IR 05000354/1981005
| ML19350E018 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 05/20/1981 |
| From: | Bateman W, Finkel A, Greenman E, Reynolds S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19350E009 | List: |
| References | |
| 50-354-81-05, 50-354-81-5, 50-355-81-05, 50-355-81-5, NUDOCS 8106160315 | |
| Download: ML19350E018 (13) | |
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v U.S. NUCLEAR REGULATORY COMMISSIOM i
0FFICE OF INSPECTION AND ENFORCEMENT Region I 50-354/81-05 i
Re~ port No. 50.355/81-05 50-354 Docket No. 50-355 CPPR-120
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Category A
' License No. CPPR-121 Priority
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Licensee: Public Service Electric and Gas Company 80 Park Plaza - 17C Newark, New Jersey 07101 x
Facility Name: Hooe Creek Generating Station, Units 1 and 2
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Inspection at: Hancock's Bridge, New Jersey
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Inspection conducted:
Apr" 5 - May 3,1981 Inspectors:
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W. H. Lateman,' Senior Resicent Inspector
' 'chtd. signed 5./$~l/
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A E. Finkel / Reactor Inspector date signed
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. D. Reynolds, Reactor Inspector date signed Approved by:
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E.'G. Greenaq @ Chiff, Reactor Projects cate signed Section 2A, Division of Resident cnd Project Inspecticn i
Inscection Summary:
Unit 1 Insp_ection of April 6 - May 3, 1981 (Report No. 50-354/81-05):
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Areas Inspected: Routine announced inspection by the resident inspector (73 hours8.449074e-4 days <br />0.0203 hours <br />1.207011e-4 weeks <br />2.77765e-5 months <br />)
and two regionally based specialist inspectors (21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />) of work in progress in-
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cluding installation of reactor vessel internals, installaticn of pipe hangers,
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structural steel erection, pipe installation and repair, storage of material and
equipment, concrete placement, structural steel welding, and electr1 cal installations and procedures. The inspectors also made tours of the site, reviewed licensee action on previous inspection findings, evaluated licensee action on construction deficiency reports, and reviewed vendor inspection records and results involving large bore pipe spools and steel embedments.
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Region I Form 12 (Rev. April 77)
181063603l5
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Inspection Sumary
Results_: Of the thirteen areas inspected, no items of noncompliance were iantified
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in twelve areas and one item of noncompliance was identified in one area.
(Failure
of vendor inspecticn to identify weld deficiencies as discussed in paragraph 3.)
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Unit ___2 Inspection of April 6 - May 3, _1981 (Reg _ ort No. 50-355/81-05):
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Areas Inspected: Reatine announced inspection by the resident inspector (16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />)
and two regionally based specialist inspectors (14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />) of work in prog ess in-i'
cluding containment erection, drywell repair activities, concrete placement, and equipment storage.. The inspectors also made site tours, reviewed licensee action on previous inspection findings, and reviewed electrical installation procedures.
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Res_ul t_s:
~0f the six anas inspected, no items of noncompliance were identified
in five areas and one item of noncompliance was identified in one area.
( Failure
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T of vendor inspection to identify weld deficiencies as discussed in paragraph 3. )
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Persons Contacted
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Public Service Electric and Gas Company (PSE&G1
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A. Barnabei, Site QA Engineer A. E. Giardino, Project QA Engineer P. Kudless, Project Construction Manager G. Owen, Principal Construction Engineer Bechtei Power Corporation (Bechtell
3. Bain, Lead Field Welding Engineer P.. Hanks, Project QC Engineer
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M. Henry, Project Field Engineer
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O. Long, Project Superintendent G. ' Moulten,. Project QA Engineer J. Serafin, Assistant Project Field Engineer
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D. Stover, Project Superintendent - Contract Administration Pittsburgh - Des Moines Steel Comcanv_(PCM)
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D. Davis, Eastern Division QA Manager M. Stiger, Site QA Manager Schnei_ der, Inc.
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G. Davidson, Construction Superintendent G. Falk, Site QA Manager J. Rush, Corporate QA Manager
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2.
