IR 05000456/1985038
| ML20137H412 | |
| Person / Time | |
|---|---|
| Site: | Braidwood |
| Issue date: | 11/26/1985 |
| From: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137H358 | List: |
| References | |
| 50-456-85-38, 50-457-85-37, NUDOCS 8512020383 | |
| Download: ML20137H412 (17) | |
Text
r-
.
.
U.S. NUCLEAR REGULATORY C0fEISSION
REGION III
Reports No. 50-456/85038(DRP); 50-457/85037(DRP)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Brridwood, IL Inspection Conducted: September 9 through October 18, 1985 Inspector:
R. D. Schulz W. J. Kropp Approved By:
t rector
// 4 [
,
Braidwood Project Date '
Inspection Summary Inspection on St.?tember 9 through October 18, 1985 (Reports No. 50-456/85038(DRP); 50-457/85037(DRP))
Areas inspected:
Routine safety inspection of licensee actions on previously identified items, plant tours, instrumentation, essential service water piping, piping attachments,- bolted flange connections, cable routing, cable pan / cable pan supports, piping supports, electrical components, and nonconformance reports / corrective action reports. The inspection involved a total of 267 inspector-hours onsite by two NRC inspectors including 32 inspector-hours onsite during off-shifts.
Results: Of the eleven areas inspected, no violations were identified in ten areas, one violation with two examples was identified in the remaining area (failure to assure that HVAC corrective actions were effectively implemented and
<
failure by the HVAC contractor to transmit nonconformance reports to the licensee for10CFR50.55(e) review (paragraph 12)).
8512O20383 851127 PDR ADOCK 0500
G
.
- -
-
.
r
.
.
Details 1.
Persons Contacted Commonwealth Edison Company (CECO)
- G. Fitzpatrick, Assistant Manager Quality Assurance Corporate
- M. Wallace, Project Manager
- C. Schroeder, Licensing and Compliance Superintendent
- D. Shamblin, Construction Superintendent
- T. Quaka, Quality Control Supervisor
- W. Vahle, Engineering Manager S. Hunsader, Quality Assurance Supervisor E. Netzel, Quality Assurance Supervisor
- L. Kline, Licensing and Compliance Supervisor
- D. Skoza, Engineering Supervisor M. Gorski, Engineer D. Boone, Project Construction Field Engineer
- E. Wendorf, Project Engineering
- J. Dierbeck, Project Construction Field Engineer Phillips Getschow Company (PGCo)
'
T. O'Connor, Site Manager K. Kranz, Quality Assurante Site Manager J. Stewart, Project Engine?r M. Galloway, Assistant Pro:ect Engineer R. Hamilton, Welding Supersisor L. Butler, Quality Control Supervisor G. K. Newberg Company (GKN)
R. Donica, Quality Assurance Manager L. K. Comstock and Company, Inc. (LKC)
T. Zych, Lead Engineer D. Bradfute, Assistant Project Engineer J. Gremchuk, Field Engineer L. Welch, Field Engineer F. Rolan, Welding Inspector L. Seese, Assistant Quality Control Site Manager Pullman Sheet Metal Works, INc. (PSM)
P. Weiker, Engineering Manager D. Butzen, Office Engineer R. Waterfield, Qaality Engineer C. Holt, Quality Assurance Supervisor The inspectors also contacted other licensee and contractor personnel, including craftsmen and engineering staff members.
- Denotes those attending the exit meeting on October 17, 1985.
(
__
.
.
2.
Licensee Action on Previously Identified Items Although all of.the corrective actions have.not been completed for the following previously issued violations, the inspector reviewed the issues and.found that the actions completed and planned by the licensee appear to be adequate to resolve the findings.
The licensee's corrective actions are delineated below:
. Violations (0 pen) 456/82-05-01; 457/82-05-01:
Inadequate corrective action with regard to bolting of the steam generator supports. The licensee will remove and either replace or reinstall all the cap screws holding the vertical supports to the steam generators.
