | |
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U. S. NUCLEAR REGULATORY CCMiISSION OFFICE CF INSPECTION AND ENFORCEMENT Region I 50-352/80-12 Report No. 50-353/80-10 50-352 Docket No. 50-353 CPPR-106 Category A
License No. CPPR-107 Priority
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Licensee:
Philadelohia Electric Ccmoany 2301 Market Street Philadelohia, Pa.19101 Facility Name:
Limerick Generatino Station, Units 1 & 2 Inspection at:
Limerick, Pa.
Inspection conducted: June 16-27, 1980 Inspectors:
.bh bb' l,II8 O J. C. Mattia, Senior Resident Inspector date signed Af < /L lhs.
l'1. 14' T o G. Walton, Reactor Inspector d' ate / signed
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%k OW hwWth, [ Ob
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c U. Reynolds, Rd actor Inspector c. ate signed'
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Of) chi 3 l & b E. Jernigan, eactor Inspector dat'J sis"' '
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hkauM<.uctJ- -
he,enh20,f9SO S. Chaudhary, Reactor Inspector date signed b Nl}l&y Mt N.}?fD Approved by:
R.W. McGaugny4Aftef Projects opyt signeo'
Section, React & Construction and Engineering Support Branch 8011190
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Insoection Summary:
Insoection on June 16 - 27, 1980 (Recort Nos. 50-352/80-12)
Areas Inspected: Routine, unannounced inspection by regional based inspectors and tne resident inspector of work activities and records relative to:
safety related pipe erection and storage activities; electrical cable termination and testing; licensee and A/E QA audits of site activities; reactor vessel internal installation activities; review of heating, ventilating and air conditioning subcontractor's activities; NRC independent measurements; review of contractor's control of design changes and as-built drawings; and control red system activities.
The inspection involved 208 inspector hours by the regional based inspectors and the resident inspector.
Results: Of the nina areas inspected, no items of nonccmpliance were identified in six areas; six apparent items of noncompliance were identified in three areas.
(Deficiencies:
-- failure to properly qualify an heating, ventilating and air conditioning (HVAC) QC inspector -- para.19a; failure to maintain the proper setting of electrode storage oven and having inaccura N thermemeters -- para. ISb; failure to folicw procedures for field construction drawings (ZC) -- para.16.a; failure of the HVAC subcontractor to follow his QA program audit requirements --
para. 19b. infractions: failure of supplier to record and insoect weld repair to coped' area of structural beam -- para.15; failure of HVAC subcontractor to follow design drawings requirements for installation of duct support inside containment --
para. 18. )
Unit 2 Insoection on June 16 - 27, 1980 (Recort No. 50-353/80-10)
Areas Insoected:
Routine, unanncunced inspection by regional based inspectors and tne resident inspector of work activities and records relative to:
pipe storage, electrical cable termination testing and licensee and contractor QA audits of site activities. The inspectors also perfonned plant tours. The inspection involved 60 inspector hours by the regional based inspectors and the resident inspector.
Results:
No items of nonccmpliance were identified.
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OETAILS 1.
Persons Contacted
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Philadelohia Electric Ccmoany
- Y. Boyer, Senior Vice President
- J. Clarey, Construction Project Manager
- 0. Clohecy, QA Engineer
- J. Conrad, Technical Assistant
- J. Corcoran, Field QA Branch Head
- 0. DiPaolo, QA Engineer J. Fedick, Construction Engineer
- F. Gloeckler, QA Engineer
- H. Walters, QA Manager Sechtel Power Corocration
- T. Altum, Supervisor Field Weld Engineer
- A. Arch, Assistant Project Field Engineer
- B. Dragon, QA Engineer
- T. Fallon, Assistant Projsct Field QC Engineer
- R. Faust, Subcontracts Engineer
- H. Foster, Project Field QC Engineer
- R. French, Field Contract Administrator
- M. Held, QC Engineer
- J. Honer, Subcontracts Engineer
- M. Iyer, Resident Project Engineer A. Jackim, QC Engineer
- G. Kelly, QA Engineer
- E. Klassin, Project QA Engineer
- R. Leingang, Assistant Project Field Engineer
- J. Reiney, Project Construction Manager
- M. Tokolics, QA Engineer
- A. Weedman, Project Field Engineer
- R. Yancy, Subcontracts Engineer
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Schneider, Inc.
H. Kilmartin, Division Manager L. Tsaggaris, Corporate Quality Assurance Manger
- J. Archer, Project Manager
- T. Lewis, QC Supervispr J. Hershberger, Project Engineer General Electric Co. (NESG & I & SE)
F. Eaton, QA Manager (I&SE)
W.Lynn,SiteManager(I&SE-Electrical)
R. Manl, Field Engineer (I&SE-Electrical)
- E. McArdle, Site Manager (I&SE-Mechanical)
- W. Neal, Resident Site Manager (NE3G)
L. Piutti, QA Representative (NE3G)
J. Smith, QA Specialist (I&SE)
E. Urick, QA Specialist (I&SE)
Reactor Controls, Inc.
