ML20106A334
| ML20106A334 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/08/1984 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| I-AWPP-4, OL, OL-I-AWPP-4, NUDOCS 8408170161 | |
| Download: ML20106A334 (17) | |
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-Wffyy'y AIR and WATER ff6
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BROAD AXC, PA.,
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il U. S. Nuclear Regulatory Cor}=ission
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Washington, D.C. 20555
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s BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In The Ma*.ter of Docket Nos. 50-352 O L,_
PHILADELIHIA ELECTRIC COMPANY and 50-353 (Limerich Generating Station, o(
Units 1 and 2)
TESTIMONY OF AIR & WATF.R POLLUTION PATROL (ROMANO)
CONCERNING CONTENTION VI-I (INFRACTIONS RELATED TO WELDING)
My name is Frank R. Routeno, Chairman of the Montgomery County Air and Water Pollution
- Patrol.
The purpose of my testimony is to show that Applicant, Philadelphia
- Electric, (1) failed to properly control performance of certain welding;*
(2) f ailed to properly inspect certain welding in accordance with Qaulity g, k '. :*. Control and Quality Assurance procedures
- and (3) failed to take proper and ef fective corrective actions when improper welding was discovered, 2nd (4) failed to take proper preventive actions when improper welding was dis-covered.
The scope of my testimony addresses the fact of hundreds of Nuclear Regulatory Commission Inspections and Engineering Reports that show failure in performance as numbered (1) (2) (3) (4) above.
In total the facts in these reports, backed by ot'ficial documentation prove there has been an apparant cover 3y Philadelphia Electric (P.E.) invol-ving crucial, safety related welding infractions at the Limerick nuclear reactor.
While there are four facets to the VI-I welding contention, as indicated j
l In the foregoing, an identity from any one of the four constitutes d'eviation from specified and required procedure and activity.
The 76-06-01, so-called " broomstick affair", is a classical example of failure on all four' facets of performance.
Facts in the 76-06-01 example are backed by official documentation that prove there has been an apparant cover up by Philadelphia Electric (P.E.) involving crucial, safety related welding in-fractions at the Limerick nuclear reactor.
8408170161 840508 l
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- A1so as it relates to Auditing.
PDR ADOCK 05000352 T
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AIR and WATER Pollution Patrol
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f BROAD AXE, PA.
(B) l Testimony of Air & Water Pollution Patrol re Contention VI-I continued:
l On November 10, 1976, reacting to an unannounced Nuclear Regulatory Commission (NRC) inspection report, Mr. Robert Carlson, of the NRC, wrote a letter (item 1) to P.E. Vice-President for Engineering and Research Mr.
Vincent Boyer. In t' hat letter, Mr. Carlson notified Mr. Boyer of serious violations in mandatory construction procedures involving welding infract-ions in the on-going construction at the Limerick reactor.
(See Inspection 50-353/76-06 (item 2), and in particular " Notice of Violation",
Report No.
Appendix A, Part A (item 3) of Mr. Carlson's letter.
As discussed under Part A, the most glaring example of repeated weld-ing violations had to do with the welding of safety-related items by non-g qualified welders, using unapproved methods in contempt of specified pro-cedures.
in th'is most glaring example, detailed on Page 5 of " Summary of Find-ings" under 76-06-01 (item 4), inspectors were recordLng as.O.K. improperly performed welds. On learning of these repeated violations from workmen, the NRC inspector, over the objection of Philadelphia Electric, demanded an immediate inspection of questioned welds, and found them to be grossly de-ficient...but recorded as 0.K. (described in item 4 above)
On December 15, 1976, Vincent Boyer responded to Mr. Carlson's Novem-ber 19 notice of violations, by writing to Mr. James P.O. O'Reilley, Dir-ector, NRC Office of Inspection and Enforcement, at Region 1, King of Prus-sia, Pa. (item 5).
Mr. Boyer wrote, "the inspector involved is no longer employed by the contractor and a reinspection of all other work performed by him has been accomplished 'where accessible". (see p 1 & 2 of attachemnt 1 of Mr. Boyer's Dec. 15, 1976 letter (item 6) (underif.ning mine).
