ML20086R590
| ML20086R590 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/25/1982 |
| From: | Riley E CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | |
| Shared Package | |
| ML20086R580 | List: |
| References | |
| FOIA-83-677 NUDOCS 8402290438 | |
| Download: ML20086R590 (1) | |
Text
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g, pijey Project Perry Nuc! car Plant Telephone Call G - Conference D With: dhn Penchol ' Company: NRC - Recion III -
Subject:
CNO AP/N45.2. vs. j / SP 709/ Contractor Proarara s 1 / Note: _.I_ called Mr. Peschel per our caxnit:ne n ti _ j (Mr. a n our meetino of Maush 17,1982. e Peschel w s here to get further
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J 4 participation in the recent C.A T clarification of concerns he had g his duri t . _
. inroection of PNPPd I infomed M that CEI would perfonn a review .
,5 $' , of its CNQAP with respect to
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;N to insure that the intended req i ANSI N45.2 references N
k result of subsequent; revisions to thu ranents were not _ - 9 ar lef a t ou j e CNQAP.
% conpleted in about a month I indicated this review Should be k (9/24/62) at which time level attactraent specs, or contract , if any revisions to the Quality b_
s be accanplished by January,1983 ors prograns were needed, these chan ges would acceptable to him. Mr. Peschel indicated this timetabl e was (He recognized on-going workl __ would 11apact oad and present prior 2 ties
-I/ this effort.) *% it . Pcsche]
(* then asked if CEI intended to - CNQAD, Ecction 0200, Pa. 3 of 4, rnake any c)arj fvino chenqes to _ strat.ing the 3rd paracraph where we _ Q A Progran 's address wi th respect" to reference indexes demon-Reg ___ precented in App . I." . Guides and ANSI as to NER and Region III. He wanted to know if this would e done b before subnittal I ir,dicated we would certainly rev i ,' clarity prior to subnittal. ew this paragraph for
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- MCE PRt 5 r:,E NT S v5f t u E hGIN! E RWG nD CON 51HUOTION Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing -
U. 5. Nuclear Regulatory Commission Washington, D. C. 20555 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Corporate QA Program
Dear Mr. fcliwencer:
The enclosed copy of Cleveland Electric Illuminating Company's (CEl's) revised Corporate Quality Assurance Procram is being submitted for your review and approval. The original Corporate Quality Assurance Program, Section 17.1 of
' the Perry Preliminary Safety Analysis Report (PSAR), was reviewed and approved by the Office of Nuclear Reactor Regulation (N.RR) and has subsequently changed.
A NRR review of CEI's revised Corporate Quality Assurance Program was re-comrnended by NRC Office of Inspection and Enforcenfent, Region III. If you have any questions, please let us know. Very truly yours, h47 Dalwyn . Davidson Vice President
- f. System Engineering and Construction ,
! DRD:mb cc: Jay Silberg, Esq., w/o attachments l John Stefano , w/o attachments i Max Gildner, w/o attachments . l John Sprahl , w/ attachments - l B. Walrath, w/o attachments l o
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%, ..... f Docket Nos. 50-440 NOV 191982 and 50-441 -
MEMORANDUM FOR: Albert Schwencer, Chief ~
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Licensing Branch #2 Division of Licensing TROM: Walter P. Haass, Chief Quality Assurance Branch Division of Engineering .
SUBJECT:
REVISED QA PROGRAM DESCRIPTION FOR PERRY DESIGN AND CONS,TRUCTION , In your memorandum dated October 4,1982, you requested our review of the attached " Corporate Nuclear Quality Assurance Program" of the Cleveland Electric Illuminating Company (CEI) for Perry Nuclear Power Plant Units 1 and 2. You requested our findings be furnished to the LPM by October 18,
'1982. Due to the workload within the QA Branch, we have~ not been able to meet that schedule. However, we contacted the LPM and ascertained that review completion and reporting by November 30, 1,982 would be acceptable.
On November 12, 19'82, we received from the LPM a rewritten " Organization" subsection and an insert for the " Instructions, Procedures, and Drawings" subsection. These later pages have been considered in our review. We have read the document, revised as noted. The document is written as a manual for CEI personnel. As a manual, it . does not provide commitments which we require to find a utility's QA program description acceptable. The prime example of this is Appendix I, " Regulatory Guides and Standards. Reference Index" which is a list of QA Regulatory Guides, their referenced ANSI Standards with title and date, and references to
" appropriate sections" of a project administration document. While some of the ANSI Standards are referenced in the text, most are not. VarE 13TH E Ot rEpifa.ent-to-compjv vith-+fre;= R_eguretwy-Guidegs-+i<--imdquendix e-L cA, 1
g [ Ffni M a m p le m 17:t t e =i a C t h C RT:Infiddlesdte -laxi pf4A-31tp3r>m : desm 2] 3 %cnyo'f-C-Hhincively contTacto_rAdE@,_end$G ,a Thus, the document submitted by CEI 'is not an updated, revised version of Section 17.1 of the Perry RSAR. F jacd % d Q.kT asw .
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Albert Sch,encer _j_ NOV 191932 hCEI's** cover letter indicates Region III recommended that f4RR review CEI's . revised Corporate Quality ' Assurance Program. Please note that it is not our policy to review QA manuals. If CEI would provide an updated descrip-tion of the QA Prograin for Perry design and construction which is responsive to Section 17.1 of the Standard Review Plan or earlier acceptance criteria (such as was used in the 1974 time frame) and indicate where the program has been revised relative to the previously approved version, we can then - perform our normal review. It does not appear that a great deal of effort would be required to ' revise the manual into a fSAR Chapter 17 type 'of submittal . . F 40 se
' alter P. Haass, Chief -
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... / FEB 101M3 Docket Hos.: 50-440 and 50-441 h{=. "< ; c.. ._
mpa ggy Mr. Murray R. Edelman . Vice President-Nuclear Group The Cleveland Electric Illuminating Company . Post Office Box 5000 - Cleveland, Ohio 44101 .
Dear Mr. Edelman:
Subject:
Requ2st for Revised QA Program Description for Design and
, Construction of the Perry Nuclear Power Plant (Units 1 & 2)
. ./ .
By letter dated September 22, 1982 (D. R. Davidson to A. Schwencer) CEI submitted its Corporate Nuclear QA Program Manual for NRC staff review, which reflects revisions to the QA Program description for the design and construction of the Perry plant. The !!RC staff has completed its review of the Manual and finds that, as a manual for CEI personnel, it does not provide sufficient information which the staff requires to find a utility's QA program description acceptable. The prime example of this is Appendix I to the Manual entitled, "Regula' tory Guides and Standards Reference Index," which lists Regulatory Guides, their referenced - ANSI Standards with title and pate, and references.to " appropriate sec.tions" of a project administration document. While some of the ANSI Standards are referenced, most are not. Furthermore, there is no commitment to comply with the Regulatory Guides listed in Appendix 1. A second example of this is the laq);_cif commitments and absence oL_the__QA Program description _ of CEI's principal contractors (e.g. GE, GiitLert Associat % _R.iserJ.nginccr_iAql. It is therefore requested that CEI provide an updated description of".the QA Program for Perry design and construction indicating specifically where the piogram has been revised relative to the program reviewed and accepted by the staff and docu-mented in the Perry Preliminary Safety Analysis Report. It is suggested that the revised QA Program description be submitted in an amendment to the Perry Final Safety Analysis Report so that NRC staff evaluation findings may be reported in a future supplement of the Perry SER (NUREG-0887). It is also requested that a copy of the revised QA Program description be sent directly to the NRC Region III office to the a,ttenti.on of: Frank liawkins, Quality As,surance Section, Division of Engineering and Technical Inspection. . . 00 U- I f,0
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1 4 Mr. Mur/ayR. Edeiman - 79 101983 . l Your prompt attentio'n to this request is urged. Please advise the project manager,
- John J. Stefano, when we may expect to receive a response within seven days after i receipt of this letter.
. Sincerely,
/
JAA.A]0 HW r B. . Y ungbloo , Chief , Licensjng Branch No.1 Division of Licensing
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.... NOV 0 71983 Docket Nos. 50-440 50-441 The Cleveland Electric Illuminating Company ATTN: Mr. Murray R. Edelman Vice President Nuclear Group P.O. Box 5000 Cleveland, OH 44101 Gentlemen:
SUBJECT:
Construction Appraisal Team Inspection 50-440/83-31,50-441/83-30 This refers to the Construction Appraisal Inspection by the Office of Inspec-tion and Enforcement (IE) on August 22-September 2 and September 12-23, 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 detailed inspection of selected hardware subsequent to Quality Control inspections, a comprehensive review of selected - portions 'of your Quality Assurance Program, examination of procedures and records, observation of work activities and interviews with management and other person-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 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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O~ . NCY 0 71983\ The Cleveland Ele ric Illuminating Company The f(RC 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 i 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 CFR 2.790(b)(1). No reply to this letter is required at this time. NRC Region III will address tne 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,
~.
