ML20080N194

Excerpt from Qvp Overview Rept,Vol I,Book 1 of 1.Related Info Encl

ML20080N194
Person / Time
Site:	Columbia
Issue date:	12/07/1983
From:	BECHTEL GROUP, INC.
To:
Shared Package
ML20080N183	List: ML20080N194
References
FOIA-83-538, FOIA-83-641 NUDOCS 8402220147
Download: ML20080N194 (150)

Text

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• ave ONO2ssa REPORT ,

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A set of Generic Problem Areas (5FA's) was deveicped prior to per-forming any reinspections. These GPA's were c mpiled from a review of the follcwing items:

o PRC Inspection Recorts o 50.55(e) Reports o Restart Findirgs c System Walkdowns

. The GPA's consist of a list of 50 areas where problems had been

\. identified on .vork completed prict to July, l4M. Ti'a purpose of tne GPA's was t: ensure, whenever cossible, that reinspections adecuately addressed the concerns over previcus noW. For active contracts, this was achieved by assigning the GPA's to all apoli-ca:le contractors and requiring that tne review process address each GPA. The ability of tne reinscection to acdress the GFA is, of course, dependant upcn the extent the problem remsins visible in the final configuration.

The list of GPA's is covered more fully in vclt me IV, Scok :.

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r, A set of Generic Problem Areat (GPA was ceveloped prior te performing

(, re!.1spection.. Th ite GPAs were expilea from a review of the following items:

o NRC Inspection Reports o 50.55(e) Re:Or:s a Festart findings c Ef t t ir, '.ial,.cawn!

TN GPAs ccnsis al a list Of !O arns mye 7:31 ems 5M Lee icer,ti' ec on work co. pleted price to Jt.ly,1980. Tre purgese of the GPA: nas t3 ensure, whenever Dossic!c, the reinser.ctions adequately addres:ec tne concerns over previous werk. Fce the active contracts, this was achievad by assignic; the GoAs to a 1 arctica51e contractors and requ$rirg that their retiew process address each Gi>A. Each contractor's response is ad-dressed within each centract reverification report, i The Gids and ass:crment ,f nen are inchde; in Attacnr.ent 7.

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Page 9 cf 31 GPAs may be cevered by 1) an estcD11sned centractor reins;ection, 2) a j (, N revisec procedural requirement, 3) a special relatyd pecgra:n, 4) a project h k,,j, corrective action program, or 5) normal on going construction. The spe-

cial rele.*.ed programs are identified in Section Four (i.e. Ancnce Scit 1 Evaluation,As-Builting,etc.).

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1 BECMCL-81-0301 t'

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Subbet: SUPPLY SYSTEM itUCLEAR PD0 JECT tiO. 2

{$ CONTRACT 2 POP 4

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2 Gentlemen:

The Bechtel Revertfication Grcup hat preparea a list of Generic Problem Areas li

' (GPAs) apolic3ble to WNP-2 to be used by participating contractort, as a guide to selecting their sarnie of hard.are to be reinspected. Tr.ese GPAs consist of items raised by the flRC, the Sup;:1y System, and others during the construc-

tion period to date.

Each GPT hastoaanotation is acpli:able particularat the ccrtoo of the first sheet showiN whether the GPA ractor. The inclusicr of a particular con-tractce cc a GPA does not necessarily indicate he was cited by the inspection authority; rather, his work includes similar activities unich rr.ay be subject

.o the came problems.

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You are tc review the attached list nf GPAs. A contractor problem area assign-l c.cnt shest is included in the list of GPAs. This assignr.cn: sneet will assist i

you in ident.ifying problem areas :pecific to ycur contract. You should, how-ever, review the remaini ig problem are:: and inform the Bechtel Reverification Grouo if vou detemir.e other problem areas are applicable to your contract. If l vou wish to r? move GPAs from ycu assig=ent, you should provMe justification I

for coin' so to the Bechtel Reverificaticn 3roup.

Ycu a e 73 ansurt: your pr.:r.d.ves coc i sg stien d:ctli ts, cred for revarifi-

} cati ,n ir.spection: of hard.'eare ar.d c u cciated dr.curant: tion. adq uately cover l

tr.e GPf:. Tha heading cf eten GPA r.ay 52 used to de. ermine which procedure covers e6ch GPA. You may find the detailed information within eacn GPA tene-

<*cial in this process. You shall provide to the Bachtel P.cVerificativn Group, prict. tc comencing inspections, a list of the procedures and checklists which resolvc each GPA. For example:

tjPA Procedure Checklis ti t 1 WP 204 3 3 UP 202 2 WP 204 3 4 WP 204 4 7 WP 203 2

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) l.f activities have already been performed as a r;sult of the Restart Program, q special task forces, or PEDS subsequent to luly 1980, your plan and/or your

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Page 2 ' Decc.iber 11, 1981 (Generic Proble Aiee List flr toe f.: sert'icr.ior, t.o;rc.3) BECMCL-81-0301

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report on completion of rJverificatic.1 should de. on:trate hcw these activities

., satisfy the GPA reinspection requiren. ants.

'i j Year reports on completion of reverification : hall in:1ude a section on any ,

GPAs not resolved by inspection in accordance with your plans and procedures.

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! If you have any questions regarding this matter, plea.se centact Robby Gaines

.j or Mel Leach, Bechtel Reverification Group, ey.tensicn 4707.

,/ __ .-- Yours trulv~

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.I S.hohtos Construction Manager l' SP/RVG!alh l cc: 0178 - UNF2 F;le: (w/a) 901A - W.S. Chin. EPA (w/a)

F.etponse Required: Yes X Nc

,- Due Cate: Decemter 30,~TEIT r -

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Attachment 7 Paga 1 of 82 GENERIC PROBLEM AREAS Table of Contents

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Contractor Problem Area Assignment Sheet. . . . . . . . . . . . . Page 1, 2, 3 l;  ;

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• GPA No. Title Information Source l t l l

1 1 Multiple Problems with Hanger Installaticn, Inspection, (NRC items 77-07/01, l and Documentatica 78-03/1/2/3/4, 80-i 08/24, 80-01/01, 80-08/38, 80-08/11, 80-04/14, 77-04/Sa, 79-t 03/01)(50.55e-#106)

(RF215,216) Notice f of Violation - 6/17/83 l 2 NDE to ASME Secticr. VIII Reouirements vs NDE to ASME (NRC itam 8C-08/22)

{ . Section III Requirements

) 3 WPP35 Committ. ment to Exaraine Possible Stress Risers at (NRCitem 79-16/05)

L , Pipe to Valve Weldments. Examination of tlall Tnickness.

. Lack of Training or Instructicn on Welding (Interprete-tion of Welding Requirements) 4 OA Inspector Missec the Final Weld Visual Exam and the (NRC item 8004/15) k By-Off of the LP Test Results Test was Performed (RF 215) 5 Drocedural Centrol of Ten;;orary Atta:cr. ants by Centecct (NRC items 50-08/35, 215 E0-08/09,30-08/06)

(RF c'.7) 5 Miscellanecus Problens with Condait and Tubing Clacos (NRC ite:n 78-10/03)

(50.55e d152) 7 Qualification and Cocumentation of i'ost Weld ifeat Treat- (NRC items 79-10/01, cent Procedures 79-1C/03)(RF215) s R OC Inspectcr Accepttd an Undersize Filiat Neld on a (NRC ite- 80-08/12)

Skewed Jcir.:

5 Control and Docunentation of Gouges or Grindeut on (NRC item 80-08/19)

. Stractural Steel (P5 215, 217)

- 150.55e 's refers to 10 CFR 50.55(e) Sucoly Systeri File Hunter RF

• r9fers to Restart Fincir.g Contract Number

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Attachtsnt 7

, Fage 2 of 82 i GPA flo. Ti '.l e Infor:.at.on Source i

'10 Grinding on Pipe Walls Without Minimun Wall Thickness (NRC item 20-08/21)

Verification (50.55e-f80 & 90) 11 Anchor Bolt Installation (NRCitems 80-08/20,

. 79-12/01,78-07/01) *

. (50.55e-#58,62,83 ic 155)(RF215,213) p

!. 12 Heat Number Missing frem Pipe Spool Nunber RSR-2018-1 l (NRCitem 80-08/26)

(RF 218)

13 Calculations were not Provided to Support the Deletion (NRCitem 80-08/29) or Re-Design of Support Welds li

. 14 Forging Bursts Identified in A325 Bolts in Reactor (NRCitem 78-10/02)

! Building Superstructure t

f 15 Failure to Properly Color Code Electrical Cables (NRC item 79-04/08)

IS Control and Calibration of Torquing Tools (NRC iten 80-C8/34) 17 Incomplete Quality Dccumentation (NRCitem 77-03/66)

(RF 215)

,' Inariequate Procedures / Checklists, for Final Document Re- (NRCiteas 80-08/26,

,' ' 18 view Prior to Turnover 80-08/37) l 19 Inadequate Cable Crimping Tool Calibration Procedure (NRC item 79-04/C9)

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t and Documentation 20 Incomplete Cable Tra;' Fasteners (NRC item 78-02/P.2) 21 Cable Pall Criculation Criteria Not Cefined (NRC iten 78-10/06) 22 Procedures Did Not Address tne Frecuency oT Calibration (:2C item 78-09/02) of Tor::ve Wrenches 23 Fischbach/ Lord Calibration Procedure Did Not Clearly .(NRCitem 79-04/06)

-.. Specify Evaluation or Documentation Requirements for

[ Equipment Found Out of Calibration 24 Personnel Qualifications (NRC item 81-01/09) 25 Structural Column Ancnor Bolts (NRC items 78-10/01, 4

76-03/04)

$ 26 Miscellaneous Problems with the Sacrificial Shield Wall (NRCitems 79-12/04,

]- : 00-04/01, 80-04/07, 1, 80-04/10, 81-05/04,

,m 80-06/05, 79-16/03, 60-04/16)(50.55e-

[ .v e !69 & 70) (RF 215) ii I

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i Attccicent 7 Page 3 of 82 GPA No. Title Iniceration Source

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27 Miscellanecas Problems with Pipe Whip Restraints (itRCitens 80-04/11, 80-04/08,80-04/09,

!J 80-04/17/18/19)(RF .

215) (10 CFR 50.55e-c! *241 il l

!j 28 L'nexplained Presence of an Installed Pipe ec! Marked (NRCitem 80-08/27)

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'h 29 Loose Locking Nuts on Limitorque Vcive Operators (NRCitem 80-06/04) p 30 Inadequate Ventilation Ductwork Supports in Battery

[d Room (NRC item 79-04/10)

U 31 Miscellaneous Arc Strikes on Safety Related Pipework (f;RC item 78-07/C2) p

{l i 32 Incomplete Receiving Inspection Records (NRCitem 78-11/04)

(RF 215, 218)

' 33 111scellaneous Problems wita Weld Documentatior. md (NRC items 70-11/03, i Inspection 77-05/ App. A Para. A, i.

' 80-05/16,80-19/01, li

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' 77-05/7b) (50.55e-#145)

(RF 213A, 215, 216, 217.

220) 34 Nonconformance Reports and Corrective Action Requasts lj, (NRCitem 80-19/04)

V Were Voided by the Quality Assurance Panager 35 Fisaligned Pipe Flanges Becntet 25 Containm2nt Weld Join: Cffsets UiR: item 77-05/02) 37 Quality Assurance Requirecerts Applied to Seismic Cate- (*;RC item 81-09/01) gery I, Quality Class II items j 3S Subcontractor Desiga Contral (NRC item 81-09/02)

33 Report of Temporary Installations Above Safet;-Related (ifRC item 81-16/02) y items h 40 installation Process Instrument Tubing (NRC item 81-17/04) h-Li 41 Pipe Spool Surface Defects (50.55e-4118) 1.

I.[ 42 Failure to Bush Hammer Concrt:te Sefore Grouting Bechtel

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Attachinent 7 Pa9e 4 of 02 GPA No. Title Information Source i ~h

\, ,, ~43 Possible Problems with Cable Separation (NRC item 81-17/05,

. 80-07/01, 79-16/09,

. 79-04/07,75-10/05)

(50.55e-#23,37,A3,

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52, 53, 54, 60, 64, '

] S2) ii l-44 In. proper fabrication of Structural Members in the Con- (50.55e-#99) trol Rooa Ceiling l 45 Structural Steel Attachment Welds - , (50.55e-414) 45 Incorrect cable Installation (50.55e-#113) 47 incorrect Identification of Electrical Conduit (50.55e-#102) 48 Special Ocors and Hatches (50.55e-#89) 49 Welding Problems with Sway Brace Brackets (50.55e 3115) 50 Failure to Maintain System Cleanlinus (NRC item 79-16/06, 79-1G/03,80-C6/32, 78-10/07,80-08/33)

(50.55e-#170) (RF 216, N 220)

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Attachu nt 7 Fage 5 of 92 ,

CONTRACTOR PROBLEl' ArtEA A35IG?iMEtiT E4EET ,

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Attach. er:t 7 CGNTT. ACTOR PROBlif4 AREA AS5IGNME17 SHEET PaSe 6 of 82 6

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Page 7 of 82 j~ CONTRACTOR PROBLEM AREA A5SIGNMEl4T SHEET w . ,

v >A No. 210 213A 215 215 217 218 219/234 220 49 X X 50 X X X X X X E

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Attachntnt 7 p g.j c Identification fic. GPA agn 8 o 82 1

Pay 1 of 6 GENERIC PROBLEM AREAS k"" Applicable Coctreets: 210_,,_ 213 A X 215 X 216 X 217 x 218 X 219/234 220 x MULTIPLE PROBLEMS WITH HANGER INSTALLATION, !USPECTION, AND DOCUMENTATION

Title:

Source Information:

Specific Prcblem - (As stated by NRC) 77-07/01 also 78-03/1/2/3/4

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In the 77-07 repcrt NRC reported on the inspection of six ccmpleted pipe supports and their associated quality records. All six hangers had been inspected and accepted by Quality Control. The fiRC identified four infractions and one deft-

, ciency.

1. Sirnificant modificatiens had been made to the hanger design without the pr. scribed ap:roval.

2. A number of nonconforming conditions were observed in additicn to the de-sign raodifications (Excessive Weld undercut, clearance beyond specified tolerances, incorrect number of welds, welding cver paint, bolt threads not upset where required).

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3. The nc.ber and nature of the observed nonconfomances indicated that the intended inspections were not performed as required.

4. A number of deficiencies were observed in the quality records for these six hangers (Missing NDE records, incomplete insoection enecklists, miss-ing weld filler metal withdrawal fems, lack of traceability between welds, we'ders, anc inspections).

5. None si tne abcve t:entioned nonconfoming conditions were decenented and precessed in accordance with established procedures.

In the 73-03 report the f4RC escribed the examination of ten completed and accepted quality class I pipe hangers and ti'eir associated quality records. The URC identified four infracticns, all of which were a repeat of the 77-0U01 report.

1. A number of design modifiatiens had been made without prescribed aporoval.

2. Ir ecdition to ti,e design cnanges a number of nonconforming cond'.tions were observed. .

3. The number and nature cf the observed nonconformances demonstrated that the intended insoections were not cerformed as raquired.

4. Ncne cf the cbcVe listed rcrcerforming conditions were documented anc processed in accordance with escatlished protecuras.

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Attachment 7 ggy 0 Page 9 of 82 Identificaticn No. CPA 1 Page 2 of 6 GENERIC PROBLEM AREAS k 215 216 117 218 219/234 _ 220

' " Applicable Contracts: 210 213A I

5 MULTIPLE PROBLEMS WITH HANGER INSTALLATION, INSPECTION, AND DOCUMENTATION i

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Source Infomation: l Soecific Problem - (As stated by NRC) 8C-08/24 l

1. Allegation thr.t material traceability discrepancies identified by field QC Inspectors had not been properly disposittened by WBG QA. The allegation was confirmed in part.

2. Allegaticn of traceability tar.pering. The inspector cculd not verify the

} allegation.

3. Duri.1 g the investigation of tna allegations the inspector r.ated tFe use of wnite typing correction fluid on a bili of materials to change a call out from three quarter inch plata to one inch plate. The inspector also noted, several cases where the MIC number described on the item did not agree witn the MIC r. umber in the package, although the mill certification in both cases appears to indicate that the proper material was installed.

4. The inspector noted a case where the material heat number and the QCThe tag number had been stencilled over a MIC number stamped on the piece.

erroneous marking over an existing mark suggests that the personnel per- 4 foming the marking did not detemine that the existing MIC code did not correlate witn the heat number which they intended to stencil on to the material 5ated on a no;e on the bill of materiais.

5. The as built drawing for hanger FFC-204 shcus a 5 in:h by 5 iach by :'S inch labeled MIC number T-75. The actual ciece of tube steel installedNeitner 's part 26 was a 4 by 4 inch piece with heat number 50303 scribcd on it.

the as-built or the CC Inspection documentation identified this discrepancy.

Note: The Licensee nas indicated that the as-built drawing contained an erron-

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cous extra part 26. The member in question was actually part number I for hanger numoer FFC-167 which is a composite hanger with FPC-2')4

6. The WBG QA/QC :taff have documented several similar concerns in a June 30, 1980 memo to CC m nagement, ana in inspe tions recorts IF-5919 and 5920.

General Problems - (As stated by the Project)

1. Lack of adequate training.

2. Failure to follow pro:adures. .

3. Failure of apolicable procedures to clearly define tracaability recuirements.

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Attechmnt 7 REV O '

Identification o. GPA 1 Page 10 of 82 Pago 3 of_6 r[

OENERIC PROBLEM AREAS

. ~3pplicableContracts:210 213A, 215 216 217 218 219/234_ 220 l t

Title:

MULTIPLE PRv8tEMS WITH HANGER INSTALLATION, INSPECTION, AND DOCUMENTATION .

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i y Source Information:

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Specific problem - (As stated by NRC) 80-01/G1 1

-i l The inspector was checking the procedures used by tne Project to insure that the

elements required for seismic analysis are incorporated in the as-built drawing to the required accuracy. The inspector found that the 215 procedures hac not

! 'ncorporatec all the specifications requirements as modified by PED-215-1823.

Burri. and Roe and the Supply System reoresentatives stated that they have audited approxi::'ately 60 out of ISO nangar as-builts and have numercus problems (discre-cancies in the bill of materials, discrepancies in member sizes, incorrect clear-ances, heccer locations cut of tolerance). As a result, Burns and Rce has not accepted an/ as-built dra. sings. -

Specific Problem - (As stated by NRC) 80-08/38

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1. Welds 5-1.and 6-1 attaching pipe support EDR-392 to the Sac Shield Wall had p,

not been mag particle tested 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more after the welding completion and cooldown period. The field enginee~rs had marked the inspection blocks for "72 Four VT and MT* on welds 5-1 and 5-6 en form SF-6B not recuired.

Ger.eral Prebler's IAS stated bv the Proje-t) -

There is no statement of the general prealeo in ths record file. However, WEG memo GAS-18 indicates that a review was made of the weid records of 372 hanger packages that were werked to the reNirements of WP-84 The purpose of this review was to establish if the NDE requirements were improperly deleted. The results of this review showed 29 cases where the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> MT requirements was j marked not applicable without an acceptable reason being referenced.

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! Saecifie Prebler - (As stated by URC) 80-08/11 9_ 1. For support number EDR-362 the maximum allcwable clearance between support

,( and pipe when sumed on both sides is 1/8". The NRC inspector observed that C

the sumed clearance was slightly in excess of 3/16". The support had been inspected and accepted by WEG Engineering and QC.

2. A similar problem was observed on support RCC-457. This support had oeen inspected and accepted by WBG OC and the-EQA audit also missed this dis-W crepancy.

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. A82a:hment 7 REV 0 ~

Identi fi,:Ption Nc. GPA 1 F29e 11 of 82 Page 4 of 6 2  : CENERIC P CBLEM AREA 5_

Applicable Contracts: 210_,,,,213A 1215 216 217 21S 219/234 220 f .*

Title:

MULTIPLE PROBLEMS WITH HANGER INSTALLATION, INSPECTION, AND C0CUMENTATION '

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'! Source Information:

'1 General Problem - (As stated by Project)

1. Inadequate as-builting program.

2. Inadequate training and/or qualifications of the engineers and QC inspectors.

h; Scecific Problem IAs stated b/ NRC) 80-N/14 l' The NRC Inspectcr checked three hangers that had been accepted by Quality Con-trol and As-Built. -

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f. 'i 1. Fillet Weld was undersized when' compared to the as-bailt drawing.

E'h 2. Strut was oriented 90 degrees from the drawing.

i General Problems - (As stated by the Project)

1. Lack of timely followup on NRC Irspection Report.

2. i.ack-of scecific 'nst ucticar for allcwable engineering substitutions in '

reference to Fille- Weld s'ce for as-acilting. Reference !!3GCAR-50E Correct've Action Dien).

Inspection Procram G4/sa Current inspection requirer, ants for pipe so: port and restraint systems are de-fined in tnree dccua nts: Quality Control Precedure No. 6 (Visual Weld Excmi-n5 tion P"ocedure) Quality Control Procedure No. 7 (General held Inspect'on Pro-cedura); ar.d llurk Precedure No. 55 (Installation of D pe Supports). The first i two documants address only the inspection of welds on the fixtures while tne third (WD-65) addresses alds and contairis the general ststement that the Quality Control Supervisor shall perfom a final inspection and sign cff for acceptance of each assembly. Discussions with the cognizant quality assurance /

L quality contral perscnnel established that there is currently no documented l' requiremen for the inspection af sucn th'ngs as torquing, materials. con-

} figuraticr.3, o cor .letencss cf tne non-weie.d porticns of the support assemalies, i

!. (continued on next pr:e}

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Attachment 7 REY 0 Identificaticn No. GPA 1 Page 12 of 82 Pa e 5 of 6 GENERIC PROBLEM AREAS

~ Applicable Contracts: 210 213A 215 216 217 218 219/234 220

Title:

MULTIPLE PROBLEMS WITH HANGER INSTALLATION, INSPECTION, AND DOCUMENTATION ,

Source Information:

Inspection Program - 77/04/Sa continued It was further reported that an estimated 20 to 25 assemblies have alraady been fully accepted by Bovee & Crail/GEil quality centrol without the benefit of a detailed inspection plan for the non-welded portions of assemblies. Quality f' assurance representatives stated, however, the t this shortcoming had been previously recognized and that a comprehensive general insee: tion precedure will Le developed to verify proper implementaticn of all pertinent requirements of Work Procedure No.' 65. It was also reported tha. tnose hangers which have already been accepted will ce reinspected against :ne new procedure after it has been approved. -

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NRC Actions at WMP-2 and WNP-1/4 Sites 03/01 The NRC inspector and investigator were dispatched to tne sites to determine the g circumstances surrounding the reported improper dec' ament signoffs and exanine the q r'

actions being taken by the licensee. This was accomplished by conducting inter- -

views with cognizant IHP employees and a former e~3loyee, examining completed quality class I work packages, reviewing selected IHP work procedures, inscetting corpleted IHP quality class I werk, and examining documentation cf the licensee's corrective action.

79-03/01 It was noted that IHP quality class I work at the WNP-2 site was just beginning, with only eight class I pipe supports having been installed. On February 2, 1979, the inspector and investigator examined seven of the eight supports and accompanying reccrd packages. It was determined frcm the examir.ation and per-sonnel interviews, that, in addition to the recblems identifying by the licensee's investigation, the IHP ouality inspection program at the WNP-2 site is not in

ccepliance with 10 CFPR. 50 Appendix B requirements. This fact was evidenced by

, one of seven supports (No. RD-405) being improperly installed, the inadequacy of inspection reference material (no means to verify proper shock arrestor identifi-cation), and the use of an unapproved inspection precedure (entitled " Procedure for Handling the Henger Installation Inspection Reports). The failure to imple-rent en effective inspection program is an item of noncompliance. (50-397/79-03/01) a.- Icontinued on ner.t page)

Attachment 7 REV 0 Page 13 of 82 Identificaticn No. GPA 1 Page 6 of 6 g N, GENERIC PROBLEM AREAS

~.  ;

'-Applicable Contracts: 210 213A 215 216 217 218 219/234 220.

1

Title:

MULTIPLE. PROBLEMS WITH HANGER INSTALLATION. INSPECTION. AND DOC'JMENTATIO'l ,

1 Scurce Information:

1 10 CFR 50 55(e) - li106 Potential Problem - Quality Audit No. 216-80-1, Finding 3, dated February 20, 1930, detenninad the measures used by the Contractor and associated subcon-

, tractor to control the design analysis of Quality Class I HVAC cuct hugers are not complete. Specifically, design centrol and checking to verify adequacy of the hangers is not clearly evident. in the design dccumentation submitted.

Failure of hangers for safety related HVA: systems could adve,sely affect the required function of these systems during dasign basis accident conditions. A question exists as to whether the hangers, as designed, would fail in service if the indicated conditlen had gone undetected. Telephone notification of the

. potential de'iciency was inade to the NRC, Region V, on November 14, 1980.

i '

Notice of Violation - June 17, 1980 Contrary to the above requirements, on February 26, 1980, for pipe support No.

LPCS-12, engineering had not indicated the NDE and visual inspection requirements for lug weld number 6 on pipe support LPCS-12 nor had a quality control inspector initialed, stampec, or dated tne applicable inspection box on tne NF-6A form for -

this weld (othar quality reccrds, however, indicated trat scoe NCE nad been per-formed en the weld).

I g_

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Attachment 7 REV 0 2 d I 0 0 Identification No. G?A - Page 1 of 1 GENER*C P10BLEM AREAS T

._,@plicable contracts: 210 213A 215 X 216 217 218 219/234 22 0____

Title:

NDE TO ASME SECTION VIII REQUIREMENTS VP, N0E TO ASME SECTION III RE0VIREMENTS I'

Source Information:

Specific Droblem - (As stated by the fGC) 80-98/22

[

! 1. Incorrect acceptance standards were used to evaluate liquid penetrant h

s examination results. ASME Section VIII criteria were used instead of ASME Secticn III. The accaptance standards fcr liquid penetrant

, examination specified by ASME Section II" contain criteria which are not addressed by ASME Section VIII. The changes in the acceptance standards did not appear to havt been reviewed or evaluated by the designer. The fai*ure to compiy eita the design drawing scecified criteria appears to be an item of non-ccepliance.

D e

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Attachment 7 REV O L' Identification flo. GPA 3 Page 15 cf C2 p , 3 7,73 m .

GENERIC PROBLEM AREA $ -

., y.

\Mplicablecontracts

210 213A X 21$ X 216_X_ 217 x 218 219/234 220 y I

Title:

WPPSS COMMITTMENT TO EXAMINE POSSIBLE ST~ESS RISERS AT PIFE TO VALVE WELE*iENTS.

I '

g- EXAMINATION OF tlALL THICKNESS. LACr. OF TRAINING OR INSTRUCTION OttilELD!t.G

• (?NTFRPQFTATinN OF uptnt E perifforveNie) .

. Source Information:

, Specific Problem - (As stated by the NRC) 79-16/05

1. A reduction in pipe outsice diar.eter was notad imediately adjacent to the weld in two areas (Inlet side of RRC-V-cOS and the lower side of RHR-V-148).

l 2. The transition of the weldment-to-valve for the lower weld on valve RHR-V-14B was sharp, creating a possible stress riser. Visual exa::i-inatior of otner pipe to fitting weldv.ents disclosed other similar conditions.

