IR 05000483/1980004
| ML19309G186 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/13/1980 |
| From: | Knop R, Lee E K, Naidu K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19309G182 | List: |
| References | |
| 50-483-80-04, 50-483-80-4, NUDOCS 8005050105 | |
| Download: ML19309G186 (15) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
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Report No. 50-483/80-04 Docket No. 50-483 License No. CPPR-139 Licensee:
Union Electric Company P. O. Box 149 St. Louis, MO 63166 Facility Name:
Callaway, Unit 1 Inspection At:
Callaway Site, Callaway County, M0 Inspection Conducted: Feb uary 12-15, 1980 J Y'bak Inspectors:
H. M. Wescott 3-/3-$b K. Naidu E#
3//kN E. W. K. Lee 3hM
<b b
u Approved By:
R. C. Knop, Chief cJ - /,.?-h
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Projects Section 1 Inspection Summary Inspection on February 12-15, 1980 (Report No. 50-483/80-04)
Areas Inspected: Routine announced inspection; followup of a previous concern; review of action on IE Bulletins and Circulars; reactor coolant pressure boundary piping - observation of work activities; reactor coolant pressure boundary piping - observation of welding activities; review of audits. The inspection involved a total of 69 inspector-hours by three (3) NRC inspectors.
Results: Of the five areas inspected, one (1) item of noncompliance was identified (Infraction - failure to respond to corrective action) and one (1) unresolved item.
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DETAILS
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Persons Contacted Union Electric Company (UE)
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- R. Dettenmeier, Nuclear Engineer
- F. D. Field, QA Manager
- L. G. Harmon, Senior Construction Engineer
- J. Laux, QA Assistant Engineer
- D. A. Ostrander, QA Engineer
- R. L. Powers, QA Supervising Engineer
- R. H. Ripley, QA Engineer
- W. H. Stahl, QA Engineer
- J.
J. Stoecklin, Staff Engineer
- W. S. Strothman, QA Supervising Engineer
- W. H. Weber, Manager Nuclear Construction Daniels International Corporation (DIC)
- J. R. Cook, QC Manager
- J. A. Holland, PQAM
- E. D. McFarland, Construction Engineering Manager
- H. J. Starr, Project Manager
- W. L. Sykora, Assistant Project Manager
- Denotes those personnel attending the exit meeting at the Callaway site.
- Denotes those personnel attending the exit meeting at the St. Lou::
company office.
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Section I
Prepared by E. W. K. Lee Reviewed by D. H. Danielson, Chief
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Engineering Support Section 2 1.
Reactor Coolant Pressure Boundary Piping - Observation of Work and Work Activities The inspector observed the following work activities:
a.
Handling and rigging of Reactor Coolant System spool No. S015 on drawing No. M-03EM-03.
b.
Fit up of Reactor Coolant System Weld No. F016 on drawing No. M-03EM-03.
c.
Fit up of Chemical and Volume Control System Weld No. 2BG-21-F024 on drawing No. M03-BG-21.
It was determined that work activities were performed in accordance with the applicable procedures and good construction practices were adhered to.
No items of noncompliance or deviations were identified.
2.
Reactor Coolant Pressure Boundary Piping - Observation of Welding Activities The inspector observed the following welding activities:
Reactor Coolant System Weld No. 2BB-01-F301 on drawing No. M-03BB-01.
a.
b.
Chemical and Volume Control System Weld No. 2BG-21-F027 on drawing No. M-03BG-21.
c.
Reactor Coolant System Weld No. 2BB-01-F304 on drawing No. M-03BB-01.
d.
Liquid Radwaste System Weld No. HB-24-FWO65 on drawing No. M-0SHB-24.
It was determined that (1) work was conducted in accordance with traveler; (2) proper welding materials were used; (3) welding procedure requirements, were met; (4) work area was free of weld rod-stubs; and (5) physical appearance was acceptable.
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No items of noncompliance or deviations were identified.
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3.