C eYou , Director Off eo nsp ion and Enforcement
Enclosures:
- 1. Appendix A - Executive Sunmary l
- 2. Appendix B . Potential Enforcement Findings j 3. Inspection Report 50-440/83-31, 50-441/83-30 l
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l APPENDIX A ! EXECUTIVE
SUMMARY
i l An announced Construction Appraisal Team (CAT) inspection was performed at the l Perry Nuclear Power plant site during the period August 22-September 2 and September 12-23, 1983. l OVERALL CONCLUSIONS The Construction Appraisal Team concludes that the results cf 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 4 given to the identified deficiencies is that nonconformance reports or other corrective action requests were immediately initiated by the applicant upon , '1 identification of the deficiency. These are discussed in the details section of the report. However, management attention is needed where some lack of resolu-i tion adequacy and timeliness were noted. The NRC CAT inspectors noted that many of the typical problems experienced at ' other facilities were experienced by the Perry Nuclear Ptswer 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 i 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 i lead the NRC CAT to question the ability of the drywell to maintain the
. specified leaktightness throughout its service lifetime. The preoperational -
l and periodic drywell bypass leakage tests are seen to be crucial tests to - l assess and monitor drywell bypass leakage from all sources. (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-j cation programs, the applicants verification program is~ in the early stages. - I i (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 l .one exception was in'the small bore piping area as discussed in'the details i section of this report.- 1 i A-1 i
\
2 i (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 f corrective actions. Examples where 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 i 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 3 (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 and 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 ad'lerence 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 the 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 l Al2
- . . .-. . , . - . . - - , - - , , ~ - , - - - ._ -, -.
s I weld-o-lets required by Section III of the A5ME 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 prograu. 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 Treceability, Storage and Maintenance: In general, the project material traccability, 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 raiseo 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 - accordance with the applicant's commitments. Nonconformances were sometimes closed before the disposition was completed and two contractors were not taking proper corrective action with regard to nonconforming conditions as required by the corrective action program. Overall, the applicant's project organization was found to be aggressive in identifying and resolving construction problems. i l A-3
c
. u APPENDIX B POTENTIAL ENFORCEMENT FINDINGS As a result of the CAT inspection of August 22-September 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).
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 ancther 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 Quality 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 -
i Sections 0500 and 1000, seismic pipe supports / restraints have in some cases not been constructed and inspected in accordance with design requirements. i In addition, the applicants "as-built" verification program for safety-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 and 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 connitments and has not initiated timely corrective action to resolve these identified problems (Section III.B.5 and _ III.B.6). B-1
e - ' 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 structural 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 Section 0900 and 1700, several examples were observed in the area of welder qualification by radiography where the radiographs did not confor;n 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 CNOAM 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). B-2
l i 1 e e. 1 l UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT DIVISION OF QUALITY ASSURANCE, SAFEGUARDS, AND INSPECTION 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 , Insp2ction Conducted: August 22-September 2, 1983 and [eptember 12-23, 1983 Inspectors: 1- Lij ')m d A. B. Beach, Sr.- Reactor Construction 10 /27/83 Dat'e Signed Engineer Team Leader) A'R U 10/27lA3 G. J. Georgiev, SVReactor Construction Dafe Signed Ergineer t e nr 1 ) tn/?1l83 fat., R. A. Rohrba'cher, Sr. Reactor Construction Dat'e S'igned Engineer
}
dj. mr L] IO/27/R3 m W. A~. Hanson, Inspection Specialist Dat'e S'igned -
. .h D. B. Osborne, Reactor Construction Engineer m/27/R3 Date Signed
'H . W . P Wklips," Reactor N Construction Engineer
!a/27/M3 Date Signed
. . & lal97lW'n Hf J. Cong, React Construction Engineer Oate .Sfgned
#1I inelhJ in/27/R3
- 4. E. Vandel, Reactor Inspector (Region III) Date Signed
)
Consultants: R. M. Compton, D. C. Ford, E. Y. Martindale, and F. A. 'Pimentel C Approved By:
- 1. F. Heishman, Chief 2^ SW l /fJ Date igned Reactor Construction Programs Branch
~ %3 i ll G O !Uf
, s l
TABLE OF CONTENTS TOPIC SECTION INSPECTION SCOPE AND OBJECTIVES.................................... I ELECTRICAL AND INSTRUMENTATION CONSTRUCTION........................ II MECHANICAL CONSTRUCTION............................................ III WELDING AND N0NDESTRUCTIVE EXAMINATION (NDE)....................... IV 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 e
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 designated responsibilities? Are quality verifications performed during tae construction process with applicable hold points ar.d 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 incl.de: Electrical and Instrumentation Construction Mechanical Construction Welding and Nondestructive Examination Civil and Structural Construction Material Traceability, Storage, and Maintenance OC Inspector Effectiveness Quality Assurance I-1
II. ELECTRICAL AND INSTRUMENTATION CONSTRUCTION ! A. Objective The primary objective of the appraisal of electrical and instru'aentation construction was to determine whether safety-related components and systems were installed in accordance with regulatory requirements, SAR connitments 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 i Within the broad categories of electrical and instrumentation construction, attention was given to specific areas. These included electrical cable, raceways, electrical equipment and instrumentation ccmponents. 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 i 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 i 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 location, material, anchor spacing, weld quality and installed configuration. i
- b. Inspection Findings 1
(1)' Cable Tray Separation f Relative to separation of cable tray, the PNPP FSAR Section 3 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 II-1
. . . . =. . . .a . . . . . .-
a , . 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 0-214-004 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 CDT. 1R33C-1040X CDT. 1R33T-27X CDT. 1R33R-407X Non-Div. 425 Division A 665 CDT. 1E22H-201C Division A 152 CDT. 1E22H-201C CDT. 1E22H-204C Division A 663 Non-Div. 1538 Non-Div. 1575 Non-Div. 3593 Non-Div. 083 Division A 150 Non-Div. 3593 Non-Div. 083 Division B 274 CDT. 1R33C-3133C Divisior. B 273 CDT. 1R33C-3133C Non-Div. 1649
. . Non-Div. 2238 Division B 272 . CDT. 1R33C-2977C CDT. 1R33R-1029C Division B 1319 Non-Div. 595 Division B 271 CDT. 1R33-2975C Division A 601 CDT. 1R33C-28110 CDT. 1R33C-315D
( l t ! 11-2 l l
l
- .i Division A 1680 CGT. 1017R-144C Division B 1326 CDT. 1C71-136C CDT. 1R33R-3020C CDT. 1R33R-917C CDT. 1R33C-2921C CDT. 1R33C-3022C Division A 153 CDT 2842C-248 CDT. 1833C-3508B CDT. 2R61A-1165B Division A 3008 Non-Div. 4555 Division B 269 Division A 141 Division A 127 CDT. 1R33C-33018 Division A 1657 CDT. 1R33C-3033 Division B 1846 CDT. 1R38C-3147C CDT. 1R33F-142C 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 separatton 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 of the cable tray does not meet the specified separation -
criteria. The NRC CAT inspectors discussed this matter with representatives of the quality organizations of both the applicant and 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 of approved barriers at some later date. The NRC CAT inspectors observed that, although barriers were shown on the design draw - ings, there were no procedures available for ins 1!allation of'
~
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 these observations, the licensee issued Action
~
Request (AR) 692 which details steps to be taken to correct these discrepancies. The AR included: i II-3
.n
l l
,. n I
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 wod/ inspection procedures are developed ta control activities associated with barrier installation and inspection. (2) Drywell Raceway Installation i. 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 Gilbart-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. Engineerin; 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 lower right hand corner. The sketches themselves did not appear to be consistently approved. Some sketches reviewed included sign-offs in the approval block by electrical, struc-tural, and civil engineers, others received 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 Conduit Detail Group indicated that these documents are controlled by the Conduit Detail Group and are not controlled or l handled by the Contractor's Document Control Section. Sketches i are issued to the field and to QC directly by the Conduit Detail i Group. The Conduit Detail Group is a rather unique part of the II-4
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 apprcved 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 revisioa 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 IP45H38-3 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) Conduit Identification Conduit identification was readily visible, properly located and appropriately used where necessary,
- c. Conclusion ~s (1) The separatirn status of numerous installed and inspected cable trays was not accurately recorded on QC inspection records. These records indicated " separation criteria l
acceptable" when, in fact, this was not the case. l l II-5 l 1 1
4 (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 installeo 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 j-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 terminated conductors). These were inspected relative to the appli-cable design and installation documents for items such as termination i 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. h 1R23F-7A 3 1/c 500 MCM 1R23F-188 3 1/c 500 MCM 1E12F-26A 3/c No. 12 1E12F-208 3/c No. 12 - The following control cables, totaling approximately 600 feet, were selected from different systems electrical trains, locations and sizes: Cable No. ))gge
-1E12C-688 l'3/c No. 14 1E12C-100B 1 7/c No. 14' 1E42D-378 1 3/c No. 14 1 9/c No. 14 IE12C-238A 1E32C-82A 1 9/c No. 14 II-6 i
i The following instrument cables, totaling approximately 600 feet, were selected from different systems, electrical trains, locations and sizes: , Cable No. Type, IC51R-7800 C0AX IC51R-7820 C0AX 1E12R-29A 1-4/STP-20 1R61A-587C 1-STP-16 The NRC CAT inspectors also observed installation / pulling activities associated with cable IE22H2010. 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 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 follo~ wing cables with installed routings that did not match those indicated on the pull slip, and for which an RCIM had not been initiated: 7 Cable IR23F-7A was pulled from tray 128A through tray 688A into equipment 1R23-S010. However, the pull slip does not indicate vertical tray 688A as part of the routing. Cable IR42D-37B is pulled to equipment 1R23-5011. However, l the pull slip indicates the routing of this cable to equip-l ment 1R23-S012 instead of 1R23-S011, l-1 l l II-7
,. i (As a result of these observations, the applicant has initiated NR P033-2132 to rework and reinspect these discrepancios and to revise procedures 4.3.6 and 4.3.17 for clarification to prevent recurrence. Also, NR OQC 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) Separatien 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.:'.2.8.2 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
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 tn 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 performed in Unit 1 ductways is acconiplished in accordance with a GE Field Design Deviation Request (FDDR). During the inspection of this area, the NRC CAT inspector observod the in-process installation of a separation barrier (duct cover) in Unit 1. The NRC CAT inspectors noted that there were no QC personnel present during this activity and further discussions with the applicant and LKC personnel disclosed that QC had not been notified of this installation activity. (LKC NR 2368 was initiated to document this condition.) . The NRC CAT inspectors concluded that the appropriate precedural controls have not been established to assure that previously inspected cables will not be damaged by the installation of barriers, and that all required barriers will be installed. As a result of this inspection, the applicant has initiated AR 720 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 without an approved installation / inspection procedure. ! Initiate an NR to document the indeterminate status of the 1 cables in the ductways. l l II-9
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 observed that the lug on the red conductor at tenninal 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 biccks 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 cables and installation of duct covers in the PGCC ductways, 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 equipment 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: (1) Motors The installation of two motors and associated hardware was inspected for such items as location, anchoring, grounding, identificati1n 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
(3)CircuitBreakers 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 The use of circuit breakers with integral under voltage trip i attachments at the PNPP was investigated. (4) Switchgear and Motor Control Centers The following switchgear and motor control centers were inspected: Emergency Service Water MCC 1R24-S030 and MCC EF1E2; and 4.16 KV Switchgear 1R22-S006 and 1R22-5007. 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 eavironmental control for installation - of both Unit 1 and Unit 2 batteries were compared with applicable requirements and QC records. $
- b. Inspection Findings (1) Motors The NRC CAT inspectors observed that the installed configuration ,
of these motors was in accordance with design drawings and~that I installation activities were performed in accordance with proce- ! dural requirements. (2) Electrical Penetration Assemblies Activities observed and documentation reviewed indicated that' the work performed was in accordance~to requirements. II-11
One item which was identified related to the certification of material used in the per.etration sleeves. This matter had been previously addressed by the applicant in a 10 CFR 50.55(e) report. (3) Circuit Breakers The circuit breakers 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 Stegral 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 NuclearPowerPlant(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 matter is discussed in Section VI. (5) Station Batteries and Racks 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. The inspection of the 125V battery racks disclosed that indeter-minate bolt material was used on the Unit 1 Division 1 and Unit 2 Division 2 battery racks. This matter is discussed in Section - VI.