The Air & Water Pollution Patrol contends a high potential for accident exists at Limerick because P.E.'s Vice-President Boyer, after welding in-fractions were discovered, failed to take proper and effective action, in failing to make it his responsibility to unsure accessible as well as inacc-essible welds were inspected.
Mr. Boyer, therefore, failed to fully exercise k l[, s s icle dYtd bW
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(C)
Testimony of Air & Water Pollution Patrol re Contention VI-i continued:
his responsibility to inspect inaccesable welds to insure inspection as was
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crucial in this particular " broomstick affair".
Mr. Boyer's failure results in repeated re-counts demonstraiting lack of control in Quality Assurance and Quality Control involving records of welding inspection activity. Such failure must be considered as increasing the potential for failure of welds to support structures, or maintain integrity under adverse conditiocs.
Seven years after the 76-06-01 affair, in order to counter out conten-tion, P.E. has changed its story. Mark Wetterhahn, P.E.'s counsel, in corr-espondence of April 27,1983 (item 7), responding to questioning by the Licensing Board relating to the possible impact of safety at Limerick, empha-tically stated, "all velds inspected by the particular inspector, not only accessible welds were re-examined". (underlining by P.E.) (See p 43 & 46)
Apparantly to further remove any doubts caused by our insistent con-tention, a follow-up letter of May 20 (item 8) from P.E.'s Counsel to the Licensing Board, contained various work records, in particular Finding Report No. N 093 (item 9), that was stated to be sent as absolute proof that all welds...accessbile as well as inaccessible welds were inspected (see p.2 of May 20 letter, lines 7,8,9,10,11).
(Report No. N093 does not even discuss inaccessible welds.)
In an order dated July 26, 1983, (item 10) the Atomic Seafety and lic-ensing Board, inspite of ordering that Air & Water Pollution Patrol's weld-ing contention be thrown out, requested affadavits from Philadelphia Elect-ric to affirm their emphatic statements contained in their April 27 letter that "all welds...not only where accessible were re-examined".
Unable to substantiate, via affidavit, information which had previous-ly and repeatedly been submitted as fact, Philadelphia Electric, through its Counsel Mark Wetterhahn's letter to the Atomic Safety and Licensing Board, dated August 19, 1983 (item 11) wrote:
In the course of preparing to respond to the Atomic Safety and Licensing Board's request contained in its Second Special Prehearing Order (LPB-83-39) dated July 26, 1983, at 38-39 for an affidavit to verify the state-
AIR and WATER WJ Pollution Patrol BROAD AXE, PA.
(D)
Testimony of Air & Water Pollution Patrol re Centention VI-I continued:
ments contained in Counsel's May 20, 1983 letter to the Licensing Board, it was learned that all inspec-tions performed by the subject quality control inspec-tor had not been identified and, therefore, not re-j inspected as previously believed. (underlining AWPP's)
Affidavits by Vincent Boyer is a confused attempt to cover up a severly serinus discovery of quasi-criminal neglect-in insuring proper welding as de-2 s'cribed in 353/76-06 01.
This incident occurred and showed up what could be found dangerous at Limerick, as was found at Midland, Zimmer etc.
At Zimmer and Midland where Bechtel, the same contractor as Limerick, was the main contractor, NRC CFR-10 appliceble regulations were found violated in too many cases, only found by accident by NRC inspectors-or on re-inspections by NRC as happened with 76-06-01. (items 14 & 15)
Even more serious than the failure of the Quality Control and Quality Assurance programs, evidenced by repeated deviations 'on AWPP submitted IE reports is the attempt by the Applicant to cover up.
The 76-06-01 affair again is the example wherein even after all welds were stated to be completely re-inspected the Applicant stated "all welds", accessible and inaccessible that the in-spector had inspected were re-inspected. Subsequent developments, including the Aug. 10, 1983 affidavit of Mr. Kemper of P.E. reveals a coverup approach-ing fraud.
Such statements indicate the shallowness of the Applicant's Quality Ass-urance program and failure by the Applicant to assure all responsibility for all activities as per PSAR Appendex D-par. D.1 and CFR-10-Appendix B.