The NRC will inspect the cap
. screws and examine.the documentation which shall include cap screw traceability, length, final torque values, and the number of Heli Coil inserts.
(0 pen) 456/83-07-02; 457/83-07-02:
Bolting deficiencies for mechanical equipment. A new Mi11 wright Supervisor was assigned to the Braidwood Site in July 1984.
The supervisor has extensive experience in the nuclear
-
industry and implemented an Equipment Inspection Retro-fit Program which includes the reinspection of mechanical equipment bolting.
Both thread engagement and torque are being examined.
Rework is being completed as required.
For excmple, the IRY01S pressurizer bolts were found to be not properly torqued and are presently being torqued to the correct values.
The Retro-fit Program is controlled by QCP-B22, Equipment Installation Procedure, Revision 8.
(0 pen) 456/83-09-07B; 457/83-09-07B:
Corrective action was not adequate concerning the acceptance of welds for which the welder was unknown and Correction Notices were not analyzed for significance.
There were originally 53 items identified as having no welder identification.
Further document reviews identified welders for 29 of the items and the remaining 24 items were dispositioned for removal.
Subsequent document reviews by Pullman Sheet Metal Works, Inc. identified 349 additional items for which no welder identification has yet been found, either by a welder stamp next to the weld or by quality assurance documenta-tion.
These welds have been properly identified by Pullman and document searches are still being performed in an effort to determine the welder.
These 349 items are being evaluated by the licensee.
A Region III specialist will examine and disposition all of the items having inadequate welder identification.
All of the Correction Notices were analyzed by Pullman for significance.
Welding was determined to have a 38% deficiency rate in November 1983.
In the period, February through July 1985, this rate had declined to 12%.
This appears to be due to additional welder training, the increase in t
.
r
.
quality control inspections during in-process work, and a significantly improved traveler control system which designates the welding procedure to be employed. Trending of Correction Notices is now done on a monthly and quarterly basis in order to determine the significance of deficient conditions.
(0 pen)456/85007-02;457/85007-02:
Installation of tio support plates for the containment spray pumps was not in accordance with orawing requirements.
Nonconformance Report No. 3963 was issued to document the deficient condition. The installations are being reworked to conform with drawing requirements as specified in the nonconformance report.
No violations or deviations were identified.
3.
Plant Tours The inspectors observed work activities in progress, completed work, and plant status during general inspections of the plant. Observation of work included high strength bolting, structural welding, anchor bolts, HVAC welding, pipe erection, safety-related pipe welding including fire protection and reactor coolant system welds, cable supports, cable trays, junction boxes, mechanical equipment, and instrument piping. Particular note was taken of material identification, nonconforming material identification, and housekeeping. Craft personnel were interviewed in the work areas.
The inspector identified a bent or bowed pipe connected to the auxiliary feedwater pump. This was brought to the attention of the Phillips Getschow Company and discrepancy report number D0254 was immediately issued by Phillips Getschow.
It appeared that this pipe was damaged during construc-tion field activities. Based on the identification of this item in the discrepancy report, for disposition by engineering personnel, this issue is considered closed.
During one tour, the inspector noticed that the scaffolding adjacent to the steam generators in Unit 1 contained several flanges, nuts, bolts, and short pieces of pipe. The licensee was notified of the existing condition and took the necessary corrective actions. The material was determined to be nonsafety-related and was taken to the appropriate material storage areas.
While inspecting the safety injection pump rooms, the inspector identified that the room for pump ISIO1PA contained bags of sand, soda-pop cans, nuts and bolts, angle iron, tube steel, pieces of concrete, and fittings. The pump had been turned over to the licensee from the contractor for preoperational testing, and was undergoing a flushing process. The licensee was notified of this condition and immediately cleaned up the area. The inspector noted no adverse hardware affect, as the sand did not enter the pump suction or discharge openings. The material was returned to designated material storage areas. The licensee was responsive to NRC concerns during the inspection period and took prompt corrective action.
r
.
e The inspector witnessed the testing associated with pour 7A X 24.
