IR 05000460/1981012
| ML20039G829 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 01/05/1982 |
| From: | Dodds R, Narbut P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20039G823 | List: |
| References | |
| 50-460-81-12, 50-513-81-12, NUDOCS 8201190191 | |
| Download: ML20039G829 (13) | |
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U. S. NUCLEAR REGULATORY C0fEISSION OFFICE OF IllSPECTIOil AND ENFORCEMENT
REGION V
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50-460/81-12
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Report No.
50-513/81-12
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, Docket No.
50-460,.50-513 License No. CPPR-134, -174 Safeguards Group Licensee:
Washington Public Power Supply System P. O. Box 968 Richland. Washington 99352 Facility Name:
Washington Nuclear Projects Nos. 1 & 4 (WNP-1/4)
Inspection at:
WNP-1/4 Site,Benton County, Washington Inspection conducted:
December 14:18, 1981 Inspectors:
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D P. P. Garbut,. Reactor Inspector
/ Jate Signed.
Approved by:
R. T. Dodds, Chief Reactor Project Section 2, P,eactor
'Date Signed Construction Projects?Beanch Sumary:
Insoection during the period of December 14-18, 1981 Areas Insoected: Routine unannounced inspection by a regional-based. inspector of construction activities including. licensee action on previous inspection findings, examination of allegations against the structural steel contractor and examination of the licensee's system of construction specification change control. The inspection
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involved 42 inspector hours ~onsite and 10 inspector hours in office by one NRC inspector.
Resul ts: One item of noncompliance was identified concerning failure to complete Errective action required by a ronconformance report prior to signing for completion of action.
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8201190191 g10106 PDR ADOCK 03000460
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DETAILS
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1.
Persons Contacted a.
Washington Public Power Supply System (WPPSS)
- D. W. Mazur, Program Director
- C. B. Organ, Assistant Progran Director Engineering
- R. B. Glasscock, Director Quality Assurance
- C. R. Edwards, Project QA Manager
- L. J. Schmidt, Project Records System
- M. H. Deter. Senior QA Engineer
- M.
J. Farrell, QA Sp?cialist M. E. Rodin, Senior QA Engineer
- W. Ront Assistant Program Director Construction C. Michel, Manager of Administration L. Dauenhauer, Site Support Supervis'or b.
Bechtel Power Corporation (Bechtel)
- E. W. Edwards, Project Manager
- T. F. Fallon, Project QC Engineer
- J. B. Gatewood, Project QA Engineer
- J. L. Ruud, QA Engineer.
- L. W. Roberts, Contract Coordinator A. Lamach, QC Engineer c.
United Engineers and Constructors (UE&C)
- V. Mani, Project Manager
- G. L. Faust, FSQA
- W. C. Siler, Assistant Project Manager
- E. C. Haren, Project Quality Assurance Manager
- K.
Iverson, MCS Engineering J. McCaleb, Document Control Supervisor R. Beattie, Design Document Group Supervisor d.
Shurtleff and Andrews (S&A)
- R. B. Engstrom. Engineering
- 4. J. Lalor, OA Manager
- R. Byrd, Superintendent 2.
Licensee Action on Previously Identified Items a.
(0 pen) (460/81-04-01) Followuc Item: TFe Sooply System does not have a consistent method of controlling FCNs/PCPs I
This item was not ready for closecut. Previously the Supply System had committed to revise all the cont. actor specifications l
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-2-to implement a consistent method of FCN control. The Supply System determined that the comitment was not appropriate and revised their comitment to analyze the situation of each contractor and revise specifications as appropriate to provide adequate FCN/PCP control, b.
(00en) (460/81-06-04) Followuo Item:
Inconsistent bolt tightening methods - Shurtleff and Andrews
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The licensee's tracking system indicated this item was ready to close, however examination showed it was not. The licensee comitted to have the bolt tightening pr3cedure revised and to l
train the craf t crews. At the time of the inspection, the contractor had not received or implemented the revised procedure.
Training had been done to the old procedure supplemented by verbal instruction, c.
(Closed) (460/80-10-01) Enforcement Item: Undersize shop fillet welds on structural steel - Allied Capitol This item had been reinspected previously. The remaining action concerned the as-built drawings for those undersize velds which were accepted as-is by engineering. At the time of the previous inspection, the as-built drawings (required by nonconformance report resolutions) were not on any licensee or contractor tracking system.
