ML20004B966

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Testimony on Contention 9,discussing Implementation of Qa/Qc Program at Facility During Const & Preoperational Testing.Reasonable Assurance That Equipment & Matls Were Procured Per Design Specs.Prof Qualifications Encl
ML20004B966
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 05/28/1981
From: Brownlee V, Girard E, Skolds J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20004B928 List:
References
NUDOCS 8106010363
Download: ML20004B966 (74)


Text

UfITED STATES OF AMERICA iUCLEAR REGULATO.'.Y C0:GilSSIO.

DEFORE THE ATO':IC S/FETY A!!D LICE!:Sif:G BOARD

(-

In the Matter of

)

)

SOUTH CAF0LiliA ELECTRIC & GAS COMPAi;Y)

Docket i;o. 50-395

)

Virgil C. Sumner tiuclear Statien,

)

Unit 1)

)

TESTJ:"J Y OF IF.C OFFICE CF li:SPECTIO:: A* D E:~r' 7CE".~NT O': CO:;TE:.TIO: 9+

Q. 1.

Would each of the panel rembers please introduce themselves by stating their names, erplcyrent affiliation, and professional qualifications.

A.

(Mr. Brounlee). My na e is Virgil L. Brownlee.

I an er.cle;..: Ly the U.S. Iuclear Regulatory Comis.;icn as a project inwector in the Region II, Office of Inspection and Enforcement. A copy of rij ;a c -

fessional qualifications is attached (Mr. Girard).

My name is Ece:atd !:. Girsef.

I an empleyvi N tt U.S. I:uclear Regulatory Commission as a reactor inspecter in the Reg.on II, Office of Inspection and Enforcercnt.

A cop,t of r./ Vc -

fessienti qualifications is attached.

(Mr. Skolds). My nane is John L. Skolds.

I am employed by the U.S.

tJuclear Regulatory Comission as a resident inspector in the Ecgion II, Office of Inspection and Enforcement.

A copy of ry professional qualifications is attached.

o Contention 9 states:

The quality contr ol of tre S u-e r p h r.t is substantia'13 tc ' c:

V,. :: m c.rds as evidenced by consistently substandard vorkmanship, in several aspocts, during the construction of the plant.

I lHIS DOCUMENT CONTAINS POOR QUAUTY PAGES 81000103 N

I-J Q. 2.

Could each of the panel members describe their. responsibilities with respect to the Summer operating license proceeding.

A.' (Mr. Brownlee).

I am '.he assigned project inspector for the V.C. Summer plant. My duties as a project inspector fcr the past 12 years have included verification of implenentation of quality assurance programs and inspection of design, procurement and 4

1 inspection of nuclear power plants.

(Mr. Girard).

I am a metallurgical engineer assigned as a reactor inspector to inspect welding and nondestructive examination i

activities.

I am preparr

'o address the areas of welding, non-destructive examination activities, pre-service inspection and certain allegations of construction shortcomings investigated by i

the office in 1979.

(Mr. Skolds).

I have been assigned as the senior resident inspectcr at the V.C. Summer plant since 1979. My duties have included review of the pre-operational test program, quality assurance, emergency planning, operations, maintenance and administrative procedures.

1 i

Q. 3.

Has the panel selected a lead member for purposes of the Office of I&E testimony on contention 9?

A.

(Mr. Brownlec )

Yes.

I am.

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. Q. 4.

Could you briefly describe the nature of this testimony?

A.

(Mr. Bro',:nlee). The testimony which follows discusses the i

implementation of the quality assurance / quality control progran at the Summer plant during constructicn and pre-operational testing, and addresses the several concerns rcised in testimony elicited on behalf of the Intervenor l

fron several construction workers on this matter at a deposition held on August 2, 1970.

Discussion of the implementation of the QA/QC progran is done primarily in terms of the inspection history compiled by the Office of Inspection and Enforcement (OIE) for the Surmer plant during construction.

I Q. 5.

Could you or anyone on the panel briefly describe the scope of the Office's construction inspection program?

A.

(Mr. Cn unlee).

Yes, t

The objective of the NRC programmatic constructicr. inspection pregran is to deterair.e, through inspection utilizing sampling techniques, that the nuclear facility is being constructed in acccrdance with applicable i

l regulations and commitments made by the applicant. A major segment of I

l this program is to determine, in conjunction with NRR, that the QA/Q:

prograr as implemented is effective and provides assurance that the safety and welfare of the public are protected.

This objective was achieved at V. C. Summer by examination of management controls, i

including quality assurance and quality centrei manual s, work pre-cedures, records and documents and by the observation of work in progress.

Work in progress was inspected for cuality workmansnip, conformance to control procedures and conformance to codes. Records were examined to verify that purchased materials ans equipment cet quality standards and that quality control inspections were performed throughout construction.

Q. 6.

When did the f;RC construction inspection begin.

A.

(Mr. Brownlee). May, 1971.

1 Q. 7.

Could someone on the pancl sumarize the level of construction inspection effort expended since the beginning.

A.

(Mr. Brorenlee).

Yes.

i From the initial inspection of V. C. Summer in May 1971 until !1 arch 31, i

1951, the NRC has performed one hundred thirty (130) construction i

inspections in accordance with internal inspection procedures and instructions.

To accomplish this program, experienced inspectors spent five hundred and one (501) man days at the construction site, contractor offices, and vendor manufacturing facilities. Also, a corporate level QA inspection of SCE&G (Columbia) and DCC (Greenville) has been j

perforced to assure establishment and iriplementation of QA programs.

Q. 8.

Could soncone on the panel define the nature of enforcement actions utilized by the l:RC to ensure compliance with regulatory re:pirements?

A. (!:r. Brownlee).

Yes.

Enforcement actions are utilized oy NRC to ensure compliance witn regulate J-requirements. These are legally binding recuirenents or prohibitions imposed : ;-

licensee via the Code of Fede al Regulatiens permits e-license.

Failure :-

1 comply with these requirtnents (rcr.conplian:t) is the basis for enfortecc-:

i action.

To provide a measure of perspective, noncompliance items are categori:c:

into three severity levels; vicictions, inf ra:tions, and deficierries.1/

1] These are items described in Attachnent A to this testirony.

1

0. 9.

Could someone on the panel summarize the items of noncompliance identified at the Summer station throughout its construction?

A.

(Mr. Brownlee).

Yes.

Construction inspections and the related items of noncompliance are tabulated in the Summer Inspection Chronology (Attachment B) and summarized below. The classification of these items utilizing the following definitions of violations, infractions, deficiencies and deviations indicates that there were no violations, twenty-two (22) infractions, eleven (11) deficiencies, and two (2) deviations ( a failure to meet an FSAR commitment, for example, Reg. Guides, codes, standards).

(i) 1;eldina anc i;ondestructive Examination (';DE) - Eleven (11) items of nuncompliance were identified in welding and I;DE programs. Of these 1

seven (7) items were identified in the welding program related to electrode control, procedure requirements and compliance, quality control surveillance, and weld data.

Four (4) items identified in the t;DE program were related to liquid penetrant, magnetic particle, and radiographic inspection of welds.

(ii)

St. ports and Mechanical Eauioment - Seven (7) items of non-ccmpliance were identified in the piping, supports and nechanical equipment programs. Of these, four (4) items i.ere identified ir the storage of safety-related equipment.

Two (2) itens were related to the installation of a snubber and hanger.

Cne (1) it r was related to the sealing and capping of piping and co.ponents.

8 0

a -

i (iii) Vendor Control - Three (3) items of noncompliance were identified as a result of inspection of the licensee's vendor control program.

Two (2) of these items were identified in vendor material control and material certifications. One (1) of these items was identified in the +o. dor qualification of personnel and procedures for clad stripping.

l (iv)' 04 Program - Seven (7) items of noncompliance were identified as a result of inspection of the licensee's QA program areas. These l

items were identified with regard to procedure noncompliance on tape, hacksaws, cadwelding, calibration, drawing control, and inspection records.

i t

4 (v) Miscellaneous - Five (5) items of noncompliance and two (2) deviaticns were identified in the area of environrental control, concrete curing, housekeeping and Part 21. Two (2) of these items of non-compliance and one (1) deviation were identified in hydrologic r.onitoring i

and erosion control. One (1) item of noncompliance was identified r

involving curing of concrete for an auxiliary building slab, one (1) item of noncompliance was identified in reactor vessel house-keeping, one (1) item of noncompliance-was identified regarding Part 21 procedures, and one (1) deviation was relative to fire pump installation, l

l

i

' Q. 10. Could someone on the panel provide a sumary analysis of the significance of these items of noncompliance?

r A.

(Mr. Brownle4. Yes.

An aralysis of the thirty -three (33) items of noncompliance and two (2) ceviations identified during the construction of V. C. Summer indicates that twenty-twa (22) were identified as infractions. inat is, if trey -

had remained uncorrected they could have resulted in the failure of a seismic Category 1 system or structure in such a manner that the sa'Ety i

f un:ticr. or ir.tegrity would be impaired.

E> cept in :ne :ase c' :ce area, these noncompliances were random in nature and were not ir,dicative of SCE&G's management nor inadequacies in the CA program.

