ML19341B763

Responds to NRC 801029 Ltr Re Violations Noted in IE Insp Rept 50-443/80-10 & 50-444/80-10.Corrective Actions: Personnel Instructed Re Proper Pipe Support Weld Installation & Inspect of Incoming Structural Steel

ML19341B763
Person / Time
Site:	Seabrook
Issue date:	12/02/1980
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19341B761	List: ML19341B763
References
SBN-141, NUDOCS 8102270425
Download: ML19341B763 (4)

Text

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PUBL.lC SERVICE camp.nyor rmw e SEA 8 ROOK STATION Engineering Office:

.20 Turnpike Road Westborough, MA 01581 December 2, 1980 SBN-141 T.F. B 4.2.7 U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention: Office of Inspection and Enforcement

Subject:

Combined Inspection Nos. 50-443/80-10 and 50-444/80-10

Dear Sir:

Pursuant to receipt of your correspondence regarding the results of the subject inspection, we offer the following reply:

NRC Notice of Violation: (80-10-03) 10 CFR 50, Appendix B, Criterion V states, in part, that: " Activities affecting quality shall be. . . accomplished in accordance with (the pre-scribed) instruction, procedures or drawings."

The Seabrook Station PSAR for Units 1 and 2 states, in part, in para-graph 17.1.5 that: "Each organization is required to perform their respec-tive quality related activities covered by this program in accordance with documented instructions, procedures, or drawings."

Pullman Power Products Hanger Drawing MS-1201-SG-08, Revision 4, indicates Field Welds 2, 4, and 5 to be of certain size, length, and position relative to the structural members being connected.

Contrary to the above, on September 29, 1980, Field Welds 2, 4, and 5 on Hanger MS-1201-SG-08 were signed off as completed by QC personnel, despite the fact that weld lengths were less than specified, portions of certain welds were undersized, and the pesitioning of the structural members, as it affected these welds, was unacceptable.

This item is an infraction applicable to Docket No. 50-443.

elosse o W

U.ji. Nuc, lear Regulatory Commission Pags 2 SBN-141

Response

Corrective Action Taken and Results Achieved Steps were insnediately taken by Pullman-Higgins (P-H) prior to the conclusion of the audit, to develop and implement an effective corrective action. The following actions were instituted:

1. Formal classes were condu,cted at which time Supervision, Engineering, Inspection and Craft personnel were instructed in the interpretation of weld symbols and proper pipe support construction tolerances.

2. Classes were conducted for craft supervisory personnel cover.'.ng exam-ination and testing requirements.

3. A general, specific and practical examination of the ASME Boiler and Pressure Vessel Code covering section NF and project procedures was developed and administered to inspection personnel to determine any areas which might require additional training.

Hanger crews have been established which include a Foreman and a Hanger Engineer.

Subsequent to fit-up and tacking, but prior to welding, the Area Hanger Engineer is required to assure that the location is correct, that proper material has been used, and that the supports are correctly orientated.

Supports in all areas have been re-inspected and deficiencies noted have been incorporated into nonconformance reports which have been forwarded to UE&C for disposition.

Subsequent to UE&C disposition of outstanding NCR's, expected by December 31, 1980, any necessary rework will be promptly accomplished.

NRC Notice of Violation: (80-10-01) 10 CFR 50, Appendix B, Criterion VII states, in part, that: " Measures shall be established to assure that purchased material. . . conform (s) to the pro-curement documents."

The Seabrook Station PSAR for Units 1 and 2 states, in part, in paragraph 17.1.7 that: "Each organization purchasing material. . covered by this (QA) program is required to establish measures to provide assurance that they conform to procurement documents."

United Engineers and Constructors (UE&C) Procedure QAS-1, Revision 7, states, in part, in paragraph 4.5 that each " Contractor shall have. . . measures to assure that purchased items.... conform to the requirements of the procurement documents;" while UE&C Specification 006-12-1, Revision 6, states, in part, in paragraph 3.3.1 that "All structural and miscellaneous steel design, fab-rication and erection shall be in accordance with AISC Manual of Steel Con-struction...."

, U.S. NuclCcr Regulatory Commiccion Page 3 SBN-141 The AISC Manual of Steel Construction, Seventh Edition, discusses the allowable methods for fabricating holes in structural steel, both in general and specifically for high-strength bolted connections. It also defines and prescribes the use of milled surfaces on structural steel bearing contact areas. No mention is made of flame cutting as an accept-able alternative for bolt hole fabrication.

Contrary to the above, on August 15, 1980, a slotted hole in a clip angle attaching a beam to a supporting wall embed for a completed high-strength bolted, bearing connection was discovered to have been flame cut. Subsequent investigation revealed the presence of additional flame cut holes in safety-related structural steel and evidence thatithis condition has existed since fabrication by the vendor.

Response

Corrective Action Taken and Results Achieved The flame cut structural steel was incorporated by Perini into their Non-Conformance Report No. 1047 which was transmitted to UE&C for an engineerb g evaluation. A re-inspection by Perini had determined that the flame-cutting had occurred at the material suppliers facility.

Although punching and drilling are the preferred methods, it is industry's practice to flame cut slotted holes for structural applications followed by dressing the cut surfaces. Based upon observations of the structural steel at the site it appears unlikely that any are cutting was used since it would produce a much rougher surface than flame cutting. AISC states that thermal cutting of edges which will be subjected to substantial stress shall be reasonably free from notchesor go u ges; occassional notches or gouges not more than 3/16 inch deep are permitted. Notches or gouges greater than 3/16 inch that remain from cutting must be removed by grinding. UE&C Specification 9763-WS-3 " Welding and NDE Requirements for Structural Steel" states that if flame cutting is employed all slag and oxide must be removed from the cut surface. In addition, preheating is required. AWS Dl.1 permits flame cutting of edges but does not make post grinding mandatory although it requires the edges to meet roughness requirements.

UE&C conducted laboratory tests of material supplied by Lyons Iron Works.

The severe tests disclosed that although mechanical tests of specimens having the original flame cut surfaces disclosed a loss in ductility (12-18% vs. 31%

elongation) , tensile and yield strength values were quite satisfactory.

The present suppliers, Cives, employs punching or flame cutting, but follows the latter with grinding to renove serrations.

Based upon the engineering evaluation it has been determined that flame cutting will not impair the integrity of the bolted connection and that no corrective action to the structural steel in question is necessary.

U.S. Nuclear Regulatory Commission Page 4 SBN-141 UE&C has issued instructions to vendor surveillance and site receiving inspection personnel requiring that they check all flame cut structural i

steel to verify that the flame cut areas have been subsequently ground 1

to remove serrations and eliminate any high hardness areas.

Full compliance was achieved on November 18, 1980.

Very truly yours, "r

John DeVincentis Project Manager JDV:t.n ,

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