ML19319B574

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IE Insp Rept 50-346/75-01 on 750122-24.Noncompliance Noted: Unapproved Installation/Fabrication Planner
ML19319B574
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 02/19/1975
From: Jablonski F, Naidu K, Sutton J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19319B568 List:
References
50-346-75-01, 50-346-75-1, NUDOCS 8001270100
Download: ML19319B574 (20)


See also: IR 05000346/1975001

Text

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U. S. NUCLEAR REGULATORY COM'11SSION

DIRECT 0PaTE OF REGULATORY OPERATIONS

REGION III

Report of Construction Inspection

IE Inspection Report No. 050-346/75-01

Licensee:

Toledo Edison Company

Edison Plaza

300 Madison Avenue

Toledo, Ohio

43652

Davis-Besse, Unit 1

License No. CPPR-80

Oak Harbor, Ohio

Category:

B

Type of Licensee:

PWR (B&W) - 872 MWe

Type of Inspection:

Routine, Unannounced

Dates of Inspection:

January 22-24, 1975

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Dates of Previous Inspection:

November 20-22 1974 (Construction)

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Principal Inspector:

J. W.

Sutton

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Accompanying Inspect. ors:

F. J. Jablonski

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K. R. Naidu

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Other Accompanying Personnel:

None

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Reviewed By:

Senior Reactor Inspector

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Construction and Engineering

Support Branch

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SUMMARY OF FINDINGS

Enforcement Action

A.

Infractions

1.

10 CFR Part 50, Appendix B, Criterion VI, states, in part,

that: " Measures shall be established to control the issuance

of documents, such as instructions, procedures .

which

. . .

prescribe all activities affecting quality.

These measures

shall assure that documents, including changes, are reviewed

for adequacy and approved for release by authorized personnel

".

. . . .

The Johnson Service Company Quality Assurance Manual, Section

4.1.2.3, states, in part, that: "The quality assurance repre-

sentative approves, signs, and dates the installation / fabrication

planner .

".

. . . .

Contrary to the above, an installation / fabrication planner

relative to service water pump Instrumentation had not been

properly approved.

(Report Details, Part II, Paragraph 2.a. (1))

2.

10 CFR Part 50, Appendix B, Criterion V, states, in part, that:

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" Activities affecting quality shall be prescribed by documented

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instructions, procedures, or drawings

and shall be

. . . .

accomplished in accordance with these instructions, procedures,

or drawings .

".

. . . .

Contrary to the above, mounting structures for safety

a.

related instrumentation were being fabricated and installed

without benefit of approved inspection procedures and

instructions.

(Report Details, Part II, Paragraphs 2.b.(1)

and 2.b. (4))

b.

Also, contrary to the above, procedures, instructions,

and/or checklists were inadequate for the inspection of

safety related piping and components stored ourdoors.

(Report Details, Part III, Paragraph 1)

c.

Bechtel Corporation Specification No. 7749 M-328, Section

5.6, states, in part, that:

the total weight

"

. . . . . .

of zine coating must be reported to the nuclear engineer

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. . . . .

Contrary to the above and Criterion V, procedures were not

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in effect to meet this reporting requirement.

(Report

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Details, Part II, Paragraph 2.b.(2))

d.

Bechtel Corporation Field Inspection Manual, Procedure No.

G-3, part 4.0.b, provides measures for the processing of a

nonconformance item.

Contrary to the above and Criterion V, approved procedures

were not followed relative to documentation and identification

of equipment known to be incorrectly installed. (Report

Details, Part III, Paragraph 3.e)

3.

10 CFR Part 50, Appendix B, Criterion VII, states, in part,

that: " Measures shall be established to assure that

. . . . . .

Documentary evidence that material and equipment conform to the

procurement requirements shall be available at the nuclear power

plant

. prior to installation or use of such material and

. . . .

equipment

. ".

. . . . .

Contrary to the above, mounting structures for safety related

instrumentation were being installed prior to the receipt of

material certifications.

(Report Details, Part II, Paragraph

2.b. (3))

4.

10 CFR Part 50, Appendix B, Criterion XIV, states, in part, that:

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" Measures shall be established to indicate by the use of markings,

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such as stamps

. the status of inspections

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. . . .

Ccatrary to the above, certain installation inspection documenta

relative to safety related instruments were stamped, indicating

that the installation was correct and complete when, in fact,

the installation had not been completed.

