ML20032B302

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IE Insp Rept 50-423/81-11 on 810901-25.Noncompliance Noted: Failure to Use Controlled Design Drawing for Erecting Cable Tray Supports & Failure to Follow Procedure Re Corrective Action
ML20032B302
Person / Time
Site: Millstone Dominion icon.png
Issue date: 10/15/1981
From: Elsasser T, Mattia J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20032B281 List:
References
50-423-81-11, NUDOCS 8111050412
Download: ML20032B302 (7)


See also: IR 05000423/1981011

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

Region I

Report No.

50-423/81-11

Docket No.

50-423

License No.

CPPR-113

Priority

--

Category

A

Licensee:

Northeast Nuclear Energy Company

P. O. Box 270

Hartford, Connecticut 06101

Facility Name:

Millstone Nuclear Power Station _, Unit 3

Inspection at:

Waterford, Connecticut

Inspection conducted: September 1-25, 1981

I At

/ o[ s/P/

Inspectors:

P

1

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b J.C. Mattia, Senior Resident Inspector

date signed

date signed

date signed

Approved by:

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date' signed

T. ElsasYer, Chief, Reactor Proje. cts

Section 1B, DRPI

Inspection Surmary:

Unit 3 Inspection on August 20-31 and Sept. 1-25, 1981

(Report No. 50-423/E1-11)

Areas Inspected:

Routine inspection by the Resident Inspector of work activitTes

associated with pipe erection; structural support welding; installation of elec-

trical raceways and training. The inspector also performed plant inspection tours

and reviewed licensee action on previously identified items. The inspection in-

volved 48 inspector hours, including 3 off-shift hours by one NRC inspector.

Results: Of the six areas inspected, two items of noncompliance were identified

in the following areas:

(1) failure to use controlled design drawing for erecting

cable tray supports (Paragraph 4); (2) failure to follow procedure for verifying

corrective action taken for items found during audits (Paragraph 5).

Region I Form 12

(Re" gi[750d12 811019

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PDR ADOCK 05000423

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DETAILS

1.

Persons Contacted

Northeast Utilities Service' Company (NUSCO)

D. Diedrick, Quality Assurance Manager

K. Gray, Construction QA Supervisor

R. Hastings, QA Engineering Technician

K. Murphy, QA Construction Technician

S. Ore # ice, New Site Construction Superintendent

J. Putnam, Senior Construction Engineer

T. Sullivan, Resident Engineer - New Site Construction

Stone and Webster Corporation (S&W)

W. B. Anderson, Assistant Superintendent Field QC

J. Carty, Superintendent of Engineering

P. A. Gagel, QA Program Administrator

J. G. Kappas, Superintendent of Construction

W. MacKay, Resident Manager

G. Marsh, Senior Engineer, Welding /NDE

M. R. Matthews, Assistant Superintendent Field-QC

A. Prusi, Assistant Superintendent of Engineering

R. Reams, Materials Supervisor

F. Sullivan, Senior Resident Engineer

G. G. Turner, Superintendent, Field QC

Westinghouse Corporation.

E. Harlow, Site Representative

C. Peterson, Site Representative

The inspector also conferred with other licensee and contractor personnel

during the course of the inspection.

2.

Pipe Supports

The inspector measured the field fillet welds for a pipe support identified

as 3-SIL-1PSR-498, located inside the containment, at elevation - 8'.

The

welds conformed to the size requirements of design drawing 12179-BZ107D-53-1,

and also to ASME code accept.ance criteria.

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3.

Safety-Related Piping Welding & Installation Activities

a.

The following weld joints, which were in various stages of welding,

located in the containment building were inspected to verify

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compliance with welding and installation procedures and code

requirements:

(1) 3RCS-029-11-1, Field Weld #001. This weld joint was

completed but had been excavated for repair due to

lack of complete fusion (Radiographic Station 28-42).

The excavated area had been radiographed and liquid

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penetrant examined and accepted. The weld repair was

in process. No items of noncompliance were identified.

(2) The inspector observed the rigging of a 29" motor-operated

reactor coolant isolation valve for the hot leg loop. -The

valve was supplied by NSSS and identified as NEU-RCPCLS-03.

The rigging and handling was in accordance with the pro-

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cedure requirements.

(3) The inspector observed the welding of the incore instru-

mentation socket weld identified as Field Weld #48 of

Control Drawing 12179-CI-BMI-1. The welding was being

performed in accordance with S&W Technique Weld Sheet

No. W13J, Rev. 1.

The inspector also-inspected completed

welds No. 49, 50 & 51 to determine compliance with

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applicable procedure requirements. The weld history

data cards were also reviewed. No items of noncompliance

were identified.

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(4) 3SIL-006-41-2, Field Weld #016. This weld joint was

approximately one-half completed. The welding was in-

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accordance with S&W Weld Technique Procedure W12F, Rev.2.

