IR 05000529/1985014

Insp Repts 50-529/85-14 & 50-530/85-09 on 850325-29. Violation Noted:Welding of New Fuel Storage Racks.Deviation Noted:Procurement of New Fuel Storage Racks

ML20127K870
Person / Time
Site:	Palo Verde
Issue date:	05/08/1985
From:	Ball J, Hernandez G, Hooks K, Miller L, Peranich M, Stein S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20127K837	List: IR 05000529/1985014 ML20127K835 ML20127K840 ML20127K858
References
50-529-85-14, 50-530-85-09, 50-530-85-9, NUDOCS 8506270624
Download: ML20127K870 (12)

Text

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No /85-14, 50-530/85-09 Docket No , 50-530 Construction Permit Nos. CPPR-142, and 143 Licensee: Arizona Nuclear Power Project Post Office Box 52034 Phoenix, Arizona 85072-2034 Facility Name: Palo Verde Nuclear Generating Station Units 2, and 3 Inspection Conducted: March 25-29, 1985 Inspectors: # // #64't M. W. Peranich, Chief, Construction bOI[b Date Signed Programs / CAT Section, IE

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. R.' Hooks,1eactor Const ction Engineer, IE

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" S .' , Stein, Rea tor nstruction Engineer, IE Date Signed GUHf (y ernan ' eni r Resident Inspector

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Date Signed (. &Inspector 005 W J.(R Ball, e Date Signed Approved By: >

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L.kF. Miller, Cht'ef Date Signed Reactor Projects Section No. 2 Summary:

Inspection from March 25-29, 1985 (Report Nos. 50-529/85-14 and 50-530/85-09).

Areas Inspected: Special, announced inspection by the NRC staff of activities in the areas of electrical cables, raceways and supports; piping and pipe supports; new and spent fuel storage racks; and design change control. The inspection involved approximately 140 inspector hours _on site by five NRC inspectors. Inspections were performed to portions of procedures 37051B, 50095, 51053, 51063B and 51064 PDR ADOCK 05000529 G PDR

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Results: One. violation'relativehotheweldingofnewfuelstorageracksand one design. deviation relative to'.the procurement of the new fuel storage racks

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were identified, (see paragraph,4). One design deviation and three followup items were identified in the' areas of electrical raceway and raceway hanger installation.~ The deviation identified involved the off center connection of a tray hanger to building steel (see paragraph 3.d). The determination of whether the identified deviation is an isolated. case is considered a followup

. item (see paragraph 3.d). The other two followup items involved minimum torque for bolts on a tray hanger (see paragraph 3.d) and an inadequate inspection plan for bolt torque- verification (see paragraph 3.c.2).

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DETAILS 1. Persons Contacted Arizona Nuclear Power Project (ANPP)

• E. E. Van Brunt, Jr., Executive Vice President

• C. N. Russo, Quality Assurance Audits / Monitoring Manager

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'*J. R. Bynum, Plant Manager

• W. E.-Ide, Corporate Quality Assurance Manager

• S. Penick, Quality Assurance Monitoring Supervisor M. Provost, Quality Assurance Engineer J.'D. Bayless, Quality Assurance Engineer D. Hutton, Quality Assurance Engineer W. J. Gratza, Quality Assurance Document Review Group a%1. W.'Montefour, Quality Assurance Engineer

• W. F. Quinn, Licensing Manager

• J. Haynes, Station Manager

'*'CL.' Rogers, Nuclear Engineering Manager

• T. J: Bloom, Licensing Engineer

• R. Burgess, Field Engineering Supervisor Bechtel Power Corporation (Bechtel)

• Black, Chief Resident Engineer D. Freeland, Pipe and Pipe Support Resident Engineer

• W. Bingham, Project Engineering Manager K. Daley, Quality Control Inspector R. Ruff, Lead Electrical / Instrumentation Quality Control Engineer H. Foster, Project Quality Control Engineer N. Bretz, Civil / Structural Resident Engineering

