IR 05000416/1978015
| ML19269C059 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/22/1978 |
| From: | Alderson E, Conlon T, Crowley B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19269C052 | List: |
| References | |
| 50-416-78-15, 50-417-78-15, NUDOCS 7901190259 | |
| Download: ML19269C059 (31) | |
Text
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UNITED STATES
/ sk* "E Guq[o Nt8 CLEAR HEGULATORY COMMISSION g
REGION II
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101 M ARIETT A sT R E ET. N.W.
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ATLANTA, GEORGIA 30303
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15 SUBJECT: Mississippi Power and Light Company Grand Gulf Nuclear Stetion Units 1 and 2 Docket Nos. 50-416 and 50-417 Allegations that the ASME code was violated in fabrication and installation of safety-related piping assemblies and that no corrective action was taken when the violations were pointed out.
Period of Investigation: September 18-22 and October 10-13, 1978 II 22 M Investigator
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E. Alderson, Registial 15vestigator Date B.R.Crowley,MetallurpcalEngineer
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Date Engineering Support Section No. 2 Reactor Construction and Engineering Support Branch Revir.'ed bf7
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T. E. Conlon, Chief, Engineering Support Section No. 2 Date Reactor Construction and Engineering Support Branch
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TABLE OF CONTENTS
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I.
INTRODUCTION II.
SCOPE OF INVESTIGATION III.
CONCLUSIONS IV.
DETAILS OF INVESTIGATION A.
Persons Contacted B.
Allegations, Discussions and Findings C.
Followup on Discrepancies Noted by ASME National Board Investigator
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o
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-1-i I.
INTRODUCTION l
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An individual wrote a letter to the Executive Director of the National Board of Boiler Inspectors alleging that he had observed several uncorrected violations of the ASME Boiler and Pressure Vessel Code at Mississippi Power and Light Company's Grand Gulf Nuclear Station.
A copy of this letter was also sent to the Nuclear Regulatory Commission by the alleger.
The allegations contained in this letter were somewhat vague and general in nature and the Office of Inspection and Enforcement, Region II began its investigation on September 18, 1978, by interviewing the alleger to obtain more specific information. As a result of this interview the investigators were able to identify seven specific allegations as follows:
A.
Unidentified materials had been fusion welded to code class piping.
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B.
Nondestructive examination procedures used at Grand Gulf had not been demonstrated to the Authorized Nuclear Inspector.
C.
Weld filler material was not properly controlled at the job site.
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D.
Chlorinated water was being used for hydrostatic testing of austenitic steel pipe in violation of the ASME Code, 1974 Edition.
E.
Socket weld fitup inspections were not being performed in the manner required.
F.
The problems identified in allegations A-E above were identi-fied to Bechtel and Kemper personnel, but no corrective action was ever taken.
G.
Material not meeting purchase specifications may have been supplied by Bristol Steel's Plant No. 3 and accepted by Bechtel for use in safety-related components, systems or structures.
Having determined the specific allegations, an investigation was conducted at the Grand Gulf job-site and Bechtel's Vicksburg Fabrication Shop during the period September 19-22, 1978. Certain records not available at the job-site were made available and reviewed by the investigators at Kemper Insurance Company's office in Atlanta, Georgia on October 3, 1978.
Subsequently, additional on-site investigation was conducted on October 10-13, 1978. The investigation also included telephone interviews and discussions
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IE Investigation Report Nos. 50-416/78-15 sud 50-417/78-15-2-with various Kemper employees during the period September 26, 1978 through October 6, 1978.
This investigation was conducted under the authority provided by Part 1.64, Title 10, Code of Federal Regulations.
II.
SCOPE OF INVESTIGATION The scope of the investigation included the following:
A.
Interview with the alleger.
B.
Review of the ASME Boiler and Pressure Vessel Code, 1974 Edition and Bechtel procedures for implementing the code requirements applicable to the investigation.
C.
Interviews with present and former employees of Mississippi Power and Light, Bechtel and Kemper Insurance Company.
D.
Field inspection of records and observation of work in progress at the Grand Gulf site and Bechtel's Vicksburg Fabrication Shop.
E.
Review of the ASME National Board of Investig,ators' report and followup of discrepancies identified in the report.
III.
CONCLUSIONS The investigation disclosed that of the seven allegations, five allegations (C-G) were not substantiated. Two allegations (A and B) were substantiated and allegation B resulted in an item of noncompliance.
Two additional items of noncompliance and one unresolved item were identified during the course of the investigation.
IV.
DETAILS OF INVESTIGATION A.
Persons Contacted In addition to the alleger, the following individuals were contacted:
1.
Mississippi Power and Light Company (MP&L)
a.
T. E. Reaves, Jr., Manager of QA b.
P. W. Sly, QA Field Supervisor c.
S. F. Tanner, QA Representative d.
D. D. Little, QA Representative
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IE Investigation Report Nos. 50-416.'78-15 and 50-417/78-15-3-2.
Bechtel Power Corporatidn (Bechtel)
E a.
