ML20235B951
| ML20235B951 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Zimmer |
| Issue date: | 02/26/1979 |
| From: | Savio R Advisory Committee on Reactor Safeguards |
| To: | Bender M, Catton I, Plesset M Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20234A777 | List:
|
| References | |
| FOIA-87-40 NUDOCS 8707090253 | |
| Download: ML20235B951 (2) | |
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?.3 UNITED STATES
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gs ',p, NUCLEAR REGULATORY COMMISSION l
i lT -lr Lo C ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
, /[,f WASHINGTON. D. C. 20555 4.
February 26, 1979 l
4 1
M. Bender M. Plesset I. Catton Z. Zudans
SUBJECT:
ADDITIONAL ITEMS FOR-DISCUSSION AT THE FEBRUARY 27, 1979 ZIMMER SUBCOMMITTEE MEETING I have included a copy of a newspaper article from the Cincinnati Post which was published after an interview with Mr. Isa Yin, a NRC I&E inspector from Region III. The events which preceded this article are described in the enclosed I&E inspection reports. I would refer you to pages 3 through 5 of the report attached to the October 3,1978 letter for. a summary of these event:. Mr. Vandel (Region III) will give a short presentation on this material on February 27, 1979. Mr. Yin will also be present and will be available for. questions.
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[l tv s R. Savio I
Staff Engineer
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Attachments:
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Newspaper Article 2.
I&E Inspection Reports File: Zimmer 1 1
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X UNITED STATES 4,k rf f *g %,h, NUCLEAR REGULATORY COMMISSION.
REGloN til 799 ROOSEVELT ROAD 7
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GLEN ELLYN,ILLINols 60137
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OCT 3~ 1978' Ra Docket No. 50-358 7) rn _.
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't Cincinnati Gas and Electric PE 2
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.j Company
.i N ' P; ATTN: Mr. Earl A. Borgmann O.
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Vice President Engineering 139 East 4th Street
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Cincinnati, OH 45201 e n,..,
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Gentlemen:
This refers to the investi'gation conducted by Messrs. J. E. Foster, Y
I. T. Yin, and E. J. Gallagher of this office on August 9-11, 15 of activities 'at the Zimmer Unit 1 construction site,
.h.
and 16, 1978, authorized by NRC Construction Permit No. CPPR-88, and to the dis-cussion of our findings with Messrs. B. K. Culver and W. W. Schwiers and others of your staff at the conclusion of the investigation.
This investigation concerned allegations of improper design and installation of pipe hangers, restraints, and snubbers at the Zimmer The enclosed copy of our investigation report iden-Unit 1 site.
Within these tifies those areas examined during the investigation.
areas, the investigation consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
During this investigation, certain of your activities appeared T be in noncompliance with NRC requirements, as described in the enclosed Appendix A.
C.> x This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code 9
Section 2.201 requires you to submit to of Federal Regulations.
this office within thirty days of your receipt of this notice a written statement or explanation in reply, including for each (1) corrective action taken and the results item of noncompliance:
achieved; (2) corrective action to be taken to avoid further non-compliance.; and (3) the date when full comp 11ance will be achieved.
Therefore, in your response Item 4 in Appendix A is a recurrent item.
please give this matter your particular attention.
As a result of our investigation, you issued Stop Work. Orders
/ elative to installation of mechanical snubbers, hydraulic snubbers We understand that you will not and concrete expansion anchors.
release these Stop Work Orders until you have deter' mined that a 1
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Cincinnati Gas and 0CT 3 1978~
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quality program has been implemented to control these activities and we are informed of these actions. We are aware that your Stop Work
. Order related to the installation of concrete expansion anchors was released.on September 6, 1978. We will review these matters during subsequent inspections.
In accordance with Section 2.790 of the NRC's " Rules of Practice,"
Part 2,_ Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room, except as follows.
If this report contains information that you or your. contractors believe to be
-proprietary, you must~ apply in writing to this office, within twenty days of your receipt of this letter, to withhold such information from public disclosure. The application must include g*.',
a full statement of the reasons for which the information is con-sidered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.
We will gladly discuss any questions you have concerning this investigation.
Sincerely, a
/JamesG.Keppler Director
Enclosures:
- h 1.
Appendix A, Notice of Violation 2.