The pour utilized grout instead of concrete for a wall in the Auxiliary Building at Elevation 475', Columns S-17 through S-19.
The grout was pumped to the location of the pour and.the samples for the testing were obtained from the pump discharge. The grout was tested for slump, air content,'and temperature in accordance with Pittsburgh Testing Laboratory Procedure QC-FSTC-1, Revision 16, dated July 29, 1985.
Six cylinders (Set No. 4252) were also prepared for future strength testing.
The results of the testing were:
Slump 6 1/4" Air content 5.0%
Temperature 71
~No violations or deviations were identified.
4.
Instrumentation Instrumentation lines detailed on the following drawings were examined:
1FT-657 sheet 2, Component Cooling Flow Transmitter
1FT-660 sheet 2, Component Cooling Flow Transmitter
'*
1PT-AF057 sheet 1, Auxiliary Feedwater Pressure Transmitter
1PSL-AF055 sheet 1, Auxiliary Feedwater Pressure Switch
Installation and inspection documentation were also reviewed.
Attributes checked included:
separation criteria
line properly pitched
-
installation clearance separation color code identification
drawing conformance
welder and joint identification
.
In addition, field change requests associated with the installation were i
reviewed for accuracy and completeness.
The installations were in accordance with Procedure PGCP-30, Revision 12, 1 -
"Installaticn Of ASME Section III and Safety Related Instrument and Instrument Lines."
!
-The procurement of instrumentation identified in Sargent & Lundy Specification L-2906, " Instrumentation Installation Work", was reviewed to verify compliance with applicable codes and standards.
The mechanical contractor, Phillips Getschow, was responsible for preparing purchase requisitions for all instruments which were designated in the Instrument
,
Index and detailed in Specification L-2906.
The licensee issued purchase
,
orders for the instruments based on the purchase requisitions from Phillips
,
E Getschow. The inspector reviewed procurement documents such as Purchase Orders (PO), Material Receiving Reports (MRR), Certificates of Conformance,
,
h l
-
i
f-
.
.
s and other supporting documents.
This review was to determine if the appropriate instruments were purchased and received.
The instruments selected and the documentation reviewed were:
Instrument identification Type Number Vendor Model No. Documentation Flow Transmitter 1FT-CS013 Rosemount 1153DB6 P0 26250.
MRR 12306.
Instrument Data Sheet FF65.
Rosemount Quality Certification of Compliance.
Flow Transmitter 1FT-CS004
"SAME AS 1FT-CS013" Flow Transmitter 1FT-AF016 Rosemount 11530B8 P0 262050.
MRR 12306.
Instrument Data Sheet FT-76.
Rosemount Quality Certification of Compliance.
Pressure Switch 1PSL-AF051 United 552 P0 262089.
Low Electric Requisition BR 52765.
Instrument Data Sheet PS-180.
Phillips Getschow Receiving Inspection Report, dated May 27, 1982.
Pressure Switch 1PSL-AF055
"SAME AS 1PSL-AF051" Low
,
-.
.
.. -
.
.- _
.
.
. -..
--
-
,
[
.
-
Pressure IPT-PC004 Barton 764 P0 282613.
Transmitter MRR 16885.
Certificate
.
of Conformance (Stallings &
Co.).
.
Certificate of Conformance (ITT Barton).
Pressure 1PT-0934 Barton MRR 11315.
.
Transmitter Westinghouse Quality Release N69246.
The Purchase Order for instruments 1FT-CS013, 1FT-CS004, and 1FT-AF016 referenced applicable technical requirements such as IEEE 323, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations" and IEEE 344, "IEEE Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations."
-
The purchase order was classified as safety-related and these instruments were received with a Rosemount Quality Certification of Compliance. This certificate referenced a Rosemount Qualification Report, No. 108025, as a
'
basis for nuclear application.