(Report Details, Part II,

Paragraph 2.a.(2))

5.

10 CFR Part 50, Appendix B, Criterion XII, states, in part, that:

" Measures shall be established to assure that tools

. . . . . .

used in activities affecting quality are properly controlled

.".

. .

Contrary to the above and the Johnson Service Company quality

assurance program, a craftsman was in possession of a quality re-

lated tool which was not assigned to him.

(Report Details, Part II

Paragraph 1.b)

6.

10 CFR Part 50, Appendix B, Criterion XIII, states, in part, that:

" Measures shall be estaolished to control the handling, storage

. and preservation of material and equipment

to

. . . . .

. . . . .

prevent damage or deterioration .

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The Johnson Service Company quality Assurance Manual, Section 5,

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page 11 (B) states, in part, that: "Q-listed .

equipment

. . .

is stored on shelves or bins .

. in the restricted access

. . .

storage area .

to facilitate retrieval and inspection.

. . . .

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Material tag .

. and any other identification tagging

. . .

shall remain affixed to equipment

. ".

. . .

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Contrary to the above, mounting structures for safety related

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instrumentation vere not properly stored or identified.

(Report

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Details , Part II, Paragraphs 1.c. (1) , 1.c. (5) , and 1.c. (6))

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7.

The Bechtel Corporation's Nuclear Quality Assurance Manual,

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Section 7.7.2, states, in part, that: "Stop work is a principle

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authority given to the quality assurance engineers at the job

site.

It permits immediate stoppage of work operations or

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construction activities determined to be improperly controlled

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Contrary to the above, a timely stop-uork order was not issued

by the Eechtel Corporation to the Johnson Service Company, even

though numerous deficiencies had been identified during Ecchtel

Corporation quality assurance audits conducted during November

and December 1974

(Report Details, Paragraph 3)

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B.

Safety Items

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None identified.

Licensee Action on Previously Identified Enforcement Matters

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Cable Trav Grounding Final Inspection Procedure (RO Inspection Reports

No. 050-346/74-07 and No. 050-346/74-10)

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2.

Emergency Diesel Cencrator Storage - Storage of 0-listed Item in

Auxiliary Feeduater Pump Room Area (R0 Inspection F.coorts No.

050-346/74-07 and "o. 050-346/74-10)

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The corrective action, for the above items outlined in the Toledo Edison

Company (TECO) letters of January 6 and 23, 1975, in response to the no:1II

letter and report dated December 3, 1974, was found to have been satisfactorily

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accomplished and documented. This matter is considered to have been re-

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solved.

(Report Details, Paragraph 1)

Design Chan$en

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No ne.i design changes were identified.

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Unusual occurrences

No unusual occurrences were identified.

Other Significant Findinns

A.

Current Findings

The licensee indicated that, as of November 1974: (1) construction

was 76% complete, and (2) engineering was 98.5% complete.

B.

Unresolved Matters

1.

Incomplete Installed Eculpment Reports

Clarification is required as to the circumstances under which

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an unapproved ITT Grinnell Corporation (Grinnell) " Installed

Equipment Report" procedure was being used for the past two

years to verify the correctness of the initial setting of

equipment.

(Report Details, Part III, Paragraph 2)

2.

List of Safety Related Items

Verification is required whether the list of safety ralated

items, complied by Bechtel, titled "D-B Nuclear Power Station

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Q-List", Revision 10, dated May 16, 1974, is complete.

(Report

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Details, Part III, Paragraph 4)

3.

Johnson Service Company - Installation / Fabrication (I/F)

Planner System

During the review of various correspondence regarding I/F

planners, it appeared that the planner system has not been

finalized.

This item will be reviewed during a subsequent

inspection.

(Report Details, Part II, Paragraph 2.a. (4))

4.

Johnson Service Company - Positioning of Seismic Class 1

Mounting Supports

During the observation of installations and review of instal-

lation drawings, the positioning of certain tubing supports

was questioned.

Documentation provided for the inspector's

review did not provide suf ficient information to justify

method of installation support.

This item will be reviewed

during a subsequent inspection.

(Report Details, Part II,

Paragraph 2.a. (5))

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C.

Status of Previously Reported Unresolved Matters

1.

Cooling Water Piping to Emergency Diesel Engine 2 (R0 Inspection

Report No. 050-346/74-07)

The inspector was informed that the relevant drawings are being

revised to provide redundancy requirements for cooling water

to diesel engine No. 2.

