ML20084A268
| ML20084A268 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/23/1984 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | |
| Shared Package | |
| ML20084A258 | List: |
| References | |
| NUDOCS 8404240485 | |
| Download: ML20084A268 (17) | |
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, . . anartDcomsponoeg, AIR and WATER W Pollution Patrol BROAD AXE, PA.
iMW U. S. Nuclear Regulatory Commission Washington, D.C. 20555 '84 APR 23 P2:63 7J-In The Matter OfBEFORE THE ATOMIC SAFETY AND LICENSI ,
PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station, and 50-353 Units 1 and 2)
TESTIMONY OF AIR & WATER POLLUTION PATROL (ROMANO)
CONCERNING CONTENTION VI-I (INFRACTIONS RELATED TO WELDING)
My name is Frank R. Romano, Chairman of the Montgomery County Air and Water Pollution
- Petrol.
'Ibe purpose of my testimony is to show that Applicant, Philadelphia Electric, (1) failed to properly control performance of certain welding;: '
(2) failed to properly inspect certain welding in accordance with Qaulity cv d' Control and Quality Assurance procedures'* and (3) failed to take proper and effective corrective actions when improper welding was discovered, and (4) failed to take proper preventive actions when improper welding was dis-covered. .
The scope of my testimony addresses the fact of hundreds of Nuclear Regulatory Commission Inspections and Engineering Reports that show failure in performance as numbered' (1) (2) (3) (4) above.
In total the facts in these reports, backed by official documentation '
up prove there has been an apparant cover by Philadelphia Electric (P.E.) invol-ving crucial, safety related welding infractions at the Limerick nuclear reactor.
While there are four facets to the VI-I welding contention, as indicoted in the foregoing, an identity from any one of the four constitutes deviation from specified and required procedure and activity.
The 76-06-01, so-called " broomstick affair", is a classical example of failure on all four facets of performance. Facts in the 76-06-01 example are backed by official documentation that prove there has been an apparant cover up by Philadelphia Electric (P.E.) involving crucial, safety related welding in-fractions at the Limerick nuclear reactor.
- Also as it relates to Auditing.
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(B)
Testimony of Air & Water Pollution Patrol re Contention VI-I continued:
On November 10, 1976, reacting to an unannounced Nuclear Regulatory Commission (NRC) inspection report, Mr. Robert Carlson, of the NRC, wrote a letter (item 1) to P.E. Vice-President for Engineering and Research Mr.
Vincent Boyer. In t' hat letter, Mr. Carlson notified Mr. Boyer of serious violations in mandatory construction procedures involving. weld.ing infract- .
ions in the on-going construction at the Limerick reactor. (See Inspection Report No. 50-353/76-06 (item 2), and in particular " Notice of Violation", l Appendix A, Part A (item 3) of Mr. Carlson's letter. '
- As discussed under Part A, the most glaring example of repeated weld - [
ing violations had to do with the welding of safety-related items by non-qualified welders, using unapproved methods in contempt of specified pro- l(
cedures. .
-In this most glaring example, detailed on Page 5 of " Summary of Find- ,
ings" under 76-06-01 (item 4), inspectors were recording as ,0.K. improperly performed welds. On learning of these repeated violations from workmen, the ,
NRC inspector, over the objection of Philadelphia Electric, demanded an immediate inspection of questioned welds, and found them to be grossly de-ficient...but recordad as 0.K. (described in item 4 above)
. - -On December 15, 1976, Vincent Boyer responded to Mr. Carlson's Novem- d 9
ber 19 notice of violations, by writing to Mr. James P.O. O'Reilley, Dir- l ector, NRC Office of Inspection and Enforcement, at Region 1, King of Prus- 4 sia, Pa. (item 5). Mr. Boyer wrote, "the inspector involved is no longer-employed by the contractor and a reinspection of all other work performed ,
by him has been accomplished 'where accessible". (see p 1 & 2 of attachemnt 1 of Mr. Boyer's Dec. 15, 1976 letter (item 6) (underlining mine).
