IR 05000423/1985046
| ML20205B478 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/03/1985 |
| From: | Kerch H, Kamal Manoly, Reynolds S, Varela A, Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20205B475 | List: |
| References | |
| 50-423-85-46, IEB-79-02, IEB-79-2, NUDOCS 8509120100 | |
| Download: ML20205B478 (42) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report N /85-46 Docket N License N CPPR-113 Licensee: Northeast Nuclear Energy Company P.O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Power Station, Unit 3 Inspection At: Waterford, Connecticut Inspection Conducted: August 12 - 16, 1985 Inspectors: M( w b" dibfI H.y.Kerch,C{tadReactojEngineer date W.gsw shbr A. Manoly, Lead Reactor Engineer ate aMWb QviaW 5'. D. Re'ynoTds 'r., Lead Reactor Engineer dats M dW
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'2P3 [ .farela[J4eadR$ctorEngineer Other Accompanying Inspectors: R. M. Campbell, NDE Technician R. H. Harris, NDE Technician S. Pleschak, Intern Approved by: _ _ _
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gerials andWrfcesses Section, DRS Inspection Summary: Inspection During August 12-16, 1985 (Report 50-423/85-46) Areas Inspected: Routine, unannounced inspection by seven region-based inspec-tors and a supervisor. The inspection covered the following areas: follow-up on outstanding inspection items; the ASME Code N-5 certification program; the stress reconciliatican program; indepeadent int,7ection and follow-up of licensee work on structural steel bolting and welding, pipe support welding and tank
- welding; review of preservice inspection data for RCS piping; an overview of i
Region I's welding inspection activities; and follow-up of the licensee actions l in response to IE Bulletin 79-0 The inspection involved 226 man hours.
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Results: No violations were identified. The inspectors noted that the N-5 and stress reconciliation programs were adequately established and that the quality of welding observed during this inspection was good. However, the in-spectors identified the need for more focussed management attention on the review of Pre-service Inspection result T e DETAILS 1.0 Persons Contacted 1.1 Northeast Utilities (NUSC0/NNECO) K.-Clement, Maintenance Supervisor D. Miller, Startup Manager
*L._Nadeau, Assistant Project Engineer *V. Papadopoli, Supervisor, Construction Quality Assurance *S. Sikorski, NUSCO Nondestructive Examination S. Orefice, Project Engineer 1.2 Stone and Webster Engineering Corporation (SWEC) *J. Capozzoli, Supervisor of Construction Services *J. Kelly,' Senior Quality Assurance Engineer M. Potter,- FQC ASME Group H. Paul, FQC ASME Group D. Bergiin, FQC ASME Group C. Benson, FQC ASME Group A. Mathes, FQC ASME Group Discipline Lead QC G. Jones, FQC ASME Group Supervisor *G. Marsh, FQC ASME Group Assistant Superintendent *M. Matthews, FQC ASME Group L. Peterson, FQC ASME Group *G. Turner, Resident Quality Control Manager N. Hammar, FQC Inspector M. Bezanason, FQC Inspector *W. Vos, Senior FQC Engineer M. Sinha, Project Structural Engineer P. Roy, Structural Engineer D. Dakers, Structural Engineer R. Currier, Structural Engineer R.-Zawacki, Lead FQC Inspector R. Hagerman, FQC Inspection Supervisor 1.3 Arcos Corporation W. Wie51, QA (by. phone)
1.4 Sandvik Corporation F..Babish, QA (by phone)
'1.5~ USNRC F. Casella, Resident Inspector-T. Rebelowski, Senior Resident Inspector l
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2.0 Follow-up Outstanding Inspection Items 2.1 (Closed) Follow-up Item 423/85-06-03: Review of microcracks on capstan spring tangs'for Pacific Scientific mechanical snubber This item is closed based NRC review of the satisfactory results of the laboratory analysis developed by Metteck Material Engineering Laboratories and on the full load functional and dynamic load testing results provided by Pacific Scientifi .2 (Closed) Follow-up Item 50-423/84-20-06: Evaluation of the adequacy of ultrasonic examinations of reactor coolant system loop piping weld Based on an onsite NRC review of an ultrasonic examination demonstra-tion performed on June 5,1985 by NUSCO and Westinghouse on centri-
, fugally cast stainless steel pipe, this item is close .3 (Closed) Unresolved Item 423/84-21-01: Verbatum compliance to AWS D1.1-73 This item is closed based on the review of the written response to the G. G. Turner letter (subject: NRC concern 84-21-01) dated January 3, 1985. This response stated the site engineering commen-tary and discussion on the comparison of AWS DI.1/ ANSI B31.1 welding requirements. The response indicates, on a line by line basis, the licensee commitments and clarifications to the D1.1 document requir-ement .4 (Closed) CDR 50-423/85-00-13: Skewed angle joints fitup criteri Based on this follow-up inspection (see section 6.2) this item is considered close .r (Closed) CDR 50-423/85-00-14: Undersized clip angle welds on structural stee Based on this follow-up inspection (see sections 6 and 7), this item <
is considered close .6 (Closed) Unresolved Item 50-423/85-00-09: Load indicating washers failed to meet test stand criteri Based on this follow-up inspection (see section 7.0), this item is considered close .0 ASME Code N-5 Certification Program The inspectors reviewed the licensee's program for certification of ASME Class 1, 2 and 3 piping and supports. The documents reviewed are included in Attachment I to this repor This program, implemented by
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, 5 l Stone and Webster (SWEC), involves a close-out documentation review of Class 1, 2 ano 3 systems and results in the affixing of an N stamp on these systems. During this inspection, the licensee's and SWEC's organ-ization for the N-5 program was reviewed along with the interfaces between responsible units in both SWEC and the licensee which were developed for program implementation. Additionally, the inspectors interviewed super-visory and working level personnel involved and examined representative documentation package .1. Organization The inspectors reviewed Quality Control Instruction (QCI) FM3-S14.2-07E and NEAM-134 which described the organization and methods to be used by SWEC to conduct the N-5 program. Figure 1 to this report depicts this organization pictorially and shows the pri-mary interfaces among SWEC FQC, SWEC Engineering and the license Briefly, the process starts with SWEC Engineering (Power) providing to FQC a rough drawing showing the line under consideration. The walkdown FQC personnel accompany SWEC Engineering (EMD) personnel who use this rough drawing to obtain the as-built dimensions for the lin Concurrently, FQC assures that all appropriate components and ,im-ensions are included on this drawing and overview the measurerent activities of engineering. The completed drawing is used by sWEC Engineering to produce a finalized Piping Locatisn isometric (PLI).