Safety Related Piping - Observation of Welding Activities
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The inspector observed the welding of Chemical and Volume Control System welds No. 2BG-23-F007 and No. 2BG-23-F003 on drawing No.
H-03BG-23.
It was determined that (1) work was conducted in ac-cordance with traveler; (2) proper welding materials were used; (3) welding procedure requirements were met; (4) work area was free of weld rod-stubs; (5) physical appearance was acceptable;
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and (6) the center of weld No. 2BG-23-F007 is approximately 1/2" below the center line of the SD radius bend of spool No. 2BG-23-S005.
It appears that this is caused by bending the SD radius bend in ex-cess of 90 degrees. The inspector stated this matter is considered unresolved pending a review of the measurement of the end to end dimension of spool Fo. 2BG-23-S005.
(483/80-04-01)
No items of noncompliance or deviations were identified.
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Section II
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Prepared by K. R. Naidu Reviewed by D. W. Hayes
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1.
Review of Licensee's Action on NCR 2S0-0854 During a previous November 14-16, 1979 inspection, the NRC inspectors observed a linear indication being excavated along the entire length of pipe spool 2BM01-S007/231 and requested the licensee to obtain the following information:
The number and location of other spool pipes supplied with the same heat number.
What corrective action, if any, was taken to preclude recurrence.
During the current inspection, the inspectors reviewed the additional information provided by the licensee. The NRC inspectors determined the following:
38 spools from the same heat No. L86053 have been supplied to a.
the Callaway Station. An additional 10 spools with the same heat number have been identified to have similar effects as 2BM01-S007/231.
On January 18, 1980 representatives from Bechtel (AE) Dravo, the fabricator, and U.S. Steel, the manufacturer, inspected the ques-tionable pipes on site to collect necessary information and samples of pipe for further metallurgical examination at the vendor's facil-ities.
The NRC inspectors visually examined the pipes in the laydown area and the installed pipe and concurred with the licensee that visual examination during receipt inspection would not identify these de-fects. At the NRC inspectors' request, the area adjacent to Field Weld F017 on spool piece 2BM-02-009 was buffed and examined.
In the buffed area, there was an indication that a possible weld repair was performed at the fabricator's shop; this could not be substantiated because the documentation did not disclose that a weld repair was made, b.
Witnessed Ultrasonic Testing on Pipe Material
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At the NRC inspectors' request, the licensee cleaned two areas on installed pipes with defects: one adjacent to shop weld-5-
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881C on spool piece 2BM-01-S006/231 and the other on a specific
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area on spool piece 3BM-02-S009 in preparation for-Inr examina-tion. A Level II UT inspector utilized a Nortec type NDT-123 Dial Thickness Gage Serial No. 123-505 to perform the test.
The calibration sticker on the instrument indicates that it was last calibrated on October 19, 1979 and was due for_re-calibration on April 19, 1980.
Paragraph 6.5 of Procedure
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NDE 7.6 dated August 30, 1977 was used by the Level II examiner with a Nortech Transducer Serial No. 9776. The wall thickness measured was below nominal wall thickness but above code speci-fied minimum wall thickness, the lowest reading being.471 (lowest acceptable was.465).
c.
Review of Quality Records The inspectors reviewed the quality records associated with spool piece No. 2BM-02-009 and identified no adverse findings.
No items of noncompliance were identified.
2.
Review of Nonconformances The NRC inspectors reviewed several NCRs documented during the first quarter of 1978 to establish whether timely corrective action was taken to preclude recurrence. The following NCRs were reviewed:
a.
NCR No. 2-2475-P-B dated March 28, 1978 identified a linear indication 12" long adjacent to the bevel edge during a visual inspection of weld preparation for field weld No. 2EF-05 F042 on Spool Piece No. 2EF-05-S035/111. Disposition proposed was to grind the indication, ascertain whether 40% of the material wall thicknera was infringed upon and to replace the pipe if the minimum wall thickness was reduced by 40%.
b.
NCR No. 2-2457-P-B dated March 27, 1978 indicates linear in-dications detected adjacent to F033 on spool piece EF-055030/123.
