ML20027D264
| ML20027D264 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/23/1982 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Percy C SENATE |
| Shared Package | |
| ML20027A855 | List: |
| References | |
| NUDOCS 8211030514 | |
| Download: ML20027D264 (2) | |
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n SEP 2 3 1982 The Honorable Charles H. Percy United States Senate Washington, D.C.
20510
Dear Senator Percy:
This is in reply to a letter from one of your constituents, Mr. Charles A.
Sanders Jr., which you forwarded to this agency. Mr. Sanders questioned the adequacy of the Nuclear Regulatory Consnission's investigation of allegations at the LaSalle Nuclear Power Station.
The NRC's Region III Office conducted a thorough investigation of allega-tions which were received from several sources, including the Illinois Attorney General. This investigation, while thorough, should also be viewed within the context of the NRC's inspection activities leading to the issuance of an operating license for the LaSalle facility. The plant's safety components have been thoroughly tested by Coninonwealth Edison with NRC personnel observing many of chese tests. Thousands of manhours were devoted by NRC inspectors during the last year of construction to assure that construction and testing activities wer#being properly completed.
When the allegations were received -- just prior to a decision on a -
license to load fuel and conduct low power tests -- the NRC staff deter-mined that fuel loading activities could be pemitted without endangering the public while the allegations were investigated. The investigation involved interviews with the allegers and knowledgeable personnel at the H
plant site, reviews of pertinent documents, and examination and testing of materials and components where appropriate.
Since fuel loading and initial criticality would not impair the investiga-tion nor represent any significant hazard to plant personnel or the public, the NRC staff permitted these activities under a restricted operating license.
Just as the investigation was being completed, the NRC became aware that some documents and allegations, which initially were thought to involve a construction site in Michigan, also involved the heating, ventilating and air condition.ing (HVAC) work at LaSalle. The documents, which are alleged to be false or inaccurate, are being investigated fully.. In addition, the NRC has required Commonwealth Edison to retain an independent consultant to review the design and installation of the HVAC system at LaSalle. This review is to be submitted to the NRC and accepted before the plant will be permitted to exceed 50 per cent power.
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8211030514 8320923 PDR ADOCK 05000373 H
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The Honorable Charles H. Percy,
The investigation of these allegations was appropriate both in scope and in depth.
I am enclosing a copy of the investigation report, which may be of interest to Mr. Sanders. No significant safety issues, aside from the pending allegations about the-HVAC system, were identified. At this time, the NRC has no basis for shutting the plant down or undertaking any further investigation.
We will continue to monitor activities at the LaSalle Station with two resident inspectors and additional inspection personnel from our Region III office in Glen Ellyn, Illinois.
I hope this information responds to Mr. Sanders' concerns.
Sincerely, N'*dWdilani. Dircks William J. Dircks Executive Director for Operations
Enclosure:
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M DATE NRC FORM 41) 9/21/82 (4e2 ROUTING SLIP ORIGlWATOR OFFICE OF THE EXECUTIVE DIRECTOR U.S. NUCLEAR REGULATORY COMMISSION EDO NUMBER FOR OPERATIONS
]ppgg INCOMING DATE 8/18/82 ACTION 6C[ N 7hWswU Signature - Letter g
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P1nnsylvma 19046 g,
TECHNOLOGIES June 28, 1982 FILE 00Pr
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l Mr.
I. N. Jackin U.
S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL.
60137
Dear Mr. Jackin:
Accompanying this letter is a trip report covering a visit I made at the request of C. D. Sellers of U.S.N.R.C.,
Bethesda, Md., in connection with technical problems relative to the installation of bolts at the LaSalle County Nuclear Generating Station on June 25 and i
26, 1982.
The report covers engineering discussion and certain recommendations and a conclusion I drew after examination of the available evidence relative to problems presented to me.
Yours sincerely, 1
db A. Craigenuvu, anager Advanced Metallurgical Products ACH/pml enc.
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C' E. Norelius - NRC l
C. D. Sellers - NRC MO7260441-gg f3,3 QyL l
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World Hetdquirters 43 Benun Erst J$ntuntown Psnnsylvania 19046 nceotocits 2 5s72. cm June 28, 1982
SUBJECT:
Visit to U.
S. Nuclear Regulatory Commission Region 3 and LaSalle County Nuclear Generating station on June 25 and 26, 1982 This report covers the visit I made to the above locations on 6/25 and 6/26, 1982 relative to a problem regarding tight 2~'
~
ness of bolts on the area in containment and outside containment of the Unit one reactor.
I was contacted by C. D. Sellers of the U.S.N.R.C. on June 24 and asked to accompany him to U.S.N.R.C.
on June 25.
I had previously had discussions with Mr. Sellers on mechanical fastening technology at Bethesda.
SPS Technologies is a major producer of precision mechanical fasteners and offers consulting advice relative to fastener design and installation upon request from 3
i industry and government agencies.
I was initially briefed on 6/25 at the Region 3 office.
The problem is made up of two elements.
The first refers to an allegation that records relating to calibration of torque wrenches used at the reactor site may have been in error over a period of several months.
In addition, a check by one of the reactor inspectors of NRC of a valve attach-ment within a containment revealed two loose bolts that could be rotated with the fingers.
The second element related to the engineering implica-tions of the calibration errors and the loose bolts.
The first element will be dealt with by the NRC and Commonwealth Edison, the utility operating the nuclear station.
I will only deal with the second element of the problem.
i l
The reactor is currently on zero power and is planned to be started up for the first time preparatory to going to full power on Tuesday, June 29, 1982.
A meeting was held at the LaSalle Nuclear Station at 1:00 P.M. on 6/25.
A copy of the list of those in attendance accompanies this report.
Also, an outline of the meeting subjects and information relating to the valves in the con-tainment area is enclosed.
Work!H;adqu rters The Ben on Erst 5
((
Jenkintown P;nnsytv:nia 19046 If(HfoOloGIES 215 572 3000
SUBJECT:
Visit to U. S. Nuclear Regulatory Commission Region 3 and LaSalle County Nuclear Generating Station on June 25 and 26, 1982 1.
Motor Operator / Yoke Connection Tightness Check Quality Assurance management from C. E. Co. said that all bolts in the subject valve attachments would be rechecked with a click torque wrench by turning the bolt head clockwise.
I suggested that a dial type wrench be used and that the data for each bolt be recorded in terms of the torque it took to get the bolt head turning.
Where the torque was too low, it could be brought up to the required minimum.
Where it was too high, it could be backed off and retightened to the proper value.
C. E. Quality Assurance management agreed to do this for the 24 valves within containment immediately.
They agreed to do it for the approximately 125 valves outside containment within 6 months.
It was stated that many of the bolts were ASTM-A193-B7 (Cr-Mo 125 ksi UTS).
C.
E.
Engineering management pointed out that many of the bolts were only called out to be " wrench tight" while others had no upper and lower tolerance for torque.
After much discussion, C. E.
agreed to establish clamping load requirements for these joints and specify an allowable upper and lower torque range for each bolt.
Where certain bolts are not accessible with a torque wrench, C. E.
Engineering and Quality Assurance indicated they would establish an engineering procedure and justify their action.
I suggested that
^
they could use a snug fit and an angle of turn as an alternative in inaccessible areas.
2.
LaSalle County Expansion Anchor Installation and Inspec-tion Values This element relates to the installation of expansion-type anchor bolts in concrete at various locations at the reactor site.