D. M. Lake, Field Construction Manager b.
R. L. Scott, Project QA Manager c.
T. W. Habermas, Project Field Engineer d.
J. H. McCarty, Project Field QC Engineer Dave Trapold, Gaithersburg Division Supplier e.
Quality Manager f.
D. W. Strohman, QA Engineer g.
W. A. Phillips, Lead Welding QC Engineer h.
A. S. Bettencourt, QA Engineer, Welding and NDE i.
J. R. Valdez, QA Engineer, Piping and Instrumentation j.
W. J. Mercer, General Superintendent k.
D. L. Bridges, QC Supervisor, Fab Shop 1.
B. J. Neal, QC Welding Engineer m.
G. A. Steen, Pipefitter Foreman n.
L. Payne, QC Welding Engineer o.
W. Kimmel, QC Welding Engineer 3.
Kemper Insurance Company (Kemper)
a.
R. Muise, Manager, Special Inspection Services b.
H. Benford, Division hanager, Special Inspection Services Section c.
D. Tevis, Nuclear Inspection Supervisor d.
R. McAfee, Authorized Inpsector (Lubbock, Texas)
L. T. Willey, Regional Manager, Special Inspection e.
Services Section f.
H. Williams, Authorized Nuclear Inspector g.
S. Clinton, Division Loss Control Officer (Atlanta, Georgia)
h.
W. MacSorely, Authorized Nuclear Inspector B.
Allegations, Discussions and Findings 1.
Allegation:
Unidentified materials were fusion welded to code class' piping for use as line-up lugs in violation of the requirements of paragraphs NB-4231, NC-4231, and ND-4231 of Section Ill of the ASME Boiler and Pressure Vessel Code, 1974 Edition.
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-4-
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Discussion:
The investigators examined:Lhe licensee's requirements and work practices for the control of temporary attachments.
This examination included the following:
a.
Review of Applicable Code and Procedure Requirements The ASME Code requirements for the control of temporary attachments are found in paragraphs 4231.2 and 4435 of the various subsections of Section III of the 1974 Code.
In suma ry, these paragraphs require:
the material be identified, suitable for welding, and compatible for welding to the base material; the welding material be compatible with the base material and certified; the welder and welding procedure be qualified; the immediate area around the attachment be identified for inspection; the attachment be
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completely removed; the removal areas be inspected and the weld or removal area be post weld heat treated where applicable.
The licensee requirements for implementing the Code are specified in: (1) Bechtel Quality Assurance Manual, ASME III, Nuclear Components, Division I (BQAM); (2) Bechtel Specification No.
9654-M-204.0; and (3) the applicable general welding specification.
In addition to these three documents, Bechtel Information Bulletin W-026, which more clearly defines the above ASME code requirements, had been issued. These four documents clearly define the code requirements, but without the Bulletin the requirements are not clearly defined. The investi-gator questioned the use of the Bulletin for this purpose since it is not a controlled document within the QA program.
The licensee agreed to
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-5-consider adding the c{htents of the Bulletin to a controDed document such as the QC Instruction Manual.
b.
Observation of In-process Work The investigators observed the following in process field welding (W).
(1) W 5 and W 28 on ISO FSK-P-195-M001-0-C were observed in the fitup stage with temporary attachments in the form of spacer blocks welded to the pipes at the joint. The spacer blocks were identified as required
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by procedures. The pipe alignruent jacking arrangement that jig, a did not require welding to the pipe, was still in place. Also the VR-6 forms, which are used to document temporary attachment welding, were reviewed.
(2)
In process fitup of W 15 on ISO M-1328F and W 20 on ISO M-1348F were obse rved.
Line-up clamps which do not require welding to the pipe were used for alignment.
The VR-6 forms which document filler material and welder were reviewed.
(3) W 98 on ISO M-1348E was observed during root pass welding. There was, no evidence that temporary atta,chments had been welded to the pipe.
The QC inspector stated that a line-up ring clamp was used for fitup.
The WR-5 and WR-6 forms were reviewed.
c.
The investigator interviewed pipe-fitter foresen and pipefitting QC personnel. All personnel interviewed were knowledgable of temporary attachment
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-6-procedural requiremente. The inter-viewees stated:
that tempora ry welded attachments are' avoided where possible; in most cases line-up ring clamps are used for alignment; where alignment or fitup requires lugs to be welded to the pipe, then that material must be identified.
d.
The investigators reviewed MP&L Quality Action Item (QAI) No. 93 and Bechtel Funconformance Report (NCR),
both dated 3/18/77, which were written to document a case where a "C" clamp (unidentified material)
had been welded to Code piping in violation of Code requirements.
The QAI was issued to cover a program deficiency
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and corrective action on the QAI was signed off as being complete on 4/29/77.
I.a t e r, Bechtel determined by chemical analysis that the
"C" clamp in question was a suitable attachment. However, it was decided to discontinue the use of "C" clamps for economic reasons.
It should be noted that the Information Bulletin referenced in paragraph a.
above was issued on 4/4/77 af ter the
"C" clamp problem was identified.
