IR 05000440/1979005
| ML19248D717 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/15/1979 |
| From: | Konklin J, Maxwell G, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19248D706 | List: |
| References | |
| 50-440-79-05, 50-440-79-5, NUDOCS 7908170246 | |
| Download: ML19248D717 (15) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-440/79-05; 50-441/79-05 Docket No. 50-440; 50-441 License No. CPPR-148; CPPR-149 Licensee: The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Units 1 and 2 Inspection At:
Perry Site, Ferry, Ohio Inspection Conducted: May 22-24, 1979 Inspectors:
J. E. Konklin 4 ('/j3/77
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Q't!. 3. ** 'V G. F. Maxwell F
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F. C. Hawkins
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N Approved By:
C. C dill ms, Acting Chief Projects Section 2 Inspection Summary Inspection on May 22-24, 1979 (Report No. 50-440/79-05; 50-441/79-05)
Areas Inspected: Ongoing plant construction activities; licensee actions relative to the resolution of Item 8 of the Region III Immediate Action Letter of February 8,1978; licensee actions relative to the resolution of reportable deficiency per 10 CFR 50.55(e)
regarding embedments; licensee actions relative to the resolution of previously identified items of noncompliance and unresolved items.
The inspection involved a total of 63 onsite inspector-hours by three NRC inspectors.
Results:
Of the areas inspected, one item of noncompliance was identified in one area (infraction - inadequate inspection of concrete work activities - Section III, Paragraph 1).
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DETAILS Per:ons Contacted Principal Licensee Employces
- M. Edelman, Manager, Nuclear QA Department
- G. Groscup, Manager, Nuclear Engineering Department
- D. Fitzpatrick, Site Construction Manager
- W. Kacer, CQS General Supervising Engineer
- J. Pepp, CQS Senior Secretary Other Personnel
- P. Gibson, CQS Quality Control Supervisor (KEI)
- R. Vondrasek, CQS Quality Engineering Supervisor (GAI)
J. Mehaffey, CQS Lead Mechanical Quality Engineer (GAI)
J. Connelly, CQS Lead Civil Quality Engineer (GAI)
R. Crofton, CQS Lead Piping Quality Engineer (GAI)
- T. Arney, Program Manager (GAI)
W. Ware, CQS Civil Quality Engineer (GAI)
M. Brown, CQS Mechanical Quality Engineer (GAI)
J. Bahleda, CQS Civil Quality Engineer (GAI)
W. Eiff, CQS Civil Quality Engineer (GAI)
R. Czyzewski, CQS Civil QC Inspector (KEI)
T. Hesmond, National Engineering QA/QC Manager W. Tu_k, Great Lakes Civil QC Inspector R. Mauchline, Structural Engineer (GAI)
- Denotes those who attended the exit interview.
The inspectors also contacted other licensee and contractor employees, including members of the quality, technical and engineering staffs.
Licensee Action on Previous Inspection Findings (Closed) Open Item (440/79-02-01; 441/79-02-01): Backfill sampling and testing frequency discrepancies between Ernst-Comstock QA/QC Procedure 4.3.12 and CEI/E-C Contract Specification SP-33-4549-00.
The inspector reviewed the revised E-C QA/QC Procedure No. 4.3.12 and determined that it now reflects the sampling and testing requirements set forth in Specification SP-33.
This item is considered to be closed.
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(Closed) Unresolved Item (440/78-11-01; 441/78-10-01):
CEI embedment inspection program; findings of CEI audit No 52.
As a result of NRC findings concerning embedments, the licensee identified a 10 CFR 50.55(e) item and conducted Audit No. 52 of the embedment inspection program.
During this inspection, the inspector closed the reported 50.55(e) item and verified that all 12 AAR's which had been issued as a result of Audit No. 52, concerning the embedment inspection program, had been closed.
The 10 CFR 50.55(e) item is discussed in detail in Section III of this report. This item is closed.
(Closed) Noncompliance (4/s0/78-02-16; 441/78-01-16):
Safety related embedments tnd reactor building structural steel column weldments which failed to meet the requirements of AWS D1.1-72.