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World Hesdauirtses The Benson East Ankmtown Pannsylva ua 19046 itcHmotocits 2in72.aom
SUBJECT:
Visit to U. S. Nuclear Regulatory Commission Region 3 and LaSalle County Nuclear Generating Station on June 25 and 26, 1982 2.
LaSalle County Expansion Anchor Installation and Inspec-tion Values (cont'd.)
Mr. T.
Longlais, head of Structural Engineering for Sargent and Lundy made a presentation on their study of anchor bolt seating torques for these bolts.
Sargent and Lundy are the firm of architects and engineers used by C. E. Co. in the construction of the nuclear station.
Studies made of the torque, holding powes and slip characteristics were presented.
Copies of pp. 21-24 of a report on their findings along with Figs. 2.12, 2.23 and 2.24 were given to the group.
A copy is enclosed.
Their studies showed that once the expansion ring makes contact with the concrete inside the hole that further applied preload has little effect on the performance of the bolt.
They did establish a preload tension above that expected to cause slip and i
these are used in anchor bolt installation.
They also-justified that a rechecking at 60% of installation torque is satisfactory and that bolts not achieving the 60% are taken to the original torque value.
I indicated that I had no problem with this engineering approach.
l 3.
Torque Wrench Calibration Accuracy ( *:D6 + 1 6%)
Concern was expressed by NRC personnel in the meeting that the errors discovered in the torque wrench calibration charts had contributed to improperly l
tightened bolts.
It is possible to determine two things.
First, the " worst case" of torque wrench effect on accurate torques can be established from the data and a recheck of the wrenches in question.
C. E. Quality Assurance said they believed that maximum j
error was not greater than 11-12%.
Second, this worst case condition can be applied to a range of torque values acceptable to C. E.
engineers for each joint in l
World HKdqusrtars Tie Benzon East
.y
,anninio.n g
P&nnsytvania 19046 TEOmOLoGIES 215-572-30 @
_4_
SUBJECT:
VisM;to U. S. Nuclear Regulatory Commission Region 3 and LaSalle County Nuclear Generating Station on June 25 and 26, 1982 3.
Torque Wrench Calibration Accuracy (cont'd.)
question.
C.
E.
Engineering management agreed to calculate the range of clamping loads and corres-ponding torque spread.
Any joint believed to be outside the acceptable range will be retightened after consultation with NRC Region 3 inspectors and engineering personnel.
I indicated that this procedure was acceptable from an engineering standpoint.
Meeting on 6/26 at NRC Region 3 Headquarters on the day following the meeting at LaSalle, NRC personnel from Region 3 and from NRC, Bethesda headquarters, met to discuss the results of the previous day.
It was the decision of NRC Region 3 personnel that they would request C.
E.
to evaluate all joints in question as a result of the calibration problem prior to allowing the reactor to go above zero power.
I concurred with this posi-l tion.
l In conclusion, after hearing the engineering statements of C.E.
Co. and their consultants and after discussions with NRC personnel, I believe that all the actions the licensee has taken and plans to take, as set forth in this trip report; j
are in the right direction.
-(srs*S 1,
A. Craig /Ecod, Manager Advanced Metallurgical Products ACH/pml encs.
6/28/82
li\\ttaclinent Y 1
T.ARAT.TR COUEITT STATION COMMONWEALTH EDISON COMPANTMcLEAR HEGULATORT COMMISSION MEETING JIINE 25,1982 - 1:00 P.E PARTICIPANTS:
NuclearRegulatoryConsnission(NBC)
NBC Consultants Comonwealth Edison Company Sargent & Lundy Engineers 1.
MotorOperator/rokeConnectionTightnessCheck 2.
LaSalle County Expansion Anchor Installation and Inspection Falues 3
TorqueVrenchCalibrationAccuracy(8%+d6%)
2
ATTENDANCE LIST C MPANY: A A G//r POCKET NO. <f73 C Pre-Inspection Conference CIbst Inspection Conference Date: /
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Attachment F
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1 Rx Containment Motor Operated Valves
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Tightness Check i
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Basic Requirements - Manufacturers Recommendation I
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I Specific Tightness Requirements Non-Specific Tightness Requirements I
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Torque Value Sta' dard Mech. Practice Standaro Torque @
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Tightening Sequence (Wrench Tight)
Referral a.
G.E. - Atwood & Morrill a.
Anchor Darling Company f
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Attachment F Rx CONTAINMENT MOIOR OPERATOR / VALVE YOKE BOLTING TIGHTNESS REQUIREMENTS VALVE NUMBERS S&L SPEC.
MANUFACTURER 1DRQUE SPEC.
TORQUE SPEC. REFERENCE IB33-F023A J-2500 G.E./Atwood&Morrill 110 Ft.-Lbs.
Instr. Manual Part IX Step 12 1B33-F023B 1B33-F067A IB33-F067B 1B21-F016 J-2938.01 Anchor-Darling Wrenchtight Instr. Manual - Confirmed w/ John Chappell, A/DV Eng'g. Manager lE12-F009 j
lE51-F063 l
1G33-F001 i'
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1G33-F100 1G33-F101 1G33-Fil2 1G33-F106 l
LWR 179 IWR180 lVPil3A J-2940 Fisher Controls Wrenchtight No Instr. Manual References Info. Obtained IVPll3B From Glenn Hyatt.
IVPll4A IVPil4B l
l 1B21-F001 J-2950.01 Anderson-Greenwood 75110 Ft-Lbs.
Drawing GNO3-6492-500, Rev. B 1B21-F002 IB21-F005 4
lE12-F099A lE12-F099B 1E51-F076 150110 In-Lbs.
Drawing #NO3-6498-510, Rev. C i
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2.4 Phnsa D - Ancher Proload Reicx:ition TGsts O
241 t=trc4=ceto-When a concrete expansion anchor is installed, a preload will be induced on the anchor as a result of torquic.g the bolt or nut.
It is known that a portion of the preload in the anchor dissipates over a period of time af ter installation.
The purpose of these single anchor relaxation torque tests was to investigate the loss of anchor preload over time (relaxation).
The tests were performed on single anchors of varying types, and diameters, installed at various embedded depths and with various torques in concrete and mortar (Types N & M).
The specific testing requirements aie outlined in Table 2.4.
2.4.2 Test Apparatus Single anchors were installed in unreinforced concrete (no reinforcement within a minimum depth of ten anchor diameters) and in Types N and M mortar.
2.4.3 Procedure Single anchers were installed in concre te and mortar in accordance with manufacturers' reconsnended installation pro-cedure s.
Installation torques are shown in Table 2.4.
The nut or bolt of the anchors was loosened 1/8 of a turn and then retorqued to its original position.
The torque required to return the nut 'or bolt to its original position was then
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record:d as a measure of remaining pralecd in th2 cachcr. On2 cncher fcr each sse cf ecsts p:rfermed w:s tasccd with a 1ccd
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cell under the nut or bolt head to establish a torque-tension relationship.
The anchors were retorqued at intervals of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 7 days, 14 days and 28 days af ter initial instal-
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lation. The anchor load and the average anchor torque versus time were plotted for each set of tests.
(Figures 2.23 and 2.24 show typical load and torque plots.)
