IR 05000443/1982001
| ML20042A337 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/04/1982 |
| From: | Cerne A, Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042A322 | List: |
| References | |
| 50-443-82-01, 50-443-82-1, 50-444-82-01, 50-444-82-1, NUDOCS 8203230337 | |
| Download: ML20042A337 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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Region I 50-443/82-01
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Report No.
50-444/82-01 50-443 Docket No.
50-444 CPPR-135 License No. CPPR-136 Priority Category A
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Licensee:
Public Service Company of New Hampshire 1000 Elm Street Manchester, New Hampshire 03105 l
Facility Name:
Seabrook Station, Units 1 and 2 Inspection at:
Seabrook, New Hampshire Inspection conducted:
January 11-February 12,1982 Inspectors:
A. C. Cerne, Sr. Resident Inspector date signed
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date signed date signed Approved by:
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R. 'M. Gallo, Chief, Projects Section 1A, da':e' signed
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Division of Project and Resident Programs Inspection Summary _:
Unit 1 Inspection on January 11-February 12,1982 (Report No. 50-443/82-01)
Areas Inspected: Routine inspection by the resident inspector of work activities relative to pipe installation, welding, and supports; structural steel connections; electrical race <
l way supports and containment penetration welding; and the cadweld testing program. The
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inspector also reviewed licensee action on previously reported 10CFR50.55(e) items and per)
formed plant inspection-tours. The inspection involved 79 inspector-hours, including sevee l
off-shift hours, by the NRC SRI.
Results:0f the five areas inspected, one item of noncompliance was identified in one area-Failure to clearly establish and assign responsibility for the modification (ie: stiffening]
of structural beams necessitated by certain electrical raceway support installations (
(Paragraph 8).
Unit 2 Inspection on January 11-February 12,1982 (Report No. 50-444/82-01)
Areas Inspected: Routine inspection by the resident inspector of work activities relative te l
general welding practices, the cadweld testing program, licensee action on previously re-
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ported 10CFR50.55(e) items, and plant inspection-tours. The inspection involved eleven inspector-hours by the NRC SRI.
Results: No items of noncompliance were identified.
e203230337 820304 PDR ADOCK 05000443
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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. E. Guillette, QA Engineer (Framingham)
J. H. Herrin, Site Manager (PSNH)
W. P. Johnson, Vice President (Framingham)
G. F. Mcdonald, Jr., QA Manager (Framingham)
J. F. Nay, Jr., Lead Mechanical QA Engineer R. P. Pizzuti, Construction Manager (Framingham)
J. W. Singleton, Field QA Manager
'w. B. Sturgeon, Jr., Station Superintendent (PSNH)
R. Tucker, Engineer (Framingham)
United Engineers and Constructors (UE&C)
R. L. Brown, Lead Piping / Mechanical Engineer D. C. Lambert, Field Superintendent of QA R. A. Mills, Lead Pipe Support Engineer J. J. Murphy, Area Field Engineer S. R. Rozelle, Project Superintendent of Disciplines G. D. Scholler, Area Field Engineer R. D. Tancibok, QA Supervisor Fischoach-Boulos-Manzi (FBM)
M. A. D'Orsay, QA Document Specialist H. P. Patel, Project Engineer i
L. A. Shea, Project QC Manager Pullman-Higgins (Pullman)
R. G. Davis, Field QA Manager
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l R. R. Donald, Field QA Supervisor
D. B. Hunt, QA Records Supervisor i
L. P Puzo, Construction Superintendent C. Scannell, Chief Field Engineer Royal Insurance l
J. C. Anzivino, Authorized Nuclear Inspector
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G. Voishnis, Authorized Nuclear Inspector Westinghouse R. Powell, Project Manager l
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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.
No items of noncompliance were identified.
3.
Evaluation of 50.55(e) Reports and Actions The following items were reported by the licensee as Construction Deficiency Reports under the provisions of 10CFR50.55(e).
-- Undetectable Failure in the Engineered Safety Features Actuation System - P-4 Circuit
-- Control and Protection System Interaction relative to the Volume Control Tank Level Both of these items were reported to the licensee and to the NRC separately by the NSSS (Westinghouse).
