ML20076G177
| ML20076G177 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/09/1983 |
| From: | Dise D, Manno S NIAGARA MOHAWK POWER CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20076G136 | List: |
| References | |
| NUDOCS 8306140564 | |
| Download: ML20076G177 (7) | |
Text
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M V NIAGARA R UMOHAWK NIAGARA MOHAWK POWER CORPORATION /300 ERIE BOULEVARD WEST, SYRACUSE. N.Y.13202/ TELEPHONE (315) 4741511 Mr. R. W. Starostecki, Director U.S. Nuclear Regulatory Commission Region I Division of Project and Resident Programs 631 Park Avenue King of Prussia, PA 19406 Re:
Nine Mile Point Unit 2 Docket No. 50-410
Dear Mr. Starostecki:
Your Inspection Report No. 50-410/82-14 dated January 10, 1983, identified three apparent violations resulting from an inspection conducted at Nine Mile Point Unit 2 Construction Site.
Niagara Mohawk's response is enclosed.
Very truly yours, S. F. Manno Vice President Nuclear Construction
(((
D. P. Dise Vice President Quality Assurance xc: Mr. R. D. Schulz, Resident Inspector r306140564 830602 PDR ADOCK 05000410 0
PDR a
NIAGARA M0 HAWK POWER CORPORATION NINE MILE POINT UNIT 2 DOCKET N0. 50-410 Response to Notice of Violations Attached to NRC Inspection Report No. 50-410/82-14 The first apparent violation was identified as follows:
A.
10CFR50, Appendix B, Criterion IX states in part, "A program for inspection of activities affecting quality shall be established and excecuted by or for the organization performing the activity to verify conformance with the documented instructions, procedures and drawings for accomplishing the activity.... Examinations, measurements or tests of material or products processed shall be performed for each work operation where necessary to assure quality."
The Nine Mile Point Nuclear Station Unit 2 PSAR adopts AISC-69, Specification for the Design, Fabrication and Erection of Structural Steel.
The Nine Mile Point Nuclear Station Unit 2 PSAR, Appendix 0, adopts the Stone & Webster Quality Assurance Program which includes installation specifications S204X, Revision 3, Erection of Structural and Miscellaneous Steel, Category 1 and E061A, Revision 5, Electrical Installation and in turn invokes AISC-RSRBSJ, 1978, Specification for Structural Joints Using ASTM A325 or A490 Bolts.
AISC-RCRBSJ, 1969 and 1978 require for inspection in paragraph 6b, that the inspector shall observe the installation of bolts to determine that the selected procedure is properly used and shall determine that all bolts are tightened.
Contrary to the above, an inspection program has not been executed which meets the requirements AISC-RCRBSJ, paragraph 6b in the Quality Assurance Program that is being executed, which inspects the installation of high strength bolting on a random sampling basis, does not provide assurance that the procedure is properly used nor that all bolts are tightened as evidenced by four of 16 beam connections examined that failed to meet installation requirements for tension.
This is a Severity Level IV Violation (Supplement II).
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' The following is submitted in response to this item of nonconformance:
Niagara Mohawk believes the inspection program for bolted connections is adequate and in compliance with applicable codes.
The Nine Mile Point Nuclear Station Unit 2 PSAR, Appendix D, states the inspections are to be performed in accordance with the Stone & Webster Engineering Corporation Quality Assurance Program. The Stone & Webster Engineering Cor'poration Quality Assurance Program commits to comply with Regulatory Guide 1.94, Revision 1, dated April 1976 which endorses ANSI N45. 2. 5-1974.
The Nine Mile Project Engineering specification stipulates that inspections are in compliance with AISC-RCRBSJ Section 6.
AISC-RCRBSJ, paragraph 6b states in part:
"The Inspector shall observe the installation of bolts to determine that the selected procedure is properly used and shall determine that all bolts are tightened."
Similarly, ANSI N45.2.5-1974 requires (paragraphs 5.3 and 5.4) visual inspections of bolting operations to " verify compliance with installation procedures and work instructions" and torque wrench inspection of completed connections to the schedule of bolt tension inspection specified in the latest edition of the Specification for Structural Joint Using ASTM A-325 or A-490 bolts. Additionally, ANSI N45.2.5-1974 requires all connection points to be visually inspected for the following items:
1.
Bolts are the correct length as indicated by at least two threads extending beyond the nut.
2.
Correct type bolt is used as indicated by the manufacturer's marking on the head.
3.
Torque has been applied as indicated by the burnishing or peening of the corners of the nut.
4.
Turning elements are on the correct face; washers are used when required.