2.4.4 Results The results are represented by Figures 2.23 and 2.24.
The loss of prelo'ad at the end of 28 days was as little as 13% for a 3/4" diameter anchor embedded in mortar and as much as 54%
for a 1/2" diameter anchor embedded in concrete. Overall, it appears that less relaxation occurred for anchors embedded in mortar than for those embedded in concrete.
f O.
2.5 C:aclusions O
2.5.1 Phase A - Static Tension Testa on Single Anchors The static tension tests oc single anchors have provided a clear understanding of the anchor behavior under loading and the effect of various parameters on that behavior.
It. is noted that the prestressing of the anchor at the time of testing does not affect the ultimate load carrying capacity of the anchor.
Phase B - Cyclic Test on Anchored Plate Assemblies 2.5.2 i
The wedge, sleeve and shell type anchors tested in cor. crete O
and block walls exhibited insignific, ant anchor displacement when subjected to seismic 'or pipe transient loadings.
It be concluded that anchors embedded in con-can, there fore,
crete can withstand cyclic loads up to 25% of manufacturer's ultimate capacity with a simulated OBE condition and 50% of manuf acturer's ultimate capacity with a simulated SSE con-dition.
It has been shown that anchors embedded in concrete block and mortar can withstand cyclic loads. The tests were conducted at load levels of 25% of the measured mean ultimate static capacity or greater.
It should be noted that anchor preload is not required for the
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anchers cascad was gsnarolly not greatse thsn 500 lbs. (0 preload) which is equivalent to tightening the nut or bolt.
approximately 1/8 of a turn after " hand" tight.
2.5.3 Phase C - Static Tension Tents on Anchored Plate Assemblies The results of tests on a flexible base plate with four expan-sion anchors show that the, prying action is of the order of 15-20 percent of the applied load.
This increase is much lower than the expected increase in an assembly with regular steel bolts where the prying action force is calculated to be 110 percent. The reduc' tion in the prying action force is due to the effective lower stiffness of expansion anchors in-striled in concrete.
2.5.4 Phasa D - Anchor Preload Relaxation Tests From the typical curves showing load or torque versus time (Figures 2.23 ar.d 2.24), it can be seen that the anchor pre-load losses are most pronounced in the first 24 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
However, it should be noted at this point that the relaxation phenomenon should not be of great concern when viewed in light of the cyclic test results which showed that preload is not required to withstand cyclic loading.
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i 4625 CEMETERY ROAD o HILUARD, OHIO 43026 l'
614/876-5719 l
June 26,1982 Mr. Davo Terao
!! ail Stop P-522 A. 5 ma d Hochanical Enginooring Branch l
U. S. liuclear Regulatory Commission k'ashington, DC 20555
Subject:
Meeting at LaSalle Plant, June 25,1982 on Technical Aspects of Torque Wrench Calibration t
Dear Dave A copy of the Agenda is in:iluded as Enclosure 1.
My comments con-cerning each Agenda item follow.
1.
Motor Operator / Yoke Connection Tightness Check Roger Lanksbury (!TRC, Region III) found (6/18/82) that two nuts on a motor operator / yoke conriection were '" finger tight".
( A possible reason is that it vaa necessary to remove the operator for clearance during con-struction and all of the nuts were not re-tightened during replacement of the operator.) The Applicant has comnitted to checking all safety-related motor operated valves inside containment (24 valves) immediately and all safety-related motor op( ated valves outside containment within 6 months. is a listing of motor operated valves inside containment.
It includes a column headed nTorque Spec." Apparently, this information' vas obtained in the last veek or so and, prior to then and presumably during the time of the alleged lack of accurate torque vrench calibration, there was n specified torque for these particular bolts when, or if, they were loosened during plant construction and then re-tightened. A discussion of the technical significance of the torque wrench accuracy, if in fact a torque vrench was used in the re-tightening, is irrevelant.
I a
.r Considerable discussionoccurr:d at ths m: sting sa to what v2s meant 3
by "Vrenchtight". In my opinion, "Wrenchtight# is an e.dxquate instruction to any competent workean. llovever, the Applicant agreed to put "A value n in place of "!!renchtight". Once that specified torque l's established (as it is for two of the four valve manufacturers as shown in Enclosure 2),
the technical significance of the torque wrench accuracy becomes reisvant.
Fron a technical standpoint, torque during bolt tightoning is a method of trying to achieve an appropriate. clamping force. As brought out by Mr. Hood of SPS Tochnologies, the relationship between torque and clamping force, for a given nominal bolt geometry (size, threads per inch, tluead tollerances, etc.) can vary widely depending upon the coefficient of friction.
My own experience (on flanged bolt bolting) indicates that if one first calibrates torque versus clamping force using a reasonably good thread and other mating surfaces lubricant, then if one continues to use that same lubricant and nominal bolt geometry,the clamping force can be predicted from the torque within a scatter of 430% vith about 90% confidence.
However, if the lubricant is not controlled, then from what I have read it appears that the clamping force, for a given torque, could easily vary by a factor of 4 or more.
Fortunately, the safe operation of bolted connections of the type under consideration are not very sensitive to preload clamping forces.
To the extent that loads are cyclic, it is desirable to have the preload highor than those loads so that the bolt st* esses vill remain essentially constant and fatigue of the bolts will not c,ccur.
In addition, even if no loads are anticipated in paper calculatt.ons, most power plant equip-ment operate in an environment of at least low level vibration and bolts should be tightened sufficiently so that the nuts do not vibrate loose in service. These considerations establish minimum desired proloads.
The naximum preload may be significant if, by any chance, prying effects are not properly ovaluated in calculating loads. However, if loads are appropriately calculated and' holt simes are seleeted to aseomme.
date those loads, then maximum preload is not significant in a loading l
M
sensa. Somo bolting caterials such ca SA 193 Grada B7 can be sunexptible to stresa corrosion cracking and exc2ssiva prolord mIy contribute to cuch cracking. ( A perhaps.necessary co-condition is lack of adequate heat treat ment control in manufacturing the bolts.)
In sunmary, a preload not less than calculated loads is desirable and, regardless of calculated loads, the bolts should be tight enough to pre-vent loosening due to vibration. Ovortightening could be a problem if stress corrosion cracking is a possibility. With controlled lubrication, a specified torque could be useful. 'Without controlled lubrication, "iirenchtight" is probably better than specified torque. In view of the large variations of clamping. force for a given torque, torque wrench accuracy of +20% is adequate.
2.
LaSalle County Expansion Anchor Installation and Inspection Values Sargent and Lundy's description or their basis for setting installa-tion and inspection specified torques for concrete anchors ( specifically, Hilti Wedge Anchors) indicates to me that torque vrench accuracy of 20%
is adequate.
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3.
Torque Wrench Calibration. Accuracy (*2% + *6%)
The#2% is the calibration fixture accuracy and the d6",is the limits vjthin which a torque wrench must be. accurate as determined by use of the calibration fixture.
In principle, the torque vranch accuracy is 58%.
Based on personal use of torque vrenches some years ago, I suspect that in " tight" placos where the torgde vrench can not be pulled on in the same manner as in the calibration, additional inaccuracies could occur.
However, in view of the vide scatter in torque versus clanping force without controlled lubrication, whether the torque vrench is accurate to
- S$ or d20% ( as used in tight pieces) is a relatively trivial consideration.
aMEEELng a
Incid:ntally, th re. is a good discunicn of preloading cf bolta in g
flanged joints in the ASIE B&PV Code,Section VIII, Elvision 1, Appendix S.