IE Investigation Rpt No. 50-358/78-18 l
cc w/encls:
Mr. J. R. Schott, Plant Superintendent l
Central Files Reproduction Unit NRC 20b
U. Young Park, Power l
Siting Commission i
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i Appendix A N
NOTICE OF VIOLATION Cincinnati Gas and Docket No. 50-358 Electric Company Based on the re.,ults of an NRC investigation conducted on August 9-11 and 15-16, 197C, it appears that certain of your activities were not conducted in full compliance with NRC requirements as noted below.
These items are infractions.
1.
10 CFR 50, Appendix B, Criterion V requires, in part, that activities affecting quality shall be accomplished in accord-ance with documented instructions, procedures and drawings.
{7' Paragraph 17.1.5 of the PSAR states, in part, " Activities
/
affecting the quality of the facility are accomplished in accordance with written instructions, procedures, or drawings which prescribe acceptable methods for carrying out the activ-ities, make reference to appropriate inspections and tests, and include acceptance criteria.
Contrary to the above, numerous (at least 8) anchor bolts for safety-related supports and restraints were installed in a manner contrary to the instructions detailed on construction drawings.
l 2.
10 CFR 50, Appendix B, Criterion IV, requires, in part, that I
measures shall be established to assure that requirements which are necessary to assure adequate quality are suitably referenced or included in the documents for procurement of material.
Paragraph 17.1.4 of the PSAR states, "QAS determines that meas-(_,!
ures have been established to ensure applicable.
. design basis and other requirements to ensure adequate quality are suitably included or referenced in the documents for procurement of essential material, equipment and services.
Contrary to the above, the procurement documents for safety-related concrete expansion anchor bolts used for anchorage of supports and restraints do not includa or reference requirements necessary to ensure adequate quality nor do the procurement documents require the suppliers to have a quality assurance program.
3.
10 CFR 50, Appendix B, Criterion X requires, in part, that a program for inspection activities affecting quality shall be er o 1 1 1_ ry 0001 PM_**1M___'_'__..________._
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1 established and executed to verify conformance with the drawings.
Paragraph 17.1.10 of the PSAR states, in.part, " Inspections and
-tests are performed in accordance with written procedures which include 1 requirements for check lists and other appropriate docu-mentation of the inspections.and tests. performed."
l Contrary to the above, La.
An inspection program has not been documented or executed to verify that the concrete expansion anchor bolts have been installed adequately, such as. verification of embedment depth, torque installation. requirements, bolt spacing.or minimum edge distance requirements.
b.
The hangers, snubbers, and restraints inspection program had not been executed to verify that the installation of
' k,j-these: items were in conformance with the design drawings.
10 CFR 50, Appendix B, Criterion III requires, in part, that 4..
measures shall be established to assure that the design basis
~
for structures, systems and components are correctly translate 6
.into specifications, drawings, procedures and instructions.
Paragraph 17.1.3 of the PSAR states, in part, " Materials will be selected which correctly meet the. requirements for the' design and intended application of safety-related components,"'and that
" Parts for equipment and components will be selected which correctly meet the requirements of the design, and their intended applications are, reviewed as set forth.... to ensure their correct application and workability for their intended function is a reliable and safe manner."
Contrary to the above, 5
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a.
Design drawings Nos. M-126-7H-15, M-126-10H-58 and M-126-10H-57 do not include the required detail information to assure adequate installation of safety-related supports, in that, the design drawings do not indicate the bolt length nor embedment depth of the concrete. expansion anchor bolts transmitting the load to the concrete structure.
b.
The design drawing Nos. M-443-6H-41 and M-488-8H-20 indicate that safety-related supports and restraints are to be anchored to nonsafety related masonry block walls using concrete expansion anchors.
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Appendix A c.
Installation of hangers and snubbers were not in accordance with design drawings. The installation was completed prior to design change review and approval.
The use of drawings with incomplete design basis was cited once previously as an item of noncompliance in IE Inspection No.
50-358/78-09).
5.
10 CFR 50, Appendix B, Criterion VI requires, in part, that measures shall be established to control the issuance of documents, such as instructions. Paragraph 17.1.6 of the PSAR states, in part, "... changes to.. documents are reviewed for adequacy and are distributed in a manner similar E
to the original document."
Contrary to the above, the use of the Inter-Office Memorandum h.
(IOM) to issue QA manual procedure change was not considered appropriate in that the content of the IOM did not receive engineering and QA review, and that the IOM is not distributed and updated in accordance with the QA manual procedure.
6.