More than that, it is evidenced that the Applicant is not above purposely attempt-ing to cover up as has been done at Midland, Zimmer, etc. And as indicated at Zimmer the acceptance of the Applicants reports of correct. ions which re-sulted in NRC closeauts of items of non-conformance is no guarrantee the non-conforming items, or subsequent same activity involved in those items were properly dispositioned.
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7 Testimony of Air & Water Pollution Patrol re Contention _VI-I continued:
)
i The oct. 28, 1983 Memorandum and Order by the Board, page 6. states AWPP's case on the merits will be limited to instances set forth in its
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required listing, absent a substantial showins of mood cause.
On the basis of good cause including absence of proper legal guidance which would have AWPP detail every report of welding infraction and used j
other discovery routes. AWPP seeks to include specific infractions invol-l ving welding not previously listed. The substantial good cause is the enabling of more, complete record for the safety of the public.
For example, IE Report No. 50-353/75-05 reporting on-inspection of i
Aug. 26-29, 1975 and Sept. 2.3.4,8. 1975, in Summary of Findings reports mr h 5) a " Deviation": Soc,e Radiography of Containment Liner Seams (AWPP page 29 and 34) states 2.5% of welded seen in the critical containment liner were radiographed instead of 4% as per requirement of PSAR, Section j
5 and Regulatory Guide 1.19 Revision 1 (Section C-1-a) That demonstrates
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a careless QA-QC contributing in later safety'related infractions. AWPP states the Applicant must show records which conclusively prove that rein-spection to conform was done on lengths of liner seam weld that were not l
previously radiographed. AWPP states the Applicant has not shown that the infraction was properly dispositioned.
l In same inspection report under 6 " Unresolved: Welded Wire Fabric For Suppression Pool Walls"(AWPP p. 30) Licensee alleged welding on the wire I
was not safety related, but the NRC inspector pointed out Licensee repre-sentative was not using Drawing C-249 as a guide as required.
In spite of Licensee's efforts to avoid compliance, the NRC inspector designated Lican-see's response as reason item was placed in unresolved status. AWPP states the Applicant failed to properly control adhearance to Quality Control re-l quirements.
Following the foregoing non-compliances and QA/QC, Applicant has been i
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charged with contempt of commitments made to the NRC as indicated under I
(
Chapter 7 " Deviations: Containment Liner Fabrication / Erection (AWPP p. 46) which states as follows: The following items had been' identified during i
previous inspections of Unit No 1 and had been identified as resolved on the basis of pendina PSAR revisions. The revised PSAR was expected in
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(f) i Testimony of Air & Water Pollution Patrol re Contention VI-I continued:
February 1975, as per information parviously provided to inspector by the Licensee (IE Inspection Report No. 50-352/75-02. item 12). As of the date t
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of this inspection.*the PSAR revision has not vet been issued for NRC re-view and amoroval. Continuation of work without prior PSAR channe review by NRC is contrary to comunitments made to the NRC in a December 23. 1974 meetina, as documented in a Directorate of Licensing " Summary of Meeting"
, dated December 31', 1974. This indicates failure by Licensee to take proper and effective action when deuistien from specified procedure._on walding.: bad been discovered.
Further demonstration of Licensee's failure to take proper corrective action is evident in Chapter 13(a) " Progress On Previously Identified Un-resob ad Items (AWPP p 49) in that a revision to clarify specified proced-ure relating to the critical containment line,r seam was claimed to be too severe by the Licensee. Licensee would seek to use its own " judgement" rather than NRC specification recommended corrective action. This is a failure to follow Quality Control and Quality Assurance to avoid future possible weld failure.
l Further under Appendix B-Notice of Violation (75-06) (AWPP page B, par. 4) i it is indicated that Applicant contributed to failure re Qus11ty Control, l
quote "The inspector stated that the licensee has not fulfilled his commit-j i
ment to NRC to issue PSAR changes for NRC review prior to adoption, and I
committed PSAR change submittals are overdue. In a subsequent telephone conversation, the licensee representative stated that changes involving adoption of later issues of codes and standards would not be submitted for prior NRC review. This is contrary to prior agreements and commitments.
(Details, Par. 7)".