The inspector observed the actual welding and verified

that the requirements of weld procedure were adhered

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to. The weld data card was also reviewed for compliance

with the applicable S&W QA procedure.

No items of non-

compliance were identified.

(5) The ir.spector observed the installation of spool piece

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SIH-9-2-4-2B into the piping system, and the fit of ths

weld joints. No items of noncompliance were identified.

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4.

Installation of Electrical Raceways

The inspector observed the erection of seismic suoports for cable trays

located in the Engineered Safety Features Building (29 ft. elevation).

The inspector noted that the two electricians who were erecting the

supports were not using a controlled design drawing.

They were using in-

stead two portions (8 " x 11") of design drawing EE-34JA-3, entitled,

" Cable Tray Support Miscellaneous Details - Sheet". The copied portions

were sections of the design drawing made on a copier. The insoector

questioned the electricians as to how they obtained these copies, and

was infomed that their foreman had given them the partial copies of

the design drawings. .The inspector informed the licensee that the use

of uncontrolled design documents is an item of noncompliance and contrary

to criterion VI (423/81-11-01).

5.

Licensee Action on Previous Inspection Findings

a.

(0 pen) Item of noncompliance (423/81-02-01):

Failure of NbSCO QA

construction to perform scheduled audits. The inspector verified

that the overdue scheduled audits (numbers A40545, A40552, A40571,

A40595) had been performed in accordance with the rescheduled dates

and that they were accomplished by qualified aud'. tors.

In cases

where there were audit findings, the corrective actions were timely

and followed up by the auditors, except for audit A40571. Audit

A40571 had one adverse finding (No S&W certification form for one

person hired in 1980 as a field QC technician) which was not followed

up in accordance with NUSCO procedure NQA 1.14.

The audit was per-

formed on fiay 20 and 21,1981, and the audit report stated that no

response to .the finding will be required since corrective action

would be taken care of by the implementation of the recently re-

vised S&W Quality Assurance Directive (QAD) 2.5 Revision D.

A

follow up audit was to have been conducted in approximately 6 nionths

to verify implementation of QAD 2.5.

The inspector noted that the

NUSCO QA Section " Audit Surveillance Schedule Follow Up", dated

9/17/81, indicated that the audit finding of A40571 was closed on

5/21/81.

The inspector also noted that the NUSCO QA Audit Surveil-

lance Schedule, dated 9/17/81, did not list an audit of S&W field

QC organization to verify the implementation of QAD 2.5.

The

construction QA supervisor stated that an audit is planned to be

conducted even though it was not on the schedule.

The inspector

informed the licensee thac this was contrary to the requirements of

their procedure NQA 1.14 and 10 CFR 50, Appendix B (423/81-11-02).

b.

(Closed) Significant observation (423/81-02-08):

NUSCO construc-

tion QA organization was not adequately staffed for Millstone

Unit 3.

The inspector reviewed the current staffing of the Unit 3

organization, which is comprised of five persons, plus a supervisor.

The supervisor informed the inspector that all requests for personnel

vacancies have been approved, and that for the current level of on-

struction activities his staff can adequately handle the work load.

The inspector verified that all five persons have been adequately

qualified as lead aucitors in accordance with the NUSCO QA Procedure

NQA 1.07.

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c.

(Closed) Unresolved item (423/81-02-11): Northeast Utilities .

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Topical Report, QA Program, Revision 3A. The Appendix C (Rev.0)

was not current.

It had listed several obsolete quality assurance

related procedures. Appendix C, Revision 1 was updated to reflect

the current procedures and was issued on June 26, 1981.

d.

(Closed) Unresolveditem(423/81-02-14):

Improper follow-up of

surveillance unsatisfactory findings. The NUSCO QA Procedure

NQA-2.10 was revised on March 3, 1981, o state that the surveill-

ance report shall remain open until corrective action by the

contractor / vendor can be verified on a follow-up surveillance

report by the Auditor. The inspector also verified that this

requirement was being implemented by sampling two surveillances

that had unsatisfactory findings.

e.

(Closed) Significant observation (423/81-02-17):

Design criteria

and interface for safety-related conduit supports not fonnally

defined. S&W issued a field construction procedure (FCP) No.297,

on June 9, 1981, to define the methodology to assure that seismic

conduit supports meet the design criteria established in the

specification E350 and design drawings EE-52A & B and EE-34JA,

JB & JC. The field construction procedure was reviewed and

approved by the licensee on Sept. 10, 1981.

f.

(Closed) Unresolved item (423/81-02-24): S&W procedure lacked

specifity in that there is no formal requirement, nor assignment

of responsibility to initiate protective measures for items stored

in-place frcm planned and or adjacent on-going construction activ-

ities.