Findings:
This allegation was substantiated, however timely corrective action was taken and the code noncompliance did not result in activities which affected safety.
The incorporation of Bulletin W-026 into a QA Controlled Procedure will be identified as inspector follbwup item 416/417/78-15-01.
2.
Allegation:
Nondestructive examination (NDE) procedures used at the Grand Gulf job-site and Bechtel's Vicksburg fabrication shop were not demon-strated to an Authorized Nuclear Inspector (ANI) in accordance with the requirements of paragraphs NB-5112, NC-5112 and ND-5112 of Section III of the ASME Code, 1974 Editio.
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78 15-7-
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Discussion:
The investigators examined Cede requirements and practices in effect at 4 rand Gulf for demonstration of NDE procedures to the ANI. It should be noted that the same NDE procedures used at the Grand Gulf site are used at the Vicksburg fabrication shop.
This examination included the following:
a.
Review of Code Requirements The requirements for demonstration of NDE procedures are found in paragraph 5112 of the various subsections of Section III of the 1974 ASME Code.
This paragraph requires that "All nondestructive examinations performed under this Subsection shall be executed in accordance with detailed written
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procedures which have been proven by actual demonstration to the satisfaction of the Inspector."
Kemper management personnel stated that they interpret the code to mean that NDE procedures must be demon-
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strated to the ANI prior to use on Code work.
b.
Review of Practices in Effect at Grand Gulf The investigators reviewed the site records for demonstration of NDE procedures.
These records consisted of two letters from the ANI to the
"ASME Interface."
One letter dated 4/7/77, covered procedures LT-VB-1,2 (Vacuum Box), MT-P-1-2 (MT), PT-SR-1-2 (PT), RT-XG (RT) and VE-BPC-2 (Visual).
The other letter dated 4/22/77, covered procedure MT-Y-1,2 (tfT ).
Review of the ANI's Log, and dis-cussions with licensee and ANI personnel revealed that the above procedures were used on ASME Code,Section III, work prior to the date of demonstration indicated in the
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-8-
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above letters.
In a%dition, the licensee readily admil.ted that UT procedure UT-PE-1,
" Ultrasonic Examination" had recently been used for inspection of Unit 1 electrical penetrations.
These penetrations were welded to ASME Code,Section III.
The ANI stated that this procedure had not yet been demonstrated to him.
The failure to demonstrate NDE proce-dures prior to their use appears to violate the requirements of Section III of the ASME Code as stated in paragraph a.
above.
This violation of the ASME Code appears to be in noncompliance with Criterion IX of 10 CFR 50 as implemented by paragraph 17.1.9 and table 3.2.1 of the PSAR and is categorized as an infraction and identified as item no.
416/78-15-02.
Finding:
This allegation was substantiated.
One neocompliance was identified as noted above.
3.
Allegation:
Weld filler material was not properly controlled as required by the 1974 ASME Code,Section III in that weld records indicated that filler material was issued in January 1977 and was not used until April 1977.
Discussion:
The investigators examined the licensee's requirements and practices for the control of welding filler material. This examination included the f'ollowing:
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-9-a.
Review of Applicable Cqde and Procedure Requirements:
The code requirements for the control of filler material is found in paragraph 4122 of the various subsections of Section III of the 1974 ASME code.
This paragraph requires that " Welding and brazing materials shall be identi-fied and controlled so that they can be traced to each component or installation of a piping system, or else a control procedure shall be employed which ensures that the specified materials are used." For the Grand Gulf site and the Vicksburg fabrication shop the latter approach was used. The controlling procedures are WFMC-1 and WD-1 which are appendices to the BQAM. These procedures require that all acceptable material be color coded when opened. The material is issued in accordance with WFMC-1 and the issue documented on form WR-6 of procedure WD-1.
The Lead Welding Quality Control Engineer (LWQCE)
signs the WR-6 after specifying the system, drawing number, weld number, welding procedure, the size and type of welding material, and the color code for the material. The supervisor foreman assigns the welder (s) on or the WR-6 form and then signs the form.
The Rod Attendant issues the material and signs the form entering the portable rod warner or centainer number on the form.
Before issuing the material the Rod Attendant ensures that the'velder presenting the WR-6 form is authorized to withdraw the material.
During documentation of the socket welds on the WR-5A form, the LWQCE transfers the filler material type from the WR-6 form to the WR-5A form.
Paragraph 6.0 of WFMC-1 specifies when unused filler
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materials are to be returned to the rod room.
The time allowed out of
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-10-the rod room is depetident upon the type of material, but in no case can the material stay out longer than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or the end of a shift whichever is less, b.
Review of Weld Material Control Practices The investigators observed weld material control practices at the Vicksburg fabrication shop and the Grand Gulf site auxiliary building rod room.
Storage of material, temperature control, identification (color coding) and issue practices were examined and found to be in accordance with licensee's procedures.
The allegation was based on the fact that the WR-6 form for a particular socket weld showed the filler material to be checked out in January 1977 and the fitup was not signed off until April 1977.
