ML20053D346

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IE Insp Rept 50-354/82-05 on 820405-0502.Noncompliance Noted:Failure to Implement Effective Measures to Indicate Status of Insps Performed on Ductwork & Installation of Ductwork Supports Different from Approved Design Drawings
ML20053D346
Person / Time
Site: Hope Creek 
Issue date: 05/10/1982
From: Bateman W, Lester Tripp
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20053D342 List:
References
50-354-82-05, 50-354-82-5, NUDOCS 8206040325
Download: ML20053D346 (9)


See also: IR 05000354/1982005

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

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Region I

Report No. 50-354/82-05

Docket No. 50 354

License No. CPPR 120

Priority

Category

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Licensee:

Public Service Electric and Gas Company

80 Park Plaza - 17C

Newark, New Jersey

07101

Facility Name:

Hope Creek Generating Station, Unit 1

fnspection at: Hancock's Bridge, New Jersey

Inspection conducterj: April 5 - May 2, 1982

Inspectors:

hjpe

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W. H. Bateman, Senior Resident Inspector

date signed

date signed

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Ll. d g/, Chief, Projects Section 2A

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Approved by:

E. Trid

'date signed

Inspection Summary: Unit 1 Inspection of April _5 - May 2,1982 (Report No. 50-354/82-05):

Areas Inspected: Routine unannounced safety inspection by the resident inspector (85 hours9.837963e-4 days <br />0.0236 hours <br />1.405423e-4 weeks <br />3.23425e-5 months <br />)

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of work in progress including upper bioshield preplacement preparations and cleanup, reactor

pressure vessel (RPV) internals installation, dewatering and concrete preplacement and

placement activities within the service water intake structure (SWIS) cofferdam, storage

of materials in and around the powerblock, structural steel welding, HVAC ductwork installa-

tion, expansion anchor bolt installation, and pipe, hanger, and electrical penetration

installation. The inspector also made tours of the site, reviewed NCR's and associated

trending activities, and evaluated licensee action on previous inspection findings.

Results_: Noncompliances: Two (failure of W-H to implement effective measures to

indicate the status of inspections performed on ductwork support bolting as described

in paragraph 3 and installation of ductwork supports different from those shown on the

approved design drawings as' described in paragraph 4).

Region I Form 12

(Rev. April 77)

8206040325 820513

PDR ADOCK 05000354

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PDR

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DETAILS

1.

Persons Contacted.

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Public Servi _c_e Electric _ and Gas Company (PSE&G)

A. Barnabei, Site QA Engineer

R. Bravo, Principal Construction Engineer

G. Dalton, Senior Construction Engineer

A. E. Giardino, Project QA Engineer

P. Kudless, Project Construction Manager

G. Stake, Senior Construction Engineer

B_ech_te1 Power _ Corporation _ (Bech_tell

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B. Bain Lead Welding Engineer

A. J. Bryan, Assistant Project QC Engineer

E. Cochrane, Contract Administration

C. Colletto, Assistant Lead QCE - Civil

W. Donnan, Assistant Project Field Engineer

M. Drucker, Lead Site QA Er.qineer

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J. Feindt, Resident Civil Engineer

J. Gohde, Superintendent Contracts

R. Hanks, Project QC Engineer

M. Henry, Project Field Engineer

W. Hindle, Superintendent of Services

D. Long, Project Superintendent

R. Packey, Resident Project Engineer

K. Mills, Lead QCE Mechanical

G. Moulton, Project QA Engineer

L. Rosetta, Field Construction Manager

D. Sakers, Assistant Project QC Engineer

J. Serafin, Assistant Project Field Engineer

D. Stover, Project Superintendent, Contract Administration

S. Vezendy, Lead Welding QC Engineer

General Electric Installation and Services Engineering (GEI&SE)

R. Burke, Site Project Manager

M. Hart, Site QC Supervisor

General Electric Nuclear-Energy Business Operations (GENEBU).

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J. Cockroft, Site Engineer

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C. Brinson, Site QA Engineer

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J. Rich Steers (Steersl

J. Gagliano, Field Engineer

M. Russell, Site QC Supervisor

W-H__ Constructors (W-_H)

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R. Garvey, Site Project Manager

M. Wita, Site QC Manager

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2.

S_ite Tour

Routine inspections were made to observe the status of work and construction

activitie3 in progress. The inspector noted the presence of and interviewed

QC and construction personnel .