S&W issued a change notice #1, on Sept. 1981, to Construc-

tion Methods Procedure (CMP) Nn. 1.3, which requires the materials

control group to perform weekly inspections of the various work

areas to insure that material / equipment in the construction areas

are in compliance with the storage requirements. The weekly

inspecticns are to be documented. This item is considered re-

solved and the inspector informed the licensee that implementation

of this change to CMP 1.3 will be inspected at a subsequent NRC

inspection.

g.

(Closed) Unresolved item (423/81-08-07): Graver temporary attach-

ment welds on the containment liner, located approximately 5 ft.

to the right of azimouth 210) at elevation 145' appeared to be not

cleaned and magnetic particle examined. A cleaning and re-examina-

tion was performed by Graver on 8/14-17/81. The inspector reviewed

the Grawr erection control sheet No. 6007, the visual and magnetic

examination reports No. 6007 detailing the methods and results of

this re-examination. No items of noncompliance were identified.

h.

(Closed) Unresolved item (423/81-08-06): Nitrogen purge was

removed on RHR heat exchanger when taken from the storage location

to its final location in the ESF building. S&W issued a memorandum

on Aug. 24, 1981, instructing cognizant personnel that they are

responsible for review of vendor manuals to insure that the vendor's

requirements are to be followed when a purge is removed

The

inspector also reviewed the field QC inspection reports Nos.

M1000234, M1000235 & M1000236, whereby a detailed inspection of

all safety related equipment stored in the auxiliary, ESF and

containment buildings was performed to verify that the vendor's

storage requirements were met. The results of the inspection per-

formed on 8/27/81 did not find any discrepancies.

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6.

Training of NUSCO QA Personnel

The inspector reviewed the training records for one of the' lead QA

auditors. The records indicated that the person was a Level II -

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" witness" in liquid penetrant.

However, the records did not indicate

that the person was certified in accordance with'NUSCO Procedure

NQA-1.09. Discussions were held with the QA auditor regarding her

certifications.

The inspector was informed that she was examined'

(written) on 3/31/81 and was given a practical examination on

6/6/81 but was not certified due to some technicality which is still

unresolved. The inspector asked her if she had witnessed any liquid

penetrant examinations performed by S&W since her examinations.

It

appears that on 7/8/81 she had observed a liquid penetrant examina-

tion being performed by a S&W field QC inspector on reactor coolant

weld joint (surveillance report #C-1636). The inspector informed

the licensee that NUSCO Procedure NQA-1.09 states that "a witness

level is an individual that is qualified to observe the NDE work

performed by others" and that when she was' performing her surveill-

ance activities (liquid penetrant-observation) she should have been

qualified.

It is the NUSCO QA manager's opinion that the Level II-

witness qualification is for when an evaluation of a L.P. examina-

tion is specifically planned, such as in a vendor shop when auditing

or doing an in-process verification. The inspector then informed the

licensee that the QA procedure NQA-1.09 should be revised to be more

specific when witness level is required. This item is condidared

unresolved pending revision of NUSCO QA Procedure (423/81-11-03).

7.

Plant Tours

The inspector observed work activities in progress, completed work and

construction status in several areas of the plant. The inspector ex-

amined work for any obvious defects or noncompliance with regulatory

requirements or license conditions.

Particular note was taken of the

presence of Quality Control Inspectors and Quality Control evidence

such as inspection records, material identification, nonconforming

material identification, housekeeping & equipment preservation.

No

items of noncompliance were identified.

During one of the plant tours, the inspector noted that two pipefitters

were straightening a containment penetration No. 116 which had an

"out of round" condition. They were using a 11.2 ton hydraulic ram.

The inspector informed the licensee that he had two concerns with the

repair.

a.

The piping specification allows repair of dents on piping,

but doesn't state the approved methods. The inspector has

seen various methods used on MS-3, either cold working;

heating & applying force; and use of hydraulic force. The

inspector stated that the approved methods should be in the

specification or a construction procedure.

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b.

The S&W ASME Manual and Quality Standard 15.1 does not address

the situation where a minor noncomforming condition is found

by construction which doesn't require a'nonconformance report

(N&D); but because of its unsatisfactory condition, S&W field

QC should be made aware of it to inspect the before and after

condition. An example of this is the repair of dente.1 or

"out of round" conditions of containmer!t penetrations, where

an inspection report should be issued documenting the condit-

ion and repair.

This item is considered unresolved pending review of licensee's investi-

gation of this matter (423/81-11-03).

8.

Unresolved Items

Unresolved items are matters about which more information is required in

order to ascertain whether they-are a:ceptable. items, items of noncompli-

ance, or deviations. Unresolved items disclosed during the inspection

are discussed in varagraphs 5 & 6.

9.

Management Meetings

At periodic intervals during the course of this inspection, meetings were

held with senior plant management to discuss the scope and findings of

this inspection.

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