The purchase order for instrument 1PT-PC004 was classified as " safety related - commercial grade." The pressure transmitter for instrument 1FT-0934 was procured by the Nuclear Steam
~ Supply _ System (NSSS) vendor, Westinghouse, and was received on site with a Quality Release, N69246.
The Purchase Order for pressure switches 1PSL-AF051 and 1PSL-AF055 was-classified as nonsafety-related.
There were no technical or quality requirements identified in the Purchase Order.
The Sargent & Lundy Instrument Data ~Index and the Instrument Data Sheet, PS-180, identified these instruments'as Class 1E and Seismic Category I.
The inspector did verify that documentation existed which qualified the United Electric pressure switch, Model 552, as qualified for nuclear applications.
This documentation consisted of a Sargent & Lundy Equipment Qualification Volume, EQ-BB115, "EQ (mild) of United Electric Pressure Switches", Revision 00, dated February 8, 1985.
Since these switches were procured as nonsafety-related, the inspector has a concern that these pressure switches might not have been properly receipt inspected, stored, installed, calibrated, or otherwise controlled. The licensee has committed to evaluate the procurement and the subsequent activities associated with pressure switches 1PSL-AF051 and 1PSL-AF055 to determine their acceptability.
The licensee also stated that the procurement of safety related balance of plant instruments will be evaluated by a surveillance conducted by their QA organization.
This matter is considered an
.
r
.
unresolved item pending a review of the licensee's evaluations of pressure switches 1PSL-AF051 and 1PSL-AF055 and the completion of the QA surveillance (456/85038-01; 457/85037-01).
No violations or deviations were identified.
5.
Essential Service Water Piping Documentation for 48" outside diameter Essential Service Water piping, which is buried underground, was reviewed for drawings ESW-2 and ESW-12.
Documents examined included:
welding inspection reports
weld rod test reports
welder qualification records
magnetic particle test reports
NPP-1 Code Data Reports
traceability of pipe and welding consumables
The records were found to be in compliance with the ASME Boiler and Pressure Vessel Code, Sections II, III, and IX.
The inspector reviewed Nonconformance Report No. 5337, which was written by the Phillips Getschow Company on August 12, 1985.
The nonconformance identified Essential Service Water spools with baso metal weld repairs whose repair cavity exceeded 10% of the wall thickness, that were not subsequently radiographed as required by ASME Section III.
This issue will remain open, pending licensee disposition and subsequent NRC review by Region III specialists.
(456/85038-02; 457/85037-02)
No violations or deviations were identified.
6.
Piping Attachments Twelve lugs welded to three reactor coolant piping spools, and two stanchions welded to a piping feedwater spool were examined for weld quality, material identification, welder stamp identification, and dimensional conformance.
The lugs and stanchions are detailed below:
four lugs on 4" 0.D. ' Spool, RC-9-2
four lugs on 3" 0.D. Spool, RC-9-4
four lugs on 4" 0.D. Spool, RC-2-4
two stanchions on 6" 0.D. Spool, FW-38-5.
- Documentation reviews disclosed that the piping NPP-1 Code Data Reports met the requirements of the ASME Boiler and Pressure Vessel Code and design specification 1540BB. The weld rod certifications w r found to be in compliance with ASME Section II, Part C and Section I11, NB-2000.
The lugs and stanchions were manufactured from material which met the
(
.
.
requirements of ASME Section II, Part A and Section III, NB-2000. The lugs were also in accordance with ASME Section III, NB-4435.
Nondestructive examination reports were reviewed and its was determined that the requirements of ASME,Section III, NB-5000 were satisfied. The welding process was controlled through welding inspection checklists.
While reviewing the Code Data Report for spool FW-38-5, the inspector also randomly selected the Code Data Report and welding material certifications for spool FW-13-7. The spool is a 16" 0.0. spool and has an.844" wall.
