ML20082L884
| ML20082L884 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/07/1983 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| Shared Package | |
| ML20082L888 | List: |
| References | |
| NUDOCS 8312050607 | |
| Download: ML20082L884 (9) | |
See also: IR 05000440/1983031
Text
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9
NOV 0 71983
Docket Nos. 50-440
50-441
The Clev' eland Electric Illuminating Company
ATTN: Mr. Murray R. Edelman
Vice President
Nuclear Group
P.O. Box 5000
Cleveland, OH 44101
Gen'lemen:
SUBJECT:
Construction Appraisal Team Inspection 50-440/83-31,50-441/83-30
This refers to the Construction Appraisal Inspection by the Offire of Inspec-
tion and Enforcement (IE) on August 22-September 2 and September 1z-23,1983, at
the Perry Nuclear Power Plant Units 1 and 2.
The Construction Appraisal Team
(CAT) was composed of members of IE, Region III, and a number of consultants.
The inspection covered construction activities authorized by NRC Construction
Permits CPPR-148 and CPPR-149.
This inspection is the fourth of a series of construction appraisal inspections
being planned by the Office of Inspection and Enforcement. The results of these
inspections will be used to evaluate implementation of management control of
construction activities and the quality of construction at nuclear plants.
The enclosed report identifies the areas examined during the inspection. Within
these areas, the effort consisted of deta11ed inspection of selected hardware
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subsequent to Quality Control inspections, a comprehensive review of selected
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portions of your Quality Assurance Program, examination of procedures and records,
observation of work activities and interviews with management and ov9r person-
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nel.
Appendix A to this letter is an Executive Summary of the results of this inspec-
tion and of conclusions reached by this office. The NRC Construction Appraisal
Team noted no pervasive failure to meet construction requirements in the samples
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of installed hardware inspected by the team.
However, management attention is
needed for the resolution of the detailed deficiencies identified during the
inspection.
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0312050607 831107
PDR ADOCK 05000440
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IE01
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The Cleveland Electric Illuminating
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Company
The NRC CAT inspectors identified a number of typical construction type defi-
ciencies which had been previously identified by the applicant's project organi-
zation. .They also perceived a quality conscious attitude throughout this project
organization.
It was noted that timely management attention was being given to
findings identified by both the NRC CAT and the project organization.
It is also our understanding that you plan to review welding of small bore piping
manufactured by Pullman Power Products at the Williamsport, Pennsylvania facility
as a result of problems identified during this inspection and by Georgia Power
Company at their Vogtle facility.
Appendix B to this letter contains a list of potential enforcement actions based
on the NRC CAT inspector observations. These have been referred to the NRC
Region III office for review and necessary actions.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures
will be placed in the NRC Public Document Room unless you notify this office,
by telephone, within 10 days of the date of this letter and submit written
application to withhold information contained herein within 30 days of the date
of this letter. Such applications must be consistent with the requirements of 10
No reply to this letter is required at this time. NRC Region III will address
the potential enforcement findings at a later date and any required response
will be addressed at that time.
Should you have any questions concerning this inspection, please contact us or
the Region III Office.
Sincerely,
ll
Richard C. DeYoung, Director
Office of Inspection and Enforcement
Enclosures:
1.
Appendix A - Executive Summary
2.
Appendix B - Potential Enforcement Findings
3.
Inspection Report 50-440/83-31, 50-441/83-30
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The Cleveland Electric Illuminating
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Compacy
Dift,3ribution (w/Recort)
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J. Naldron, Plant Manager
L. Beck, General Supervisor
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Licensing and Fuels Management
DMB/ Document Control Desk
Sr. Resident Inspector, R-III
Terry J. Lodge, Esquire
James W. Harris, State of Ohio
,
Robert H. Quillin, Ohio Dept. of Health
SECY
OPE
OCA (3)
R. DeYoung, IE
J. Taylor, IE
E. Jordan, IE
J. Partlow, IE
Regional Administrators
RCPB R/F
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APPENDIX A
EXECUTIVE SUMMARY
An announced Construction Appraisal Team (CAT) inspection was performed at the
Perry Nuclear Power plant site during the period August 22-September 2 and
September 12-23, 1983.
OVERALL CONCLUSIONS
The Construction Appraisal Team concludes that the results of this inspection
indicate several construction program weaknesses. NRC Region III has been made
aware of these weaknesses and is pursuing them with applicant management. The
applicant is initiating corrective action and/or continuing efforts to resolve
the identified concerns. An indication that prompt management attention is being
given to the identified deficiencies is that nonconformance reports or other
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corrective action requests were immediately initiated by the applicant upon
identification of the deficiency. These are discussed in the details section of
the report. However, management attention is needed where some lack of resolu-
tion adequac, and timeliness were noted.
The NRC CAT inspectors noted that many of the typical problems experienced at
other facilities were experienced by the Perrj Nuclear Power Plant (PNPP) pro-
ject. However, an agressive attitude in the identification of problems was
demonstrated through the applicant's project organization, and was further
reflected by the amount of applicant's management involvement at the PNPP site.
The identified construction program weaknesses are as follows:
(1)
The current practice of installing concrete expansion anchor bolts in the
drywell wall is a concern to the NRC CAT inspectors. The number of
intended anchor bolt installations and the real potential for cracking
of the drywell wall as a result of normal, transient, and accident loadings
lead the NRC CAT to question the ability of the drywell to maintain the
specified leaktightness throughout its service lifetime. The preoperational
and periodic drywell bypass leakage tests are seen to be crucial tests to
assess and monitor drywell bypass leakage from all sources.
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(2)
A number of examples were identified where the QC inspection program and
the "as-built" verification program for piping and pipe supports / restraints
did not ensure that installed items conformed to design requirements.
While many installations have progressed through the contractor's verifi-
cation programs, the applicants verification program is in the early
stages.
(3)
The welder qualification program for two contractors needs attention to
ensure welder qualifications are properly performed. Better controls
to ensure welder identification should also be utilized.
The NRC CAT
found few hardware deficiencies in the welding area, and in general, the
in-process and completed welds reviewed exhibited good workmanship. The
one exception was in the small bore piping area as discussed in the details
section of this report.
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(4)
A number of examples were found where corrective actions related to con-
tractor identified problems were not taken in a timely manner and where
nonconformances were closed out prior to completing all of the required
corrective actions. Examples wher'e timely corrective actions were not
taken include undersized welds on HVAC supports, "as-built" program defi-
ciencies, improper valve actuator installations, and reverifications for
required material traceability. Examples of improperly closed-out noncon-
formances include problems involving training for concrete placement crews
and a failure to submit a required FSAR amendment.
AREAS INSPECTED AND RESULTS
Electrical and Instrumentation Construction:
In general., the installation of
electrical and instrumentation components inspected was in accordance with
design documents and exhibited good workmanship. However, several program
deficiencies were identified.
Two problems were identified relative to electrical separation. One problem
involved documentation for Class 1E raceway installations that indicated
separation criteria to be satisfied when in fact a number of raceway instal-
lations examined did not conform to requirements. The other problem involved
the lack of adequate procedural controls to assure that the duct covers
(barriers) for the Power Generation Control Complex (PGCC) received the
appropriate quality inspections.
The NRC CAT also identified a problem where sketches were used to install'
conduit and conduit supports in the Unit 1 containment drywell area without
appropriate document controls such as issuance, revision, retrieval ar.d approval.
Mechanical Construction: HVAC and piping runs were found to be constructed in
accordance with the applicable requirements. However, a number of examples were
identified by the NRC CAT which indicate that some piping and pipe support /
restraint deficiencies have not been identified during QC construction accept-
ance inspections or during the "as-built" verification program. A weakness
in procedural adequacy and adherence was observed in these areas. The HVAC
inspection and "as-built" verification programs exhibited similar deficiencies
and procedural weaknesses.
In addition, two issues were identified regarding the lack of adequate corrective
actions taken by the applicant to identified deficiencies. One issue involved
HVAC support welding deficiencies which were not properly or promptly addressed.
The condition included missing and undersized welds, improper configurations
and inadequate documentation. The other issue involved the lack of action where
known conflicts existed between installed pumps and valves and the design
criteria specified in the FSAR or in the purchase specifications. For example,
a number of valves containing actuator models which differed from tb original
design were identified by CEI, but no corrective actions had been initiated at
the time of this inspection.
Welding and Nondestructive Examination:
In general, welding and nondestruc-
tive examination (NDE) reviewed by the NRC CAT exhibited work performed in
accordance with requirements. However, several deficiencies were identified.
These included improper visual welding inspection of fillet welds made under the
rules of the AWS D1.1 Structural Welding Code; improper reinforcement on
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weld-o-lets required by Section III of the ASME Boiler and Pressure Vessel Code;
and inadequate procedural controls of heat inputs for the welding of stainless
steel socket welds.
The welder qualification program for two contractors was found to be deficient in
that film quality of radiographs used for welder qualifications did not satisfy
ASME Code requirements. Additional controls should be applied to the welder
qualification program to further ensure proper welder identification during
qualification.
Civil and Structural Construction:
Current concreting activities and erected
structural steel appear adequate.
Past records of concrete placement, soils
backfill operations, and structural steel installations show conformance to
specification requirements. However, problems were found in the dispositioning
of some seismic clearance violations identified by the applicant's inspection
program. Examples of a lack of proper engineering consideration were also
identified. There is concern regarding drywell leaktightness due to the current
practice of installing numerous (8,000-10,000) expansion anchor bolts through the
drywell liner plate.
Material Traceability, Storage and Maintenance:
In general, the project material
traceability, storage and maintenance programs were found to be acceptable.
However, some deficiencies were found in the areas of fastener traceability and
material control of some small components, in-plant storage of safety-related
equipment and the control of maintenance in the central warehouses.
QC Inspector Effectiveness:
Interviews were held with inspectors randomly
selected from the applicant's organization and from contractors on the construc-
tion site. There were no instances of intimidation or threats reported.
In
one instance, issues were raised that could have an effect on the contractor
QC inspector effectiveness. This instance was referred to the NRC Region III
Office for resolution.
Quality Assurance: Selected portions of the QA audit program reviewed indicated
an adequate QA program was in-place to monitor construction activities by both
the applicant and his contractors. Audit personnel were found to be qualified in
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accordance with the applicant's commitments. Nonconformances were sometimes
closed before the disposition was completed and two contractors were not taking
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proper corrective action with regard to nonconforming conditions as required by
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the co rective action program. Overall, the applicant's project organization was
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found to be aggressive in identifying and resolving construction problems.
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APPENDIX B
POTENTIAL ENFORCEMENT FINDINGS
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As a result of the CAT inspection of August 22-Septriber 2 and September 12-23,
1983, the following items have been referred to NRC Region III as potential
enforcement findings (section references are to the detailed portion of the
inspection report).
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Electrical and Instrumentation Construction
1.
Contrary to 10 CFR 50 Criteria V, X and XVII, and the Perry Nuclear Power
Plant (PNPP) FSAR Section 8.3.1.4.1.4., separation requirements relative to
some raceway installations had not been properly inspected.
In one area,
inspection activities performed to determine the acceptability of Class 1E
raceway installations were not accomplished in accordance with applicable
procedures.
Inspection records ' indicated separation criteria to be accept-
able when in fact a number of installations examined did not conform to
requirements.
In another area, adequate procedural controls were not
established to assure that the installation of Power Generation Control
Complex (PGCC) duct covers (barriers) received appropriate inspections
'(Sections II.B.1 and II.B.2).
2.
Contrary to Appendix B, Criteria VI and XVII, and the PNPP Corporate
Nuclear Qua'lity Assurance Manual (CNQAM), Sections 0600 and 1700, raceway
sketches used to perform installation of conduit and conduit supports in
the Unit 1 containment drywell area lacked appropriate procedural control
for items such as issuance, revision, retrieval and approval.
Inspection
records generated for in-process inspections performed in accordance with
these sketches did not contain the applicable sketch revisions (Section
II.B.1).
Mechanical Construction
1.
Contrary to 10 CFR 50, Appendix B, Criteria V and X, and the PNPP CNQAM
Sections 0500 and 1000, seismic pipe supports / restraints have in some cases
not been constructed and inspected in accordance with design requirements.
In addition, the applicants "as-built" verification program for safety-
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related valves, valve operators and pipe supports / restraints have in some
cases failed to identify discrepancies between installed items and design
drawings (Sections III.B.1 and III.B.2).
2.
Contrary to 10 CFR 50, Appendix B, Criteria XV ar.d XVI, and the PNPP CNQAM
Sections 1500 and 1600, the applicant's heating, ventilating and air
conditioning (HVAC) contractor's corrective action programs failed to
promptly and properly identify, evaluate and correct recurring deficiencies
in installed and QC accepted HVAC duct supports.
In addition, the appli-
cant has identified purchased equipment that does not meet FSAR ccmmitments
and has not initiated timely corrective action to resolve these identified
problems (Section III.B.5 and III.B.6).
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Welding and Nondestructive Examination
1.
Contrary to 10 CFR 50, Appendix B, Criteria V and X, and the PNPP CNQAM
-Sections 0500 and 1000, the performed welding inspection for AWS welds
in structurai steel and HVAC applications were found to be deficient with
respect to the requirements stated in the AWS D1.1 Structural Welding Code.
Fabrication requirements for field installed branch connection weld-o-lets
and measures to control the welding'of stainless steel socket welds were
found to be deficient with respect to the requirements contained in the
ASME Boiler and Presure Vessel Code (Sections IV.B.2, IV.B.5, and IV.B.7).
2.
Contrary to 10 CFR 50, Appendix B, Criteria IX and XVII, and the PNPP
CNQAM Sec tion 0900 and 1700, several examples were observed in the area
of welder qualification by radiography where the radiographs did not
conform to appropriate quality standards (Section IV.B.1 and IV.B.2).
Civil and Structural Construction
Contrary to 10 CFR 50, Appendix B, Criterion III, FSAR Section 1.8, and Regula-
tory Guide 1.29, Revision 3, Paragraphs C.2 and C.4, engineering dispositions of
seismic clearance violations have not in some cases been performed in a manner
which would ensure structural integrity.
Examples include: a lack of considera-
tion in some analyses for deficient hardware conditions and in lateral movement
of fire protection piping near Class 1E cable trays; improperly dispositioned
seismic clearance violations and several related calculation deficiencies
(Section V.B.1).
Material Traceability, Storage and Maintenance
Contrary to 10 CFR 50, Appendix B, Criteria VIII and XIII, and the PNPP CNQAM
Sections 0800 and 1300, the storage / issuance, application and installation of
fasteners and some components have not been adequately controlled to prevent the
use of incorrect parts (Section VI.B.1).
Quality Assurance
Contrary to 10 CFR 50, Appendix B, Criterion XVI, and the PNPP CNQAM Section
1600, nonconformances were closed prior to completion of the entire scope of work
proposed by the disposition of the nonconformance and the required corrective
actions completed (Section VIII.B.2.c).
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UNITED STATES NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
DIVISION OF QUALITY ASSURANCE, SAFEGUARDS, AND IMSPECTION PROGRAMS
REACTOR CONSTRUCTION PROGRAMS BRANCH
Report No.: 50-440/83-31,50-441/83-30
Docket Nos.: 50-440, 50-441
Applicant: Cleveland Electric Illuminating Company
Post Office Box 5000
Cleveland, Ohio 44101
Facility Name: Perry Nuclear Power Plant, Units 1 and 2
Inspection At: Perry Nuclear Power Plant, Units 1 and 2, Perry, Ohio
Inspection Conducted: August 22-September 2, 1983 and
[eptember 12-23, 1983
Inspectors:
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L U ') J.n c t.)
la/27/83
A. B. Beach, Sr. Reactor Construction
Dat'e Signed
Engin er TeamLesc>-)
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G. J. Georgiev, S(/ Reactor Construction
Dafe Signed
Eryjineer
N tSoulo
in/27/n3
[cu R. A. Rohrba'cher, Sr. Reactor Construction
Date S~igned
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Engineer
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m W.'A~. Hanson, inspection Specialist
Dat'e S'igned
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D. B. Osborne, Reactor Construction Engineer
Date Signed
4[M
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'H . W . P
lips,"ReactorfConstruction Engineer
Date Signed
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Hf J. Tong, React ~ Construction Engineer
Dat6 Sfgned
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4 . E. Vandel, Reactor Inspector (Region III)
Dat6 Signed
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Consultants:
R. M. Compton, D. C. Ford, E. Y. Martindale, and F. A. Pimentel
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Approved By:
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'R. F. Heishman, Chief
Date Signed
Reactor Construction Programs Branch
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831107
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TABLE OF CONTENTS
TOPIC
SECTION
INSPECTION SCOPE AND OBJECTIVES....................................
I
ELECTRICAL AND INSTRUMENTATION CONSTRUCTION........................
II
MECHANICAL CONSTRUCTION............................................
III
WELDING AND NONDESTRUCTIVE EXAMINATION (NDE).......................
IV
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CIVIL AND STRUCTURAL CONSTRUCTION..................................
V
MATERIAL TRACEABILITY, STORAGE, AND MAINTENANCE....................
VI
QC INSPECTOR EFFECTIVENESS.........................................
VII
QUALITY ASSURANCE..................................................
VIII
ATTACHMENT A - PERSONS CONTACTED AND DOCUMENTS REVIEWED
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I.
INSPECTION SCOPE AND OBJECTIVES
The objective of this inspection was to evaluate the adequacy of construc-
tion at the Perry Nuclear Power Plant Units 1 and 2.
This objective was
accomplished through review of the construction program and selected portions
of the quality assurance program, with emphasis on the installed hardware
in the field.
Within the areas examined, the inspection consisted of a detailed examina-
tion of selected hardware subsequent to applicant quality control inspec-
tions, a selective examination of procedures and representative records,
and observation of in-process work.
Interviews were conducted with
designated site managers, quality control inspection personnel and craft
personnel .
For each of the areas inspected, the following was determined:
Is the hardware installed in accordance with the approved design?
Do individuals with assigned responsibilities in a specific area
understand their design.ated responsibilities?
Are quality verifications performed during the construction process
with applicable hold points and are quality verifications conducted
to adequate inspection acceptance criteria?
Do personnel involved with Quality Assurance / Quality Control have
the organizational freedom to perform their tasks without harassment
or intimidation?
Are management controls established and implemented to adequately
control activities in the subject area?
The areas in which a selected sampling inspection was conducted include:
Electrical and Instrumentation Construction
Mechanical Construction
Welding and Nondestructive Examination
Civil and Structural Construction
Material Traceability, Storage, and Maintenance
QC Inspector Effectiveness
Quality Assurance
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II.
ELECTRICAL AND INSTRUMENTATION CONSTRUCTION
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A. Objective
The primary objective of the appraisal of electrical and instrumentation
construction was to determine whether safety-related components and systems
were installed in accordance with regulatory requirements, SAR commitments
and approved construction specifications and drawings. Additional objec-
tives were to determine whether procedures, instructions and drawings used
to accomplish construction activities were adequate and whether quality-
related records accurately reflect the completed work.
B. Discussion
Within the broad categories of electrical and instrumentation construction,
attention was given to specific areas. These included electrical cable,
raceways, electrical equipment and instrumentation components. Addition-
ally, a review was made of a selected number of documents associated with
design change control and nonconformance reports.
1. Electrical Raceway Installation
a. Inspection Scope
The NRC CAT inspectors selected eight conduit runs, with a total
length of about 750 feet, from various plant areas for detailed
inspection. These runs were inspected for conformance to require-
ments relative to routing / location, separation, bend radii, supports,
support spacing, identification and attachments. An additional 200
feet of conduit, associated fittings and supports were inspected for
general workmanship, separation and identification.
Thirteen runs of installed cable tray, with an aggregate length
of about 1000 feet, were inspected relative to support location,
separation, mounting, protection and physical loading. Samples
were selected from plant areas which included the control complex,
radwaste, reactor and intermediate buildings.
Twenty raceway supports were examined in detail for such items as
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location, material, anchor spacing, weld quality and installed
configuration.
b. Inspection Findings
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(1) Cable Tray Separation
Relative to separation of cable tray, the PNPP FSAR Section
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8.3.1.4.1.4 states in part "... cable trays of different divi-
sions have a minimum horizontal separation of three feet when
there is no physical barrier between trays. Where horizontal
separation of three feet is unattainable, the trays will be
separated by fire resistant materials...
In cases where trays
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must be stacked one above another, a minimum separation of five
feet is maintained. Where vertical separation cannot be main-
tained, the trays will be separated by fire resistant materials."
Specific acceptance criteria for divisional separation between
cable trays and conduits are detailed on Gilbert Associates, Inc.
(GAI) Drawing D-214-004 Rev. K.
During inspection of the selected cable tray sample, the NRC CAT
inspectors observed the following tray segments (listed below)
which did not maintain the required separation between divisions.
The cable tray segments in the left column do not meet the
required separation relative to the tray segments listed in
the right column.
Division B 269
Division A 156
Division A 603
Non-Div. 2327
Non-Div. 1260
Division A 656
Non-Div. 1260
Division A 655
Non-Div. 425
Division A 665
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Division A 152
Division A 663
Non-Div. 1538
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Non-Div. 1575
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Non-Div. 3593
Non-Div. 083
Division A 150
Non-Div. 3593
Non-Div. 083
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Division B 274
Division B 273
Non-Div. 1649
Non-Div. 2238
Division B 272
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Division B 1319
Non-Div. 595
Division 6 271
Division A 601
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Division A 1680
CDT. 1017R-144C
Division B 1326
Division A 153
CDT. 1833C-3508B
Division A 3008
Non-Div. 4555
Division B 269
Division A 141
Division A 127
Division A 1657
Division B 1846
The NRC CAT inspectors reviewed the inspection records for these
installations. The records were in the form of an inspection
checklist issued as part of L. K. Comstock (LKC) Procedure 4.3.1,
" Cable Tray and Conduit Installation". Section 3.4 of this
procedure details the requirements for quality control inspection
of cable tray and conduit installations. With regard to separa-
tion, Section 3.4.4.11 states... " verify installed cable tray and
channel tray have not violated the separation criteria." In
reviewing the records of this inspection activity, the NRC CAT
inspectors noted that line item 11, separation criteria accept-
able, had been initialed by the QC inspector. This indicates an
acceptable installation when in fact the installed configuration
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of the cable tray does not meet the specified separation
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criteria.
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The NRC CAT inspectors discussed this matter with representatives
of the quality organizations of both the applicant a1d the
electrical contractor. The results of these discussions indi-
cated that the initialed acceptance of the subject raceway
installations was intended to be contingent upon the installation
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of approved barriers at some later date. The NRC CAT inspectors
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observed that, although barriers were shown on the design draw-
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ings, there were no procedures available for installation of
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these barriers. Additionally, at the time of the CAT inspection,
material to be used for barrier applications had not been speci-
fied.
As a result of tnese observations, the licensee issued Action
Request (AR) 692 which details steps to be taken to correct these
discrepancies. The AR included:
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the stamping of all existing Form 17 and Form 82 (Cable
Tray and Conduit Inspection) Checklists with the words
" barrier installation not verified"
the revision of Procedure 4.3.1 to define the term "separa-
tion criteria"
the revision of Procedure 4.3.1 to procedurally address the
use of this stamp.
Further attention will be required by the applicant and elec-
trical contractor to assure that inspection records accurately
reflect the actual hardware installation and that work / inspection
procedures are developed to control activities associated with
barrier installation and inspection.
(2) Drywell Raceway Installation
During inspection of raceway installation within the drywell, NRC
CAT inspectors noted that construction activities were being
accomplished using sketches. A review of the program which
establishes use of these sketches indicated that initially the
installation of raceway in the drywell area was in accordance
with Gilbert-approved 500 Series drawings. However, as construc-
tion coordination problems in this area increased, a variance to
use sketches was requested via Field Variance Authorization (FVA)
4331-33-899. This FVA was approved on 8/19/82. Subsequently, a
review by the Site Quality organization indicated that the use of
an FVA to establish this program was not in accordance with
established procedures. Engineering Change Notice (ECN)
1327-33-2422 was then initiated to provide the appropriate
incorporation of the Reactor Building As-Built Drawing Program
into Electrical Construction Specification 33-4549-00.
The NRC CAT inspectors examined several sketches from areas
including the electrical contractor's QC file and the field stick
files. These sketches detailed conduit and conduit support
installations. Many sketches included specification variances.
Some variances were individually initialed, others were circled,
still others were apparently approved by initialing the sketch in
the icwer right hand corner. The sketches themselves did not
appear to be consistently approved. Some sketches reviewed
included sign-offs in the approval olock by electrical, struc-
tural, and civil engineers, others rectived only an initial
and date outside of the approval block. The NRC CAT inspectors
reviewed the program for issue and control of these sketches and
concluded that there was no formal, procedural control of this
activity. Discussions with the applicant and representatives
from the Coriduit Detail Group indicated that these documents are
controlled by the Conduit Detail Group and are not controlled or
handled by the Contractor's Document Control Section.
Sketches
are issued to the field and to QC directly by the Conduit Detail
Group. The Conduit Detail Group is a rather unique part of the
II-4
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_
.
.
PNPP project organization in the Nuclear Construction Engineering
Section. The detailers in the group work for the electrical
contractor (LKC), but the group technically reports to the
architect-engineer (GAI).
.
The NRC CAT inspectors asked about the control of revised or
superseded sketches without the use of a procedure. The appli-
cant was unclear as to whether revised or superseded sketches in
the field were retrieved or destroyed by the foreman.