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I Additionally inspection of May 28-30, 1975, under C. 1. of General Electric Company (AWPP p. 39) points out another non-compliance infraction discovered under Chapter 4. (AWPP p. 42 through AWPP p. 44),As per PSAR G.
7.7.1 and 7.2 (AWPP p. 44) top paragraph Licensee committed that field prac-tices would be equivalent to shop practices. However, NRC inspectors Haynes and Walton found site practices were less than equivelent to shop practices.
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Testimony of Air & Water Pollution Patrol re Contention VI-I continued:
Under Response to Item of Applicant Deviation (AWPP p. 54) relating to I
' July 22, 1975 lettar to James O'Reilly (AWPP p. 53) Mr. V.C. Boyer states "the more censitive radiolographic inspections of the surface irre'gularities of the stainless steel back-cladding were described as stated in the devia-tion. However, these. discernible indications do not detract from the cap-ability of the process to detect relevant indication of defect". While the discernible indications may not detract from the capability to detect rele-vant indication of defect, in closing out the infraction Applicant has not shown that the observed discernible indications themselves were not relevant.
AWPP states, absent of final proof that the NRC inspectors concurred in the dispositioning, that Applicant failed to take proper corrective action that ignored the conclusions of inspectors Haynes and Walton, and thereby risk future weld failure.
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1 Testimony of Air & Water Pollution Patrol re Contention VI-I continued:
The failure by the Applicant to forthrightly take responsibility for all activities involved in the construction of a nuclear facility even 1
after the 76-06-01 affiar is obvious in the March 5, 1984 chronology listing AWPP sent the Board (exhibit 1).
Just as the 76206-01 " Broomstick affair" was, inspite of the failures of the Applicant's Quality Control and Quality Assurance program. checked out and closed out...it is now known that many rationalized welding deficiencies remain to increase accident potential and consequences there of.
The confused attempts to explain away the deficiencies by Mr. Boyer's affadavits of Sept 16 and Sept 29, 1983 do not provide the margin of safe-ty the public deserves. AWPP calls for full sworn statements from every-one involved in such confused recount efforts. Further AWPP sees insuffic-l innt proof of validity of the "use as is", or " engineering analysis" catch 1
all means of rationalizing away the infractions.
AWPis chronology submitted to the Board, dated March 5,1984 with AWPP page numbers for easy reference showed:
(a)
AWPP p-139, 1398, AWPP'180b (NRC 1366, three of hundreds of exam-
)
ples of NCR's routinely dispositioned by wordage "use as is".,
AWPP chalanges P.E. to show proof that information supplied for close out by NRC is sub-l stanciated by records.
(b)
AWPP-144 /77-02-01 Applicant arbitrarily used its " judgement' to interpret rules which results in deviation from specified procedure.
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AWPP requires proof that the response to the infraction that resulted in j
the close out was sufficient to insure the Applicant did not repeat using l
its own " judgement" or interpretation of specified procedure. As late as deposition taken of Mr. Boyer and Mr. Clohesey of Philadelphia Electric on March 15, 1984, the use of " judgement" on how to proceed (inspite of specified procedure) by inspectors and even the welder involved in the 76-06-01 affair was condoned as per Mr. Boyer's deposition page 54, line 6,7 and 15, 16.
(c)
AWPP 152 (50-352/77-02; AWPP 155(50-352/78-03; 78-04; AWPP 156 (50-352/78-03; AWPP 156,157 (50-352/78-04, on up with AWPP 24'6 (50-352(81-05),
l.
and other listed examples showing one or other of failure to control welding l
and failure to take proper and corrective action after discovery.
I (d)
Like AWPP 144 (b) above, AWPP 189 (50-352/79-07-02 AWPP 237 4
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i Testimony of Air & Water Pollution Patrol re Contention VI-I continued:
i Applicant again is found to be arbitrarily making decision against specified procedures.
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The Applicant was required by the Oct. 28, 1983 Board Order to describe how it assurred that the qualified welders are not qualified by fraud.
