IR 05000400/1987001
| ML20211C397 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/12/1987 |
| From: | Blake J, Harris J, Lenahan J, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20211C349 | List: |
| References | |
| 2.206, 50-400-87-01, 50-400-87-1, NUDOCS 8702200086 | |
| Download: ML20211C397 (30) | |
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UNITED STATES jk NUCLEAR REGULATORY COMMISSION f
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o REGION il
-g 101 MARIETTA STREET,N.W SulTE 2900
ATLANTA, GEORGIA 30323
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Report No.:
50-400/87-01 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket No.:
50-400 License Nos.: NPF-63 Facility Name: Harris Inspection Conducted: Dece ber 3 1986 January 23, 1987 f///[f7 Inspectors:
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Date Signed J. J. Lenahan iNIhud
.1/n/Fr7 J.R.Harrisk Dhte Signed
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Date Signed Approved by:
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J. J.'Blake, Section Chief Date Signed Engineering Branch
/l Division of Reactor Safety SUMMARY Scope:
This special, announced inspection was conducted to followup on concerns identified by a former employee in the intervenor's 2.206 petition dated October 17, 1986.
Results: No violations or deviations were identified.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- R. Brown, Civil Engineer, Harris Plant Engineering Section (HPES)
J. Eaton, Supervisor, Expansion Anchor Construction Inspection
- G. Forehand, Manager, Quality Assurance
- M. Holvak, Principal Engineer, HPES L. I. Loflin, Manager, HPES R. Marlar, Supervisory Civil Engineer, HPES
- J. W. McKay, Resident Civil Engineer, HPES R. Parsons, Manager, Prudency Audit Team
- W. Pridgen, Senior Engineer
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- W. Seyler, Construction Project Manager
- M. G. Wallace, Regulatory Compliance Staff
- R. A. Watson, Vice President, Harris Project Other licensee employees contacted included ten construction craftsmen, four civil engineers, and four civil QC inspectors.
NRC Resident Inspectors
- G. Maxwell, Senior Resident Inspector S. Burris, Resident Inspector
-* Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on January 23, 1987, with those persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findings.
No dis-senting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
4.
Unresolved Items Unresolved items were not identified during this inspectio,
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3-5.
Background On October 17, 1986, a petition was filed by Wells Eddleman and Coalition for. Alternatives to Shearon Harris (CASH) pursuant to 10 CFR 2.206 to revoke, suspend or modify' the Construction Permit for the building of' the
= Shearon Harris Nuclear Power Plant.
In Section III of this petition, a confidential informant, herein after referred to as the alleger, asserted to improper practices in the areas of sign-off of procedures; inadequate inspection procedures for concrete expansion anchors; unauthorized material substitution; and falsification of design documents that craft personnel used to install safety-related expansion anchors.
The concerns stated in the petition were non-specific.
Specificity was only provided in reference to location of concrete expansion anchors where alleged problems may have occurred.
A summary of the concerns stated in the 2.206 petition are as follows:
Sign-off of design approval block on concrete expansion anchor place-a.
ment reports (APRs) by unauthorized individuals.
b.
" Sand bagging" of concrete expansion anchors to achieve minimum. torque.
c.
Individuals used bogus stamps to swap non-Q for Q materials.-
d.
Alteration of design documents by craft personnel to permit the craft to. deviate from approved construction practices.
Failure of QC inspectors to check undercut tolerances for holes drilled e.
to receive " maxi-bolt" anchors.
f.
Rampant material substitution by craft in areas which were to be under water.
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- Craft changed elevation and location of shear plates installed in Emergency Service Water Intake Structure.
h.
Use of Concressive 1411 Epoxy grout under baseplates.
In order to followup on these concerns, NRC Region II attempted to interview the alleger for clarity and specificity (letter to intervenors dated October 22,1986) but the alleger, through his attorney, initially declined to be interviewed in a phone call to the NRC Region II Regional Counsel on i
f November 13, 1986.-
NRC Region 11 contacted the alleger's attorney on several occasions subsequent to November 13, 1986, and repeated the request
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for an interview with the alleger.
After these additional contacts, the
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alleger agreed to an interview with NRC which was conducted on December 18,
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1986, in Raleigh, North Carolina. During the interview, which was conducted
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by telephone, the alleger declined to provide any additional specific information regarding the concerns expressed in the 2.206 petition; however,
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he did provide some clarification regarding the concerns.
The alleger also
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expressed some additional concerns during the -interview regarding adequacy of engineering analysis of testing of concrete expansion anchors; use of Concressive 1411. epoxy inside containment; changes to procedures; grouting of the intake structure gate guides; coatings used on intake structure shear
plates; and unauthorized substitutions of embedded anchor bolts.
Unfortu-i nately, the alleger provided no specific information regarding these-addi-tional concerns.
Review of concerns listed in the 2.206 petition'by the inspectors commenced in the Region II office on December 3, 1986. The in office review consisted
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of review of FSAR commitments, the CP&L response. to IE Bulletin 79-02, l
review of inspection reports documenting results of inspections performed by i
other Region II inspectors, design specifications, licensee work and inspec-tion procedures, and quality records documenting results of inspections performed by licensee QC inspectors.
Onsite inspections were conducted by the inspectors on December 8 and 9, 1986, January 5-9, and January 20-23, 1987.
In addition, the concerns were examined by the NRC Resident Inspec-
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tors, S. Burris and G. Maxwell.
Their inspections consisted of witnessing testing of expansion anchors (both wedge and maxi-bolts) and shear plates in the intake structure and inspection of completed work alleged te be defec-tive. The results of their inspections of the 2.206 concerns are documented
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in Inspection Report 50-400/86-94.
The results of the detailed inspection j
performed by the regional inspectors are discussed in the following j
paragraphs.
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6.
Followup On Concerns Expressed In 2.206 Petition Sign-Off of Design Approved Block on Anchor Placement Report (APRs) by a.
Unauthorized Individuals t
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The 2.206 petition states that a breakdown in the required design approval procedures occurred in sign off of APR numbers IS 190 016, i
I 019, 024, 038, 042, 045, and 046. The petition states that the design j
approval block on these APRs was signed by the CP&L Electrical or Pipe managers, and not by the area engineer who was the only individual l
qualified to verify design inclusion in the work packages. During the December 18 interview, the alleger questioned whether or not the two
l managers who signed the documents were knowledgeable of the design documents required for installation of the anchors for the above listed
APRs.
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Discussion I
The APRs referenced in the concern were for installation of steel plates which provide lateral support to traveling screens in the emergency service water intake structure (ESWIS).
These plates are referred to as shear plates and are attached to the intake structure
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Review of the APRs listed in the 2.206 petition and an additional 42 other APRs for the emergency
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service. water intake structure disclosed that the " Design Approval" block on Section 8 of the APRs had been signed by the discipline managers as stated in the 2.206 petition. The inspectors examined.CP&L Work Procedure WP-33, Installation of Wedge Expansion Bolt Anchors.
This review disclosed that WP-33 states that Section B of the APR including the design approval block, is to be completed and signed.by the Area or Discipline Engineer.
Discipline managers supervise the area and discipline engineers.
It is acceptable practice for'supervi-sors to sign 'and approve documents in the absence of the individuals they supervise.
Therefore, the discipline manager signing the APR in lieu of the area engineer did not violate the licensee's procedures.
The design approval block sign.off does not indicate approval of the design, but rather verifies that the proper. design documents, i.e.,
drawings, procedures, and specifications, are referenced on the APR for use by craft personnel in the installation of the expansion anchors.
The inspectors examined the referenced. APRs and verified that the correct design documents were listed on the APR.
Therefore, there is no indication that the discipline managers were not familiar with the design documents required for installation of the expansion anchors..
The inspectors noted that, after the design approval block on the APR had been initially signed, additional design requirements were added to the APRs as the, work progressed.
These were due to design changes, e.g..' the need to relocate the shear plates due to interferences, need to cut rebar, and various other reasons.