The finalized PLI is reviewed by FQC and approved by Engineerin Finalized PLI is then used for stress reconciliation by Engineering and becomes part of the As-Constructed drawing package used by EQC for the N-5 program. ASME-FQC, using the As-Constructed drawing, identifies and complies all documentation required to support N-5 certificatio Work done by NNECO, principally removal and reinstallation of bolted connections, is controlled by Automated Work Orders (AWO) which are provided to ASME-FQC for work on Class 1, 2 or 3 systems. ASME-FQC assures SWEC and the Authorized Nuclear Inspector are afforded the opportunity to inspect the work covered by the AW ASME-FQC performs a final system review to assure that the latest drawing were used and that all E & DCRS, N & Ds and UNSAf' Inspection Reports are accommodated in the N-5 packag SWEC and the ANI then affix the N stamp to the syste ~ Based on the review of this area, and on discussions with cognizant SWEC and licensee personnel, the inspectors concluded that the or-ganization was acceptably defined and understood by those involve One minor problem with control of the interface between SWEC and NNECO was identified and is described in paragraph 3.2 of this re-por ,
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3.2 Interfaces Between The Licensee and SWEC As indicated in Figure 1, there were two principal interfaces found between the licensee and SWEC regarding implementation of the N-5 program. Firstly, NUSCO was found to be performing an oversight role wherein it maintained cognizance of SWEC's N-5 program implemen-tation. The second interface involved the relationship between the NNEC0 Maintenance organization and SWEC FQ As indicated in SWEC ASME QA Manual Section 9/ML and in NNECO pro-cedure EN 31100, NNECO is responsible for notifying SWEC of work performed by NNECO on ASME systems prior to completion of N-5 certi-
~ fication for these systems. Based on discussions with an FQC en-gineer and with the NNECO Maintenance Supervisor, this notification is made by NNECO Maintenance providing, to the ASME FQC group, copies ~~ of the Automated Work Orders (AWO) under which NNECO's work is being performe To test the adequacy of interface controls in this area, the inspec-tor selected for review 4 work orders, M3-85-18807, M3-85-18812 M3-85-19876, and M3-05-19879, which dealt with removal and replace-ment of the startup strainers for. two pumps in the service water syste Upon checking with FQC, the inspector determined that, although the work orders covered work activities should have been reported by NNECO to SWEC, notification was not made. Based on a discussion with the Maintenance Supervisor, the inspector learned that a single maintenance foreman was invol_ved in the 4 work orders. This foremen did not forward copies of the AW0s to ASME-FQC because he had assumed that the N-5 program had been completed for the_ pipelines involve The inspector's review of the AW0s indicated physical work had been completed and a post-maintenance inspection by NNECO Quality Control had been performed in each case. Therefore, the inspector determined that adequate confidence existed that the mechanical joints insolved were returned to an acceptable configuration after the maintenance work; thus no adverse safety impact developed. However, to verify that this instance was isolated, the NNECO Maintenance Supervisor - committed to review all other AW0s affecting the service water system and to review all AW0s processed during the previous 3 months bt the specific maintenance forema The adequacy of implementation of the N-5 program will remain unre-solved pending completion of the licensee's review of the above des-cribed AW0s (Unresolved Item 50-423/85-46-01).
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3.3 ASME N-5 Documentation Review , The inspector reviewed typical ASME N-5 documentation packages, SWEC procedural specifications applicable to the review and collation of complete N-5 systems, and applicable checklists. Discussions were held with personnel in all levels of the SWEC FQC ASME Group. The procedural documents reviewed are shown in Attachment The inspector reviewed, in detail, the N-5 checkoff lists for the specific N-5 boundary pipe line segments shown in Attachment It was noted that these documents contained errors and correc-tions in nondestructive examination (NDE) records, notation of filler metals in weld data sheets (WDSs) and weld material requisitions (WMRs), and instances where FQC inspectors who conducted surface NDE inspections also signed WDS records for document completion. More detailed discussions of the above findings are included in subsequent sections of this repor .3.1 Supplementary Surface NDE Review of WDS and NDE records for line 3-CHS-002-283-2 isometric drawing (IS0) CP 374501) indicated that this spool piece was welded and surface NDE-inspected in the SWEC Fabrication Sho Surface NDE inspections by FQC for welds on the spool were signed off as acceptable on each respective WDS on July 5, 1983, with FQC sign off for complete weld documentation verification on August 24, 1983. Additional acceptable surface NDE examin-ations were conducted on these same welds on October 6, 1983 with subsequent notations on the October 6,1983 NDE examination records that indicated the October 6, 1983 examinations were
"for information only." Investigation of the reason for the additional NDE inspections failed to determine why these in-spections were conducted. The inspector's review included a discussion with one of the two FQC inspectors who conducted the additional examinations which occurred on October 6, 1983 and with other cognizant personnel. As a result, the inspector determined that, because the governing document for accept-ability of the ASME weld was the original NDE signoff on the WDS, the welds met Code requirements and the additional NDE inspections were, in fact, superfluou The inspector also visually inspected accessible portions of the subject installed spool piece, verified that dye penetrant ex-aminations were performed and identified no discrepant condi-tions.