Disposition proposed was to grind the indications.
If the grinding process to remove the indications exceeded the 40% of the existing wall thickness, then the pipe was considered to be irrepairable and was to be replaced.
c.
NCR No. 2-2420-P-B dated March 21, 1978 was generated to in-dicate three linear indications found in pipe spool identified as 2-EF-04S022/111 at field weld No. 2-EF-04-F-020 in Bechtel drawing FS-M-DM03 EF04 Q Revision 3.
Disposition was to cut and replace a 11'-10" length of the pipe.
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d.
In a " Deviation Investigation Request" dated April 24, 1978, Daniel requested the licensee to evaluate these conditions along with NCR 2-2708P. The following is the sequence of events which took place thereafter:
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(1) The licensee in a letter ULS-2198 dated May 1, 1978 re-
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quested the SNUPPS organization to respond to the proposed corrective action to prevent recurrence.
It included a concern "although hydrostatic and visual surface examina-tion are the only code requirements for the. seamless pipe material, we are surprised these indications escaped de-tection by the subject vendor during NDE of shop ' elds."
w (2) SNUPPS letters SLBM 78-180 dated May 5, 1978 and SLBM
'78-184 dated May 8,1978 to Bechtel justifies that these
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instances are not considered reportable and requests the following action if Bechtel determines that some or all the components in question are " basic components":
(a) Remind suppliers of obligation to supply components l
under existing contracts.
(b) Document either unavailability of components from sub-tier suppliers or justify the cost increase to the utilities.
(c) Identify components critical to plant schedules whose delivery is impacted by regulation provisions.
(d) Recommend a procurement plan to obtain the components under contract provisions required by regulation.
(3) Bechtel's letters BLSM-8419 and BLSM-8420 dated June 23, 1978 in reply to the above mentioned letters justifies that the matter is not reportable and fails to respond to corrective action plans to preclude recurrence, From the available documentation and discussions with licensee e.
personnel at their corporate offices, the NRC determined that Bechtel did not attempt to investigate this matter further with the vendors as requested in SNUPPS letters mentioned in para-graph d(2).
f.
The inspector reviewed Deficiency Report No. 25D-0854-P which identified linear indications extending full length of the pipe spool 2-BM01-S007/231 on October 25, 1979.
In the "Cause of Deficiency and Action Taken to Prevent Recurrence" column it was stated " Pipe Received from Manufacturer does not meet the Section III installation requirements. Action to prevent recurrence not applicable." The licensee did not initiate any action to determine the cause of the adverse condition in in the piping and did not plan to take corrective action to preclude repetition until the NRC inspectors identified this
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matter as a potential problem area. The NRC inspector identi-fled this matter as an item of noncompliance contrary to the-7-o
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requirement of 10 CFR 50, Appendix B, Criterion XVI. The in-
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spector informed the licensee that a written reply is not necessary because corrective action was initiated which re-sulted in a visit to the site by representatives of the manu-facturer, the fabricator and the AE.
(483/80-04-02)
g.
During the period after June 23, 1978, field personnel'were
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advised to disposition nonconformances by replacement or repair without engineering approval.
As such, " Deviation Reports" (DR), which do not require engineering to review the disposi-tion are being used to document nonconforming conditions, instead of NCRs. The NRC inspectors expressed concern to the licensee representatives that an important tool to promptly detect and correct an adverse trend in the quality of the procured pipe may have been disabled by eliminating the engi-neering review from the review process of the DRs instead of NCRs.
The licensee's site QA in a letter 10-79/03 dated October 11, 1979 alerted their management of a possible adverse trend in the base metal of pipes after reviewing twenty-four NCRs/DRs.
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Details in the NCRs are documented in sub paragraph g.
The licensee's management in a reply dated November 20, 1979 re-ferred the site QA to Bechtel's letters BLSM-8419 and 8420 dated July 23, 1978.
h.
