ML19211D235
| ML19211D235 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/19/1979 |
| From: | Maxwell G, Suermann J, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19211D227 | List: |
| References | |
| 50-440-79-10, 50-441-79-01, 50-441-79-1, NUDOCS 8001170140 | |
| Download: ML19211D235 (19) | |
See also: IR 05000440/1979010
Text
.
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report Nos. 50-440/79-10; 50-441/79-10
Docket Nos. 50-440; 50-41
License Nos. CPPR-148; CPPR-149
Licensee: The Cleveland Electric Illuminating
Company
P. O. Box 5000
Cleveland, OH 44101
Facility Name: Perry Nuclear Power Plant, Units 1 and 2
Inspection At:
Perry Site, Perry, OH
Inspection Conducted: October 16-18, 1979
[r[" A ->c W. 4 L
Inspectors: J.E]Konklin
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K. R. Naidu
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J. F. Suermann
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Accompanying Personnel: C. C. Williams (October 17-18, 1979)
.
C. E. Jones (October 17-18, 1979)
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Approved By: C. C.c Williams , / Chief
//-/ 9- 7f
Projects Section No. 2
Inspection Summary
Inspection on October 16-18, 1979 (Report No. 50-440/79-10 and 50-441/79-10)
Areas Inspected: Licensee actions relative to previously identified items
of noncompliance and unresolved items; licensee's compliance with ASME
1762 049
soo1170 /VO
,
Code certification requirements; licensee's maintenance program for NSSS
equipment;
status of tagging of electrical equipment; procedures, work
activities and quality records related to placement of safety-related
concrete, implementation of the requirement of T/I No.2512/4. This
inspection involved a total of 88 onsite inspector-hours by four NRC
inspectors.
Results: Of the five areas inspected, three items of noncompliance were
identified in three of the areas (infraction - inadequate procedures and
failure to follow procedures for qualification of inspection and testing
personnel, two examples,Section IV; infraction - inadequate identification
of nonconforming equipment,Section II; infraction - lack of prompt correc-
tive action to assure that ASME Code requirements are met,Section I.)
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'
DETAILS
Persons Contacted
Principal Licensee Employees
- M. Edelman, Manager, Nuclear QA Depar'. ment
- G. Groscup, Manager, Nuclear Engineering Department
- D. Fitzpatrick, Site Construction Manager
- W. Kacer, CQS General Supervising Engineer
- A. Kaplan, General Supervising Engineer, Construction
- B. Barkley, General Supervising Engineer, Design
- P . Ma rt it. , General Supervising Engineer, PQS
- D. Cooper, CQSS Supervisc
Other Personnel
- P. Gibson, CQS QC Supervisor (KEI)
- R. Vondrasek, CQS QE Supervisor (GAI)
- T. Arney, QA Program Manager (GAI)
R. Crofton, CQS Lead Piping Quality Engineer (GAI)
J. Connelly, CQS Lead Civil Quality Engineer (GAI)
J. Mehaffey, CQS Lead Mechanical Quality Engineer (GAI)
W. Wre, CQS Civil Quality Engineer (GAI)
S. Tulk, CQS Electrical Quality Engineer (GAI)
G. Parker, CQS Mechanical Quality Engineer (GAI)
M. Combs, CQS Engineering Aide (GAI)
K. Pech, Assistant Project Manager (GAI)
T. Hesmond, QC Manager (National Engineering)
T. Gage, QC Inspector (National Engineering)
R. Thornton, QC Supervisor (National Mobile)
D. Burnbaum, Project Engineer, Hoboken Office (UST)
P. Wang. Laboratory Chief (UST)
L. Medley, QC Inspector (UST)
The inspectors also contacted and interviewed other licensee and contractor
personnel.
- Denotes those attending the exit interview on October IS, 1979.
Licensee Action on Previous Inspection Findings
(Closed) Open Item (440/78-12-03; 441/78-11-03): Failure to distribute
procedure on Field Questions. The inspector reviewed CEI Memorandum
dated October 3, 1979 which was transmitted to the site contractors and
which contained twenty-one project procedures (including the procedure on
Field Questions). This item is considered closed.
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051
(Closed) Open Item (440/78-03-07; 441/78-02-07): Possible trend in relax-
ation of civil code requirements. The inspector reviewed the construction
Quality Assurance Nonconformance Trend Analysis transmitted by CEI Memorandum
dated March 22, 1978.
The licensee took corrective action between
March and July 1978 to correct deficiencies noted in the trend analysis.