• P. Huber, Quality Assurance Engineer

' *D. Hawkinson Project Quality Assurance Manager

• T. Horst, Project Field Engineer

• W. Miller, Construction Engineer

• S. Nickell,-Project Superintendent Combustion Engineering S. Mager, Mechanical Engineer NRC

. *R. Zimmerman, Senior Resident Inspector

• D. Kirsch, Acting Director, Division of Reactor Safety and Projects

• Denotes personnel attending the NRC Exit Management Meeting conducted on March 29, 198 _. . -

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2. Review of As-Builts: Unit 3

., Review of Procedures ,

A limite'd reviewJof the following documents was performed to iden-tify.theestabli[shedacceptancecriteriafortheselectedareasof ENRC' inspection niscussed in paragraphs 2b and c belo . Arizona Puolic Service'(APS) Palo Verde Nuclear Generating Station (PVNGS) Manual, Procedure No. 78AC-0ZZ13, "As-Built Records Management (ABRM) Document Control", Rev. 3, February 26, 198 *

. Bechtel Power Corporation (Bechtel) Engineering Department Procedure (EDP) 4.37, " Design Calculations", Rev. 7, October 6, 198 . EDP-4.47, " Drawing Change Notice", Rev. O, August 1, 198 . EDP-4.62, " Field Change Request (FCR)", Rev. 2, May 27, 197 . Bechtel Arizona Nuclear Power Project (ANPP) Internal Procedure (IP)4.2, " Design Calculations", Rev. 16, December 10, 198 . IP-4.12, " Drawing Change Notice", Rev. 13, April 6, 198 . IP-4.33, "As-Built Records", Rev. 7, April 24, 198 . IP-4.34, " Design Change Package", Rev. 14, August 22, 198 . IP-4.37, " Final Design Verification for Safety-Related Piping Systems", Rev. 4, December 10, 198 . IP-5.8, " Construction Interface", Rev. 11, August 15, 198 . IP-5.13, "Nonconformance Reports (NCR)", Rev. 9, October 25, 198 . IP-5.14, " Field Change Request, Subcontractor Change Request, and Client Correction Suggestions", Rev. 12, May 3, 198 . IP-5.17. "Startup Field Reports and Startup Work Authorizations", Rev. 9, September 21, 198 . Bechtel PVNGS Work Plan Procedure (WP/P) 3.8, " Field Generated Drawings / Field Change Notice", Rev. 11, March 21, 198 . WP/P-3.9, " Control of Pipe Support Drawings", Rev. 4, February 20, 198 . WP/P-20.0, " Field Change Request", Rev. 21, January 29, 198 . WP/P-QCI (Quality Control Instruction) 22.0 " Design Change Package", Rev. 14, October 17, 198 . Specification 13-PM-204, " Field Fabrication and Installation of Nuclear Piping Systems," Rev. 1 Design Changes The following design change documents were reviewed for adherence to applicable procedures, including statement of the problem (Existing Condition) and resolution (Change Request / Sketch): Field Change Requests (FCRs)

. 82.754-E

. 82.714-C

. 82.662-E

. 84.829-P n

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. 87.191-P 4

. 88.151-J

. 88.128-C

. 88.125-E

. 88.123-P

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. 88.118-P

. -88.076-C

~ Design Change Package (DCP) No. 3CJ-EC-30 The NRC inspector requested design change backup material (i.e. , written justification, calculations or revisions to calculations, checklists, etc.) for FCRs 87.191-P, 88.128-C and 88.076-C and DCP 3CJ-EC-302. No backup material was available because the. changes were considered by the engineer to require no specific documentation. The procedures and instructions reviewed appear to provide no guidance on when documented justification for design changes is required, except for changes affecting Pipe Stress and Supports (PS&S) calculations (see IP-4.2). Discussions between the NRC inspector and engineering personnel did not result in identification of any other explicit guidance or requirements. Therefore, the actual

eview practices applied to the FCRs and DCP identified above were discussed with engineering personnel. The NRC inspector concluded that these specific changes had received review commensurate with their significance and the applicable procedural requirements. The inspector has no further questions on these change No violations or deviations with NRC requirements were identifie Inspection of Piping Systems Portions of two piping systems were inspected for piping location, configuration and size, weld location and identification, support location, type and configuration and valve location, type and orientatio . High Pressure Safety Injection (HPSI) System, Train A, from the HPSI pump discharge nozzle to support No. 100-H-006. The following Piping and Instrumentation Drawing (P&ID), Piping Isometric and Pipe Support Drawings were used:

. 13-M-SIP-001

. 13-P-SIF-203

. 13-SI-100-H-003

. 13-SI-100-H-006

. 13-SI-100-H-008 Auxiliary Feedwater System, Train A, from the steam turbine driven pump nozzle to support 003-H-008. The following P&ID, Piping Isometric and Pipe Support Drawings were used:

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. 13-M-AFP-001

. 13-P-AFF-132

. 13-AF-003-H-001

. 13-AF-003-H-002

. 13-AF-003-H-003

. 13-AF-003-H-004 ,

. 13-AF-003-H-005

. 13-AF-003-H-006

. 13-AF-003-H-00A

. 13-AF-003-H-007

. 13-AF-003-H-008 No violations or deviations with NRC requirements were identifie . Electrical Cables-Observation of Work: Unit 3 Review of Procedures A limited review of the;following documents was performed to ident-ity the established acceptance criteria for the selected areas of NRC-inspection discussed in paragraphs (3b) through (e) belo ,

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. 'WP/P-QCI- 251.'0, " Raceway Installation," Rev. 20, November 6,

- 1984 and/ Rev.'21,' March 21, 198 . WP/P-QCI 251.1, " Raceway Separation," Rev. 3, October 21, 198 . 'WP/P-QCI 254.0, " Cable Installation," Rev. 23, December II, er 198 .. Specification'13-EM-300, " Installation Specification for

,' , Electrical / Cables in Cable' Tray," Rev. 7, July 3, 198 ,

. -Sp~ecification 13-EM-302, " Installation Specification for Cable Tray Hangers," Rev. 9, December 7, 198 .- Specification 13-EM-303, " Installation Specification for

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' Electrical Cable and Raceway Identification," Rev. 10, November 8, 198 .

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. Drawing 13-E-ZAC-077, " Cable and Raceway Physical Separation Guide," Rev.' . Bechtel Construction Incorporated /Bechtel Constructors Corpora-tion (BCI/BECC) QC-1, " Quality Control Personnel Certifica-tion," Rev. : . Various Raceway and Hanger Plan and Detail Drawing Power Cable Installation The following medium voltage power cables totaling about 740 feet were inspected for identification, size and type of cable, location, routing, separation, conductor spacing, and required termination point . 3EEW01BCICA 3/C 4/0 AWG SkV 380 feet

. 3ESI14CCIFA 1/C 2/0 AWG 600V 44 feet

. 3EPN01AC1KA 1/C 2/0 AWG 600V 315 Feet No violations or deviations with NRC requirements were identified.

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' ,; A review 'of the' status of fina11 inspections for raceways found

'th'at NCR No. EX5484:was; issued on January 14, 1985 to review, correct and reinsp'ct e t.wo thirds (6700) of the installed Class

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IE raceway. ~At;the, time.of this NRC inspection only 453 i raceway segments had been' inspected and accepted through NCR EX5484 by the g licensee's quality control organizatio Approximately 100 feet of the following raceway segments

.previously accepted by_ Quality Control under NCR No. EX5484 were selected and inspected for size, material type, location, separation, and, identification. The following raceway segments were examined:

. 3EZCAEARK28 3-inch diameter conduit 42 feet

. 3EZA1AATRBK 4x24 inch tray 15 feet

. 3EZAICATRBD 4x24 inch tray 15 feet

. 3EZJ4ACTXCF 4x12 inch tray 30 feet

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No violations or deviations with NRC requirements were identifie .-. A review of WP/P-QCI 251.0 Raceway Installation, revealed an inadequate inspection plan for verification of raceway and raceway ha'nger bolt torque. Table II (Exhibit 251.0-4) of the