It was assumed by the alleger that the joint had to be welded after fitup verification.
Based on the system being used by Bechtel (See paragraph 5 below for a description of the system) to verify socket weld fitup, the fitup can be checked before welding or any time after velding.
Therefore, filler material could be checked out in Janua ry and the joint welded in Janua ry,,yet the fitup not verified and signed off until some time after welding. -
Finding:
The allegation was not substantiated. No items of noncompliance or deviations were identified.
4.
Allegation:
Chlorinated water was used for the purpose of hydrostatic testing of austenitic steel pipe subassemblies in violation of the 1974 Cod.
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-11-Discussion:
The investigators examined *< ode require-ments, licensee requirements, and licensee practices for the control mf water used for the hydrostatic testing of stainless steel.
This examination included the following:
a.
Review of Applicable Code and Procedure Requirements The requirements for test medium used for hydrostatic testing are found in paragraph 6212 of the various sub-sections of Section III of the 1974 ASHI code.
This paragraph requires that " Water shall be used for a hydrostatic leak test".
For the Grand Gulf site, the hydrostatic test
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water requirements are specified in Bechtel specification No. 9654-M-204.0,
" Design Specification For Field Fabrication and Installation of Nuclear Service Piping and Instrumen-tation."
Paragraph 5.10.5 of this
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specification requires that deminer-alized water be used for hydrostatic testing of piping requiring cleanliness levels A or B and that fresh water, equivalent or superior to drinking water, with certain limits on halogens, sulphur, and low melting point metals be used for hydrostatic testing stainless steel piping requiring cleanliness levels C or D.
b.
Review of Licensee Practices for the Control of Water Used for Hydrostatic Testing
.
The investigators reviewed the hydrostatic test log which revealed that very little "Q" (safety-related)
stainless steel piping has been hydrostatically tested. During this review, only one instance was found where "Q" piping requiring the use of demineralized water had been teste.
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-12-This occured under Test Release No.
G41-001-1 for pipingc on drawing FSK-S-1088-021-B.
For-this piping, drinking water was used in lieu of demineralized water which the licensee documented on NCR No. 1255 dated 10/28/76. The investigators noted a similar condition on NCR No. 2899 for a non "Q" pipe in system P21.
In both cases it appeared that appro-priate corrective action had been taken.
For the above listed piping requiring the use of demineralized water and the below listed piping requiring the use of drinking water, the investigator reviewed hydrostatic test records consisting of " Piping System Test Record, Valve and Closure Lineup",
form CPS-P-18.05 and " Piping System Test Record," form CPS-P-18.04 for Test Release No. G41-001-1 which required demineralized water and for Test Releases G41-004-1 (dtd. 3/30/77),
G41-006-1 (dtd. 7/15/77), and G41-020-1 (dtd. 12/1/77), all of which require the use of drinking water.
c.
Review of the licensee's practices for the control of water used for bydrostatic testing revealed the following problem areas:
(1) Site drinking water is used for hydrostatic testing and is supplied from site wells. These wells are chlorinated using automatic equipment. There are certain wells which have been approved as acceptable sources of drinking water and other wells which have not been approved.
The only checks made on the chemistry of the water are for the purpose of insuring that the water meets drinking water standards and to meet a require-
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-13-ment for water d in mixing concrete (see paragraph 7.3 of Spec.
9645-C-191.0).
These checks do not insure that the water meets the requirements specified above for use in hydrostatic testing of clean-liness levels C and D stainless steel pipe.
On occasion, the water has been tested (see Environmental Protection Systems Inc. report dated 3/9/77) to determine that chemistry requirements for hydrostatic testing of stainless steel can be met; however, there is no requirement in Bechtel's program to periodically check to insure
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that the requirements of the above specification (9654-M-204.0)
are met.
It appears that, although the well water may not change, some provision should be made to periodically check the
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water chemistry in case the automatic chlorinating equipment malfunctions or the halogen, sulphur, and low melting point metals vary from one approved well to another approved well.
(2) There is no consistency in recording the " test medium" on the CPS-P-18.04 form. One form reviewed indicated "Gr. B water",
another indicated " water" and still another indicated " drinking H 0".
Finding:
The allegation is not substantiated in that the ASME code specifies only that
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" water" be used for hydrostatic testing.
However, based on the two problems stated above and the cases where the grade of water used did not meet Bechtel specifi-cation 9654-M-204.0, it appears that the
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-14-
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controls for water used fy hydrostatic testing should be more cle.a rly defined.
This matter is considered unresolved and is identified as item no. 416/417/78-15-03.
5.
Allegation:
Socket weld fittings were not being inspected for fitup prior to welding in accordance with the requirements of the 1974 ASE Code,Section III.
Discussion:
The investigators examined code require-ments, licensee procedure requirements and licensee practices for inspection of fitup on socket welds. This examination included the following:
a.
Review of Applicable Code and Procedure Requirements The only requirement relative to fitup of socket welds is found in paragraph 3661.2(b) of the various subsections of Section III of the 1974 ASE Code.