Findings-The allegation is substantiated in that discipline managers signed some APRs in lieu of the area engineer.
However, this did not violate either licensee procedures or NRC requirements and has no safety significance.
b.
" Sand Bagging" of Concrete Expansion Anchors to Achieve Minimum Torque Concern The 2.206 petition states that the integrity of Phillip Expansion Anchors installed in the Reactor Auxiliary Building was compromised by sand bagging in order to achieve minimum required torque values. The petition further states that this was done in holes that were errone-ously drilled oversize by pouring fine sand-blasting sand into the hole so that the anchor would bind against the sand when the anchor was tightened and torqued up to minimum values. The petition specifically references APR RA305 003, 006, and 007 for examples of where this l
problem occurred. During the December 18 interview, the alleger stated that he was concerned that the addition of sand in the drilled holes would weaken the performance of the expansion anchor.
He stated that this problem could not be checked by performance of a torque test on
j the anchors, but that a tension test would indicate the anchors had
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reduced capacity. The alleger indicated that the sand bagging may have occurred on up to 25 percent of expansion anchors in the referenced placements.
He stated that most likely it occurred in anchors which were relocated due to interferences.
Discussion The term " sand bagging" is not a known technical term or slang expres-sion used to describe the practice discussed in this concern, but rather appears to be a term originated by the alleger to refer to pouring the sand into oversized drill holes to enable the anchor to achieve minimum torque values.
Phillips expansion anchors are wedge anchors manufactured by ITT Phillips for installation in concrete.
A description of the steps used to install these concrete expansion anchors is as follows:
(1) Determine locations where concrete expansion anchors are to be installed.
(2) Drill a hole in the concrete using the proper size (diameter)
drill.
For each size anchor, the diameter on the hole is speci-fled in the manufacturer's installation procedures, and the size of the drill bits used to drill the holes for various size anchors is carefully controlled.
Since these anchors are non-bottom bearing, a precise hole depth or hole clean out is not required.
(3) Install the concrete expansion anchor in the hole.
This is done by driving the anchor into the hole with a hammer.
(4) " Set" the anchor by torquing the nut on the expansion anchor to a minimum torque value specified in the installation procedures.
This preloads the expansion anchor to the required installation values. Application of the required torque value causes the wedge anchor to expand a one piece stainless steel clip into the side of the hole, thus preventing anchors from pulling out of holes.
i The inspector examined the following specification and procedures which control the installation of concrete expansion anchors:
EBASCO Specification CAR-SH-CH-19, Drilled In Expansion Type
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Anchors, Seismic Category I (
CP&L Technical Procedure TP-39, Inspection of Drilled - In Expan-l
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sion Anchors and Thru-Bolts
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CP&L Work Procedure WP-33, Installation of Wedge Anchor Expansion (
Bolt Anchors
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These documents specify the load carrying capacity of the anchors, anchor materials, installation requirements, inspection and testing practices, and quality assurance requirements.
The inspector also examined the licensee's responses dated July ~6,1979, and January 4,
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1980, to NRC Region II for IE Bulletin 79-02, Pipe Support ~ Baseplate
Design Using Concrete Expansion Anchor Bolts.
The minimum torque values specified in the procedure to set the anchors were established by the licensee and the manufacturer after completion of an onsite testing program.
The' safe working loads used for design were established by a four to one safety factor applied to the average of ultimate static tensile and shear loadsfor each anchor size.
This is in accordance with the requirements specified in IEB 79-02.
The results of the onsite testing program are documented in a report titled Field Test Results of ITT Phillips Drill Division Red Head." Wedge" Type Anchors at the Shearon Harris Nuclear Site," dated February 29, 1980.
The inspector reviewed this report and verified that the working load was established with a four to one safety factor applied to the ulti-
mate static and tensile loads.
In order to attempt to duplicate the practices described in the 2.206 petition, the licensee conducted a series of tests on December 20 and 21, 1986, on expansion anchors which had been intentionally " sand bagged." These tests, which were witnessed by the NRC Senior Resident Inspector, are discussed in Inspection Report 50-400/86-94. The " sand bagged" anchors did not fail when tested to 115 percent of their
allowable design capacity per procedure requirements.
The te'st load was. increased to 140 percent of allowable design capacity when failure, slip, initially occurred on some of the anchors.
Further testing of intentionally " sand bagged" anchors were conducted
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on January 6 and 7,1987.
These tests, which were witnessed by Region II inspectors, were conducted to more closely duplicate the practices described by the alleger during the December 18 interview.
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The test methods were specified and observed by the Region II i
inspectors.
For these tests, three-quarter inch diameter anchors were installed in oversize holes which were drilled with a 0.837 inch diameter " maxi-bolt" bit. The maximum size bit used to drill the hole for a normal wedge anchor installation has a 0.787 inch diameter.
However, the maxi-bolt bits were not available on site when these alleged practices occurred.
The intent of these tests was to drill the holes large enough so that the anchors could not be set normally and to detcrmine if, by adding sand, they could be set (torqued to specified minimum
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values). The tests were conducted as follows:
Five holes were drilled using the oversized drill bit.
The inspectors measured the diameter of the drill bit and the drilled holes. The anchors would not slip loosely into the holes, so four holes were enlarged (" wallowed out") using the drill bit to ensure
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. the anchors would slip ' loosely into the hole.
The anchors, designated test numbers W-1 through W-4, were inserted in four of the holes and' attempts were made to set (torque) the anchors prior to adding sand to the hole.
When it was confirmed the anchors would not torque up without the' addition of sand; sand was roared into the hole around the anchor until the anchor could no longer be rotated by hand.
The anchors were then torqued with a cali-brated torque wrench.
Two of the anchors would not torque to the minimum specified torque (minimum pre-load) of 150 foot pounds on
.the.first attempt.. Additional sand was added to these anchors and
- the minimum _ torque was obtained on one of the anchors.
The remaining anchor, number W-2, slipped beyond the minimum accept-able embedment and could only be torqued to a maximum torque of 100 ft. Ib., after which it began rotating in the hole.- Under normal practices,. this anchor would have been rejected for failing to obtain the required minimum torque and the minimum embedment.
The fif th anchor, number A-1, was installed in the same size oversized hole, but the hole was intentionally not wallowed out for information purposes.
This anchor satisfactorily torqued up without sand being added.
All five anchors had torque values independently verified by a construction inspector (CI).
The CI applied torque indicator paint to each anchor and the anchors were allowed to set for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, after which they were tension tested.
This is in accor-dance with normal installation, inspection and testing practices.
Licensee procedures require that tension tests be conducted on every one-hundredth anchor.
The minimum specified tensile test ~
load is 115 percent of.the. static working load of 5200 pounds, that is 5980 pounds, for 3/4 inch diameter anchors.
l The tension test results are summarized in the table below. The slip load is defined to be the point where the anchor does not l
slip more than 1/16 (.06) inches and is specified during the test
as the point where the washer under the nut can be turned by hand.
Review of the results of the onsite tests documented in the 1980 test report disclosed that the slip load is less than 40 percent
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of the ultimate load of the anchors.
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Table Test Anchor Actual Load At Slip (in pounds)
W-1 9640(161% of static tensile load)
W-2 4560 (76% of test load)*
W-3 10210 (171 % of test load)
W-4 8320 (137 % of test load)
A-1 6710 (112 % of test load)
- Anchor carried 88 percent of static working load of 5200 pounds, but would have normally been rejected due to failure to obtain required minimum torque and embedment.
Based on the results of these tests and those previously conducted and witnessed by the resident inspectors, the inspectors concluded the " sand bagged" anchors are acceptable if they obtain the required minimum torque.
These tests reconfirm the importance of installing wedge anchors to their proper torque values.
The inspectors discussed this practice with craft personnel involved in installation of anchors and with construction inspectors. One individ-ual stated that he overheard a supervisor (foreman) instruct an in-staller to pour some sand into a drill hole to assist the anchor in achieving the required minimum torque.