To:

i non:oTpliances were written regarding the control of duct tape but SCESG

ool as:itional a:tions 'to avoid recurren:e of the prcolem.

The safety significance of these items was individually analyzed by South Carolina Electric and Gas (SCE&G) and, in turn, by the NRC.

In each case, SCE&G identified the corrective actions and measures taken to i

preclu::e recurrence. The corrective actions were confirred thrc.;n *E insee:tions.

Of the items identified, the welding orcble:rs with the

ri ary icop nelding are icer.tified as the most signifi
a.: i r T a 'er to the safety of the plant. These items have been cc~t:ted 3:::':'.cg to approved engineering procedures and are consicerec te :e a::i;;;:le for the intended service.

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Q. 11 Could son;eone on the panel surn.arize the office's investigation of the worker allegations raised at the August 2, 1978 deposition before the Licensing Coard?

A.

(P.r. Crov nlee)

Yes.

' Allegations to the Licensing Coard on construction activities z:

Virgil C. Summer Nuclear Piant were identified in a prehearing conference and witness depositiens on August 2, 197S. The Office of Inspection and Enforcement (OIE) Region II received the transcripts a 'd identified specific areas of concern which may have safet) significance.

Ine areas of concern, which were identified and investigated, were as fcilows:

(witnesses cnd transcri;t pages are ncted).

a.

Prehearing Conference (D. Delerch) t Splicing of electrical cable was being performed within the containment. (page 262) l b.

Witness No.1 Deposition (C. G. Wnisennar.t) i l

l A prcbier exd stec with repeated repairs to a weid (F..-f er 150 SW-02). (Pages 10, 34, and 83) i

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Witt ns t.. 2 Deposition (S. O. Fort)

(1) F e c v:, wcil ccroon steel piping was being welced witneut proper ;. reheat. (Pages 4-12)

(2)- A pecHcn with bad E-7018 electrodes existed in that electrodes darker in color did not weld properly.

(:'a g e 12)

(3) './< W e s could move quali ficatier. test assenly dei g welding centrary to ASME Code requireecr.ts of r find position (Page 42)

(d) Witr.e ss N. 3 Denosition (M. Lowe)

Ne spt:'fi: areas of concern having safety signi#icar:t

v. e r s ider.tified for investigation. General concerns were o p ::-sed on co-crete pours during rain, wooden forns, ar.d reba r.

(Paa r 21, 22, 23)

(e) Vitness t.c. 4 Dc.;osition (R. Hinson)

(1)

Circa'a:ing water punp capacity being ir:airt c e tc a th et foot s;: ace behind the intale anc e os' itself

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(2) Service water pumps were very much distorted and out of level af ter being in place for two or three months.

(Pages 12-13,19-20)

(3)

Scme safety-related welds were not x-rayed. (Fcges 13, 15,27-28,34-35)

(4) Not using stainless steel shims on safety-related eouip ent after being instructed to do so.

(Pages 15-17,21,23-24,47)

(5) Putting cencrete grout ir. the cracks to maintain the structural integrity of the pump motor building. (Page 36) l l

(6) Workers not trainec in methods to ccintact NRC on cuality I

problems. (Pages 42, 43) f.

Witness No. 5 Deposition (E. Laitala) l i

No specific areas of concer.1 having safety significance were identified for investigation.

I Q. 12 Could you describe the nature and results of these investigations?

A.

Yes.

During the period of August 1978 through April 1079, nine inspectors investigated the various areas of concern icentified to the Hearing B:.ard. Inspection results were de:urented ir !E Re;:-:

Nos. 50-395/75-16, 50-395/78-17, 50-395/78-25, 50-395/7E-26, 50-395/79-01, 50-395/79-05, 50-395/79-06 and 50-395/79-12. Each of the areas of concern were investigated and findings were documented in the inspection reports or Region II memoranda.

The detailed results of the inspections are summarized in Attachment C hereto.

Q. 13.

Did the investigation reveal any items of noncomplian:,c A.

No.

Q. 14.

At the prehearing conference held on April 7-8, 1921, Intervener Bursey mentioned a former worker at the plant site had made certain j

allegations of construction shortcomings to the Region II Office (Tr. 432) which the Staff was able to ascertain forced the subject of an investigation conducted by the Region in 1979 (Tr. 625-26).

Could someone on the panel please describe the background of this matter and the nature of the allegations involved?

l A.

(Mr. Girard).

Yes.

An individual contacted the NRC Region II office er Au.:ust 3:.

1979, expressing his concern with regard to welding and inspectien i

l I

practices and the use of drugs and liquor at South Carolina Electri: and Gas Company's (SCE&G) Virgil C.

Su mer Nuclear Station. Represertatives of Region II subsequently met with the individual to discuss his concerns on September 10, 1979.

Telepn:ne conversttic.ns were hela with the incisic;hi to furtner discuss his concern: on 0::cber 3D and 3; and hcraer 7. 9, 20 and 22,1979; and on January 23 and July 14, 1930. As a result, an investigation was initiated into the followine allegations:

a.

QC inspe:ters were not adequately trcined to inspect fillet weld sizes en piping se:Iet wclds.

As a consequence r:ny undersize socket welas were acceptea in safety-related piping.

b.

Carbon steel rotary wire brushes were often used on stainless steel piping, as evider.ced by the appeara.:e of rust on the piping. This violates licensee prc:edural requirements whi:h specify the use of stainless steel wire brusnes en stcirless steel piping.

c.

QC inspectors in the Fab Shop scretimes signed off ins;e:-

tions of welds before the welds were perforced.

(This took place in the Fab Shop area).

Three inspectors were narce. one of whom was icentified as the

14 main offender, Specific examples of items on which inspections were bypassed could not be identified.

d.

Q: inspectors were not adecuately trained to parfor ni;b-low cnecks on butt weld t it-ups, it was common practice wner cutt weld fit up Drct.ler.'s witt nigh-low cb' cks were er.ce;nteer tc-relieve high creas by the grinding away (where accessible ir 12-inch diaieter and larger pipe) the _interi_cr cf tne pipe surf ace so that an " apparent" acceptable high-low check would result.

Minimum wall thickne:s limits were frequer:1 n: t met. Exterior misalignment continued to bc visible on sucn pipe.

Potential examples were icentified by tra a'le;e as bEing in the Service Water (3W) intake pipe anc in [: ;O'$rt Cooling (CC) system pipe at the 412 elevatier ir the Intermediate (IM) Building.

e.

High-low code requirements on the butt welcs were violated en some difficult to reach welds with the knowledge of both the QC inspector and the welcing superviscr ( speci fic e ra p'.es could not be identified).

f.

Non-ccce pipin; was ucgraded to ( ASME Sectier. I':) Clas s I with no evicence of proper testing and cocLme-tE on.

Ine alleger recalls that the Class 1 and non-coce ;ipe dif'et ed visibly su dace finis *.

The Class 1 rirt var " m - c",

wnile tne non-coce pipe hao a " mill skin" er it. Tre clie;e-believes the heat number recorded on the documentation v.as a

carryover frot previously used Class I pipe rather than the actuel hect nu.ber on the pipe being substituted. The pipe may still carry its true heat number. He further stated that the pipe was 2" Scn 160.

He thought it was used in the RC system about June or July 197e. Aoout 15 or 20 pie:es were used.

g.

An undersize fitting was installed in safety-related piping.

The fitting was identified as a 6,000 lb. fitting, but based tn its size relative to the piping in which it was being installed, it appeared to the alleger to be a 3,000 lb.

fitting.

The alleger stated that the fitting was a 2x1 reducer insert and that be believed it was installed in the RC, CS or SI system h.

Sometimes pipe was not properly withdrawn from sockets prior to making socket welds.

The frequency of lack of proper f

withdrawal in seeket welds from the Fab Shop should be 25% or less. Pipe not being cut sufficiently scuare contributed to i

this problem.

The alleger could not identify specific examples.

i.

QC inspectors and others use alechol and drugs or, the job.

j.

Service water line piping was damaged (arc-burns) while j

cutting lugs on nearby items. The damaged area was ground, welded, and ground again to. hide the damage.

The QC ir.spectors cid not know of the work and did not perforr. the recuired.16spections. This piping is inaccessioit ncs cecause it is buried.

L.

The alleger wa: performing a qualification test by weldirg a j

" Carpenter 20" stainless steel test sample. The test sampie was st.bmitted and accepted by radiographic examination even though the alleger noted cracking in tre test weld. This was 4

j nct for safety related welding certificati:r.

Tne alieger speculated that this might also have occurred ir, cualifi-4 cation testing for safety-related welding. He die nct know of 4

i any such cases however, i

1.

Carben steel plates in the incore pit liner were imprcperly j

installed with backing strip clearance in excess of the required 1/16 inch. The backing strips were not close enough to the veritical welds for the first sections put in at the f

bottom. No backing strips were used on the horizontal weids.

i m.

W ics on the carbon steel plates in the lir.er cf the incere i

j pit in some instances entrapped substantial amour,ts of slag i

yet were subsecuently ultrasonically tested at a:ceo:Ebie.

Tne alleger is concerned that the nondestructive test i

r s

o

-17 examiners were either improperly trained or falsified their findings.