Subsequent to this finding, the licensee identified a 10 CFR 50.55(e) item concerning embedments. The 10 CFR 50.55(e) item was closed during this inspection.
(Refer to Section III of this report.) The licensee initiated and completed the repair of the 17 reactor building columns and the 100%
magnetic particle testing of fillet welds. The control complex steel was also visually inspected and 20% of that steel was magnetic particle tested by PBI.
In addition, the annulus platform steel was visually examined and 20% of it was selected for 100% magentic particle testing at Levinson Steel with site representatives present.
Based on these examinations, the steel was determined to be acceptable for use on site. This item is closed.
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Section I Prepared by J. E. Konklir.
Reviewed by C. C. Williams, Acting Chief Projects Section 2 1.
Licensee Actions Relative to Region III Immediate Action Letter of February 8, 1978 The inspector reviewed licensee actions relative t o the resolution of Item 8 of the RIII Immediate Action Letter (IAL) of February 8, 1978.
Previous RIII inspections, as documented in Reports No.
50-440/78-11, 50-441/78-10; No. 50-440/78-13, 50-441/78-12; No.
50-440/78-16, 50-441/78-15; and No. 50-440/79-01, 50-441/79-01 have covered specific aspects of the development and implementation of the revised CEI QA Program. The purpose of this inspection was to close the review cycle by comparing the quality assurance requirements of selected site contractors to the overall require-ments of the revised CEI QA Program, to determine whether the revised requirements are being adequately factored into the contractors' QA programs and procedures.
This section of the report discusses the reviews of the QA programs and procedures for two of the four site safety related concrete placement contractors, Dick Corporation and S&M Constructors, Incorporated (S&MC).
Section II of this report discusses similar reviews for three other major site contractors which perform safety related work, Pullman Power Products (PPP), Newport News Industrial Corporation (NNIC), and Pittsburgh Bridge and Iron (PBI).
With regard to the evaluation of the Dick Corporation QA require-ments, the inspector reviewed the following:
The Dick Corporation Quality Assurance Program Manual, a.
Revision 1, dated December 15, 1975.
b.
The Dick Corporation Quality Control Manual, dated April 19, 1979, including the Field Quality Control Procedures (FQCs).
c.
Attachment Specification SP-708-4549-00, Revision 6, dated February 6, 1979, " Structural Contractors Quality Program Requirements for Safety Related Structures."
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Attachment Specification SP-202-4549-00, Revision 5, dated
.\\pril 5, 1978, " Placing of Reinforcing Steel for Safety Class Structures."
GAI letter to Dick Corporation, PY-GAI/ CON-638QA, dated e.
February 8, 1979, with enclosure, which presents the results of a review of the conformance of the Dick Corporation QA Program to the quality level specifications.
f.
Engineering Change Notice (ECN) No. 2022-19-42, dated May 3, 1979; ECN No. 1994-19-41, dated April 12, 1979; and ECN No. 1629-19-32, dated February 15, 1979, all of which modify the Dick Corporation quality requirements to provide conformance.
The inspector noted that, although the Dick Corporation Quality Assurance Program Manual, which was issued in 1975, does not contain references to the Regulatory Guides and ANSI Standards committed to in the CEI QA Program, appropriate requirements are contained in other Dick Corporation specifications and procedures. For example:
FQC-13.1, Revision 2, references ANSI N45.2.2 and contains a.
appropriate instructions for storage of reinforcing steel, embedments, and cadwelding materials.
In this regard, it should be noted that storage of concrete materials is the responsibility of the batch plant operator, National Mobile.
b.
ECN 2022-19-42, dated May 3, 1979, modifies SP-708-4549-00 to include appropriate housekeeping requirements in accor-dance with ANSI N45.2.3.
c.
FQC-1.2, Revision 0, references ANSI N45.2.6 and contains appropriate instructions regarding qualification of inspec-tion and testing personnel.
In addition, SP-708-4549-00 requires trat inspection and testing personnel be qualified in accordaace with ASNI N45.2.6.
With regard to the evaluation of the S&MC QA requirements, the inspector reviewed the following:
a.
