IR 05000443/1981014
| ML20041B726 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/04/1982 |
| From: | Cerne A, Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20041B724 | List: |
| References | |
| 50-443-81-14, 50-444-81-11, NUDOCS 8202250127 | |
| Download: ML20041B726 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION Region I 50-443/81-14 Report fio.
50-444/81-11 50-443 Docket No.
50-444 CPPR-135 License No. CPPR-136 Priority
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Category A
Licensee:
Public Service Company of New Hampshire 1000 Elm Street Manchester, New Hampshire 03105 Facility Name:
Seabrook Station, Units 1 and 2 Inspection at:
Seabrook, New Hampshire Inspection conducted:
November 17,1981 - January 8,1982
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t!w/b 2-Inspectors:
A. C. Cerne, Sr. Resident Inspector date signed date signed date signed 2-hL Approved by:
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R(fl. Gallo,(Qh4f, Projechs Section 1A, date signed Division of Resident and Project Inspection Inspection Summary:
Unit 1 Inspection on November 17,1981-January 8,1982 (Report No. 50-443/81-14)
Areas Inspected: Routine inspection by the resident inspector of work activities relative to the field fabrication of reinforcing steel; pipe installation, welding, and supports; electrical component storage, supports, and welding; blast monitoring for safety-related effects; and design verification controls. The inspector also reviewed licensee action on previously identified items and performed plant inspection-tours. The inspection involved 68 inspector-hours, including five off-shift hours, by the NRC SRI.
Results: Of the five areas inspected, one item of noncompliance was identified in one area-c Failure to assure that applicable design considerations (ie: thermal pipe growth) were cor-rectly translated into pipe support modification details (paragraph 6c ).
Unit 2 Inspection on November 17,1981-January 8,1982 (Report No. 50-444/81-11)
Areas Inspected: Routineinspectionbytheresidentinspectorofworkactivitiesrelativetg the field fabrication of reinforcing steel; pipe installation and supports; blast monitoring and design verification controls. The inspector also performed plant inspection-tours.
The inspection involved 18 inspector-hours by the NRC SRI.
Results: Of the four areas inspected, one item of noncompliance was identified in one area-c Failure to assure that applicable design considerations (ie: thermal pipe growth) were correctly translated into pipe support modification details (paragraph 6c
).
8202250127 820210 PDR ADOCK 05000443 G
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DETAILS 1.
Persons Contacted Yankee Atomic Electric Company (YAEC)
F. W. Bean, Lead Electrical QA Engineer D. L. Covill, Lead Civil QA Engineer R. S. Faulkner, Staff Assistant (PSNH)
J. H. Herrin, Site Manager (PSNH)
G. F. Mcdonald, Jr., QA Manager (Framingham)
J. F. Nay, Jr., Lead Mechanical QA Engineer J. W. Singleton, Field QA Manager R. Tucker, Engineer (Framingham)
United Engineers and Constructors (UE&C)
M. A. Edgar, Resident Construction Engineer R. A. Kountz, Welding Superintendent D. C. Lambert, Field Superintendent of QA R. A. Mills, Pipe Support Engineer R. D. Tancibok, QA Supervisor Fischbach-Boulos-Manzi (FBM)
M. A. D'Orsay, QA Document Specialist Pittsburgh DesMoines Stieel Co. (PDM)
W. A. Stiger, QA Manager
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Pullman-Higgins(Pullman)
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R. G. Davis, Field QA Manager R. R. Donald, Field QA Supervisor D. B. Hunt, QA Records Supervisor M. MacCrae, NDE Supervisor C. Scannell, Chief Field Engineer Royal Insurance J. C. Anzivino, Authorized Nuclear Inspector Westinghouse R. Powell, Project Manager
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2.
Plant Inspection-Tours (Units 1 and 2)
The inspector' observed work activities in-progress, completed work and plant status in several areas of the plant during general inspections of the plant. The inspector examined work for any obvious defects or noncompliance with regulatory requirements or license conditions. Particular note was taken of the presence of quality control inspectors and quality control evidence such as inspection records, material identification, nonconforming material identification, housekeeping and equipment preservation. The inspector interviewed craft personnel, supervision, and quality inspection personnel as such personnel were available in the work areas.
Specifically, the inspector examined the installed condition of a vertical, structural steel post in the Unit 1 cable spreading room, inspected the connections to the floor embed plate and ceiling structural beam, and checked the authorization (ECA 01/2668A), welding (UE&C Procedure WS-3), and location and size (UE&C drawing F101366, Revision 6) for the erected column. The limited work authorization (LWA) for commencement of installation activities on certain Unit 1, hold-tagged pipe whip restraint components was verified.