The centract 215 QC Inspectors have been ir. consistent in interpreting 3.

welding requirements.

I t

er O

e w_---__-_.- - - - . - _ _ . _ - - . .

Attachment 7 0 4 "98 0 Identification fio. GPA gf g, gw GENERIC PROBLEM AREAS

- k.MplicableContracts: 210 213A X 21Q_216 X 217 X 218 219/234: 2 2 0 _ __ x _ _

Title:

QA If4SPECTOR MISSED THE FINAL WELD VISUAL EXAM AtlD THE BY-0FF CF THE i LP TEST RESULTS. TEST WAS PERFORMED. .

Source Infornation:

j Specific Problem - (As stated by flRC) 80-04/15,

1. Final visual inspection and verification of acceptable NDE by Quality Con-trol was not comoleted.

l 2. It appeared that when the weld record was prepared that the Quality Control holdpoints were omitted for ecld number 6.

General Preblems - (As stated by the Proje:t) g Failure to follow procedural requirements.

4 l

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Attachment 7 REV 0 ^

Identification i;o. GPA 5 Page 17 of 82 , p,9, 3 gf 7 f

g ... s GENERIC PROBLEM AREAS l, smsh plicable Contracts: 210 213A X 215 X 216 217 218,___,219/234 220

'l j

Title:

PROCEC'JRAL C0;iT?DL OF TEMPORARY ATTACHMENT 3 BY CONTRACT 215 1 .

j

,i Scurce Inferration:

1 .

' ', Soe-ificProblem-(As*statedbyNPC)80-03/Q5,

1. It was aliadged that it is uncertain whether a staging ladder which was I

.ack welded inside a Main Steam Line was removed.

i- 2. It wa: fLrther alledged th3t the controls for temporary attachment welds 1 aere not applied.

c 3. The allegation was partly confirmed by the follcwing:

-f:0 temporary attachment records ere found in the document packages for the pipe in question or three similar pipe packages in the immediate vicinity

-The document package shows a liquid penetrant record for weld number 6

,, after fit up lug renoval, but there i no record of the welds having teen

made. Similarly, there is an inspection report IR 2633 for gouges in the pipa frcm fit up log removal. There is no welding documentation for temporary attachment weld and no liquid penetrant record.

General orcblems - (As stated by the Project)

1. Inadequate procedural centrol fer temporary installatio .

2. Lack of dccumentaticr. and procedural controi of temporary tack weids.

3 Specific Problem - (As stated by the NRC) 80-08/09

1. The inspector examined the record packages fcr three (3) '.PCS pipe spects.

A The records indicated tnat tercporary weld attachmerits nai been rade, how-

. ever, ti:ey failed to reveal the required weld record forms.

j General Problem - (As stated oy the Project)

1. Inadequate procedural control for handling temporary attachments.

(cortir.ueo on next page) s

./

I

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n.

0 Attachment 7 REV

!centification flo. GPA 5 Page 18 of 82 Page 2 of ?

GENERIC PROB g Eg

. \. ...pplicable Contracts: 210 213A 215 216 217 218 219/234 220 _ _.

Tith. PROCEDURA:. CONTROL OF TEMPOR/AY ATTALXiENTS BY C0fiTRACT 215

Source Infomatioq

1 Specific, Problem - ( As stated oy the !!RC) 80-08/C3

1. It was alleged that WBG procedures do not reflect specification require-ments for renoving *.e perary attachments. The allecation was not sub-stentiated.

2. Work procedure nu.7ber 57 (large bore pipe fabricationi e.idresses the weld-ing of temporary attachments. However, it dces r.ct appear to address the re:noval of temporary attachments. Pcccedure number WP-117 (large bore hangers) does recaire temporary welds to pressure toundaries and pressure bouncary attachment welds that are removed snall 'ee ground smocth and MT or PT perfomed. Ternporary welds will be dccumented on attachment form NF-286." The licensee agreed to consider the need for inclusion of this requirenent in WP-57 siso.

Gene,al Problem - (As stated by the Project)

I

1. Questionable procedural control of temporary attachments.

9 k

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s- /

i

Attachment 7

< Page 19 of 82 REV 0 Identification ?!o. GPA g Page 1 of_2 m,

GENERIC PROBLEM AREAS g g i U- 218 x 219/234 220 x Ap;licable Contracts: 210 213A 215 x 216 X 217 X N

Title:

MISCELLANE0US PROBLEMS WITH CONDUIT AND TUBING CLAMPS ,

j Source Information:

Specific Problem - (As stated by the NRC) 78-10/03

1. Installation of Unistrut Clamps in close proximity to the edge of

!. it's channel creating a potential for the clamp to come out of the char.nel during a seismic event or .while tightening it's retaining bolt.

ME: This iten was reported as 10 CFR 21 and 10 CFR 50.55(e).

2. 10 CF'l 50.55(e) - #152 - Nature of Deficiency - Mechanical friction clamps (conduit and tubing clamps) have t,een installed that were not adequately tightened (torqued) and certain types and sizes of clamps

(~ 's han been shown to have insufficient load capacities.

1 /

'> The following types of clamos were used on SNP-2 and were tested and reviewed for adequacy:

U-bolts Unistrut Pil Series Unistrut P2558 Series Operstrut 702 Series Superstrut ~03 Series -

l'.orn RA 0.Z. Gedney UBC T&B Ona hole clamp j 0.Z. Gedney 14-Series one hole clamo 9 0.Z. Gedney C-clamp Generally, only the larger sizes of these clamos were found to have l' . inadeoutte load capacities. No clamps were found to be absolutely deficient by design. However, two types, Korn RA and 0.A. Gedney UBC Series, were found to have faatures which were undesirable unless used

in pairs.

y. Future installation 'of clamps wi'el be generally limited to the Unistrut P7558 Series and U-boit types. Other types will only hu allowed on a

][ control!ed basis.

(- s j (continued on next page)

,s i

Attachment 7 REV 0 Page 20 of 82 Identificaticn ND. GPA 6 Page 2 of  ?

?

GENERIC PROBLEM AREAS

~~

'Appli:able Contracts: 210 213A 215 216 217 218 219/234 220 1

Title:

M:SCELLANEOUS PROBLEMS WITH C0llCUIT AND TUB!f'G CLAPPS ,

??

Scuece Ir. formation:

4 4

4 Corrective Action - The installing contractor has been directed to replace the inadequate clamps or install additicnal clamps to the conduit or tubing runs. All existing clamps will be toroued to a specific value. The contractor will document all work.

3. Insecure cam nuts ha'. been found on unistrut channel.

1 i

[ 4 ~.

Attachment 7 rey 0 7 Page 21 of L12 Identificat%n ilo. GPA pag, 1 or 1 4

. _ . 3E.'IERIC FR00.D1 AREAS licable Contracts: 210 213A X 215 X 215 X 217 X 218 219/234 220X t_

5 Title. QUAI.IFICATION AND DOCUMENTATICil 0F POST WEl.D HEAT TREATMENT PROCEDURES

-j Source Information:

i Specific Problem UAs stated by the t'RC) 79-10/01 .

1 1. . Precedure PWHT-1 was not qualified. No qualificacir,n tests were conducted to assure that the method of post weld heat treatment emoloyed by this procedure properly heat treatec tre pipe welds. Questionable as to whether the weld received adequate tire at temperature or whether the area of pipe j directly under the heaters was subjected to excessive temoeratures.

i 79-10/03 Safficient records were not rr.aintaired to furnish evidence of proper post weld -

haat treatment.

Several of the heat treatment charts were illegible to the degree tnat the

> 1 ther:rocouple numbers could not be identified (e.g. welds 6, 7, and 8 of iso-

- rr.etric no. RFW-419-4, and welds 1, IA, and 2 of isometric no. RFW-418-5.6). ,

Thennoccuple indications were not recorded on sone oortions of the recorder  ?

charts (e.g. welds 1A and 2 of isometric no. RFU-419-5.7). There were in-consistencies cn charts and certification sheets for thereccot. ole identifi-ca ion numbirs (e.g. weld 8 cef iscr.:etric r.o. RFW 318-1, we'd 1 of iscrretric nc. RFW-41P-7.8, welds 6, 7, L ,f isometric RFW-418 4). No caerators r.ames -

'u: teen reccrded en data re:cres k.g. i. eld 6. 7, 3 cf isometric RF'.!-4*.9-4, welds 1A, 2, 3 of iscmetric TJW 119-5.7). Tnore were inconsistencier. in tre ca:e 0.7 heat treating a shewn on certification sr.ce:: and the recordar charts (e.g. welds 6, 7, S of isometric no. RFu-418-4, welds 1,1A, 2 of isomstric na. RFW-418-5.6, weld 4 nf isorretric RFW-418-4). The failure to

' maintain sufficient quality recccds to furnish evidence of proper post weld

neat treatrent is contrary to the. require.mnts of 10CRF50 Appendix B. This is an apparent iten of noncompliance (59-397/79-10/03).

J e

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Attachment 7 REV O l Identification No. GPA 8 Page 22 of 82 pag, 3, of 3 GENERIP, PROBLEM AREAS 7-

• j.

..jplicableContracts: 210 X 213A X 215 X 216 Y 217_X 218 X 219/234 220 X QC INS?ECTOR ACCEPTED AN UNDERSIZE FILLET WELD ON A SKEWED JOINT l: -

i. :

l Source Infcrmation:

t.

Specific Problem - (As stated by NRC) 80-08/12 .

1 i

,, 1. Undersize Fillet Welds wre observed on support RCC-457. This support was

inspected and accepted by WBG QC. The E0A audit performed did not identify i this discrepancy.

Fi -

2. The connection involved a skewed joint and the QC/EQA Inspectors apparently did not have sufficient training / criteria to evaluate this gecmetry.

General Problem -(As stated by the Project)

! ., 1. The acceptance of an undersize fillet weld by QC/EQA and engineering was probably due to inadequately trained personnel. The lack of specific cri-

},

teria addressing a skewed geometry undcuttedly contricuted to the situation.

"'~

However, the evaluation of a weld size for a skewed joint is within the scope of an engineering evaluation.

t -

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4 $ '

f.y d

{i 1- ' *.

i . ,

4 .

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Attacht.ent 7 RE7 0

~~

Identification fio. GPA , 9 Page E3'cf 52 pag 1 of 1 GENERIC PRC5LE!! AREAS

" Applicable Centracts: 210 X 213A X 215 X __

216 217 218 219/234 220

Title:

CONTROL AND DOCUMENTATI0tl 0F GOUGES OR GRIN 00VT Off STRUCTURAL STEEL ,

Scurce Information:

Specific Problem - (As stated bv NRC) 80-08/19

1. Gouges ce grindout areas wera c5 served to be circlad in red cn the under-side of a F.eavy structural steel member at about t.t e 512' elevation intoard J' of pad P-83 attached to the containment vessel wall.

2. PED-215-05-3595 provides that one sixtcerth inch be the maximum ailewable depth of grindout marks on structaral steel. Marks in excess of one six-teenth inch shall be either repaired or reported for furtner evaluation.

Actions to assure identificaticn in repair of structural steel defects will te examined during a future inspection.

l

(,, , General Problem - (As stated by the Project)

Questionable controls and follewup a: tion on gouges, grindcats, and damage inadvertently caused which were discovered after planned. work was completed.

s 1

]

Attachment 7 RE/ 0 Itantification 10. GpA 10 N ge 24 uf 82 page 1 of 3 GENERIC FROPLE'1 AREAS _

)

(-ipplicableContracts: 210 213A X 215 X 216 X 217 X 218 219/224 220jt, 3

Title:

GRINDIriG ON PIPE WALLS WITh0VT MINIMUM tlALL THICKf1E53 VERIFICATION ,

Scarce Infomation:

Spec.fic Probler - (As stated _ b; NRC} 80-C3/21 _

I

1. ALLEGAi!Oti: Insufficient management action has been taken regarding signi-ficant daficiencies in pipe wall tninr.ing:

a) weld end preparation enurterboring results in marginal pipe L

~

walls (e.g. line RCIC559) b) reduceo cerrosion allcvance on n3in steam piping results in marginal pipe walls c) LPCS and HPCS pipe pitting rescits in marcinal pipe walls d) small bore piping enos were gre,und excessively for socket weld fitups FINDI!4GS: Substantiated in part, however, WBG*& B&R QA programs had already foentified the above prcblems.

2. WBG recognized that grindir.g the exterior of the pipe at the weld joint erea j (counterboring) had the potential to reduce local wall thickness below the i

minimu.n acceptable and issued applicable NCR's for overgrincing. B&R issued CAR 1448 against WBG for not taking action to correct the proble n of over-grinding. BaR engineering issued a PED to change the specification ta recu1re UT thickness measurements on weld areas ground for inservice inspecticn pro-files. B&P. :lanned to have WBG ins: ect previousif de e work. 'WBG su:gested ruert ng tre condition as a 50.5E e; bu: the reportsbi'ity cercarn wu not 4

t anveyed to tne licensee beccuse Bad fait there was insufficient infccm3 tion j to detemire reportacility.

3. PED 215-9-1747 designates a reduction in corrosien for main stem piping (reduction from .120 inch to .090 inch allcwance). There is ne directicn j 20 ledace the require 1 wall thickr.ess belcw design thickness.

i a. UCR-5997 was written to cover surfaca p1ttim o' LPCS and HPCS large bom piping and questions the validity of UT perfwed by the Dipe supplier.

5. The sccket weld joint problem was reported to the NRC under 10CFR SC.55 (e).

PED 21E-M-3335 issued to recuired UT pipe 'aall thickne:s measurements on all ASi1E Class I socket weld joints and sa.mpiing of Class 2 and 3 joints.

E. A sai down by t'.e t;PC inspectcr identifies tse pire scuges. ine gouges should nhve been clanded in accordance wita tr.e requirements of the ASFE coce.

. (conti med on next page) 4

Attachment 7 REV 0 Identification No. CPA 10 Page 25 of 82 Page 2 of 3

g. GENElIC PROBLEM AREAS

(,;jpplicableContracts: 210 213A 215 216 217 218 219/234 220 4

GRINDING ON PIPE WALLS WITHOUT MINIMUM WALL THICKNESS VERIFICATI0tl

.i

Title:

1 _

1 1

Source infoma+ ion

. 7. Although pipe wall thinning was previously addressed in NRC Findings, -

the current inspection demonstrated that further attention is warranted in several respects of wall thinning causes. The licensee identified

. it as a potential gt etc proble?., agrecd to expedite its consideration as a 50.55(e) and was in the proce'ss of fomulating an inspection prograr..

I 8. Concern was raised regarding controls applicable to pressure bour.dary grinding activities. The f4RC inspector observed instances where grinding had been perf',rmed on pressure boundary piping and questioned the need to verify that the piping minimum wall thickness had not been violated.

9. Contract 215 spec requires minimum wall verification following machining /

g*inding as specifieo by the referenced code in the Piping Material Speci-rication sheets. 215 work / repair /QA procedures did not implement this requiremerit.

10. Observation of work activities revealed the following discrepancies: ,

. 1 a) ' grinding to dress up a fillet weld extended into the pipe base metal. The discrepancy had not been identified or documented by QC Inspection or Engineering Quality Audit.

c) !io evidence of required miniuum wall thickness verifica-tion following grinding tc remove pipe attachment chces prior to rewelding. UT performed after disccvery of con-dition by the NRC Inspector revealed that the Minimum wall thickness had been violated by grinding.

c) Fillet weld grinding resulted in grinding into the pressure boundary. Subsequent engineering and QC inspections did not

( identify this discrepancy. No evidence of minimum wall i

thickness verification.

11. flIX NDE rcports identified NDE perfomed on QCI. pipe spcol welds after grinding, however, the required code documented evidence of verification p)t2 of minimum wall thickness verification was unavailable.

s (continued nn next page)

'- 1

o-r Attachment 7 REV 0 identificaticn No. GPA 10 Page 26 of 82 p,g, 3 ,fy i

k, GENERIC PROBLEM AREAS 216 217 218 219/234 220 Appitcable Contracts: 210 213A 215 GRINDING ON PIPE WALLS WITHOUT MINIMUM WALL THICKNESS VERIFICATION ,

Utle.

i ,

'Scurce Infor.Tation:

i 10 CFR 50.55(e) - #80 t

Description of Deficiency. - Carbon steel smil dia?eter pipe has been in-stalled witn less than tne minimum allowable wall thickness specified for the applicable pipe 'senedule. This cendition occurred when the Mechanical In-stallation Cortractor (215) utilized grinders and other power tools to remove oxide and mill scale from the oipe in preparation for weiding. The wall

. thinning is localized at the ends of the pipe as socket weld joint. Correc-tive Action - Contract-215 has issued instruction- to their personne1~to use wira crusncs instead of grinders when preparing ;,ipe for welding and their work procedures are being revised accordirgly. A technical evaluation of the condition identified via Nonconforsnce Repc-t No. 215 05196 1: being perform- ,

ed by the A/E. It is anticipatcd that wall thickness measurements and de-

. sign evaluation will be perfomed for the affected high pressure systems.

Any socket weld connections which do not satisfy the :nini tum design wall thickness requirements will be corrected.

10 CFR 50.55(e) *90 Descriotion of Ceficiency - Large diar.eter piping nas been f0und to have less -

than the ASME Code recuired ninimum wall tnickcess. This undenall condition was causeo by over-grinding while preparing weld profiles for A5ME Section XI In Service Inspection (ISI). Corrective Action - Project Engineering Direc-tive, PED-215-M-3337, has been issued to cur mechanical contractor, which centrols grinding, assures tnat wall thickness measurements are performed on all blended areas and directs the mechanical ~ contractor to revise appropriate

j. procedures accordingly. A separate cor. tract issued to Lambert, McGill and Thomas Co. (C14402) directs them to measure the remaining wall thickenss of -

all previcusly blended ISI areas and to report the results to UNP2 Engineer-

. -ing. This dats.is being evaluated to detemine the scope of the problem. Sub-T sequent to this evaluation,-individual areas will be repaired, as required, to t .

conform to the A3ME Code. Completion of the physical re-wo*k is estimated to t be Sept 1mber,1981. This date is contingent upon the resolution of the current labor negotiations and the lifting of the Stop Work Orders effecting Quality Class I work at HNP-2.

, , . . < c, < . n 'am

Attachment 7 p.Ey 0 Identificaticn No. GF A 11 ,

E3V6 27 Of 82 Mb d 3 GENERIC PROSLCM MEA.5 Appifcable Contracts: 210 X 213A X _ 215 X 216 / 217 X 213 X 219/234 220 X

Title:

ANCHO?. BOLT INSTALLATION i

h' 1

Source Infomation:

l Spacific Problem - (As state _d by the NPC) 80-08/2n ,

I 1. ALLEGATION: Welding washars en hancer support plates when concrete anchor bolts are in pla:c and torqued, has resultad in anchor bolt failure.

i '

FINDING: Substar.ciated. Hanger LPCS-3 had one support base pull out of the concrete durin; either welding of a wnher or torcuir.g of ,

anchor bolts. Apolicable pipe suopert and Anchor installa* ion proce-dures did not caation against wcidir.; stiffners va th tightened anchar bolts. The insocctor fa.-ther cctermined that box beams are welded to base plates after tt.e base platus are bcited to tne v. alls. -

i

, 2. Additional base plates had full shear cone type anchor failures, not caused by welding stiffeners at the time of failure. Failure occurrad while torquing a flat base plata with many small anchors (1/2" HDIS) to a curved concrete surface.

L 3. The abcvc two types of failures raises the concern that other installa-tions wMch may not Mye failed cy nava iost a significant ocrtion cf their total load capacity tecause of cur ent instsilation cractices.

Socc"fic Problem - (As : a:ec bv t',e GC) 79-12/01,

. 1. .To resolve aifferences te ween practices and Bulletin 79-02 recuirements the li:ensee agreed to; a) Add a check that tno sleeve has not f.ulled against the plate for all future anchor bolt reinspections and new instr.llaticos.

Fecheck anchor bolts already reinsoected ancf or reworked to verify the sleeves have not pulled uc against the sucport plate by perfoming a sampling using a recognized statistical sam linc plan.

b) Improve procedure compliance by changing procedures to include desirable options, train personnel and audit the anchor bolt inscection and rework areas for procedure compliance.

] 2. Subsequent EC Fcil:w-up Inspections icentified additienal anchor Scit j s.

ct:blect which the license ecmmitted te ad:'ress:

2

, continued on re).t nage) h i

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Attachw.nt 7 REi 0 _

-Identification No. GPA 11 Page 23 of 82 Pag 9_ 2 of 3

- GENERIC PROBLEM AREAS l i. ,..pplicable Contracts: 210 213A 215 216 217 218 219/234, 220 p

b

Title:

ANCHOR SOLT INSTALLATION i .

j. ,

l Source Information:

a) Prohibition on the reuse of phi' lips Red Head Anchors.

j~. b) Acceptability of concrete anchors in grouted flocr column supports.

c) Initiate a sampling prcgra::1 ccr PED 215-CS-2405 78-07/01 l-Work in progress on three cartially completed pedestals for steam relief line c,uenchers was examinea. It was noted that 11/8-inch Hilti drop-in concrete anchors were being used to anchar the pedestals to the concrete ficor, and discussion with F0W s Quality Assurance personnel disclosed i

that the anchor inspection program had not yet been fully defined.

10 CFR 50.55(e) - #58 The nature of the deficiency is irproper installation (under expansien) j of concrete anchors. Tne corrective action consisted of procedures of '

affected contracts have been reviewed. Engineering change orders, up-dating the installation and inspection requiren.ents, including a retro-fit program, have been issued to all contractors whose procedures did -

not assure proper installation. Installed inserts will be tested /in-spected to assure compliance with requirements or will be replaced.

10 CFR 50.55(e) d62

) Nature of Deficiency - Mechanical conntetions of supports were not accomp-(,* lished in accordance with approved drawings. Anchor bolts were cut shor+

l, and then tack welded to the back side of the foot plates. The anchor boits wre not threaded into the concrete an:nors and, in at least one case, no concrete anchor was installed. Visual inspection of the installation wou'd appear satisfactory, when in actuality the installation would be ccmpletely unsatisfactory. Corrective Action - An Engineering Change Order, updating

the installation and inspection requirements, including a retrofit program, i

has been' issued to the contractor pertaining to the installation of concrete

,f anchors. The Change Orde*, originally designed to assure the precer instal-lation of the concrete anchors, raquires that the anchor bolts be removed, and will assure that tne condition described in the " Nature of Deficiency" abcVe, will be identified and corrected.

(continued on next page)

Attacnm:nt 7 g' Page 29 of E2 NEY l der.tification No. GPA 11 Page_ _ 3 o f_1__

j ,

GENCUC PPs0BLEM AREAS t -

UpplicebleCentracts: 210 _

213A 215 216 217 218 219/234 220

.- Title ANCh0R B.0LT INSTALLATILd ii '

.1 .

!t i<

lI Scurce Infoma_t*gn_:

hI r 10 CFR_50.E3(e) - #83 3

hi Nature of Deficiency - Concrete anchors used for installation of safety re-

~j

! lated hangers were net fully expanced. Approxirtately 50% of a sar:ple of 75 installed hangers were conhide*ed'to have anchors u.1 acceptably expanded to

.j accocur.odate design loading:. Corrective Action - Specificctions have been T' revised to provide specific 1".stallation and inspection requirements. Rein-spe: tion of all hangers has been directed (approxicately 2500 installed as of May 1979). As of August '931, such reinspection was substantially :cm-plate. Unacceptable ancnors are reworked, replaced and/cr the nancer modi-fled for new anchor 1ccations tc meet estaDlished desicn criteria.

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' 10 CFR 50.55(e)

• 155 1 .

Descripcion of Deficiency. - In two cases v.elding stiffeners to bar.ger buse-

plates that were attached to toe concrete by drilled-in concrete anchors which had been toroued resulted in concrete failure around the anchors. In T i.: another case, concrete anchor failure during baseplate installation cccurred but the exact cause was unknown. It is suscected that the craftsnen were tefi ne to mate 7 flat plata confera to a curled surface. Actroach to Fesolu-Men cf Proble - Contractcrs Hort Procecure 330 specifically o*:aicits weld-

".9 cn catepic:es without -irst backing-c U enchor 301:3 for all fut'.re in-stallations. In acdition, Work Prccedure 23'- provides a tcrauing sec.us .c?

for tne ancr.or bolts. Concracc 215 has developed Special Requirer.ents Cna-k-list Mc. I whici nrovides fcr the review cf all existing Seismic Category I hanger installation records. Hangers where the record review indicates weld-ing after torcuing was performed will be field inspected for damage.

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Attachment 7 REV 0 Identification l0. GRA 12 r ge 20 of 32 Page 1 of 1 ,

GENERIC PROBLEM AREA 5 l 's ..ppitcable Contracts: 210 213A X 215 X 216 217 218 219/234 _ 220 Y HE i NUMBER HISSING FACM ?IPE SP0'3L NU'iBER RHR-2018-1 U tle t .

q Source Infor.1ation:

s I

1- Specific Prc51 ems - (As stated by NOC) 80-08/2C

1. Four foot section cf 2" pipe between weld 9 .md 10 of spcol nunber 2HR-2018-1 did not have a heat nunte. or ider.tification marking as t required by 1:BG precedure OC?-17 paragraph 5.1.

General Protiems . (as stated by the_ Peoject) r Inadeauate and/or impreper imclementatica of ea*.eria; traceability control.

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Attschment 7 REV O Page 31 cf 82 Identific.iticn No. GPA 1? p

)s. GENEPIC PROBLEM AREAS Y

-Applicable Contracts: 210 X 213A X 215 X 216 x 217 X 218 X 219/234 220X CALCULATIONS WERE NOT PROVIDED TO SUPPORT THE CELET!ON OR RE-CESIGN OF

Title:

SUPPORT WELDS ,

$succe Infor-tation:

Specific Problem - (As stated by NRC) 80-08/29

1. A quarter inch fillet weld (number 4) called for on the Burns and Roe approved drawing for hanger RRC-3 was not made as called out on the drawing.

2. The As-Built drawing shows a quarter inch fillet wcid made perpendicular to the axis of the structural member and fully across the member.

3. The changed welding de all on the as built was dated after the final as-built was completed and accepted by 1BG engineering anc OC.

, 4. An ECA audit identified that weld number 4 on the approved drewing did l- not exist in the field, but did not identify the existence of the weld transverse to the beam ar.is.

5. In response to the EQA inspectors finding a HEG engineer, without Burns ,

i and Roe apprcval, modified the weld details of the as-built drawing and then provided the resolution " Accept-As-Is" based on the fact that the existirg welding conforned to t.5e as-built drawit . However the as-built drawing did not identify *be C0dific: tion o; tha as-built weld

. detail when compared to tne approved construction drawing.

-c. The specification requires tnat welding perpencicular to the axis of menbers shall be subject to approval of tne Owrer. WBG had not obtained the required approval prior to the above v.elding. In addition wncn tne l as-built drawing was changed to agree with the as-built ccndition, no action appeared to have been taken to determine why the previously acproved as-built did not reflect the actual configuration or why the welding did not cnnfenn to the original approved construction drawing.

