IR 05000358/1978017
| ML20147C056 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 09/07/1978 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| Shared Package | |
| ML20064B897 | List: |
| References | |
| NUDOCS 7810110269 | |
| Download: ML20147C056 (2) | |
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4, UNITED STATES
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h f t N UC LE A R REGULATORY COMMISSION C I j REGloN lit j,p,g',/ p i
799 sooseve LT noAo o. U. "f o u u u m u,~o,s -
y SEP 0 71978 Docket No. 50-373 Docket No. 50-374 THIS DOCUMENT CONTAINS Commonwealth Edison Company ATTN:
Mr. Byron Lee, Jr.
P00R QUAUTY PAGES Vice President P. O.
Box 767 Chicago, IL 60690 Gentlemen:
This refers to the investigation conducted by Messrs. J. E. Foster and W. J. Key of this office on April 3-6, 18-21, and May 4-5, 1978, into the quality of reactor components to be utilized at the La Salle Nuclear Power Plant, Units 1 and 2 authorized by NRC Construction Permits No. CPPR-99 and No. CPPR-100.
This investigation was conducted due to concerns expressed by one of our inspectors relative to reactor core internals manufactured by the Sun Shipbuilding and Drydock Company. These concerns applied to several reactor sites, and were related to equipment at the La Salle sites. The enclosed copy of our investigation report identifies the areas examined during the investigation. Within those areas, the in-vestigation consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
No items of noncompliance with NRC requirements were identified during the course of the investigation.
However, it is of some concern that there apparently had been some breakdown of the quality control program of the vendor which had not been detected and corrected previously.
We are aware that General Electric Company has performed a re-inspection of the affected equipment to identify any existing nonconformances, and have no current safety concerns.
In accordance with Section 2.790 of the NRC's " Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed investigation report will be placed in the NRC's Public Document Room, except as follows.
If this report contains information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this letter, to withhold such information from public disclosure. The application must include a full statement of the 1 fr 1@ 11 #2 69 i
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SEP 071978
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Commonwealth Edison-2-Company reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.
We will gladly discuss any questions you have concerning this investigation.
Sincerely, w w.12 /[y g h
' James G. Keppler Director
Enclosure:
IE Investigation Report No. 50-373/78-20 and No. 50-374/78-13
REGION III==
Report No.
50-358/78-17; 50-373/78-20; 50-374/78-13 Docket No.
50-358, 50-373, 50-374 License No. CPPR-88; CPPR-99; CPPR-100 Licensees:
Cincinnati Gas and Electric Company 139 Eas t 4th Street Cincinnati, Ohio 45201 Commonwealth Edison Company P. O. Box 767 Chicago, Illinois 60690 Facilities Mames:
Zimmer Nuclear Power S tation, Unit 1 i
La Salle County Station, Units 1 and 2
Investigation At:
San Jose California, Chester, Pennsylvania, Eimmer 1 site Investigation Conducted:
April 3-6, April 18-21, and May 4-5, 1978
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'b Tf,b7 Inves t igator:
. E. Foster
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Inspector:
W. J. Key
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Reviewed By:
Charles E. Norelius E f 2') f 78 Assistant to the Director N L1tL 'h*f Chie J,
9 / j, D. H. Danie on, Engineering Support Section 2
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i Investigation Summary Investigation on April 3-6, April 18-21, and May 4-5, 1978 (Report No.
50-358/76-17; 50-373/76-20, 50-374/78-13)
Areas Inspected:
Special, announced investigation into the quality of reactor core internals supplied by Sun Shipbuilding and Drydock Company, and the Quality Assurance program of General Elect ric Company; review of pertinent records, inspection of manuf acturing activities, interviews with personnel. The investigation involved 60 inspector-hours onsite by two NRC inspectors.
Results: Of the areas investigated, no items of noncompliance with NRC regulations were identified.
It was of concern that there had apparently been a breakdown in the vendor's quality control program.
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INTRODUCTION Sun Shipbuilding and Drydock Company (Sun), manuf actures nuclear reactor core internal components, under contract to General Electric (CE), for use in Boiling Water Reactors designed by CE.
Core internals supplied i
by Sun include the core plate, shroud, core spray assembly, top guide, steam separator and shroud head. At a particular GE designed reactor facility, all of the preceeding equipment may not have been supplied by Sun.
REASON FOR INVESTICATION
On February 28, 1978, a NRC Region III (RIII) inspector advised the Chief, Reactor Operations and Nuclear Support Branch, by memo (Exhibit I),
of concerns he had relative to reactor core internals supplied by Sun to the Zimmer 1 and La Salle 1 and 2 nuclear power plants. The memo detailed the items which triggered the inspector's concerns, and recommended that a NRC investigation into Sun's quality assurance program be initiated.
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On the basis of this memo, and discussions with the inspector, an investiga-tion into the matter was initiated.
SUMMARY OF FACTS I
The concerns identified by the RIII inspector related both to the, GE overview of the Sun quality assurance program, and the Sun quality j
assurance program as applied to equipment supplied to the Zimmer 1 and La Salle 1 and 2 sites. Specific areas of concern included:
bent pins on the core support plate, tack welds on core spray nozzles, the quality of welds on steam separators, and dye penetrant testing which had apparently been omitted by Sun.
The concerns were directly related to equipment at t he Z imme r 1 s i t e, but applied in part to the La Salle site also as described in a later memo by the inspector (Exhibit II).
Nonconformances related to bent core support plate pins, tack welds on the core spray nozzles, omitted dye penetrant tests, and welds on the steam separator or shroud head assembly had been identified at the Zimmer 1 site previously.
Several core support pins had been found to be bent at the La Salle site, apparently as the result of a shipping accident.
Inspection of other parts of the core internals at the La Salle site had not. been performed.
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During April 3-6, 1978, Rill representatives visited the GE Nuclear Energy Division, San Jose, Galif ornia., Records there indicated that the Sun-supplied core internals for the Zimmer site were manufactured during 1972-1973, and the internals for the La Salle site were manufactured during 1974-1975. ' Documents reviewed indicated that the GE Quality Assurance (QA) program implemented during this time period relied heavily on reviews of documents provided by Sun, but did include some observation of work in progress. The GE field representative assigned to Sun noted a number of deficiencies which were brought to the attention of Sun for correction. A review of reports of nonconf ormances identified during the manufacturing process (Deviation Disposition Requests) indicated that the nonconformances were properly evaluated and tracked for corrective action.