Specification F/L-2739 stipulates the special requirement that Charpy Impact Tests must be performed on ASME Section III, Class NC feedwater piping in accordance with ASME Section III, NB-2300. The inspector found that the Charpy Impact Tests had been performed for both the spool and welding consumables.
No violations or deviations were identified.
7.
Bolted Flange Connections Piping Procedure PGCP-15, Rev. 5, " Bolted Connections," was reviewed; the controlling document for bolting flanges together is a Mechanical Joint Checklist (MJC). The MJC specifies the following attributes for the I
craftsmen:
J
_
approved lubricant, Fel-Pro-N-5000
_
assembly sequence torque values
-
material identification
-
drawing identification
_
joint identification The MJC also establishes quality control hold points for the following aspects:
_
component identification internal cleanliness
-
joint faces clean
-
bolting material male / female inspected for damage
_
correct bolting / gasket material used and recorded
_
threads lubricated and lube type entered
_
flange surface parallel measurement recorded prior to bolt-up
_
gasket properly centered
_
joint properly tightened
_
The MJC's for two Safety Injection flange connections were examined for compliance with procedure, PGCP-15, Rev. 5 and design table 140BB. The
-
- -
- -
-
F
.
.
MJC's were in compliance with the procedure and design table.
The 6" 150 lb. raised face, weld neck flanges were to be connected to a Unit 2 safety
. injection pump and were designated SI-23-F1 and SI-23-F2.
The work had not been performed but the quality control hold points had been properly established and the correct material had been drawn.
Subsequently, the MJC's for two Chemical and Volume Control flange connections were examined.
The connections had been completed and the quality control hold points had been appropriately signed off.
The 4" 150 lb. raised face, weld neck flanges were designated as connections CV-3-F3 and CV-3-F-4-1.
The connections were examined by the inspector and the flanges were installed in accordance with the checklist.
The checklist met the requirements of Procedure PGCP-15 and design table 140BB.
The flanges, nuts, and bolts were traceable and met the requirements of design specification F/L-2739.
Certifications were reviewed for the flanges and bolting material.
The inspector did have a question with regard to Procedure PGCP-15, Paragraph 5.1.2.2.
The Paragraph states:
"For mechanical joints (including valve bonnets) in high pressure steam piping and high pressure feedwater piping using the 600 lb., 900 lb.,
1500 lb., or 2500 lb., pressure design standard in sizes 2 1/2 inch and larger, a predetermined and measured torque calculated to produce an initial ptress of approximately 45,000 pounds per square inch in the fastener shall be specified on the M.J.C."
The inspector requested that the licensee evaluate their justification for not including the high pressure emergency core cooling systems in their requirements for predetermined torque that is to be specified on the MJC.
This is considered an open item pending licensee review (456/85038-03; 457/85037-03).
No violations or deviations were identified.
8.
Cable Routing The following L. K. Comstock procedures were reviewed:
4.3.8, Cable Installation, Revision E
.
4.8.8, Cable Installation Inspection, Revision C.
- Five Unit 1 installed cables were inspected in the upper cable spreading
.
room for compliance to IEEE-384, the cable pull cards, and Procedure 4.3.8, Cable Installation.
Subsequently, the L. K. Comstock quality control inspection reports were reviewed for compliance to Procedure 4.8.8 and the actual cable installations.
Detailed below are the cables which were inspected:
i i
l
r
.
.
Cable No.
From Raceway To Riser / Raceway M
10C117 12025C 1R482 12-C-14 IVX004 12015C 1R480 12/C-14 1VV092 12028C
/11909C 2/C-14 10126 12025C 1R482 12/C-14 1VC017 12025C 1R480 12/C-14 The inspectors determined that Cable No. IVV092 was not routed thru raceway 12026C as required by the cable pull card.
The quality control inspector accepted the pull as being correct on November 20, 1981.