Inspection personnel were observed performing

required inspections and those interviewed were knowledgeable in their work

activities. Work items were examined for obvious defects or noncompliance

with regulatory requirements or license conditions. Areas inspected included:

Unit 1: Upper bioshield preplacement and cleanup, dewatering and concrete

preplacement and placement activities within the SWIS, rebar installation,

structural steel bolting and welding, material and equipment storage, and

housekeeping and fire protection.

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No items of r.oncompliance were-identified.

HVAC-ReviewofDuctwork_SupportInstallationA[tivities

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The inspector reviewed W-H's procedures, procedure implementation, completed

work, quality records,(and . interviewed construction and QC , personnel regarding

expansion anchor bolt EAB) installation activities. The inspection was part

of a to;.al site inspection discussed in paragraph 9 of this report. As a

result of this inspection the inspector determined that effective measures

were not being implemented to indicate the status of inspections performed

on ductwork support EAB's. In particular EAB torquing operations that were

performed by craft personnel were indicated as complete by placing a small

amount of quick harden paint on the nut and bolt or on the bolt head and its

bearing surface. This paint was placed such that if the bolt or nut was

loosened, the paint would crack. The purpose of this paint, as explained

to the inspector by W-H personnel, was to indicate that the bolts had been

torqued and had not been loosened. The inspector questioned who applied

the paint and was informed the crafts who installed the EAB's applied the

paint.

The inspector explained that inspection status of a quality activity cannot

be controlled by those perfonaing the quality activity,but that it must be

performed by other than those who performed the quality activity,and in this

case; by quality control personnel . The licensee stated that W-H QC inspec-

tion records of EAB installation were the official inspection status, not the

dab of paint.

In reply to this statement the inspector pointed out:

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(1) W-H personnel, who explained the system to the inspector, under-

stood that application of paint indicated the bolts had been

torqued, and

(2) Review of QC inspection records for EAB installation contained for

W-H hanger section H-21 on W-H drawing SM-131 did not support their

statement in that EAB installation data sheets existed for supports

that were not installed using EAB's; no EAB installation data sheets

existed for supports that were installed using EAB's; and EAB data

sheets were not specific as to which baseplate of a particular

support they applied to.

The failure of W-H to maintain an inspection status of ductwork support EAB

torquing either by quality records or by lack of QC involvement in applica-

tion of paint is contrary to Criterion XIV of Appendix B of 10 CFR 50 and

is an item of noncompliance.

(354/82-05-01)

4.

HVAC - Review of Ductwork Support Installation Activities

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As part of the W-H EAB program review, the inspector noted discrepancies

between as-built conditions and design requirements specified on Bechtel

design drawing P-9131, Rev. 8 and W-H drawing SM-131, Rev. 2.

In p :.aticu-

lar, for hanger section H-21 (which consisted of 8 hangers numbered 1-8),

both of the above drawings required that EAB's be used to fasten baseplates

onto the concrete wall to facilitate attachment of the load carrying members

of several hangers including hangers 1 and 4.

Review of as-built conditions

indicated that in lieu of the EAB/basepute design, embedded Unistrut was

used as the attachment point for henger 1 and portions of hanger 4.

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as-built conditions were not reflected on the design drawings,nor had they

been approved by the designer.

W-H personnel, when questioned by the inspector about this problem, stated

that they had the option to use embedded Unistrut if it was available and

referred to a note on Bechtel drawing P-9132 which gave them this option

based on designer approval of the option used. The inspector pointed out to

W-H personnel that Bechtel drawing P-9131 did not offer the option that

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P-9132 did and that it was was not permissable to assume a note on one

drawing could be applied to other drawings.

It was also pointed out that

designer approval of the option used was required.

The failure of W-H to follow their contract specification requirements to

obtain design approval prior to deviating from approved design drawings is

contrary to Criterion V of Appendix B of 10 CFR 50 and is an item of non-

compliance.

(354/82-05-02)

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HVAC - Review of Ductwork Support Installation Activities

As part of the W-H EAB program review, the inspector reviewed qualification

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records of EAB installers and QC personnel'who qualified the EAB installers.

This review disclosed that two EAB installers had not signed their qualifica-

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tion forms as required by Appendix A of contract specification C-129(Q), Rev.

5.

W-H QC personnel addressed this discrepancy by having the two installers

sign their qualification forms.

Review of qualification records of W-H QC personnel involved in EAB installer

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qualification determined that qualification records were not available on

site for one QC inspector. The validity of the qualification of the EAB

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installers qualified by this inspector is unresolved pending review of the

QC inspector's qualification records.