The GE QA program also included a review of all records related to quality, performed after manufacture of the equipment, when the complete
record package was sent to GE from Sun.
The GE document review disclosed a number of deficiencies which required either additional documentation or corrective action.
Correspondence between GE and Sun indicated that the GE document review for the Zimmer internals had disclosed that some dye penetrant tests performed by Sun had been performed prior to heat treatment of the equipment, rather than after heat treatment, as required. The corrective action taken for this was to authorize dye penetrant tests of the affected welds at t he Z imme r s i t e.
GE representatives indicated that cracks and other deficiencies in tack welds on the core spray nozzles had been identified as a generic problem as a result of inspections at the Limerick and Zimmer plants. Utilities having affected plants had been instructed to perform an inspection of the welds and report any defects found to GE in San Jose.
RIII representatives, accompanied by a GE representative, visited the Sun facility during April 18-21, 1978.
At Sun, attention was focused on records pertaining to the Zimmer 1 site.
Records pertaining to welding and inspection of equipment were acceptable according to standards in effect at the time the equipment was manufactured. The format and content of these records would not be corsidered acceptable under current standards. Specific dates when welding was performed or weld inspections were conducted cannot be determined, since inspection details were not recorded.
Documentation for the La Salle plant was found to be in a different format, and contained more detail.
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Sun documents indicate that an inspection of the core support plate was performed, but do not appear to indicate the method of inspection, or the criteria utilized for the inspection.
Sun representatives stated that the core support plate and pins had been shipped in good condi-tions, and miyht have been damaged subsequently.
Since a full onsite inspection of core spray nozzle tack welds at the Zimmer 1 site identified many def ects, an in-depth review of pertinent records was performed.
It was found that the documentation for the tack welds on the core spray nozzles consisted of a single page entry in the permanent record folder which has several anomolies which make the document questionable. The document incorrectly references a drawing, and incorrectly indicates the number of nozzles inspected.
No other records were available to substantiate the information in this inspec-tion report.
In addition, the equipment it refers to had been completed six months prior to the noted date. The report is dated the day some before a GE inspection visit. Discussion with Sun personnel indicated that the date may reflect the date on which the inspection was finished, or the date on which the documentation was produced.
The Sun inspector identified as having performed inspections of the tack welds was interviewed. He stated that he had performed the inspec-
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tions as documented. However, as inspections of these tack welds at the Zimmer and La Salle plants disclosed numerous def ects, including missing welds, it appears that the inspection was not performed.
During a brief tour of Sun's facilities, the RIII representatives observed the following problems:
(1) weld rods were inadequately con-trolled, with welder training and production welding being perf ormed in the same general area, (2) open containers of low hydrogen and stainless steel electrodes were observed in the production area, (3) tools contain-ing lead were present and apparently in use, (4) welding defects dis-closed by dye penetrant were being repaired without removal of the dye penetrant materials. These observed deficiencies were brought to the attention of GE and Sun representatives.
A visit was made to the Zimmer 1 site on May 4 and 5,1978, to obtain j
additional information on the bent core support plate pins and perform a general inspection of the core internals.
It was found that the core support plate pins were bent on the order of 15-20 thousandths of an inch, which would not be obvious during visual inspection. No informa-tion as to the cause of the pins being bent could be developed.
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GE dete rmined that an inspection of core components supplied by Sun should be conducted at each affected reactor site. To insure that the inspections were conducted using the same criteria, a GE team visited each site and performed the inspection.
Field Deviation Disposition
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Reports (FDDRs) reflecting any observed deficiencies were generated for each site.
FDDRs generated at the Zimmer site as a result of this GE inspection identified welding deficiencies on the shroud, core support plate, shroud head, and top guide.
FDDRs generated at the La Salle site identi-fied similar deficiencies. These deficiencies, as well as those identified previously, will be evaluated and dispositioned by CE.
GE has indicated that, as a result of the identified problems with Sun supplied core components, a reviewed and augmented GE inspection program will be instituted during manufacture of future core components by Sun.
CONCLUSIONS
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No items of noncompliance with NRC regulations were identified during the investigation.
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It is of some concern to the NRC that there apparently was a breakdown in the quality control system of Sun which was not identified by the GE overview.
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A Sun inspection of tack welds on core spray nozzles for the Zimmer and La Salle sites was apparently not performed.
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No conclusive evidence could be developed to indicate the cause for bent pins on the core support plate for the Zimmer site.
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GE's voluntary action, in the form of a complete inspection of all Sun-supplied components, was considered appropriate.
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DETAILS Personnel Contacted General Electric Company (CE)
L. L. Aiello, Quality Control Representative (Zimmer)
T. E. Bloom, Resident Site Manager (Zimmer)
J. Barnard, Plant Quality Assurance Manager A. Breed, Manager, Quality Assurance Section C. R. Chavarria, Quality Control Representative W. C. Cohn, Manager Quality Control Engineering J. Murray, Manager, Reliability Engineering J. K. Powledge, Manager, Quality Assurance Engineered Equipment H. T. Thomas, Vendor Quality Control D. York, Quality Control Engineer Sun Shipbuilding and Drydock Company (Sun)
M. Lubragge, Quality Assurance Engineer B. Taylor, Quality Assurance Engineer R. Tompkins, Quality Assurance Auditor Cincinnati Gas and Electric Company B. K. Culver, Project Manager J. R. Schott, Station Superintendent W. W. Schwiers, Principal Quality Assurance and Safety Engineer R. L. Wood, Quality Assurance Engineer Reactor Controls J. O'Connor, Assistant Site Manager R. L. Kannen, Quality Control B. Mayes, Individuals Individual
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Scope This investigation focused on the specific concerns identified by a Region III inspector relative to core internals manufactured by Sun Shipbuilding and Drydock Company for use in the Zimmer I and La Salle 1 and 2 nuclear power plants. Emphasis was placed on nonconformances found in the core internals for the Zimmer plant. The quality assurance and quality control programs of the vendor and of GE were also reviewed during the investigation, but only as they relate to core internals manuf actured by Sun Shipbuilding with emphasis on the program utilized during the manufacture of core internals for the Zimmer plant.