Inspection of raceway installed in accordance with this program
is not accomplished until the "as-built" information from these
sketches is incorporated and approved on a Gilbert 500 Series
drawing. The exception to this is the inspection for placement
of Hilti bolts and welding of supports. These activities are
performed as an in-process inspection.
Inspection records
reviewed for this activity did not indicate the sketch revision
number. The NRC CAT inspectors were unable to discern to which
revision of a sketch these in-process inspections were performed.
Based upon these observations, the program for installation of
raceway in the drywell area appears to require additional proce-
dural controls.
(As a result of the NRC CAT review in this area,
the applicant has proposed changes to LKC Procedure 4.3.1, " Cable
Tray and Conduit Installation", and to Procedure 4.2.2, " Field
Engineering Changes", to clarify responsibility and control
of raceway sketches.)
(3) Raceway Separation
In the Unit 1 Auxiliary Building, the minimum separation distance
between redundant division conduit and pull boxes (PB) was not
,
met relative to conduit 1R33C4239B, PB-1-346 and PB-1-2925. [LKC
documented this condition on Nonconformance Report (NR) 2288.]
,
(4) Conduit Support
The water-tight flexible portion of conduit IP45H3B-3 in the
Emergency Service Water Pump House was supported by a piece of
tie-wire that was cutting into the outer covering.
(LKC initi-
ated NR 2292 to document this condition.)
(5)ConduitIdentification
Conduit identification was readily visible, properly located and
appropriately used where necessary,
c. Conclusions
(1) The separation status of numerous installed and inspected
cable trays was not accurately recorded on QC inspection
records. These records indicated " separation criteria
acceptable" when, in fact, this was not the case.
II-5
,
.
.
(2) Some drywell installation and inspection activities were being
accomplished without formal, procedural controls for the sketches
being used.
(3) Although a few minor deficiencies were noted, no major problems
were identified relative to the installed raceways.
2. Electrical Cable Installation
a. Inspection Scope
The NRC CAT inspectors selected a sample of installed electrical
cable runs that had been previously accepted by site quality control
inspectors. The sample included high voltage, power, control and
instrument cables. For each of these cable runs, physical inspection
was made to ascertain compliance with applicable design and installa-
tion criteria relative to size, type, location / routing, bend radii,
protection, separation, identification, physical loading and sup-
ports.
Additionally, the NRC CAT inspectors selected 56 cable ends (306
terminatedconductors). These were inspected relative to the appli-
cable design and installation documents for items such as termination
location, correct size and quantity of conductors and correct identi-
fication of cables and wires.
The following high voltage and power cables, totaling approximately
1,100 feet, were selected from different systems, electrical trains,
locations and sizes:
Cable No.
Type
IR23F-7A
3 1/c 500 MCM
3 1/c 500 MCM
3/c No. 12
3/c No. 12
The following control cables, totaling approximately 600 feet, were
selected from different systems electrical trains, locations and
sizes:
Cable No.
Type
1 3/c No. 14
1 7/c No. 14
1 3/c No. 14
1 9/c No. 14
1 9/c No. 14
II-6
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The following instrument cables, totaling approximately 600 feet,
were selected from different systems, electrical trains, locations
and sizes:
.
.
Cable No.
_ Type
IC51R-7800
C0AX
J
IC51R-782D
COAX
-
1-4/STP-20
1-STP-16
The NRC CAT inspectors also observed installation / pulling activities
associated with cable 1E22H2010. This is a 3/c 500 MCM cable to
HPCS pump motor 1E22-C001. Observations were made to determine
compliance with installation requirements, such as protection during
handling and pulling, use of cable lubricant, conduit condition prior
1
to pulling, use of a tension monitoring device and size and profi-
'
ciency of pulling crew.
b. Inspection Findings
(1) Routing
The LKC QA/QC Procedure 4.3.3, " Cable Pulling Procedure," Section
3.1.3, states "The cable size, type, and routing is as shown on
the pull slip or as modified by an approved RCIM (Routing Change
Modification). Obvious routing errors shall be brought to the
attention of the Project Organization by the Comstock Cable
,
,
Engineer. Routing of cable may be revised in the field by the
Project Organization. The authorized Engineer shall sign and
date all revisions to the original cable pull slip as well as the
'
work and QC copies in the field. QC shall have in his possession
an approved RCIM (document this RCIM on applicable form 105A)
stating revision to routing prior to final acceptance of cable
pull."
During inspection of the selected cable sample, the NRC CAT
inspectors observed the following cables with installed routings
-that did not match those indicated on the pull slip, and for
which an RCIM had not been initiated:
l
Cable 1R23F-7A was pulled from tray 128A through tray 688A
l
into equipment 1R23-S010. However, the pull slip does not
indicate vertical tray 688A as part of the routing.
'
Cable 1R42D-37B is pulled to equipment 1R23-5011. However,
the pull slip indicates the routing of this cable to equip-
ment 1R23-5012 instead of 1R23-S011.
i
II-7
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(As a result of these observations, the applicant has initiated
NR P033-2132 to rework and reinspect these discrepancies and to
revise procedures 4.3.6 and 4.3.17.for clarification to prevent
recurrence. Also, NR 0QC 302 was initiated to document the
discrepancy on circuit 1R2D-37B.)
Although several discrepancies were identified in this area, only
one instance was the result of poor construction / inspection
practices. A review of design information associated with the
remaining cables disclosed that routing discrepancies were a
result of errors in the pull slips. Although these errors should
have been identified by site QC personnel, there were only a
small number of discrepancies noted by the NRC CAT inspectors in
this area.
(2) Separation
The PNPP FSAR Section 8.3.1.4.1.1 states in part ... " electrical
equipment and wiring for Class 1E electrical systems are
segregated into separate independent divisions... such that no
single credible event is capable of disabling sufficient
equipment to prevent reactor shutdown, ... division separation
requirements apply to equipment and wiring systems concerned."
Separation of redundant divisions in general plant areas is
discussed in paragraph 1 of this section. For the purpose of
clarification, separation, as referred to in this section, deals
only with cable and wiring installed in the Power Generation
Control Complex (PGCC) ductways and panels.
LK Procedure 4.3.30, "PGCC Control Room Work / Inspection Procedure",
Section 3.3.1 states in part... "All cable routing in the PGCC
area will be accomplished using Cable Pulling Procedure 4.3.3."
LKC Procedure 4.3.3, Section 3.2.28.1, states in part, " pulled
through circuits will be routed as shown on wire list and drawing
to maintain the required separation within the duct work.
Separation shall be maintained both externally and in-panel."
Section 3.2.2.8.2 states... "QC shall inspect 100% of all pull
through circuits in Control Room only. Safety related circuits
shall be pulled in safety related raceways only."
Section 3.2.28.7 states... " divisional cables shall be separated
from cables of other divisions by six inches or metallic conduit
or barriers or as directed by Project Organization."
II-8
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.
,
During the inspection of cable installations in the PGCC ductway
of the Unit 2 Control Room, the NRC CAT inspectors observed that
many cable separation violations existed. Cables of one division
'
were installed in physical contact with those of another divi-
,
sion.
Discussions with the applicant, LKC and General Electric
(GE) indicated that approved barriers would be installed at a
.-
later date to correct this condition. LKC representatives
initiated an NR to document this situation.
Items indicated on
this report had been transferred to a master deficiency list by
'
the applicant.
The NRC CAT inspectors further reviewed installations in this
- .
area and concluded that installation of barriers had yet to be
accomplished.
It was estimated that there are as many as 400
locations in which barriers will be required. Concurrently, the
installation of pull through circuits has progressed to the point
of 60-70 percent completion.
Examination of several potential barrier locations indicated
that the installed configuration of cable may significantly
impair the installation of barriers. Additionally, the NRC CAT
-
inspectors found no formal procedures for installation and
inspection of barriers.
Work currently being perfomed in Unit I ductways is accomplished
'
in accordance with a GE Field Design Deviation Request (FDDR).
During the inspection of this area, the NRC CAT inspector
observed the in-process installation of a separation barrier
(ductcover)inUnit1. The NRC CAT inspectors noted that there
were no QC personnel present during this activity and further
l
discussions with the applicant and LKC personnel disclosed that
QC had nct been notified of this installation activity.
(LKCNR
,
2368 was initiated to document this condition.)
'
The NRC CAT inspectors concluded that the appropriate procedural
controls have not been established to assure that previously
inspected cables will not be damaged by the installation of
,
l
barriers, and that all required barriers will be installed. As a
-
result of this inspection, the applicant has initiated AR 720
l
which makes the following recommendations:
LKC QC to ensure that coverage is provided for the estab-
lished hold point on the installation of PGCC duct covers for
the balance of Unit 1,
.
!
No bulk installation of duct covers to proceed in Unit 2
l
without an approved installation / inspection procedure.
,
I
Initiate an NR to document the indeterminate status of the
!
cables in the ductways.
l
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Provide both craft and QC training pertaining to the above
mentioned requirements.
.
(3) Terminations
LKC Procedure 4.3.6 sets forth the criteria for cable
,
terminations. Contrary to this procedure, the NRC CAT inspectors
j
observed that the lug on the red conductor at terminal point T3
,
of cable #1E12F-53B exhibited a 1/4" gap between conductor
insulation and lug.
(NR LKC 2313 was initiated to rework this
'
connection.)
In general, the terminal blocks and lugs were of the specified
material, terminal lugs exhibited evidence of proper crimp tool
usage, conductors were free from jacket / insulation damage,
conductors were terminated as shown on applicable wiring
diagrams and conductors did not violate bend radii criteria,
c. Conclusions
With the exception of problems identified relative to separation of
i
cables and installation of duct covers in the PGCC dt:ctways, the
installation of the cable inspected is in accordance with design and
installation documents.
In general, cables, terminations and associ-
ated items exhibited proper configuration and good workmanship.
, Inspection records reflected the current status of the installed
components.
3. Electrical Equipment Installation
a. Inspection Scope
Over twenty pieces of installed electrical equtpment and associated
items were inspected. Samples were selected based on system function
and safety classification. Additional equipment samples are included
in paragraph 4 of this section.
The following specific electrical components were inspected:
' ) Motors
(1
The installation of two motors and associated hardware was
inspected for such items as location, anchoring, grounding,
identification and protection. The motors were the Emergency
Service Water Pump Motor IP45-C001B and the Emergency Closed
Cooling Pump Motor IP42-C001A.
(2) Electrical Penetration Assemblies
The following containment penetration assemblies were inspected:
1R22-5011, 1R22-5026 and 1R22-5004
The location, type, mounting
and identification were compared with the installation drawings.
II-10
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3
(3) Circuit Breakers
i
i
The following Class 1E circuit breakers were examined to deter-
,
mine compliance with the design and installation documents for
size, type, mounting, system interface, and maintenance:
'
RHR Pump "A" Feeder Breaker EH-1110
HPCS Pump Feeder Breaker EH-1303
Emergency Service Water Pump "A" Feeder Breaker EH-1106
Diesel Generator Breakers EH-1201 and EH-1101
.
RPS Electrical Protection Assembly Breakers 1C71-S003 and
!
IC71-S003A
j
The use of circuit breakers with integral under voltage trip
attachments at the PNPP was investigated.
,
(4) Switchgear and Motor Control Centers
4
The following switchgear and motor control centers were
inspected: Emergency Service Water MCC 1R24-5030 and MCC EF1E2;
and 4.16 KV Switchgear 1R22-S006 and 1R22-S007.
'
The installations were compared with installation requirements
,
relative to location and mounting (welds, concrete anchors and
'
bolting).
Installation inspection records for the above equip-
ment also were reviewed.
,
(5) Station Batteries and Racks
The 125V battery rooms were inspected including the installed
batteries, battery racks and associated equipment. The location,
mounting, maintenance and environmental control for installation
of both Unit 1 and Unit 2 batteries were compared with applicable
requirements and QC records.
!
b. Inspection Findings
,
t
(1) Motors
!
The NRC CAT inspectors observed that the installed configuration
of these motors was in accordance with design drawings and that
installation activities were performed in accordance with proce-
dural requirements.
j
(2) Electrical Penetration Assemblies
Activities observed and documentation reviewed indicated that
the work performed was in accordance to requirements.
.
I
II-11
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One item which was identified related to the certification of
material used in the penetration sleeves. This matter had been
previously addressed by the applicant in a 10 CFR 50.55(e)
,
report.
(3) Circuit Breakers
The circuit breabrs inspected were installed in accordance with
-
design drawings and installation procedures.
An on-site review and discussions with the applicant indicated
that no circuit breakers with integral undervoltage trip
attachments, such as the W DB or GE AK-2 types, are planned for
use in safety-related appTications. Additionally, the applicant
,
has requested the NSSS and the AE to confirm that breakers of
.
the above type have not been specified or supplied for the Perry
Nuclear Power Plant (PNPP).
(4) Switchgear and Motor Control Centers
,
During the inspection of switchgear 1R22-5006, the NRC CAT
inspectors noted cabinet connection bolts of indeterminate
material had been used in cubicles EFH-1204 and EFH-1209. This
I
matter is discussed in Section VI.
(5) Station Batteries and Racks
4
The condition of the battery rooms was found to be in good order,
clean and free of debris. Ventilation systems were installed and
in operation. Access to these areas was controlled by keyed
entry, and the appropriate danger signs had been posted to
indicate no smoking or open flames.
'
i
!
The inspection of the 125V battery racks disclosed that indeter-
minate bolt material was used on the Unit 1 Division 1 and Unit 2
i
l
. Division 2 battery racks. This matter is discussed in Section
VI.
'
!
c. Conclusions
,
i
l
.Except for bolting material discrepancies relative to battery racks
and switchgear cabinet connections, the electrical equipment
inspected was installed in accordance with applicable requirements.
4. Systems Installation
a. Inspection Scope
In addition to the inspection of randomly selected plant components,
the NRC CAT inspectors. designated two plant systems for inspection of
electrical and instrumentation system integrity - the residual heat
removal and the reactor protection systems.
.
II-12
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Within these systems, electrical and instrument components,
cables, associated raceway, signal lines, and supports were
inspected relative to the applicable design documents and
,
construction drawings. The following samples were selected:
RHR System
RHR Pump Motors 1E12-C002B and 1E12-C002C
RHR Pump Motor Thermocouples
1E12-N486, IE12-N485, 1E12-N488 and 1E12-N489
Power Feed to 1E12-C0028 (Cable 1E12H-2B)
Power Feed to 1E12-C002C (Cable 1E12H-38)
Motor Operated Valve 1E12-F004B
,
M0V Control Cables IE12F-12B and 1E12C-40B
RHR Pump B Breaker EH-1208 and Pump C Breaker EH-1212
RPS System
RPS Power Distribution Panels 1C71-001 and IC71-P002
RPS Motor Generator Set IC71-S001B
b. Findings and Conclusions
During the inspection of these systems, the NRC CAT inspectors
observed that not all of the instrument components for these systems
have been installed. Additionally, several of the tubing runs
inspected, which appear to be essentially completed, have yet to
receive QC inspection.
The installation of electrical and instrument components inspected
in the RHR and RPS systems was in accordance with the applicable
requirements. Components reviewed were installed in accordance with
the latest construction drawings and exhibited good workmanship.
Documentation reviewed, including inspection and test records,
indicated acceptable installations and reflected the current
installed configuration.
5. I_nstrumentation
a. Scope
Six instrument panels and five instrument racks, including
associated instrument components and related items, were selec-
ted for inspection from various areas of the plant. The sample
included about 60 safety-related instrument components within
such systems as reactor protection, engineered safety features,
residual heat removal, high pressure core spray, some components
in the main steam line radiation monitor and reactor vessel instru-
mentation sub-systems. The racks ana panels were inspected for
compliance with installation requirements, including location,
protection, mounting / anchoring and separation of redundant components
and panels. Additionally, about 1000 feet of instrument tubing was
inspected against installation requirements relative to location /
II-13
O
e
routing, supports, support location, identification and protection.
The majority of the tubing runs inspected were from the process
connections to the sensors / transmitters installed on the above racks
and panels. Associated tubing penetration assemblies were also
inspected. The type, range, accuracy, material, and similar attri-
butes of 30 of the above installed instrument components were com-
pared with their specification requirements.
Instrument panels, and
associated instruments, inspected in detail included: H22-P001,
H22-P004, H22-P005, P22-P018, H22-P026 and H22-P027 in Unit 1.
b. Inspection Findings
Numerous installed components (mostly Rosemount transmitters) have
failed required qualification tests. The applicant is aware of this
situation'and has tagged the components that require replacement,
and some components have already been removed.
'
A compression fitting was installed in a completed welded-joint
tubing run near valve 1E12F0530A and related to panel P22-P018.
This run was modified by the addition of a compression fitting tee by
Johnson Controls, Inc. (JCI), the instrument contractor, at the
request of the Nuclear Test Section (NTS) of the PNPP project organi-
zation.
It was not clear to the NRC CAT inspectors that this modifi-
cation was appropriately recorded, scheduled for rework and subse-
quent re-inspection. Additionally, the installed tubing clamps were
removed from this tubing and not properly controlled. About 20 feet
was left unsupported and unprotected.
(Procedures pertaining to
modifications requested by NTS and performed by JCI are to be revised
to correct this type of problem.)
In several locations, safety-related instrument tubing ,;as, at best,
marginally protected from damage from adjacent construction activi-
ties and from inadvertant damage which may occur during plant opera-
tion.
It was observed that some non-safety-related instrument tubing
was more suitably protected from damage than some safety-related
tubing.
A choker used for rigging to relocate instrument panel 1H22-026 was
attached to internal panel members and across a section of tubing
rather than attached to the panel frame.
(An NR is to be initiated
to document this condition.)
Although much of the safety-related instrument tubing has been
installed in Unit 1, the tubing is not color-coded as specified. The
applicant indicated that color-coded tape will be applied after
tubing hydro tests.
c. Conclusions
Although some minor discrepancies were noted,' no items of major
safety significance were identified.
In general, the racks, panels,
components, tubing and associated items inspected were installed in
accordance with applicable requirements - or appropriately tagged
and/or recorded as nonconforming.
II-14
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.
6. Design Change Control and Nonconformance Reports
a. Inspection Scope
The design change program and related procedures used at the Perry
site were reviewed.
In regard to electrical and instrumentation
installation activities, 70 LKC ECNs and 50 LKC FVAs were reviewed;
35 JCI ECNs and 25 JCI FVAs were reviewed; and 10 GE Field Design
Instructions and 10 GE Field Design Deviation Requests were reviewed.
The NRC CAT inspectors also reviewed a sample of NRs issued by the
electrical and instrumentation contractors. These reports were
reviewed for items such as content, completeness, timel'iness of
review, proper approval, technical justification, and document
processing. Approximately 45 NRs initiated by the electrical
contractor and 20 NRs initiated by the instrumentation contractor
were examined. Additionally, several reports initiated by GE and
the PNPP Project Quality Organization were reviewed.
b. Inspection Findings
GAI approves design and engineering changes either at their home
office in Reading, PA. or by the GAI assistant project manager at the
Perry site. Processing and control of these changes are in accord-
ance with GAI Interface Procedure, Appendix N.
GAI initiates ECNs,
indicates whether the change is specification or drawing-related and
transmits the ECN package to the project Nuclear Construction Engi-
neeringSection(NCES). ECNs can also be written to accomplish
construction work under the direction of the Nuclear Test Section
(NTS). This work is to be controlled by the Corporate Nuclear
Quality Assurance Program.
For drawing-related ECNs only, GAI may issue the ECN to the affected
contractor prior to transmittal to the project NCES, but only for
minor modifications to electrical conduit routings, conduit and tray
supports, cable terminations and piping supports including
instrument piping supports.
For minor changes only, FVAs may be used. They are generally used
for drawing changes, but may be used for specification changes if no
design change is involved. FVAs can be initiated by either the
applicant or the AE (GAI), but FVAs require GAI approval.
In accordance with site procedures, contractors utilize a nonconform-
ing reporting system to document discrepancies which render the
quality of an item indeterminate or unacceptable. Of the noncon-
forming reports reviewed, it was noted that they had been initiated,
reviewed and processed in accordance with the applicable procedures.
II-15
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c. Conclusions
The general program and procedures established to control
design and engineering changes were, in general, considered adequate.
.
However, two problems were identified that indirectly relate to
design change controls. One problem, as discussed in paragraph 1
.
of this section, pertains to the lack of formal, procedural controls
'
of sketches used for conduit installation activities. The other
-
problem relates to the weakness in the control of changes under the
direction of NTS - as mentioned in paragraph 5 of this section.
Nonconformance reports reviewed were initiated, reviewed and
processed in accordance with the applicaole procedures.
.
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III. MECHANICAL CONSTRUCTION
A. Cbjective
The objective of the appraisal of mechanical construction was to determine
if installed and Quality Control (QC) accepted safety-related mechanical
items conformed to engineering design, regulatory requirements and licensee
commitments.
B. Discussion
The specific areas of mechanical construction that were evaluated were:
piping, pipe supports / restraints, the piping "as-built" program, c.oncrete
expansion anchors for pipe supports / restraints, mechanical equipment and
heating, ventilating and air conditioning (HVAC) systems. To accomplish
the objective, a detailed field inspection of a sample of, QC accepted
hardware was performed in each area.
In addition, certain programs,
procedures and documentation were reviewed as required to support or
clarify hardware inspection findings.
1. Piping
a. Inspection Scope
Ten piping isometric drawings were selected and the installed piping
inspected for conformance to design and procedural requirements.
The installed piping was examined for pipe identification (via ASME
Code Data Plates), proper configuration, valve identification, valve
and valve operator orientation, bolted flange makeup, interference
and support / restraint location (partial). As a result of a problem
identified during the inspection with valve / valve operator orienta-
tion, an additional 10 valves were selected to verify conformance of
their orientation to that shown on the isometrics. Approximately
eight flanged joints were inspected for proper gasket and bolting
material and proper makeup.
See Table III-1 for a listing of the
piping inspection samples and observations.
The following documents provided the basic acceptance criteria for
the inspections:
Pullman Power Products Procedure IX-3, Rev 4/5/83,
" Fabrication and Field Installation Specifications for
,
Nuclear Power Plant Components, Piping Systems and Appur-
tenances ASME-Section III"
Pullman Procedure IX-5, Rev 1/31/83, " Torquing of Flanged
Joints in Piping Systems"
Pullman Procedure VI-5, Rev 8/12/82, " Control of Process
Sheets and Weld Rod Stores Requisitions"
Pullman Procedure X-4, Rev 6/8/81, " Final Inspection
(Field)"
Applicable piping isometric drawings
III-1
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b. Inspection Findings
In general, the piping runs inspected were found to conform to
requirements for the attributes verified. Hcwever, one bolted valve
and two valve operators were not oriented as shcwn on the iscmetric
drawings. As a result of these observations the NRC CAT inspectors
selected 10 additional valves for inspection of proper orientation
(See Table III-1). Three of these valves and one of the valve
I
-
operators were oriented in conflict with the isometric drawing. It
should be noted that three of the seven valves oriented in conflict
with the isometric drawings had been "as-built certified."
Even though some of the valve installations had been "as-built",
Pullman, the responsible contractor, does not inspect piping for
configuration, valve orientation, flow arrows, and other similar
attributes until the final turnover walkdown inspection per their
Procedure X-4.
Also, none of the valves in question had been
inspected for joint makeup per Procedure IX-5.
However, joint makeup
process sheets do not specify or require verification of proper
orientation. The NRC CAT inspectors do not consider the current
scheduie of piping / equipment configuration (construction acceptance)
inspection tc be timely, nor prudent from a potential rework / repair
standpoint.
ln addition, the NRC CAT inspectors do not consider the
Pullman final walkdown procedure, Procedure X-4, to be specific with
regard to the detailed inspections required, the applicable inspec-
tion / acceptance criteria and the methods of dispositioning unsatis-
factory conditions; i.e., punchlists, deficiency reports, or noncon-
formances.
c. Conclusions
(1) With the exception of valve and valve operator orientation,
no major hardware deficiencies were identified in the
piping runs inspected.
(2) Valves and valve operators are being improperly installed
by the crafts and the "as-built" program has failed to
identify the discrepancies.
(3) The construction acceptance inspections for certain piping
features are not being performed in a timely manner and the
final piping turnover walkdown procedure lacks specificity
regarding responsibilities, inspection / acceptance criteria
and discrepancy processing.
2. Pipe Suoports/ Restraints
a. Inspection Scope
Twenty-eight QC accepted safety-related supports / restraints were
selected for inspection which provided a variety of types, sizes,
systems and locations. These supports / restraints were inspected for
configuration, identification, location, fastener / expansion anchor
III-2
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
_
__
__
_
.
.
installation, clearances, member size and damage.
In addition,
approximately 50 unidentified safety- related supports / restraints
were observed in the field for obvious deficiencies such as loose or
missing fasteners, improper clearances or angularity, damage and
improper concrete expansion anchor spacing.
The NRC CAT inspectors also selected and inspected eight Class 4
supports / restraints. These supports / restraints are installed on
fire protection systems or, although not installed on safety-
related piping, have a safety function due to their proximity to
safety-related items. They are designed to seismic Category I
requirements and must not fail during seisn! c/ accident condi-
i
tions. See Table III-2 for all of the pipe supports / restraints
inspection samples.