.QCI is a multiple sampling plan requiring the torque-testing of an initial 10 percent of the total number of bolts on a hanger assembly or cable tray splice plate. The inspection plan requires an increase in sample size when the reject limit is reached or exceeded but does not provide for an ultimate: reject

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decision ~for the assembly being inspected. The plan permits the inspector only two options: accept the assembly, or torque more bolts. Use of the inspection plan was discussed with Bechtel QC personnel. They indicated that in practice an additional 10 percent sample of bolts would-be torqued whenever the reject limit'was reached or exceeded on the previous sample'. The' assembly would be accepted on-the:first additional 10 percent' sample which did not. reach the reject limit. The-accept decision would be independent of the total number of bolts from previous samples that had not initially achieved minimum torque. The inadequate inspection plan for WP/P-QCI 251.0 and other like inspection plans, should they: exist,~and their implementation is_ considered a followup item. (Followup Item No. 50-530/85-09/01).

' Cable Tray Hanger Installations

Three cable tray hangers from various locations in the plant were

~ inspected for material type and size, location, configuration and bolt torque. The hanger numbers and location drawings were:

. H43 drawing 13-E-ZJC-045 Rev. 9

. H107 drawing 13-E-ZJC-042 Rev. 9

. H12 drawing 13-E-ZAC-039 Rev~.9

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Although no discrepancies were noted in the three hangers sampled, two discrepancies were found with hanger H106 adjacent to hanger H10 Several bolts on hanger H106 were torque tested and two of the bolts moved less than 1/4 turn before achieving minimum torque. Bechtel Quality Control has issued NCR No. EJ-5893 to identify and correct this discrepancy. This is an item that will be examined in a future inspection, to examine the licensee's corrective action with respect to this nonconformance repor (Followup Item No. 50-530/85-09/02).

. It was also noted that one of the vertical support legs of hanger No. H106 was not located within'1 inch of the structural beam center line, as required by note 13 on drawing 13-E-ZAC-043, where the leg is attached to the beam. Although the hanger installation and Quality Control inspection (July 1982) preceded the drawing require-

. ment (October 1982) Design Change' Package (DCP) 3CC-ZJ-038 was issued _'in October 1982 to identify, evaluate and if necessary rework these'off center connection When the NRC inspector questioned the acceptance status of hanger H106 under the DCP, research by Bechtel QC and Resident Engineering indicated that, although within the scope-of DCP 3CC-ZJ-038, hanger No. H106 was apparently neither identified nor evaluate The status research was hampered by the fact that cable tray hangers are not individually identified during configuration inspection by Bechtel. As required by WP/P-QCI 250.1, hanger inspection is per-formed in conjunction with the cable tray inspection and is recorded on the Raceway Inspection Record, but the specific hangers inspected with the cable tray are not recorded. Since inspections of hangers are not individually identified, it should be determined whether the missed identification and evaluation of hanger No. H106 under DCP 3CC-ZJ-038 is an isolated cas The off center connection of hanger H106 to building steel is considered a deviation from design requirements. The licensee's determination of whether this is an isolated case and whether this condition is applicable to Units 1 and 2 is considered a followup ite (Deviation Nos. 50-530/85-09/03). (Followup Item No. 50-530/

85-09/04). In-Process Cable Installation Inspection Scope The inspector selected in process electrical cable installation activities in Unit No. 3 Containment to observe in process installation and inspection activities relative to a Class 1E cable pull and cable termination activities at electrical penetration No. 41. For the cable pull, the inspector examined each of the. cable runs to ascertain compliance with applicable design criteria relative to size, type, location, routing, bend radii, protection, separation, identification and support. For the terminations, the inspector examined both in process and J

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( completed terminations to' applicable design .and installation

' , documents, for such, items,as lug size _ and type, proper termina-

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3 ' tion',;prophr tensination point, configuration, correct'identi-

