ML20039B513
| ML20039B513 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/25/1981 |
| From: | Cerne A, Gallo R, Reynolds S, Schulz R, Varela A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20039B508 | List: |
| References | |
| 50-443-81-12, 50-444-81-10, NUDOCS 8112230174 | |
| Download: ML20039B513 (15) | |
See also: IR 05000443/1981012
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Region I
50-443/81-12
Report No.
50-444/81-10
50-443
Docket No. 50-444
CPPR-135
License No.
CPPR-136
Priority
Category
A
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Licensee: Public Service Company of New Hampshire
1000 Elm Street
Manchester, New Hampshire 03105
Facility Name: Seabrook Station, Units 1 and 2
Inspection at: Seabrook, New Hampshire
Inspection conduc ed: October 5-November 16,1981
Inspectors:
H')
i
A. C. Cerne, Sr. Resident Inspector
date signed
,0 O '
l'
8l
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5'. D. R'eynol ds , / Reactor Inspector
date signed
OL L
nlmlet
fa R. D. Schulz, Reactor Inspector
date signed
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A. A. Vaktla, Reactor Inspector
d~te signed
a
Approved by:
N
(
ll 2 d9 l
R. M. Gallo, Chief, Projects Section 1A,
date signed
Division of Resident and Project Inspection
Inspection Sumary:
Unit 1 Inspection on October 5-November 16,1981 (Report No. 50-443/81-12)
Areas Inspected: Routine inspection by the resident inspector and regional. based inspectors
of work activities relative to the piping QA program, pipe installation, welding, and
supports; concrete placement preparation, cadweld splicing, site civil testing, and con-
tainment liner and concrete interfacing; component installation; instrumentation supports;
and structural connections to include design control over the structural impact of combined
loadings. The inspectors also reviewed licensee action on previously identified items and
perfonned plant inspection-tours. The inspection involved 96 inspector-hours including five
off-shift hours, by four NRC inspectors.
Results: Of the five areas inspected, one item of noncompliance was identified in one area--
failure to erect instrumentation supports in accordance with the controlling design
document (paragraph 8
).
Unit 2 Inspection on October 5-November 16,1981 (Report No. 50-4 4/81-10)
Areas Inspected: Routine inspection by the resident inspector and two regional based in-
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spectors of work activities relative to'the piping QA program, concrete and cadwell installa-
tion, and plant inspection-tours. The inspection involved 17 inspector-hours by +nree NRC
inspectors
Results: No items of noncompliance were identified.
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DETAILi
1. Persons Contacted
Yankee Atomic Electric Company (YAEC)
F. W. Bean, Lead Electrical QA Engineer
F. X. Bellini, Site Geolocist (PSNH)
D. L. Covill, Lead Civil QA Engineer
J. H. Herrin, Site Manager (PSNH)
D. A. Maidrand, Project Engineer (Framingham)
G. F. Mcdonald, Jr., QA Manager (Framingham)
J. F. Nay, Jr., Lead Mechanical QA Engineer
J. W. Singleton, Field QA Manager
R. Tucker, Engineer (Framingham)
United Engineers and Constructors (UE&C)
R. G. Blair, Civil Superintendent
G. Burriello, Welding Engineer (Philadelphia)
M. A. Edgar, Resident Construction Engineer
J. A. Grusetskie, Assistant Liaison Engineer
A. J. Hulshizer, Supervisory Structural Engineer (Philadelphia)
R. A. Kountz, Welding Superintendent
D. C. Lambert, Field Superintendent of QA
D. E. McGarrigan, Project QA Manager (Philadelphia)
R. A. Rebel, Resident Construction Manager
G. Shaw, Structural Steel Superintendent
R. D. Tancibok, QA Supervisor
Johnson Controls, Inc. (JCI)
A. O. Kennedy, QC Manager
R. G. Walter, Project Engineer
Perini Power Constructors (PPC)
S. M. Bednar, Chief Cadweld Inspector
K. B. Grandmont, Cadweld Superintendent
G. E. Myers, Assistant Site QA Manager
R. W. Narva, Supervising QA Engineer
PittsburghTestingLaboratory(PTL)
H. Ruffner, Site Manager
Pullman-Higgins (Pullman)
R. G. Davis, Field QA Manager
R. R. Donald, Field QA Supervisor
D. R. Geske, QC Supervisor
D. B. Hunt, QA Records Supervisor
C. Scannell, Chief Field Engineer
Royal Insurance
J. C. Anzivir.o, Authorized Nuclear Inspector
G. Voishnis, Authorized Nuclear Inspector
J. Ellis, Welding Engineer
R. Powell, Project Manager
C. E. Walker, Liaison Engineer
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2.