Acceptance criteria for the field inspections are contained in
the following documents:
Pullman Procedure VII-2, Rev 12/2/82, " Material Control"
Pullman Procedure VIII-1, Rev 9/8/82, " Procedure for
Identification of Materials, Parts and Components"
Pullman Procedure IX-6, Rev 7/21/83, " Installation and
Inspection of Pipe Supports"
Gilbert Drawing, 4549-5-322-002, Rev C, " Pipe Support
Dimensions and Tolerances"
Gilbert Drawing, 4549-5-322-004 Rev C, " Pipe Support Erection
Standards"
Power Piping standard drawings and catalogues
l
Applicable support / restraint detail drawings
ITT Grinnel Special Installation Instructions (GE
Supports / Restraints)
b. Inspection Findings
General Electric Company (GE) is responsible for the installa-
tion and inspection of approximately 154 Unit 1 safety-related
supports / restraints for two systems, Reactor Recirculation
and Main Steam (MS), in accordance with Cleveland Electric Illumi-
nating (CEI) Specification 38. As none of these ITT Grinnel Fabri-
cated supports / restraints were in a final, QC accepted condition,
only one support was inspected in the field for proper configuration.
No problems were identified. The NRC CAT inspectors reviewed in
detail the partially completed travelers gov aning the installation
of GE supports 1 B33-H355A and 1 B33-H301A. No problems were identi-
fied. The final assembly and adjustment travelers were still in
preparation.
III-3
- ______________________ ____________
.
.
.
Pullman Power Products (PPP) is responsible for the installation and
inspection of the remainder of the safety re-lated and balance of
plant pipe supports / restraints. Gilbert Associates, Inc. provides
the detailed support / restraint design draw;ngs which are redrawn by
the hardware fabricator, Power Piping. Pullman adds field weld
numbers and any applicable change documents such as Engineering
Change Notices (ECN's) or Field Variance Authorizations (FVA's) and
issues the drawing to the field for installation.
Pullman performs QC inspection of safety related supports / restraints
in three phases as follows:
Phase I - Verification of primary attachment to the building
structure.
Phase II - Verification of installation details of completely
installed assembly.
Phase III - Verification of final settings, clearances, tight
fasteners, completeness and freedom from damage just prior to
system turnover.
Of the approximately 13,200 large bore and 4,600 small bore safety
related supports / restraints in Unit I and common areas, approximately
2,900 had been Phase II inspected at the time of the NRC CAT inspec-
tion. Class 4 (nonsafety-seismic) support / restraints are also QC
inspected for proper installation.
Inspections are documented on
detailed checklists.
Discrepancies identified on QC accepted supports / restraints by
the NRC CAT inspectors are listed in Table III-3.
In summary,
three out of 28 safety related supports / restraints, six adjacent
supports / restraints and two of eight Class 4 supports / restraints
were found not to conform to design requirements. In addition,
one Class 4 installation had been QC accepted with an inadequate
weld size and wide flange shape size specified on the drawing
(1P11-H098).
The following miscellaneous discrepancies were also identified
during the NRC CAT inspection activities:
Restraint 1E32-H100 had been disconnected from the pipe,
but had a Phase II tag attached contrary to the require-
ments of Procedure IX-6.
It was later determined that no
Phase II inspection checklist existed for this restraint.
The travel stop had been removed from spring hanger IP42-H225
prior to the Phase III inspection.
Clamp bolt threads were not staked on support 1G36-H062.
This item would have been verified again during the Phase
III inspection.
III-4
.
-
_ - _ - _ _
-
.
.
The Phase II checklist for restraint 1E12-H748 was signed, dated
and on file but none of the checklist items had been marked as to
whether the iteins were acceptable, unacceptable or not appli-
cable.
The welding process sheets for supports 1P42-H1043, IP45-H360,
"
IE12-H178 and IC11-H516 (four of 12 examined during the observa-
tion of in-process welding activities) did not indicate the
latest Pullman issue number of the installation drawing; some as
many as five issues behind.
However, each work package did
contain a copy of the latest issued drawing.
Three supports / restraints (1821-H006,1E12-H010 and 1E12-H614)
were found to have potential clearance problems with other
structures. There were no seismic clearance violation (SCV)
stickers in these areas indicating prior identification by the
SCV inspection group.
Even though overall " area" inspection
effort by the SCV group may at some point identify these clear-
ance problems, the NRC CAT inspectors consider that clearance
criteria should be clearly specified for hardware installation
and that each contractor should verify proper clearance for their
hardware prior to and during acceptance inspections. This will
provide greater assurance that all clearance problems will be
identified and resolved and minimize rework / reanalysis efforts.
See Section V of this report for more details on the SCV inspec-
tion group activities.
During this review, controls that Pullman exercises to maintain
required traceability of supports /restaints were evaluated,
This is
discussed in detail in Section VI.
,
Several Pullman QC inspectors and field engineers and CEI QC Surveil-
lance personnel were informally observed and interviewed in the field
by the NRC CAT inspectors. These personnel appeared to be know-
ledgeable of their responsibilities and of the requirements of the
activities they were performing.
c. Conclusions
(1) No extensive or gross structural integrity problems were
identified on installed supports / restraints.
(2) Some ASME Section NF (safety related) and Class 4 supports /
restraints that had been QC accepted were found by the NRC
CAT inspectors to be nonconforming with design drawing and
procedural requirements.
III-5
_
_
_ _ _ - - -
.-
.-
_ _ - _ _
.
.
3. As-Built Program (Pullman)
.
a. Inspection Scope
The NRC CAT inspectors reviewed approximately 10 redlined drawings
from the as-built field files. Also reviewed were the as-built
procedures and program activities of Pullman field engineering,
drafting and QC personnel, as well as the CEI Nuclear Construction
Engineering Section.
Three of the piping runs and eight of the pipe supports / restraints
inspected as detailed in Sections III.B.1 and III.B.2 had been
"as-built certified" by Pullman Power Products,
b. Inspection Findings
Discrepancies between installed hardware and drawings were noted
on six cut of 11 " certified as-built" drawings included in the
NRC CAT piping and pipe support / restraint samples. See Tables
III-1 and III-3 for listings of identified discrepancies.
The review of "as-built" documentation and program activities
indicated several additional deficiencies and weaknesses. For
restraint IP11-H059, the field redlining was performed and the
certified "as-built" issued against ECN 12198-45-890 Rev. A, but
ECH 12198-45-890 Rev. C was the current revision listed on the
Pullman issued installation drawing.
Procedure X-24, " Procedure
for As-Building Piping Systems and Components," is not being
followed in that QC is not involved in all walkdown inspections,
walkdown teams are not signing and dating redlined drawings in
all cases (IP45-H529,1P45-H485) and the field engineering group
is not determining conformance of hardware to erection toler-
ances.
It should be noted that PulIman personnel were aware
that this procedure was not being followed, but had not taken
corrective action.
The NRC CAT inspectors consider that Procedure X-24 needs to more
clearly define who determines when redlined dimensions are out of
tolerance and, if so, what specific action is to be taken. The
Pullman drafting group has issued at least four "as-builts"
(IP45-H590, 1P45-1176, 1E12-H2002, IP45-H1277) and has numerous
others in the final stage of preparation that had been identified
informally to Pullman QC as having conditions requiring determination
,
of acceptability (conflicts between redlined information and the
latest design drawing) but, for which no response had been given.
Procedure X-24 is also unclear and is inconsistently being applied
regarding the determination of elevation, location and concrete
expansion anchor diameter and length for supports / restraints.
A review of the CEI program to review "as-builts" as detailed in
Site Project Administration Procedure 0303, Rev. 1, "As-Built
Drawings" indicated a thorough engineering review.
In fact, this
review has been resulting in rejection of a high percentage of
Pullman "as-built" drawing submittals since April 1983.
From April
III-6
.
.
- _ _ _ _ _ _ _ _ _ .
- -
.
-
-
-
-
_ . _
.
.
through July, 1017 of 4164 support / restraint "i Nuilts" (24%) and
645 of 1667 piping "as-builts" (39%) had beer
ted by CEI.
Most of the submitted "as-builts" have been
safety related
hardware. However, the same people and proces, re "-M
for safety
related work. CEI QC involvement in the "as-built" t.rfort appears to
be limited and CEI's program has not effectively identified and
rectified significant deficiencies in the Pullman "as-built" program.
The NRC CAT inspectors reviewed the Gilbert Associates, Inc. site
procedure " General Procedure for IE Bulletin 79-14", Rev. 3, detail-
ing actions to meet the requirements of IE Bulletin 79-14, " Seismic
Analyses for As-Built Safety-Related Piping Systems". Related
program activities were discussed with the Gilbert Site IEB 79-14
Coordinator. This review revealed that the 79-14 program is essen-
tially a separate Gilbert executed program, involving walkdown
redlining of piping and valve data verification. However, as Pullman
support / restraint "as-builts" are utilized as input to the 79-14
~
evaluation, inaccuracy in Pullman's program may affect the safety
system analysis,
c. Conclusion
The review of procedures and the "as-built" program implementation
reflected by hardware and documentation deficiencies, indicate a
number of discrepancies and weaknesses in the Pullman "as-built"
program. Pullman and CEI have not taken prompt action to correct
previously identified deficiencies in the 'as-built" program.
'
4. Concrete Expansion Anchors for Pipe Supports
a. Inspection Scope
Twenty eight pipe supports / restraints containing 108 concrete anchors
were inspected for proper torque. Table III-4 provides a listing of
supports and torqueing results. The supports were installed in eight
different safety related systems and contained anchors ranging in size
from 5/8" to 1-1/4" diameter . Additional examinations performed by
the NRC CAT inspectors included verification of the proper length
,
marking on the anchor, installation of washers, proper engagement of
nut, and measurement of the length of anchor extending from the
concrete (only for those anchors that appeared excessive). The
Pullman Power Procedure IX-6 " Installation and Inspection of Pipe
Supports" dated 7/21/83 was reviewed as part of this activity,
b. Inspection Findings
(1) Torqueing
The vast majority of nuts exhibited no rotation when the
minimum specified torque (per ECN 10493-44-1641 Rev. C) was
applied. The maximum rotation was 3/16 of a turn for one
nut.
III-7
-
_ _ - _ .
.
..
..
-
.--_
_
-
-_-
.
.
(2) Nut Engagement
All anchors were at least flush with the top of the nut per
the procedurtI requirements.
(3) Anchor Embe hent
To verify proper anchor embedment, the anchors that had 2 inches
or more of standout from the concrete were noted and the embed-
ment for these anchors was calculated and compared to drawing
requirements. A :otal of five anchors on four supports equaled
or exceeded 2" of standout. Four of the five (three supports)
had less than the specified minimum embedment, ranging from 1/4
to 1/2 inch. See Table III-5 for a comparison of data on these
anchors.
(4) Miscellaneous Discrecancies
One anchor on support (1G41-H253) did not contain a marking.
An ultrasonic examination (UT) performed on both anchors on
this support verified that they were the specified length of
10 inches.
On support 1G36-H1024, there were no washers ir. stalled on the 2
anchor bolts as required. Nonconformance Report (NR) CQC 2880
was issued for this condition.
c. Conclus'ons
i
(1) The Field Process Sheet for the concrete expansion anchors do not
contain a signoff for verifying bolt diameter. The bolt identifi-
cation marking relates to length only. Although not a hardware
problem for the sample selected, it is conceivable that without
this verification, improper torques could be applied in addition
to installing improper sized bolts.
'
(2) With the exceptions of missing washers and the anchor embedment
on three hangers no hardware problem was identified. The appli-
cant should provide justification that expansion anchor embed-
ments are adequate and are being properly inspected.
5. Mechanical Eouipment FSAR Comparisens
a. Inspection Scope
A sample of mechanical equipment was reviewed to determine that
purchase specification requirements conform with FSAR commitments
and whether installed hardware conforms with supplier documentation,
purchase specification requirements and FSAR commitments. To accom-
plish this task, equipment from the RCIC and RHR systems were chosen
because of preponderance of operational data given in the FSAR for
these systems. Nine components were reviewed including an RHR pump,
an RCIC pump, an RCIC turbine, and several RCIC valves. Table III-6
III-8
._.
.
.
provides a listing of the inspected equipment along with the opera-
tional parameters reviewed. Table III-7 provides a listing of
documentation reviewed.
b. Inspection Findings
A summary of discrepancies is provided in Table III-8. Of the five
discrepancies noted, three require revision to the FSAR. The other
two require follow-up action by CEI to assure that acceptable
material is installed.
It should be noted that CEI had previously
uncovered the problem or problems of a similar nature for the dis-
crepancies identified by the NRC CAT inspectors. The more signifi-
cant discrepancies are discussed below.
(1) RCIC Isolation Valve (F063) Not Meeting FSAR Requirements
The NRC CAT inspector discovered that a discrepancy (non-
conservative) exists between the purchased RCIC Isolation Valve
(F063) and the FSAR commitment (see Table III-8).
In 1979,
Gilbert suggested changing this valve from being normally open to
normally closed (along with other modifications) so as to reduce
the energy release from a rupture in the 4" RCIC steam supply
line. Because of the logic change, less stringent requirements
for the valve from that shown in the FSAR were apparently pos-
sible. The NRC CAT inspector did not verify the adequacy of
these requirements since these requirements will be reflected in
a FSAR revision and will receive appropriate review at that time.
CEI was aware of problems between the FSAR and system design
descriptions prior to the NRC CAT review as evidenced by their
1982 audit of Gilbert which identified two discrepancies between
system design and FSAR commitments. Action Requests (ARs) were
issued requiring complete FSAR review by Gilbert against system
design descriptions. As a result of the NRC CAT inspection,
the appl b nt has commited to include procurement specification
requirements > the FSAR review. Additional programs include a
CEI FSAR VerificaMon Program and a future audit of GE's procure-
ment program.
Proctdures have not yet been developed for the
CEI FSAR Verificatio i Program, so that its adequacy cannot be
determined.
A Gilbert Procedure entitled Technical Document Revision (#QAP
3.1) dated 2/14/83, requires that the procurement document be
reviewed to verify that the design criteria are consistent with
SAR commitments. There is no evidence that this procedure was
followed or if another program / procedure was applicable to the
valves and pumps in question. The NRC CAT inspectors do not
consider FSAR verification after all equipment is in place to be
either prudent or timely from a potential equipment replacement
standpoint or from a re-analysis standpoint.
III-9
.
-- -.
_
_
-
- . _
.-
,_.
.
.._
.
-__
-
-
. =
.-
_
-
..
_ .. _
.
.
(2) Incorrect Actuator Model # on RCIC Suction Valve (F031):
This discrepancy was initially identified by CEI in the summer of
1982 after the valves and actuators had been installed in the
field.
In addition to identifying valve F031, CEI identified
over 100 valves containing actuator models which differed from
the design. The identification of these valves by CEI was part
of an inventory program (no procedure identified) for ordering
spare parts. A fornal procedure existed which, if followed,
should have identified the problem prior to the arrival of valves
and actuators on site. Section C.1.K of Gilbert's Manufactur-
ing Surveillance Plan 043, Rev. O dated 2/6/78 requires final
inspection of 50% of each type of valve for the correct specif.ied
motor operator (actuator). With over 100 valves not in compli-
ance with the design, there was an obvious breakdown in this
procedure. Gilbert has contacted the valve manufacturers (Borg
Warner and Contromatics) to assure that the installed actuators
are suitable for the specified conditions. The NRC CAT inspec-
tors observed no documented evidence that the valve manufacturers
had responded.
c. Conclusions
(1) The depth and importance of the FSAR verification effort should
be emphasi::ed, since there is an obvious conflict between pur-
t
chased equipment and what the designer intended as reflected in
the FSAR. These efforts should be adequately administered so
that the equipment in the field satisfies the FSAR commitments.
Furthermore, effective programs should be in place to verify
that equipment currently being purchased satisfy FSAR
requirements.
(2) While the discrepancies involving over 100 valves containing
a
actuator models which differed from design were identified by
CEI, the identification was part of an inventory program for
spare parts. The Gilbert manufacturing surveillance procedure
that should have been followed to identify discrepancies of this
type was apparently not followed and corrective action to prevent
re-occurrence was not initiated.
6. Heating, Ventilating and Air Conditioning (HVAC)
a. Inspection Scope
HVAC systems installation work is essentially complete in Unit 1
and common areas. The contractor for HVAC is the Robert Irsay,
Co. (RIC0) who fabricates, installs, inspects and leak tests
systems in accordance with Gilbert design drawings and specifi-
cations.
System M40 and portions of M15, M36 and M30 have been
turned over to CEI.
The NRC CAT inspectors selected samples of 10 supports / restraints, 15
pieces of equipment and 22 duct segments for field verification of
conformance to design and procedural requirements. Duct joint makeup
III-10
.
'm,iwen-e
e
-iw
o- - - .
-w
w-=,
?i.-..-
-
.v.e.y-.,_
rwa
m
.9-
-e--e
---.--s
--..-----.-ppg
= _ = -
. - . -- .
. _ - - - .
.- - --
.
a
.
i
was examined on numerous other unidentified duct segments during
other NRC CAT inspection activities. Features verified were config-
uration, member size, identification, weld size, fastener / expansion
anchor installation, duct gasketing and bolting. See Table III-9 for
a listing of inspected items.
The following documents provide the acceptance criteria for HVAC
hardware installations:
-
The Robert Irasy Company (RICO) Quality Assurance Manual
RICO procedure QCP-6-4/707, Rev 2, " Installation Inspection of
Safety Related Drilled in Concrete Expansion Anchors"
RICO Procedure QCP-11-5/707, Rev 4 " Inspection of Seismic
Supports"
RICO Procedure QCP-11-6/707, Rev 2, "HVAC System Walkdown
Inspection"
RIC0 Seismic Duct Brochure
j
RICO Drawings 0-937-901, 902, 903, 905, 906, 907, 908, sad 909,
" Duct Support Standard Connections" and D-937-920, "At-
ment
Schedule"
1
l
Applicable construction drawings and fab tickets
b. Inspection Findings
Two of the 10 supports / restraints inspected had significantly
undersized member to building structure attachment welds. Three
adjacent supports also were observed to have undersized attach-
ment welds and similar findings by the NRC CAT welding inspec-
tors are detailed in Section IV.
RICO QC stated that they
believed these inadequate welds could be traced to inspections
performed by one individual who was on site from May 1979
,
through June 1980 and who is no longer employed on-site. A
reinspection of the suspect supports and a sampling of supports
inspected and accepted by the previously employed inspector and
j
others was performed by RICO QC.
Preliminary results of this
'
reinspection indicated that, although deficiencies were noted in
the work of several additional inspectors, the largest percentage and
most technically significant problems were identified on supports
inspected by the one inspector.
In fact, RICO quality management had
been aware that the work done by this individual was suspect and the
site lead QC Technician had stated this in an internal memorandum on
June 8,1982 to the RICO QA manager. The memorandum also stated that
a complete reinspection of the work performed and inspected by this
individual was proceeding. However, there does not appear to be any
documentation to consolidate the work scope of this individual nor
has all his work been completely reinspected some 15 months later.
A RIC0 review of nonconformance reports (NRs) issued between May
1982 and May 1983 revealed at least 39 NRs directly attributable to
,
III-11
,
e
v..--y.--~--
-- - . ~ , _
y v
,, - -
,---,y--,,
,--- --- ._,
~y
-,
.
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, , - , , , , - - _ , - - - - - . - - - , - - - - - - - - -
.
.
this individual's work and 7 additional NRs that may be attributable
to him. This amounted to approximately 27". of all NRXs issued during
that period. The conditiors reported included m'issing and undersized
welds, improper configuration and inadequate documentation. Many
1
required rework or repair.
In general, the NRs identified the
unsatisfactory work as done by craftmen and inspectors no longer on
i
site. All NRs are reviewed by RICO and CEI management and CEI
quality engineers perform a trend analysis on NRs. However, neither
organizations' programs identified this significant and recurring
problem as needing timely and formal corrective action or evaluation
for reportability.
It should be noted that the current inspection
program, although not per procedure as described below, would
probably have identified the deficiencies present in currently
accepted work.
Related to the above issue, and possibly indicative of a general
weakness in procedural matters, were a number of relatively minor but
related problems identified during the NRC CAT review of in-process
turnover documentation packages. RICO procedure QCP-11-6/707 speci-
fies a three phase sequenced walkdown inspection of a duct system;
pre-leak test, post leak test and a " final" inspection. RICO QC is
performing the " final" inspection prior to the pre-leak test inspec-
tion. Due to the known problems with earlier inspections, RICO QC is
now performing a detailed inspection of supports / restraints during
the " final" walkdown. While this is a correct action to take, it is
not required or defined by site procedures.
In addition, RIC0 QC
does not have a specified or executed means to void out existing
QC inspection documentation when rework is required to QC accepted
hardv re. Also, in the review of the " final" walkdown deficiency
punalist for systems OMIS and 1M36, a number of instances were
diu. overed where conditions were being identified and closed cn the
punchlist that should have been identified on nonconformances.
Examples include missing welds on supports DS-0G-2001-and 2002,
improper washers installed on supports DS-0G-4025 and 0S-1B-3126
and undercut welds on support DS-IB-4059. Finally, the responsibili-
ties and processes for teveloping "as-built" drawings are not clearly
defined by site procedures.
Minor discrepancies were noted during the inspection of supports /
restraints,' equipment and duct runs and are summarized in Table
III-10.
c. Conclusions
(1) With the exception of undersized attachment welds, HVAC
hardware material, configuration, location and installation
appeared to generally conform to design documents.
(2) The work performed by certain craftsmen and/or inspectors
appears to have been deficient, especially as identified
with undersized structural attachment welds.
III-12
____
- _ _ - _-.
_
._ - _ _ _
_ -
.
.
.
,
(3) The quality assurance programs of both RICO and CEI failed to
'
properly and promptly identify, evaluate, correct and document
potentially significant and recurring deficiencies in instal-
led HVAC hardware.
(4) Additional attention is needed to ensure that RICO site proce-
dures are adequate and work as specified in these procedures is
correctly performed.
7. Design Change Control and Nonconformance Reports
a. Inspection Scope
Seventy NRs were reviewed in the mechanical area for technical
adequacy and to determine if the NRs were properly closed in accord-
ance with the approved disposition. Twelve hanger supports were
selected when work was in-process to determine if design changes
were properly controlled.
~
b. Inspection Findings
Nonconformance reports reviewed were dispositioned adequately. With
one exception, reports reviewed indicate proper closecut. Noncon-
formance Report CQA 136 dated 1/30/80 was improperly closed out in
that the action required for close out [i.e., the listing of compo-
nents and supports requiring the use of Code Case N-242 must be
identified in the Safety Analysis Report (SAR)] was not accomplished.
The NR required as part of its disposition that an FSAR change be
submitted. However, the NR was inappropriately closed and no FSAR
change was submitted. This NR involved the acceptance of a large
number of safety-related pipe spools.
Relative to design changes, traveler packages in the field were
reviewed te revisions on both the applicable drawing and process
sheets. This information was compared to the current information
regarding the latest design for each of the subject hangers. No
problems were identified.
!
c. Conclusions
.
Because of improper close out of CQA-126, the requirements under NRC
Regulatory Guide 1.85, Revision 16 could not be satisfied. This
l
Regulatory Guide requires that components and supports that are
accepted by the use of Code Case N-242 be identified in the SAR.
Similar examples of improper closecut of nonconformance reports are
discussed in Section VIII under Corrective Action Systems.
Design changes reviewed indicated that they were processed in
accordance with the applicant's program requirements.
III-13
.
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- _ . _ . _ . , .
,-
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, _ _ _ . _ , _ _
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, . . _ , , _ . ,
_
-._
.
-
___
._
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..
.
.
,
TABLE III
1
PIPING INSPECTION SAMPLES AND OBSERVATIONS
Pipe
Observations
System
Isometric
Class
Diameter
(AR/NR Issued)
1&2
12" & 18"
2
12" & 18"
2
8"
2
8"
2
12"
FPC&C
OG41-9*
3
10"
Valve F557B rotated
90 degrees (NR PPP-4005)
FPC&C
OG41-27
3
10"
.
OP42-31*
3
10"
Valve operator F445
rotated 180 degrees
(NR PPP-4005)
OP42-32
3
10"
OP42-34
3
10"
Valve operator F260
,
rotated 90 degrees
-
Additional Valves Selected for Orientation
Valve
Isometric
Observation
F140
OP43-29
,
l
F787
OP43-29
F551
OG41-39
F280
OG41-39
F285
OG41-39
F060
OP50-15
Valve rotated 86 degrees
F780
OP43-28*
Handwheel rotated 180
degrees
F150
OP50-5
Valve rotated 90 degrees
F060
OP50-8
Valve rotated 86 degrees
F785
OP43-19
,
- "As-built certified"
III-14
_ _
..
.
.
