ML20081G759
| ML20081G759 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/15/1983 |
| From: | Millett J REACTOR CONTROLS, INC. |
| To: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20081G748 | List: |
| References | |
| NUDOCS 8311070174 | |
| Download: ML20081G759 (11) | |
Text
__ __
1 Enclocure 2 Reactor Controls, Inc.
R September 15, 1983 1
United States Nuclear Regulatory Comission Office of Inspection & Enforcement 4330 EastWest Highway, Room 305 i
Bethesda, MD 20014 Attention:
Mr. Edward L. Jordan Director
Subject:
Your letter dated Aug$st 8,1983 and
" Draft of IN83-XX" Reactor Controls, Inc.
Construction Deficiencies Gentlemen:
We thank you for pennitting us an extension to the response date for your subject
. letter.
Reactor Controls is seriously concerned about a negative report and the subsequent effect that could result following the issue of your Draft Information Notice.
Reactor Controls.has always been recognized as a Quality contractor em-ploying competent people.
Therefore in the time available to us to prepare a response, it is our purpose herein to. offer sufficient infonnation to you to decide not to issue the draft notice.
If the information is not entirely sufficient, it is our hope to cause you to at least doubt your first conclusions and give us an opportunity to fur-ther demonstrate that Reactor Controls should not be singled out as a contractor with significant problems of construction deficiencies.
Because the projects niferred to were completed years ago, we have not yet had access to the indivi-duals and documents necessary to completely research thorough answers.
If after reading this letter you are still inclined to issue the notice, we request ad-ditional time to be able to obtain additional material with which to strengthen our case. We also request an opportunity to meet personally with you"for first' hand discussions.
We do not claim to have never made mistakes, but our QA Program has always been capable of finding and correcting them. W'e believe that the observations and findings referred in the draft notice deserve and require coglete input from Reactor Controls before being published. We sincerely hope that you agree with us. We submit' the following in response to each item identified in your draft noti ce.
0311070174 031025 PDR ADOCK 05000324 S
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September 15, 1983 US Nuclear Regulator;.
Commission Reactor Controls, Inc.
page 2 Response to Comments on Zimer Item 1 - Control Rod Drive Mechanism (CRDH) Work platform a, b, c & d.
At anytime during installation of the customer supplied equipment, of which this item is one example, when the work could not be completed 1
in accordance with drawings and/or specification requirements, the cus-tomer or his agent were contacted to provide resolution.
Any and all deviations were approved by the customer or his agent through issuance of a Field Deviation Disposition Request (FDDR).
Reactor Controls, Inc.
did not supply any material or items for this installation, and any-de.
viations from the AISC Manual or other specifications, were the respon sibility of the equipment designer.and supplier.
RCI did not~ provide any of the materials or items installed.
Everything was p'rovided to RCI by the ewner except welding materials, which RCI did provide.
A CCI can accept as fact that the items as reported during the recent examination may be true.
However we strongly point out that in the years since RCI left that jobsite a lot of disassembly, reassembly and modifications may have been performed.
Therefore to suggest that the present status b the work of RCI is presumptious.
t Coment:
At the time of installation, the CRD Work platform was considered
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temporary due to interferences preventing proper operation and future modification would be required to enable proper operation. RCI did the work in accordance with the customer instructions as the platform was necessary to perform other installation operations. The rework of the platform'was not performed by Reactor Controls, Inc. and possibly has been mworked since RCI left the jobsite.
Item 2 - CRDH Lateral Restraint Beam During installation of the beams, all bolts were tightened with wrenches at without reference to specific torquing valves.
RCI did not receive
. specific torque value: requirements for any bolting installations for the i
f period of time work was performed. Later, Sargent & Lundy Engineers did prepare and issue a torquing procedure titled Concrete Fastener Installa-tion Procedure (CFIP) but it was not issued to Reittor Controls, Inc.
It is likely, others have performed work in' thes6 areas since RCI left
- the site as it has been determined all bolts were tight when installat' ion
_ was complete.
b.' The use or 'non use of washers during installation cannot be determined l
' from inforniation available to RCI.. The dse.of comon machine bolts by-RCI is unlikely as RCI did not provide any equipment or material during
^ installation.
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l Comment:
Attached please find a copy of~arCG & E Field Work Order l
No. RCI-1 dated August 22, 1975.
This is typical of the manner in which
' RCI was directed to perfonn operations which did not initially meet f
drawing or specification requirements.
RCI does not have copies of tre FDDRs as CG & E issued Field Work. Orders to direct RCI performance of e
/
work outlined in the FDDRs.
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l September 15, 1983 US Nuclear Regulatory Comission Reactor Controls, Inc.
page 3 Item 3 - CRD Housing Support Assembly This assembly was installed as designed and supplied. Attached are pictures a.
of this type of assembly in the Hatch Nuclear power Plant which is identical A check of the G.E. Co. installation drawing revealed this is to Zimmer.
normal for this installation and the installation was in accordance with the drawing.
A check with the component designer, G.E. Co., indicated this is the actual design of the component.
i The b.