The individual stated that he believed it was one of the anchor placements referenced in the 2.206 petition. To the best of his knowledge, he believed it was confined to only one anchor. However, since only a small number of individuals who were involved with the anchor program are still employed at the site, the inspectors did not pursue the interview process, but instead concluded that this practice may have occurred.
However, even if it did, testing has demonstrated that " sand bagging" does not affect the integrity of the anchors.
The specific concrete expansion anchor 9 tee;,e rts listed in the concern are no longer accessible for tensitn ;t,/t' s due to proximity of The.nsp'ctsrs were able to visually installed electrical equipment.
e examine the installed anchors and review the quality records pertaining to thase anchor installations.
Review of the records disclosed that a Discrepancy Report, Number DR-C-1761, was written to address problems with these ins +411ations and some others.
The Discrepancy Report was reviewed.
This review disclosed that the problem was not due to oversized drill holes, but rather as a result of relaxation of the expansion anchors during installation of adjacent anchors in the same baseplate.
This was due to the fact that each of these placements involved installation of between 10 and 80 expansion anchors in the same large plate used to support electrical cabinets in the RAB. The anchors in these placements were reset to the proper torque values to disposition and close out the DR.
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Findings Based on discussions with individuals still employed at the site, this concern is partially substantiated.
The inspectors concluded the integrity of the anchors was not comprised by " sand bagging."
In some-cases, anchor capacity may actually: be increased by this practice..
These conclusions are based on the testing conducted by the licensee and witnessedjby the resident and regional inspectors.
c.
Individuals Used Bogus Stamp to Swap Non-Q for Q Materials Concern The 2.206 petition states that in the early stages of the anchor program it was very easy to substitute specified baseplates for other items.
The real problem was created in 1983-1984 with the use of the A-36 material stamp.
This stampfwas in the shape of a triangle with the number 36 inside the triangle'. The petition stated that it was an accepted-practice to " buy'off" material by having it stamped by the QC '
inspector.
These stamps were not available to anyone other than the
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inspection group, but the anchor general foreman and at least two other a
general foremen had stamps made by' a company in Richmond, VA and they could create Q (A-36) material instantly by just stamping the material with the stamps.
During the December 18 interview, the alleger stated that he was not
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sure from where (either the city or company) the bogus stamps were obtained from, but that two iron worker general foremen had their own
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stamps.
He declined to identify these individuals by name.. He stated i
that he saw the stamps being used, but that the foreman would not do-
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the stamping themselves.
The foremen directed craftsmen working under them to do the stamping. The alleger stated that the bogus stamps were
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used for materials in pipe hangers and field fabricated materials in
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the structural steel frame at the north end of the fuel handling i
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l Discussion r
The licensee's commitments pertaining to traceability of Seismic Category I item are stated in the FSAR on page 1.8-37.
Traceability of Seismic Category I items to documentation (certificates of compliance in lieu of certified material test reports) was required and verified at the source of supply (site warehouse or site fabrication shop)
during receipt inspection.
After the material source was verified as acceptable for Seismic Category I applications based on supporting documentation, the A-36 steel or ASTM A-500, Grade B (tube steel) was marked with the A-36 stamp.
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The inspector's review of the QA program identified no faults with the licensee procedural controls in place.
Instruction QCI 18.4, Control of A-36 Steel Stamps, provides guidelines for rigid custodial control and use of the stamps.
The licensee obtained the controlled stamps from a firm in Igomar, Pennsylvania. Likewise, instruction QCI 7.1, QA Inspection Status Identification and work procedure WP-18, Miscellane-ous Steel Fabrication address guidelines for stamping applicable items after receipt inspection and for transfer of markings during fabrica-tion.
These instructions and procedure specify that QC provides the controlled A-36 stamp to the craftsmen, who in turn, stamp the item or materials with QC witnessing the stamping.
It is conceivable that what the alleger saw was the craftsmen stamping structural steel materials with a legitimate A-36 stamp provided by a QA/QC inspector.
If so, the material would be acceptable.
The 2.206 petition uses the words that it was accepted practice to " buy off" material by having it stamped with the A-36 stamp.
This implies that materials were accepted as "Q" material without having a sound basis for doing so.
However, as discussed above, the application of the stamp to a material was done under control of QA/QC inspectors.
The use of the stamp indicated that the material imprinted with the stamp was fabricated from Q materials received and inspected under the licensee's QA/QC program.
The licensee had identified a problem with material control which resulted in the issuance of a discrepancy (nonconformance) report (DR),
number DDR 1775 in July 1983.
The subject DDR identified problems associated with the issue and documentation of surplus / stock steel materials for use in the plant; non-seismic materials that were substi-tuted on seismic hangers; documentation which identified incorrect
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hanger purchase orders; and use of material (i.e., a different type steel) other than mentioned in the documentation.
Research was con-
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ducted by the licensee into all stock structural shape purchase orders (Q and non-Q) to consider all possible material grades of steel which could have been installed in the plant.
Those purchases orders which provided no specific requirement for material type were assumed to be l
non A-36; although, in fact, they may have been A-36 or better.
Percentage of suspect material were defined for each shape classifica-tion and ASTM grades of steel with lower structural properties than the steel specified were assigned.
Harris plant general structural design
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and pipe hanger design are based on AISC allowable stress.
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research and engineering evaluation concluded that any possible suspect material that may have been substituted had yield strengths that were
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above the allowable stresses used in the design calculations for A-36
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steel which was 60% of A-36 (21,600 psi). This indicates that although the original design margin may be reduced with the use of a substitute material, the fabricated item would not be stressed to the point of failure.
The actions taken by the licensee to resolve nonconformance DDR 1775 were examined and discussed by Region II inspectors in Inspec-I
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tion Report numbers 50-400/84-43 and 50-400/86-21.
Region II inspec-tors concluded that the engineering evaluation and corrective actions taken were acceptable for the closure of this item.
The inspectors walked down the fuel handling building (FHB).
The FHB is a reinforced concrete structure and does not contain any large structural frames, with the exception of the fuel cask handling bridge The crane, including the crane rails was fabricated off site crane.
and did not require any field fabrication.
Since the inspectors did not have any specific information, no additional followup could be performed on this concern.
Findings Examination of licensee procedures, quality records, and discussions conducted with licensee engineering and QC personnel did not substan-
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tiate this concern.
In any event, although the possibility exists that indeterminate material other than A-36 or A-500 Grade B (tube steel)
could be installed, the standard AISC allowable stresses used in structural steel and pipe hanger designs are less than the minimum yield strengths of any postulated substitute material that could have been used.
In addition, Region II inspectors have performed numerous inspections of the licensee's program for procurement, receipt inspection, storage and handling, and materials traceability. With the exception of a few minor violations, material control in the construction of the Harris plant met NRC requirements.
d.
Alteration of Design Documents By Craft Personnel to Permit the Craft to Deviate From Approved Construction Practices Concern In the 2.206 petition, the alleger stated that during 1982 and 1983 the craft supplied all applicable design documents which QC inspectors used to perform their inspections.
The craft personnel would alter the controlled design documents by modifying the information on them to agree with what they had constructed.
The concern states that the craft would obtain blank blue paper (unique color of paper used for controlled documents) and fill in the information they wanted on these sheets and substitute these altered documents for documents in the controlled design document package.
This precluded the need for the craft to obtain approval for cutting rebar, moving anchors, and alter-ing plate sizes.
Additional information provided by the alleger during the December 18 interview indicated that the altering of documents was generally for cutting rebar.
This was done because for one reason or another they would have to put an anchor in a particular spot and they couldn't relocate it or move it or shift it.
Thus they would have to cut the
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rebar.
They would ask for permission to cut the rebar via a permanent waiver (PW) or Field Change Request (FCR) but generally on a permanent waiver. Sometimes that permission was not granted. To circumvent this problem, they would get an approved PW and write or type in the infor-mation they wanted to approve cutting the rebar. The alleger indicated that this took place between 1981 and 1982 and that sometime between 1982 or 1983 because of a procedure change you could no longer cut rebar by using a falsified document.