- K. Aspinwall, QC Supervisor
- L. Eddinger, QC Supervisor
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- 'Jenotes those present at ex.it interview.
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Other Acccmcanying Personnel A. Sassani, NRC, Region 1 2. fgnt Tour - Units 1 & 2 The inspector observed work activities in progress, completed work and the plant status in several areas of the plant during a general inspection of the plant. The inspector examined work for any obvious defects or nonccmpliance with regulatory requirements or license conditions.
Particular note was taken of presence of quality control, evidence such as inspection records, material identificatior., housekeeping cod equipment preservation.
The inspectors interviewed, when appropriata, crai't personnel, craft supervision and QC personnel in the work a.eas.
No items of noncompliance were identified.
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3.
Review and Inspection of Reactor Core Internals Reoairs (lJnit 1)
Reactor Controls Inc. (RCI) is conducting specific repairs in accordance with GE F00R's to rectify workmanship and quality problems in the Sun Shipbuilding fabrication of the core internals. This item was previously discussed in Inspection Report 352/80-07.
a.
The inspector reviewed applicable RCI welding procedure specifications (WPS), welding procedure qualification records (PQR), weld data sheets (WDS), process requirement sheets (PRS), weld filler metal control sheets (FCS) and filler metal certifications for the work in progress.
The inspector also visually inspected the work in progress.
During the review of the applicable documents, it was observed that RCI welding procedure W-8/8-0TS-ll indicated that ER 308 filler metal is specified for GTAW welding of P8 to P8 materials. RCI welding data sheets for the work in progress (e.g. WDS#1 for J/P Instrument Penetration Seal 2850 azimuth) indicate that ER308L filler metal is being issued and used for this welding. This is not an ASME code violation, nor is it a violation of tne GE welding specifications which RCI is required to meet, but it represents a laxity in 411owing specific procedural requirements.
Imediate action was taken by RCI to revise the applicable procedure specification to permit the use of either ER308 or ER308L. This item is unresolved pending(352/80-12-01),
final inclusion of the revised documents in the licensee's i
system b.
During review of a sampling of welding data sheets for work in progress on the reactor core internals repair, it was observed that many of the data s Mets were incompletely filled in by the QC inspector specifically in the preheat and interpass temperature control entry areas. RCI QA Manual paragraph 6.2.1 requires that all criteria on the welding data sheets be addressed in the QC inspection. RCI took imediate action and is precessing an NCR to address this deficiency.
This item is unresolved pending disposition of the NCR (352/80-12-02).
c.
Review of GE Specification 22Aa:02 which RCI is recuired to meet for the subject repair welding indicates in paragraph 9.1.2 (Fillet Weld Size) "where a gap is allowed by (the) installer, the fillet size specified in the installer's documents shall be increased by the amount of the gap allowed". Paragraph 9.3.3 (Fillet and Partial Penentration Welds) indicates that the gap for fillet welds and partial penetration welds shall not exceed the lesser of T or 1/8 inch, where T is the thickness of the thinner member being joined or as otherwise specified. Although the RCI documents control the inspection of the fit-up to meet maximum gap requirements, there is no specific indication that the size of the fillet welds produced meets the requirements of paragraph 9.1.2.
This is an unresolved item, pending satisfactory review and accroval of a system to control the fillet weld size (vs. gap size) and review of the work accomplished to date where fillet welds have been used.(352/80-12-03).
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4.
Review of Bechtel Welding Procedure P8-AT-Ag (Unit 1)
The subject Bechtel welding procedure has general me for making single sided open root for stainless steel butt welds. The procedure was reviewed to assess its effectiveness in "providing sufficient control over Mieat input" to minimize sensitization. The concern over inter-granular stress corrosion cracking of coolant pressure boundary pipirg caused by res,tdual welding stresses, sensitized austenitic materials and the BWR'S'ervice envircnments has been expressed in Reg. Guide 1.44, NUREG -0313, and the GE Welding Specification 22A2284. The GE Alternate Approach to Reg. Guide 1.44 as expressed in Enclosure to BLP-185.5
" Regulatory Guide Status Summary" indicates that the maximem bea' input.
