IR 05000410/1982001
| ML20042B450 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/10/1982 |
| From: | Kister H, Schulz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B446 | List: |
| References | |
| 50-410-82-01, 50-410-82-1, NUDOCS 8203250326 | |
| Download: ML20042B450 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION Region I Report No.
82-01
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Docket No.
50-410 A
License No.
CPPR-112 Priority Category
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Licensee: Niagara Mohawk Power Corporation 300 Erie Boulevard West Syracuse, New York 13202 Facility Name: Nine Mile Point, Unit 2 Inspection at: Scriba, New York Inspection conducted: January 18, 1982 to February 26, 1982 Inspectors:
'M.,0 fcI<d 9[J//Z-
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R. D. Schulz, R sident inspector
' date signed date signed date signed
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Approved by:
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U if. 8. KisterNhief, Reactor Projects
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l Inspection Summary:
Inspection on January 18, 1982 to February 26,1982 (Report No. 50-410/82-01)
Areas Inspected: Routine inspection by the resident inspector of work activities relative to whip restraint supports, structural steel heat treatment, structural steel welder qualification, structural steel nondestructive examination, piping welding procedure qualifications, safety related piping, nonconformance and disposition reports, and procurement. The inspector also performed plant inspection tours and reviewed licensee action on previously identified items. The inspection involved 88 inspector hours.
Results: Of the eight areas inspected, one violation was identified in each of the two following areas:
Failure to establish a training program and maintain training records (paragraph Sc) and Failure to follow instructions concerning pre-heat control (paragraph 6).
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Dan {nn I Form 17 8203250326 820311 PDR ADOCK 05000410
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DETAILS 1.
Persons Contacted Niagara Mohawk Power Corporation J. L. Dillon, Q.' C. Engineer, Site Lead R. A. Norman, Q. A. Supervisor R. Spencer. Q. A. Inspector J. Swenszkowski, Assoc. Q. A. Technician G. J. Doyle, Q. A. Technician E. Manning, Q. A. Technician P. E. Francisco, Nuclear Licensing Engineer J. P. Ptak, Manaqer of Construction, Site M. S. Dunlop. Q. A. Technician Stone & Webster Engineering Corporation J. Crytzer, Q. C. Senior Engineer G. Pierce, Site Q. C. Supervisor R. Kelvin, Senior Q. C. Engineer T. Dean, Senior Q. C. Inspector J. P. Jones, Q. C. Engineer
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R. Huggon, Q. C. Engineer R. Hardison, Q. C. Engineer B. L. Holsinger, Q. A. Engineer C. Sperling, Senior Material Controller B. Poythress, Material Manager J. C. Thompson, Superintendent of Field Q. C.
E. A. Magilley, Assistant Superintendent Field Q. C.
S. W. Crowe, Assistant Superintendent Field Q. C.
A. E. Perley, Construction Supervisor Chicago Bridge & Iron T. Dougherty, Welding and Q. A. Superintendent C. Hall, Construction Superintendent ITT Grinnell Industrial Piping, Inc.
M. E. Poissant, Q. C. Engineer D. R. Giguere, Q. C. Manager R. Graiko, Senior Project Engineer D. L. Grodi, Inspection Supervisor L. Pela, Technical Supervisor D. Giguere, Jr., Welding Technician J. L. VanWie, Lead Engineer J. Thompson, Engineer C. Kuk, Q. C. Technician Cives Steel Corporation K. Williams, Assistant Field Administrator C. Robbins, General Foreman
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2.
Plant Tours The inspector observed work activities in-progress, completed work and plant status in several areas during general inspections of the plant.
The inspector interviewed craft personnel, supervision, and quality inspection personnel such as personnel were available in the work areas.
Within the past month there has been a significant amount of piping moved into the primary containment. The inspector observed adequate handling and rigging techniques with regards to protection of end details and workmanlike practices to prevent damage, as pipe was transferred into the primary containment.
Storage, within both the primary and secondary containment areas, needs improvement as materials and equipment stored within these areas, in many cases, is not positioned so that it will not be damaged by construction activity. The inspector observed instances where pipe was used to support metal ladders, structural steel items were placed on top of piping components, and pipe spools were positioned in doorway entrances. Poor housekeeping at the bottom of the suppression pool a s noted as trash was deposited on various areas of the floor and the 1/8" stainless steel plate, which was stored on the floor by Chicago Bridge & Iron, was covered with water, in contact with carbon steel items, positioned so that it could easily be damaged by construction activity, and used to support grating.