This was because of exhibits in the technical procedure which required construction inspectors CI to document cutting rebar.
The alleger also stated during the interview that the changes were often made on the original document (blue copy)
using either a pen, pencil or typewriter and then it was not necessary to obtain another blue copy of the altered document, since the inspec-tor would be shown the original altered document.
Discussion In following up on this concern, Region II NRC inspectors reviewed controlled documents which included procedures and specifications, and changes to these documents which include field change requests (FCRs)
engineering change notices (ECN), permanent waivers (PW), and field modifications (FMs).
This review showed that these documents are printed on blue paper and distributed by the licensee's document control gro'ap to various groups on site. These include craft supervi-sors, QA/QC inspection supervisors, engineering personnel, construction inspectors CI, and licensee management.
The distribution of these documents is controlled by the licensees QA program in accordance with the requirements of 10 CFR 50, Appendix B.
Individuals are not permit-ted to copy or alter these controlled documents. Extensive inspections of the document control system have been performed by Region II inspec-tors since the start of construction. With the exception of some minor violations, none of which related to bogus documents, the licensee's document control program complied with NRC requirements.
Discussions with licensee personnel disclosed that QC inspection personnel sometimes used the craft's copy of the design documents to perform their inspections. Therefore, it is possible that if the craft personnel had altered the documents, the inspectors would not have detected the changes during their inspection.
While it is possible that some craft personnel may have altered design documents, their motivation for doing this is difficult to understand.
Also, it is doubtful that an inspector would not readily detect changes made to a document, if he was using the original altered document, and not a copy of an altered document.
Changes made to a document are usually very obvious.
Changes to baseplates were routinely made by the licensee when interference were encountered.
These changes involved relocation of anchors, relocation of baseplates, cutting rebar, and altering plate sizes.
When the craft could not install a baseplate, or any other piece of hardware in accordance with the design requirements, they would contact engineering for assistance.
Engineering would then take the lead for having the design documents changed by issuance of an FCR,
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PW or FM.
There would be no reason for any craft personnel to alter any documents.
In fact, it would be more difficult for the craft to alter the documents than to request engineering assistance to resolve the problem. The consequence for an individual found to have altered a design document without authorization was termination.
In following up on this concern, the licensee examined 1166 Anchor Placement Reports (APR) covering safety-related expansion anchors installed in 1982 and 1983, the period identified in the 2.206 peti-tion.
Review of these placements by the licensee showed that fifty of these placements involved cutting rebar, which was documented in the QC inspector's records and the applicable design document which permitted cutting of rebar.
Review of procedures by the Region II inspectors showed that procedure TP-39, Inspection of Drilled-In Expansion Anchors, did not have a requirement for inspection of. reinforcing steel until Revision 4 which was issued on October 13, 1982.
This revision only required documen-tation of rebar encountered during placement of anchors. The require-ment to document cutting of rebar by CI first appeared in Revision 7 which was issued April 24, 1984.
However, review of Specification CAR-SH-CH-19 Drilled in Expansion Type Anchors Rev. 2 through Rev. 7, August 1980 through June 1986, and procedure WP-33, Installation of Wedge Expansion Bolt Anchors, Revision 0, which was issued on May 21, 1980, showed that there was a requirement tc relocate the anchor if reinforcing steel was encountered and that in no case was reinforcing steel to be cut unless prior approval was given by EBASCO (Architectur-al Engineer responsible for design).
Further review of this item by Region II inspectors included the anchor placement reports IS 190-001 through IS 190-050 referenced by the alleger and 300 additional Anchor Placement Reports and associated documentation in the anchor placement packages of anchor installations that took place between April 17, 1981 and October 1984.
Review of these packages showed that the first drilling for expansion anchors began on April 17, 1981. Review of this first installation showed that
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the encountering of rebar was identified and documented on the first installation.
Review of these packages showed that even though proce-dure TP 39 did not require the Construction Inspector to document encountering of rebar until Revision 4, October 1982 and cutting of rebar until Revision 7, April 1984, that encountering and cutting of rebar was identified and documented by the construction inspectors on exhibits included in the anchor placement packages.
Review of the original FCRs and PWs showed that cutting of the rebar was identified on the FCRs and PWs and approved by the appropriate design engineer.
Finding Discussions with licensee personnel disclosed that QC inspection personnel sometimes used the craf ts' copy of design documents to perform their inspections.
Review of procedures showed that procedure
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TP-39 Inspection of Drilled in Expansion Anchors, did not adequately address encountering of rebar until Revision 4, October 1982 and the cutting of reinforcing steel until Revision 7, April 1984.
However, the requirement to identify encountering and cutting of reinforcing steel did occur in procedure WP-33 Revision 0 and specification CAR-SH-CH-19.
Review of anchor placement reports and associated exhibits from the first anchor installation which began on April 17, 1981 thru October 1984, showed that even though there were some initial inadequate procedure instructions for documenting encountering and cutting of rebar, that the cutting of reinforcing steel was documented and identified by construction inspectors.
Review of the APR reports, FCRs and PWs showed that where rebar was cut that approval was given by the design engineer and that this information was referenced on the APR and documentation included in the APR package. Thus even though it may have been possible for the craft to alter their copies of FCRs and PWs to permit cutting rebar, review of the documentation and original copies of FCRs and PWs does not show any evidence that this occurred.
This concern was not substaintiated.
Failure of QC Inspectors to Check Undercut for Holes Drilled to Receive e.
" Maxi-Bolt" Anchors Concern The 2.206 petition states that quality control procedures were compro-mised by failure to check undercut tolerance for holes drilled to receive maxi-bolts.
During the December 18 interview, the alleger stated that he was concerned with the failure of QC inspectors to check undercut tolerance prior to this requirement being incorporated into the inspection procedures.
The alleger stated that the change to the procedure to require check of the undercut tolerances was the result of an INP0 finding.
The alleger also stated that the Craft would sometimes change the embedment depth of the maxi-bolt by backing off the conical nut or the bottom cf the maxi-bolts one or two turns to add an eight to quarter of a inch oc the embedment so that the maxi-bolt would pass inspection.
The alleger stated that this was being done because the depth of the undercut in the drill hole was an eighth to a quarter inch higher than permitted by procedures.
Discussion Maxi-bolt undercut expansion anchors are manufactured by Drillco Devices, Ltd, for installation in hardened concrete.
The maxi-bolt consists of a threaded bolt with a conical nut which is encicsed in an expandable metal sleeve.
A description of the steps used to install Maxi-bolts is as follows:
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(1). Determine location where the maxi-bolts are to be installed.
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(2) Drill a cylindrical hole in the concrete using the proper size
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(diameter) drill bits specified by the manufacturer. -
(3) Create a conical undercut in the bottom of the hole using:a calibrated maxi-bolt undercutting tool.
(4) Install the maxi-bolt in the undercut drill hole.
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(5) Set the anchor using a calibrated hydraulic jack to draw the
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conical nut on the bottom of' the anchor up into the anchor's expansion sleeve.
When the sleeve is expanded, it is forced to move laterally into the undercut portion of the hole.
This
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creates a positive anchorage mechanism which results in an anchor-l capable of developing the minimum ultimate strength of the steel.
(6) After the anchor is set, the attachment (i.e., place of equipment or fixture to be fastened to concrete) is placed over the maxi-bolt and the maxi-bolt is retensioned with the hydraulic jack to
,j preload the maxi-bolt.
The inspector examined the procedures which control installation and inspection of the maxi-bolts.
These procedures include EBASCO specifi-cation CAR-SH-CH-19, CP&L's technical procedure TP-39, and CP&L's work
l procedure WP-42, Installation of Maxi-bolt Undercut Expansion Anchors.
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Review of procedure WP-42 disclosed that this procedure was initially
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issued (Revision 0) on March 7,1983.
