IR 05000483/1978008

IE Inspec Rept 50-483/78-08 on 780724-27 & 0810-11 During Which 2 Items of Noncompliance Were Noted:Failure to Document in Instruc That a Team Leader Be Appointed for Each Audit Team & Failure to Take Prompt Action on Audit Finding

ML20062F561
Person / Time
Site:	Callaway
Issue date:	10/27/1978
From:	Barrett P, Mattia J, Schweibinz E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20062F550	List: IR 05000483/1978008 ML20062F548 ML20062F552
References
50-483-78-08, 50-483-78-8, NUDOCS 7812190155
Download: ML20062F561 (14)

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U.S. NUCLEAR REGULATORY COMMISSION l OFFICE OF INSPECTION AND ENFORCEMENT REGION III l l

Report No. 50-483/78-08

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Docket No. 50-483 License No. CPPR-139 .4 Licensee: Union Electric Company l Post Office Box 149 St. Louis, MO 63166

_ Facility Name: Callaway, Unit 1 Inspection At: Callaway Site, Callaway County, MO

, ; Inspection Conducted: July 24-27 and August 10 and 11, 1978 E . ,

/O-26-528 Inspectors: E. R. Schweibinz 3 ,

SS* E*N P. A. Barrett

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J of- C. Mattia (Region I)

i Other Accompanyin Personnel: G. W. Roy s

,g Approved By: . y s, C /0 2'J /J[

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Projects Section i

Inspection Summary Inspection on July 24-27 and August 10 and 11, 1978 (Report ';o. 50-483/

78-08)

Areas Inspected: Allegations relative to construction work; electrical implementation procedures; and Daniel audits. The inspection involved I a total of 83 inspector-hours onsite by three NRC inspector Results: Of the three areas inspected, no items of noncompliance or deviations were found in two' areas. Two items of noncompliance were identified in one area (Deficiency ; failure to document in instructions or procedures the requirement that a team leader be appointed for each audit team - Section III, paragraph 1.a.(1); Deficiency - failure to take prompt and appropriate action en an audit ~ finding - Section III, para-graph 1.b).

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DETAILS i

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Persons Contacted

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Union Electric Company (UE)

• M. I. Doyne, General Superintendent, Callaway Construction

• R. L. Powers, Site Quality Assurance Group Leader

• W. H. Stahl, Quality Assurance Engineer

• J. C. Gearhart, QA Assistant Engineer

• S. M. Hogan, QA Assistant Engineer

• R. Veatch, QA Assistant Engineer

• H. Wilson, Construction Supervisor *

J. Baker, Construction Supervisor Daniel International Corporation (Daniel)

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(% *H. J. Starr, Project Manager

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• L. Sykora, Assistant Project Manager

• E. D. McFarland, Const,ruction Engineering Manager

• A. Holland, Project Quality Assurance Manager

. * N. Kaelin, Project Audit Response Coordinator The inspectors also contacted and interviewed other licensee and con-tractor personnel, including craftsmen, QA/QC, technical and engineering and staff member * Denotes those attending the exit meetin * Licensee Action on Previous Inspection Findings (Closed) Followup Item (50-483/77-06-06): Implementation of QC correc-tive action for structural steel components without identification tag The inspector reviewed Quality Assurance Audit Finding (QAAF) N t J 77-06-01-02 dated June 16, 1977 which initially identified the problem g and Quality Assurance Report (QAR) No. 77-07-01 which provided the -

followup audit on this item. The corrective action taken and its ;

implementation was found to be acceptable. This item is close (Closed) Followup Item (50-483/77-06-07): Corrective action for UE QA audit of November 2-4, 1976. The inspector reviewed the corrective actions taken and the followup audits and found all items identified in ;

the original' audit to be closed. This item is close s

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(Closed) Unresolved Item (50-483/78-01-05): Reactor vessel support weld repair documentation indicaten that only one of two welds was reexamined and accepted. Teledyne Brpwn Engineering has performed

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an investigation to determine the impact of each of these discrepancies on the respective hardware and has determined that none of tt.e discrep-i ancies affect the quality of the hardware. Review of the latest repair documentation indicates that both of the welds in question were reexamined and accepted. This item is close (Closed) Noncompliance (50-483/78-02-06): Responsibilities and authority not clearly established for QC inspector Interim Change Procedure No. ICP-1, Revision 0 dated June 27, 1978, has been issued to specifically identify the QC inspector's responsibilities and authority in accordance with ANSI-N45. (Closed) Unresolved Item (50-483/78-02-02): Fire prevention and protection. The following has been accomplished in response to Report No. 50-483/78-02,Section I, paragraphs as listed:

2.c.(1) The inspector observed 20 portable fire extinguishers which were located at their assigned stations and were adequately charge .c.(2) All of the assigned extinguishers noted above were properly tagge . c. (3) The use of combustible lumber had been deemed by Union Electric to be only an economic consideration and will continue to be use .c.(4) The inspector observed the power block and surrounding outside areas and observed no flammable plastic materials being used to protect equipmen .c.(5) At elevation 1984 of the control building, 6 charged extinguishers had been individually placed throughout the approximate 5,000 square foot are ~

2.c.(6) The inspector reviewed Daniel Construction Procedures

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Manual No. AP-XIV-0 >$

Paragraph 3.4 adequately addresses all solvent waste, oily rags, and flammable liquids and their disposa Paragraph 3.10 adequately addresses the storage of flammable liquids and other hazardous materials in permanent buildings during construction in accordance '

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with the National Fire Protection Association standards.

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Paragraph 3.13 adequately addresses the control of liquified petroleum gas in accordance with Occupa-tional Safety and Health Administration regulations for construction (Subpart H and Subpart F).

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2.c. (6a) Two 5-gallon safety cans'were observed throughout the plant area; one in the auxiliary building and one outside the power block area. Both cans appeared to be undamage Storage appeared to be in accordance with NFPA Standard No.30-512 .c.(6b) The inspector observed 3 safety cans of cutting oil stored in an open tool area within the control buildin This storage appeared to be in accordance with NFPA Standard No.30-512 .c.(6c) The inspector observed no kerosene throughout the plant are m

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2.c.(6d&e)The inspector observed no kerosene fuel heaters in any buildin .c.(7) Per Union Electric response dated June 16, 1978, to IE Inspection Report 78-02, fire hose stations will be installed as construction allow .c.(8) The correct Appendix I to Daniel International Procedure No. AP-XIV-03, Revision 0 dated November 19, 1976 has been distributed and the old outdated issues have been discarde I 2.c.(9) The fire extinguisher inspection logs used by the inspec-tion personnel are as specified in the latest Daniel International Procedure No. AP-XIV-03, Revision < (open) Unresolved Item (50-483/78-02-01): Crounding of Class lE Systems not identified as a safety related item. The licensee

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• concurs with Bechtel Corporation that grounding is not a safety related item and intends not to identify it as suc IE's review of this matter has not been complete (0 pen) Unresclved Item (50-483/78-02-03): Training of personnel other than QA/QC. In response to the Union Electric Audit Finding No.1/78-01 Daniel International has developed and received Union -

Electric approval on Interim Instructicn No. 28 titled, " Employee Training Program." The instruction has established interim require-

_r.ts and methods for training of personnel other than QA/QC. The-4-

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expiration date of the Interim Instruction No. 28 is August 8, 197 l

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Procedure No. DI-AP-XIII-07 for training was submitted for approval but was rejected by Union Electric on June 30, 1978. The procedure was being rewritten at the time of this inspectio (Open) Unresolved Item (50-483/78-02-04): The following has been accomplished in response to Report No. 50-483/78-02,Section I, paragraphs as listed:

3.c.(4).(b) Drawing Change Notice No. C0403-3-1 has been written to provide instructions as to how bolting requirements can be adequately achieved. This instruction was based on tests performed by the Daniel International Project Electrical Engineer (craf t personnel torquing practices)

and a design analysis made by Bechtel Corporation (documented in a letter from Bechtel Project Engineering Manager to the Executive Director of SNUPPS dated June 27, 1978).