This paragraph requires in part that
"A gap of approximately 1/16 in.
shall be provided between the end of the pipe and the bettom of the socket before welding." The code does not address how verification of this requirement is to be obtained.
The licensee's program for verification of the 1/16" end gap is documented in paragraph 8.4 of procedure WD-1 of the BQAM.
This paragraph requires that a r,c ribe line be applied two inches from the end of the pipe.
A second scribe line is applied to the 0.D.
of the fitting corresponding with the bottom of the socket. After fitup, the distance between the two lines must be 21/16 to 21/8 inches.
After welding, the distance between the two lines must be greater than 2 inches. Also, distances other than 2 inches may be used where necessary, provided the distance that is used is
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-15-e documented on the {R-5A form.
Paragraph 8.8.3 of procedure WD-1 requires that the fitup be checked on each joint either before or after welding in accordance with paragraph 8.4 and if acceptable, initials and date are to be entered in the space provided on the WR-SA form.
In addition, paragraph 8.5 of-WD-1 requires that the Lead Field Welding Engineer (LFWE) monitor the fit-up of socket weld joints as necessary to ensure compliance with paragraph 8.4.
b.
Review of Licensee Practices For Verifying Socket Weld Fitup The investigators obse rved the following in process work at the Vicksburgh fabrication shop:
(1) Two socket welds were observed during fitup.
In addition to the scribe marks 2 inches apart, the fitters were also placing a scribe mark on the pipe that corresponded to the depth of the socket fitting bore.
The pipe was withdrawn f rom the socket bore until this scribe line on the pipe was 1/16" to 1/8" away from the face of the socket and the joint was then tacked.
The investigators measured the 2"
dimension between scribe lines on approximately 12 completed welds. In addition the inspector checked the scribe line location on approximately 12 fittings and pipes prior to fitup.
The equipment for scribing the pipe and fittings was demonstrated to the investigators. The scribing equipment consisted of a vibrotool rigidly attached to a jig which provided very accurately located scribe mark.
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-16-
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(2)
In addition to ttie above obser-vations, the investigators reviewed the ANI's current log at the Vicksburg shop.
Logbook entries on 8/28, 8/29, and 8/30/78 revealed that 4 socket welds presented to the ANI for inspection had been rejected.
Weld No. 2 on dwg. FSK-I-2061 A-308-T was rejected for not having a scribe line on the pipe to check fitup.
Weld no. 2 on dwgs. FSK-I-1061A-312-T, 309-T, and 310-T (3 welds) were rejected because the distance between the scribe lines did not exceed 2 inches after welding as required by the procedure.
Further invertigation revealed that the welds were cut out and re-welded and that procedures were not followed in two instances, as detailed below, during the cutout and re-weld:
(a) The welds were cut out and rewelded without the issuance of a nonconformance report (NCR). This is in violation of paragraph 6.1 of QC instruction 9.1-9 and paragraph 11.3 of Appendix 3 to the BQAM which state in part, "A nonconformance report shall be prepared
. whenever any of the
...
' following conditions apply:
. (1) When welds have been made that are not in accordance with the qualified welding procedure or applicable job
....
specification
....;
(5) when any condition is found after the veld has been completed, examined and accepted that does not meet the ASME Code require-
,
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-17-thhjob speci-ments or fication requirements."
This appears to be in noncompliance with Criterion V of Appendix B to 10 CFR 50 as implemented by paragraph 17.5.1 of the PSAR and is categorized as an infraction and identified as item no.
416/417/78-15-04.
Upon discovery of this item, the licensee initiated immediate corrective action by issuing Discrepancy and Correction Report (D&CR) #1109.
In addition Bechtel issued NCR
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No. 2930 against the joint and at the same time issued a memorandum to all QC personnel reiterating the requirements for the issuing of NCR's.
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(b) Observation of the four welds as installed in pipe subassemblies at the Grand Gulf job site, review of the re-weld WR-5A forms, and discussions with Bechtel QC personnel revealed that the 2 inch scribe lines were not used for fitup check during the rework as required by paragraph 8.4 of procedure WD-1.
In lieu of scribing the pipe 2 inches from the end, a line was scribed on the pipe correspcoding to the depth of the socket bore.
The QC inspector stated that he had witnessed the withdrawal of the pipe so that the scribe mark on the pipe was 1/8 inch from the face of the fitting at fitup.
The 1/8 inch dimension was recorded by the QC inspector on the WR-5A form as the fitup dimension. QC personnel attempted to justify the use of this
.
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-18-method by referripg to the last part of paragraph 3 4 of procedure WD-1, which states " Distances other than 2 inches may be used, where necessary, provided the distance that is used is documented on the WR-5A form. It should be noted that for the case in question, it was not necessary to use a distance different from 2 inches as there were no geomet-rical limitations, such as short nipples, etc..
Also, if some geometrical limitation had required the use of the scribe line 1/8 inch from the face of the fitting, the recorded fitup dimension on the WR-5A form should have been the depth of the socket bore plus 1/8 inch and not 1/8".