Improper storage of the stainless steel plate which is being used to cover the bottom of the suppression pool and had previously been damaged, was also noted in inspection repnrt 410/81-14. The poor storage conditions for the 1/8" stainless steel plate was once again promptly corrected after notification by the inspector. The licensee was informed that overall housekeeping and storage standards for the control of work activities, conditions, and environments that may affect the quality of important parts of a nuclear power plant during the construction phase, as stated in ANSI N45.2.3,1973, requires increased surveillance.
Specifically, the inspector observed welding and grinding on 18" residual heat removal piping in the north auxiliary bay and secondary containment, pre-heat control for 24" service water piping in the secondary containment, welding of 16" and 4" residual heat removal piping in the secondary containment, welding of 6" reactor core isolating cooling piping in the secondary containment, and welding of 12" residual heat removal piping in the suppression pool.
In addition, the inspector examined work in progress regarding removing temporary attachments to the primary containment steel liner. The inspector toured the suppression pool floor and observed the curing of concrete pour 1-122-078P at elevation 175', covering half of the suppression pool.
The concrete was wet and covered with burlap, and inspection records indicated compliance with ACI temperature parameters. After the concrete completed its curing period, the inspector observed work in progress by Chicago Bridge & Iron, which involved placing and welding 1/8" 304L stainless steel plate over the concrete with attachments to embeds.in the reactor pedestal, quencher support embeds, liner embeds and embeds in the floor of the suppression poo.
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No violations or deviations were identified.
3.
Licensee Action on Previous Inspection Findings and Part 21 Items a.
(Closed) UNRESOLVED (81-07-02):
Clarification of the electrical installation specification regarding holes in cable tray side rails.
Engineering evaluation determined that cable tray strength is not affected when a lug hole occurs underneath a splice plate.
Furthermore, it was determined that field drilled holes close to support points is a better practice, but not mandatory and not a restriction invoked by the manufacturer. The specification has been revised to reflect these engineering determinations.
b.
(Closed) VIOLATION, SEVERITY LEVEL V (81-12-03):
Incorrect completed documentation of unprocessed spool pieces.
ITT Grinnell revised procedure FQC-4.1-3-7, Weld Data Report Instruction for Inprocess Inspectors, requiring welding inspectors to verify spool piece numbers being joined or heat numbers as applicable, by initialling the identification markings on the weld data report. The inspector verified this documented identification by examining numerous weld data reports in the field.
In addition, the inspector examined ITT Grinnell records concerning their audit of all safety related welds, for assurance that welds were complete as documented.
c.
(Closed) VIOLATION, SEVERITY LEVEL V (81-12-04): Nonconformances concerning concrete curing and corrective action. The following corrective actions have been taken by the licensee thru Stone & Webster:
(1)
Increased quality control surveillance from the program required four inspections per week to two to four inspection per pour.
(2)
Increased Walsh Construction Company surveillances from twice a day during the regular shift to three times per day, at least six hours apart, including weekends.
(3) Verified adequate training has been given to applicable personnel.
(4)
Instituted short term trending (weekly) for concrete curing nonconformances.
As a result of the corrective action measures, it has been determined that concrete curing nonconformances have been reduced, taking into account ratio of inspections per nonconformance.
Inspections of concrete curing are now in accordance with ANSI N45 2.5-1974.
d.
(Closed) PART 21 (81-88-01): Electrical separation for PGCC-HPCI and RCIC Isolation. Nine Mile Point, Unit 2 has a diesel powered HPCS and not a steam powered HPCI. Therefore, a problem involving separation of HPCI and RCIC steam line isolation valves would not be applicable to Nine Mile Point, Unit.
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e.
(Closed) PART 21 (81-88-02): Defect in instrument cable. The instrument cable is not applicable to Nine Mile Point, Unit 2 but to Nine. Mile Point, Unit 1, Unit 2 is not using coaxial cable.
4.
Licensee Action on Bulletins and Circulars The inspector examined records and interviewed licensee personnel to verify action taken with respect to IE Circulars.
For each Circular shown below, the inspector verified that the identified prc,blem was resolved as indicated:
(Closed) CIRCULAR 80-18, Safety Evaluations for Changes to Radioactive Waste Treatment Systems.
(Closed) CIRCULAR 78-18, Vertical Cable Tray Fire Test.
(Closed) CIRCULAR 80-02, Nuclear Power Plant Staff Work Hours.