The inspector examined the actions taken since the last inspection of this item. A series of letters had been written directing action, the last of which was a letter BEC-207-81-0124, from Bechtel to Shurtleff and Andrews dated September 22, 1981 which confirms commitments made by Shurtleff and Andrews which included having as-built drawings available within thirty days. At the time of inspection, the as-built drawings were not available at Shurtleff and Andrews and the QA Manager stated the generation of those as-built drawings were not a Shurtleff and Andrews responsibility.
The inspector re-reviewed the original nonconformance reports written regarding the undersize welds. The nonconformance reports were signed off as complete by the integrated Supply System /UE3C QA inspectors although the required actions; "show on as-builts" were not completed at the time of signoff. The applicable procedure, Field Quality Standard FQS-15-1. " Control of Nonconfonning Materials Parts and Components", Revision 3 of 5/1/80 states in paragraph III.B.I.d, "All NCRs shall remain open until disposition has been resolvea, implemented, and reinspected and the NCR completed (closed)."
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The following example NCRs were closed on the dates shown without having the as-built drawings completed:
1-NCR-207-087 closed 2/3/81 1-flCR-207-090 closed 1/7/81 1-NCR-207-092 closed 12/11/80 The failure to verify actions required by the flCR were complete prior to closing the NCR, contrary to the procedure requirement, and is an apparent item of noncompliance.
(EnforcementItem:
460/81-12-01).
Since the control of as-builts was the only remaining action on item 460/80-10-01, that item is considered closed in light of the new item of noncompliance.
3.
Control of Chan':es to Contract Technical Specifications The inspector examined the current status sri past problems with the licensee's control of ch3nges to contract technical specifications.
Such changes are issued as field changa notices (FCNs) and quick fix project change proposals (QFPCPs). The scope of the review, problems by the licensee, corrective action concerns, licensee discussion on the subject, and the implementation status of two specific actions are discussed belo,w:
a.
Scope of Review
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The licensee s staff had identified a number nf problems in the control of FCNs and PCPs in 1980 prior to Bechtel becoming the construction manager. The inspector reviewed the previously identified problems discussed in the following references:
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FCN Task Force Report Contract 254 - uadated 2).
FCN Task Force Report Addendum Contract 253 - undated 3)
Williams to Edmondson Meno of 8-1-80 Review of RFIs on 211 and 257 contracts 4)
Brown to Loprete Memorandum of 9-5-80 FCN Task Force Research for Contractors 211/257, 213, and 216 5)
Houchinsto Rohler Memorardum QA 1/4-80-363 of 9/17/80 FCN/RFI Task Force Results 6)
Goodman to Kohler Mencrandum of 9/30/80 Action Items to Resolve QA Findings from FCN/RFI Task
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Irwin to Loprete Memorandum QA 1/4-80-347 of 8-27-80
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FCN Task Force Contract 218 8)
Bryans to Houchins Memorandum of 10-1-80
FCN/RFI Task Force Report
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Kohler to Distribution Memorandum of 10-3-80 Action Items to Resolve QA Findings from FCN/RFI Task
Force
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Houchins to Kohler Memorandum QA 1/4-80-397 of 10-16-80 Comments on Draft PSP 5.6, Quick Fix Technical Changes
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Ahearn to Latch Letter' UEAW-80-5271 of 12/2/80 Corrective Action Request 1-CAR-254-08
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Houchins to Mazur Memorandum QA 1/4-80-472 of 12-23-80 Assessment of Action Taken to Resolve QA Findings from FCN Task force 13)
Mazur to Kohler Memorandum of 1-9-81 Quality Assurance Findings from Field Change Notice Task
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Force
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Ahearn to Contractors Memorandum of 2/19/81 Processing and Control of FCHs and PCPs 15)
Bryans to Distribution Memorandum of 3/25/81
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Field Pr.oject Engineering, Quick Fix PCPs, Block 16 i
161 Quality Finding Report QFR WNP-1/4-0039 of 8-11-81 b.
Problems Identified by the Licensee and Others The problems identified in the above documents include the following:
RFIs (requests for information) were improperly used to give technical direction and were not superceded by FCNs or included on a drawing index.