(is restricted) to 110,000 Joules / inch. The Bechtel positf on tc the Reg. Guide indicates "... welding practices are controlled to avoid severe sensitization..." GE Specification 22A2284, Rev. 2, paragraph 4.3 (Heat Input for Austenitic Stainless Steel) indicates "Regardless of the welding process used for joining austenitic steel, the heat input frcm welding shall not exceed 50,000 Joules / inch with a maximum interpass temperature of 3500F." Bechtel's response to 2EA2284 Section 4.3 in GE FDDR HH1-274 dated 1/3/80 states in part, "+.neir (Bechtel) procedures provide sufficient control of heat input consdstent with obtaining sound welds". The GE response to the Bechtel ceme.it on 4.3 provides restrictfons to weaving techniques and states in part tha';, "If the above bead width limitations are met, it is assumed that the heat input limitations are being met".
Bechtel's welding Procedure Specification F8-AT-Ag, Rev. 4, dabd 8/17/79 permits a calculated worst case heat input of 258,800 Joules /ina.
The NRC inspector questioned the justification of welding parameters permitting 258,800 Joules per inch as a process that provides " adequate control over heat input" to meet tr.: GE specification heat input requirements. This item is considered unresolved pending review of licensee's evaluation of the controls far welding stainless steel pipe.
(352/80-12-04).
5.
Review of RCI Welding Procedures for the Multi-functional Succort Fabrication The RCI welding of the multi-functional support is required to conform to GE 22A4202 including paragraphs 9.1.2 and 9.3.3.
RCI has indicated verbally that their design of the support system includes (assumes)
a 1/8" gap in the sizing of fillet welds. The RCI inspection program pennits a 1/8" gap in the fit-up for fillet welds. The fillet weld si:e vs. gap size question is unresolved pending receipt of an engineering verification letter on this subject (352/80-12-05).
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6.
Paview of 'E. I & SE Product Quality Reocrt - 807 (Units 1 & 2)
The NRC inspector reviewed and inspected the mechanical test specimens, metallographic results and radiographs for the composite F43 buttered P8 to F43 buttered P8 qualification for instrument nozzles for the reactor vessel field change. The PQR document has not been accepted by the licensee and is in the state of revision. The proposed revisions were reviewed.
No items of noncompliance were identified.
7.
Review of Uncaoped Outdoor Stainless Steel Pioing Storage (Units 1 & 2)
Unresolved item 50-352,79-02 was written concerning the adequacy of outdcor stcrage of stainless steel piping withcut end caps. The NRC inspecter conducted a random visual inspection of the piping for possible deletericus cerrosion effects from the cutdoor uncapped storage. Special attention was paid to areas adjacent to circumferential welds with ID reinforcement where aquecus corredants would concentrate. No indications of corrosion were noted.
This item will remain unresolved pending review of the licensee.'s flushing procedures for removal of corredants introduced by the cutdcor exposure.
8.
Review of RCI Documents (U' nits 1 & 2)
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The NRC inspector reviewed the following RCI dccuments for compliance with Regulatcry & Code requirements:
MS-1 Rev. 3 dated 1/11/79 MS-4 Rev. 4 dated 2/14/79 MS-2 Rev. 3 dated 1/30-79 MS-13 Rev. O dated 8/15/77 VE-100 Rev. O dated 4/13/78 PE-100 Rev. 2 dated 10/25/78 FL-100 Rev. 1 dated 4/28/78 CP-100 Rev. 2 dated 10/16/79 MS-5 Rev. 3 dated 4/12/79 RE-100 Rev. 1 dated 2/1/79 GWS-1-44 Rev. 2 dated 2/20/80 RCI P0 1754-00 for Sandvik ER308L and ER309 filler metal No items of noncompliance were identified.
9.
Power Generation Comolex Center (PGCC) (Units 1 & 2)
The inspector reviewed the reports attached to the GE letter to PECO (PE-2129). The reports are entitled:
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-- Factory Reinspection of Limerick l cables
-- Factory Reinspection of Limerick 2 cables
-- Limerick 1 & 2 T Mods
-- Reinspecticn of Limerick panels - wiring workmanship
-- Bechtel quality question respenses
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T'e inspector reviewed the results of testing on Unit 1 termination modules (T-Mods) which were tested in accordance with GE document FDI-TNCX (Revision 1). The testing consisted of a 100% inspection of T-Mods fJr damaged wire insulation.
The inspector witnessed the testing of Unit 2 panel connectors which were tested in accordance with GE FDI-TROC (Revision 2). Thc test consisted of a 100% inspection of connector crimps and utilized GE procedure CA-014 (Revision 4).
The inspector witnessed the inspection of and reviewed the results of Unit 1 PGCC cables addressed in NCR-4066 and GE FDDR-HH1-1064. This activity consisted of PGCC cable inspection for damage to jackets, conduc-tors, connectors or pins.
No items of nonc'ompliance were identified.