(Closed) CIRCULAR 80-07, Problems With HPCI Turbine Oil System.
(Closed) CIRCUL AR 80-09, Problems With Plant Internal Communication System.
(Closed) CIRCULAR 80-12, Valve-Shaft-To-Actuator Key May Fall Out of Place When Mounted Below Horizontal Axis.
(Closed) CIRCULAR 81-08, Foundation Materials.
5.
Whip Restraint Supports a.
Procedures and Records The inspector reviewed ITT Grinnell procedures and records to ascertain that whip restraint supports were installed in accordance with applicable licensee and regulatory requirements. The following were included in the inspectors review:
P30lX-ITT-G1, Revision 1, dated November 24, 1981, Installation of
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Pipe Rupture Restraints and Restraint Structures, Erection Procedure.
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P30lX-ITT-G2, Revision 0, dated July 31, 1981 Installation of Pipe Rupture Restraints and Restraint Structures, Pre-heat Procedure.
FQCR-4.2-31.0, dated July 31, 1981, Visual Weld Inspection.
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FQCR-6.1-31-0, dated July 31, 1981, NDE Listing.
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FQCR-4.1-31-0, dated August 11, 1981, Material Identification and
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Control.
FQCR-4.2-32-0, dated July 31, 1981, Field Cleaning.
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Field Planner and Control Reports
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Weld Data Reports
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Item Identification Checklists
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Pre-heat Records
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Magnetic Particle Reports The inspector discovered that an inspection program, consistent with the schedule for accomplishing the activity, has not been established to verify conformance with ITT Grinnell installation procedures and approved drawings for installed pipe whip restraint supports.
In addition, ITT Grinnell was using an unapproved restraint structure inspection record (weld data report), which did not verify
conformance with the Stone & Webster approved visual weld inspection procedure and the ITT Grinnell welding inspectors had erroneously marked for identification restraint structure pre-heat inspection records, which did not verify conformance with field planner instructions. The incorrectly marked pre-heat inspection records were for cantilever restraint supports MSS-PRS-032 and RHS-PRS-003.
Pending review by Niagara Mohawk and Stone & Webster of the whip restraint inspection program and NRC evaluation of any further licensee corrective action, if required, this item is unresolved.
(410/82-01-01)
b.
Observation of Work The inspector observed work in progress and completed work on the following whip restraint support structures:
Identification Number Location Type _
RCS-PRS-034 Primary Containment Cantilever RCS-PRS-036 Primary Containment Cantilever RCS-PRS-007 Primary Containment Pin RHS-PRS-002 Primary Containment Pin Craft personnel were interviewed concerning installation procedure requirements.
Interviewees appeared knowledgeable in erection procedures.
c.
Training The inspector questioned ITT Grinnell engineering personnel who have the responsibility of filling out field planners regarding pre-heat requirements for whip restraint supports. The engineers appeared uncertain of code and procedural specifications for pre-heat temperature requirements.
Subsequently, the inspector investigated the training program and requested training records on all engineering personnel
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associated with whip restraint installations. The inspector discovered that there were no training records on the field engineer, piping engineer or pipe restraint project engineer.
The pipe restraint project engineer was no longer employed in that position, having been transferred over to a production assignment.
In addition, a training program had not been established by either the Field Quality Control Manager or the Department Supervisor to assure that engineering personnel were proficient _in their respective activities concerning whip restraint supports.
Lack of a training program is contrary to 10CFR50, Appendix B, Criterion II and the ITT Grinnell Quality Assurance Manual. This is a violation.
(410/82-01-02)
6.
Heat Treatment - Structural Steel The inspector reviewed heat treatment procedures to verify whether these procedures specified acceptable pre-heating methods, provided requirements for monitoring and recording pre-heat temperature before, during and if specified post heating temperatures after welding. Weld data reports for various structural steel welds made by Cives Steel Corporation were examined for heat treatment documentation, including beam seats, gussets, and other plate attachments to biological shield wall overlays. Work in progress was observed concerning pre-heating of whip restraint structural weld areas to biological shield wall overlays.
During the pre-heating the inspector observed that neither thermocouples or pyrometers were being used for pre-heat control.
Subsequently, it was confirmed with Stone & Webster construction personnel and quality control personnel that tempilsticks have been used instead of thermocouples or pyrometers on numerous occasions for pre-heat control. This was verified by examining weld data reports which documented the use of tempilsticks for pre-heat control.