- c. Conclusions 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. Insoection Scope In addition to the inspection of randomly selected plant corrponents, 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
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 Pura Motors 1E12-C002B and 1E12-C002C RHR Pump Motor Thermocouples 1E12-N486, IE12-N485, 1E12-N488 and 1E12-N489 F.wer Feed to 1E12-C002B (Cable 1E12H-28) Power Feed to 1E12-C002C (Cable 1E12H-38) Motor Operated Valve 1E12-F0048 MOV Control Cables 1E12F-1Ed and 1E12C-40B RHR Pump B Breaker EH-1208 and Pump C Breaker EH-1212 RPS System i 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. Instrumentation a . Scg,o_e_
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 and panels were inspected for l compliance with installation requirements, including location, l protection, mounting / anchoring and separation of redundant components
- and panels. Additionally, about 1000 feet of instrument tubing was l inspected against installation requirements relative to location /
i II-13
i l i . 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 cM-
- 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-
- l. 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 was, at best, marginally protected from damage from adjacent construction activi-ties and from inadvertant damage which may occur during plant opera-i 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 I 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.. T.he i 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, i components, tubing and associated items' inspected were installed in i accordance with applicable requirements - or appropriately tagged' l-and/or recorded as nonconforming.
II-14
- 'a -W^- N w- e =a+'**'W'* -
P 3
- 6. Design Change Control and Nonconforcence 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 ana 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, timeliness of
- review, proper approval, technical justification, and document 2
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. i
- 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 contrcl of these changes are in accord-j 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-neering Section (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 l 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.
1 i 4 i II-15
- c. Conclusions The general prcgram and procedures established to contrc 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 fornal, 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 applicable procedures. s e 4 II-16
i 1 III. MECHANICAL CONSTRUCTION i A. Objective Tne 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, concrete l expansion anchors for pipe supports / restraints, mechanical equipment and heating, ventilating and air conditioning (HVAC) systems. To accomplish 2 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 l
- 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 j identified during the inspection with valve / valve operator orienta-i tion, an additional 10 valves were selected to verify conformance of 1 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.
l' 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" l - 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
- . . -_ . - - . - - . - . . ~. _
, b. Inspection Findings In general, the piping runs inspected were found to conform to requirements for the attributes verified. However, one bolted valve and two valve operators were not oriented as shown on the isometric 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 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 schedule of piping / equipment configuration (construction acceptance).
{ inspection to be timely, nor prudent from a potential rework / repair standpoint. In 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-j 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 p41ng 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 Supports / Restraints
- 1
- a. Inspection Scope Twenty-eight QC accepted safety-related supports / restraints were-selected for inspection which provided a variety of types, sizes, o
(. systems and locations. 'These supports / restraints were inspected for. configuration, identification, location, fastener / expansion anchor t g 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 seismic / accident condi-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 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 governing the installation of GE supports 1 B33-H355A:and 1833-H301A. No problems were identi- ' fied. The final assembly and adjustment travelers were still in preparation. III-3
I Pullman Power Products (PPP) is responsible for the installation and inspection of the remainder of the safety related and balance of plant pipe supports / restraints. Gilbert Associates, Inc. provides the detailed support / restraint design drawings 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 coninon 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 - (IP11-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
- l 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 items were acceptable, unacceptable or not appli-cable.
The welding process sheets for supports 1P42-H1043, IP45-H360, 1E12-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, IE12-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 &cceptance 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) Soma 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 desi.gn drawing and.
procedural requirements. 1 III-5 i
I a i 3. As-Built Program (Pullman) l l
- a. Inspection Scope I 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 i inspecteu as detailed in Sections III.B.1 and III.B.2 had been "as-built certified" by Pullman Power Products.
- b. Inspection Findings l
Discrepancies between installed hardware and drawings were noted on six out 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, t The review of "as-built" documentation and program activities
- indicated several additional deficiencies and weaknesses. For restraint IP11-H059, the field redlining was perfonned and the certified "as-built" issued against ECN 12198-45-890 Rev. A, but ECN 12198-45-890 Rev. C was the current revision listed on the Pullman issued installation drawing. Procedure X-24, " Procedure i for As-Building Piping Systems and Components," is not being followed in that QC is not involved in all walkdenn inspections, walkdown teams are not signing and dating redlined drawings in -
- all cases (IP45-H529, IP45-H485) and the field engineering group
! is not determining conformance of hardware to erection toler-ances. It should be noted that Pullman 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" (1P45-H590,IP45-1176,IE12-H2002,1P45-H1277)andhasnumerous 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 j
Site Project Administration procedure 0303, Rev.1, "As-Built > Orawings" 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 l III-6
-- , ,. -- - 1
n l I l through July, 1017 of 4164 support / restraint "as-builts" (24%) and 645 of *.667 piping "as-builts" (39%) had been rejected by CEI. Most of the submitted "as-builts" have been of non-safety related hardware. However, the same people and process are used for safety
- related work. CEI QC involvement in the "as-built" effort appears to i be limited and CEI's program has not effectively identified and rectified significant deficiencies in the Pullman "as-built" program.
I The NRC CAT inspectors reviewed the Gilbert Associates, Inc. site , i 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 j 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 walkdow'n i redlining of piping and valve data verification. However, as Pullman i support / restraint "as-builts" are utilized as input to the 79-14 evaluation, inaccuracy in Pullman's orogram may affect the safety ,
l 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" 3 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 i 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 6 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 o applied.- The maximum _ rotation was 3/16 of a turn for.one R nut.
- )
l III-7 g 1
-w
(2) Nut Engagement All anchors were at least flush with the top of the nut per the procedural requirements. (3)AnchorEmbedment i 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 total 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 j anchors.
(4) Miscellaneous Discrepancies 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 IG36-H1024, there were no washers installed on the 2 anchor bolts as required. Nonconformance Report (NR) CQC 2880 , was issued ror this condition.
- c. Conclusions (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 4 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 Equipment FSAR Comparisons i 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 anti FSAR conunitments. 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 sumary 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.
J (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 comitment (see Table III-8). In 1979, l Gilbert suggested changing this valve from being normally open to l normally closed (along with other modifications) so as to reduce l the energy relet.se from a rupture in the 4" RCIC steam supply I line. Because of the logic change, less stringent requirements ! for the valve from that shown in the FSAR were apparently pos- l 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. I 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 comitments. Action Requests (ARs) were issued requiring complete FSAR review by Gilbert against system design descriptions. As a result of the NRC CAT inspection, the applicant has comited to include procurement specification requirements in the FSAR review. Additional programs include a - CEI FSAR Verification Program and a future audit of GE's procure-ment program. Procedures have not yet been developed for the CEI FSAR Verification 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 comitments. 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 cons'ider FSAR verification after all equipment is in place to b2 either prudent or timely from a potential equipment replacement standpoint or from a re-analysis standpoint. III-9
I l (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 formal 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 specified motoroperator(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 emphasized, since there is an obvious conflict between pur-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 actuator models which differed from design were identified by CEI, the identification was part of an iventory 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 correctiu. action to prevent re-occurrence was not initiated.
- 6. Heating, Ventilating and Air Conditioning (HVAC)
- a. Inspection Scope HVAC systeni; installation work is essentially complete in Unit 1 and common areas. The contractor for HVAC is the Robert Irsay, Co. (RIC0) sho fabricates, installs, inspects and leak tests systems in accordance with Gilbert design drawings and specifi-cations. System M40 and portions of MIS, 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
1 l f 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 provida the acceptance criteria for HVAC hardware installations: The Robert Irasy Company (RICO) Quality Assurance Manual RIC0 Procedure QCP-6-4/707, Rev 2, " Installation Inspection of Safety Related Drilled in Concrete Expansion Anchors" RIC0 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 Ouct Brochure RICO Drawings D-937-901, 902, 903, 905, 906, 907, 908, and 909,
" Duct Support Standard Connections" and D-937-920, " Attachment Schedule" 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 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 1.nspector. In fact, RICO quality management. had-been aware that the work done by this individual w.s 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 sccpe of tnis individual nor has all his work been completely reinspected some 15 months later.