The S&MC Nuclear Quality Assurance Manual, Revision 1, dated October 7, 1976.
b.
The S&MC Standard Operating Procedures QAP-001 through QAP-013 and QCP-101 through QCP-107.
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c.
Attachment Sp.ecification SP-708-4549-00, Revision 6, dated February 6, 1979, " Structural Contractors Quality Program Requirements for Safety Related Structures."
d.
GAI letter to S&MC, PY-GAI/ CON-635QA, dated February 8, 1979, with enclosure, which presents the results of a review of the conformance of the S&MC QA Program to the quality specification requirements, including a summary of the deficiencies identified and the corrective actions to be taken for each item.
e.
ECN No. 2026-29-53 dated May 3, 1979, ECN No. 1998-29-52,
??ted April 12, 1979, and ECN No. 1633-29-47 dated February 15, 1979, all of which modify the requirements of SP-708-4549-00, Revision 6, to provide conformance.
The inspector noted that the detailed conformance review of tne S&MC QA requirements documented by GAI (d. above)
identified all of the RIII inspector's concerns except for one, the lack of an S&MC rigging and hoisting procec'ure.
Since the S&MC tunnel work will require the lifting and handling of large safety related items, such as the two tunnel intake structures, there is a need for an approved rigging and hoisting procedure in the S&MC program. The inspector discussed this matter with the licensee, who
' ben provided the inspector with a copy of a letter from CEI to S&MC, dated January 30, 1979, i:hich advised S&MC of the need for a rigging and hoisting procedure for the tunnel intake structures. The licensee stated that such a procedure will be required prior to shipment of the intake structures to the site.
Based on the reviews of the Dick Corporation and S&MC QA require-ments, discussed above, and the reviews of the PPP, NNIC, and PBI QA requirements, discussed in Section II of this report, the inspectors concluded that the revised CEI QA Program require-ments are being adequately factored into the QA programs of the site safety related contractors. Therefore, Item 8, the last remaining open item of the RIII Immediate Action Letter of February 8, 1978, is now considered to be closed.
2.
Licensee Actions Relative to HVAC Contractor Deficiencies The inspector discussed with the licensee and reviewed docu-mentation relative to deficiencies which had been identified in-6-
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the activities of Robert Irsay Company (RICO), a site contractor with responsibility for safety related HVAC work. The defi-ciencies had been reported by a site employee to the CEI CQS Supervisor, and involved documentation, material traceability, and inspection manpower problems in the RICO work. Specifically, the inspector reviewed the following:
a.
PNPP Audit Report No. 272, dated May 3, 1979, and the three associated Action Requests (ARs), regarding inade-quate documentation of weld inspections and lack of qualified QC inspection personnel by RICO.
b.
Minutes of Meeting, dated May 7, 1979, between the licensee and RICO, to discuss the licensee's concerns regarding the above deficiencies.
c.
The RICO report, dated May 7, 1979, recirding RICO Stop Work Action No. 1, dated May 2, 1979. The RICO report discussed in detail the actions being taken by RICO to correct the deficiencies noted in the E!PD udit.
d.
CEI letter to RICO, dated May 14, 1979, which indicates acceptable responses by RICO on each of the ARs associated with Audit Report No. 272.
Based on the discussions with the licensee, and the review of the aboxe documents, the inspector concluded that appropriate actions are being taken by the licensee and RICO to correct the identified deficiencies.
3.
Zero-Degree Pipe Whip Restraints The inspector discussed with the licensee defects which had been found by the licensee in welds on the Unit 1 zero-degree pipe whip restraint. The defects are discussed in Deviation Analysis Report DAR-003, dated April 26, 1979, as well as in three CQC Nonconformance Reports, NRs No. 1158, 1159 and 1160, which detail the specific defects.
The Unit I restraint has been shipped from the Site to the Newport News shop in Greenville, Tennessee, where ultrasonic testing of 95% to 99% of the welds will be done. The Unit 2
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restraint, which is 40% to 50% complete, is at the vendor's (Raynor Industries) shop. The welds on the Unit 2 restraint will be 100% UT'd prior to acceptance by CEI.