Upon further investigation, the inspector discovered that the following specifications require the use of pyrometers or thermocouples for pre-heat control:
Specification P301X, Installation of Pipe Rupture Restraint and
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Restraint Structures; states in CP-3, dated January 13, 1982, paragraph 4.2.2, "The primary control of pre-heat shall be with calibrated thermocouples or pyrometers. A minimum of one (1)
thermocouple or contact pyrometer shall be placed on each weld area as defined in 4.3 (at about midlength of the weld)."
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Specification S204X, Erection of Structural and Miscellaneous Steel Category I, Revision 2, dated June 27, 1981 states in part, "The primary source of pre-heat control shall be calibrated contact pyrometers or thermocouples."
Specification S204X; E&DCR No. P00944, dated September 19, 1981,
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states in part, "The primary source of pre-heat control shall be calibrated contact pyrometers or thermocouples."
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Contrary to the above specification instructions and 10CFR50, Appendix B, Criterion V, the following welds did not use thermocouples or pyrometers for pre-heat control:
(1) Whip restraint structural welds to biological shield wall overlays, FW-PRS-008-WR 184 and WR 185.
(2) Structural steel welds greater than 1 inch, FP6, FP11, FP13, RB166 and RB165.
(3) Overlay to the biological shield wall, OB07.
This is a violation.
(410/82-01-03)
For connections to the biological shield wall, specifications also require that a post heating temperature of 2250F be maintained for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after 'he weld area has been completed.
Stone & Webster's inspection program calls
- random inspections regarding post heating.
Records indicated only c..a out of approximately thirty-eight welds requiring post heating had been inspected by Stone & Webster quality control personnel for post heating temperature maintenance. This item will remain unresolved pending review by Niagara Mohawk and Stone & Webster of the adequacy of the post heating inspection program and NRC evaluation of any further licensee corrective action, if required.
(410/82-01-04)
7.
Welder Qualification - Structural Steel The inspector reviewed welder qualification records in order to determine that welders were qualified with regard to the requirements in the following documents:
(1) Stone & Webster Welder Performance Qualification Methods Manual.
(2) AWS Dl.1, Section 5, Part C, 1977.
(3) QS 9.31, Welder / Welding Operator Qualification.
(4) QAD 9.2, Welder / Welding Operator Qualification Inspection.
Specifically, the following welders records were examined: qualification test records, history logs, weekly qualification lists, and quality control checklists verifying welders qualification tests.
In' addition, welding records on numerous joints were reviewed in order to determine that the welding was done by personnel who were qualified for that given process.
The inspector discovered that the qualified welder's list, which was used by quality control for verification that welders were qualified in the given process that had been used for welding, was not approved by quality assurance or quality control personnel. The list is generated by production personnel every four to six weeks. The licensee stated to the inspector that prior to future issuances of the qualified welders list, the document l
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will be reviewed and approved for accuracy by quality control personnel.
This issue will remain open for verification of document approval by quality control.
(410/82-01-05)
No violations or deviations were identified.
8.
Structural Steel Nondestructive Examination a.
Procedures Reviewed, The magnetic particle procedures were reviewed for procedure and technique in compliance with ASTM E-109 and acceptance standards in compliance with AWS D1.1, paragraph 8.15, as stipulated in specification S-204X, Erection of Structural and Miscellaneous Steel Category I, dated June 27, 1981. The liquid penetrant procedures were reviewed for method and techniga in compliance with ASME Boiler and Pressure Vessel Code,Section V, Article 6 and acceptance standards in compliance with ASME Boiler and Pressure Vessel Code,Section VIII as stipulated in P-283V, Shop Fabrication and Field Erection of Refueling Liners, dated September 2,1981.
b.
Records Reviewed / Storage of Penetrant Materials The inspector reviewed numerous magnetic particle records for structural steel welds in the following categories:
(1) Temporary attachments welded to permanent members.
(2) Welds attaching structural steel to the pedestal embedment plates.
(3) Welds greater than 1 inch.'
In addition, the inspector reviewed numerous liquid penetrant records for temporary attechments welded to the fuel pool liner. Certifications were examined for magnetic particle powder and penetrant-developer-cleaner furnished by Magnaflux. The reports met the specification requirements, including the residual sulphur and halogen contents.
Storage of the liquid penetrant material was adequately controlled, taking into consideration its flammable nature.
Personnel performing magnetic particle and liquid penetrant tests were qualified in accordance with SNT-TC-1A.
No violations or deviations were identified.
9.