This procedure prescribes the I-materials and methods for setting the maxi-bolts and specifically
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prescribes methods and tolerances required for. undercutting the maxi-
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bolt holes.
Review of TP-39 disclosed that requirements for the
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Deviation Notice 4 dated March 7,1983, to Revision 4 of TP-39.
The j
inspector noted that there were no specific requirements to inspect
undercut in the procedure.
Inspection of undercut in maxi-bolt holes was not made a procedural requirement until Revision 7 of TP-39 which
was issued on April 24, 1984.
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i The inspector discussed the lack of procedural requirements for inspec-j tion of the undercut with licensee engineers and QC inspectors. These
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discussions disclosed that even though there were no procedural re-
quirements to perform inspections of the undercut, the need to inspect i
the undercut was recognized by licensee inspectors.
Review of QC inspection documents disclosed that inspection of undercut was docu-mented in the comments section of Exhibit 4 to TP-39, Drilled in
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l Expansion Anchor Visual Inspection Report, for approximately 25 percent i
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of the maxi-bolts installed prior to the issuance of Revision 7 of
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Review of construction inspection personnel training records i
disclosed that inspection of undercutting was discussed during a
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. training session held on November 1,1983. - However, the inspection records document that inspection of the undercut was performed prior to this date.
Based on review of licensee records, the inspectors con-cluded that inspection of undercut was performed prior to incorporation -
of this requirement into TP-39 since it was a requirement specified in procedure WP-42 and specification CAR-SH-CH-19.
Review of licensee QC inspection records disclosed that the licensee inspectors occasionally identified cases where the Crafts' undercutting blades were worn beyond the minimum allowable tolerances.
When this occurred nonconformance reports were issued and the holes ~were either undercut with properly calibrated tools or were accepted for "Use-as-is" based on previously conducted testing. The licensee also performed testing to decrease the minimum undercut-diameters specified in work procedure WP-42.
The testing was documented on FCR-AS-7744.
This testing showed that decreasing the undercut-did not affect the integri-ty of the maxi-bolts.
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The inspectors examined the 1984 INP0 Construction Project Evaluation.
Review of this document disclosed that there were no findings related to installation of either wedge anchors or maxi-bolts.
In fact, the INP0 report discussed good practices (Good Practice Item CC.4-6)
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related to the licensee's installation and inspection program for wedge anchors and maxi-bolts.
Also, the INP0 evaluation was conducted after Revision 7 to TP-39 was issued.
Examination of maxi-bolts disclosed that backing off the conical nut on the bottom of the maxi-bolt would not effect embedment of the maxi-bolts.
Embedment is based on the location of the expandable portion of the metal sleeve.
Since the top of the sleeve is flush with the concrete surface, the depth of embedment is controlled by sleeve length, and not the location of the conical nut. Adjusting the conical nut does not effect embedment depth.
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I In order to respond to the 2.206 petition, the licensee conducted a
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l series of tests on maxi-bolts which were installed in cylindrical drill holes without any undercut.
These tests were witnessed by the NRC l
Senior Resident Inspector.
These anchors were tensile tested to a s
l tensiled load of 12000 pounds as required by licensee procedures. At the request of the resident inspector, the licensee tested one of the bolts to 23000 pounds, which is almost twice the required acceptance load. The bolt did not fail at this load. The capacity of the testing device precluded testing the anchor to failure.
These tests demon-strated that the absence of an undercut does not affect maxi-bolt anchor performance.
These tests represented a worst case postulation of maxi-bolt undercut tolerance since no undercut existed.
The NRC inspectors concluded that failure of licensee QC inspectors to check undercut would not have affected the integrity of the anchors.
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Findings The concern was not substantiated.
Even though the licensee's inspec-tion procedure TP-39 did not initially require inspection and documen-tation of undercut in maxi-bolt holes, discussion with licensee inspectors and review of licensee records' disclosed that undercut was inspected by QC inspectors prior to the time when the specific require-ment was incorporated into the procedure..In addition, testing per-formed by the licensee and witnessed by the resident inspector clearly demonstrates that the maxi-bolts would meet design requirements even if they had been installed in holes without any undercut.
Thus, this concern has no safety significance.
f.
Rampant Material Substitution by Craft in Areas Which Were to be Under Water Concern The 2.206 petition states that rampant material substitution occurred in the emergency service water intake structure (ESWIS) in areas which would be submerged underwater.
The petition stated that craft person-nel did this based on their belief that underwater shear plate instal-lations were unverifiable.
The petition implied that the shear plates may have been fabricated from unqualified materials.
During the December 18 interview, the alleger stated that procedures were violated by craft when they installed plates intended for use in other struc-tures for the shear plates in the ESWIS. The alleger stated during the interview that he did not anticipate there would be any technical problems with the installed plates, but that procedures had been violated by these practices.
Discussion In order to followup on the concern expressed in the 2.206 petitions, the licensee dewatered the intake structure on December 20, 1986, and performed field in-place hardness tests on 20 of the shear plates.
These tests were performed by CP&L testing personnel.
In addition, independent hardness testing was performed by Law Engineering Testing Company which verified the accuracy of the licensee's testing.
The licensee also cut one-inch by six-inch samples from eight of the approximately 45 plates which are normally under water.
The sample locations were selected at random by the NRC Senior Resident Inspector.
Each sample specimen was cut in half to obtain two specimens. Labora-tory physical and chemical tests were performed on one specimen from
l each sample at the CP&L testing laboratories, while the remaining
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specimen of each sample was retained by the NRC Senior Resident Inspec-tor for possible future testing by an NRC independent testing laborato-Portions of the in-place hardness testing and obtaining of the
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samples was witnessed by the NRC Senior Resident Inspector.
The I
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physical tests involved performance of tensile testing to determine the yield point and ultimate tensile strengths of the steel.
Chemical testing involved performance of tests to determine the carbon, sulfur and phosphorus content in the steel.
The field and laboratory test
results are documented in a CP&L Metallurgy Unit Memorandum, dated January 19, 1987 Subject:
Emergency Service Water Intake Structure Shear Plate Testing, and Law Engineering Testing Company letter dated December 23, 1986, Subject:
Hardness Testing - Intake Structure.
These reports were reviewed by the inspectors and a Region II Metal-
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lurgical Engineer.
The test results showed that all the shear plates met the requirement for A-36 steel with the exception of one tensile test result which yielded approximately 5% below the ASTM A-36 require-ments.
However, the yield strength was well above the design basis used for A-36 (60% of yield).
Also, the ultimate strength of this specimen was 6 percent higher than the A-36 requirement.
Therefore, this minor discrepancy has no safety significance and is considered within expected standard deviations obtained during testing.
Site fabricated miscellaneous steel is generally custom made for its intended purpose.
It also covers rework of items due to changes in design or deficiencies in previous fabrication.
The inspector examined CP&L procedure WP-18, Miscellaneous Steel
Fabrication.
This procedure covers work requirements for fabrication of miscellaneous seismic Category I steel, including materials control,
documentation, and inspection hold points.
The QC inspection require-ments for miscellaneous steel fabrication are specified in CP&L inspection procedure CQC-21 Seismic Category I Steel Fabrication.
The
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j inspection requirements covered verification of material identification
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markings, e.g., A-36 stamp, welding, if applicable, and material dimensions.
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Discussion with licensee engineers and review of the drawings attached
to permanent waivers (PW) which controlled installation of the shear i
plates disclosed that the shear plates were custom made for installa-i tion in the intake structure.
The width and length of the plates varied with the elevation they were to be installed in the ESWIS.
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While it is possible that an individual could obtain a plate from another area and install it as a shear plate, it is questionable why
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they would do so.
In addition, as discussed in paragraph 6.c. above, the material in the substituted plate would still comply with design
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requirements, provided it was the proper size.
The dimensions of the
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shear plates were verified by QC during installation and during the
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as-built process documented in PW C-4604, R-1 and C-4626, R3.
No
discrepancies were identified.
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Findings
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The concern was not substantiated.