This item remains open pending physical

inspection of the piping modification.

2.

Hydraulic Snubbers (RO Inspection Report No. 050-346/74-07)

The licensee informed the inspector that Bechtel Corporation

(Bechtcl) had written two letters (dated January 8 and 15, 1975)

to Grinnell requesting them to use oil, GE Type 1154, in the

snubbers.

The inspector will review this matter further during

subsequent inspections.

3.

Design Drawing Change Verification (R0 Inspection Report No.

050-346/74-07)

The licensee informed the inspector that, as part of corrective

action taken relative to design change verification, a repro-

ducible of a drawing revised in the field vill be sent to

Grinnell for verification, along with sufficient internation

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to verify the correctness of the changes made.

The inspector

will verify the implementation of the corrective action during

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subsequent inspections.

4.

Cable Tray Installation Procedure (R0 Inspection Report No.

050-346/74-07)

This matter remains open pending the inspector's review of the

licensee's procedure that vould verify that these items are

included as part of the inspection program.

5.

Cable Tray Storage (RO Inspection Report No. 050-346/74-07)

This item remains open pending the inspector's review of

procedures and observation of the storage area.

6.

Calibratien Records - Stress Relieving Instrumentation and

Equipment (R0 Inspection Report No. 050-346/74-07)

The inspector was informed that, as a result of corrective

action taken by Babcock & Wilcox Company (E6W) a revised

calibration procedure, No. 9T 101, Revision 4, was prepared

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and submitted for formal approval.

Implementation of this procedure

will be verified during a subsequent inspection.

7.

Diesel Generator - Relays (R0 Inspection Report No. 050-346/74-07)

This item remains open pending the inspector's review of these documents.

8.

Reactor Coolant Pumps Suction Weldment Linear Indications (R0 Inspection

Reports No. 050-346/74-04, No. 050-346/74-07, and No. 050-346/74-10,)

This item remains open pending receipt of a final 10 CFR Part 50.55(e)

report from the licensee.

9.

Class IE Electriccl Cable Trays (R0 Inspection Reports No. 050-346/74-02

No. 050-346/74-04, No. 050-346/74-07, and No. 050-346/74-10)

The inspector reviewed documentation issued to Bechtel, dated November 27,

1974, indicating that Class lE cable trays would be added to the

Davis-Besse Q-list, after Section 4.3150, titled " Installation of Cable

Trays".

This change would include inspection of all activities,

including " Receipt Inspection, Storage, and Installation of Cable Trays".

This matter remains open pending implementation of the instruction and

will be reviewed during a subsequent inspection.

10.

Westinghouse Electric Corporation (W) Hi,gh Pressure Inj ection Pump,

'p.

Motors (R0 Inspection Reports No. 050-346/74-01, No. 050-346/74-02,

No. 050-346/74-04, No. 050-346/74-07, and No. 050-346/74-10)

This item remains open pending receipt of a final 10 CFR '

' 50.55(e)

report from the licensee.

11.

Review of Bagwell Coatings, Incorporated (Bagwell) Quality Assurance

Manual (R0 Inspection Report No. 050-346/74-07 and No. 050-346/74-10)

This item remains open pending the licensee's final review and acceptance

of the Bagwell's QA manual.

12.

Review of Bagwell's Closeout of Outstanding Items as Listed in the

Toledo Edison Company (TECO) Audit of May 21, 1974 (R0 Inspection

Reports No. 050-346/74-07 and No. 050-346/74-10)

This matter remains open pending the inspector's review of Bagwell's

corrective z.ction pertaining to these items.

13.

Instruction for Handling Piping, Components, Etc. Purchased by Grinnell

_(_RO Inspection Report No. 050-346/74-10)

The inspector reviewed Grinnell's revised procedure, No. SS1201,

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Revision D, dated December 16, 1974, and states, in part, that:

"

rigging equipment will be used as approved by the con-

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struction manager".

The inspector pointed out that, in the past,

Crinnell completed planners were neither approved nor reviewed by

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the construction manager.

The Grinnell representative could not

provide the inspector with a method to verify whether the construction

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manager had approved the rigging equipment procedures.

This item will

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be reviewed during a subsequent inspection.

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Management Interview

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A fornal management interview was not held at the conclusion of the in-

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spection.