- The Air & Water Pollution Patrol contends a high potential for accident exists at Limerick because P.E.'s Vice-President Boyer, after welding in-fractions were discovered, failed to take proper and effective action, in failing to make it his responsibility to unsure accessible as well as inace-cssible welds were inspected. Mr. Boyer, therefore, failed to fully exercise j
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l (C)
Testimony of Air & Water Pollution Patrol re Contention VI-i continued:
his responsibility to inspect inaccessable welds to insure inspection as was crucial in this particular " broomstick affair". Mr. Boyer's failure results j in repeated re-counts demonstraiting lack of control in Quality Assurance and Quality Control involving records of welding inspection activity. Such failure must be considered as increasing the potential for failure of welds to support structures, or maintain integrity under adverse conditions.
Seven years after the 76-06-01 affair, in order to counter our conten-tien, P.E. has changed its story. Mark Wetterhahn, P.E.'s counsel, in corr-espondence of April 27,1983 (item 7), responding to questioning by the Licensing Board relating to the possible impact. of safety at Limerick, empha- i i
tically stated, "all welds inspected by the particular inspector, not only i accessible welds were re-examined". (underlining by P.E.) (See p 43 & 46)
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Apparantly to further remove any doubts caused by our insistent con- ,
tention, a follow-up letter of May 20 (item 8) from P.E.'s Counsel to the Licensing Board, contained various work records, in particular Finding Report No. N 093 (item 9), that was stated to be sent as absolute proof that all welds...accessbile as well as inaccessible welds were inspected (see p.2 of May 20 letter, lines 7~,8,9,10',~11) . ~~ (Report No. N093 does not even discuss inaccessible welds.)
In an order dated July 26, 1983, (item 10) the Atomic Seafety and lic-ensing Board, inspite of ordering that Air & Water Pollution Patrol's weld- !
ing contention be thrown out, requested affadavits from Philadelphia Elect-ric to affirm their emphatic statements contained in their April 27 letter that "all welds...not only where accessible were re-examined".
Unable to substantiate, via affidavit, information which had previous-ly and repeatedly been submitted as fact, Philadelphia Electric, through its ,
Counsel Mark Wetterhahn's letter to the Atomic Safety and Licensing Board, dated August 19, 1983 (item 11) wrote:
In the course of preparing to respond to the Atomic Safety and Licensing Board's request contained in its Second Special Prehearing Order (LPB-83-39) dated July 26, 1983, at 38-39 for an affidavit to verify the state-
AIR and WATER W Pollution Patrol BROAD AXE, PA.
(D)
Testimony of Air & Water Pollution Patrol re Contention VI-I continued:
ments contained in Counsel's May 20, 1983 letter to the Licensing Board, it was learned that all inspec-tions performed by the subject quality control inspec-tor had not been identified and, therefore, not re-inspected as previously believed. (underlining AWPP's)
Affidavits by Vincent Boyer is a confused. attempt to cover up a severly serious discovery of quasi-criminal neglect.in insuring proper welding as de-sEribed ln 353/76-06201.
This incident occurred and showed up what could be found dangerous at Limerick, as was found at Midland, Zimmer etc. At Zimmer and Midland where
. Bechtel, the same contractor as Limerick, was the main contractor, NRC CFR-10 appliceble regulations were found violated in too many cases, only found by accident by NRC inspectors--or on re-inspections by NRC as happened with 76-06-01. (items 14 & 15)
Even more serious than the failure of the Quality Control and Quality Assurance programs, evidenced by repeated deviations 'on AWPP submitted IE' reports is the attempt by the Applicant to cover up. The 76-06-01 affair again is the example wherein even after all welds were stated to be completely re-inspected the Applicant stated "all velds" , accessible and inaccessible that the in-spector had inspected were re-inspected. Subsequent developments, including the Aug. 10, 1983 affidavit of Mr. Kemper of P.E. reveals a coverup approach-ing fraud.
Such statements indicate the shallowness of the Applicant's Quality Ass-urance program and failure by the Applicant to assure all responsibility. for all activities as per PSAR Appendex D-par. D.1 and.CFR-10-Appendix B. More than that, it is evidenced that the Applicant is not above purposely attempt-ing to cover up as has been done at Midland, Zimmer., etc. And as indicated at Zimmer the acceptance of the Applicants reports of correct. ions which re-sulted in NRC closeouts of items of non-conformance is no guarrantee the non-conforming items, or subsequent same activity involved in those items were properly dispositioned.
Testimony of Air & Water Pollution Patrol re-Contention VI-I continued:
The Oct. 28, 1983 Memorandum and Order by the Board, page 6 states
- AWPP's case on the merits will be limited to instances set forth in its required listing, absent a substantial showing of good cause.