These required inspections of a bolted connection would assure that all l
bolts in a connection have been tightened.
The Stone & Webster Engineering Corporation Field Quality Control l
Inspection instructions (Inspection Plan N25204XFA001) comply with the above requirements (Project Engineering Specifications, AISC-RCRBSJ, ANSI N45.2.5-1974) as follows:
1.
Inspection Plan Item 11, Section 8 - Requires witnessing of the installation of high strength bolts for conformance to the installation section of the RCRBSJ specification. Witnessing is l
performed as a weekly surveillance. Stone & Webster Engineering Corporation Field Quality Control performs the surveillance to assure that the procedure for the installation of bolts is properly used.
2.
Inspection Plan Item 16
" Perform a visual inspection to ensure that a minimum of one washer has been installed under the part turned in tightening." As a part of this inspection, in the past, the inspector looked for peening or burnishing (The Inspection Plan has now been clarified to specifically address burnishing).
3.
Inspection Plan Item 17 - Perform an inspection to ensure that at least one full thread projects past the face of the nut.
This exception to ANSI N45.2.5-1974 is identified in the Stone &
Webster Engineering Corporation Quality Assurance Program.
This exception has been approved by the Nuclear Regulatory Commission.
4.
Inspection Plan Item 20 - Perform a visual inspection to determine by standard identification markings that bolts and nuts are the specified type.
These inspections, detailed in Items 16,17 and 20 of the Inspection Plan are defined as requiring 100 percent visual inspection of a connection.
These inspections are performed for each bolted connection and not on a random sample basis, and provide assurance that all bolts are tightened.
1 5.
Inspection Plan Item 19 - Requires witnessing of torque testing at the RCRBSJ specified frequency; 10 percent but not less than two bolts per connection.
This is consistent with ANSI N 45. 2.5-1974 which is endorsed in Regulatory Guide 1.94.
The violation cites an incident in which Construction did release untightened connections to the Field Quality Control for inspection.
However, the fact that a representative of the Nuclear Regulatory Commission observed a Stone & Webster Engineering Corporation Field Quality Control inspector find these conditions during his normal inspection using the above attributes is evidence that the inspection program is adequate.
However, based on discussions with the Nuclear Regulatory Commission Resident Inspector, Niagara Mohawk Power Corporation has directed Stone &
Webster Engineering Corporation to perform additional torque tests on 200 bolts installed by each contractor involved in safety-related high strength bolting to provide additional assurance of program adequacy.
This reinspection will be completed by June 30, 1983.
The second apparent violation was identitied as follows:
- l B.
10CFR50, Appendix B, Criterion V states in part, " Activities affecting quality shall be prescribed by documented instruction, procedures.... and shall be accomplished in accordance with these instructions, procedures..."
ITT Grinnell Industrial Piping, Inc.
Quality Assurance Manual, Section 5.
Welding Quality Assurance states in QCF-5.4, Revision 4, that welding materials shall be recorded by heat / lot on the process planner by the Quality Control In-Process Examiner.
ITT Grinnell Field Quality Control Procedure FQC-5.1-1-6 states in part that the rod room attendant shall complete the weld material requisition form by recording the heat and lot numbers of the weld rod and sign the form.
Contrary to the above:
1.
The Quality Control In-Process Examiner did not record, on the process planner, two heat / lot numbers of welding materials used on feedwater field weld No. 011, identified by rod requisition numbers 22814 and 13118.
2.
On four weld rod requisition field forms, the rod room attendant failed to record the heat / lot numbers and sign the form.
The rod requisition numbers were 22809, 22810, 22811 and 22814.
This is a Severity Level V Violation (Supplement II).
The following is submitted in response to this item of nonconformance:
The root cause of item 1 of this violation was that the In-Process Inspector did not enter the additional heat / lot numbers on the weld data report.
As corrective action to this item, all heat / lot numbers on the original weld rod requisitions applicable to ISO 47-13FW-Oll including weld rod requisition numbers 22814 and 13118 were verified as acceptable by the Receiving Supervisor and have been recorded on the weld data report.
The root cause of item 2 of this violation was that the day the violation occurred, an inadequately trained substitute rod attendant was filling out the rod slips.
The pink copies of weld rod requisitions from Rod Issue Station No. 2 and No. 5 were reviewed for the past 90 days.
It was found that there were three additional pink copies of weld rod requisitions without heat / lot numbers or signatures. Since this was found to be isolated to one substitute rod attendant on the same day, it was determined that other rod issue stations did not require further review.
In addition, on November 22, 1982, the Weld Inspectors performed a surveillance of all active welding and found that all pink rod slips did have the applicable heat / lot numbers entered on the rod slip.