This appears to be in noncompliance with Criterion V of Appendix B to 10 CFR 50 as implemented by paragraph 17.1.5 of the PSAR and is categorized as an infraction and identified as item no.
416/417/78-15-05. Upon discovery of this item, Bechtel initiated immediate corrective action by issuing NCR No. 2928.
Finding:
The allegation was not substantiated in that the APfE Code does not specify the method to be used for verification of socket weld fitup.
However, two noncompliances',
as noted above were identified.
6.
Allegation:
The problems identified in allegations 1 through 5 above, were identified to Bechtel and Kemper personnel; however, no corrective action was ever taken.
Discussion:
During investigation of the above 5 allegations, the inspector reviewed records and interviewed licensee and
.
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-19-pIrsonnel to licensee's contractor determine what corrective action was taken at the time the problems were identified.
This review revealed the following corrective action records relative to each of the 5 allegations:
Allegation 1, Unidentified Attachment a.
Materials On 3/18/77, approximately the same date the problem was identified by the ANI, MP&L issued Quality Action Item (QAI) no. 93 and Bechtel issued NCR no. 1621 for welding a
"C" clamp (unidentified material) to a code pipe. The corrective action for this incident addressed not only the
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i specific incident, but addressed the problem in general. In addition, the investigators reviewed minutes of a meeting between Kemper and Bechtel dated 3/29-30/77 where the "identi-fication of temporary attachments",
as identified in ANI letter dated
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3/17/78, was discussed.
On 4/4/77, Bechtel issued Information Bulletin W-026 which further defined the code requirements for temporary attachment material.
Based on a review of current practices, the above corrective actions appear to have been adequate.
b.
Allegation 2, Demonstration of NDE Procedures The investigators were unable to locate any documentation to sub-stantiate that the alleger had identified this problem to Wemper or Bechtel.
The investigators did review letters dated 4/7/77 and 4/22/77 which indicated that NDE procedures in use at that time were demonstrated to the satis-
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-20-faction of the ANI. These dates were about the same time ;the alleger indicated he had a
problem.
Discussions with the alleger indi-cated that his problem was more with the method of demonstration than the lack of demonstration.
However, the ASME Code does not specify the method of demonstration, only that the procedures be demonstrated to the satisfaction of the inspector.
c.
Allegation 3, Weld Filler Material Control This allegation was not substantiated.
However, the investigators did review a letter (dated 3/16/77) from the Fab Shop ANI to his supe rvisor which discussed problems in the use of WR-5, WR-5A, and WR-6 weld rod control forms. The investigators also found that this matter was discussed in the minutes of the March 29-30, 1977 meeting between Kemper and Bechtel.
d.
Allegation 4,
Use of Chlorinated Water fc.?i ostatic Testing d
Although ts
- SME code does not specify the saality of water to be used for hydrostatic testing (See paragraph 4.a.
above),
Bechtel specifications do specify water quality for hydrostatic testing. The only instances the investigators could find where the proper quality of water, had not been used were identified on NCR's.
The investi-gators reviewed NCR No. 1255 for "Q" piping and No.
289, for non "Q" piping.
In both cases, it appeared that appropriate corrective action had been taken.
e.
Allegation 5, Inspection of Socket Weld Fitup
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-21-
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This allegation was notaubstantiated.
Therefore, no corrective action was required. However, the investigators noted in review of the meeting minutes referred to above, that the inspection of socket weld fitups was discussed.
Finding:
The allegation was not substantiated. No items of noncompliance or deviations were identified.
7.
Allegation:
Material not meeting purchase specifications may have been supplied by Bristol Steel's Plant No. 3 and accepted by Bechtel for use in safety-related components, systems or structures at the Grand Gulf Nuclear Station.
Discussion:
Discussions with the alleger indicated that his concern was "significant voids" in structural steel shapes innished by Bristol Steel that could have been used for safety-related structures or component supports.
These voids were observed by the alleger in I-beams being fabricated into parts at Grand Gulf.
Also, the alleger referred to a memorandum dated 4/9/76 f rom a Bechtel resident inspector at Bristol Steel to his supervisor, which sumnarized a number of problems found by the Bechtel inspector at Bristol plant 3, to further substantiate problems with steel furnished by Bristol Steel.
The memorandum referenced several " Surveillance Inspection Reports" which detailed various problems found by the Bechtel inspector.
,
The investigators conducted a review of material specifications, associated records, and the ANI Logs, and interviewed licensee and licensee's contractor personnel as follows:
a.
The investigators reviewed Bechtel specifications 9645-C-121.0 and 9645-C-131.0, which covered the safety-related structural steel supplied by Bristol Steel.
In the
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-22-cases where the materhl was to be furnished as fabricated parts, the fabrication was accomplished at one of the Bristol Eteel plants.
In other cases where the material was to be furnished as stock structural shapes, the material was shipped directly from a steel manuf acturer such as Bethlehem Steel. The material furnished as structural shapes without further fabrication went into plant stock and could be used for any structural steel application (i.e.
temporary material,
"Q' material, or non "Q" material).
b.
