IR 05000483/1979003

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IE Insp Rept 50-483/79-03 on 790306-12.Noncompliance Noted: Failure to Follow Established Procedures for Training non- Qa/Qc Personnel Who Perform safety-related Work Activities
ML19259C307
Person / Time
Site: Callaway Ameren icon.png
Issue date: 04/02/1979
From: Hanson W, Jablonski F, Knop R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19259C302 List:
References
50-483-79-03, 50-483-79-3, NUDOCS 7906140570
Download: ML19259C307 (18)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-483/79-03 Docket No. 50-483 License No. CPPR-139 Licensee: Union Electric Company P. O. Box 149 St. Louis, MO 63166 Facility: Callaway, Ur.it 1 Inspection At: Callaway Site, Callaway County, Missouri Inspection Conducted:

rch 6-9, 11-12, 1979 3/ sh Inspectors:

W. A Hanse'n' ~ ~

T-AT-)f b

F. J. Jablons i h

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!77 C.

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K. R. NaYdu 3 - A 9,6 $

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J. Mattia (

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AccompanyngPerso(nnel:B. Beach (Region IV)

Approved By:

R. C.

o, 7f Projects Section Inspection Summary Inspection on March 6-9, 11-12,1979 (Report No. 50-483/79-03)

Areas Inspected: Procedures and activities for moving, installing and storing the reactor pressure vessel and internals; receiving and Quality records of safety related componen!P', Cable tray ADStallation

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and electrical panel storage and control; containment fabrication,

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penetration installation and quality documentation; safety related piping installation work activities and records. This inspection involved a total of 127 inspector-hours onsite by six NRC inspectors.

Results: Of the areas inspected, one apparent item of noncompliance was identified in one area (infraction - failure to follow established procedures for the training of non QA/QC personnel who perform safety related work activities - Section III, Paragraph 1).

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DETAILS Persons Contacted Union Electric Company (UE)

  • W. H. Weber, Manager, Nuclear Construction
  • M. E. Doyne, General Superintendent, Callaway Construction
  • R. L. Powers, Site Quality Assurance Group Leader
  • W. H. Stahl, Quality Assurance Engineer
  • J. Laux, Quality Assurance Assistant Engineer
  • J. C. Gearhardt, Quality Assurance Engineer
  • R. Veatch, Quality Assurance Engineer Daniel International Corporation (Daniel)

E. J. George, Group Manage * Maintenance and Millwright Group

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  • H. J. Starr, Project Mana: -

E. D. McFarland, Construction Engineering Manager

  • J. A. Holland, Project Quality Assurance Manager
  • J.

N. Kaelin, Project Audit Coordinator

  • J. R. Cook, Quality Control Manager W. L. Petrie, Quality Assurance Supervisor C. Gardner, Project Mechanical Engineer M. Smith, Audit Response Coordinator W. Petrie, Quality Assurance Engineer Chicago Bridge and Iron Company W. Hiser, Project Welding and QA Supervisor The inspectors also contacted and interviewed other licensee and contractor personnel, including craf tsmen, QA'QC, technical and engineering staff members.
  • Denotes those attending exit meetings.

Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (50-483/78-10-05): Liner Plate in the spent fuel storage facility and the reactor refueling cavity was not considered by the licensee to be safety related.

In a position received from NRR dated January 25, 1979, fuel pool liners are not required to be designed and erected to Seismic Category I requirements. The pool liner is to

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provide a leak tight barrier and surface suitable for decontamination rather than a critical safety structure. However, The fuel pool storage structure, storage racks, supports and piping are still required to be designed and erected to Seismic Category I requirements. This item is closed.

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(Open) Noncompliance (50-483/78-10-02): Uncontrolled weld rod stubs.

The licensee initiated a program of:

(1) instructing welders and supervisors regarding control requirements; (2) placement of additional weld rod waste containers in work areas; and (3) instituted a program of monitoring work areas by supervisors. During this inspection, however, several pieces of uncontrolled weld rod were found in pipe chase 2 of the auxiliary building.