10 CFR 50, Appendix B, Criterion XIII requires, in part, that measures shall be established to control the preservation of equipment in accordance with instructions to prevent damage.
Paragraph 17.1.13 of PSAR states, in part, ".
. equipment manufacturers' instructions prescribe controls for the onsite handling,.. and preservation of material and equipment in accordance with work and inspection instructions as necessary to prevent damage or deterioration."
Contrary to the above, several installed Bergen-Paterson hydraulic snubbers were observed without accumulator indicator protective
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covers as required by the manufacturer.
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'U.S.' NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 50-358/78-18 Docket No'. 50-358 License No. CPPR-88 Licensee:
Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, OH 45201 Faeility Name:
Zimmer, Unit 1 Investigation At:
Zimmer 1 Site,-Moscow, OH
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Investigation: Conducted: August 9-11, 15 and 16, 1978
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(LA b 1[2ff7i Investigator:
. E. Fos,ter b/J/.L a. s 1 ) /-r ~ ~
9hP!78 Inspectors:
/gI. T. Yin
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E. J. Gallagher
./e r Reviewed By:
Charles E. Norelius 1/2?[77 Assistant to the Director Q'
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j Duane H. Danielson, Chief
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Engineering Support Section 2
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Richard L. Spessard, Chief
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Engineering Support Section 1 Investigation Summary Investigation on August 9-11, 15 and 16, 1978 (Report No. 50-358/78-18)
Areas Inspected: Special, unannounced inspection of procurement, design control, inspectien program, and installation procedures for pipe hangers,
- restraints, and snuobers; review of pertinent records, inspection of I N d
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installed components and interviews with personnel. The' investigation involved 84 inspector-hours onsite by three NRC inspectors.
- Results:_ Six items of noncompliance (all infractiene) were identified
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in the following areas; (Installation of concrete expansion bolts for hangers and snubbers not in accordance with drawings - Section III, Paragraph 2; Inadequate procurement documents for the concrete expan-sion bolts - Section III, Paragraph 3; Inadequate QC inspections for installation of hangers, snubbers and concrete expansion bolts -
Section II,' Paragraph 1 and Section III,-Paragraph 2; Inadequate design control and review for hangers, snubbers, and goncrete expansion anchor bolts - Section II, Paragraph 2 and Section III, Paragraph'1; Inadequate control of. issuance of procedure changes - Section II, Paragraph 3; Inadequate measures to protect hydraulic snubber components from damage - Section II, Paragraph 4).
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i INTRODUCTION The Zimmer Unit i nuclear power plant', licensed'to the Cincinnati Gas and Electric Company, is under construction near Moscow, Ohio.
Sargent
. and Lundy is the Architect-Engineering firm" for the plant, which is being constructed by Kaiser Engineering, Inc..
The facility will utilize a Boiling Water Reactor (BWR) designed by General Electric Company.
REASON FOR INVESTIGATION Dn June 27, 1978, representatives of NRC contacted Individual "A" by telephone, and discussed concerns which he had relative to the design and installation of pipe hangers, restraints, and. snubbers at the Zimmer 1 plant. During the conversation, Individual "A" alleged various
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problems related to design and installation of this equipment.
An investigation was initiated into these allegations.
4
SUMMARY
OF FACTS
- On June 27, 1978,. an individual contacted the NRC Division of Nuclear Reactor Regulation in Bethesda, MD, and indicated that Individual "A"-
had concerns related to design and installation of piping equipment at the Zimmer site. NRC personnel contacted Individual "A" on that date, discussed his concerns, and received several allegations of improper construction. Information from this discussion was transmitted to NRC Region III (RIII) for action.
On June 29, 1978, RIII personnel contacted Individual "A", an employee at the Zimmer 1 site, and discussed concerns relative to pipe hanger,
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restraint, and snubber design and installation. General information as to the various concerns was obtained, and Individual "A" was requested to note specific locations of nonconforming equipment.
RIII representatives interviewed Individual "A" on July 11, 1978.
Discussion indicated that his concerns related to what he felt was inadequate design, and improper installation of pipe hangers, restraints, and snubbers. Design concerns expressed included:
insufficient thickness of base plates for pipe supports, insuf-
- ficient bolt diameter, overall hanger geometry, and lack of consideration given to design loading conditions.
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problems discussed' included' improper embedment length of_ expansive concrete anchors. installation of pipe supports attached to block walls, and lack of lock nuts where required.