Welcers not prc;;erly qualified or certified perforv.ed welcing n.

on the incore pit liner curing late 1976 or early 1977. One of these welders also weic:-d stainless steel at unspecified locations in the IM building while uncertifiec. Tne inci-viduals were not identified as performing these weids in the records.

o.

Welders sometimes violated welding requirerer.ts (on socket welds) to expedite their work Examples of violaticre included single past weldi and undersized fillets en societ welds performed in the Fab Shop.

The welding superviser condoned this practice as a means of exnediting work On occasior, workers would not be permitted to leave the jeb urtil assigned work was complete.

I In several instances where the alleger provided speci#ic informatior related to inadecuate workmanship, he indicated that l

l this knowledge was based on the fact that he had persona'ly performed the inade::uate work

f !

o Q. 15 Could you describe the nature of the investigation conducted i '

into these allegations?

j A.

Yes.

The investigation at the Summer site commenced with the Septerrber 30, 1979 neeting hold with the alleger to discuss his concerns. Durir.; the i

J pericd of October 29 thru December 19, 1979, the investicaters ir.:er-4 vie,eed 33 individuals currently or forraerly employed at the site.

In

-addition to conducting interviews, the investigators revie <ed pro-cedures and recoros and examined installed piping.

f The primary phase of the investigation was concludec on De:ercer 19, 1979.with a reeting of NRC and the Summer management du*ing whict

ne preliminary results of the investigation were outlined. TN results of 3

this phase of the investigation were documented in IE Report SC-395/79--

35.

The status of many of the allegations remained erres:lvsf.

Sufficient justification for. concern was established, hciever, to l

identify a number of items requiring further examinatier. and revier, the investigation was continued within NRC Region 'II's' normal inspectior.

I program.

The licensee cooperated in providing data and engineering -

evaluations for examination arid review by the NRC for the unresolved.

f I

items. Inspection results for the remaining items were documented in IE i

{-

Report Nos. 50-395/80-03, 50-395/80-07, 50-305/80-12, 50-395,'80-17, 50-i 395/80-20, 50-395/80-30, 50-395/80-39, and 50-395/C1-06.

4 s

4

-m Q. 16. Could you state any findings and conclusions reached as a result of this investigation?

A.

Yes.

The findings were regar to the allegations were as follows:

Item Finding a.

Allegation confirmed by direct observation.

Extensive reinspection and repair was required for correc-tion.

b.

Alleged actions were determined not to have safety significance.

c.

Allegation confirnied in interviews with craf t.

Extensive reinspection and evaluation were provided to assure the adequacy of previously accepted work. Allegation was confirmed to have no safety significance.

d.

Allegation confirmed by examinations. Engineering evaluation of sampling data indicated no repairs would be required.

e.

Not specifically confirmed but related to (d.)

The engineering evaluation acclied to (d.)

was consicered applicable to this item.

. f.

One of 16 individuals interviewed confirmed this allegation. It could not be confirmed by direct cbsc vrtion.

If correct, the allegation is not considered to be a significant safety concern.

g.

Allegation.cor. firmed by nondestructive examinatior and documentation review.

Measures were established to assure identification and-evaluation of ' this and similar items te determine the need for replacement.

h.

Allegation confirmed by interviews with craft.

Engir. sering evaluation of radicgraphic data from a scmple ci the subject items, design data and historical exoerierce v.i -

such welds indicated the condition present would provide to significant safety concern.

i.

Allegation confirmed by licensee management and craft. Not considered widespread. No evidence was found to indicate that any safety-related work had been sigr.ificar. 13 l

affected.

j.

Could not be confirmed or denied.. An engineerir.g evaluation, taking into account design cata on the su:fect piping, indicates that the alleged actions would not crovice significant 53#ety cencern.

4 23 k.

' Based on extensive NRC inspection in this area, the

. alleged action was not considered to ' provide a significant i

safety concern.

1.

Based on an engineering evaluation of the cesign, the alleged actions are not consic'ered to have safety

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l significance.

i m.

Same as (1).

~

I n.

Same as (1).

(This allegation was conf.irmed in.

part, by tne licensee frcm their data),

o o.

Confirmed in interviews with craft. Engineering i

i evaluation of consequences of alleged actions, including data from examination of sample welds and histroical cata ar.d I

information frcm interviews with craft, indicate the alleged I

actions would not provide a significant safety concern.

I l

h Two items of noncompliance were identified.

These specifically l

addressed items (a) and (d).

No deviations were identified..The cause and corrective actions taken by the licensee relative to the items i

of noncompliance were considered applicable to the other confirmed-allegations with safety significance. NRC Region II is satisfied that the licensee has taken aceouate corrective action relative to the safety 1

f significant confirmed allegations described above.

i i

. Q. 17.

In light of the above testimony, could someone on the panel summarize the offices position on the Applicant's overall quality assurance and quality control performance during construction?

A.,

(Mr. Brownlee).

Yes.

Based upon the inspections conducted to date in accordance with the NRC construction inspection program, which included selective examination

.of procedures and representative records, interviews with craftsmen and site personnel, and indepth observations by the inspectors, there is reasonable assurance that the equipment and materials were procured pur-suant to design specifications.

V. C. ' summer has been constructed and the equipment installed in accordance with FSAR commitments and the plant can be operated safely without danger to the health and safety of the public.

The licensee has demonstrated its commitment to 0A at the V. C. Summer Nuclear Plant by expanding its involvement in the construct-ion program.

This included taking corrective actions on identified deficiencies and by staffing a group of construction engineers and QC inspectors at the constructior. site for the vendor inspection program.

A-1 ATTACHMENT A DEFINITION OF ITEMS OF NONC0"?LIANCE a.

Violation A violation is an item of noncompliance of the type listed below, or an item of noncompliance (1) which has caused, contributed to or aggravated an incident of the type listed below, or (2) which has a. substantial potential for causing, contributing to, or aggravating such an incident or occurrence; e.g., a situation where the preventive capability or controls were removed, or otherwise not employed, thus creating a substantial potential for an incident or occurrence with actual or potential consequences of the type listed below.

(1) Exposure of an individual.in excess of the radiation dose specified in 10 CFR 20.403(b) or exposure of a group of individuals resulting in each individual receiving a radiation dose which exceeds the limits of 10 CFR 20.101 and a total dose which exceeds 25 man-rems for the group.

(2) Radiation levels in unrestricted areas which greatly exceed the regulatory limits.

(3) Release of radioactive materials in amounts which.

exceed the limits for concentrations of radioactive materials in effluents specified in the regulations.

(4) Fabrication, construction, testing or operation of a Seismic Category I system or structure in such a manner that the safety function or integrity is lost.

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10 CFR 20.101 and a total dose which excee:s 25 man-rems foi he grcup.

t (2) haciation levels in unrestricted areas which ' greatly exceed tr.e regiatory limits.

I (3)

Release of radioactive' materials in amounts which exceed the limits 'for concentrations of radioactive materials in effluents specified in'tne regulations.

i (4)

Fabrication, construction, testing on operation of a Seismic Category I sy stert or structure in such ' a manner that the safety function er integrity is lost.

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A-3 (5) The failure to properly function or loss of integrity of a Seismic' Category I system, or structure; or other component, system, or structure with a safety or consecuences-limiting function.

(6) Exceeding a safety limit as defined in technical specifications associated with f acility licensee.

(7) Diversion or thef t of plutonium, uranium 233, or uranium enriched isotope U-235.

(8) All security barriers or controls removed or inoperative.

(9) A breakdown in management or procedural controls as evidenced by significant items of noncompliance in several areas of the QA crieria and license requirements.

b.

Infractions An infraction is an item of noncompliance of the type listed below, or an item of noncompliance (1) which resulted in a reduction of p-eventive capability below requirements but redundant controls precluded an item of noncompliance of the violation category or (2) which caused, contributed to or aggravated such an incident or occurrence, e.g., the preventive cap-1 er,

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A-4 ability or controls were removed or otherwise not employed and there was surstantial potential for an incident or occurrence with actual or potential consequences of the type listed below:

(1) Exposure of an individual or groups of individuals to radiatier in excess of permissible limits but less than the values in 10 CFR 20.403.

(2) Release of radioactive materials in concentrations or rates which exceed permissible limits.

(3) Failure to function or loss of integrity of a Seis-ic Category I system or structure, or other component, system, or structure with a safety or consequences liiniting function during testing; or failure to reet surveillance frequencies.

(4) Fabrication, construction, testing or operation of a Seismic Category I system or structure in such a manner that the safety function or integrity is impaired.

(5) Exceeding limiting condition for operation.

(6)

Inadequate managtment or procedural controls.

(7) Security degraded or impaired by removal or impairment of a recuired barrier or cor. trol but a redundant system operative.

A-5

~

(8) Exceeding limits or limiting conditions for ~ operation in licenses,'

technical specifications; guides, codes, cr standards which are imposed for the purposes of minimizing adverse environmental impact.

I c.