Based on finding this weld rod material, this item of noncompliance will remain open until the control of weld rod stubs is demonstrated.

(Closed) Unresolved (50-483/78-10-03):

It was previously reported that the actual welds on cable tray supports were longer than specified by 2 inches. Drawing C-0404(Q) titled " Typical Details Cable Tray Supports" sheet No. 4 in detail 16 requires a Unistrut type P1357 bracket to be velded with a 3/16" size 1 1/2" long weld on three sides. A letter from the Bechtel Site Liason Engineer dated December 11, 1978, to the Daniel Project Electrical Engineer confirms that the weld lengths called for on the Bechtel drawings C-04XX and C-06XX are the minimum required lengths; any welds over the minimum were acceptable.

(Closed) Unresolved (50-483/78-10-04):

It was previously identified that inspections were documented on Welding Surveillance reports instead of separate welding inspection reports as described in procedure QCP 507. Paragraphs 4.1.1, 4.1. 3, 3.21 and 2.9 of the procedure QCP 508 have been revised to cross reference QCP 507, e.nd the revision clarifies the responsibilities of the discipline engineer and the welding QC inspector.

(Closed) Unresolved (50-483/78-07-05):

It was previously reported that the contractor was in the process of developing suitable provisions to establish that welding is performed within the parameters specified in the WPS. QCP 505 dated January 9,1979, has been established, which d

reqc es that each piece of welding equipment actually in use will be tested avery six months. Verification of t' e implementation of the procedure included review of Welding Equipment Surveillance Reports (WESR).

WESRs document the inspections. To date, the characteristics of 41 pieces of welding equipment have been verified.

(Closed) Unresolved Item (50-483/78-02-01): Grounding of Class 1E systems and components. This matter was forwarded to IE for review. To IE's knowledge, the functionability of Class 1E electrical systems is not dependent on electrical continuity and grounding of raceway systems, therefore, there is no requirement for site quality assurance of grounding.

(Closed) Unresolved Item (50-483/78-02-03): Development of a training

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program for project electrical personnel other than QA/QC. This matter was updated in report 50-483/78-08; during the present inspection, this matter was determined to be in noncompliance. Refer to Appendix A and Section III, Paragraph I for details.

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(Closed) Unresolved Item (50-483/78-02-04): Acceptance criteria for inspection of raceway and supports. This matter was updated in report 50-483/78-08; item 3.c. (4)(d) should be corrected to read " Fastening requirements have been delineated for anchor bolts and concrete expan-sion anchors: anchor bolts in Note 6 of Bechtel drawing No. C-0003; concrete expansion anchors in Specification No. 10466-C-103A, Paragraphs 5.3.3, 5.3.4 and Appendix A."

Subsequent to the inspection item

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3.c.(4)(e) QCP 301, has been revised to include definitive inspection criteria in accordance with Paragrpah 5.3.3 and Appendix A of

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specification 10466-C-103A.

(Closed) Unresolved Item (50-483/78-14-04): Gas Tech Incorporated Instruction Manual recommended that their model IP-201 oxygen analyzer be calibrated monthly. Daniel was calibrating them on a six month interval. Daniel requested Gas 5sch Incorporated to clarify their recommendation of six months.

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Gas Tech letter dated January 23, 1979, states that a six month 2ab test and certification calibration interval is adequate providing two field steps (instrument operation check) are performed prior to normal use.

The inspector verified that this (field check) was performed by the users of instrument. This item is closed.

(Closed) Noncompliance (50-483/78-10-06): Failure to respond to audit findings within the required thirty days. The inspector reviewed Daniel interoffice memo dated December 15, 1978, directing all group managers to respond to audit findings during the allotted time period.

The inspector also reviewed the response times for two licensee audits (December 11-15, 1978, and January 8-14, 1979) conducted since the noncompliance was issued.

The response times were within the thirty day period.

This item is closed.