Individual "A" provided the RIII representatives with a number of
-locations where allegedly deficient pipe hangers and snubbers could be located. He indicated that this list was a selection of observed problem locations, not a full list of all locations.
Individual "A" stated that, limiting of.NRC inspection to these areas would not be-j necessary, as a general inspection of pipe hangers and snubbers would identify similar defects.
Discussion with personnel of the NRC Office of' Standards Development.
indicated that possible deficiencies related to design to pipe support base. plates had been identified as a generic problem affecting all reactor sites, and was under review. As such, the concern related to base plate design will not be treated in this report.
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A Zimmer site inspection performed during August 9-11, 15 and 16, 1978, reviewed the allegations.
During the inspection, a selection of the locations provided by Individual "A",
and several additional locations selected at random were inspected.
The inspection revealed that significant deficiencies did exist relative to design control and review, installation, and inspection of pipe hangers, restraints, and snubbers, as alleged.
Four items of noncom-pliance with NRC requirements were identified in areas where deficiencies were alleged, and two items were identified during inspection of related areas.
The licensee was advised of the findings of the investigation on August 11, 1978, and further discussions were held during August 15 and 16, 1978.
On August 15, 1978, the licensee advised RIII repre-sentatives that a stop work order had been issued for installation of concrete expansion bolts.
On August 28, 1978, the licensee informed
' {if RIII that a stop work order had been issued for hydraulic snubbers.
A stop work order for installation of mechanical snubters was issued previously.
It was indicated that the stop work orders would remain in effect until evaluations had been completed and corrective measures had been established. As part of the corrective action program, Sargent and Lundy design engineers have been assigned to the Zimmer site to review and coordinate design of pipe hangers and snubbers.
A design review committee will be formed to review future designs, and an inspection team will be formed to review completed installations. -
This program will be reviewed by RIII inspectors during subsequent inspections.
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A CONCLUSIONS
- 1. :
Adequacy of pipe support base plate design was not reviewed as a part of this-investigation, but will be. treated as a part of a generic issue..
1 2.
.Six items of noncompliance with NRC requirements were identified, four of which were directly related to allegations made.by.
Individual "A".f These items of noncompliance were related to:
f concrete anchor bolt installation, pipe. hanger and concrete anchor bolt inspection, quality documentation for concrete anchor bolts,'
l pipe hanger design control, document control and review, and j
protection of equipment during construction.-
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h DETAILS Section I t
Prepared by.J. E. Foster l
Reviewed by C. E. Norelius, Assistant to the Director 4.
1.
Personnel Contacted
' Cincinnati Gas and Electric Company B. K.' Culver, Project Manager D. C. Kramer, Quality Assurance Engineer
- J. R. Schott, Station Superintendent
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W. W. Schwiers, Principal Quality Assurance and Standards Engineer J. F. Weissenberg, Quality Assurance Engineer Kaiser Engineering, Incorporated E. Arnett, Pipefitter W. Garner, Pipefitter R. Marshal, Construction Manager W. Puckett,-Lead Mechanical Quality Assurance Inspector K. T. Shinkle,-Hanger and Mechanical Inspector R. Turner, Quality Assurance Manager Individuals Individual "A" I
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Scope This investigation' focused on the expresse.d concerns of Individual g
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'"A",' relative to pipe hangers, restraints, and snubbers at the
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Design and installation of pipe hangers and snubbers 1
Zimmer 1 site.
An expressed concern relative f
, ere principal areas of interest.to base plate design (thickness) was n w
scope of this investigation, as it is being treated as a generic issue.
NRC Headquarters personnel contacted Individual On June 27, 1978, "A".
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O On June' 29, 1978,. RIII personnel contacted Indiviaual "A" by -
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telephone.
On July. 11, 1978, RIII personnel' interviewed Individual "A".
During August 9-11, 15 and 16 -1978, an on-site inspection was performed.
3.
Initial contact with Individual "A" On June 29, 1978 RIII personnel contacted Individual "A" by' tele-phone.. Individual "A" indicated that he was employed at the Zimmer-site, and was involved with work on pipe hangers, restraints,'and snubbers. He stated that he felt that_there were major problems related to' piping equipment at the site. 'These problems included both design and installation of hangers, snubbers, and restraints.