There was no evidence that the
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practice described in the concern occurred.
Regardless, even if it did occur, it would have no safety significance.
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Craft Changed Elevation and Location of Shear Plates Installed in Emergency Service Water Intake Structure Concern In the 2.206 petition and during the December 18 interview the alleger stated that the elevation and location of shear plates in the Emergency Service Water structure were changed by craft and that practically all sign-offs for field location verification were by-passed by craft supervisors.
During the December 18 interview, the alleger implied that field location of other installed baseplates may be incorrect since field location verification may have been bypassed by craft supervisors in other areas.
Discussion Review of records by the NRC inspectors showed that the proper location of plates was checked and verified by QC inspection personnel when the plates were initially installed.
In addition, after the shear plates had been installed, the as-built locations were surveyed by field engineers and documented on PW C-4604, R1 and PW C-4626, R3.
As an additional followup on this item the licensee dewatered the intake structure on December 20, 1986, and checked the location of eight shear pl ates.
This was done by measuring from known reference points in the intake structure.
The NRC resident inspectors observed licensee personnel making these measurements and verified that the correct measurements were obtained. No discrepancies were found. An addition-al followup of this concern by the Region II inspectors consisted of a visual examination of the shear plates in the intake structure that were above water.
This inspection showed that the shear plates ap-peared to be in the proper location.
Review of procedure WP-33 Rev. 7, dated October 1983 showed that the civil manager or hi' designee had the authority to "N/A" and sign and date the field engineer (location)
sign-off block of Exhibit 1 of the Anchor Placement Report when he determined that sufficient controls existed.
The inspectors noted during review of the APRs for the shear plate installation that some had N/A in the Field Engineer signoff.
The N/A indicated that suffi-cient controls existed for installation of these plates and that it was not necessary for the field engineer to establish additional controls in this work area.
Because of lack of specific information regarding other areas where baseplates may have been installed in incorrect locations, the inspec-tors were not able to perform a followup inspection on this item.
However, as discussed above, QC was required to inspect and to document location of installed baseplates.
Also, the baseplates were often installed in relation to other equipment. Therefore, it would normally be very obvious when the baseplate was installed in the incorrect location.
In addition, there were programs that required the licensee to verify that as-built conditions complied with design requirements.
For example, CP&L procedure WP-141, "As Constructed Pipe," required
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walkdowns and surveys to verify seismically analyzed piping systems were installed in accordance with design requirements.
If baseplates supporting pipe hangers for piping systems had been installed at the incorrect locations, these problems would have been identified during the walkdowns and would have been evaluated by engineering and correct-ed if necessary.
Another example of a program which would identify improperly installed baseplates which would have potential safety significance was the review conducted for potential interaction of non-safety with safety-related systems.
This program, which was conducted in accordance with requirements specified in NRC Regulatory Guide 1.29, was reviewed by an NRC consultant.
The consultant's finding are documented in Inspection Report No. 50-400/86-77.
CP&L's engineering procedure 7.6.8, Regulatory Guide 1.29 " Verification Walkdown," delineates the requirements for this program.
If baseplates had been installed at incorrect locations on nonsafety systems which would affect safety-related system, the discrepancies would have been evaluated by engineering and corrected if necessary. Thus, even if the concern was correct as stated by the alleger, discrepancies would have been identified and corrected if necessary.
However, due to the lack of specific information, there is no evidence to substantiate this Concern.
Findings Review of records, visual examination of the shear plates and observa-tion of measurements made by the license on the shear plates by NRC inspectors indicated that the shear plates were installed in accordance with requirements.
Review of procedure WP-33 showed that the civil manager or his designee had the authority to N/A and sign and date the Field Engineer sign-off block of Exhibit 1 of the Anchor Placement Report when he determined sufficient controls existed.
This concern was not substantiated.
h.
Use of Concressive 1411 Epoxy Grout Under Baseplates The 2.206 petition states that procedures were revised to permit Concressive 1411 epoxy grout to be used as a bearing material under baseplates. The petitioner also stated that the 1411 epoxy was affect-ed by heat generated when welding attachments to the baseplates.
The concern with this is that deterioration of the bearing material (the epoxy grout) would affect the integrity of the anchor bolts.
The petition named specific expansion anchor placements in the diesel generator building as examples of where the 1411 epoxy was used as a bearing surface under the baseplate.
During the December 18 interview, the alleger stated that there were numerous other problems with the concressive. These problems included times when the concressive would not set up in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in cold weath-er, but the attachments would be welded to the baseplates even though the material had not set (solidified).
The alleger stated that some-times the concressive material would not set up for over a week after
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it had been placed in cold weather during the months of January and February.
Other problems involved times when the concressive hardened (set up) too quickly.
This would be a problem with repairing unused drill holes when the concressive would set up and plug the holes instead of structurally repairing them.
The alleger stated during the December 18 interview that the indication on Section 1 of the APR as to whether a baseplate is to be on a bearing or non bearing surface is preliminary approval only and may have no relation to how the baseplate was finally installed in the field. The alleger stated, that in his opinion, many of the baseplates that were installed on surfaces coated with the Concressive 1411 grout were actually bearing surfaces, regardless of what is indicated on the APR.
That is, in his opinion, the plates required full bearing and would not have full bearing when placed on a concressive surface.
Discussion Concressive 1411 epoxy grout is a proprietary grout manufactured by Adhesive Engineering Company.
The product is a two component epoxy, which, after it is mixed and cured for seven days, has an unconfined compressive strength well in excess of normal weight concrete.
The inspector examined procedures WP-33 and WP-42.
Review of these procedures disclosed that use of concressive grout as a nonstructural grout under any baseplates where design documents did not require a structural (i.e., Portland Cement) grout was addressed in Revision 7 to procedure WP-33 which was issued in October 1983.
Prior to this time, concressive was not used under baseplates, but was used for cosmetic repairs (e.g. fill unused drill holes). Nonstructural grout could not be used on floors unless it is specifically indicated on design docu-ments.
The procedure stated that the concressive could be used as a nonstructural grout in all areas except inside the containment.
The procedures state that Concressive 1411 shall be mixed and placed in accordance with the manufacturer's recommendations which are attached as Appendix G to the procedure.
The procedures contain the following statement pertaining to the effect of temperature on curing of the concressive grout:
"There is no minimum application or cure temperature for Con-cressive 1411.
There is no requirement for upkeeping of curing logs when using Concressive 1411.
The installer should be cognizant that at temperatures below 50'F the Concressive 1411 will cure (harden) at a lower rate, but that quality of the product is still maintained.
Minimum cure time required is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (regardless of temperature)."
Review of the APR (Exhibit 1 to WP-33) attached to Revision 7 and subsequent revisions of WP-33 disclosed that the Section A (Preliminary Approval) portion of the APR included the question, "Is bearing grout required under the fixture?"
followed by checkoff blocks for either
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"Yes" or "No."
Procedure WP-33 requires the Area / Discipline Engineer to complete Section A of the APR.
The basis for the Area Engineer's determination of whether or not bearing grout is required is the design documents (drawings) which will specify grout if it is a bearing surface.
During the December 18 interview, the alleger implied that, since the determination as to whether bearing grout was or was not required under the fixture was indicated in the preliminary approval section of the APR, this decision would be subject to latter review and possibly changed.
This assumption was incorrect.
Unless the design documents were changed, there would be no reason to change the type of grout to be used under the baseplate.
However, the procedure clearly states the option that a structural grout could be applied under a baseplate in place of a nonstructural grout (Concressive 1411).
Completion of Section A of the APR permitted the craft to start instal-lation of the baseplate.
After completion of Section A, the craft was permitted to lay out the expansion anchors (determine installation locations) and drill the holes for the anchor installation. Additional work (anchor installation torquing, etc.) could not proceed past this point until Section B, Final Approval, of the APR was completed.
The inspector examined the specific baseplate installations (placement numbers 1 DG 2610136 thru 166) referenced in the 2.206 petition and compared the "as-built" installed baseplates with the completed inspec-tion records. This review disclosed that sixteen of the baseplates had structural grout under them.
