IR 05000483/1981010
| ML20009B080 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/17/1981 |
| From: | Konklin J, Martin L, Neisler J, Vandel T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20009B070 | List: |
| References | |
| 50-483-81-10, NUDOCS 8107140743 | |
| Download: ML20009B080 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-483/81-10 Docket No. 50-483 License No. CPPR-139 Licensee: Union Electric Company Post Office Box 149 St. Louis, MO 63166 Facility: Callaway Construction Site, Unit 1 Inspection At:
Steedman, M0 Inspection Conducted: May 5-7, 1981 Inspectors:
J. H. Neisler, RIII M _ j-/7-7/
L. E. Martin, RIV 6 - / 7 - I/
T. E. Vandel, RI\\
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Accompanied By:
J. E. Konklin, RIII Approved By:
J. E. Konklin, h (
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Projects Se on 2A Inspection Summary Inspection on May 5-7, 1981 (Report No. 50-483/81-10)
Areas Inspected: Routine, unannounced inspection of constructio?. and preoperational activities including review of procedures and records for installation of seismic Category II electrical raceways above seismic Category I electrical raceways (II/I).
Review of proc <..ures for instal-lation of II/I piping and for conducting construction and preoperation testing. The inspection involved 64 inspector aours onsite by three NRC inspectors including 0 inspector-hours ensite during off-shifts.
Resuits: Of the three areas insprcted, two violations (failure to provide appropriate procedures; failure to follow approved procedures) were iden-tified in one area.
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8107140743 810624 PDR ADOCK 05000483 G
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DETAILS Persons Coatacted
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Principal Licensee Employees
+D. Schnell, General Manager Operations
- B. L. Powers, Superintendent, Site Quality Assurance
+*W. H. Weber, Manager, Nuclear Construction
+*J. V. Laux, Supervisor Engineering, QA Construction
+*J. N. Kaelen, Superintendent, Startup
+W.
H. Stahl, Supervisor, Startup
- S. M. Hogan, QA Assistant Engineer
- C. J. Plows, QA Consultant
+J. L. Harden, QA Consultant Daniel International (Daniel) Personnel
- A. D. Arnold, Project Quality Manager
- W. L. Sykora, Assistant Project Manager
- J. A. Holland, Engineering Manager
- J. C. Weaver, Electrical Manager
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- M. K. Smith, Audit Response Coordinator J. Mullin, Project Electric D. Shwartz, Lead Power Block and Outside Engineer H. Collins, Compliance Engineer, Panel Division L. Hill, Lead Hanger Engineer J. Hanvey, Lead Power Block Piping Engineer T. Shoemaker, Assistant HVAC Engineer
- Denotes those persons attending the exit meeting on May 7, 1981.
+ Denotes those persons attending the exit meeting on May 6, 1981.
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Section I
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Prepared By:
L. E. Martin T. E. Vandel 1.
Electrical Cable and Raceway The NRC's inspector reviewed the following procedures pertaining a.
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to the installation and inspection of II/I cable tray and cable tray supports for compliance with the FSAR, NRC Regulatory Guides, and IEEE standard commitments.
II/I is the Bechtel designation for non-safety components, equipment, and supports whose failure could reduce the ability of a safety related or class IE system to perform its function as addressed in NRC Regulatory Guide 1.29.
WP-03, Revision 2, " Field Fabrication and Installation of Seismic II/I Supports and Block Walls" WP-301, Revision 9, " Installation of Electrical Raceway Supports" 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality be prescribed in documented procedures appropri-ate to the circumstances, including quantitative or qualitative acceptance criteria for determining satisfactory accomplishment of the activity.
NRC Regulatory Guide 1.29, Position 4 requires that pertinent quality assurance requirements of Appendix B to 10 CFR 50 be applied to all activities affecting the safety-related functions of those portions of structures, systems, or components whose continued function is not required, but whose failure could reduce the functioning of a safetyrelated function.
The NRC inspector determined the following:
(1) WP-03 Paragraph 4.3 states, "For Seismic II/I Electrical Raceway Supports, the installation shall Tx11ow the pro-cedure detailed in Reference 2.15 with the following additional steps.
"... Reference 2.15 for WP-03 is WP-301.