' 3.3.2 Supplemental Radiography (RT) Review of the radiographic records on FW 53-1 on 150 CP407254 indicated some confusion existed on the radiographic coverage
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between film marker station 5 and film marker station 1. The original examination was conducted on July 22, 1984 and dis-positioned on August 9, 198 # The original radiographic report indicated that the marker 5 to marker 0 area was not covered. An additional shot was made of this area on August 9, 1984, (indicated initially as "0-5") and dispositioned on August 9, 1984. The WDS for this weld was signed off by an FQC Level II radiographer and the ANI on August 9, 1984. Review by FQC ASME Group personnel indicated that they were not satisfied with the second radiographic no-tation for the marker 5 to marker 0 area. The FQC Level II radiographer was asked to review the records and he subsequently changed to "O t 5" to "5 to 0" on the NDE record. He initialed his change, but put the date of the original 5-0 shot on the initialled change. The NRC inspector reviewed the records and held a technical discussion with the cognizant FQC Level II radiographe The radiographer indicated that he erred when he indicated the date of the change to the second RT record as August 9, 1984, but considered it not significant because it was editorial in nature. The inspector concurred with this assess-ment and noted that QCI FM3-0172-010 (rough draft) would provide instructions to FQC personnel to date this type of change on the date the change is actually mad The inspect,r had no further questions in this are .3.3 Filler Metal Notations Review of WDS records by the inspector indicated questionable filler metal notations on WDS, WMR and the heat trace file re-cords. Also noted were corrections made to filler metal nota-tions on WOS records. Two specific cases were reviewed to determine if these notations and corrections adversely affected material traceability. Both cases involved 5/32" consumable insert In the first case, the WDS indicated a 5/32" IN 316 EB insert with the heat nurrber as 464843. The WDS was subsequently changed to indicate a heat number of $464843 which agreed with the heat trace list for this materia Investigation by the in-spector indicated that the material was supplied by Sandvik and purchased on SWEC P0 18541 (IR W3054983). Based on discussions with a Sandvik representative, the inspector learned that the
"S" prefix is not part of the heat identification per se, but
, ' rather an internal Sandvik identifier meaning " drawn at the Scranton Plant (Clark Summit)". The SWEC heat trace file in-dicated the S prefix and the size, form and chemistry (5/32" EB IN 316). Unfortunately SWEC also has Sandvik (coated) SMAW electrodes (E316-15, P010700, IR W0051304) listed in the heat
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file as 464843 (i.e. without the "S"). This material more properly should have been indicated by the lot number as the heat number only identifies the core wire chemistr In either case, the inspector found that material traceability back to the filler metal was maintained through use of the heat trace file using the heat numbers, size and form. The inspector also veri-fied traceability back through warehouse records to the sup-plie , In the second case the WDS indicated a 5/32" IN 316 consumable insert as either 4113T316, E4113T316 or AC-E4113T316. Review of the WMRs also showed similar variable notations. In some cases the WDSs and WMRs did not agree. The heat trace file < indicated the material as AC-E4113T316. Based on discussion with the vendor (Arcos), the inspector learned that the heat number is actually 4113 and is-traceable in this form back to the supplier (Arcos, P.O. 007876, IR W 9050097). The prefixes and suffixes add nothing to the actual heat number which is 4113. ( AC i s a special Arcos U.S. Government accountability identifier, E in an internal Arcos size designation, T indicates the primary melter, ,, and 316 the nominal chemistry). Also noted was a variable no-tation of I-23413-B which is the MIL-I specification for con- - sumable inserts and not a " lot" number as indicated on the WDS
, record In summary, the inspector's filler metal review indicated that SWEC notations of filler metals in all of their documents ( WDSs, WMRs and heat trace file) followed no explicit methodol-ogy. _ This fact may have resulted in editorial cc rections (by additf or.a1 prefix / suffix notations) made to the WDR filler metal notations. In all cases, the inspector verified that taterial traceability was maintained using the combination of actual heat number, size and form (which were also shown on the involved WDSs). Addition of the "S" in S464843 and the "AC-E" in AC-E4113T316 constituted merely editorial changes which were not substantive l 3.3.4 Review of WOS Records By The Same FQC Personnel Who Performed N5$
A number of WDS records show that the same FQC inspector con-ducting a required NDE inspection also signed off the WDS for FQC document verification. The inspector determined that as the FQC inspector was ' qualified to perform.the NDE and the final record review, there is no QA regulatory reason he may not also sign off for the document completion verificat' ton.xThis is
' < neither a violation of the site QA requirements nor ASME code f
requirements. Also no violation of 10 CFR 50 App (ndix B re-quirements existed. The independence requirement is written to prohibit the person making the weld (i.e. construction) from conducting an NDE test on a weld he mad i
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Review of NDE certifications verified that personnel conducting . NDE (PT or MT) were qualified at the time of the NDE inspections I 'and were qualified by training to review the WDS documents for
- *campletion verification.
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' .-3.3.5 ANI Interface The inspector reviewed the ANI-SWEC interface activities in WDS ,
sign off In accordance with NRC regulatory requirements, the activities of the ANI are not considered a required part of the
: 4 licensee's quality program (which must stand on its own without crediting ANI hold point and sign offs). The ANI hold points ,
and review of documents do, however, constitute a third party
, quality review, and are a requirement of the ASMei Cod l The NRC inspector held technical discussions with the ANI Site Coordinator to clarify his reply to an SWEC Inter Office Com-
- munication (IOC) (George Jones to Bill Braden) dated August 5, 1985, concerning re-review of WDS records by the ANI following
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re-review by ASME-FQC. The ANI indicated that review of records je by the FQC individual who also conducted the NDE test on the
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weld as discussed previously above did not present a problem if the FQC reviewer was properly qualified. He stated that he in-
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vestigated the training of the FQC document completion sign off personnel and found it to be acceptable. He further stated that
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he wished to be informed of any data changes that were not purely editorial in natur It was noted that the draft of QCI FM3-D17.2-010 requires that FQC inform the ANI of any changes to . WDS record , , 3.4 Summary of Findings Regarding the N-5 Program
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No violations were identified.