The inspector also reviewed the approved procedure (PDM Engineering Corrective Action Request) for repair welding and NDE of an arc strike on the Unit 1 containment liner caused by a defective welding cable and witnessed some field ultrasonic testing of an in-place, Unit 2 containment liner ring plate.
No items of noncompliance were identified.
3.
Licensee Action on Previous Inspection Findings a.
(Closed) Noncompliance (443/81-02-03): Failure to perfonn magnetic particle testing (MT) examination on RPV anchor bolts. The inspector reviewed the licensee response to the NRC Notice of Violation ano verified implementation of the following corrective actions:
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-- Modification of the Vendor Surveillance Check Plan for witness /
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verification of MT.
-- Certification of NDE for anchor bolts included in record data packages.
-- Disposition to UE&C Nonconformance Report (NCR) 849 to accept embedded anchor bolts based upon satisfactory MT of the exposed, threaded sections.
Acceptance of the embedded portions of the anchor bolts is reasonable, since any defects caused by the threading operation are likely to have been also manifested on the exposed sections of the bolts, which the field MT indicated that they were not. The inspector reviewed all relevant records associated with the above corrective actions and considers this item closed.
b.
(Closed) Noncompliance (443/81-05-01):
Failure to qualify a flued head WPS for impact testing. The inspector reviewed Pullman Procedure Qualification Records (PQR) 308 and 324, which successfully qualified
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the questionable Welding Procedure Specification (WPS) and a related WPS to impact test requirements for the proper thickness range.
Pullman NCR 907 has been dispositioned to accept the hold-tagged welds, while corrective measures have included further instruction of QA Process and Engineering personnel. This item is closed.
c.
(Closed) Unresolved item (443/81-12-03): Material discrepancies between supplied pipe and specification requirements. The inspector reviewed the section of UESC Specification 248-1 granting the use of alternative materials upon receipt of written approval.
Certain Dravo Deviation Requests, documenting UE&C concurrence on material substitutions, were examined and the licensee produced evidence that a sampling of material discrepancies indicated that all changes had been previously authorized by either a Deviation Request or a generic memo.
The licensee took action to obtain for the current site record files copies of all Dravo Deviation Requests from the UE&C Home Office.
Concern for changes in future in-service inspection parameters, which may be affected by the material substitutions, were addressed by the licensee in an outline of the programatic steps which would preclude improper ISI based upon erroneous pipe material and thickness assumptions.
The inspector verified QA surveillance of this program and the resultant contractor drawings.
No items of noncompliance were identified.
4.
Blast Monitoring (Units 1 and 2)
During this inspection period, blasting operations have been conducted for the nonsafety guard house foundation. The inspector verified that adequate measures have been implemented to monitor the effects of the blasting upon the nearest safety-related structures.
The responsible licensee and QA personnel were interviewed and the following record samples were examined:
-- UE&C Surveillance Report 1990, December 31,1981.
PSNH Blast Monitor Charts, December 21-28,1981.
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-- Qualification of the Vibration Monitors by an Engineering Geophysics Consultant.
-- Blast Monitors (S/N 134 & 135) Calibration Logs, October 21,1981.
The above blast monitoring and surveillance activities were evaluated with regard to requirements set forth in the following documents:
-- UE&C Quality Control Procedure, QCP 10-2 (Revision 1).
-- UE&C Field Civil Construction Procedure, FCCP-10 (Revision 3).
-- YAEC/PSNH Procedure PSY-1 (Revision 4).
No items of noncompliance were identified.
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5.
Field Fabrication of Reinforcing Steel (Units 1 and 2)
The inspector reviewed and verified the procedural controls over field fa-brication activities of reinforcing steel. He witnessed rebar bending of
- 11 bars in the Unit 2 sid at Elev. (-26) and checked the engineering authorization and documentation (Site Approved Change, SAC 41/2687A).
Certain Perini Supplied Material Deficiency Reports (SMDR) were examined to assure that dispositions authorizing field alteration of supplier fabricated rebar are being directed in accordance with procedural and Code restraints (ASME Boiler and Pressure Vessel Code,Section III, Division 2).
The following documents were reviewed:
-- UE&C Specification 14-2 (Revision 6).
-- UE&C Procedure MPS-3 (Revision 2).
-- Perini Field Civil Construction Procedures, FCCP-160 and 162 (both Revision 1).
-- Perini Quality Assurance Procedure, QAP-10.2 (Revision 3).
The inspector also verified that A/E structural personnel are aware of a recently published article (Concrete International / June 1981) regarding
" strain aging" concerns for cold bent rebar. The licensee is currently evaluating the rebar material properties and the presently instituted rebar bending controls for adequacy in light of any new " state-of-the-art" considerations.