On the basis of good cause including absence of proper legal guidance which would have AWPP detail every report of welding infraction and used other discovery routes AWPP seeks to include specific infractions invol-ving welding riot previously listed.- The substantial good cause is the enabling of more, complete record for the safety of the public. .
For example, IE Report No. 50-353/75-05 reporting on inspection of .
Aug. a X.
26-29, 1975 and Sept. 2,3,4,8, 197f, in Summary of Findings reports
-GRmm. 5) a " Deviation": Spot Radiography of Containment Liner Seams (AWPP page 29 and 34) states 2.5% of welded seam in the critical containment liner were radiographed instead of 4% as per requirement of ?SAR, Section 5 and Regulatory Guide 1.19 Revision 1 (Section C-1-a) That demonstrates a careless QA-QC contributing in later safety related infractions. AWPP states the Applicant must show records which conclusively prove that rein-spection to conform was done on le'ngths of liner seam weld that were not ..
previously radiographed. AWPP states the Applicant has not shown that the infraction was properly dispositioned.
In same inspection report under 6 " Unresolved: Welded Wire Fabric For Suppression Pool Walls"(AWPP p. 30) Licensee alleged welding on the wire .
was not safety related, but th~e NRC inspector pointed out Licensee repre-sentative was not using Drawing C-249 as a guide as required. In spite of ,
Licensee's efforts to avoid compliance, the NRC inspector designated Lican- l see's response as reason item was placed in unresolved status. AWPP states the Applicant failed to properly control adhearance to Quality Control re-quirements.
Following the foregoing non-compliances and QA/QC, Applicant has been (
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charged with contempt of commitments made to the NRC as indicated under Chapter 7. " Deviations: Containment Liner Fabrication / Erection (AWPP p. 46) ,
which states as follows: The following items had been identified during ,
previous inspections of Unit No 1 and had been identified as resolved on !
e the basis of pending PSAR revisions. The revised PSAR was expected in s 9
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Testimony of Air & Water Pollution Patrol re Contention VI-I continued:
February 1975, as per information perviously provided to inspector by the Licensee (IE Inspection Report No. 50-352/75-02. item 12). As of the date of this inspection, the PSAR revision has not yet been issued for NRC re-view and approval. Continuation of work without prior PSAR change review by NRC is contrary to commitments made to the NRC in a December 23, 1974-meeting, as documented in a Directorate of Licensing " Summary of Heeting" dated December 31', 1974. This indicates failure by Licensee to take proper and effective action when dev.iation from specified procedure. on velding. bad been discovered.
Further demonstration of-Licensee's failure-to take. proper corrective action is evident in Chapter 13(a) " Progress On Previously Identified Un-
- resolved Items (AWPP p 49) in that a revision to clarify specified proced-ure relating to the critical containment liner seam was claimed to be too severe by the Licensee. Licensee would seek to use its own " judgement" rather than NRC specification recommended corrective action. This is a failure to follow Quality Control and Quality Assurance to avoid future
, possible weld failure. -
Further under Appendix B-Notice of Violation (75-06) (AWPP page B, par. 4) it is indicated that Applicant contributed- to failure re Quality Control, quote "The inspector stated that the licensee has not fulfilled his commit-ment to NRC to issue PSAR changes for NRC review prior to adoption, and committed PSAR change submittals'are overdue. In a subsequent telephone conversation, the licensee representative stated that changes involving adoption of later issues of codes and standards would not be submitted for prior NRC review. This is contrary to prior agreements and commitments.
(Details, Par. 7)".
Additionally inspection of'May 28-30, 1975, under C. 1. of General Electric Company (AWPP p. 39) points out another non-compliance infraction discovered under Chapter 4, (AWPP p. 42 through AWPP p. 44) As per PSAR G.
7.7.1 and 7.2 (AWPP p. 44) top paragraph Licensee committed that field prac-tices would be equivelent to shop practices. However, NRC inspectors Haynes and Walton found site practices were less than equivelent to shop practices.
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(,)
Testimony of Air & Water Pollution Patrol re Contention VI-I continued:
Under Response to Item of Applicant Deviation (AWPP p. 54) relating to July 22, 1975 letter to James O'Reilly (AWPP p. 53) Mr. V.C. Boyer states "the more sensitive radiolographic inspections of the surface irregularities of the stainless steel back-cladding were described as stated in the devia-tion. However, these discernible indications do not detract from the cap-ability of the process to detect relevant indication of defect". While the discernible indications may not detract from the capability to detect rele-vant indication of defect, in closing out the infraction Applicant has not shown that the observed discernible indications themselves were not relevant.
