ML20126D599
Text
r o
e ef#*'%,
UNITED STATES NUCLEAR REGULATORY COMMISSION
,ej
,l REGION IV 811 RYAN PLAZA DRIVE. SulTE 1000 ARLINGTON. TEXAS 76011 October 19, 1983 MEMORANDUM T0: W. A. Crossman, Chief, Reactor project Section B 1
FROM:
G. L. Constable, Senior Resident Inspector, Waterford 3
SUBJECT:
MISSING INFORMATION The first three pages attached involving penetrations 38 and 65 were part of the missing allegation.
I believe there may have been a fourth page involving another penetration.
p,.a fu p.se
,c., h d
" 4 " 14 6//q /are b f.a+ sa fA In addition, I have attached other information /9')ided by the same individual.
s, de fro hws Q 2/n prov Whether the note 'ittached to the door was from this individual or not, I don't know, but I do have reason to believe it is.
To restate information I provided when first considering this information as an allegation, the individual whose name I can supply, if needed, does not consider the information supplied an allegation. He considers it information to help NRC do its job better. He has not and will not approach his own management about these issues because he feels they already know. He feels it is our job to investigate these matters and that it is more effective when we do. He has spent considerable time in the resident's office discussing vague allegations. These typewritten details are his answer to a request from me for more specificity.
Since these issues are construction-related, I requested that after a determination on whether the investigators want this issue, that a construction inspector be assigned to assess the significance of these coments.
I am forwarding this as a package in hopes the original can be found and appropriate action taken.
If I can hel., least:qet me know.
'G.T onstable
&jf} WYh cc w/ attachments Tom Westerman j [(o6f r
ww GMDE84 y.
4-55 pm l
r
. Piping Penetration #38 Traveler #QMC-SI-P38 i
Sheet 2 Rev. 4: Details have been improperly erased / deleted from ISO / Drawing.
Bill of 2)
Sheet 3 Rev. 4. Item #3. 3/4" X 3 1/4" X 6" plate. S5 has incorrect Mat'l heat number ente, red.
"BP" is material manufacturers initials (BERGEN.
PATERSON) not a heat code or number.
Also, sheet 3 rev. I lists a different heat number for this same item. 810056. The heat log in-dicates this to be a PVN Steels Inc. heat number.
Other information in the related hanger traveler (SIRR-1246) indicates the material used was provided by Bergen-Paterson and not PVN as indicated by rev. 1 of the bill of material. Also, the correct B-P heat number is 26931.
From the above info it is not clear which material was used.
Need field walkdown of this item for confirmation.
Bill of 3)
Sheet 3 Rev. 4. Item number 4. 1/2" x 2 1/2" x 6" bar also has "B-P" Mat'l listed as heac number. This is incorrect and the correct heat number per a copy of CMTR found in package is F91512.
(Need to tie CMTR to traveler via index).
Bill of 4)
Sheet 3 Rev. 4. Item number 5. 1/4" caps, thread missing heat number.
Mac'1 Weld 5)
Sheet 6 Rev. O. Category "2/MC" is incorrect.
FW3 is an AWS D1.1 Record weld.
Weld 6)
Sheet 6 Rev. 1. FW4. FW5. FW6 and FW7:
Weld record lists filler material Record as ER-308 using WP 8.1.
Rod withdrawl slips, however, indicate E-308-16 filler material was used, it appears that the velds were initially in-tended to be made using the GTAW process but when lack of space did not allow this the SMAW process was used instead.
Either process is acceptable
- however, the weld record was never changed to reflect the actual process used.
Weld 7)
Sheet 6 Rev. 1. FW6 and FW7: The veld record contains " Write overs" on Record the fitup dates for FW6 and 7 indicating that the ficup dates have been altered without proper authority or procedure.
Weld 8)
Sheet 6 Rev. O. FW3. incor' ely lists procedure B31.1.
Should be AWS Record D1.1.
Traveler 9)
Sheet 7 Rev. 2: Missing AWI signature for ANI established hold points on Erection items 9 and 10.
Sheet Code 10)
Code Data is incomplete.
No reference was made to attachment ring. This Data Report item also needs a CMTR.
., _ _ -. -. - _ _. ~ _, _
u o
1 TRAVELER # QMC-LLRT-P65 ISO # D-22999 1.
Piping Penetration #65 1)
Sheet 2 Rev. 5 of the ISO /DWG has new " Red-Lined" information added which is not covered by the latest T&B and Ebasco revision stampo. This drawing should be marked "As-Built" not "Per Design" as presently marked.
?) The ISO /DWG bill of material is incomplete.
See item 3, 9, and 10 on the traveler bill of material.
3)
Sheet 2 Rev. 5; FCR-1736R1 calls for lest test connectio p.pe (item #3 on ISO bill of material) to be A-312.
The ISO kill of material indicates that SA-376 was used instead.
- 4) The weld ID sheet shows incorrect type of penetration for this package.
This is a type II (modified) penetration.
(Flued lead is welded to a cap not the process pipe).