Deficienc_y 4

A ceficiency is an item of noncompliance in which the threat to the health, safety, or interest of the public or in the cc mon defense and security is remote and no undue expenditure of time or resources to implement corrective action is required. Deficiencies include such items as ncnccmpliance with records, posting, or labeling requirements which are not serious enough to amount to infractions, r

(

I I

l

s B-2 5:-395/73-1 1/24-25/73 Swan QA Audit None McFariand 1

i l

5C-395f73-2 5/10-11/73 McFarland Licensee Audit None of A/E (Giloert) 1 i

50-39;/73-3' 5/16-17/73 McFarland Licensee Audit of None i

CBI Nuclear 4

50-395/73-4 7.'31 -

McFarland QA Audit Nere S/2/73 5E-395>73-5 9'4-6<73 M:Farland Construction /QA None

?

Swan h

i t

i' 50-395/73-6 9/24-26/73 McFarland Licensee Audit of Ncne NSSS (Westinghouse) l l

50-395,73-7 11,29-30/73 McFarland Construction /QA N:ne 50-395r74-1 1/E-9/74 Olier Vendor / Chicago N:ne Bridge and Iron Works 5 -3s5 74-2 1/IC-17774 McFarland Licensee Audit of f.cr e A/E (Gilbert) r-g9e-e-.

y--9

,--te--ypqi w_,q.-

4

_s g4g 9 7 mg p.-

. - -ww

  1. w,9 y y

,-,-w-q=

y.

ym mu -w 9 y9ewiwq -w w-*

w wp9.--qwg--.-

y pgg-usyg g y e y-g-q T-r,W4

(

B-3 SC-395!/a-3 2/5-7/74 Oller Vendor / Westing-None rouse t

5f;-395.74-4 2/26-27/74 Oiler-Vendor /CBI (74-4-Al huclear (II)) Ciac Strip-Ba:t Procedure i

Qualifica-tion 50-395/74-5 2/26-27/74 Swan Construction /QA/-

None QC i

50-395/74-6 4/2-4/74 McFarland Licensee Audit None of NSSS (Westing-1 house) l l

(

l 50-395/74-7 4/5/74 Oller Vendor / Westing-None house i

I l

50-395774-8 9/20-13/74 McFarland Construction /QA/

None 0

50-395/74-9 10/16-18/74 McFarland C:nstruction/CA N;ne Foster

-.. ~..

B-4 4

i 50-395/74-10 10/22-25/74 Swan Environmental None Cunningham Program, Concrete i

and Foundations

)

5i-395 75-1 1/29-31/75 McFarland Construction QA/

(75-1-Al Wright QC (III)) Curinc Deficiency i

50-395/75-2 5/21-22/75 Swan Construction QA/

None QC i

I 30-395/75-3 7'15-17/75 McFarland Construction QA None 50-395/75-4 8/26-28/75 McFarland Construction QA/

(75-4-Al f

Porter QC (II))

i Swan Welcing Electrode Control 50-395/75-5 10'9-10/75 Cunningham Envi rontrental None Protection F

l t

i i

. ~..

6 a

B-5 50-395/75 12/2-4/75 McFarland Construction QA/

(75-6-Al 5 san QC (III))

of Inspections curing Storage SC-395/76-1 1/29-30/76 McFarland Construction QA/QC, hone Wright

Concrete, Foundations, Batch Plant-50-395/76-2 2/12-13/76 McFarland Construction QA/

None-Wright QC, Concrete Beratan 50-395/76-3 3/30 -

McFarland Construction QA/

(76-3-Al 4/2/76 Wright QC, Concrete (III))-

Cad,,elding Failure to f

s Follow Pro:edure l

50-395/76-4 5/4-7/76 McFarland Const-uction QA/

N o r.e Porter QC. Welding F

1

?

i 4

l l

t

r i

B-6 l

50-395/76-5 6/22-25/76 McFarland Construction QA/

None Wright QC, Welding, Dams, Blake Contair. ment, RV Vallish and Co ponents SC-395 76-6 7/29-30/76 McFarland Construction QA/

None Porter OC. Welding i

1 5C-395/76-7 S/31 -

McFarland

' Construction 0A/

(76-7-Al 9/3/76 Porter QC, Wsiding, (II))

Wright Dams Materials Certifications 50-395/76-S 11/30 -

McFarland Construction 0A/

None 12/3/76 Blake OC, Welding i

l E0-395/76-9 12/8-10, 13/76 Cunningham Environmental (76-9-Al I

Protection (III))

l.

Hy:rclogi:

Monitoring l

50 3f5/76-10 12/14-17/76 Soan Construction 0A/

Nore c

l l

QC, Lakes, Dams, Canals, and Centainrent i

I l

B-7 50-395<77-1 2/28 -

Blake Censt-uction QA/

(77-1-Al 3/2/77 QC, Welding (II))

Pipe Welding QC_

j Surveillance procedure i

I 50-395 77-2 4/25-27/77 Crowley Construction None QA/QC, Welding r

50-395'77-3 6/02-24/77 Cochrar Constructier. QA/

None McFarland QC, Principal Inspector Turnover 50-395/77-4 7/5-7/77 Swan Containment None Tendons, Concrete i

J 50-395/77-5 8/9-12/77 Porter Construction (77-5NI)

~

Cochran QA/QC, Welding Inadeouate McFarland SR Tanks Control /

Inspection of Crowley Purchase 4

Material-

B-8 (77-5N1)

Irace uate Inspe: tion of Complete Cerronents 5C-295<77-6 9/19-20/77 Hunt Construction None OA/QC, Electrical 5C-395'77-7 10."-6/77 Porter Construction QA/

Nere QC, Welding 50-296/77-E

0/::-13<77 Coenran Construction None Soan QA/QC, Contain-Vallish ment Ring Girder, Service Water Intake 5C-395 77-9 10/27/77 Cc:nran Vendor /D.G.

Nore I

0'Brien Inc.

i 1

5C-395,77-10 11/14-17/77 Cochran Construction QA/

None 1

QC l

r l

'B-9 50-395/77-11 11/29 -

Cunningham Environmental (77-11) 12/2/77 Prote: tion-Hycrole-gic-Monitoring

-(77-11)

Ceviation Land' Ma r.s g s.T e n t.

50-395/77-12 12/19-22/77 Crowley Construction.

None QA/QC,. Welding-50-395/78-1 1/4-6/78 Cochran Construction-QA/

None QC, 10 CFR

'Part 21 50-395/78-2 2/27 -

Cochran Construction (78-02-1) 3/1/78 Foster QA/QC, Welding Use of Murphy.

Hacksaw on Stainless Steel 50-395/78-3 3/20-21/7E Swan Construction None Gibbons QA/QC, Fire Protection, Con: ete

B-10 50-395/7E-4 4/11-13/78 Cochran Construction (73-04-01)

Blake QA/QC, Welding Rejectacle Economos Radio-Annast

.grapns 5';-3' 5 7E-5 5/15-13/78 Cochran Construction (72-C5-02)

Burdette-QA/QC, RV Inter-Storage of Ang nals RV Compton Internals 50-395/7E-6 5/17-IS/78 Jape Operations Inspection Lewis Meeting

- C-3 95/78-7 5/23-24/78 Cunningham Environmental tJone Protection 50-395/78-8 5/22-25/78 Blake Construction (78-08-01)

QA/QC, Welding Storage of i

Safety-Relatec Ecaic: rent i

i 50-305 75-9 6/12-15/78 Ang Construction t one Safen-Related i

Bryant Components, i

Allegations on Weld Cracking L

B-10A 1

50-395/78-10 6/21-23/78 Cochran Inspector (78-10-02)

Porter Turrover Welding 50-395/78-11 6/27-29/78 VanDoorn

Piping, f;one Welding 50-395/78-12 7/11-13/78 Compton Containment, (78-12-01)

Economos Pipe Supports Hangar Welding and Restraints, (78-12-02)

Piping Code Requirc: cents (78-12-03)

Storage 50-395/78-13 7/25-27/78 Blake

Piping, i;one Per.e tration Gelding 50-395/78-14 7/31-8/2/78 Porter Piping, Bulletins, f;one Thomas Reporting, Circulars 50-395/78-15 8/8-11/78 VanDoorn Piping (78-15-02) l l

Conlon Tape Girard 50-395/78-16 8/21-24/78 Crowley Containment, (78-16-01)

Piping failure to fellow l

irspecticn and ualdir.;

pro:edures

B-11 50-395/78-17 8/29-31/78 Gibbons Construction t;one QA/Q:, Electrical 5:.'95<75-18 9/5-E/7s Modenos Construction (75-li-C1)

Ang QA/QC, Mechanical

- o ; :- s,. r e p -

ing SC-395/78-19 Operation Inspec-tion 50-395/7E-20 9/21-22/78 Burdette Construction, t;one Co:hran Inspector Turnover 50-395/78-21 Operations Inspec-tion 50-39E'78-22 10/3-5/78 Vallish Construction None l

QA/QC, Safety-Rela ed Structures, Service Water Intake Components

' - 3. 5. 7E-23 10/10-12'75 Gix,ans Cons-uction OA/

t,;. e Hardnick QC, Electrical l

t-B-12 i

50-395/78-24 10/17-19/78 Peery Radiolegical None j.