L l

/. The as-built drawing for rupport F.SLC-21 deleted a fillet weld that would appear to cause increased stress at the connection. Calculations had not

!- been pre?ared to justify the modification and the changed welding details-3

' wcre rot initialed or dated.

8. As-built drawing for hanger RHR-326 specified square groove welding for

[ welding pipe to web, whereas the actual weld joint was cap welded.

t.

!. 9. Hanger nuirber RhR-326 underwent two design changes scecifying a weld of l , lower grade than originally specified, with no calculations to ',ustify

'-- dcwngrading of the weld.

(continued on next page)

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I Attachnant 7 REV O Identification ';o. GPA 13 Fage 32 of 82- Page 2 jof 2 GENERIC PROBLEli AREAS, 1 - 3,

[i

- L. ,_.pplicable Contracts: 210 213A 215 216 217 218 219/234 220

'h

Title:

__ CALCULATIONS WERE NOT PROVIDED TO SUPPORT ThE DELETION OR RE-DESIGN

-i

'1 0F SUP.00RT WELOS .

S q __o_u_rce Information:

General Problems - (As stated by the Project)

The basic deficiency has been the absence of direction to H2G engineers, and QC perser.nel defining specifically what can 'ce done and what cannot be doae once the design /fabriciation instructions are determined to ba

. not workable. This lack of clear direction has resulted in improper decisions wherein liberties were taken with the existinc directions and hangers were substantially altered without proper consideration being -

made.

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0 l A-tactment 7 RE'l Identificaticn No. GP4 l' F.ise 23 r f S2 Fage 1 of.1

, GE.'4ERIC.._FR.C_EL_EM AREAS E 3 s

$d.spplicableCont* acts: 210_ _X 213A 215 215 217 718 219/234 220

,- r P

! 7g 7,. FORGING EURSTS IDENTIFIED IN A325 EOLTS I.i REACTOR BUILDI:iG SUPERSTRUCTURE

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t: Source Information:

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!i 78-10/02 -

{ j! . Forging bursts viere identified in A325 hieb st.ength bolts used in tr.e gl reactor building sucerstructurt.

L: The A325 bolts identified in the last NRC inspaction have been removed It ,

ana replaced, ard docur.ented on NCR No. 207-3692. As of Nover.ioer 15,

1973, the licensee had completed a 100; visual reinspection of ap; oxi-mately 16,000 belts. Eight

< belts were identivied as 4t'estierable.

These bolts will be re.:cved. Ar.y indication wnicn is on the cearing sur-face and any bolt w1:h the chanfer circle breken is considered rejectacle..

A secondary program to rard:nly pull ar.d inspect an sdditional 160 toits a

is planned.

3 The inspector examineo approxinately 5C0 boltr in various locaticnc on

. the west and r.ortn wills of tne Reactar Guildir-0 c verify the adequac; of 'th? reinspection program. One bolt with a forging burst was identi' icd

, by the intpector. This bolt was marked by the licensee for rer. oval. l he bolt storage areas were checked to 0; cure that the rejected bolt ."ere beinc nraperly segregated ard c r,trailec.

A ew *** W e e we 0 . k 09' e I is acpeccejate to ;orrect tr.s c nfi :2.7. t L

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Attachm:nt 7 REV O Page 34 of 82 Identification Ho. GPA 15 GENERIC FROBLEM AREAS

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! policable Contracts: 210 213A 215 216 217 218 X 219/234 220

\N..

FAILURE TO PROPERLY COLOR CODE ELECTRICAL CABLES i

.ltle:

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-i Source Information:

r 79-04/08 I

The following items were identified during the examination:

Cable Color Coding - It was noted that the PSAR established requirements to i; attach color coded identification tags at the end of each cable as one method ,

of assuring cables of different safety divisions are properly segregated.

F/L procedure QAP-404.1 (entitled " Inspection of Insulated Cable Installa-tion")' requ' red that safety division 2 cab'e tags be color coded orange and tnat divisior. 3 cable tags be celor coded red. Tne procedure further re-quired quality assurar.ce inspectors to. verify cables are properly identified.

, Contrary to these requirements, the inspector observed five division 3 cables l1 wnich are labeled witn orange color ceded tags:

4- -,

,. Catle Control Room Location l 3 HPCS-0381-C-DIV3 Panel P680G

] 3 HPCS-0091-C-DIV3 Panel P680G 3 HPCS-0257-C-DIV3 Panel P681A 3 HPCS-0258-C-DIV3 Panel P681A 3 HPCS-0259-C-DIV3 Panel F681A Quality records indicate that each of the cabies iad been inscected and accepted by inspection personnel on Cecem;er 11 and 12,1978. The failure to properly color code electrical ca* '.es is an item of nor.complianca.

(50-397/79-04/03) l 4

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j-Attach.?ent 7 NEY- O Ider.tification No. GPA lo. '

Paga 35 of 82 Page 1 of 1 g g GENE _RIC_ PROBL_EM AREAS t ,

-j- G dplicable Contracts: 210 X 213A X 215 x 215_[_ P~ 9X 219/234__220 X I

-i j 1,; CONTROL AND CALIBRATION OF TORQUI' e

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,j Source Information:

• j

^

Specific Problem - (As statad by t?RC) 80-03/34

- ; 1. A fcur to one torque multiplier was used instead cf two to one torque

multiplier.

-; 2. Surveillance rsport number M-230 indicated that the centractor did r.ct c have a centrol systen for cifferentiating bet'.reen the issuance of four to :ne and two to one torque multipliers prior to April, le80. Ee:ords were not maintainec cf their usage in the t'ield.

General Problems - (As stated by the Frciect)

.~, 1. The probacle cause for this problem was that the work en the Velan vaiv:S

. in pump house 1A and IB was accomplished by a site work order feca the Supply System ind the docut?ntaticn was thougt.t to have been accomplished by the Supply System Quality organization. J

2. Inadequate peccedural cen.rol of caliorated instruner.ts (ie. various ratics cf torque multipliers).

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REV 0 Attachment 7 Identification fio. GPA 17 Fa:.9 36 of 82 P&ge 1 of 1 GENERIC PROCLEM AREAS V.

l. Applicable Contracts: 210 X 213A 215 216 217 218 219/234 220 f .?

Title; INCOMPLETE QUALITY DOCUMENTATION _'

Scurce Information:

t Review of Quality Records 03'6b

. The PKS quality related records concerning placement preparation, concrete delivery, placenent, finishing and curing were examined. It was noted that although PKS had been the prima civil contractor since November 1976, and that a great many concrete placement; had been completed since that tine, the a were no ccmpleted concrete olacement packages on file as of the date of the NRC inspection. PK5 representatives stated that outstanding fiCP.'s and change recuests prevent the completion of the packagas. However, examination of a sampling of the packages reetaled that piccements performed on Aprii 4 and 22,1977 (r.os. 3W3,1A, 4.1.1) were accomplishec without

, obtaining the approval signature cf the Project Superintendent or the Quality

t. Assurance Manager on the approval form, violating Paragraph 11.2 cf Ccnttruc-tion Procedure C?-1. Conflictir,g ?our dates were noted on the records of placceents 394A and d.4.1. Incorplete Quality Assurance Engineer sign-offs d were noted on numerous placement records including these for placements 3N6, 3W6B, 3H8, and 3X913. WPPSS representatives stated tnat effects wculd be made to cxpedit;odsly tcmplete the ceccrd sacka;es.

MCR'; relatir.c ta c ncrc 2 placecent were cceie<.e: with r.: :t:malie r.o tea.

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Attachment 7 REV 0 Identification No. GPA 18 Page 37 of 82 Page 1 of 2

, [ GENERIC PROBl.EM AREAS

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_

i Applicable Contracts: 210 X 213A X 215 X 216 X 217 X 218 X 219/234 v 220_x I

Title:

INADEQUATE FROCEDURES/ CHECKLISTS FOR FINAL 00CUMENT REVIEW PRIOR TO TURNOVER .

p, l.: -

1 Source Information:

Specific Problem - (As stated by NRC) 80-08/36 The Inspector was investigating allegations that documents (NF6 and NF69 Forms) have been changed without explanation or initials /detes. The alle-96tions were not substantiated in that these conditions had been previcusly i identified by the QA program and were being properly handled. However, during the investigation of the allegations, several additional concerns were identified. These were:

1. No precedures had been developed to control the final review of structural record oackages althcugh such packages had been reviewed and turned over i to the licensee (eg., structural inside containment elevation 565).

( .2. Equip.2ent document packages were being reviewed with inccmplete check-lists (e.g., no checklist ite": to examine weld records associa*.ed with equipment installation). .

a  ;

I~ 3. There was no coc'prehensive checklist to tell the document reviewer which docunents are recuired to be in a specific ecuipment docunent package.

4. In reviewing the structural steel padage for the 524 elevaticn if a welo reca'r record was not present in the pack:ge for a part cular weld i segment :he docta.ent reviewer r.1d no eay to tell whether or not it shoula be present.

5. Incomplete records of training for document review personnel.

f- General Problems - (As stated by the Project) 3- 1. Inacequate checklists established for final review of structaral work packages.

k 2. Ina :eouate procedures and/or lack cf training to the effective procedures.

Scecific Problem - (As stated by NRC) 80-08/37 h

1. Comcarison uf cid documant review procedures witn later revisions in-

, dicated that tne checklists had been significantly abbreviated and that the new checklists lacked an item to verify that dates an the re-

.- cords follow a' logical sequence.

(continued en next page)

Attachment 7 --

"' 0 Page 38 ef 82 Identification No. GPA 19 Page 2 _of 2 GENERIC PROELEM AREAS

'- . pplicable Contracts: 210 213A 215 216 217 218 219/234____ 220

Title:

INADEQUATE PROCEDURES / CHECKLISTS FOR FINAL C0CUMENT REVIEW ?RIOR TO TLRMOVER li .

i.

Vi, 11 r:

Source Information:

}'

2. A review of the training records far nine document reviewers revealed

, two instances where training records did not indicate completion of

, the required training although the individuals were currently perform-ing the document reviews.

L.

3. Ten ccrpleted quality document packages were examined. The review re-vealed the following:

-Package EDR-390 document checklist had not been filled out.

-Package FOR-693, the checklist had been checked in the wrcng -

columns in sevcral iccotior.s.

/- -Package LPCS-P-2, the cocum.ent review v.as signed off on Cecember

, 10, 1979. However, there are recc*ds in the package indicating that tae pump was subsequently unbolted, realigned, and rebolted r.

during the period of December 10-13, 1979. No final record k package review was perfarncd after this date as required by the field QA Panual.

General Prob 1 cms - (Ts stet:-d ty the Prof e:t)

1. Lac ( of qtalifisc parsonnel due to iradequate and inconsictent training.

e

2. Inacequate document review checklists esulting from procedural inade-quacies.

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y Attachment 7 R~V Identificaticn No. GEA I? FACO 33 C#Z Page 1 of 1 g GE'IERIC PR08'.2M AREAS

- Applicable contracts: 210 213A 215__ _ 216 217 218 x 219/234_ 220 =

1- INACEQLYTE CABLE CdIMPI E TOOL CALIBRATIO:1 PROCEDURE A1D DOCUMENTATION

Title:

!} _

i

.Scurce Infnemati3n:

4 79-04/G9 Hydraulic crimping toal- calibration - Calibration procedure (No. T1-2) for tne 15 ten, Mccel TBM-15 rydraulic operated crimping tools recuires tnat hydraulic pressures of 100 psi and 9.800 - 10,000 psi se applied during specific calibration cnecks. There was no documented eviderce that these checks had Leen pcefoned at the specified hydrael!c pressurss. The above findings had been identified previously by a conuacter ccrporate audit conducted January 23-25, 1979. The site QA rescense to .c.e audit did net Scoress this finding. It was ncted that the e wipment calibration tecnn?-

dras bad been using e.10,000 psi pressura gauge with 500 psi increment mrkir.gs, speced about 1/8" apart. Consequently, interpolatian of the

, maxicw pressure reached at cut-off was difficult. A new gauge witn more

- N appropriate markings was installed with a tell-tale indicater to orevide

.n.cre precise indication of cut-of# pressura. From ciscussicn: with ecuia-7 . ment ca!icraticn tecnnicians, it was determined that the newer modals of the equipment are supplied with an acjustable eicctrical cut-off switch which the mant facturer scecifies to ba set at 9,7C0 psi. The technicians stated that a numter of these switches were set frc:' 100 ps! to 200 psi tow when the equi; ment ws: received for .ecalibraticn 3rd had to be ad usted upward to meet the 9,500 psi criteria. Racords ider,tiSing those TBM-15s a#f actac were nct se;r.. TM inspect:r noted th:t, if tne cut-o#f raitcr.

were adju2ted to 9,d'O psi, tre raiief valv: ege n ti .m 3: !~.-; re si>tments (3,dCJ - 10,090 :si) cruid ret be verified. Cn sarer 11, 1979, tne crirc-ing tocl marufacturer pecvidea infort ation estab.ishiag that crim:s rade

, at hydraulic pressuras of 9,9'.'C psi were satisfactory and tnat any crir.cs which acnieve deformaticns of specified dit.ensions arc satisfactory (re-gardless of pressure). Tescing by the licensee verified satisfactory

[ crimps were made at pressures as low as 8,000 psi. The contractcr cotained 7 signed statements from the calibration techniciars establishing that the tools nad never been received from the field with a cum pressure belct.

9,500 psi. The contractor than samaled defarnations on 36 termations (each with a uinimum of four crimps per termination for a minimum total of 144 crimps) and found all to be acceptable. Based on the above infor-nation, the licensee concluded that all installed crimos made with a TBF-15 are satisfactory. The licensee stated that TBM-15 calibration data wculd i

os documented in the futu*e. Tnis item will be examined further durir.. a st,bsecaent *:RC ins)ection. (5C-397/79-40'09) l

f Attachment 7 ggy 0 Page 40 of C2 Identi fication flo. GPA 20 Page 1 of 1 5 GENERIC PROBLEM AREAS 215 E16 217 218 y 219/234 220 Applicable Contracts: 210 213A INCCHFLETE CABLE TRAY FASTENERS Titie- ,

Source Information:

Electrical f, Components and Systems) 78-02/P. 3 Fischbach/ Lord's cable tray installation activities wera observeo. These observations included a visual inspecticn of nine completed, and QA accepted, cable tray nodal sections for such items as material configura-tion, location, readiness for cable pulling, and fastener installation.

Tray Nc. 7286 was found to have fcur r.uts and bolts missing in splice plates, and tray no. 8094 contained one nut which was not perperly tight-ened. Both of these conditions were correc ed pricr to completion of the inspection. The subject of cable tray installation and inspectico will be evaluated further during a subsequent NRC inspection.

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J Attachcent 7 REY 0 Page 41 of 82 Identification No. GPA e3

' Page 1 of 1 4 GENERICPROBLEP;_!REAS

. .: 3 .

215 216 217 X 218 X 219/234 220

~ Applicable Contracts

210 213A

!j

Title:

~

CABLE PULL CALCULATION CRITERIA NOT DEFINED l1 w

j, 4 ,

Source Information:

Review Of Guality Records 10/06

, The inspector examined quality records associated with five control cab'ie installations. termination documentation, crimping tool calibratien, in-

precess cable pulls, and a nonconformance report. No iters of noncompli- ,

I ance or deviations were identified. Powever, the inspector found that 6 additicnal criteria cay be appropriate for determining the need for cable pull calculations. Contractor representatives stated that it was their practice to calculate arid document on F/L Form 224 the cable pull tension for each high voltace cable. Two 4160 volt cables under review, however, .

did nct have such dccumentation. A "worksheet" calculation had been made

and was shown to the inspector. It was apparent to tne inspecter that

! , , ,' from this "worksheet" calculation and from observing the short (50 foot) i ler.gth of these cables that this was a cable placement .4ithin the scope

. of the " simple pull" definition of F/L CP-404, Rev. 4, V.A.14.b. The in-spector observed that clear criteria for determining when cable pull calculations need not be made was apparently not available to those who must perfern this task. Contractor representatives stated that this top c would be reviewed and approcria e ' action taken. This item will be 2xamir.ed in a subsecuent inspection (337/78-10/06).

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Attachment 7 0 REY Pcge 42 of 22 Identifica?icn lo. GPA 22 _ _ p 3 of 7 GENERIC PROBLEti AREA 5

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3  ;

- A;;plicable Contracts: 210 X 213A X 215_X_ 216 x ?17 X 218 X 219/2?4 220 t

{

Titie: PROCEDURE 5 DID f407 ADDRESS THE FRE00EtiCY OF CALIBUTIO!J Or mpnne 90:Neoce .

3 _

So;rce Inforratian:

78-09/02 It was observed that PDM's proceduras cid not address tre fiequency of

cLlibration of the torque wrenches or the Skidacre-Hilhelm bolt tensicn indicating cevice. Also, not specified was not how o' ten tne torque wrenches would receive a calib;ation check to verify the job inscecting torque. License 3 representatives stated that this e,atter would be inve t-igated erd aporer.riate action taken.

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1 Atta:hrent 7 REV O Page 41 of 82 Identification No. GPA 23 Page 1 of I

l3 GENERIC PFOBLEM AREAS a 218 x 219/234

>y - ( ..$plicable Contracts: 210 ^ ..

213A X 215 X 216 X 217 x 2201 ei .

Title:

FISCHDACH/ LORD CALIBRATION PROCEDURE DID NOT CLEARLY SPECIFY EVALUATf0'l OR .

DOCUMENTATICN REQUIREMENTS FOR EQUIPMENT F09ND OUT OF CALIBRATION -

i

!-; Source Information:

i i

Review of Quality Assurance Im91ementing Precedures 04/06 j The inspecter examined two procedures of the electrical installation con-tractor, Fischbach/ Lord, to ascertain tFeir ccr.pliance with PSAR anc

, licensee's QA program requirements. . The procedures examined were Nos.

CP-801 and QAP-801 (both entitled "Calibratien and Certificacion of Tools, Inspection and Test Equipment"). No items of noncomoliance or deviations were identified. It was notea, however, that while an evaluation cf test equioment found out of calibratior, was required, neither procedure specified those aspects tr. ba considered in the evaluation nor did they require documentation of the corre:tiva actions determined pursuant to such evaluations. F/L and B&R personnel stated that the procedures would y be revised to correct the oversight. The revised procedures will be examined during a subsequent inspec:icn. (50-397/79-04/06)

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+_ ______ _ __ ___-_--_______- -_-. _ _ _ _ _ _

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Attachnent 7 ggy 0

• Page 44 of 52 Ideatification No. GPP. 26 Page 1 of 1

. *: GENERIC PROBLEM AREAS -

.; t Applicable Contracts: 210 X 213A X 215 X 216 X 217 X 218 X 219/234 X 220 X

Title:

PERSONNEL QUALIFICATIONS ,

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Source Information

Specific Problem - (As stated by NRC) SI-01/09

1. Tr.e correspondence exanined by the inspector showed detailed che: king j of only 17 of the' 48 resumes semitted by WBG. Of these 17 ouestions

! arcee relative to 4.

2. Uc informatior. was prov'ded relative to addi ticnal action on tt.e re-

raiairg 31 resuces.

. 3. No infomaticr. was provided relative tc th teche.ical evaluction of the

[ -1:rplications on the work pe-for:ned by the 4 incividuals who's restces j ,

were questioned.

Generel Prchlems - (T.s stated by the Projcet) l' Need better controls over jcbshcoper personnel niring and ascignment practices.

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Attachment 7 0 REV

- Page 45 cf 92 -

23 Identification No. GPA page,,,,1_of 1 p .

GE*4ERIC PROBLEM t.995 217 218 219/234 220 hoplicaoleContracts: 210 X 213A y 215 y 216 1 R OW.N MR BRTS ,

Title:

J

,i Scurce Infomation:

J 78-10/01 L

Burns & Rce Drawirg Mos. S727-Rev.13 ard S650-Rev. 27 identify the reot.it e-ments for the bolting of vertical structural columns at the 6C5 foot ele-l, vation of the Reactor Building. The columns provide support for the h Reactor Building bridge crane. It was ob;ervoo by the inspector that three anchor bolts, on one of the six cel sn: insoected, were missir.g and required locking r.uts. The construction work in this arca was considered to be cc:.-

plete and no soecific inspectior. reauirner.ts hcd been sp3cified for this bolting. The failure to install the Icek nuts in acccrdance with the de-sign drawings is considered to be an item of nor. compliance. (397/79-10/0'.)

,' Structural Stesl Bolts 03!:14 The inspectors noted that pussibly u' controlled A325 bolts were observec 2.0 various locations in and arcuno the primary containrent and that a bucket of unmarked bolts was located inside the containment adjacent to ongo'ng 4 structural steel erection. 7he licensee was informed that this indicated a nenkress in the control of stru:tural bciting cractice: that could lead to urstec4fied bcit s be'rc in:ts'.ied in tne str.ct.ura. Tie licenne s:ated tr,9y < ocid f r'.ves-igate tre inatt3r 1r,d ins a;;;;. :criate a:t 01.

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FE7 0 25 ttach. ent pa s 7 tointification No GPA of 3 GENERIC PRGBLE". AREAS 3

210 213A 215 x 216 217 218 219/234 220

<l )pplicableContracts:

't Titi,. MISCELLANEOUS CROBLEMS '.4ITH THE SACRIFICIAL SHIELD WALL jf ' Source Information:

!-l 79-12/04

l. During the inspection of the sacrificial shield, it was noted that there r, are shims between sections 3 and 4 resulting in a through-shield gap of up to 1/2 inches in some places. The autnori:ation and installation

instructions for the shims or an analysis of the possible deletericus

, effects of the gaps were not readily available. This item will be

} ,4: examined on a future inspection. (50-397/79-12/J4) 80-04/01

. Ultrasonic- examination of the shield wall was performed prior to ?pproval

," of the UT engineer (85R) (50-397/80-04/01).

. (

A / S0-04/07 j .

Infor: nation on restraint and shield wall quality records was occassionally

,- omitted. Inspectors, at some later date, filled in the missing information withcut having cirect knowledge of the activity which the record was to document. Records oc not accurately reflect the activities perferred. (50- g 397/S0-04/07, shield wail; 50-397'30-04/03, whip restraints).

E0-04/10 Individuals who were never qualified by the contractor performed nondes-J tructive examinations (NDE) on the sacrificial shield wall and pipe whip restraints. In the case of the restraints, qualified irspectcrs names were appMed'to the NDE mcords so that the records would appear accep*.-

able'(30-397/80-04/09. whip restraints; 50 ~97/80-04/10 shield wall).

~

81-05/04 ,

f M The evaluation, recair and inspection of the weld interface / lack-of-pena- l tration situation is unresolved pending review of the final corrective i E acticn plan and its irplementation. (397/31-05-04) f b i (cent nued on next paje) 4 'h-

, i .

REV O Icentification No- GPA 26 Attachment 7 p 2 g3 age 4r of Sc.

GENERIC PROBLEM AREAS t y- . , ~ ' Applicable Contracts: 210 213A 215 216 217 218 219/234 220 i:

MISCELLANEOUS PROBLEMS WITH iHE SACRIFICIAL SHIELD WALL f:

Title:

Scurce Information:

Sacri #icial Shield Wall-Potential Lamellar Tearing at Attach..ent helds W TiG6

.i

A major part of the SSd are tr.e attachments being made to it. A number of these attachments, such as the radial beams, were rade with weid joints i susceptable to lamellar tea'ir.g. Lamellar tearing is separation of the base metal caused by high locali:ec stresses and strains induced by weld

, metal during soldificat:on and ccoling, combined with lower strength and

duttility of the base r.etal in the sno, t tranverse direction (I - direction).

The SSU base metal is ASTM A36 structural steel. The reduction in area values of A36 steel are generally 0-15*, in the Z - direction as comered with 50-70t in the longitudinal direction. The SSW plates v.are but;ared prior to welding which is standard practica where lamellar tearing is a potential problem. Though som2 c' these SSW weld joints have been ultra-Y f sonically tested there is possibility of delayed lamellar tearing failures i . rom added loads in the 2 - direction. At the exit meeting a commitment was made by the licensee representatives to evaluate weld joints for their susteptibility to lamellar tearing where high welding and operational 1

stresses in the Z - direction are encountered (50-397/30-06/06).

79-16/03 Revi2w of the SSW facricaters quality ::rogram and its implemertaticn, in-ciuding material traceabili:1 and inspecticn duct.nentation (50-397/79-16/03).

80-04/16 Heat straigqtening was accomplished on each of the three seg:nents of shield wall ring beam 3 and segment 2A of ring beam 2 without the benefit of con-trailing crocedures.

This conditicn was previously reported in paragraph 5.b.(1) above.

Vi 'Information on restraint and shield wall quality :ecords was O

y( cmitted. Inspectors, at scma later date filled in the missing infon::ation w:thout having direct knowledge of the activity which the record was to 1 document, The reccrds do not accurately reflect the activities per'ormed.

(ccntinueo on next page)

i REV O Identification No. GPA 26 Attachnent 7 .

Page 46 cf 22 Page 3 _o t 1 GENERIC PROELEM AREAS

i. , Applicable Contracts: 210 213A 215 216 217 218 219/234 220 Titie: MISCELLANEOUS PROB!. EMS WITH THE SACRIFICIAL SHIEL3 WALL l .

!- Source Information:

}

1

$~ The above concition was stated by individuals interviewed and is s;pported i by a large number of inconsistencies and irregularities found in t>:a records themselves. As examples, fo- the pipe whip restraints: ((1)) UT reports for restraints nos. PWS 1-1 and 2-1 reported that the UT was performed on i October 5,1976 after post weld heat treatment (PWHT) where as the manu-Jt facturing orders for the same restraints recorded PWHT as occurring on October 6, 1976; ((2)) The UT report for PWS 30-5 was dated October 5, 1976, wa: labeled "after stress relief" and h3d a ph.tocopied inscector's sig-nat tre whereas the stress relief chart for the load of cor.ponents which

. contained this pipe whip restraint indicated the stress relief date as October 7, 1976; ((3)) Manufacturing Order No. 0750 for restraint No. pWS-53-14 indicates tr.at insoector No. 5 performed MT on the restraint on Sept-l amber 24, 1976, whereas the MT report for that restraint bears the photo-( copied signature of a different inspector; ((4)) Magnetic particle inspec-A tion (MT) report for restrai.,t PWS 35-9 reports that MT was performed on i

welds r and 7 on August 3, 1976 whereas the record bears the pho,cocopied signature of an inspector who was not hired until August 16, 1976; ((S))

} MT reports for PWS 36-23, 52-8, 36-1, 35-58, 34-5B, 32-7 centains data an.: inspection results written by one ins::ectar and bears the photocopied sig%ture of a different inspector (the two ind1viduals reported that they oi.? not collaborate on the inscections irsolved); ((6)) Shield wali altra-m ic test re:ce: frr nisca "o.113/75 is nct dated and res.;l s cf test-ing are not indicated: ((7)) 5 Meld wail Panu'acturiw Crier No. C00017 11dicates that welds 1 a on drawing 75 were perfcrmed using veldirg pro-cecare Nc. OM1-13-06.(the electroslag welding process); tne weld map Gr i these welds ir.dicates the welas were made using procaduce No. 0C01-01-10 1 (the shielded metal arc welding process); ((S)) Two shield wall weld maps Nos..A333ED/029092 were used to make welds 4, 5, and 6; the second trap irdicates electrodes Nos. A333ER/036084 were used to make the same welds.