Discussion with RIII Inspection Discussions with the RIII inspector who requested the investigation indicated that he had visited the Zimmer and La Salle sites, and had become aware that deficiencies had been identified on the core internals j
for both sites. These deficiencies pertained to bent pins on the core support plate, nonconforming tack welds on the core spray nozzles, dye penetrant testing which was being pertormed at the site (which he believed was omitted at the manufacturer's shop), and the quality of welds on the steam separator / shroud head assembly. The inspector acknowledged that these problems had been properly identified, and would be corrected
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before operation of the reactors, but he questioned why the problems had not been identified prior to delivery of the core internals. He also acknowledged that his concerns were primarily related to the core internals the internals of the La Salle site had not been of the Zimmer site, as available for inspection.
The inspector indicated that he was concerned that the GE Product QC Checklist appeared to indicate that the equipment had been inspected and found to be acceptable, and yet several defects had later been identified. He indicated that he felt that this brought the quality control programs of both the vendor and of GE into question.
A copy of the GE Product QC Check'.ist for the Zimmer internals (with the exception of the top guide which had a separate checklist) was discussed with the RIII inspector, focusing on the areas of his concern.
He indicated that he felt the GE QC checklist indicated that it was mostly a " paper review", with very little observation of work in progress or independent verification of tests performed.
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t Visit to GE, San Jose During April 3-6, 1978, RIII representatives visited the CE Nuclear Energy Division offices in San Jose, California.
Concerns expressed by the RIII inspector were discussed with GE personnel, and documents related to core internals manufactured by Sun for the Zimmer and La Salle sites were reviewed, with emphasis on those records relating to the Zimmer site. Documents reviewed included:
weld maps, certificates of inspection, inspection reports, construction drawings, deviation disposition requests, field disposition instructions, audit reports, material reques ts, purchase orders, trip reports (f rom GE field repre-sentative), and correspondence between GE and Sun.
In addition, discus-sions were held with GE personnel regarding the procedures followed in their quality control program at the time the internals for Zimmer and La Salle were being manuf actured.
For the Zimmer plant, this was during 1972-1973, and for La Salle, this was during 1974-1975. GE repre-sentatives indicated that the GE program is basically one of overview of the Quality Control program of the vendor. A GE field representatives might witness a test of a weld, for example, but would not participate in the test.
An audit type of inspection was performed, with a percent-age of specific tests observed, and an audit of a certain percentage of the QC documentation performed. CE representantives indicated that when full documentation for a piece of equipment was completed, the entire package was fully reviewed by a documentation specialist to insure that all tests and certificates were present.
A field audit of tests and documentation was performed by a field represent-ative, GE personnel stated. The field representative was apparently not a resident inspector during the time of the manufacture of Zimmer and La Salle core internals, but a resident inspector is a part of the present GE program. A review of trip reports from the field representative who visited the Sun facility during the period in question indicated that he had performed an acceptable audit, and had been critical of the quality control program implemented by Sun. On several occasions, his observa-tions were the basis for the issue of Deviation Dirposition requests.
A review of the GE Product QC Checklist, comparison of the checklist with documents in the Zimmer file, and discussion with G2 represent-atives did not indicate that the GE field representative had audited the areas where discrepancies were later found. That is, the field represent-ative had not observed the inspection of core support plate pins, tack j
welds on the core spray nozzles, or the welds on the snroud head assembly which were part of the RIII inspector's concerns.
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A review of documentation indicated that dye penetrant examination of core internals which was performed at the Zimmer site had been brought about by the final quality document review at GE, San Jose. GE person-nel indicated that the document reviewer noticed that the dates on dye penetrant tests were prior to heat treatment for certain portions of the shroud. As the specification called for dye penetrant testing of these portions after heat treatment, GE initiated Deviation Disposition Report (DDR) No. 9136, which was used as the basis for issuance of Field Disposi-tion Instruction 35/63000.
Field Disposition Instruction 35/63000 directs personnel at the Zimmer site to perf orm the required dye pene-trant tests. These tests then came to the attention of the Rlll inspector during his visits to the Zimmer site.
A review of DDR No. 9136 indicated that the recommended disposition was to use "as is."
GE did not agree with this disposition, and directed that the dye penetrant tests be performed. DDR No. 9136 indicates that the GE disposition of the DDR is " disapproved", which GE personnel stated meant that GE did not agree with the proposed disposition.
On further discussion, CE representatives indicated that the use of the " disapproved" designation had been an error, as " disapproved" DDR's are not sent to the affected site. This error was corrected by the re-issuance of DDR No. 9136, with the disposition checked as "other".
This had no effer.t on the work being done at the Zimmer site, but provided site personnel with a copy of the initiating DDR.
Discussions with GE representatives and a review of pertinent records indicated that deficiencies in tack welds on the core spray nozzles had been identified during inspections at the Limerick and at Zimmer plants, and was being treated as a generic problem. GE documents indicated that all potentially affected sites had been instructed to perform an inspection of the core spray tack welds and report the results to GE.
A review of the inspection reports for the Limerick and Zimmer plants indicated that the inspections had identified numerous defects in the tack welde, including
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cracks, porosity, under size, melt through, and missing welds. Other inspec-tion reports were not available.
GE personnel indicated that they were not aware of any particular problems with the welds on the shroud head / steam separator assembly.
They indicated that they were aware that a number of the one-half inch pins on the core
support plate plant had been found to be bent out of tolerance, but they
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could not of fer any explanation for this condition.
Visit to Sun Shipbuilding and Drydock Company GE personnel indicated that their records do not include all of the docu-mentation produced during the manufacture of core internals, and that additional documentation would be available.at the Sun manufacturing facility in Chester, PA.
RIII representatives, accompanied by a GE representative, made an announced visit to the Sun facility during April 18-21, 1978.
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Documents related to the manufacture of core internals for the Zimmer and La Salle plants were reviewed, discussions and interviews with Sun personnel were held, and a tour of the Sun reactor internal manufacturing l
facilities was made.
During the document re vi ew, attention was focused on j
those documents pertaining to the core internals for the Zimmer plant.
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i Reco-ds pertaining to the welding and inspection of equipment (weld maps)
were reviewed, and were considered acceptable according to the standards in
effect at the time the equipment was manufactured.
The format and content of these records would not be acceptable under current standards, as the i
specific date when a weld was made or the date on which it was examined cannot be determined (see Exhibit III for sample weld map page). Backup
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information, in the form of Job Package Tickets, indicated when a particular operation was complete, but does not detail the dates of inspection, or the criteria used during the inspections (See Exhibit IV for sample Job Package Ticket).