The licensee was notified and the electrical quality assurance supervisor stated that a nonconformance report would be written and that additional cables which were inspected by the same quality control inspector would be reinspected for compliance with the pull cards.
The licensee's review concluded that the incorrect routing was not design significant.
Pending the reinspection effort and NRC evaluation, this issue will remain unresolved (456/85038-04).
The licensee stated that they did not believe the incorrect routing was design significant because the cable passed through another "CIE" raceway, the same category as raceway 12026C, and then returned to the correct routing.
'
NRC inspections of the cables included the following attributes:
raceway free of debris
raceway free of sharp edges
- -
raceway free of damage
segregation codes correspond
raceway corresponds to routing shown on pull card
cable routed per pull card
cable correct size and type
cable free of damage
cable correctly identified e
cables are properly supported
No violations or deviations were identified.
9.
Cable Pan / Cable Pan Supports The inspector performed field inspections on 13 Unit 1 randomly selected cable trays and their structural supports in order to determine if they were installed in accordance with the design drawings.
The cables, associated supports, and applicable Sargent & Lundy design drawings are detailed below:
.
I
.
.
Cable Trays ~
Supports Drawings 11516M
'H118, H126 0-3671, 1-3061H 11521M H099, H170 0-3671, 1-3061H 11584K H102, H103, H104, H141 0-3671, 1-3061H 11585K H105, H106 0-3671, 1-3061H 11587KJ H042 0-3672, 1-3061H 11591J H038, H039, H040, H041 0-3672, 0-3061H
- 11592J H048 0-3672, 0-3061H 11593J H034, H035 0-3672, 0-3061H 11597J H049 0-3672, 0-3061H'
11600J H018 0-3672, 0-3061H 11601J H016, H017 0-3672, 0-3061H 11682J-H033 0-3672, 0-3061H 11683J H032 0-3672, 0-3061H The cable trays ond supports were installed per the drawings. Locations, dimensions, and correct identification for both trays and supports were examined. Dimensional checks included distances between supports.
The inspector subsequently reviewed the installation and quality control inspection records for the. trays and supports. The electrical contractor was unable, at the close of the inspection period, to produce quality control welding inspection records for structural cable tray supports H102, H141, H104, and H106. Pending the outcome of the electrical contractor's search-for these records, or reinspections, if' justified, this issue will remain unresolved (456/85038-05).
No violations or deviations were identified.
10. Piping Supports The following pipe supports were examined for drawing compliance including configuration, weld details, dimensional tolerances, location, and correct components:
Identification System hpe M-1CC12002R Component Cooling Mini Strut M-1CC12009X Component Cooling Sway Strut M-1CV18002X Chemical & Volume Control Sway Strut M-1CV18048R Chemical & Volume Control Sway Strut M-1CV18063R Chemical & Volume Control Sway Strut M-1CV18079G Chemical & Volume Control Structural Tube M-1CV18083R Chemical & Volume Control Structural Box M-1CC12017X-Chemical & Volume Control Mini Sway Strut M-1SX47003X Essential Service Water Sway Strut M-1SX5003X-Essential Service Water Sway Strut The supports were installed in accordance with the drawings.
No. violations or deviations were identified.
_
I
.
.
11.
Electrical Components Installed junction boxes 1JB011A, 1JB005A, and and 1JB015A were inspected for compliance with the following established requirements:
junction box installed per the latest drawings as to size, location,
and box type junction box is adequately supported
junction box identification is correct
junction box is free of any internal or external damage
_ junction box is clean, no debris, tools or foreign materials are
stored in or on the junction box concrete expansion anchors are installed in accordance with
Specification BY/BR/CEA The following drawings were used in the inspection:
20E-1-3610 20E-1-3301 20E-1-3607 20E-0-3393T 20E-0-3393M 20E-0-3393J 20E-0-3390 The junction boxes were installed correctly.
The inspector reviewed LKC NCR No. 4302 which stated that concrete expansion anchors have been installed in several locations without quality control inspections being performed because of construction crews failing to turn in installation reports which initiate the quality control inspections.