Corrective action included, but was not limited to: specific evaluation
of the relaxed ceJe requirement; formation of an Ad Hoc Committee to
review the use of Field Variance Authcrizations and Nonconformances;
training classes; and revised policy guidance on the use of FVA's, NR's
and ECN's.
This item is considered closed.
(Closed) Unresolved Item (440/76-06-01; 441/76-06-01) The review of
Gilbert Associates Incorporated (GAI) Specifications SP-17 and SP-96,
Newport News Industrial Corporation (NNIC) Procedures 465-NC-v101, 946-N-W001
and 948-N-W001 and NNIC QA Manual by the NRC inspector was incomplete.
The procedures and specifications were reviewed. The test requirement
was verified for the 5/64" diameter E-70TG type electrode.
This type
electrode was used on the 1-2A/B weld and is identified with a unique
number, 77N1547. Records indicate that Lincoln Electric Company manufac-
tured and supplied this electrode; Certified Material Test Report (SMTR)
dated July 21, 1977 certified that the electrode complies with requirements
of paragraph NB-2400 of the ASME Code Section III (1974) with the summer
and winter addenda.
Charpy V-notch impact test results exceeded the 20
ft.-lbs. at -20 F requirement specified in paragraph 5:09.2.7.a.(3)(b)
of Specification SP-17.
(Closed) Unresolved Item (440/78-09-02; 441/78-08-02) Additional information
was provided on the following items:
1.
The PBI QA Manual was revised and revision 1 dated January 18, 1979
specified the use of a model DA-200 contour probe for MT examination.
The yoke method was not used.
2.
An eye examination was administered to the level III inspector; his
visual acuity was acceptable and is documented in a record dated
August 1978.
3.
A letter from Lincoln Electric Company dated July 3, 1979 to CEI
quotes Table 8 on pages 18-19 of the AWS 5.1-69 as not requiring any
mechanical tests on 3/32" and 1/8" electrode.
(Closed) Noncompliance (440/78-12-04) The internal cleanliness of the
Unit 1 Reactor Pressure Vessel was contrary to the requirements of GE
Procedure 22A2537. NICC generated Nonconformance Report (NCR) 38-6,
collected samples of the foreign material and subjected it to visual
spectrographic analyses. The analyses indicated that the material was
typical manufacturing debris.
CEI QA personnel determined that there
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1762 052
were no documents to indicate that the RPV was cleaned after the feed-
water nozzle modifications were made in the shop. The Unit 1 RPV was
scheduled to be scrubbed utilizing GE Procedure 22A2537, titled " Final
Cleaning Procedure", with approved solvents under GE supervision. However,
due to modifications on the recirculation inlet nozzles this operation
will be done after completion of work. To prevent recuaence, CEI personnel
performed first line inspections on Unit 2 up to its' shipment. The
licensee informed the insp etor that the cleanliness of Unit 2 RPV was
acceptable on arrival at site.
(Closed) Unresolved Item (440/78-12-05) The Unit 1 RPV alignment was
offset an average .048' in the x plane which exceeded the maximum permissible
value .025'.
The offset was attributed to adverse accumulation of tolerances
during machining of the vessel support flange.
GE safety / reliability
review dispositioned the Field Deviation Disposition Request #KL1-0012 to
"use as is".
The alignment on Unit 2 RPV was initially performed on
December 18, 1978 and subsequently verified on April 21, 1979; the check
indicates that the middle target shifted from .023NE in the first quadrant
to .013NW in the fourth quadrant measured at the target at the Shroud
Support Ring. CEI is continuing to follow up on this matter. The inspector
has no further questions at this time.
(Closed) Unresolved Item (440/78-12-05) Inadequate information on GE's
three Product Quality Certificates (PQC) #N975, N993 and HH768 dated
December 16, 1976, April 4, 1977 and June 9, 1978.
determined that the above PQCs were not final records and obtained the
following clarifications:
1.
PQC N975-MPL-B13-D003, P0 #205-H8953.
This PQC is for Unit 2 0-
rings only.
2.
PQC #N993-MPLB13-D003, GEP0 #205-AE208. This PQC is for RPV Unit 1.
3.
PQC #HH768-MPL #B13-D002; GE P0 #205-AH431. This PQC is to cover
the completed RPV Unit I with the intervals installed and its 0-ring
seals.
(Closed) Noncompliance (440/78-12-07) Failure to follow procedures relative
to " Hold Point" sign offs and approve procedures prior to use.
conducted an independent investigation and confirmed that the contractor
and construction quality control personnel failed to adhere to the program
requirements even though they observed the referenced hold points.
in a letter dated August 28, 1979 to all CQC and CQE personnel requested
adherence to programmatic requirements relative to " Hold" and " Witness"
points. Relative to approval of procedures, NNIC initiated Engineering
Change Notice (ECN) 1190-38-31 to revise the review and approval require-
ments for Manufacturing Installation Instructions (MII). NN1C requires
MII's to be submitted to the site organization for review, recording and
approval at least four weeks prior to commencement of work unless otherwise
noted. An item of noncompliance (441/79-07-02) was identified related to
the signoffs on MIIs.