4,'
Individual."A"' indicated that he questioned much of the criteria apparently utilized ~in the design of plant piping suspension systems. He discussed concerns related to the size of bolts used on pipe hangers, thickness of pipe support base plates, snubbers possibly misaligned with anticipated load axes, pipe supports' acting as anchors, and the' adequacy of pipe support anchorages mounted to block walls.
He also indicated that, in many cases, installation of pipe hangers, snubbers, and restraints was improper. He indicated that crafts-men frequently installed components not in accordance with the design drawings. The deviations were ' recorded 'in'as-built drawings and were sent to Sargent and Lundy for' approval.. Individual "A" also stated that concrete expansion bolt type anchors were improperly 1:
installed, locknuts were missing in some hanger locations, and 0:
' seismic snubbers were improperly installed.
(.y 4.
Interview of Individual "A" On July 11, 1978, Individaal "A" was interviewed by RIII personnel.
He repeated the comments made previously, and provided details as to locations and drawing numbers for a number of pipe hangers and snubbers alleged to be deficient. Individual "A" indicated that this was not a full listing of~1ocations of deficient components, and a general inspection of hangers and snubbers would easily identify the problems he mentioned.
Individual "A" provided additional information as to improper installation of concrete expansion anchors. He indicated that there were many examples of incorrect embedment depth for the l
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,n anchors, and locations where the anchor bolts had been cut off to disguise improper embedment depth (the top of the bolt would be cut off to make it appear that the proper length of the bolt was embedded).
Individual "A" stated that he believed that "Phillips red head" concrete anchor bolts had been substituted for "Hilti-quick" anchor bolts in some locations.
Discussion with Individual "A" provided additional information as to possible design problems. He indicated that in many places, pipe restraints designed as rigid supports were actually " anchors" as they would not allow pipe movement in any direction.
Con-cerns related to the thickness of pipe support base plates were discussed, and Individual "A" was advised that base plate thickness (rigid plate analysis) had been identified as a generic issue applicable to many architect-engineering firms, and was being pursued by the NRC.
Individual "A" indicated that an additional design problem was indicated by the fact that site specifications prohibited welding C'..
of attachments across the flange of a steel beam, and yet this had been done on the snubbers for the main steam Jines.
Individual "A" stated that a possible design de.iciency existed where attachments were welded to Bergen-Paterse, pipe clamps rather than utilizing additional clamps. He stated that this may overstress the pipe clamps.
5.
Inspection Information developed through contacts with Individual "A" was provided to RIII inspectors for review during a site inspection of pipe hangers, restraints, snubbers, and related piping com-1 ponents.
The details of inspection findings are covered in i
I Sections II and III of this report.
An RIII Investigation Specialist accompanied the inspectors during the initial portion
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of the inspection. During the inspection, a number of the l
locations provided by Individual "A" were inspected.
6.
Concerns not covered by this report 1
Several concerns indicated by Individual "A" are not treated in l
this report.
These apply to items not yet fabricated, or instal-l lation problems such as the lack of locknuts or other easily correctable problems.
It was found that the licensee had not performed final inspections of any safety-related hangers, snubbers, and restraint installations, and thus had not had the opportunity to identify and correct minor nonconformances.
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Section II m
Prepared by I. T. Yin
' Reviewed by D.-H.'Danielson, Chief-Engineering Support Section 2
.1.
Uanger and Snubber Inspection Program More than 50% of all'the safety related hangers and snubbers have been installed, however, none of these items have received final quality control inspection and signoff.'f Many of these-installed items were inspected for proper welding procedures,.
materials, weld size, and-surface conditions. The inspector observed approximately 30 safety related hangers, snubbers, and p
restraints and identified the following:
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a.
Installations that Deviated From Design Drawings 1WS - 027SR - The snubber weld attachment was bolted to the wall instead of welded to a embeded plate as shown on the drawing.
1WS - 033SR - Same deviation as 1WS-0275R.
1WS - 138HA - The vertical anchor structure plate was fastened to the concrete by 2 bolts on one side and welded to a embeded plate on the other side instead of being completely welded to the embed plate as shown on the drawing.
1WS - 025HV - Two of the four pipe riser shear lugs were
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not resting on the pipe clamp.
1RT - 0145R - An additional structural member was welded between the web of the I-beam and the snubber veld attachment.
1RT - 016SR - The snubber was attached to a horizontal beam instead of vertical post as shown on the drawing.
The attachment differed from that shown on the drawing.