TABLE III - 2
PIPE SUPPORTS / RESTRAINTS INSPECTION SAMPLES
Support / Restraint
Type
Class
Size
Location
1821-H006
3
14"
Reactor
U-bolt
3
10"
Control
Strut
3
10"
Control
IB21-H117
3
10"
Reactor
IP42-H148
Box / Lug
3
12"
Control
IP45-H167
Spring
3
20"
Auxiliary
Box
3
12"
Intermediate
U-bolt
3
10"
Intermediate
IP45-H447
Box
3
8"
Diesel
- 1E22-H024
2
16"
Auxiliary
Box
2
2"
Auxiliary
Spring
2
18"
Auxiliary
Box
3
10"
Intermediate
IP45-H147
Strut / Box
3
16"
Auxiliary
,
1821-H223
Box / Lug
3
2"
Reactor
IC11-H032
Box / Strut / Lug
2
8"
Reactor
Strut
3
4"
Reactor
Spring
3
8"
Reactor
IB21-H414
Box
3
12"
Reactor
- 1E12-H1061
Box
2
11"
Auxiliary
- 1E12-H1041
Box
2
11"
Auxiliary
- 1E12-1062
Strap
2
3/4"
Auxilia ry
Box
1
12"
Reactor
IE21-H014
Spring
1
12"
Reactor
1
12"
Reactor
Restraint
1
6"
Auxiliary
U-bolt
2
4"
Reactor
- 1B33-H352A
Spring
1
16"
Reactor
- 1P11-H059
Strut / Lug
4
8"
Reactor
IP54-H017
Box
4
4"
Reactor
- 1P11-H098
Strut
4
12"
Auxiliary
Strut
4
12"
Auxiliary
IP54-H199
Strut
4
6"
Intermediate
- 1P11-H065
4
8"
Reactor
IP54-H1011
Strap
4
li"
Auxiliary
- 1P11-H056
Box
4
8"
Reactor
- "as-built certified"
- General Electric installation
,
i
III-15
L
--
--
-_
_
.
.
TABLE III - 3
PIPE SUPPORT /RESTRAlflT INSPECTION OBSERVATIONS
Support / Restraint
Observation (AR/NR/DR Issued)
'
\\
Safety Related Samole
1821-H006
1/8" clearance to drywell liner (SCV-2544)
No clearance between pipe and U-bolt (NR PPP-4135)
- 1E22-H024
Load pin spacers 1/8" thick vs. 1/16" on drawing
Attachment plates switched in position "As-Built"
(A.B.) pin to pin dimension in error
(NRCQC-2865)
IE12-H138
Loose U-bolt nuts
,
I
- 1E12-H1062
2 attached hangers not shown on A.B.
Phase 11 checklist on file incompletely filled out
Contact point on drawing has 1" gap (NR P044-2164)
i" clearance to decking
Adjacent Safety Related
size U-bolt and non-safety material installed
Wrong (NRCQC-2877)
1G36-H1046
Threads on U-bolt had been extended by crafts
(NRCQC-2878)
Phase III tagged, clamp bolts not staked
IP42-H225
Travel stops removed (NR PPP-4034)
No washers over slotted holes (Procedure IX-6,
Rev. 8/10/82, Para. 8.4.6).
Clips for sliding
connections welded-not shown on drawing
(NRPPP-4114)
No washers over slotted holes (Procedure IX-6,
Rev. 8/10/82, Para. 8.4.6).
Clips for sliding
connections welded-not shown on drawing
(NR PPP-4114)
I
.
III-16
I
.
.
I
TABLE III - 3 (Continued)
Support / Restraint
Observation (AR/NR/DR Issued)
No washers over slotted holes (Procedure IX-6,
Rev. 8/10/82, Para. 8.4.6).
Clips for sliding
connections welded-not shown on drawing
(NR PPP-4114)
IP45-H458
No washers over slotted holes (Procedure IX-6,
Rev 8/10/82, Para. 8.4.6).
Clips for sliding
connections welded-not shown on drawing
(NR PPP-4114)
Support disassembled, Phase II tag attached,
no Phase II checklist on file (AR 704)
Class 4 Sample
- 1P11-H058
Clip angles installed 2}"x21"x3/8", drawing
specifies 3"x3"x3/8"
Strut angularity exceeds erection tolerances
DCC issued drawing without latest ECN Revision
As-built walkdown and drafting performed to
superceded ECN Rev (DR 2391)
- 1P11-H098
Drawing specifies 1/16" attachment fillet weld
and shape that is not manufactured. Baseplate
is 1" thick vs. 3/4" on drawing (DR 2394)
Pipe attachment location off by 4-3/4" (DR 2392)
Nowashersbetweennutandbaseplate(NRCQC2880)
- "as-built certified"
III-17
.
.
. ..
- _ _ _ _ _ _ _ _ _ _ _ _ __
_--_ -__
-
. - -
_-_
_
.
8
O
TABLE lIl-4
i
l
CONCRETE EXPANSION ANCHOR SAMPLES AND OBSERVATIONS
Support / Restraint No.
Observations (1)
i
One nut rotated 1/8 turn
One nut rotated 1/8 turn
One nut rotated 1/8 turn
i
1P57-H1052
IG41-H253
One nut rotated 1/8 turn
1G41-H362
Two nuts rotated 1/16 turn
!
Three nuts rotated 1/16 turn
Two anchors with 3 3/4 inch standout
One nut rotated 3/16 turn
One anchor with 2 1/2 inch standout
Two nuts rotated 1/16 turn
IE21-H053
4
1E21-H1010
,
1E21-H026
One nut rotated 1/16 turn, One nut
,
rotated 1/8 turn
One anchor with 2 inch standout
1E32-H152
1G36-H036
IP42-H1164
One anchor with 2 inch standout.
.
One nut rotated 1/8 turn
1P42-H1219
,t
NOTE:
'
(1) Observations were made.after the minimum specified torques (per ECN
10493-44-1641 Rec. C) was applied to the nuts.
i
e
l
l
l
i
l
III-18
,
!
.
. _ . _ _ . _ _ . . , . . . .._ . _ _ .
. _ . _ . . _ - . . _ _ _ _ _ . _ . . . . _
_
_ _ ,., ,_=,. .
_ . _ . .
_ . _ ,
_ _ _ _ _ _ -
_ _ _ _ _ __ . _ _ _ __ _ _ .-_.
.
.
.
.
4
TABLE III-5 - EMBEDNENT OF CONCRETE EXPANSION ANCHORS
4
Measurement (Top
Marking
Minimum
of Bolt to
Computed
Required
i
i
Support / Restraint No.
on Bolt
Length (in.)
Concrete) (in.)
Embedment (in.)
Embedment (in.)
i
T
12
3 3/4 (2 bolts)
8 1/4
8 1/2
IE21-H030
R
10
2 1/2
7 1/2
8
1
0
8 1/2
2
6 1/2
6 7/8
1
0
8 1/2
2
6 1/2
5 1/2
4
4
l
i
C
xL
e
l
i
o
i
I
I
i
9
.
'
,
4
'
~
j
.
_ _ _ _ _ _ _ _ _ _
.
.
TABLE III-6
MECHANICAL EQUIPMENT FSAR COMPARISONS
-
Serial #/(Actuator Model)
Operational Parameters
Field
MPL No.
Equipment
Documentation
Observation
Item
Specs.
E51-C001
RCIC Pump
15210030
15210030
Total Pump
725gpm
725gpm
Discharge
Water Temp.
40 F to
40 F to
Range
140 F
140 F
21 ft. min.
21 ft. min.
Developed
2980 Ft.'
2980 Ft.1
llead
610 ft.2
610 Ft.2
,,
-
)[
BilP, Not
825 IIP 3
825 llP3
o
to Exceed
150 HP4
150 llP4
l
Design
1525 psig
1525 psig
Pressure
Design
40 to
40 to
Temperature
140 F
140 F
NOTES:
8 At 1192 psia reactor pressure
2 At 165 psia reactor pressure
3 At 2980 feet developed head
'8 At 610 feet developed head
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
-
_
.
-,
.
TABLE III-6
.
MECHANICAL EQUIPMENT FSAR COMPARISONS - Cont.
Serial #/(Actuator Model)
Operational Parameters
Field
MPL No.
Equipment
Documentation
Observation
Item
Specs.
E51-C002
RCIC Turbine
38176-A
Steam Inlet
1150gsia,
1150gsia,
Pressure
min.
min.
,
'
150 min.c
150 min.6
Turbine
25 psia,
25 psia,
-
Exhaust
max.5
max.5
Pressure
25 psia,
25 psia,
.
max.6
max.C
i
l
Design Inlet
1250 psig
1250 psig
7
7
gj
Pressure
$3
Design Exhaust 165 psig
165 psig
7
7
Pressure
E51-F045
RCIC Steam Supply Valve 60810
60810
Max. Opening
15 sec.
15 sec.
(SMB-0-25)
(SMB-0-25)
and/or Closing
Time
Differential
1400 psi
1400 psi
Pressure
!
Notes:
,
S H.P. Condition
6 L.P. Condition
7 At Saturated Temperature
-
_-____
_ _ .
.
.
'
T/.8LE III-6
MECHANICAL EQUlP. MENT FSAR COMPARISONS - Cont.
Serial #/(Actuator Model)
Operational. Parameters
Field
MPL No.
Equipment
Documentation
Observation
Item
Specs.
FSAR'
E51-F063
RCIC Steam Supply
72965
72965
Max. opening
20 sec.
10 sec.
Isolation Valve
(SMB-1-60)
(SMB-1-60)
and/or closing
time
Differntial
741 psi
1177. psi
Pressure
E51-F064
RCIC Steam Supply
43512
43512
Max. opening
10 sec.
10 sec.
Isolation Valve
and/or closing
time
,
x
}l
Differential
1177 psi
1177 psi
Pressure
n>
E51-F017
RCIC Pump Suction
1
1
Relief Setting
75psig
75psig
Relief Valve
Flow
14 gpm
14 gpm
Notes:
8 At 10 percent Accumulation
,
__-. _ _ _ _ _ .
_ _ _ _ _ - _ - _ _ . _ . _ _ _ _ _ _ _ - _ _-.
. . . -
,
.
._. ..
.
.
TABLE III-6
MECHANICAL EQUIPMENT FSAR COMPARISONS - Cont.
Serial #/(Actuator Model)
Operational Parameters
Field
MPL No.
Equipment
Documentation
Observation
Item
Specs.
E51-F022
RCIC Pump Test
60809
60809
Max. dif-
1400 psi
1400 psi
Return Valve
ferential
i
pressure
capable of
throttling
i
control
,
-
1
Closure
-
75 psi
against dif-
ferential pres-
sure of
,
-
1*
E51-F031
RCIC Pump Suction
61522
61522
Opening and
75 psi
75 psi
-
E!
Valve, Suppression Pool
(SMB-000-5)
(SMB-00-10)
closing against
j
differential
pressure of
E12-C002
RHR Pump
741-5 1410
741-5-1410
Head Capacity Some as FSAR
See FSAR
,
Curve
Fig.
5.4-15
.
2
See FSAR
ment Curve
Fig.
!
5.4-15
l
Brake HP
750 HP
250 HP
!
08000 gpm
@8000 gpm
,
h
n
l
!
-_.
.
.
__
.
.
TABLE III-7
DOCUMENTATION REVIEW FOR MECHANICAL E0VIPMENT
,
Certification
Applicable
Eauipment-
Report Number
Purchase Order
Specification
RCIC Pump
Bingham-Willamette 205-AG-534 Rev. 8
21A9443AW
certification dated
Rev. 1
4-10-78
RCIC Turbine
PQC C772
205-A6-745 Rev. 1
21A9526AE
Rev. 1
RCIC Steam Supply
5618-18-39
P-1364-K
521.02
Valve (F045)
B/M RNN 261
RCIC Steam
5466-82-10
P-1364-K
521.02
Isolation
B/M RNU 209
Supply (F063)
Valve
RCIC Steam
5618-80-11
P-1364-K
521.02
Supply Isolation
B/M RNU 206
Valve (F064)
RCIC Pump Suction
9128-80-19
P-1257-K
523-4549
ReliefValve(F017)
B/M RNQ-200
RCIC Pump Test Return
5618-18-39
P-1364-K
521.02
Valve (F022)
B/M RNN 261
P-1364-K
521.02
RCIC Pump Suction Valve,
--
Suppression Pool (F031)
B/M RNN 260
RHR Pump
PQC R 239
205 A6 070 Rev. 9
21A9514AE
Rev. 3
III-24
..
- _ _ _ _ _ _ _ _ _ - _ _ _ _ _ .
__
_.
_
- -
. _ _ _
'
.
,
TABLE III-8
SUMMARY OF DISCREPANCIES
Equipment
Discrepancy
CEI Action
.
1.
RCIC Turbine
Serial # on PQC certification
Request GE confirmation
(C002)
disagrees with # in field.
that serial # in field
conforms to Purchase
Order (1)
2.
RCIC-Isolation
Valve does not meet FEAR
Will revise FSAR to
Valve (F063)
opening and/or closing
conform to purchase
requirement of 10 cec.
specifications
and differential pressure of
1177 psi.
3.
RCIC Test Return
Purchase specification does
Will revise FSAR to
Valve (F022)
not mention closure again:t
exclude 75 psid closure
75 psid.
requirement.
4.
RCIC Suction
Actuator Model Number in field
Identified this valve
.
Valve (F031)
is not the same as specification
previously along with
requirement.
approximately 100 others
as having the wrong
activator model
numbers (2)
5.
RHR Pump (C002)
Brake HP in FSAR is approximately Will revise FSAR to
1/3 of that shown in specifica-
reflect the specified
tions,
value (3)
Notes:
1 Letter, CEI to GE, PY-CEI/ GEN 168 QA, dated 9/21/83
2 Letter, CEI to Gilbert, PY-CEI/GAI-5305, dated 7/29/82
3 PNPP FSAR Change Request C/R # 51
1
$
t
,
111-25
..
.
. - .
-.
-
. .,
- . - .
. . - - -
. .
.
,
.
. . - .
-
,
- .
.
TABLE III - 9
HVAC INSPECTION SAMPLES
Supports / Restraints:
_
DS-IB-7032
DS-0G-2022
DS-IB-7072
DS-CC-1008
DS-CC-1040
DS-CC-1007
DS-IB-7062
DS-IB-3130
DS-0G-2001
DS-CC-6162
Equipment:
'
Fire dampers
FDCC-721, FDCC-756 and FDIB-308
Fans'
1M15C001A, 2M15C001A, 2M15C001B, OM40C001B,
OM40C002C
Plenums
2M15D001A, IM15D001A, 2M150001B, OM40C002B,
OM40D001C
Flow dampers
1M15F070A and 1M25F130A
Duct Segments:
QM15-739
Pieces 51-68 and 76-79
QM15-722
Pieces 67-70
.
a
III-26
.
.
_
-
.
- . . - .
. - - _ . - . - _ . . . _ . . _
- - _ , _ . _ - - _ . . _ . . _ . . _ . . . _ .
_
. - .
_
.
.
TABLE III - 10
.
HVAC INSPECTION OBSERVATIONS
ITEM
OBSERVATION ( AR/NR/DR/F0 ISSUED)
Support DS-0G-2001
Support to building structure attachment
weld undersized (1/4" vs 3/8")
Support 05-1B-3130
. Support to building structure attachment
weld undersized (1/4" vs 3/8")
Support DS-IB-3099
Support to building structure attachment
weld undersized (1/4" vs 3/8")
i
Support DS-IB-3129
Support to building structure attachment
weld undersized (1/4" vs 3/8")
Support DS-IB-3072
Support to building structure attachment
weld undersized (1/4" vs 3/8")
Support DS-IB-7072
Two duct to support welds missing
(NCR RIC0-501)
Support DS-0G-2022
"Y" dimen. specified as 2", actual = 1-i"
Plenum 0M15-D001A
One foundation nut less than full engage-
ment (approx. I thread) (FQ 31769)*
Fan OM40-C002B
Three foundation nuts less than full
engagement (approx. 1 thread) (FQ 31769)*
- As a result of this finding RICO is reinspecting all previously installed
seismically mounted HVAC equipment for full thread engagement of foundation
fasteners.
III-27
.
.
..
.
_ _ _ _ _ _ _ _ _
.
o
.
IV.
WELDING AND NONDESTRUCTIVE EXAMINATION (NDE)
A. Objective
The objective of the appraisal of welding and NDE was to determine if work
in progress and Quality Control (QC) accepted work related to welding and
NDE activities are controlled and performed in accordance with design and
NRC requirements, SAR commitments, and applicable codes and specifications.
An additional objective was to determine if personnel performing welding
and NDE activities are adequately trained ano qualified in accordance with
established performance standards and applicable code requirements.
B. Discussion
To accomplish the above objectives, welds and welding activities for
piping, pipe supports / restraints, structural steel irstallations, pipe whip
restraints, heating, ventilation and air conditionins (HVAC) installations,
electrical supports and instrumentation and control twaing were inspected.
NDE examination activities were appraised through review of radiographs of
piping welds and observation of NDE field activities, review of NDE person-
nel qualifications, and interviews with NDE personnel. This inspection
activity involved the following contractors: General Electric (NSSS),
Pullman Power Products (piping and supports), Newport News Industrial
(containment liner), Johnson Controls (instrumentation and controls), L. K.
Comstock (electrical), Pittsburgh Bridge and Iron (structural steel), and
Robert Irsay (HVAC).
1. General Electric Company (GE)
a. Inspection Scope
The NRC CAT welding inspection activities relating to the GE con-
tracts were in the areas of piping systems welds, support / restraint
welds, welding procedures, welder's qualification, and in-process
welding. NDE procedures, personnel qualifications, and the review of
radiographic film for shop and field fabricated welds were also
included in this inspection.
(1) Welding Activities
The NRC CAT inspections of piping systems consisted of walkdcwns
of the main steam (B21) and the reactor recirculation (B33)
systems. Approximately 700 feet of pipe involving approximately
50 ASME Class 1, 2, and 3 welds were inspected (see Table IV-1).
Both field and shop welds were inspected to determine if attri-
butes such as mismatch, weld surface contour and appearance and
weld reinforcement were in accordance with the ASME Code require-
ments.
It should be noted that many of the surfaces for the
inspected welds had previously been blended for in-service
inspection.
.
IV-1
,
.
-.
.
.
. -
-
_-,.
.
.
Specification 21A2005, for shop fabrication, Specification
21A2005AD for solution heat treatment of shop welds, and Specifi-
cation CEI527 for cladding the internal diameter of field welds
were reviewed to determine if GE welding activities are being
performed in accordance with the guidance provided in the NRC
Regulatory Guide 1.31 (Rev. 3) " Control of Ferrite Content in
Stainless Steel Weld Metal," and NRC Regulatory Guide 1.44 (May
1973) " Control of the Use of Sensitized Stainless Steel".
The NRC CAT also inspected welds on 10 ASME NF Class 1 pipe
supports. These welds were inspected for weld size, length,
contour and appearance in accordance with the requirements of the
ASME Code (see Table IV-2 for a listing of the supports /
restraintsinspected).
Ten welders were observed while performing in-process welding of
piping and support / restraint welds. The supporting documentation
for the inspected welds such as filler material withdrawal and
process travelers were also reviewed for adequacy.
In addition, the qualification records of twenty-five welders
were reviewed. These welders were qualified by either bend tests
or by radiography in accordance with Specification GEP-N-004,
which was reviewed to the requirements in the latest edition of
ASME Section IX. Radiographic film and records of personnel
qualified by the radiographic option were also reviewed (see
Table IV-3 for a listing of the welder qualifications reviewed).
(2) Nondestructive Examination Activities
The NRC CAT inspection of NDE activities for GE contracts
included the review of radiographic film for snop and field
fabricated pipe welds, witnessing of in-process field NDE inspec-
tions and the review of NDE procedures and personnel qualifica-
tions.
A total of 10 shop welds involving 136 film were reviewed for
film quality, weld quality and compliance with GE's specifica-
tions and ASME Sections III and V.
These welds were fabricated
by ITT Grinnel for GE. Additionally, 15 welds which were fabri-
cated by GE and radiographically inspected by Magnaflux Corpora-
tion were also reviewed. These welds involved 106 film.
The NRC CAT inspectors reviewed the personnel qualification
records for 12 NDE technicians and witnessed in-process inspec-
tion activities performed by four Magnaflux NDE personnel. Five
pieces of NDE equipment were inspected for calibration and
compliance with governing specifications and standards.
IV-2
.
--
.
_
. - - - .
-,
,
-_
--.
. _ .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
l
!
b. Inspection Findings
(1) Welding Activities
No problems were identified in the area of welding procedures
and in-process welding.
Inspected shop and field fabricated
welds met the quality standards of the ASME Code.
.
However, the review of welder qualifications revealed that
radiographic film quality does not comply with the film quality
requirements of ASME Section IX and GE's welder qualification
Procedure GEP-N-004. As a result of this finding, Action
Requests (ARs) 714, 715, 716, 717, and 721 were prepared by the
CEI (Cleveland Electric Illuminating) project organization.
(2) Nondestructive Examination Activities
No problems were identified in the area of nondestructive
examination.
c. Conclusions
With the exception of the findings previously discussed, all inspec-
ted welding and NDE activities were found to conform to the require-
ments of the applicable Code and the CEI SAR commitments.
2. Pullman Power Products (PPP)
a. Inspection Scope
The NRC CAT welding inspection activities relating to PPP contracts
were in the areas of piping system welds, support / restraint welds,
welding procedures, welder qualifications, and in-process welding.
NDE procedures and the review of radiographic film for shop and field
fabricated welds were also included in +his inspection.
(1) Welding Activity
Approximately 8,000 feet of both field and shop fabricated ASME
Class 1, 2, and 3 piping was inspected. A total of 1250 welds
were visually inspected to determine if attributes such as
mismatch, weld surface contour and appearance were in accordance
with ASME Section III requirements.
It should be noted that many
of the piping welds had previously been blended for in-service
inspections (see Table IV-1 for a listing of piping inspected).
The NRC CAT also inspected welds on 56 ASME Section III,
Sub-section NF Class 1, 2, and 3 supports / restraints.
These
welds were inspected for size, length, contour and appearance in
accordance with the requirements of the ASME Code (see Table IV-2
for a listing of the supports / restraints inspected).
IV-3
.
.
Twenty PPP welders were observed while performing in-process
welding of piping and supports / restraints. The supporting
documentation for the inspected welds such as filler material,
withdrawal slips and process travelers were also reviewed for
adequacy.
In addition, the qualification records of 22 welders were
reviewed (see Table IV-3). Welders were qualified by either bend
tests or by radiographic inspection of the test sample in accord-
ance with specification II-8, " Welder Performance Qualifica-
tions," which was reviewed for compliance with the latest
edition of ASME Section IX requirements. Radiographic film and
records of personnel qualified by the radiographic option were
also reviewed.
(2) Nondestructive Examination Activities
The NRC CAT inspection of NDE activities for PPP contracts
included the review of radiographic film for shop and field
fabricated piping welds, witnessing of in-process field NDE
inspections and the review of NDE procedures.
A total of 67 shop welds, fabricated by PPP (Williamsport, Pa.),
involving 746 film were reviewed for film quality, weld quality,
and compliance to PPP specification and ASME Sections III and V
requirements (see Table IV-4 for a listing of shop welds
reviewed).
A total of 91 field-fabricated welds involving 686 film were
reviewed (see Table IV-4 for listing of field welds reviewed).
Seventeen in-process NDE field inspections involving nine PPP NDE
personnel were observed and the radiographic film for three
welder qualifications were also reviewed for adequacy.
b. Inspection Findings
(1) Welding Activities
No problems were identified in the areas of welding procedures
and in-process welding.
Inspected piping and support / restraints
welds were found to be in compliance with the quality standards
of the ASME Code.
However, problems related to piping installation were noted in
the areas of branch piping weld joints. NX-4244 of ASME Section
III requires that a fillet size of certain minimum dimensions be
met for corner welded nozzles and branch piping connections.
PPP fabrication and inspection procedures do not specify these
ASME Section III requirements regarding a minimum specified
fillet size for branch connections.
Field inspection of piping
runs revealed that several branch connections had sizes less than
those required by the ASME Code.
IV-4
___ _ __-__ _ _ _
.-
.
As a result of this finding, CEI issued Nonconformance Reports
(NR) 2916 and 2917 respectively.
Another procedural problem regarding the welding of stainless
steel socket welds for the control rod drive (CC11) system was
also identified. Socket welds for- the control rod drive system
required additional welding to the pipe side of the socket weld
as a result of an engineering design evaluation. The weld size
on the pipe side was increased to 2 times the weld size on the
socket or fitting side of the weld. Thus, for 11 inch socket
welds, the weld length on the pipe side is approximately 3/4
inch.
Field inspection of actual socket welding revealed that
the piping is subject to higher welding heat inputs due to the
increased weld size on the pipe side. Welding Procedure WPS-29,
which was used to weld the subject welds, is qualified in accord-
ance with ASME Section IX of the Code.
It covers materials
from 1/16 to 8 inches thick with an amperage range of 50 to 175
.
amps. The amperage range of WPS-29 appears to be too broad to
control heat inputs to the relatively small mass of socket weld
as compared to an 8 inch thick weldment.
In-process field welds
observed by the NRC CAT inspectors were cherry red because of
.
this excessive heat input permitted by welding procedure WPS-29.
Sectioned samples of socket welds, welded using Procedure WPS-29,
were examined by the NRC CAT inspectors. Samples of normal (1:1
weld legs) socket welds and socket welds exhibiting weld leg size
of 2:1 (pipe leg 2 times leg of fitting) were compared.
Inspec-
tion of the internal surfaces of the sectioned specimens revealed
a heavy metal discoloration on the internal surfaces of the
socket welds with the 2:1 leg ratio. This heavy metal
discoloration indicates that excessive heat inputs were used
during the welding of this specimen. Thus, an amperage range to
ensure control of heat input to the socket welds should be
considered for incorporation into WPS-29.
The reviewed welder qualification records established that the
welders were qualified in accordance with the requirements of
Section IX of the ASME Code either by bend test of radiography.