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5-
(Closed) Noncompliance (440/78-12-08) Visual inspection of eight welds
were unacceptable; inspection records documented these welds as acceptable.
NCR 96-191 was generated by NNIC to identify the eight nonconforming
welds. An Action Request (AR) was written by Quality Engineering requesting
NNIC to identify quality program concerns raised in NCR 96-191. A three-fold
corrective action was recommended: (a) evaluate the adequacy of the
visual inspection in NNICO Instruction 948-N-N002, (b) reinspect similar
welds (c) retrain NNICO inspectors in visual inspection and examine their
proficiency by reviewing their inspections.
CEI rejected NNIC's initial
reply on the basis that the reinspection was restricted to the Bioshield
walls and requested NNIC to broaden the range of inspection.
NNIC
Document #701-2708 dated May 1, 1979, indicates that reinspection of
welds in Units 1 and 2 bioshield was performed and several unacceptable
welds were identified and repaired. NNTC conducted a two hour training
session on September 20, 1978 on visual inspection of welds and discussed
NRC findings. Additionally, National Inspection And Consultants (NIC)
conducted a training session for NNIC inspection personnel on visual
inspection requirements and awarded a certificate dated January 19, 1979.
The NNIC statistical interpretation of the unacceptable welds identified
during the reinspection concluded that the visual inspections were acceptable.
The findings are documented in NCRs 17-88, 17-89 and 96-269.
To date NCR
96-269 is c1csed and the repair, reinspection and acceptance of welds
completed are documented in NCR 96-269. CEI QA through their audit and
inspection program subsequently identified several additional problems
related to inadequate inspections which resulted in CEI issuing a Stop
Work Order No. 79-06 dated September 6, 1979.
(Closed) Noncompliance (440/78-15-02; 441/78-14-02) Failure to assure
that ourchased materials (embedments and structural steel) conformed to
the specification requirements.
1.
Nelson Stud attachments to the stainless steel Spent Fuel Liner
Plates were reinspected and the unacceptable welds were repaired
reinspected and accepted. Weld history record for Welds 53-32-1,
-2,
-3, dated April 13, 1979 reflects the work performed.
2.
The stitch welds on Unit 2 wier wall were reinspected. NNIC document
701-2624 dated February 27, 1979 indicates that a sample size of 216
welds were reinspected out of which nine welds did not meet the
requirements; the welds were accepted based on paragraph 8.15.1.6 of
AWS D1.1276 code which permits an underrun of the nominal fillet
size by 1/16" without correction provided that the undersize dces
not exceed 10% of the length of the weld.
(Closed) Noncompliance (440/78-15-03; 441/78-14-03) Inadequate control of
welding process.
1.
Training sessions were conducted on May 1 and 2, 1979 by NNIC to
emphasize the preheat requirements and is so documented; a list of
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054
attendees who were present is attached to the record. Discussions
with the NNIC QA manager indicate that several training sessions
were conducted subsequently.
2.
NNIC developed a procedure, 701-F-W003, which was approved by CEI on
April 20, 1979, titled " Monitoring Welding Parameters other than
NDE".
This procedure adequately addresse.s the parameters to be
monitored during welding to verify that welding procedures are being
followed. The inspector reviewed surveillanca reports and determined
that the welding parameters were being adequately monitored to
determine compliance with the respective welding procedures.
(Closed) Noncompliance (440/78-15-04; 441/78-14-04) Deficiency in pressure
test documentation. NNIC document No. 701-2683 dated April 10, 1979
indicates that all the pressure test records from November 23, 1977
through May 11, M78 were reviewed with the inspectors who performed the
tests.
It was determined that the inspectors were qualified to SNT-TC-1A
Level II and that only the documentation was discrepant in some areas.
The Level II inspectors were given proper instructions. The leak test
procedure, H65-N-T005, was revised on March 14, 1979 and the revised
format of the Leak Test Report appears to eliminate discrepant entries.
(Closed) Unresolved Item (440/79-09-01; 441/79-09-01) - All MCCs which
have been installed for Units 1 and 2 have not been identified as " conditionally
released". This item is closed as an unresolved item and is being upgraded
to an item of noncompliance in this inspection report; details Section
II.