AWPP states, absent of final proof that the NRC inspectors concurred in the dispositioning, that Applicant failed to take proper corrective action that ignored the conclusions of inspectors Haynes and Walton, and thereby risk future weld failure.
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(H)
Testimony of Air & Water Pollution Patrol re Contention VI-I continued:
The failure by the Applicant to forthrightly take responsibility for all activities involved in the construction of a nuclear facility even after the 76-06-01 affiar is obvious in the March 5, 1984 chronology listing AWPP sent the Board (exhibit 1) .
Just as the 76-06-01 " Broomstick affair" was, inspite of the failures of the Applicant's Quality Control and Quality Assurance program. checked out and closed out...it is now known that many rationalized welding deficiencies remain to increas.e accident potential and consequences there of.
The confused attempts to explain away the deficiencies by Mr. Boyer's affadavits of Sept 16 and Sept 29, 1983 do not provide the margin of safe-ty the public deserves. AWPP calls for full sworn statements from every-one involved in such confused recount efforts. Further AVPP sees insuffic-ient proof of validity of the "use as is", or " engineering analysis" catch all means of rationalizing away the infractions.
AWPP's chronology submitted to the Board dated March 5, 1984 with AWPP page numbers for easy reference showed:
(a) AWPP p-139, 139B, AWPP 180b (NRC 1366, three of hundreds of exam-ples of NCR's routinely dispositioned by wordage "use as is".. AWPP chalanges P.E. to show proof that information supplied for close out by NRC is sub-stanciated by records.
(b) AWPP-144 /77-02-01 Applicant arbitrarily used its " judgement' "o interpret rules which results in deviation from specified procedure.
AWPP requires proof that the response to the infraction that resulted in the close out was sufficient to insure the Applicant did not repeat using its own " judgement" or interpretation of specified procedure. As late as deposition taken of Mr. Boyer and Mr. Clohesey of Philadelphia Electric on March 15, 1984,. the use of " judgement" on how to proceed (inspite of specified procedure) by inspectors and even the welder involved in the 76-06-01 affair was condoned as per Mr. Boyer's deposition page 54, line 6,7 and 15, 16.
(c) AWPP 152 (50-352/77-02; AWPP 155(50-352/78-03; 78-04; AWPP 156 (50-352/78-03; AWPP 156,157~(50-352/78-04, on up with AWPP 24'6 (50-352(81-05),
and other listed examples showing one or other of failure to control welding and failure to take proper and corrective action after discovery.
(d) Like AWPP 144 (b) above, AWPP 189 (50-352/79-07-02 AWPP 237
(r)
Testimony of Air & Water Pollution Patrol re Contention VI-I continued:
Applicant again is found to be arbitrarily making decision against specified procedures.
The Applicant was required by the Oct. 28, 1983 Board Order to describe how it assurred that the qualified welders are not qualified by fraud.
The Applicant did not file its report in a month of the prehearing as ordered but was received by AWPP, perhaps three or more months later. The undated copy entitled " Report Regarding The Involvement of Philadelphia Electric Cc=-
pany Management in Assuring The Quality of Welding At Limerick Generating Station" , while first talking about levels of control in attempting to insure welders were not qualified through fraud, but that they were properly qualified, admittoi at page 37 and 38, in discussing welding audits, states "these audits have confirmed that the first two levels are working effectively to insure the Limerick Generation Station will be a safe and reliable plant".
Applicant, thereupon, qualified the previous statement of reliability by saying: "However, this does not mean that the audits have not identified areas that need improvement" AWPP seeks to know what areas need improvement. What type of welds were involved? AWPP challenges the audit itself." In fact In-spection Report No-50-352/82-16 dated Feb. 10, 1983 from NRC's Thomas Martin, Director , Division of Engineering and Technical Programs re inspection on 11/29/82 under Observations, Section 4.3.4 indicated "PECO open audit find-ings needmore explicit guidance to imporve the timeliness of closure".
AWPP has deposed Mr. Clohesy, inspector for Applicant as stating he uses his own judgement re audits. AWPP's witness will check out the adeqeccy of judgement as it relates to assurance of validity of audits.