(Closed) Noncomplionce (50-483/78-08-04): Failure to appoint a team leader for audit teams. The inspector reviewed the revision (No. 3)

to administrative procedure AP-III-03 which was issued to require that a team leader be appointed whenever an audit is conducted by more than one auditor. Although the procedure was issued in January, the appointment of team leaders by Daniel QA group was started soon after the NRC inspection, when the noncompliance was found. The inspector reviewed audits QAR 78-08-01 and 78-12-01 and verified that team leaders were appointed. This item is closed.

(Closed) Noncompliance (50-483/78-08-05): Failure to certify Chicago Bridge and Iron (CB&I) welding supervisors for visual inspection. The inspector reviewed the certifications for five CB&I welding supervisors.

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This also included one supervisor who was assigned to the site for a two week period. The certifications met the ANSI N45.2.6-1973 require-ments. The inspector also reviewed the CB&I Division No. 6 " Visual Examination" procedure in their personnel training program. No items a

of noncompliance were identified. This item is closed.

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Section I Prepared by C. H. Erb Reviewed by D. H. Danielson, Chief Engineering Support Section 2 1.

Procedure and Observation Work - Reactor Pressure Vessel The Procedure for " Loading, Transporting and Setting the Reactor Pressure Vessel Rev. 2" tas examined. Two other supplementing procedures "No Load Test" and " Overload Test" were also examined.

Bechtel specification 10466-M-063Q was applicable. While the Crawler, moved the vessel from one side of the site to the other on March 6, 1979, the lift to remove the vessel from the Crawler did not take place until March 8, 1979, because the temperature was 27 F and the W beam was limited to use at 40 F or above. The vessel, beam and links were covered with plastic sheet and heated overnight to meet the temperature requirements.

Reactor Vessel No. RBB01 weighed 350 tons and for the overload Test Rev. 2, a 525 ton load was lifted and transported. The check list of inspections made on stressed parts of the lifting equipment after the overload test, was verified by the inspector. Upending, lif ting and setting was pe-formed on March 9 and 11,1979, and was witnessed by another inspector (see Section II of this report).

2.

Observation of in-Service Preparation in the Reactor Vessel Pit This pressure vessel, which was manufactured by Combustion Engineering Company, can be UT inspected from the outside surface. Vertical tracks have been installed inside the mirror insulation which will enable a small crawler to inspect the vertical welds and with sufficient reach horizontally to inspect the circumferential welds.

A dimensionalcheck and testing this equipment, which was supplied by Southwest Research Incorporated, was performed before the vessel was set.

3.

Storage of Reactor Vessel Head and Internals These items were stored in a heated building. All the stud holes in the vessel head were properly sealed, although protection on the diaphragm sealing surface on the head flange could not be determined because of dunnage interference.

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4.

Receiving and Quality Records - Safety Related Components a.

Records for Letdown Reheat Heat Exchanger No. EBG-05 manufac-tred by Applied Engineering Company and supplied by }[ under Quality Release QR-34680 were examined. This component is Class 2 on the tube side and Class 3 on the shell side and was manufactured to the requirements of ASME Section III 1974 edition, summer 1974 addenda.

a The material and fabrication certifications for this component were on microfische and appeared to be in order except for one difficulty which is explained under Unresolved items, Paragraph 5.

b.

Records for Accumulator, National Board No. 360, manufactured by Southwest Fabricating and Welding Company were examined.

This item was supplied by }[ under QR-31262 and is a Class 2 vessel built to }[ E-Spec 679065R3. ASME Section III 1974 edition, summer 1974 addenda is applicable and the certificate of shop inspection was signed by the Hartford Steam Boiler and Insurance inspector. Microfische records of certifications and tests by the manufacturer appeared to be complete and in order.

5.

Unresolved Item The tensile test results for stainless materials on the letdown heat exchanger described in Paragraph 4.a were much lower than expected in pounds / square inch.

It appears that the results (16,700 pounds) were not reduced to pounds / square inch.

The licensee representative agreed to contact }[ and Applied Engineering Company for explanation.

This item is unresolved until an answer is received from the licensee.

(483/79-03-01)

No items of noncompliance or deviations were identified in Paragraphs 1-5 above.

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Section II Prepared by W. A. Hansen Reviewed by R. C. Knop, Chief Projects Section 1.