(354/82-05-03)

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6.

Reactor Coolant _ Pressure Boundary Piping Pipe Whip Restraints - Observation

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of Work and Work Activi_t_ies

The inspector observed installation activities of pipe whip restraints (PWR's)

inside the drywell. The particular PWR's observed were supplied by GENEB0

as part of the NSSS package. The inspector noted that in some cases an

excessivegap(upto

") existed between the PWR and the embedded plate ~ surface

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to which it was being welded. Subsequent followup by the inspector to deter-

mine resolution of this fitup problem involved a review of the following

documents:

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Bechtel Dwg. C-0943. Rev. 10

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Bechtel Dwg. C-0975-0, Rev 9

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Bechtel FCR C-3670

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Bechtel FCR C-5791

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Bechtel FCR C-6190

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Bechtel FCR C-6323

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GE FDDR No. KT1-046, Rev. 0

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Upon completion of review of these documents, it appeared that a design

interface problem existed between Bechtel and GENEB0.. In particular, the

GE FDDR required that the fitup constraints stated in AWS D1.1 had to be

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adhered to and that any PWR's not meeting AWS fitup requirements had to be

dispositioned by GE prior to welding.

(AWS limits the fitup gap to 3/16".)

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The interface problem resulted from Bechtel's assumption that the weld joint

in question was a Bechtel design and, therefore, only required Bechtel dis-

position. Based on this assumption,Bechtel initiated three FCR's to address

the fitup problem and proceeded to make the attachment welds between the PWR's

and the embedded plates.

The inspector met with licensee, Bechtel, and GENEB0 personnel to attempt

to determine why Bechtel would make the PWR connecting weld with an open GE

FDDR requiring a disposition prior to welding. Based on these meetings,it

became apparent that the Bechtel disposition was technically acceptable to

GENEB0 but that confusion existed between Bechtel and GENEB0 as to GENEB0's

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jurisdiction at the NSSS bcundaries. The lack of a well defined and under-

stood definition of GENEB0's jurisdiction at the NSSS boundaries is an un-

resolved item pending establishment of and agreement by both parties to a

definition of GENEB0's jurisdiction at the NSSS boundaries.

(354/82-05-04)

7.

Licensee Action on Previous Inspectio_n Findings

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(Closed)

Inspector Follow Item (354/79-06-02): Pipe wall thickness less

than minimum specified. The original concern resulted from a review of NCR's

that indicated a trend of pipe minimum wall thickness problems. At the time

of the original inspection, the trend had been identified and the problem was

under investigation. Review of the results of the investigation indicated that

meetings were held with the pipe spool manufacturer

(Dravo) to determine

the cause of the minimum wall problem and correct it. The meeting was held

in the summer of.1979. A review of pipe minimum wall NCR's issued since the

Dravo meeting indicated that the large majority were with spools shipped to the

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site prior to mid-1979. Based on this improvement, the inspector considers tha'.

the corrective action taken was effective and considers this item closed.

(Closed) Unresolved Item (354/81-10-01): As-built condition of reactor

building cylinder wall. The original inspection discussed out-of-roundness

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conditions of the reactor building cylinder wall at elevation 132'. This

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condition resulted in requiring modification prior to installation of exterior

roof slab beams, slab radial beams, and slab intermediate beams all at eleva-

tion 132'.

The inspector at that time determined from discussions with Bechtel

personnel that the cause of the problem at elevation 132' resulted from use

of guy wires to suppo:t the formwork, the effects of moderate winds during

the time of placement on the guy wires and formwork, and failure to adjust the

guy wires during the placement to compensate for formwork movement.

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The item was left unresolved pending review of actions taken to ensure this

problem did not recur, nor had occurred previously at lower elevations. The

inspector reviewed survey data of three subsequent 30' lifts above elevation

132' and determined that the out-of-roundness problem at 132' was correctly

compensated for and that elevation 162' was within acceptable tolerances.

Additionally, elevations 192' and 222' were within tolerance. Survey data

was not available for elevations below 132' . However, a lack of NCR's re-

lating to installation of structural steel at elevations below 132' indica-

ted there were no problems prior to elevation 132'.

The corrective action taken above 132' included use of snbedded H-beam columns

to aid in support of formwork and development of specific procedures requiring

periodic monitoring of formwork inovement during concrete placement. The in-

spector had no further questions and considers this item closed.