The Applicant did not file its report in a month of the prehearing as ordered but was received by AWPP, perhaps three or more months later. The undated 1
copy entitled " Report Regarding The Involvement of Philadelphia Electric Con-pany Management in Assuring The Quality of Welding At Limerick Generating Station", while first talking about levels of control in attempting to insure welders were not qualified through fraud, but that they were properly qualified, admitted at page 37 and 38, in discussing welding audits, states l
"these audits have confirmed that the first two levels are working effectively to insure the Limerick Generation Station wiii be a safe and reliable plant".
j Applicant, thereupon, qualified the previous statement of reliability by saying: "However, this does not mean that the audits have not identified areas j
that need improvement" AWPP seeks to know what areas need improvement. What type of welds were involved? AWPP challenges the audit itself.~ In fact In-spection Report No-50-352/82-16 dated Feb. 10, 1983 from NRC's Thomas Martin.
Director, Division of Engineering and Technical Programs re inspection on l
11/29/82 under Observations, Section 4.3.4 indicated "PECO open audit find-4 l
ings needmore explicit guidance to imporve the timeliness of' closure".
AWPP has deposed Mr. Clohesy, inspector for Applicant as stating he uses I
his own judgement re audits. AWPP?s witness will check out the adequacy of l
judgement as it relates to assurance of validity of audits.
Further on page 37 the report discussed finding of poor quality welding j
and poor quality assurance programs as it,related to "HVAC subcontractor's entire Quality' Assurance inspections" Since it is the complete responsibil-l ity of the Applicant to be sure subcontractors have a proper Quality Assur-ance programs, this report only demonstrates weakness...not. assurance of a i
safe reliable plant.
On page 38' Applicant, after having failed to insure sufficient inspectors
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were available for HVAC to perform proper work assurance, Applicant states it "is confident its audit program works well. Page 39 and page 40 tells of the HVAC pitiful Quality Assurance program example which seems to be an unreal 7-i
Testimony of Air & Water Pollution Patrol re Contention VI_I continued:
rationalization to cover serious deficiency in the responsibility to take serious concrete action and concern after deficiencied have been discovered.
AWPP submits the name of Dr. Gudsond Iverson, Professor of Statistics, Swarthmore College, Swarthmore, Pa. Who will be witness for AWPP as it re-lates to the auditing methods used by Applicant and audits performed as their scientific validity as it relates to Quality Assurance In submitting this testimony. AWPP states it lost the use of Saturday and Sunday because the testimony was due on a Monday rather that a Tuesday.
I was denied a one day extension so that the deficiencies resulted.
I will check and follow up, via an appendix.
Respectfully submitted, AIR & WATER POL ION PARTOL R.
Romano, Chairman 61 Forest Ave.
Ambler, Pa. 19002 l
We certify the above was served on the latest service list.
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- 6.
Unrenolved; Welded Wire Tahr'ic for Suppression Pool Walls The inspector noted that welded wire f abric was shown on reinfore-ing steel design drawings for the containment suppression pool walls.
Drawing C-249 Revision 11 shows 6x6 WWF at the outermost layer of number 18 reinforcing steel.
Specific location tolerances were not shown.
Licensee representatives stated that the wire was not " safety-related," however, this was not so indicated on the drawings.
The inspector examined the project Q-list and noted that' the wire fabric was not listed under " Exceptions" in Section 5 Containment.
The licensee stated that the Q-list would be revised i
to identify the status of the wire f abric.
Mention was also made of the difficulty in recording the quality status of each and every i
item, especia11y' individual components of larger items, when some of those components are not safety-related.
This item is unre-solved pending future'IE inspection of licenses stated actions.
I
- 7.
- Unresolved: Samplina Point for Concrete Strength Test Specimens The licensee committed in PSAR, Section 5.2.5.2.1, to the ACI-SP-2 l
Manual of Concrete Inspection, 5th edition 1970, as a basis for construction procedures and practices.
This code of practice may l
states that ready-mixed concrete to be tested for acceptance,should be sampled as it is delivered and, should be sampled as near as possible to its final location.
The concrete construction spec-ification C-61, " Furnishing and Delivery of On-Site Concrete,"
originally end in revisions up to'#4 of 7/18/75 ccmplied with this.
j code. However, in the latter revision C-61 states that samples for
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compressive strength shall be at the batch plant.
t The NRC audit disclosed that specification C-61 up to revision #4 also contained in section 6.3.9, " Concrete Compressive Strength, 1
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Unit Weight and Temperatures," the statement that sampling pro-j codures may be revised by the Project Engineer once correlation is l
established between the batch plant and the point of placement.