The radiographs for two welders were found to be deficient
with respect to the film quality requirements of PPP Procedure
IX-R1-5 and ASME Section IX of the Code.
The overall welder qualification program was reviewed by the NRC
CAT and was found to conform to the requirements of the ASME Code
and existing regulatory requirements. However, the program was
also reviewed in order to assess the adequacy of existing safe-
guards needed to preclude the possible use of stand-ins for
welder qualification tests. This problem was recently addressed
in IE Information Notice 83-61 " Alleged Use of Stand-Ins for
Welder Qualification Tests". As a result of the review, the
following deficiencies were identified.
A lack of controls to insure that new hires are properly
identified.
IV-5
_ _ - _ _ _ _
. _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
A lack of positive welder identiiication on weld test samples
and test coupons for qualification (new hires and regular
employees taking qualification tests).
(2) Non-Destructive Examination Activities
No problems were identified in the area of NDE procedures,
personnel qualification and in-process NDE.
However, during the review of radiographs for PPP shop welds,
three of 67 PPP shop welds were rejected by the NRC CAT inspec-
tors for weld quality problems. The three welds were identified
as 1!111-GMS-ITB, IN27-G-FW-1295T, and 1-N27-G-FW-143HB. Noncon-
NR 2362 was prepared as a result of these findings. Two welds
were rejected for violation of minimum wall thickness. Minimum
wall violations were confirmed by ultrasonic examination of these
welds and NR TAS-0057 was prepared as a result of this finding.
The review of reader sheets for PPP shop radiographic film
indicated that the sheets have not been signed by the PPP radio-
graphers. The names on the reader sheets were either printed or
initialed. AR 724 was prepared as a result of this problem.
Problems concerning shop welds fabricated by PPP at Williamsport
have been found to exist at other nuclear facilities. The NRC
CAT inspected a number of completed shop welds fabricated at PPP
during the inspection at Perry. Most of these were large bcre
piping welds and had been blended for in-service inspection.
Several deficiencies including lack of compliance for weld
quality and minimum wall violations were found in small bore
piping welds. However, the sample size for welds in small bore
piping was small in relation to the total number of piping welds
reviewed (see Table IV-4). The NRC CAT understands that the
applicant plans to review small bore shop walded piping from PPP
at Williamsport to ensure similar deficiencies do not exist at
Perry.
During the review of radiographs for PPP field welds, three of
the 91 welds were also suspected of not meeting the minimum wall
thickness requirements. These welds were identified as 0-111-9,
welds 02, 03 and 04. The welds were buried undergrour.d and the
wall thickness could not be verified by ultrasonic examination.
These welds are now under investigation and the use of radio-
graphic step wedge thickness versus film density method is being
considered as a alternative method of evaluation. NRs TAS-058,
-
TAS-059, and TAS-060 were prepared for these welds.
The radiograph for weld 0-P11-9, FW01 was rejected by the NRC CAT
inspector for failure to display the 4T hole in the penetrameter
for the subject weld. NR TAS-062 was prepared for this condi-
tion. Another radiograph was rejected for lack of fusion and NR
PPP-4021 was prepared as a result of this finding.
IV-6
)
. _ _ _ _ _ _ .
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
..
_ _ _ _ -
l
.
.
c. Conclusions
With the exception of the findings previously discussed, all
inspected welding and NDE activities were found to comply with
the requirements of the ASME Code ano the CEI FSAR commitments.
3. Newport News Industrial (NNIC0)
a. Inspection Scope
(1)WeldingActivities
The NRC CAT welding inspection activities relating to NNICO
included inspection of field welding (both ASME and AWS D1.1),
in-process welding, welding procedures and welder qualifications.
NDE procedures, personnel qualifications, and the review of
radiographic film for the containment liner welds were also
included in this inspection.
A total of four welding attachments to the liner plate were
witnessed and the complete documentation involving eleven welds
was reviewed in order to ascertain that the welding was
performed in accordance with the requirements of the ASME code,
specifications and drawingc.
The qualification records for six welders and the welder
qualification procedures were also reviewed for adequacy.
(2) Nondestructive Examination Activities
Radiographic film for approximately 98 feet of the liner plate
was reviewed by the NRC CAT (see Table IV-4 for a listing of the
liner plate welds reviewed).
b. Inspection Findings
Welding / Nondestructive Examination Activities
No concerns were identified in the area of inspected welding and
NDE activities.
c. Conclusions
No problems were identified in the areas of inspected NNIC0 welding
and NDE activities.
4. Johnson Controls, Inc. (JCI)
a. Inspection Scope
A total of 225 welds were inspected for compliance with the require-
ments of the ASME Boiler and Pressure Vessel Code. Welding proce-
dures and the qualification test records for 25 welders were
IV-7
._
_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _
.
.
reviewed.
In addition, NDE procedures and personnel qualification
records were also reviewed.
Four NDE inspectors were observed and
evaluated for their abilities to use the ASME Code and to follow
the Johnson Control (JCI) NDE procedures.
b. Inspection Findinos
No concerns were identified in the areas of inspected welding and
NDE activities.
c. Conclusions
No problems were identified in the areas of inspected JCI welding
and NDE activities.
5. Pittsburgh Bridge and Iron (PBI)
a. Inspection Scoce
A total of 340 welds were visually inspected for compliance with the
requirements of AWS D1.1 Structural Welding Code. Welding proce-
dures, welder qualification records, NDE procedures and NDE personnel
qualifications were reviewed.
In addition, a sample of NDE inspec-
tors were observed and evaluated for their abilities to use the AWS
01.1 Code and follow the PBI NDE procedures.
'
b. Inspection Findings
(1) Eight of the sampled 340 welds were found to be undersized,
having excessive concavity or unacceptable contours and were
,
deficient with respect to the acceptance criteria stated in the
AWS D1.1 Code. As a result of this finding, the project organi-
zation issued nonconformance report (NR) PBI 981 and the welds
will be repaired and reinspected as required by the AWS D1.1
,
!
Code.
(2) Active welding procedures were found to be in accordance with the
requirements of AWS D1.1 Code.
Procedure GR-2, Revision 0 was found to be deficient with respect
,
to the AWS D1.1 Code because it included ASTM A569 material
which is not listed in Table 4.1.1 of the Code. Since this
material is not listed in Table 4.1.1, the procedure can not be
used as a prequalified procedure.
PBI indicated that procedure
GR-2 was never used in production welding and it will be removed
<
from the approved procedures list.
(3) The welder qualification records for welders were found to be in
compliance with the requirements of the AWS D1.1 Code. Welders
were qualified by bend testing except for one welder whose test
plate was qualified by radiography.
1
IV-8
_
_ _ _
,
.
The review of the qualification radiograph revealed that the
radiograph was not acceptable with respect to the film quality
requirements of the AWS D1.1 Code.
PBI re-radiographed the,
original test plate and the second radiograph was found to be
acceptable.
In addition, 20 additional welds which have been
made by this welder were visually inspected. All inspected welds
were found to be of excellent quality indicating that the work
was completed by a qualified craftsman.
c. Conclusions
With the exception of the findings previously discussed, inspected
welding and NDE activities were found to comply with the requirements
of the AWS D1.1 Structural Welding Code.
6. L.K. Comstock (LKC)
a. Inspection Scope
A total of 160 sampled welds were visually inspected in accordance
with the requirements of the AWS D1.1 Code.
Welding procedures and the qualification test records for 18 welders
were reviewed.
In addition, NDE procedures and personnel qualifi-
cation records were reviewed. Two NDE inspectors were observed and
evaluated 'for their abilities to use the AWS D1.1 Code and to follow
the LKC NDE procedures,
b. Inspection Findings
No concerns were identified in the areas of inspected welding and
nondestructive examination activities.
c. Conclusions
No problems were identified in the areas of inspected LKC welding
l
and NDE activities.
l
7. Robert Irsay (RICO)
a. Inspection Scope
Total of 160 welds were inspected comprising a sample of vendor
i
procured welds and field welds completed by RICO. Welding proce-
dures, welder qualification records, NDE procedures and NDE personnel
l
qualifications were reviewed.
In addition, two NDE inspectors were
observed and evaluated for their abilities to use the AWS D1.1 Code
and to follow the RICO NDE procedures.
.
IV-9
.
4
0
b. Inspection Findings
(1) During the visual inspection of completed field welds, some of
the welds were found to be undersized. As a result of this
finding, the project organization issued NRs RIC0-488, RIC0-489
and RIC0-490 and all deficient welds will be required to comply
with code and specification requirements.
(2) Vendor supplied multi-blade dampers were found to be tack welded
instead of the required 1" stitch weld. As a result of this
finding, the CEI project organization issued NR MCC F-40 to
address this item.
(3) The welding and NDE procedures reviewed were found to be in
conformance with the requirements of the AWS D1.1 Code.
(4) The welder and NDE personnel qualification records reviewed met
the requirements of the AWS D1.1 Code,
c. Conclusions
With the exception of the previously discussed findings, inspected
welding and NDE activities were found to comply with the requirements
of the AWS D1.1 Structural Welding Code.
.
4
1
IV-10
,
,
Table IV-1
PIPING RUNS INSPECTED
System /Name
Class
Size
IB21/ Nuclear Boiler System
3
10", 1?", 14"
1G33/ Reactor Recirculation
1
20", 28"
1C11/ Control Rod Drive
2
11", 16", 8"
1E12/ Residual Heat Removal
1,2,3
3", 4", 6," 10", 12", 18"
1E21/ Low Pressure Core Spray
1, 2
2", 12", 14", 24"
1E22/High Pressure Core Spray
1, 2
10", 12", 16", 24"
1E32/ MSIV Leakage Control
2
21", 3", 4"
1E51/ Reactor Core Isolation Cooling
1, 2
2", 4",
6", 10", 12"
1G33/ Reactor Water Cleanup
1, 3
4", 6", 12"
1G36/RWCU Filter /Demineralizer
2, 3
4", 6", 8"
1G41/ Fuel Pool Cooling and Cleanup
3
8", 10"
IG42/ Suppression Pool Drain and
Cleanup
3
8", 10"
1G42/ Suppression Pool Drain and
Cleanup
3
8", 10"
1G61/ Liquid Radwaste Sumps
2
21"
1N27/ Feed Water
1
12", 20"
1P11/ Condensate Transfer and Storage
2
10", 16"
1P42/ Emergency Closed Cooling
3
4", 10", 12"
1P45/ Emergency Service Water
3
4", 8", 10", 14"
1P47/ Control Complex Chilled Water
3
3", 6", 8", 10"
IV-11
.
.
.
_ _
_
_ _ _
- _ _ _ _ .
_.
.
- e
,
TABLE IV-2
Pipe Suoports/ Hangers Inspected
,
Supports / Restraints No.
Results
H101 B(A)-1
Welds acceptable
H101A(A)-1
"
H101A(B)-1
"
,
'
"
H1010(A)-1
"
H1028-1
"
"
H305A
"
"
H3538-1
"
H101B(B)-1
H101D(B)-1
"
"
H3568-1
NOTE: These supports / hangers listed on this page are installed by General
Electric
,
i
l
'
i
f
i
IV-12
...
,_ ... -
.
._
- _ .
_ _ _ - -
.
-
-
-
,
-
--.
_ - . , . .
,
.
TABLE IV-2
PIPE SUPPORTS / HANGERS INSPECTED - Cont.
Supports / Restraints No.
Results
IB21-H006
Welds Acceptable
IP42-H113
a
"
"
"
"
IG41-H247
"
"
"
"
,
'
"
"
"
"
1821-H223
"
"
'
"
"
"
"
"
"
"
"
"
"
"
"
"
"
"
1P42-H345
Rejected by CEI
Phase 11 inspection
IP42-H139
Under sized fillet welds (2)
NRC 2540R11 had been prepared
for undersize welds
Welds acceptable
"
"
"
'
"
"
"
1821-H006
NOTE: The supports / restraints on this page are installed by Pullman Power
Products
IV-13
-
--
. _ . .
_
_ _
-_ , _.
. _ - . _
-
.
.
TABLE IV-2
PIPE SUPPORTS / HANGERS IINSPECTED - Cont.
Support / Hanger No.
.Results
IP45-H167
Welds Acceptable
-
"
"
"
1C11-H614
Reviewed for welding
and Design Change
Control. Acceptable
"
IC11-H642
"
"
'
"
"
1833-H1068
"
"
"
"
"
1821-H107
"
NOTE: The supports / restraints listed on this page are installed by Pullman
'
Power Products
)
-
IV-14
__
. . _
_
_
. .
_ . _ ....
_
_
_
.
.
..
.
TABLE IV-3
WELDER QUALIFICATIONS
Method of Testing /
Welder I.D.
Commments
GEP-005
GEP-071
Bends
"
GEP-072
"
GEP-082
"
GEP-084
"
GEP-104
"
GEP-105
GEP-113
"
GEP-118
GEP-121
Bends
GEP-132
"
GEP-140
"
GEP-160
GEP-175
RT & Bends
GEP-177
RT (1)
GEP-187
RT(1)
GEP-199
GEP-210
Bends
GEP-217
Bends
GEP-271
RT(1)
"
GEP-274
"
GEP-279
GEP-288
GEP-290
RT (1)
GEP-297
Pullman Power Products
Method of Testing /
Welder I.D.
Comments
l
l
RX
Bends
FZ
RT & Bends
'
AJV
Bends
"
X2
i
"
AGK
"
"
ARA
"
.
JT
"
ADE
"
ATH
"
ATM
IV-15
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
TABLE IV-3
WELDER QUALIFICATIONS - Cent.
'
Pullman Power Products - Cont.
Method of Testing /
-
Welder i.D.
Commments
"
"
ALN
"
E2
"
ABJ
"
ADF
"
AUH
"
ATP
"
AJK
RT & Bends
"
ARD
AC4
RT (1)
AMQ
RT (1)
Newport News Industrial
Method of Testing /
Welder I.D.
Comments
018-4144
"
018-488
"
441-1745
"
441-4469
"
065
"
024
Others
PBI/ Kelly Steel - A total of 57 welder qualification records were
reviewed. 56 welders were qualified by bend test
and one by radiography.
Johnson Controls - A total of 25 welder qualifications were reviewed.
All welders were qualified by bend testing.
L. K. Comstock
- A total of 18 welders were reviewed. All welders were
qualified by bend testing.
Robert Irsay Co. - A total of 17 weldres were reviewed. All welders were
qualified by bend testing.
NOTE (1): The radiographic film quality was unacceptable per ASME Code.
IV-16
i MA i
'
i
_ _ _ _ _ _ _ _ - _ _
_ _ _ _ _ _ _ _
- _ _ _ _ _ _ _ _ _ _ _ _ - _ _ ______ -_____ ___ __ _________
-_____ ___ ____ - __ _ ___
.
.
TABLE IV-4
RADIOGRAPHIC FILM REVIEW
2
General Electric (Shop Welds)
Weld I.D.
KER-1701-250
St. Seam
702-E-82-9G010
B1-LSWOL
1-821-MS-LOOPC
Weld 8012A
1-821-MS-L00PC
Weld 0038D
1-B21-MS-L00PB
Weld 0090
1-B21-MS-LOOP
Weld 4B
1-821-MS-L00PD
Weld 602
1-B21-4A-FRT-F-CL
Weld 6A
1-B21-4A-FFB
Weld 4A
1-B21-7D-MS-FCL
Weld 4A
1-821-A3-F-TRA
Held 6A
1-821-Al-1PC-1-3A
Weld 3A
1-B21-D2
1-B21-7CT1821
Weld 031
1-B21-4CT1821
Weld 026
i
1-B33-RRA19LOOPA
1-B33-RR10-A-1
'
1-B33-RR-002
Weld A-10
2-E32-GMSIV-63AB
Weld A
2-E32-GMSIV-63AB
Weld B
2-E32-GMSIV-63AB
Weld C
2-E32-GMSIV-51AB
Weld A
2-E32-GMSIV-51AB
Weld B
2-E32-GMSIV-51AB
Weld C
2-E32-GMSIV-52AB
Weld A
j
General Electric (Field Welds)
FRT(B33-1-34)
FGL-10
"
,
FRT(B33-1-38)
'
"
FGL-10
"
RCC-1-RCB33-RR
"
RCCA12G33-1-A12
"
f
l
RCCB33-1-A
"
I
V
.
l.
i
l
l
!
!
I
IV-17
(
.
.
.
TABLE IV-4
RADIOGRAPHIC FILM REVIEW - Cont.
Pullman Power Products Shop Welds (67)
Weld I.D.
- 2$12-GRH-91AB
Weld B
'
Weld C
- 1N27-GFW-129ST
Weld E
Weld A
Weld C
- 1N27-GFW-143HB
Weld A
- 2E21-GHR-91AB
Weld E
Weld D
Weld C
Weld A
Weld B
Weld B
IE51-GRCIC-33AB
Weld F
IN27-GFW-129ST
Weld A
IN27-GFW-129ST
Weld B
IN27-GFW-136ST
Weld B
IN11-GMS-1TB
Weld A
- INH-GMS-1TS
Weld B
Weld G
Weld A
Weld B
Weld C
Weld D
Weld E
Weld G
2-E12-G-RH-220AB
Weld J
2-E12-G-RH-220AB
Weld D
2-E12-GRH-4-AB
Weld E
2-E12-GRH-4-AB
Weld B
2-ER-GRH 19-AB
Weld G
-
1-E12-GMSIV-10RAB
Weld N
1-E12-GMSIV-10RAB
Weld H
1-E12-GMSIV-10RAB
Weld A
1-E12-GMSIV-10RAB
Weld A
1-E12-GMSIV-2AB
Weld A
2-E12-GGRH-4AB
Weld C
2-E12-GRH-220AB
Weld C
2-E12-GRH-7AD
Weld A
1-G-38GRWC-20-RB
Weld A
1-E21-GLPG-7-AB
Weld A
Weld C
Weld A
Weld A
Weld B
Weld B
Weld C
Weld B
IV-18
.
.
--__
___________ _ _ _ _ _ _ _ _ _ _ _
.
.
.
.
TABLE IV-4
RADIOGRAPHIC FILM REVIEW - Cont.
Pullman Power Products Field Welds (91)
Weld I.D.
1-G33-GRWCU-20-AB
Weld A
1-E12-35-1510460
Weld 01
1-E51-2
Weld 46
1-E22-2
Weld 05
1-E22-2
Weld 09
1-E22-5
Weld 02
1-E22-5
Weld 01
1-E22-5-
Weld 04
1-E22-5
Weld 31
1-N27-1
Weld 09
1-E22-4
Weld 08
1-N27-1
Weld 15
1-E12-11
Weld 20
Cont WNI-90
15' Vert weld
1-G-23-5
Weld 02
1-G-23-6
Weld 04
1-E-51-2
Weld 09
1-E-51-2-
Weld 01
1-E-51-2
Weld 40
1-G-33-5
Weld 32
1-G-33-5
Weld 03
1-G-33-3
Weld 01
1-E-12-34
Weld 02
1-E-51-8
Weld 01
1-E-51-8
Weld 02
1-N-27-2
Wela 01
2-E-12-G-RH-220-AB
1-E-12-11
Weld 20
1-E-12-17-
Weld 10
1-E-12-22
Weld 03
1-E-12-22
Weld 05
1-E-12-22
Weld 06
1-E-12-22
Weld 07
1-E-12-22
Weld 08
1-E-12-22
Weld 10
1-E-12-31
Weld 05
1-E-12-35
Weld 01
1-E-12-36
Weld 12
1-E-12-31
Weld 06
1-E-12-12-
Weld 05
1-E-12-14
Weld 01
0-P11-9
Weld 02**
0-P11-9
Weld Ol***
0-P11-8
Weld 01
1-C41-510
Weld 44
0-Paa-9
Weld 03**
0-P11-9
-
Weld 04**
0-P11-10
Weld 01
IV-19
_. -
.-
.
TABLE IV-4
,
RADIOGRAPHIC FILM REVIEW - Cont,
Pullman Power Products Field Welds (91) - Cont.
Weld I.D.
0-P11-10
Weld 02
1-E12-20
Weld 03
1-E12-30
Weld 20
1-E12-20
Weld 03
1-E12-23
Weld 01
1-C41-4
Weld 02
1-C41-4
Weld 08
1-E12-2
Weld 10
1-E12-4
Weld 03
1-E12-5
Weld 12
1-E12-5
Weld 13
1-E12-11
Weld 03
1-E12-12
Weld 03
1-E12-15
Weld 02
1-E12-15
Weld 03
1-F12-17
Weld 01
1-E12-32
Weld 15
1-E12-33
Weld 07
1-E12-33
Weld 08
1-E12-45
Weld 05
1-E12-48
Weld 05
1-E32-7
Weld 04
1-E51-3
Weld 08
1-E51-3
Weld 01
1-E51-5
Weld 04
1-E51-6
Weld 06
1-E51-7
Weld 03
1-E51-7
Weld 03
1-E51-1
Weld 01
1-E51-1
Weld 02
1-E51-2
Weld 60
1-E21-2
Weld 03
1-E21-2
Weld 117
1-E21-3
Weld 04
1-E21-3
Weld 06
1-E12-14
Weld 09
1-E12-17
h'cid 08
1-E12-20
Weld 01
1-E12-23
Weld 02
1-E12-27
Weld 09
1-E12-24
Weld 21
1-E12-27
Weld 08
1-E12-24
Weld 05
1-E12-28
Weld 03
IV-20
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
o-
o
.
TABLE IV-4
RADIOGRAPHIC FILM REVIEW - Cont.
Pullman Power Products Field Welds
Weld I.D.
Weld A
Weld G
Weld F
1E32-G-MSIV-10R-AB
Weld M
1E32-G-MSIV-10R-AB
Weld L
1E32-G-MSIV-10R-AB
Weld G
1E32-G-MSIV-10R-AB
Weld E
1E32-G-MSIV-10R-AB
Weld J
1E32-G-MSIV-10R-AB
Weld B
1G32-G-MSIV-10R-AB
Weld C
,
1E32-G-MSIV-10R-AB
Weld D
2E12-G-RH-4-AB
Weld A
2E12-G-RH-4-AB
Weld D
2E12-G-RH-4-AB
Weld F
Weld C-R1
,
Weld C-R2
,
Weld E
Weld E-R1
,
1-G-33GRWCU-20-AB
Weld B
1-G-33GRW-CU-20-RB
Weld C
1-G-33GRWCU-20-RB
Weld D
Welds rejected by NRC CAT for lack of compliance for weld quality
Rejected by NRC CAT for minimum wall violation
Rejected for failure to display 4T hole of the penetrameter
,
Containment Liner Review
Newport News Industrial (NNIC0)
INN 0-2(177-179) Horizontal Seam
INNI-90 Verticle Seam
Approximately 98 Ft. Film for containment liner plate reviewed
IV-21
~
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_ _ _ - ___
.
.
TABLE IV-5
IN-PROCESS NDE INSPECTIONS
Item
Contractor
Method
Inspected
Results
G.E.
R.T.
Piping Welds
Acceptable, Witnessed
4 R.T. Technique / setups
PPP
P.T.
Piping Welds
Acceptable, Witnessed
1 P.T. Exam
R.T.
Piping Welds
Acceptable. Witnessed
3 R.T. Exams
JCI
P.T.
Piping Welds
Acceptable. Witnessed
6 P.T. Exams
V.T.
Piping Welds
Acceptable, Witnessed
l
6 visual exams
l
l
LKL
V.T.
Structural Welds
Acceptable, Witnessed
l
2 visual exams
P.T.
Structural Welds
Acceptable, Witnessed
'
2 P.T. Exams
RICO
V. T.
Structural Wclds
Acceptable. Witnessed
,
2 visual exams
P. T.
Structural Welds
Acceptable, Witnessed
2 visual exams
j
PBI
V.T.
Structural Welds
Acceptable, Witnessed
7 V.T. Exams
M.T.
Structural Welds
Acceptable, Witnessed
7 M.T. Exams
P.T.
Structural Welds
Acceptable, Witnessed
3 P.T. Exams
U. T.
Structural Welds
Acceptable, Witnessed
1 U.T. exau
.
IV-22
I
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_ _ _ . _ _ . _
l
.
.
V.
CIVIL AND STRUCTURAL CONSTRUCTION
A. Objective
Determine by independent evaluation of work in progress, completed work,
and by review of dccumentation whether work, inspection,. and test activi-
ties relative to the civil engineering area were accomplished in accordance
with project specifications and procedures. These objectives were met
through evaluation of the Seismic Clearance Program, concrete expansion
anchor bolts, concrete placement, in-situ concrete and reinforcing steel
placement quality, concrete and soils records, containment vessel steel,
structural steel installation activities and design changes and
nonconformance reports in these areas.
B. Discussion
1. Seismic Clearance Program
.
a. Inspection Scope
The applicant's Seismic Clearance Program provides for the identifi-
cation and review of those instances in which seismic clearance
criteria have been violated. The criteria, established by the
architect er:gineer, Gilbert Associates, Inc. (GAI), cover safety-
related components (i.e., piping and supports, HVAC ductwork and
supports, and electrical conduits and cable trays) and also non-
safety-related components which in a seismic event could affect
safety-related components. The seismic clearance inspections are to
be perf'ormed in accordance with Construction Quality Assurance
Instruction 21-1007, Rev. 1, dated 7/5/83, " Seismic Clearance Inspec-
tion." The review of the violations of seismic clearance criteria is
described in the site Procedures Manual, Volume 4, 4-0500, "GAI
'
Interfaces," dated 9/30/82. The regulatory requirements are spect-
,
fied in paragraphs C.2 and C.4 of Regulatory Guide 1.29, Rev. 3,
l
dated 9/78, " Seismic Design Classificacion."
l
A sample of 26 hardware installations in the field was reviewed
to determine the workmanship quality. The hardware reviewed were
those which had been identified as violating the seismic clearance
criteria and had been resolved by GAI engineering with or without
repair work being required. This review was performed to verify
whether the quality of workmanship was adequate for those components
for which GAI had performed analyses.