Further on page 37 the report discussed finding of poor quality welding and poor quality assurance programs as it related.to "HVAC subcontractor's entire Quality Assurance inspections" Since it is the complete responsibil-ity of the Applicant to be sure subcontractors have a proper Quality Assur-ance programs, this report only demonstrates weakness ...not. assurance of a safe reliable plant.
On page 38 Applicant, after having failed to insure sufficient inspectors wase available for HVAC to perform proper work assurance, Applicant states it "is confident its audit program works well. Page 39 and page 40 tells of the HVAC pitiful Qualicy Assurance program example which seems to be an unreal i-
3 (JJ i
Testimony of Air & Water Pollution Patrol re Contention VI_I continued:
rationalization to cover serious deficiency in the responsibility to take serious concrete action and concern after deficiencied have been discovered.
AWPP submits the name of Dr. Gudsond'Iverson, Professor of Statistics.
Swarthmore College, Swarthmore, Pa. Who will be witness for AWPP as it re-g lates to the auditing methods used by Applicant and audits performed as their ,
I scientific validity as it relates to Quality Assurance In submitting this testimony, AWPP states it lost the use of Saturday and Sunday because the testimony was due on a Monday rather that a Tuesday.
I was denied a one day extension so that the deficiencies resulted. I will check and follow up, via an appendix.
Respectfully submitted, ,
AIR & WATER POL ION PARTOL gg. , -- .
R. Romano, Chairman 61 Forest Ave.
Ambler, Pa. 19002 We certify the above was served on the latest service . list. -
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- 6. Unresolved: Welded Wire Fab'rie for Suppression Pool Walls -
The inspector noted that velded wire fabric was shown on reinfore-ing steel design drawings for the containment suppression pool valls. Drawing C-249 Revision 11 shows 6x6 WWF at the outermost layer of number 18 reinforcing steel. Specific location tolerances were not shoun. Licensce representatives stated that the wire was not " safety-related," however,,this was not so indicated on the ,
drawings. The inspector examined the project Q-list and noted that the wire fabric was not listed under " Exceptions" in Section 5 -
Containment. The licensee stated that the Q-list would be revised to identify the status of the wire f abric. Mention was also made of the difficulty in recording.the quality status of each and every item, especially' individual ce=ponents of larger ite=s, when some of those components are not safety-related. This item is unre-solved pending future IE inspection uf licensee stated actions.
- 7. " Unresolved: Sa= cling Point for Concrere Strength Test Specimens The licensee cormitted in PSAR, Section 5.2.5.2.1, to the ACI-SP-2
. Ibnual of Concrete Inspection, 5th edition 1970, as a basis for construction procedures and practices. This code of practice - e-me-states that ready-mixed concrete to be tested for acceptance,should be sampled as it is delivered and, should be sampled as near as possible to its final location. The concrete construction spec-ification C-61, " Furnishing and Delivery of On-Site Concrete,"
originally end in revisions up to #4 of 7/18/75 complied with this code. However, in the latter revision C-61 states that samples for -
ce=pressive strength shall be at the batch plant.
The NRC' audit disclosed that specification C-61 up to revision #4 also contained in section 6. 3.9, " Concrete Compressive Strength, ~
Unic Weight and Temperatures," the statement that sampling pro-cedures may be revised by the Project Engineer once correlation is established between the batch plant and the point of placement.
Proceeding concrete mixing and placing for the reactor vessel ped ,
estal on 9/2/75, the NRC inspector requested to see the documenta-tion of correlation t,esting and was informed that no documentation was available. Preceeding the start of concrete mixing and place-ment for the pedestal on 9/3/75. the NRC inspector was informed that compressive strength testing and temperature vould be per-formed on concrete samples obtained at end of pipe discharge. The NRC inspector observed that this practice was adhered to throughout all the pedestal placement.
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R. Hartstern, Quality Control' Engineer
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. C.,0. Wright, Quality Assurance Engineer, D., Wells, Quality Assurance Engineer - ,
R. .Sevo, Quality Assurance Engineer '
W.~ Moring, Quality Assurance Engineer - '
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5 T. Dougherty, Welding and Quality Assurance Supervisor
- J. Vandergrift, Quality Assurance Engineer
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,'.,, S. J. Bellows, Quality Control Representative ' ' '
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. were discussed as noced below:The following inspection findings were 'prese .,,.'