Discussions with Sun representatives and a review of pertinent documents did core support plate not provide any additional information regarding the bent pine.
Documents at Sun indicated that the pins had been inspected, but no
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documentation was found to indicate that the pins had been inspected for
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angularity.
Sun personnel stated that the pins had been inspected for angularity, using a machinist's square.
Sun personnel further stated that their position was that the core support plate had been properly inspected,
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packaged, and had left the Sun facility in good condition. Sun personnel indicated that the pins could have been bent during shipping, storage, or site handling.
Sun records indicated that several problems related to welding of the steam separator / shroud head had been identified during the manuf acturing process, and had been corrected under Deviation Disposition Reports.
An in-depth review of documentation for the core spray nozzle tack welds was performed. This documentation consisted of a single page entry in the permanent record file (see Exhibit V).
This entry, rather than a weld map, is a statement that the inspection has been performed.
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Correspondence reviewed at the CE, facility in San Jose indicated that the GE document review had disclosed that this documentation was missing, and that GE requested Sun to supply inspec tion documentation.
The document, incorporated as page 163 of the core internals documentalon package by Sun, has several anomolies which make the document questionable.
It incorrectly references drawing 158B566.
This drawing was found to be
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a nozzle drawing, rather than a tack weld drawing or seld map.
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addition, the document is dated approximately six months after the manu-facture of the equipment, and one day prior to the day the CE field representa-tive visited the plant to review the Sud dotumentation package.
Sun personnel
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indicated that they felt that the date may reflect the date on which the inspection was finished, or may just be the date on which the documentation of the inspections was drawn up, based on the inspector's memory of the inspections (pe rformed scme six months previously). The inspection report indicates that 102 nozzles were inspected, when only 100 nozzles we re ins talled (two were provided as spares).
No other records were available to substantiate the information contained in the core spray tack weld inspection document.
The individual noted as having performed the inspection was interviewed by RIII personncl.
He stated that he had performed the inspection of the core spray nozzle tack welds for the Zimmer plant sometime in 1973, although he could not remember specifics of the inspection.
Following a discussion of identified defects in these welds, he indicated that, in retrospect, he might not have done a very good inspection of the tack welds, or may have misinterpreted the inspection criteria. When questioned as to how he had identified the welder who had performed the tack welds, he indicated that the welds had to be made by one of two men on a particular shift, and that he must have checked with their foreman.
Notwithstanding the statement that the inspection was done, recent inspec-tions at the Limerick and Zimmer sites disclosed numerous defects in the core spray nozzle tack welds, including missing welds and misplaced welds.
Inspection at the La Salle site also disclosed missing tack welds.
This inspection was conducted in the same manner as the original inspection was to have been conducted, by performing a visual inspection using 5X magnifi-cation and adequete illumination.
It is not logical to assume that an inspection utilizing 5X magnification would not indicate that a weld was missing, and it appears that the original inspection was not performed.
RIII and GE representatives were taken a brief tour of the Sun reactor internals manufacturing facilities, conducted by Sun personnel.
During the tour, a completed core support plate was observed by the RIII repre-sentatives, and a rough estimate of the angularity of pins on the core plate was made with the use of a machinist's square.
Several pins appeared to be 0.015-0.020 inches from plumb.
Sun representatives indicated that a final check of the pins was yet to be performed.
During the manufacturing facility tour, several quality control problems were observed in relation to equipment currently under manufacture. An area with welding booths and a supply of various types of weld rod was found to be located in the general area where production welding was being performed.
Measures had not been taken to insure that prcduction welders did not use welding materials from the booth area.
Weld rod stored in the booth area consisted of various types, including low hydrogen rod which was in open packages, in poor condition. Weld wire was found lying in several locations,
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a further indication of a lack of weld rod and wire control.
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I A welder was observed under the direction of a quality control inspector, apparently repairing seld defects found through dye penetant examination.
The welder was not removing the dye penetrant ma terial bef ore welding ove r the areas of indication.
This is not in accordance with Sun examination procedures.
A welder was observed working on a shroud head, and he had with him a n.allet with a lead-bearing head.
Sun apparently has no procedure to limit the use of lead-bearing tools during the manuf acture of core internals. This deficiency was discussed with the GE representative, who indicated his belief that there was nothing in the purchase specification which required the control of lead containing tools.
All of the above problems were brought to the attention of the accompanying Sun and GE representatives.
A full inspection was not performed, as it was considered beyond the scope of this investigation Visit to the Zimmer Site
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A visit was made to the Zimmer 1 site during May 4-5, 1978, in an effort to ootain additional information on bent pins on the core support plate, and to observe the core internals.
During the visit, records related to site receipt and inspection of the core internals were reviewed, discussions were held with personnel from Reactor Controls, Incorporated,and the individual who had attempted to straighten some of the core support pins was interviewed.
A review of records indicated that an individual had been observed attempting to straighten some of the half-inch pins on the reactor core support plate using a lead mallet. This was documented on Field Deviation Disposition Request (FDDR) No. KN-1-104, which indicated that lead contamination should be removed, and all core support pins be checked for angularity. The inspection results attached to the FDDR indicated that 84 out of 137 pins were found to be out of tolerance (this inspection was performed using a Sun go-no go gauge).
Reactor Controls, Incorporated documents indicated that the pins originally observed as having been bent were bent on the order of 0.015-0.020 inches from plumb (which would not be observed during a visual inspection).
The individual who had attempted to straighten the pins indicated that the discovery that the pins were bent was accidental.
He stated that a workman toying with a machinist's square had backed it up against a core support pin ind noted that the pin was not straight.
A review of site documents indicated that the core internals had been visually inspected f or evidence of shipping damage when received onsite (November 6, 1973), and had been stored until recently.
It appeared that the inspection had been performed as required in the licensee's commitments, and no items of nocompliance with NRC regulations were identified. No information as to the cause of the pins being bent could be developed.
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A brief visual inspection of the available core internals (the core l
support plate was submerged) indicated minor welding problems on the steam separator assembly, and two areas on the shroud skirt where there seemed to be indications of carbon steel contamination of the stainless steel. The noted problem areas were brought to the licensee's
)
attention. The licensee indicated that a complete inspection of the core internals had not been pe rf ormed.
GE Inspection of Affected Facilities Partially due to the concerns expressed by the NRC, GE initiated an inspection of core components supplied by Sun at each affected reactor site.