Plant Inspection-Tours (Units 1 and 2)
The inspectors observed work activities in-progress, completed work and plant
status in several areas of the plant during general inspections of the plant.
The inspectors examined 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 and equipment _ preservation. The inspectors
interviewed craft personnel, supervision, and quality inspection personnel as
such personnel were available in the work areas.
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Specifically, the inspectors examined the control and accountability of
cadweld tensile testing with regard to the USNRC regulatory position of
Reinforcing steel delivery and installation and
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cadwelding operations were witnessed in Units 1 and 2 containment building
areas, as were welding activities on the Unit 2 eleventh containment liner
ring. .
The temporary installation and support of the Unit 1 main steam and feedwater
piping inside containment was observed. An inspector witnessed fabrication
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activities for the Unit 1 pipe whip restraint installation and spot-checked
.estraint schedules and drawings for adequate control of material, location,
and assembly details. An embedded' plate in the primary shield wall which
was designed for interface support of restraint PW-201-2 was visually checked
for correct size, orientation and location and ultrasonically examined for
proper thickness, with reference to UE&C drawings F104036, Revision 2, and
F104075, Revision 5.
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Also, a regional inspector accompanied licensee and NRR geologist personnel
on a tour of the two nonsafety-related cooling water tunnels on October 19,1981.
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Bed rock features on portions of the completed machine-bored tunnels, currently
being lined with formed concrete, were observed.
No items of noncompliance were identified.
3.
Licensee Action on Previous Inspection Findings
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a.
(Closed) Unresolved item (443/80-12-01): Justification for multiple
cadweld splices in series - NRC inspection report #443/81-07 continued
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this item unresolved pending the following:
1.
Licensee concurrence in UE&C technical evaluation and conclusion that
the effect of multiple splices in series in Unit I containment shell
is insignificant.
2.
NRC technical review of the potential effect that multiple cadwelds, as
located, have upon the containment shell concrete.
The Licensee concurred in the UE&C evaluation of the significance of
multiple cadwelds on containment concrete shell crack control. Also,
the NRC has reviewed the UE&C technical evaluation and recommends that
one of the areas with multiple splices be selected to perform crack-
mapping during the containment structural integrity test (SIT). At-
this inspection the licensee committed to identify one of the areas with
multiple splices as one of the five areas to be mapped according to
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The inspector was informed by the licensee that
this will be entered into YAEC's computer program of long term verification
items to assure that the aforementioned test and evaluation of that area
is performed. Since any future potential safety concerns would be
identified by the SIT and its data analysis, the inspector considers
this item currently closed.
b.
(Closed) Noncompliance (443/80-13-03): Fiald initiated design changes /
controls for rebar cadweld splice stagger. The inspector reviewed UE&C
Engineering Change Authorization (ECA) 01/2127A and noted that it had
been incorporated by interim procedure change into the affected Pe'ini
QC procedure, QAP 10.3, Revision 5.
The corrective actions don'meited
in the licensee response to the NRC Notice of Violation were conlmed.
This item is closed.
c.
(Closed) Noncompliance (443/81-01-02): Lack of skewed fillet weld
acceptance criteria. The inspector reviewed ECA 25/0327A, Pullman Field
Instruction FI 103 (Revision 1) and Pullman Procedure JS-1X-6
(Revision 2) to substantiate procedural controls over the handling of
ASME Section III skewed fillet welds. Various random field inspections
of ASME NF support installation confirmed that welders were installing
welds and that QC inspection was being accomplished in accordance with
the newly established criteria. The inspector verified the conduct of
training in this area. This item is closed.
d.
(Closed) Noncompliance (443/81-03-02): Unspecified pipe support weld
lengths - Also reported as a potential significant deficiency under
10CFR50.55(e). The inspector examined ECA 25/0559A and notec the issuance
of revised pipe support details for approximately 24 hangers, to include
minimum weld length criteria. Discussions with Pullman engineering and
QA personnel confinned that official Requests For Information to the A/E
would be initiated for any welds for which weld lengths were undefined
and could not be determined dimensionally. The licensee investigation
of this design deficiency uncovered no actual cases of installed supports
with inadequate weld lengths.