Numerous weld raps showed evidence of cnanges in inspector, welder, weid-ing procedure, and filler c:aterial idertification numbces without explana-f tien.

- Based on the above it is not assured that the quality records accurately reflect the activities performed en the structures. This is centrary to the requirements of 10 CFR 50, Appendix B, Criterion XVII which requires sufficient cuality records he maintained to furnish evidence of activities affecting quality. These are apoarent items of noncompliance (50-397/B0-4- 04/16, shiele wail; 50-397/80-04/17. 13, 19, pipe whip restraints). Refer to aragraph 5.b.(4).(a) for additional examples of tnis nonco::mliance.

2 (see M so 10 CFR 50.55'e) e59 and d73) i e

REV U 27 Attacha

• 7 Identification 40. GPA ~

Pa9e 4'i cf 82 Page 1 of 3 GE'!ERIC PRO?tEP APEAS .-

j 213A 215 X 216 217 2D 219/224 220

]QplicableContracts: 210 i m .-

I

! MISCELLANEOUS PROBLEMS !!!TH PIPE WHIP RESTRAINTS

Title:

.'l 3 .

h..

I;

];

Source Information:

it j2 80-04/11 31 i; Restraint tolting was not accomplished in accordance with AISC High Strength Bolting Specification, i.e. plate or bar washers have not been used over lq long slotted holes (50-397/80-04/11).

80-04/08

~,-

Information on restraint and shield wall gaality records was occassionally omitted. Inspectors, at sotre later date, filled in the missing infor.r.ation

• without having direct knowledge of the activity which the record was to

.f document. Records da not accurately reflect the activities perfomed. (SG-397/S0-04/07, shield wall; 50-397/80-0a/03, wnip restraints).

80-04/09 Incividuals who were never qualified by the centractor perfor ad n:ndes-tractive exar.inations (NDE) on the sacrificial shield wall and pipe whip restraints. In the care of the .cstraints lualified inscectors names wcce applied to tne NDE records so that the re:Ords uculd acccar accept-aH e (50-397/30-04/03, whip restraints; 50-397/SG-04/10 shield wali).

4 60-04/17/18/19 Heat straigntening was accomplished on each of the three sigments of shield wall ring beam 3 and sigment 2A of ring bean 2 without the bensfit of con-trolling procedcres.

This condition was praviously reported in paragraph S.'b.(i) above.

Inforeetion on restraint and shield wall quality records was occasionally omi tted.~ Inspectors, at some later date filled in the missing infomation

' without having direct knowledge of the activity which the record was to document. The records do not accurately reflect the activities perforr.ed.

- . (continued on next page) m 4

ll

( - _____

i z,u:.g . , .. .. Attachient 7 37 Paje 50 nf E2 l

~ - - -,4. . '.. w T .>> .i '.'q t Id:ntification No. GPA ---

GalERIC PROBLEM APEAS

-~~ -

(g \. 213A 215 216 217 218._

e

• ' b Applicable Contracts: 210

-m .g ,

" L. . Ch. I

Title:

MISCELLANEGU3 PROBLEMS WITri PIPE WHIF RESTPAINTS

.s m.0,i!

q _

..;..:I i.

Source Information_:

. m aw - - - - ~ .

a. The above condition .ias stated by individuals in erviewed and

. ,y;!;w. . 4."...,.......y..

by a large number of inconsistencies and irrsgularities found j , ? . . ! ,. * *g..M m.'4(.,l,y 1 ,

themselves.

As examoles, for the pipe wn1p restraints: ((1) for restraints nos. PWS 1-1 and 2-1 *eported that the UT was

! October 3,1976 after post weld beat treatment (PWMT) mtere e t facturing crdecs for the :ane restraints recorded PWHT as occ October 6, 1976; ((2)) Tre UT report for D'iS 30-5 was dated C relief" and bad a phctocopied inser was labeled "3'ter stres: .

-_ _ _ _ - mama'a .

natt.re wrera3s the stress relief chart Tor the iced of c:cac-

. . . . ., contair.ea this pipe wnia restraint it.dicated the s ress reli.

.; ~ . C October 7, 1476; ((3)' Manufacturir.g Order fio. 0750 fcr rest 53-14 indicates that inspector Do. 5 performed MT on the res

) ember 24, 1976, whereas the MT report for tnat restraint bea copied signature of a different inspecter; ((4)) Magnetic pa

(', - ..

tiu (MT) report 'or restraint PWS 36-9 reports that MT was welds 6 a;d 7 en August 4,1976 .hereas the record beers the I signature cf an inspector who was riot hi ed until August 16, MT reports for FWS 36-23, 52-8, 36-1, 35-53, 34-53, 32-7 cori

'" ~~9 ***d arc inscection res:lts written by one inspector and bears t!'

-  % ~ , .

signature of a (M fferent in:,pector ',tr.e twc individua's reps on tne inspectieni involved); ((s)) Sh-2 - i Jid not co'.iabeate .h. 113/ ~1 is ret datad are res:

st" . test re cr' for cisce

~'

in: are not ind catec; ((~)) Shield all . anuf acturin; 2"de-indicates tna* welcs 1-4 on drawing 75 were perfer-ed eing th-cedure No. ".,001-13-06 (the electroslag welding crecess):

these welds indicates the welds were made using procecure 'l (the shielded metal arc welding process); ((6)) Two shield were used to make welds 4, 5, and 6: the, ilos. A383ED/023092 indicates electrodes Hos. A333EV036084 were used to make

'lumerous weld rtaps showed evide'1ce of changes in inscector, f ing procedi.r , and filler material identification n:;ders w t

tior,.

m 4 _

7--- .

Based on the above it is not assured that tne quality reco!

! .. .f h .J::r.4p...S Q .g.;- .s.

reflect the activities performd on the structures. This is tne requirements of 10 CFR 50, Appendix C, Criterion XVII v

.:- ' . :. . "~' ' I sufficient cuality records be maintained to furnish evidenr affecting qtiality. These are ancarent items of ner.c clisi Mi16, shield wall: SC-397/80-Ca/17, la, 19, pipe wM; rer l

to para;r5ph 5.o. (d).(a) for adcitional examples of t1is n:

• -nd'm'*AL M q % ctitin aad or next oage) 4 s,

$4 *9 IMAGE EVALUATION

'2 gIV4 9 [f// ,

4zzz e+4-, 1es1 mee1 <m1+

, f

+ .

1'0 'N M hlj ll-E

'u l' En l.8 1.25 1.4 1.6

< 150mm

• 6" #

l

1. 4 # / 4%

+f'y47 ,)r>/ ,

<>>A 4 o

u

<+(v.

f

k 5' & 49

$[ 'g j,777g. g?/

e/

// IMAGE EVALUATION f((f @ #

y, TEST TARGET (MT-3)

/g,%pj<<4 e[$

+  %

19 l,0 isan Du ii

= = m Ip' =2

& su

"!! l,l {m ll!Ils l01 i.25 ut i.6

, = =

< 150mm >

• 6"

• 5>%

?;y+/,b/? h+++ W v

I

' REV 0 ~

identificatien ?!o. GPA 27 Attacnrent 7 Page 51 or 82 Page. 3 cf- - -

-GENERIC'PROLLEM

--- ARCAS

), k s Applicable Contracts: 210 213A 215 216 217 218 _ 219/2:4 220 2

i i

Title:

MISCELLANEOUS PR00LE45 UITH PIPE WHl? RESTRAINTS

.j.

I1 ..

Scurce Information

10 CFR 50.GS(e) - #34 ii t

Nature of Deficiency - Pipe whip restraint brackets used in support-l ing the Residual Feat Renoval (RHR), Reactor Feed Water (RFW) and the

. !1ain Steam Piping System, inside containment, were found to have j numerous weld defects in the electreslag welds. These defects consisted

, of slag inclusions and porosity, and have been documented on IR -

1192 (215), NCR 215-03410 and PED 215-CS-0117. The weld deficiencies could only be a result of a departure from the approved electreslag weld precedure.

, Cctrective Action Taken - Forty-five (45) pipe whip restraint brackets were fabricated using the Leckenby electroslag process. These bracket ,

, welds were evaluated using the radiographic and/cr ultrasonic tecnnique.

(- ,

Twenty (20) brackets were completely refabricated, fourteen (14) which obtained lesser defects were repaired and eleven (11) were found to be acceptable. At this tima all brackets hava been installed in the

. plant. ~

i e

e

=g

REV 0 Identifica2icr. f',. GPA 28 Attachme:i2 7 o ,. 7 Page 52 cf Sg Page g GENERIC PRGELEM AREAS g - ..

' Applicable Contracts: 210 213A X 215 X 216 7 217 X 218 219/234 220 X

',../

UNEXPLAINED PRESEiICE OF AN *i; STALLED PIPE S?00L MARKED SCRAP

Title:

t i

i Scurce Information: -

E 80-08/27 Allegation: In pipe spool RHR-667-8.12, a pipe with heat flo. L-24897 painted on it was installed between welds SA and SG. This same pipe 4

also had the work " scrap' painted on it.

Finding: The allegation is true but this fa:t had already been identi-fied by WBG QC and documented. The fact that the pioe had ' scrap" painted on it was not a findirg of the QC intrectcr. The resolutien of this apparent discreper.t conciticn in tractability x.arking and the apparently inconsistent fact that a pipe markec "scrac" was installed

, in the RHR system will be exar.ined during a fu:s;c inspection.

, (50-397/80-08/27) 1 t

e

REV 0

~

Id:ntification No. GPA 29 Att:chnant 7 of g Page 53 cf E2 Pace 3 GENERICPROBLEMAREg 1; 3pplicable Contracts: 210 212A 215 X 216 217 218___ 219/234 220

Title:

LOOSE LOCKING NUTS ON LIli! TORQUE VA'.VE OPERATORS p,- . . -

i>, _

P Scurce Information:

80-06/04 1

IEC 79 Loose lccking nut on limitorc,ue valve operators: The circu-lar has been reviewed by site personnel who de" mined that the locking nuts would be examined during system lineup tests. WPPS3 rr.emorandum

no. F-79-1141 stated that test procedure SLT-M-6 was being prepared to cover the inspection procedure.

Response from 81-09

The inspector examined procedure no. SLT-M6, Rev. O, "Lcose Lccking Nut on Limitorque Valve Operators" which will be used to inspect and secure 4 the-locking nuts ca limitorque type S!15 and SMC valve cperators. This procedure has been approved and will be implemented during systen lineup.

l l

l i

i

.)

h I.,

REV G Identificaticn No. GPA 30 Attacnment 7 7. c,,

Page 54 er 62 Tage 7 GErlERIC_ ER3B'.EM AR5Q

'(, 'pplicanle Contracts

210

. 213A 215 216 X 217 218 219/234 220 I

Title:

It!%DEQt! ATE VENTI!.ATI0fl DUCnl0RK SUPPORTS Ifl BATTERY ROCM

,t

[g .

r1 -

{L }

+ Sou ce Infomction:

s 79-04/13 Regarding the physical protecticn of the. batteries, the inspector observed that three supports for ventilatior. ductwork travarsing the rocra nousing j battery 31-1 appeared to be improperly anchored to the overhead. Dis-cussions .~ith B&R personnel indicated that, due te a large number of de-ficiencies noted in toe work of that particular c:ntractor, a IC3Y, rein-spectica was being perfomed cf that contractor's Quality Cicss I work and that the insoection of ventilation support antror: was just beginning.

This item will be ex.n.in2d further during a subsequent inspection when .

l the magnitude and enent of rework has been dctemined. (50-397/79-04/13).

j>

Y 1

}

}

4 l .

e

.e

t rey 0 31 Attach.ent 7 of 1 Page Identification No. CPA Dace 55 cf 82 GENERIC PROBLEM AREAS

(* _213A X 215 X 216 X 217 218 219/224 220 X I '

- Applicable Contracts: 210 MISCELLANEOUS ARC STRIKES ON SAFETY RELATED PIPEWORK f Title. '

4

?

2:

L Source Information:

t 78-07/02 The inspector exa-ined the installation of the following safety related piping:

3 .1 Drawino No.

Svstem Reactor Core Isolation Cooling RCIC-66C-6 Reactor Care Isolation Cooling RCIC-565-1.3 High Pressure Core Spray HPCS-630-11.12 High Pressure Core Spray HPCS-629-5.7 low Pressure Core Spray LPCS-756-19.21 Low Pressure Core Spray LPCS-756-8.10

(,

( The inspector also noted that a considerable number of arcstrikes were present on the piping and, in several cases, in the area of the welds ~

{- Due to other crafts working and welding near

)

t joining the piping spools. installed piping, scme of those arcstrikes may have be '

dividuals other than the pice welders. Discussicas with contractor per-sonnel disclosed their concern for the arcstrike problem and the inspec-ter was shown a clan that is being develooed to find and clean up arcstrikes curicg systcc walidcwn. Additionally, they ars reemphasizing to their All arc-inspectors anc welcers the importance of cleaning up arcstrikes.

strikes roted during the inspacticn were documented by tneofcortractor The suoject arcstrikeson an inspection report for subsequent remeval.

will remain an open item pending irrpiementation of the procedure for sys-tem walkdown and will be examined further during subsequent URC inscec-L tions, t.

1 yi i_ .,

J' e*

9 i

V

~

Attu:hmtnc 7 E E- I!

Identificaticn No. GPA 32 Pag;__1 _of 1 Page EC uf 82 GENERIC FROBLEM AREAS 4 .

. 's..., Applicable Contracts: 210 X 213A ^ 215 x 216 X 217 X 218 X 219/234 X 220 x

Title:

INCOMPLETE RECEIVING INSPECTICN RECORDS fl i .

I 5:urce Information:

{ Containment Electrical Penetrations 11/04 The inspector examined four llastinghouse cannister-type penetrations, Nos.103A, B, C, and D that were in the. final stages of installation.

The procedures, nonconformance reports, material receiving reports and

, inspection reports relating to these electrical penetrations were re-viewed for compliance with the licensee's requirements. Weld records, welder and inspector qualification for the work performad en the cres-sure retaining welds were also reviewed.

During review of the receiving irspection records, it was noted that two of the checklists did not have all of the required attricutes checked off, although the f:rm was signed off as comcleted. The li-

/~'N censee stated that this matter would be investigated and appropriata action taken. This item will be re-examined curing a subsequen'. in-spection.

Y I

.V 9

Ms L

r~

REV 0 identification No. GPA 33 Attachment 7 paae i o ,. .,.

Page 57 of 32

' GEilERIC PRCRLE" AREAS

$s. - hpplicableContracts: 210 7 213A X 215 X 216 X 217 X 218 X 219/234 220 X Titla. MISCELLANECUS PROBLEMS WIT.4 WELC DOC'EITAT10!i AND INSPECTI0ft I .

?

L r .

J Source information:

73-11/03 - Paview of Quality Records -- ~

Quality records relative to completed welds observed in the Sampling and

, Analyzer and CRD platfonn areas were unavailable for review. A Peter Kiewit Sons' representative stated the records could not be located, al-though the reids had been inspected and accepted. NCR No. 206A-3537 was issued to document this situation and a program was started to reinspect the welds and establish replacement records.

77-05 Accencf x A Paracrach A Contrary to 10 CFR Part 50, Appendix B, Criterion V, "Instrt.ctions, Pro- ,

c '-

cedures, and Drawings," and the re;uirements of Fischbach/ Lord Electric Company cable tray support drawings, a total of four welds on supports TS-1840 and TS-1981 v.ere found to be less than the required size and one weld on TS-2084 had not been cleaned for inspection as evidenced by slag ,

on the weld. Each of these welds had been reported as acceptable by the contractcr's inspecto's.

SC '8l%

'Jele prredern -6 calls fo. use cf E309-16 ucid electrode and the welc reccros tnow tnac this was used. Weid crocedure =5 calls for 2308-16 electrode. The icococer procadura 46 was ipecified and usec, contrary to specificaticn 2808-215 Section 17A pa agrapn 3.4. On July it 1980 3/R issued NCR-05405 relative to this matter. The failere to control welding of stainless steel thermocouple wells in accordance with aopli-cable qualified procedure d5 represents a noncomplianca with Criterion V of Appendix B of 10 CFR 50. (50-397/8')-03/16' i, 80-19/01 - Irragularities in the Mechanical Contractor's Weld Records

Specific Proolem - (As stated by NRC)

1. Allegation of falsification of weld records /not substantiated.

2. -ome :r.inor documentatv.- disc:epanci n . vere nr.tec during the investi-gaticr. of the aileaction. (Peference 31-03 review).

(centinued on rix page)

REV O Identification No. GPA 32 Attachment 7 Page 2 o '. 3

' Page 50 of 52 GENERICPROBLEMARE 215 216 217 218 219/224 220 j Applicable Contracts: 210 213A MISCELLANE0ijS PROBLEMS UITH UELD DCCUMENTATION AND INSPECTION

Title:

di - '

<1 il' 3 Source Information:

j 77-05/75 - Review of Ouality Records

'deld and inspection records associated with the vacuum breaker tee welds,

buttering welds, and tee stiffener tack welos were examined with the

folicwing discrepancies noted

1. Records for tack weids 1-B, 2-B, and 3-B or stiffener no. ST-4 indi-cated these welds had been visually inspected and found satisfactory on 10/6/77. Howeve", as noted in pa.agraph 7a. above, these welds .

were covered with wald slag.

. 2. Records for tack weld 2-B on stiffener no. ST-2 indic:tec electrode no. 9106 (a 5/32" rod) was used to cerf9em the welding, whereas the j weld procedure requires the use of a 1/8" red.

[ 3. No inspection records were available fcr tack weld 3B on s:iffener no. ST-2. A visual inspection by the NFC inspector verified that this j$ weld Fad been completed. Inspection records required by precedure j 1,i should have been gererated to irdicate such tnings as a joint align- 4'

' ment and fit-up, preheat tem:erature, welder and electrode identifi-Cdtion CUGber 4 Records for Areas 1, :' 5, and 6 but cring nelds did r.ot include a

finisn" time for weld prereat cs ra uired Q the record for .

5. Records for Area 2 butterir.g dic not shcw the electetce iG.ntifica-ti o r'. number nor the serial number of the magnetic parti:le test (MT) i - machine used for MT of tne weldment.

l Records for Area 6 buttering indicated an tii nachine with serial nunber j ' Y5" was used for the performance of MT, wheren F0ft records do not

] identify any MT mach;nes with thtt serial nunber.

j fj 10 CFR 50.55(e) - #145 i

Shear lugs are attached by fillet welds to ASMR Boiler and Pressure Vessel Code Section III, Class 1 small diameter (less than 21/2 inches) piping.

[

1 Contract f;o. 220 standard B-220-STD-106 Typ; cal sheae lug installaticn.

Contract No. 220 shear lugs already installed include attachmenc to 3/4" diameter piping on instru~.en*. racks 13-62, 55, 55, 69.

'b ' (continued on next rage) i

EEV O identificatic7 f c. GPA - 33 Att:chr.:ent 7 Page 59 of 82 ,ap 3 of 3

. GENERIC PROSLE+1 .~

AREAS.

, e,

\

~~-

. Applicable Conertets: 210_ 213A 215 216 217 213 219/234 220 t-

Title:

MISCELLANEOUS PROBLIMS WITH WELD DOCUMENTATION AND INSPECTION 1!

l_ __

l Sou-ce Intonnation:

! Lugs are attached to tha pressure boundary by tear.s of fillet welds rather than full penetration welds and are not used as locating lugs (see reference in 3 below).

A3ME B & PV Secticn III, 1974 Edition, Subsection NS-a433, NC-4433, ND-4433.

The Code requires full penetration continuous welds for integral attach-ments such as lugs.

4 i

r a-i it p

p ~

l II

wri g) -

Att:chment 7 Identification 'lo. ,29,., _ ,, A Pag E cf 87 Pane 1 of 1 GENEgl' PROBLEk' APEAS ,

4 Npplicable Centracts: 210 1 212A X 215 x 216 X 217 X 218 X 219/224.i 220 x i.

1 N..,,

f!ONCONFORMANCE 'lEPORTS AND CORRECTIVE ACTI0tt REQ'J~STS WERE VOIDEC BY THE Title QUALITY ASSURANCE 'iANAGER . .

I

! Source Information:

,f 80-19/04 Inspection Report tio.1480 dated Decerber 9,1976 was issued to document

j. overnight storage of quality class I main steam isolation valves in less than tne specified level 'B' storage conditions. Honconformance report No. 2062 was issued in conjunction witn this inspection findine on Decem-ber.10, 1975. On Cecember 16, 1976 this ronconformance report was toided upon the cirection of the quality assurance ranager. However, attached to the voided nonconfornance report was an explanatory note which stated thac the valves were adequately covered to meet the level 'C' storage re-cuiremrts of the General Electric s:ecificati:ns. The note also directed <

that toe Inspection Report !,o.1480 be recocner' as Reiision 1. The in-spector was unable to loct.te the Inspectica Report No.1?80, Revisicn 1, ,

to verify that this apparent deficiency hcd been properly resched. The i licensee is atter.pting to locate this document.

Corrective action report No.1213 dated December 9,1976 addresses re-noval of the s:me quality class valvez fecm the WPF55 warenouse aithout 4 A obtaining oaner release for installeticn. This corrective action request was voided n Cece:nber 15, 1975 without exalanation and contains the

. [

V' i quality assurance manager's init ais. !aspection F.eport i;o. R-1279 which

l. is referenced on tce nonconforrance repnt was not in che licensee's docu-l ment vault *:ut a copy was 1ccat2d and found cc te voice; at the direc. ion cf the auc14 ty a:s'.:raa:e manager.

! Ouality Asn.rirce 3recedure fic. EE3-0-1.13, 2evision 7, "Correctiva Action Request" provides no directica on the teiding of cere:tive action requests, nor does procedure No. 2808-0-1.25, 3evision 3, for centrol of nonccnformar.ces.

t does not appear tnat a policy exists cc,ncerning the voiding of quality 1 assurance documents. The licensee is exacining tile circumstances of this j- corrective action request to detericine if documentation to suoport resolu-V' tice of this deficiency exists. The investigation of voided quality docu-trents will centinue.

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Attachment 7 Pajt 61 of B2 REV 0 Identification Nc. GPA 35 Page 1 of 1 r ,

GENERIC PROBLEM ARE.53_

' Applicable Contracts: 210 213A 215 X 216_!__217 X 218 219/234 220 x

Title:

MISALIGNED PIPE FLANG 5 .

4 3

Source Infornation:

Specific Problem - (from Lead Engineer's reply to IOM dated November 19,1981)

Pipe flanges in the field have been installed incorrectly. Flanges that mate pipe to pipe, pipe to valves, and pipe to pumos are mismatched in

[ any of the directions, vertically, horizentally, face to face, etc. This mismatch causes stresses en the pump bearings and may reflect the cold springing of pipe.

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U REV 0 Identification f:o. GPA 36 Attachment 7 Page 1 of_1 Page 52 of 82 GENERIC PROSLEM AREAS

Applicable Contracts: 210 213A X 215 216 217 218 219/234 220 CONTAINMENT WELD JOINT OFFSETS

Title:

Source Information:

77-05/02 A number of weld joint offsets (some as great as 1/4 ir.ch) were noted in some flanges cf vertical tee stiffeners inside the containment at the 450-foot elevation.

The aporoved PDM procedure for correcting the flange nisalignment of the WT8 x 18 vertical stiffeners was examined by the inspector. Forty-one (41) flange joints nave been identified for rap?ir. The procedure specifies the addition of weld filler me al using previcusly approved welding procedures followec by grinding as required to obtain a 3:1 taper.

This is in accord with the governing 3ar3 graph NE-4232 of ASME Section III, Division 1.

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p REV 0 Attachment 7

!dentificatic.' flo. GPA 37 Page 63 of 32 Tc e I __.of 1_

GENEDIC PROBLE!! AREAS.

( ,

Applicable Centracts: 210 X 213A X_ 215 X , 216 X 217 X ?l8 X 213/234 220X 79g),. QUALITY ASS'JRANCE REQUIREMENTS APPLIED TO SE!SMIC CATEGORY I, C'!ALITY CLASS l -II ITEMS ,

-Source Informetion:

, 81-09/01

! The inspector examir.ed correspondence between the licensea and Burns and Roe regarding the quality assurance requirements of 10 CFR 50, Appendix B that are to be applied to components, systems, and structures that have been classified Seismic Category I, Quality Class II (i.e. having the potential to adversely impact Quality Class I equipment). The licensee hhd not yet determined the pertinent 10 CFR 50, Appendix B requirements to be applied to Seismic Category I, Oaaiity Class II items. The ins;ector expressed concern that work r.ay be proceeding en Seircic Category I, Quality Class II items in the absence o' defined quality assuraace require-ments, particularly since the 215 centractor is taking actice to eliminatc quality contro' involvement in (cality Class II work.

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E REV 0

?dentification llo. GPA 38 Attachment 7 Page 1 of 1 Page 64 of 82 GENERIC DROBLEM ARE,is

] Applicable Contracts: 210 213A 215 216 X 217 X 21C 219/234 220 i

SUBCONTRACTOR DESIGN C0ffTROL

Title:

ii s

Scurce Information:

81-09/02 i The inspector examined MCC Powers design methods and design drawings for quality class I supports for cenpliance with 10 CFR 50, Appendix B and

. applicable contract requirenents.

• MCC Powers is a subcontractor to The Waldinger Corporation (TUC) contract 216 HVAC performing Quality Class I and II work. Quality Class I work con-sists of the fabrication and installation of instrumant panels and the design and installation cf supports #or instru. ment panels and tubing. Tha li ensee presently has a hold en all MCC Pcwers Cuality Class I or Seismic Category I werk.

During an examination of MCC Pcwers design methods, the inspector observed that MCC Powers could not produce design calculation or design drawings i for supports of the following instruments, tag norters: CCHV-1, C0u7-4 and WMA-TT 53A. The inspectcr was not able to datermine if MCC Powers or TWC had established measures to assure that applicable regulatory require- ,

< ments and design basis were correctly translated into drawings, procedures i and instructions.

The licer.see indicated tnat MCC Powers tras not resiewed by the Reverifica-tion cf Comoiated Safety Related Werk Task Force (QCSU) and sill not be allowes to resta-t Outli ty Class

• ve-k entil a re dew cf MCC -P0wers is conducted by EC24.

