ML19329F764
| ML19329F764 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/20/1980 |
| From: | Beach A, Crossman W, Randy Hall NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19329F759 | List: |
| References | |
| 50-382-80-09, 50-382-80-9, NUDOCS 8007110076 | |
| Download: ML19329F764 (8) | |
See also: IR 05000382/1980009
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0FFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No. 50-382/80-09
Docket No. 50-382
Category A2
Licensee: Louisiana Power & Light Company
142 Delaronde Street
New Orleans, Louisiana 70174
Facility Name: Waterford Steam Electric Station, Unit No. 3
Inspection at: Waterford Site, Taft, Louisiana
Inspection Conducted: April 21-25, 1980
Inspector:
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A. B. Beach, Reactor Inspector
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Engineering Support Section
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Approved by:
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R. ET Hall, Chief, Engineering Support Section
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V. A. Crossman, Chief, Projects Section
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Inspection Summary:
Inspection on April 21-25, 1980 (Report No. 50-382/80-09)
Areas Inspected: Routine, announced inspection of construction activities
related to the review of quality records and the observation of activities for
safety-related steel structures and supports. The inspection involved forty
hours by one NRC inspector.
Results:
In the areas inspected, four apparent items of noncompliance and one
deviation were found (infraction - failure to follow procedures for the
documentation of the Quality Assurance Program - paragraph 3.a.(1); infraction -
failure to perform required inspections as prescribed in contract inspection
procedures
paragraph 3.a(2); infraction - failure to follow contract procedures
relative to the care of safety-related equipment - paragraph 3.a(2); infraction -
- ailure to follow contract procedures relative to the care of safety-related
piping
paragraph 2; and deviation - use of QC inspectors who did not meet
the ANSI N45.2.6 experience qualifications
paragraph 3.a(3).
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DETAILS
1.
Persons Contacted
Principal Licensee Employees
- L. Bass, Project QA Manager
B. Brown, QA Engineer
- C. Chatelain, QA Engineer
- T. Gerrets, QA Manager
- 0. Pipkins, QA Engineer
- B. Toups, QA Engineer
Other Personnel
- C. Breedlove, Project Manager, Tompkins-Beckwith
- J. Crnich, Site Manager, Ebasco
'J. Gore, Site QA Manager, Tompkins-Beckwith
- R. Hartnett, QA Site Supervisor, Ebasco
- R. Milhiser, Project Superintendent, Ebasco
- J. Moskwa, Field QA/QC Manager, Nuclear Installation Services Co. , (NISCO)
- D. Shah, QC Engineer, NISCO
- J. Weaver, Project Manager, NISCO
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The IE inspector also interviewed other licensee and contractor personnel
including members of the engineering and QA/QC staffs.
- Danotes those in attendance at the exit interview.
2.
Site Tour
The IE inspector toured the plant areas several time-
ring the inspection
period and observed the progress of construction and i a construction
practices involved. One tour was made during a back shift inspectica on
April 23, 1980.
During this back shifc inspection, the I2 inspecter observed three spools
of Component Cooling Water Piping lying directly on the concrete flooring
in the Reactor Containment Building at Elevation 0.
In addition, the
piping (3CC-10-13A/B-11, 3CC-10-57, and 3tc-10-33B-22-1) was not segregated
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from the storage of other materials. These materials included reinforcing
steel, tools, pieces of scaffolding and other items apparently used by the
construction trades working in the area.
Section P.9 of the Ebasco Contract Specification for Tompkins-Beckwith,
Contract No. W3-NY-11, requires that the contractor abide by the
guideline provisions of ANSI N45.2.2:
" Packaging, shipping, receiving,
storage, and handling of items for Nuclear Power Plants." Section 6.1.1
requires that during construction the possibility of damage to materials
or components or the lowering of quality due to corrosion, contamination,
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or deterioration be minimized. Also, Section 6.1.2 requires that items be
stored on cribbing or equivalent to allow for air ciculation and to avoid
trapping water.
Due to the conditions observed for the applicable Component Cooling Water
Piping, this is considered to be a failure to meet the contract specifi-
cation and is considered to be an item of noncompliance with the require-
ments of Criterion V of Appendix B to 10 CFR 50,
i.e.,
failure to follow
contract procedures relative to the care of safety-related piping.
3.
Containment Steel Structures and Supports
a.
Review of NISCO Quality Assurance Program Implementation
and Procedures
(1) Audits
The implementation of the Quality Assurance program for the
installation of the Nuclear Steam Supply System and the per-
formance of related work as prescribed in the Ebasco Contract
Specification W3-NY-18 is to be accomplished by the contractor,
NISCO, in accordance with the "NISCO QA Manual - ASME, Section
III," with the applicable revisions.