IUR - 215HR - The horizontal pipe line was supported on a column instead of resting on a structural system con-sisting of a horizontal beam, vertical hanger, and a U-bolt.
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.1 IWR -~ 200 HR - The pipe line was supported on a column instead"of-by'a structural system consisting of a swivel linkage.
1WR -. 214HR Same deviation as 1WR' -1200HR.
-1RH 011HR - The rigid strut.was welded to the web of W 12 x 27 below instead of being welded to an embedment-plate above. 'The filler weld size was' measured to be 1/4",'same as.the web thickness of W'12 x 27.
The weld measured to be 1/4" was.not in accordance.with the' require-ments of KEI QACMI M-12.
A Design Document Change (DDC)'was written.for 1RH-011HR and was approved tor the' Architect Engineer and the licensee.
The actual installation' differed from that. approved by the DDC. A DDC has been written for 1WS-033,'but was not.yet approved..7Vo DDC's for 1RT-0145R and 1RT-016SR were in
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preparation.
. b.
Conflict Between Design and Construction Requirements Welds crossing a beam flange were observed at many locations including the_following snubber and hanger beam attachments:
1RT - 008SR 1RH - 485HR-1RT - 009SR 1RH - 486HR 1RH - 006SR 1RH - 487HR 1RH - 004SF 1RH - 002SR The welding was as. s;ccified on the design d'rawings, how-ever welding across k beam flange is in conflict with common industrial practice,"and the. requirements of KEI QAMC1 M-12.
{t In view of the above identified problems, the licensee's hanger 3
and snubber inspection program appears to be inadequate in that, repeated nonconformances were permitted to continue because none of the installation has received final inspection.as of the date l
of NRC inspection.
This11s considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion X, and Wm. H. Zimmer, Unit 1, FSAR Paragraph 17.1.10 requirements.
(358/78-18-01) 1 e.
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2.
. Review of Design Changes An. Inter-of fice Memorandum (1011), entitled " Essential Piping
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Hanger Installation Criteria and Inspection Requirements,"
4 issued by the KEI QA Manager, dated September 22, 1977,.was reviewed by the inspector. Among the instructions,.it states.
that " Modifications to hanger designs will be accomplished by
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issue of a DDC.
Inspection verification of compliance with DDC's will be recorded on the inspection record copy of the drawing. A copy of the DDC must be available to Quality. Assurance prior to performing the construction change.
In the event. con-struction modification is to be accomplished prior to formal approval of the DDC, Quality Assurance will perform inspections in accordance withLthe unapproved DDC's requirements.. In these cases final acceptance will be withheld until an approved copy of the DDC is received."
This instruction deviated from the Cincinnati Gas and Electric k_! '
Company QA. Manual, dated May 6, 1977, Paragraph 3.12.2(c),
which states that "DDC's are used when it is desired to obtain expedited approval of drawing or specification changes without waiting for a formal. revision of the affected document."
As noted in Paragraph 1.a above, hangers and snubbers have been installed contrary to design requirements.
In discussion with with KEI QA inspection group, the inspector was informed of the site common practice of " red lining" as-built deviations after component. installation and submitting these " red lined" drawings to the design engineer's office in hopes that the changes would be acceptable.
This is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion III, and Wm H. Zimmer, Unit 1, FSAR Paragraph 17.1.3 requirements.
(358/78-18-02) h,~,i' 3.
Document control The use of IOM to document work instruction as described in Paragraph 2 above without issuance, review, and approval as well as other document controls such as updating and distribution is considered an item of noncompliance with 10 CFR 50 Appendix B, Criterion VI, and Wm H. Zimmer, Unit 1, FSAR Paragraph 17.1.6 requirements.
(358/78-18-03) e s......
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The inspector questioned if work instructions for other safety related construction had been issued through IOM's? It was further noted that all instructions documented in IOM's should be'placed in controlled manuals or procedures. The licensee agreed to resiew this matter.
4.
Protection for Hydraulic Snubbers Bergen-Paterson (B-P) snubbers numbered 1RT-017SR, 1RT-015SR, 1RH-006HR, IRH-00lSR and 1WS-044SR, which represent approxi-mately 20% of all the snubbers observed, were observed without the required accumulator indicator protective covers. The requirement for installing these covers was discussed during a previous RIII inspection on May 31 and June 1-2, 1978, (Report No. 50-358/78-10 Paragraph 5.b).