Plans for this inspection ef fort were transmitted to the NRC by let ter to Mr. James G. Keppler, Rill Director (see Exhibit VI).
These inspections were performed by a GE inspection team which visited each site, to insure that each inspection as performed utilizing the same inspection criteria. The attachment to the letter to Mr. Keppler indicates that GE intends to implement an augmented inspection of Sun supplied core components currently being manuf actured, with special emphasis on welded areas.
Mr. David York, of the GE San Jose of fice, was contac tea on July 20, 1978.
He indicated that GE had completed the inspections of all affected reactor site with the exception of one Mexican reactor site, whose inspection had been deferred.
He stated that Field Deviation Disposition Requests, at each site, would reflect all deficiencies identified by the GE inspection team.
FDDR's generated at the Zimmer site as a result of the GE inspection team visit reflect welding problems on the shroud, core support plate, shroud head, and top guide.
FDDR's at the La Salle site identified similar problems. All of the identified problems will be treated as routine FDDRs, GE personnel indicated, and will be evaluated and dis-positioned in accordance with GE procedures.
Attachments:
Exhibits I through VI
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. February 23, 1973 Docket No. 50-358 Docket No. 50-373 MDORANDUM FOR:
C. Fioralli, Chief Raaetor Operaticca and Nuclear Support Branch THRUt W. 5. Littie, Chief, P ataar Support Saction Isactor Inspostor TRON:
-
SURJECIs CONCERN RECARDINC QA PRDCRAM DURING MANUFACTURE UF COEX INTmALE AT SG SHIFBITILDING (ZDOGR 4, TNit)
'
This is to infera you of a concern I have regarding the Quality Assurance (QA) Frogram at Sua Shipbuilding and of the audits performed by General Electric and the licensees of the work at Sun Shipbuilding of reactor internals. This also reflects om our vendor program.
I became concerned following a series of inspections at the LaSalle County Nuclear Station and the William E. Zimmer Nucisar Power Station
during the months of January and February 1978. The core internals for both sites were manuf actured at San Shipbuilding. Maybe the problem is that I do not understand QA, but at present, I feel someone is not doing his job. To me QA and QC mean more than a papar review to ensvre all documentation is in order;iit raans that the final product is built i
l as it vaa supposed to be.
l Now to the reasons for my concern. During my visits to Zimmer, I became l
aware of licenses problems with the core eupport plate pins. These pins are used to align the fual support piece. A review of the problem showed
,
that 84 out of 137 pins are bens innexcess of allorahla. The licensee is
'
studying ways of correcting the problem. There are dif ferent opinions as i
to where the pins were bent with a CE representative stating the core support plate lef t Sun Shipbuilding in good condition and the licensee l
disaaresing.
I feel the problem occurred during manuf acturing because l
of the large number of pins damaged and because at LaSalle the same probles was found. At least 4 pins at LaSalle are badly bent, but the licensee
l has not yet used the vandor's gauge to detarmine bow many more are out of l
tolerance.
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' Exhibit I RIII RIII page 1 Of 2 Little
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2/27/78 2/27/78
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It should be noted that the Gemaral Electris Prodnet QC rsmehumer does not
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Admatify the problem as part of item 4.7, Cere Plate Final Inapestiam
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It A encend problem involves the tack welds on the core syrsy metales.
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has been discovered that some of the welds are afasiag-coms have craaks,
,j erster pits, eta., er are undernised. Both LaSalle and Zimmar have this d
problem and I understand GI is sending a generic istter to all BWE 5
ownars te daspect thase welds. Again, I like to point out that according
-
to GE's QC Checklist the aosalas, albows and deflectors were correctly assembled, and that dye peastraat and visual avantnation ei walts were
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witmassed for 153 and record revissed ist 100%. No proklaas were acted.
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l A third problem eoneerns the steam separator or shrood head assembly.
Tbs quality of the walds appears to be ppor. Some that I looked at ta
.i January had pita er craters and many had crevicae where future corrosias
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fatisme erarking coo 1LA originate. In addition, I acted the licenses was
dys penetrast e w =g a large number of horisontal walds during my j
January visit. The reason was that Sun Shipbe11 ding had forgotten to de
But, again, secording to the GE Product QC Chechtist, all accessible
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malda were dye penetreat chaehad.
One thing I noted in the QC Checklist
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is that moottof it conadsaa of reaord review and very little actual witnessing of the work. So I wonder, who's minding the store? I de not
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know if the ehrood hand for f ***Ha has similar problems because it was d
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not accessible for taspection last month.
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i WhMa I raaHua that the identified problems can be corrected in the
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fiald, I wondar if all dafeeta have been identifisd. Afcar tha== events, j
f I tend te loose faith in tha vendor's QA program which is some instances j
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j even borders om supplying false information.
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I feel the NEC should eenduct a thorough investigation of the vender's s
QA Fregram as it applias to both the Lasalle and zimmar centracts.
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14 actor laspector j
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se L F. Esishnam L F. Warnick Exhibit I
T. L. Harpstar
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NUCLEAR RE GUL ATOR Y COMMISSION
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March 15, 1978 Doch t No. 50-356 Docket No. 50-373 MEMORAS3UM FOR:
C. Fiorelli, Chief, Reactor Operations and Nuclear Support Branch 3 /
THRU:
'A'. S. Little, Chief Nuclear Support Section
, 'l FROM:
, Reactor Inspector SUBJECT:
CONCERS REGARDING QA PROGRAM DURING MANUFACTUFI 0F CORE INTERNALS AT SUN SHIPBUILDING (ZIMMER 6 LASALLE)
This is tn update :ty last umemo sto you of _ February.28,'.19.78.
Since then, additional conversations uith LaSalle personnel'have revealed-that the core support plate and top guide _were not manufactured by Sun Shipbuilding; however, the core spray headers, shroud and steam s,eparators were.
Therefore, while my comments regarding the core support plate apply only to Zitmer, all other comments apply to both facilities.
Reactor Inspector cc:
R. F. Heishman R. F. Warnick T. L. Harpster Exhibit II
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SUN SHIPBUILIENG & mY IDCK COV.PM PG.