Section 4.4.3 of this
manual (Revision C, dated 6/6/78) requires that a Vendor Per-
formance Record File be maintained in the NISCO home office
under the direction of the Manager, QA, consisting of the
following documents:
Vendor Perforcance Reports
NISCO Vendor Audit Reports
NISCO Nonconformity Reports
The Manager, QA is to forward to the Field QA/QC Manager and
the Project Manager copies of the records in the Vendor Performance
Record File for each vendor used at the site.
Contrary to the above, the NISCO contractor personnel stated
that these records were not available at this site, and that they
could not substantiate whether or not these audits were being
performed.
An " Approved Vendors List," dated January 18, 1980,
was reviewed by the IE inspector, indicating that the subject
audits were, in fact, being rerformed.
A review of the NISCO Manual 103.2, "NISCO Shop Audits," indicated
that periodic audits of the program were being performed, but
a comprehensive audit of the entire program in a twelve month
period was not being performed as required by Section 15.2.2.3
of the NISCO QA Manual, " Site Audits." A review of Audits 3015-1
through 3015-17 revealed that segments of the program were
b2ing reviewed, but the total results of this segmented review
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did not cover the entire program in an annual audit program
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as required.
In addition, during this review of NISCO
Manual 103.2, there was evidence of several vendor surveillance
audits, but the contractor personnel could not verify whether
or not these were to be a part of the Vendor Performance Record
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File as required.
These conditions discovered at the time of this inspection are
considered to be an item of noncompliance with the requirements
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of Criterion V of Appendix B to 10 CFR 50;
i.e.,
failure to
follow procedures for the documentation of the NISCO QA Program.
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(2) Handling and Storage
Section 5.6.3 of the "NISCO QA Manual - ASME Section III"
(Revision C, dated 6/6/78) requires that the " Maintenance and
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-Surveillance Report" be utilized to document the required main-
tenance services and to provide "erification that these inspec-
tions are performed at the required frequency.
Discussion with
contractor QC personnel, however, revealed that these " Main-
tenance and Surveillance Reports" were no longer being used and
that inspections were currently being performed on a daily basis
in accordance with ES-67-CE, " General Cleaning and Housekeep ag."
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The NISCO QA Manual had not been changed to reflect this
procedural change.
Section 5.6.4 of the NISCO QA Manual delineates the storage
area as the responsibility of the NISCO Field Engineer.
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In addition, Section 5.6.5 requires periodic inspections
of the storage areas to be conducted by the Field QA/QC
Manager or his designee to preclude damage to safety-related
materials and components while in storage. Also, the
procedure ES-67-CE requires a daily inspection and examination
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of the storage area for conformance to procedures
in the following areas:
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Adequacy of access control
Evidence of damage or deterioration
Adequacy of protection from fires, weather, and
movement of equipment or other factors that may result
in damage to stored items
A review of daily inspection reports by the IE inspector indicated
that daily inspections were being performed, but not in the NISCO
-storage area.
Further discussion with the contractor QC personnel
revealed that daily inspections were not being performed in the
NISCO storage area or the Fuel Handling Building because there
had been no direction for tha.m to do so from the F' eld QA/QC
Manager.
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In addition, Care and Maintenance Instruction No. 36 for the
Flow Eaffle and the Reactor Vessel Closure Head Lifting Rig requires
a monthly inspection of the general condition of the equipment
to ensure it meets the degree of quality required by the contract.
From observation of the storage conditions, it was determined
that this procedure, likewise, was not being performed by the
contractor.
The failure to perform these inspections of the storage area and
components as required by the NISCO QA Manual and contract pro-
cedures is considered to be an item of noncompliance with the
requirements of Appendix B to 10 CFR 50.
Subsequent to this review, the IE inspector toured the NISCO
storage area and observed the following:
(a)
The area was not identified nor its boundaries defined as
a storage area for seismic Class I and safety-related com-
ponents.
(b) Surge Line Restraints (E8-E6-W1) were noc properly stored
on dunn'ge, while some of the dunnage was stacked on top
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of the restraints.
(c) The Reactor Vessel Lif ting Assembly (NISCO Drawing 1564-G-
1551, P.O. 403402) did not have proper identification or
identification tags.
(d)
The Flow Baffle Assembly (NISCO RIR-211, P.O. 403402) was
outside of its storage container without proper protection
from movement of equipment and inadequate protection from
damage.