That Appendix gives an equation that.gives an indication of what "vrenchtight" means in terms of clamping stress in the bolts.
S = 4500d/.> T (1) where S = probable bolt stress developed manually when using standard vrenches d = nominal diameter of bolt.
Equation (1) was developed by E. C. Patrie in 1937. It is limited to dh1/2n and probably to d d 2"; vell' lubricated threads and other mating.
surfaces; HC threads below d et"., the 8 thread per inch series above d=1".
Yours Very Truly b
E. C. Rodabaugh Enclosures 1 and 2 cc S. E. Moore S
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Hural Hou!e 61, t$0x ZZU M;>seilts,Illin is 61341 T2phona 815/357-6761 IEHQ FIIE copy July 8, 1982 Mr. James G. Keppler Regional Administrator Directorate of Inspection and Enforcement - Region 111 U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
SUBJECT:
LaSalle County Station Units 1 and 2 Review of Morrison Construction Company Records
Dear Mr. Keppler:
The purpose of this letter is to provide you with copies of the quality Assurance and Projegt Construction reports of the subjectgeview.
Commonwealth Edison believes that these reports demonstrate that, although various deficiencies have been observed, the adequacy of construction of the plant is satisfactory.
If there are any further questions in this matter, please immediately contact C. V. Schroeder, Nuclear Licensing Administra-tor for LaSalle at (312) 294-3962 (office) or (312) 329-1087 (home).
70M Q 04 KA (4de u c ) At A. - 6 &f-SoF7 Very truly yours, b %.
\\.
l Cordell Reed Vice-President v
CR/CWS/djp l
_S20726044t 820719 PDR ADOCK 05000373 G
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Ccmm:nwealth QUALITY ASSURANCE MANUAL AUDIT REPORT EHQ FILS con G.O. Audit of Morrison Construction Company LaSalle Project Type Audit:
/
/ Program Audit
/
/ Product Inspection Point
/
/ Records f_.y/Special To:
J. Hamilton, Morrison Construction Company - Project Manager Project LaSalle VisirDate 6/29 --7/EReport Date 7/8/82 1982 System N/A Component Identification N/A Material Description N/A Vendor Morrison Construction Co.
Location LaSalle I
Subcontractor N/A Location N/A Contacts See Report P.O. No. 181110 Spec. No.
J-2530 Recommended Inspections:
6 mos 3 mos 1 mo Other:
As Scheduled Notes:
See Report l
Auditor f
Date b
Leef.
ditor A K. Jl Hansing ieQe L
' /./:ns k Date
'/- $ ~ b'Q Kev cc:
Manacer of OL Director of QA (Engr-Constr)
Site Constr. Supt. or Proj.
Engr.
Site Quality Assurance Project Manager Project Engineering Mgr.
(List others as required)
Manager of Projects hXTg Lead Auditor 8207260437820719 PDR ADOCK 05000373 G
pgp
AUDIT REPORT FOR MORRISON CONSTRUCTION COMPANY IASALLE PROJECT JULY 8, 1982 PURPOSE The purpose of this audit was to evaluate Morrison Construction Company's (MCCo) calibration practices and procedures, various quality control records, records control and the Quality Control review functions. Additionally, the audit, inspection and surveillance activities in the area of MCo calibration were evaluated to determine if required reviews were performed and to assess the credibility of their reviews and associated documentation.
SCOPE This audit examined the following areas:
1.
GCo audits of MCCo calibration activities 2.
GCo auditor qualifications 3.
Credibility of CECO audits 4.
GCo surveillances of MCCo calibration activities 5.
Authorized Nuclear Inspector's involvement in MCCo calibration activities i
6.
MCCo audits of McCo calibration activities 7.
NRC involvement in MCCo calibration activities 8.
GCo or MCCo NCR's generated which address calibration activities 1
9.
Requirements and performance of Quality Control reviews
- 10. Dispositioning of out-of-calibration or damaged calibrated tools and equipment.
- 11. A broad scope review of other documentation activities to assess whether the types of documentation problems identified in the torque wrench calibration activities existed in other areas
- 12. Training, skills, and qualifications of MCCo personnel performing calibration functions
- 13. MCCo review of calibrations performed by others for them
- 14. Records control
- 15. Accountability of records 16.
Performance of calibrations
- 17. Calibration procedure adecnrcy
- 18. Storage and maintenance of calibrated tools and equipment
- 19. A review of all calibration records not recently reviewed by the NRC as part of the investigation.
P ga 2 AUDIT TEAM The G.O. QA audit team consisted of the following personnel:
Principal Team Members D. A. Brown Auditor QA Supervisor-Braidwood.*
S. M. Jaquez Auditor QA Engineer-Braidwood S. J. Reutcke Auditor QA Engineer-LaSalle R. D. Vine Auditor QA Engineer-LaSalle R. E. Waninski Auditor QA Engineer-LaSalle K. J. Hansing Lead Auditor QA Supervisor-Byron G. F. Marcus Management Observer Director Quality Assurance (Engr /Constr) l Others G. M. Maksimuk Auditor-Data Taker QA Engineer-LaSalle A. M. Montalto Auditor-Data Taker QA Inspector-LaSalle E. A. Kram Auditor-Data Taker QA Engineer-Braidwood R. F. Smeets Observer QA Engineer-LaSalle M. J. Wendell Observer QA Engineer-LaSalle Auditing activities conducted by the data takers and the LaSalle personnel were performed under the direction of a principal team member and were reviewed by an off-site member of the audit team.
PERSONNEL CONTACTED The following personnel were contacted during the course of this audit:
M. Wherry MCCo QC Supervisor D. Kanakares MCCo QC Inspector D. Kozlowsky MCCo QC Inspector P. Granby MCCo QC Inspector B. Hamilton MCCo QC Inspector l
B. Angell MCCo QC Inspector R. McClosky MCCo QC Inspector T. Harrington MCCo (Former) QC Inspector K. Hamilton MCCo Project Manager B. Balz MCCo Head Doc. Clerk J. Terry MCCo QC Inspector J. Bitner MCCo QC Inspector D. Shamblin CECO Proj. Constr. Super.
A. Patak Continental Insurance MCCo. ANI W. Caldwell Hartford Insurance CECO's ANI e
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Paga 3 Eh*IRANG )EETING An entrance meeting was conducted on June 29, 1982 with the following personnel in aitendance:
- R. Waninski GCo QA Auditor
- S. M. Jaquez GCo QA Auditor
D. A. Brown GCo QA Auditor
- K. J. Hamilton MCCo Project Manager
- M. Wherry MCCo QC Supervisor
- W. E. Vahle GCo PCD Lead Mechancial Engineer R. A. Braun GCo QA QA Supervisor R. D. Vine GCo QA Auditor
- D. J. Skoza GCo PCD Engineer D. J. Kanakares MCCo QC Inspector G. F. Marcus GCo QA - GO Management Observer The scope of the audit was discussed at this time.
denotes present at exit meeting.