The licensee was informed that a management interview would be

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held subsequent to the inspection at TECO's corporate headquarters

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Management personnel of L'RC Region III would attend the meeting.

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REPORT DETAILS

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Results of Inspection

1.

Cable Tray Grounding Final Inspection Procedure (RO Inspection

Reports No. 050-346/74-07 and No. 050-346/74-10)

The licensee's supplemental letter of January 23, 1975, amending

item A-1 of the January 6, 1975 letter, indicates that a completion

inspection program for grounding of Class lE cable trays would be

conducted using approved inspection procedures.

Inspection of the

trays would be documented. Areas of inspection vould include veri-

fication of proper ground cable, cable continuity, pro,er use and

installation of cable tray connections, and proper connection of

ground cable to building steel and/or station ground system.

Verification of the use of these procedures will be made by the

NRC inspector during a subsequent inspection.

2.

Emergency Diesel Generator Storage - Storage of Q-listed Item in

Auxillary Feedwater Pum, Room Area (R0 [nspection Reports No.

050-346/74-07 and No. 050-346/74-10)

The licensee's corrective action, as stated in the January 6,

a.

1975 letter to Region III, was revicued.

Inspection documentation

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was available and reviewed.

Bechtel and Fischbach & Moore,

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Incorporated (FOI)/Colgan Electric (CE) management have taken

steps to provide storage, preservation, logging, component

condition inspection, meggering, and audits of the storage of

the diesel generators.

Reviews of TECO and Bechtel QA cudits

will be conducted during subsequent inspections.

b.

The Bechtel management has taken steps to control the clean-

liness of the auxiliary feedwater pump room.

Instructions

were reviewed by the inspector.

Cleanup areas have been des-

ignated for all site contractors.

k' eld rod stub buckets have

been provided to all Grinnell welding personnel and were ob-

served to be in use.

Subsequent audits by TECO and Bechtel will

be reviewed by the NRC inspector during subscquent inspections.

3.

Bechtel Stop-k'ork Authority

The inspector was informed by Bechtel's project quality assurance

engineer that, prior to the current NRC inspection, meetings had

been held with Bechtel and Johnran Service Company (Johnson)

management regarding the unacce, table QA/QC condition found during

QA audits.

No positive action was taken during this time, which

spanned a three-four week period.

During the initial part of the

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current NRC inspection, it became apparent by NRC inspection and

observations that the ongoing construction activities, related to

safety areas, were not being properly controlled, even though

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numerous deficiencies had been identified by Bechtel QA personnel.

This matter was thoroughly discussed with TECO's QA canagement.

Prior to the completion of the current inspection, the NRC, inspector

was notified by the Bechtel proj ect QA manager that a stop-work

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order had been issued to Johnson to stop all safety related and

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ASME/ Code work.

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REPORT DETAILS

Part II

Prepared By:

F. J. Jablonski

Persons Contacted

The following persons were contacted during the inspection.

Bechtel Corporation (Ecchtel)

R. M. Bush, Instrument Engineer

L. D. Jensen, Instrument Engineer

W. C. Lowery, Electrical Quality Assurance Engineer

Fischbach & Moore, Incorporated (F6M)

H. J. Harris, Quality Control Coordinator

D. M. Moeller, Quality Control Manager

Johnson Services Company (Johnson)

J. A. Bushnell, Proj ect Manager

H. W. Fosholdt, Quality Assurance Representative

G

W. S. Morrow, Prnj ec t Engineer

F. T. Murphy, Project Superintendent

J. W. Pasch, In-Process Welding Inspector

T. Sambaer, Electrician

R. Schroeder, Director of Quality Assurance

Results of Insnection

1.

Observations of Work - Instrument / Electrical

a.

The incpector observed the instrument installation performed by

Johnson upon "Q-listed" item Mo. 32280 for the number one

service water pump.

The ':utallation did not appear to be

complete. The tubing was not adequately protected from the

surrounding construction activities or other activities, and

a loose instrument valve packing nut was observed.

b.

The inspector observed a Johnson employee to be in possession of

a quality controlled crimping tool, No. Q-lll, which had been

assigned to another workman.

The Bechtel QA representative

indicated that Johnson's tool control procedure would be reviewed.

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c.

The inspector observed Johnson's outdoor storage areas and

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determined the following:

(1) An instrument mounting stand, with "Q-listed" instrument

No. 2918 attached, was stored in the welding fabrication

area without a plug over the electrical installation port.