Ned upon Oe scope of licensee corrective action, evidence that previous
hanger instaliations are adequate, and revisions to the contractor
procedure (Ptilman JS-1X-6) controlling the welding of safety-related
pipe support: , all aspects of this issue, both as a noncompliance and a
potential sitnificant deficiency are considered closed,
e.
(Closed) Unrtsolved item (443/81-05-03): Regenerative Heat Exchanger
bolting and torquing to ASME and design considerations. The inspector
reviewed the following documents which confirmed that the regenerative
heat exchanger and any other potentially affected ASME Section III
items which are supported by noncode anchor bolts, have been consicared
with regard to design torque and NF bolting requirements and installed
accordingly.
-- UE&C Memo S/L CE-1491 (10/8/81)
-- ECA's 01/1875D, 01/24618, 01/2737A, and 08/1166A
Since the A/E has confirmed code applicability to the component / bolt
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interface and specified design torque requirements for all previously
questioned components, to include the regenerative heat exchanger, this
item is considered resolved.
f.
(Closed) Unresolved item (443/81-07-02): NRC concerns o. u the lamellar
tearing potential on the RCPB crossover leg support welding. Both the
resident inspector and a regional based specialist observed the conduct
of the crossover leg support welding and discussed the in-process
controls to prevent the occurrence of lamellar tears with welding,
engineering, and QC personnel. Details of the inspection of this area
are presented in paragraph 12:.
Both the governing procedures and the
conduct of welding to date appear to have adequately addressed the specified
NRC concerns. This item is resolved.
4.
Concrete Construction and Inspection Activities (Units 1 and 2)
a.
Cadweld Splicing of and Installation of Reinforcing Steel in Unit 1
Containment Wall
Inspections were performed of Perini work and QC activities in cadwelding
- 18 reinforcing bars for the Unit I t.ontainment exterior wall. The NRC
inspector evaluated these activities for conformance to criteria identified
in the following:
- Seabrook Station PSAR Section 3.8 and its referenced Standards
and Chapter 17
- P.P.C. Quality Control Procedure 10.2, Reinforcing Steel Placement
Inspection
- P.P.C. Quality Control Procedure 10.3 (Revision 5) with IPC 4,
Cadwelding Inspection
- UE&C Field Civil Construction Procedure FCCP-7, Mechanical
Splicing of Reinforcing Bars
- ERICO Publication RB-10M-974
The fabrication of horizontal #18 reinforcing hoop splices was observed
for adequacy and QC control during off-stand rebar preparation, cadweld
splice equipment fit-up, powder and starter placement and firing. Post-
fire inspection and documentation by QC were observed. Cadweld operators
and QC inspectors appeared qualified and thoroughly knowledgeable of
their respective procedures. The inspector also witnessed installation
of interior hoop splices at elevation 105' and discussed with the PPC
cadweld foreman, field engineers and supervisory QC personnel the occurrence
of a below strength sister-splice tensile test (Sleeve #244-905-368/
splice #3010), and resulting PPC nonconformance report (NCR) 2220 and
Stop-Work Directive (SWD) 7.
The disposition of the NCR and lifting of
the SWD were observed to conform with the ASME III, Division 2 requirements
in section CC-4300.
No items of noncompliance were identified.
b.
Concrete Placement in Unit #1 Containment Exterior Wall and Common
Circulating Water Pump House
Inspections were performed of Perini work and QC activities in preparation
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for and during concrete placement and post-placement curing of the
following pours:
(1) Personnel air lock portion of containment #1 exterior wall, pour
- PAL-1-CS-IT-2
(2) Circulating water / pump house walls, pour #S-CWTH-BF, at elevation
-15' to
-7'.
The NRC inspector evaluated these activities for
confonnance to criteria identified in the following:
-- Seabrook Station PSAR Chapter 17 and Section 3.8 and its
referenced codes and standards
-- Job Specification 13-1- Safety related concrete work, other
than containment
-- Job Specification 13-2, Containment Concrete Work
-- Job Specification 5-1, Civil Testing Facility and Services
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-- PPC Quality Control Procedures:
- QAP 10.4, Concrete Batching, Delivery
- QAP 10.5, Concrete Pre-placement and Post-placement Inspection
- QAP 2.0, Qttalification and Certification of QA Personnel
- QAP 10.0, Qualification and Certification of Concrete
Production Facilities
-- PPC Field Civil Construction Procedure - FCCP 2, Formwork and
Handling, Placing, Curing, Finishing and Repair of Concrete
-- PTL Quality Control Procedure QC-FSTC-1, Field Sampling and
Testing of Concrete, and PQ-2, Qualifications for Inspection
and Testing Personnel.