Final licensee reports on these generic issues indicate an intent to implement Westinghouse recommendations in the employment of plant procedures which will be written to assure proper operator action and testing for safety system operability.
The inspector verified that specific necessary corrective action has been communicated to the licensee by Westinghouse and that the operational staff has been made aware of the additional procedural requirements. Discussion l
with PSNH station staff personnel confirmed that 50.55(e)/Part 21 report
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items will be utilized as input to a tracking system for reviewing and verifying the adequacy of operating procedures.
The inspector has no further questions on the handling of these items.
i 4.
Cadweld Testing Program (Units 1 and 2)
The inspector reviewed licensee action on two separate issues identified l
by the contractor personnel as nonconforming cadweld conditions and documented in Perini Nonconformance Reports (NCR) 2401 and 2407.
a.
NCR 2401 - Cadweld Test Failure of a #18 rebar sister splice:
Stoppage cf cadwelding work using sleeves of the affected lot number was effected immediately. Additional cadweld sister splices were fired and tested in accordance with ASME Section III, Division 2, Article CC-4333.4.5(b), and they passed. The sampling frequency was started anew in accordance with the regulatory position on substandard tensile
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te'st results in USNRC Reg Guide (RG) 1.10.
Disposition of the NCR to accept-as-is was justified by the Review Bohrd, b.
NCR 2407 - Improper method of casting sister splices identified on
- 18 rebar test samples:
Investigation of available sister splices tested between December 11,1981 and February 8,1982 revealed that seven had rebar left intact prior to cadwelding. Upon discovery of the problem, a 100% fit-up inspection program for sister splices, which had been reduced to a sampling program as of December 14,1981, was reinstituted.
100% final inspection of cadwelds has always been in effect. The seven production splices, which the improper-sister cadwelds represented, were cut out of the Unit 1 dome and tensile tested in the presence of the NRC resident inspector. All passed the test with a low recorded reading of 97 ksi (Note: 75 ksi is required).
It should be noted that the identified improper technique used to cadweld the sister splices could not have been actually used in any structures,
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since the rebar located there are by nature two separate pieces, requiring the cadweld splice.
Future issuance of rebar for cadweld sister test splices will consist of two separate sections, precluding the recurrence of this problem.
The inspector reviewed the current status of NCR 2407 thru Revision 2, as well as, additional information, memoranda, review board responses, and the governing Perini procedure, QAP 10.3 (Revision 5) with Interim Procedure Change IPC No. 1.
While the investigation continues and the NCR remains open, the inspector believes that the current data and test results support the position that no evidence of improper cadwelding actually exists in the in-place structural rebar. He has no further questions on this issue at this time.
No items of noncompliance were identified in the licensee's handling of either of the above nonconforming conditions.
5.
Safety-Related Piping (Unit 1)
a.
Welding The inspector observed joint preparation, in-process welding, or completed welds on the following pipe spools being installed in the field:
-- 1-RH-160-04, Field Welds F0405 and F0408
-- 1-CS-318-02, Field Weld F0204
-- 1-RC-49-02, Field Weld F0201
-- 1-RH-159-03, Field Weld F0302
-- 1-RC-08-01, Field Weld F0103 Pullman Field Weld Process Sheets, Weld Rod Store Requisitions, and Welding Procedure Specifications were checked to verify identification, documentation and inspection of criteria procedurally required for quality welding.
QC inspection verification of hold point items on the weld process sheets was noted and some welders were interviewed regarding
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tec biques and in-process controls.
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The inspector reviewed applicable nonconformance reports (eg: NCR 1373 for the CS318 weld), Field Instruction FI-132 for Reactor Coolant (RC) loop piping installation, and isometric drawings for specific requirements.
On the RH-160 welds, the inspector determined that the wrong filler metal (ER + E308) had been specified on the isometric drawing and welded into the 316 stainless steel base metal joint.
Upon further checking, it was learned that this had already been identified by Pullman personnel and an NCR was being drafted. While the metallurgical concerns of such a mistake may be of little significance, the programmatic cause was discussed with licensee and contractor QA personnel and the inspector verified proper attention to this issue beyond the technical disposition to the NCR.