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i The licensee's and SWEC's organization for conduct of the N-5 program ! .
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aurther, the NRC inspector concluded that corrections that were being made to WDS documents were made by FQC personnel exercising their own
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discretion in areas where expiteit instructions were not available for better guidance. Such guidance will be indicated in QCI FM3-017.2-010 when it is issued. There was no safety significance to these corrections because in all cases examined, they were editorial in nature. However, the ifcensee was informed that the SWEC filler metal notation methods did not give explicit instructions to these , personnel in the filler metal control system as to what significant j heat and lot identifiers should have been used.
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1 There was no QA or 10 CFR 50 Appendix B significance to FQC NDE per-sonnel signing the WDS for documentation completion. However, the inspector noted that QCI FM3-D-17.1-010 will indicate that this is not a recommended SWEC practic Further, the inspector learned that a SWEC supervisory review would be conducted of those WDSs which show that one FQC inspector signed both for the NDE and document completio t 3.5 Review of SWEC Investigation Report During discussions conducted with cognizant SWEC personnel regarding the documentation findings described above, the inspector learned of an investigation which appeared to address similar concerns. The inspectors reviewed a copy of the report of this investigation, dated July 26, 19R The investigation covered three allegations identified to SWEC by NUSCO regarding the ASME-FQC Review Group. The allegations were: 1) Improper alteration of material heat numbers on Weld Data Sheets during the final document review ) ASME FQC Review Group personnel reviewing their own work in that the same FQC engineer could have performed nondestructive ex-amination on a weld and also performed the final document ver-ification during the N-5 revie ) Backdated changes were being made to the Weld Data Sheets and/or isometrics thus precluding review S/ the Authorized Nuclear Inspecto The SWEC investigation involved document reviews and interviews with persont.el . The inspectors noted similarities in the documents re-viewed and individuals interviewed during the SWEC investigation and during this inspection. The conclusion of the SWEC investigation was that no evidence existed;that the quality of field-installed hardware was comprised. However, several recommendations for field corrective . actions were identified to imp;ove the document review proces These included the development of a procedure to address correction of ASME records and the need for training of the personnel involved in the ASME review process in this procedur The inspectors concluded that the SWEC investigation adequately addressed the identified allegations and was reasonably thoroug Further, the inspectors verified that an Assistant Superintendent-FQC was in the process of formally responding to the recommendations and implementing interim corrective actions. These actions included development of a draft procedure for record correction. As a result
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of discussions with the inspectors, the Assistant Superintendent-FQC committed to promptly complete training of the Review Group in the draft procedur I No violations were identifie .0 Stress Reconciliation Program 4.1 Areas Reviewed The-review of the stress reconciliation program for safety related piping and support systems covered the following areas:
* Organization- * Technical aspects * Quality assurance / quality control interface The objective of this review was to assess the various functions and activities contributing to the stress reconciliation program and to determine whether acceptable engineering practices, regulatory requirements and liceasee commitments had been me .2 Organization The stress reconciliation program for safety related piping and sup-port systems is conducted by SWEC, the Architect / Engineer (A/E) of record, as part of the As-Built program and ASME III system comple-tion. The program involves the evaluation of safety related piping and supports by project engineering utilizing as constructed dimen-sional data in addition the Stress Data Packages (SDPs) to verify that existing safety related piping and support installations confirm to the requirements of ASME III and ANSI B31.1 codes. The overall As-Built program is addressed in procedure NEAM 122. The procedure provides two methods for developing the required documentation which depicts the as-built condition and those-installed conditions nec-essary to perform the stress reconciliation. The first method is designated As-Designed documentation,.and is prepared by updating the design _ documents to reflect design changes contained in selected E&DCRs, irs and N&Ds. The second method is designated As-Installed documentation,-and is developed by first preparing As-Designed doc-umentation and further verifying installations by taking appropriate physical measurements and/or performing additional documentation verification The first phase of'the stress reconciliation effort for.specified systems commences after the construction of piping and supports and continues throughout the completion of construction activities and
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the incorporation of vendor supplied data. This phase of reconcil-fation is conducted by performing walkdowns of the piping system installations by teams involving SWEC's Power Division, FQC and En-gineering Mechanics Division (EMD) personnel. This phase is con-cluded by the issuance of the "As-Constructed" Piping Location Iso-metrics (PLI's). The second phase of reconciliation is performed by the EMD personnel and involve the evaluation of the "As-Constructed" installations, in relation to the "As-Designec" conditions, utilizing the final system design data from the SDP Upon the completion of the evaluation effort, EMD's stress reconciliation group issues stress reconciliation reports which are filed with the respective piping design packages. The stress reconciliation effort is followed by the preparation of the ASME III stress reports for incorporation in the N-5 program and piping stress design packages. The processing of ASME III certification is addressed in procedure NEAM 13 A flow diagram of activities conducted prior to and involved in, the stress reconciliation program is shown in Figure 4- The implemen-tation and sequencing of activities as outlined in the flow diagram was verified during this inspection and no discrepancies were identi-fied.