Preceeding concrete mixing and placing for the reactor vessel ped,
i ental on 9/2/75, the NRC inspector requested to see the documenta-tion of correlation t,es, ting and was informed that no documentation was available.
Preceeding the start of concrete mixing and pince-ment for the pedestal on 9/3/75, the NRC inspector was infor=ed that compressive strength testing and te=perature would be per-formed on ennerate samples obtained at end of pipe discharge.
The i
NRC inspector observed that this practice was adhered to throughout all the pedestal placement.
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. C.,0. Wright, Quality Assurance Engineer.
J D., Wells, Quality Assurance Engineer i
R..Sevo. Quality Assurance Engineer
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J W.'Moring, Quality Assurance Engineer
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T. Dougherty, Welding and Quality Assurance Supervisor J. Vandergrift, Quality Assurance Engineer
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j S. J. Bellows, Quality Control Representative r.
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- ~ ;c The following inspection findings were presented by the. inspectors, and i *: ',. d.
were discussed as noted below:
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A.
The principal scope of the inspection included reactor pressure ves'sel i
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field fabrication records, containment liner velding aLnd associated 7-records, containment suppression pool, wall rebar installation, valve i
wall thickness verification, program and previous unresol've~d'ite=s.
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B.
Specific a'reas were examinitd and are considered acceptable.as noted
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under " Current. Findings."
(Details, Paragraph 14) 3 i
C.
1.
Certain activities were found by the inspector to involve
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Items of Noncompliance or Deviations as noted under " Enforcement i
r Action." Extensive discussion was held on the item relating
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I to the radiography of reactor pressure vessel field welds.
The inspectcr stated that IE:1 would contact the ASME code l4 J, inspector for this work to obtain further data.
(This contact 1
was made on June 4, 1975).
In a subsequent June 5 teliphone conversation with the NRC inspectors, the licensee stated that j
his metallurgist had now examined the radiographs in question j
and was of the opinion that unacceptable defects could not be masked or confused with the images of weld irregularities.
j (Details, Paragraph 4) 2.
Extended discussion also was held on the noncompliance re-i lating to the installation of containment rebar contrary to design.
The inspector acknowledged that QC inspection had not l
yet been made of the installation, and that all rebar was not yet in place, but that this did not alter the fact that work forces were accomplishing installation activities contrary to instructions and drawings.
(Details, Paragraph 6) y-t W
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- 2. ' Ceneral r
This inspection encompassed welding in progress and records o'f con-
'7 tainment' liner penetration and hemisphere dome sections, ir. stalled rebar for containment suppression pool walls, records of reactor
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j pressure vessel field fabrication, valve wall thickness verifica-tion program, and status of previous unresolved items.
General.
site tour / inspection was included.
j 3.
Construction Status r
l A heavy equipment operator strike has delayed most site activities since May 5.
Containment liner is in place including the'dryuelli except for the top flange / dome sections.
There are some penetration:
E' and hatches which remain to be installed and some seams to be installed.-
i Rebar is almost complete up to the diaphram floor; rebar for the r',
diaphram floor has not commenced. Turbine floor support columns -
.a'nd the lower floor of the auxiliary building are in place.
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4.
Deviation:
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l Reactor Pressure Vessel Field Wald Radionrechy
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Co,ntrary 'to the licensee's coussiement in Appendix C to (ht PSAR,
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j Sections C.7, C.7.1 and C.7.2, the inspector found that'the site practicas associated with the stainless steel back-cladding of 1
the reactor pressure vessel field welds and the radiographic 1
..i inspection of these welds were less than equivalent to shop i
prattices.
As a result, radiographs of the welds contained i
discernible indications which were attributed by the licensee, his representatives and the Authorised Inspector to the surf..ta regularities of the back-cladding.
During this inspection, the inspector observed that se'retal of the radiographs of the reactor pressure vessel circumferential welds, identified as AA and ).B (lower head to #1 ring and #I j-ring to #2 ring), contained faint lines running in a direction j
parallel with the weld.
