IR 05000362/1982011

IE Insp Rept 50-362/82-11 on 820524-28.Noncompliance Noted: Failure to Install safety-related Seismic Restraints

ML20055A013
Person / Time
Site:	San Onofre
Issue date:	06/23/1982
From:	Eckhardt J, Hernandez G, Wagner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20055A006	List: IR 05000362/1982011 ML20055A005 ML20055A008
References
50-362-82-11, NUDOCS 8207150383
Download: ML20055A013 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /82-11 Docket N License N CPPR- 98 Safeguards Group Licensee: Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Onofre Unit 3 Inspection at: Construction Site, San Diego County, California Inspection conducted: May 24-28,1982 Inspector ' m f h -&,- 6,/73/f 7

. J. Wagner, Reactor Inspecto- Date Sihned G

()ernandez,ReactorQnspector

/ '$s? y./// / S-k} l, FEL Date Signed Approved by: [ D  ! (/7:'/P/

Dite Signed

'J . . Eckhardt, Acting Chief Reactor Projects Section 1 Summary:

Inspection on May 24-2_8, 1982 (Report No. 50-362/82-111 Areas Inspected: Routine, unannounced inspection by regional based inspectors of construction activities involving safety-related components, structures and supports, and licensee action on unresolved items. The inspection involved 62 onsite inspection hours by two NRC inspector Results: One item of noncompliance was identified in the area of safety-related structures and supports (see paragraph 2).

8207150383 820629 PDR ADOCK 05000362 G RV Form 219(2)

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DETAILS , Persons Contacted Southern California Edison Company (SCE)

• D. C. Stonecipher, Construction QA Supervisor

• V. A. Gow, QA Engineer

• D. B. Schone, Project QA Supervisor

• C. J. Trenkle, Construction Engineer

• D. E. Nunn, Project Manager G. P. Vaslos, QA Engineer N. M. Ferris, QA Engineer W. E. Kirby, QA Engineer Bechtel Power Corporation (Bechtel)

• J. W. Sheppard, Project QA Supervisor

• D. T. Lobree, Project Fleid Engineer

• J. H. McCarty, Project QAC Manager

• F. B. Marsh, Project Engineer

• H. F. McCluskey, Project Manager J. L. Sabina, Field Engineer D. D. Simpson, QC Engineer W. M. Senn, Receiving QC Engineer N. P. Besich, Welding QC Engineer R. S. Rubin, Welding QC Engineer, Supervisor S. L. Vernon, Mechanical QC Engineer Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (50-362/82-08/02): Cask handling crane rail records were not available for revie ' ~

The required quality records were reviewed during this inspection and the records appeared to be complete and met all applicable requirements. The inspector had no further questions on this matter. This item is close * (Closed) Unresolved Item (50-362/82-08/01): Installation records for the Unit 3 Shutdown Heat Exchangers were not available for revie Three major concerns were addressed under this item during the April 19-23, 1982 NRC inspection; however, because of new items identified during this inspection, this unresolved item will be closed out and the new concerns given follow-up numbers where appropriate. The findings of the inspection are as follows:

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-2-(1) During the NRC inspection of April 19-23,1982, the inspector observed that filler plates had been added between horizontal channel restraint members and the wall plates for the northside Shutdown Heat Exchanger which were not detailed in the applicable drawing (Civil Drawing No. 23623-11). This condition was observed only in the urcer three seismic restraints of the northside Shutdown Heat Exchanger (S/N S3-1206-ME-004). However, because at the time the installation records could not be located for review, the inspector could not determine whether the installation / change had been accomplished in accordance with the licensee's design change procedure During this inspection, it was determined that the

, installation had apparently been made without generation and issuance of a Field Change Request (FCR). Accordingly, on May 4,1982, the licensee issued Nonconformance Report No. C-3079, which required, among other things, an evaluation of the acceptability of the undocumented filler plates (shims). On May 20, 1982, Bechtel Project Engineering's evaluation determined that the "looking east" shims were acceptable and gave approval to remain "as-is". The

"looking south" shim was determined not to be able to perform its safety function and was ordered removed. The

"looking south" restraint member would then be re-installed as detailed on the drawing. Calculations by Bechtel civil / structural engineers had determined that the i "looking south" shim could possibly buckle and fail under postulated accident conditions.