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1 4.3 Documentation Reviewed A review of applicable sections of engineering and quality assurance documents was conducted during this inspection to verify that appli-cable regulatory requirements, designs basis and FSAR commitments for piping and supports, were correctly translated into specifica-tions, procedures and instruction .3.1 Engineering Documents I The engineering documents governing the stress reconciliation effort which were reviewed during the inspection, covered the following activities:
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Preparation of stress reconciliation Piping Location Isometrics (PLI's)
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Preparation, review, approval and control of Power Division Stress Data Packages (SDPs) and EMD Pipe Stress Analysis and Supports (PSAS) document Review and stress reconciliation of seismic category I piping location isometrics and tubing isometric Pipe stress analysis criteria ;
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Evaluation of integral welded attachments to piping
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Stiffness representation of supports, anchors, and restraints for pipe stress analysis and-pipe support design
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Pipe support design criteria
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Processing of calculation
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Preparation of stress reports for ASME III, Class I piping As a result of the review of the documents governing the above activities, and upon further discussions with SWEC's engineering l and FQC personnel, the following observations were noted: 1 The Power Division Stress Reconciliation Piping Design Group (SPDG) is responsible for the following: Determining the lines, by turnover system, for which PLIs must be prepared Preparing the ISO /PLI for stress reconciliation mea-surement, performing the documentation review and finalizing the PLI by incorporating measurements and data
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. 17 Notifying FQC and EMD prior to conducting the walk-down and measuring effort Measuring and recording the required dimensions and data necessary for conducting the stress reconcili-ation effort Review of all PLIs in accordance with procedure FCP-33 . The EMD Stress Reconciliation Group (SRG) is responsible for the following: Identifying the locations of all ultimate and terminal anchors to complete the required stress summary pro-blem Providing training to the SPDG personnel involved in the walkdown and data collection effort. In the ini-tial phase of the PLI preparation, a representative of the EMD-SRG group was assigned to accompany each walk-down team which was composed of two SPDG personnel and one FQC representativ Providing and identifying support changes via CRNs and/or E&DCRs which affect piping installations after release for measurements and FQC verificatio Performing PLI evaluations and preparing stress recon-ciliation reports according to NETM 31. Two possibil-ities could exist:
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When installations are within identified toler-ances in the piping field fabrication specifica-tion, M-968, the evaluation would be based solely on engineering judgemen Consideration of cum-ulative tolerances in support installation is an example of a reconciliation topic which would require varying amounts of engineering judgement , by EMD-SRG engineers depending on the number, ' magnitude and location of these tolerances on-a particular run of pipin _
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Where deviations from these tolerance existed, they would be evaluated considering the potential effect on thermal flexibility, pipe-support loads, equipment loads, system natural frequen-cies, dynamic loads and resulting changes in stress level _ _ _ _ _ _ _ _ .
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System operating data from applicable SDP's is utilized in conjunction with the criteria for pipe stress analysis (NETM 44) for the evaluation of the identified deviations. The evaluation could utilize simplified hand calculations by SRG engineers or complete re-analysis of the par-ticular piping system which would then be per-formed by the EMD-stress analysis group. Changes in support loads are also evaluated according to the design criteria for pipe supports (NETM 45). Field QC is responsible for the following: Accompanying the SPDG walkcown teams Inspecting installations to verify the accuracy of information provided on the PLI Verifying that the measuring devices used are issued and controlled in accordance with SWEC calibration program SRG evaluation reports utilize a check list format which includes: input documents; overall determination; accep-tance criteria and results of reconciliatio . The SPDG personnel conducting PLI walkdowns are piping layout designers from SWEC's Power Divisio . The EMD's stress reconciliation group is composed of eight engineers with a minimum of three to four years of experi-enc No discrepancies were identified during this revie .3.2 Inspection Criteria j l A review of the inspection documents governing field quality control activities was conducted during this inspection. The documents covered the following areas:
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ASME III-Division 1, QA/QC manual for fabrication and installation control
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ASME III N-5 inspection
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FQC handbooks for inspection of piping, welding and support installation _ _ _ _ _
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- 19 As a result of the review of the documents governing the above activities and further discussions with SWEC's FQC personnel, the following observations were noted: The role of FQC during PLI walkdowns with SPDG was not intended to be for performing actual measurements. The FQC function in this activity was to verify that designers and engineer are correctly employing the measuring techniques which would produce i
l linear and angular measurements within the required accuracy ( 1/2 inch and 3 degrees). The role of FQC during inspection of PLIs was to verify that the following information was identified by SPDG teams on the PLI drawing:
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Branch connection types explicitly identified
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Fitting types, location, and orientation
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Radii of pipe bends and radii of elbows other than long radius
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Changes in direction other than 90 to x, y & z axis
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Standard vent, drain and instrument connection . Support location, mark numbers, orientations and functions regardless of support class (NF or non-NF) '
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Angular measurement required for the stress analysis such as valve orientation and pipe offsets
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Valve description number, mark number and line number FQC was also required to physically verify the first four items in (2) above.