WP-301 Paragraph 3.19 provides the above referenced installa-tion details, quote, " Seismic II/I Raceway Supp)rts shall be fabricated, installed, and inspected per Reference 2.14.,"
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where Reference 2.14 is WP-03.
The cross reference between the two procedures does not provide any guidance for the installation of the II/I Electrical Raceway Supports.
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WP-03 Paragraph 4.3.6 requires inspection of all II/I hanger locations and configurations using Bechtel Drawing EPR-8900 as a guide.
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Bechtel Drawing E0R-8900, " Raceway Notes, Symbols, and Details,
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contains general notes and details for raceway, but does not provide suitable information to install or inspect raceway supports. EOR 8900 does not provide appropriate acceptance criteria for determining satisfactory accomplishment of an activity affecting quality.
c.
WP-03 Paragraph 4.3.6 also requires the documentation of the II/I raceway supports inspections on the " Conduit and
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Tray Record" (Work Assignment) which is Exhibit A in WP-301.
The Conduit and Tray Record is not designed for use as an inspection report. The record does not provide an appropri-ate space for inspection results (sat /unsat), it provider no inspection criteria, capability for inspector remarks, nor appropriate signature block for the Engineer Inspector, or date of inspection. At the time of this review, the Project Electrical Engineer's (PEE) signature block was being used to indicate the satisfactory completion of the II/I raceway supports. This signatare block is normally used to indicate Engineering's authorization to the craft to accomplish the work assignment. WP-301 does not indicate that the PEE block is an inspection signature.
d.
WP-03 and WP-301 do not address any requirements for the inspection of the bolted connections of the II/I raceway or the connection of the raceway to the II/I supports.
Bechtel utilizes the cable tray stiffness in the design of seismic raceway supports, and it is assumed that the raceway will remain intact. The inspector notified.the licensee that these connections need to be inspected and, therefore, should be addressed in the appropriate II/I installation and inspection procedure.
The above four items are specific examples of areas where Procedures WP-03 and WP-301 fail to provide appropriate documented procedures including quantitative or qualitative acceptance criteria.
This is a violation (50-483/81-10-01).
WP-03 requires that all II/I inspections be performed by Engineering Inspectors that have been selected and trained by the Project Discipline Engineers. The engineers that have been performing these inspections to date have, for the most part, been the Area Discipline Engineers, or have worked directly for the Area Discipline Engineers.
ihis may put the Engineering Inspector in the position of inspecting activities for which he also has direct and indirect responsibilities for sched-uling, engineering oversight, and cost accountability. The Engineering lospectors are not either in a separate group or are not designated in-dividuals with a significant (egree of independence. The NRC inepector noted this as an item of concern and requested that this item be addressed by the licensee in the review and response to this inspection (50-483/81-10-02).
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2.
The NRC inspector reviewed II/I raceway support inspection records to determine the implementation of the requirements of WP-03 and WP-301.
10 CFR 50, Appendix B, Criterion V requires that activities affecting quality to be accomplished in accordance with documented instructions, procedures, or drawings.
a.
The NRC inspector selected thirteen raceway supports designated as II/I raceway supports on Bechtel Drawings E-0R-3411, Revision 12
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and E-0R-3511, Revision 12.
The installation of these supports were covered on the following Conduit and Tray Support Records (WA):
II/I Support Number WA Number No. SU1Z16 EA-TS-3119 WA-TSX-3160 No. 5J1W14 WA-TSX-3174 No. 5J1W10 No. SU5L10'
EA-TSX-3125 No. SU4B10 No. SU5L12 WA-TSX-3160 No. SU4B12 No. SU1209 WA-TSX-3155 WA-TSX-3195 Nc. 5J5A05 WA-TSX-3113 No. SU4A05 No. SC8R05 No. 5J5A01 EA-TSX-3115 No. SC8ROI
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WP-03 Paragraph 4.3.1 requires that the Project Electrical Engineer mark the Conduit and Tray Support Record (WA) as II/I and that a copy be forwarded to Welding Engineering prior to beginning field work.
On May 6, 1981, the NRC inspector found that five of the nine WA listed above did not indicate that the associated raceway supports were II/I. Of the thirteen supports selected ten were i
l not properly identified as II/I.