No items of noncompliance were identified.
b.
Pipe Supports
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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:
-- 160-SG-1801 g
-- MS-1201-SG-08 (NCR 439 Corrective Action)
-- 287-SG-07 and 08
-- 251-SG-34
-- CBS-TK-101A (Encapsulation Tank)
Pullman' Hanger Field Weld Process Sheets were examined for documentation of the correct weld joint status, to include hold point inspections.
The inspector spot-checked hanger material and weld dimensions,
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identification and configuration. Welding items were evaluated with regard to the criteria delineated in the following documents:
-- ASME Section III, Subsection NF (Winter '77 Addenda)
-- ASME Division 1 Appendix XVII
-- UE&C Procedure WS-1-NF
-- Pullman Procedure JS-1X-6 (Revision 2)
No items of noncompliance were identified.
c.
Piping Runs and Components The inspector traced the routing of the installed portions of the following pipe runs, spot-checking components, supports and overall dimensions and clearance.
-- RC Pump seal water flow piping (ISO CS-327)
-- Chemical and Volume Control charging flow piping (ISO CS-355-01)
-- Residual Heat Removal and Safety Injection fl u piping to the RC system hot legs (IS0s RH-159, RH-160, and SI-251)
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Specific attention was paid to redundant pipe routing in light of comon mode failure considerations, committments made in the Seabrook
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Station FSAR, section 3.68, and RG 1.70 guidance.
P&I drawings, applicable NCR documentation, and pipe support details were all reviewed, as applicable.
In the CS-327 pipe run, the inspector identified a section of piping out-of-tolerance with respect to both its placement on support 327-SG-02 and its position relative to established wall line (reference: UE&C Specification 248-51, Revision 8). Upon confinnation of this condition, Pullman issued an NCR and discussed with the inspector the planned program for verification of "as-built" piping conditions with regard to design allewance and further stress calculation. The inspector noted the recent issuance (December 30,1981) of Revision 1 to UE&C Administrative Procedure AP-39 covering "As-Built Documents" and determined that the existing program would have ever:ually accounted for such an error.
On this same CS-327 line, however, the inspector found the piping running across or in contact with pipe supports (eg: MS-332-RG-5 and MS-328-SG-06) the design of which had not considered any loadings imparted by this piping. While the pipe support drawings had indicated the subject line as a " phantom" (unidentified) pipe with clearance requirements which could be inferred from the relative elevations, the allowable construction tolerances in the location of either the pipe or the pipe support negated these clearances.
Discussion with UE&C engineering personnel revealed that construction tolerances had not been considered in the design routing of such " phantom" lines. Further discussion with licensee engineering personnel revealed not only the generic applicability of this issue, but also its relation to the noncompliance identified in the last NRC inspection report (IR 443/81-14 and 444/81-11) regarding support installation to assure the free thermal growth of pipes.
In recognition of these clearance problems, the licensee is working with UE&C toward the issuance of a general clearance directive to account for all potentially adverse movement of piping and o Qer items relative to each other.
Pending promulgation of the necessary guidelines to address these concerns and assure that items can be constructed such that all relevant design basis location requirements are considered, this issue is unresolved (443/82-01-01).
l The inspector also examined selected components, as noted below, in i
their installed location and reviewed the documentation packages on these items for conformance to procurement specification requirements.
-- Globe Valve CS-V-141 l
-- Butterfly Valves COP-V-01 and 04
-- Gate Valve SI-V-47 No items of noncompliance were identified.
d.
Pioe and Suoport Installation - General (Units 1 and 2)
While inspecting various pipe and pipe support installations, certain discrepancies between UE&C specification requirements and actual practice l
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or contractor procedures were identified.
For example, UE&C Specification
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248-51 indicates a specific sequence of pipe attachments to equipment nozzles, which in fact was not followed in the welded piping connection to the pressurizer and which the piping contractor admitted was not being rigidly adhered to. Also, Pullman pipe support installation procedure JS-1X-6 (Revision 2), which was approved by UE&C, incorrectly-tates a requirement for increasing fillet weld size depending upon fit-up gap when viewed within the context of ASME Section III, NF requirements for throat size and AWS guidance.