- 5) Sheet 4 Rev. 1. FWl: Weld ID sheet incorrectly shows FW1 to be locsted on process pipe.
It is actually located on guard pipe per design drawings.
- 6) NCR-W3-2980 for filler metal heat #065150 (Ref. FW1) and NCR-W3-5721 for FW3 which utilized an SMAW process, should be listed on the package NCR index.
- 7) Need heat # for item 6 k" caps, thr'd.
8)
Sheet 6 Rev. 5. FW9 and FW10, need pipe and fitting heat #'s.
9)
Sheet 5 Rev. O. FW3, missing filler metal heat d.
10)
Sheet 6. Rev. O, TW3, weld record lists incorrect procedure B31.1.
Should be AWS Dl.l.
11)
Sheet 6 Rev. Os Category "MC" is incorrect.
FW3 is a category "2" weld.
12)
Sheet 6 Rev. Os In notes at bottom of sheet states:
"l/8 seal weld in field, min-2 passes". There is no reference to source of this call out anywhere in traveler.
4 l
l
Io
(-hrT Ohe.r4
..... ~. - - "
e.S (en O
% <- Tsv < < e. ns o*Qsrs SEALS INSTALLATION. REMOVAL AND REWORK 1)
The removal of conduit seals and fire breaks is not documented on a trackable form to ensure replacement.
2)
No verification method is in place to ensure existing control measures are being followed.
3)
The requirement for removal or rework of all e,eal types are not included on procedures of contractors who may require this action.*
PIPE SUPPORTS 1)
No contractor procedures or programs exist to assure supports are maintained in the design verified condition, other than modifications or revisions that the contractor implements.
2)
No planned contractor au'dits exist.
3)
Unauthorized hanger removal and modifications have been found, for example:
NCR-W3-5801 and LP&L memo number W3K83-0281 WELDING ON PENETRATIONS 1)
T&B Welding Procedure 1.8 is not qualified for impact (CVN's) or Post Weld Heat Treatment (PWHT).
This procedure was used on penetrations and this indicates also a generic problem.
2)
TBP6 procedure requires velding procedure specifications to be qualified to NB, NC, and ND.
The velding procedures are qualified to NE only and we are not even sure that it vill meet even this requirement.
4 The velding procedure nu=bers are:
1.1, 1.2, 1.3, 1.4, 1l5, 1.6 and 1.7 All of the above procedures for impact testing do no qualified per above requirements.
3)
Some of the T&B procedures do not meet the require =ents for i= pact testing by the ASME Section III Code.
4)
Look f or vrong filler material being used on velds, such as A-E70S-2 or E7018 used on S/S or stainless steel filler material used on carbon steel.
5)
Bi-Metal velds made with carbon steel and not 309 as required.
6)
Welds that have been cut out and made with carbon steel and later repaired with 309 I
Ae 9
d \\i
~
I. Piping Penetration #65 (Continued)
, eld Record 13)
Sheet 6 Rev. 5, heat #M2747 was changed to " Vendor" in error.
W This item was not vendor supplied (Ref. FCR-MP-1944).
W21d Record 14)
Sheet 5 Rev. O, FWl; ISO /DWG #D22999 is referenced as the controlling document but there is no FW1 shown on this drawing.
(Weld record needs to refer to weld ID sheet).
W21d R cord 15)
Sheet 5 Rev. O. FW1; Wald record incorrectly lists base mat'l.
as " GUARD / SLEEVE" it should be " GUARD /N0ZZEL".
Wald Rccord 16)
Sheet 5 Rev. O. FWl The base mat'l. spec. is incomplete.
Need SA106 and SA333.
NDE R:psrt 17)
PT-15551 under item " TOTAL LENGTH EXAMINED" incorrectly lists weld plate descriptions as follows:
2" x h" plate should be 2" x 3/8" plate; 7b" x h" plate should be 7h" x 3/8" plate.
NDE R:psrt 18)
RT report W3-449 incorrectly lists description as " GUARD PIPE /
SLEEVE" should be " GUARD PIPE /N0ZZEL".
- 19) Need CMTR for tus 1" cpig. heat # XU.
CMIR
C cf C
- 23) Need C of C for k" cs), thr'd., #3000.
Travc1cr
- 24) ANI " holds" not transferred to latest revision.
Ercc. Sheet W:ld R: cord 25)
Sheet 5 Rev. O. FWl Item No. 7 on veld record " preheat temp."
indicates that a 50* min. temp. was required and that CT-136 was used to verify this on 8-16-78.
However, CT-136 was found out of calibration on 7-28-78 (Ref. DN-815) and sent to Honeywell for repair and recalibration.
T-B did not receive re-certification back from Honeywell until 8-21-78 for CT-136, five days after CT-136 was reported used to verify min. preheat temperatures.
oda Data
- 26) Code data report is incomplete. No reference is made to attachment e:p;rt ring.
CMTR is also required for this item.
EXISTING PROBLEMS
% hs C,.,rhik "I
SEALS INSTALLATION, REMOVAL AND REWORK
- 1) The removal of conduit seals and fire breaks is not documented on a trackable form to ensure replacement.