EXIT MEETING An exit meeting was conducted on 7/8/82. The audit results were discussed and acknowledged by those present. The following personnel were present at the exit meeting in addition to the personnel indicated above:
A. R. Huffman MCCo QA Engineer R. T. Rose GCo PCD Lead Struct. Eng.
J. J. Maley GCo Manager of Projects 4
I I
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I
Pzga 4 OVERAIL AUDIT ASSESSMENT It is the conclusion of this audit team, based on the extensive review of MCCo quality records, that the documentation problems It originally identified by the NRC are limited to calibration records.
was further concluded that the duplicating of some signatures and data did not appear to be an attempt to falsify quality records but rather was a time saving measure used to ha.ndle the numerous, repetitious calibration records as they vie'ad the calibration functions as a go, no-go type check.
Relative to the adequacy of the surveillance and audit activities, our evaluation indicates that many qualified individuals had examined this area and that without being sx cifically attentive to looking for record alterations they would not hve identified this as a quality l
issue. Examination of the overall surveillance and audit process, however, does indicate that our auditing methodology involving large ntnbers of similar records needs to be changed to provide that larger samples be taken to achieve a better assessment. As a result, Quality Assurance has committed to implement this change.
i Evaluation of the reports where torque wrenches were found to be out l
of calibration or had questionable calibration data or records were deemed to have no adverse impact on plant construction. This is based on the records reviewed and the results of independent inspections of bolt The torquing by the Independent Testing Agency involving Morrison.
inspection, conducted by CECO.'s Independent Testing Agency, examined Only 81 of the 6,756 Morrison installations between 1977 and June 1982.
l 6,756 installations were rejected for low torque values during the 6 year i
The reject rate of less than 1.2% supports the conclusion that period.
torque wrench calibration was not a problem and helps explain, at least in part, why this calibration documentation matter had not surfaced.
In addition, examination by Quality Assurance of follow-up checks conducted by Project Construction of other calibration areas has not identified any cases where the installed condition of Unit #1 equipment appears questionable.
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i SLBNARY 1.
Assessment of Audit Questions 1-12 1
In order to ascertain if there were any actions which could have discovered the " deficiencies" in Morrison calibration records which are a
the subject of this audit, the following areas were investigated.
- 1) Adequacy of, site QA audits 4 surveillances
- 2) Involvement of GCo 4 MOCo ANI's
- 3) Trends of applicable GCo 4 MCCo NG's
- 4) Adequacy of MCCo internal auditing
- 5) Past NRC site inspection activities
- 6) Adequacy of Co G.O. QA audits 4
The effort was directed at determining if this problem went undetected due to oversight by many parties or a widespread problem not adequately addressed. The results in these areas can be generalized as
'follows:
(1) McCo's ANI and GCo's ANI did not document evidence of examining calibration reports as this was their normal practice in the past.
(2) Region III Inspections (57 in 1981 6 1982) did not uncover any I
problems with McCo quality control records. Five of the fifty-seven site visits involved review of MCCo quality records.
One of these visits involved an NRC investigation of an allegation of lack of control of quality records.
l (3) No GCo NCR's have had to be issued for concerns relating to MCCo calibration records. Therefore, no trends were overlooked.
I
"(4) No MCCo NCR's have had to be issued for concerns relating to calibration records. Therefore, no trends were overlooked.
(5) Morrison internal audits of calibration activities have been extensive and did not identify any calibration record problems.
(6) GCo Site QA surveillance acitivites consisting of 27 calibration surveillances, which specifically covered thirteen calibration records since 1979, were found to have adequate coverage and frequency.
(7) Twenty-four Site GCo QA audits were done on schedule with qualified auditors and recorded objective evidence is sufficient to support the conclusions of those audits. Of the audits conducted since 1979, nine covered site calibration activities.
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1 P ga 6 (8) G.O. audits addressed the areas of Morrison calibratior.
activities and did not discover similar calibration documentation probl es.
(9) Site CECO QA examined 64 MOCo calibration reports during its surveillances and audits since 1979.
(10) None of the Morrison calibration documents found deficient in the NRC investigation were specifically examined in any CECO audit or surveillance.
In sumation, many qualified individuals examined the calibration l
docunents as well as many other McCo quality documents in accordance with quality auditing and surveillance plans; however, by the nature of the sampling process inherent in the audit and surveillance process they did not specifically discover the calibration record deficiencies.
Furthermore, without being sensitized to look for record alterations or repetition either by allegations, specific training and experience or as a result of previous problems, it is doubtful that the McCo calibration docunent type problems would be identified in the normal audit and surveillance process.
2.
Assessment of audit questions 13-16 In order to determine the adequacy and accuracy of Quality Control reviews of quality records, the following record types were examined:
a.
Calibration records b.
Material procurement documents c.
Material receipt records i
d.
Installation documentation / travelers e.
NDE reports f.
NCR's I
g.
Test reports h.
Procedures and work instructions An evaluation was made of the adequacy of the Quality Control reviews for the above listed record types by examining the Quality Assurance manual and procedure requirements and by interviewing the Quality Control personnel who perform the reviews.
It was found that the requirements and meaning of the Quality Control reviews were not clearly delineated in the procedures for several of the record types. As a result of interviewing the MCCo Quality Control
{
personnel performing the actual reviews, it appears that these Quality Control personnel are knowledgeable in how to do the reviews and overall are doing adequate technical reviews. The lack of delineated requirements for Quality Control reviews is identified as a deficiency in Attachment A of this report.
i I
)
i
Attachment H l
Page 7 To verify accuracy of Quality Control reviews, a sample of each above listed record type was examined. With the exception of calibration records all of the record types reviewed were found complete and acceptable. The deficiency relating to calibration records is identified in Attachement A of this report.
To determine proper disposition of out-of-calibration or damaged calibrated tools and equipment, MCCo NCR's were reviewed and compared to the McCo Deleted Instrtsment Log and Hold Tag Log entries involving calibrated tools and equipment. Through this review it was determined that MCCo.'s Quality Assurance Manual requirement, Section 10.10, was not being consistently followed in that nonconfomances were not generated each time a calibrated tool or piece of equipment was suspect and put on hold. The need for issuance of an NCR for suspect equipment became a requirement on October 8,1979. MCCo Procedure PC-31 does not include this requirement and thus appears to be a contributory factor in the inconsistent issuance of NCR's for suspect calibration tools and equipment. This deficiency is identified in Attachment A of this report.
3.
Assessment of Audit Questions 17-22 A review of all MCCo calibration reports, not previously reviewed by NRC, was performed to determine the types and extent of documentation problans. This review identified a generic problem relating to reproduction of signatures and data and is identified in Attachment A of this report.
Also, in an effort to determine if the problems found in the calibration area were present in other McCo Quality Control documentation, a review of the following documents was performed:
a) Receiving inspections b) Weld data, and traveler packages c) As-Built drawings with checklists (small bore) 6~e.
k 8
Attachmmt H Page 8 d) Com:enent support checklists e) Mecunical revision directives f) Nm's g) N m Log h) Final line walk reports
- 1) Pressure test reports j) AfME Code Data Reports (CECO Supplied) k) NDE Reports
- 1) Quality Control surveillances m) On-Site audits n) Purchase requisitions o) Welder qualifications p) Quality Control inspector qualifications q) Calibration personnel certifications This extensive review found only isolated instances of the use of white-out, incomplete information and stamping of Quality Control approval signatures. Also, the isolated cases of white-out identified were judged to be corrective actions and not an attempt to falsify.