t The FQC pipe welding inspector's handbook provided a quick ref-erence to the various inspection elements which required cov-erage by the FQC inspectors. The handbook also provided in-spection quidelines for the PLI inspection and for the ASME III i documentation verification of PLI's. Many of the requirements in the handbook were from the piping installation specification, M-968, in addition to weld inspection and NDE requirement It was also noted that the piping handbook was being used for the inspection of NF-supports since the requirements for pipe welding in ASME III are also applicable to NF-hangers. Specific
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guidance was provided to the QC inspectors regarding the ver-ification of As-Constructed NF-supports. This guidance was found to be appropriat . The FQC inspector's handbook for large and small bore pipe support covered all piping supports, including specific instruc-tion for pipe rupture restraints (Specification M-940). It should be noted that the majority of the pipe supports for ASME III piping were designed and installed to ANSI B31.1 require-ments with the exception of approximately fifty multi-function pipe whip / support hangers which were designed to the requirements of ASME III subsection N No discrepancies were identified during this revie .3.3 Review of Design Related Activities l A review of design activities was performed by auditing five stress reconciliation reports. The reports were selected from a status list provided by SWEC's SEG-EMD group. The reconcil-fation reports were reviewed to assess the technical adequacy j of the engineering judgements being employed for justification and acceptance of As-Constructed installations. The review was , 'also intended to verify that the evaluations were performed according to project technical procedures and that they met regulatory requirements. The stress reconciliation reports which were reviewed during this inspection are identified below: Stress Reconciliation Report: Calculation No. 12179-NP(B)- 1704-2 ASME Fabrication. Installation Drawing and PLI No. 12179-C.I.-FWA-511 System: Steam Generator Auxiliary Feed Water Piping-Con-tainment Interior Structure
" Stress Reconciliation Report: Calculation No. 12179-NP(B)- X 1717A-3 ASME Fabrication Installation Drawings and PLI Nos: 12179-C.I.-FWA-91 12179-C.I.-FWA-10 12179-C.I.-FWA-17 12179-C.I.-FWA-18 ' System: Steam Generator Auxiliary Feed Water Piping-ESF Building , t
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21 Stress Reconciliation-Report: Calculation No. 12179-NP(B)- X 207-4 ASME Fabrication Installation Drawings and PLI Nos: 12179-C.I.-MSS-507 12179-C.I.-MSS-508 12179-C.I.-MSS-509 12179-C.I.-MSS-510 J System: Main Steam Piping-ESF Building Stress Reconciliation Report: Calculation No. 12179-NP(B)- X 1917-1 ASME Fabrication Installation Drawings and PLI Nos: 12179-C.I.-SWP-70A 12179-C.I.-SWP-708 12179-C.I.-SWP-86 ' 12179-C.I.-SWP-86A 12179-C.I.-SWP-86B 12179-C.I.-SWP-86C 12179-C.P.-319712 System: Service Water Lines-Auxiliary Building Stress Reconciliation Report: Calculation No.12179-NP(F)- X 202-1 ! ASME Fabrication Installation Drawings and PLI No: 12179-C.I.-MSS-503 i System: Main Steam Lines-Containment Structure
~
, No discrepancies were identified during this revie .4 Summary of Finding for the Stress Reconciliation Program No violations were identified and no discrepancies note .0 Structural Steel Bolting and Welding 5.1 Background d During the NRC Construction Assessment Team (CAT) inspection at Millstone 3, several concerns were raised with respect to fillet welds on tanks, skewed tubular steel connections, structural steel , slotted connections, structural bolting and pipe support .2 Purpose ,
- The purpose of this inspection was to verify the adequacy of the licensee's corrective action program regarding the NRC CAT findings 4 in these areas. This was accomplished by duplicating the examin- l ations required of the licensee and evaluating the results. NRC in- I
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spectors randomly selected weldments and bolted connections during walkdown inspections in the field to provide a representative sample of structural steel welding, slotted connections and bolting, tank welding and pipe support weldin .3 Quality Documents Reviewed The following documents were reviewed in order to provide the basic acceptance criteria for this inspection:
: * M 968 Rev 3 " Field Fabrication and Erection of Piping" i * M 152 " Design and Fabrication of Piping Supports" * Inspection Handbook (piping supports) * Applicable drawings (IS0s)
5.4 Inspection Criteria for Examination of Fillet Welds Through Painted Surfaces Due to the state of construction completion at the site, the welds examined were found to have been painted. Consequently, the inspectors determined those weld characteristics which could reason-ably be inspected over paint. Therefore, the visual inspection of painted structural steel supports and pipe hanger fillet welds were evaluated for the following criteria:
* Support Identifications * Weld size and location * Weld profile, including convexity and concavity
' * Large porosity * Coarse undercut * Overlap 5.5 Results
The specific results are described in section 6 of this repor However, no violations were identifie .0 Inspection of Pipe Hangers, Tanks, and Supports
: 6.1 Vendor Supplied Tanks Seven nozzle connection fillet welds were visually inspected and the welds were gaged. These welds were on vendor supplied-tanks located in the Auxiliary Building (See Table 1). The inspection results com-pared favorably to the licensee's prior examination results, except in one instance where it appeared that the licensee had inadvertently failed to process an N&D report for undersized fillet welds on four heat exchangers. After investigating the inspector was satisfied that the omission was merely a transcription error and not indicative t
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. of a problem with licensee personnel training, or with procedure The licensee issued N&D reports 14253, 14254, and 14255 on August 13, 1985 to document the undersized fillet weld condition No violations were identifie .2 Skewed Weld Joints In Tubular Steel Nine hangers with skewed weld joints were. visually inspected and gaged in the ESF and Auxiliary Building (see Table 2). The inspec-tor also reviewed the Itcensee's actions taken for 133 skewed joints . with identified undersized toe weld The 133 joints included:
* 65 2-sided welds * 68 3-and 4-sided weld The inspector noted that SWEC engineering had_ performed calculations to justify a use-as-is disposition for the 3-and 4-sided welds. The results were found to be satisfactory by the inspector. SWEC had also performed a review of all 2-sided weld Preliminary results of : SWEC's review and re-inspection indicated seventeen supports inside containment required additional welding. Sixteen supports were re-welded in containment. Subsequently, engineering calculations showed
the originally 2-sided. welds would have been' acceptable with no additional welding. Therefore no action was necessary for the one remaining joint in containment. No violations were identifie .3 Pipe Hangers and Structural Supports The following numbers of welds were visually inspected and weld profiles checked as follows: (see table 3) Hangers / Supports Location 19 Auxiliary Building , 13 Diesel Generator Building
, 33 Containment 50 ESF Building Several small bore piping supports and hangers were also inspected for welding and workmanship during the course of the walkdown inspec-tion No violations were-identifie .0 Inspection of Structural Steel Bolting, Washers and Slotted Connections The inspector noted that the licensee had completed a re-inspection of structural steel welds bolting and slotted connections in the Containment
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and Main Steam Building. The licensee had re-inspected the Auxiliary Building and was in the process of correcting the resulting findings. The licensee also identified slotted connections in the Fuel Building and in the Control Building that would require re-inspectio The inspector selected the Auxiliary Building for an independent walkdown in order to observe the conditions found by the licensee and to verify licensee _ corrective action. The following types of items were identified by the licensee and reviewed by the inspector:
* missing bolting * missing washers a bolting installed upside down * improper torque for slotted connections The licensee's corrective action plans for the above problems was judged satisfactory by the inspector.-
3 ~ Additionally, the inspector was verified load indicating washer (LIW) gaps
.and reviewed the acceptability of the washers use No violations were identified.