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The failure to install safety-related seismic restraints in accordance with prescribed drawings and without assuring that changes to plant design are reviewed and approved by responsible personnel is considered an apparent item of noncompliance with 10 CFR 50 Appendix B, Criterion V,

" Instructions, Procedures, and Drawings". (Noncompliance:

50-362/82-11/01)

The apparent failure by the licensee to follow quality usurance program requirements for the specific case noted above requires that assurances be provided to affirm that the shim material is acceptable and meets the requirements of the site quality program. Therefore, at the exit interview on May 28, 1982, the inspectors requested and received a commitment by the licensee that a coupon from the removed shim be provided for analysis by a NRC contract laboratory. The subsequent material analysis would then be compared against the site accepted material certification This is a follow-up ite (Foll ow-up: 50-362/82-11/02)

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-3-(2) During the April 1982 inspection, the inspector also observed that the 1/4" fillet weld size called out in the

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drawing for the horizontal restraint members to the 2"

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wall plate appeared to conflict with the minimum fillet weld size requirement of paragraph 2.7.1.1 of AWS D1.1-1975, when a prequalified joint design is utilized. The table in paragraph 2.7.1.1 requires that if the base metal (of the thicker part joined) is 3/4" or larger, the minimum I

fillet weld size shall be 5/16". The welding of the I seismic restraints was performed using Bechtel Welding Procedure Specification, P1-A-Lh (Structural), which utilizes the AWS prequalified joint procedure On May 28, 1982, the licensee provided documents which indicated that the licensee had addressed a similar problem with respect to undersized fillet welds on pipe supports which did not meet the minimum fillet weld size requirement of table 2.7 of AWS D1.1. This was addressed in SCE Corrective Action Request (CAR) No. S023-S-392 issued to Bechtel on November 1,1978. Bechtel in response initiated a variety of verification / qualification tests to justify the existing welds which did not comply with the AWS requirements. The CAR was closed on March 21, 1980 based on the results of the Bechtel tests which concluded that the undersized welds were adequate to perform their intended function and that an adequate margin of safety existed for prevention of underbead crackin Therefore, the licensee contended that the Bechtel study justified all existing undersized structural welds made prior to March 21, 1980, which were undersized with respect to the AWS requirements. Furthermore, the licensee stated that all drawings issued after March 21, 1980 had been revised to call out, where appropriate, 5/16" welds instead of 1/4" welds to comply with the AWS requirements when a prequalified joint design was utilize Also, the licensee pointed that the installation of the seismic restraints had been made to revision 6 (dated October 28, 1977) of civil drawing No. 23623 and the installation completed on December 7,197 The inspector agrees with the licensee's position on this subject and has no further questions on structural welds made before March 21, 1980. However, the inspector will audit civil / structural drawings issued after March 21, 1980 during a future NRC inspection to assure that weld details are in accordance with the AWS requirements, when

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-4-a prequalified joint design is utilize This is a follow-up ite ( Follow-up: 50-362/82-11/03)

(3) Also during the April inspection, the inspector observed that the high strength bolting for the seismic restraints did not have washers under the bolt head or the nu During this inspection, the inspector reviewed Bechtel's response to SCE Corrective Action Request No. S023-F-1085 issued on May 18, 1982 in response to the above concer The Bechtel reply indicated that the installation of the ASTM A325 bolted connections fell under the jurisdiction of the Nuclear Field Engineering group who had installed the fasteners by the turn-of-nut method in accordance with the requirements of the 7th Edition of the American Institute of Steel Construction (AISC) Manual. In accordance with AISC, A325 fasteners may be installed without hardened washers when tightening is by the turn-of-nut method. The bolted connections were installed in accordance with WPP/QCI-300 and documented on Construction Inspection Data Reports (CIDR) Nos. S3-1206-ME-003, Sequence 0, Revision 0, and S3-1206-ME-004, Sequence 0, Revision This item is close . Welding Procedure Specification A review of Bechtel Welding Procedure Specification No. P1-A-Lh