From the 26 hardware installations reviewed, an evaluation was also
performed of seven engineering calculations done by GAI which had
accepted the hardware installations. The engineering calculations
were evaluated to verify the technical adequacy of the dispositions
of the seismic clearance violations.
V-1
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_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ .
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
.
.
b. Inspection Findinas
For the 26 Seismic Category I, nonsafety-related hardware installa-
tions (see Table V-1), the general quality o'f workmanship (i.e., weld
appearance, nut tightness, structural integrity assessment, and
support spans) was reviewed. The review also included the inspection
of supports and components in the vicinity of the seismic clearance
violation (those conditions which could affect the engineering
analyses). Seven supports were inspected in detail for conformance
to the design drawings. The findings are detailed in Table V-1.
The significant hardware installation problems identified by the NRC
CAT were:
1) excessive lateral movement of fire protection piping
among safety-related cable trays; 2) instances of missing or poor
welds; 3) one support spring can out of alignment; and 4) excessive
piping spans with a minimal number of supports. For the sample of
hardware installations inspected by the NRC CAT, except for the fire
protection piping among cable trays, the hardware deficiencies appear
to be isolated cases and were not of a condition which would jeopar-
dize structural integrity; however, the deficiencies were of a nature
that could affect engineering analyses in other more critical appli-
cations.
Seven GAI engineering calculations were reviewed by the NRC CAT.
This review included: use of current seismic floor response spectra,
proper analytical techniques, proper analysis assumptions, and proper
evaluation of the calculation results. The calculation review
findings are summarized in Table V-1.
Twenty-two floor response
spectra curves, used as input into the calculations, were verified to
be the current response spectra. However, it was identified that the
curves were not being formally distributed to those on-site design
groups using these curves. Two significant issues were identified:
(1) The lateral movement of fire protection piping among safety-
related cable trays was not considered by the GAI engineers.
In
addition, the impacting of the fire protection piping with the
cable trays was considered in the engineer's judgment to be
"insigni ficant" .
In the actual hardware installation, the only
lateral restraint is at the branch connection at the main header
piping, allowing the fire protection piping to move laterally,
impacting cable trays or adjacent conduit.
(2) Generally, the calculations were found to be performed in r
manner not well controlled. Exgamlesare: a bolt cepacity . tot
properly evaluated for adequacy', use of differing factors oi
safety for the same component without guidance as to which fa-tor
of safety should be used and under which circumstances, differing
allowable capacities for threaded rod, assumptions for field
hardware not verified, calculation references made incorrectly,
use of the wrong size bolt (larger than actual) in a calculation,
and generic calculations which analyzed similar seismic clear-
ance violations were not based on the most limiting hardware
installation parameters.
Although, in the calculations reviewed,
no cases were identified in which the lack of detailed design
V-2
_.
_ _ _ _ _ _ _ _ _ _ _ _ - __
.
.
control caused a significant analysis error, the errors should
not have been made nor passed through the checking process
without the errors being identified.
It appeared that without
formal design / analysis guidance each GAI engineer used analysis
techniques and methods of their own choosing. This led to some
analysis inconsistencies.
In the review of an added support (CC-574-FD-4) required to
satisfyseismicclearanceviolations(SCVs),theNRCCATidenti-
fied undersized welds and weld splatter (SCV #187). Final
inspection of the added support had not been performed; however,
the violation had been already closed by GAI.
It was determined
that 29 SCVs had been dispositioned by GAI engineering as
" accept-as-is" when, in fact, the violation could only be closed
if additional work was performed (installation of supports or
removal of temporary lines). The use of " accept-as-is" vice
" repair" dispositions by GAI caused the closure of these viola-
tions prior to completion of the necessary repair work.
This practice may preclude the repair work from being properly
tracked (using a work package) and properly inspected. These
early closures of violations are contrary to the implementation
of Appendix Y (Section 2:03) to GAI Interface Procedure, Volume
4, 4-0500, dated 9/30/82, " Interfaces." As a result of the NRC
CAT finding in this area, Action Request (AR) #706, dated
9/12/83, was issued to identify and reopen those SCV's erro-
neously dispositioned " accept-as-is." This AR was closed on
9/22/83.
c. Conclusions
(1) The GAI engineering resolution for cases of fire protection
piping among cable trays (SCV 2442,2460,2492) was improper
in that lateral movement was not considered. There has been
inadequate attention to those analyses which relied mainly on
engineering judgment.
(2) Generally, GAI engineering calculations have been performed in an
inconsistent manner, and not well controlled.
In the sample of
calculations reviewed the inconsistencies and errors were not
of a magnitude to invalidate the conclusions reached. However,
this is indicative of a lack of attention to detail by the
engineer and checker.
(3) Cases of deficient installation workmanship were identified
which could be significant under other more critical situations.
(4) Seismic clearance violations were identified which had been
closed prior to the completion of the necessary repair work.
Improper dispositions by gal engineering had caused closure
prior to verification that the nonconforming conditions were
fully resolved.
V-3
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_ _ _ - _ _ _ _ _ _ _ _ _ .
i
__ ___________ ____
o
.
2. Concrete Expansion Anchor Bolts (Hilti Bolts)
'
a. Inspection Scope
The qualification test report and installation specifications were
reviewed for the predominant type of concrete expansion anchor bolt
used at Perry (Hilti Kwik-Bolt). The inspection and installation
procedures for the Hilti bolts were also reviewed for two contractors
(Pullman Power Products and L. K. Comstock).
It was identified by the NRC CAT that concrete expansion anchor
bolts (Hilti Kwik-Bolts) are being installed in the drywell wall
through the drywell liner plate and into the concrete behind the
liner plate. The 5/8" and 3/4" diameter anchor bolts are being
used primarily to support instrumentation and control lines, electri-
cal conduits, and pipe supports. Based on discussions with the
applicant, the total number of anchor bolts anticipated to be
installed in the drywell walls are 6000-8000 per unit. Approximately
2000 were installed as of the time of this inspection,
b. Inspection Findings
On-site qualification tests for Hilti Kwik-Bolts were performed
and the results are summarized in GAI Report No. 2304, " Perry Nuclear
Power Plant: Report on Evaluation of Hilti Kwik-Bolt Qualification
Tests," dated 5/11/81. The report summarized the qualification tests
performed from November 1978 through hovember 1980. The current
installation specificatiens and installation procedures for Pullman
Power Products and L. K. Comstock were compared by the NRC CAT with
the qualification report and found to be in agreement. The following
was noted in the review of the qualification report:
(1) Torque-tension relationships were established based on the
qualification testing.
In all cases, except for 1/2" diameter
Hilti bolts, the specified inspection torque provides a preload at
least equal to the allow dle load. The installation torques are
higher than the inspectior torques. The use of 1/2" diameter
Hilti bolts was discontinued in November 1980.
(2) The 1/2" diameter Hilti bolt testing showed capacities less
than the value required by GAI specifications (8% low). However,
the GAI design practice had been to double anchor bolt loads in
order to account for base plate flexibility. For the standard
4-anchor bolt base nlate, doubling the bolt load is generally
overly conserva*'.ve and the slight reduction in the capacity of
1/2" diameter anchor bolts can be offset by the doubling of the
bolt loads. Additionally, there had been only a small number of
1/2" diameter anchor bolts installed prior to their discon-
tinuat'on. A random sample of approximately five small bore pipe
support designs were reviewed and verified by tne NRC CAT that
the anchor bolt loads were in fact doubled and proper anchor bolt
allowable loads used.
V-4
,
. .
.
-
_ _ _ _ _ _ _ _ _ _ .
--_
.
.
.
(3) The ultimate capacities used by GAI for Hilti bolts are based on
Hilti catalog recommendations. The qualification testing was
done to confirm that the Hilti recommended anchor bolt capacities
were being achieved in actual site concrete.
~
(4) The use of 1" diameter Hilti bolts has been discontinued due to
the poor test results of four 1" diameter anchor bolts in a
closely spaced pattern. The 1/2" diameter Hilti bolts showed
similar poor results in a closely spaced pattern. The problem
of anchor bolts in closely spaced patterns has been reported
previously by the licensee in a 10 CFR 50.55(e) report.
The issue of Hilti bolts being installed through the drywell liner
plate is of concern to the NRC CAT due to the number of anchor bolts
being installed (6000-8000) and that the drywell must meet bypass
leakage limits. The method of Hilti bolt installation is to drill
holes through the liner plate and into the concrete behind to a depth
approximately 7", install the Hilti bolt, place HVAC metal air duct
sealer tape material (similar in consistency to putty) in the annular
space between the Hilti bolt and the drywell liner plate with a small
amount of overfill, install the attachment, and then torque the Hilti
bol t.
The attempt is made to restore in part the leak tightness
of the liner plate that was lost when the Hilti bolt was installed
through the drywell liner.
The leak tightness of.the drywell is questioned by the NRC CAT based
on the following discussion:
(1) The Hilti bolts, especially with the large number being
installed, could contribute to crack initiation or propagation in
seismic or dynamic loading conditions leading to unacceptable
through wall cracking.
(2) The General Electric (GE) topical report on drywell cracking,
NED0-10977, "Drywell Integrity Study:
Investigation of Potential
Cracking for BWR/6 Mark III Containment," dated August 1973, notes
in Section 2.2 that the results of the study do nut include any
construction defects (such as construction joints, honey-combing,
or rock pockets) or local effects of stress concentrations caused
by penetration or associated embedments. This GE topical report
was presented as evidence that the drywell liner was in fact not
required to minimize bypass leakage. However, embedments, such
as Hilti bolts, in the drywell wall were not addressed in the
GE study and in addition, ".e NRC has not formally accepted the
GE topical report.
Investigation of other facilities using the Mark III containment
design, shows that River Bend has a steel drywell liner but does
not install concrete expansion bolts through the drywell liner
plate. The Grand Gulf FSAR, Section 3.8, specifically indicates
that the drywell concrete is the pressure retaining structural
element and in fact does not utilize a drywell liner. However,
the FSAR does present an analysis and evaluation for drywell
concrete cracking.
V-5
.
'
'
'
' -
-
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_
- _ - _ - _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _
O
e
(3) Drywell bypass leakage will be tested during the pre-operational
phase at the full drywell design pressure and periodically at a
reduced pressure of three psi differential. The allowable
leakage limits for the full pressure test is 0.168 square feet of
leakage area. This limit is equivalent to approximately 1.2*, of
the space between the 8000 Hilti bolts and the drywell liner
plate contributing to the bypass leakage not even considering
other bypass leakage paths. The periodic test at reduced pres-
sure may not detect excessive bypass leakage for the full 40 year
life of the plant.
(4) Concrete cracking is a comon phenomenon resulting primarily
from volumetric changes (drying shrinkage, creep under load, and
the mal stresses) and the loading conditions. Cracking is
rc.,gnized by the American Concrete Institute (ACI) in ACI
207.2R-73 and the ACI Comittee 224 Report, " Control of Cracking
in Concrete Structures" wherein it is realized that with the use
of large, closely spaced bars and minimum cover requirements, it
will likaly require smaller maximum aggregate sizes and wetter
mixes for placement ease. Subsequent volume changes and cracking
may therefore increase rather than decrease.
It is also recog-
nized that cracks of the magnitude of 0.009 inches will allow
some leakage (water being referred to, but applicable to air).
The ACI Committee 224 report recommends a limit on the allowable
crack width for water retaining structures of 0.004 inches.
Leak tightness can in most instances only be achieved if specific
measures are taken beforehand.
(5) Several (15 to 20) small areas of voiding behind the drywell
liner plate have been identified thus far during the Hilti bolt
installation process and docu:.cnted on nonconformance reports
(NRs). These voids have occurred in almost all cases just below
the liner plate horizontal stiffener. The voiding indicates the
difficulty in achieving complete fill and consclidation in
congested areas inside the drywell wall, increasing the potential
for through wall leakage.
In addition, two NRs from Pullman Power Products (PPP) concerning Hilti
bolts in the drywell wall (NR PPPF-3842 and PPPF-3500) were reviewed.
One NR was found to be improperly dispositioned by GAI and the other NR
had bypassed the established trending program for tracking NRs. NR
PPPF-3500 described a problem with an oversized hole for a Hilti bolt.
The proposed disposition was to grout the hole and redrill it.
GAI engineering agreed with the proposed disposition. However, it is
not standard industry practice to allow grouting and redrilling of holes
for expansion anchor bolts. The NRC CAT concern is whether the grout
will actually bond tightly to the concrete to transfer the loads into
the concrete without the pulling out of the grout portion in the hole.
This is an instance of an improper engineering disposition.
'
Project and GAI civil engineering personnel had been informally moni-
toring NRs which described problems in achieving torque for Hilti bolts
in the drywell wall. Their interest is due to the fact that the
inability to achieve torque could be indicative of voiding or honey-
V-6
_ _ _ _ - _ _ _ _ _ _ _
_ .
.
.
combing of the concrete behind the drywell liner pla, ..
It was identi-
fied by the NRC CAT that NR PPPF-3842 had not been brought to the
attention of site and GAI personnel working in this area. The repair
~
was to grout the holes and redrill them as discussed previously.
As evidenced by these two NRs, it appears that Pullman Power Products
and internally within GAI, personnel are not properly distributing to
the appropriate project and GAI engineering personnel information
concerning problems with Hilti bolts and, in particular, Hilti bolts in
the drywell wall.
Engineering review by personnel knowledgecble in the
area of Hilti bolts and Hilti bolts through the drywell liner would most
likely have properly identified these two NRs as requiru.g additional
attention,
c. Conclusions
The above findings indicate that:
(1) Hilti Kwik-Bolts have been properly qualified in accordance
with specifications and procedures for their use at Perry.
In addition their installation and inspection by contractors
,
i
has been controlled by the use of specification and procedure
changes.
(2) The NRC CAT is concerned that under normal, transient, and
accident loading conditions whether the drywell wall can maintain
its leak tight integrity over its service lifetime of 40 years
considering the large number of expansion anchors currently
being installed. The preoperational drywell bypass leakage test
is important in that it will be the first test for drywell
leak tightness. This issue is under additional NRC review.
(3) From the review of two NRs, it appears that one contractor
(Pullman) and internally within GAI, personnel have not conauni-
cated to ensure that problems with Hilti bolts are properly
dispositioned and brought to the attention of project and GAI
personnel working in this area.
3. Concrete Placement
a. Inspection Scope
The concrete placement activities for two areas were witnessed by the
NRC CAT. The areas were:
three Diesel-Generator Building construc-
tion blockouts (Pour Nos. DG0-W01-638, DG0-W02-635, DG0-WO3-638) and
,
the Unit 2 Shield Building Dome (Pour No. RB2-08C-754). These
!
placements were made by Dick Corporation during the NRC CAT inspec-
tion. The activities witnessed included: pre-placement cleanliness,
rebar and embed plate placement, batch plant activities, in-process
testing, and concrete placement and consolidation. These activities
were reviewed for conformance to specifications, regulatory require-
ments and commitments. The review of applicable specifications and
procedures included:
V-7
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.
.
..
_
___
_
.
.
- Dick Specifications:
SP-19-4549-00,Rev.V,(4/12/78),Constructionof
Shield Building Walls and Domes for Reactor
Buildings 1 and 2
SP-201-4549-00, Rev. 6, (6/12/78) Attachment Specification -
Placement of Structural Concrete
SP-202-454%-00, Rev. 5, (4/5/78), Attachment Specification-
Placing of Reinforcing Steel for Safety Class Structures
- Dick Quality Control and Work Procedures:
FQC-10.1, Rev. 7, 2/3/82 - Concrete Control General
FQC-10.2, Rev. 7, 12/1/80 - Preplacement, Placement,
and Post-Placement of Concrete
FQC-10.3, Rev. 2, 11/8/76 - Reinforcing Control
CWP-10.1, Rev. 1, 2/23/77 - Pumping Concrete
CWP-10.2, Rev. 3, 12/1/77 - Placement of Concrete
- U.S. Testing Company Quality Control Procedure:
QCP-3, Rev. 11, 1/19/82 - Quality Control Procedures
for Sampling and Testing of Concrete
b. Inspection Findings
The placement areas were reviewed prior to the actual placement
of concrete, during placing activities, and during in-process
testing. The following observations were made:
(1) Reinforcing and embedded plates were of the specified size and
grade, properly located, and secured in accordance with the
design drawings, including Engineering Change Notices and Field
Variance Authorizations. Lap splices were verified to be stag-
gered and of the specified lap length.
(2) Concrete cover distances were maintained.
(3) Forms were free of standing water and debris and were adequately
secured.
(4) Construction joint surfaces were prepared, where required, by
bush hammering to expose the coarse aggregate. A Field Question
(No. 31237) was initiated on the Shield Building Dorre placement
to determine whether the vertical construction joint with a
keyway required bush hamering. GAI engineering responded that
joint preparation was only required on the horizontal
construction joint.
(5) Wall thicknesses were maintained.
(6) Batch plant operations were observed and batch tickets
reviewed against the mix design-daily mix adjustment
sheets. Batch plant operations were continuously under QC
surveillance.
V-8
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ . _
_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
_ _ _ _ _ _ _ _
. _ _ _ _ _ .
.
o
(7) The concrete placement crews were observed during placement
operations and the number of crew members was sufficient to
control the placement operation.
Concrete placement in the forms
minimized segregation of the concrete. There was no excessive
movement of concrete by vibration. One vibrator head could not
be removed from the forms (Pour DG0-WO2-635) and it was necessary
to cut the vibrator cable and leave the head embedded in the
wall. Dick NR 215 was written for this condition. GAI engi-
neering accepted this condition and the NR is now closed.
(8) Concrete in-process testing was performed by U.S. Testing at
the concrete pump discharge or truck discharge as appropriate for
the placement. The concrete was tested for slump, air content,
temperature, and unit weight and concrete cylinders taken in
,
accordance with the frequency specified in the construction
specifications. The ccncrete in the first truck for placement
DG0-W01-638 was tested and found to have an e(cessive slump (5
3/4" vs. 5").
Procedures were followed for additional field
i
testing when the concrete was found to be out of specification
l
requirements. Since approximately three cubic yards of the high
!
slump concrete had already been placed, Dick NR 214 was issued
and accepted based on acceptable cylinder strength tests at 28
days (minimum tested strength - 6155 psi vs. minimum required
,
strength - 3000 psi). The NR is now closed.
(9) Post-placement. inspection of the pours was performed by the
applicant and areas were identified in placement DG0-WO2 and
DG0-WO3 of superficial honeycombing. These areas were documented
in Dick NR 216. As part of the NR and attached to the NR were
the Perry Review Board comments on 9/8/83 which stated, " Training
of crafts to be documented and attached 1.0 this NR prior to
closeout." However, the closeout date of Dick NR 216 is 9/14/83,
whereas the training documentation indicates that training was
not given until 9/21/83 (one week after the NR was formally
closed). AR 716 was initiated to identify the cause of the
discrepancy and the steps to prevent recurrence. This is an
example of the closure of an NR prior to completion of all the
required actions (see Section VIII).
c. Conclusions
The placement activities witnessed indicate that generally concreting
is being performed in accordance with procedures and specifications.
The problems which occurred during the placement process were
properly identified, addressed by procedures, and the procedures were
followed, except in one case concerning improper closure of a noncon-
formance report prior to completion of the required actions.
V-9
.
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.
.
4. In-Situ Quality of Concrete and Reinforcing Steel Placement
a. Inspection Scope
Four construction access blockouts were reviewed by the NRC CAT
for proper reinforcing steel placement, cadweld quality.and concrece
quality. The blockouts are listed in Table V-2.
In addition, approximately 30 cadwelds were reviewed in the Unit 1
and 2 Reactor Building annulus areas. These cadwelds were being
installed as part of the reactor building containment fix and
included both cadwelds done in-place and those done above and then
put into the annulus area. The cadwelding was done by Dick.
b. Inspection Findings
In the four blockout areas reviewed by the NRC CAT, reinforcing
' steel placement was found to be in accordance with the design
drawings, including applicable Engineering Change Notices and Field
Variance Authorizations. Dowels into the blockout areas were the
specified length. Reinforcing steel bar size and grade were as
specified and lap splices the required length. Cadwelding in the
blockout areas and the Unit 1 and 2 annulus areas was found to have
evidence of proper centering of the cadweld sleeve, no excessive
voiding, no burn through of the sleeve, no slag at the tap hole, and
proper identification. Concrete quality was good with no areas of
honeycombing and good bonding with the reinforcing steel.
It was noted'that at some of the construction access blockouts,
reinforcing dowels had been accidentally bent probably by items
being passed through the opening.
In one case, the bent reinforcing
dowels had been previously identified in an NR; however, in another
case of bent rebar no NR had been initiated. CQC NR 2871 was issued
concerning the bent rebar during the NRC CAT inspection and remains
open pending closing of the access opening at a later date.
c. Conclusions
From the construction blockouts and annulus areas reviewed, it
appears that reinforcing steel was placed in accordance with the
design drawings, cadwelds were made properly, and concrete quality
appears acceptable.
5. Concrete and Soils Placement Records
a. Inspection Scope
The records associated with concrete and soils placements were
reviewed for conformance to construction specifications and regula-
tory requirements. The documentation reviewed included records of
inspection, in-process testing, material certification, surveillance
testing, and cadwelder qualification, performance, and surveillance
testing. The records covered 28 concrete placements (see Table V-3).
The review of the 28 concrete placement records included: all four
V-10
_ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ - _ _
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
contractors in safety-related concreting (National Engineering and
Contracting Company, Great Lakes Construction Company, Blount
Brothers Corporation, and Dick), a sample of 26 Receipt of flaterial
Inspection Reports (RMIRs) with their associated material certifica-
tion records (CMTRs or Certificates of Compliance), in-process
testing of concrete and aggregate, curing records, and concrete
cylinder strength testing.
In addition, the annual records for
in-process testing of cement, aggregate, and admixtures were selec-
tively raviawed primirily for the years 1976 through 1979. Three
Class A backfill inspection records and one excavation inspection
record were reviewed for conformance to the specifications and
requirements. The records were reviewed for three cadwelders
eupioyed by Dick for qualification and production testing.
b. Inspection Findings
The concrete and soils records were found to generally meet the
construction specification requirements, except in three instances.
The records were reviewed for proper frequency of testing or sur-
veillance, satisfaction of acceptance criteria. proper materials
used, material properly certified, and qualification of material and
cadwelders.
The following are the three instances in which discrepancies were
identified.
(1) In the review of monthly in-process testing of aggregates, the
NRC CAT identified one instance in which the August 1976 aggre-
gate sample was actually drawn cut on September 7,1976.
In
fact, the September 1976 sample was also drawn on September 7,
4
1976. Apparently, the aggregate sample for August 1976 was not
taken. However, material drawn on September cannot be substi-
tuted for a sample which should have been drawn the previous
month. As a result of th h finding, NR P014-2186 was initiated.
Additional investigation by the appliant of all the aggregate
sampling records revealed only three additional instances of this
occurrence.
In two instances, there was only a one day discre-
pancy and in the other case, there was a delay of only three
days. The last occurrence was in June 1979, with the others
occurring in February, April, and August of 1976. The concreting
program was initiated in 1976 in which the initial startup of the
activity could have contributed to this condition. NR P014-2186
has been closed.
(2) The review of selected US Testing records for in-process testing
of admixtures for the years 1976 through 1978 showed that in
three instances for the infrared spectrophotometric analysis
there was no documentation of the evaluation of the analysis
results. The graphical analysis was attached to the US Testing
report, however, there was no statement of the analysis evalua-
tion.
It was noted that other similar test reports did provide
an analysis evaluation. As followup to this finding, the licen-
see identified three additional instances of this occurrence
V-11
.
.
..
-___-_______ -_.
_-_
_________________________________________ __ ____
_ _ _ _ _ _ _ _ _ _ _ _ _ _ .
.
.
and US Testing was requested to perform the analysis evalua-
tion. The analyses were found to be acceptable.
It was noted that the US Testing records turned over to the
applicant had not yet been accepted. Based on discussions,
these records will be reviewed by the applicant for completeness
and adequacy prior to acceptance. As evidenced by this finding,
,
a records review for just the existence of the test report will
not be sufficient to identify any similar problems in the test
reports.
(3) A review of NR QCA-100 (Blount Brothers) identified that the
NR was voided although the specification requirements for soils
testing was not met. The specification requirements for the dry
unit weight (at 85% relative density) is a minimum of 120 pcf.
The voided NR identified test results of 119.7, 119.4, and 117.2
pcf.