The licensee stated that, depending on the results of the reinspection of the Unit I restraint, an evaluation will be made to determine whether a report per 10 CFR 50.55(e) will be made to Region III.
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Section II Prepared by G. F. Maxwell Reviewed by D. W. Hayes, Chief Engineering Support Section 1 CEI Action Relative to RIII Immediate Action Letter of February 8, 1978 1.
The inspector interviewed several CEI QA personnel and reviewed correspondence which CEI has generated relative to Item 8 of
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the RIII Immediate Action Letter of February 8, 1978. The inspector observed that CEI has taken action to ascertain continuity between site contractor's QA programs and the appli-cable CEI Project Administrative Procedures (PAPS), and thereby, commitments to certain Regulatory Guides.
2.
The inspector compared Project Specification SP-709-4549-00, Rev. 4 (Draft 2) - titled " Contractors Quality Program Requirements for Safety Related Installation / Erection" with the requirements of the CEI Corporate QA Program Section 0700, Paragraph 1.1 and the applicable CEI PAPS. The specification was then compared with the QA Manuals and procedures being utilized by two site contractors; Newport News Industrial Corporation (h'NICO) and Pullman Power Products (PPP).
The Pullman Power Products Corporate Field QA Manual a.
(dated Februa ry 1, 1979) and procedures numbers XVIII-1 (November 3, 1978), XIII-5 (February 14, 1979), XIII-4 (April 25,1978), II-5 (February 12, 1979), XVII-1 (March 5, 1979), XVII-4 (September 1, 1978), III-4 (March 5, 1978),
IX-3 (September 20, 1978), and XIII-4 (April 25, 1978)
were compared with specific requirements in SP-709-4549-00, Rev. 4 (Draft 2).
The specific requirements included those for:
(1) Quality assurance program requirements during construc-tion - Regulatory Guide 1.28/ ANSI N45.2.
(2) Quality assurance requirements for cleaning of fluid systems and associated components of water cooled nuclear power plants - Regulatory Guide 1.37/ ANSI h45.2.1.
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(3) Quality assurance requirements for packing, shipping, receiving, storage and handling of safety related items - Regulatory Guide 1.38/ ANSI N45.2.2.
(4) Housekeeping requirements - Regulatory Guide 1.39/
(5) Qualification of nuclear power plant inspection, examination and testing personnel - Regulatory Guide 1.58/ ANSI N45.2.6.
(6) Collection, storage and maintenance of quality assurance records - Regulatory Guide 1.88/ ANSI N45.2.9.
(7) Quality assurance requirements for installation, inspection and testing of mechanical equipment and systems - Regulatory Guide 1.116/ ANSI N45.2.8.
(8) Requiremer.ts for auditing of Quality Assurance Programs for nuclear power plants - ANSI N45.2.12.
b.
The Newport News ASME QA Manual (Rev. C) with Perry site addendum Rev. B) and procedural instructions numbered 701-NCWH001 (Rev. E) and 701-NI002 (Rev. D) were compared with specific requirements in SP-709-4549-00, Rev. 4 (Draft 2).
The specific requirements included those for:
(1) Quality assurance program requirements during construc-tion - Regulatory Guide 1.28/ASNI N45.2 (2) Quality assurance requirements for cleaning of Fluid Systems and associated components of water cooled nuclear power plants - Regulatory Guide 1.37/ ANSI N45.2.1.
(3) Quality assurance requirements for packing, shipping, receiving, storage and handlint of safety related items - Regulatory Guide 1.38/A:lSI N452.2.
(4) Housekeeping requirements - Regulatory Guide 1.39/
ASNI N45.2.3.
(5) Qualification of nuclear power plant inspection, examination and testing personnel - Regulatory Guide 1.58/ ANSI H45.2.6.
(6)
Collection, storage and maintenance of quality assurance records - Regulatory Guide 1.88/ ANSI N45.2.9.
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(7) Requirements for auditing of Quality Assurance Programs for nuclear power plants - ANSI K45.2.12.
3.