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The principal scope o'f the' inspection 1nclud'ed reactor pressure ves'sel
'- 7 field fabrication records, containment liner velding and associated records, containment suppression pool vall rebar installation, valve '
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vall thickness verification, program and previous unresofve'd 'ite=0.
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Specific areas were examined and are considered acceptable as noted
- under " Current. Findings." (Details, Paragraph 14) ..
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j Certain activities were found by the inspector to involve U .
Items of Noncompliance or Deviations as noted under " Enforcement Action." ..
Extensive discussion was held on the item relating
.t to the radiography of reactor pressure vessel field welds.
The inspector stated that IE:I'would contact the ASME code inspector for this work to obtain further data. (This contact ..
was made on June 4, 1975). In a subsequent June 5 telephone conversation with the NRC inspectors, the licensee stated that ,
y his metallurgist had now examined the radiographs in question
.l and was of the opinion that unacceptable defects could not be .
l masked or confused with the images of weld irregularities. '.
_ (Details, Paragraph 4) - .9 * .
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Extended discussion also was held on' the noncompliance re- ,
.d lating to the installation of containment rebar contrary to design.
The inspector acknowledged that QC inspo: tion had not ..
yet been made of the installation, and that all rebar was not .
yet in place, but that this did not alter the fact that work .
forces were accomplishing installation activities contrary to instructions and drawings. (Details, Paragraph 6) -
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.. J This inspect' ion encompassed welding in, progress and records 'of con- -
tainment'11ner penetration and hemisphere dome sections, installed -
rebar for containment suppression pool walls, records of reactor - *
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, pressure vessel field fabrication, valve wall thickness verifica- .'
f., tion program,.and status of previous unresolved items. General-i - . site tour / inspection was included. ,
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, 3. Construeden Status '
I A heavy equi.pment operator strike has delayed most site activities *
. . since May 5. Containment liner is in place including the'dryvell.- ,,
except for the top' flange / dome sections. There are some penetration: , ,
and hatches which remain to be installed and some seams to be installed.- *;
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Rebar is almost complete up to the diaphram floor; rebar for the r ' , . . ..
diaphram floor has not commenced. Turbine floor support columns - r
', a'nd the lower floor.of. the auxiliary building are in place.
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. 4. - Deviation: Reactor Pressure Vessel Field Weld Radionraphy ,.
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, Co,ntrary 'to the licensee's commitment in Appendix G to t,he. PSAR, ". .
Sections G.7, G.7.1 and G.7.2, the inspector found that the site
- practicas associated with the stainless steel back-cladding'of .
, the reactor pressure vessel field welds and the radiographic ' *
" inspection of these welds were less than equivalent to shop ,. '
prat.tices. As a result, radiographs of the welds contained , ".,
.- discernible indications which were attributed by the licensee, .
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. his representatives and the Authorized Inspector to the surface .
t regularities of the back-cladding. . ..
.e During this inspection, the inspector observed that several of .
the radiographs of the reactor pressure vessel circumferential welds, identified as AA and AB (lower head to #1 ring and #I i .. t
.. ring to #2 ring), contained faint lines running in a direction
- parallel with the weld. The inspector noted that the indications vere located in the area of the pressure boundary weld. The inspector found that the responsible Chicago Bridge t. Iron Com- '
, pany (f abricator) inspectors, General Electric Company (NSS
- Supplier) inspector and the inspector of the Authorized Inspec * *'
tion Agency had accepted the radiographs and attributed the
- faint lines to the as-welded condition of the back-cladding.
The inspector observed. the back-cisddin;; and found that cladding had been applied using the manual metal are process. The inspec-
- tor saw that the stringer beads of the cladding worc left, for the most part, in the as-wclded condition, i.e., soma surface h~
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be met without grinding. ..
concurred with this position. General Electric Company representativ es In view of the licensec's pSAR co=mitments on th .
tihractices and thatreactor pressure vessel that field practJces
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, site radiocraphic inspection vemu hethe the oniv differences he W hop g ,
Citms and the method of radiocrachy, *
'gan=a-ray radiography for the site fabri i.e., more extensive use ofnrang ,
that the . site practicos which resulted incated vessel, it appears .
- field ucids were less than equivalent
. practices, r pressure vessel. to the cd -
orresponding shop, c.
- 5. Deficiency: t- ,'. " !
Bolting Material For Structural Steel .; . ..' . .'.