It appears that this NR was voided due to a misinterpreta-
tion of the specification requirements. Based on this review, NR
CQC-2919 was initiated and GAI has accepted the test results
not meeting specifications based on actual in-place density
meeting relative density requirements. All other NRs of this
contractor were reviewed by the applicant and no additional
instances were identified. This NR is now closed.
c. Conclusions
From the concrete and soils placement records reviewed above, it
appears that these activities were performed in accordance with the
construction specification and regulatory requirements. The three
instances in which records did not meet specification requirements
can be attributed to the fact that the concrete and soils programs
were just beginning at that time and some minor problems can be
expected. Additional investigation by the applicant of two instances
shots that the problems identified were isolated cases. For the
third instance concerning US Testing test reports without analy-
sis evaluations, the NRC CAT finding should be considered prior to
the applicant's acceptance of these records.
6, Containment Vessel Shell Steel Installation
a. Inspection Scope
The containment vessel shell steel installation activities performed
by Newport News Industrial (NNIC0) were reviewed. The shell steel
installations included six stiffener ring assemblies and one pene-
tration stiffener area (approximately 25 members) in Units 1 and
2 (see Table V-4).
The stiffener installations were inspected
against the design drawings for configuration, member size, and weld
size and appearance.
.
V-12
_
_ _ _ _ _ _ _ _ _ _ _
,
. _ .. . .. . . . .. _ --_ _ _______ _ _ _
o
.
b. Inspection Findings
For the shell stiffener steel installations inspected, no problem
areas were identified. The configuration and member sizes for all
items were found to be in ccnformance with the design drawings and
associated NRs. The welding was of the proper size and length and
was visually acceptable.
c. Conclusions
From the above findings, it appears that the containment vessel
steel stiffener rings and penetration stiffeners have been installed
in accordance with the applicable design drawings.
7. Structural Steel Installation
a. Inspection Scope
The structural steel installation activities of Pittsburgh Bridge
and Iron (PBI) Industries were reviewed by the NRC CAT.
Installed
and QC accepted structural steel was inspected for member size,
configuration, conformance of bolted and welded connections to the
design drawings, and structural steel bolts were tested using a
calibrated torque wrench to determine whether the bolts were properly
tightened. The building structures inspected were: Units 1 and 2
Auxiliary Building, Unit 2 Suppression Pool, Unit 2 Reactor Building,
Units 1 and 2 Control Complex, and Intermediate Building (see Table
V-5).
The structural steel installations reviewed included: 33 members and
stiffeners checked for proper size and dimensions, 26 bolted and
welded connections, and approximately 260 bolts were tested for
minimum installation torque.
b. Inspection Findings
The 33 structural steel members and stiffeners and the 26 bolted and
welded connections were found to be in conformance with the design
drawings except for one case. High strength bolts were tested to
determine whether minimum torque requirements were met. The bolts
tested included 3/4", 7/8", and 1" diameter A325 bolts tested to 355,
570, and 850 ft-lbs respectively. The test torques were compared
with those values obtained by Skidmore testing and were found to be
in general agreement. The Skidmore testing was witnessed by the NRC
CAT and specification and precedure requirements were met. The
approximately 260 bolts were found to have at least the minimum
torque requirement.
The only discrepancy identified by the NRC CAT was undersized clip
angles fcr a column to embed plate connection. The discrepancy
is at Elevation 661' of the Control Complex building at column lines
CC-6 and 3'-0" north of CC-E (column mark number 715-C3). The
installed clip angles were 5"x3"x1/2" (6" long), however, the design
drawings specified clip angles 6"x4"x1/2" (6" long). The clip angles
V-13
.
. . .. .
._ ..
_ _ _ _ _ _ _ _ _ _ _
__
__
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
.
.
were installed in late 1979. Based on this finding, NR PBI-982 was
initiated to investigate the cause for the discrepancy and identify
any other similar discrepancies in clip angle size. Based on the
additional investigation, the following was identified:
(1) Similar discrepancies exist for five other columns. All six
column connections are located in the same structural bay and
,
elevation of the Control Complex.
(2) Additional investigation t'y the applicant and NRC CAT for proper
clip angle size revealed no discrepancies other than those
described in (1) above.
(3) Revision A to drawing D-514-301 specified the change in clip angle
size from 5"x3"x1/2" to 6"x4"x1/2". The only other work changed
in Revision A to the drawing was also for a change in clip angle
size and these clip angles were verified in the field to be the
proper size.
1
'
(4) A review of material shipment documents revealed that an insuf-
ficient number of the proper size clip angles were ordered and
also a PBI drawing revision had a typographical error in the
piece mark number for these clip angles.
j
(5) Recent changes at that time in job supervisor and inspection
personnel may have contributed to the discrepancy not being
identified in the installation process.
c. Conclusions
In general, the structural steel installation activities (member
size and configuration, connections, and bolt torque) by PBI
Industries were found to be in conformance with the design drawings.
The discrepancy of undersized clip angles appears to be an isolated
instance and not a generic concern based on the additional investi-
gations of work nearby, work done by inspection personnel, and work
affected by the same drawing revision.
8. Design Change Control and Nonconformance Reports
a. Inspection Scope
Design change control activities and nonconformance reports in the
civil engineering area were reviewed by the NRC CAT. The review
consisted of a sampling of nonconformance reports, engineering change
notices, and field variance authorizations for the contractors in the
civil area (National Mobile Concrete Corporation, U.S. Testing, PBI
Industries, Dick, National Engineering and Contracting Company, Great
Lakes Construction, NNICO, and Blount Brothers). This includes NRs
issued by the Perry project organization. The areas covered con-
crete, structural steel, containment vessel steel, and soils activi-
ties. Approximately 150 nonconformance reports, 10 engineering
change notices, and 10 field variance authorizations were reviewed
for: r^9per use of the design change documents, identification of
V-14
.
..
. .
_ _ _ _ _ _ _ _
-
_ _ _ _ __
.
.
the issue, proper engineering disposition, QC verification of the
disposition, and proper review for changes to the Safety Analysis
Report (SAR). Selected design change records were reviewed against
the current design drawings,
b. Inspection Findings
For the design change documents reviewed in the civil engineering
area, all were found to be performed in accordance with the program
requirements, except three instances previously discussed in Section
V.B.2 (PPPF NR 3842),Section V.B.3 (Dick NR 216), and Section V.B.5
(Blount Brothers NR No. QCA-100).
c. Conclusions
From the above findings, it appears that design changes and noncon-
formance reports in the civil engineering area were generally accom-
plished in accordance eith program and regulatory requirements,
except in three instances. These instances are discussed in detail
in previous paragraphs and/or in Section VIII.
V-15
..
..
_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ .
___
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- _ _ _ _ - _
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ _ - _
.
.
TABLE V-1: SEISMIC CLEARAf1CE PROGRAM REVIEW
Seismic Clearance
Workmanship
Calculation Review
Violation fio.
Findings
Findings
2442, 2460, 2492
Excessive lateral motion
GAI engineering did not
of fire protection piping; evaluate for lateral
in some cases lines
'
motion of fire protection
actually impact safety-
piping.
related cable trays.
821
Two supports reviewed
against design drawings;
one of two pipe supports
has missing welds.*
898
Poor weld on an adjacent
support; spring can out of
alignment on an adjacent
support (not same support
as poor weld).
1877
Only one deadweight support
for over 50 feet of floor
j
drain piping.
f
1678
Bent beam C amp.
1681
Poor support welds.
1551
Poor weld on a support
on the piping run in
vicinity of SCV #1551.
187
GAI disposition was
splatter on repair work.
" accept-as-is" although
additional supports had
to be installed.
1182
Acceptable.
Spans used in calcula-
tions checked by HRC CAT
and found to match those
actually in field.
- The applicant had recently identified tne missing welds and the condition was
documented on Nonconformance Report-PPPF 4066 dated 9/6/83.
V-16
I
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
TABLE V-1
r
SEISMIC CLEARAtlCE PROGRAM REVIEW - Cont.
Seismic Clearance
Workmanship
Calculation Review
Violation No.
Findings
Findings
2542
Acceptable.
Hilti bolt capacity check
mistake by GAI.
2519
Acceptable.
Acceptable.
1953, 1965
Acceptable.
Hilti bolt embedment
assumed for analyses,
but in some cases not
verifiable in the field
(conservative assumption
notused); improper
references to another
calculation; improper
bolt size (larger than
physically possible) used
in analysis; wrong value
used in equation allow-
able vs. actual.
2181
Acceptable; 4
supports reviewed
against design drawings.
1603
Acceptable; one
support reviewed
against design drawings.
1634
Acceptable.
Acceptable; spans used
in calculations checked
by NRC CAT and found to
match those actually
in field.
1993
Acceptable.
1970
Acceptable.
2471
Acceptable.
2306
Acceptable.
2356
Acceptable.
1630
Acceptable.
V-17
.
_ . _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
.
TABLE V-1
SEISMIC CLEARANCE PROGRAM REVIEW - Cont.
Seismic Clearance
Workmanship
Calculation Review
Violation No.
Findings
Findings
2032
Acceptable.
2053
Acceptable.
Total of 26 violations
Total of 7 GAI
reviewed in the field.
calculations reviewed.
V-18
.
.
_ _ _ _ _ _ _ _
,
.
TABLE V-2
'
IN-SITU CONCRETE QUALITY
,
Placement
Drawing
Location
Pour No.
Contractors
Date
No.
Aux. #2 Roof
AX2-SO4-652
National
10/09/79
D-462-302,
Slab
Engineering
Rev. H
D-452-304,
Rev. C
.
Control
CC0-WO3-705
Great Lakes
12/07/78
D-414-524,
Complex Wall
Construction
Rev. A
Co.
Intermediate
IB0-WO5-680
National
08/14/79
D-413-118,
Building
Engineering
Rev. D Walls
Walls
0-413-182,
IBO-W16-680
National
07/25/79
Rev. A
Engineering
0-413-162,
Rev. E
.
e
V-19
- - _ . . . . . .
.
.
TABLE V-3
CONCRETE PLACEMENT RECORDS REVIEW
Date of
Contractor
Pour No.
Placement
RMIR* Reviwed
National Engineering
Bio-Shield Wall:
and Contracting Co.
RB1-HWT1-616
06/09/79
3242, 3243
RB1-HWT2-616
06/10/79
(see RB1-HWT1-616)
RB1-HWT5-654
12/07/80
3945, 3946, 3947, 3953
RB1-HWT6-654
12/13/80
(see RB1-HWT5-654)
RB2-HWT2-618
06/14/80
3822, 3825, 3826, 3827
RB2-HWT3-630
12/14/80
(seeRB1-HWTS-654)
Drywell Wall:
RB1-W01-616
06/04/79
3219-3224
RB1-WO2-630
07/13/79
RB1-WO3-645
10/16/79'
3508, 3509, 3512
RB1-W181-641
02/22/80
RB2-W01-616
07/30/82
4359, 4361
RB2-W01-648
02/06/81
RB2-W02-648
02/06/81
RB2-WO3-646
12/04/80
Great Lakes
Control Complex
Construction Co.
Basemat:
CCO-M27-575
12/15/76
CCO-M22, 28,
01/05/77
32-575
CCO-M29-568
11/30/76
CC0-M31-575
12/15/76
Emerg. SW
Pump House:
EPH-W11-585
10/04/78
2679, 2682
EPH-W1-585
08/30/78
- RMIR - Receipt of Material Inspection Report with attached material certification
records
,
V-20
-
.
__
_
_
f
.
.
l'
l
l
l
TABLE V-3
CONCRETE PLACEMEf1T RECORDS REVIEW - Cont.
1
!
Date of
Contractor
Pour No.
Placement
RMIR* Reviwed
i
Blount Brothers Corp.
Reactor Building
l
Basemat:
RB1-M1-574
09/22/76
RB1-M4-574
11/01/76
RB2-M3-574
11/19/76
1042, 1045, 1046
RB2-MS-575
11/24/76
i
l
Dick
Shield Building-
l
'
RB1-W6-677
12/15/77
RB1-W6A-677
11/07/78
- RMIR - Receipt of Material Inspection Report with attached material certification
records
.
d
V-21
- - -
_ - _________________
.
.
TABLE V-4
CONTAINMENT VESSEL SHELL STEEL
NNICO
Location
Assembly No.
Drawing No.-
Unit 1 - Shell Stiffeners
Ring No. 4
98-7
249716 Rev. F
99-46
249716 Rev. F
Ring No. 5
97-1
249717 Rev. D
Ring No. 6
99-9
249717 Rev. D
Unit 2 - Shell Stiffeners
99-17
249716 Rev. F
94-2
Unit 1 - Penetration Stiffeners
249923 Rev. F
Elev. 592'-2" to
249924 Rev. D
604'-11"
249925 Rev. D
Az. 23 -30' to
249926 Rev. D
32'-00'
with NR
No. P017-758
4
,
i
V-22
_ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _
.__
_
_l
, .
.
. . . _ . .
___
.-
.
TABLE V-5
STRUCTURAL STEEL INSTALLATION
NRC CAT Inspection Area
Structure
Drawing No.
Member Size
Unit 1 Aux. Bldg.
D-512-023
and Connections:
D-561-011
0-561-084
Unit 2 Reactor Bldg.
D-561-051
'
D-512-066
Unit 1 and 2 Control
D-514-101
l
Complex
D-514-102
D-514-011
'
.
D-514-022'
l
!
D-514-301
D-514-302
0-514-303
Intermediate Bldg.
D-513-015
D-513-018
j
Bolt Torquing:
Unit 1 and 2 Control
D-514-021
Complex
D-514-022
0-514-101
D-514-201
0-514-202
Unit 2 Aux. Bldg.
D-562-021
Unit 2 Reactor Bldg.
D-561-020
D-561-021
V-23
__ _ ______- ____.____ ___
. - - - -
- _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _
.
.
VI.
MATERIAL TRACEABILITY, STORAGE AND MAINTENANCE
'A.
Objective
The objective of this portion of the inspection was:
to examine material
traceability and centrol, to review storage and maintenance of safety-
related equipment and material, and to determine the adequacy of the
applicant's program relative to these activities.
-
B. Discussion
The approach used to perform this part of the inspection was to identify
and select samples of installed safety-related material and equipment for
examination. Some samples of delivered material and equipment not yet
installed, but stored in warehouses or lay-down areas, were included. A
total of 178 samples were examined to varying extents.
Applicable procedures for these various activities were reviewed. Table
VI-1, " Summary of Samples", indicates the Perry Project contractors con-
tacted and the types of activities and samples examined. Table VI-2,
" Sample Breakdown By Contractors", shows the number and type of samples
applicable to the selected contractor. Table VI-3, " Weld Filler Material
,
'
Compliance", contains a list of weld filler material samples.
The following sections describe the results of the inspection in the areas
of material traceability, storage, and maintenance.
1. Material Traceability
a. Inspection Scope
_
A total of 178 samples were examined for traceability to drawings,
specifications and procurement records, if applicable. Supplier
certification, including required Certified Material Test Reports
(CMTR) or Certificates of Compliance (C of C), heat numbers or other
required documentation were reviewed. Table VI-2 indicates the
types and quantities of samples examined.
b. Inspection Findings
In general, it was noted that the applicant and contractors per-
forming safety-related work had appropriate procedures in place for
control of material and for material traceability. The applicant
utilizes a computerized Master Parts List (MPL) program to control
the identification of equipment and components on a project-wide
basis. An overall records management program had been planned and is
now being implemented to help control the flow and transfer of
documentation from the Construction to the Operation phase. Several
deficiencies involving material traceability and material control
were noted by the NRC CAT inspectors as follows:
VI-1
____ - ___________________ _
_ _ _ _ _ -
..
_
.
.
(1) Material Identification Markings on ASME Class 1 Hangers
Lack of material identification markings on parts of ASME Class 1
hangers was noted for Reactor Recirculation (B33) and Main Steam
(Nil) Systems.
The NRC CAT inspection of material traceability for General
Electric (GE) ASME Section NF Class 1 supports / restraints identi-
fled problems regarcing the lack of visible unique identification
marking of support / restraint items, marked materials not trace-
able to verification documentation and the thoroughness of the GE
material traceability reverification program.
A prior audit by the Cleveland Electric Illuminating (CEI)
project organization and follow-up activities revealed the lack
of visible unique identification marking of support / restraint
items, including the lack of visible marking after welding on 14
clevises involving 14 of 34 hangers for these systems. Two
nonconformance reports (NRs) [GE-38-0522 and GE 38-0523] were
issued requiring reverification and recording of material
identification for parts of the hangers. Samples were cut from
the 14 clevises for chemical analyses, and the results confirmed
the proper material for the clevises. Even though the two NRs
were prematurely closed out, the applicant stated that other
" reverification work was proceeding" (This early close-out of
NRs is discussed further in Section VIII). New reverification
drawings were being prepared. The NRC CAT inspection of four
hangers, however, resulted in the questioning of the clarity of
a marking on one additional clevis, and the lack of the visibility
of material identification markings on cther parts.
The applicant initiated action for a chemical analysis to be made
of a sample of material from the additional clevis, and issued a
new NR (GE 38-0708, dated 9/6/83) to require completion of material
identification and the recording of material markings for the
Main Steam and Reactor Recirculation hangers.
Also, the NRC CAT inspectors noted three clamp studs for hanger
H1028-1 marked as 055B, yet this marking was not on the appli-
cable material letter code list. The applicant indicated that
this matter had already been identified under the NR activity and
i
had not been fully resolved. A letter dated 9/2/83 -from ITT
l
Grinnell (the hanger supplier) confirmed that the material
specified was SA-36, which is designated as "A" on the code list.
The licensee stated that in resolution to this documentation
deficiency, reference would be provided consistent with the ITT
Grinnell letter.
The controls that Pullman Power Products (PPP) exercises to
maintain material control and traceability of ASME Section NF
support / restraint materials were evaluated. This evaluation
included a review of procedures, discussions with responsible
individuals, verification of records to hardware traceability for
four supports (1E21-H014, IE120-H010,1E51-H037 and 1E12-H748),
VI-2
r
L
.
_ _ _ _ _ _ _ . _ _ _ . _ _ . _
.-
- _ _ _ _ _ _ _ _
o
.
and field observations. The NRC CAT found the overall controls
regarding receiving, marking and maintenance of traceability
through installation for PPP to be in accordance with
requirements. A documentation weakness in the program had been
corrected in the latest revisicn to Pullman Procedure IX-6,
" Installation and Inspection of Pipe Supports" by specifically
requiring QC verification and recording of material heat or LCN
numbers on process sheets at installation.
(2) Weld Filler Material
Twenty-one samples of weld filler material were examined and
traceability documentation, including CMTRs and heat numbers,
were reviewed. Table VI-3 is a listing of samples reviewed
including those examined in detail. However, questions were
raised regarding the material data for three of the samples as
follows:
(a) Weld Wire ER-705-2, 1/8" x 36", 1200 lbs., GE Purchase Order
No. 380N0803-524, GE Specification GEP-PS-5011 Rev. 7 Heat
No. 401L3151. On reviewing the CMTR for this material, it
was noted that N/A is marked in the " Stress Relieved" block
under " Additional Test Results". This material, if used in
applications specifying ASME Code NB-2430 (Weld Metal Tests),
must undergo time at post-weld heat treatment for eight
hours. The applicant indicated and later confirmed that no
applications for this material were involved which required
the eight hours of stress relief prior to mechanical testing.
(b) Insert Material,1/8"x5/32", 5000 f t. , E70S-2 or 6, SFA5.18,
Pullman Purchase Order No. 7691-575, Heat No. 4644B131. On
reviewing the CMTR dated 9/3/83, it was noted that exactly
identical impact test results were listed foru ix sets of
test results. Since it is not considered probable that six
actual test results would be exactly identical, the accuracy
of the CMTR listing of test results was questioned. The
applicant proceeded to examine this matter further in an
attempt to explain the unusual impact testing values. A
welding engineer contacted the testing laboratory involved
and was advised that the six test results were actual
results, and that written confirmation would follow.
(c) Filler Material (for consumable insert rings), ER 308, Heat
No. X43724. This heat of filler material failed to have the
required delta ferrite content. GE Specification Z1A2005,
Paragraph 4.3.4, " Welding Materials," requires a delta
ferrite content of 8% minimum for the 308 filler materials.
GE CMTR for Heat No. X43724 indicates a delta ferrite content
of 6.5%.
This material was utilized for welding of at least
three details. The affected details are 1,em G010A-1,
G012A-30-1, and G011A-90-1. Although not meeting site
'
specification requirements, the subject filler material does
meet the minimum delta ferrite content of 5% specified by NRC
Regulatory Guide 1.44, and ASME Section III, Subsection NB.
Two NRs were issued to document these conditions (NRs TAS0063
andTAS0064).
VI-3
-
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
O
(3) Fasteners
'
Examination of 32 samples of fasteners, both installed in the
plant and in contractor's bins revealed several deficient conci-
tions regarding material control as follaws:
(a) Bolts in Bin (Comstock Storeroom). A bin and a carton in the
bin were both labeled A-325. However, 1/2" x 1 1/2" long
bolts in the carton showed a marking B7 and manufacturer's
identification on the heads of the bolts. A review of
documentation revealed that the carton of bolts were of
material SA 193 Gra7 and that a CMTR was filed for these
bolts. The bin and carton were incorrectly marked for these
bol ts .
(b) Bolts for Battery Racks 1R42-S002 and 2P42-S0_0_3. The NRC CAT
3
inspectors reviewed the vendor's manual and appropriate
design documents for these installations. One document
(Flight Dynamics, Inc. Report FDI A-3-82 prepared for Exide
Power Systems Division) detailed the seismic analysis of two
step "G" size high seismic battery racks. Based upon this
report, it was determined that the 125V DC Battery racks for
the Perry Nuclear Power Plant (PNPP) had been seismically
qualified using SAE Grade 5 and Grade 2 bolting materials.
The NRC CAT inspection of the Unit 1 Division 1 battery rack
disclosed a total of forty-eight (48) bolts which were of
indeterminate material; i.e., the bolts were not marked
SAE Grade 2 as specified. The inspection of the Unit 2,
Division 2 battery rack indicated a total of seventy-four
(74) bolts with the same status.
The NRC CAT inspectors reviewed vendor (Exide) shipping
documents and receiving inspection reports to ascertain what
material types were supplied. Page 3 of the packing list,
dated 6/8/79, indicated that all bolts supplied were SAE
Grade 5 or ASTM A-449 or better. Additionally, a vendor
surveillance report (Gilbert / Commonwealth Quality Assurance
Division Report 9948-80-05, dated 2/29/80) indicated that the
vendor had supplied SAE Grade 5 or ASTM A-449 or better
bolting materials. Discussions with the installing contrac-
tor indicated that the installation had been accomplished
using only vendcr-supplied materials.
Further historical
review of the battery rack installation records and discus-
sions with the applicant did not disclose any information
that would help to clarify why bolting material other than
that specified and supplied was used in the installation of
the 125V DC battery racks. As a result of this inspection,
the applicant issued NR 0QC-307 recommending that all bolts
in question be replaced with the SAE Grade 5 material and
that the bolts in question be submitted for testing.
VI-4
.
..
. .
..
_ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _
.
.
.
(c) Bolts for 4KV Switchgear Cabinet 1R22-5006. The vendor had
specifiec by letter. that switchgear interTrame bolting would
be accomplished with SAE Grade 2 hardware. Bolts , installed
were not marked SAE Grade 2 as specified.
The NRC CAT inspectors reviewed installation inspection
records for the equipment. These records did not indicate
deficiencies relative to bolting materials. As a result of
this inspection, the applicant initiated NRs 0QC-0324 and
0QC-0325 to address these problems.
(d) Bolts for Flanged Joints of Diesel Starting Air Liae 1R44509.
Some studs for fianged joints of the Diesel Starting Air Line had
markings, but others had no markings. Four of eight studs at one
flange joint were not marked. Some of these joints had missing
studs.
(e) Bolts for Class 1E Motor Control Center 2R24-5019.
Examina-
tion of hardware attaching adjacent cabinets of the Motor
Control Center (MCC) revealed that 1/4" round head bolts and
nuts were used.
It was noted that some of the bolt heads and
nuts were not properly seated. Some used flat washers,
others did not. The bolts appeared too small for the holes
in the cabinets and improper seating resulted. However,
examination of other Class IE cabinets revealed that larger
bolts were being used, and as in the one case of cabinet
2H13-P747 1/2" bolts had been installed (to comply with an
NR). The applicant issued four NRs on 9/19/83 to initiate
action to check and correct this improper fastener condition
(NRs 0QC-318, 0QC-319, 0QC-320 and 00C-321).
(f) Fasteners for Standard Com0066.7t Supports. The NRC CAT
inspectors observed in four areas that crafts were not
maintaining traceability of small items and threaded compo-
nents of standard component supports (catalogue items such as
struts, clamps, spring cans, snubbers, and other similar
types of components).
Paragraph 5.2.3 of Pullman Procedure
IX-6 requires items to be marked or remain attached as an
ossembly until the time of installation. The following
conditions were observed in different areas of the Auxiliary
Building, 620' elevation on September 13 and 14,1983.
. Pipe clamp for 1E32-H014 with a missing bolt
. A 12" pipe clamp with no bolts, no marks, no tags
. Pipe clamp for 1E12-H526 with a missing bolt
. Snubber clamp with a missing load pin, no tags,
or markings with support or LCN numbers
. Spring hanger 1E12-H184 with missing rod, eye-
nut, clevis, pin and pipe clamp
VI-5
c
"'
'
-
E
_._
_ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
,
I
t
C. Conclusions
The overall material control and material traceability program was
considered adequate, except for some traceability program deficien-
cies and for the material control of fasteners and small items.
Traceability program problems were identified regarding the
thoroughness of application of the traceability program procedures
for material identification markings on ASME Class 1 hangers and
the thoroughness of the contractor's revesification efforts to
satisfy site traceability program requirements for ASME Class I
hangers.