This condition was upgraded to an item of noncompliance, because it
appears to be a condition requiring more attention than has been paid to
it by CEI since June 27, 1979.
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055
.
Section 1
Prepared by:
J. E. Konklin
Reviewed by: C. C. Williams, Chief
Projects Section No. 2
1.
Review of Licensee Actions on Previous Inspection findings
The RIII inspectors reviewed *.he licensee's actions relative to the
resolution of specific inspection findings which were identified in
previras RIII inspection reports and which were still in an open
tratus prior to this inspection.
The items reviewed, and the licensee
actions relative to the resolution of the items are discussed in the
foregoing section of this report.
2.
Review of Licensee's Compliance with ASMI Code Requirements
The RIII inspector reviewed the licensee's implementation of the
ASME Code certification system requirements on the Perry Project.
The review indicated that safety-related components and systems at
Perry are being designed, fabricated and installed under various
editions and addenda of the ASME Code and that specific questions
exist as to whether appropriate and timely actions have been taken
by the licensee to assure full compliance with all ASME Code require-
ments.
Work on safety-related components er systems which require ASME Code
certification has been performed by three major Perry site contractors,
Newport News Industrial Corporation (NNIC), Pullman Power Products
(Pullman) and Johnson Controls, although the licensee has recently
removed the work oa the NSSS systems from NNIC and has contracted
with General Electric for this work.
Five basic contract specifications, SP-38, SP-39, SP-44, SP-47 and
SP-90, are involved in the ASME Code work at Perry.
The applicable
installation code for the work which has been done by NNIC under
Specifications SP-38 and SP-39, and which has recently been awarded
to General Electric, is the 1977 Edition, Winter 1977 Addenda. For
the work being done by Pullman under Specifications SP-44 and SP-47,
the applicable installation code is the 1974 Edition, Winter 1975
Addenda and for the work being done by Johnson Controls under Specifi-
cation SP-90, the applicable installation code is the 1977 Edition,
Winter 1977 Addenda.
With regard to certification of the site contractors, the inspector
verified that NNIC, Pullman and Johnson Controls possess current
"NA" and "NPT" authcrizations and that the General Electric I & SE
Group, which will assume the work under Specifications SP-38 and
SP-39, will be required to have the appropriate code authorizations
prior to start of work.
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056
-8-
.
The rules of the Summer 1976 and earlier editions and addenda require
that installations shall be affixed with an "NA" Code stamp, but do
not require the affixing of an "N" stamp. The rules of the Winter
1976 and later editions and addenda require that an "N"
Certificate
holder having overall responsibility for the system shall affix an
"N" Code stamp to the completed system.
"Overall responsibility"
includes materials, design, fabrication, examination, testing,
inspection and certification for manufacture and installation of the
entire system.
During discussions with the licensee and review of licensee documents
relating to code certification, the inspector determined that the
licensee has been aware of the need for further actions with regard
to the code certification requirements and has taken the initial
steps to obtain an Owner's Certificate of Authorization for the
Perry Project. However, the inspector also noted that Code interpre-
tation III-1-78-186, issued on June 1, 1978, states that the Owner's
Certificate of Authorization does not authorize the owner to act as
the "N" Certificate holder. The document reviewed by the inspector
included the following:
a.
The Inspection Service Contract, dated September 19, 1977,
between CEI and Hartford Insurance Company, for inspection
services (as the Authorized Inspection Agency) and a Quality
Assurance Program audit.
b.
A letter from CEI to the ASME, dated November 30, 1978, documenting
CEI's agreement to file the required N-3 Data Report Form with
the Jurisdictional Authority (the State of Ohio).
c.
A letter from ASME to the State of Ohio, dated January 8, 1979,
notifying the Jurisdictional Authority that an application has
been received from CEI for an Owner's Certificate of Authorization.
d.
Report of an evaluation performed by Gilbert Associates for the
licensee, dated February 13, 1979, and titled, " Requirements
for 'N'
stamping ASME Section III Piping for the Perry Nuclear
Power Plant."
The discussions with the licensee and review of the above documents,
elicited the following significant concerns regarding the licensee's
compliance with ASME Code certification requirements:
a.
The installation codes currently in effect for Specifications
SP-38, SP-39 and SP-90 require final overall responsibility
signoff by an "N" certificate holder.
At present, there is no
"N" Certificate holder on the Perry Project. Although no
significant instrumentation installation work has been done by
Johnson Controls under Specification SP-90, the work covered by
Specifications SP-38 and SP-39 is approximately 20% complete.
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Technically, the "N" stamp authorization is not required until
final system acceptance; however, the documentation and trace-
ability requirements to assure full code compliance make an
early "N" authorization essential.
b.