The technical significance of these issues appears overshadowed by their relation to past NRC findings (443/80-10-02 and 443/81-05-01) in which the piping contractor openly used construction practices in conflict with UE&C specifications.
In light of these new findings, the licensee has commenced a program audit of contractor procedures versus A/E specifications in order to eliminate unnecessary requirements and assure confonnance to those requirements that are necessary.
This program was started for the piping contractor and will continue for the other major site contractors.
Checklists are being developed to insure complete coverage.
The licensee committment to this rigorous inspection of each major contractor's program satisfies the inspector's concerns that additional, and potentially more significant, engineering deviations may exist.
Future routine inspection by the inspector will gauge the effectiveness of these planned corrective actions.
6.
Structural Steel Connections (Unit 1)
The inspector examined the following structural connections for the Unit 1 Containment annulus steel verifying member sizes, bolting material, weld detail, stiffener addition, and overall confonnance to design drawing criteria.
Azimuth Elevation (Approx.)
f 320'
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300*
(-14 and -16)
289'
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263*
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126 (-17)
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UE&C drawings, Engineering Change Authorizations (ECAs), and Cives fabri-
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cation drawings were all reviewed as was a test report on a specific set of high-strength anchor bolts. The inspector questioned the installation of an anchor plate at azimuth 289*which appeared to deviate from certain installation requirements of both UE&C drawing F112330 and ECA 01/2094D.
Although final structural connection had not been made to the anchor plate, a Perini NCR was written to record the deviation, involving anchor bolt spacing, for further engineering disposition.
The inspector also examined a structural column pedestal support at azimuth 220', checking dimensions, member sizes, and welds and the authorization (ECA 01/2624A) for reduction of the containment liner to concrete isolation
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gap with regard to FSAR committments and other design details for the seismic isolation joint.
In the Control Building at elevation (+73),
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structural beams were added (Design Change Notice, DCN 03/702A) and another beam lowered (ECA 01/2860A), with the inspector confirming procer control over the implementation of these changes to include necessary inter-discipline reviews.
No items of noncompliance were identified.
7.
Electrical Welding a.
Containment Penetrations (Unit 1)
The inspector witnessed welding of slip-on flanges to the containment liner electrical penetration sleeves inside containment.
Craftsmen and a foreman were interviewed regarding techniques and procedural controls.
The FBM Welding Procedure Specification (WPS), the Procedure Qualification
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Records (PQR), and the Welder Performance Qualification Test Records were all examined relative to the observed field welding and ASME Section IX qualification criteria and required test records.
The inspector reviewed the following documents for conformance of the matertal type and thickness, dimensions, and configuracions to engineering design consistent with contractor procedures.
-- UE&C Procedure WS-2 (Revision 6)
-- Westinghouse Drawings E40143 and E40144
-- FBM Procedures FECP-413 with IPC No. 1, and QCP-413 No items of noncompliance were identified.
b.
General (Units 1 and 2)
The inspector questioned two construction practices being utilized by FBM in their AWS welding which appeared to infringe upon the intent of specific AWS Code D1.1 and A2.4 requirements.
(1) Fillet welds of sizes less than those designated in AWS 01.1, Table 2.7, were being installed erroneously as "Prequalified Joints".
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(2) Intermittent fillet welds were not being continued to the ends of joined members in apparent conflict with AWS A2.4 standard i
definition and practice.
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The inspector was able to ascertain that problem (1) was not based in inadequate weld sizes, but rather in the fact that a separate qua-
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lification was needed.
NRC contact with a representative of the AWS 01.1 Committee revealed that mass cooling effects upon weld soundness represent the major concern.
FBM NCR 034 was written to document the qualification question and procedure qualification tests were subsequently performed and documented (PCR 27) to verify the acceptability of the FBM procedures (FECP-403) for several weld positions of both single and multiple passes.
The inspector had no further questions on this item.
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The inspector's primary concern regarding problem (2) was his observance
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that in certain cases, support loadings had been attached to the welded members at least partially outside the edoes of the end fillet welds.
A UE&C welding memorandum was written immediately to address the nonconfonning weld practice and an ECA (03/13968) was being drafted to provide guidance as to where attachments could be positioned relative to the end fillets.