_ Site _ Tour
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Routine tours of the site were mad' to observe the status of work and con-struction activities in progress. The inspector noted the presence of and l
interviewed QC and construction personnel. Work items were examined for
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obvious defects or noncompliance with regulatcry requirements or license conditions. Areas observed included:
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i Unit 1:
Installation of strain gauges and thermocouples on inside surface
of drywell, storage and maintenance of material and equipment, structural
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steel erection, concrete preplacement and placement activities, and pipe
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handling, fitup, welding, and weld repairing.
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. Unit 2:
Equipment storage, drywell repair activities, concrete placement, i
containment erection, structural steel erection, and mechanical splicing of rebar.
No items of noncompliance were identified.
.3.
Safety Related Structures (Welding) - Unf t 1_
Installation of pipe whip restraint embedments in the shield wall immediately surrounding the drywell required modification of the embedments to facilitate
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their installation into sections of the wall that were heavily congested with
rebar and clcsely spaced penetrations. The majority of embeds in this wall
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were Type X.
These Type X embeds are detailed on Bechtel Dwg. C-0852-0, Sheet 2 Rev.1 and were fabricated by ACME Steel Engdneering Co., Inc. per j
their detailed drawing no.197 (Sechtel Vendor Dwg. File No.10855-F-7798-
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305-2F).
Mcdification of these embeds involved removal and relocation of anchor bars and shear bars which were connected to the embed face plate by fillet welds.
During air are gouging operations to remove the old fillet welds, subsurface
porosity was revealed. Additionally, surface porosity was observed. As a
result of these welding defects NCR 1086 was issued to identify and resolve the porosity problem. A partial disposition to NCR 1086 stated, in part,
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that:
... a review of. the AWS 01.1 Code has determined that exposed sur-
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faces of weld exceeding the allowable limits shall be repaired. Therefore, those welds that are surface examined and found acceptable may be used as
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The NRC inspectors objected to this partial disposition based on the fact l
that air arc gouging done to examine for subsurface porosity on two emceds
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had revealed subsurface porosity in areas where there were no indicctions of surface porosity. The NRC expressed their opinion that this type of grets
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subsurface porosity was indicative of welding procedure parameters not
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being controlled, e.g., surface cleanliness not within acceptable limits.
l The CO2' shielded FCAW process, if controlled within procedure rarameters, would result in subsurface quality far in excess of that in evidence. Con-
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sequently, the rational to use a surface examination per AWS D1.1 paragraph
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f 8.15.1 to justify acceptance of a known subsurface problem was not considered sound. The NRC inspector proceeded to measure fillet weld size on embeds
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already installed in position in the shield wall for compliance to drawing
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requirements. This sample inspection revealed that a number of fillet
welds were undersized by up to 1/8" in leg size, one vertical shear bar weld was missing, and many welds were not accessible for surface examination i
either because the welds were covered with excessive amounts of foreign i
matter and rust or were obstructed by rebar and penetrations.
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f In order to perfonn the visual surface examination of all the embed welds as required by NCR 1086, the ACME embeds on site that were not installed or in the process of being modified, were removed off site to the offsite
fab shop in Paulsboro to be cleaned up prior to inspection. This examination
included not only the Type X but also the Type IX, XI, and XII embeds fab-
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ricated by ACNE. The r*sults of this examination were as follows:
Type _
Total Examined _
Total R_ ejected Cause_ for Rejection X
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Surface Porosity, Undersize
fillets i
XI
3 Undersize fillets
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XII
1 Undersize fillets
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Based on the results of the visual inspection at Paulsboro it was decided
to perform radiography of embed fillet welds to attempt to establish a cor-(
relation between surface porosity and subsurface porosity. The welds of r
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the first five embeds radiographed indicated that a conclusive correlation
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could not be established between weld surface conditions and subsurf ace
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porosity. As a result, the licensee made a report in accordance with the t
rules of 10 CFR 50.55(e) officially informing the NRC of a potential de-
ficiency involving weld deficiencies of ACME embeds embedded in concrete
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prior to the identificaticn of this problem. Additionaliy, a program was undertaken ensite to remove the embeds from the shield wall (wall was never poured) for complete examination and rework and to initiate a comprehensive
embed inspection program for all ACME embeds, a sample inspection program i
for embeds by other manufacturers, and to repair or fabricate new embeds t
as a function of the results of the comprehensive inspection program.