The inspector has no further questions at this time on rebar field fabrication activities. fio items of noncompliance were identified.
6.
Safety-Related Piping a.
Welding (Unit 1)
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i The inspector observed joint preparation, in-process welding, or completed welds on the following pipe spools being installed in the field:
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-- 1-SW-1818-03, Field Weld F0301
-- 1-SI-204-02, Field Weld F0202
-- 1-RC-49-02, Field Weld F0201
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-- 1-CBS-1216-11, Field Weld F1107
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Pullman Field Process Sheets, Weld Rod Store Requisitions, Repair Process Sheets, and Dravo fabrication sketches, as applicable, were checked to verify identification, documentation, and inspection of criteria proce-
durally required for quality welding. The inspector reviewed QC inspection verification of hold point items, fide requirements, and noted the use
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of purge gas and special purge dams (water soluble) where authorized.
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The qualification of procedures for expando joint welding in the service water line and the aoplicability of ASME Code Case fi-237, approved for j
use by fiRR, in the containment spray lines, were verified.
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On a thru-wall repair to the above s'afety injecti.on (SI) weld, the insoector confirmed that a Pullman Memo (5/28/81) had considered and placed limits upon the maximum root gap.
In the area of the same weld, discovery of a rejectable radiographic (RT) indication on the adjacent Class 1 valve (SI-V-47) has resulted in a plan for further single-wall RT to determine if repair is required on the forging itself or only the transition weld overlay.
The inspector noted that weld end prep details provided to the field for the fit up of the above reactor coolant (RC) line to the pressurizer were not in full accordance with UESC Engineering Change Approval ECA 08/1408A. While these parameters are not ASME Section IX essential variables and the quality of the welding is not questioned, Pullman did issue a Nonconfonnance Report NCR 1857 to document the discrepancy and took steps to prevent the recurrence of similar end prep detail mismatches.
The inspector had no further questions on the above items and licensee /
constructor actions.
No items of noncompliarce were identified.
b.
Pipe Erection (Units 1 and 2)
The inspector observed the in-process installation of SW pipe spools in the cooling tower. Material handling, flow direction, and pipe orientation relative to the tapered configuration of the pipe polyurethane elastomer lining were examined.
Spool to spool and spool to valve temporary flange connections were checked for inspection status and procedurally evaluated with regard to requirements specified in the following documents:
-- UE&C Specification 248-51 (Revision 8)
-- Pullman Procedure IX-5 (Revision 8)
No items of noncompliance were identified.
c.
Pipe Supports (Units 1 and 2)
The inspector checked the in-place condition, either final accepted or still in process, of the following pipe supports and compared them with their Pullman detail drawings:
-- 1820-SG-05
-- MS-2-1812-SG-08 Hanger welds, configuration, and location within construction tolerances were all spot-checked with regard to drawing, specification (248-51)
and procedure (Pullman JS-IX-6) requirements.
On MS-2-18'.2-SG-08 the inspector noted a 2" drain line off the supported 24" SW pipe to be in close proximity to the supoort itself. This 24" line is part of the Train B service water loop to the cooling tower. The inspector reviewed ECA 25/0665A which authorized the modification to the subject Unit 2
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i support, as well as a similarly configured Unit 1 Train B support, to accommodate'the 2" drain line. Specification 248-51 requirements regarding the placement of hangers relative to thermal pipe growth considerations were noted. However, when the inspector discussed the thermal growth question with licensee and A/E engineering personnel, it was learned that the ECA had erroneously not considered pipe movement, that the directed modification was improper, and that besides the subject supports, this problem may be generic.
i The modified design of the above hangers presented a potential for loss of service water coolant through drain lines which could be damaged by
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the supports during thermal pipe movement. Since the hanger design
change details issued to the field had apparently neglected this design basis consideration, the inspector informed the licensee Corporate and
Field QA Managers and the Site Manager during an exit interview on i
January 8,1982 that this failure represented a noncompliance with regard to 10CFR50, Appendix B, Criterion III (443/81-14-01 and 444/81-11-01).
7.
Design Verification Controls (Units 1 and 2)
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The inspector reviewed the following UE&C procedures relevant to design control activities for Seabrook Station:
--NuclearQualityAssuranceManual, Procedure 2-A(Revision 3)
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-- Administrative Procedure, AP No. 15 (Revision 13)
-- Field General Construction Procedure, FGCP No. 15 (Revision 6) with i
Interim Procedure Changes thru IPC No. 4 i
Controls are required over the numerous documents which are related to design
changes. The types of documents which are procedurally defined are listed
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below:
-- Design Change Notice (DCN)
-- Engineering Change Approval (ECA)
-- Interim Change Approval (ICA)
-- Field Change Request (FCR)
-- Site Approved Change (SAC)
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-- Request for Infonnation (RFI)
The inspector discussed with licensee and A/E engineering and QA personnel those specific controls being implemented to provide design verification of changes.