2)
Generic FCNs (applicable to more than a single drawing or specification) are not referenced in specifications work
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packages or procedures for a certain contractor. Contractor usage of these generic FCNs cannot be verified.
3)
FCNs are generated by UE&C against contracter drawings.
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4)
There is no evidence a contractor has received all FCNs.
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RFIs were closed out with a statement that a drawing would be revised at a later date.
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Drawing revisions do not show incorporated FCN or ECN t
numbers in the revision block.
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7)
RFI snswers call for standard items such as rods, hangers,
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and base plates without reference to standard drawir:s or j
vendor catalogs.
8)
FCNs have not been incorporated in design drawings.
9)
The old FCN form did not differentiate between affected and reference drawings.
10)
There was no method to verify what FCNs apply to a given drawing.
11)
There was no as'surance work was done to the latest requirements.
12)
FCNs were incorporated in a drawing revision differently than approved.
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FCNs were incorporated on the wrong drawing sheet.
14)
There was no evidence of QC inspection of FCHs in contract 218.
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15)
Instructions to implement PCPs were not issued.
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FCNs were not available at drawing stations.
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No master register existed which identified all FCNs and PCPs.
c.
Corrective Actions Concerns The documented corrective actiors for the above prcblems in general addressed fixing the existvig systems for change control for future work and did not address complete <1 work adequacy. The inspector categcrized the general concerns as follows:
Was past work done and inspected in accordance with all engineering directions intended?
2)
Will as-built records be accurate, reflecting all incorporated changes for comparison to all intended changes?
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Is the current work being perfomed to the proper engineering directives including old changes which are still current?
d.
Licensee Discussion The licensee A/E and CM staff made 'a presentation to the inspector on December 18, 1981.
In general, the staff stated that each of the specific identified problems had been addressed but the resciutions had not necessarily been documented. The infomation presented in the staff's response to the inspector's questions generally referenced procedural requirements which should have controlled the noted problems but the infomation did not generally include data which supported the premise that the procedural requirements were adequately followed at the time the problems occurred.
The licensee committed to review the information gathered and to define a position as to whether the problem was adequately researched and resolved and secondly to define the remaining actions to be taken, responsibilities, and complet4 dates.
This infomation was committed to be made available.or NRC review by January 15, 1982.
This item will be inspected further in e future inspection (Followup Item 50-460/81-12-02).
e.
Implementation Status
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The inspector examined the implementation status of two specific actions which should provide an improved degree of control for design and construction specification changes. The two actions examined were the fomulation of DCS (document control cystem)
and the DDG (design document group).
1)
Document control System (DCS)
The inspector interviewed several involved personnel and reviewed the sample prtntouts from the ccmputerized DCS.
Aaditionally, the DCS data for drawing 101423 was compared against the marked up print in the posession of the 207 Contractor (Shurtleff and Andrews) and the marked up crint in the possession of the UE&C discipline engineers (which is used by Bechtel QC at thir tine for a source documut for QC surveillance of change control).
The following conclusions were drawn from the interviews and drawing data:
a)
The discipline engineers files for drawing 101423, Rev.17 agree with the DCS for outstanding changes
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not incorporated in the latest' revision. DCS shows an additional twelve FCNs not included in the discipline files requiring as-builts drawings to be submitted by the contractor.
This is not considered a problem.
b)
The DCS system does not show 3 applicable FCNs or PCPs for drawing 101423. The missing changes are:
FCN-207-1-79-316 FCN-207-1-79-294 PCP-04Q-0790C The accuracy of the DCS system has not been assessed by the licensee or the A/E. During the inspection, licensee neaagement stated that their intent was to assess the accuracy prior to release of the system for use. The inspecter noted that the DCS was loaded using hard copy files of FCNs and PCPs and was not checked against the originating source logs.
Licensee management stated that a check against source logs would be done as part of the accuracy assessment.
c)
Additionally, it was determined that generic FCNs were not included into the DCS system. Generic FCNs
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do not apply to a single drawing but apply to all work performed under the contract. They can be used to make substantial changes to the contract documents such as allowing smaller weld sizes than shown on the design drawings. The Shurtleff and Andrews copy of 101423 showed two such generic FCNs applied:
FCN-207-1/4-80-540 FCN-207-4-80-464 There was no assurance that the contractor was
recording all generic TCNs used on the drawing.