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is planned, as a result of the comprehensive inspection program, that the worst case embed will be identified. This worst case embed will then be
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destructively tested as part of the effort to address the reportability of
i those embeds already embedded in concrete.
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I The cause of this problem can be traced back to lack of confomance to the
procurement document by ACME Steel. The procurement document required that
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all welding be performed in accordance with the requirements of AWS 01.1.
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This requirement applied to both the welding procedures used and the in-r
spections perfomed. Examination of the embeds onsite resulted in the con-r clusion that AC'E Steel did not confom to the requirements of their approved welding procedure when making a substantial number of the total number of welds and that they did not perfom inspection per the requirements of para-
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i graph 8.15.1 of AWS D1.1.
In addition to the failure of ACME Steel to meet l
their commitments, a breakdown occurred in licensee surveillance inspection
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of ACME Steel. Had tha shop surveillance inspection been effective, the weld defects would have been identified and corrected prior to shipment. The failure of ACE Steel and the licensee surveillance inspection programs to identify and correct the weld defects discussed in this paragraph is an item of noncompliance relative to Criterion VII of Appendix B of 10 CFR 50.
(354/81-05-01;355/81-05-01)
4.
Containment (Structural Steel _ Welding) _ Observation of Work _ Activities - Unit 2
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During an inspection of shop fabricated assemblies in the PDM laydown area, the inspector noted that beam seat assemblies were fabricated with gaps at tee-joints ranging up to 3/16" in the worst case. A review of the PDM drawings for the beam seats indicated that ASE III Subsection NF was the
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applicable design and fabrication code. This code does not address the gap between members joined by a fillet weld in a tee-joint configuration. How-
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ever, the AWS 01.1 Structural Welding Code does address the gap situation and requires for joints connected by fillet welds that the fillet weld size be increased by an amount equal to that amount of the gap greater than 1/16".
t Because the ASME III Code does not address this gap question, it may be
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that the ASME III Ccde assumes no gap.
In any case, the NRC inspector
measured a sample of the beam seat fillet welds and determined that a number
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were undersi:ed because of insufficient leg length and/or insufficient l
throat. Althcugh the amount of undersize in most cases did not exceed t
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1/16", this undersi:e combined with the gap between the pieces joined re-sulted in the question does actual weld strength meet design weld strength requirements. PCM initiated ECAR F-25, dated 4/23/81, to resolve this question. This ECAR identified all the gap and undersize problems that
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were found during an inspection of all the Unit 2 beam seats.
The acceptability of the gaps in the beam seat tee-joints combined with undersized fillet welds is unresolved pending licensee determination that
- i the strength of the as-welded tee-joints meet or exceed the design strength t
requirements. (355/81-05-02)
5.
Licensee Action on Previous Insoection Findinas_
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(Closed) Noncompliance (354/79-04-01):
Failure of Dravo to document per-fonnance of Code required nondestructive examination of weld buildups.
The regionally based inspector reviewed the Bechtel documentation associated with pipe spoel piece weld joint buildups. The review included typical Class 3 piping class sheets, e.g., Bechtel drawing 10855-P-0500, Rev. 6 sheet 42 of 86 for Class HBB piping (which calls for SA-155 grade KC70 Class 1 pipe) and Rev. 7 sheet 43 of 86 for Class HBC piping (which calls
for SA-155 grade KC70 Class 2 piping). Typical Dravo NPP-1 forms and drawings were reviewed, e.g., order E3035, drawing 10981-EIA-074-502 Serial
17148 dated 11/7/79. The Dravo NPP-1 form included the QC and A Data Sheets. The review also consisted of a re-review of paragraphs ND-4214, ND-4130, and ND-2560 of ASME Section III, SA-155 and SA-655 of ASME Section II, and proposed Code Case N-292 (N-80-52). A meeting was held with represen-i tatives of Dravo Corporation at their request to present a position on weld j
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buildup. Review of all data by the NRC indicates that it is the intention of the ASE Code to consider weld buildup as a repair and to require as _a minimum the level of NDE required for the circumferential weld joint.