The investigators reviewed the Bechtel memorandum referenced above which had to do with material fabricated in the Bristol shop (Plant 3). In addition, the investigators reviewed Bechtel
" Surveillance Inspection Reports" Nos. 13, 12, 28, 29, 30, 32, 40, 41 and 42 which were referenced in the memorandum. These reports were dated late 1975 through early 1976 and pointed out many problems with the fabrication in Bristol plant no. 3.
Correspondence dated in April,1976 between Becht;'. and the president of Bristol Steel indicated that Bristol was aware of their problems in plant no. 3 and were taking actions to correct the problems.
In order to determine if the problems were confined to just that period of time or continued on, the investigators briefly reviewed
"Surveillence Inspection Reports" 45 through 92 dated 5/7/76 through 4/8/77 for P.O. 9645-C-121.0 and 43 through 87 dated 4/2/76 through 4/21/77 for P.O.
9645-C-131.0. The problems appeared to clear up after April of 1976. However, the investi-gators noted the following two problems concerning this matter:
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-23-(1)
It appeared that nonco(formances were being found and reporte.d on Surveillance Inspection Reports and no other paper work was issued to track the problem.
Discussions with the licensee revealed that this problem was identified in 1977 and corrected with the issue of the "Bechtel Procurement Supplier Manual," which required that supplier deficiencies be reported on a " Quality Surveillance Deficiency Report" (QSDR). This report requires records of followup, corrective actions, and closeout of all items identified. It should be noted that the investigators'
review of " Surveillance Inspection Reports" did not reveal any case of
nonconformances being identified without later closeout on a subse-quent report.
(2)
In review of the surveillance reports the investigators noted that about
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the time the problems cleared up in plant no. 3, the Bechtel inspector at plant no. 3 was changed. Discussions with the Bechtel Gaithersburg Division Supplier Quality Manager revealed the following:
(a) The normal assignment of a resident inspector at a plant was about two years.
The transfer of the inspector was a normal career rotational reas-signment.
(b) The. problems that Bristol plant no. 3 had were with light structural fabrication.
The plant had not had a problem with heavy girder Work. About the time in question, the remainder of the light structural work for Bechtel was transferred to another Bristol plant.
The only
"Q" work remaining at plant no. 3 was CRDM embeds and a Ring Girde.
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-24-Transfer of the I kht structural steel out of plant no. 3 was a contributing factor to the decline in problems reported at Bristol.
c.
The investigators reviewed the ANI Log covering the period that the alleger indicated problems with voids in I-beams occurred. The only related entry found was on November 17, 1976, which read,
"A shop discussion of voids in a 12"x133 lb. I-beam from Bristol Steel. This material -C1. 1 material being used for crane hoist.
This beam is being put in hold area."
Discussions with Bechtel personnel who remembered this incident, revealed that the I-beam (A-36 steel supplied by Bristol and manufactured by Bethlehem Steel) was to be used for a base support for a construction pedestal crane (Fab request #FR-T-052). This material was not permanent plant material but came from the same stock (see paragraph a. above) as permanent material.
Bechtel personnel stated that all other like material in the shop at that time was ITT inspected and defective material was scrapped.
Later, in March of 1977, an A-36 WF 4"x13 lb.
1-beam supplied by Alfab, Inc., manufactured by Bethlehem Steel, was cut for fabrication of some permanent plant parts. The cut revealed a
1 3/4" x 1/4" pocket (void)(lamination) in the center of the web.. NCR's 1658 and 1786 were issued. As a result of this incident, Bechtel " Management Action Report" (MCAR) GGNS No. 24 was issued and an investigation was initiated which included all Bethlehem shapes whether installed as fabricated shapes or still in stock.
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-25-The investigation by Bachtel was well documented and the in8ident reported to NRC as a possible 50.55(e) item.
Region II reviewed this item during normal inspections.
The review is documented in RII Inspection Reports 50-416/417/77-7, 77-9 and 77-11.
Corrective action appears to have been adequate to insure that defective beams were not installed in safety-related structures and supports.
Finding:
This allegation was not substantiated.
Defective material was received and installed, but records indicate that adequate corrective action was taken. No items of noncompliance or deviations were identified.
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C.
Followup on Discrepancies Noted By ASME National Board Investigator Since the original allegations were made to the National Board of Boiler and Pressure Vessel Inspectors, the Board performed an investigation.
During the investigation, four " Procedural
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and Code Discrepancies" were noted.
The NRC investigators reviewed these items as detailed below. Each discrepancy is directly quoted from the Board investigator's report:
1.
Discrepancy:
"The WPS PI-A-DI, Rev. 1, referenced in the complaint, (but not questioned) is not completely acceptable as mentioned in Item 5, of investigation at the San Francisco office.
This same deficiency had been detected during my audit of this company's Quality Control program for non-nuclear work on July 18, 1978, and corrective action is being rushed to correct this deficiency.