- 2) No verification method is in place to ensure existing control measures are being followed.
- 3) The requirement for removal or rework of all seal types are not included on procedures of contractors who may require this action.'
PIPE SUPPORTS 1)
No contractor procedures or programs exist to assure supports are maintained in the design verified condition, other than modifications or revisions that i
the contractor implements.
i j
- 2) No planned contractor audits exist.
i
?
- 3) Unau,thorized hanger removal and modifications have been found, for example:
i N:'R-W3-5801 and LP&L memo number W3K83-0281
{
WELDING ON PENETRATIONS
- 1) T&B Welding Procedure 1.8 is not qualified for impact (CVN's) or Post j
Wald Heat Treatment (PWHT). This procedure was used on penetrations and this indicates also a generic problem.
- 2) TBP6 procedure requires welding procedure specifications to be qualified to NB. NC, and ND.
The welding procedures are qualified to NE only and we are not even sure that it will meet even this requirement.
The welding procedure numbers are:
1.1. 1.2, 1.3. 1.4. 1.5. 1.6 and 1.7 All of the above procedures for impact testing do no qualified per above requirements.
3)
Some of the T&B procedures do not meet the requirements for impact testing by the ASME Section III Code.
4)
Look for wrong filler material being used on welds, such as A-E70S-2 or E7018 used on S/S or stainless steel filler tuterici used on carbon steel.
l 5)
Bi-Hetal welds made with carbon steel and not 309 4.s required.
e e
t se
To: 'C h t o k.r
~
.i Fme las C.ar 44 FISCHBACH AND MOORE ger.g Pksu c ll uks, yes 4/ns773 i coanoaano NEW ORLEANS g/M p.f.
g 9
.p April 22, 1983 POST OFFICE BOX 1608 Louisiana Power and Light Company KENNER. LOUISIANA 70063 Waterford Steam Electric Station 4so 31ST STREET KENNER. LOUISI ANA 70062
. 1504) 466-8541 Re Response to LP&L Construction Q.A. Comments Status Review SUS # 48 C.nf m % f W srs/
.k-le. A. 4 4 YesT Pan. #
101 1)
I.R. 306-27-84:
Item 11
" Weld Bead Width" verified by H. Bernard for FY per closure of I.R. & completed installation checklist.
111 2)
I.R. 306-49-78 added to package. See page 43 of 43.
I No. NDE is required due to welding of Lee Plugs completed on 11-11-80. 2 of NCR-W3-1755 R/2.
and R/3 deleted NDE requirement on 11-6-80.
118 3)
No NDE required due to welding of Lee Plugs completed on 11-3-80. 2 of NCR-W3-1755 R/2 & R/3 deleted NDE requirement on 11-6-80.
125 4)
I.R. 306-49-78 added to package.
See page 64 of 64.
I.R. 306-27-93:
Item 11
" Weld Bead Width" verified by H. Bernard for'FY per closure of I.R. and completed installation checklist.
133
- 5)
- No NDE required due to welding of Lee Plugs completed on 11-7-80. 2 of NCR-W3-1755 R/2 and R/3 deleted NDE requirement on 11-6-80.
135 6)
NDE in package.
See page 37 of 87.
hL d b alu: -
1 acs F.J. Brown PROJECT Q.C. MANAGER l
OFFICES IN PRINCIPAL CITIES THROUCHOUT THE UNI ED STATES AND CANADA l
w
+-
.s CB&I CONTAINMENT DOCUMENTATION QUALITY RECORD DEFICIENCIES POTENTIALLY IMPACTING ILRT ITEM NO.
PROBLEM DESCRIPTION 2
CB&I records for installation / repair work subsequent to early 1979 is missing.
Such documentation covers the reinstallation of the construction /
equipment hatch and clip attachments.
4 NDE reports (MT and PT) lack specific traceability to the field work.
5 Missing Non-Destructive Examination reports on weld overlay.
6 Radiograph reports are missing on all penetrations which have pressure boundary welds (T joints).
8 Lack of traceabil-from velder qualifications to weld acceptance on shop welds.
10 Lack of traceability between qualified welders and weld repairs.
11 Missing records demonstrating material traceability and installation record traceability on the crane clips, crane girder, and a;tachments.
12 Missing documentation demonstrating the continued qualificacion of welders.
(Do have the original quality record).
15 Missing documentation defining problems / disposition for those cases where records exist accepting welds and then subsequently repair velding was performed.
16 Lack of Non-Destructive Examination record traceability on repaired velds which have a common weld number designation with shop welds.
17 Areas requiring repair are not dimensioned such that the repair documenta-tion defining extent of repair do not confirm code compliance.
22 Certain weld repair checklists are missing.
23 CB&I provided no copies of shop audits or nonconformance reports.
25 CB&I records lists instruments / equipment noted as "out of service" due to damage or failure to recalibrate. Documentation is missing which defines extent of corrective action taken or required.
t e