10. 4160 Volt Tennination to Safeauard Bus (Unit 1)
The inspector witnessed portions of cable tennination of 4160 volt cable from 1B Core Spray Pump to 0124 Safeguard Bus, in Panel 1101All606.
The inspector verified the following:
-- The activity agreed with Wire and Cable Notes and Details, E-1412 (Revision 11) sheets 3.5 & 3.6
-- The activity agreed with Job Rule for Permanent Plant Cable Installation and Termination procedure, 8031-JR-E-10 (Revision 2)
-- The activity agreed with procedure QCI E-5.0 (Revision 4)
-- The data sheet was completed and in accordance i
with the specified requirements.
-- Cable code #H17 agreed with electrical circuit schedule E-1506 No items of noncompliance were i fentified.
11. Soade Lugs on Terminacion Modules (Units 1 & 2)
The GE specification, main control rocm panels, #22A2805AM (Revision 3)
sheets 8 and 9 identifies the solderless ring type tenninaticns to be used in the control room and PGCC terminations to terminal blocks. The inspector identified spade lugs in use on terminals of T-Mods. This is a specificaticn
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deviation that was addressed in the PECO internal letter ct March 8, 1979.
The inspector infonned the licensee that GE did not amend their design specification to allow the use of spade type connectors. During this inspection period GE issued field deviation disposition requests HH1-1087 (Unit 1) and HH2-1088 (Unit 2) to amend their design specifica-tion 22A2805A to allow the use of spade type connectors.
No iteins of noncompliance were identified.
12. Soray Pond P"mp House Erection (Unit 1)
During a general walk-thrcugh inspection of the spray pond pump house area the inspector observed the following:
a.
The retar curtain for the pump house wallswas being installed, b.
The mechanical splices in #14 bars in many places were installed adjacent to each other at the same i
elevation and same face withcut any st:gger.
c.
Some hori: ental #14 bars were attached to structural steel colum " by welding.
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At corners, the rebar ccngestion was such that tne
minimum spacing was not maintained.
To detennine the acceptability and adequacy of above work, the inspector reviewed the following documents and held a discussion with licensee personnel.
a.
Bechtel Specification C-34, Rev.13, Splicing of Reinforcing Steel".
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Bechtel Specification C-36. Rev. 13. " Forming, Placing, Finishing and Curing of Concrete".
c.
ACI-318-71, " Building Code Requirements".
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Drawing C-1146; Rev. 8.
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Drawing C-ll47; Rev. 6.
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Bechtel Specification 8031-Q-List, Rev.12.
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Bechtel correspondence REM-182 and 193.
h.
LGS PSAR, Appendix C, Sec. C.2.6.
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Based on the above review and discussion, the inspector determined that
' presently there is no requirement in the project procedure to stagger splicing in reinferr.ing steel.
The embedded )ortions of structural steel columns in the pump house are not classified safety-related, thus they are outside the scope of full quality assurance. Therefore, the welding of support bars to columns was not controlled, inspected or documented.
The rebar installation inspections are conducted with Bechtel design drawing, which do not show the splice location.
The work was still in process and the final inspection by quality control had not been cone'ucted.
No items of noncompitance were identiff%d.
13. Review of Civil Field Change Reouests (Units 1 & 2)
a.
The inspector reviewed Field Change Requests (FCR) pertaining to civil / structural area. The FCR's were reviewed for conformance to the
' following formal requirements; adequate technical description of the requ,:ted change; formal approval; and controlled dfstrfbutica.
The inspector also verified that completed and closed FCR's are readily available on site for reference. The inspector reviewed the following documents:
PECO QAP, Appendix W covering record management.
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Job Rule G-5, " Design Document Control".
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FCR's C-3500 to C-3599, ccvering the period
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July 1977 to August 1977.
FCR's C-5000 to C-5099, covering the period
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September 1978 to November 1978.
FCR's C-6000 to C-6099, covering the period
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August 1979 to September 1979.
Based on the above document review, personal observations and discussions with licensee and A-E/ constructor personnel, the inspector determined the following:
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1) The FCR's were ccuplete and confomed to the required famat.
2) The FCR's were adequately controlled in distribution, filing and retrievability.
3) All FCR's were approved by project and/or field engineering and contained adequate technical description of requested changes.
However, the inspector noticed that a substantial number of these documents contained corrections by "Wite-out" correcting fluid obliterating the orevious information; also the new infomation entered onto them was not initia11ed and dated by the individual entering such infomation. A few FCR's also contained cut-cuts from drawings pasted on them showing changes and other information.
The inspector questioned the propriety of such practices on controlled pemanent records.
In response to the inspector's question, the licensee and the A/E's Resident Engineer replied that there are no provisions or rules on the project which specifically prohibit these oractices; and they have been using these practices extensively cq this project for a number of years.