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ENGINEERING DIVISION GENERAL ELECTRIC COMPANY,175 CURTNER AVE., SAN JOSE, CALIFORNIA 95125 l
May 15, 1978 70 - /30 $
Mr. James Keppler, Director 7p _ jgg9 Region III S0- 358'
US NRC 60-3pj ]7f 799 Roosevelt Road Glen Ellyn, ILL 60137 Mr. Keppler:
Recently, Mr James Foster and Mr. William Key conducted inspections j
i of our General Electric facilities in San Jose and of Sun Ship-building & Drydock Co. regarding the Shroud Assemblies for the Zimmer and LaSalle sites.
The General Electric intended inspection program for corrective action was discussed with them.
Through Mr. David York, in our organization, we have continued to keep them apprised of the program.
On May 10, they conveyed to Mr. York your desire to obtain a copy of our complete inspection plans.
Attached for your information is a copy of our internal letter of May 5, 1978 to GG Sherwood, Manager, Safety & Licensing regarding those plans.
I hope that it will convey the information you desire.
We have completed the activities at the Hatch 2 site, and are scheduled to conduct the remaining inspections at the Zimmer site this week.
If you desire further information, I will be pleased to assist you.
Sincerely
.
02J b hp
.
J. Powledge, Manager QA-Engineered Equipment Exhibit VI
& Installation page 1 of 16 MC 727, Extension 6731/32 M;y 17 ]g7g cc:
BA Podberesky GG Sherwood
DS York
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ENGINEERED EQUIPMENT PROCUREMENT OPERATION SAN JOSE, CALIFORNI A CC:
WA Anders N
Biglieri AP Bray A
Breed
May 5, 1978 f
f"$f*us DL Fischer FD Judge EW O'Rorke JK Powledge J Barnard, Manager HE to P6QA0 KB Webster lfe GG Sherwood, Manager Safety 6 Licensing SUBJECT:
CORE SPRAY SPARGER MANUFACTURING DEVIATION, PRC 78-02 REFERENCE:
Letter WHD/69/78, WH D' Ardenne to NL Felmus, et al, dated April 11, 1978.
The referenced letter concludes that the several BWR4-5 core spray sparger nozzle tack weld deficiencies do not constitute a reportable deficiency.
However, it requests EEPO to identify the corrective action to be taken to preclude recurrence in the future.
All BWR-5 Shroud Assemblies, containing the installed core spray spargers, have been shipped to the sites except Nine Mile Point 2.
That Shroud Assembly is currently in fabrication at Sun Shipbuilding.
QA-EE6I has already taken steps for an assured and documented 100%
inspection of the spurger nozzle tack welds by Sun Shipbuilding with a documented 100% overcheck inspection by the GE QC Representative.
These actions must confirm that the nozzle installation meets require-ments prior to release to ship the Shroud Assembly.
,
For the BWR4-5 Shroud Assemblies that have been delivered to requisition 71 ant sites that are not operational, QA-EE6I and Design Engineering have taken several actions:
1.
Regarding the Core Spray Sparger Nozzle installation, FDI's have been generated to conduct detail'ed examinations of the Nozzle Tack Welds at the following plants:
Limerick 1/3 Zimmer 1 Exhibit VI Shoreham LaSalle 1/2 page 2 of 16 Fermi 2 Bailly Susquehanna 1/2 Hope Creek 1/2 Hatch 2 Laguna Verde 1/2 Hanford 2 i
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05/05/78
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Page-2-
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The status of accomplishment of these inspections is j
reflected in Attachment A.
Note that we are conducting the inspections at Ho (Shroud Assemblies by Rotterdam Nuclear)pe Creek 5 Fermi and Hanford, Bailly, Susquehanna and Laguna Verde 1 (Shroud Assemblies by CBIN) to determine if the problem is design / fabrication-generic or is unique to Sun Shipbuilding workmanship.
2.
Because of numerous scattered problems reported on Sun Shipbuilding manufactured components, QA-EESI and Design Engineering are undertaking a task-force inspecti;n of all available BWR4-5 core structure components made by Sun Shipbuilding.
This activity is being performed to establish i
through integrated action, the as-built quality and to establish best-balanced field corrective actions for any deficiencies noted.
The scope of this program is contained in Attachments B G C.
Completion of both of these programs is highly dependent upon project schedules, component availability and customer attitude.
Some inspections have already been accomplished, others are imminent, and some, like Laguna Verde, will be delayed in accomplishment because of site conditions.
However, regardless of the timing, we intend to re-establish customer confidence in the quality of these core structures and GE's willingness to properly confront and correct problems.
To further improve our performance on 6e forthcoming BWR-6 Core Structure Components, we will increase our physical inspection /
surveillance of the hardware, particularly in the welded areas,
by a factor of at least two/three times that in the past.
We will document this through the QC Representative completion of Engineering Surveillance Parameter Check Lists.
These checklists will be prepared by the QC Engineers, with inputs from Design Engineers, to focus the inspection on areas or attributes of the Core Structure components deemed to be critical or important to satisfactory performance or service.
Exhibit VI M
BA Podberesky, P qager page 3 of 16
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Engineered Equip.
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ATTACHMENTS
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CORE SPRAY SPARGER TACK WEl.D-INSPECTION STATUS
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INSPECTION INS 3ECT ON
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SITE-FDl/FDDR STATUS MFG R ESUL~ ~S REMARKS
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MERICK I FDDR-HHO-089 COMP.
SUN CRACKS & MISSING WLDS.
- MERICK ll FDDR HHO-089 COMP SUN CRACKS & MISSING WLDS.
IMMER I FDDR KN-1-137 COMP.
SUN UNACCEPTABLE & MISSING WLDS.
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MREHAM FDI65/KS-01-170 COMP.
SUN CRACKS ETC. & MISSING WLDS.
LSALLE I FDI53/HAl-086 COMP.
SUN 21 CRACKS.
L SALLE 11 FDI32/HA2-056 COMP.
SUN 3 CRACKS, 46 MISSING TACKS.
ERMI II FDI79/(LATER)
PARTICAL h RDM DONE-NO MISSING TACKS SHROUD DROPPED POSSIBLE CRACK.
INSP. DELAYED.
ILILLY FDI44/(LATER)
CBIN llSQUEHANNA I FDI25/IN PROCESS COMP.
CBIN 2 MISSING TACKS-NO FDDR'S TO FOLLOW CRACKS, 20% A LITTLE UNDER SIZE.
hSQUEHANNAII FDI25/IN PROCESS COMP.