Substantial amounts of hardware under Specifications SP-38,
SP-39, SP-44, SP-47 and SP-90 will be installed to code editions
which are earlier than the code editions and addenda in effect
for the design and fabrication of the components. There are
special cases where this may be acceptable under the code, such
as when a total system is designed and procured under one order
at one time to one editiot of the code; however, most of the
design and procurement under the above specifications was not
done on a systems basis.
c.
Although the licensee has been aware since late 1977 of the
potential need for an "N" Certificate authorization for the
Perry Project, CEI has taken no significant actions since the
February 1979 study noted above either to obtain the
"N" Cartificate
authorization or to obtain an exemption with regard to the need
for such a certificate. During this inspection the licensee
stated that a decision has not yet been reached as to whether
CEI will apply for the "N" Certificate authorization, whether
another onsite organization will be requested to obtain the
authorization, or whether a request for exemption from the "N"
certification requirements will be made.
The inspector informed the licensee during the onsite exit meeting
on October 18, 1979, that the failure of CEI to take timely action
to obtain, or to have another onsite organization obtain, an "N"
Certificate authorization for the Perry ASME Code work, or to take
steps to seek relief from the requirement, was a potential item of
noncompliance with Criterion XVI of 10 CFR 50, Appendix B.
Following
evaluation at the Region III office, the inspector notified the
licensee by telephone, on October 31, 1979, that this lack of timely
corrective action will be cited as an item of noncompliance with
Criterion XVI (50-440/79-10-01; 50-441/79-10-01).
During the above mentioned telephone conversation, the licensee
stated that CEI is preparing a letter to NRC which will:
State that the installation work by GE on Specifications SP-38
a.
and SP-39 will be done under an earlier edition of the ASME
Code than that presently specified for the work; an edition
which does not require final acceptance by an "N" Certificate
holder, and
b.
Request an exemption from the "N" Certificate requirements for
the portions of the work under Specification SP-90 which now
require such an authorization.
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058
.
3.
Corrective Action on Unit 1 Zero Degree Pipe Whip Restraint,
Reported Per 10 CFR 50.55(e)
The inspector reviewed the corrective actions taken by the licensee
with regard to welding deficiencies found in the Unit 1 zero degree
pipe whip restraint structure. The deficiencies were initially
reported to Region III as a potential 10 CFR 50.55(e) item on June 27,
1979. The final report on the subject was transmitted by the licensee
to Region III on July 23, 1979.
The reported deficiencies were discovered during receipt inspection
and sampling UT of the structure at the Perry Site. The restraint
was fabricated by Ranor Incorporated of Westminster, Massachusetts.
Based on the results of the sampling UT on site, the structure was
shipped to Greenville Metals Manufacturing in Greenville, Tennessee,
a Newport News Facility, for re-UT and repair. At the Greenville
facility, approximately 99% of the welds were re-UT'd, and all
identified defects were repaired. The structure underwent final
inspection at the Greenville facility on July 17, 1979 and was
accepted. The restraint was received onsite on July 19, 1979 and
passed receipt inspection.
To prevent the same type of problem on the Unit II pipe whip restraint,
that structure was removed from Ranor, Incorporated and taken to the
Greenville facility. The licensee stated that all welding done on
the Unit II restraint will be 100% visually inspected and all welds
requiring UT will be re-UT'd at Greenville.
Based on the above, the inspector concluded that appropriate corrective
actions have been taken by the licensee relative to the zero degree
pipe whip restraints. The above 10 CFR 50.55(e) reportable deficiency
is considered to be resolved.
4.
Interviews With Site Construction Craftsmen
During this inspection, implementation of temporary instruction
number 2512/4 (Interviews With Craftsmen at Construction Sites) was
initiated by the two accompanying Region III personnel. The purpose
of this effort is to solicit any substantive concerns and opinions
with respect to construction quality and/or deficiencies in safety
related work. Five (5) craftsmen were interviewed under controlled
circumstances. These craftsmen were involved in containment suppression
pool, piping, and cable tray hanger fabrication activities.
In
general, the craftsmen were collectively impressed with the quality
efforts involved in their site fabrication activities.
Subsequent
NRC inspections shall include increased emphasis on the identified
area of construction activity. Approximately 25 more craftsmen will
be interviewed during subsequent NRC inspections.
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059
.
Section II
Prepared by: G. F. Maxwell
Reviewed by: D. W. Hayes, Chief
Engineering Support Section No. I
1.
Interim Maintenance of NSSS Equipment - Units 1 and 2
The inspector observed that, since the cancellation of the
a.