(~T 3.c.(4).(c) Bechtel Specification No. 10466-C-103A, Revision 2, dated March 30, 1978, Paragraphs 2.3 and 6.2.2 requires expansion anchors to be subject to torque testin .c.(4).(d) The fastening requirements for both the anchor bolts and the concrete expansion anchors have been delin-eated in Note 6 cf Bechtel drawing No. C-0003 and Specification No.10466-C-103A, Paragraph 5. . c. (4) . (e) QC inspection requirements per ANSI N45.2, paragraph 11, have not been delineated. The licensee indicated that the applicable documents will be revised to include I inspection requirement (Closed) Noncompliance (50-483/78-03-01; 50-483/78-03-02): Two rein-forcement bars were found to be missing in the center wall and one rein-forcement bar was found to be missing in the south wall of the diesel

._/ generator basemat pour. Review of the corrective action taken and i the approval by Bechtel of the recommended disposition for NCR N C-A was found to be acceptable. The corrective action taken to avoid further noncompliance was also found to be acceptable. This item is close (Closed) Noncompliance (50-483/78-05-01): Runoff water from the barge landing / intake structure construction activities was directly discharged ,

into the Missouri River without using runoff ditches, settling ponds, -

filter drains or contour grading and temporary roadway surfacing to pro-tect the quality of surface water as required by the construction i

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.t permits and the Final Environmental Statement (FES). The corrective action taken was reviewed and observed and found to be acceptable.

This item is close (Closed) Noncompliance (50-483/78-05-02): Contrary to the licensee's control program, for the month of August 1977, the monthly visual inspection of the site area was not made to check for unexpected harmful environmental effects or evidence of serious damage during facility construction. The corrective action taken and the results achieved were found to be acceptable. This item is close Functional or Program Areas Inspected Details of functional or program areas inspected are documented in Sections I, II and III as follows:

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Section I

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Prepared by E. R. Schweibinz r

Reviewed by D. W. Hayes, Chief ,

Projects Section Allegations Relative to Construction Deficiencies The following allegation was receivad via letter from Individual A dated July 1, 1978 and received in the Region III office on July 6, '

1978. The letter indicated that a defect was present in a wall at '

the plant. The nature of the defect was that a nut which was to have been tack welded to a plate but was not welded existed in a containment wall. Also it was stated that some reinforcement bars had been relocated from where they belonge g On July 8, 1978, Mr. James Foster of this office called Individual A to discuss his concerns and obtain information as to the location of the wall that was mentioned in th- letter. During this conver-sation, Individual A indicated that concrete had been placed in the wall well over a month ago. Since the items mentioned as being defective would not be visible now and did not present an immediate hazard, Individual A was informed that those items would be covered during the next routine inspection of the Callaway site. During the discussion Individual A indicated that the condition was the result of the disposition of a nonconformance repor Findings

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The embedded plate in question was found to be the subject of NCR No. 2-2401-C-A dated March 20, 1978. The disposition of the NCR

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required that the two bottom anchor bolts be replaced with longer

' anchor bolts of a dimension of four feet long as opposed to the origir.al dimension of two foot, two inche This longer dimension 4 removed the initial interference that was caused with one pipe sleeve but caused some additional interference with an embedded '

plate that was located deeper into the wall. The embedded plate in question was located at the southeast end of the west wing wall in the reactor containment. The center line elevation of this plate was 2,010 feet 9 inches. The embedded plate that was pro-viding the new interference with the anchor bolt was located on .

the east side of the west wing wall with a center line elevation of 2,010 feet 6 inches. A careful review of the drawings indicated that some interference could have existe l-7-

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The RIII Inspector requested that the licensee perform a survey to

obtain the exact locatica of the two embedded plates relative to each

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other. Results of the survey indicated that the plate with the anchor bolts that was extended was 1 1/2 inches higher than the original design, also that the bottom left hand bolt of the reference plate had

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i a nine inch projection rather than the eight inches that was designe Interviews were conducted with craft personnel that had worked on the anchor bolts in question. It was found through these interviews that two of the personnel did remember tack welding the nuts to the plates in question on the morning of the concrete pour. Individual B and Individual C made a written statement to this effec (Exhibit I)

A Nonconformance Report NCR No. 2-3459-C-A dated July 27, 1978 was

' written to address the embedded plate that was out of toleranc ,

Discussions with the craf t personnel also revealed that some movement

' of the reinforcement bars in that area did occur, but that all bars l' were back within tolerance prior to the pou (s, The other nonconformance reports that were reviewed during the inspection of this allegation were the following: NCR N C-D, 2-2028-C-D, 2-2040-C-A, 2-2092-C-D, 2-2108-C-D, 2-2113-C-D, 2-2127-C-D, 2-2145-C-A, 2-2259-C-D, 2-2372-C-D, and 2-3023-C- The following drawings were reviewed during the inspection of this allegation: Bechtel drawing No. C-0C2311(Q) Rev. 8, C-0C2915(Q)