The inspector compared Project Specification SP-708-4549-00, Rev. 6 - titled " Attachment Specification Structural Contractors Quality Program Requirements for Safety Related Structures" with the requirements of the CEI Corporate Nuclear QA Program Section 0700, Paragraph 1.1 and the applicable PAPS.
The specification was then compared with the QC/QA Manual (November 22, 1978) of PBI, a sitc contractor responsible for installation and inspection of safety related structural steel. The specific requirements which we'.e compared with SP-708-4549-00, Rev. 6, were those for:
Quality assurance program requirements during construction -
a.
Regulatory Guide 1.28/ ANSI N45.2.
b.
Quality assurance requirements for packing, shipping, receiving, storage and handling of safety related items -
Regulatory Guide 1.38/ ANSI N45.2.2.
c.
Qualification of nuclear power plant inspection, examina-tion and testing personnel - Regulatory Guide 1.58/ ANSI N45.2.6.
The inspector was informed by the licensee that PBI's activities are very limited, i.e. they only purchase welding filler material; receive and store structural steel and bolting materials; nupervise installation and conduct installations of structural s. eel.
The inspector considered that, for the activities being concacted by PBI, relative to aforementioned ANSI Standards, the PBI QC,lA Manual (November 22, 1978) is adequate.
No items of noncompliance were identified.
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Section III Prepared by F. C. Hawkins Reviewed by D. W. Hayes, Chief Engineering Support Section 1 1.
Observation of Concrete Work Activities and Related Quality Records a.
Pre-Placement Inspection (AX2-WO5A-650) - On May 23, 1979, the inspector performed a pre placement inspection of Placement No AX2-W05A-650. The Auxiliary Building II rattlespace wall contained approximately 90 cubic yards of concrete and was place' by the National Engineering Contracting Company (h..C).
At approximately 12:30 p.m. the CEI QC inspector was requested by NECC QC to release Placement No. AX-WO5A-650 for concrete placement. After completion of his pre-placement inspection, the CEI inspector requested the pour be " blown out" again to assure proper cleanliness of the reinforcing steel, horizontal and vertical construction joints, and formwork as required by NECC Procedure QP 10.1, Rev. 13.
At approximately 2:00 p.m., NECC production personne)
ordered grout to begin the rattlespace wall placement.
At that time, the RIII inspector identified embedded duct tape in the vertical keyed construction joint, contaminated reinforcing steel, and general unacceptable cleanliness of the horizontal construction joint. The accompanying CEI QE representative concurred with the inspector and requested that NECC continue the clean-up of the pour area. At approximately 3:15 p.m.,
the pour area was satisfactorily prepared and concrete placement commenced.
The licensee was advised that this failure to execute the program for inspection of activities affecting quality to verify conformance with documented instructions, procedures, and drawings is considered an item of noncompliance with the requirements of 10 CFR 50, Appendix B, Criterion X.
(440/79-05-01; 441/79-05-01)
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Placement Inspection (AX2-W05A-650)
(1)
In-Process Concrete Testing (a) United States Testing field QC personnel performed slump, temperature and percent ent. rained air tests as follows:
Ticket No.
Slump (in.)
Temp. ( F)
% Ent. Air 39445 3 1/2
6.4 39446 3 1/2
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39454 3 1/2
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39464 4 1/4
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All test results were within the allowed limits and performed at the frequencies specified.
(b) Fi21d curing houses which were suitably equipped to maintain freshly cast compressive strength cylinders at the initial curing temperature specified by ASTM C31 were inspected.
(c) The inspector reviewed the training and qualification records of three U. S. Testing QC field technicians and determined that each met the requirements of ANSI N45.2.6.
(2) Delivery and Placement (a) Concrete was pumped to the placement area and deposited via concrete drop chutes which ade-quately confined the concrete with a maximum five foot free fall.
(b) Concrete was observed to be properly consoli-dated using internal concrete vibrators which had been checked to verify the 8000 VPM frequency required by ACI 301-72, Chapter 8.
These checks had been properly documented on the NECC placement checklist as required by NECC Procedure QA 10.1, Rev. 13.