The inspector observed both work performance and quality control activities
and verified the scope and adequacy of the following licensee / contractor
actions:
-- Verification of rebar_ adequately installed; cadweld splices
inspected and tested.
-- Formwork: clean, with required rebar clearance and securely
braced.
-- Construction Joints:
treatment for both vertical and horizontal
joints was identified by a UE&C field engineer and found
confonning to requirements of ACI 318 Section 11.7.9.
-- Preplacement Preparation and Inspection Report:
check-out
card signed off by craft supervisors; field engineer check-out
and signature; incomplete items on clean-up are closed; iden-
tification of specific items inspected; QC inspector sign-off;
release of pour by area engineer and QC supervisor; approval
by UE&C field engineer and resident engineer for the placement.
-- Delivery and Placement: proper mix specified, batched and
transported to pump locations; tested prior to discharge into
pump for slump and air and in-process tested for record purpose
at end of pump discharge by qualified inspection personnel.
-- Placing Crew and Equipment:
adequate craft personnel and
equipment, as required by special procedure, were coordinated by
field engineers and craft supervision.
-- Placement Practice and Consolidation:
the advance of concrete
and placement of successive lifts was accomplished while co crete
was still plastic and coordinated to prevent segregation and rock
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pockets; limitation of horizontal movement, control of free fall
through top layers of steel, and consolidation with calibrated-
high speed vibrators were all observed to prevent honevcomb
voids.
-- Testing at Placement Location: qualified test personnel using
calibrated test equipment wereiobserved to meet frequency
requirements and ASTM standards for sampling and testing concrete
for temperature, air, slump, . unit weight and casting of cylinders
on concrete discharged from pump lines.
-- Adequate finishing, curing and green cutting were observed
No items of noncompliance were identified.
5.
Review of UE&C Surveillance Reports on PTL Laboratory Activities
The inspector performed a documentary record review of UE&C Surveillance of
PTL test laboratory activities during the-current year. UE&C's Level 2
program for surveillance of each subcontractor's approved level 1 program
covering the containment structure and other safety-related civil / structural
activities, includes coverage of concrete manufacture and placement, soil
compaction, reinforcing steel installation, structural steel erection: and
the testing laboratory. Quality control procedure 10-1, revision 4,
dated January 30,1981 establishes requirements for-UE&C level 2 surveillance.
The inspector observed that sixteen surveillance reports were generated
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in 1981 up to October 16,1981. Each report covers different generic types
of QA activities. These following PTL activities were surveilled by
UE&C in 1981:
1. Qualifications for inspection, examination and testing personnel
2. Control and reporting of nonconformances
3. General housekeeping
4. Tool, gauge and instrument control-
5. Procurement document control and receiving inspection
In addition to the inspector's verification of UE&C surveillance activities,
he spot-checked some PTL Laboratory and field activities to include cali-
bration of test equipment, service water pipe backfill compaction and nuclear
gauge testing of backfill.
No items of. noncompliance were identified.
6.
Review of Requirements and Records-Relating to Interface Between Containment
Liner Plate and Exterior Concrete Wall Construction Tolerances
The requirements for the containment liner plate fabrication and erection
in UE&C specification 15-1 were reviewed by the NRC inspector. The requirements
of ASME code,Section III, Division 2, CC-4500 are involved. He verified
that the specification states the method of measurement and documentation
of data for the as-erected liner, which includes the containment vessel
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cylinder, spherical dome roof, penetrations and attachments and that
established bench marks and a centerline are utilized. The liner plate
contractor (PDM) implemented these programmatic requirements and the post-
weld erection tolerances are contained in-field survey procedure FSP-01.
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The UE&C specification 15-1 requires that PDM's survey infomation shall
be submitted to the Construction Manager for approval prior to placing
containment shell concrete. Utilizing the liner plate as the pemanent
inside fom for the containment exterior conc'ete wall, PPC is required
by UE&C specification 13-2 to make allowancer for his exterior form work
design for the containment shell concrete tc accommodate tolerances con-
forming to' ACI 301, ACI 347 and ASME Code, S ection III, Division 2.
incorporated all specification requirements into their Field Civil Construction
Procedure FCCP-121, Monitoring of the Containment Shell Wall Liner During
Concrete Placements. The inspector's record review found that revision #1
(August 3,1981) to this procedure eliminated checking by PPC of liner
plumbness and diameter. Approval of this revision by UE&C is based on
UE&C's acceptance of the liner for both diameter and plumbness.