The NRC inspectors selectively reviewed nonconformances iden-tified during 1979 and determined the following:
(1) NCR No. 2SN-0172P dated February 9,1979 identified po-rosity and linear indications in pipe spool 2-EF-S029 at
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F033A while performing P.T. of final weld. Disposition was to remove defects by grinding and repair in accoraance with procedure WP-504.
(2) Deficiency report No. 2SD-0081-P dated December 18, 1978 identified linear indications extending 56" on spool piece 2-EF-02-S025 during PT and NT examinations. Disposition was to replace the affected 5 foot length of the pipe.
This deviation report superceded NCR-25N0007-P.
(3) Report No. SD-0267-P dated March 14, 1979 identifies a linear indication on spool No. 2-GN-01-S027 at Field Weld No. 2-GN-01-F028, which was 9" long starting from one end of the spool. Disposition was to repair the indication utilizing procedure No. WP 504.
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(4) Report No. 2SD-0658-P dated August 23, 1979 identifies
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linear indications on spool pieces No. 2-EF02-S009/142 extending from F050 to shop weld. Disposition was to cut the affected portion of the pipe and replace it.
(5) Report SD-0833-P dated October 16, 1979 identifies,an apparent hairline crack approximately 10" long at weld
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S020 as it crosses column "AL", at elevation 1995'-1".
Disposition was to grind the surface conditions and re-pair any minimum wall violations.
(6) Report No. SD-0413-P dated May 17, 1979 identifies a minimum wall violation of approximately 4-1/2" away from field weld joint F020A on spool piece SO47. The report states that the vendor supplied the spool piece with minimum wall violation. The minimum wall thickness mea-sured was 0.314", which is below the code specified 0.319";
the nominal thickness of the 10" diameter pipe is 0.365".
The UT was performed by a Daniel Level II inspector uti-lizing procedure NDE 7.6 and the results are documented in report UT-00163 dated May 10, 1979. This minimum wall thickness violation could not have been detected if the thinning occurred in the length of the pipe other than the ends, because the inspection requirements in paragraph 6.3.1 of the Bechtel specification 10466-M-201B and sub-section NC-2551(b) of the ASME Section III require only the ends of the pipe to be tested.
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Based on the above information, the NRC inspectors conclude that if prompt corrective action was taken in a timely manner, such as reviewing vendor's manufacturing processes and quality assurance program implementation relative to in process inspec-tions, some of the nonconforming conditions such as minimum wall thickness violations and spiral indications on rolled pipe may have been reduced.
3.
Review of Shop Radiographs The NRC inspectors reviewed the radiographs for the following welds:
a.
Shop Welds 881C, D and F on spool piece 2-BM-01-S006/231 b.
Shop Welds 884B and D on spool piece 2-BM-01-S006/231 c.
Shop Welds 862B and C, 861-D, 864-B on spool piece 2-BM-02-S007/232 d.
Shop Welds 865 B and C on spool piece 2-BM-02-S010/232
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Field Weld No. F017 joining spool piece 2BM-02-S009 to 2BM-02-S010
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The inspectors determined the following:
(1) Reader sheets were available with the radiographs (2)
Iridium isotopes of various strengths were used with Type
"T" Kodak film
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(3) The film density was within acceptable limits
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(4) No unacceptable indications were identified No items of noncompliance were identified.
4.
Observation of Installed Piping
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The NRC inspectors observed a section of the steam generator blow-down pipe at elevation 2020' installed with a gradient outside the shield wall inside the containment. The relevant drawing No.
M-03BM.01 (2) Revision 5 indicates no gradient change between spool pieces 2BM-01-S017, Valve No. V001 and 2BM-01-S016. Hanger No.
PM01-H009 supports the piping. The licensee and contractor personnel acknowledged the improper installation which caused Ja unacceptable fit up for line 03PE08 which fit into a socket in 2BM-01-S017 and stated that this discrepancy was documented and that the installed pipe would be reworked. The joint was not tagged to indicate that rework was pending. The inspector reviewed the documentation rela-tive to this field weld identified as No. 2-BM-01-F025 joining the valve V001 to spool piece 2-BM-01-S017 and determined the following:
Weld Control Record documents the following:
a.