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Post-Placement Inspection Curing - During a check to determine the adequacy of the NECC and Great Lakes Construction Companr (GLC) concrete
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curing programs, the inspector observed on May 22, 1979, that placement numbers RWO-W20A (GLC), EPH-W2-638 (GLC),
and RWO-W3R-645 (GLC) were not being cured in accordance with Specification SP-201, Section 1.15, and ACI 301-72, Chapter 12.
On May 23, 1979, tbc inspector identified placement numbers IBO-W-02-652 (NECC) and DGl-S-01-635 (NECC) which were not being properly cured. The accom-panying CEI QE inspector concurred with the RIII inspector's observaticat and took appropriate action to correct the nonconforming conditions.
Several discussions over the inter:t c f *he ACI 301-72, Chapter 12, curing requirements were nela.
It was mutually agreed that, to properly cure concrete, an effective moisture barrier must be establiGhed at the concrete surface. To accomplish this, the licensee agreed that the curing medium must be in contact with the surface to be cured.
These failures to execute the program for inspection of concrete curing to verify conformance with Specification SP-201 and ACI 31-72 are considered fur' sher examples of noncompliance as cited previous 2y in Section 1 a of this report.
(440/79-05-01; 441/79-05-02)
2.
Observation of Non-Shrink Grout Work and_1: elated Quality Records The inspector observed in process grouting in Auxiliary Building 2, at elevation 568. The following specific observations were made:
Review of the NECC Pre-Placement Checkout. Record confirmed a.
that all applicable check points had been met and signed off by the responsibie QC inspector prior to the commence-ment of grouting work.
b.
The NECC QC inspector was present to assure proper mixing and placing of the Masterflow 713 Grout in accordance with MECC Procedure QP 10.1, Rev. 13.
The inspector verified that four 2" grout cubes were cast c.
by U. S. Testing as required by NECC Procedure SP 10.1, Bev. 12, Section 1.5.
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Review of 10 CFR 50.55(e) Item Reported by the Licensee -
(Embedment Evaluation Report)
On May 21, 1979, the RIII inspectors discussed with CEI and GAI representatives the following two specific questions with regard to the embedment evaluation:
a.
Does the embedment report take into account the fact that embedded studs will be loaded in shear and in combinations of shear and tension? Response: No separate mention of combine shear and tension loadings was made because the method of investigation was to test weld quality.
Since the weld quality was adequate, as demonstrated by the tensile tests, there was no further concern that the studs would not perform as intended.
b.
Are the tension tests suitable for evaluating stud welds since studs are used in tension, shear, and combinations of both? Response: The direct tension test was chosen for several reasons:
(1) An incomplete weld would show up in lower tension test results, both from a reduced area effect and also from a possible notch effect.
(2) The tensile test is a standard test (AWS Dl.1, Section 4) involving a minimum number of variables.
In contrast, a shear test would introduce at least one additional variable by the concrete medium and could have a wider variance of test results independent of the weld quality. Reduced stud capacities due to weld defects, would therefore, be more readily identi-fiable in a tension test.
As additional juttification for the tensile tests, the licensee again mentioned the general conservation of the testing. The studs chosen were all non-conforming studs (except for 15 control specimens) and were, therefore, representative of the poorest workmanship.
Secondly, a majority of the studs had been bent 10 -20 during their inspection in accordance with the AWS recommendation for nonconforming welds. These studs were straightened before testing. The bending and straight-ening was an additional challenge to the stud welds. The third conservatism was the extent of testing. The number of specimen tests (83 nonconforming studs) was more than 1/3 of the estimated in place nonconforming studs. This testing produced only seven 14 -
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weld failures (all.other studs failed in the shank).
For all seven of the weld-failure specimens, the stress levels at failure exceeded the required 60,000 psi ultimate stress level.
The RIII inspectors concurred with the licensee that the method
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of test used to evaluate studs was suitable, and that the capability of the embedded studs was demonstrated through this test program.
This item is considered to be closed.
Exit Interview The inspectors met with site staff representatives (denoted under Persons Contacted) at the conclusion of the inspection or. May 24, 1979. The inspectors summarized the purpose and findings of the inspection. The licensee acknowledged the findings reported herein.
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