The NRC resident and regionally based inspectors have reviewed the Bechtel typical response to the classification of the buildup as a repair, as shown on NCR 891 and the specific response to 79-04-01, as shown in the licensee's letter to the NRC dated 4/1/81. The response indicated by the licensee is considered to be acceptable.
(Closed) Nancompliance (354/80-07-02; 355/80-07-01):
Failure to use a
qualified weld procedure to weld beam seat support brackets to embedded plates. Amendment 2 to Weld Procedure Specification (WPS) P1-A-Lh added the groove geometry that was not.prequalified and included the Procedure Qualification Record (PQR) 687 for this geometry. Acditionally, meetings were held en site between the NRC inspector and contractors / subcontractors perfoming safety related welding to ensure the inspector that all future welding will be acccmplished using qualified procedures. The results of the two meetings with POM, GEI&SE, and Schneider, Inc. illustrated:
(1) For ASME welding the ASPE ce>.e requires a fitup signoff prior
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to welding. This fitup signoff requires that the joint gecmetry be verified to be in accordance with a qualified procedure.
(2) For AWS D1.1 welding a fitup signoff similar to that for ASME has been instituted to assure qualified procedures are employed for each joint geometry encountered.
As a result of these meetings, the inspector is satisfied that proper controls exist to ensure that all welding is accomplished using qualified procedures.
Implementation of these controls will continue to be inspectet.
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As new organizations start safety related welding activities on the Hope Creek project, it is incumbent upon the licensee to verify that all welding be
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accomplished using ' qualified procedures.
(Closed) Noncompliance (354/80-16-02):
Failure to comply with housekeeping requirements to ensure piping internal cleanliness. Response letter from T. J. Martin (PSE&G) to Boyce H. Grier (NRC) dated 1/5/81 stated that the i
Schneider, Inc. (SI) housekeeping procedure has been upgraded and weekly
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surveillance inspection has been reinstated. This response letter was written with the knowledge of a third noncompliance in the area of piping internal cleanliness that was identified in NRC Inspection Report 80-21
(354/80-21-01) and, therefore, responds accordingly. A management meeting as conducted en February 5,1981 as documented by NRC Insagetion Report 81-03 to, in part, discuss this piping internal cleanliness problem. As a result of that meeting, licensee action to correct the SI piping internal cleanliness problem has been effective.
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-(Closed) Noncompliance (354/80-16-03):
Failure of Bechtel and PDM sur-veillance programs to identify serious installation errors and recurrent -
SI piping internal cleanliness problem. PDM, as a result of this non-l compliance, assigned a QC inspector specifically to monitor SI activities.
Bechtel revised Section IX of the Construction Quality Control Manual to require that additional action be taken when a contractor's performance repeatedly fails to meet requirements and also increased contractor /sub-contractor surveillance inspection. The increased surveillance inspection by both PDM and Bechtel has been effective in ensuring SI's activities are performed in accordance with contract requirements.
(Closed) Nonccmpliance(354/80-20-01): Failure to follow project pro-cedures resulted in an unqualified QC inspector inspecting concrete f
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activities. PSE&G reviewed 24,700 inspections performed during 1980 and found two individuals who performed inspections without documented class-roem training in one specific inspecticn procedure. This review indicates
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that a generic problem dces not exist regarding the use of unqualified in-spection personnel. Training sessions were conducted for all QC supervisors stressing the importance of using certified QC engineers for all inspections.
i Additionally, a QC adninistrative directive was issued by Bechtel to all OC supervisors instructing them to maintain a log on each QC engineer under their direction documenting the status of training received. The actions taken are considered sufficient to ensure that a generic problem does not exist and to ensure future p 'oblems are avoided.