Review of Licensee Action on Previous Inspection Findings The RIII inspector reviewed the licensee actions relative to the resolution of specific noncompliances and unresolved items which had been identified in previous RIII inspection reports, and which were still in an open status prior to this inspection. The itere reviewed, and the licensee actions relative to the resolution cf each item, are discussed in the Licensee Action on Previous Inspection Findings Section of this report.

2.

Procedure Review and Observation of Work Related to the Reactor Pressure Vessel Installation a.

The reactor vessel was rigged for lifting in accordance with drawing No. FS-C-0376 Rev. 3.

Rigging drawings were being used at the job site by Quality Control personnel to monitor reactor vessel lifting, b.

Reactor vessel installation '4as performed using the " Procedure for Loading, Transporting and Placing in Storage Position in Reactor Cavity" Rev. I dated February 20, 1979.

The vessel was (1) lowered, (2) correctly positioned, (3) final shim measurements recorded, and (4) seated on temporary shims in accordance with the procedure.

c.

Protective covers were installed at each nozzel and on the top of the vessel to prevent the entry of foreign material.

No items of noncompliance or deviations were identified in Paragraphs 1 or 2 above.

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Section III Prepared by F. J. Jablonski Reviewed by D. W. Hayes, Chief Engineering Support Section 1 1.

Review of Electrical Quality Assurance Implementing Procedure (483/78-02-03)

Daniel International construction procedure AP-II-05 " Orientation and Indoctrination of Personnel" states, in part, that " Complete and comprehensive programs shall be developed to provide personnel (Daniel and subcontractor, as applicable) with the basic information for them to efficiently, effectively, and safely perform the job functions necessary to build a nuclear power plant to the Quality Assurance requirements committed to in the SNUPPS standard plant PSAR chapter 17.1 and Callaway Plants Units 1 and 2 Addendum to SNUPPS standard Plant PSAR, Section 17.1 and Section 17B."

Union Electric's January 4-9, 1978, audit of Daniel International's QA program, included a finding that training programs had not been established and implemented for Construction Engineering personnel and others fnvolved in quality related activities.

During an NRC inspection conducted during March 20-22, 1978, Report No. 483/78-02, RIII inspectors identified training deficien-

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cies in the Project Electrical Department. The deficiencies were made independently of the Union Electric audit information, however, since inspection and audit findings were similar, the matter was considered unresolved, thus 78-02-03.

Daniel Iaternational developed construction procedure AP-XIII-07

" Employee Training Program". The procedure outlines the require-ments and methods for training of personnel who perform safety related functions other than QA and QC. A general requirement is that Department Managers are responsible for the development and imple-mentation of training requirements which consist of a reading index and course of instruction nocessitiated by individual job performance.

On March 7, 1979, the RIII inspector determined the Electrical Department Manager did not, in accordance with procedures AP-II-05 and AP-XIII-07:

a.

prepare or present a course of instruction; 2279 325-9-

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b.

initiate supplements to the reading indicies necessitated by changes in the initial reading material (several reading indices had not t.een updated in accordance with Revision 8 of the Procedure Status Index) or to add additional material as necessitiated by job site requirements, e.g. 10 CFR 50 Appendix B, 50.55(e),10 CFR 21; c.

sign his own revised reading indicies nor verify the signature of other department personnel who should have read the revised material.

Contrary to 10 CFR 50, Appendix B, Criterion V and paragraph 17.1.5 of the SNUPPS PSAR, this condition is an item of noncompliance as identified in Appendix A of.he report transmittal letter.

(483/79-03-02)

2.

Observations of Electrical Work Activities a.

In the upper and lower cable spreading rooms the RIII inspector reviewed ten drawings of Holder No. 537. The drawings are used for the installation of cable tray supports. All ten draw-ings were the current revision.

In all applicable cases, change notices were either annotated on the drawing face or attached to the drawing in accordance with Section 3.2.31 of Daniel International procedure AP-X-03, Rev. 5.

b.