They were able to show me records in the San Francisco office to verify the procedures were correct and that they had been properly documented but the information had not been properly recorded on the WPS and PQR to permit effective use at the job-site.
(QW-201, QW-201.1 and QW-201.2)."
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-26-
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Discussion:
The NRC investigators reviiyed item 5 of the National Board's investigation report.
Item 5 indicated that procedure WPS-PI-A-Ili was deficient in one area.
The Board investigator also noted two other areas of procedure discrepancy.
These three areas of the procedure were reviewed and compared with the applicable code as follows:
a.
The Welding Procedure Specification (WPS) was deficient in that the voltage range was not specified.
Section IX of ASME, paragraph QW-201.1, requires that the WPS list in detail the essential and nonessential variables described for each process. For the process in question, SMAW, voltage is a nonessential variable and therefore must be included in the WPS.
The licensee had previously identified this problem on similar procedures and issued D&CR No. 1097. Supplement No. I was issued to the D&CR to add procedure PI-A-LH and include a review of all WPS's. This item will be reviewed by NRC on a future inspection and is identified as inspector followup item no.
416/417/78-15-06.
b.
The Board investigator stated in his report that since Revision 1 to the WPS was prepared on 11/8/74 and some of the supporting PQR's were certified prior to that time and revision 1 did not identify the changes made, the ASME inspector could not determine whether the WPS was valid.
Section IX of the ASME code allows the use of earlier procedure quali-fications. Therefore, this condition does not appear to violate the ASME code.
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-27-c.
The Board investigatot stated that PQR's 9 and 10 do not;show voltage and amperage and the code requires such information to be recorded even though they are not essential variables.
He also indicated that the dimensions of tensile test specimens are not shown on any of the PQR's.
Section IX of ASME code, paragraph QW-201.2 requires that essential variables and test results be documented on the PQR but does not specify that nonessential variables be documented.
The lack of tensile test specimen dimensions on the PQR does not appear to violate the ASME code.
In many cases, the specimen dimensions are recorded on a tensile test report and only the tensile strength is transferred to the PQR.
Finding:
The discrepancies have been reviewed and, except as detailed in paragraph a., do not appear to violate the ASME code. No item of noncompliance or deviations were identified.
2.
Discrepancy:
"The required corrective action of deficiencies found during the Semi-Annual audit had not all been accomplished nearly 3 1/2 months later and no " follow-up" action had been taken as required by NA-4133.18.
The San Francisco office (from which the audit had originated) had no record of any corrective action, but the job-site records showed all but four of the 17 deficiencies had been corrected rather quickly and that the remaining four were policy procedure changes only.
Although it would appear the essential items were corrected promptly, there was a lack of follow-up by the San Francisco of fice as required by their Quality Program."
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-28-
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Discussion:
The NRC investigators reviewed the Semi-Annual audit. At the time of the review (10/12/78) all of the audit findings except QAF's 9 and 15 had been closed out.
Corrective action was complete on QAF 15 but the site did not have a copy of the signed off record. QAF 9 is a procedural change only and is awaiting the next anunendment to the BQAM. As noted by the National Board investigator, all but four of the items were corrected in a timely manner and these four were paper problems where delayed action did not present a safety problem.
Discussions with the licensee reveal that the audit in question was a Gatherisburg Management Audit and the San Francisco office (M&QS) only served to aid the Gatherisburg office during the audit.
Therefore, M&QS was not required to have records of followup.
Finding:
No items of noncompliance or deviations were identified.
3.
Discrepancy:
"Several conflicts and editorial type deficiencies were noted in their RT procedure RT-XG-2.
However, the specific RT being used at the job-site and reviewed by me was found acceptable. This appears to be a break 'own in the Quality System."
Discussion:
The NRC investigators reviewed the RT procedure in question and agrees that the procedure cont.ains conflicts and editorial'
errors as pointed out by the Board investi-gator. However, RT, except for final film interpretation is being performed by Peabody Testing in accordance with their procedure 3.20.A.2.
The Bechtel procedure in question is being used for final inter-pretation of film by Bechtel.
MP&L is in the process of evaluating the procedural conflicts and editorial errors to determine if procedural revision is
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IE Investigation Report Nos. 50-416/78-15 and 50-417/78-15-29-warranted. This item will [e reviewed on future inspections to detertine if corrective action taken is adequate and is identified as inspector followup item 416/417/78-15-07.
Finding:
No items of noncompliance or deviations were identified.
However, an item for followup on future inspections was identified as noted above.
4.
Discrepancy:
"The weld material control does not require the material issued to be recorded by quantity, nor does it require quantity returned at completion of the welds to be recorded. It does require stub ends to be returned to the issuing clerk, but the quantity returned is not recorded. In my
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opinion, this does not satisfy Code require-ments for Class 1 items (NB-2150)."
Discussions:
The NRC investigators reviewed the licensee's practices for the control of filler material (see paragraph IV.B.3 above for details of this review and the
^
applicable code requirements).
The code does not require that the quantity of material issued and returned be recorded.
Finding:
No items of noncompliance or deviations were identified.
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