It shculd be pointed out, however, that Inspection Report 30-20 raised a question regarding what is an acceptable experience base for an inspector and that a meeting was held
ensite 2/24/81 to discuss this issue (see NRC Inspection Report 81-02). The results of that meeting were not conclusive, consequently, continted NRC inspection into the area of personnel qualification will continue.
t (0 pen) Unresolved Item (354/80-15-02): Connection of cable trays to supports
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shall be per tray manufacturer's detail. Bolts shall be installed snug tight using full effort of a man with an ordinary wrench.
This definition was not adequate to meet the seismic requirement for this type of installation. The licensee changed drawing No. E-1406-0 paragraph 3.38.1 to read:
"The design bolt torque shall be at least 50 ft-lbs for 1/2" diameter bolts and 19 ft-lbs for 3/8" diameter bolts." During this inspection, the i.7spector witnessed the re-torquing of safety-related installations. The tast is expected to be completed in approximately 45 days. This item will remain unresolved until the above task has been completed and all installed safety-related raceway installations have been verified.
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(0 pen) Unresolved Item'(354/80-15-03): Unsupported length of tray section, measuring from a modified hinge, exceeded the qualification design require-ment of 2 feet, 6 inches. The engineering evaluation indicated that the maximum overhang without requiring a seismic support is 4 feet. Specification E-1406 paragraph 3.25, revision 8 was changed to read:
" Maximum space be-tween supports will be 8'-0" for Seismic Category 1 Cable Tray Supports and v
9'-0" for the others.. Maximum overhang 2'-6" unless noted otherwise on the i
design layout drawing.
I The verification of-the installed safety related tray supports has not been completed by the licensee during this inspection. This item will remain open until the verification of the installed trays has been ccepleted.
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Rev_iew of Nonmutine Events Reoorted by the Licensee A.
By letter dated April 5,1981, the licensee reported a significant
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deficiency in accordance with the requirements of 10 CFR 50.55(e) in-
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volving distort. ion of a portion of the Unit 2 drywell that occurred as the result of a concrete placement underneath the drywell. NRC Inspection Report 81-04 discussed the specific details of this event. Activities
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since the last inspecticn report have involved ultrasonic examination of a portion of the weld connecting the outer support skirt to the dry-l well, MT of portions of this same weld, anu removal of the upper and
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lower drywell gussets that were considered to be within the boundaries
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of the final cut that will recove the affected portion of the drywell steel plate. The boundaries of the final cut hive been establisned as
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being 8'-5" wide between the azimuths of 50 ant 660 starting at approxi-mately 8" out from the inner support skirt. Replacement material has been located, however, it is 1" thick compared to the original material thickness of 7/8". The results of the NDE were acceptable, i.e., no
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unacceptable indications were identified. Additional concrete removal-t
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from under the drywell in the area adjacent to the bulges is being sccomplished to facilitate ease of installation of the replacement
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section.
Work activity to resolve this problem is continuing satisfactorily.
(355/81-00-01)
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B.
By letter dated September 2,1980, the licensee reported a potential
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significant deficiency in accordance with the requirements of 10 CFR i
50.55(e) involving possible qualification problems with the epoxy surfacer system used to coat the reactor vessel concrete pedestal and t
concrete floor located inside the Unit i drywell. By letter dated t
April 15, 1981, the licensee submitted a final report.on this issue l
stating that the deficiency was determined to be reportable because the
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qualification data submitted by Con / Chem, the material supplier, was
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falsified:
the actual Oak Ridge National Laboratory test data returned t
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to Con / Chem reported that the surface'? systen failed the LOCA environment tests, however, the actual test results were falsified by Con / Chem and sent to Bechtel as part of the material qualification package indicating that the coating system had passed the tests. Results of the actual test irdicated that the epoxy coating would fail and peel off during a LOCA and, therefore, could potentially plug or partially plug suctions to safety related pumps thus adversely affecting design LOCA response performance.
Corrective action taken by the licensee included removal of the Con / Chem material from all concrete surfaces inside the drywell. These surfaces will be recoated at a later date. Future suppliers of qualified coating systems will be required to have independent lab test reports submitted directly to Sechtel by the testing laboratory. Additionally, Bechtel performed a spectrographic analysis of the surfacer materials used and
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confirmed that lower grade materials were not used as sut.stitutes for the advertised materials.