~

Envi rer. mental i

Monitoring 1

(i t,

L

.50-395,72-25 10f16-19/75 Burcette Construction I,one 1

Girard QA/QC, Weiding l

i 50-395/7E-26 10/31 -

Vallish-Construction QA/

finne 11/2/78

. Lenahan QC, Me:hanical j

l

- Crowley Ccmpe er.ts, Welder Economos Training and Quali-3 i

fication Program i

a 50-395/75-27 10/27-30/78 Burdette Construction (78-27-05) l Brownlee QA Program Centrcl of i

Rausch Drawings l

i Ruhlman f.

50-395.75-25 12.'4-7/75 Compton Co n st r.ac ti on

' cne l

l Modenos QA/QC, Contair. ment i

Prest essing Work l

50-395 78-29 Operations :rs:e:-

tion i

l

'r i

--r,--

,.. ~

.e

,,4,

,+,,_-,,%,...-,~

,,,~,m,,

..,,~,....,.,w..v,__,..,_.,-y,,

B-13 4

E:-395/78-30 12/11-14/78 Walters Construction OA/

(78-30-01)

Girard QC, Electrical, Calibra-Hardwick Welding tion Review

L-3i5 75-31

- 12,15-15/78 Burdette Licensee Audit hone of A'E (Gilbert) 4 i

10-395/79-1 1/E-11/79 Compton Cens uction (79-01-01)

Modenos QA/QC, Ccmponents' Pipe Support Servi:e Water and Installa-Circulating Water- - tion Pumps F0-395'79-2 1/22-26/7' Hardwick Construction OA/

hone-l QC, Electrical i,

50-395/79-3 1/22-26/79 Girard Construction QA/

(79-03-01)

QC, Welding Use of Duct l

Tape l

50-395 79-4 Emercency-Planning Initial Managemer.t Meeting l

5C-3i5 7E-5 2/5-5 79 Burdette Const-u: tion

'. : - e Bradley QA/0C i

I l

i I

t g

p.,---,9y-y--

g..

--,+g y-,-,--*--y.-

4--

.--v+-

e wr,-'---.-mer

-,,-.--,ge--+v-9

+y-w,ww-,-,-n+g-,yvs--,

y t-

- + -w' w

y-

=

-w wvvv v

T-r*

-T-i

=

B-14

,t 50-395/79-6 2/12-15/79 Lenahan Construction None QA/QC, Containment Prestressing Work t

50-395/79-7 Operations Inspec-tien 5C-395/79-8 3/12-15/79 Burdette Construction-f.c r.e QA/QC 50-395/79-9 3/20-23/79 Gibbons Construction Nore QA/QC, Electrical l

50-395/79-10 3/20-23/79 Blake

' Construction QA/

(79-10-01)

F QC, Welding No Require-j i

ments on Weld j

Profile 50-395/79-11 4/3-6/79 Swan Construction QA/

f;or.e QC, Centainment Prestressing Wo-k I

Cc.s-uction

'sc r e 50-395/79-12 4/16-19/79 Burcette n

QA/QC o

l i

er

_w,-. - -, _..,,,., - - -

.w.,,,, - -

--+v--

--+4 7

g-e-.,.-.e m.-,-.-,,.

,eg

'*gP=y

--"y~n--

  • e-Pr<w

---w~~---tv

-- g 5-Tv'r,

' e -met-t v 7 e* *-+ w f

B-15 5?-295: 79-13 4/9-12/79 Ruff CorstrL: tion None QA/Q:', Electrical i

5:-395,75-14~ 4/30 -

Swan Constrc: tion QA/

None i

5/1/79 QC, Cor:ainment i

Prestressing Work 50-395/79-15 5/5-11/79 Walters Constru: tion QA/

None QC/ Electrical r

50-395/79-16 5/21-24/79 Crowley Constructio,.QA/

None VanDoorn QC, Radiography 50-395/79-17 5/22-25/79 Miller.

Fire Protection /

(79-17-01)

Prever: ion Deviation -

J Substandard Fire J

1 Purrp l

Installation i

i 50-395/79-18 5/22-25/79 Hardwick Const cction (79-18-C2)

QA/QC, Electrical Cabie Tray S :rort i:

Irstaliat'cr 5:- ?! 5 '79-19 5'5-11/79 Girard Cors: action id re QA/Q:. Weiding

..m.,, -

-_._m,....,,_.,_.

B-16 50-395/79-20 6/25-27/79 Burdette Construction QA/

None QC 50-395/79-22 9/26-26/79 Walters Construction None Electrical i

50-395/79-23 7/11-13/79 Ang Construction None General Expansion Anchors 50-395/79-24 7/31 -

Burdette Construction Q/A None S/3/79 i

j' 50-395/79-26 8/28-31/79 Girard Construction None Welding 50-395/79-27 9/12-14/79 Girard Construction None Preservice Inspec-tien 50-395/79-30 10/3-4/79 Eurdette

.Constructior. 0/A 79-30-09 10 CFR Part 21 i

Pr::scures Not i

adequate t

i

_ -.__,,.,. -- --_-._. _,~. _,_-._,. _..

B-17 4

L S0-395/79-32 10/30 -

Ruff Construction None 11/2/79 f

50-395/79-34 10/30 -

Ang Construction 79-34-01 Mechanical Inacecuate 11/1/79 (Seismic

- Insce: tion I

Analysis) of Pipe Hanger l

SC-395/79-36 11/5-8/79' Burdette Construction OA None 1

1 50-395/79-38 11/19-29/79 Lenahan Concrete and None 4

Cadwelding l

50-395/7S-39 11/27-29/79 Walters Electrical None 50-395/79-40 11/10-13/79 Burdette QA None 5;-395.'50-02 1/E-11/80 Gibbons Electrical None Hardsick Instrunentation Merriweather I

50-395/30-03 1/22-25'SO Girard Reacter Coolant.

50-03-01 i

and Pressure Irsdec. ate i

Boundary Piping U 6 ss:ri:

2 Testing I

l

,r w,

2

,r

.-y--,.-

m,, -

y, w.,,w,

+,,,

,,7%,

r-

, ~,,,,.,. -,,,,

.,,,._.ty..

r

.- -.=._.

P B-18 i

50-395/80-04 1/24-25/80 Ang Mechanical and None Seismic 50-395/60-05 1/25-28/80 Burdette QA None i

50-395/20-07 3/3-6/80 Girard Piping and None Welding 50-395/80-08 3/3-6/80 McFarland Mechanical.

None Reactor Vessel i

i Internals i

50-395/80-10 4/14-17/80 Burdette QA None r

50-395/B0-12 4/22-25/80 Girard Radiography-None I

i L

i 50-395/80-14 5/13-16/80 Gibbons Electrical ~

None Merriweather and Instrument-l ation N ne 50-395'S0-16 6/10-12/80 Burdett QA 50-395'80-27 6/24-27/40 Girard Preservice N0ne l

Inspection 1

i i

i a

3

- - ~ -

www,,----,e r w +-er e era - <

,<w.---r-n

,me-g, e-.-m-,.wr

,.,-wen

-swe~,+m e,,- w n-r e-,,

rv,v-,-.-,,-e-,

w--r-e - - s, er --

,-m--~

, ~ -- -

B-19 i 3-3 95 'F O-19 7/10-18/80 Ang Anchor bolts None and seismic supports

~;-3s5 50-20 S/5-6/80 Kleinsorge Piping and 80-23-Ci Welding Fitur P roc e::u-e No. Fo'ioae::

. " 3 E 5 'S0-21 E'12-15-80 Walters Fire Barriers, No r.e Electrical /

Instrumentation 50-395c50-28 9/23-25/80 Rausch QA None 5:-395 50-30 10/20-24/80 Girard Preservice None Inspection

.:-395 50-37 12/ -5/20 McFarland QA None 5:-3'E 30-3E 12/1^/S0 Crowley IEB-13 None 5:-3?i'50-39 12'16-19/80 Girard Preservice f.; r e Inspection

o E 'O 50-395/81-02 2/3-5/81 Crowley Certainment (81-02-01)

Fere: rations Installation Inspection R6cC"Cs 50-395.'81-04 2/18-20/81 Gibcons Licersee Identi-focr e fied items, IE Bulletins,and Circulars 50-395/81-06 3/24-27/31 Girard Lice see Identi-Ncre fiec items, IE Eali stins, Fre-service Inspec-tion 50-395/79-35' 9/10 -

Marsh Construction 79-25-01 12/19/79 Investigation Refer tc questions / answers 14 and 15 for a summary descri; tion of the investigation and findings.

The status of a number of itcms identified in this investigation wa unresolved and they.;ere addressed in subsequent inspections conducted during 1930 and 81 as denoted in questien/ answer 15.

B-21

.E5.79 *2' 11/19e79 Marsn Construction

f. :. e S/7/80 Investigation

~hese investigations were initiated to ascertain the degree of truth'a'ress 5 :

c.tstance of the information provided by those alleging tnat safet3-re'a. :

c;t's i tie s a re s t.b sta.dard. (See questions / answers 11, 12 and 13).

C-1 ATTACHMENT C DEPOSITION ALLEGATIONS OF IMPROPER CONSTPUCTION l

[ rehearing Conference i

Area of Concern i

Splicing of electrical cable was being perforced within the containment.

(Page 262)

Inspection Findinos for Concern - IE Report 50-395/78-17 l

At the request of the Atomic Safety and Licensing Board the inspector exarired the containment building for reported splices in electrical cables to containment penetrations.