CBIN NO MISSING 7ACKS OR CRACKS, 20% A LITTLE
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UNDER SIZE.
i I, INSPECTION WILL
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0;PE CREEK I FDI33/(LATER)
PARTICAL h RDM CRACKS B
M PE CREEK ll FDI27/(LATER)
PARTICAL h RDM CRACKS FR TH (UNITS l
hTCHIl FDDR-HF2-331 COMP.
SUN VERY MINOR PROBLEMS NGUNAI FDIlA/ UNKNOWN CBIN DELAYED hGUNAII FDI12/ UNKNOWN SUN DELAYED
'ANFORD ll
$E FDI43/ UNKNOWN CBIN UTILITY AND
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i CONSTRUCTOR RE-
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SCHEDULED INSP.
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HEEK 05/08/78.
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FAGE 1 0F 2 (
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ATTACHMENT B
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i SUN SHIP CORE STRUCTURE QUALITY PROBLEMS BEING FOUND AT PROJECT SITES Due to the fact that various weld quality deviations have been found at several different project sites on Shrouds supplied by Sun Ship, it has been decided that an overall review for re-inspection of the total core structure fabricated by Sun Ship should be considered.
Considerations in determining the need for re-inspection of the complete core structure supplied by Sun Ship on a one team approach included:
1.
Weld quality problems found on the Zimmer and Limerick Shrouds,
specially on the LPCI System, the Core Spray Sparger System and i
the Seismic Blocks have 1e:Ed to concerns about other attachment type welds in the core structure.
2.
Issuing of one generic inspection FDI for all suspect Sun Ship Core structures will be less costly and less time consuming than i
issuing Inspection FDI's on piece meal bases for each type deviation found.
3.
One inspection by one team will result in better inspection uniformity, minimize re-inspection time and assure more factual information.
4.
Quality concerns on all attachment welds and other related items can be factually answered to re-established product acceptability for General Electric, Sun Ship, Customer and NRC.
This review resulted in the following conclusions:
1.
A team should be established for the re-inspection of the core structures for projects listed in Item 2 below.
A.
The team should consist of the following:
1.
Responsible BWR 5 Core Structure Q.C. Engineer 2.
Responsible BWR S Core Structure Design Engineer 3.
Materials Engineer - 1st few plants 6 as needed there-after.
4.
Q.C. Representative at each site or site person as assigned when deviations are found and FDDR's are to be issued.
S.
Sun Ship Representativp if possible to be arranged by Purchasing.
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Exhibit VI page 5 of 16
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ATTACHMENT,B
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2.
The Projects that should be looked at include:
PROJECT L0 CATION
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Lilco Site 1) Top Guide 6 Core Zimmer Site Suppgrts fabricated by Bingham-Williamette.
Hatch II (Limite4 only Site 2) The Core Spray Sparger Shroud Head available Hardware f abricated by for inspection)
Murdock.
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Limerick I 6 II Site 3) LaSalle II and Laguna LaSalle I 6 II*
Site Verde II Shrouds were inspected in shop after Laguna Verde II*
Site LPCI re-inspection FDI Nine Mile Point 2*
Shop was issued.
Total 9 Units including Hatch II.
l 3.
One generic FDI should be issued to cover the re-inspection of all core structure components f abricated by Sun Ship for the projects identified in Item 2 above.
Initially, the welds should be re-inspected visually for contract compliance for each of the maj or component features as outlined on the attached lists.
i Shroud Welds - See Attachments of FDI Shroud Head Welds - See Attachments of FDI Core Support Plate Welds - See Attachments of FDI Top Guide Welds - See Attachments of FDI
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Exhibit VI page 6 of 16
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DRAFT ## I
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, FIELD DISPOSITil INSTRUCTION
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INITI ATING DATE. '
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FDINO.
REV NO.
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GEN ER AL h ELECTRIC SHEET OF PROJE CT UNIT NO.
NUCLEAR ENEROY DIVISION FDI DIRECTED TO Proiect ltanaaer (OE F ALLO REPRESENT ATivE AND LOC ATION)
EQUIPM ENT rnen Strnetorn MPL NO.
O MAKE O suY AFFECTS A SAFETY RELATED FUNCTION OYES O NO
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DESCRIPTION OF TASK: (EXTENT OF DESCRIPTION DEFINED IN EP&P 5.3.1)
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PURPOSE:
Visual inspection of the core structure fabrication welds on Shroud Head & Separators, Core Plate, Top Guidead Shroud to verify welding requirements are in complian:e with GE Purchase Order on Sunship.
GE Dwg. #
SunShip Dwg. #
VPF #
REQUIRED DOCUMENTS:
Shroud Core Plate Top Guide Snroud Head &
Separators
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Purchase Specification 21 A3319 Rev.
Purchase Order Number Rev.
PATERIAL REQUIRED:
1) Scaffolding Ladders and other equipment, preparations /
and/or unpacking necessary for access to the core structure componets for visual inspection of all welds made by Sunship during shop fabrication.
2) Steel Scales Fillet Gages, Lighting, Mirrors and/or other visual aids necessary to visually inspect, measure and verify the welds and weld assembly details required by the above referenced requirement drawings have been complied with.
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page 7 of 16 1. ORIGIN ATOR
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2. DESIGN ENGINEERING *
QATE COMPLETED _
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3. PROJECT MAN AGER VERIFIED PY:
4.OTHER
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CONTINU ATION SHEET
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FIELD DISPOSITION INSTRUCTION
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GENERAth ELECTRIC SHEET
0 F_.3 unttu tstm omsica
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PROCEDURE:
1) Visually inspect all welds as necessary to verify welding and weld assembly details that were completed by SunShip in their shop on the Shroud, Shroud Head &
Separators, Core Plate and Top Guide with particular emphasis on the welds of attachments.
2) The following lists of attachment welds applicable for
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core structure component shall as a minimum be visually inspected.
3) The team shall work to check lists and/or drawings and document their findings in writing for evidence of Quality acceptability.
4) All deviations from attachment weld Quality and original Purenase Order requirements shall be suomitted on FDDR to the above Project Manager per E0P 55.3.00.
The FDDR shall be issued while the Inspection Team is available at the respective sites to assure that consistent and factual deviation descriptions get in the TDDR.
To insure that sound Engineering and economically feasible Dispor.itions are made by the Tea: Members, all rework or reinspection Dispositions shall require Purchasing, Engineering, Quality Assurance and Projects review for acceptance before FDDR Disposition is implemented.