RCI had no responsibility for surface treatment of the components.
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supplier of the equipment provided the surface treatment.
i Keeping in mind RCI has been off site since 1979, the fact a fillet weld is c.
cracked at this time is not evidence it was cracked at time of installation or that inadequate techniques were enployed to perfom the welding.
Item 4 - Reactor Lower Head Insulation ~ Frame This work was not in the scope of the RCI contract as evidence by S & L Specification H-2832, page 1-9, paragraph 17.
Item 5 - Scram Discharge Volume Level Switch Supports The use of self drilling anchor bolts was common practice at the time of installation.
The system design specification was supplied by Sargent 0
& Lundy Engineers and it was not until issuance of IE Bulletin 79-02 that emphasis was given to anchor bolts. The action taken by S & L at -
that time was the issuance of CFIP (Concrete Fastener Installation Proce-dure) and it was issued to other contractors on the Zimer jobsite but was not included in the design specification for the RCI scope of work.
The use of threaded rod being substituted for bolting is not a normal l
RCI practice and was apparently performed without Site personnel knowledge.
The use of " hardware store" quality nuts & bolts is a condition we cannot comment on as we do not have knowledge of what that is or where the bolts-were used. The use of threaded rod for a U-bolt was an approved design condition indicated.on'the installation drawing.
l To conenent on weld rod being stuffed into a tubular support member would All filler material be presunptious to assune it was RCI filler material.
issued by RCI was documented out and in and a record of all transactions I
is on file.
The other items identified here may or may not have been performed by RCI during installation.
Again, keep in mind that RCI work has been modified by others since RCI left the site.
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Ssptember 15, 1983 US Nuclear Regulator.
Comiss1on Reactor Controls, Inc.
Page 4 Response to Comments on Brunswick, Grand Gulf & Pilorim Item 1 - Carolina Power & Light Company (LER 80-055)
Base plates and the anchors used for installation were installed in accor-RCI did dance with the design specification provided to RCI by CP & L.
not have design responsibility and the use of expansion anchors was an accepted practice at the time of installation.
Reactor Controls, Inc.
completed installation work at Brunswick in early 1975 and IE Bulletin j
79-02 was not issued until 1979. The use of the term " faulty installation techniques by RCI" has not been explained or compared to the standards in existance at the time of construction. The criterie for nuclear power plant construction has changed since 1975 and the reased size of base plates may be required now, whereas at the time of ' ;tallation the base plates met the design criteria.
Item' 2 & Item 4 - Mississippi Power & Light Company (PRD 80/56) and (PRD 82/13)
The implication in the report that' Reactor Controls, Inc. did not have a method for documenting, controlling and approving deviations from design drawings is inaccurate.
l The facts surrounding the events leading up to the status report issued on January 23, 1981 were as follows:
RCI work during the time period of January,1981 was incomplete in relation-ship to the supports being installed for the Control Rod Drive Hydraulic The client had determined that new design criteria were being System.
applied for the supports for the Control Rod Drive Hydraulic System and therefore the supports that were' already installed probably would not be adequate to support these new loads.
It was jointly decided by RCI & MP & L at this time, that RCI should complete the installation of the supports on a temporary basis in order that the pre-op testing of the Control Rod Drive Hydraulic System Piping and Components could be started by MP & L.
The pre-op testing could not be started'.if the supports were not installed for Therefore Reactor Controls did in fact install the supports the system.
in a temporary fashion and the installation of these supports was documented to assure all work would be identified.
During the installation there were incidences where material was substituted for that called out on the drawings due to information supplied by the personnel performing the analysis.
In some cases, the material was supplied to Reactor Controls, Inc. by Bechtel Corp., because they had the material on site and for Reactor Controls, Inc.
to purchase the material. in order to. complete the installation process at that time would have been time consuming and would have delayed the sche-duled completion of the supports.
It was with the knowledge of Bechtel and RCI that some of the support members were installed not in accordance with The the drawings because it was determined the installation was temporary.
temporary installation was recorded on marked up drawings & ECNs in the field and provided to RCI engineering for incorporation into the design When the re-drawings to be used for analysis of the permanent supports.
analysis was performed on the supports, the work was then restarted in ac-cordance with the new design drawings supplied to the field.
Where the supports installed were adequate for the new design loads, the information was recorded and the temporary installation was upgraded to a permanent installation and inspections were performed to ascertain that the installa-tion was in accordance with the drawings. During the time.of this installa-
September 15, 1983 US Nuclear. Regulatory Reactor Controls, Inc.
pjY" Item 2 & Item 4 (Con't) tion, in the period from mid 1981 thru mid 1982, the client had determined the plant's start-up date and Reactor Controls was informed that our work could not impact the scheduled operation of the plant.
It was during this time that Reactor Controls provided additional personnel and went to a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 day a week schedule to complete the installation of the supports for the Control Rod Drive Hydraulic System.