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1 Att:chment 7 REV O Identifichtion No.' GPA 3 $_. P ge 65 of 82 Pace 1 of 1 Et:ERIC CROELEM AREAS

' Applicable Contracts: 210 X 213A X 215 X 216_X 217 X 218 X 219/234 X 220 X Ti:le:

REPORT OF TE!!PCRARY INSTALLATIONS ABOVE SAFETY-RELATED ITE:S 9

Scurce Information:

31-16/02 t A site employee repo"ted that three years ago a tempcrary telephone con-duit was i, stalled between mannole El and the switching roca in the rad-waste building. He reported that the conduit was stili there, and he was concerned that it nay fall on safety rela +.ed equipmen+. The individual identitied the foreman wno had worked on the original installation, who

( was still on-site. The inspector interviewed the foreman and traced the installed c nduit through tne plant. Tae c:nc~uit dic r.ot appear to be routed over er near any seismic designed or etner safety-relatad equip-cen', although it dic share supports with varicus perr.ar.ent plant ecuio-r.ent in the radwaste building. The foreman sta:cc that no design proce-dures were involved in this irstallaticn, and the electricians sinoly installed the conduit to tneir usual indattrial practices. The inspector j p identified no safety-related ccncern with tFis scecific iter.'. He advised tha WFPSS assistant construction manager of the existing details of this s matter, 'or consideration under the WPPSS Hctline program. He also intro-

, ducad tne general question of controls cver: previously installed temporary

l iter.3 in safety-related areas. The auestion of temporary attachment, to piping and structural steel has previously been addrcssed by NRC/WPPSS, and accepictla resolu', ion identified. The assistant ccnstruction marager agreed ta cdvise the inspector of his findings r213.ive to rencval con-trals. This matter wili be furtSer examired at a futura cate (297/81 C?'

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4 Attacnment 7 TEU n Identification No. GPA 40 .Page 65 of SE Pege 1 of 1 GENERi P90ELEM AREAS

"~ ~Apolicable Contracts: 210 212A 215_ 216 217 218 219/223, 220 X 4

Title:

INSTALLATION PROCESS INSTRUNENT TU21:G

.a Source Infornation:

01-17/04

,- In-process installation of safety-releted instrument lines was examined for compliance with ASME Section !!I code and Technical Sptcification No.

• 2005-220 Division 50A. Installation was coserved en primary ccatainment staple handling line nos. 25.0-X650 and 25.0-A85E. Examination of these lines revealed the slope of the gaseous filled lines were not in a: cord-

ance with the technical specificat;on or the Installation and Fabricaticn (I/F) drawing. The specification requires that gaseous filled lines shall be slocec so that any condensate will drain back to the instrument ra

k.

The I/F drawing requires 1/8 inch slope tow;rd the instrument rack.

The inspectcr regtested measurements for sloce be performed on instrument line r.cs. 25.0-X850 and 25.0-X35E cetween tuoing hanger nos. 106) anc 1073.

Slope for line no. 25.0-X850 was found to be less than the minimum spect-I r fied on I/F draaing 25.0-X850. Slece for line no. 25.0-yB5E was found to lq be in the incorrect direction as specified on I/F drawing 25.0-X85E. Tne inspector furtner determinec :55t the Quclity Inspectors were not issued tools, such as levels for che: Ring : lope.

The inspector rotes tnat the above stated lines . vere still being con-st ucted, howeser, due to tre tubing support arrangarcent it was nct apoarent trat tne incorrect s tone arrar.get.en: coult be readily correcteo when the dditional sucrrrt Or. tha h ae .s completsd. it.e futint sr;00-t 2:. sten docs ac; :peear cc 211c4, far ar.y ac ustment enc. insta'.ied.

The lack of irsDcctcr na33uremer.t cf irstalled instrument tubing is a

, perceived weakness in the Jo&. sen Cr.ntrcis inspection arcgram (followup item 50-397/81-17-04).

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Attachment 7 ggy 0 Pace G7 of 82 Identific tien No, GPA , 41 -

Page 1 of 1 j- GENERIC PROBLCM_ AREAS

! Applicable Contracts: 210 217 X 218 219/234 220 y 213A__X_ 215 X 216 X

Title:

PIP S?OOL SURFACE DEFECTS

, Source Information:

~

10 CFR 50.55(e) - =118 t

Potential Problen - An inspection report (IR-5505) was filed against a

. spool piece in the High Pressure Core Spray (HPCS) system for surfcce defects whose depth was in non-compliance with ASME Section II. The concern is that the surface defects nay h6ve reduced tne wali thickness below the minimum allowed by ASME Section III.

i Acoroach to Resolution cf Problen - A Project Engia:ering Directive (PED-W215-M-3804) has ceer issued to the contractor to ceasure tne LPCS and

. HPCS spool cieces by ultrasonic testing (25 locations on LPCS. 15 loca-tions on HFCS) where the surface defects are ceepest to get a survey of the actual minimum wall thicknesc. The material shall be visually in-spected for surface defects before ultrasonic test examination. Scabs,

[ laps, seams, heavy or locse scale, rough or titted surfaces, shall be suitably conditicned by flane cescaling, grit, blasting o- crindin3 to ensure a satisfactcry resconse.

In additien, a 1005 volumetric exam shall be conducted by Supply System 3DE, and Startep is te ensure that the pipe meets ASME Code.

Status cf .'rc:csed _0.e131ution - Test: en tne surface *2fects are be ng

concuctec at tnis time. Cum-letico af thess tests anc evi'uaticns wl11 l Le finali

ea by Ncsenter 30, 1931.

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REi n Identification No. GPA 42 Attacnment 7 Page 1 of 1 Page o3 of 82 -

GENERIC PROBLEP AREAS

,' ,,f'ApplicabieContracts:

i.

,-- 210 X 213A____ 215 216 217 218 219/234 220 FAILURE TO EUSH HAM"ER CONCRETE BEF0DE GROUTING

Title:

a 1

Source Information:

Ottestions ref red by Bechtel QA and Lead Engineers of concitions in the

, field.

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REV 0

!dcntification No. GPA 43 Attachment 7 Pic.e 1 of 4 Pago 69 cf 82 GE':EP.IC PRGBLEM AREAS

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i I lAoplicableCentracts: 210 213A 215 215 217 218 X 219/234 220

,! /

pg)g POSSIBLE PROBLEPS WITH CABLE SEPARATION i]

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. Source Infomation:

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. 81-17/05 1

q The inspector t eviewed Fisch::ach/ Lord constru.tica/cuality assurance g nrocedure on cable nu-ber reassignr.ent and prine cable identification

? (CP/QAP-424). Based en the review, it was detemined that tr.e con-l tractor was nnt prov'd ng quality control verification cf croper cable i instailation fer cable redesignated as 'prire" (associated circuits) j when the original designat'cn was non-cla;s IE and tne cable had not Deer culled in accordarcc with class I recairer.ents. The inspector pointed out that as';ccitted cah'cs must be treatec like class 1E cir-cuits and that auality can' ol measures similar to these for clast IE cables should be applied. Sir.,31y relabaling tne cable without quality centrol inspecticn tre anure undsmagea cable after installa-i tion is considered tc be insufficient. Th5 contracter was not aware that " prime" cables were assadated circuits. Moreover, the construe-(/.

tion mar.acer, Bechtel, was 3129 eraware of the cable designatier.s and separation er quality contrc' receiremer.ts for various caole desig-j nations unless specifically directed by Burns and Roe Engineering.

The Burns and Roe site eng reerirc qcnage" stated ty letter that the Burns and Rea OA precran crevides .ecessary surveillarca to insure that engir.eering design is cone :er establishec cri;eria, cnd that dr.$ ings precarec ::y durr; :ni '>ce do nortain all the . ccessary in-stallation ce:aii to tee: tne se;;aration criteria recuircents. wa-ever, in the case of CP/CA? 4? , Burns ayd Pc3 did r.c nave a review resoonsibility. The reviawing organizations could uniy review to the Burns and Poe P.E.D. which established the requirement for rsdesig-nating circuits and therefore we-c anacle to .ote the lack of cualit/

control coverage on the " prime' designated associated circuits.

The lack of clear cable sepa-ation criteria by the centractor pro-viding ciectrical installation anc by the const.uction manager pro-viding contractor quality surve 11hnce 4

was viewed os a weakness in the si c cuality control crcram.

.0-07/01 - Specific Pec5 em - (As stated by the NRC)

1. R.e of isolation devices to separate C'.acs IE acwer sources fr;n Ntan-Class li loads. Cen'ornar.ce to tna :SA2 reaui-ements is net clear in tais araa.

(ccr.iiquec en rext page)

I REV 0 Identificaticn N3. GPA 43 A22achment 7

,3 age /0 or 8 p 2 g4

, GENERIC PROBLEM AREAS-l (f)ApplicableCentracts: 210 213A 215 216 217 218 219/234 220

) .:. .

Title:

POSSIBLE PROBLEMS WIT 4 CABLE SEPARATION b .

ii 4

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] Scurce Information:

[:

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[ 2. Designation of Non-Class IE circuits supplied frcm Mon-Class IE power l{ as " associated circuits" and compliance with the separation criteria

! of IEEE 384 and Reg. Guide 1.7S. Ccnformar.ce to the FSAR requirenants 1 in this ar?a is not clear.

i

• j 79-1S/09 -

Specific Problem - (As stated by the NRC) i 1. Four " turbine first stage pressar2' pressure switches (PSNC03 A thru D) were not clearly labeled as Clas: IE equipment. Moreover, their sensing lines were nct treated as safety related equipment as to lo-cation and seismic qualification.

2. Position switches (POS NCC8 A thru 0)'were supplied as comercial grade l items, contrary to requirements of the FSAR and IEEE-279. The electri-

\ cal cable for these devices was treated a: ncn-class IE up to electrical 1

i teminal boxes TB-RPS-A1, B1, A2 & B2. The non-class IE wires were to i j j- be terminal boxes which were located within the turbine missile cone. 1 l 3. Sensing lines to PS-005A thru 0 were treated as non-safety related and were found uncapped.

l a. The specification pwcnne anc u.e cf non-clas; IE circuits and co co-l nents and th2ir direct ccr.ncction to class IE cables is net in accord-cnce with FSAR rc<;uirements for this system.

Test solenoid vaives asscciated with turbine governor valve fast clo-

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5.

. sure pressure switches (RPS-SPV-5A thru D) were observed to be uncapped.

1~

E. The inspector could not identify in tne FSAR any statements discussing the pcssible com-'on failure due to lccation of turbine step valve 4

position switen teminal boxes (TB-RPS-A1, A2, B1, and 82) within the turbine missilecene apprcximately five feet from the turbine shell.

1

'. 79-04/07 - Soecific Problem - (As stated by the NRC) i

1. Concern was expressed by the NRC inspector with regard to the licensee estaolishing a program to assure adequate separation of all safety re-lated cables and terminctions.

[' (continued on next page) t

Attachment 7 REV 0 Iden-ification fio. GPA 43 Page 71 of 82 Page 3 of 4 GENERIC PP.0SLEM AREAS r,

I Applicable Contracts: 210 213A 215 216 217 218 219/234 220_ __

Title:

POSSIBLE PROBLEMS WITH CABLE SEPARATION .

l .

l Source Information:

78-10/05 l

Patential cable separatinn problem between safety divisiors

It was noted that tilere is a potential separaticn problei.: betreen wirevays for Division 2 and Division 3 cables t'elcw Contrc' Roca Par.cl .e580, Bay G. This ; cbiem caarot be furtner evaluated until cable installa-tion is complete and fire barriers are in place. This item will be re-axanined during a subsequent inspe-tion. (3#.7/78-10/05) 10 CFP 50.55(e) - #52 Natura of- Deficiency - Several separation violations exist within the U.TS involving m.islabeling of devices witr. control r:om onnels. Tais mislabeling resulted in divisional safety related control : witches and

( x g, instrumentation of one division being mour.ted near and asscciatad wiring

3. being routed with switches and wiring of the redundan: division.

10 CFR 50.55(e) *32 L

Ce:criction of DeFc'ency - The decunentnion eerify'c; tae instal'at:cr of ratety relatec cacie.s in tr.e Pcer Generaticn Certroi Corciex (03CC :

floor ducts (main ecMrci rocc under ficor raceways) is incomplete ren-deri19 the PGCC cable roating sumarits invalid. ih! :GCC was supplied oy General Electric Company and installed by the electrical contractor; l the balance of plant portion of the PGCC was designeo by Burns and Roe,

, Inc. It has been determi.ted that: 11 there is no definitive inspection I cri teria: 2) changes to tr.e OA records are not traccaole in sore cases;

} .and 3) routing sneets used to installed the cables do rot natch the CA i record document for approximitely 2Z of tre cables. Corrective ;ction -

Prc, lect Engineering Dire'.tive (PED) No. 218 E2679 ^.as ::een issued revising j' the electeical contracter's precedure: to provida accurate documentatico for all future centrol room cable routing and termination. PED No. 218-E-305a provides a 100% reinspection and documentation of existing cable routing and terminaticn.

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Attachrent 7 REY 0 Page 72 of S2 Ider.ti ficatiun No. GPA 4i Page 'a of 4

,- GENERIC FRGBLEM AREAS i

Applicable Cont. acts: 210 213A 215 215 217 218 219/224 229_____

-Titic: FOSSIBLE PROBLEMS WITH CABLE SEPARATION __

-Source I.formaticn:

10 CFR 50.55(e) - 923, 37.13, 53, 54, 60, 64 Description of Deficiency - To date the Plant Main Control Rcom has been re-viewed ano approximately 150 instarces hate been discovered involving vic-la' ions in the application of UNP-2 Electrical Separstion Criteria to safety related cables and panel wiring. In general, the daficiencies involved in-correct labeling, routing, termination, or pcwer scurce of safaty related cabling within PGCC or Control Rcom Danels. Es.amples of deficiencies fcuni are as follows:

1. Division 3 HFCS instrumentatior powered ' rom a Division 1 source;

2. Division 3 HPc.5 cables routed in Divis*cn i PGCC ducts :nd Division 1 cable trays in the cable spreaaing roca.

Correccive Action - A task force is currently reviewing the Main Control Accm anc plant areas for other viciations of UNP-2 Seoaration Criteria in a.i safety related applications.

The U"P-2 Separation Criteria t as haer refir.ed 3r.d clarified anc is teie.g used ;/ tne 3eparatior Task F0cce as crite-i1 tj ,hich to judge iant :e; ace-clan cs designed and installec. Inis same criteria will be subtittec in sa FSAR amence.ent. Ali instances 0f deficiencies identified 30 criteria Vic-lations will be evaluated and corrected via . Scoject Engineering Directives (PES's). to the appropriate ;cntractor.

The task force is working to ar. action plan which to date has resulted ir the comoletion of the Main Control Room review and identification of de-ficiencies as described above. The remainder of the review which inc'ud-s Jucn. tnings as MCC's, local Panels, etc., is sc'eduled n to be complete by October of 1973. -Note that ongoing reviews will te conducted as warranted by construction completion.

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Attachr.ent 7 Page 73 of 82 REV 0

. Identification No. GPA 44 page i of i

[  ; GENERIC PROBLEM AREAS

\ ;s-1 Applicable Contracts

210 X 213A 215 215 217 218 219/234 220 l L'

Title:

IMPROPER FABRICATION OF STRUCTURAL MEMBERS IN THE CONTROL ROOM CEILING ,

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l Source Inforwation:

, 10 CFR 50.55(e) - #99_

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Nature of Deficiency - The control room ceiling was installed with oversized SoTt holes in tne diagonal bracing, slotted holes in the verfical truss men-4 i-bers, and portions of the diagonal bracing were bent at end connections to correct fabrication errors. Corrective Actico - The installing contractor

'; has been directed to weld washer plates over tne slotted and oversized bolt

, holes and to replace or to add sti*feners with engineering aoproval, f ar the bent diagonal bracing.

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Att:chtent 7 FE/ 0 a5 Page 74 cf 82

'Id:ntification No. GDA ,g, } f }

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- - ].l GENERIC PROBLEf1 AREA 5

_, N ' Applicable Centracts: 210 213A X 215 216 _ _ 217 218 219/234 220 j

Title:

STRUCTURAL STEEL ATTACHMENT WELDS ,

t Y Source In'ormation:

10 CFR 50.55(e) - 414 Li Inspection results have identified cracks in field welds made to heavy

structural beams wnich makeup the 541' elevation platform inside the

<j . containment drywell. This platform spans between the sacrificial 1 shield and the contairment vessel and is primarily designed to carry j pipe whip restraint lead: for large diameter and high energy piping systems including Pain Steam and Reactor Feedwater lines. In addi- >

- tion, this platform is used for Ot:pporticq seccndary loads including

,; air handling equipment, recirculating pump motors, pice hangers and snubber supports as well as structural supports for other miscellane-cus equipment in that ticinity. Tne crack: were identified as a re-

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sult of extra inspeccion requirements imposed to resolve a nonconforr.-

r;;

ing condition related to welding procedures.

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'- Subsequently, magnetic particle cramination has bean expanded to include i all field welds which affect tie ir.tegrity of the pipe whip support i structures througncut containment ano in the main steam tunnel. Pre-H sently over 60 field welds on the 541' elevation platform have been re-paired. As repair efforts at this elevation near comoletion, inspections and necessary repairs will commence at other pipe whio sup? art lccations.

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attacnment 7 REY o a7 Page 75 of 82 '

Identification No. GPA Page 1 of 1 GE.'@ICPROELp,1,jRg

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Applicable Contracts: 210 213A 215 216_ 217 X 218 X 219/234 220__ __

l

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Title:

INCORRECT IDENTIFICATI0Pl 0F ELECTRICAL CONCUlT *

- Source Inferr.ation:

10 CFR 50.55(e) - #102 Description of Ceficiency - Tagging of conduits throughout the Reactor Building around tne periphery of the Main Control Room and in the Cable Spreading Room has been found to be deficient. Ccnduits containing both safety-related and non-safety-related cables were tagged with the "non-safety-related" designation. This has been determined to be a reportable deficiency under 10 CFR 60.55(e). l Corrective Action - Project Engineering girective No. 218-E-3085 was issued revising conduit identification procedures directing tagging of conduit to be based on the most restrict ve cable type routed within i

tne conduit.

i A 200% review of existing conduit identification will be conducted and all incorrect tagging will be correctly identified.

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Attachment 7 1 Fage 75 of C2 i Identification No. GPA 14 6 REV_ 0 PaJa l_-

\' GENERIC PRCELEM AREAS

'- Ap;11ceble Contracts: 210 213A '

21G _ 215_ 217 218 X , 219/234_

Title:

INCORREC7 CAELE INSTALLATION 3 =.

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Sou e12_!r.foma t ion :

2 10 CFR 50.55(e) - 4113 4

i Cable BTRB-9028 is not long wasover enough to move runinto intotrecuticle proper 8-S3 instead of T1e cubicle. cubicle cable B-8.

' was included PA Pkg. 46.2-2 Pl. A Q-I term siip to be too short to cove. 'Jpon this diservery, the cable was found The cable will be de-terminated and spared.

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Attach.;ert7 REV _r

' Fage n a E3 identification 'ia. GPA AS Page 1 of i

}3 r,EMERIC PROBLEM AREAS lc' ' Appli

able Centracts: 210 X 213A 215 216 217 218 219/224 220 4

I

Title:

SPECIAL DOORS CND HATCHES --

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{ Source Information:

i-y 10 CFR 50.55(e) d89 l Potantial Preblem - De'iciencies have been identifiec relative to Quality y Class I special doors and hatenes, which involve materials, fabricatior.,

.; testing, and docu:nentation. These doors include watertight doors in the ij basement of the reactor building, airtight doors and hatches in the reactor and control buildings, and blast decrs in the reactor and control buildings.

Failure of the doors and hatches te perform the'c intended functiot couh adversely affect the safe shutdown and the control of radicactiva releases during a cesign basis accident condition.

( A question existed as to whett.er the doors and hatenes would have failed in service if the indicated conditicns had gone undetected.

I Final Evaluation - Ali of the deficier.cies have been reviewed, evaluated, i and resolved with the exception of those related to the rn; watertight doors (222' elevation, Reactor Buildf rg.'. The welding deficiencies on the EH dcces deviated sigr.ificantly from the desico s:ccification/ drawings and would have required a comprehensive engineering evaluatien to cetamine if tese dacrt, in -hi: as-built un11tian, mio :erfem their interced function. It wa: corc!udad that this extensive engirear eg evaluation was not econcaically warrar.t:d. ine CH doors have Leen returnec to Raycreof, Inc. - for extensive repair: whicn will bring ther into conformance with de si on/ soeci fi ca ti on rea u i rement s .

, \'

S2 nary - Special doors /hatchec 8I, CJ, 8K, BL, 211, and SN have been reviewed and evaluated for potential reportability under 10 CFR 50.55(c) criteria.and nave been detemired to be nenreportdble. All deficiencies noted have been rescived by normal site nor.conformance procedures.

'Special doors 8H have been reviewed and evaluated for reportability under 10 CFR 50.55(e) and have been determined to be reportable. These doors are j screduled for repair which will bring the docrs into confomance with design criteria.

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Attachnent 7 Edge 70 of 82 RE'l 0 Identification fio. GPA di pacc I of I

' ' ~

GEflERIC PROBLEM AREAS

(. s) i ' ' Applicable Contracts: 210 212A X 215 X 216 217 218 219/234__ __ , 2 2 0 i

WELDING PROBLEMS HITF SWAY ERACE BRACKETS

Title:

I

[' Courca Information:

j .

10 CFR 50.55(e) - #115 Descriction of Deficiencv - It has been determined that Power Piping Co.

Beam Attachments SS-142, used in rigid sway brace assemblics were supplied with undersized welas as required oy ASHE Section III, Div.1, i Mandatory Appendix XIII, Table X!II - 17*0.1 (Winter 1973 Addenda).

These weldrents wera observed to be of pocr quality with lack cf fusior, at the toe of the weia. U;ing ASME Code Allowables, an analyti: ca ?r-mined that a design deficiency exist: for these brackets when leads are applied at an ar.gle greater than 150 off perpeadicular. .

This iten has been resolved. The corrective action is fully described f

in item #115.

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Attachment 7 REV 0

Page 79 of 82

!dentification No. GPA 50 Page 1 of 4

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[. _'

GENERIC PROBLEM AREAS c

Aoplicable Contracts: 210 213A X 215 X 216 X 217 X 218 x 219/234 220 X FAILURE TO MAINTAIN SYSTEM CLEANLINESS ,

Title:

Soqr:e Infermation:

79-16/06 f Fischbach/ Lord Procedure CP208 requires " covers, caps, plugs and other closures shall be maintained intact." It also requires that "... mechan-ical cleaning shall be employed to keep the structure as clean and dry as possible."

Failure to maintain adequate cleanliness of transmitting instr.2=ents and associated sensing lines in accordance with established procedcres is an apparent item of noncompliance. ,

,- 79-16/08 i

( At the close of the work day the inspector identified seven process instru- ,

ment lines, associated with 3 containment penetrations, open and enattended. -)

- These instrument lines were under the control.of Johnson Controls, Inc. 4

! Johnson Controls, Inc. Procedure No. SP-2005-H2 (Installation and Erection 1 Procedure,-QI and ASME III) requires all pipe and tube ends to oe capped cr otherwise closed at the end of each cay. The licensee stated that the problem of closure of systens may be the rssult of other craf ts removing protective cones witncut author:::.t:cn.

The failure of Johnson Controls to maintain system cleanliness in accord-ance with established procedures is an apparent item of noncomoliarce.

This is a repeat of a previous NRC finding of 27 February and 1 March, 197?.

]

80-08/32 The inspector examined installed piping cleanliness. Three pining runs

' were examined for internal cleanliness by removing the pipe a.id cleanli-ness caps. Two of the runs were satisfactory. The third piping run was

1. -

RWCU-812-3.7 which was being reworked to replace orifice flanges with a t venturi in ;accordance with PED 215-M-5161. The crifice flanges had been

" cut out by air arcing and the pipe ends sealea. Inspection of the inter-

i. nals of the pipe revealed not only the expected air arcing slag out soce debris. The debris consisted cf flapper wheel shrecs ar.d grincing parti-

.cles. There was an evenly distributed layer of about 1/4 cup of debris

] (

l (continued or, next page) li '

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Att:chment 7 0 Paga 80 of 82 REV Ideritificaticn flo. GPA _53-- Page 2 of_ 4

(_ GEflERIC PROBLEM AREA 5

. Applicab e Contracts: 210 213A 215 215 217 218 219/234, 220

Title:

FAILURE TO MAINTAIN SYSTEP. CLEANLI'lES3 .

source Infomation:

per 12" ler.gth of pipe. The debris was visible fcr about six feet in the horizontal run of piping and continued around the first pipe bend. Since the edges of I.D. of the air arced pipe had not been worked with a flapper wheel or grinde", it was possible that the debris could have been there from the original construction and was not introduced from the current modification work. The presence of the debris indicates that there is doubt as to whether the Grade B clean systems reeet the cleanliness defi-nitions of ANSI N 45.2.1.

Tnis item will be examined during future inspections pending the licensee's examir4 tion of the general subject. (50-397/20-08/32) b 9

78-10/07 Work Procedure flo. 23 requires the ptmp internals be coated with Tower j 435RP preservative. It is noted that the pumps are installed in a Class .

{

B clean system as defined by ANSI N 45.2.1. A!lSI N 45.2.1 states that -

components in Class B syste

s shall have internal surfaces free of organic films and contaminants such as treservatives.

Licensee representatives sta ed that a n11ca51c wor < cr :edures would te reviewed and apprcpria:s actt:n ta,:en. This item will be er.anined furtner in a subsequent ins ecticn. G97/78-10/07) 20-08,33 Allegation: No system flush is planned before hydro. There 's all kinds

, of gartaqe in tne lines.

Finding: The allegation was confir;:ed in cart. The licensee's procedures ano practice allow hydrostatic tests to be performed prior te system flushes. However, this practice is not prohibited by any of the appli-

' cable codes and standards. The interral cleanliness of the installed piping was determined as described previously and may not be in accord-ance with the cleanliness standards of ANSI fi 45.2.1.

_, (con-inued on next page) f

^ ^

u. .chment 1 Pag 2 81 of 02 REV 0 Ider.tification No. GPA 50 Page 3 of a

'l , , glE't!C PROBLEM AREAS

. r Applicable Contracts: 210 213A 215 216 217 218 219/234 220

, w

Title:

FAILURE TO MAINTAIN SYSTEM CLEANLINES5

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t: '

I Scurce Ir formation:

}

Additionally, the inspecter examined radioraph review records fron June 1979 to December 1979. These records are basically a log of wrat was reviev;eo and the reruits. There were appcximately 500 radiographs

logged during this period. Of these, the inspector detemired 16 of

> the radiographs were rejectej because of " dirt", " material" or " trash" l' in the pipe. By discussion with the 5.evel III axaminar, it was deter-mined that raterial was generally weld rec stuts, a gravel-like apcear-it:g . material, and in one case a tape menure. The inspector exa'nined four of the examples for evidence of quality centrol ir.s;ection of cicacliness during weld joint fitup. In all fcur cases, the Jc.ats were in locations where .ateef al could have entered the pice from ctrer i

openings after proper cleanliness verification cf the joint.

t

('- Tne as-fabricated cleanliness of tre ciping systems may to in question.

The adequacy of the flush progrrm to remove the type of debris indi-

. cated by the radicgraphs will be subsequently evaluated during flush-L ing operations. (50-397/80-03/33) 10 CFR 50.55(e1 - =170

~~

Cescriotion cf Mickr.cv - Dring re en pr: visional accetance checks 7crB ;n material a,- ce sis have ha n ice'tified in sc h .y criated sys-tems.