5) Reportable Findings that are not covered or required by Purchase Order requirements originally placed upon Sunship are to be so identified, documented, and dispositioned accordingly.
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Exhibit VI I
page 8 of 16
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CONTINU ATION SHEET
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FIELD DISPOSITION INSTRUCTION
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FDI NO.
GENER AL h ELECTRIC SHEET
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uutttu latest emsion STARDARDS, REFEREtlCES AND REC 0KiEilDATIONS:
1) Liquid Penetrant reinspections must be authorized via FDDR Deviation Documentation and Disposition.
2) The Re-Inspection Team shall consist of two primary member. rand three support members.
Primary members:
1. David York
- QC Engineer 2. Clyde Morton - Design Engineer Support members:
1. David Sandusky-Materials Engineer 2. Site QC Rep as assigned by L. Duff 3. George Barry - Team Leader Prin. QC Engineer Note: The supplier Sunship may also include a primary participating member on the Inspection Team which will be arranged by Purchasing when possible.
Exhibit VI page 9 of 16
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C Shroud Welds
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Top Guide Blocks
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Seismic Blocks
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Top Guide Hold Downs Blocks 4.
Guide Pin Lugs 5.
Bench Mark Blocks 6.
Shroud Head Bolt Hold Down Lugs 7.
Lifting Lugs
- 8.
Align Blocks for Horizontal Design Core Plate & Top Guide 9.
Water Dae Plate to Top Tiange 10.
Sparger System Weld Requirements Sparger Brackets Sparger Pipe / Inlet Sparger "T" Box Cover Plate Sparger Nozzle Ta k
- 11.
LPCI (Water Box Weld Requirements)
Tillet Welds Tull and Partial Penetration Welds Bracket Welds
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- Design Feature not Applicable for all Plants.
Exhibit VI page 10 of 16
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Shroud Head Welds 1.
Bolt Lugs 2.
Guide Pin Lugs 3.
Lift Rod Lugs 4.
Stand Pipe to Doce Welds 5.
Stand Pipe Stiffeners Straps 3" 6.
Stand Pipe Stiffeners Plates 48" 7.
Bolt Ring Gussets 8.
Stea Separator Tie Bars 9.
Stand Pipe to Separator Veld Collar or Full Penetration 10.
Lift Eye to Lift Rod
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Core Plate Velds 1.
Beams to Rim 2.
1/2 Pins to Top Plate 3.
Rim to Top Plate Veld 4.
Peripheral Fuel Support Casting to Top Plate 5.
Incore Pipe to Rod 6.
Align Block to Ric l
Exhibit VI page 12 of 16
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Top Guide Welds 1.
Aligner Blocks to Rim
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2.
Lift Eye Blocks to Rim
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Boss to Cover Plate Ring - Seismic Block
- 4.
Beam to End Block Weld - Certain Designs only 5.
Beam Blocks to Pin Welds
- 6.
Corda 11 Plate to Rim Weld
- 7.
Top Guide Latch Hold Down Block Welds i
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- Design Teature Not Applicable for all Plants.
Exhibit VI page 13 of 16
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ATTACHMENT C
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BWR 4 6 5 CORE STRUCTURE REINSPECTION-SUN SHIP SUPPLIED
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GROUND RULE PURPOSES:
1.
Re-establish overall product acceptance and document the same.
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2.
One time Inspection that will address all doubts and questions once and for all.
3.
Guidelines for uniform, obj ective and practical Inspection approach that will yield positive findings.
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4.
Guidelines for documenting deviations and/or findings and for making expeditious dispositions based upon sound Engineering and Economics.
This would include providing for administrative concurrance/ controls by Purchasing, Projects, Quality Control and Engineering to assure the best balanced disposition and implementation for over-all General Electric Interests.
Exhibit VI page 14 of 16
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ATTACHMENT C
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BWR 4 6 5 CORE STRUCTURE REINSPECTION - SUNSHIP SUPPLIED GROUND RULES:
(Based upon stated purpose)
1.
Initially perform only Visual Inspection (unaided eye) to the original Purchase Order requirements on all welds and related including structural and attach-workmanship made by Sun Ship, defined workmanship.
ment welds and specification 2.
Inspection of tack and intermittent welds originally requiring 5 power magnification for Visual Inspection need only be sample reinspected using 5 power magnification unless weld Quality deviations are found that would justify need for more extensive inspection.
3.
Visual Inspection of welds that required P.T. on final surface.
If the final surface conditions or visual defects are present that would make a valid P.T. Inspection on the weld or section of weld improbable, then an FDDR is to be issued and appropriate reinspection or other disposition is to be made.
(P.T. or other methods such as 5 X Visual could be appropriate reinspection)
4.
Guidelines for Inspection of open crevice welds.
Open crevices are to be accepted based upon the following:
No visual weld defects or evidence of wrong weld process a.
application, b.
Weld characteristics and location comply with Purchase i
Order requirements.
l ho other factual evidence to substantiate non-compliance, c.
If it can not be determined that open crevice welds are in compliance with Purchase Order requirements and there is some factual evidence that there is likely flux process weld material open to reactor water, then the factual evidence is to be written up on n'
FDDR and dispositioned as to action necessary to establish i
acceptaole or unacceptable open crevice welds in question.
This could include either seal welding the crevice or cutting out pieces of weld and testing to determine what type of root process w as us e d.
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5.
All Reportable Fi.ndings must be agreed upon by all GE Team Members or findings will not be considered valid until resolved by San Jose Management of respective Team, Members.
Exhibit VI page 15 of 16
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ATTACHMENT C PAGE 3 OF 3
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6.
Reportable Findings that are not covered or required by Purchase Order requirements originally placed on Sun Ship are to be so identified, documented and dispositioned accordingly.
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7.
Deviation Findings which do not meet the minimum requirements of the Purchase Order are to be documented on FDDR's and dispositioned, if possible while Team is at the site.
FDDR dispositions prior to implementation are to have review and concurrance of Purchasing, Quality Control and Engineering Managers, and respective Project Managers via telephone and TWX authorization through the responsible GE Buyer to assure the following:
Vendor participation and Purchasing Consideration
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warranty cost reimbursements.
Engineering Consideration -
Design and Safety require-ments as well as rework effects on hardware 6 costs.
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Deviation causes and correction Quality Control
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Consideration actions.
Disposition effects on schedule Projects Consideration
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and costs as well as customer and NRC relations and legal aspects.
Exhibit VI l
page 16 of 16
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