The inspector noted that the indications vere located in the area of the pressure boundary we3d.
The inspector found that the responsible Chicago Bridge & Iron Com-i pany (fabricator) inspectors, General Electric Company (NSS Supplier) inspector and the inspector of the Authorized Inspec '
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tion Agency had accepted the radiographs and attributed the faint lines to the as-welded condition of the back-cladding.
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The inspector observed the back-claddin;; and found that cladding had been applied using the manual metal are process. The inspec-l tor saw that the stringer beads of the cladding vore loft, for j
the most part, in the as-wclded condition, i.e., some surface 4
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be met without grinding.
concurred with this position. General Electric Company represent In view of the licensee's PSAR commitments on t
,.t reactor pressure vessel that fimid_prac1;1cas wa@c to -'a=_3_ractices anA site fabricated
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that y dv=1ae site radinerschic inspection ~ 5d hathe oniv dirrerene** haevenn ; shop and
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Cums and the method of radiac-ashva 1.e.,precassing of radfog tha gamma-ray radiography for the site fabri more extensive use of that the. site practices which resulted in thcated vessel, it appears dications showing on the radiographs of reactore several discerni I
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field welds were less than equivalent to the corr pressure vessel
-practices.
esponding shop.
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5.
Deficiency:
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Bolting Material For Structural Steel
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documentary evidence that the material confo
,[g x B Criterion VIIl hardened washers for bolted connections ins i
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to procurement re-r e
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on of the elevations 217 and 234
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e RPV pedestal a,c i
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Nonconformance r~eport NCR-1124 identifies that ficate of' compliance called for by the purchas 3
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v'ndor certi-e Nonconforming Haterial Installation Release dat d M pecifications.
identifies that the material was released for inst 1 i
e arch 17, 1975 structures within the reactor pressure vessel pedestal I
a ation on based upon site management review and concurrence i
spaca material which lacks required documentation i
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n of notification by TWX or written report exists at the job si i
upplier's indicating that the item conforms to the procurement d 1
i The licensee could produce no such TWX or written te ocu=ents.
mance of the' material.onstrate that the vendor had report to dem-
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confor.
The licensee representative stated that he had al this deficiency in the constructor's QA progready identified inspectnr an April como (QC-FMC 31) ram and he showed the 28, 1975 fact.
QA and corporateHe stated that the matter had becn discussed be I
conformance report was to be initiated by the site Q ween sito noted that such an nonconformance report had still not b as of May 30, 1975, The inspcetor corrective action to be ecmpleted within a reasonablenor w e
or proper tisc.
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The tie rod and No.18 bar reinforcing steci did not satisfy' a.
the 1 inch clearance from penetration sleeves specified in the tolerance notes of d(aving C-247 Revision 6 at position i
4 55' elevation 220, positidE'50* elevation 218, and' position.
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2908 elevation 192.
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The inspectot interviewed the contracto'r quality control (QC)
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personnel responsible for inspeciion of reinforcing steel, to
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discusscontractorinspectionp{anningandapplicablerecords.
2.
,The QC personnel stated that no ihapection of reinforcing steel location and security had been conducted to date'on the contain-(
ment suppression chamber walls, except for positioning bars for
,cadwalding. The staff demonstrated some initial uncertainty as
'to who would ultimately be responsible for verifying reinforcing
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steel location, but the licensee representative subsequently clarified who was responsible for the~ verification.
The QC staff stated tha-the inspection effort would require about two days effort by two r
inspectors to verify conformance with drawings and specifications.
The inspector subsequently discussed nonconforming dimensions
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C" with the responsible field engineer who stated that reinforcing-1,:,
steel work is in progress and not yet complete and that noncon-
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forming dimensions would be corrected.by jacking the steel, or by i
other appropriate means just prior to each of the several* concrete placements.
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The inspector noted that the reinforcing steel work was practically
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complete with the exception of two hcop rings at the level of the~
diaphram floor, installation of horizontal ties above approxicate elevation 195, and installation of exterior mesh.
Eight layers of principally No.18 rebar,have been installed, plus reinforcement i
around penetrations.
Three catwalks within the rebar matrix have l
not yet been removed.