Section P.9 of the Ebasco Contract Specification for NISCO
Contract No. WE-NY-18, requires that the contractor abide by
the guideline provisions of ANSI N45.2.2, " Packaging, Shipping,
Receiving, Storage, and Handling of Items for Nuclear Power
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Plants." Section 6.1.1 requires that during construction the
possibility of damage to materials or components or the lowering
of quality due to corrosion, contamination, or deterioration
be minimized.
Section 6.1.2 requires that items such as piping
be stored on cribbing or equrvalent to allow for air circulation
and to avoid trapping water.
Section 6.3.3 requires that all
materials be identified with proper protection from movement
of equipment.
Due to Lne storage conditions observed, this is considered to be
a failure to meet the contract specification and is considered
to be an item of noncompliance with the requirements of Criterion
V of Appendix B to 10 CFR 50, i.e. , failure to follow contract
procedures relative to the storage of safety-related equipment.
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(3) Quality Control Inspector Qualifications
The qualification of NISCO QC inspector personnel is to be
accomplished in accordance with NTSCO Procedure ES-116-2,
" Qualification and Certification of Inspection Personnel."
After a review of this procedure, the IE inspector reviewed
records relative to the qualification of the NISCO QC inspectors
being utilized at the site.
Section 4.2 of NISCO Procedure ES-116-2 delineates that there
shall be three levels of qualification:
Level I, Level II, and
Level III.
It further states that a Level I individual shall
have sufficient training and experience to properly perform the
necessary inspections, and shall be responsible to a Level II,
or a Level III inspector. A Level II inspector shall be qualified
to direct and carry out inspections in the method certified,
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while a Level III inspector shall be capable of interpreting
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specifications and codes.
Contrary to the above, it was discovered that a "QC technician"
was performing inspections (normally performed by Level I and
Level II QC inspectors) in accordance with ES-67E, " General
Cleaning and Housekeeping," and ES-148, " Welder Surveillance."
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ES-67E provides an inspection and surveillance procedure for
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housekeeping and ES-148 provides a method of verification that
Code and contract requirements are being adhered to in the
welding operations and provides a means of documenting these
inspections. The site QC records indicate that QC technicians
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have been performing these inspections since approximately
June 1979, and that the QC technicians did not meet the levels
of qualification for a Level I QC inspector at the time of their
employment, since they did not satisfy the one year work
experience requirement.
In addition, during this review, the IE inspector was given
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records for an individual'
Level II Quality Control Inspection
Certification. The individual's qualification records indicated
that he had been originally hired as a QC technician, and after
approximately one year and six months in that specific capacity,
had received certification as a Level II inspector, and had per-
formed back shift inspections on his own without any assistance.
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His experience record did indicate he had successfully completed
all of the necessary proficiency training.
Table 17.2-1, of the LP&L FSAR, "LP&L Quality Assurance Program
Guidance Documents," references Regulatory Guide 1.58, "Qualifi-
cation of Nuclear Power Plant Inspection, Examination, and Testing
Personnel." This regulatory guide endorses ANSI N45.2.6," Quali-
fication of Inspection, Examination, and Testing Personnel for
the Construction Phase of Nuclear Power Plants" and also requires
(per Section 3.1.2) that a candidate, to be considered for certi-
fication, be a high school graduate with four years of inspection
or testing experience. Even though it also allows variation
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from the education and experience requirements specified, one
NISCO Level II inspector is qualified only to the Level I expertise.
This inspector had been utilized as a Level II inspector even
though he did not meet the work experience guidelines.
The utilization of inspectors without specified experience quali-
fications appears to deviate from the licensee's commitment in
Table 17.2.1 of the FSAR.
b.
Review of Quality Records For The Polar Crane Ring Girder
The IE inspector reviewed Ebesco Specification LOU 1564.717, Rev. 10,
" Steel Containment Vessel." The following records were then reviewed
for girder assembly 67-A of the polar crane support assembly:
CBI Daily Fabrication or Stores Release Report, dated 7/19/76
Test Reports (Ref: Heat-Slab Numbers 180, 181, 182, 183, 184,
and 185)
Test Certificates from Lukens Steel Company
MPT Inspection Reports, File 7.4
CBI Detail Checklist, dated 6/6/77
Welding Material Authorization and Release Report
Mill Certifications for Welding Material
Records of Nondestructive Examination Performance
Non-Conformance File 71-2426, 8.6.1
All of the records reviewed were found to be in accordance with the
Ebasco Specification LOU 1564.717, Revision 10, and with Chicago Bridge
and Iron Drawing No. 67, Revision 8, dated November 3, 1975.
No items of noncompliance or deviations were identified.
4.
Exit Interview
The IE inspector met with the licensee representatives (deouted in
paragraph 1) at the conclusion of the inspection on April 25, 1980.
The IE inspector summarized the scope and the findings of the inspection.
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