Piping Welding Procedure Qualifications The inspector examined ITT Grinnell Welding procedure specifications and procedure qualification records to verify compliance with ASME Boiler and Pressure Vessel Code,Section IX, Article II, 1974 and the ITT Grinnell ASME Section III, Quality Assurance Manual. The procedure qualification records documented the essential variables of the specific welding process
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and the type and numbers of test specimens for mechanical tests were in accordance with QW-451 of Section IX. The following welding procedure specifications and associated procedure qualification records were reviewed:
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Welding Procedure ~#
PQR #
Process 1 -1 -1 -7 14690 GTAW/SMAW - (impact tests)
1-4-2-2 T-21655-A~
GTAW (Insert)
1-4-2-2 T-21654-B GTAW(Butt)
4-4-3-9 14425 GTAW (0 pen Root)
8-1-7-7 14532 SMAW No violations or deviations were identified.
10.
Safety Related Piping - Observation of Work Actual welding conditions and conduct, the sequence of operations, and the use and documentation of weldin'3 materials were spot-checked. The inspector noted the presence or availability of Q. C. welding inspectors and checked their inspection verification of hold point items on the weld data sheets. The welders symbol was noted to be marked adjacent to each weld on the applicable spool piece. Welding was evaluated in accordance with ASME Boiler and Pressure Vessel Code,Section IX and alignment was evaluated in accordance with ASME Boiler and Pressure Vessel Code,Section III.
Specifically, the inspector observed end preparation, pre-weld cleanliness, pre-heat control, alignment, root pass, and final visual on the following systems:
24" Service Water Piping - Secondary Containment
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4" Service Water Piping - Control Room Building 3" Service Water Piping - Secondary Containment
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12" Residual Heat Removal Piping - Suppression Pool
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6" Reactor Core Isolation Cooling Piping - Secondary containment
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6" Chilled Water Piping - Control Room Building 20" Low Pressure Core Spray Piping - North Auxiliary Day
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In addition, the inspector examined a weld on a 12" service water line in the turbine pipe tunnel which had been ground and rewelded due to porosity. Service Water and Chilled Water were classified ASME Section III, Class 3,' and the remaining systems were classified ASME Section III, Class 2.
No violations or deviations were identified.
11. Nonconformance and Disposition Reports
The inspector reviewed Stone & Webster nonconformance and disposition l
reports for the month of January in order to determine the adequacy of disposition details and that measures had been implemented to control nonconforming material.
Stone & Webster personnel found that hanger components stored in the fab shop (numerous U bolts, nuts and clamps), were not identified to provide traceability in accordance with ASME Boiler and Pressure Vessel Code,Section III, NF-2150. This was discovered during a storage inspection and was documented on Nonconformance and Disposition Report #2858. However, on a subsequent inspection by the resident inspector, it was discovered that the material had not been placed on hold or segregated to prevent installation. Upon questioning Stone & Webster personnel, it was learned that the lack of traceability also involved previously installed material and would be addressed as a generic site problem. The inspector pointed out that this generic problem should be stated in a nonconformance report addressing the installed material. Also, controls should be documented and implemented to prevent further installations. The resolution of this problem will be reviewed in a future inspection period.
(410/82-01-06)
No violations or deviations were identified.
12.
Procurement The inspector reviewed eight safety related procurement documents for technical adequacy, QA program requirements, 10CFR21 provisions, specific identification of items, and that the orders were placed in accordance with the provisions of the approved suppliers list. The inspector discovered, during a review of three similar purchase orders to Interstate Steel, that only one of the orders required that all material be furnished under a Quality Assurance Program which meets the intent of 10CFR50, Appendix B.
Purchase order FP0-11844 included the 10CFR50, Appendix B applicability statement, while purchase orders FP0-13247A and FP0-12550 did not reference 10CFR50, Appendix B or any quality assurance program statements.
Furthermore, the approved vendors list had a stipulation that for orders placed with Interstate Steel, the furnished material must be purchased from an ASME material manufacturer, material supplier or customer approved source. This requirement was not stated in any of the above mentioned purchase orders. Pending clarification of the application of 10CFR50, Appendix B statements to purchase orders and licensee justification for not including the approved vendors list
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stipulation statement in purchase orders to Interstate Steel, this item is unresolved.
(410/82-01-07)
13. Management Meetings At periodic intervals during the course of this inspection, meetings were held with senior plant management to discuss the scope and findings of this inspection. The licensee acknowledged the inspectors findings and concerns, and all parties were cooperative.
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