This item is unresolved pending further review.
(352/80-12-06; 353/80-10-01)
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-.The inspector noticed that a substantial number of FCR's b.
had been issued for only one specific condition. These FCR's had a note from design engineering indicating that the affected drawings would not be changed or revised to show the requested change.
The inspec*ar determined that it is currently not required that the approved FCR's be even referenced on the affected drawings.
In response to the inspector's concern in this regard, the licensee and the A/E's Resident Engineer indicated that they have initiatei a i
program in April IS80 which will reference all approved FCR's on the affected drawings. Therefore, any changes not incorporated in
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design will be readily traceable and retrievable for review and i
inspection during the plant life. However, the licensee's Quaiity Assurance Plan, Appendix W does not designate FCR's to be a life-time record. The FCR's are designated as a one-year record by the licensee. Therefore, the inspector determined that referencing
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of FCR's on affected drawings does not adequately satisfy the inspec-I tor's concern. A reference of an FCR on any drawing is of no value if the FCR itself will not be available for the life of the plant.
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This item is considered unresolved pending review of licensee's evalu-
atfon.
(352/80-12- 07)
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14 Review of In-Process Rework Notices (Units 1 1 2)
The inspector reviewed the civil / structural in-process rewcrk notices
issued by quality control. The reports were reviewed for format, complete-ness, adequacy of technical details and corrective action. The following documents were reviewed:
SF/ PSP-C-6.4, Project Special Provision Notice, Rev.1
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In-Process Rework Notices:
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C-2027 C-2012 C-1996 C-1921 C-2036 C-20ll C-1992 C-1923 i
C-2020 C-2008 C-1987 C-1929 C-2018 C-2005 C-1915 C-1930 C-2016 C-2004 C-1919 C-1920 In-Process Rework Notice Log
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Based on the above document review and discussions with licensee and A/E personnel, the inspector detennined that the rework notices were properly used as provided in the project procedures. The notices were properly filled, had adequate technical detail describing the problem and'were properly controlled.
No item of noncompliance was identified.
15. Structural Steel Storage Area (Units 1 & 2)
During a general walk through the laydown area for structural iteel, the inspector noticed that a structural beam identified as 80L1-F-5747, C-671-403A had an apparent indication of repair in the coped area on one end. On a closer examination it appeared that during the coping operation,
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the cope was extended beyond the prescribed limit and this excess was repaired by welding. The repair weld also seemed to have an indication.
The licensee initiated an investigation to verify the inspector's observation and to determine the extent of this problem.
The inspector reviewed the following documents to confirm his observa-tions:
Bechtel specific &cion C-43, Rev.14, " Furnishing,
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Detailing, Fabrication and Delivery of Miscellaneous Embedded Steel and Non-Embedded Steel and Furnishing Unfabricated Stock Material".
QCIR-C-43-MRR-62697, dated 3/27/79.
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Industrial Mechanics Specification 425, dated 10/25/79.
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Industrial Mechanics Certificate of Conformance No.
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TMI W.0. # 8141-A AWS D1.1-72, Rev.1-73, Rev. 2-74
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The inspector also witnessed an etch test conducted by the licensee.
At the conclusion of the investigation, the licensee informed the inspector that the cope was in fact repaired by welding, and the weld was not acceptable due to slag inclusion and lack of fusion. Also, there was no indication of this repair on the beam in supplier's docu-mentation package accompanying the material. The inspector also determined that the supplier is recuired to inspect the material 100%
before shipment.
(The licensee has uniquely identified the beam as PECO NCR Tag # N-196.)
Based on the above observation ard inf6rmation, the inspector informed the licensee that failure to exercis sufficient control over the purchased material and services to assure receipt of proper and conforming material on site is an iten of noncompliance contrary to 10 CFR 50, Appendix B, Criterion V.
(352/80-12-08)
16.
Review of Field Precared Drawings (Units 1 & 2)
a.
The ins;ector reviewed the field generated drawings in the civil /
structuial area. The drawings were reviewed for conformance to the requirement of project procedures, timely revisions and control.
The inspec'or reviewed the following procedures and drawings:
Job kele G-5, " Design Document Control"
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Job Rule G-30, "As Built Documents"
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Specificati'n 8031-Q-List, Rey. 12
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Drawings:
ZC-450, Rev. 1, dated:
8-31 -77
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ZC-455, Rev. 1, dated:
8-31-77 ZC-456, Rev. 1, dated:
12-20-74 ZC-457, Rev. 2, dated:
3-6-75 ZC-458, Rev. 1, dated:
3-26-77 ZC-459, Rev. 1, dated:
3-26-77 ZC-660, Rev. O, dated:3 8-31-77 C-602, Rev. 21, dated:
5-15-79
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Based en the review of the above documents and discussion with licensee personnel, the inspector determined as follows:
1) The ZC series drawings are covered by project precedure G-5 as a controlled document.