Newport News contract relative to installation and inspection
of NSSS equipment identified in Contract Specifications SP-38
and SP-39, the following events have occurred:
(1) CEI Engineering department has been assigned interim
responsibilitity for the storage and maintenance of the
NSSS equipment located at PNPP Units 1 and 2.
(2) Newport News has been directed, since the issuance of the
"Stop Work" order by CEI (dated September 6, 1979), to
accumulate all applicable quality related documentation
and turn it over to CEI.
(3) CEI Engineering Department has assigned three staff members
the responsibilities of assuring that, during the interim
period prior to re-assigning to a contractor the responsi-
bilities of NSSS equipment, site NSSS equipment is properly
handled and stored.
(4) To assist in carrying out the physical inspections, which
are required during routine maintenance inspections, CEI
has assigned a QC inspector to overview the activities of
the interim maintenance group.
(5) Open noncomformance reports which were generated by Newport
News prior to their receipt of the "Stop Work" order dated
September 6, 1979, are being converted by CEI into "new"
nonconformance reports. The "new" reports will re-direct
those responsible for corrective action (s) to be taken
relative to resolving the unsatisfactory conditions identified
in the open nonconformance reports.
b.
The inspector observed that the assigned CEI Engineering department
personnel and CEI QC inspector (s) have been utilizing draft
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t76.
060
.
copies of the CEI procedures which were written for use during
the interim maintenance period. However, the inspector noted
that the procedures were finalized and approved on October 16, 1979
to become effective on October 23, 1979.
The final versions of
the procedures were compared with the draft copies of the
procedures currently being used; no significant differences
were observed.
The inspector has no further questions about
these two procedures (numbered 2-1301 and 3-1302), at this
time.
The inspector interviewed the CEI Engineering personnel who
c.
have been assigned responsibilities for the interim maintenance.
These personnel were found to be cognizant of their responsi-
bilities and duties, as they relate to the maintenance program
and the implementation of the CEI procedure titled, " Field
Storage Maintenance of Equipment" (3-130-2).
As a result of
the interviews;
the inspector observed that the individual
responsible for the " visual" inspection of NSSS equipment
storage did not have certifications showing that he was certi-
fied to the inspection levels as prescribed in ASNI N45.2.6
Section 2.2. Prior to the completion of the inspection, the
RIII inspector was given a copy of the aforementioned individuals
certification, indicating that the individual was qualified as
a " Mechanical (limited) Level II" inspector. The inspector has
no further questions about this matter, at this time.
d.
The inspector selected two pieces of NSSS Associated equipment
to determine if their storage conditions were satisfactory.
Both were found to be protected and covered, with space heaters
energized (RCIC pump motor IE-51-C001 and Fuel Pool Circulation
pump motors 0641-C003 A and B).
The inspector observed that
the assigned CEI QC inspector has not, in either case, conducted
the independent physical inspections as required by CEI. QA
personnel had already identified this unsatisfactory condition
in a nonconformance report numbered CQC NR #1415. Further, the
inspector was informed that this condition is limited to approxi-
mately twelve pieces of safety-related mechanical equipment and
that the inspection points, which were missed, will be inspected
during the upcoming scheduled monthly inspections. The inspector
has no further questions about this matter at this time.
2.
Inspection Status of Safety-Related Materials - Units 1 and 2
a.
The inspector observed that on June 27, 1979 a nonconformance
report was generated by CEI to identify that almost all of the
electrical equipment and motor operated valves, which were
still under control of the receiving warehouse, had " inadequate
documentation". The inadequate documentation was related to
-' -
i762 06)
the environmental testing of Class IE equipment, as required by
purchase specifications to assure compliance with IEEEE 323
and/or IEEE344. The inspector was informed by the CEI representative
responsible for the receipt inspection and control of CEI/ Gilbert
purchased materials that:
(1) Ninety-nine percent of the affected Class 1E equipment and
motor operated valves, which are still being controlled by
CEI warehouse personnel - not released to site contractor
personnel for installation, have been clearly identified
as nonconforming.
(2) The CEI representative does not know the identification
status of the affected motor operated valves and Class 1E
equipment which had been released to site contractor
personnel prior to June 27, 1979.
b.
On October 17 and 18, 1979, the inspector, accompanied by CEI
QA personnel, toured the Pullman Power Products (PPP) piping
installation work areas in the Auxiliary and Intermediate
buildings. The inspector selected five safety-related motor-operated
valves which had been released to PPP prior to June 27, 1979.
One of the valves was in the process of being installed, one
was not being installed and had not yet been installed and the
other three had been installed. None of the valves had any
identification showing that they were nonconforming or had been
" conditionally released.