In accor-
dance with the liner specification, PPC is required now only to perfom a
check on the penetrations pre-and post- pour and to monitor the liner during
concrete placements according to prescribed details. The final survey data
reviewed by PPC's QA is then fowarded to the UE&C Resident Construction
Engineer and the Authorized Nuclear Inspector prior to the next placement.
Approval by UE&C of PDM's as-erected liner data and approval also by UE&C
of PPC liner monitoring during placement of the exterior wall concrete
appears to assure adequate control and confomance to code requirements.
No items of noncompliance were identified.
7.
Programmatic QA Inspection of Piping
The inspector conducted a Quality Assurance review of Pullman-Higgins to
ascertain that site work is being performed in accordance with regulatory
requirements and procedural comitments. The following areas were inspected:
procurement, storage, receipt inspection, welding process checklists, qua-
lification of personnel, audits, nonconformances, corrective action, and
drawing adherence. The Seabrook Station PSAR, QA Section 17.2, and the
Pullman Power Products QA Manual (5/8/81) were reviewed for procedural control
and specification of QA criteria relevant to the piping program.
During a review of field purchase orders the inspector noted that statements
referencing 10CFR21, concerning reporting of defects and noncompliances,
were omitted from welding material purchase crders. The following UE&C
purchase orders were lacking the regulatory statement required by 10CFR21.31:
-- Arcos - P.O.#9763-011-16514, dated 7/16/81
-- Sandvik - P.O.#9763-011-17727, dated 5/1/80
-- Chemetron - P.O.#9763-011-18643, dated 8/7/80
-- Arcos - P.O.#9763-011-16520, dated 7/15/81
Material is procured by UE&C, but requisitioned by Pullman. All of the above
orders procured welding material to the ASME B & PV Code, Section NB,
which is material unique to the nuclear industry. The inspectors discussed
this apparent discrepancy with licensee and A/E personnel and were told that
a statement of Part 21 applicability would be added to the fomat of all
nuclear field purchase orders (P.O.).
This comitment was later verified for
implementation by an inspector review of a UE&C Speed' Letter to the Purchasing-
Supervisor and examination of a recently issued field P.O.
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The inspector reviewed the audit program of Pullman-Higgins, noting that the
entire program, including all eighteen criteria of IbCFR50, Appendix B,
is routinely scheduled for audit oy theiPullman corporate office during four
-day periods, twice a year. The inspector questioned the scope of this audit
program with regard to Criteria XVIII of 10CFR50, Appendix B, which requires
a " comprehensive" system of planned and periodic audits.
Eight days of
formalized auditing can only marginally provide reasonable assurance that
activities are in compliance with all aspects of the Quality Assurance Program.
However, the Pullman site QA organization is presently institutingia site
audit / surveillance program under the direction of the Field 0A Manager.
In addition, YAEC QA is in the process of expanding their. addit coverage.
With licensee commitment to this broader audit coverage of the piping QA
program, the inspector indicated no further question of this audit issue,
but stated that the program would be routinely evaluated for the timeliness
and effectiveness of the new program direction.
8.