The final disposition of this nonconformance will remain an open issue pending licensee corrective action and subsequent NRC review (456/85038-06; 457/85037-04).
Equipment panel IPA 33J, located adjacent to the control room, was inspected and it was determined that the panel was installed and aligned per the latest drawings.
The applicable drawings were 20E-0-3371B and 20E-0-3391C.
The inspector noticed that the panel did not appear to be properly covered to prevent the entry of foreign matter. The licensee was notified and immediately covered the panel with a protective tarpaulin.
No dar. age was observed.
No violations or deviations were identified.
(
l 12.
Nonconformance Reports / Corrective Action Requests Piping nonconformance reports, No. 5300 through No. 5349, written by the Phillips Getschow Company, were reviewed for correct identification of the condition, adequate corrective action, and disposition compliance with the ASME Boiler and Pressure Vessel Code.
The inspector reviewed the corrective action system at Pullman Sheet Metal Works (PSM) as described in PSM Procedure B16.2.F, " Corrective Action",
Revision 0.
This procedure became effective January 18, 1985.
This review consisted of verifying that the corrective action system established by Pullman is in compliance with applicable codes and standards.
The corrective action system described in PSM Procedure B16.2.F requires the issuance of a Corrective Action Request (CAR) when a significant condition adverse to quality is identified.
The following five CARS were reviewed by the inspector:
CAR Issued Date Status
-
002 January 30, 1985 Closed on June 13, 1985 003 N/A Invalidated on May 3, 1985 004 N/A Invalidated on June 20, 1985 005 June 19, 1985 Closed on July 17, 1985 006 August 2, 1985 Corrective Action being implemented and is scheduled for completion on March 31, 1986.
The above CARS were reviewed for adequate description of the adverse condition, adequate follow-up verification of the corrective action, and adequate documentation for justifying the invalidation of CARS 003 and 004.
The justifications for invalidation of CARS 003 and 004 were signed by the PSM Quality Assurance Supervisor and Quality Assurance Director.
The justifications appeared appropriate for the invalidation of CARS 003 and 004.
The review of CARS 002, 005 and 006 resulted in identifying the following:
a.
The " Description of Condition" block on CAR 006 stated that Nonconformance Reports (NCRs) 748 and 749 did not identify the possibility that some clips to existing building steel welds may also be questionable and need further evaluation to determine appropriate corrective action if necessary.
Documentation available and discussions with PSM's QA Supervisor revealed that some of the clip to existing building steel welds were noted as being undersized.
During a sample (60) inspection of 52.1 connections conducted between May 21-28, 1985, it was noted that some of the clip to building steel welds were undersize (1/4", 3/16", etc.).
Sargent & Lundy (S&L) drawing 1261, sheet 6, specified a 5/16" fillet weld.
Therefore, the clip to existing building steel welds were not questionable at the time of the issuance of CAR 006 on August 2, 1985, but were deficient in that the welds did not meet the applicable S&L drawing.
PSM 16.2F, Revision 0,
f
.
.
Paragraph 6.1.B.2, requires that the block on the CAR titled "Descrip-tion of Condition" provide sufficient details as to fully describe the deficient condition including source, if applicable. Since the other four CARS reviewed had the " Description of Condition" block completed in accordance with procedural requiremerits, this concern is considered an isolated case. CAR 006 has been revised by PSM to provide sufficient details as to fully describe the deficient condition. The proposed action to assure the quality of installed items identified on CAR 006 was also revised to accurately describe the actions being currently implemented by PSM QA/QC.
b.