Regarding material control, six of the 32 samples of fasteners
examined revealed improper control of the application of fasteners.
Five conditions of improper control of traceability of small items
and threaded components of standard component supports were noted.
2. Storage
a. Inspection Scope
A total of 62 samples were examined for appropriate storage in
warehouses, in laydown areas and in the plant. Site storage facili-
ties themselves were also examined.
b. Inspection Findings
Warehouses and outside storage facilities were found to meet require-
ments.
It was noted that the only Class A storage facility, the
site Calibration Laboratory, utilized properly calibrated temperature
and humidity recording indicators showing conditions within required
limits. Held rod storage, issue stations and holding ovens in
various locations on tF site were examined and found to be satis-
factory.
.
Several examples of improper storage and protection (from damage and
deterioration) of safety-related equipment in the plant and in a
lay-dov:1 areas were noted. Some protective covers were missing.
Some equipment damne from nearby construction activities was noted.
Poor housekeeping was noted on or around the equipment. Also,
improper marking of safety-related steel was noted in an outdoor
lay-down area. The following is a list of samples examined:
(1) Motor Control Operated Valve 1E22-F001
(2) Motor Control Center 1R24-5024
(3) Reactor Core Isolation Cooling Pump 1E51-C001
(4) Emergency Closed Cool Pump / Motor 1P42-C001B
(5) High Pressure Core Spray Pump / Motor 1E22-C001
(6) Safety-related pre-fabricated structural steel parts for Reactor
Building No.1 in the "PBI/ Kelly" lay-dovin area.
Regarding item 6, the procedures reqire labeling of these parts for
identification and -control af ter coatings are applied. These parts
VI-6
.
.
_ - _ _ _ _ _ _ _ - -
. - - _ _ _ - . __ _
l
.
.
4
were found to be not adequately marked. The metal tag for part
239M2 was corroded and separated from the part. Tags were missing
and parts were temporarily marked with a soapstone marker for parts
240M2-L, 240 M2-L, 240 M2-R,.and 240 M2-R.
The NRC CAT inspector was informed that a Field Question (F.Q. 31006)
was issued 8/19/83 requesting Engineering direction to improve the
marking technique and remark steel prior to the onset of adverse
weather. Re-identification and re-marking of steel in storage was
authorized for the Field Question 8/22/83. The NRC CAT inspector was
informed 9/28/83 that re-identification and re-marking, with QC and
Engineering assistance, was proceeding initially for Turbine Building
steel in storage, and that re-identification and re-marking of coated
safety-related Reactor Building items would follow,
c. Conclusions
The storage and related procurement, receipt and warehouse procedures
as well as the facilities themselves met regulatory requirements,
except for storage of some safety-related material and equipment in
the plant. Five of 62 samples inspected for storage were found to be
inadequate.
3. Maintenance
a. Inspection Scope
A total of 43 samples of safety-related equipment were examined.
Maintenance requirements and history records were reviewed for items
stored in warehouses and installed in the plant.
b. Inspection Findings
Manual lists and schedules for equipment received at the central
warehouse, and determined by engineering to require maintenance, are
maintained by central warehouse personnel. Records are kept of
maintenance performed on each item.
Items issued to Comstock and
Johnson Controls are then controlled by manual lists and maintenance
schedules by these two contractors. Other material and equipment
requiring maintenance after issuance for installation are listed in
the project computerized system for scheduling and control of mainte-
nance. The applicant's computerized system used during Construction
will later evolve into the Operations mai.n.tenance control system.
As items are turned over from Comstock and Johnson Controls, such
items will also be included in the Operations maintenance control
system.
It is planned that the overall Operations maintenance
program will utilize the computerized data base, and the system will
then be further developed to meet operational maintenance needs. The
NRC CAT inspector inquired regarding the omission of computerized
control of maintenance in the central warehouse and of maintenance
performed by Comstock and Johnson Controls.
It was noted that a
recent Project Internal Audit of Maintenance identified ceficiencies
VI-7
_ _ _ _ - _ _ _ _ _ _ _ - _ _
_
.
_
_
-
-_ _
-_
_ - - _ _
.-
.
regarding the control of maintenance in the warehouses, and that this
matter is being considered further.
On examining equipment in the plant requiring maintenance control by
the applicant and reviewing maintenance records, no unsatisfactory
conditions were noted. 'However, on reviewing procedures and activi-
ties pertaining to storage and maintenance, and examining samples and
records in central warehouses #1 and #2, some celays in initiating
required maintenance provisions were noted.
An initial review of nine items revealed three with periods exceeding
10 days:
(1) over five years, (1) over thirty days, and (1) over
five months. T.his requirement is defined in " Nuclear Design and
Procurement 3-1301", Rev. 4, dated 8/16/82 which states that "the
Responsible Engineer is to forward a copy of the Storage. Maintenance
Requir.ements (SMR) form within 10 days of receipt of the Receiving
Report".
Specific examples are as follows:
Received
SMR Date
a.
~High Pressure Core Spray
12/01/77
01/25/83
Pump Bowl Assy. 2E22-C001
b.
Low Pressure Core Spray
04/20/83
05/31/83
Motor E21-C001 (Spare)
c.
Power Supply MR 20078
05/05/82
10/18/82
Further review of records for a total of 43 samples revealed 11
for which the SMR was not issued until later than 10 days.
Also, SMRs had never been issued for 18 of the 43 items, some of
which may have required maintenance,
c. Conclusions
In general, the overall project program for control of maintenance
I
was found to be adequate, except for the control' of maintenance in
I
the central warehouses. Eleven of 43 samples revealed situations
I
where the Responsible Engineer had not issued Storage Maintenance
Requirements for safety-related equipments requiring maintenance
until later than the time specified by procedure (which is within 10
days after receipt). Three of the samples revealed that receipt of
the 5torage Maintenance Requirements had not occurred for periods of
~30 days to 5 years.
VI-8
.
_ _ _ _ _ _ _
_ _ _ _ _
TABLE VI-1 - SUFF.ARY OF SAMPLES
Contractors
Activities and Samples
No. of Samples *
Pullman
Piping, hangers, weld joints,
36
welding mtl., fasteners
NSSS equip., piping, hangers,
26
I
weld joints, welding mtl.,
I
fasteners, shims
)
1
Comstock
Electrical equip., cables,
30
I
hangers, weld joints, welding mtl. ,
fasteners
Instru. & Controls, racks,
22
,
welding mtl., fasteners, tubing
I
RIC0
HVAC equip., control panels,
16
mtl., fasteners
PBI
Structural mtl., weld mtl.,
23
fasterners
NNI
Liners, vessels, weld joints,
22
weld mtl., fasteners
Dick
Cadweld sleeves
3
TOTAL
178
- NOTE: Some items served as multi-purpose samples
l
(e.g., for traceability, storage and maintenance).
l
.
VI-9
..
.
TABLE VI-2 - SAMPLE BREAKDOWN BY CONTRACTORS
Pullman
Comstock JC
RICO
PBI
NNI Dick Total *
1.
Equipment
5
8
13
4
5
-
-
-
35
7
-
-
3
2. LPipe
4
-
-
-
-
-
-
15(L)
-
-
3
2
8
3.
Steel
2
(Structural)
2
1
1
5
-
9(L)
4.
Steel Plate /
-
-
-
Sheet
10
5.
Hangers /
2
5
2
-
1
-
-
-
Supports
6.
Weld Filler
6
2
3
2
2
3
3
-
21(L)
Material
7.
Weld Joints
12
4
2
2
2
4
11
37
-
3(L)
-
-
3
8.
Elec. Cables
-
-
-
-
-
- (Reel s)
9.
Fasteners
5
5
7
2
3
7
3
-
32
10. Shims
2
-
-
-
-
-
-
2(L)
-
11. Cadweld
-
-
-
-
-
-
-
3
3(L)
-
-
-
4
-
-
-
-
4(L)
12. Tubing
TOTALS
36
26
30
22
16
23
22
3
178
- L = Lots
.
VI-10
_
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
--__-
__ - ___ _ _
_ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
..
.
TABLE VI-3
WELD FILLER MATERIAL COMPLIANCE
Material
H.T. No./
Compliance
Contractor
Designation
Material I.O.
Comments
ER308R
NG460
Acceptable'
05845
Acceptable
05345
Acceptable
06004
Acceptable
E308-16
95533
Acceptable
741102
Acceptable
E308-16
740654A
Acceptable
434788
Acceptable
E308-16
741619
Acceptable
-
740014
Acceptable
75213
Acceptable
X43724
Les: than 8%
Ferrite
'
l
ER70S-2
401L3151
Acceptable
401K0151
Acceptable
'
8M13C Mix 22 (trace)
Acceptable
GE .
E7018
401J1571
Acceptable
NNI
E308-16
77NNI507
Acceptable
NNI
E308-16
77NNIS08
Acceptable
NNI
E309-16
77HNI509
Acceptable
NNI
77NNI549
Acceptable
NNI
80NNIO97
Acceptable
NNI
81NNIO39
Acceptable
NNI
77NNI1525
Acceptable
NNI
E7018
79NNIO19
Acceptable
NNI
E7018
81NNIO55
Acceptable
NNI
E7018
77NNI589
Acceptable
NNI
E7018
115K (trace)
Acceptable
NNI
E7018
115L (trace)
Acceptable
NNI
08544
Acceptable
PPP
E7018
70612
Acceptable
PPP
743927
Acceptable
PPP
3548R308L (K shape)
Acceptable
PPP
065312
Acceptable
PPP
E705-2
4644B131
Identical impact
test results
E7018
4121C1391
Acceptable
JC
07665
Acceptable
JC~
E7018
422S1961
Acceptable
PBI
E7018
33042
Not checked
PBI
AA7018
422W8351
Not checked
PBI
467267
Not checked
COMSTOCK
E7010-Al
614AF (trace)
Not checked
COMSTOCK
E7018
34-4B2A (trace)
Not checked
COMSTOCK
E7018
2-215C4B (trace)
Not checked
RICO
E7018 (LH)
411T1231
Not checked
RICO
E7018 (LH)
412N2851
Not checked
VI-11
_ _ _ _ - _ - _ _ _ _
--_-__
_ _____-__ -__
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ ,
.
.
VII. QUALITY CONTROL INSPECTOR EFFECTIVENESS
A. Objective
The objective of this portion of the inspection was to determine if quality
control inspectors function freely in performing their tasks, without
intimidation by craft personnel or supervision, and to determine if inspec-
tion personnel are qualified, trained and have the organizational freedom
to perform their tasks.
B. Discussion
1. Inspection Scope
l
Implementation of the Quality Control Program was determined from
l
discussion with the Quality Control personnel and their supervisors,
reviews of the inspector training and certification procedures, review
of the inspector training records, and review of the recording of
inspectiun results.
2. Inspection Findings
a. Inspector Support
Discussions were held with inspectors selected from the applicant and
contractor organizations performing work on the construction site. A
total of thirty inspectors were ;iected from the.Clevelond Electric
Illuminating (CEI) organization and from the eight contractor organi-
zations. The discussion subjects included the inspectors areas of
assignment, experience, education, training, and the inspectors
knowledge of any form of intimidation by craft or supervisor person-
nel.
During these discussions, certain issues were raised that could
have an effect on inspector effectiveness relative to one contrac-
tor's organization. The significance of these points will require
investigation beyond the scope of this inspection and has been
referred to the NRC Region III Office for further review.
b. Inspector Qualification / Certification
Records were reviewed to determine whether the training and certifi-
'
cation files for the inspectors interviewed contained the correct
documentation to meet the Applicant's Quality Assurance program
commitments.
(1) It was found that inspectors were certified prior to performing
inspections. Appropriate forms and documents were on file in
accordance with the applicant's commitments to ANSI N45.2.6,
" Qualification of Nuclear Pcwer Plant Inspeciton, Examination,
and Testing Personnel Requirements". These documents attest to
the inspectors experience, education and training.
VII-1
_ _ _ _____
_.
-
.
.
.(2). Training and indoctrination of inspectors was appropriately
documented. Training and indoctrination of newly hired inspec-
tors, in some instances, was done in only a fcw days, which could
be questionable. However, of the inspectors reviewed, all had
i
inspection experience at other nuclear construction sites.
1
3. Conclusions
There was no reported intimidation of inspector by craft or super-
vision. However, in one contractor organization, there were issues
,
'
raised by QC inspectors that require further review. The certifi-
cation and training of Quality Control inspectors reviewed met ANSI
standard requirements.
VII-2
. .
.
. .
..
_ - _ _ _ _ _ _ - _ _ _ _ _ - _
-
.
.
VIII. QUALITY ASSURA!!CE
A. Objective
The objective of this review was to determine the adequacy of selected
portions of the applicant's Quality Assurance (QA) Program. The program
was reviewed to establish that:
it was appropriately defined in instruc-
tions and manuals; the construction quality assurance effort was monitored
through audits and other management actions; on-site contractors work was
reviewed and monitored; on-site contractor audits were performed effec-
tively; the applicant or selected site contractors had instituted an effec-
tive corrective action system; and instructions and drawings used during
the construction process were controlled.
B. Discussion
1. Inspection Scope
Implementation of the Quality Assurance Program was determined by
reviewing: the organizational structure; the construction audit pro-
gram; the corrective action system of the applicant and selected site
contractors; and a sampling of design / installation drawings to assess
document control (current issue status).
2. Inspection Findings
a. Organization
Quality Assurance functions were performed by CEI and site organi-
zations contracted to perform construction work. The quality assur-
ance function appeared to be performed by an organization having a
sufficient degree of authority and freedom,
b. Audits
The project and contractor audit programs were reviewed to the
applicant's commitments defined in the CEI QA program.
(1) CEI Program
The CEI audit program is performed to ensure that commitments and
responsibilities at the project level are met and to ensure that
contractor commitments have been met. The program is implemented
by various corporate and project level procedures that fully
describe the program.
Audit areas were reviewed for: scheduling; development and use
of checklists; reporting; audit finding resolution; and auditor
qualification and certification.
Audits from 1981, 1982 and 1983 were selected for review.
Eighteen project level audits and forty audits of contractor
activities were selected for review. Audits of contractor activi-
VIII-1
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
-.
.
ties varied from a complete review of the contractor's program
compared to 10 CFR 50, Appendix B, to a review of a specific work
activity (for example, cable pulling). Although the number
varied from year to year, ir. the order of 150 audits of contrac-
tor activities and 35 audits of project activities were performed
i
each year.
The comments provided below are based on these audit reviews and
personnel interviews.
(a) Audit Scheduling
Document reviews and interviews of personnel associated with the
audits performed at the project level revealed that a system of
annual audit scheduling with quarterly review and updating was used.
Audit schedules were systematically developed and periodically
reviewed to factor in supplemental audits.
The review of completed contractor audits and the Construction
Quality Surveillance (CQS) audit status log revealed that audits
were performed on a periodic bases to monitor contractor activi-
ties.
(b) Audit Reporting
Audit reports prepared by each part of the CEI organization
provided a description of the audit scope; identification of
auditors; persons contacted; summary of results; and a descrip-
tion of any deficiencies or findings.
The NRC CAT found that Audit findings were clearly written. The
QA program i$equired that the finding be evaluated for adequacy,
and described the action taken to prevent recurrence be
described.
(c) Audit Program Effectiveness
The combination of audits performed at the project level and the
audit and surveillance inspections performed at the contractor
level in most cases monitored and controlled construction con-
tractor activities.
One weakness in the program was the length of time taken by some
l
contractors to resolve audit findings. Some contractors, Pullman
l
Power Products and L. K. Comstock for example, allowed audit
[
findings to remain unresolved for nearly a year. Some audit
I
findings were made in 1981 and 1982. CEI action was not effec-
tive in resolving this problem. There has been improvement
in the time taken to resolve audit findings in 1983. NRC RIII
had previously identified this proolem and is monitoring it as
an unresolved item (NRC Report 50-440/83-12).
VIII-2
- __ _ __________ _-__ -
_ _ _ _ _ _ _ _ _ _ _ -
!
-
.
(d) Auditor Qualification and Certification
The records and certification reports of 12 Lead Audito s in the
CEI audit program were reviewed. Lead auditors were selected
from CEI organizations auditing at the project and at the con-
tractor level of activity. The~ program was established and Lead
Auditors were certified to the requirements and applicant's
commitments as defined by ANSI N45.2.23, " Qualification of
Quality Assurance Program Audit Personnel for Nuclear Power
Plants."
(2) Contractor Audit Programs
A sampling of contractor audit programs was made to determine if
the contractor programs complied with CEI committments. The
programs.of Robert Irsay Company, Johnson Controls Inc., L. K.
Comstock, Pullman Power Products and Metalweld were reviewed.
Results of the Review
The audit program descriptions for the contractors and the audits
reviewed met the requirements of ANSI N45.2.12 " Requirements. for
Auditing of Quality Assurance Programs for Nuclear Power Plants."
Lead auditors for Johnson Controls, L.K. Comstock, and Pullman
Power Products were certified to the ANSI N45.2.23, requirements.
Audit findings, identified by Johnson Controls, were not indi-
vidually documented for follow-up and resolution as audit find-
ings prior to June 1983.
In June 1983 the program was revised to
require that Quality Nuclear Findings (QNF) be written to docu-
ment and track any findings.
Audit findings identified by L.K. Comstock were documented on
.
Audit Finding Reports (AFR). Some AFRs were opened in September
1981 and not closed until April 1983. All of the AFRs reviewed
had been closed prior to the NRC CAT inspection.
Metalweld corporate officials performed audits of on-site
activities related to 10 CFR 50, Appendix B.
Although the
auditors were not certified in accordance with ANSI N45.2.23, the
audits appeared to be comprehensive in that the observation of
work underway and work that had been performed and inspected in
the field was included. There was little completed work (hard-
ware inspection) sampling performed by the other contractors as a
final check of the installation and inspection process.
c. Corrective Action Systems
The applicant's overall corrective action and nonconformance control
program was reviewed. The provisions for the corrective action
system are included in the Corporate Nuclear Quality Assurance
Program, Section 1600, Revision 4, dated 6/1/83. The policy states
that; for conditions adverse to quality, the cause of the conditions
VIII-3
.
--
_ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _
.
.
shall be determined and appropriate action taken to preclude repeti-
tion, the identification, cause, and actions taken are documented and
reported to appropriate levels of management, significant conditions
within the intent of 10 CFR 50.55(e) or 10 CFR 21 are reported to
appropriate-levels of management and to tne CEI Nuclear Quality
Assurance Department (NQAD).
Three of five contractor programs reviewed satisfied the system's
procedural requirements. Two contractors did not comply with the
procedural requirements. The program of two other major contrac-
tors were not reviewed since NRC Region III had recently reviewed
their programs. A potential problem with the corrective action
system of one of these contractors is still under review (NRC Report
No. 50-440/83-12).
Procedural problems identified are as folows:
(1) Instrumentation Contractor
There was no method identified to adequately identify and follow-
up on audit findings; therefore, the corrective action procedure
was used.
The procedural requirements for responses and for corrective
actions had not been enforced.
The CEI site organization issued AR 693 to Johnson Controls,
Inc., the contractor on 8/26/83, requiring that both the Cor-
rective Action and Auditing procedures be changed to resolve this
problem.
(2) NSSS Equipment Installation Contractor
Late in 1982 the contractor experienced difficulty with AWS
welding, in that the procedure was not being followed, which
resulted in cracking or other defects in the completed welds.
Twenty-two Nonconformance Reports (NRs) were written regarding
AWS welding problems during the first quarter of 1983, however,
the contractor, General Electric (GE), did not identify the
problem as a corrective action item nor as a reportable signifi-
cant deficiency either prior to or subsequent to action taken by
the CEI site organization.
The site organization issued Corrective Action Request (CAR)
- 82-28 on 1/6/83 citing the contractor for AWS welding problems.
This CAR recommended investigation of all AWS welding and proce-
dures to determine if problems also existed in other areas of
contractor work.
It was further observed that this significant deficiency was not
reported by the applicant as a 50.55(e) item. A significant
deficiency had been reported to the NRC Region III office identi-
fied as Pipe Whip Restraint Bracket Welds for 821/B33 systems
[CEI Deviation Analysis Report (DAR) 111 dated 12-21-82)]. The
VIII-4
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_ _ _ _ _
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i
significant deficiency, however, did not describe the full scope
of the problem. The above identified welding problem was the
cause for the whip restraints unacceptability as well as for
s
other safety component welding problems (i.e., polar crane, fuel
handling crane, etc) where the same AWS procedure had been used.
Tha NRC CAT Inspector learned that the applicant had initiated
action to require contractor procedure modifications and, in
addition, planned to expand the scope of the significant deficiency
report to appropriately address the deficient condition and the
extent of impact.
'
In addition to the overall review of the applicant's corrective
action systems, the NRC CAT reviewed approximately 300 NRs as refer-
enced in other sections of this report. NRs reviewed were processed
in accurdance with procedural requirements.
In most cases, noncon-
fcrmances were being identified and dispositioned as required.
Hcwever, as described in Sections III (CQA-136),Section V (NR-215
and QCA-100), and Section VI (GE 38-0522 and GE 38-0523) of this
report, certain identified nonconformances have been closed prior to
completion of the entire scope of work required by the proposed
disposition of the NR. This has resulted in some cases of less than
adequate action taken to identied deficiencies and does not comply
with the applicant's program requirements.
d. Document Control
The system utilized on site for control of issuance of documents,
such as instructions, procedures, and drawings, including changes
thereto, was reviewed by obtaining a broad base sampling of drawings
available to craft and inspection personnel and determining the
current status as maintained by the CEI site organization. No
instance of obsolete revisions of safety-related drawings was identi-
fied in a sampling of drawings as follows:
Electrical Drawings
24 drawings
Piping Iso-drawings
14 drawings
Piping Hanger Drawings
18 drawings
Structural Drawings
32 drawings
3. Conclusions
With few exceptions, both the project and contractor audit programs
reviewed were implemented to meet CEI commitments. Generally, the audit
and surveillance program performed by CEI has provided an overview that
has identified construction problems. However, audit findings identi-
fied by CEI and contractor auditors have not always been resolved in
a timely manner.
In addition, certain key issues identified in sections
II, III, and VI of this report were not identified by the applicant's
audit and surveillance organizations as well as by the contractor audit
program.
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The corrective action systems in use by some contractors reviewed were
,
inadequate. However, the CEI site organization has taken action to
provide control.
In some instances, NRs have been improperly closed
prior to completion of the entire scope of work required by the proposed
disposition of the NR.
The system for Document Control is being effectively employed by the
applicant at the Perry Nuclear Power Plant (PNPP) site.
.
G
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
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,e
ATTACHMENT A
-A.
PERSONS CONTACTED
The following list identifies the applicant's representatives, including
coordinators for specific areas, contacted during this inspection:
.
1.
Entrance or Exit Meetings
B. Barkley*
L. Beck
J. Bellack
T. Boss
M. Brown
W. Coleman
R. Davidson*
M. Edelman
J. Eppich
R. Farrell
P. Gibson
L. Hartline*
C. Hunter
R. Jadgehew
K. Kaplan
J. Kerr
J. Kline
M. Kritzer
R. Krotseng
J. Lastovka
G. Leidich
M. Lyster
'
J. Marjenin*
P. Martin
J. Mehaffey*
G. Parker
K. Pech
E. Riley
E. Shaw
C. Shuster
P. Solanios
F. Stead
E. Sterle
'
T. Swansiger*
D. Tackas*
S. Tulk
H. Waldron*
H. Walls
B. Walrath
- Attended exit meeting only.
.
AA-1
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.,
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ATTACHMENT A
2.
Applicant's Coordinators
a.
Civil / Structural
M. Kritzer
b.
Mechanical
R. Matthys
R. Solt
c.
Electrical, Instrumentation and Control
K. Cimorelli
~W. Morris
d.
Welding and NDE
H. Walls
e.
Material Traceability, Storage and Maintenance
M. Franchuk
C. Hubbard
f.
QA and QC Inspector Effectiveness
T. Boss
In the course of this inspection, numerous craftsmen, inspectors, engi-
neers, and supervisory personnel who are not specifically listed were
also contacted.
AA-2
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_
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ATTACHMENT A
B.
' DOCUMENTS REVIEWED
The documents listed below were reviewed by the inspection team members
~
to the extent necessary to satisfy the inspection of objectives stated in
o
Section I of this report. References to specific procedures are contained
with the body of the report.
1.
Final Safety Analysis Report
2.
Quality Assurance Manuals (CE 1 and Contractors)
3.
Quality Assurance Procedures
4.
Quality Control Procedures
5.
General Electrical Specifications
6.
General Concrete Specifications
7.
General Mechanical Installation Specifications
8.
General Piping Installation Specifications
9.
Maintenance Procedures
10. Procurement, Receiving, and Storage Procedures
11. Material Traceability Procedures
12. QA Audit Reports
13. Trend Analysis Reports
14. Procedures for Initiating & Processing Field Changes
15. Procedures for Initiating & Processing Nonconformances
16. Construction Test Procedures
17. Nonconformance Reports (NRs)
18. Field Question Reports
19. Project Engineering Directives
20. As-Built Packages
21. NDE Procedures
22. Personnel Qualification Records
23. Purchase Orders
24. Drawings and Specifications
25. Receiving Reports
26. Documentation Packages
27. Storage Maintenance Requirements
1
AA-3
1