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(Structural) determined that the specification sheet did not depict l a typical joint design as is the usual practice when utilizing AWS l prequalified joints. The usual practice is to write a specification sheet for joining specific base materials and specifying a particular AWS prequalified joint detai Other AWS required details usually included on the specification sheet are minimum and maximum root and pass size, and whether single pass fillet welding is require The Bechtel procedure as written depends heavily on the knowledge

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of the intricacies of the AWS Code requirements by the welder and

! the weld inspecto The licensee stated that they would investigate this matter and take appropriate action as necessary. This item will be examined

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further during a future inspection. This is a follow-up ite ( Follow-u p: 50-362/82-11/04)

4. Quality Assurance Audits The inspector examined four Bechtel audits for compliance with the

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Bechtel Quality Assurance Manual, applicable quality procedures,

and 10 CFR 50 Appendix B criteria. The following audits were

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examined:

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Number Description Audit No. 2093/G-4 Audits and Corrective Action Audit No. 2089/G-42 Project Quality Assurance Trend Analysis Audit No. 2106/S-9-2 Bisco Audit No. 2124/C-8 Structural Steel Erection and Bolting No items of noncompliance or deviations were identifie . Review of Quality Records The quality records relative to reactor vessel installation, reactor vessel internals, and reactor coolant pressure boundary piping were reviewed. The review was to ascertain whether these records reflect work accomplishment consistent with NRC requirements and PSAR connitment Reactor Vessel Installation (1) Storage Inspections The following QC inspection records were reviewed to assure that stored vessel inspections were made and that protection requirements were maintaine . Field Surveillance Report No. M-264-77, " Offloading and Transport to Oceanside Storage"

. Field Surveillance Report No. M-3-78, " Transport from Oceanside Storage to SONGS 3 Jobsite" (2) Handling and Installation Pertinent Quality Assurance and Quality Control records were reviewed to ascertain whether the reactor vessel was installed in accordance with specifications and work procedures, and that the required Quality Assurance activities were accomplished. Records reviewed were:

. Field Surveillance Report No. M-266-77, " Unit 3 Reactor Vessel Installation"

. Field Surveillance Report No. M-7-78, " Surveillance of Installation in Containment 3"

. CIDR (Construction Inspection Data Report), " Reactor Vessel Installation"

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. CIDR, " Reactor Vessel Head Guide Cone Repair"

. CIDR, " Reactor Vessel Column Stud Tensioning" l

. CIDR, " Reactor Vessel Head from Shipping Skid to Temporary Storage in Containment"

. CIDR, " Reactor Vessel Head Relocation"

. NCR No. N-372, " Reactor Vessel Head Alignment Keyways Out of Tolerance". Dispositions, including reviews by cognizant field and Quality Assurance Engineers are appropriat (3) Installed Vessel Protection The inspector reviewed four Housekeeping Inspection Data Reports of Quality Control inspections made of the

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installed reactor vessel. The records confirm that only authorized personnel, tools, and equipment were allowed

] in the area designated as Zone III-A. The inspector also i reviewed Bechtel audit activity reports of April 29, 1981 and of November 4,1981 to assure that the required frequency of audits and inspections were performed. The inspection records indicate that vessel cleanliness was maintaine No items of noncompliance or deviations were identifie b. Reactor Vessel Internals (1) Storage Inspections The inspector reviewed the receipt inspection data reports on dowel pins, guide lug inserts, guide tube

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clusters, and guide cone assemblies. After receipt, the

reactor vessel internals were stored in a warehous Review of the storage inspection data reports revealed i that the protection requirements were maintained, and I that the stored internals inspections were made in accordance j with ANSI N45.2.2.

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l (2) Handling and Installation

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Reactor vessel internals handling and installation i Quality Assurance and Quality Control activities are documented on CIDRs (Constf action Inspection Data Reports).