(1) Weld Procedure Specifications (WPD) N-1-1-B-1 and -2 were used.
(2) Fit up, shielding gas flow rate, preheat, interpass heat were verified and determined acceptable.
(3) Welders qualified for the WPS, welded the joint.
(4) RT report No. 02618 dated July 5, 1979 identified incom-plete fusion in the 7-10-1/2 area of the circumference of the weld. The area was repaired, reexamined and RT report No. 02635 dated July 6, 1979 indicates that the weld was acceptable.
(5) The NRC inspectors independently reviewed the radiographs and concurred that the veld was acceptable.
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b.
Weld Control Record, which documents the inspections en pipe
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support No. 2-BM-01-H009/231 Q which supports the Apool piece, indicates the following:
(1) WPS N-1-1-A-6 was used with weldrod typ< E-7018 (2) Preheat 65 F was verified
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(3) Fit up, welder ID and visual inspections were performed and determined acceptable The inspectors informed the licensee that they have no further questions on this matter.
No items of noncompliance were identified.
5.
Review of Audits The inspectors reviewed the SNUPPS QA Committee Audit Schedule for the audits performed during 1978 and 1979, and the proposed schedule plan for 1980 and determined the following:
Dravo Corporation was audited in February 6-9, 1978.
Pullman-Kellog was audited in October 6-8, 1976. No audit was scheduled or perform-ed during 1978 and 1979.
a.
Audit on Pullman Kellog (1) October 6-8, 1976. The documents available at Union Electric, St. Louis, Missouri, indicate that an audit was performed during October 6-8, 1976 at Pullman Kellog facilities in Williamsport, Pennsylvania. One of the six audit members was from Kansas Gas and Electric Company.
The report indicated that 19 quality elements were audited and five audit findings were identified. One of the five (audit finding No. 4) determined that a review of process sheet on S08251 Bechtel Order 10466-M 201(a) (which is the purchase order for Callaway) indicated that the inspection activities such as welding, magnetic particle testing, and cleaning were signed off without recording the specific procedures on the sheets. Corrective action recommended was for the supplier to implement procedures to record procedures used on the process sheets, for provisionr to verify that those proceoares were in fact used, and that personnel receive addiuional training or instructions on the above requirement.
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(2) Reaudit May 13, 1977. A Bechtel, San Francisco letter
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dated June 24, 1977 refers to a re-audit performed on May 13, 1977 to verify and evaluate the corrective action taken on the audit findings; the results of the reaudit indicate that the corrective action was satis-factory.
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(3) Audit October 18-20, 1977. A Bechtel, San Francisco letter dated November 14, 1977 indicates that during October 18-20, 1977 Bechtel performed a " Full Scope" audit of the Pullman Kellog's QA program by members from the various Bechtel offices. The audit covered 19 " Quality Elements", and one audit finding was identi-fled relative to inadequate review by Kellog's management to determine whether corrective actions included action to prevent recurrence.
No items of noncompliance were identified.
6.
Review of Action Taken on IE Bulletins and Circulars IE Circular 79-02 The licensee received a response from Westinghouse, the NSSS supplier, advising them that Time Delay Devices are used at the Callaway Station (instead of static inverters) in the vital AC circuitry; the settings use and testing of the said devices are provided in their instruction manual for 7.5 KVI., 60HX1 Vital AC inverters.
IE Circular 79-20 The SKUPPS organization in a letter dated October 2, 1979, trans-mitted the circular to Bechtel Gaithersburg.
IE Circular 79-23 Records indicate that seventy four (74) Nema size 3 starters at the Callaway Station were replaced by Gould representatives.
IE Bulletin 79-01A The licensee is continuing to evaluate the environmental qualifica-tions of the class IE equipment.
IE Bulletin 79-09 The licensee in their letter dated June 14, 1979 indicate that
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General Electric Type AK-2 circuit breakers are not installed at the Callaway Station.