Splices were found at the specified locations; however, each spliced cable was identified to be temporary construction wiring. There are no i

safety related electrical penetrations installed at this time.

Tne irspector examined Specification SP-559-0:4461-000 for electrical penetrations.

The specification requires use of splicing sleeves en some miscellareous power circuits.

The bill of material has been revised to cancel this usace.

The Electrical Construction G 41delines for Caole Irstallation f;ucer 04-1461-5-200-912, dated 7/1/77 has detailed splicing instructions. The caole instal-

.., _.. ~

.m.

l C-2 luien procedures FOCP 7.1.1, states "No splices permitted unless specifically

311ec for on drawings or approval of engineer" by Field Change Notice.

l N.e <eport of splicing has been verified but there are no safety-related c? Dies

.volved. The licensee does have provision for splicing but only u ;er'the

.ntrol of design engineering.

Within the areas examined there were no~ items of noncompliance identified.

Witness No. 1 3

4 A'ea of Concern 1

Mr. Whisennant alluded to a problem with repeated repairs to FW-6 on ISO SW-02.

4 r ges 10, 34 and 83) a t

!asrection Findings for Concern - IE Memo to File from B. R. Crowley

.ted 0:tober 19. 1978 e inspector reviewed weld records for this weld.

The records 1 dicated two

. :-airs attempts and then the joint was cut.

Af ter cutting, one repair was

' -e d.

'e irsoector reviewed the " controlled weld joint records" for all alding j

1.:eng rcrairs.

In addition the welding procedure and weicer ::alif':stier

.:e-:s were reviewed. Although several repairs were recuired. ne -ecords

-.. ~.

C-3 arear to be in order and there is nothing to indicate that acceptability of the fir.'sned weld should be questioned.

Witness No. 2

'-ea of Concern #1 M.. Fort, who was employed as a welder, indicated that heavy wall carbon steel l

piping in his work area was being welded withodt proper preheat in that attempts

.ere being made to maintain preheat with " rosebud" torches. Procedures reouire t 200 degree F minimum preheat and require that the preheat not be interrupted until tne weld is 30'. complete. (Pages 4-12) 4 Inspection Findinos for Concern #1 - IE Memo to File from E. R. Crowley dated October 19, 1978 Ine licensee's contractor (DCC) has determined that Mr. Fort did not weld any l

<afety-related pipe.

The licensee is performing further investigation to l

l, c:termine what welds were made by Mr. Fort and in what areas of the plar.t.

fee paragraph 5 of RII inspection report 50-395/7E-16 for additional findings l

relative to this problem.

,. _,,-,.-, c _ -

t e

j C-4 4

i l

sre: ion Findincs for Con:ern #1 - IE Report 50-395/78-16 l

. ga.:-ach 5 1

.'ety-Rela:e: Pipirg (Welding) - Ocservation of Work and kcrt A:thities i

ne inspector observed the safety-related pipe welding activities ces: riced below

{

o cetermine whether the requirements of the applicable code, spe:ifications and poce::ures were being met. The applicable code for the welding is tne ASME Boiler and Pressure Vessel Code, SEction III, Subsect' ion' NC and ND,1971 Edition with i

adder.ca through the su-mer of 1973 as required by DCC specification 50- "C-0!!af1-i

{

C00, " Erection of Nuclear Piping, Virgil C. Summer Nuclear Statior., Uri: 1".

The I

folicoing in pro:ess welds were observed at various stages of f abri:sticn:

)

1 FW-S:

150 SP-06 FW-3:

150 MS-06 1

l rW-1:

150 MS-09 FW-13:

ISO FW-11 74-10:

150 MS-08 i

Fh-13R1 150 MS-09 PW-17:

150 MS-DE

h 150 WG-13 TW-14:

150 FW-11 ri-1:

150 MS-09 FW-11:

150 WD-08 i

-*7*eT r

-v-ygr%

wygrie m -- +r vemtTowi-ga 9y tw4,cp g-y sw-e

-v egrum g,,,e eseroim,ppew,e---q-t-eg-r---ey* eye 4i--

pm,w y---

+ = w e w -s'pe t t gg-q M

-4 $

w-t*1**e-rV =67-wFDap4e

-+e'Tg M4 u+-*

't g

wrtw-

C-5 i

k 'd %ntification, joint preparation and alignment, evidence of OC verification of fitup, use of specified weld procedures, weld appearance, welcer qualification, i

ute of specified preheat and interpass temperatu-es, use of specified weld rcterial, and practice of grinding starts and stops, as applicable to each weld, were examineo.

i FW 10,150 MS-05 and FW 13R1, ISO MS-09 were examined to determine if surf aces were suitable for the required NDE and if the proper NCE was being performed at the proper state of fabrication.

During observation of the welding activities, the inspector paid special attention to preheat and interpass temperature controls and practices. Most of the welds observed were heavy wall carbon steel which required a minimum preheat cf 200 degrees F.

The preheat was not to be interrupted until the weld was 30% complete.

In all cases observed these requirements were being met. The prebeat was being maintained with electrical resistance heaters and blankets.

The only time a

" rosebud" torch is used for preheating is for fitup and tack welding. Interviews with welders indicate that this practice of preheating is the only practice in use on safety-related piping.

I helding wire room Nos. 2 and 4 were examined for stcrage conditions, issue records and handling of returned material. Welding areas were examined for the presence cf ur:entrolled welding materials.

'n the areas inspected, no items of noncompliance or deviations were icenti#ied.

4 v

-,--e.-

-y ce

-.---e

-g-_.y

-n-.,--

,e

,---n-

--yw---

g-n, e-.-

C-6

  • -ua of Concern M2

r. Fort talked about a problem with bad E-7018 electrodes. He indicated that the ac e'ectraces were darker in color (which he attributed to moisture in the coat g and dio not weic good.) (Page 12)

Inspection Findings for Concern #2 - IE Memo to File from B. R. Crowley dated October 19, 1978 a

Weldirg material control practices for E-7018 electrodes were revieaed by the inspector. Welding wire room Nos. 2 and 4 were examined for storage conditions, issue records, and handling of returned materials.

The inspector found that two brand names of E-7018 electrodes are in use at the site - Airco and Mc"Jy.

Visual inspection of the two electrodes reveal that the McKay electrodes have a much darker coating than the Airco. Discussions with licensee personnel revealed that the welders prefer the Airco electrode and for that reason very few McKay electrodes are issued. The licensee further stated inat wnen the McKay electrodes were first put into use, the welders complained about the operating characteristics of the electrode. Some of the electrodes were sent out for testing.

The testing revealed that the electredes, altncugr different from the Airco in welding characteristics were acceptable.

It should be noted that the welding characteristics of each manuf acturer's electroce is a little different. Once a welder gets used te a :articelar 0 and, when ne switches to a new brand he is likely to think there is a p-c le witn :ne

C-7 new brand because he tries to weld with it exactly like he welded with the old

~

brand.

Anea of Concern #3 For welding performance qualification. Mr. Fort hinted that welders could move their qualification test assembly during welding. The ASME Code requires that the test assemblies be welded in fixed positions. (Page 42)

Inspection Findings for Concern #3 - IE Memo to File frcm B. R. Crewiey dated October 19, 1978 See paragraph 4.c of inspection report 50-395/7E-16 for findings relative to this problem.

In addition to the inspection effort of paragraph 4.c, the inspector interviewed several of the welders during the in process weiding discussed in paragraph 5 of the report.

All of those interviewed indicated that during qualification, their test assemblies were fixed in position and could not be moved.

Inspection Findings for Concern #3 - IE Reoort 50-395/72-16. Daragraph 4.c Y

Welding Qualification Test Shoo The inspector observed in process welder qualifi:4 tion work in the welding qualification shop. Five (5) pipe welders were observed in the process of weiding their performance qualification test assemblies.

In all cases the welcers had a technique sheet describing how the assemblies were to be welded.

C-8 Tre assemblies were welded to fixtures 12 the weld booths and could not be noved en of position.

n :ne areas inspected, no items of noncompliance or deviations were icentified.

1 Witness No. 4 A.rea of Concern #1 i

Ci culating water pumps capacity being impaired due to a three foot space behind the intake and the wall itself. This limitation of space is on 3 sides of the ir:ake. Per the manufacturer's representative these purps need 11 feet space on eve y side of the intale to meet its capacity. Also at its present location ir the pocos will probably vibrate and fall apart (pages 8-10, 37).

i Irspection Findings For Concern #1 IE Report 50-395/79-1 Rt cuired clearances exist between circulating water pump inlet and surrounding 5

uctures. Tne inspectors examined vendor and construction drawings and vendor cor esponden:e approving the circulating water pump layout. No discrepancies were i c e r.t i f i e d. It is noted that these pumps are not safety-related equipment.

Ne eviations or items of noncompliance were identified.