The rechanical contracter orccedures required i cleanliness inspection to be performed prior to fit-up of pipe and closure cf equioment. Cut pipe was also to be examined to detemine the internal presence of any loose fcreign material. Mcwever, these inspections were apparently not perfor: red. Tiiere are three documented instances cf materiais being found in:ide Clcss I completed systems:

1. F.etal tailings in the 24" turbecharger suction line to

. standby diesel generator engine IA2. The loose material

. in the pipe was identified by WBG on a maintenance work crder dated 12-4-79 and on NCR 08022, dated 6-16-81.

4 (contineec en next page) e r

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Attach. ment 7 REV r, 50 Paga 82 of 82 Identification Na. GPA Page 4 of 4 l

I GENERIC PROBLEM AREAS f'

1. 218 219/234 220 Applica',le Contracts: 210 213A 215 216 217 l

l l

Title:

FAILURE TO MAINTAIN SYSTEM CLEANLINESS ,

l, Sg.3 Inforration:

.i hl 2. Two nails found on 9-21-81 in AHR-P-2B by Supply System l

Startup, one in the third stage weer ring. Ideatified j on Startup Ceficiency Report SDR-!11085 dated 9-21-81.

6 3. A three foot 1" x 2" piece of wood found inside pu: p 1

RHR-2?R on 9-21-81. Identifies en Startup Deficiency Report SDR-M1035 datad 9-21-31.

A .eview of the RHR-P-2B record package did not provide any ir.spection

!. recerar for cleanliness. Further 'nvest.gati.:n revealed that this ,

! pump had inadvertently been back floocad during the flushing of another l b-g ., system or portion of the RER system by Supp!y System Startup.

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A list of Generic Problem Areas (GPAs) was sent to PDM on Decerter 11, 1921.

sk The Table of Contents and the Contractor Assignment Sheet from the list of I

GPAs is included as Attachment 3. Part I. Tr. ccr.o iete li s t of GP As is incl 2ded in the Cechtel 5/ sten:: Corr::le"cn Depart.

PDM provided a response to tne GPAs on January 26, 1982 ahich is included as Attachment 4. Part I. The BRG performed a thorough review of the contrac-tor's procedures to oetermine if the procedures adecuately resolved the con-cten: raised by the list of GPAs. This review for PCM eveeled tha all CPAs were appropriately covered in the procedures, which met the recuirements for reverification reinscections. The following items are included to clarify

. PDM's roso::r.se t: the GPAs:

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2:

Page $

L l. ~PA 2 =7 - ilo P0st Wld Feat Treatt:er.t (PMHT) wa: Oerf0rmed e:

a W';P-2 by FDM.

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2. GPA #39 - The installation of te:nporery items was not witnin

', tr.e scoce of PDW s centrar.t..

3. GPA #45 - Structural steel attachment welds ware not within the scope of PD'"s ccatract.

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s.-. . ,., . u.... - s13 $1

. . .. , 7, s.

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w Pittsburgh-Des Moines Corporation P.O. Box 928

'- . ' Richtand. Washington 99352 Hanford 1 & : f 503) 377-2581 m nford 2 ;509) 377 2071 0

i i , Janusry 11. 1982 PDMWNP2-2133-CM-62-004 File: C.I.A.F.

i Centric:: 17'54 Mr. S. Pohtes Site Ccr.struction Manager

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, 9e:htel Power Corperatiec R t. , E ! ,/ E D t

'JPP55 Nu: lear Pr: Ject No. 2

'r ~ Sechtel Trailer e51 Decinet i'ower Corcoret:cn t- Eichland. Washington 99352 l'

Subfect: r JAN 141982 Gen.e..,w. Qete' 3gyT.tst T.orAhe i a -- J 7 JOB NO.14631 l-

Reference:

BECM0;.-e l-0301 I /

T. Gentlemen: -

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I y The following information is prrvaded in respo,se to the referenced ccrres-pendence.

PDM's Contract Reverification Report has been submitted and accepted by t g SP C a n d 'a'P P S S . That report centa:ned pertinent infor.a: ion rela::ve to CFA's 2nd is f re:uen:ly referenced herein.

OPA al - Multipl3 Pr::Lo s ei:n Fange ' s talla- :ni:nspec:.:r/Docu-ena:i: .

~7-07  ?.einsre::icas an :: plets d: c .,e r. : review ics beer recuire:.

Reference Reverification report. Sec:ier XV.

1-2 The PCM QA Prcgran requires cny deviations from the design be 8

reported prior to toplementstion, and the chance must be reflected on the approved drawing before w:rk can proceed. Reference the Reverifica:icn e Repert, Section T.' ice reinspe: tion activities to c:rrect sny deficicncies.

I S0-08/2c The docueentation retteu includet verificati:n :f caterial trace-ability (reference Reverification Report, Sec. ion IV). This review also inc;uded previously dis;csitioned nonconformance reports to assure proper l

resolution was provided. All documentation corrections were judged to

, :he requirements of PDM's Documen: Correction Procedure UQA-103.

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[ 30->1 Cl ?DM ?r:cetur: A3-1 '.as bea- suomittee to 1,? /5&? for app; val.

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Tais pr:cedur: adcre. eses as-b.ilti.; -ind sub=1::als :1ereef. Ic ca:e. e.

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as-bu:1:4 nate been submi.ted ta :he AE.

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, Pagt 2 of 5 Pittsburgh-Des Meines Steel Company i ':r. 3. ?chtos PDMUNT2-21J2-CM-S2-0C9

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!C.-C3 32 Ne sir.i'ar ;r:51? s were toer.d : ?CV accumar.:t:for during :n.

review treference Revert f t::: ion hepor . Sec::er. S'!. Wer% is conte:lled ,

Art dire::vd thecugh :ne use of F4:rica:icn 'he t Lists i s'C'

• s a c.r Adden-da s 'F~A's'. These FCL's .'or FCA's) 112- in cetiil :te steps re.utred to perform the construe ion and inspeetten of verk. Jney are revieved and signed by the QA Manager (or his deri;reei sed the ANI prier t:

1:suance. They are revie wee upon cer.pt. :.:n to asvare the a:tivity was per:ormed proper'.y. "o sigt.tricant changas tr- permitted unless approved v the ANI and CA Ifaneger. .Any discrepanc:es fauna arc docur.ented and

, s:ditional t re:nin.' is required for perso.rel : sus.nc th2 discrepancy.

6~-03/11 Rcqui re d shimmine gaps were re'.e r t f.2d as ;.a rt of the waind:wn of cempleted werk (reference Ree+rifica:ian Tepe- . Sectien VI!). C:n-

1'ns found :o ' e anse  : c e p t a o l .a per drawing rezaireman:s were decuzer:ed en CAR /ICAR's for Engineerir.g ev !uation. Accit;onaliy. walkcowns :f the

!!SRV lines for surf ace inspection dsc amen.+d are2.s vnere the pipe was 1:es:e3 adjacent ta otner struct is :y si assent lets than permit:ed.

These :enditiens were rep r:ed :e he AI .ia "A? C ~A.'. C'C R .

6 7 -04 < '. 4 Re ferenced Rever fica:icn Fecor r .Section XV. fer reinspec:lans 4~ per:orsed en :copleted work.

77-Oct$a Procedures have been and

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.-s i effec: for ancher bel: installa-tien and torquing (Procedures FP-15".3-23 and ~~i. Ctner non-welded items were ::n:rt.lled :hrcugh ene use uf Fr./ JA's, whien gave detailed ins ruc- /

tions on hev to hancie'them.

??-03/01 Conditions ne:*d as a resul: ef the de:ume-: revi v and vaik-cerns :erformed 142 to reinspecti:n f ep'.e:s: hardwara. Referen:c the Eeverificat ion heport. Tre review dit not reve+1 the 2se er una:;rceed

c cecurcs,

(

i l :CF'..! : . 5 5 ( e ) - 410s .N : similar ::ndi:1cr.3 se , metec .n ::n:r.c ~i;A.

l 'lotice of Violation - June 17 1953 The f.cntr:c: 213A Reverificati:n

( F.e pe r provides information cn aciions tak?n i*- tne time frame of 2'8C to current. Those actirns includea all phases et .ork, and pregrammaric revisions / raver:fication.

GFA 23 Frecedure ~V!-2 resuires the veld, as well as an ere adjacent

s :ne se'd be inspec:ed. A thickness measuring procacure (TM-1) and a material thickrcss precedure (PP-;5713-33) are referen:ed within 'a~7-2.

4 Refer _:o the Reverification Psport. See:ian IV. f:: reinspections. Also see 5cc:icn 111.2 pertaining.to 0.nega 2eal pipe :ut: join:s.

~

'.C inspe:: son pc rsonnel - airin; has 'ce -n it..e..si:ied and imprcvs d te a d t r. :ensis:ency of 'CE of ..elja.

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ATTACHMENT.d Page a. or. b Pittsbur3h-Des Moines Stee! Comoany , ,

Mr. S..Fehtos PCMtGP2-2133-CM-52-C09

_C T A a f. See :he Dever11;:stton F ;crt, Sn:ien "!. See comment.s t.i OPA =!

,, _ _.- sec-08/35) rela:ive :o ! o'd pnn s t er inspect ion. ,

G.*% - 3 Surf aces are being inspected en : cms where te .cerary attachments were used. P:ccadure TA-2 is f er the use ud ccacrol et tc np. ::ry at:ach-nents. P::cedure RF-3 sddresses the removal cf tampe-ary attrchments f und welde: in pl.:e, but not traceable s to velder 2" me:arial 1.D.

All aress f un !,: hat evidence g :nding are .rearec as te~.cor.ary attach-men: removal area 2. The are. ef removals is als( checked per procedure

- TM-1 for :hickness.

CCA7 Nc FWT was :erforme: n W ?-2 ty PLM.

';PA 4 See the Pescrification Repert - Se :iun A'.'. Fkcaec fi'let welds are addres;ed in the FDM Entineering Inst ruction Spe:ificatien (EIS-li, which is called out in :..e visual procedu e ( Tv!-21 us,d for reinspections.

}PA 9 See the Feverificati:r hp e: . 2.se t ;c T/. Im pectior per th:s s.ecriac are perf ormes per pro:e jurea '4VT-2 t Vi,ucli anc ;67:3-PP 's2 (Material Thicknet,3 sequi re:re nt s ) .

(,;- GPA *10 See the Reverification Report, Section .T/. Also, Section 7III J of tne report addressed the review oi.the radiog:apna, which would hr.ve

\. noted any significant reductions in wall thickness sdjacent :o tne veld.

The procedure used for reinspections is i!VT-2 (visualf which references lu 713-Pr-3 ': fMaterial Thichn2ss Requirements). f.

\

CFA all FOM Preceduras it71?-?F-22/21. were used fer installatien and torquir.g of c'.n:h type anch:r 5:'.:3. Reference tr.e Fevertfication ic::r ,

See:ian XV. M.

.;? A :12 3e4 t he T.e ve r *. f t e n ;c n Fe:ce: ter por: 2c:..nt *Mn :c adcrrsi

.at: rial t sceability.

GPA *13 The a/ stem used by ?OM r2cuires that all work m. perfor.ed in accordance si:h the acpreved erection drawing. Any deviations must be appreved, prior te implementat; n, sy che Projec: Engineer. Any changes to the !.E Design must be supoorted by a F.E.D.

C." A ' :16. Calthra:icn of torque wrenches was addretssc in Pr: edures CP-1 and id713-PP-24  : was a requirement :c record the serial numcer of all pieces used in combination to perform torquing.

GPA #18 See th2 Reverification Report. See: ion IV.

ira *22 Pre:edu:9 Ic713-FP-23 hat h en used on Contrae: 213.A , and has scdressed cali: riticn recuiremert.s and calibration cheeks. The skid.e e "Jilhelm '*evice nas not been used on Con:r m 213A.

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ATTACHMENT 6 Pace 4 of 5 Pittsburgh-Des Moines Steel Company b

l M

(. -- I Mr. S. Pchcos -u- TDMVNP2-212P-2M-E2-004 i

GFA =23 FOM's Q A Mar.aal sect i:n on aancenf ermar.c.s has :=er. re f eren:ed in

1

! :he calibration procedure as the me:had for dispost:1cning, r.cr.::nforming .

• quipment.

n 4

i CPA d26 All job shoppers sre requestec througr. WPPS3. Ne pretlems have

,j 'ocen f ound with the rssumes of previously cuplef e: je: sh::per:.

2

{ CFA s25 $:ru:: ural bolts have been hardied in acccrdaate with AS':E j Section 111 QA Manual requira ents. No un .ceptable concitice.s have c' been found rela:ed to s: uctural belts.

ta

] GPA A:S Material that was scrapped required . hat the I.D. Number be

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re .cVed and :he material ta s:cred in a dea:;nated trea. Material had

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. ce requisitioned frca 0.a. ;; permi: installaticn.

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!l CPA =31 Areas tha: have been subjected :: at: strikes, etr., are fir.al

nspe::ed for .hese problems as the 1. :, t pheses of opera:: ens. Also, all PCM work telew :he ws:erline in the wet-ell :s suoje : to cea:ings inspec: ton, uni:h requires a cetailec tr.specciar. by coating inspectors.

CPA 332 The receiving reoorts nave been reviewed, and wil be reviewed

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(- again in preparation for turnover. '

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GPA *33 All weld recerds/ inspection records were thoroughly rev:evec.

'.; See the Reverification Report,Section IV.

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[' CPA #34 All nenconformance repcrts were subject of the cocumera: review.

5(e the Reverii;:ation Repor:, Se:: ice IV. Also. 2 wri::er pel:ty in etiec: at TCM raquires depar: ment heac (QA er Ergineering? ::rcurrence er snv d.ccumen:s :o te v?;ced.

-, a. e- n. r.

.. h e ur.. t :ng;neer,.ng .nstarc: ton 5, ec 1::ca:. 1 . -t .e::ner criter a fer cisaligr. ct.:. Ttis criteria is referen:ed .r. :he v;2;a'.

proce:u e (WVT-2) used for ft: up inspec:icns. Alec, see :ne T.eteriif-catics Report, Section 7// f or reins;e:tten ictiv ::es.

{

GPA 231- .All work in PDM's rec,c: vas/is classifted Quality Class 1.

T.PA *39 No similar circamstaace 2xists en Centrac: 213A work, sir.ce n ne ci the-hardware is fragile, i.e. irs:rumentation pane.7 are.

OPA #41 Main Steam Relief. Valve. piping is being inspected complete.J

in the vetwell.- Results on the initial 7 (of 13) lines have been r?por

-

lj~ oec :o B&R Engineering per NCE 213B-08996. The direction proviced by this NCR will'be used to como'ete the inspection and pertor repairs es raquired.

Other systems cid

- .ot exhitt: .ir:as of concern turing the al.< downs par-l ccreed. but wi' 1 :e rent:cecc d aring t he comple t ion' .,i cons: rue; ten.

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ATTACINEtiT 4 Fa9e 5 of 5 ,

Pittsburgh-Dos Moinos Stool Company LA-Ii

':s -6/.i Mr. 5. ?oh:ss PCMWNP2-213 3-C!-82-0C 9 r

h- CFA =s9 The cr.ly su.y tra:e besckets useu by Ocn:rac: 213A vere tr.e sueject

] of Steo Uurk Creer =10. and per le::c WNFIF;M-213-F-61-0301. FCM was given a full release te use these bra-ke:3.

1 ~

-j GPA #50 Si:uacions identifying debris in the pipe have been identifiac when per:ctming radiography on :he MSRV and upper spray headte piping systems.

Direction was prov ded by Eng

eering to cicar the debris as necessary te vbtain acceptable radiographs, anc that the debris wegic be remsved during

] .

fir.a1 flush and hydro :et:ir.g.

't

-j le should be noted that CFA -43 was lis:cd as applirable to 213A. but the

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.I' content of the GPA as wrt: ten is indtective that 1: was not fer 213A work.

We feel that these responses shou'.d serve :? dement.: rate chr.t all GPA's nave t-tec:. adecuately addressed thr: ugh actions taken.

i~

Very truly yours.

PITTSE'JPGH ~ ES MOIN!t CORFC AA01C.

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he D. U. Culver Ae.:irg Fr ject Mar. age:

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_ CWC/TJFrah J

c. F. C. Car-:ng:ce

.i 3. Shel::n

2. 7:tr. o?M. Sacrar.rt:.

. Cortese - Ete tel. 5:t=

>l . S. C.'.'i - SPA 25-2 7 .tF-2 Files T. J. Estev - F M. 3ite 4

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'e sn.-

gG V<ffW SECTECM FI'lE #

. ~~ 3ENERIC PROBLEM. *EAFf US ,

.' \._./

' 5.1 GE!!ERAL A list of generic problem areas (GPAs) applicable to Wi;P-2 was compiled i

by the BRG and is included with the contractor problen area assignment ,

} sheets in Attschment 5-2. The list was developed to te used as a guide in selecting the reverification inspection attributes as aonliable to the j centractor's specific GPAs indicated on tne proble'n area assignment sheets. Diese GPAs are more fully ciscussed in ne Systemt Coroleti:n Report.

The BRG has reviewed tne GPAs for Contract 215 and identi' led the appli-cable related progra:ns, documentation review programs, cr oca!ity Control Instru.tions, which ensure tne problem areas have been adequately sccress*d. A list cf tre GPA3 with the car-espond'n: response action

.2hi:le 's provided in AttacFment 5-1.

5.2 REL4TED 01 -R A"S

• f isteral : 1tec crogra s nave been esta:l' sed at .09-2 *.itr. -ecuire

,. eitos- 3 <aMem samolina or 1r0 ,:ercent reinso+ction and ework, anre .

necassary, cf variouc safety-related problem areas. These related cro-orams are described in Section Four o# this reoort. !n the response to tna GP As, tne related prograd applica 1e to a GP is specific 31;v ident-ified i:1 Att?ch :ent 5-1.

5.3 TC';. MENT ATI0t; REVIEW A review of '.48G's cocumentation un cerformed to ensure technical ade-TJacy of the cccumentatien and to identify the installation status. A 100 cercerc review was performed by W6G, .vith snat-cneckino ind surveil-lance perf r-ed :y Bechtel QC. Tne '.iCG Docurentaticn Review is describec in Sectic Two of this recort. This review cr3vides the resolutinn fcr correcting several of the concerns in tne GPAs, as illustrated in j Attachment 5-1.

5.1 OUALITY C01:TRCL "!STECTIC.*:S f CCIs1 Three Sechtel Reverification 001< RVSS 1.00. U 2.00 and R'P 3.00) were develooed frem existir P.ecntei ,CIs, which were used as the base criter-E-1

.?

la for the hardware reinspec'.icns. The disc::ssion on the derelo~nent of

-! these OCis and copies of the actual instructiens are included in Section N Two of this report. Specif!c' reference to indivioual CCIs have been made in resnonse te tne apeiicae:e GPAs in Att,1:*. ment.5-1.

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-h h Attachr.ent 5-1 Page 1 of 3

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KEY

_p_ ,

A - WBG Documentation Review: refer to Secticr. Two in the Contract il5 Reverification Report.

t i 9 - Related Programs: refer to in Section Four of the Contract 215 Reverification Resort.

4 I .

OC: - Quality Centrol :rstructicn: refer t.) Section wo in the Contract 215 Reverification P.eoc-t.

~

i 1

4 APDLICAS:.E

. GPA QCI, A, 8 RV-2.00 - A 1)

2) A

3) AVP-3.00, para 4.;d

4) A

5) RV-2.00, F.VP-3.00, R'/SS-1.03, para 4.4h E

6) Not in C215 Sccoe

7) A t

5) RV-2.00, RVSS-1.00, para 4.4A, ' CAP.-3

9) P.VSS-1.00, para 4.5 i

RVP-3.00, para 4.55 10) i

.g C20

. . _ _ ~.

fi28achment 5-1

, Page 2 of 3 -

t t

APPLICABLE GPA OCI, A, B

11) RV-2.00, para 4.2.4, 4.2.5, 4.2.6, 100% anchor bolt ret rque - 8

12) RVP-3.00,. para 4.3.1

]

3 13) RV-2.00, RVP-3.00, RVSS-1.00, para a.2 Bechtel As-Built Procram - 8

14) Structural Steel Bolting - 8

16) Anchor Bolt Reterque, Structural Steel Boltino - 8

18) A

~

22) Anchor Bolt Retorquing, Structural Steel Solting - B 23; Ecuipment Evaluations - 8

~

l_ 24) A

25) Anchcr olt 9etorque, Structural Stael Boltinc - B

26) Sacrificial Shield '4all Reinspection Prceram - 3

27) Leckenby Fabricated Components inside the Drywell - B -

i

29) RVP-3.00, para 4.3.1

29) RVD-3.00, para 4.2.3 31; RVP-3.30 a.Ec,.*rc Strike Evaluation 3 l 32) See Receiving Inspection Reoort in the Scecial Task Peport j Element of tne QVP Reccrt.

33) RYP-3,00 - A t

34) A

35) RVP-3.00, para 4.2.6

37) Ouality Class II, Seismic Category I item were &lso examined during the Reverification Procram in accordance with QCIs' RV-2.00, RVP-3.00, and RVSS-1.00, results are included in Centract 215 Report.

.it I

!- C90

Attachment 5-1

. Page 3 cf 3

-i

APPLICABLE i

GPA gCI,A,B

[ '

!- 39) RV-2.00, RVP-3.00, RVS3-1.00, para 4.4h

41) RVP-3.00, para 4.5

45) RVSS-1.00, Ccntract 215 Structural Steel Report, refer to final Contract 215 Reverification Report.

49) RV-2.00, para 4.4

[ 50) RVP-3.00. para 4.5d 1

4 3

f 1

d i e

3 A

6 o

i 030 4

L

Attcchment 5-2 Page 1 of 7 GENER!C PROBLEM AREAS D'~ Table of Centents 4

l

'.l j Centractor Problem Arca Assignment Shect. . . . . . . . . . . . . Page 1, 2, 3 -

i .-

1 1 GPA No. Title :nfomation Scurce l 7

1 i  ! Pul:!p e Drotalens with Hanger Inst.11atien, Inscec'ior., (NRCitems 77-07/01, and Documentation 78-01/1/2/3/4, 60-08/24, 80-01/01, 80-1 1

C8/38, 80-08/11, 80-04/14, 77-04/5a, 79-03/01) (50.55e-#1CS)

(RF 215, 216) Notice af Viciatic - 6/17/80 2 f;9E to A",ME Section VIII Ecquirerents vs tile to 'ts'iE '

.NRC item 20-03/22)

Section III Requirersc-ts .

' WPPSS Cc mittrent to Examine Possible Stress .ikce at U:RC i:Em 79-15/r5)

/ Pipe to Valve Weli en:s. Exanistier of 'ull 7hichnu:.

• l

\, Lack of Train 1r.g or Instruction on Weiding (:nter;-eu-

• i z of Welding Require.Ter.ts) i .

. J QA' Inspector Missed the Final Weld Visual E. tam and the UtRC itan 80-Oi/15) l Sy-Off of tce LP Test Pesutts Test was Perforwi (RF 215) 5 Procedural Centre' of Temperary Attachrrer.ts by Ccntrae (NRCitems 50-02/35,

15 00-CE/C?, ; -CF /CE)

(?? 217) 5- Miscellaneous Problems witn Conduit ar.d Tubing Clar.ps MRC i:cm 7S '.C/03) s.50.55e-1152 )

7 'jualification and Occumntati:n of Fost Weld Heat Trea:- (NRC items 79-10/01, cent frocedures 79-10/03) ('?

d 215) 3 QC !nscector Accepted an Ur.cersi:e Fi!!et Weld ca a (t;RC itea 80-C8/12)

De.ved Jcint d -? Control and Documentation of Gouces or Grindout on (NRCitem 80-08/19)

. atructural Steel (RF 215, 217)

' 5 c J -efart to lu CFR 50.55(e) Supply Cystem File krter y refers to Restart Fincing Ccr. tract Nur. er ,

1

7 Attachment 5-2 -

Page 2 of 7 GPA No, Title infcrmation Source 3

J

- Grinding on Pipe Walls Withcut Minimum Wall Thickness (NRC iten 20-08/21)

Verification (50.55e-f30 & 90) 11 Anchor Bolt Installation ~

(NRCitems 80-08/20, 79-12/01,78-07/01)

(50.55e-f58,62,83 ii 155) (RF 215, 218) 12 Heat Number Missing from Pipe Spool Number RHR-2018-1 (NRC item 80-08/26)

__(RF 218) 13 Calculations were not Provided to Support the Deletien ('iRCitem 80-08/29)

,j or Re-Design of Support Welds 14 Forging Sursts Identified in A325 Bolts in Reactor (NRC item 78-10/02)

Building Superstructure l Failure to Properly Color Code Electrical Cables 15 (NRCitem 79-04/08) 15 Control and Calicration of Tcrq.;irg Tosis (ti?.C ite : 20-03/ a) 17 Iacen:lete Quality Dccumentation (C !!E- 77-C3/65) ~

f)F 215) d Inada;uate Procedures / Checklists for Final Occ:.: w. Re- (*;?C i rs 37-08/35,

. siew Prior to Turnoser 80-C2/37)

$' 19 Inadequate Cable Crieping Tool Calibraticn Proceaure (4RCitem 79-04/09)

- and Occumentation 20 Incomplete Cable Tray Fasteners (NR item 73-02/P.3) 21 Cab'3 Pull Calculati

n Criteria Not Defited @F.: i:2m 7?-1MO 22 Fracedures Cid Not 4dcress the Frequency of Cal'bratten (NF.C i te- 73-09/02) of Torque Wrenches 23 Fischbach/'_ord Calibration Procedure Did Not Clearly .(NRC iter 79-04/CS)

Specify Evaluation or Documentation Requirements ~

Equipment Found Out of Calibration l 24 Cersonnel Qualifications (NRCite,S1-01/09)

25 Structural Column Anchor Bolts WRC item.s 78-10/01, 76-03/04) 26 Miscellaneous Prcblems with .the Sacrificial Shield Wa'.1 (NPC items 79-12/0a, SC-Ca/01, 80-Cf./07, 30-C4/'.$, 21-05/04, -

80-C6/06, 79-16/03, 80-04/16) (50.55e-M 9 1 70: (RF 215) it t

Attachr.ent 5-2 Fa>Je 3 of 7

. *% No . Titir Information Ecurce N't

~

27 Miscellaneous Froblems with Pipe Wnip Restraints (NRC items 80-04/11, i 80-04/08,80-C4/09,

80-04/17/18/19) (RF

, 215) (10 CFR 50.55e-

, #34) 28 'Jnesplained Fresence of an Installed Pipe 50001 Marked (NRCitem80-C8/27)

Scrap

2? Loose Locking Nuts en Limitorque Valve Operators (NRC iten 80-06/04) 30 Inadequate Ventilaticn Ductwork Supports in Battery (NRC item 79-04/13)

Room 31 . Miscellaneous Arc Strikes on 3afety Related Fipework (NRC item 78-07/02) f

2 Incorplete Feceiving Ins::ection Reccrds (NRC it'em 78-11/04)

(RF 213, 218)

, 33 itiscellaneous Probleas with Weld Doventation and '(NRC items 78-11/03, Inspection 77-05/4c0. A Para. A, 80-08/16, 80-19/01, 77-05/7b) (50.55e d145) 5 (RF 213A, 215. 216, 217, 220) 24 Nanconformance Reports and Corrective Action Requests (NRCitem 80-19/04) 1

'Jere Voided by the Ouality Assurance Manager 35 Mica'.igned Pipe Fiar.ges Bech tel 36 Ocntainmer.t Weic Joint Offsets (NRO item 77-05/02) 37 Quality Assurance Requireme-ts Applied tc Seismic Cate- (NRCitem 81-09/01) gory I, Quality Class II items 38 Sutcontracter Gesign Control (NRC item 81-09/02) 39 Resort of Temocrary Installations Above Safety-Related (NRC item 81-16/02)

Items 40 Installation Process Instrument Tubing (NRC item 81-17/04) 41 Pice Spool Surface Defects (50.55e-#118)

.22 ea ilure to Bush Far.rer Ccrcrete Befcre Grouting Sechtel iii

r Attachrn:nt 5-2 l' Pago 4 of 7 GPA Nc. Title Infer.Tation Source h.