Non-bearing grout was specified on the APR and was permissible under the remaining fifteen baseplates.
The inspector examined the design documents (pipe hanger sketches) pertain-ing to the fifteen plates. This review disclosed one discrepancy which was related to APR 1 DG261-155.
The pipe hanger sketch specified Portland cement grout under the baseplate for APR 1 DG 261-155 (fire protection hanger FP-H-2618 mounted on the wall of the diesel generator building), while the APR indicated that bearing grout was not required under this baseplate.
The inspector discussed this discrepancy with licensee engineers.
The design calculations were revised and the baseplate was reanalyzed assuming a gap under the baseplate (i.e.,
assume plate is on non-bearing grout). For this condition, the stress-es in the plate were well below the allowable values (11300 psi stress in plate versus allowable of 21,6000 psi which is design basis of 60 percent of 36,000 psi used for A-36 steel).
The fact that the area engineer checked the incorrect block on Section A of APR 1 DG 261-IST had no safety significance.
The error was corrected by revising the hanger sketch to agree with as-built conditions, i.e., bearing grout not required under baseplates.
The inspector examined an additional 1500 anchor placement reports for baseplates which have been installed since October 1983. The check-off blocks pertaining to the need for bearing grout under the baseplate were reviewed on these APRs.
The inspector noted that the block "No" was only checked on approximately 50 of the APRs. Twenty-five of these APRs were for pipe hangers.
The remaining were for door frames and electrical equipment.
Bearing grout was specified (i.e., block "Yes"
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was checked) on the remaining 1450 APRs.
Review of the inspection records for these APRs disclosed that grout had been installed as-required per the APR.
The inspector examined the pipe hanger sketches for the twenty-five hangers relating to the APRs which had the "No" block checked for bearing grout.
This review disclosed a similar problem as that discussed above in that the hanger sketch indicated that grout was required under pipe hanger FP-H-2740 (APR 1 DG 261-231)
while the APR indicated no bearing grout required.
This discrepancy was reanalyzed assuming a gap under the plate (i.e., plate on non--
bearing grout).
The stresses in the plate were less than 1000 psi versus an allowable of 21,6000 psi.
Thus, the error made by the area engineer in checking the incorrect block on APR 1 DG 261-231 had no safety significance.
The error was corrected by revising the hanger sketch to agree with the as-built condition, i.e bearing grout not required under baseplates.
Findings The concern is not substantiated.
Concressive 1411 grout was not used under baseplates which required bearing surface.
Within the areas inspected, no violations or deviations were identified.
7.
Followup On New Concerns Expressed During December 18, 1986 Interview a.
Adequacy of Testing and Engineering Evaluation of Tests Performed on Maxi-Bolts Concern The alleger stated that testing of maxi-bolts which was performed to justify decreasing the minimum undercut tolerances permitted for maxi-bolts was witnessed by a co-op student but signed off by an engineer who did not witness the testing. The alleger also stated that the engineering evaluation, in his opinion, was inadequate.
Discussion The testing performed to justify decreasing the maximum undercut tolerances for maxi-bolts is documented on FCR AS-7744.
The field testing consisted of applying a load to maxi-bolts that had been installed by craft personnel and measuring the deflections under these loads.
The application of the test loads and measurement of the deflections was performed by the discipline engineer responsible for expansion anchors.
Discussions with this engineer disclosed that a co-op student was not involved in these specific tests. However, this individual and other licensee engineers stated that co-op students assisted in other testing, including performing some of the measure-ments.
For these tests, the co-op's role would have been limited to
recording and plotting the test data and not evaluating the data. The evaluation of the test data for FCR AS-7744 was performed by civil engineers in the Harris Project Engineering Section (HPES).
The inspector reviewed the test data attached to the FCR.
This review disclosed that the engineering evaluation performed by HPES was accept-able.
No discrepancies were identified.
Decreasing the minimum undercut tolerances did not result in pullout of the maxi-bolts.
Findings The concern was not substantiated.
Testing of the maxi-bolts was witnessed by the discipline engineer.
The engineering evaluation of the test data was adequate and properly performed.
b.
Unauthorized Substitutions of Embedded Anchor Bolts Concern Since low-strength and high strength anchor bolts purchased for con-struction had identical physical dimensions there was frequent substi-tution of anchor bolt types; especially during 1978, 1979, and 1980 in the waste processing and fuel handling building.
Discussion The licensee identified this problem in nonconformance report DDR-1476 which was written on April 18, 1983.
Construction Inspection was required to verify anchor bolt type; however, only a dimensional check was made to identify anchor bolts with missing or illegible tags.
Therefore, certain anchor bolt types having the same physical dimen-sions but lower material requirements could have been substituted for required high-strength bolts.
Initial random sampling by the licensee indicated some substitution of bolts had accurred. Actions were taken to prevent any further recurrence of the problem.
This included revising technical procedure TP-05 to specifically require material identification as part of the anchor bolt inspection and by collecting and segregating all anchor bolts on the job site that did not have proper markings or tags (CP&L Memorandum MS-12063 and Daniel letter, dated November 15, 1983, to McKay from M. Walton).
The licensee initiated a comprehensive test program to examine the material type of all installed questionable anchor bolts.
Samples of the questionable anchor bolts (obtained by cutting a section off the top of the bolt)
were sent to a materials test laboratory to determine if the bolts used had the structural properties required.
Although substitutions had occurred, subsequent engineering evaluation of the test results and the anchor bolt usage found all bolts to be acceptable as-is.
The inspector examined one of the several metallurgical analyses test reports (PW-C-4846, for anchor bolts installed in the waste processing building) and the subsequent engineering disposition for all the Plant's questionable anchor bolts discussed in PW-C-4196, R.
This nonconformance was reported to the NRC on May 3,1983, as a potential reportable item par the provisions of 10 CFR 50.55(e).
However, after the licensee had completed the testing and analysis of the anchor bolt materials, the licensee concluded that this item was not reportable under 10 CFR 50.55(e).
A metallurgical engineer from Region II examined the licensee's actions taken to resolve this issue (Inspection Report 50-400/86-11), and concurred with licensee conclu-sions that the item had no safety significance and thus was not reportable.
Findings The ( ancern was subs:antiated; however, the licensee identified the problem back in 1983.
Proper corrective action was taken by the licensee to prevent recurrence of the problem.
The metallurgical analysis and engineering evaluation resulted in a disposition that all the unverified anchor bolts installed in the plant had acceptable structural properties that allowed them to remain in place.
This finding has no safety significance, c.
Coatings Used on Emergency Service Water Intake Structure Shear Plates Concern The rampant substitution of materials in areas which were to be under water (discussed in paragraph 6.f. above) resulted in a coatings problem in the Emergency Service Water Intake Structure (ESWIS).
Sometimes steel plates were arbitrarily swapped from other structures and installed in the ESWIS.
These plates did not have the proper
" flake tar" (a coal tar epoxy) coatings on them.
Plates with asphalt tar on them would be substituted regularly for those witti flake tar.
Repaired drill holes in the plates were not recoated or if they were recoated the coatings were not inspected.
Discussion The Harris Plant FSAR states that the project complies with the re-quirements of ANSI N101.4-1972 and endorses Regulatory Guide 1.54 for protective coatings applied to containment surfaces (steel and con-crete) and exposed surfaces of large equipment and pipe installed inside containment.
CP&L defines coatings on systems and components which are installed in the containment structure and which may be exposed to a loss of coolant accident (LOCA) as Class I Service Level, this definition of " Class I Service Level" items is consistent with both ANSI N101.4-1972 and ANSI N101.2-1972.
A rigid QA program is required for the interior surfaces of containment to prevent failure of coatings during a LOCA which could clog up the reactor building sumps serving the containment spray and the emergency core cooling systems.
Additionally, smooth coating surfaces are beneficial in meeting ALARA
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guidelines by providing expeditious decontamination.