Furthermore, the use of white-out on quality documents was not specifically prohibited at the site until February 1982 when a letter to this effect was sent to all site contractors as a result of a recent NRC penalty assessment against the Zirnner Project. As a result, it is the conclusion of this audit that the documentation problems only involve the calibration area and the quality control document review activities of a specific Quality Control Inspector. Also, one case was identified during the review of Quality Control Inspector qualifications where the certification of an inspector was not signed but otherwise appeared in order. This deficiency is identified in Attachment A to this report.
Since most of the problems identified in the calibration area were traceable to one Quality Control individual, an expanded review was performed of other records processed by that person. A selection of records from the following record types reviewed by that McCo Quality Control Inspector were examined:
a) Receiving and storage inspections b) NCR's c)
Installation records d) Receiving reports e) Heat treatment records f) Purchase requisitions g) Pressure test memoranda 6 test results
This examination found'no repetitious cccurr ncos of the i docu=ntation problem:: noted in' the calibration area. This further supports the audit ccnclusion that the gsneric documentation problems are isolated in the area of calibrations.
4.
Assessment of Audit Questions 23-26 A review of training and qualification records for the mi11 wrights and fitters performing calibrations indicated that all were properly trained and the training was documented. The training appeared adequate and further the required skills were within craft capability.
Eye examinations of Quality Control Inspectors performing calibration activities were reviewed to assure they had required vision capabilities and all were found acceptable. Additionally, the mi11 wrights and fitters performing calibrations were eye tested for near and far vision acuity and all passed. An examination of the areas where calibration is performed was conducted to assure that adequate lighting was present; all areas were found acceptable.
A review of MCCo's handling of calibrations performed by the Operating Station Maintenance Department indicated that MCCo does not have adequate guidelines to assure review of test results for acceptability of the calibration. 'Ihis deficiency is identified in Attachment A to this report.
5.
Assessment of Audit Questions 27-33 MCCo has established and implemented measures to control access to the documentation vault by using a listing of personnnel authorized to remove doctnents from the vault and requiring logging of documents being taken in or out and identification of the person involved. Also, since June 29, 1982, a security guard has been posted at the vault to countersign issuance of documentation, monitor the review of such issued documentation to assure no alterations are made and assure that Unit #1 and common documentation with Unit 2 is only reviewed in the presence of the guard. Additionally, all Unit #1 documentation in the vault is secured with locks on the file cabinets. This special security arrangement is to be maintained until conclusion of the NRC investigation.
Prior to the actions taken on June 29, 1982, the CECO Project Construction Superintendent had verbally communicated to the McCo Project Manager, on June 24, 1982 that actions should be taken to insure that no documentation would be altered. This requirement was connunicated to the Quality Control personnel verbally on June 24, 1982 and again on June 25, 1982 in the fom of written correspondence from the MCCo Quality Control Supervisor to the Quality Control personnel. During the week of June 21, 1982 when the McCo Quality Control Inspector involved in the calibration documentation problem became aware of the fact that duplicated signatures were unacceptable on calibration reports, he decided to go back and initial those calibration reports he had issued with his signature duplicated. This. initialing of signature's which occurred for about two hours ended on June 24, 1982.
It was the auditor's opinion that the addition of the initials was done to correct an omission as opposed to falsifying records.
I Paga 10 In the area of records accountability this auditor determined that MCCo.'s logging systems are adequate to verify accountability of records. However, there was no documented evidence that MCCo has performed reviews to determine if documents are missing. Also, current i
procedures do not sisecifically provide instructions for replacing lost records. This deficiency is identified in Attachment A to this report.
6.
Asessment of Audit Questions 34-38 A review of the storage and maintenance of calibrated equipment and tools noted that they are kept in an orderly manner and in locked cabinets. Observance of mi11 wrights and fitters in the performance of calibrations indicated they were knowledgeable and competent in their jobs. One procedural deviation was noted with the calibration of torque wrenches and is identified in Attachment A of this report.
The following procedural deficiencies were identified regarding calibrations:
Acceptance criteria and calibration points are not stated a.
for each type of tool or instrument.
b.
Not all calibrated equipment is addressed in procedure PC-31.
The specific deficiencies are identified in Attachment A of this report.
For the majority of the calibrations witnessed, the procedure and actual performance of the calibrations was determined to be acceptable.
I Upon interviewing personnel performing calibration and reviewing 1
calibration histories it was concluded that, in instances where the actual test data was extremely close to the established test reading, the actual values may not have been recorded in all cases; rather, the generic test point values were recorded.
In other words, a go, no go check was performed. The interviews did, however, indicate that out-of-tolerance calibration readings were identified. The deficiency relating to recording of actual data is identified in Attachment A to this report.
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Response
Morrison Construction Company is requested to respond in writing to the Findings and Observations listed in Attachment A to this report by July 23, 1982. The response must include the following:
1.
Action taken to correct the deficiency 2.
Action taken to prevent recurrence 3.
Data for full compliance Please address your response to:
Commonwealth Edison Company G. F. Marcus Director of Quality Assurance (Eng./Constr.)
P.O. Box 767 Chicago, IL 60690 With copies to:
Commonwealth Edison Company W. J. Shewski Manager of Quality Assurance P.O.. Box 767 Chicago, IL 60690 and Commonwealth Edison Company K. J. Hansing QA Supervisor - Byron Station Byron, IL 61010 e
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ATTACHMENT A FINDING #1 Contrary to 10CFR50 Appendix B Criteria XVII the Quality Control final review 'and acceptance of calibration reports was not adequately implemented to assure complete and acceptable calibration records.
Discussion An examination of completed and accepted calibration reports identified the following problems:
a)
Wrench type was not indicated on torque wrench #10894 calibration reports dated March 16, April 3 and September 25, 1981.
b)
Quality Control review of torque wrench #97366 calibrated on July 31, 1981 was not documented.
c)
Error measurements were not indicated on the report for torque wrench #97366 calibrated on January 2, 1981. The error values, however, were attainable from information on the report and found acceptable.
d)
Test data was not recorded for pressure gauge #PG-31 calibrated on June 8, 1982.
FINDING #2 Contrary to MCCo Quality Assurance Manual Section 10.10, nonconfomance reports have not been generated for disposition of each calibrated tool or instrument found suspect.
Discussion A review of MCCo's Deleted Instrument Log, Hold Tag Log and NCR's indicated the following torque wrenches as damaged or out of calibration but records of NQt's for each was not available:
a)
Torque wrench #4292 - Hold Tag #1106 - Torque wrench was scrapped instead.
b)
Torque wrenches #15758 and #10468 - hold tag #1223 - Torque wrenches needed to be repaired.
(The Hold Tag Log showed item was repaired and the Hold Tag removed.)
c)
Torque wrench #E40468 - hold Tag #1171 - Torque wrench was damaged while being used.
(Hold Tag Log showed item was repaired and the Hold Tag removed.)
e
PJga 2 Attachment A Other instances of hold tags being issued on calibrated torque wrenches or torque screwdriver without references to applicable N G's are as follows:
Hold Tag s #1131, 1132, 1133, 1134, 1108, 1129, 1092, 1103.
Furthermore, a review of procedure PC-31 Rev. 3 dated July, 1977 indicates that the requirement of Section 10.10 is not addressed and thus could be a contributing factor in the inconsistent implementation of NG's for suspect calibrated tools and equipment.
FINDING #3 Contrary to 10CFR50 Appendix B Criteria XII, MCCo has not established and implemented adequate guidelines for receipt inspection review of calibration reports as to acceptability of calibrations perfomed by outside agencies.