I

,...w...

i C-9 A-ea of Concern #2 Ser. ice water pumps were very much distorted and out of level af ter being in place f or t o or tnree montns. Tne pumps were not workicg properly. This was caused fr:- ine foun:ation snif ting and tne concrete walls cracking in rany places. The n.n:'e fcundatior had shifted c.id one end of the building was much lower than the c.t r e r. Pum;s were reshimmed. (Pages 12-13,19-20)

Instection Findines for Concern #2 - IE Report'50-395/79-1 Pum nouse settlement effects on Service Water Pumps. Pump installation records, pum:ncese settlement records and the present physi:al condition of the pumphouse and pump installations were examined by the inspectors. No unusual conditions or adverse ef fects from settlement were noted.

fo :eviations or items of noncompliance were identified.

Iarr.ection Findinas for Concern #2 - IE Report 50-395/78-26 This e'fert was to include a review of the QA recceds for final setting of the St,:ce Water Pumps, and to review the detailed irstallation of the (RHR) pumps, and tne high pressure safety ' injection pumps and to confirm their procer 1rital:ation ey review of the QA records.

t t

e i

C-10 The 'ollowing' documents were reviewed to determine the licensee's commitments and OA, L: recuirenients for the installation of these pu ps:

i 4

1 l

5:

.5 Fiela Q: Procec:ure 6.2.1, " Inspection of Aligr ent of Rotating Equipment"

)

5:is3 Field 0: Pro:edure 6.2.2, " Installation of Rctating Equipment" I

D:: Constru: tion Procedure AP-VIII-03 RS, " Cleaning, Mandling and Preservation",

atd Exhibit A, " Plant Equipment Maintenance Log"'

1 i

a.

Service Water Pumps i

ine fo11coing C;I drawings were reviewed and used to verify lo:atiens, orientation details and installation requirements for thest pumps:

E-026-102 R13, " Service Water Screen and Pump Fouse Plans and Sections" 1

E-426-702, " Service Water. Intake Screen and Famo House Plan - Floor Ele.

  • 25' - 0" - Concrete Outline" d

d ine S:H.3 audits of Goulds Pumps were reviewec in File 301.1.7, "Serveillance and Audits". These were the pre-award of contract 0A audits of tne vendor on De:e.ber 10 and 11, 1974, anc Feoruary 12 and :3,1975, anc a o-e-sni;;ine of oumps audit insrection of June 29 and 30, 1977.

All findings were I

c'sresiticned in a tirely, adecuate manner.

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C-11 The installation of the three service water pumps was inspected in the service water pump house. These pumps are ider.tified as XPP-39A. E and C-SW.

Some discharge piping is connected to the pump bowls, but the discharge header is cisassembled and awaiting the backfilling of tne lines outside the pump house struc+.ure. The pump motors are not maunted on the pumps and final alignnent and grouting of the pumps is to be accomplished.

Nonconforming Condition Notice (NCN) 0,527 dated October 24, 1978, concerning the three pumps discharge flange connections was reviewed. Actions are being taken to resolve this open NCN.

9 No.tems cf noncompliance were icentified.

Area _of Concern #3 5-e safety-related welds were not x-rayed. After a length of time some of these w:1cs were cutout and replaced. These welds were stainless steel and loceted in e e reactor building at elevation 412. (Pages13,15,27-28,34-35)

1 1

C-12 I s: ; tion Findings _For Concern #3 - IE Report 50-395/78-25 f

e We1.fs and weld records were inspected for three piping welds located at tne 412

<a:

siesation in the containment:

a.

Resicual Heat Removal System Weld FW-1 on Isometric RH-10 The inspactor reviewed the -following records for compliance w'th t-e I

specified ASME section III C1.1 (71W73) requirements.

I 1.

Controlled Weld Joint Records (CWJR) of August 17, 1977 i

2.

Welcer qualification for No.1310 3.

Welding material requisition sheet 108719 and 1070504 4

Fir.al radiographic film and report (R1989) 0

~.

Fr.:eaure qualification records for weld'ng procedure E-E-EA-6 Rev.

(PDT 64 and 94).

Tne delta ferrite values neted on the CWJR were checked for ccmpliance with

e license's F5AR commitment.

ne we'd was visually e>.amined for compliance with t're see:ifie: A5"E 5e:: ion-

~

I C1.1 (71h73) requirements.

h C-13 Tne weld was visually eramined for compliance with the specified ASME Section, III C1.1 requirements.

f.c ceviatiers or items of noncompliance were icent e fied.

Safety Injection System Weld FW-1 on Isometric 51-14 (Weiding Still in b.

Process).

The inspector reviewed the follow'ing records for compliance with the specified ASME SEction III C1.1 (71W73) recuirements.

1.

CWJR of September 19, 1977 2.

Welder qualification for No.1177 3.

Welding material requisition sheet 146648 No deviations or items of noncompliance were identified.

Safety Injection System Weld FW-1 on Isometric SI-34 (Completed Weld) c.

The inspector reviewed the following records for compliance witn the

pecified ASME Section III C1.2 requiremerts.

1.

CWJR of March 25, 1978

.1 J

C-14 1

2.

Welder cualifications for Nos. 1405,1072 and 1009 3.

Welding material requisition sheet 116282 and 155401 4.

Final radiographic film and report (R3324)

The delta ferrite values noted on the CWJR were checked for comaliance with the licensee's FSAR commitment.

(

The weld was visually examined by the inspector for compliance oitr. 'ne specified ASME Section III C1.2 requirements.

No deviations or items af noncompliance were identifiec.

l-lrspection Findings For Concern #3 - IE Report 50-395/79-12

(

1 l

0-e item brought out during the deposition concerned x-raying of safety-related i

we'as was examined.

I e -der to l

T e irsrector performed an inspection of welds at the 412' elevation ir i

.1-cerly select welcs and determine if radiographic film was avai'.able f;r the j

l se' e:ted welds. The following welds were selected for this revie. -

2..reteric Field Weld No.

Report Date Film Read

.E-25-09 FW-7 R3523 12-19-7E i

t

C-15 SE-CS-ia FW-2 R3462 10-30-78 SE-51-17 FW-4 R2102 3-25-79 SE-51-:6 FW-14R2 R4733 3-25-79 SE-ND-il FW-1 R4687 3-22-79 SE-51-37 FW-9 R4351 2-15-79 l

SE '4'D-23 FW-1 R4234 2-02-79 f

SE-51-16 FW-3 R3677 12-01-78 i

SE-RH-09 FW-6R1 R4071 1-22-79 l

The irspector determined that radiographic film was available for the sele:ted welds and the radiogr... tic film had been reviewed for acceptance by radiographic fiim irterpreters.

t No items of noncompliance or deviations were identified.

Area of Concern #4 l

Not i. ing stainless steel shims on safety-related equipment after being instructed (Fages 15-17, 21, QC personnel not concerned which type of shim used.

to c: so.

t 23-24, 47) i 50-395/79-01 Insrection Findinos'For Concern #4 - IE Reoort l

Discussions with Material reouirements for shims on safety-related equipment.

cer.struction craf ts and QC personnel indicated that stainless s eel shins are used unless other materials a-e specified by manuf acturers or design do:uSents. A review of several construction /QC procedures showec that specific shim

C-16 rater als are not specified. Equipment shims are not considered safety-related

n. ate
  • Sis.

Area.f Ccnce-n Va Futtir.; concrete g 'ut in tne cracks to maintain the structural integrit) of the pumc motor building. (Page 36)

Inspection Findina For Concern #5 - IE Report 50-395/79-06 I

An item brought out during the deposition was examined.

The item cencerned putting concrete grout in cracks in the pump motor building. Examinatior of tne se vice water pu enouse and discussions with responsible engineers disciesed tr.dt the pumphouse had not cracked. Therefore grouting of this structure was not recuired. However, the service water intake tunnel, which carries water f rom the j

late to service water pumphouse, had cracked during construction due te excessive I

aifferential settlements. This was reported to NRC Region II as a 50.55(e) Item.

The cracks in the intake tunnel were grouted in December 1977 and January 1978.

l l

The irspector esamined the following documents concerning the groutir; coE*ations to repair the cracks in :ne service water intake structure.

I Specification " Technical Requirements for Filling Cracks ir : crc ste witn a.

Epoxy Grout" t.

Preliminary Test Frogram Checklist

C-17 2

Receiving Inspection Checklist for Epoxy Grout c.

5 E&G Compression Test Results Performed on Epoxy Grout Materials d.

i OC Records of Grouting Inspection e.

- Grouting in Walls and Renf of Service Water Intake f.

Completion Report Structure, dated January 21, 1978 Service Water Intake Structure Settle ent Effects and Related Werk, Retort g.

Numbers 1 and 2.

4 In acdition, the inspector examined 10 of the 15 core sar:ples :aken of the grouted 1

Based on examination of quality records and core cracks in the the structure.

the cracks in the structu-e have been satisf actorily samples, it appears that repaired.

The licensee will perform an underwater inspection of the service water intake tunnel in Spring - Summer, 1979 to verify that acditional cracking nas nct occurred since the repairs were completed.

No items of noncompliance or deviations were identif'ed.

l

C-13 Ires of Concern #6 i

i.:rt ers not trained in methods to contact NRC on quality programs, (pages 42, 43)

Irspe: tion Finoinos For Concern 76 - IE Report 50-3 :-5 / 79-C5 One item brought out during the deposition concereed reporting of conditions adverse to quality noted by craf t personnel was examined.