The inspector and the accompanying
CEI QA representative requested that the selected valve numbers
be cross-checked by Gilbert Site Engineering to determine if
these valves were also nonconforming due to " inadequate documentation".
The provided " Perry Valve Bill of Material Status Report"
indicated that each of the selected valves were listed as being
among those motor-operated valves not having adequate documentation
to assure compliance with the afore IEEE Standard (s). The
inspector informed the licensee that this failure to clearly
identify and track nonconforming materials is contrary to 10 CFR 50, Appendix B, Criterion XIV; PNPP PSAR, Chapter 17,
Section 17.1.14.1; CEI Corporate Nuclear Quality Assurance
Program, Section 1400, paragraph 1.1, and CEI PNPP Construction
Quality Section Procedure 1502 (dated May 1, 1978), paragraphs
5.2.2 and 5.2.3 (440/79-10-02; 441/79-10-02).
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Section III
Prepared by: K. R. Naidu
Reviewed by: D. W. Hayes, Chief
Engineering Support Section 1
Observation of Work Activities - Welding of Unit 1 Reactor Building Columns
The inspector observed welding activities associated with the installation
of the columns in the Unit 1 Reactor Building and determined the following:
A.
All the 17 columns have been installed in place. Pittsburgh
Bridge and Iron (PBI) subcontracted the installation work to
Kelley Steel Company (KSC) who perform work under the PBI QA
Manual. Procedure Exhibit AQ titled, " Procedure for Installation
of 17 Botton Tier Columns", was used to install the columns.
Prior to welding the botton stub (which is embedded in concrete)
to the column, an ultrasonic test was performed on the base
metals utilizing NDE Procedure #U.T.NIC-059, Revision 4.
A.
Welding on two columns identified as 4 and 6 was in progress.
C.
Weld Procedure Specification prequalified to the AWS D1.1-72
code for joint BU5a was being utilized.
D.
E7018 type electrode was being used.
E.
Records indicate that weldors performing the weld were qualified.
F.
The root pass and subsequent layers of the weld were subjected
to Magnetic Particle (MT) examination by the prod method utilizing
MT-NIC-052 Revision 2, dated May 9, 1979. Records indicate
that the Level II NDE inspector was qualified to perform MT.
G.
On column 10, an MT after the root pass revealed an indication.
PBI-105, dated September 13, 1979, was generated to identify
this unacceptable condition.
The indication was explored to a
depth of 5/16".
The inspector reviewed NCR PB1-118, dated October 3, 1979 which was
generated to identify a 2" x 8" area of porosity in the welds
attaching the bent plate to the upper flange located on the east
side of beam 305B4. The beam is located at elevation 679'-6" in the
control room complex. This unacceptable indication was apparently
overlooked during fabrication. Corrective action recommended was as
follows:
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~1762OS3
A.
Grind out areas of excessive porosity to sound base metal.
B.
Repair weld ground areas in accordance with Weld Repair Procedure
15.6 (PBI QA Manual).
C.
Grind repaired areas to base metal.
D.
Visually inspect repaired areas.
CEI approved the corrective action and included MT examination of
each layer of weld.
The inspector has no further questions on this matter.
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064
Section IV
Prepared by: J. F. Suermann
Reviewed by: D. W. Hayes, Chief
Engineering Support Section 1
1.
Containment Structural Concrete - Procedures
As part of observing a containment pour, the inspector reviewed the
training and qualification procedures of U. S. Testing Company prior
to reviewing the records of four QC inspectors who performed inspections
on the pour. The inspector had no comments on U. S. Testing Company
Procedure QCP-6, " Training of Inspection and Test Personnel", Revision
1, dated May 3, 1978. Review of Procedure UST-TQ-1, Revision 9,
" Training and Qualification of Inspection, Test and Audit Personnel",
dated March 23, 1979 revealed that the procedure specified experience
factors for use as a basis of qualification that were less stringent
than the minimum capabilities stated in ANSI N45.2.6-1973.
Although
the requirements of Paragraph 3.1.2 of Procedure UST-TQ-1 are recognized
in that other relevant factors may be considered in qualifying
inspection and test personnel, the paragraph is not sufficient
authority for exercising less stringent criteria than that contained
in Regulatory Guide 1.58 and ANSI N45.2.6, to which the licensee is
committed. Discussions with U.S. Testing Company personnel and a
records review (see paragraph 3 below) indicated that Paragraph
3.1.2 was apparently being used as a " loophole" to hire personnel
with little or no prior experience, relying on site conducted indoc-
trination as a basis for certification. The liberal interpretation
on the part of the procedure requiring certain prior experience
levels does not meet the intent of ANSI N45.2.6 and as such is in
noncompliance with 10 CFR 50, Appendix B, Criterion V (50-440/79-10-03;
50-441/79-10-03).