Discussion Five calibrations were accepted for the torque wrench tester where the tester was out of calibration. CECO NCR #599 has been issued for engineering disposition.
FINDING #4 Contrary to 10CFR50 Appendix B, Criteria XII and V, MOCo Procedure PC-31 has the following deficiencies:
a)
Not all calibrated tools 6 equipment used by MCCo are covered by this procedure.
b)
The procedure does not address acceptance criteria for all the calibrated tools and equipment and c)
The procedure does not always address the calibration method and specifically the points of calibration where applicable.
Discussion a)
A review of calibration equipment indicates that some tools and equipment have not been included in procedure PC-31. These items are:
- 1) Deadweight tester
- 2) Torque wrench tester
- 3) Densitometer
-- -.---- -- --- --- l, l
Atttchment A b)
R e following items, although listed in MCCo procedura PC-31, did not have specific calibration acceptance criteria listed (ie. acceptance tolerances). The auditor was told that the manufacturers recommendations were used as the basis for acceptance.
4
- 1) Gauge blocks
- 2) Multi point recorder
- 3) Micrometers
- 4) Linear measuring devices
- 5) Optical level
- 6) Ameter
- 7) Standard micrometer lengths
- 8) Standard verniers In addition, the following list of items were found to have acceptance criteria discrepancies or lack clarity.
9)
PC-31 states that dial indicators only need free movement of the plunger, but calibration Certification form PC-61 indicates tools should be within 0.001" of a standard.
-10)
PC-31 indicates pressure gauges are to be calibrated within
+ 5%. While witnessing pressure gauge calibration Hemonstration, MCCo personnel were noted to be divided as to whether this means 5% of full scale or each incremental calibration value.
c). While PC-31C was noted to be very specific about data recording for torque wrenches, the following inconsistencies were noted in other areas:
1)
Micrometer (S/N QC-5) was tested on June 4, 1982 at six settings, whereas on March 4,1982 it was tested at thirteen settings.
2)
Test settings for pressure gauges are listed on Calibration Certification form PC-61, but are not indicated in procedure PC-31.
FLNDING #5 Contrary to 10CFR50 Appendix B, Criteria XII and XVII, it was an c
accepted MCCo aractice not to record the actual test data on calibration records when tie dm was extremely close to the standard value used.
Discussion Through interviews with the personnel performing and witnessing the calibration activities and a review of the historical records, it became evident that MCCo did not always record the actual test data readings when they were within acceptable limits. S e generic test point values were recorded. A go, no go check was performed. The interviews did conclude, however, that out of tolerance calibration readings were being identified.
I
Fage 4 Atttchment A FINDING #6 Contrary to 10CFR50 Appendix B, Criteria XII and XVII, Morrison Construction Co. is not adequately controlling calibration documentation for measuring and test equipment.
Discussion A review of all calibration records on file at Morrison was conducted to deternine the extent of documentation deficiencies. The deficiencies involvedy (1) the frequent use of reproductions of calibration report forms already signed by the cognizant Quality Control Inspector and Witnesses to record calibration data, (2) the incompleteness of data, dates and signatures on calibration reports and (3) the use of reproduction of calibration data on consecutive reports.
FINDING #7 Contrary to 10CFR Appendix B, Criteria IX and XVII and Morrison procedure PC-41 Rev. O, three (3) voltage / amperage (V/A) readings recorded on Morrison Quality Control surveillances were found to be out of procedure tolerances and there was no evidence of corrective action.
In addition, there were instances of incomplete and/or incorrect information on the surveillance forms, such as lack of proper procedure revision and V/A ranges listed on the form which were not consistent with the procedure ranges.
Discussion a) The following reports had the V/A readings out of procedure tolerances.
Report Date Reading Procedure Range Observed Procedure i
4/24/81 Amps60-250 55 amps P1-3LS Rev. 7 1
6/1,2/78 Amps60-250 50 amps P1-11LS Rev. 7 12/2/77 Amps60-110 125 amps P1-20LS Rev. 4 The audit team subsequently reviewed the three above cases with a Sargent 6 Lundy Welding Engineer. This discussion included a review of the associated weld procedures, the materials being welded, and the weld inspections performed. Based on this review, it did not appear to this S6L Engineer that a quality concern exists.
4 P:ga 5 Attachment A b) In addition, inaccurate recording of surveillance information was identified. Out of 343 surveillance reports reviewed,104 had incorrect or no procedure revision identified on the report form and 95 had V/A ranges listed which were not consistent with the ranges provided in the applicable procedure.
t OBSERVATION #1 Quality Control final review requirements on quality records are not clearly defined in MCCo procedures or site instructions.
Discussion The following record types receive a final review by McCo Quality Control personnel but the meaning and requirements of this review are not delineated:
a)
Calibration records b)
Installation documentation / travelers c)
NDE reports d)
Test reports Additionally, the final Quality Control review of the Weld Data Record is performed, but documentation to indicate acceptance, other than entering selected information from it on the Status Log, is not provided.
OBSERVATION #2 MCCO has not performed reviews of records to detemine if documentation is missing. Additionally, current procedures do not provide instructions for replacing lost records.
Discussion MCCo's systems of logging documentation appear adequate as a means of accounting for documentation but no evidence was available to indicate i
that McCo had performed reviews for, missing documentation. McCo also has l
not established steps to be taken to replace documents discovered missing.
l
+
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Pago 6 Attachment A OBSERVATION #3 M111 wrights were observed calibrating torque wrenches with some variation from procedure PC-31.
Discuw ion While observing millwright and pipefitter demonstrations of the calibration of varimas tools, it was noted that " clicker type" torque wrenches were manually calibrated. A review of procedure PC-31 indicates that these wrenches are to be calibrated using the mechanical lead device which is built into the torque wrench tester rather than be pulled by hand.
The following cements are relevant to this observation:
1)
The pipefitters and mi11 wrights >erforming the various calibration functions appear to')e competent.
2)
Although use of the mechanical lead device would seem to make the recording of calibration data more accurate, the results obtained by manually calibrating the " clicker type" wrench were not substantially different.
3)
The mechanical device on the torque wrench tester can not accocraodate large (500 ft-lbs) torque wrenches.
OBSERVATION #4 MCCo Tool / Instruments Inventory listing is not current.
Discussion Gauge blocks (S/N bel-9) are not listed on MOCo Tool / Instruments Inventory List. Also, as a comment, the list should be updated as several hand written entries were noted.
OBSERVATION #5 A Quality Control Inspector certification was not signed by the MCCo certifying individual.
Discussion A review of certifications for all Quality Control Inspectors identified the omission of the Certification r,ignature for J. R. Ragan, Level II Limited. Other than the missing signature, the infomation on the certification form and back up documentation appeared to be in order..
x
LASALLE COUNTY UNIT I & II REPORT OF:
ACTION TAEEN EY PROJECT CONSTRUUTION AS A RESULT OF NRC AND C.E.Co./Q.A. CONCERNS RELATIVE TO MORRISON CONSTRUCTION COMPANY CALIBRATION RECORDS.
DATE:
JULY 8, 1982 REPORTED 3Y:
A DAN SK0ZA U
FROJECT CONSTRUCTION ENGINEER RE7IEWED BY:
wf VAREDI VAHLE PROJECT CONSTRUCTION LEAD MECHIE10aL ENGINEER b
APPROVE 3 BY:
ROJECTS
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SUMMARY
This report summarizes the confirmatory measures performed by Project Construction to verify the adequacy of the field work done by Morrison Construction Company which requi:ced the use of calibrated torque wrenches and hydro teat pressure gauges. Our review sub-stantiates our conclusion that bolts were properly tightened and pressure systems were properly measured.