Failure to protect safety related component during installation is considered an item of noncompliance with 10 CFR 50, Appendix B.
("' i Criterion XIII, and Wm. H. Zimmer, Unit 1, FSAR Paragraph 17.1.13 requirements.
(358/78-18-04) 5.
Design Review The following hauge'r, snubber, pipe whip restraint, and attached structures were observed by the inspector.
1RT - 016SR - The installation deviated from design drawings (Para. 1.a).
The torsional moment at the horizontal I-beam may be excessive.
1RT - 014SR - The installation deviated from design drawings (Para. 1.a).
This snubber and snubber 1RT-016SR were welded at the same location.
The attachment of snubber 1RT-016SR to the horizontal beam could impose an additional torsional moment.
(?,4 The 1/4" fillet veld on the W 8 x 17 beam having a web thickness kJ of 1/4" is not in accordance with REI QACMI M12 which requires the weld at the web to be 1/16" less than the web thickness.
1 WS - 138HA - The installation deviated from design drawings (Para. 1.a).
The structural arrangement may not be sufficient for the loadings shown on the drawing.
1 RH - 011HR - The installation deviated from design drawings (Para. 1.a).
The loading shown on the drawing may be excessive for the as-built condition.
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1 WR - 322HA - The anchor attachment to_the pipe may not be
- sufficient to withstand the loading shown.on the drawing.
1 RH - 271HV - The two tack welds cn1 the pipe saddle may not-be sufficient to withstand system vibration loadings.
1 WS.- 025HV - The installation deviated from design drawings (Para.-l.a).
Excessive loading could be imposed on the pipe riser lugs.
RHFR - 1003 - A portion of the pipe whip restraint ring section (2'-6" dia. x 8" wide x 2" thick) was removed to provide clearance for the pipe. The DDC S-1276 allowed a 1 3/4" x l'-3" cut with radius corners.
The starting edge of the cut was shown to start 3" from the edge of positioning structure. The actual cut started 9 3/4" away from the edge of positioning structure and extended outward at approximately 45 without radius corners. The inside dimension of.the cut was approximately 2 7/8" x l' -10".(near
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center) and 2' -1" (at the edge of the ring).
The outside dimension of the cut was approximately 2" x l' -10" (near center) and 2'
-1" (at the edge of the ring).
The. cut was tapered at all locations. 'A nonconformance report had not been written.
2 Beam Cuts - One side of the'l-beam flanges on a W24 x 68 radial structural beam at E1. 534' was cut out to the edge of the web.
The cut length was 12" at the top and.24" at'the bottom. The flange of a W14 x 314 beam was velded to the web of the W24 x 68.
No reinforcement was at the cut.
The cut was made to clear the recirculation loop discharge valve actuator.
The structural arrangement is shown on S6L Drawing S-398.
l 3 RH-017SR - A DPE load of 4686 lbs. As shown acting on the 1/4" I
thick web of a W 8 x 17 beam.
The structural adequacy is questioned.
In addition, a 1/4" fillet veld is shown on the drawing, which is
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in conflict with KE1 requirements, (see IRT-014SR above for explanation).
1RH-443SR and IRH-455SR - Two horizontal seismic restraints are installed on each side of valve 1E12F073B and valve 1E12F074B.
The pipe'line is 1RH 56BB 1 1/2".
The inspector questioned the following:
a.
The adeqauacy of the W 8 x 17 beam to resist the torsional-moment imposed by this installation.
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b.
The weight of.each valve including the motor operator is 220 lbs. + 10% and is about 13" off the centerline'of the Il 1/2" pipe. The adequacy of the pipe section to withstand
'the total offset loading of 440 lbs., taking into consideration local pipe stress and seismic restraint requirements.
Beam Stiffeners A number ~of. beam gusset plates were welded to.
I-beam sections in the area'of the RHR Heat Exchanger Room West.
The plates were welded on three sides without opening at the corners. This is not considered an acceptable industry practice because-the triaxial stresses imposed due to welding could result in cracking at the weldment.
The licensee agreed to perform a complete review of hanger, restraint and attachment structure. designs used on all safety-related piping systems. This is considered an unresolved item.
(358/78-18-05) 1
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Section III Prepared by E. J. Gallagher I
Reviewed by R. L. Spessard, Chief Engineering Support Section 1 1
1.