Instrument Line Supports (Unit 1)
The only safety-related instrumentation installation to date was accomplished
with the attachment of the Combustible Gas Control-(CGC) tubing lines to pipe
supports on the Unit 1 containment liner dome prior to the lifting and erection
of the liner dome into position onto the standing portion of the containment
liner. The inspector spot-checked the installation prior to the lift,
reviewed QC inspection and engineering documents, ard discussed the work
with licensee and contractor personnel. The Johnson Controls, Inc. (JCI)
support installation packages for supports (SG-2802-1 thru 2802-18) and
(SG-2806-1 thru 2806-18) were examined for the following control and
inspection documents:
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-- I/F (Installation / Fabrication) Planners
-- Weld Data Reports and Weld Material Requisitions
-- Weld Visual' Inspection Reports
-- Hanger / Support Installation Inspection Reports
The use of applicable inspection attributes, the sign-off of hold points,
and the traceability of weld rod were all verified. Both the installation
and records were evaluated with regard to criteria specified in the following
documents:
-- ASME B & PV Code,Section III, Subsection NF
(W77 Addenda) and Appendix XVII
-- UE&C Specifications 46-1B (Revision 4) and 248-8 (Revision 4)
-- JCI QA Procedures QAS-1101-SS (Revision 1) and QAS-1001-SS
-- JCI QA Manual w/ addenda
-- ITT Grinnell standard component catalog (PH81)
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-- UE&C drawings F805169 (Revision 2) and M805169S
-- UE&C ECAs 08/1197A and 25/0608A
The inspector noted that UE&C sketch SK-5/14/81-AF nrovided details for the
installed supports per the above referenced ECAs. This sketch illustrated
that each support would use a standard ITT Grinnell pipe clamp with two
each SA-325, " diameter bolts. However, while JCI material requisitions
indi.cated that the proper bolts had been ordered thru UE&C, an error in
coor'dination between UE&C and ITT Grinnell resulted in standard, non high-
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strength bolts being supplied with the clamps. These incorrect bolts passed
the UE&C site receiving inspection and were installed, inspected and accepted
by JCI. Subsequent to the inspector's inquiry into the adequacy of the
installed bolts, a nonconfomance report was issued to document this supply,
erection, and' inspection error.
Since both the UE&C and JCI program had failed to preclude the subject
installation of over 30 CGC tubing supports with improper bolts, the inspector
informed the licensee Field QA Manager and Site Manager during an exit
interview on November 13,1981 that this failure represented a noncompliance
with regard to 10CFR50, Appendix B, Criterion V (443/81-12-01). The
inspector later learned that planned corrective actions will include replace-
ment of the subject bolts.
9.
Structural Connections and Design Interfaces (Unit 1)
a.
The inspector examined the combination welded / bolted connections utilized
to support the containment recirculation pump screen steel off a concrete
building structure wall. Material dimensions, weld sizes, and piece
fit-up tolerances were all checked, as was the engineering control over
design changes to the members' method of attachment. While these
particular connections could not be classified as Framed Beam Connections
under the general design criteria of Table III of the AISC Manual,
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documentary evidence existed that their design as special connections
had been originally approved (Cives drawing sheet E1001, Revision 1,
Section 10-10) and modified (UE&C ECAs 01/2705 A and B) to provide
structurally adequate supports.
The inspector also checked the interfacing concrete embed for type,
size, and thickness against the-drawing requirements and discussed the
handling of any potentially adverse field conditions with QA personnel.
No items of noncompliance were identified.
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b.
The inspector reviewed several UE&C Specifications (eg: 12-2, 45-9,
46-1, and 48-2) covering various- disciplines, such. as instrumentation and
HVAC, whose support design must interface with the-structural building
steel throughout the plant. Specific issues such. as the allowance of
transverse welding across the tension flange of structural beams are
addressed differently in the various specifications. Addit'onally, the
inspector identified several cases of approved design or design changes
for attachment to building steel without any apparent structural discipline
review of the impact on beam load allowances or flange stresses. Some
examples follow:
-- HVAC: Supports FN5822 and FN6A105 have a total of five transverse
weld' connections to the same structural beam with UE&C
approval of this design without any apparent structural
discipline review.
-- Piping: The disposition of Pullman nonconformance reports (NCR)
571 and 930 allows additional transverse welding beyond
project requirements (reference: UE&C'memoMM5195A)
without a structural review.
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-- Electrical: UE&C ECA 25/0714A allows the relocation of two
vertical support members off the neutral axis of
the building steel without specific structural
discipline sign-off.
-- Instrumentation: UE&C Specification 46-1 (Revision 4) provides
authority for the contractor to install transverse
welds up to one-half the flange width without
further UE&C approval and apparently without
consideration of the existing flange fiber stresses
relative to the allowable tensile stress.
Also an examination of ECAs 25/0714A and 25/0746A revealed that design
changes were made to safety-related pipe supports with the resulting
attachment welds to the structural members being undersized relative to
the code requirements of the AISC Manual of Steel Construction for
" Minimum Size of Fillet Welds".
While discussion of this general issue of control over the design
interfaces to building steel has heretofore resulted in the A/E position
that loadings and conditions on the structural members will be verified
in their as-built state at some future time, the above mentioned cases
of apparent specification differences, undersized welds, and transverse
weld loadings have caused the licensee to specifically request frcm
the A/E justification and an explanation of how the structural review
process is or will be accomplished. Pending the presentation of the
licensee position on this issue and a review for the adequacy of controls
on this process by the NRC, this item is unresolved (443/81-12-02).