Daniel Corst uction procedure ADII-05 is the contrc' ling procedure f or crientin;.

indoctrinating and training Daniel Project Personae 1.

The Project Training Coordinator (Daniel) is responsible for the administration and inco:trination of all Caniel Freje:t Training Frog-ams. He or his des'gnee is also rescens' le for conducting the orientation presentation for newly hired Daniel pers nnel.

Ir addition, the Training Coordinator administers examinations as ne ciers necessary, and periodically performs and analysis of Deficiency and N:.:or-fonnance Notices to determine if there are existing adverse trends and if trends a

can be reduced through subsequent training. The ir.soector held discussicn witn l

ne Project Training Coorcinator and reviewed training foicers for six :-aft persennel in:1uding two each from the following trades: welding, pice fitting, mili w-ights, and electricians. The inspector aisc eviened tne t-air.in; 5:Pedule a

for the week of February 5,1979, and attended a rajor portion cf the "CA Gene-al Le::u-e" Class conautted cy the Training Coordinat:.

I Ir es ticating tre provisions for craf t orientation, incc:trinatier. End :-I'-i a

dd 5:ussion with the Proje:t Training Coordinator re.ealed ene ite of :c :e-r.

C-19 Cra't eersonnel are not being rade aware that notices. v.hich provide direction on The need tc acvise craf t personnel re m ting ouality concerns, have been posted.

cf tre posted notices and their location was brought to the attention of licensee 395/73 This item is icentified as an Inspector Fe'.ic -Up Ite-too.

ranagement.

SCEL3 nas agreec to re-evaivate C3, Craf t Training on 'eocrting Osality Concerns.

t RC posting requirer.Ents are being r.et.

esisting training provisions, l

l l

VIRGIL L. BRO. NLEE pR0 FESS 10NAL QUALIFICATIONS REGION II - 0FFICE OF INSPECTION AND ENFORC.EME,NT U.S. NUCLEAR REGULATORY COMMISSION My nai.e is Virgil L. Brtwnlee.

My business address is 101 Marietta Street, NW, Suite 3100, Atlanta, Georgio 30303.

I am etaployed by the United States N 4cle3r Regulatory Caraission, Of fice of Inspection and Enforcement as a Project Inspector.

My priracy assignment e.s Project Inspector encompasses the period from May I?C9 through p esent.

During this period, I have participated in over two hurdred inspecticns relating predor;inately to design, procurement and construction of nuclear power plants.

My primary duties have included verification of i. -luten-tation of the QA programs and inspection of design, procurement and construction activities including receipt, storage and installatinn of equipnent ar.d vandor related activities.

To accomplish this, I coordinated the inspection efforts of irdividual in:spectors and consultants, participated in programrod inspections and prescribed special inspectinn efforts inspecific areas of ccEc'ern.

I My present arsigrTent as project inspector includes five sites (8 reactors).

Five ur.its are operational and three have construction permits.

Prior to my enployment with the Atomic Energy Commission, I was a memb:r of the U.S. Air Force and was assigned to the Army Nuclear Power Program from Dece-her Ic58 through June 1969.

My major assignments with the Arqy Nucl.;r Fewer Program were as follows:

1.

Ovalified eperator on three reactors--SM-1, Fort Belvoir, Virginia:

F.Y-1. Sundance AFS, hjoming; Nuclear Engineering Center, Uright-Pattersen AFB, Ohio.

2.

Shif t Supervisor / Maintenance Superintendent on two restigts,-F:1-3 Sundance AFS, Wy n.ing; Nuclear Engineering Center, Wright-Patterson AF3, Unio.

g,

2 3.

Construction / Test and Startup operation of two reactor facilitics--

PM-1, Sundance A~S, Wycning; Nuclear Engineering Center, Wright-Patterson AFB, Oaio.

I have received ny secondary education in a public school system in Illinois.

I have completed accredited college courser frce. Black Hills College and Wright State University.

During my Air Force and NRC career, I have completed several military and civilian ccurses related to the nuclear field.

The related courses included:

nuclear physics; nuclear, electrical and mechanical engineering; instr e.:ntation and control systems; Operators training; reactor safety (MIT); weldir.s (GS);

radiography (Ecdal); Nondestructive examination (Convair); ?WR Systcos (HEC);

PWR Operations and Transients (NRC); PWR Simulator Operations (8RC); and BWR Systems (NRC).

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JOHN L. SK0LDS PROFESSIONAL QUALIFICATICh3 REGION 11 - 0FFICE OF INSPECTION AND ENFCRCEMENT U.S. NUCLEAR REGULATORY COMMISSION My name is Jonn L. Stolds.

My business address is Rt. 1. Box 54, JenLinsville, S: 29210.

I an employed by the United States Nuclear Regulatory Cor.snission, Office of Inspection and Enfcrcement as Senior Resident *nspector at the

C. Surner Naclear Station.

I graduated from the United States Naval Academy in 1972 with a Bachelor of Scier.ce Degree in Applied Science.

I have attended Georgia State University.

Atirnta, Georgia and am presently attending the University of Scuth Caroline in the pursuit of a Mester of Business Administration Degree.

I am a mer6cr c.' the Sicr.a Pi Sigma, the Physics National Honor Society.

Fra,1972 to 1973, I was a student in the Navy Nuclear Pcreer Program.

From 1973 to 1975. I was a division officer on board the USS FR*NCIS SCOTT FEY (SSSN 657), a nuclear submarine. While on board, I qualified as Engineering Officer of tqe Watch and Officer of the Deck.

Froa 1975 to 1977, I was assigned as Leading Engineering Officer cf an operatirg crew at the Navy Nuclear Power Training Unit in West Melton, New York.

In t",is cana:1ty, I w6s the Officer in charge of an operating crew during c:nsteu:tico, precoeratienal testing, initial criticality and 1c, power physics testing for a new prototype nuclear power plant.

I qualified as En;'neerino Of fir.or of the Wctch and Chief Engineer.

In 1977, I joined the l'.5. N; 1. r Reg;;atery Cc:-ission as on Operatiens Inspe :er.

Daring this e :pl o,crent, I perfonied inspections in varicus operational c reas incleding cuality acaurance, Technical Specifications, operating and raint; nance trocedure revie'.

I completed the Nuclear Regulatory Cc nitsic.'s Fressurized n

'..?ter Feactor (P.$) courses and Boiling Water Reactor (E'.'R) coueses,

John 1.

Skolds In 1979, I was assigned as Senior Resident Inspsetor at the V.C. Suorer N; clear Station. My duties have included review of the preoperational test pregra.. quality assurance, eriergency planning, operations, nainten: ce a'd adrit,istrative procedures.

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STATEMENT OF QUA'_IFICAT:CNS 2

E. H. Girard From 1903 to 1956, ! -as a

  • ta..rs'st at the Mattis anc ;cnt ols Civ sion of i

Texas Instruments in Attletero. M2s:a: Susetts where t duties inctaded conducting progre..ts on deveic; cert of.-.te:-ivo : cat 1*g>

f:r re' a: a y net 61. cer v.it-etal,ioi ci ng rest a-n.

A r.a

...: "'sirr of tm 4secr:h h ea t-=,t'<- mttal-logra,,hy labora tory.

Ft.r1 W6 tt 1967. I *n > P r ' e,e 3 : a S'-ict % t11'i. ;-'.; at M- '41 c r Rc 3.;3 r:f Cerpo-ation in Des P'ad e:. I

ar t.

I sc riec 0*

h. l.; p.e r t af riher a-d in:ulation and :c-r ': ac:c:t':A' 1 4'<- e.a > f a t t.. r - - r<::H :ss F-:m 1967 tc 1971, I was eme':/+: Ac A ' water W tal',eg'st at +rs General atomic Comorny in San D: ego, Calife m 3.

as eso:rs4 'e fo-ve icus meter'als eng'ree-irg ::rc: css devel:r v : A r.. ' s : t i e s ( 'J c t ' r g, a e ' d ' * ;, adresive bendiag, ocwder metallurgy, cleaning a :c c. a'ings) fur.,ss in ru:'eae f uel trarLf a:ture anc Drecuttion of a nuclea pen-ac r e:t : er.3y cor.e ;f ra ger.e-ator, Eram } 97} to 1972, I C 3-t i r.ut*d y e t ' UyrSt.$r t a t the Geaeral At:.f c CcaLany in * *,e position of a QA En;i.rer res:

s ti. 'cr auditi g precessing and ecords in c

t tr.anuf a:ture of tue n e,.e-ent s ::.r a nu:,ea-rea: c.

f ro-I ~ 72 to !??E. *. cen t e.-

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"c e al At:mi: C:.ary as a l

Se 'e-E mineer:Gt E ;* nee-e ;: ent.':: + ' o - r + v ' *,, a s d e ::; - v a l <> ' c u s t:~e r anc internal oncumert:

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. s STATEMENT OF Q'JA*.!FIC AT: CMS 3

E. H. Girard l

Frer 1976 to 1978. I was e.C. ye:' as a Sseict Eagineer at Offs.*:re ::aer Systems in Jacksenville, Florida.

1

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I-29 3, I a t >rted a :ssitice as a Re-a ta-Ir. :(: tor with the b.

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