i 8.0 Review of Preservice Inspection (PSI) Ultrasonic Data for Centrifugally Cast Stainless Steel (CCSS) The inspector, along with licensee representatives held discussions re-garding the adequacy of tne baseline PSI ultrasonic data resulting from the examinations of reactor coolant system welds. Also, during the NDE van inspection (May 20-June 14, 1985), other discussions were held with ! licer.see representatives regarding the same subject. Several concerns l were identified by the inspector, during the current inspection, examples , of which follow: 1 The preservice ultrasonic reports selected for review did not in-dicate whether the results of the examinations were acceptable or rejectable, or show a signature of a licensee representative indi-t cating disposition of the test result . Several ultrasonic reports such as the one for welds LPI-CL-2A-SW-0 , and RCS-LPI-CL2A-1 FMR displayed nozzles.with examination limitations-involving up to 85% of the weld. There were no sketches or other information available with these reports as to the exact location or , the specific causes for the limitations. Also the report for these two welds showed, in the results section, that there were no indica-tions identified. However, when reviewing the actual " ultrasonic indication data sheet, the inspector found documentation of a re-flector which had a peak DAC of 200% with an annotation that indi-cated "ID signal due to OD Configuration". The data on the sheet was i
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thus inconsistent with the "no indications" notation found on the cover sheet of the repor Further evaluation was not included with this report to substantiate the disposition shown on the data sheet.
The report for weld RCS-LPI-FW-EC2-BMR had the same type of findings as above, except that, in.this case, there was included a report of ' examination limitations.that provided only general information as to the location and cause of limitation. In this particular instance, the inspector question whether a change of transducer would have resolved the problem (s) causing the limitation.
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Therefore, as a result of the above findings, the inspector consid-ered the adequacy of the licensee's PSI examination of RCS piping
. welds to be unresolved pending licensee action and NRC review (UNR 50-423/85-46-02). The inspector informed the licensee at a meeting on August 15, 1985 and again at the August 16 exit meeting, that '
licensee management review of the RCS UT data is required to resolve the above concerns.
I
9.0 Review of NRC Region I Welding Inspections Performed Relative to Steel Structures and Supports During the course of inspection 50-423/85-46, a programmatic review of previous NRC welding inspections was conducted to evaluate licensee activ-ities in the welding of steel structures and supports. The following was determined:
* Welding Procedure Specifications and QA Procedure Review Applicable welding procedure specifications >nd QA procedures have been reviewed since initial plant construct . on a routine basis and in detail during the 50-423/85-04 CAT inspection.
.
* Welding Material Control Review
t Welding filler metal control has been evaluated at the same time as the piping filler metal control on numerous inspections and during the CAT inspection.
,
* Observation of Welding Activities Within Containment Observation of welding activities within. containment was evaluated in previous inspections and specifically in detail during the in-spection of restraints for the reactor coolant pip * Observation of Welding Activities Outside Containment
- Observation of welding activities outside of containment was
] : conducted on previous inspections and during the CAT inspection
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l * Welding Heat Treatment (PWHT) Review Review of the applicable structural fabrication. details indicated that no PWHT was contemplated or conducted on safety related
,, weldments at Millstone . * Weider Performance Qualification Review
] Welder qualification for steel structures and supports was conducted
along with reviews of piping welder qualification and specifically during the CAT inspection.
J
* Special Welding Applications
! ' Inspection of ti,e containment cross over pipe restraint, supports to CU-NI piping, LAMC0 component supports, and internal support stands were performed. These inspections were documented in during previous inspection reports and also in the CAT repor .0 NRC/IE Bulletin 79-02-Pipe Support Base Plate Designs Using Concrete Expansion Anchors The inspection effort in this areas was directed toward ascertaining the following aspects relating to the bulletin: a
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Adequacy and timeliness of licensee responses
, --
Conformance of engineering specifications and QC implementing 1 ' procedures to the requirements of the bulletin
i
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Licensee involvement in quality assurance activities relative to work activities and acceptance of disposition of nonconformance
- report ! 10.1 Review of Bulletin Responses
] The inspector ascertained in his review of the licensee's and SWEC's responses to IEB.79-02 that all applicable items of the bulletin received adequate attention. The status of construction in 1979 on , pipe supports precluded the need of testing installed concrete ex- !. pansion anchors, hence tensile testing of completed expansion anchors ! was not required. The bulletin requirements on expansion anchors in i concrete block walls and regarding structural shapes bolted with l expansion anchor bolts were found not to be applicable at Millstone,
since 'SWEC's standard design procedure (EMTR-612) requires the use of support. base plates. Licensee and SWEC were in the owner's group for response to this bulletin and subscribed to the NRC - approved tech-
~
nical tests conducted by Teledyne Engineering.