10.
Safety-Related Components (Unit 1)
a.
Boron Injection Tank (BIT)
The inspector examined the present state of installation of the Boron
Injection Tank (1-SI-TK-6) in place on its anchor bolts and pad in the
Primary Auxiliary Building (PAB). Material, configuration, sizes, and
welds were all spot-checked for the tank and its supports including the
concrete anchor bolts.
Preventive maintenance records were examined and
the existence of the required nitrogen inerting atmosphere was verified.
The QA records package for the fabrication of the tank by Southwest
Fabricating and Welding was reviewed and the BIT was compared to its
as-built drawing details.
The above items were evaluated with regard to the design requirements
specified in the following documents:
-- Westinghouse Equipment Specification, 679065 (Revision 3)
with Interim Change No. 1
-- Westinghouse NSD NSSS Component Receiving and Storage Criteria
-- Westinghouse Drawing 1219E77 (Sheets 1 & 2)
-- UE&C Drawings F805062 (Revision 9); F101526 (Revision 7); and
F101697 (Revision 10)
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No items of noncompliance were identified.
b.
CS Charging Pumps (Chemical and Volume Control System)
The inspector examined the in-place, grouted condition of the CS charging
pumps with particular note of the field modification of the base plate
anchorage to the concrete anchor bolts for one of the pumps.
Control
and inspection of the modification process as provided by the disposition
to Pullman NCR 216, the appropriate Pullman Field Process Sheets, and
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Westinghouse Field Deficiency Report.(FDR) NAH-M-10008, as well as
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participation in the redesign details by the pump manufacturer (Pacific
Pumps), were verified.
The rework-was inspected to the requirements of ASME Appendix XVII,
Westinghouse E Spec. 952470 (Revision 2) with Interim Change No. 1,
Westinghouse drawing 300-E49746 (Revision 4), and UE&C Procedure PTG-1
(Revision 1). Anchor bolt material, size and spacing were evaluated with
regard to the design requirements of UE&C drawing F101526 (Revision 7)
and the Westinghouse E Spec.
No items of noncompliance were identified.
11. Safety-Related Piping (Unit 1)
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a.
Welding
The inspector observed joint preparation, in-process welding on completed
welds, on the following pipe spools being installed in the field:
-- 1-RH-180-01, Field Welds F0101 and F0103
-- 1-CC-752-02, Flow Element joint prep repair
-- 1-RH-155-03, Shop Weld (pipe to elbow)
-- 1-RH-158-07, Field Weld F0701
Pullman Field Process Sheets, Weld Rod Store Requisitions, and Welding
Procedure Specifications, or Dravo fabrication sketches, as applicable,
were checked to verify identification, documentation, and inspection of
criteria procedurally required for quality welding. -QC inspection
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verification of hold point items on the weld process sheets was noted.
The inspector also spot-checked offset and reinforcement conditions to
the requirements of ASME Section III and reviewed the record packages
for the RH--180-01 welds, to include verification of the proper NDE on
the original and any repair welds'and use of the proper.penetrameter in
the radiographic examination process.
For field weld F0701~on line
RH-158, the weld filler metal certification records were.also inspected.
No items of noncompliance Were identified.
b.
Pipe Run
The inspector walked the Residual Heat' Removal 6" pipe line in containment
from the class 1, gear assisted manual operated gate valve (1-RH-V-59)
to the 8" class 2 pipe on the outer side of the spec. break, swing check
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valve (1-RH-V-15). Pipe run components, bends, welds and branch connections-
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were all examined for conformance to the details specified in'the following
drawings:
-- UE&C drawings F800155 (Revision 11) and F805000
-- Dravo sketches E2936-164,~165, and'166
The Westinghouse record packages for RH valves V-15 and V-59 were also
spot-checked for documented. valve material and process traceability.
No items of noncompliance were identified,
c.
Pipe Supports
The inspector checked the in-place condition, either final _ accepted or
still in process, of the following pipe supports and compared them with
their Pullman detail drawings:
-- 155-RG-28
-- 833-RG-10
Pullman Hanger. Field Weld Process Sheets were examined for documentation.
of the correct weld joint status, to include hold point inspections.
The inspector checked hanger material and weld dimensions,. identification,
and configuration. Concrete embed plates, interfacing with hanger items,
were spot-checked for proper size, thickness, and location.