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, f -fication ~of cable and conductors, proper crimping of lugs or

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- connectorsLand 'the absence of z insulation or jacket damag Approximately 50 terminations were examine ~

Additionally,~ the inspector examined the qualification records for seven-electrical Quality Control Inspectors, and the training and indoctrination methods for electrical craft personne ^

. The followi'ng~ cables totaling approximately 500 feet were examined in the above mentioned cable pull:

Cable N Type System

, . EC3ECP01ACIRF 3 Conductor /No'14 Containment Purge

. EC3ECP03ACIRF .3 Conductor /No 14 Containment Purge-

. EC3ECP02AC1RA 9 Conductor /No 14 Containment Purge

. EC3ECP02AC1KA 3 Conductor /No 10 Containment Purge

. EC3ECP02AC1RH 2 Conductor /No 14 Containment Purge

. EC3ECP04ACIRH 7 Conductor /No 14 Containment Purge

. EC3ESI50ACIRD 7 Conductor /No 14 Safety Injection

. EC3ECP04ACIRA 9 Conductor /No 14 Safety Injection

. EC3ESI48AC2RB 4 Conductor /No 14 Safety Injection

. EC3ESIS0AC2RD 4 Conductor /No 14 Safety Injection

. EC3ESI48ACIRB 7 Conductor /No 14 Safety Injection

. EC3EHC05ACIRA 2 Conductor /No 14 Containment HVAC Inspection Finding Electrical Cable Installation Activities No problems were identified in the areas of electrical cable installation activities. .The activities were foun to comply with the applicable construction codes and-specification Qualification of Associated Materials The inspector's review determined' that the cable lubricant

.(Polywater A, C, and G) was approved by procedure (Work Plan Procedure / Quality Control Instruction (WPP/QCI) N .0) and by' the cable manufacturer as a compatible substance with their cable compound. The environmental'

qualification records for the cable ties and mounts, and the terminal boards, indicated that the materials had been qualified to a 40 year life in accordance with IEEE 323-1974-(cable ties and mounts) and IEEE 317-1976 (term-inal boards). l Qualifications of Quality Control Inspectors

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The qualification of seven electrical and instrumentation Bechtel Quality Control inspectors were reviewed. This sample represents,25% of the electrical and instrumenta-tion inspectors currently qualified on site. The records were: reviewed for education, work experience prior to certification, eye examinations, training received and other pertinent data. In all cases the qualification of

.the inspectors either met or exceeded the qualification requ'irements of ANSI N45.2.6-197 '

. Electrical Craft Training Discussion with licensee personnel indicated that the site holds weekly safety and quality meetings to review and implement corrective actions for potential, recurring, and isolated problems. The meetings are attended by the responsible construction supervisors, engineers, foremen, and craft. As a result of such meetings, responsibility is fixed, timely corrective action is implemented and work quality is improve Additionally, all foremen are required to read all elec-trical related' installation procedures and revisions. The craft are required to read a training manual which inclu-des summaries of the installation procedures to insure that they understand any new or difficult installation procedure No deviations or violation with NRC requirements were identifie . New and Spent Fuel Storage Racks: Units 2 and 3 Areas Examined The inspector examined procurement documentation and quality records ( related to the purchase of spent fuel and new fuel storage racks in Units Nos. 1, 2, and 3. The inspector also reviewed completed construction inspection records for new fuel racks installed in Units 1 and 2, and physically examined new fuel racks intended for installation in Unit 3, as well as hardware modifications made to new fuel racks in Unit Applicable Specifications and Procedures The following is a listing of specifications and procedures govern-ing _ the procurement and installation of spent fuel and new fuel racks which were reviewed during the course of this inspectio . Bechtel Specification No.13 CM 175, " Specification for Spent Fuel Storage Racks".

. Combustion Engineering Specification No. 14273-RCE-0816,

" Project Specification for Fuel Storage Racks for Arizona

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. Combustion Engineering Specification No. 00000-WQC-5.1, " Vendor .