This is based on (1) the contractor had errcneously recordeo FCNs on drawing 101423 that did not apply
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and (2) generic FCNs are not required by the procedures to be recorded on applicable drawings.
The concern here is how the use of generic FCNs will be recorded and to what level of detail (e.g. per weld, per drawing, or per contract) and how this infomation will be used in design verification.
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d)
The DCS does not address work completion. Bechtel has a system in place which will ensure work completion
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closeout for recent and future quick fix PCPs. The inspector noted and alerted licensee management that
.the record copy of completed QFPCPs was not currently flowing through the paper system in a timely manner but this was not seen as a significant problem.
However, there appeared to be no work closecut system for old FCNs and PCPs.
Licensee management comitted to review FCN closecut methods by contract and ensure all FCNs and PCPs were closed out.
The license?, actions, described above, regarding assessing
the accuracy of the DCS system, the tracking of generic
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FCNs and clos mut of old FCNs will be inspected further
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in a future inspection.
(FollowupItem: 50-460/81-12-03).
Design ~ Document Group (DDG)
The design document group was examined briefly. The
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. group is unique to the WNP-1/4 effort. The group uses
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the DCS as input and reviews the change documents one for
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one against-the contract drawings. Its function is to j
implement the 9/90 (9 changes or 90 days) program to update desfgn drawings which have outstanding changes.
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The sampling of work done by DDG indicates the work is
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done in an orderly, retrievable, and documented manner.
However, an omission was noted in the review of a sa.5ple of the FCNs/PCPs which had been reviewed by the DDG and i
found to be "not applicable" to drawing 101423. PCP 04Q07915 authorized relocating shear studs on columns at elevation 501. The PCP was in fact not applicable to drawing
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101423. However, the discipline engineer had not listed
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what drawing was affected. The DDG did not apparently follow through on this PCP to have the discipline engineers determine what drawing was affected.
This INm was discovered af t. r the exit interview and was
discussed with the licensee QA staff. It will be inspected further during a future inspection.
(Followup Item: 50-46C/
81-12-04)
4.
Structural Steel Welding - Shurtleff and Andrews The inspector examined two allegations regarding structural steel welding at Shurtleff and Andrews (S&A), Contract P.~
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In addition,
the inspector examined the methods by which S&A controlled design change documents that they had received.
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a.
Design Document Change Control i
The S&A FCh/PCP tracking is done by recording the received i
FCNs/PCPs in two logs. The master log was found to have some errors in that applicable FCNs were not recorded. The log
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also contained disccntinuities where roora had been left to enter unreceived FCNs within a block of FCNs. The S&A QA
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manager presumed that the FCNs not received were either voided by UEAC or not applicable. The S&A system had no feedback mechanism to track the missing FCM numbers. All the sample FCNs tracked by the inspector were available at S&A, however, either by reference in a second informal S&A status log or in the S&A hard copy file.
The weakness of the S&A FCN/PCP tracking should be rectified by the licensee's conaf tment described in paragraph 3.e(1)(d)
to assure the completion status of all FCNs/PCPs.
b.
Allegations Regarding Structural Welding (1) Allega tion: Structural steel weld ff tup inspections are not being done.
Finding: Not substantiated. The inspector examined the requirements of AWS D.1.1972 through 1974 Revision.
Specification 9779-207 Sectica 17 and 52A, and S&A inspection i
procedure QAP-2C Rev. 5 of 8-12-80, regarding weld fitup inspection. The inspector also interviewed the QA manager, one QC inspector and the Bechtel QC engineer responsible for contract 207 surveillance.
AWS D.1.1 and the requirements of the specification and implementing procedures do not require an inspection of
each and every fitup. They do require inspections sufficient
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to establish that the requirements of AWS D.1.1 are being
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met. Survefilance inspections, rather thar each time inspections, have been considered acceptable.
S&A and Bechtel personnel interviewed stated that surveillance inspections were being performed and fitup has not been a problem. The contractor recently inititted a revised
" Form 9C" to document surveillance fitup inspections which had not been specifically done in the past. The I
old Form 9C indicated inspections made at the time of preheat application which would be concurrent with fitup.