(2)

Unistrut used for the support of scismic Class 1 tubing

was stored, in some cases, directly on the ground.

(3)

Unistrut welds were not properly coated subsequent

to

factory welding.

Rust was forming at these points.

(4)

Unistrut factory welds appeared to have cracks and blow-

holes.

(5)

Completed instrument mountings, which support "Q-listed"

instruments, were stored in various positions, directly

,

on the ground.

Rust was showing through the painted sur-

faces.

(6)

None of the stored material was identified to be accepted

or rejected according to' provisions of the Johnson QA manual,

d.

The inspector physically traced instrument cable 2CV235BD, in-

fs

stalled by F&>l, fr.om centrol panel C5717 to penetration P2C56X

(

)

and verified the following:

(1)

The cable tray had been inspected prior to the cable in-

stallation.

(2) The tray was clean.

(3)

Cable crossovers did not exist.

(4)

The cable was neatly clamped at the required points.

(5)

The routing was verified per the routing card.

(6)

The cable was scaled at the nonterminated end.

(7)

The tray spacing of redundant systems was not exceeded.

(8)

The cable was properly determined to be free of grounds.

(9)

The cable was properly tagged and terminated by Johnson.

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2.

Record Review

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The inspector reviewed the installation / fabrication (I/F)

a.

planner No. PI-1373 and noted the following:

(1)

The quality assurance representative (QAR) had not apprcved

the I/F planner, nor verified that the proper hold points

had been checked per the Johnson QA manual.

These QAR

functions had been performed by the quality engineer (QE).

The QAR could not provide documentation which would indicate

that the QE could officially approve the I/F planner.

(2)

The QA documents for PI-1373 indicated, by a QA stamp and

date, that the installation was complete with the exception

of pressure tests and final inspection. The IE inspector

reviewed Johnson Drawing No. I/F 1373-0.

Discussion with

the Bechtel instrument engineer indicated that a required

tubing support location had not been finalized.

Bechtel's Audit Finding Report (AFR) dated January 22, 1975,

also identified the above problem and other findings which

remain unresolved.

(3)

Bechtel's SpecificaHon No. 7749M-328, Section 3.3, requires

that the instrument installation contractor submit isometrics

(q

for all seismic Class 1 tubing systems to the construction

)

d

manager for review and documentation.

There vas no stamp

or other identifying mark on this drawing which verified

that these requirements had been met.

This problem was

also identified by Bechtel's AFR Mo. 123-E, dated January 9,

1975.

(4)

A review of letter No. FL23-818, dated January 13, 1975,

and Bechtel Conference Notes, dated January 16, 1975, in-

dicated that the 1/F planner system had not been finalized.

While these reviews and conferences were in session, Q-

listed installations were progress.

(5)

Drawings used for the design of seisnic Class 1 mounting

supports are referenced on the main I/F drawing (No. I/F

1373 - 0).

The IE inspector reviewed Drawing Nos. J-G16-4,

Revision 0, and J-G16, item 4.

The drawings did not agree

with the actual installation.

The Johnson engineer stated

that the seismic support would perform equally well if

installed in any position,

i.e., horizontal or vertical.

The Johnson engineer used Bechtel Conference Notes dated

January 16, 1975, as the basis for his evaluation.

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review of these notes by the inspector, it was determined

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that the notes in themselves do not provide adequate infor-

mation which would allow the indiscriminate positioning

of seismic Class 1 tubing supports,

b.

The inspector requested that fabrication and installation records

for the floor mounted instrument structure of PI-1373 be pro-

duced for inspection. The following were observed:

(1) Bechtel Drawing M-552-G108, SHT. 2, Revision 5, titled

" Seismic Class 1 Instrument Mounting Details" and stamped

"Q" indicates, in detail 2, that the " Maximum instrument

and accessory weight equal 60 pounds".

The Johnson

Quality Assurance Representative (QAR) could not provide

a procedure which would satisfy this requirement.

(2)

Bechtel Specification No. 7749 M-328, Paragraph 5.6, states:

"Most of the standard raceway or supporting materials

are galvanized.

L' hen used inside the Containment Buildings,

the total weight of zine coating must be reported to the

nuclear engineer on the project to allou his computation

of the maximum potential H, evolution for accident analysis".

The QAR could not provide a procedure which would satisfy

this requirement.