Since a previous NRC inspection finding (443/81-07-03)
had addressed similar cantilever extension attachments, FBM inspections had been in progress and were extended to specifically check the conditions of problem (2). AH nonconforming cases have been documented in FBM inspection reports ano further corrective action will be effected upon final receipt of the UE3C weld guidance and ECA criteria.
The inspector has no further questions on these issues.
No items of noncompliance were identified.
8.
Electrical Raceway Supports (Unit 1)
The inmector examined several electrical raceway support strut connections to structural beams in the Control Building and Primary Auxiliary Building (PAB). An evaluation of existing conditions with regard to the notes and typical details of UE&C drawings (M300229) was made and FBM QC Inspection Reports for welding, bolting, and installation were spot-checked.
The inspector noted that strut connections to the bottom flange of several structural members had been moved off the neutral axis of the beams.
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While this is apparently allowed by normal construction tolerances, it is recognized that specific torsional loads are placed on the structural steel l
by such movement.
However, the inspector could find no requirement or mechanism for identification of these off-center, as-built conditions for
further A/E design review. A current NRC open item (443/81-12-02)
I questions the controls over design interfaces to building steel and the inspector notified the licensee that this additional item on electrical
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l strut loadings and movement will be made part of the NRC review to resolve the more generic issue.
With regard to specific connection details on drawing M300229 (Sheet T47),
the inspector noted that Revision 2 had on March 5,1981 added the requirement to stiffen certain beam sizes to which particular types of connections were made and Revision 3 had expanded the types of connections for which stiffening was necessary. However, as of January 22,1982, several connections of the subject types had been installed with cable tray erection following, and without either the beams having been stiffened, any status report indicating the need for this work, or any defined program as to when the stiffeners I
would be installed and by whom. The problem was complicated somewhat by trade and contractor jurisdiction in that while FBM electrical personnel made the strut connections, it was eventually decided that beam stiffener addition would be accomplished by the structural contractor.
The inspector informed the licensee Site Manager and Corporate and Field QA Managers during an exit interview on February 12,1982 that this failure to clearly establish the responsibility for this safety-related activity represented a noncompliance with regard to 10CFR50, Appendix B, Criterion I (443/82-01-02).
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a Prior to the conclusion of the insp@ction, FBM Construction Procedure FECP-529 was issued to delineate the program for such structural steel
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The inspector also spoke to the responsible Construction
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Manager, QA, and engineering personnel regarding the need for tracking such interdiscipline work to successful completion.
The inspector's review of FECP-529 revealed the existence of an adequate tracking mechanism and he determined that full compliance with Appendix B in this regard was achieved on February 12,1982. A question regarding the need for Construction Manager direction for future interdiscipline work still remains unresolved, as is highlighted in paragraph 9 below.
9.
Control of Interdiscipline Work In examining the pipe routing discussed in paragraph Sc, the inspector noted and questioned piping sleeve connections between the independent Train A and B, RHR vault rooms at the lowest elevation in the PAB.
Certain spare sleeves had been installed by the structural contractor several years ago, but plates had not yet been welded into place per UE&C drawing F805563 (a drawing routinely used by the piping contractor).
This plate welding is essential to seal the rooms to prevent leakage from one vault to the next, thus creating the potential for common made failure.
While the installation of the seal plates certainly can still be accompli hed, the questiion of who is responsible for assuring that such work is done anc how eventual completion is tracked is of concern to the inspector.
Conversation with several responsible licensee, A/E, and contractor personnel indicated the existence of no clearly defined program for assigning responsibility or tracking such miscellaneous, but important safety-related work, particularly where cross-discipline and contractor interfaces are involved.
The licensee agreed to investigate the need for programatic control over such interdiscipline design requirements.
Pending presentation of the licensee position or evidence of a viable program to control and track such work to completion, this issue remains unresolved (443/82-01-03).
10.
Unresolved Items Unresolved items are matters about which more infomation is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items d'sclosed during the inspection are discussed in Paragraphs Sc and 9.
11.
Management Meetings
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l At periodic intervals during the course of this inspection, meetings were I
held with senior plant management to discuss the scope and findings of l
this inspection.
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