On hanger 833-RG-10, the welding for which had been inspected and accepted
by QC personnel, the inspector found that an uncommon, double-arrowed
weld symbol had been misinterpreted resulting in two completed field
welds each lacking 2" of required fillet weld. 1 Pullman NCR 1591
was immediately written and the following corrective action initiated.
(1) A review of hanger drawings for weld symbols similar to the
one that caused the error is in progress.
(2) A review of the particular inspector's work is planned.
(3) The weld symbol in question will be incorporated and demonstrated
in future training sessions.
(4) The craft personnes involved will be provided additional
indoctrination and training.
Based upon the preliminary results of the ongoing reviews, it appears
that this weld length error is an isolated case. The inspector has no
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further questions on the continuing licensee corrective action or other.
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aspects of this issue.
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No items of noncompliance were identified.
d.
Pipe Material
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The inspector randomly selected a number of vendor supplied pipe spools,
some of which are already installed, for a check of component and material
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type and identification. Comparison of the Dravo sketch documentation of
the ASTM processes used for fabricating the material with the governing
requirements of the applicable " Piping Schedule and Material Data Sheets"
of UE&C Specification 248-1 (Revision 4) revealed several cases of
conflicting data. While some of these were easily recognizable as
transcript errors, at least two cases required the issuance of an ECA
(08/1381A) to document the material acceptability of portions of the
supplied pipe spools. Other identified discrepancies are currently being
researched; however, it appears that substitutions of ASTM specified
standard material were generally made for several spool pieces as compared
to the 248-1 data requirements.
The inspector requested that the licensee produce evidence that these
substitutions were approved in advance and that proper controls exist
for material type changes, particularly where, for example, the sub-
stitution of welded for seamless pipe may alter future in-service examination
requirements. The licensee is currently investigating whether the apparent
discrepancies may have been caused by specification revisions or the
issuance of broad authorizations of certain. material type substitutions
prior to spool fabrication.
In either case, documented evidence of the
approval of such substitution, beyond the Dravo Sketch data, must exist
in some fonn to not only complete the quality records, but also assure
that proper material, compatible with all specification requirements,
has been supplied.
Pending clarification of the material discrepancies on a programmatic
basis by the licensee in conjunction with the A/E and supplier, this
item is unresolved (443/81-12-03).
12. Cross-Over Pipe Support Welding (Unit 1)
The inspectors observed welding on the Cross-over supports at several different
times during the inspection period.
Particular attention was given to the
contractor controls implemented to preclude the potential lamellar tearing
problems discussed in previous NRC inspection reports (443/81-07 and 81-08).
Pre-weld buttering, MT inspection, preheat controls, and the engineered
sequencing of the support welds were all verified, as was the presence of
a UE8C home office welding engineer during the commencement period of these
welding activities.
An inspector visually examined several butter welds and specifically inspected
final welding on joints 9207, 9208, 9209, and 9216, to include a repair weld
on 9207 as documented in the disposition to Pullman NCR 1454 and the applicable
Field Process Sheet. QC inspection, the control over sequence criteria and
hold points, and the traceability and certification of E7018 electrode
(Heat No. ZZZ028)were all spot-checked.
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The inspectors discussed continued contractor awareness of the lamellar
tearing potential with QA personnel and evaluated all inspection items with
regard to the governing requirements of AWS Standard D1.1, UE&C Specification
WS-3, Pullman Field Instruction FI-92, and WPS AWS-I-2.
No items of noncompliance were identified.
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13. Fire Protect'on
The inspector reviewed documented audit findings-and discussed QA program
requirements with licensee and contractor personnel regarding the arrival
on site of shipments of material for the plant fire protection system. While
this material is not itself safety-related, the reduced ten-point QA requirements .
of USNRC Branch Technical Position ApCSB 9.5-1 as' discussed in the Seabrook
Station " Evaluation and Comparison" to Appendix A of that document have been
applied as stated in the Seabrook Station FSAR. The inspector verified
continued licensee _and construction manager supervision and direction
over the contractor to assure the supply and erection of a quality system.
No items of noncompliance were identified.
14. Unresolved Items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, items of noncompliance,
or deviations. Unresolved items disclosed during the inspection are discussed
in Paragraphs 9b and lid.
15. Management Meetings
At periodic intervals during the course of this inspection, meetings were
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held with senior plant management to discuss the scope and findings of this
inspection.
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