Two drawing Monitor Reports, Nos. 161 and 169, of drawing Holder No. 537 were reviewed by the RIII inspector. Combined deficiencies were 2.5% (10/394). Field Monitoring graph No.

537 for a period between April, 1978, and March, 1979, indicated an overall decreasing trend of drawing deficiencies as follows: high of 26%; low 0%.

Inadequate drawing control was identified as an item of noncompliance in IE Report No. 50-483/77-10.

Corrective action as outlined in that report appears to be effective in the electrical construction department.

c.

In plant storage of electrical equipment, i.e. switchgear, motors and motor operated valves, was observed by the RIII inspector. At elevation 1974' of the auxiliary building, motors were covered by impervious, flame retardant covers and had heaters energized.

The switchgear had been installed recently, March 1, 1979, in the control building at elevation 2000'; heaters were being prepared for energization. The switchgear room met Housekeeping Zone 5 requirements as defined in Daniel International (

Construction procedure AP-V-10, however, storage and eating of food in equipment areas is not allowed per measures delineated 2279 3

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in Daniel Construction Procedure AP-IV-09.

Time restraints

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have limited implementation of those measures. This matter was

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discussed at the exit meeting. Licensee action in the areas of housekeeping will be reviewed during a subsequent inspection.

(483/79-03-03)

No items of noncompliance or deviations were identified in Paragraph 2 above.

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Section IV Prepared by J. C. Mattia Reviewed by R. W. McGaughy 1.

Safety Related Piping (Welding) Observation of Work Activities The inspector observed welding of cafety related piping at various stages of weld completion to determine if the requirements of the technical specification (10466-M-204(Q)), QC Procedure (No. 200)

and work procedure (No. 205) requirements were adhered to.

The following weld joints were observed:

a.

Weld joint fit-up was completed and no welding started.

Weld joint No. 2EM-01-F027 Size - 4", 0.531" vall Section III, Class 2 Material - P8 Welder M-78 The inspector reviewed the traveler card for this weld joint and also observed the QC engineer's inspection of the fit-up.

b.

Pipe to fitting weld (beyond root pass) joint.

Weld joint 2-BG-02-S005 (FW 8)

Size - 8", 0.282" vall Section III, Class 2 Material - P8 Welding - Stamp No. R-21 The following attributes were inspected for the above weld joint (Note: This weld was performed with automatic weld machines.):

- Specified weld procedure was used.

- Physical appearance of weld and use of specified weld material.

- Correct heat treat (pre and interpass) used.

- Correct weld parameters (feed rate, voltage, amperage and frequency) used.

- Weldor identification and qualification.

Weld traveler card data.

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No items of noncompliance were identified.

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c.

Nondestructive testing of completed joint. The inpector selected a completed weld joint 2EJ-01-F008 (size 12",

P8 material) which was going to be radiographed (of f-shif t)

that day. The inspector reviewed the film and interpreters sheet to verify compliance with the code and the contractor's procedure (NDE 7.5N2, Revision 2).

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No items of noncompliance were identified.

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Safety Related Piping (Welding) Review of Records The inspector selected various records associated with welding of pipe to ascertain that these records reflect work accomplishments consistent with NRC requirements and PSAR commitments. The following completed weld joints were selected:

2-EN-01-F002 (including repair records)

2-EN-01-F028 2 EJ-02-F026 2-EJ-02-F025 2-EF-02-F030 2-BG-01-F011 2-AL-01-F006 2-AL-01-F005 2-BG-01-F004 The records reviewed for the above weld joints were as follows:

Weld History Data

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Weld Material Reports

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NDE Equipment Calibration Record

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Weldor Qualifications

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NDE Technician Certifications

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- NDE Reports No items of noncompliance or deviations were identified in Paragraphs 1 and 2 above.

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Section V Prepared by K. R. Naidu Reviewed by D. W. Hayes, Chief Engineering Support Section 1 1.

Observation of Containment Structural Steel Installation Activities The inspector observed the containment structural steel installation activities being performed by Chicago, Bridge and Iron (CBI).