- Contrary to the requirements of 10 CFR 50 A ,
documentary evidence that the material confoppendix B Criterion V .
1 hardened washers for bolted connections elevations 217 and 234 ation of the itside -
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the RPV pedestal at
,. ,l Nonconformance report NCR-ll24 identifies th ficate of compliance called fortheby thecerti-vendor purchasr '
Nonconforming Material Installation Release d e specifications.
identifics that the material was released ated March 17, f 1975 , <
based upon site management review estal nce. However, space. and concu -
material which lacks required documentation ation of
- u notification by TUX or written indicating that the item conforms to the procure report exists a supplier's o
at the j b site '
The licensee could produce no such TWXment or documents.
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mance of the material.onstrate that the vendor had been contacted
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erified confor ,
The licensee representative stated that he had this deficiency inspector an Aprilin28,the constructor's QA pralready identified 1975 's fact. como (QC-FMC 3 ogram snd he showed the Ho stated that QA and corporata QA the matteron management had Maybocn 5,1975, discussed and thato an non- betu conformance report was to bo initiated byThe the sito QA l noted as of May that 30, such 1975, an nonconfornanco report had still inspector nor van other action ycc i i i not been issued corrective action to be cc plcted within a ransonabin t ated for pro c time. ,
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The tic rod and Ec. 18 bar reinforcing stec1 did not, satisfy.
the 1 inch clearance from penetration sleeves specified in -
.$ the tolerance notes of d(awing C-247 Kevision 6 at position "
55 55' clevation 220, positifn'50 elevation 218, and position . .
2"i : .
290 elevation 192. , ,.
S , , '
5 The inspector interviewed the contractor quality control (QC) -
".)
personnel responsible for inspec(ion of reinforcing steel, to .. .
discusscontractorinspectionp{anningandapplicabicrecords. ,
The QC personnel stated that no ihspection of reinforcing steel -
T. .
' location and security had been conducted to date on the contain- -
M 4
ment suppression chamber walls, execpt for positioning bars for 5 The staff demonstrated some initial uncertainty as M ,
,cadwelding.to who would ultimately be responsible for verifying reinforcing ,
5 steel location, but the liccasce representative subsequently C clarified who was responsibic for the verification. The QC staff stated zd the inspection ef fort would require about two days ef fort by two
"'T ,
inspectors to verify conformance with drawings and specifications. ;
cc.;g The inspector subsequently discussed nonconfor=ing dimensions Ma"" -
with the responsible field engineer who stated that reinforcing
- steel work is in progress ar.d not yet complete and th,at aoncon- '.
=$ .
forming dimensions would be corrected by jacking the steel or by
- Si other appropriate means just prior to each of the severa'1* concrete q,g j pisec=ents.
=:.2= The inspector noted that the reinforcing steel work was practically gh .
coepicte with the exception of two hoop rings at the IcVel of the ig,;~;;;
diaphram floor, installation of horizontal ties aboveEight c.pproxieste layers 2=M -
elevation 195, and installation of exterior cesh.
if, of principally No.18 rebar ,have been installed, plus reinforecment "gn around penetrations. Three catwalks within the rebar =strix have not yet been removed. Continuing werk has been deferred due to i
"'" the heavy equip =ent operators strike. * '
The licensee representatives repeatedly stated their position that since the verk had not been completed and inspected it should not be considered as having been accomplished contrary ec drsvings cad
..as instructions. The inspector stated that the construction staff
_'. . a '
had cicarly not secomplished their assigned quality af fceting -
@=M cetivities in accordance with drawings and instructions, in spite "M. of the possibility that the contractor quality control staff may-N
.T at a future date detect these f acts.
"t L Cen tr. innen t Linor Tnbrfcation/ Traction
-U 7. Deviatient:
. C_'*
The follouing items had boon identified during previous inspections of Un: L No.1, and bV hn identified ts' rc:.olved of the basic The revin d P.W. was expcetud~in of penuing l'SAR_ reviQonn, I
f*
7
,, -l e. - -
- 12. Resolution':
CBIN NDI Procedures for Reactor Press 6re Yessel
- All indications, arising from liquid penetrant or magnetic particle. '
examination of' pipe, tubes and fittings for the RPV, are intended .'