Region II has l
performed several inspections of the coatings applied inside
containment,(i.e., the service Level.I coatings).
These inspections t
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are documented in Region II. inspection reports.- ANSI N101.4-1972
i specifies that for Service Level Class II. systems and components quality assurance and/or documentation is not mandatory and shall be
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used only to the extent required by the project specifications. Since
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are applied to provide maximum protection from deterioration and are
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not safety related.
Application of protective coatings in the ESWIS and other areas outside containment is simply a cost-benefit option the i
licensee has chosen.
Therefore, the protective coatings for the Emergency Service Water Intake Structure plate steel are not safety
related.
These coatings are covered by CP&L work procedure WP-52, i
Protective Coating for Service Level II (SL II) and Balance of Plant-
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(80P).
Section 4.10 of this procedure specified that inspection of
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SL II and BOP coatings shall consist of monitoring all coating applica-i tion activities as directed and/or requested by CP&L's Construction Coating Engineer.
The craft foremen and supervisors for SL II and BOP
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coating are responsible for surface preparation and final inspection and documentation of these coatings and all other requirements con-tained in the procedures.
The above coating records are not safety
i related quality records but are kept more for historical purposes and i
assurance that the crafts have completed their work as prescribed.
i Discussions with licensee engineers and QC inspectors disclosed that
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i the coatings engineer requested that QC inspectors examine the coatings on the shear plates in the ESWIS.
These inspections are documented in
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a Field Inspection Report dated March 8,1984, for inspection of
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protective coating for the ESWIS bays No. 6, 8, B and C.
The inspector i
examined this report.
The report summarizes these inspections stating
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that "all items that require protective coatings have been completed and are acceptable as per applicable specifications.
Findings i
The concern was not substantiated.
In addition, the coatings in
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questions are not safety related and there are no regulatory require-ments covering the protective coatings used in the ESWIS.
Coatings l
application in the ESWIS is strictly good practice to prevent advance
deterioration and ar economic consideration.
CP&L's Harris Plant coatings program meets the intent of their commitment to Regulatory
Guide 1.54.
When the NRC Resident Inspectors inspected the ESWIS on
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December 20,1986(InspectionReport 50-400/86-94), they did not report
any findings concerning uncoated plates or the utilization of different
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j coating materials. This item has no safety significance.
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d.
Changes to Procedure WP-33, Installation of the Wedge Expansion Bolt Anchors Concern The alleger stated that in the revision process of procedure WP-33, the procedure was changed practically daily.
He indicated that before the procedure would be revised there would have been ten or fifteen changes made to it before the changes were incorporated into that particular revision.
He indicated that there would be long periods when things were acceptable and then due to an NRC or INP0 findings, or some other person, the procedure would be drastically changed.
Something would change dramatically and nothing would be done about work which had been previously completed.
Discussion The inspectors reviewed all 16 revisions of WP-33, (Revision 0 thru 15).
Review of the revisions showed that WP-33 was revised four times before the first expansion anchor was installed on April 17, 1981.
Review of the remaining revisions showed the following order of revi-sions; Revision 4. August 1981; Revision 5, April 1982, Revision 6, September 1982; Revision 7, October 1983; Revision 8 March 1984; Revision 9, October 1984; Revision 10, May 1985; Revision 11, September 1985; Revision 12, January 1986; Revision 13, May 1986; Revision 14, July 1986; and Revision 15, October 1986.
Review of the various revisions showed that changes were made to the procedures before the next revision.
These changes were documented on exhibits designated as a Procedure Change Notice (PCN).
Review of procedure revisions showed that the number of PCN's varied for the most part from one to 12 PCNs with only Revision 6 having 21 PCNs.
Review of the revisions and attached procedure change notices showed that the purpose of these revisions and procedure change notices was to clarify require-ments for installation of the expansion anchors. The procedura change notices were attached to the procedures before the next revision because it was not practical to issue a revision everytime a clarifi-cation was needed.
Procedure change notices to procedures is a common practice and is not a violation of NRC regulations.
No evidence was found that changes were made to the procedures daily as stated by the December 18 interview.
Finding Review of WP-33 showed that 16 revisions were made to WP-33 and that procedure change notices were made to these revisions.
The revisions and procedure changes were made to clarify installation requirements.
Changes to procedures by a PCN prior to the next revision is a common practice and is not a violation of NRC regulations.
No evidence of a PCN being made to the procedure on a daily basis was identified.
Review of the changes made to the procedures showed that the changes were appropriate. The concern was not substantiate.
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e.
Use of Concressive 1411 Grout Inside Containment Concern The alleger stated that he was concerned with the use of Concressive 1411 epoxy grout inside containment since the epoxy grout is affected by heat. He stated that the epoxy grout was used to repair abandoned drill holes and under baseplates which had bearing surfaces for incore instrumentation supports under the reactor vessel.
Discussion Review of procedures WP-33, WP-42, and TP-39 disclosed that concressive was not used prior to issuance of procedure deviation notice (PDN) 2 to Revision 5 of WP-33 on May 6,1982.
This PDN, which was issued as a result of approval by design engineering of field change request (FCR)
C-3100, permitted use of Concressive 1411 for repair of unused drill holes in concrete in all areas on the project except for inside the containment primary shield wall between elevations 236 and 249. Review of all the revisions to the above listed procedure disclosed that concressive was not permitted to be used under baseplates inside containment.
Review of the anchor placement reports for anchors installed inside containment disclosed that concressive was not used under baseplates installed inside containment.
The use of epoxy materials inside containment was addressed in the licensee's response to IE Information Notice (IEN) 83-40, Need to Environmentally Qualify Epoxy Grouts and Sealers.
This response is sumarized in EBASCO letter dated March 27, 1984, Subject:
I&E Infor-mation Notice 83-40.
In addition, the use of epoxy compounds inside containment was the subject of a QA surveillance report conducted by a licensee civil QA specialist in July 1983, in response to IEN 83-40.
As a result of this surveillance report, DDR 1789 was issued due to the fact that documenting evidence (quality records) was not available onsite to demonstrate that design basis accident (DBA) testing had been performed on the Concressive 1411 epoxies used for repairs to drill holes inside containment.
This data was provided with the EBASCO March 27, 1984 letter. The EBASCO letter stated that the 1411 grout is considered to be used for nonstructural applications. The patching of expansion anchor drill holes and filling of fine cracks and surface irregularities on concrete surfaces are considered cosmetic repairs.
Findings This concern was previously addressed by the licensee in response to IEN 83-40.
The concern was evaluated previously and has no safety significanc.
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Grouting of the Intake Structure Gate Guides Concern t
The alleger stated that there were problems when the gate guides were
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grouted. However, the alleger did not provide any specific information as to what the problems were.
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Discussion b
The inspector was unable to determine what hardware the alleger was specifically referring to when he stated the above concern.
Discus-sions with licensee engineers and review of construction drawings
disclosed that the gate guides were embedded in the concrete prior to the concrete placement. Discussions with licensee engineers and review of records disclosed that no grouting was required for the gate guides.
i However, the inspectors noted that grouting was required for the shearplates discussed in the 2.206 petition.
Review of the grouting records for the shearplates disclosed that various types of problems
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were encountered during grouting operations.
However, these problems i
were typical of those often encountered during grouting and the records
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indicated the problems were corrected in accordance with licensee
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procedures and acceptable engineering practices.
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Findings i
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The stated concern was nonspecific and was not substantiated. The gate guides were not grouted as stated in the concern.
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Conclusions i
Of the fourteen concerns examined, two were substantiated and one was
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partially substantiated.
One of the substantiated concerns (paragraph 7.b)
The was previously identified and corrected by)the licensee's QA program.
other substantiated concern (paragraph 6.a was simply a statement of fact
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and'does not represent a violation of licensee procedures or NRC require-j ments.
The partially substantiated concern (paragraph 6.b) has no safety significance.
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Within the areas inspected, no deviations or violations were identified.
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