A RICO review of nonconformance reports (NRs) issued between May_ 1982 and May 1983 revealed at least-39 NRs directly attributable to III-11
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 conditions reported included missing and undersized l l welds, improper configuration and inadequate documentation. Many required rework or repair. In general, the NRs identified the unsatisfactory work as done by craftmen and inspectors no longer on 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 j problem as needing timely and fonnal 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 proble.ms identified during the NRC CAT review of in-process i 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" walkdowa. While this is a correct action to take, it is ] not required or defined by site procedures. In addition, RICO QC 4 does not have a specified or executed means to void 'out existing QC inspection documentation when rework is required to QC accepted hardware. Also, in the review of the " final" walkdown deficit.ncy punchlist for systems OMIS and 1M36, a number of instances were discovered where conditions were b31ng identified and closed on the punchlist that should have been identified on nonconformances. Examples include missing welds on supports DS-0G-2001-and 2002, improper wa::hers installed on supports DS-0G-4025 and.DS-IB-3126 and undercut welds on support DS-IB-4059. Finally, the responsibili-ties and processes for developing "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 sunnarized in Table III-10.
- c. Conclusions i (1) With the exception of undersized attachment welds, HVAC hardware material, configuration, location and installation i appeared to generally conform to design documents.
l (2) The work performed by certain craftsmen and/or inspectors appears to have been deficient, especially as identified with undersized. structural attachment welds, i ! III-12
i i
- (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. i l (4) Additional attention is needed to ensure that RICO site proce-i 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 l adequacy and to determine if the NRs were properly closed in accord-j ance with the approved dispositicn. Twelve hanger supports were 1 selected when work was in-process to determine if design changes j were properly controlled. , ! b. Insoection Findings Nonconformance reports reviewed were dispositioned adequately. With one exception, reports reviewed indicate proper closecut. Noncon-4 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-nentr 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 to 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 segulatory Guide 1.85, Revision 16 could not be satisfied. This 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 closeout of nonconformance reports are. discussed in Section VIII under Corrective Action Systems.. Design changes reviewed indicated that they were processed in l accordance with the applicant's program requirements. III-13
TABLE III - 1 PIPING INSPECTION SAMPLES AND OBSERVATIONS ASME Pipe Observations System Isometric Class Diameter (AR/NR Issued) RHR 1E12-24 1&2 12" & 18" RHR 1E12-38 2 12" & 18" RHR 1E12-47* 2 8" RCIC 1E51-7 2 8" RCIC 1E51-1 2 12" FPC&C OG41-9* 3 10" Valve F557B rotated 90 degrees (NR PPP-4005) n FPC&C OG41-27 3 10" ECC OP42-31* 3 10"
- Valve operator F445 rotated 180 degrees (NR PPP-4005)
ECC OP42-32 3 10" ECC OP42-34 3 10" Valve operator F260 rotated 90 degrees Additional Valves Selected for Orientation Valve Isometric Observation F140 OP43-29 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 -
I TABLE III - 2 , PIPE SUPPORTS / RESTRAINTS INSPECTION SAMPLES Support / Restraint Type Class Size Location 1821-H006 Snubber 3 14" Reactor 1P42-H113 U-bolt 3 10" Control 1P42-H139 Strut 3 10" Control 1821-H117 Snubber 3 10" Reactor IP42-H148 Box / Lug 3 12" Control i 1P45-H167 Spring 3 20" Auxiliary 1G41-H247 Box 3 12" Intennediate 1G41-H354 U-bolt 3 10" Intermediate IP45-H447 Box 3 8" Diesel
*1E22-H024 Snubber 2 16" Auxiliary 1E12-H2109 Box 2 2" Auxiliary 1E12-H138 Spring 2 18" Auxiliary 1G41-H362 Box 3 10" Intermediate IP45-H147 Strut / Box 3 16" Auxiliary ,
1821-H223 Box / Lug 3 2" Reactor 1C11-H032 Box / Strut / Lug 2 8" Reactor 1G36-H045 Strut 3 4" Reactor J 1G36-H065 Spring 3 8" Reactor 1821-H414 Box 3 12" Reactor
*1E12-H1061 Box 2 11" Auxiliary
*1E12-H1041 Box 2 11" Auxiliary
, *1E12-1062 Strap 2 3/4" Auxiliary 1E12-H748 Box 1 12" Reactor 1E21-H014 Spring 1 12" Reactor IE12-H010 Snubber 1 12" Reactor 1E12-H037 Restraint 1 6" Auxiliary 1M51-H022 U-bolt 2 4" Reactor
**1833-H352A Spring 1 16" Reactor
*1P11-H059 Strut / Lug 4 8" Reactor 1P54-H017 Box 4 4" Reactor
*1P11-H098 Strut 4 12" Auxiliary IP11-H078 Strut 4 12" Auxiliary -
1P54-H199 Strut 4 6" Intermediate
*1P11-H065 Snubber 4- 8" Reactor IP54-H1011 Strap 4 li" Auxiliary
*1P11-H056 Box 4 8" Reactor l
*"as-built certified"
** General Electric installation l
l l III-15
TABLE III - 3 PIPE SUPPORT / RESTRAINT INSPECTION OBSERVATIONS Support / Restraint Observation (AR/NR/DR Issued) Safety Related Sample IB21-H006 1/8" clearance to drywell liner (SCV-2544) 1G41-H354 No clearcnce 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) 1E12-H138 Loose U-bolt nuts
*1E12-H1062 2 attached hangers not shown on A.B.
1E12-H748 Phase 11 checklist on file incompletely filleo out 1E21-H014 Contact point on drawing has 1" gap (NR P044-2164) 1E12-H010 1" clearance to decking Adjacent Safety Related 1G36-H1045 size U-bolt and non-safety material installed Wrong (NRCQC-2877) 1G36-H1046 Threads on U-balt had been extended by crafts (NRCQC-2878) 1G36-H062 Phase III tagged, clamp bolts not staked 1P42-H225 Travel stops removed (NR PPP-4024) 1P45-H055 No washers over slotted holes (Procedure IX-6, i Rev. 8/10/82, Para. 8.4.6). Clips for sliding connections welded-not shown on drawing 1 i (NR PPP-4114) IP45-H058 No washers over slotted holes (Procedure IX-6, Rev. 8/10/82, Para. 8.4.6). Clips for sliding i connections welded-not shown on drawing (NRPPP-4114) 1 III-16
TABLEIII-3(Continued) Support / Restraint Observation (AR/NR/DR Issued) IP45-H452 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) 1E22-H100 Support disassembled, Phase II tag attached, no Phase II checklist on file (AR 704) Class 4 Sample
*1P11-H058 Clip angles installed 2}"x2i"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) 1 1P11-H078 Pipe attachment location off by 4-3/4" (DR 2392) 1G36-H1024 No washers between nut and baseplate (NR CQC 2880)
*"as-built certified" -
l l l III-17
TABLE III-4 CONCRETE EXPANSION ANCHOR SAMPLES AND OBSERVATIONS Support / Restraint No. Observations (1) 1G36-H1024 One nut rotated 1/8 turn 1G36-H1045 One nut rotated 1/8 turn 1G36-H048 One nut rotated 1/8 turn 1G33-H043 1P57-H1060 1P57-H1052 1G41-H253 One nut rotated 1/8 turn 1G41-H414 1G41-H362 Two nuts rotated 1/16 turn 1E21-H080 Three nuts rotated 1/16 turn Two anchors with 3 3/4 inch standout 1E21-H030 One nut rotated 3/16 turn . One anchor with 21/2 inch standout i 1E21-H081 Two nuts rotated 1/16 turn 1E21-H1013 4 1E21-H053 1E21-H021 1E12-H2001 1E21-H1010 1E12-H2002 1E21-H026 One nut rotated 1/16 turn, One nut rotated 1/8 turn 1E32-H163 One anchor with 2 inch standout 1E32-H225 l IE32-H152 1E12-H1059 1G36-H036 1P42-H1164 One anchor with 2 inch standout. 2P42-H043 One nut rotated 1/8 turn 2P42-H057 1P42-H1219 - NOTE: (1) Observations were made after the minimum specified torques (per ECN 10493-44-1641 Rec. C) was applied to the nuts. III-18
TABLE III EMBEDMENT OF CONCRETE EXPANSION ANCHORS Measureme.it (Top Marking Minimum of Bolt to Computed Required Support / Restraint No. 'on Bolt Length (in.) Concrete) (in.) Embedment (in.) Embedment (in.) 1E21-H080 T 12 3 3/4 (2 bolts) 8 1/4 8 1/2
'1E21-H030 -R ~ 10 2 1/2 7 1/2 8 1E32-H163 0 8 1/2 2 6 1/2 6 7/8 IP42-H1164 0 8 1/2 2 6 1/2 5 1/2 1 "L e
o
TABLE III-6 MECHANICAL EQUIPMENT FSAR COMPARISONS Serial #/(Actuator Model) Operational Parameters Field Equipment Documentation Observation Item Specs. FSAR MPL No. 15210030 15210030 Total Pump 725gpm 725gpm E51-C001 RCIC Pump Discharge Water Temp. 40 F to 40 F to Range 140 F 140 F NPSH 21 ft. min. 21 Ft. min. Developed 2980 Ft.1 2980 ft.1 Head 610 ft.2 610 Ft.2 0 7* BHP, Not 825 HP3 825 HP3 E$ to Exceed 150 HP4 150 HP4 Design 1525 psig 1525 psig Pressure Design 40 to 40 to Temperature 140 F 140 F NOTES: 1 At 1192 psia reactor press.ure 2 At'165 psia reactor pressure 3 At 2980 feet developed head 4 At 610 feet developed head d W
l TABLE III-6 MECHANICAL EQUIPMENT FSAR COMPARISONS - Cont. Serial #/(Actuator Model) Operational Parameters Field MPL No. Equipment Documentation Observation Item Specs. FSAR E51-C002 RCIC Turbine F-38176-A 38176-A Steam Inlet 1150gsia, 1150gsia, Pressurc min. min. 150 min.8 150 min.8 Turbine 25 psia, 25 psia, Exhaust max.5 max.5 Pressure 25 psia, 25 psia, max.8 max.8 Design Inlet 1250 psig 7 1250 psig 7 {} Pressure
$3 Design Exhaust 165 psig 7 165 psig 7 Pressure E51-F045 RCIC Steam Supply. Valve 60810 60810 Max. Orening 15 sec. 15 sec.