Vertical and horizontal stiffeners were being installed on the roof assembly at approximate elevation 2138'.

The inspector determined that applicable requirements were being met in the following areas:

a.

The vertical and horizontal stiffeners were being installed to CBI drawing 623 and 621 titled " Roof Stiffening Assembly Details" and " Roof Stiffening Assembly" respectively.

b.

Inspectors qualified to CBI's Training and Indoctrination program were performing the inspections.

5" x 3" x 1 1/4" angles, l' 5 7/8" long identified as 619-1 c.

and 620-1 were being attached to 5 1/2" x 1/4" har identified as 611-1 with a 1/4" size fillet veld, d.

Qualified welding procedure was being used; E-7018 type weldrod was being used.

e.

Qualified weldors were performing the welding activities.

f.

The welds required visual examination; the Rill inspector selectively examined the welds at approximate elevation 2138'

at location V-19, V-26 and V-30 and decermined them acceptable, g.

The RIII inspectors reviewed the weldrod burn-off rates recorded by the CBI inspector; the values indicated that the welding variables were within specification limits.

No items of noncompliance were identified.

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2.

Review of Equipment Supports Quality Assurance Records The inspector reviewed the quality assurance records associated with the steam generator lower lateral supports (SGLLS) - Westinghouse (W)

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spin identification RCESGL. These supports were manufactured by Lamco Industries in California and are accepted at site through a Quality Release from E.

The inspector reviewed the following documents and observed the storage of the components (which were covered) and determined that the records meet the E certification system in the following areas:

a.

Daniel personnel received the material. Material Receiving

Report (MRR) No. B14-01 dated August 21, 1978, indicated that 49 components of the steam Generator Lower Lateral Supports were received on July 3, 1978, with no visible shipping damage from Lamco Industries, California.

b.

y Quality Release (QR) No. 33700 dated June 28, 1978, indicates that the material met the requirements of Specification 952628 Revision 2 and drawings E 1459F04/4, 14.59F04/4 and 1459013/6.

A deviation notice (DN) No. 13349 identified that due to misinterpretation of the specification, the Magnetic Particle (MT) examination of the root pass of fillet welds had not been performed. The DN as approved on June 2, 1978, accepting the welds as is and confirming the MT requirement on the root passes of subsequent welds.

The code data forms were available.

c.

MR No. B14.01 dated August 21, 1978, indicates that one piece of the Steam Generator Lower and four pieces of the Upper Lateral Supports were received with no visible shipping damage from Lamco.

d.

E QA 33622 dated July 7, 1978, indicates that the supports met the requirements of y specification 952628 Revision 2 and Lamco drawings 6883 Revision B and 6884-2 Revision 2.

Deficient Documentation Log (DDL) No. 781 dated July 28, 1978, identifies missing code data forms. The DDL was closed on September 26, 1978, after receiving the missing documentation.

No items of noncompliance were identified.

3.

Observation of Containment Penetration Work Activities The inspector observed the installation activities of main steam flued head AB-01-F098 to containment sleeve P-2.

Electrical resistance heating was being used to maintain the required preheat temperature on the sections being welded. A digital read out indicator indicated that the preheat temperature was above 250 F.

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The fitup had been completed and inspected. The RIII inspector concurred with the QA welding inspector that fitup was acceptable.

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Tungstem Inert Gas (TIG) process was being used for the initial I

passes. The following attributes require QC veri ication:

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a.

Fit up and material identification.

b.

Flow rate of shielding gas.

Preheat temperature (250 F minimum).

c.

d.

Interpass temperature (250 F minimum /350 F maximum).

c.

Visual examination of the veld.

f.

Release of the veld for NDE (Radiography).

g.

Release for Post Weld lleat Treatment (PWHT).

Weld Procedure Specification (WPS) N-1-3-BA-22 Revision 3 dated November 20, 1978, was specified. Review of the WPS indicates that the procedure was qualified to thickness range 0.625" minimum and 1.942" maximum. The thickness of the flued pipe was 2 3/8".