(Closed) Inspector Follow Item (354/80-02-04): PD:1 to establish a QC hold

point to assure all affected material removed prior to rewelding. Based on

subsequent revisions to the material removal procedure, it was determined

not necessary to establish a QC hold point prior to rewelding. The inspector

considers this item closed.

Reactor Ve_ssel Internals - Observation of Work and Work _ Activities

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The inspector observed the continuing efforts to complete the weld of the

shroud to shroud support ledge. At the end of this inspection report period,

it appeared that adjustments to the welding sequence were successful in pro-

viding the desired weld shrinkage. Air carbon arc gouging was used to remove

deposited weld metal from the shroud to support weld prior to making the

successful weldout. Because paragraph 5.6.9 of GENEB0 specification 22A2537

states that copper, among other elements, shall not be used in direct con-

tact with stainless steel and nickel base alloys and because the air carbon

arc gouging electrode was copper coated, the inspector questioned the

acceptability of air carbon arc gouging based on the inevitable deposits

of copper within the stainless steel clad vessel. GENEB0 responded that

the amount of copper involved was not significant enough to warrant concern.

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The inspector observed rain leakage into the vessel through the vessel top

cover during a period of heavy rainfall. The inspector expressed concern

regarding this inleakage because of the many construction activities in

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progress above the top of the vessel and the resultant contaminants that

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could be picked up by the rain water prior to leakage into the vessel.

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Action was taken to identify and clean those areas in the vessel that were

wet. Investigation of the steel vessel top cover revealed that construction

activities outside the vessel had resulted in damaging the sealant between

the top cover and hatches provided in the top cover for access into the

vessel. The damaged sealant was scheduled to be replaced.

Vessel access was controlled as well as were eating, drinking, and smoking

activities.

No items of noncompliance were identified.

9.

Revie_w of Expansion Anchor Bolt Installation Program

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The inspector reviewed work in progress and completed work, interviewed vari-

ous site personnel, and reviewed the following dccuments as part of a total

site review of installation of safety related expansion anchor bolts (EAB's):

Bechtel Specification C-129(Q), Rev. 4, Furnishing and Installation

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of Expansion-Type Anchors

W-H Constructors Expar.sion Anchor Bolt Installation Procedure

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Bechtel QCI C-1.50, Rev. 4 Testing and Inspection of Expansion-

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Type Anchors

Bechtel SWP/P-C-4, Rev. 5, Installation of Expansion-Type Concrete

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Anchors

Bechtel Specification C-136(Q), Rev. 6, Installation of Expansion-

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Type Anchors

Various cut rebar as-built drawings

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Various EAB installation data reports

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A review of the Bechtel program indicated that installation, inspection, and

records requirements were met or cxceeded. For example:

(1) The program requires a torquing inspection of 10% of all EAB's

installed, but Bechtel QC witnesses 100%.

(2) Cut rebar as-built drawings are maintained.

(3) A single individual has been designated as tne Designated Field

Engineer for all site EAB activities.

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(4) -Area superintendents control issuance of core drill bits to control

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inadvertent damage to-rebar and embedded pipe and conduit. Core

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drill bits are issued only after a thorough review of applicable

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civil drawings to determine locations of embedded items.

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(5) Bechtel EAB test results flow from QC to engineering as required

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to ensure problems are identified and controlled in their early

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stages.

(6)- All QC disciplines inspected including civil

electrical and p'pe and

hangers have their own method of grouping EAB's to QCIR's that is

effective and sufficiently limits EAB grouping to a workable size

that facilitates continuous input of test results to engineering.

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The inspector interviewed craft personnel who were installing EAB's and QC

personnel who were performing required inspection activities. The personnel

were knowledgeable as to EAB installation requirements, action to be taken

when encountering rebar, requirements for drypacking unused holes, minimum

edge distance requhements, and method to determine correct length of EAB

to ensure sufficient embedment.

No items of noncompliance were identified.

In addition to Bechtel, W-H Constructors is also installing EAB's. A review-

of their program resulted in two noncompliances and one unresolved item.as

discussed in paragraphs 3, 4, and 5 of this report.

10.

Unresolved Items

Unresolved itens are matters about which nore information is required in

order to ascertain whether they are acceptable items or items of noncom-

pliance. Unresolved items identified during the inspection are discussed

in paragraphs 5 and 6.

11.

Exit Interview

The inspector met with licensee and contractor personnel at periodic in-

tervals during this inspection report period. At these times, the inspector

sumarized the scope and findings of his inspection activities.

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