2.
Containment Structural Concrete - Observation of Work
The inspector was notified that a pour was in progress in Containment
1. National Engineering and Contracting Company, a site concrete
contractor, was placing pour No. RB1-WO3-645; the pour was a drywell
wall of approximately 600 CY of 5000 psi concrete placed from elevation
630'-9" to elevation 646'
At the time the inspector arrived, the
grout construction joint layer had already been placed and approxi-
mately two feet of concrete had been placed. The Pre placement
Checkout Record was reviewed and it appeared the required checkoffs
were made and the final QC clearance was obtained prior to the pour.
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'
The Concrete Pour Card and Placing Record were in order and indicated
that the six man vibration crew was briefed on proper technique
prior to the pour. The Inspection Report for Concrete Placement,
dated October 16, 1979, indicated that the required hold points for
concrete pre placement, reinforcing steel placement and concrete
placement were met.
It further indicated that the six vibrators
used on the pour were checked for calibration as required. All six
vibrators met or exceeded the minimum 8000 cpm calibration requirements.
The inspector observed the placing and vibrating crews in progress.
Placement operations appeared under control; concrete was confined
to a maximum free fall distance of five feet; concrete was not moved
excessively in a lateral direction; the placing sequence appeared to
prevent the formation of cold joints; vibrator crews appeared to be
achieving the proper consolidation and were following procedures
regarding mode and time of vibrator insertion.
QC personnel carefully
followed both the placing and vibrating operations.
U. S. Testing
Company QC inspectors performed the required slump, temperature, air
entrainment and unit weight tests per procedures.
Concrete compression cylinders were made according to ASTM requirements
and the sampling frequency was followed according to procedures.
Field curing boxes were used to retain the cylinders for a maximum
of twenty-four hours. The inspector noted that one of the three
curing boxes indicated the temperature range exceeded the maximum
permissible 60-80 F limits during the initial curing cycle. The
licensee correctly identified this as a nonconforming situation and
took prompt corrective action to remedy the problem and also prevent
its recurrence. The inspector noted water was added at the truck
discharge point prior to emptying the drum contents. Procedures
permitted this practice and the amount of water added was controlled.
Water sight gauges on the trucks were operative and checked by the
QC inspector. QC inspectors were aware of the requirement to mix
added water with 30 revolutions of the drum.
No items of noncompliance were identified in this area.
3.
Containment Structural Concrete - Quality Records
a.
Concrete data and related equipment -
The IE inspector reviewed the calibration records for the
testing apparatus used on pour RBI-WO3-645, and found the
following equipment had current calibration stickers:
air
meter #14, slump cones #7 and 14, unit weight bucket #8, field
scale #24, and thermometer #124. Calibration records for
trucks 66, and 83 and 84 indicated all water sight gauges were
operating within tolerance and the trucks unitormity test
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.
1762
066
.
results met ASTM C-94-73A requirements.
NRMCA certifications
for the main and back-up batch plants were current.
The main
batch plant automatic console gauges, admixture meters, and
scales were currently calibrated. The concrete and placement
Identification Sheet for the pour indicated that the specifi-
cation requirements were met with regard to slump, air entrainment,
temperature and unit weight.
Compression test specimen cylinders
were made as required by the specification.
b.
Personnel qualification records -
The records of the four U.S. Testing Company personnel assigned
to pour RBI-WO3-645 were checked against the requirements of
procedure UST-TQ1 and against ANSI N45.2.6.
Three of the four
record files inspected revealed the following:
(1) The documented experience and education factors did not
meet the procedural and/or ANSI requirements committed to
with regard to type or duration.
(2) Site conducted proficiency testing appeared to be the main
basis for certifying individuals and was the only relevant
factor in the personnel backgrounds.
(3) Supportive requirements such as eye / physical exams, pertinent
training and indoctrination were being administered after
the date of qualification of the individual.
(4) The Document of Qualification did not specify the period
of qualification. These practices are contrary to Regulatory
Guide 1.58 and ANSI N45.2.6 and as such are in noncompliance
with 10 CFR 50 (Appendix B), Criterion V.
This is a
second example of the previously cited item of noncompliance
(50-440/79-10-03; 50-441/79-10-03).
Exit Interview
The inspectors met with site representatives (denoted under Persons
Contacted) at the conclusion of the inspection on October 18, 1979. The
inspectors summarized the scope and findings of the inspection.
The
licensee acknowledged the findings reported herein.
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067