The contractor had terminated the welding on penetrations AB-02-F102 and AB-01-F100 af ter attaining a 1.9" buildup. Discussions with the contractor personnel indicated that WPS N-1-3-BA-22 was developed and qualified based on preliminary information that the thickness of the material was 1.9".

Daniel's corporate office is in the process of qualifying a WPS for the correct thickness range.

The RIII inspector reminded the licensee of Paragraph 17.1.9 of the SNUPPS QA manual where he commits to use qualified procedures.

The licensee issued a stop work order to terminate welding on AB-01-F-096 af ter attaining a 1.9" thickness. The RIII inspector informed the licensee that this matter is considered an unresolved item pending verification of the changes in the essential variables in the revised WPS.

(483/79-03-04).

The inspector reviewed the radiographs on weld No. 2-AE-04-F038, a 30" diameter penetration in the Main Feedwater System. Radiographic Test (RT) was performed to RT procedure No. NDE 7.5 N2 R2 with Iridium 192 source. Porosity within acceptable limits was observed in six radiographs.

No items of noncompliance were identified.

4.

Verification of Installed Pipe Supports The inspector verified the installed pipe supports in the auxiliary building at floor elevation 1988' 0".

The hangers were installed

utilizing Daniel procedures WP-205 and QCP-200 titled " Preparation and Processing of Travellers" and " Inspection of Fabrication and Inspection of Piping and Component Supports" respectively. The inspector compared the installation with the relevant drawings and

determined the following:

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The location of pipe supports H001/123Q supporting a 3" a.

Chemical Volume and Control System (CVCSJ letdown flow to Volume Control Tank pipe'line - 017 GCB-3 were in accordance with the drawings FS-M-DO-BGO4-H001/123Q and FS-N-DO-BG04-H002/123Q. However, the positions of the pipes inside the

supports did not meet the drawing requirements. The design and normal operating temperatures of this line are 400 F and 124 r respectively.

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b.

The location of pipe support'H005/123Q supporting a 10" Residual Heat Removal System (RER), line 23-ECB-10 was in accordance with drawing FS-M-DO-EJ02-H005/123Q. However, the position of the pipe inside the support did not meet the drawing requirements.

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Discussions with the contractor and licensee personnel indicate the following:

c.

The field welds were inspected to QCP200, the position of tha pipe do not require verification. The contractor stated that the location of the pipe would be verified during a final pipe walk down.

d.

The drawings do not provide tolerances relative to either the size of the welds or the position of the pipe inside the support.

The relevant specification M-204 contains ambiguous requirements which do not complement each other. Typical quotes from 15e specification are as follows:

(1) Paragraph 5.2.1.a states " Piping center lines can deviate up to + 1 1/2 inches from the design location."

(2) Paragraph 5.9.1.a states " Pipe supports shall be installed in accordance with piping design drawings and hanger detail drawings."

(3) Paragraph 5.9.20.1 states " Fabrication tolerance for all noncatolog pipe supports and restraints to be fabricated in accordance with specification M-216(Q), shall be determined by the Installer based on good manufacturing practices. However, the following requirements shall be strictly observed:

Final fitup clearances for all box type supports shall be in accordance with Appendix E.

(Appendix E shows a graphic

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relationship between the maximum allowable clearance between the pipe an its support).

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The inspector requested the licensee to provide additional information to evaluate whether the above matter is an item of noncompliance contrary to Criterion III, V or I.

Appli-cable specification requirements have not been translated into installation drawings, adequate tolerances have not been indicated on drawings, to derive acceptance / rejection criteria and requirements are inadequate to properly inspect the position of the pipe inside the support. This is considered an unresolved item.

(483/79-03-05)

Unresolved Matter Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in Section 1, Paragraph 5,Section III, Paragraph 1,Section III, Paragraph 2,Section V, Paragraphs 3 and 4.

Exit Meeting The inspectors met with licensee representatives (denoted in the Persons Contacted paragraph) at the conclusion of the inspections on March 9, 1979, and March 11, 1979.

The inspectors summarized the scope and findings of the inspection.

The licensee acknowledged the noncompliance identified in Section III, Paragraph 1.

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