- to be explored as described in procedures without exceptions. .This ., a ,,
resolves item number 3 of the Details section of IE Inspection l Report No. 50-352/75-01. , -
The inspector previously reviewed procedures MrP-10,' PTP-9 and'MTP-11, .! '
- and had questioned the acceptance criteria regarding unaccepechle in-
- dications. The licensee has clarified the intent of the proceeures ' .!
in advising the inspector that "all indications will be explored by the method described in paragraph 7.3." The inspettor stated that-
- he has no further questions on this item at this time. '
i, !
' : ,r .:
13.
i Progress on Previously Identified Unresolved Items
.. b* ,:.-Q \
- a. 5 Containment Liner Specifications - Remov'al of Imperfections:'
'l, '
.? i-eThe insrector reviewed revision 7 to specification 8031-C2 for . ,,
~
the. containment liner. This revision was intended to clarify ',,
,,the definition of " shallow imperfections" which are to be . . .
removed from the liner plate by grinding. The revis~ ion is *"
now clear in that it requires removal of all imperfectionc r.ot. .
~'
deeper than a specific depth. However, the licensee noted that he has not yet closed out this item in that the criteria appears ,
overly severe and may be further re.*ised. This item 7 of IE !
Inspection Report 50-352/75-03 is still unresolved pending re-
', view of licensee follovup action. '
b.
. . t Reactor Pressure Vessel Pre-fabrigation Cleaning: '
. ,98 '
y l a licensee representative stated that an engineering change g Oh notice ECN-38587 has been prepared to clarify acceptan*ce criteria .' ' ,
p of procedure 1, 1975. CCS-1, and that it will be available onsite by July The licensee als_o noted that the oroced - -
ge, qualifications identified in de:I 4 of repare M-353/M M ., ,
ge T'; v'ould also be Tva ua n e on that date. .
- .y action Items Wich Are Considered Acceptable
- P '
- a.
- Reactor Pressure Vessel Field Pabrication Records - The inspector .
audited the follevir.g records of the field fabrication of the reactor pressure vessel. '
i (1) Final postucid host treat records of the bottom head,to l
- 1 ring and the #1 ring to #2 ring veld were reviewed.
?
- 1 ;. - . '
- 12. Resolution: CBIN TDE Phocedures for Reactor Pressure Yessel -
All indications, arising from liquid penetrant or cagnetic particle-examination of' pipe, tubes and fittings for the RPV, are intended '
to be explored as described in procedures without exceptions. .This i resolves item number 3 of the Details section of IE Inspection ,,
Report No. 50-352/75-01. ,
~
The inspector previously reviewed procedures FTTP-10, PTP-9 and'MTP-11, i and had questioned the acceptance criteria regarding unacceptable in-dications. T,he licensee has clarified the intent of the procedures in advising the inspector that "all indications will be explored by the method described in paragraph 7.3." The inspector stated that '
he has no' further questions on this item at this time.
l
- 13. .,. .:
Protress on Previousiv Identificd Unresolved Items *
~
a.. Containment Liner Specifications - Remov'al of Imper'fections: -
- The insrector reviewed revision 7 to specification 8031-C2 for .
'the containment liner. This revision was intended to clarify -
.the definition of " shallow i= perfections" which are to be .
removed from the liner plate by grinding. The revis* ion is .
now clear in that it requires removal of all ir.perfectionc not .
deeper than a specific depth. Fiowever, the licensee noted that he has not yet closed out this item in that the criteria ap' ears , s overly severe and may be further re.*ised. This item 7 of IEp Inspection Report 50-352/75-03 is still unresolved pending re-view of licensee followup action. .,
- b. . . :
Reactor Pressure Vessel Pre-fabrication Cleaning.
--og4 '
i :
g /Ch .
e licensee representative stated that an engineering ~ change notice ECN-38587 has been prepared to clarify acceptan*ce criteria
- of procedure July 1, 1975. CCS-1, and that it will be available onsite by The licensee also noted that the orocedo-a -
- qualifications identified in icei 4 of report 50-3 53 /7 5-m .
g/c / , Mg ge
~
sould also be avo m bAe on that date._
S 3
cetion Items t&f ch Are Concidered Acceptable '
- v. .y
- 7.4 a.
- Reactor Pressure vessel Field Fabrication Records - The inspector
. audited the follovir.g records of the field fabrication of tha reactor pressure vessel. ,
(1) Finci postweld heat treat records of the botto: head to
- 1 ring ar,d the fl ring to //2 ring weld were reviewed.
_