Exceptions that were found represent small percentages of the sample. It is not evident that these exceptions are tzsceable to calibration deficiencies.
All exceptions discovered have been corrected or are otherwise addressed in this report. Therefore, we believe that the plant construction is adequate and satisfactory.
O e
r REPORT I.
TORQUE VRENCH CERTIFICATIONS:
Of the approximately 6,000 MCCO torque wrench certifications the following Minor and Major catorgories were identified.
A.
Specific Concerns Deemed Minor 1.
Torque wrench type misidentified or not stated.
2.
Math errors on certification but wrench within tolerance.
3 Error calculations not performed but wrench within tolerance.
- h. Missing QC signatures or report date.
B.
Specific Concerns Deemed Major 1.
Eingle zeroxed report - data and all signatures.
2.
Group xeroxed report - data and all signatures (1-6weekperiod,1-12weekperiod,1-3weekperiod).
3 Missing tester or witness signature.
h.
Incomplete or uncertain data at isolated data points.
- 5. Missing reports.
C.
Torque Wrench Out-Of Tolerance Concerns Certifications identified with out-of-tolerance readings at isolated data points and had been accepted by MCCO Q.C.
l l
D.
Generic Concerns 1.
Numerous series of consecutive reports with identical original test data indicating actual test data was notrecordedbutago/nogotestwasutilizedand nominal values recorded when the data point' Gas deened within calibration tolerance.
2.
Numerous cases of Q.C. acceptance stamp xeroxed onto calibration data sheet already signed. Only date of Q.C. review and page number was affixed to indicate Q.C. acceptance review.
l 3
r w-7.
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1 The specific concerns deemed minor required no remedial field checks of the work done with the subject wrenches.
In all cases the concern is a paper problem. Other infomation existed on the certification to correct the concern, or a calculation was easily perfomed to correct the concem, or the Q.C. review was performed on the calibration certification.
The specific findings deemed major and the out of tolerance wrenches required ascer+*4
- g the safety related work performed with the wrench in question and field checking the torque for acceptability. $, hangers with approximately 12, CFA's and bolting 2
on 2 valves were required to be rechecked. The results of the re-checks indicated ik CEA bolts on 9 hangers were found lower than the specified test torque. These bolts will be retorqued or re-placed per LS-CEA requirements. The first h of these hanger as, semblies were recalculated and found that they would function with-out the subject CEA's. The remaining corrective action will be ce=pleted by July 12, 1982.
The basis for accepting the installed work given the generic findings are the following:
A.
MOCO general calibration procedure PC-31 only requires a 6 month frequency for torque wrenches utilized on all work except CEA's.
CEA work required weekly or monthly calibra-tions of torque wrenches. Calibration certifications with actual data exist to meet the 6 month frequency intervals.
B.
It has been shown that torque wrench accuracy is not important for CEA work. Se primary reason for specifying l
a torque value in CEA work is to assure an auditable method of ascertaining that the CEA is set in the concrete. Once the anchor has been shown to be set, torque tightness of the CEA becomes irrelevant. This being the case, the go/
no go calibration test utilized should be sufficient to ascertain that the torque wrench is accurate enough to set the CEA. An independant check performed by ConAm Inspection Agency with their own calibrated torque wrenches on a mini-l mun of one anchor per hanger assemblies but at least one out of each ten expansion anchors installed in that assembly.
showed no excessive rejection of CEA's throughout the work l
history. Se rejection has been extremely low; on the order of 1% of the bolts tested.
l e
Attachment H C.
Evidence exists that torque w enches were discarded or returned to the manufacturer when calibration data showed the wrench out-of-calibration.
D.
Evidence exists that the torque wrench calibration certi-fication did receive a Q.C. review even thcush the Q.C.
stamp and signature were zeroxed. The date of review and page number were original writings.
In summary, we have concluded that the torque wrenches were sufficiently accurate to assure the installed work meets its func-tional requirements.
II.. TORQUE WRENCH TESTER CAT m ATION:
During the NRC review a concern was stated that the tester utilized to calibrate the torque wrenches was out-of-tolerance on specific scale readings. Commonwealth Edison Company Nonconformance Report 599 documented the calibration discrepancies. Pre 14=4 = v reviews have indicated the following:
A.
Variables such as the tester condition and operator variance probably caused the erroneous readings in the ranges identified.
3.
The torque tester or torque wrench calibration tolerances are not the primary concern in torque operations. Tolerances can be relaxed in most situations with assurance the installed bolt condition is acceptable.
On the above basis, no checks of the installed work has been initiated.
III. HYDRO PRESSURE GAUGE CALIBRATION CEftnr1 CATIONS:
Approximately 1000 MCCO Hydro Test Pressure Gauge Calibration Certifications for 100 gauges were reviewed by C.E.Co. Q.A. auditors.
The known concerns are the following:
~
Attachment H i
o A.
Specific Concerns 1
Partial or no calibration data listed.
2.
Nowitnessand/orQ.C. signatures.
1 3
Inste. of calibration in error.
h.
Out-of-tolerance readings accepted by Q.C.
- 5. Calibration missing.
6.
Tester and 4.C. signature not original.
E.
Generic Concerns 1
Actual test data was not recorded but go/no go test utilized and nominal values recorded when the data point was deemed within calibration tolerance.
2.
Witness and Q.C. signatures zeroxed onto calibration data sheet. No objective evidence exists on calibra-tion data sheet indicating tests were witnessed.and Q.C. reviewed.
h e specific concerns can be resolved without remedial field checks.
The questionable gauges were not utilized at all, or not utilized in the ranges with the problem data.
B, Generic concerns require several different explanations and actions to resolve them:
1.
Variations in industry instrument standards and dial reading techniques which include paralar effects tend to vary the readings taken during instrument calibrations.
In some cases, time was not taken to log the actual readings if it was apparent that the values were within the specified tolerances. In these cases, the nom 4=1 settings were apparently logged. Reviews of the calibra-tion files for each instrument and successive calibrations of the same instrument have shown only several instances of instruments out of tolerance and only within a small part of their range. These reviews substantiate that the readings taken were of sufficient accuracy to use as a basis for the certifications. Additionally, records indicate 35 hydro test pressure gauges out of 107 were discarded during the course of work when calibrations could not be completed within specifications.
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2.
The establishnent cf validity of the zeroxed witness and Q.C. signature can be done through the Rydro Test Pressure Gauge Usage and Calibration Log and by virtue of the fact that gauge calibration is a two(2) man operation. For each gauge, a log is kept identifying the dates the instrument was calibrated and the test number corresponding to that date. The Q.C. inspector that witnessed the test then signs the pressure gauge log indicating the test was completed. his was done with original signatures on a 100% basis. The testing apparatus requires two people to operate, one to pump the machine and read the pressure gauge and another to assure the dead weights are free floating. This has been done historically by a Pipetitter and Q.C. inspector.
On the above basis, it was not necessary to establish a program to recheck previous pressure tests.
The containment valve structural bolting review has been completed.
IV. All bolts on the safety related valves have been torqued to within the ranufactures' recommended values.
1 l
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