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(3) The material to be used for the fabrication of the "Q-listed"

stands is identified on Bechtel drawing M-552-6108.

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Fabrication and installation of the stands was in progress

without verification of material certifications.

(4)

The Johnson representative indicated that there was no

provision for documenting the fabrication or inspection

of seismic Class 1 instrument stands which support "Q-listed"

instruments.

The Johncon representative further stated

that these installations were not considered to come under

the provisions of the ASME Code,Section III.

The QAR

also indicated that a formal welding red stub control

procedure had not been prepared.

The inspector reviewed F&M installation records for instrument

c.

cable No. 2CV235BD.

All records appeared to be completed and

included the following:

(1)

Nondestruttive examination.

(2)

Cable pull.

(3)

Cable inspection.

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Also reviewed were FEM's periodic equipment log and other

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electrical surveillance records.

All records were found to

be complete and appeared to meet inspection requirements.

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The incpector arbitrarily chose motor control center "o.

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and verified that the required space heater and humistat

controls were energized.

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REPORT DETAILS

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Part III

Prepared By:

K. R. Nnidu

Persons Contacted

The following persons were contacted during the inspection.

Toledo Edison Cornany (TECO)

E. A. Wilcox, Field Quality Assurance Specialist

C. T. Daft, Quality Assurance Engineer

ITT Grinnell Corporation (Grinnell)

D. Giguere, Quality Control Manager

C. Keller, Incoming Receipt Inspection

Babcock & Wilcox Company (EEW)

W. R. Klingler, Project Manager

J. W. Marshall, Quality Control Supervisor

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A. Bentley & Sons (Bentley)

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R. Sauders, Quality Control Engineer

D. Ponke, Quality Control Supervisor

D. Loe, Millwright Supervisor

Results of Inspection

1.

Outdoor Storace of Safety Related Components

During the inspection of the outdoor storage area, the inspector

noted that inspection checklists were not being prepared for use

by Quality Control personnel to inspect stored safety related

components outdoors.

As a result, in the absence of specific,

acceptable criteria, the inspector found that the QC inspectors

were unable to identify nonconformances.

The inspector reviewed

the Grinnell specification for outdoor storage of safety related

components.

The storage procedure had been developed from Dechtel's

Specifications No. M453 and No. N458, which contain general terms.

The inspector observed four pieces of safety related piping com-

ponents, with ends inadequately protected from possible deterioratJon

by corrosion or contamination.

A seismic restraint was found lying

in mud.

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Examination of the nonconformance reports, prepared by TECO's QA

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agent, Bechtel, revealed that corrective action recommended was

merely to " conform to Bechtel's Specifications No. M453 (five pages)

and No. M458 (twenty pages)" without specific details.

2.

Incomplete Installed Eauipment Reports

During review of Grinnell quality assurance records, the inspector

noted that, in several " Installed Equipment Reports", (IER's)

there was no evidence that any of Bechtel's representatives had

verified the correctness of the activity.

Upon inquiry, it was

determined that, in a letter to Bechtel, da*ed March 13, 1973,

Grinnell had requested formal approval to use the Installed Equipment

Report Form which was to have been prepared to meet the intent of

Bechtel's Specification 1:o. 7749-M-454, Paragraph 5.4.

This form

was intended to indicate that the activity involving the removal

of the specified component frem its storage area and correct placement

was verified and found to be correct if signed.

Three signatures

are required to complete this report:

(1) Grinnell's receiving

inspector, (2) the equipment installer, and (3) Bechtcl's repre-

sentative.

The signatures would indicate that the activity had

been correctly accomplished.

The inspector reviewed IER's No. 79 and No. 84, which were properly

signed by Grinnell's inspectors.

There was no indication that

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Bechtel's representative had verified these activities.

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The licensee's QA representative informed the inspector that this

matter would be investigated.

Results of the findings and corrective

action taken will be verified during subsequent inspections.

3.

Approvals Without Adecuate Verification

During the inspection, it was observed that, although service water

pumps No. P3-3 and No. P3-2 were not installed as specified in

Drawing No. M135, Revision 10, the pumps were not tagged as non-

conforming items.

The inspector expressed concern over a possible breakdown in the

licensce's QA program, as a result of the following findings in-

volving approvals without adequate verifications,

a.