NCRs 748 and 749 associated with CAR 006 were noted as potentially reportable (10 CFR 50.55(e)) by Pullman QA. These NCRs were not transmitted to the licensee and therefore were not evaluated by the licensee for reportability in accordance with Procedure PCD-23, Revision 1, " Site Contractor Nonconformance Reports / Procedure Processing." A review of Pullman Procedure B16.1.F, Revision 7,
"Nonconformance," revealed that it does not require NCRs identified as potentially reportable to be submitted to the licensee. Subsequent to identifying this lack of a 10 CFR 50.55(e) review, appropriate licensee personnel have conducted and documented the necessary 10 CFR 50.55(e)
review in accordance with Procedure PCD-23. The failure to have documented instructions to assure that Pullman NCRs identified as potentially reportable are submitted to the licensee is considered a violation of 10 CFR 50, Appendix B, Criterion V (456/85038-07; 457/85037-05).
c.
CAR 002 and CAR 005 were closed without fully verifying that the corrective action was implemented and was effective as required by PSM Procedure B16.2.F, Revision 0, Paragraph 6.3B.
In regards to CAR 002, which identified that PSM drawings were not reviewed for variance from the S&L design drawing, the following were noted:
(1) The action taken to assure quality of installed items, which is documented on CAR 002, required that PSM shop drawings be reviewed for variance from the S&L design drawings. This review was to identify all items that were not fabricated or installed in compliance with the design drawings. This action also stated that PSM QC has been inspecting to S&L design drawings since September 17, 1984. There was no objective evidence that PSM QA verified the implementation and effectiveness of the action taken to assure the quality of installed items prior to closing CAR 002.
(2) The action taken to prevent recurrence of the deficiency noted on CAR 002 included revising the PSM Procedure B3.2.F, " Drafting,"
to requhe the necessary reviews of all shop drawings before issuance and to perform a QA surveillance of the review process.
CAR 002 was closed on June 13, 1985, based on the revision of
l'~
.
.
Procedure B3.2.F and the fact that a QA surveillance was scheduled for June 1985. A review of PSM QA surveillance activities avealed that a surveillance (QA-S-85-054) was conducted on June 21, 1985, but it did not address the review process for PSM drawings as described on Procedure B3.2.F.
The inspector also reviewed the PSM QA audit records and noted that an audit (85-04) of Procedure B3.2.F was conducted on July 16-18, 1985. A review of the audit checklist determined that there was no objective evidence that the audit covered the drawing review process.
A potential problem pertaining to a welders certification was identified on CAR 005.
The corrective action to prevent recurrence included revising the active welder log to provide a column for documenting the surveillance of welder certifications by PSM QC.
This revision of the active welders log was to provide adequate tracking for maintenance of PSM QC surveillance activities.
PSM QA closed CAR 005 based on the active welders log being revised to include the QC surveillance column. There is no objective evidence that PSM QA verified the effectiveness of the revision of the active welders log for QC surveillance activities.
The failure to perform proper follow-up verification to assure that the corrective action was implemented and effective as required by PSM Procedure B16.2.F for CAR 002 and CAR 005 is considered a violation of 10 CFR 50, Appendix B, Criterion V (456/85038-08; 457/85037-06).
During the review of the corrective action system at PSM, the inspector noted that PSM Procedure B16.2.F, " Corrective Action," required CARS to be transmitted to the licensee for "information only." Since these PSM CARS are utilized to identify significant conditions adverse to quality, the inspector is concerned that the licensee reviews only an "information" copy.
The processing of site contractor documents which identify significant conditions adverse to quality ty the licensee in a manner at least commensurate with the processing of NCRs is considered an open item (456/85038-09; 457/850037-07).
13.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed by the inspector and which involve some action on the part of the NRC or licensee or both.
Open items disclosed during the inspection are discussed in Paragraphs 5, 7, and 11.
14.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
Unresolved items disclosed during the inspection are discussed in Paragraphs 4, 8, and 9.
1
r
%
.
.
,.
15.
Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph 1 at various times during and at the conclusion of the inspection on 0ctober 17, 1985.
The inspector summarized the scope and results of the
~
inspection and discussed the likely centant of this inspection report.
The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.
17