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The SNUPPS organization in a letter dated July 24, 1979 indicate i
that Westinghouse Type DB-50 or DB-75 circuit breakers are not being used in any safety-related applications.
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The SNUPPS organization in a letter dated October 26, 1979 indicates that the exciter power transformer of the diesel generator has a delta connected primary and therefore this bulletin does not apply.
IE Bulletin 79-25 The SNUPPS organization in a letter dated January 1980 indicate that Westinghouse Type BFD/NBFD relays are not included in the safety-related systems.
IE Bulletin 79-28 The SNUPPS organization in a letter dated February 1, 1980 state that the investigation concerning.he planned use of NAMCO type EA180 switches is not complete.
IE Bulletin 79-27/29 The licensee is awaiting information from the SNUPPS organization relative to the Class 1E and non Class IE buses supplying power to
safety and non-safety-related instrumentation and control systems which could affect the ability to achieve cold shutdown condition using various procedures.
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- Section III
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l Prepared by H. M. Wescott Reviewed by R. C. Knop, Chief,
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Projects Section 1
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1.
Review of IE Bulletins The inspector reviewed IE Bulletins to verify that the licensee response and review of bulletins was technically adequate and re-presents the action taken as required by the bulletin, as follows:
a.
IE Bulletins 79-05 Nuclear Incident at Three Mile Island.79-05A 79-05B 79-06 Review of Operational Errors and System Misalignment Identified During the Three Mile Island Incident 79-06A 79-06A, Rev. 1 79-06B The inspector reviewed the following correspondence:
Letter, Westinghouse to NRR (NS-TMA-2087) dated May 17, 1979 w/
attachment which responds to 79-06A, item No. 7.
Letter, SNUPPS to Bechtel (SLBE 79-264) that discusses Bulletin 79-06A.
Letter, Westinghouse to SNUPPS dated April 30, 1979, discusses Westinghouse presentation to ACRS.
The above IE Bulletins are not closed out, and will remain open pending the licensee's resolution to ongoing studies of the Three Mile Island-Incident. The licensee considersBulletins 79-05 and 79-06 as the same general subject and is acting accordingly, b.
79-13
" Cracking in Feedwater System Piping".
The inspector reviewed the following:
Letter, SNUPPS to Bechtel (SLBE 79-468) dated July 6, 1979.
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Letter, SNUPPS to KGE, RGE, UE, and KCPL (SLT-118) dated September 28, 1979 discussing contracting of Westinghouse to develop a solution.
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Letter, Bechtel to Westinghouse (BLWE-1093) dated October 16,
1979, requesting information regarding cracking problem in order to evaluate and make any required changes.
The above remains open pending the licensee's impleventation of any required changes.
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2.
Review of Audits The inspector reviewed Dravo audits to ascertain that audits had been scheduled and performed and that timely followup had taken place where necessary.
a.
Review of Dravo Audit Files 59D01 as follows:
(1) Limited scope audit, dated February 22-25, 1977 (2) Letter, Bechtel Power Corporation to Drano, File No.
M-201A dated November 14, 1977 (3) Letter, Drano to Bechtel dated December 7, 1977 discussing findings and corrective actions (4) Meeting notes dated December 15, 1977 at Dravo to review and verify corrective actions of November 9-10, 1977 meeting (5) SNUPPS QA Audit S-5, dated February 6-9, 1978 with followup The inspector found the above adequate. A continuing review of audits will be performed at subsequent inspections to verify that audit schedules are met and that timely followup is being performed to assure that appropriate corrective action is being taken.
No items of noncompliance or deviations were identified in this area of the inspection.
3.
Unresolved Items Unresolved items are matters about which more information is re-quired 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 3.
4.
Exit Intervieu
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i The inspectors met with the licensee representatives denoted in
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Details section under Persons Contacted at the conclusion of the inspection at the Callaway site on February 14, 1980, and February 15, 1980 at the conclusion of the inspection at the i
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corporate office in St. Louis, Missouri. The inspectors summarized the purpose, scope, and findings identified during the inspection.
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