t
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The Millstone Unit No. 3 specification for Drilled-In Anchors requires that, during the prequalification test program, the minimum installation torque for proper setting of wedge type anchors be establishe (Shell-type anchors were not used for Millstone 3 Category I pipe supports). The test program conducted by Hilti Fastening Systems Inc. at the plant, using two 3, 000 psi concrete test panels, provided the following technical basis to satisfy the bulletin requirements at Millstone # installation torque develops a bolt preload at least 1.5 times the allowable bolt load
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Category I anchors are torque tested to 80% of their torque value at installation, this assures cyclic load capability
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utilization of unique factory markings on bolts was an accep-table approach for denoting overall bolt length 10.2 Licensee QA/QC Involvement Installation of concrete anchors for pipe supports base plate designs at Millstone #3 initially utilized embed plates with shop-welded anchor studs installed prior to concrete placement. Where design
, location of pipe supports had not been finalized, Richmond insert patches were installed prior to concrete placement. The above approach reduced the use of drilled-in wedge-type anchors. When expansion anchors were used, SWEC specification number C924 provided engineering requirements for installation and defined attributes for quality control. Revision number 1 of this specification, used up to January 1983, did not identify spacing of adjacent drilled-in anchors to embedded items. As a result of E & DCR P-S-5029, initiated Jan-
! uary 3, 1985 by SWEC's Boston office following field requests on clarification of spacing requirements by the structural design super-visor, anchor bolt spacing was added as a QC attribute. SWEC Field QC procedure was then similarly revise The specification revision and QC procedure change affected the installed drilled-in anchors, embedded plates and Richmond insert anchors. By agreement between the licensee and SWEC, a Hilti Bolt Spacing Retrofit inspection was undertaken. The program entailed retroactive identification of surface mounted plates that violated the anchor spacing and edge distance required by revision number 2 of specification C924. The retrofit inspection covered approximately 5300 Hilti bolts. The number of unsatisfactory conditions found amounted to 800. QC inspection reports on these Unsat conditions were segregated into three categories by SWEC engineering as follows: i
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i
!
28 , Require.no calculations to disposition _ Require minor calculations to disposition . Require major calculations and possibly rework to !
' disposition The status of dispositions as of the time of this inspection is that 14 inspection reports involving 23 Unsat support conditions are still open. Of the 777 dispositioned Unsat conditions only two required rework modification, the. rest were dispositioned to be Accept-As-I The licensee QA/QC involvement in the above retrofit inspection and . in the close-out of Unsat irs was evaluated by'the NRC inspector. He viewed three NUSCO surveillance reports on Hilti installation /QC inspection prior to issue of the change to specification C 924 iden-tified above and five following the chang These reports reflect licensee involvement and provide details in resolution of technical issues. The licensee's' acceptance for close-out of SWEC responses, where required, was also found to be acceptably documente Based on the above observations, the inspector concluded that NRC IEB 79-02 requirements have been adequately' addressed at Mill-stone Unit . Unresolved Items Unresolved items are matters about which more information is necessary to determine whether they are violations, deviations, or acceptable. Unre-solved items are discussed in paragraphs 3 and . Attachements and Lable References Attachment 1 is a listing of documents reviewed during the course of this inspectio Table 1 is a tabulation of specific Vendor Supplied Equipment inspected and the result Table 2 is a list of skewed fillet weld joints re verififed and the result Table 3 is a list of specific pipe hangers and structural supports in-spected and the associated result .- Exit Interview The_ inspector met with the licensee representatives denoted in para-graph 1 at the conclusion of the inspection. The inspector summarized the scope and applicable findings of this inspection. No written in-formation was given to the licensee by the inspector during the course of this-inspectio _
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29 Attachment 1 - Documents Reviewed Related to FQC ASME Group Document . SWEC Organizational Chart for the FQC ASME Group (current as of August 9, 198 . SWEC QA and QC Manual ASME Section III Division I Sections 9(Rev.A), 10(Rev. M), 17(Rev.J), 20(Rev.N) and 9/ML( Rev.D) . SWEC FCP-122, " Preparation and Correction of Permanent Plant Records", Rev.1, Dated March 5,198 . SWEC 05-14.2, " Inspection Report System", Rev. F, dated February 6, 198 . SWEC NEAM 134, " Processing of ASME III Certification", Rev. 1, dated March 4, 1985 and Change Notices 1 and . SWEC QCI FM3-514.2-120 " Resolution of Incorrect ASME III Code Data Reports" SWEC QCI FM3-514.2-07E "ASME III N-5 Inspections" dated August 7, 198 . SWEC QCI FM3-017.2-010 "ASME III N-5 Data Reports and Associated Documentation" (includes resolving errors in SWEC site documenta-tion) - Draf . NNECO Procedure EN31100, " Post Turnover ASME Section XI Work Control", Rev. 1, dated August 25, 198 . N-5 Boundry Pipe Line Segment Documents: The following ISO document packages were reviewed including applicable WDS. WMR, NDE, and IR records. The number of field welds revised is also indicate * ISO CI-SIL-21A: 20 field welds
*
ISO CP-407023: 20 field welds
*
ISO CP-37501: 29 field welds
*
ISO CI-SIL-507: 6 field welds
*
ISO CI-SIL-43: 19 field welds t
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, 30 Specifications, Procedures, Criteria and Instructions Reviewed Related to Stress Reconciliation Specification M968, " Specification for Field Fabrication and
- Erection of Power Piping". NETM-30, " Procedure for the Preparation, Review, Approval, and Control of Power, Hydraulic, and Environmental Division Stress Data Packages and Engineering Mechanics Division PSAS Documents".
- FCP-337, " Field Construction Procedure for Preparing Stress Recon-
_
,
ciliation Pipping Location Isometrics (PLI's)". NETM-31, " Procedure for Seismic Category I Piping Location Isometric , and Tubing Isometric Review and Stress Reconciliation".
- NEAM 122, " Procedure for As-Built Program". NEAM 134, " Procedure for Processing of ASME III Certification".
i NETM 44, " Pipe Stress Analysis Criteria Document". NETM 45, " Pipe Support and Duct Support Design Criteria Document".
- NEAM 126, " Preparation of Stress Reports for ASME III, Class 1 Piping".
1 NEAM 41, " Procedure for Processing of Calculations".
1 EMD 84-06, " Procedure for Evaluation of Integral Welded Attachments
.
to Piping".
I 1 EMTP 9.13-0, " Integral Welded Attachments to Pipine-New Designs".
1 EMD-80-2, " Stiffness Representation of Supports, Anchors, and Re-l straints for Pipe Stress Analysis and Pipe Support Design".
. 1 QS-14.2, " Quality Control Instruction for ASME III N-5 Inspections".
1 SWEC's QA and QC ASME - Sectior. III Division 1 Manual for Fabrication and Installation Control (Section 9).
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