No. preceding support number above indicates the supports that were not properly identified as II/I.
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i Failure to properly identify the above supports as II/I may have resulted in failure to acccmplish II/I welding inspection.
The NRC inspector did not pursue this due to time constraints, but did address this concern to the licensee representative.
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b.
The NRC inspector reviewed completed II/I Conduct and Tray
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Records (WA) in the document vault.
WP-03, Paragraph 3.1 states, "All inspections shall be performed by Engineering Inspectors, selected and trained by the Project Discipline Engineers. The selection shall be based upon education and experience, and documented in a signed letter of authorization upon completion of the raquired training."
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The NRC inspector found the following seven WA's that were signed-off as having been II/I inspected by individuals whose name did not appear on a list of persons authorized by the PEE to perform II/I inspections.
WA-CSX-1144 WA-TSX-1103 WA-CSX-1124 WA-TSX-5105 WA-CSX-5108 WA-TSX-1246 WA-CSX-5101 A further review of the training records and discussions with the
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PEE failed to provide any documentation of training received or authorization to perform II/I inspections for these individuals at the time the II/I inspections were performed.
The above two items are examples of areas where the requirements of WP-03 were not followed in accomplishing an activity affecting quality.
This is a violation (50-483/81-10-03).
Based on the two violations above:
(1) Failure to provide appropriate ptucedures, and (2) Failure to follow procedures, and the percentage of the II/I raceway activity affected, the validity of the inspections performed to date on the II/I raceways is questionable.
3.
Mechanical and HVAC The NRC inspector reviewed the following procedures pertaining to the installation and inspection of II/I piping, HVAC and the associated supports for compliance with FSAR and NRC Regulatory Guide 1.29.
WP-03, Revision 2, " Field Fabrication and Installation of Seismic II/I Supports and Block Walls."
WP-250, Revision 7, " Field Fabrication and Installation of Non-Safety Related Piping and Component Supports."
The above procedures, used in conjunction with one another, adequately address II/I inspection of piping and HVAC; however, the NRC inspector expressed concern regarding the indepenJence of the Engineering Inspector.
This is included as ptet of the unresolved item (50-483/81-10-02) noted above.
No deviations or violations were identified.
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Section II Prepared By:
J. H. Neisler Construction and Pre-Operational Testing The inspector reviewed administrative procedures established for controlling construction and preoperational testing at Callaway. Specific procedures reviewed during this inspection included:
1.
Union Electric Procedure NCAI-1, Revision 1, dated February 3, 1981,
" Preparation, Review and Approval of Nuclear Construction Administrative Procedures." This procedure establishes controls and assigns respon-sibilities for the development, review and approval of administrative procedures used in the Callaway test program.
2.
Union Electric Procedure NCAI-4, Revision 1, dated November 13, 1980,
" Construction Completion Testing Procedure Development, Test Conduct and Results Approval." The inspector noted that Section 9.0, " System Restoration," requires that space will be included at each step in restoration procedures for the individual performing the system re-storation to place his initials and the date when the activity was accomplished. The procedure is unclear as to how inspections to assure that the restoration activity has been accomplished in accordance with approved criteria will be documented. This matter is unresolved (50-483/81-10-04).
3.
Union Electric Procedure NCAI-6, Revision 0, dated December 2, 1980,
"Startup Document and QA Record Control."
4.
Union Electric Procedure NCAI-7, Revision 0, dated September 16, 1980
" System-Release for Testing." This procedure established the require-ments and assigns reponsibilities for the release by the constructor to the owner's testing organization for the performance of system testing.
The procedure states, "DIC/UE system walkdown does not necessarily verify as-built construction." The procedure does not identify the method or procedure that verifies as-built construction.
Licensee personnel at the exit interview indicated that this procedure is being revised and that the new revision should clarify this matter. This item is unresolved (50-483/81-10-05).
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. Unresolved items disclosed during the inspection are discussed in Section II of this report.
Exit Interview The inspectors met with licensee representatives (denoted under persons contacted) on May 6, 1981, and on May 7, 1981. The inspectors summarized L
the scope and findings of the inspection. The licensee acknowledged the findings as reported herein.
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