(SMB-0-25) (SMB-0-25) and/or Closing Time Differential 1400 psi 1400 psi Pressure Notes: 5 H.P. Condition 6 L.P. Condition 7 At Saturated Temperature-9 m
TABLE III-6 MECHANICAL EQUIPMENT 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 w
j' na
, Differential 1177 psi 1177 psi Pressure E51-F017 .RCIC Pump Suction 1 1 Relief Setting 75psig 75.psig Relief Valve Flow 14 gpm 14 gpa l Notes':
l a At 10 percent Accumulation < l l l l - I
- e
TABLE III-6 MECHANICAL EQUIPMENT FSAR COMPARIS0NS - Cont. Serial #/(Actuator Model) Operational Parameters Field MPL No. Equipment Documentation Observation Item Specs. FSAR E51-F022 RCIC Pump Test 60809 60809 Max. dif- 1400 psi 1400 psi Return Valve ferential pressure capable of throttling control Clot.are - 75 psi against dif-ferential pres-
,, sure of i* E51-F031 RCIC Pump Suction 61522 61522 Openir,g and 75 psi 75 psi Ej Valve, Supprer,sion Pool (SMB-000-5) (SMB-00-10) closing against differential pressure of E12-C002- RHR Pump 741-S-1410 741-5-1410 Head Capacity Same as FSAR See FSAR Curve Fig.
5.4-15 NPSH Require- Same as FSAR See FSAR ment Curve Fig. 5.4-15 Brake HP 750 HP 250 HP
@8000 gpm @8000 gpm i
P
TABLE III-7 DOCUMENTATION REVIEW FOR MECHANICAL EQUIPMENT Certification Applicable Equipment 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. 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 Supply Isolation B/M RNU 209 Valve (F063)
RCIC Steam 5618-80-11 P-1364-K 521.02 4 Supply Isolation B/M RNU 206 Valve (F064) RCIC Pump Suction 9128-80-19 P-1257-K 523-4549 Relief Valve 'F017) B/M RNQ-200 RCIC Pump Test Return 5618-18-39 P-1364-K 521.02 Valve (F022) B/M RNN 261 RCIC Pump Suction Valve, -- P-1364-K 521.02 Suppression Pool (F031) B/M RNN 260 RHR Pump PQC R 239 205 A6 070 Rev. 9 21A9514AE Rev. 3 III-24
l 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 FSAR Will revise FSAR to Valve (F063) opening and/or closing conform to purchase requirement of 10 sec. specifications and differential pressure of ,
1177 psi.
- 3. RCIC Test Return Purchase specification does Will revise FSAR to Valve (F022) not mention citsure against 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 l III-25 . r
\ .. . TABLE III - 9 HVAC li.. 'ECTION 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 2M150001A, IM15D001A, 2M150001B, OM40C0028, OM40D001C Flow dampers 1M15F070A and IM25F130A Duct Segments:
QM15-739 Pieces 51-68 and 76-79 QM15-722 Pieces 67-70
+
III-26
TABLE III - 10 HVAC INSPECTION OBSERVATIONS ITEM OBSERVATION (AR/NR/DR/FQ ISSUED) Support DS-0G-2001 Support to building structure attachment weld undersized (1/4" vs 3/8") Support 0S-18-3130 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") 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 = l-i" Plenum OM15-0001A One foundation nut less than full engage-- ment (approx. 1 thread) (FQ 31769)* l Fan OM40-C002B Three foundation nuts less than full engagement (approx. I thread) (FQ 31769)* I
*As a result of this finding RICO is reinspecting all previously installed seismically mounted HVAC equipment for full thread engagement of foundation fasteners.
I III-27
1
. .. I IV. WELDING AND NONDESTRUCTIVE EXAMINATION (NDE) l 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 and 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 installations, pipe whip restraints, heating, ventilation and air conditioning (HVAC) installations, i electrical supports and instrumentation and control tubing 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 inclucad in this inspection. (1) Welding Activities The NRC CAT inspections of piping systems consisted of walkdowns of the main steam (321) and the reactor recirculation (833) 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. l
- IV-1
~
. - _ . . _ . -~ . .- .- _
l i 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 /
- restraints inspected).
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 -* 1 process travelers were also reviewed for adequacy. In addition, the qualification records of twenty-five welders t were reviewed. These walders 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 radicgraphic option were also reviewed (see
- Table IV-3 for a listing of the welder qualifications reviewed).
l (2) Nondestructive Examination Activities The NRC CAT inspection of NDE activities for GE contracts included the review of radiographic film for shop and field 1 fabricated pipe welds, witnessing of in-process field NDE inspec-tions and the review of NDE procedures and personnel qualifica-tions. j - j 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-1 tion were also reviewed. These welds involved 106 film. i 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. i IV-2 . l _ . ..m . ~ _ .
- b. Inspection Findings (1) Welding Activities No problems were identified in the area of welding procedures and in-process welding. Inspected shop ar.d 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 i 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 commite nts.
- 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 fabricatea welds were also included in this inspection. (1)WeldingActivity 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 inspectea to determine if attributes such as mismatch, weld ' surface contour and appearance ivere in accordance ( t 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 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). l l l f IV-3 L i
i . *
- 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 i 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 regaroing 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.
l IV-4
. .= - . -_ - _.
l
= . \
i i i As a result of this finding, CEI issued Nonconformance Reports (NR) 2916 and 2917 respectively. Another procedural problem regarding the welding of stainless i 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 j 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 l weld legs) socket welds and socket welds exhibiting weld leg size i 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 inouts were used during the welding of this specimen. Thus, an. amperage range to ensure control of heat input to the socket welds should be j considered for incorporation into WPS-29. i 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, i
-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 - l guards.needed to preclude the possible use of stand-ins for- , welder qualification tests. This problem was recently addressed l in IE Information Notice 83-61 " Alleged Use of Stand-Ins for u l Welder Qualification Tests". As a result of-the review, the l following deficiencies were identified. A lack' of controls to insure that new hires are properly identified. IV-5 l l'
._ , ,_ - _ _ ,_ .- _ ___u . . . . .u . _ __ __ .,
. ._ .=.
l l A lack of positive welder identification 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 1M11-GMS-ITB, IN27-G-FW-129ST, 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 bore 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 welded piping from PPP at Williamsport to ensure similar deficiencies do not exis*. 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 ur)derground and the wall thickness could not be verified by ultrasonic examination. These welds are now under investigation and the use ui 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 Mas rejected by the NRC CAT inspector for failure to display the )T 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. l IV-6
- 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 and the CEI FSAR commitments.
- 3. Newport News Industrial (NNICO)
- a. Inspection Scope (1)WeldingActivities The NRC CAT welding inspection activities relating to NNICO included inspection of field welding (both ASME and AWS DI.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 drawings. 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 l
l No problems were identified in the areas of inspected NNICO 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 l
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 Findings 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 Scope
- 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 ano evaluated for their abilities to use the AWS D1.1 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 rergirements 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. l l 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 -
and NDE activities.
- 7. Robert Irsay (RIC0)
- a. Inspection Scope Total of 160 welds were inspected comprising a sample of vendor procured welds and field welds completed by RICO. Welding proce-dures, welder qualification records, NDE procedures 'and NDE personnel qualifications were reviewed. In addition, two NDE inspectors were observed and evaluated for their. abilities to use the AWS 01.1 Code and to follow the RICO NDE procedures.
IV-9
- 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 tue previously discussed findi'ngs, inspected welding and NDE activities were found to comply with the requirements of the AWS D1.1 Structural Welding Code.