Tb: inspector noted, hceever, that the procedure QAP-2C was very weak for an implementing procedure. For example, T
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it did not specifically require fitup inspection by surveillance; it did not directly invoke AWS D.1 for acceptance criteria; the only mention of AWS D.1.1 was that it was listed but not invoked as a reference document; and the soecific requirements in AWS D.1.1 to increase fillet vald leg size for fitup gaps greater than 1/16" were not included in the procedure or referenced to AWS D.1.1.
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Inspection personnel interviewed were familiar with the AWS D.1.1 requir e1ents for increasing fillet weld leg sizes for fitup gaps greater than 1/16 inch. Their fomal training in this regard by S&A however was minimal.
AWS D.I.1 is not required reading in training and the only reference to AWS D.I.1 in the written examination is a True/ False question as to its applicability.
Although the procedural controls and fomal training cppear weak, no further NRC action is considered warranted for this item at this time based on a) the lack of identified problems in actual welding quality, b) the remedial actions being taken as a result of Bechtel surveillance activities of the contractor, and c) there is very little work remaining to be completed for this contract.
Further, additional NRC inspections in the structural welding area are planned in the forthcoming year.
(2) A1.l egation: Work discrepancies are being reworked / repaired prior to processing nonconformance reports by using
" quick fix" memorandum which are not prescribed by procedure.
Long periods have elapsed before nonconformance reports are issued on some canpleted quick fixes.
Finding: Partially substantiated. The inspector interviewed involved personnel, examined examples of CNCRs (contractor nonconfomance reports) and examined craft time sheets in order to establish when work was done relative to when documents were generated.
The S&A system allows the QA manager to perform wcrk "at risk" prior to receiving CNCR resolution from UE&C. per discussion, the UE&C fomal answer to the CNCR has consistently approved the S&A recomended action. S&A controls this at risk work by issuing the CNCR to crafts for work prior to UE&C approval but they do not perfom closeout inspection until the answered CNCR is received from UESC.
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The inspector determined there is a form in use at S&A called a QFPI (quick fix problem identification) which is not described by any procedure. The form as written was described by responsible personnel as a vehicle for craft supervision to identify problems in writing to quality control personnel for action.
The inspector was able to determine that, in one case, work was performed prior to authorization. Beam 2749E on drawing 101423 was not able to be installed due to interference of existing bolts on beam 2093A. The solution recommended was to trim the beam lugs on beam 2749E. On 6-9-81 that action had apparently been completed since the beam was installed (as evidenced by the weld inspection record form W-1 for elevation bracket E-341).
i On 6-10-81 the craf t foreman wrote QFPI 107 without identifying the corrective action taken. On 10-12-81.
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1-CNCR-207 476 was initiated and subnitted to UE&C describing the problem, and recommending the corrective action (already apparently taken). On 12-13-81. UE&C authorized the lugs on beam 2749E to be trimmed. This had already been done and the beam welded on 6-9-81.
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The inspector examined a limited number of other CNCRs to a
determine if work had been performed prior to authorization but did not identify any o.ther anomalies.
The inspector also provided the licensee with CNCR l
numbers 1-CNCR-207, -479 -481, -477. -473, and -461 for review. The licensee committed to determine whent. work.was performed for those example CNCRs.
Because the inspector could not determine if the work performed on beam 2749E was an isolated case, this item is considered unresolved and will be inspected further in a future inspection (Unresolved Itsu 50-460/81-12-05).
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c.
Allegations Regarding Structural Welding, Mot Examined Two additional allegations were received but not examined for the reasons detailed below:
Allegation: Completed welds (older than nine months) have not been inspected (backlogs),
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W rk backlogs of and by themselves are not a Discussion.
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safety concern. The inspector did not examine this item
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Allegation: Weld rod ovens are not controlled by QC for each
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and every rod issuance.
Discussion: This item was not examined since the S&A nethods of weld rod issuance control has bean previously examined and found to be satisfactory.
5.
Unresolved Items Unresolved items are matters of which more information is required to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items identified during this inspection are discussed in paragraph 4.b.(2) of this report.
6.
Exit Interview
l The persons identified in paragraph I met with the inspector on December 18, 1981. The scope of the inspection and the findings as
discussed in this report were discussed.
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