Review of the Quality Assurance master audit plan and selected CIDRs indicate that installation of the reactor vessel internals was in accordance with specificatiot.s

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, and procedure The following describes the purpose of the specific CIDRs reviewed by the inspector:

(a) Establish requirements for the installation or removal of the Core Support Barrel (CSB) into or out of the Reactor Vessel (RV).

(b) Establish requirements for the installation or removal of the CSB into or out of the RV following Alignment Pin and Alignment Key installatio (c) E;t2 dish guidelines for (a) the alignment of the Coi' SW9 port Plate, (b) the installation of the pernanent Alignment Pins, and (c) the alignment of the Upper Guide Structure.

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(d) Handling and transporting the In-Core Instrument Support Plate from the Mesa to the jobsite, and specifying the requirements of the preparation, installation, and removal prior to and after the plant hydrotes (e) To document trial installation of the CSB into the RV and measurement for Snubber Shim (f) Establish guidelines for the alignment of the Reactor Head and machining of the Alignment Key (g) Establish guidelines for the final alignment check i of all major internal component (3) Installed Vessel Protection Review of Quality Control inspection reports relative to j post-installation vessel internals indicate that adequate i

access control is being provided, and that vessel internals cleanliness was maintaine No items of noncompliance or deviations were identifie c. Reactor Coolant Pressure Boundary Piping The inspector reviewed the quality records relative to pipe .s spool number 3-RC-015-4 (12-inch diameter) and number 3-RC-033-1 (6-inchdiameter). Documents reviewed include material test'

reports, certification records, vendor shop manufactoring and l

NDE records, vendor inspection, and receiving inspection data l

report Review of the storage inspection data reports

' indicate the pipe spools were maintained and inspected during storage bi-weekly in accordance with WPP/QCI-008 and ANSI N45.2.2.

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, The inspector also reviewed the installation records of five

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pipe spools to ascertain that the required scope of inspection was performed and that installation procedures were met. The following pipe spool CIDRs were reviewed:

Pipe Spool N Pipe Size (length)

S3-S I-ML- 045-5 8" (25')

S3-RC-M L- 002-503-3 42" (14' )

S3-RC-ML- 003-503-06-2 30" (16' )

S3-VC-ML- 010-1 F 2" (19' )

S3-VC-ML- 055-1 4" (18')

The CIDRs reviewed described the inspection procedure followed for pipe line installation. The pipes were checked for configuration and location, physical damage, and field closure compl etio The inspector reviewed Bechtel Quality Assurance Audit No.1988 covering the audit of ASME Section III piping installatio The audit activity was performed in accordance with WPP/QCI-400 for the period of June 20, 1981 through July 24, 198 No items of noncompliance or deviations were identifie . Exit Interview The inspectors met with licensee representatives denoted in paragraph 1 on May 28, 198 The scope of the inspection and the inspectors'

findings as described in this report were discusse The licensee acknowledged the concernsiidentified by the inspectors and stated that they would take appropriate action, as necessary.

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10 CFR 50, Appendix B, Criterion V, as addressed in paragraph 5.1 of the

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Quality Assurance Program in Appendix A of the PSAR, states in part:

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 " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures,
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or drawings. . . ." a Bechtel Civil Drawing No. 23623 Revision 11, details in Section E, the

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configuration for the field welding of the Unit 3 Shutdown Heat Exchanger

 , upper seismic restraint members to the wall anchor plate is Contrary to the above, as of May 24, 1 982, the as-built configuration
,, for three upper seismi restraints were found not to conform to that
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specified in the drawing in that each restraint member had an added filler plate between the channel restraint member and the wall anchor pl a te.

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The filler plates were undocumented and no Field Change Request (FCR)

" could be found which approved the design change. Subsequent calculations    3 a

by Bechtel civil / structural engineers determined that the "looking south" member (as installed) would not be able to perform its safety

 function under postulated accident conditions. This installation was    i n

completed and inspected on or about December 7,197 I

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