4 IV-10 1
1 I Table IV-1 PIPING RUNS INSPECTED System /Name Class Size 1821/ Nuclear Boiler System 3 10", 12", 14" 1G33/ Reactor Recirculation 1 20", 28" 1C11/ Control Rod Drive 2 11", 11", 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" 1 Gal / Fuel Pool Cooling and Cleanup 3 8", 10" i 1G42/ Suppression Pool Drain and Cleanup 3 8", 10" 1G42/ Suppression Pool Drain and Cleanup 3 8", 10" 1G61/ Liquid Radwaste Sumps 2 21" - IN27/ Feed Water 1 12", 20" 1P11/ Condensate Transfer and Storage 2 10", 16" 1P42/ Emergency Closed Cooling 3 4", 10", 12" 1945/ Emergency Service Water 3 4", 8", 10", 14" 1P47/ Control Complex' Chilled Water 3 3", 6", 8", 10" l l IV-11
l TABLE IV-2 Pipe Supports / Hangers Inspected Supports / Restraints No. Results H101B(A)-1 Welds acceptable H101A(A)-1 H101A(B)-1 H101D(A)-1
" i H102B-1 H306A-1 H305A H3518-1 H3538-1 H101B(B)-1 H1010(B)-1 H3568-1 NOTE: These supports / hangers listed on this page are installed by General Electric -
IV-12
+ .. o l l TABLE IV-2 PIPE SUPPORTS / HANGERS INSPECTED - Cont. Supports / Restraints No. Results 1821-H006 Welds Acceptable IP42-H113 " 1P42-H139 " 1821-H117 " 1P42-H148 " 1P45-H167 " 1G41-H247 "
, 1G41-H354 "
1P45-H447 " 1E22-H024 " 1E12-H2109 " ' 1E12-H138 " 1G41-H362 " 1P45-H147 " 1821-H223 " 1C11-H032 " 1G36-H045 " 1G36-H065 " 1821-H414 " 1E12-H1061 " 1E12-H1041 " 1E12-H1062 " 1E12-H748 " 1E21-H014 " 1E12-H010 " 1E12-H037 " 1M51-H022 " l 1P42-H345 " 1E12-H2095 " 1G41-H209 " 1P42-H099 " 1P45-H120 1P42-H345 Rejected by CEI Phase II inspection IP42-H139 Under sized fillet welds (2) NRC 2540R11 had been prepared for undersize welds 1E12-H1062 Welds acceptable - 1E12-H136 " 1P42-H113 " 1P42-H148 " 1E12-H2109 " 1821-H117 " 1B21-H006 ! NOTE: - The supports / restraints on this page are installed by Pullman Power Products IV-13
. - - ~ . - -
4-- TABLE IV-2 PIPE SUPPORTS / HANGERS IINSPECTED - Cont. Support / Hanger No. Results IP45-H167 Welds Acceptable 1G41-H247 1G41-M354 1P45-H447 1C11-H614 Reviewed for welding and Design Change Control. Acceptable IC11-H642
- IC11-H021 1E12-H072 1C11-H015 1833-H1068 1P42-H1043 1E12-H178 1P45-H360 a
1C11-H516 1821-H107 1P45-H1516 NOTE: The supports / restraints listed on this page are installed by Pullman Power Products 1 IV-14 l
I TABLE IV-3 WELDER QUALIFICATIONS General Electric Method of Testing / We_1 de r I .D. Commments GEP-005 RT GEP-071 Bends GEP-072 GEP-082 GEP-084 GEP-104 GEP-105 GEP-113 RT , GEP-118 GEP-121 Bends GEP-132 RT GEP-140 GEP-160 GEP-175 RT & Bends GEP-177 RT (1) GEP-187 RT (1) GEP-199 RT GEP-210 Bends GEP-217 Bends GEP-271 RTa (1) GEP-274 GEP-279 GEP-288 RT GEP-290 RT (1) GEP-297 RT Pullman Power Products Method of Testing / Welder I.D. Comments RX Bends , FZ RT & Bends l AJV Bends X2 AGK ATC i ARA JT ADE ATH ATM IV-Iti
i TABLE IV-3 WELDER QUALIFICATIONS - Cont. Pullman Power Products - Cont. Method of Testing / Welder I.D. Conenents ARC ALN E2 ABJ ADF AUH ATP
" i AJK AP RT & Bends ARD AC4 RT(1)
AMQ RT (1) Newport News Industrial Method of Testing / Welder I.D. Comments 018-4144 RT 018-488 441-1745 a 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 i qualified by bend testing. - l NOTE (1): The radiographic film quality was unacceptable per ASME Code. , I l IV-16 ! I I I
l
=
.. l TABLE IV-4 RADIOGRAPHIC FILM REVIEW General Electric (Shop Welds) Weld I.D.
KER-1701-250 St. Seam 702-E-82-9G010 81-LSWOL 1-B21-MS-LOOPC Weld 8012A 1-821-MS-LOOPC Weld 0038D 1-B21-MS-LOOPB Weld 0090 1-821-MS-LOOP Weld 48 1-821-MS-L00PD Weld 602 1-B21-4A-FRT-F-CL Weld 6A 1-B21-4A-FFB Weld 4A 1-821-7D-MS-FCL Weld 4A 1-821-A3-F-TRA Weld 6A . 1-821-Al-1PC-1-3A Weld 3A 1-B21-D2 1-821-7CT1821 Weld 031 1-B21-4CT1821 Weld 026 1-B33-RRA19L00PA 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 General Electric (Field Welds) FRT(B33-1-34) FGL-10 - FRT(B33-1-38) FGL-10 RCC-1-RCB33-RR RCCA12G33-1-A12 l RCCB33-1-A
'IV-17
r TABLE IV-4 RADIOGRAPHIC FILM REVIEW - Cont. Pullman Power Products Shop Welds (67) Weld I.D.
**2E12-GRH-91AB Weld B IN27-GFW-1295T Weld C *1N27-GFW-129ST Weld E 1E12-GRH-216HB Weld A 1E12-GRH-216AB Weld C *1N27-GFW-143HB Weld A **2E21-GHR-91AB Weld E 4
2E12-GHR-91AB Weld D 2E12-GHR-91AB Weld C 2E12-GHR-91AB Weld A i 1E22-GHPC-8AB Weld B IN27-GFW-140HB Weld B 1E51-GRCIC-33AB Weld F IN27-GFW-1295T Weld A IN27-GFW-1295T Weld B IN27-GFW-136ST Weld B IN11-GMS-1TB Weld A
- INH-GMS-1TB Weld B 2E-32GMSIV-37AB Weld G
- 2E-32GMSIV-52AB Weld A 2E-32GMSIV-56AB Weld B 2E-32GMSIV-56AB Weld C 2E-32GMSIV-56AB Weld D 2E-32GMSIV-56AB Weld E 2E-32GMSIV-56AB 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-GRM-220AB Weld C 2-E12-GRH-7AD . Weld A 1-G-3BGRWC-20-RB Weld ~A 1-E21-GLPG-7-AB < Weld A 1E21-GLPC-2-AB Weld C 1E12-RCIC-12-AB Weld A 1E21-GLPC-8-AB Weld A 1E21-GLPC-11-AB Weld B 2E12-GRH-7-AB Weld B 1E51-GRCIC-30-AB Weld C 1E31-GRCIC-11-A8 Weld B IV-18
i l 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 Weld 01 2-E-12-G-RH-220-AB 1-E-12-11 Weld 20 1-E-12-17 Wela 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 i 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 Weld 06
- l. 1-E-12-12 Weld 05 l 1-E-12-14 Weld 01 0-P11-9 Weld 02**
0-P11-9 Weld Ol*** ! 0-P11-8 Weld 01 l 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 -Weld 08 1-E12-20 Weld 01 1-E12-23 Weld 02
~1-E1?-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
TABLE IV-4 RADIOGRAPHIC FILM REVIEW - Cont. Pullman Power Products Field Welds Weld I.D. 1E31-GRCIC-11-AB Weld A 2E12-GRH-9-AB Weld G 1E12-GRH-19-AB Weld F 1E32-G-MSIV-10R-AB Weld M 1E32-G-MSIV-10R-AB Weld L 1E32-G-MSIV-10R-AB Weld G IE32-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 i 2E12-G-RH-4-AB Weld A 2E12-G-RH-4-AB Weld D 2E12-G-RH-4-AB Weld F 2E12-G-RH-220-AB Weld C-R1 2E12-G-RH-220-AB Weld C-R2 2E12-G-RH-220-AB Weld E 2E12-G-RH-220-AB 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 (NNICO) INN 0-2 (177-179) Horizontal Seam INNI-90 Verticle Seam Approximately 98 Ft. Film for containment liner plate reviewed IV-21
TABLE IV-5 IN-PROCESS NDE INSPECTIONS NDE 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 6 visual exams LKC V.T. Structural Welds Acceptable, Witnessed 2 visual exams P.T. Structural Welds Acceptable, Witnessed 2 P.T. Exams RICO V. T. Structural Welds Acceptable, Witnessed 2 visual exams P. T. Structural Welds Acceptable, Witnessed 2 visual exams 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. exam IV-22
i o f V. CIVIL AND STRUCTURAL CONSTRUCTION A. Objective Determine by independent evaluation of work in progress, completed work, and by review of documentation whether work, inspection, and test activi-i ties relative to the civil engineering area were accomplished in accordance with project specifications and procedures. These objectives were met I 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, str'etural steel installation activities and design changes and nonconformance reports in these areas. B. Discussion j 1. Seismic Clearance Program 1 t
- a. Inspection Scope l
l 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 engineer, 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 performed 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 speci-fied in paragraphs C.2 and C.4 of Regulatory Guide 1.29, Rev. 3,
. dated 9/78, " Seismic Design Classification." A sample of 26 hardware installations in the field was reviewed j 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 GA' 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 l 9
l
-, e +-y-, --
r - -- g .m.- ,e - . ,re--- +,e e - - e- -
- b. Inspection Findinos.
For the 26 Seismic Category I, nonsafety-related hardware installa-tions (see Table V-1), the geneni quality of workmanship (i.e., weld appearance, nut tightness, stri .:tural integrity assr.ssment, and support spans) was reviewed. ihe 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 peor 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 fonnally 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 nf the fire protection piping with the - cable trays was considered in the engineer's judgment to be
" insignificant". 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 a
. manner not well controlled. . Examples are: a bolt capacity not.
properly evaluated for adequacy, use of differing' factors of safety for the same component without guidance as to which factor 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 satisfy seismic clearance violations (SCVs), the NRC CAT identi-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 GAI engineering had caused closure prior to. verification that the nonconforming conditions were fully resolved. V-3L
--_--________------_--_----_----___.----------.~J-
- 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 i 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 perfonned from November 1978 through November 1980. The current installation specifications and installation procedures for Pullman Power Products and L. K. Comstock were compared by the NRC CAT with the qualitication report and found to be in agreement. The following 1 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 allowable load. The installation torques are - higher than the inspectica torqces. The use of 1/2" diameter Hilti bolts was discontinued in November 1980. (2) The 1/2" diameter Hilti Dolt testing showed capacities less than the value required by GAI specifications (8% low). However, l 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 plate, doubling the bolt load is generally overly conservative and the slight reduction in th~e 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 l 1/2" diameter anchor bolts installed prior to their discon-l tinuation. A random sample of approximately five small bore pipe support designs were reviewed and verified by the NRC CAT that the anchor bolt loads were in fact doubled and proper anchor bolt allowable loads used. V-4 l
a AA -s a- _.3 S -- +4-ihJ4 -a------ aeA a = a A - E-.a .