2) The project procedure G-30 classifies the ZC series i
drawing as an "as-built" document.
3) Bechtel drawing C-602, Rev. 21, note 4 indicates that actual "as-built" locations of construction joints are shown on ZC drawings.
4) The ZC series drawings are not properly controlled, maintained and up-dated by licensee.
5) The licensee indicated that ZC series drawings are not currently intended to be design or "as built" drawings, and are not covered by quality assurance requirements.
6) The procedure JR-G-30 requires that each ZC drawing shall contain a note specifying the ultimate use of the drawing.
If the drawing is not to show as-built conditions, then a note, " Installation shown on this
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drawing is not required to reflect the As-Built condition" must be placed near the title block of the drawing.
However, the inspector determined that the ZC drawings listed above had no ultimate use note near the title block. Drawing ZC-456, Rev.1, dated 12/20/74 does not reflect the as-built location of a construction joint in a wall, and the licensee personnel indicated that they are not concerned about these deficiencies, as they do not consider the drawings as design and/or as-built documents.
The licensee was informed that the failure to follow the requirements of Job Rules G-5 and G-30 and design drawing C-602 is an item of noncompliance contrary to Criterion V of Appendix B, 10 CFR 50.
(352/80-12-09)
b.
During this inspection period the licensee revised the Job Rule G-5 and
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G-30 and design drawing C-602 to delete references to the "ZC" drawings.
The inspector questioned whether this'would hamper the retrievability of records for a specific wall cr slab concrete placement. A seismic Class I wall was chosen by tN inspector at randem. The QC records for this concrete placement were not readily retrievable without the use of nonpermanent recorcs. The licensee was infonned that if the "ZC" drawings are not to be used for as-built records, then their system for readily retrieving records will be reviewed at a subsequent inspection.
This item is considered unresolved.
(352/80-12-10).
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17. Review of Licensee OA Audits & Surveillances (Unit 1 & 2)
The inspector reviewed a random sample of audits, surveillances and finding reports perfomed by the licensee's site QA group to deternine compliance with their QA procedures Q.A.I.-18-ll, Revision 4; Q.A.I.-18-21, Revision 4.
The following documents were reviewed:
Audit Report # G-084 Audit Report # M-188 Finding Report # C-244 Audit Report f G-035 Audit Report # M-214 Audit Report # M-224 Audit Report # M-276 Surveillance Report # M-282 Surveillance Report # M-281 Audit Report # M-231 Audit Report # M-243 Finding Report # C-214 Finding Report f C-225 During the inspection of the above documents, two unresolved items were noted, which are as follows:
a.
The inspector was concerned that two of the licensee's findings (C-214 and C-225) were issued in June of 1979 and have not been closed out. These findings involve the subcontractor that was responsible for the post tensioning the fuelocal girders. The work on fuel pool girders has aeen completed for several months.
Further investigation also indicated that there were several Bechtel quality control exceptions (Nos. 34 th.ough 41, dated 10/10/79 through 1/24/80) that are still outstanding. The inspector reviewed all of these outstanding quality related items and also discussed them with the PECO and Bechtel cognizant engineers.
It is their opinion that the actual work (post tensioning) performed by the subcontractor was satisfactory and the remaining outstanding quality items are to upgrade the quality dccueents to acceptable levels.
Bechtel issued a letter to the subcontractor on May 5, 1980 infoming them that they are withholding $140,000 until all the quality related problems are satisfactorily resolved. The inspector informed the licensee that this item is consicered unresolved, pending review by NRC of the resolution of the quality related problems. (352/80-12-11 and 353/80-1042 ).
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b.
The review of the above PECO documents did not indicate that the PECO field QA group was conducting a post-surveillance or audit conferences with the site subcontractor after the surveillance or audit had uncovered an item requiring corrective action, as required by PECO procedures Q.A.I. 18-11 and Q.A.I. 18-21.
The PECO QA group is conducting what they call a " finding draft for exit meeting".
This meeting is held with all concerned parties and the PECO finding is then discussed in detail prior to issue. This meeting is not documented as to when it was held or who the attendees were. The inspector informed the licensee that this item is considered unresolved pending review by NRC of the revision of the PECO procedures to reflect hcw the post conferences are held.
(352/80-1212 and 353/80-10 03 ).
18. Welding to Primary Containment Liner Plate The inspector noted that the heating, ventilation and air conditioning (HVAC) duct support #11 had improper tack welds at the support flange (Channel MC8 x 18.7) to the containment floor liner plate. The A/E was informed of this. Further investigation by them indicated that the subcon-tractor made unauthorized tack welds.