Incomplete Deviation Report Cleared

Deviation Report (DR) No. F98 was prepared on June 10, 1974, by

Grinnell requesting that the Bechtel construction manager approve

the placing of the service water pumps' position without t>

use

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of planner FF105A (which is required Ier procedure SS1201C).

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Bechtel's construction manager approved the above deviation on

June 28, 1974.

As a result, the pumps were left installed in

the incorrect location.

Further, it was noted that the above DR was incomplete because,

instead of inserting the relevant drawing (M135) used for

selecting the location of the pumps, "NA" was inserted in the

intended column.

b.

Pumps Released for Grouting Without Adequate Verification

Without proper verification, speed letter No. 8-428, dated

December 27, 1974, was issued by Bechtel to Benticy releasing

the incorrectly placed pumps for grouting.

c.

Alignment Documented as Correct

Without verifying that the correct pump was hooked to the cor-

rect pipe, the " alignment prior to hookup" was signed off by

Bentley (November 25, 1974), Eechtel (November 27, 1974), and

TECO (November 25, 1974).

d.

Concrete Placement Verified

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Without verifying that the correct pump had been set on the

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foundation, the Bechtel field engineer signed off the " Concrete

Placement Checklist" (Forn 10) on December 30, 1974.

e.

Inadequate Communication of Nonconformances

A Field Inspection Report (FIR) dated January 21, 197~, ident-

ified the inadvertant placement of service water pumps, No. P3-2

and No. P3-3, and informed the Bechtel " Area Coordinator" by

a copy of the FIR.

The pumps were not " Red Tagged" to denote

a nonconformance at the completion of the current inspection.

The above inspection reports indicated that QC personnel did not

participate in the inspection of activities concerning safety related

items.

4.

Safety Related Items List (Q-list)

During the inspection, the inspector no*ed that, "the component

cooling water return from decay heat pump bearing housing seals . . .

water return header" on page 33, Revision 4, of M602, was identified to

be seismic Class 1. but was not listed as a safety related item.

The

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licensee's representative showed the inspector, for verification,

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a Q-list compiled by Bechtel, titled " Davis-Besse Nuclear Power

Station Q-List".

The inspector noted that this list was~1ast re-

vised on May 16, 1974.

The inspector inquired if the list had been

reviewed after issuance of Revision 10 of the FSAR in December 1974.

In Volume 5 of the FSAR, the inspector found Figure 9-4 (M-036)

Revision 9, dated September 1974, which appears to show the above

line in the component cooling system as a "Q"

item.

5.

QA Engineer's Report Review

The inspector reviewed the following QA engineer's reports:

a.

QA Engineer's Report 91, covering November 18 - 29, 1974.

b.

QA Engineer's Report 92, covering December 2 - 13, 1974.

c.

QA Engineer's Report 93, covering December 16 - 27, 1974.

d.

QA Engineer's Report 94, covering December 30 - January 10, 1974.

The above documents indicated the number of DR's have been reduced

and that corrective action was being taken ef fectively.

6.

Reactor Vessel Closure Head (RVCH)

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The inspector reviewed the inspection records of the RVCH maintained

by B&W.

Inspections appeared satisfactory and were in accordance

with B&W Procedure No. FS-111-lb-14, titled " Receipt Inspection,

Handling, Storage, and Installation of the RVCH" dated July 10, 1973.

Inspections concinued after the RVCH vas removed from its original

shipping condition and set in the containment building.

During the.

current inspection, the inspector observed that preparations were

being made to assemble the control rod driving mechanisms.

Pro-

cedure No. 57, Revision 3, dated January 17, 1975, was available

at the place of work and inspections, indicated by signoffs, had

been performed at various stages.

7.

QA Documentation on NSSS Components (B&W)

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The following mechanical components were selected from within the

reactor coolant pressure boundary system for QA documentation

review.

a.

High pressure injections pump; identification P-1A; serial

No. 68980.

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b.

Seal return coolers (heat exchangers); identification MUGX2a

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and MUHX2b, Serial Nos. 1768 and 1769.

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c.

Seal injection flow isolation valve; identification MU-HV-66A;

Serial No. W7-374-13MS.

The B&U QA records for the above ncchanical components appeared to

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be acceptable by selective review of:

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(1)

Storage inspection reports

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(2) Material and fabrication reports, which included:

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(a) Material identification

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(b) Material certifications

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(c)

Conformance to manufacturing requirements

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(3) Material and shop NDE reports

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Deviation reports

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Surveillance and test reports

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