\
l (3) The ultimate capacities used by GAI for Hilti bolts are based on ! Hilti catalog reconnendations. The qualification testing was 4 done to confirm that the Hilti recommended anchor bolt capacities i 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. I The issue of Hilti bolts being installed through the drywell liner i plate is of concern to the NRC CAT due to the number of anchor bolts beinginstalled(6000-8000) and that the drywell must meet bypass t leakage limits. The method of Hilti bolt installation is to drill l 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 th~e attachment, and then torque the Hilti bolt. 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. I The leak tightness of the drywell is questioned by the NRC CAT based j 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 not 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 j 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 1 GE study and in addition, the NRC has not formally accepted the GE topical report.
~
l . 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 i plate. The Grand Gulf FSAR, Section 3.8, specifically indicates i 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. y.5 :
(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 detec' 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 thermal stresses) and the loading conditions. Cracking is recognized by the American Concrete Institute (ACI) in ACI 207.2R-73 and the ACi Committee 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 a will likely 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 Comittee 224 report recomends 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 documented 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 consolidation 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. l 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 hole's~ l for expansion anchor bolts. The NRC CAT concern is whether the grout will actually bond tightly to the concrete to transfer the loads into l 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- , i V-6 .
)
\
l
combing of the concrete behind the drywell liner plate. It was identi-fied by the NRC CAT that NR PPPi-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 knowledgeable in the area of Hilti bolts and Hilti bolts through the drywell liner would most likely have properly identified these two NRs as requiring 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 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 communi-cated to ensure that problems with Hilti bolts are properly dispositioned and brought to the attention of project and GA1. - 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 b;ockouts (Pour Nos. DG0-W01-638, DG0-WO2-635, DGO-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:
I
)
V-7
- Dick Specifications:
SP-19-4549-00, Rev. V, (4/12/78), Construction of 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-202-4549-00, 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 Ocme placement to determine whether the vertical construction joint with a keyway required bush hammering. GAI engineering responded that l joint preparation was only required on the horizontal t 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 l l
9 (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 exc.assive 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 l 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 concrete in the first truck for placement DG0-W01-638 was tested and found to have an excessive slump (5 3/4" vs. 5"). Procedures were followed for additional field i testing when the concrete was found to be out of specification 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 to this NR prior to closecut." However, the closeout date of Dick NR 215 is 9/14/83, whereas the training documentation indicates that training was not given until 9/21/83 (one week after the NR was fremally closed). AR 716 was initiated to identify the cause of ttw 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
t
- 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 reinforcino steel placement, cadweld quality and concrete quality. The blockoucs 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 dore 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 I 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 i reviewed for conformance to construction specifications and regula-tory requirements. The documentation reviewed included records of l inspection, in-process testing, material certification, surveillance testing, and cadwelder qualification, perfonnance, 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
s 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 Material 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 reviewed primarily 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 employed 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, :atisfaction 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 out on September 7,1976. In fact, the September 1976 sample was also drawn on September 7, 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 this finding, NR P014-2186 was initiated. Additional investigation by the applicant 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 l has been closed. (2) The. review of sele'cted 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-i tion. It was noted that other similar test reports did provide l an analysis evaluation. As folicwup to this finding, the licen-see identified three additional instances of this occurrence V-11
s - and US Testing was requested to perfonn 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 soilt, 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 shows 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 Sc_ ope The containment vessel shell steel installation activities performed by Newport News Industrial (NNICO).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 inspe.cted against the design drawings for configuration, member size, and weld size and appearance.
V-12
- 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 conformance with the design drawings and associated NRs. The weiding 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 (PSI) 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 procedure requirements were met. The approximately 260 bolts were found to have at least the minimum torque requirement.
The only discrepancy identifled by the NRC CAT was undersized clip angles for a column to embed plate connection. The discrepancy is at Elevation 661' of the Control Complex building at column lines 1 CC-6 and 3'-0" north of CC-E (column mark number 715-C3). The i 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 l 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 1.he Control Complex. (2) Additional investigation by the applicant and NRC CAT for proper clip angle size revealed no discrepi..::les 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. . (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. (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 inspetion 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, PSI 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; proper use of the design change documents, identification of j V-14
s 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 V.B.2 (PPPF NR 3842), Section V.B.3 Dick (previously NR 216), anddiscussed in Section 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 with program and regulatory requirements. .
except in three instances. These instances are discussed in detail in previous paragraphs and/or in Section VIII. l l l 1 V-15
t TABLE V-1: SEISMIC CLEARANCE PROGRAM REVIEW Seismic Clearance Workmanship Calculation Review Violation No. 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.* I 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 i for over 50 feet of floor drain piping. 1678 Bent beam clamp. 1681 Poor support welds. 1551 Poor weld on a support on the piping run in vicinity of SCV #1551. 187 Undersized welds and weld 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 flRC CAT and found to match those act0 ally in field.
*The applicant had recently identified the missing welds and the condition was documented on Nonconformance Report-PPPF 4066 dated 9/6/83.
V-16
,t TABLE V-1 SEISMIC CLEARANCE PROGRAM REVIEW - Cont.
Seismic Clearance Workmanship Calculation Review
'liolation 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 not used); improper references to another calculation; improper boltsize(largerthan 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. l 2306 Acceptable.
'2356 Acceptable.
1630 Acceptable. i i j V-17 l
9 TABLE V-1 SEISMIC CLEARANCE PROGRAM REVIEW - Cont. 1 Seismic Clearance Workmanship Calculation Review Violation No. Findings Findings 2032 Acceptable. 2053 Acceptable. l l l Total of 26 violations Total of 7 GAI
- reviewed in the field. calculations reviewed.
I a I i i T V-18 e,
i j 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 0-462-304, Rev. C Control CCO-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, i Building Engineering Rev. D Walls Walls D-413-182, IB0-W16-680 National 07/25/79 Rev. A Engineering 0-413-162, , Rev. E l i i i- -V-19
i , 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 (see RB1-HWT5-654) Drywell Wall: i RB1-W01-616 06/04/79 3219-3224 RB1-W02-630 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-WO2-648 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 11/30/7F CCO-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 I
]
V-20 1
\
TABLE V-3 CONCRETE PLACEMENT RECORDS REVIEW - Cont. Date of Contractor Pour No. Placement RMIR* Reviwed Blount Brothers Corp. Reactor Building 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 Dick Shield Building: s RB1-W6-677 12/15/77 RB1-W6A-677 11/07/78
- RMIR - Receipt of Material Inspection Report with attached material certification records .
l V-21
e I 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 240716 Rev. F t , 94-2 I Unit 1 - Penetration Stiffeners 249923 Rev. F l Elev. 592'-2" to 249924 Rev. D 604'-11" 249925 Rev. 0 l Az. 23*-30' to 249926 Rev. D 32*-00' with NR No. P017-758 V-22 9
TABLE V-5 STRUCTURAL STEEL INSTALLATION NRC CAT Inspection Area Structure Drawing No. Member Size Unit 1 Aux. Bldg. D-512-023 and Connections: 0-561-011 0-561-084 Unit 2 Reactor Bldg. D-561-051 0-512-066 Unit 1 and 2 Control D-514-101 I Complex D-514-102 D-514-011 D-514-022 i D-514-301 0-514-302 D-514-303 Intermediate Bldg. D-513-015 0-513-018 Bolt Torquing: Unit 1 and 2 Control D-514-021 Complex D-514-022 D-514-101 0-514-201 D-514-202 Unit 2 Aux. Bldg. D-562-021 Unit 2 Reactor Bldg. D-561-020 0-561-021 V-23
VI. MATERIAL TRACEABILITY, STORAGE AND MAINTENANCE A. Objective The objective of this portion of the inspection was: to examine material traceability and control, 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 l The approach used to perform this part of the inspection was to identify
; and select samples of installed safety-related material and equipment for t 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 i VI-1, "Sumary 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 I a. Inspection Scope A total of 178 samples were examined for traceability to dra' wings, 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-i forming safety-related work had appropriate proceduras 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:
w VI-1
l (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 (833) and Main Steam (N11) Systems. The NRC CAT inspection of material traceability for General Electric (GE) ASME Section NF Class I supports / restraints identi- - fied problems regardin5 the lack of visible unique identification marking of support / restraint items, marked materials not trace-able to verification docucentation 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 i' 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 other 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 had not been fully resolved. A letter dated 9/2/83 from ITT 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 thi's 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 traceab1lity for four supports (1E21-H014, IE120-H010, 1E51-H037 and 1E12-H748), VI-2
1
\
l and 'ield observations. The NRC CAT found the overall controls ! regarding receiving, marking and maintenance of traceability l through installation for PPP to be in accordance with [ requirements. A documentation weakness in the program had been i corrected in the latest revision to Pullman Procedure IX-6,
" Installation and Inspection of Pipe Supports" by specifically requiring QC verification and recording of material heat or LCN nusabers 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, questiort 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 l was noted that N/A O marked in the " Stress Relieved" bl]ck under " Additional Test bsults". This material, if used in applications specifying As. tie 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 ft., E70S-2 or 6, SFA5.18, l Pullman Purchase Order No. 7691-575, Heat No. 4644B131. On l reviewing the CMTR dated 9/3/83, it was noted that exactly l identical impact test results were listed for six sets of i 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 un' usual impact testing values. A selding engineer contacted the testing laboratory involved and was advised that the six test results were actual l 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, i Paragraph 4.3.4, " Welding Materials," requires a delta l ferrite content of 8% minimum for the 308 filler materials. GE CMTR for Heat No. X43724 indicates a delta ferrite content l of 6.5%. This material was' utilized for welding of at least I three details. The affected details are item 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 - and TAS0064). VI-3
o , (3) Fasteners Examination of 32 samples of fasteners, both installed in the plant and in contractor's bins revealed several deficient condi-tions regarding material control as follows:
- (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 l 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 GrB7 and that a CMTR was filed for these bolts. The bin and carton were incorrectly marked for these
' bolts.