PSAR Chapter 17 commitments, and FSAR commitments to USNRC Regulatory Guide 1.64 and ANSI Standard N45.2.11 were utilized to evaluate the established
programmatic and procedural controls.
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While nc items of noncompliance were identified, the inspector's followup of
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the noncompliance in paragraph 6c above resulted in finding that a related ECA
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(25/0811A) had been worked on and issued by a site engineer without any peer review. Further discussion revealed the existence of a site engineering prac-
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tice which allows approval of design change details without the existence of a design review.
Such changes were termed " intuitive" by nature in that it was felt they were simple enough so as not to infringe upon the ultimate design bases.
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While the inspector did not question the simplistic nature of the subject ECA, he asked licensee QA personnel whether this apparent lack of design verification was allowed in light of FSAR and program commitments.
Furthermore, he questioned whether a peer review of ECA 25/0811A may have,
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.in fact, identified the design problem on related ECA 25/0665A, which led to the noncompliance.
It is arguable that the very determination not to seek alternate calculations, analysis, or review, may itself be one type
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of " intuitive" decision which should receive a peer review.
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Pending licensee clarification of how design verification is being implemented for such " intuitive" design changes, this issue is unresolved (443/81-14-02).
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8.
Electrical Inspection (Unit 1)
a.
Supports I
The inspector examined the installed configuration of the following
components with emphasis upon the method of support and qualification i
requirements to IEEE Standard 344 criteria.
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-- Class IE Battery Racks
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--SelectedMotorControlCenters(MCC)andtransformersintheControl l
Building
-- Sample of Seismic Wireway Supports in the Cable Spreading Room Bolting, welding, material substitutions, authorization for design modifications, details of the attached embedded material--all were checked to the governing specification and drawing requirements.
FBM j
Quality Control Installation Reports for the battery racks and wireway supports were spot-checked. The support installations were evaluated i
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j Battery Racks
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-- UE&C Specification 137-1 and ECA 03/1178A
-- Gould Seismic Battery Rack Catalog and Drawing 064293D
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-- FBM Procedures FECP-511 and QCP-511
-- IEEE Standard 484 and USNRC Reg Guide 1.128 i
MCC and Transformers
-- UE&C Drawings F300208 and F300209 and ECA 03/1161A i
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Wireways
-- UE&C Drawings F310509 and F310513
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-- UE&C Cable Tray System Notes and Typical Details, M300229 (SheetsT45,T47,andT112)
No items of noncompliance were identified.
b.
Control Panel Storage l
The inspector examined the storage conditions for five main control board panels placed in a limited access, temporary enclosure in the Unit 1 Control Room. Zone III cleanliness and modified Level A storage criteria i
were verified in accordance with York Modified Operating Procedure t
M0P 214-3637 and UE&C ECA 05/0605A.
Controlled access, heat and humidity control and recording, and QA inspection surveillance activities in the storage area were spot-checked.
The inspector evaluated the above inspection items with regard to the requirements in UE&C FGCP-8 (Revision 4) thru IPC No. 4, the applicable ANSI N 45.2 series standards, and the endorsing USNRC regulatory guides.
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No items of noncompliance were identified.
c.
Preparation for Cable Pulling The inspector reviewed the following FBM procedures to confirm that raceways were being given adequate inspection to preclude damage to the cables during pulling activities:
-- FECP-503 (Revision 1) and FECP-504 (Revision 2)
-- QCP-504 (Revision 2) thru IPC No. 3 While FECP-504 indicated that raceways shall be checked for sharp edges in the pulling area, no existing inspection criteria appeared to cover this requirement. Discussion with licensee QA personnel revealed that this lack of a specific inspection point was noted and documented on a YAEC Deficiency Report DR No. 126 (November 24,1981) prior to the
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inspector's inquiry and also prior to the commencement of safety-related cable pulling.
Before the conclusion of this inspection period Interim Procedure Change IPC No.4 to QCP-503 was issued to instituts a final
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inspection point to the " Quality Control Installation Reporn for Cable j
Tray", insuring the tray is free of burrs or sharp edges.
No items of noncompliance were identified.
9.
Unresolved Items i
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item disclosed during the inspection is
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discussed in Paragraph 7.
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10. Management Meetings At periodic intervals during the course of this inspection, meetings were held with senior plant management to discuss the scope and fi.; dings of this inspection.
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