The action taken to resolve this problem is considered responsive and complete and, therefore, this item is closed.
(354/80-00-03; 355/80-00-03)
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Reactor Ves_sel Internals - Observation _ of Wo_rk and Work Activities - Unit 1
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The resident inspector and a regionally based inspector observed the continuing activities associated with the welding of the jet pump adapters to the shroud support plate. The welding techniques, cleanliness, and limited access controls
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- discussed in NRC Inspection Report 81-04 were again observed for compliance with established procedures. The inspectors observed SMAW welding in procress and questioned craft personnel as to problems associated with this activity.
Welding on all but two of the joints was in the intennediate or completed stage.
Two of the joints had not been fitted up for root pass welding.
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There appear to be no problems associated with this installation activity.
No items of none 1pliance were identified.
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8.
Electrical (Cemoonents/ Systems) Implementing Procedure Review - Units 1 and 2 The inspector reviewed the following "Q" procedures to determine whether these documents conformed to the requirements described in the facility SAR and Quality Assurance programs.
Installation of Electric Mctors - SWP/P-E-26, Revisien 1 dated
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February 10, 1981 Installation of Electric Control Scards, Switchgear, Motor Control i
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Centers, Load Centers, and Distribution Panels - SWP/P-E-33, Revision 4 dated February 10, 1981
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Installation Cards - SWP/P-E-105, Revision 4 dated September 26, 1979,
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E-2.0 Installation of Class IE Raceway, Supports, and Bracing, Revision 8
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dated June 17, 1980
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E-6.0 Installatien of Electrical Equipment, Revision 3 dated March 13,
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1980, E-6.7.1 Installation of Batteries and Racks; and,
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E-1406 Racewa'y Notes, Symbols, and Details.
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The present documents described above do reflect the requirements described (
in the facility SAR and QA programs at this time. The inspector noted that
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the documents referenced have changes in engineering being reviewed at this
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time and review of these documents will be required during later NRC in-t
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No items of nonccmpliance were identified.
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9.
Electrical (Components / Systems) Work _ Observations - Unit 1 The inspector examined work performance, partially completed work and com-plated work pertaining to safety related cable trays to detennine whether the requirements of applicable specifications, work procedures, drawings,
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and instructions have been m'rt.
The inspector observed the re-torquing of bolted tray connections per drawing E-1406 paragraph 3.38.1.
New tray installation was not in progress during this inspection period. The inspector examined the inplace storage of MCC 108242 in the Reacter Building East Corridor 4201, Elevation 77' of Unit 1.
The MCC was partially welded in piece with no work in progress at the time of observation. The MCC was covered and protected as required by specifications. The inspector reviewed the QCIR for this item and deter-
-mined that it was in accordance with QC requirements.
No items of noncompliance were identified.
10.
Safety Related Pipe Support and Restraint __ Systems _- Unit _1
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The inspector made a preliminary review of ASME III Subsection NF hangers /
supports installed to date. The review was considered preliminary because only a small percentage of these hangers are installed at this time and none have received a final GC inspection.
In particular, the following attributes were inspected:
Attachment of hanger to building steel
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Blocks installed in spring hangers
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Hot and cold indicators on spring hangers
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Completeness of bolting including full thread engagement of nuts and
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locking devices on nuts Application of Code st mp on each hanger
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Interferences with other piping or equipment
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Shear lugs present where required
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The results of this preliminary inspection indicated that a Code stamp was missing on supports 1-p-BC-044-H10 and 1-p-BC-049-H23 and in some cases nuts were not fully threaded and locking devices wcre not installed on nuts. These discrepancies were pointed out to the licensee. The licensee subsequently stated thut'Bechtel's system had previously identified the missing Code stamps and appropriate corrective action was in progress.
i No items of noncompliance were identified.
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11.
Unres_olved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or items of noncompliance.
An unresolved item identified during the inspection is discussed in paragraph 4.
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12.
Exit Interview The inspectors met with licensee and contractor personnel at periodic intervals ciuring this inspection report period. At these times the inspectors sumart:ed the scope and findings of their inspection activities.
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