Continuing work has been deferred due to the heavy equipment operators strike.
The licensee representatives repeatedly stated their position that since the work had not been completed and inspected it should not be considered as having been accomplished contrary tc drawings cod instructions.
The inspector stated that the construction staff had clearly not accomplished their assigned quality affecting activities in accordance with drav$ngs and instructions, in spite of the possibility that the contractor quality control staff may-at a future date detect these facts.
7.
Deviatione:
Conenin ent 1.iner Tahrication/ Erection
- The following items had been identified during previous inspections of Unit No.1, and hpLhagn identified as' rcsolved op the basic of pending PS/4,revis,,$ons, The revind PSAR was expaetud in 1
A'ITACEME3T III (cont'd)
Response to Item of Annarent Deviation As a result of the more sensitive radiographic inspection the surface id regularities of the stainless steel back-c1=AA4ng yggg giggggg{glg gg gggggg
.in h deviation. Bowever, h oe discernible indications do not detract fromtheospabilityoftheprocesstodetectrelevantindicationsofdefects]
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per Code reguirements for the following reasons:
1.
'the density differences in.the radiographs for the surface irregular-u ities are less than or equal to the density difference for h 1T sensitivity hole in the penetraneter and the penetrameter itself hreby indicating that any relevant indication egual to or exceeding a nominal 1% would be discernible and not masked; and I
2.
h density differences in the radiographs for h surface irregula>
ities are gradual b reby allowing detection of relevant indications; such as non-fusion defects, which exhibit abrupt density differences in radiographs.
In sumanary, h above reasons support h fact that the sensitive radio-graphy, although revealing the surface irregularities of h back-cladding, meets h quality assurance requirements referred to in Section G.7 of Ap-pendix G to h PSAR and also meets h applicable Code requirements. This i
reasoning is supported by qualified personnel from Chicago 3 ridge & Iron Company, General Electric Company and Philadelphia Electric Company and W Authorised Code Inspector who have reviewed the radiographs.
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III-2/2 50-352/75-06 l
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12.
Resolution':
CBIN NDE Procedures for Reactor Pressure Y'essel i
All indications, arising from liquid penetrant or magnetic particle.
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examination of' pipe, tubes and fittings for the RPV, are intended
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to be explored as described in proceduros without exceptions..This
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resolves item number 3 of the Details section of IE inspection Report No. 50-332/75-01.
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1 The inspector previously reviewed procedures NFP-10 ' PTF-9 and'MTP-11,'
i, and had questioned the acceptance criteria regarding unaccepechle in-i dications.
The licensee has clarified the intent of the procedures l
in advising t'ha inspector that "all indications will be explored by the method described in paragraph 7.3."
The inspe:cor stated that he has no further questions on this item at this time.
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13.
Pronress on Previousiv Identified Unresolved Items y.'
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- s. [ Containment I.iner specifications - Remov'al of Imperfections:
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eThe insrector reviewed revision 7 to specification 8031-C2 for,
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- he containment liner.
This revisipn was intended to clarify t
.the definition of " shallow imperfections" which are to be
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removed from the liner plate by grinding.
The revis*1on is i
p now clear in that it requires removal of all imperfectione net, i
deeper than a specific depth.
However, the licensee noted that i
he has not yet closed out this item in that the criteria appears overly severe and may be further re.'ised.
This item 7 of II Inspection Report 50-352/75-03 is still unresolved pending re-view of licensee followup action.
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Reactor Pressure Vessel Pre-fabrication Cleaning:
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e licensee representative stated that an engineering change notice ECN-38587 has been prepared to clarify acceptan*ce criteria I
of procedure CCS-1,'and that it will be available onsite by 1
1 July 1, 1975.
The licenses also note _d that the procedu a c.
qualifications identified in ited 4 of recore 50-353ns M go /. g-I trould also be avau ne on that date.
k ection Items Which Are Considered'Accootable
!T/d Reneter Prescure Vessel Field Fabriention Records - The inspector a.
y
. audited the following records of the field fabrication of the,
l reactor pressure vassol.
(1)
Final postweld heat treat records of the bottor. head to i
- 1 ring and the il ring to #2 ring weld were reviewed.
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11.
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