The Bechtel design drawing C-1411 Detail 10, Rev.1 doesn't require any welding of this HVAC duct support to the liner plate. Bechtel issued a nonconformance report #4207 for these four unauthorized tack welds. The inspector informed the licensee that this unauthorized welding is contrary to Criterien " of Appendix 3 in 10 CFR 50.
(352/80-12 14 l
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19.
Installation of Heating, Ventilating and Air Conditioning Systems (HVAC) - Unit 1 The inspector audited the contractor's (Schneider Inc.) activities for installing the HVAC system in the centainment building. The following areas were audited:
a.
Personnel Qualifications - Quality Control Insoectors Review of Schneider procedure PPM 5.1 Revision 0, Qualification and Certification of Inspection and Test Personnel. This procedure requires that QC inspection personnel receive training and have sufficient experience to perform inspections. The procedure states that it shall be the responsibility of the Corporate Quality Assurance Manager or his designee to certify Quality Control inspectors as Level I, II or III.
The inspector reviewed personnel records for five QC inspectors who had performed inspections on site for Schneider, Inc.
o QC Inspector Level II, certified September 10, 1979 o QC Inspector, Level II, certified April 24, 1980 o QC Inspector, Level II, certified May 5,1980 o QC Supervisor, Level II, certified May 1980 o QC Inspecter. This individual was not properly certified as being qualified. There is a letter on file which states the individual is qualified as of April 24, 1980 based on the following performance:
(1) Read Procedure PPM 5.2 (2) Performed 2 field receipt inspections (3) Oral interview with QC Supervisor The above listed actions are not in compliance with the procedure requirements for certifying QC inspectors. Specifically for performing inspections, the individual must have previcus experienc,e as a Level I.
This requires examinations and certification as a Level I.
For perforning examinations, the individual must be a certified Level II.
Paragraph 4.2.2 of Procedure PPM 5.2 states, " Level II; is an individual who can perform the duties of Level I a7d evaluate and report the results of inspections...." There is no record of this individual ever holding a Level I or Level II qualification in accordance with Procedure PPM 5.2.
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t A review of his previous work experience does not show any previous experience in either Quality Control or nuclear type disciplines
(mechanical, welding, electrical,etc.).
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There are records of receipt inspections performed by this individual, for example, report number CF-075 performed on June 18, 1980.
This is contrary to Appendix B, Criterion V, and Schneider, Inc. procedure PPM 5.1, " Qualification and Certification of Inspection and Test Personnel" in that the individual was performing receipt inspections without certificaticn as required by the above documents.(352/80-12-14)
b.
Weld Rod Storage Oven Temcerature Control The inspector audited the calibration and storage facilities for weld rod evens. This included a review of the " Weld Material Control" procedure PPM 3.8, Revision 5, dated 12/79. This procedure reqsires
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that"Lowhydrogentypecoatedelectrodesandstainlessstgelcovered I
electrodes shall be stored in vented ovens at 2500F to 350 F.
The ovens shall be checked quarterly using a calibrated thermometer and the temperature documented on fonn 3.8.b."
The inspector requested a temperature check of weld rod oven number 1 which contained E7018 electrodes: The following conditions were observed:
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A calibrated thermometer identified at 002 was used and indicated a
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temperature of 3710F, Since this indicated a temperature of 200F over
that allowed, a second calibrated thermemeter 001 was used.
This showed
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a temperature of 2900F which was 810F lower than the 002 reading.
The inspector then requested that the temperature using thermometer 002 be
1 retaken.
The second reading was 332 F, a change of approximately J0op, It appeared that thermometer 001 and 002 were givino erroneous readings.
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A third thermometer 015 was used which showed a 400 F temperature.
This
corresponded to the control setting on the oven.
The QC supervisor i
stated that 015 thermcmeter appeared to be correct.
The inspector stated that this temperature was 50 F over the allowable temperature.
The contractor acknowledged this and took the following corrective
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actions.
(1) Thermometers 001 and 002 were taken out of the calibration program and destroyed.
(2) The oven temperature was reduced to below
350 F.
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The aspector stated that this was in violation of Appendix 3, Criterion V and Schneider procedure PPM 3.8, Revision 5 Weld M&terial Control Procedure in that on June 20, 1980 the temperature of oven number 1 was 40CcF whereas the re!ufrescontroloftemperatureat25CoFto3500F. procedure (3 2/80-12-15)
c.
Procedure Review and Direct Insoection of Succorts and Ductino The inspector audited the following procedures and documents appli-cable to the installation of the HVAC:
o Schneider QA Manual, dated October 28, 1977 o Weld material distributien log o Quality control checklist o Calibration of test equipment o Storage of components o Nonconformance and disposition report o Shop standards book o Occument controls o Weld rod storage and issue The inspector verified conformance with applicable requirements by re-examinations.