I] .., Possible Probier.s with Cable Separation (NRCiten 81-17/05, 80-07/01, 79-16/09, 79-04/07, 78-10/05)

(50.55e-!23,37,43, -

52, 53, 54, 60, 64, 82) 44 Improper Fabet:ation of Structural Mem':ers in the Con- (50.55e399)

< trol Race Ceilinu 45 Structural Steal Attach. Tent '<ields (50.559-=14) 46 Incorrect Cable Installation (50.55e d113) 47 Incorrect identification of Siectrical Conduit (50.55e 4102) i da Special Doors and Hatcnes (50.55e-!89) 49 :ielding Proolemt vf t5 Swsy Brace Braci.e:s (50.55e il15) 50 failure to Maintain Cyste* C eanliness (W.C item 79-15/05, 79-15/02, 80-08/32, 78-10/07, 80-08/33' l (50.55e-#170} (RF 215, l ,

20) i 3

s. _.

t.

W ..,~ a . -- - w .= w 1 - - , -- - -.-- - e2J --

- -.y.____. - - -

Attachment :-2 Page 5 of 7 CONYRACTOR PROBLEM AREA ASSIGNMENT SHEET

! ,k ' - - -

! GPA Ho. 210 213A 215 216 217 218 219/234 220 i' e b

1 X X X X X X i 2 X t

I

2 X X X X X a

] t X X X X l

X i 1 5 X X s

.}

.; 6 X X X X X I, X X X X X

! 3 X X X X X X X

.- ; 9 X X -

X j i.

X X X X X

.- i*

• X X

. .' X X i

V X .X X X X 12 ,

i l 1 X X X X X X X r

13 s l

X X

13 l l X X X X X X 15 X i

17 X i

.I  ;

X X

la X X X l

X X g X g

[

19 X 20 L X

' ' X X 21

~

X X 4 22 X X X X X i ,

I x x x x x

.x x t

I X X X X

'X X X .1

$ _1 o

)-

. . - - . . - . ~ _ . - . . . = _ . ---

M .

Attachment 5-2 CONTRACTOR FP.CSLEM AREA ASSfGNME?tT SHEET Page 6 of 7

'd . _I

' :* bb-

. . 1o. 210 213A 215 216 217 218 219/234 220 i .

.! 25 X X X 26 X

, 17 l X 28 X X X X X 23 X 30 X

• l 31 X X . X 32 X "X X

l X X X X X 33 X X X X

_X X X e

~S X j .(

l X- X X X X X 1

I i l l X X X X

, 1 g ,.

l X

,, 33 g 37 X X X X X X X l t 23 5 X l l ,

}

l ,

2 39 X  ! X X X X X X

t.  !

1 40 X l .

42 X ,

i 43 X 44 X 45 X 46 X l

l .' \ l I X X 1 l 1

3 ~$ I' X f l l

2 k-_

Attachtrent 5-2 Page 7 of 7 CONTRACTOR PROBLEM AREA ASSIGNME'lT SHEET

~s -- - --

%.. No. 210 213A 215 215 217 218 g 219/234 220 t .

.. l

- 49 X X i 50 X X X X X  !' X 1 -

'}

i i

.(F O,

I O e

• t l'

+

9 3

~

's)( W PT FRDR Zl(a flEP0$T Ptge 7 c' d 5

i -

S r'

( '.

t

(

W NLTV1RF10m WeWfEf A list of Generic Problem Arecs (Goo )s was sent to TWC or. Cecc..ber 11, 1931.

The Table of Centents and the Contractor Accignment Sneet frca the list cf GDAs l-it included in TWC's report. The completa list of GPAs is incit.ded ir. the

,. Bechtel Systemi COT.pletion Reoort.

J f 6WC proviced a response to the G?ns which is included in TWC's report. The SPG h performed a thorough review of the contrac;or's procedures to deter?.ine if the p*oceduras adequately rasc'.23 toe ccccerns rais2d by the list of Gc As. Thi s r sv i s,s 'or TWC revnted tnat all G?% ware .'r.;:rc;ri ately cove. ed i 1 the pr')cedures, nnich ne; the reTJirements fcr reverificaticn rainspscticrs, i

t l-7 i

i .

,$ \. /

b t

y . - -

@CatPr- @ m GA>.1-13 ird

&I& 12-@ W vg A L.OI14(412'S Isv. 0 t

12/14/81

( ,

l GCA'.!TT ASSURANCE IN5.nr.uON NO.13

-I 5 8 h. $fM -

Ap,rova:

Q.A. Superviser

1. Purpose This instruction is to define the ineshod The Waldinger Corporation Quality organisa ica sha'i use to accomplis.s and docu:nent t.he reverification of work ccepleted pr:.or to *uly 1990 as directed t

by Construction Management (Be:htal Power Cczporation) in reference e below. -

~

J-

2. References a. EECWC-216-91-0337 (w-13170)

< b. BECw -216-81-0425 (w-1!380)

c. Tic TQCP Manual e

3. Applicabilit-?

Inis instru=:. ion shall be complied with by The Maldinger Corporatics Quality organization personnel assigned to the f WNP-2 jobsite for the reverificatien of the werk described above.

4. P

__rocedure 2e following action will be taken to acco=plish the

, raftired reverification:

4.1 Identificatie- and San.311nc e me Lead Q.C. Inspector with i tse assistance of the assigned Q.A. Engineer shall identify and develop a list of the supports (hangars), ductv:rk and f equi; ment that was installed and insrcted (production work

.t complete - Quality do=umentation ecstplets and reviewed except

'~-

/ for final as-built and seismic calculations; prior to *uly .

1980. The sour:ss used fer preparation of this list shall be ,

the weekly reports of coupleted hangers and duct, for the period up to April 1960 and the listing of w:rk completed 90 dayr, prior to shutdevn which we prepared for the POS*,*. team. Bardware itemr subsequently s'leleted er 1ewerked and totally reinspe-ted shall be deleted fr== the lict.

4.1.1 The I.QC: e.nd the QAI shall rande=ly select 104 cf the

,ite= gc kthe lis g r,ep,y,e e AdyQe.;;;,,, xra ' ' * * ' ** -

• • • • AS NED

' a) N b _ i b ?)urchlass" areas,*isfdst % =t'fram (

~

i i - ,_~__ m , _ x _ ..-_ -,--.n-u _-

1. J,

._ _ . _ .. . . . -.- ~ e-

} b) the variots systems, work coutplexity, personnel

} invclvsment, documentation requiremants and time .

span, on the total list.

c) the various Walders performing the work.

d) the variour inspectors parforming the inspections.

4.1.2 sample selected sliall be sutaitted to Dechtal Reverification Group for review & approval.

~ . -

I i

i. __ . _ _ , . , _ . . _ _ . . _ . _ _ . . _ . . _ . . . . _ .

c r

Q,.l b p

{~ Section 5.0

! , f

.3.vy;wenantProDiem as=as.,uraT- f The Waldinger Corporation Quality Assurance organization has reviewed the Generic Problem Area list provided by the l Bechtel Reverification Group and provided a listing of

• Waldinger procedures which resolve each GPA identified applicable te Contract 216. The remaining GPA's (not identified ao applicable tc our Contract) were also re-viewed, and none were determined to be applicable to i Contract 216.

j The Waldinger Corporations response to this item was provided January 15, 1982 by WCBEC-216-82-029. See Attachment II.

, e I

i l

t l

1 i

t\

1

, 1 V

i

• \

Page 1 of i y v . - _ . - , _. , , -

( THE WALDINGER CORPORATION 9.O. DDR K1/ nCML,AND, we sangt / 888/3194t1 am2774tes Jenscy 15, 1982 .

m -216-82-029 (W,13793)

Bed.:el Pcue Cc:pera:ic:

?.0. Son 600 Caller Service i Richin-d, WA 99352 - -

d i

1 Atteca: 16 . Stra: Poh:os Site Ccos:::uc-'m Ma.:ager

Subject:

W.O. 2 SOS

, WFPSS Nuclear Pro -: No. 2 i

7

1. 7fEMI fee'1!ba W@

e Referecca: EC-M1-81-0301 G;-13613) i Gen-J.emen:

In respecse to be refemH lete, The Etidi ger Cor cra-ica cuality i k.- Assurance ergs:d.::atizm has reviewed the Generic Problem Areas ihM*4ed I

, A.- as applicable :o cmm : 216, and prepared the at:a6.ed lis: of M:

procedures and cheklist stich resolve each GPA.

[ The re4-45 GPA's (no ide.HW as appTd-Ale to Centract 216) stre also revieM, as suggested in de re.ference 12::s , and none w e der-2 ed to be applicable to IWO.

Shxld ycu '.me any cuestiens re3c--.2=g this en::er, plance cen:ac: W.O.

Mack at 377-2441.

Very ::,:17 y:xes,

'DE MM.DDER CORPORATICN t

r .-. carner Projec F-= =7 D3:dac gp _

i cc: G. !t :*" h E Files QAC*' , <

F. Earvev -

QAS "

g4

'vD Mack 4 6/Y A U1 OTHERS -E QA Files -

FILE _ ellh I .

)

'CKEC-216-82-029 (k*-13793)

. 1/15/E2 Page 2 THE WALDINGER CORPORATION 2

4

. _,. @A  ?? h ws/ChL M er CS2OCS 1 MC?-2.1 j .W-3 . 0 ,

MC?-10.4 I ,' K O -8.0

M T-10.0 i MC?-15.0

, , K C-15.1

.i FQ2-17.2

] W-1.6

.: Fe -6.0

, PO-1 Adhem 1,2&4

'. 3 MC?-2.1 Spef ^~ c GPA :o :

<pp2.icable to T4

+

g 4 M O-10.4 M G -17.1 KG-17.2 6 --

Not applicable to TC t

j ,

7 ?Q-1 Adder.da 1, 2 & 4

/. ' S FOCP-2.1

,(

i

' Q 2-10.0 QCP-10.4/ Fig. 2 -

' 4

10 --

Not a:plicable to UC 11 K C -10.2/ Fig. lA, S-1, C-1. L-1 13 . E-1.17 16 QC?-12.C/F4 1 18 MCP-2.1 MCP-17.1 K C -17.2 22 M CP-12.0/ Table 1

. 23 KG-12.0 i

i 24 MCP-2.1 25 MCP-8.0 MC?-10.3 MCP-14.0 i

W . em ea3og

,__-7,,p y e-y w -

e 7 w -w - h w

k 2 C-216-82-329 G-13792) 1/15/82 N'*2 THE WALDINGER CORPORATION

,(_. -

GPA s Fiva~E/CE-ECDlST C1!GNIS 30 FQCP-10.2 Lat:ery Pa ms were t c e letely re-inspected .

!. to MCP-10.2 p:dm to

, July 1980 & again re-irspec:cd to assure ce pliance to la x

i eleased PED's.

i ~'i 31 K'?-1.18 t

MCP-10.0 4

MCP-10.4

, 32 MC?-4.0 MCF-10.3 2 . W -17.1

,; . i FQC?-17.2 m,,= ,..-

n a, .

MCP-10.0

~

M C -10.1 MC?-10.4

! MC?-17.0

, ~ .

FQO-17.1 MCP-17.2 s.,

'- 34 MC?-15.0 -.

i MCP-17.0 ,

35 --

Nc: a:p" r ele c TI 37 O!M Sectic. I-FID-357 Q~?-10.4 33 QCP-7.1 i MC?-18.0 1 ,

39 --

Not appHcele to 74 l 41 MC?-15.0 Specifi: G?A tot

applicable to T4 50 MCP-13.0/F441 (Appendix A, B, C, D)

FQC?-10.5/ Fig. 1 MCP-10.3/ Fig.1 '

(Aspendix A, E, C) e p.-_

. . _ - __ _. _ __ _ . _ _ _ . . _ , . . _ . ~ . -

GXc6RPr FROm iI'7 PEFoLT'

(\/OL-.E,Sco)<- #1

• F I4 ') ,

Ecge 6 of E

't '

s 5.

r A list of Generic Problem Areas (GDAs) was seat to 3 entry en Dececter 11, 1931.

The Tacle of Contents and the Contractor Assigreent Snect frca tne list of GPAs

is incluaed as Attachmen . 3 to Part I. Tne cumplete list of GPAs is incl'uded in i

l [~ the Bechtel Systems Coct etion Repo-t.

\

!_ Sentry provided a respr. to the GPAs which is included in Seatry's report. j

~

The response te the r.cchanical iter's is indiccted in Secticn I cf Sentry's re.:crt and the resper.se to t!e electr';al items is '.ncluded in Secticn 3. GFAs 21 and 47 do not 431y te Ccntrau O, <hich cces of. have Oniity C'..ss ' cacles or raceways. The BRG performed a thcrou;b review vf the contracter's precedures to a determine if tne procedures adecuately resolved the concerns raised by the list of fi

! GPAs. This review for Sentry revealed that all GPAs were apprcpriately covered in

! the precedures, wnich Tat the requirements for everification reinspections.

8 i,

(217.9 f

8 -

L-g _ . . . _. - -.

Company 5 .

Fire Detection DeslGne, anc hettsetom 1106 54m t .. Avenue East Tuoma Weenington M424 December 21 ,1981 me s:24Su SABEC-217-F-81-0324 .

4 Mr. S. Photos, Site Construction Manager WPPSS Nuclear Project No. 2 P.O. Box 600 '

Richland, Washington 99352

Subject:

Contract 2808-217 Management Reverification Plan - Mechnical a

~

Referer.ce: 8ECMCL-81-0301 /Genirrc M TECKFjT"1T. s,t] M Gentlemen:

The referenced list makes assignments of generic problem areas to be included in our reverification efforts and requires Contract 217 to provide justification for removal of the assignments from j your list.

I: ems 3, 4, 7, 8, 10, 28, and 41 shculd be removed frem the 217

, portion of your list since they have no application to the work perforced by this contract. .

Respectfully, SENTRY AUT0t1ATIC SPRINKLER COMPANY A

, Ben Craper P.oject Manager i

I- DD/DL/tig

(.

1 cc: WC Bibb I B&R Doc. Centrol B

.J Local;on8:

Tacems For'Jand APChomqt Sooksne Rechand Salt Lake City Reno Las vegas Donver

.e. , 3%Q .

Sanciego l . _ . . ... .-

? .4 Y

l

N Page 3 of10 Date 6/2/82

, CONTRACT 217

~

)

REVERIFICATION REPORT - MECHANICAL

.t

. 2) SCOPE (Cont'd.) i 1

. The scope of reverification includes all QC I and II, SC I items

! installed and final inspected (partial or complete) to this contract l

f ;'

prior to July,1980 (Set: Attachment B for listing of systems and hangers). This included Systems 79 tnru 84 in the Diesel Generator pj Building; Fire Extinguisher Brackets in the DG, Reactor, Racwaste

j and Service Water Building; and welds at the 606' level of the 4 Reactor Building,

,} There was no offsite fabrication of QC I hardware. QC II piping

!# for SC I designed systems was fabricated in Tacena ct home office l to Work Procedure 01.

The mechanical portion includes 775 OC I and QC II, SC I piping hangers and 49 SC I fire extinguisher brackets. Of the 775 hangers, 43 were partially or completely installed in the DG Suildirg and

, all of the SC I fire extinguisher brackets were installed crior to July, 1980.

j

)

The electrical portion includes 115 SC I/QC II Reactor Building

!: unistrut and sensor bracket welds. The results of document and r . - record review is reported in Section 3 of the Electrical Reverifi-l} .i cation portion of this report.

i

3) OTHER PROGRAMS Sentry initiated reinsoection of electrical support welds and some Diesel Generator sup; orts pric to nie er.tatien of tne Reverification Program. This activity was conducted and nonconformino items dccumented in accordance with approved procedures and the QA Program.

r 4) ea'altM Weigg In accordance with Attachment A.1, Generic Problen a.reas 1, l'., 13, 16,18, 22 thru 24, 32 thru 35, 37 thru 39, and 50 apply to the mechanical protion of 217 contract. The Generic Problem Areas are suninari:ed and responded to as follcws:

3

_.]

c r .~

E f

Page 4 cf 10 Date C/2/C2 I

CO'4 TRACT 217

~

REVERIFICATION REPORT - MECHAliICAL

4) 6 Q s,t:=:,y cy c.,, g g ,

GPA #1 - Multiple Problems with Hanger Installations:

Design changes not author 1::ed, inspe:.tient and OC records incomplete, material not traceable, hanger clearar.ce, undersize welds, PED not incorporated, inadequate design analysis, etc.

Response

None of the above conditions were cbserved during reverification.

Se'itry's systen (!P-19 and EP-5) in effect ther. and new requires all design changes to be authorized and dated before inspection. Inspection Checklists contain every major attribute of the Insi.allation Procedures. The '<!ork N ckage c ncept details the recuired records and " a record of raterials requiring tra:eability. Recorcs are reviewed orior to ccmoletion.

PED incorocraticn and dos gn analysis is an Engineering '

function. PED's are rout d to each decartment for intact comments / action anc imple7entation monitored by Project

' ', Manager. Design analysis was aucited bj Bechtel in

~'

September,1981 (Report 1.10.1), re-audited ard found -

acceptable.

GPA #11 - Multiple Proble 1s with Concrete Anchor:

Lleiding after anchor installation, base ciate becring surface, anchor pull out, improper installation, etc.

Resacnse:

Sentry's welder and OC personnel recert that no wcids have been nade to torqued plates on the wail. Base plate bearing inspection criteria was incnrporated in IP-8, Rev. 12 on I 4/29/81, via PED CS-183 5 1 all SC I hangers have beer.

inspected to this criteric.

s All SC I hangers were ir.s'alled or reverified in accordance with PED's C5-033, 037, 0a1, 043, 053, 055, 059, C61, 063, 064, 081,113,127,135,139,141, ISS.196, 204, 205; PMI 5-13; and Concrete Anchor Inspection Checklist ( Attachment C) which address the multiple problems.

' Page 5 of 10 Date 6/2/22 L C0!! TRACT 217 REVERIFICATION REPORT - PECHANICAL i

GPA #13 - Welds Not Per Drawing i

i Response:

i Weld detaih are calculated by Sentry and reviewed and approved by B&R. Welds are insr:ected to controlled cooy of approved detail, Engineering approvea red line or are considered nonconforming per Sentry apprcved procedures.

These procedures were in effect during all SC I original installation and reverification.

GPA 415 - Torque ftultipliers h

Response

Sentry did not use toraue wrench extensions until after it was approved in Rev.13 of IP-8. No torque multipliers were used on hangers subject to reverificatien.

GPA 418 - Inadaouate Record Review

, e Response:

Sentry began turnovar review in Novenber,1981, tc QAP-100, Rev. 3 and IP-20, Rev. O Work Packages. The Work Package Index specifies and documents required records. Records are

^

reviewed to checklists (Attachment D). All personnel ]i reviewing records have been trained in above procedures and have been given instruction usinc checklists.

Reverificaticn records have been reviewed es acave.

SPA +22 - Frequer.cf ci Calibration cf Tceq;e Ursn: hts and Cut of

2. 123 Calibration Evaluation.

Response

Fig.1 of QAP-700 specifies the frequency of calibration

! (6 months for torcue wrenches; decreased to 2 months by QA fianager (oat in January,1982) and requires a documented evaluation (Para. 3.10) for tools found out of calibration.

This procedure was in effect since May,1981. All anchoe:;

installed prior co l'.ay,1981, were reinspected and retcrqued to the latest approved procedure.

r Page 6 of10 Date 6/2/82 i [h CONTRACT 217

! REVERIFICATION REPORT - MECHANICAL 1

4) fQ Um)K-AlJve wyN94 ,

j GPA #2a - Personnel Qualification Respense:

i Sentry QA and :ngineering personnel have teen evaluated to QAP-900, Rev.1 (4/29/82) unich imposes Owners

e. l. , evaluation criteria from PED 217-B-095.

i QA personnel have the minimum experience as determined by the CA Manager based on treir experience with Sentry, Bechtel and Burns and Roe.

jj GPA #32 - Receiving Inspection Checklists

Response

Per 0AP-300, Sentry used a Receiving Inspectico Checklist (Form QAF-2) and Special Inspecticn Instructions to perform receiving inspe: tion. A Quality Engineer reviews physical,

~

test and other vendor records and when complete, returns I, ... them to Qual'ty Control for closecut of the checklist.

v GPA #33 - Weld Documentation fI

\

Response

No welding was involved in installation of piping and fire 2xtinguisher hangers. No ASME pressure boundaries are included in the contract. Several problems were detected with electrical weld records and welds in March of 1931.

QC I and QC II, SC I welds and weld re:Ords v:ere reinscected and reviewed. Nonconforming welds and records were dccumented and dispositioned completa on four NCR's.

GPA #34 - Voided NCR's and CAR's

Response

Per Paragraph 4.1 of QAP-200 and 4.2 of 0AP-800, CAR's and NCR's cannot be voided without justification and QAM/Bechtel apprcval.

4 This system was in effect during installation.of reverification hardware. The QA Manager knows of no incidence where NCR's

< or CAR's were voided without Supply System or Bechtel approval.

[i j GPA #35 - Cold Spring 'Aelded Flanges 1

-- Response:

( Sentry has not used welded fittings to date. Weld Procedures specify allowable fit-up gap, mismatch, and alignment.

Page 7 of W Date 6/2/82 i(G '

' CONTRACT 217 REVERIFICATION REPORT - MECHANICAL

4) -

GPA #37 - Licensee Applicatio n of QA to Seismic Category I Items

Response

Sentry has complied with the contract and addressed these issues in responses to PED 217-B-0185.

GPA #38 - Subcontractor Design Control

Response

g Electrical subcontract design was pre-approved and furn-t ished by B&R. Subcontractor maintains document centrol, nonconfonunce control, records and as-built controls via approved peccedures.

GPA #39 - Temporary Installations Response: .

.- Sentry does maintair a centr)lled method for temporary

'( installation (Form 022 and cap-201) whicn requires

\ __. - verification of removal pric e to Work Package closecut.

GPA #50 - Cleanliness A Resporse:

Sentry requires pipe and fitting to be received clean and maintained clear ner 0;;-300, ?eceiving Inspecticn and IP-21, G esnliness. In-::rocess surv=il;ance and final ir.s::ecticns (Fem 033, Hanger /Dipe Inspection Checklist) require

. maintainance of cleanliness including caps and no unattended Open p1De.

5; SANPLING 1

. Based on walkdown and review of 49 fir a extinguisher brackets, 43

, Diesel Generator (DG) supports and 115 electrical support welds

'; designated for reverification,100t reinspection was perfomed.

1

l ' Sample review was requested and granted per Attachment A.3 to sample 3 10f. of records for DG supports.

Extinguisher bracket record; were 100~, reviewed. Electrical support record review is reported in Section 3 of the Electrical Reverification

, of this report.

\

Hom SEC. 5 of ZI] flfP M Page 4 5

(4)

~GENERFCTPROBLEMAREA$E[

Per Bechtel letter number BECMCL-81-0301, the following is a list of " Generic Problem Areas" assigned to Contract 217 and the applicable . s k3pff.jg pro- .

cedures that cover these areas:

GPA PROCEDURE CHECKLIST COMMENTS 1 CP-15 Attachment 1, 2 and 3 CP-20 None Checklists of CP-15 apply 3 Piping does not apply Weld penetrant testing does not apply

[ 4 6 CP-15 Attachment 2 SC-I hanger detail designs supplied by Burns and Rce 7 Post weld heat treat does not apply i

1 8 Skewed joint does not apply 10 Pipe grinding does not apply i 11 CP-15 Attachment 1 y and 3 CP-ZO None Checklists on CP-15 apply i 13 SC-! hancer design supplied by Burns l and Rce - does not a: ply 16 'CP-204 Aopendix "A",

Attachment "A" 18 AP-101 Enclosure 1 21 u. .6 All cable pulling done by hand y

22 CP-204 Appendix "A",

l Attachment "A" 23 CP-204 Within procedure itself j

i 24 QCP-605 Attachment

1, 2 and 3 i

i- 28 Pipe does not apply W-0 -- . .. _ _

4 Page 5 i

4 . "' h M.ih 1 J KW / M UNttbni GPA PROCEDURE CHECKLIST COMMENTS 32 CP-201 Attach:nent 1, 33 IP-ll Weld Record Form 025 34 QCP-601 Procedure dces not allow voiding 35 Pipe dces not aopiy 37 All All All SC-I, OC-II installations are covered oy Lord Ele;;ric precedures 33 Ouality Class I does not a ply 39 All installations attached in approved Owner designed athod 41 Pipe spool does not apply

( 47 Our conduit is not identified in field and does not apply 50 PMI-5-2 All Lord Electric work is QC-II

OWN WM Llb(CEVOLT (Vol. E %4 t o om)

/

P3ge l.e O f 19

.I J

l 1-i.1 l i-I' WE'7NEWAreatI w_ -

J A list of Generic Problem Areas (GPAs) was sent to F/L on 12-11-81. The Table of Contents and tne Contractor Assignment 3hset from the list of GP3.s it included in Attachme.it 3 to Part 1. The complete list of GPAs is included 'n the Becntcl Systems Com;:letion Report.

I

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j F/L pr0 Viced 3 'esporse tG the "iPAi whir _n is 3;G0 included as Attachren' S to Part I. The SPG performed a tnorough ravi'ew o' the contractor's res:Snse and -

Orcced':res t0 assur+ i' the ccncerns r3: sed by tne iist cf SPAS ..are adect.ately n.s c i ve d.

k_

b-C51 C51

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l.

, . ~

z.

i I

5.0 -.M. _. M_.__ M._ ,

. F/L has reviewed the Generic Prob;em Area List provided by the Bechtel Reverification Grouo. A response t,hich resolves each GPA applicable to F/L was ;rtiided on 'ette. Fi.5E:-213-F-dE-3385.

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I

.- A)34 a es I - 7 Cl"C. O f_ A77AcuMENT 8 - N

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Paga 8 of 15

.. Gencrit hm blem $r203 (GPA)

Lis t.

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FISCHBACH/ LORD ELECTRIC COMPANY A JolNT V ENTURE ll \-

j

• P.O. 80X 771/ P!CHLANo. WASHINGTON 9935:

PPoNE 509/377 2751 WA Uc. No. Pl.00-PL-E19 cod

SUBJECT:

W. O. 2808 WPPSS Nuclear Project No. 2 Contract 218 M:FrobTemii ArnRT d?fhil

%4s.bmn= wm n=1 ce.t.swo A Vg \W*

, Fd = ry 3, ' 0 J FLBEC-218-F-82-3385

%)-____ .