Rev. 4, C-0C2917(Q) Rev. 4, C-0S2951(Q) Rev. 3, and C-0S2951(Q)

Rev t (483/78-No items of noncompliance or deviations were identifie ) The following allegation was received from Kay Dre s Allegation

"As an indication of the ongoing problem of keeping defective embeds segregrated, a concrete pour of the auxiliary building floor at 1988 slab elevation had originally been placed on

" hold" for several months, awaiting a decision on the faulty embed question. In late October or early November, 1977, however, the hold was for some reason lifted, and the floor -

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was poured with the untested embeds still installed. Rein-forcing bars were being installed around untested embeds at

4 the 2000 elevation, as well, in November 1977, after a hold which had been imposed on that area was also suddenly lifted."

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Finding A list of all concrete pours that occurred from October 13, 1977 to December 30, 1977 was reviewed to determine which ones were at elevation 1988 and elevation 2000 in the auxiliary building. The list was reviewed for both wall and slab pours.

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The concrete pours that fell within the above parameters are listed as well as the dates of the pour as follows: Pour No. 2C-135WO2, October 13, 1977; 2C-121S01 and 2C-123S01, October 21, 1977; 2C-122S01 and 2C-124501, November 11, 1977; 2C-122W01, November 29, 1977; and 2C-132S02, Dece=ber 22, 197 The following NCR's were reviewed to determine their applicability to the above allegation: Pour No. 2C-135WO2, NCR Nos. 2-1136, 1166, 1179, 1210, 1245, 1264, 1291, 1426, 1537, 1590, 1779, 1817, 1831, 1953, 2847, 2989, 3024, 3036 and 3356. For Pour Nos. 2C-121S01 and 2C-123S01, NRC Nos. 2-1003, 1043, 1132, 1152, 1255, 1279, 1305, 1831, 1817, 1953, 2015, 2692, 3101, and 3455. For Pour No ,~3 2C-122501 and 2C-124S01 NCR Nos. 2-1386, 1253, 1568, 1575, 1604,

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1817, 1953, 1973, 2057, 2058, 2508, 2726, 3028, 3024, and 339 For Pour No. 2C-122W01 NCR Nos. 2-1344, 1349, 1368, 1369, 1475, 1777, 1953, 2057, 2058, and 2250. For Pour No. 2C-132502 NCR Nos. 2-1612, 1667, 1723, 1787, 1806, 1820, 1846, 1847, 1953, 2057, 2058, 2193, 2250, 2412, 3024, and 304 Through a review of the above nonconformance reports as they relate to the allegation, it was determined that none of the nonconformance reports that were written prior to each of the concrete pours were related to defective embeds. The NRC's dealt primarily with problems dealing with rebar interferences

,, and rebar detailing errors. No information was obtained that would substantiate the allegatio Two of the nonconformance reports reviewed, NCR Nc. 2-1215-C-B

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and NCR No. 2-2250-C-A were related to embedded plates that were

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misfabricated from A-36 plate in lieu of A-516 grade 70 plat ,

These nonconformance reports were both dated March 3, 197 These nonconformance reports although they do relate to embedded plates did not occur until after the concrete pours were mad No items of noncompliance or deviations were identifie (483/78-08-02).

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Section II Prepared by P. A. Barrett  ;

Reviewed by R. L. Spessard, Chief Engineering Support Section 1 i Electrical Implementation Procedures The RIII inspector rsviewed the following Daniel International Con-struction procedures:

" Work Procedure No. WP-305, Revision 1, dated June 26, 1978 -

Installation of Electrical Equi men (. Quality Control Procedure No. QCP-305, Revision 1, dated

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July 14, 1978 - Inspection of Electrical Equipment Installatio . Work Procedure No. WP-303, Revision 0, dated May 9, 1978 -

Installation of Wire and Cabl . Quality Control Procedure No. QCP-303, Revision 0, dated June 27, 1978 - Inspection of Cable Pullin The procedures have been established in accordance with SNUPPS PSAR Section 17.1.5 and the Callaway Plant Units 1 and 2, Addendum SNUPPS PSAR Section 17. The procedures defined responsibilities,

, scope, applicability, interfacing documents, and acceptance criteri Procedures No. WP-303 and WP-305 utilize attachment exhibits and appendices which will be completed to identify specific acceptance criteria for specific equipment and components. The specific accep-