. Quality Control Program Specification for PSG Quality Class 12A".

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. Bechtel Construction Inspection Plans (CIP) Nos. 350-130-1 and 2, " Installation of New Fuel Storage Racks".

. _ Design Change Packages Nos. ICNFX003, 2CMFX003, and 3CMFX003,

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. "Modification of New Fuel Racks".

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, . The inspector also reviewed the applicable vendor. drawings,

- field generated drawings, and related nonconformance report Findings The FSAR in Table 3.2-1, " Quality Classification of Structures, Systems,and Components", lists the quality assurance classification for new' fuel racks as being Quality Clacs Q and Seismic Category Additionally, page 3.2-37, note No. 4, of the FSAR states that Quality Assurance Class, (Q) requires compliance with 10 CFR 50, Appendix B. Under its contract with Bechtel Power Corporation, the-licensee's prime contractor, Combustion Engineering procured the 'new

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fuel racks from a subvendor, Joseph Oat Corporation. Review'of Combustion Engineering Specification No. 00000-WQC-5.1, " Vendor Quality Control Program Specification for PSG Quality Class 2A",

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. indicated that the program requirements placed on Joseph Oat Corp-oration via this document failed to incorporate the design require-ments specified by the licensee. The new fuel racks were procured and manufactured.under a program which did not comply with Appendix

- B requirements. Items designated by Combustion Engineering as Class 2A do not have a Quality Assurance Program applied which incorpor-ates all 18 criteria of Appendix Further, the inspector's examination of the Unit'No. 3 new fuel racks identified a number of

' discrepancies, which.arelbelieve.d to have resulted from a failure to r

3; identify.and procure sthe'new fubl racks as Quality Class item *

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. .The. failure fo7 assure, procurement documents comply with stated

, - design bases for Units 1,12land 3 is considered a deviation from the

' licensee's, approved design. (Deviation No. 50-530/ 85-09-05).

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' identified,a number physical examination of' discrepancies of the

.with Unitperformed welds 3 new fuel byracks the

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. ' vendor ~ including missing and incomplete welds, additional welds not

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lidentified 'on ' design" drawings, arc strikes, weld splatter and ; slag.

t- 1? Joseph Oat . Corporation drawing No. 6676 " Typical Module-New Fuel

'T ,/ Racks" states is-the geneFal' inspection notes that all welds shall

'be' visually examined per< quality control procedure QC-8012-60 Visual.

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Examinations'ofWelds.(~QualityControlProcedureNo.QC-8012-60 states in<Section 5.0, " Acceptance Standards" that, surface and adjacent base material shall be essential free of' weld splatter and

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slag and shall be free of are strikes," and that, "The minimum size of fillet welds shall be as indicated on the shop drawings."

All welding identified above was inspected and accepted by Quality Control inspectors of the Joseph Oat Corporation for module 1A3 on July 21, 1980 for modules IB1, 1B2, and IB3 on August 6, 1980 and for modules 1El, and IE2 on December 4, 198 The failure to assure that welding on new fuel racks comply with drawing requirements is considered a violation of 10 CFR 50, Appen-dix B, Criterion V, " Instruction Procedures and Drawings." (Non-compliance No. 50-530/85-09/06)

Coincident with this inspection, the licensee's contractor, Bechtel, identified similar problems on new fuel racks the inspector had not examined, and as a result initiated a Nonconformance Report (NCR)

No. WF132 Additionally, the inspector determined that the intermediate fuel racks were also procured through Joseph Oat Corporation. The inspector discussed this observation with the licensee. The lic-ensee indicated that the intermediate fuel racks would be considered in their resolution of concerns related to the new fuel rack . Followup Items Followup items are matters that require further review and evaluation by the NRC inspectors to ensure adequate followup. Four followup items were identified during this inspectio . Exit Interview The NRC inspectors met on March 29, 1985, with licensee management repre-sentatives denoted in paragraph 1. The scope of the inspection and inspection findings as noted in this report were discusse t

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