This was acccmplished through direct use of micro-meters, weld gages, thickness meters and scales. The following items were examined:
bolt lengths, washer sizes and locations, structural steel dimensions, hole locations, fillet weld lengths, sizes and locations, location and size of slotted holes. The inspector found discrepancies with the slotted holes, but it was later found that PECO Quality Assurance reports M293 and M307 had previously identified the discrepancies. Another questionable area found by the inspector, the " torquing of bolts", was also previously identified by PECO (Quality Assurance reports M286, M264, M311 and M308).
The inspector found that except for those items documented elsewhere in this report, all areas reviewed were acceptabl d.
Review of QA Site Audit Reports The inspector reviewed reports of site audits conducted by the subcontractor's (Schneider Inc.) corporate office QA personnel. This review was performed to determine whether the audit program was being implemented in accordance with requirements delineated in the QA Manual. The inspector's review included reports of audits concucted during the 1978 and 1979 calendar years. The inspector fcur.d that site QA activities controll.ed by each section of the QA Manual had been audited during 1978 and during 1979, with the exception of
" Document Control", (Secti' n 6 of QA Manual).
Reports of audits o
conducted in 1978 of the field implementation of Cecument Control indicated deficiencies that required corrective action. However, reports of audits conducted during 1979 did not include the follow-up of the corrective action of tne previously identified document control deficiencies. Furthermcre, documents reviewed by the inspector did not indicate that the annual audits required by tne QA Manual were performed of Section 6 during 1979.
This is contrary to Appendix B, Criterion V, and Schneider Inc.
Quality Control Manual Section 18, titled, Audits.
(352/80-12-16)
The inspector also noted that a recent recrganization invalidated the Quality Assurance Manual description of the reporting respcnsibilities of the site QA Supervisor. The contractor representative stated that necessary changes are being made to reflect the current organi:ation and assigned responsibilities.
The inspector had no further questions regarding this matter.
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20. Direct Verification Inspection - Unit 1 The inspector performed direct verification inspection on two separate piping systems to verify minimum wall thicknesses. This was acccmplished using an ultrasonic thickness gage, Nortec t;0T 1230.
The welds and 101-11-5 adjacent base materials were verified on piping systems GBC and GBC 101-3. The thickness readings obtained verified that design nimimum wall thickness was obtained.
No items of nonccmpliance were identified.
21. Preservice Insoection Activities - Unit 1 The inspector audited the personnel qualification records for four nondestructive examination inspectors to ascertain compliance with applicable procedures and governing document SNT-TC-1A.
The follcwing records were reviewed:
1st inspector - Qualified Level II in PT, UT & Vis.
2nd inspector - Qualified Level III in LP, UT & MT.
3rd inspector - Qualified Level II in MT, PT & UT.
4th inspector - Certified Level I UT on 8/15/79, Certified Level II PT on 8/15/79.
The inspector questioned the qualifications of the fourth inspector on the following basis: The governing document, SNT-TC-1A, requires a UT Level I to have six months experience plus 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> training before certification to Level I.
It further recogni:es a minimum of three months ex::erience if the individual has additional experience in other NCE disciplines. The NES procedure requires a minimum of three months experience under the direction of a certified Level II before qualifying as a Level I in UT.
To be qualified as a Level II in PT, the procedure requires the candidate to have one month experience before qualifying as a Level I and two months experience as a Level I before qualifying as a Level II.
A review of this individual's experience certification record shews the following:
4/79 - S/79 -- 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> UT training at Spartan School of Aeronautics.
Sixty hours MT/PT training at Scartan School of Aeronautics.
Employed at NES on 8/14/79 and certified as qualified on 8/15/79.
The inspector stated that the experience equirements were not met for this individua.._
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In an interview with the individual involved, the inspector determined that he had only worked in the capacity of an assistant in UT. He has not actually performed any inspections in UT or PT.
The inspector was further advised that the Authorized Nuclear Inspector had questioned this individual's palifications and as a result, the records would be reviewed by the NdS Level III. Corrective actions would be taken where required.
This item is unresolved pending a review of the actions which have been initiated.
(352/80-12-17).
22. Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, items of nonccmpliance, er
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deviations. Unresolved items disclosed during the inspection are dis-cussed in paragraphs 3, 4, 5, 13, 16, 17 and 21.
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23.
Exit Intervfew The inspectors met with licensee representatives (denoted in para.1) at
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the cor.clusion of the inspection on June 27, 1980.
The insoectors sunnarized the purpose and the secpe of the inspection and the findings.
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