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tance criteria will be reviewed during a subsequent inspection es part of the routine inspection pla (483/78-08-03) ,

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No items of noncompliance were identifie ,

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Section III i Prepared by J. C. Mattia (Region I) i

Reviewed by R. W. McGaughy, Chief

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Projects Section (Region I)

t 1. Constructor Audits (Daniel)

The inspector reviewed the constructor's audits to verify that they were scheduled and conducted, that the scope of the audits were consistent with the purpose stated, that appropriate l

standards were referenced for measuring performance, that qualified auditors were selected, that the audited organizations received copies of the audit reports and that corrective action was taken. The following audit reports and schedule 2 were

(3 reviewed:

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Schedules January 1 - March 31, 1978 schedule of audits, issued on

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January 9, 1978 March 1 - May 31, 1978 scr.edule of audits, issued on March 28, 1978 May 1- July 31, 1978 schedule of audits, issued on May 1, 1978 June 1 - August 31, 1978 schedule of audits, issued on June 9, 1978

Audit Repcrt No Date of Report 76-01-01 1/30/76 76-03-01 4/5/76

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76-04-01 5/5/76 (~ 76-05-01 6/9/76 y

76-11-01 11/29/76 l 77-04-01 5/2/77 77-05-01 6/3/77 77-07-01 8/3/77 77-08-01 9/8/77 78-05-01 6/9/78

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The inspector noted two items of noncompliance with 10 CFR 40, 2 Appendix B and the provisions of ANSI standards when reviewing the above audit report ,. . ~ - .. . . - - - w : w --

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. Audit Report No. 77-04-01 The licensee has committed to the provisions in ANSI N45.2.12 (Requirements for auditing QA programs) when conducting audits, however, contrary to these commitments, the contractor did not perform the following for an audit of the containment subcon-tractor:

(1) This audit consisted of three auditors and a team leader was not designated as recuired by ANSI N45.1.1 Review of the audit procedure AI-III-03 failed to produce a requirement that a team leader be appointed for each audit team. The team leaders' responsibilities include orientation of the team, coordinating the audit process, establishing the pace of the audit, assuring communications within the team and with the organi-zation being audited, participation in the audit performance, and coordinating the preparation and g., issuance of report ,

This is an item of noncompliance with 10 CFR 50, Appendix B, Criterion V. (483/78-08-04)

(2) The audit report (77-04-01) did not list the names of the three auditors and the names of the persons contacted during the audit. This item was also found to exist in several other. audits. Corrective action was taken by the contractor on all audit reports from number 77-08-01 and up, and the inspector verified thi Audit Report No. 77-07-01 i

This audit report (item 8.2.1) had an audit finding whereby the containment liner subcontractor's project welding supervisors whom are engaged in visual examination of velds

' were not certified in accordance to the requirements of NRC Regulatory Guide 1.58 which endorses ANSI N45.2.6-197 * This finding was uncovered during the month of July, in 1977 and after several months of discussions and letters it was closed out in June of 1978 by Daniel, based upon the con-clusions of the licensee that the Bechtel Specification

, 10466-C-151A(Q) for the erection of the containment did not require certification of personnel who performed visual examinations of welds. The inspector informed the licensee ,

that the requirements of ANSI N45.2.6 apply to all personnel i who perform inspection activities that assure the quality of important parts of a Nuclear Power Plant during the construction phas .

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This is an item of noncompliance with 10 CFR 50, Appendix B,

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Criterion XV (483/78-08-05) .,

Exit Meeting The inspectors met with the site scaff representatives (denoted in the Persons Contacted paragraph) at the conclusion of the inspection on July 27, and August 11, 1978. The inspectors summarized the scope and findings of the inspection including the two apparent items of noncom-pliance identified in Section III of the Details section of this repor The licensee acknowledged the finding Attachment: Exhibit I, Written

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Statement from Individual B and Individual C

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July 26, 1978 i

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On this date we state that the two embedded 1 1/4" x 8" x 8" plate.a covered s on NCR 2-2401-C-A were tack welded to the nuts. We each did one of the l This welding was performed on the morning of the day of the concrete pour, [

(March 30, 1978).

P This statement is freely made by u ,

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~ t Witness: Edward R. Schweibinz July 26, 1978 ,

Gen W. Roy July 26, 1978 f

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EXHIBIT I i.

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