Due to the re-analysis being performed on each installation, many Engineering Change Notices were issued due to' interferences and/or evidence the initial' design was inadequate and changes had to be made. Even though this may have caused some confusion during the installation process, inspections were being performed as work was being completed. These inspections were termed initial inspections, and with the knowledge of all concerned Bechtel, MP & L and RCI, a final inspection would be undertaken prior to the final as-built drawings to assure that the system being turned over to the client would be per the drawings and as designed.
The implication that Reactor Controls failed to follow the requirements of their QA Program is inaccurate.
Reactor Controls program required Quality Control Hold Infomation Notices (Nonconformance Reports) be initiated when installation was not in accordance with the design drawings. QC Hold Information Notices were issued to identify deviations at the time of in-stallation.
It was at this time that Bechtel Corporation chose to point out several QC Hold Notices that had been issued by RCI as an incicdien of RCI not perfoming work in accordance with our program.
Investigation of these QC Holds by ~Bechtel showed that RCI had performed work in accor-dance with our program. This investigation proved the program identified the deviations and did provide corrective action to correct dev'ations during the construction process.
The utility constructor's Quality Control personnel were assigned late in the project to do parallel inspections of the supports being installed by Reactor Controls with the intention to eliminate the need for additional inspections when RCI turned the equipment over to the client. These inspections would have been required to be performed under the IE Bulletin 79-14 and the thought was to parallel our inspections to provide the 79-14 l
walkdown inspections prior to the conplete turnover of the system. This would enable the utility to maintain their scheduled start-up of the l
Grand Gulf Unit 1 plant. There was at-no time an implication made that l
these inspections were being performed because RCI personnel were,not cap-able of performing adequate inspections.
RCI did in fact perform their l
inspections and provided documentation of the work performed and this was O.urned over to our customer at the end of the project.
Item 3 - Boston Edison Company (LER 82-005)
The use of the term "four seismic supports not completely installed" does not provide enough information for RCI to determine the validity of the 1
statement.
RCI work at Pilgrim Nuclear Power Station was completed in mid 1971.
Since that time many new designs and requirements have been imposed which are more stringent than at the time of installation.
In all probability there has been substantial work perfomed by others on l
the supports RCI installed and to indicate RCI's original installation
September 15, 1983 US Nuclear Regulator,.
Reactor Controls, Inc.
p,gY" Item 3 - (Con't) practices caused pipe clamps to be loose or missing is an unreasonable presunption.
Conrnent: It is apparent from reviewing the wordiug of the proposed Information Notice, and investigation of the circumstances identified for each item, there is a lack of evidence to support publication of a document that would be damaging to RCI. Within the time frame permitted to give reasons why we feel this information is inaccurate we feel the RCI response is-
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more than sufficient to raise doubt as to the validity of the IE Information-Notice titled " Reactor Controls Incorporated Construction Deficiencies".
We further contend, given the opportunity to provide additional information or to attend a meeting sith those personnel responsible for compilation of the data proposed to be published, there is no doubt the outcome would be RCI's ability to disprove the contents of this draft notice.
Reactor Controls,' Inc. has been involved in fabrication and installation of safety related equipment in numerous nuclear power' plants since 1964 and in all cases we have proven to be capable of perfc,rming all work contracted.
Our customers have always been satisfied with our work and have expressed satisfaction with personnel assigned to their projects. The publication of this document, with so many unfounded accusations, would be irreversibl.v emaging to Reactor Controls, Inc. We, as a company are very proud of our pe: formance and our highly qualified and respected personnel.
Our perfor-maice has been exceptional and cooperation with agencies has been excellent.
Very truly yours, R
OR CONTROLS, INC.
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THE CINCINNATI GAS A ELECTRIC COMPANY COLUMBUS AND 500TilERN OHIO ELCCTP.IC COMPANY' f
THE DAYTON.PO'.lER AND LIGHT COMPANY P. O. Box 960 Cincinnati, Ohio 45201 FIELD ORDER NO. /7d/- /
DATE:
August 22, 1975 To:
Reactor Controls, Inc.
. Attention: John Klaus RE: Contract No. H-2832
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R.P.V. Internals and CRD System i
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Gentiemen:
You are hereby authorized to perform the following described work in accordance with the cost plus provisions of the above contract:
1.
Furnish supervision, labor, tools and equipment 'and do all things necessary to erect owner furnished CRD Housing Restraint Supports and Beams per G. E. Drawings 762E658 and K.E.I.
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The estimated cost for the above work is A5r.rne dI'vM This work is 'to be invoiced separately with reference made
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Invoice must list labor and material separately.
Charge thi,s work to W.0.
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SUBJECT CRD Siipport Beam and Brackets Ref KN-1-13 dug-761E970 Sheets 1 and 2 r*.
Due to i=bedment problems, modificat,1on 'of General...Electr.ic...s'iTpplie.d...e.qu.ipment is authorized as follows.
Beam 7 Cut long leg on bracket,J18.._so bracket. will.. fi.t.1mbe.dment.,...This. =ust..
leave 3" of the beam bearing _ on _ the.. bracket.......,
Elongat e the hole in b..e.a.m. 7 180
- end...t..o.. a..l...i. gn...b..e..a...m....a..n...d.....b..r.a..c..k.e. t....h.. oles..
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