(b) Bolts for Battery Racks 1R42-S002 and 2R42-S003. The NRC CAT 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.
- l. 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 /Comonwealth 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 vendor-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- recomending that all bolts in question be replaced with the SAE Grade 5 material and that the bolts in question be submitted for testing. i l \ VI-4 l l
(c) Bolts for 4KV Switchgear Cabinet 1R22-S006. The vendor had specified by letter that switchgear interframe 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 00C-0324 and 0QC-0325 to address these problems. (d) Bolts for Flanged Joints of Diesel Starting Air Line IR44509. Some studs for flanged 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 IE Motor Control Center 2R24-S019. Examina- i 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 1E cabinets revealed that larger bolts were being used, and as in the one case of cabinet 2H13-P7471/2" bolts had been installed (to comply with an i 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 Component Su) ports. The NRC CAT inspectors observed in four areas t.1at 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 assembly 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 IE32-H014 with a missing bolt
. A 12" pipe clamp with no bolts, no marks. .no tags
. Pipe clamp'for IE12-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 i
n l l l VI-5 l
i ., l
- c. Conclusions The overall material control and material traceability program was cor,sidered adequate, except for some traceability program deficien-cies and for the material control of fasteners and small items.
2 Traceability program problems were identified regarding the thoroughness of application of the traceability program procedures ,
; for material identification markings on ASME Class I hangers and the thoroughness of the contractor's reverification 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 a;'propriate 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 j site Calibration Laboratory, utilized properly calibrated temperature and humidity recording indicators showing conditions within required limits. Weld rod storage, issue stations and holding ovens in various locations on the site were examined and found to be satis-factory.
1 Several examples of improper storage and protection (from damage and -
. deterioration) of safety-related equipment in the plant and in a lay-down areas were noted. Some protective covers were missing.
Some equipment damage 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-S024 (3) Reactor Core Isolation Cooling Pump IE51-C001-
- 4) Emergency Closed Cool Pump / Motor IP42-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-down area. Regarding item 6, the procedures reqire labeling of these parts for identification-and control after coatings are applied. These parts l l VI l-
~_
~
were found to be not adequate y 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-markir.g 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 issu:.d 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 maintenance control syste:n. 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 deficiencies VI-7 l l
+ 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 delays in initiating required maintenance provisions were noteo. 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. This requirement is defined in " Nuclear Design and Procurement 3-1301", Rev. 4, dated 8/16/32 which states that "the Responsible Engineer is to forward a copy of the Storage Maintenance Requirements (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 :ontrol of maintenance was found to be adequate, except for the control of maintenance in the central warehouses. Eleven of 43 samples revealed situations 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 aftcr receipt).' Three of~the samples revealed that receipt of' the Storage Maintenance Requirements had not occurred for periods of 30 days to 5 years.
VI-8 l
\
TABLE VI
SUMMARY
OF SAMPLES Contractors Activities and Samples No. of Samples
- Pullman Piping, hangers, weld joints, 36 welding mtl., fasteners GE NSSS equip., piping, hangers, 26 weld joints, welding mtl.,
fasteners, shims Comstock Electrical equip., cables, 30 hangers, weld joints, welding mtl., fasteners Johnson Controls Instru. & Controls, racks, 22 . welding mtl., fasteners, tubing RICO HVAC equip., control panels, 16 hangers, weld joints, weld mtl., fasteners PBI Structural mtl . , weld mtl. , 23 fasterners NNI Liners, vessels, weld joints, 22 weld mtl., fasteners Dick Cadweld sleeves 3 TOTAL 178 i
- NOTE: Some items served as multi-purpose samples (e.g. , for traceability, storage and maintenance).
I VI-9
TABLE VI SAMPLE BREAKDOWN BY CONTRACTORS Pullman GE Comstock JC RICO PBI NNI Dick Total *
- 1. Equipment 5 8 13 4 5 - - -
35
- 2. Pipe 4 - -
3 - - - - 7
- 3. Steel 2 - -
3 2 8 - - 15(L) (Structural)
- 4. Steel Plate / - - - 2 1 1 5 -
9(L) Sheet
- 5. Hangers / 2 5 2 - 1 - - -
10 Supports t
- 6. Weld Filler 6 2 3 2 2 3 3 -
21(L) Material
- 7. Weld Joints 12 4 2 2 2 4 11 -
37 -
- 8. Elec. Cables - -
3 - - - - - 3(L) (Reels)
- 9. Fasteners 5 5 7 2 3 7 3 -
32
- 10. Shims -
2 - - - - - - 2(L)
- 11. Cadweld - - - - - - -
3 3(L) Sleeves
- 12. Tubing - - -
4 - - - - 4(L) 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.D. Coments GE ER308R NG460 Acceptable GE ER308L 05845 Acceptable GE ER308L 05345 Acceptable GE E308L-16 06004 Acceptable GE E308-16 95533 Acceptable GE ER308 741102 Acceptable GE E308-16 740654A Acceptable GE ER308 434788 Acceptable GE E308-16 741619 Acceptable GE ER308 740014 Acceptable . GE ER308 75213 Acceptable GE ER308 A43724 Less than 8% Ferrite GE ER70S-2 401L3151 Acceptable GE E70S-2 401K0151 Acceptable GE E308L-16 8M13C Mix 22 (trace) Acceptable GE E7018 401J1571 Acceptable NNI E308-16 77NNIS07 Acceptable NNI E308-16 77NNIS08 Acceptable NNI E309-16 77NNISO9 Acceptable NNI E70T-G 77NNI549 Acceptable NNI ER308L 80NNIO97 Acceptable NNI E70T-1 81NNIO39 Acceptable NNI E308L-16 77NNI1525 Acceptable NNI E7018 79NNIO19 Acceptable NNI E7018 81NNIO55 Acceptable NNI E7018 77NNI589 Acceptable NNI E7018 115K (trace) Acceotable - NNI E7018 115L (trace) Acceptable FNI ER309L 08544 Acceptable PPP E7018 70612 Acceptable PPP E308L-16 743927 Acceptable PPP ER308L 3548R308L (K shape) Acceptabh
. PPP E70S-2 065312 Acceptable.
PPP E705-2 46448131 Identical impact test results PPP E7018 4121C1391- Acceptable JC ER308L 07665 . Acceptable JC E7018~ 422S1961 Acceptable PBI E7018 33042 Not checked PBI AA7018 422W8351 Not checked PBI E709L-16 467267 Not checked COMSTOCK E7010-Al 614AF (trace) Not checked COMSTOCK E7018 34-482A (trace) Not checked COMSTOCK E7018 2-215C4B(trace) Not checked RICO E7018(LH) 411T1231 Not checked RICO E7018 (LH) 412N2851 Not checked VI-11 l
I l i VII. QUALITY CONTROL INSPECTOR EFFECTIVENESS A. Objective The objective of this portion of the inspection was to detennine 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 Implementation of the Quality Control Program was detennined from 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 ,
inspection results. I
- 2. M oection 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 selected from the Cleveland 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 fann 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 NPC Region III Office for further review.
- b. Inspector Qualification /Certi,fication 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 Power 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 few days, which could be questionable. However, of the inspectors reviewed, all had inspection experience at other nuclear construction sites.
- 3. Conclusions There was no reported intimidation of inspectors 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.
5 l l l VII-2
"liI. QUALITY ASSURANCE 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; or.-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-dnce 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 (1) CEI Program The CEI audit program is performed to ensure that comitments and responsibilities at the project level are met and to ensure.that contractor comitments have been met. The program is implemented by various corporate and project level procedures that fully describe the program. l Audit areas were reviewed for: scheduling; development and use of checklists; reporting; audit finding resciution; 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
1 ties varied from a cocplete review of the contractor's program compared to 10 CFR 50, Appendix 8, to a review of a specific work activity (for example, cable pulling). Although the number varied from year to year, in the order of 150 audits of contrac- I tor activities and 35 audits of project activities were performed each year. The coments provided below are based on these audit reviews and personnel interviews. (a) Audit Scheduling Document reviews and interviews of personnel associated with the audits perfonned at the project level revealed that a system of annual audit scheduling with quarterly review and updating was used. l 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)AuditReporting Audit reports prepared by each part of the CEI organization < i 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 required 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, i One weakness in the program was the length of time.taken by some contractors to resolve audit findings. Some contractors,' Pullman
- Power Products and L. ~ K. Comstoc'k for example, allowed audit findings to remain' unresolved for nearly a year. Some audit
. 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 problem and is monitoring it as an unresolved item (NRC Report 50-440/83-12).
i. VIII-2' t 4
(d) Auditor Qualification and Certification The records and certification reports of 12 Lead Auditors 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 cocumented 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-i 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 the 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 reconnended 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 B21/B33 systems [CEI Deviation Analysis Report (DAR) 111 dated 12-21-82)]. The VIII-4
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 other safety component weiding problems (i.e., polar crane, fuel handling crane, etc) where the same AWS procedure had been used. The NRC CAT Inspector learned that the applicant had initiated action to require contractor procedure modifications and, in addition, planned to expand the scope af 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 accordance with procedural requirements. In most cases, noncon-formances were being identified and dispositioned as required. However, as described in Sections III (CQA-136), Section V (NR-216 , 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.
VIII-5
. ; e . 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. 1 4 4 1'
- a e
i VIII-6 , i
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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. Eppish 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 1:. 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
d o . o ., e j 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. -
.i e s AA-2
,y ..
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 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 i
- 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. Cons ruction Test Procedures
- 17. Nont.onformance 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 AA-3}}