The following are the results of ITT Grinnell's investigation concerning the three pink copies of weld rod requisitions which did not have heat / lot numbers as well as the one pink copy of a weld rod requisition identified by the Resident Inspector.
1.
Rod slip no. 22809 for 2WCS-PRS-007 dated November 20, 1982 -
heat / lot numbers are not noted on the Weld Data as of November 22, 1982. This is due to the fact that the first inspection hold point (first progressive 1/2") has not been accomplished yet.
Heat / lot numbers on original weld rod requisitions were verified to be acceptable.
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2.
Rod slip no. 22810 for 2 MSS-PRS-018 dated November 20, 1982 -
heat / lot numbers were entered on the Weld Data per rod slip dated November 19, 1982, heat / lot numbers on the original (No. 22810) are the same.
3.
Rod slip no. 22811 for 2FWS-PRS-002 dated November 20, 1982 -
heat / lot numbers were entered on the Weld Data per a rod slip dated November 19, 1982. Heat / lot numbers on the original (No. 22811) are the same.
4.
Rod slip numbers 22814 for ISO 47-13FW-011 dated November 20, 1982 -
heat / lot numbers were verified to be correct by checking against the original white copy of the weld rod requisition slip and then entered on the applicable weld data sheets (process planner) as well as the applicable pink weld rod requisition slip.
The following are ITT Grinnell's actions to prevent reoccurrence to the violations:
1.
At the weekly inspectors meeting November 23, 1982, it was reiterated the importance of entering the heat / lot numbers on the Weld Data Report.
2.
Additional training was held for all rod room attendants explaining the correct procedure for issuing weld rod.
3.
The ITT Grinnell Field Quality Control Manager has issued instructions to Construction that when a substitute attendant is in the rod room to notify Quality Control who will assist the attendant at the rod station to ensure that all rod slips are filled out properly.
The third apparent violation was identified as follows:
C.
10CFR50, Appendix B, Criterion V states in part that activities affecting quality shall be accomplished in accordance with instructions and procedures, including appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Installation Specification S203G, Revision 3, Drilled-In Expansion Type Concrete Anchors stated in part, "The required turns of the nut range shall be checked by observing the thread projection behind the outer nut."
Engineering and Design Coordination Report No. F00265, dated January 21, 1982, referencing one clarifying Installation Specification S203G, required that one to five threads be exposed after a drilled-in concrete anchor has been installed.
Contrary to the above, numerous anchors were installed with no threads being exposed beyond the outer nut and accepted by Stone &
Webster Quality Control Inspector.
This is a Severity Level IV Violation (Supplement II).
m
- The following is submitted in response to this item of nonconformance:
As a result of this Nuclear Regulatory Commission finding, Stone &
Webster Engineering Corporation issued Nonconformance and Disposition Report No. 4068 addressing various drilled-in concrete anchors which were not in compliance with Specification No. S203G for final thread projection. Some drilled-in anchors had less than the required final thread projection.
The Nonconformance and Dispositon Report No. 4068 was dispositioned " Accepted As Is" on the following basis:
Specification No. S203G presently requires that anchors are to have an initial thread projection of zero + 1/2 thread prior to torquing.
The bolt is then set with the prescribed turns of the nut until proper torque is achieved.
The intent of this installation procedure would require a final thread projection to achieve the level of assurance that bolts are installed properly. The same level of assurance can be achieved by verification of final embedment depth and acceptable results from a torque test for those anchors which do not have the required projection.
Specification clarification is required since the projection requirements is for ease of inspection and should not be used as a rejection criteria where adequate torque has been achieved. An acceptable bolts installation requires proper embedment, full engagement of the nut and proper torque. The bolts referenced on Nonconformance and Disposition Report No. 4068 were torque tested, had full thread engagement and met embedment requirements.
Engineering and Design Coordination Report No. F00660 has been issued to revise Specification S203G to allow acceptance of a bolt without specified thread projection if it meets the embedment, full engagement of the nut and torque criteria.
The Stone & Webster Engineering Corporation Field Quality Control inspectors had accepted the anchor bolts, stated above, prior to obtaining an approved specification change.
In order to prevent reoccurrence, all Stone & Webster Engineering Corporation Field _
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' Quality Control personnel have been instructed by memorandum to adhere to all specification requirements as stated or obtain properly approved changes to these requirements prior to inspection / acceptance.
In addition, Stone & Webster Engineering Corporation supervisory construction personnel and site contractors were instructed by a memorandum dated February 11, 1983 to adhere to all specification requirements as stated or obtain properly approved changes from Engineering.
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