Site Construction Manager Secatel Power Corporation P. O. Box 600 Ricnland, Wasnington 993E2

, REFERE! ICE: BECMCL-31-0301 i

l Gentlemen, We have enciesed our responses to the GPA's as required by the .

\ referenced letter.

The responses have been reviewed with Mr. Nel Leach of the Bechtel Reverification Grcup .ed his ::=.e 1 and reco.sendaticr.s have been in-Corporated.

l If you have any questions please contact Mr. Roger Erickson of

[ Fischbach/ Lord Electric.

Very truly ours, hW l

j C. J. knam Pmje Manager CJP: E: pja Q i CC: J. J. Verderber, ElR, Inc., w/o ggg N A. I. Cygelman, B&R, Inc. , w/o

• J. A. Formst, B&R, Inc. , w/o g COF,POR ,ggy,

- i Chin, BFA, ./o gggFt.\. i grj31 rf/RHE/ LOP l

{ . .

I

ATTACHMENT S

, Pece 9 cf 15

,.- -- j-

2 GCA ri Prior to the restart program Fischbach/ Lord hao not corrinenced the fir.31 i inspection and acceptance of the installed raceway and equipment supports.

Subsequent to the release for restart Fischbach/Lerd began the firal in-spection and acceptance of tray and conduit supcorts. As Fischbach/ Lord had

?

not began this final prc5 ram pricr te restar: this activity was not revievied under the reverificaticn program.

GPA #2 cischbacn/ Lord has no apolicatior, of tnis type of wtri within their present centract secpe.

GPA #3 fischoacr./Lc-d has nc applicatien of inis tyce cf work witnin their present centract scoce.

GFA 54 F'schbach/Lorc has nc ap3'icatien of this type cf work within their

'( .

present contract scope.

GPA 55

! Cischbach/Lcrd has rc 2:siication of this type of work within their cresent centract sccce.

1F ** = 5 Fiscncach/ Lord received direction v'a a PED to modify the ccnduit clamaing methods in Februa y 1980, Fischbach/Lerd implemented a chance to CP/0AF 402 "Electricai Raceway Installation and Inspection." T' procedure change iodified new instaliation activities.

Subsequent direction was received by PED's which required a procedure o be issued, requiring reworn on ccnduit saaport and ciamping devices.

h >

The rework / replace. ment procedure R'iP-6 was issued in July 1951. This

. rework /reolacement procedure applied to all Seismic Class I conduit supcorts and tray supports with conduit attacnments.

With this program being initiated after the Fischbach/ Lord release for j,

8 ,

Restart the reverification crogram dces not acply.

dije I Cf 7

ATTACHMENT 8 Page 10 of 15

• YMk

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GPA #7 ii Fischbach/ Lord has no application of this type of work within their *

[:

i-present contract scope.

GPA #8 i.

j This GPA was nct addressed under the Reverificatica Program as final

! inspection and acceptance of the Fisenbach/Lerd welding did not cemence until after the 215 Restart Release. However as requested by BRFL-218-F

! 82-0490 a review of oractices in design, fabrication and inspection of skewed welds was conducted and documented on lecter FLBEC-218-F-82-3138.

GPA #9 Fischbach/Lced has no apolication of this type of work within their present contract scoce.

GPA #10 Fischbach/Lorc has no application cf this type of work within their

, , , present contract scope.

(!.

GPA #11 .

f Fischbach/ Lord initated a concrete anchor reinspection program as directed by various PED's in February 1980. An additional prograa for the Evaluation, p )

Acceptance and Pework of Supcort Baseplates was i.molemented in March 1981.

Tnese twc progra .s are RdP and RWP 5 respectively. 'dith the reir.spection of these items, they are categcri:ed as scecial tasks :nat required 100% accentance of eacn c'. ass I anchor and were excluded frcn ne reverification crceram.

New installaticns a':er restart are performed, inspected and documented per CP/QAP 505.

j GPA #12 Fischbach/ Lord has no application cf this type of work within their

( preser.: cor. tract sccoe. ,

GPA si3 i

This GPA was not addressed during reverification. Support design eval-uation program was implecented after July of 1930.

1 GPA *14 3

! Fischbach/Lcrd has no 2colication cf :nis type of work within their 6

( present contract scope.

l Fage 2 of '?

f u

k.

ATTACEMENT 8 Fcge 11 of 15 f

3rnmtaticir s GPA #15 i -.

This GPA relates to CP/QAP 404 and CF 412 which were covered under the .

reve-ification pregra?. These procedures were also reviewed during the re-

+

start program. Also, Findings under the reverification program have been

. documented on tne appropriate Fischbach/ Lord inspection documents.

GPA #16 During the reverification prograT the activities which required tool j

calibration were reviewed against CP/0AP 801, " Calibration and Certification 3 of tools, ins:ection, and test equiccent."

1 I

GPA #17 i

Fischbacn/ Lord has no application of this ty;e of work within their present contract scop 3.

GPA !!8 A complete review to the present program recuirements was made of the 10%

,, reverification installation document sample.

( '

This GDA was not addresse: in the reverif t:ation program as final document turnover by Fischbach/ Lord, had not commenced prict to the issuance of Stop Work Order #9 dated July 1930.

GPA =19 Caring tne reve-ifi:atier pecarar, the activit i es am.ich recuired toci cal-bration were rev'evec 2;2 n:: C: :4: :T. , "C1't:rati:n and Cer;ificati:n cf t:ois ,

ir.soecti:, an: ts:t e:ui ment."

l Findings uncer t*.e rever'fication arogram have been documented on the appro-priated Fischcach, Lcrd inspection decar.onts.

l l GPA v20 The installation ard inspecti:n activities discussed in this GPA were ad-dressed under the P.everification Pre; ram with the review of CP/QAP 40E "Elec-trical Raceway Installation and Inspection.' Raceway Release Only.

U. .

1- Findings under the reverification program have been documented as recuired.

il A 100% reinscection of tray splice ciates was performed after restart per CAR

. ,! . Corrective Aetfqn Cornit?ents. (f2? 431' 5

ge 2 of -

I

ATTACHMENT 3 Page 12 of 15 l(

y.

GPA #21

,1 The cable pulling pro:edure was reviewed by the Restart Program. CP/

QAP 404 and its attachments was addressed by the Reverification program. >

Ali findings under the reverification program have been decurented as required.

GPA #22 Fischbach/ Lord hat r.c aopli:ation of tais type of work within their present contra:t scope.

. GPA #23 During the reverification program, the activities which required tool caliarat'en were reviewed agai.1st CP/0AD 3'Ji, ' Calibration Certification of tools , inspecticn ar.d test equ.pment."

Findings under the reterificaticn prcgram have been documer.ted on the appropriate Fiscabacn/ Lord inspection documents.

~

c i GPA *24 This GPA was not reviewed during reverification program but ir.ternal 4 Fischbach/ Lord program is included in the Fischbach/ Lord Company Suoervisors j Personnel Handoock.

GPA 725 i

l Fisentacnitor: r.as no acci::a-icr- of r.is :y;e of wo-i wi:nin :neir

resen: ::ntra:t s:::e.

GPA #26 Fischbach/ Lord has no application of tnis type of work within their present contract sc00e.

GTA #27 Fischbach/ Lord has no application of tnis type of work within their present ccn ract sco;e.

_, GPA #23 1*

Fischbach/ Lord has nc acriication of tnis tvae of work within their 4 - rasent centract secpe.

I

s. _ .

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Page 4 cf F

ATTACHMENT 8

, Page 13 of 15 .

[Y

[' .. . -

, GPA #29

.j .

.; Fischbach/ Lord has not application of this type of work within theic

! present contract scope.

i GPA r30 4

4 Fischbach/ Lord has no apolication of this type of work within their i present contract sccpe.

GPA #31

]

i Fischbach/ Lord has no application of this type of work within their

present contract scope.

1 l  !

GFA !32 This is an isolated case anc the Restart Progran reviewed the applicable Fisch:ach/ Lord receiving prc. edures.

Fischbach/ Lord has ccmpleted a review crogram (CAR 36) which reviewed re-ceiving documents for those items which Fischtach/ Lord was respcnsible for the procurement activities.

( ..

GPA =33 This GPA was not Eddressed under the Reverification Progran as final in-sce: tion and acceotance of the Fischtacn/Lerd welding did not comence until after the 218 Restart Release.

2M G The Reverification Program covereo the arsa of concern in this GPA. The Raverifica: ion Program did address QAP c01.

', Findings under the Reverification PFogram have been documented as required.

l All voided NCR's ard CAR's are sent to tr.e Owner.

u GPA =35 Fischbacn/ Lord has no application of this tyoe of work within their present

contract scope.

1 i GPA #36 Fischbach/ Lord has no application of this ty:e of werk within their present centract scope.

. ._. / GF =37 Fischbacr/Lerd's current procedures recui e the same inspecticns for Quality C' ass II Seismic Category I as Quality Class ! Seismic Category I.

Page 5 of 7 r .

ATTACHMENT 8 Page 14 of 15 4,+.

)

k

_- N GPA #37 Continued i

!! With this requirement in the Fischbach/ Lord procedures the programs -

ii reviewed under the reverification plan did enco::: pass a review of the type

'2

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of installations. All procedures used during reverification were applicable to this GPA.

GPA #38 i

Fischbach/ Lord has no application of this type of work within their

, present contract scope.

GPA (39 This GPA was not addressed under the Reverification Program. In the opinion of Fischbach/ Lord our internal procedures and inspections prevent this type of activity from taking place.

GPA 540 i; Fischbacn/ Lord as cc applicaticn of thi tyce of work within their present contract scoce.

t ,

i GPA 441 u

l* Fischbach/ Lord has no application of this type cf work within their present contract scoce.

• 1?A # 2 Fisch::acr lord 'as n: 1.?olication of P'is tyce cf w:rk within tr.eir pre:ent contrac: sco:e.

GPA =43 m

I Ine Reverification Progran examined the applicable installation pro-cedures for conduit installation, cable pull and cable terminaticn. These or:cedures reflect the requirements of tr.e 218 specification.

Any findings discovered during the Reverifiution Progra:n have been appropriately documented.

GPA #44 Fischbach/ Lord has no acplication of this type of work within their present contract scoce.

Page 6 of 7

ATTACHMENT C Paga 15 cf 15 ,

.i (6,e i

i GPA #45 Fischbach/ Lord has no ap:lication of this tyce of work within their ji 14 present contract scope.

1 G?A #46 l-

['i The Reverification Program examined the a plicable installation pro-cedures for conocit irstallstion, cable pull and cable termination. These

{f procedures reflect the requirements of the 218 specificatf or.

1s' Any findings discoverad during the Reverification Program have been i aooropriately documented.

GPA 447 2rgineering direction a 31icabla to this GPA w:: received and imple:ented

, su: sequent tc the restart pre ram.

.. GPA #48 1.

4 -

Fischba:n/ Lord has no app'ication of this tyse cf work within their L

( present contract scors.

GPA #49 Fischbach/ Lord has c.o ar?lication of this tyce of work within their '

present c:n:ract secpe.

IP2 =50 l 21E d:es n : nave re;u're,. ants :a . main::in system cleanliness as de:cribed in this GPA. Fis:htach/L rd does nave a :r:gran f r cleanliness

!c of eie:trical installations cnd is cerf:rmed du. ing the mainter.ance pro-gran CPf0AP 20S.

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dt g-I Page 7 of 7 f.

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6)(QW$ @24Mi $ O U UVQ(W

[ VOI s $ r%Y I5 Yp 5 og g U ..

i i

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.. s4CJ. , W' C A list of Generic Problem Areas (GPAs) was sent to JCI on Cecember 11, 1981.

The Table of Contents and the Contractor Assignment Sneet from the list of GPAs is included in JCI's report in Attachment 9 to Part II. The complete list of GPAs is included in the Bechtel Systema Completion Report. #

' JCI provided a response to tne GPAs which is incluaed in JCI's report in i!

Attachment a to Part II. The BRG perfer: ed a thorougn review of the contrac-tor's resper.se and procedures ta determine if tne ;oncerns raised by the li:t of GPAs were adequnely resclved. This review indicated initially that all the GPAs were adequately resolved with the exception of GPAs 16, 22, and 23 which relate to calibration of torque wrenches. A letter to this effect was sent to JCI and is included as Page 9 of Appendix B. Following discussions with JCI and a review cf Revisicn 0 of Procedure QAS-1304-H2, Torque Wrench Comparison Procedure, the BRG is now satisfied all the GPAs are adequately resolved.

t

p . \KWS Wuc2 car DT 4 ;ct J3

• P.O Boa .:20

, / R :m:and. WA '9352 Te: 509'377 11::1 J DH%3 C*27205 ,

Te.e::;ner 505/377 2770 g t

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[-(hV s

JCIS K-220-81-492 l

K]

' \ December 21, 1981 MON _

. S -

i Systems Engineering & COnStruCliOn Mr. Strat Pohtos, Site Construction Hgr OjdSiGn Bechtel Poe.r Corporation i: '

P.O. Bcx 600 .

Richland, E 99352

Subject:

QualIN* M M Y Y M ]

Peferences: BKJCI-220 0208 JOIBEC-220-81-281 BKJCI-220-31-0365 BrJCI-220-81-0378 QVI-01 .. . _ .

.- t'y l Dear Mr. Pchtoss

Intro duction It is the intent of Johnscn Controls, I c.., to supply the coner and its representatives the inspections and information required to properly meet the conmitrents of the*" Reverification Prtgram" (CVI-01) . As (s _

previcusly discussed in ssveral meetings with reverification perscnn'al and noted in referenced correspondence, Cohnson Contuls, Inc., has ,

an approved program that should satisf,f all regairements necessarf to l occplete this activity.

! Acerc ved Fro: ram

- . cur original lettar of n0ritW_ (JC'J:EC 22-SI-251, dated Septe ber 21, 1981), there we e a ncher cf cuestions generated and ansoers requestei perJCI-22C-Sl-0365) . A reeting wis held and all questicns satisfactorily ansered. It es agreed that Johnson Controls, Inc., in the subnittal,

(

had failed to supply several checklists used in its verification prcgram.

n ese checklists answered nearly all questions that had beenigenerated.

It was also agreed that a few items needed to be added to the " System Walde n Checklist", this infonration is nos incorporated. A revised Final Decrentation I: struction and all checklists used in our verification prcgram (Attaci:.nents I thru X ) are being supplied with this letter for your information and records.

It should be noted that .Tohnson Centrols, Inc., is performing a 1004 verification of all work performed in ccr:pliance with the referenced .

approved program. Agreement has been reached with verification personnel i cn hoa this contract is to report its verification - reverification pro-gress. De foun titled " Reverification Prcgress Repert" has been developed and will be used to report on a rack basis as required.

~

r I

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. - , , -,---,,-.r. -m,,-,,,n-n.

Johnson Contrcis, Inc. -

JCIES:'-220-81-492 Deccrbar 21,19C1 - .

W ,,

Page 2 ,

Johnsen Controls, Inc., is to reprt when they sttrt fermal verification walk-

dcw.s as referenced in CAS-603-H2 and re;

ort agt.in when wahn is cceplete.

j .

A final reprt is to.be suomitted when all R.P-2 work is ccmpleted. ,

,j It should be noted that all reverificatien is carpleted using the criteria 1

j specified cn released for construction fabrication drawings and latest approved

procecures. _ . . . _ _ _

i! The owner has identified a list of fifty (50) items, found to be problems,

! encountered at WP-2. Not all items identified pertain to the 220 contract and ij have been so noted. Follcwing is our req:ence to this list, by number, review-1 ing applicability and status of those itc:rs believed to affect this contract:

! 1. M11tiple Problems with Hanger Installation, Inspections, and Documen . ..

tation - In Octcber,1980, Johnscn Controls, Inc. , established the criteria Yor cceplete reinspection of all SI supprts. This program was conducted until it was satisfactorily desenstra+ad that this was not a concern. This information was delivered tc the cwner (Car No, i '

8) and the program te=ninated. It should be noted, hcmever, that all f ,

,... supprts will be reverified again under the approved prcgram.

t .

%,. 2. N/A.

, 3. Stress Risers at Pipe to Valve Weld::ents - Johnson controls, Inc., weld

?' all fittings with scx-ket weld attac.$nents, the only way to get a riser is fer under cut to exist. All inspecticn perscnnel are trained to procedure CAS-1101-H2 v.hich re:;pires inspection for this ccndition.

5/A to C-220.

1

4. Q.A. Inspector missed final mid visual e:ca . .. results - Ons is a 215 procedure proble:t rcc ger.eric to cite centractcrn. Jchnson Centrols, Inc., will review under reverificaticn program all weld dcc.: mentation to assure its accuracy end cortpleteness.

5. N/A.

C. Miscellaneous problems with tubing clangs - Under approved prcgram s all clangs are verified to assure prcper installation as specified

( on installation drawines.

. 7. Post weld heat treatrent g -Phre qualificaticn - Johnson Controls,

! Inc., has no requirement to post weld heat treat its pipe welds. 'Ihis t' item is, therefore, N/A to C-220.

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Johnson Centrc:s, Inc.

JCIB I-220-81-492 Decenter 21, 1981 ,

f C. Page 3

3. Inspector accepted an undersize fillet weld on skewed joint - Sare as

.. Itam 1. Criteria for skewed joints is covered by thic prcgram.

2

9. N/A.

l' 10. Grinding cc Pipe Walls without wall thickness verification - Uchnson Controls, Inc., unlike many contractors uses flapper wheels for weld ~

, preparation to eliminate the possibility of excessive grinding. .krj i -

questionable areas in pipe repair have been reviewed, calculated or .-

i rencved by C-220 on all its installation.

5-

11. Anchor Bolt installation '"his problem can be divided into two categories, shell' installation and thread engagement.

? 3ased on the criteria established by PED-220-CS-0247, incorporated into ywc.idure SP-2004-H2, Johnson Controls, Inc., developed, a,reinspecticn program stere all past installations of shells were reinspx: red and reports generated docu: renting proper installation. All installations are tcday properly installed and documented.

I ':hread engagenent inspection criteria was also added to SP-2004-E2 and a program developed to reinspect. Under the initial reverificatien of i these bolts it was determined, two specail conditions existed that ray 4, ~ be of concern. 'Ihese conditions are addressed and inspected under the approved revarification program. ,

12. Heat Number missing frtru pipe spool - This is not of concern to C-220 it addresses a prcblem with C-215 procedure cnly. ASME code reg 2 ires raterial be traced to pcint of firal installation cnly. All ratarial

> is verified befcre welds are started and material refe enced on weld data sheets. Cent.rol ci rat?.-ial is covered by pr cedures SP-2005-H2, C.S.3-1101-H2 and CAS-902-H2. All raterials are verified, hcraever, e.de.r approved verification program.

13. Calculations not supplied to support redesigned supports - Jchnson Controls, Inc., has inplenented training and other programs which define, conditions requiring owner appro rJ.. Drawings and cal-culations are approved prior to installation.

14. N/A. - .

4 15. N/A.

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J0hnson Controis,Inc.

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JOIsm-220-81-492 Deceter 21, 1981

< .I

i. Page 4

16. Control and calibration cf trquing mois - Johnscn Centrols, Inc.,

has approved procedures and controls all calibrated tools and instrurents.

4 i

. 17. N/A.

18. Inadequate procedures / checklists prior *w turnover - Johnson Controls, Inc., has an approved prograr. and procedures which are being used for __ _

this purpose. No tuInover of Q.I. iters has been c npleted to date.

All turnover packages will, therefore, fall under an approved program.-

' his finding N/A 'a C-220.

, 19. N/A.

20. N/A.

21. N/A. _ _ _ _ _ _ _ ,

22. Procedurds did not address frecuenc-f calibratica - Sa.e as Iter.16.

I

23. Instr rnents out of calibration - See Item 16. Not applicible to this contract.

( 24. Personnel Oaalifications - All personnel connected with installation or inspections have had qualifications reviewed. Any wrk p:rferred r by individuals with suspect qualifications bas been reinspected and f recoved or rewrked as required. 'Ihis was an action required prior -

1 to restart for this contract.

25. N/A.

26. N/A.

27. N/A.

28. Unexplained presence of an installed pipe srcol rarked scrap - Jchnson Centrols, Inc. , does not install large tore pipe or individual " spool" pieces. 'Ihis condition would be noted on walkdown.

29. N/A.

30. N/A.

31. Arc strikes on pipewrk - Johnson Controls, Inc.,. has included this ander the daruge section of the checklist used for field walkdowns.

If this ccndition is cbserved it is repaired or cut out as required.

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Johnson Controls, Inc. I JCIE!r-220-81-492 teceser 21, 1981 .

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. Page 5 '

32. . Incomplete receiving and inspection reports - All receiving and inspection reports are verified under the approved program. Receiviryg -

.- and inspection are covered by procedure CAS-802-H2.

[' 33. MiWlaneous problems with weld documentation and inspecticn - All

}'

wel.d documentation is reviewed and reverified under approved program.

lf the specific finding on shear lug welds identified in GPA-33 is no i- longer valid, the code Johnson Centrols, Inc., works to has been l changed to the 1980 addenda which allows fillet welds.

34. - NCR's and CAR's voided by Q.A. Manager - Johnson Controls, Inc., to

[ ' _' the best of its knowledge has never experienced this problic. Docu-4; mentation is reviewed prior to final turnover..

35. Misaligned Pipe Flanges - Under the approved program, all installations

.' are walked down to assure proper installation, of all. items including pipe flanges.

. 36. N/A.

37. Cuality Assurance regaireitents applied to SI-QII items - This appears a c. .

to be an owner problem. Johnson Controls, Inc., houver, has approved

[ procedures that cove,r the installatica and inspection of supports (SP-2004-H2) that have been designed to SI requirements. Tasse install-ations and associated d e ntations are also covered and reverified

. under approved pf. 4.  ;

f~ 38. N/A.

39. Temporary insta11atiens ateve safety related iters - Jchnso. Cent:cis, Inc., will wrk wich tne accrs const;xcrien m nager to a:sure total rencval of ter ;nrary items prier to leaving the site.

40. Installatica Process Instru: Tent Tiibing - All installations are verified

[

)

100% for prcper installation under tne approved progran and the check-

' list t.esd covers all items found in past to be of concarn.

p 41. Pipe Spool Surface Defc:ts - Johnson Ccntrols, Inc., does not deal with large pipe spool pieces. This is a specific problem not generic.

} All raterial received by C-220 is inspected under procedure C.tS-802-H2.

All installations are also reverified for surface damage under approved 4 program.

J

- 42.~N/A.

43. N/A. 3

44. N/A.

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45. N/A.

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4-Jchnsen Controls, Inc. .

JCIBT-220-81-492 l December 21, 1981

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46. N/A.

47. N/A. .

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48. N/A.

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l 49. N/A. -

50. Failure to maintain system cleanliness - All construction and inspection personnel are trained to maintain a c:nstant curveillance of work in a progress to assure installaticas are being properly maintained.

Johnsen Controls, Inc. , feels that all problems, applicable to its contract, are' properly addressed through existing programs and procedures. We believe that with the infornation supplied by this and earlier conespondence, Johnson Controls, '

Inc., has develcped acomplete prcgram satisfying the needs of the "Feverification Pr. gram". We w-ili continue to ir:plemnt and repcrt on this program as approved to rneet not only cur cemit:nents but .the owners as well.

If there are any further questiens, please feel free to contact this office.

Sincerely, .

.  ; ca- an=S, 23C.

p fa WED i }

! W. E. Dunn Project Manager I

MED/EM/ /1as cc: Site Files (SF) - 2 copies NNP-2 Files - 1 ccpy BPA (W. S. Chinn) - 1 copy H. L. bk: Call - BPC

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APPE!: DIX 3 Pac. e 9 o f 13 Bechtel Power Corporation h pee 9 S-con 5!rbCf 0f 5 I~

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WNP 2 P O Son 600 cater seroce A'ch and WA 993$2 January 25, 1982

~ ~ ~ '

Johnson Controls, Inc.

P.O. Box 429 I

Richland, WA 99352 3

Attention: Mr. W. E. Dunn 1

Subject:

SUPPLY SYSTEM NUCLEAR PROJECT ?!0. 2 CONTRACT 2808-220 JOHNSON CONTROLS REVERIFICATION PROGRAM e

I

Reference:

JCIBEC-220-81-492 Gentlemen:

The attached plan / procedure entitled " Quality Reverification Program," Rev. O, has been reviewed by Bechtel and is hereby approved by the Bechtel Reverifica-tien Group.

Future revisiens to any of the procedures or checklists used in lhe rcverifi-l, c' cation program shall be approved by.the Bechtel Reverification Group.

s I

- The responses to the _ Gene 6r,;PechiEA'ia'AI are considered adecuate except for items 16, 22, and 24. Tour nnal report shall explain the rationale for deter-r.ining Johnson Controls has not had any problems with the calibration of torque wrenches.

If you have any cuestions regarding this r.a:ter, please contact Robcy Gaines or "el Leacn, Bechtel Reverificaticn Grcup, extension 4585.

"ours tr:1y,

!! O G% G #p S. Pontos Construction Manager SP/r<yGfQ

• ttacnment cc: 901A R. Knawa ,

I 917Y EDC UNP-2 Files w/a 954W A.I. Cygelman (2) w/la bec:

917B W.S. Chin, BPA w/a J. Croall w/o T. Logan w/o Resconse Required: Yes  ?;c X T. Mangelsdcrf w/r R. Clayton w/a 1

I T. R:berts w/o H. McCall w/o C. Seards ey w/o E. Steiner w/c C. Feil w/o D. Johnscn w/o BCF w/a I

6XkW FPAM %%Q fSf0LT

['/c .g[ Soo c. I4 o e ) +)

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RICH 081.Dtj AREAS g

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A list of Generic Problem Areas (GPAs) was sent to Cannon on Decerter l'.,1981.

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Tne Table of Contents and the Contractor Assigr. ment Sheet frcm the list of GPAs 3

are included as Attachment 3 to Parr !. Tne ccv.ilt.te list of GPA:, is it. cia:ad --

in t.,e 3echtel Systems Ccmplet7en Rc;: art.

G an provided a response to the GPAs which is 19:luded in its report. The i

BHG aerforme.1 a tnorough re/iew of the centractor's peccedures to cetermin2 if the procedures adequately resolved the concerns raised by the list of GPAs.

This review revealed that all GPAs were apprapriately coverec in the proca-dures, which met the requirements for reverification reinspections.

}

W 053 L

Page 2 Of 4

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. 71ve generic problem arens were identified as having bearing on Con-tract 234 activities. These were:

2 GPA PROCEDURE IS QCP-17 32 QCP-7 s.

24 QCP-21 31 OCF-15 & 16 39 N/A t

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' i.h El{ B . C A *. N O N r, S O 'J f .*, r' ,

Fev. !

, O. B. Cannon's corresponding precciurcs h.:.c been reviewed and approved by Bechtel QC and QA, and the Supply Syrtem. It was determined that

, the precedures fulfilled all requirements set forth by the GPAs. GPA 39 deals with temnerary installation of itens on or near permanent

, safety re*ated items. There have been no temporary attachments made to permanent plant equipment by O. 3. Canncn: :herefore, it does not cdnstiture a cencarn.

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