. Review of Design / Construction Drawings For Installation of Anchorage of Supports Using Concrete Expansion Anchor Bolts The inspector reviewed selected drawings being used to install safety-related supports and restraints anchorage to concrete using concrete expansion anchor bolts.
The following are the results:
a.
Drawing Nos. M-126-10H-58 (1WS 172SR), M-126-10H-57
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(1WS 171SR), and M-126-7H-15 (1WR 137HR) are Sargent and (5',
Lundy detail construction drawings which do not include instructions critical to the anchorage detail to assure anchorage capacity, i.e.,
expansion bolt length nor embedment depth. These drawings have received design review and QA review.
b.
The following drawings reviewed do not include the embedment depth to which the anchor bolts are to be installed to assure adequate anchorage capacity: M-448-3H-29 (LWR 205HR),
M-126-7H-19 (1WS 220HR), M-448-3H-64 (1WR 175SR) and M-448-3H-61 (1WR 236HR).
It was brought to t,he inspector's attention that none of the detail drawings issued to date include these instructions to assure proper installation.
c.
Specifications, procedures or instructions have not been written to date, regarding the use, installation or testing
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required when using concrete expansion anchor bolts for
- n-anchorage of safety-related supports or restraints.
Instruc-tions that would be required include minimum embedment depth for each diameter bolt, minimum spacing requirements, minimum edge distance, instructions when in contact with reinforcing steel, relocation instructions and torque requirements to assure the bolts are capable to develop the tensile capacity required.
d.
The inspector reviewed design / construction drawings which indicate anchorage of safety-related supports and restraints a
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to non-safety related block walls both hollow core block (concrete filled) and high density shielding block walls bonded together with a mortar mix.
Specification H-2174, Section 4-1 (masonry work) includes hollow core block and high density block walls.
This specification was identi-fled as (nonessential) non-safety related work.
Examples of thic condition are shown on drawings M-448-6H-41 (1WR08HR) and M-488-8H-20 (1WR232SR). The safety-related supports are designed to transmit loads to structural members.
This f ailure to assure that applicable design bases, as indicated above in a through d, for safety-related supports and restraints are correctly translated into specifications, procedures, drawings or instructions is considered an item of noncompliance with 10 CFR j
50, Appendix B, Criterion III.
(358/78-18-06)
This same condition was previously identified in RIII Inspection
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and Enforcement Report No. 358/78-09 (Item 358/78-09-04).
l 2.
Observation of Anchorage of Supports and Restraints Installed The following table is a list of support and restraints installed that the inspector observed to ascertain the quality of the installation versus the details on the design drawings:
Design Drawing No.
(Restraint No.)
Observations 1WR087SR (1) Three of four expansion bolts are (M-448-6H-24) saw cut, therefore the length of the bolt is questionable.
(2) The plate is not fully bearing on the
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concrete due to improper embedment Y',
depth. The support at this time is unrestrained and free to move under i
load conditions.
1MS0104SR Main steam line snubber is welded (M-401-9H-6 3) across the flange which conflicts with requirements of inspection pro-cedure QACMI-M12 Section 5.2.12(a).
1WR175SR At least three holes are drilled next (M-448-3H-64) to installed anchor bolt plate.
Holes reduce the effective concrete stress cone resisting anchor plate loads.
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- 1WS220HR (1) Plate is 3/4 inch off floor slab.
(M-126-7H-19)'
Detail drawing indicates bearing directly on slab.
(2) Due to condition in (1) improper embed-ment depth is evident, 1WR013SR.
(1) Drawing indicates use of embed plate (M-448-5H-42) where restraint' installed uses expansion 1 anchor bolts.
(2)' Washers _under nut turns yet nut.has been tightened.
(3) Two nuts have not been tightened or torqued.
(4) One bolt has a stack of four washers,
{7, therefore reducing embedment depth required.
(5) Bolts have improper embedment. depth as per manufactures instructions, i.e.,
4.5 times diameter of bolt.
(6) Bolts installed on angle reducing capacity of bolt.
(7) Bolts installed violate manufacturers '
minimum spacing requirements, i.e.,
10 times anchor diameter q
J 1WR205HR Drawing indicates base plate under (M-448-3H-29) pipe stanchion; no base plate installed and pipe is completely restrained to
(.7j0 walls. ' Base plate unable to be installed in this situation.
1WS033SR (1) Nuts on bolts not fu13y engaging threads; (M-126-11H-32) potential cause for thread failure under
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J (2) Drawing indicates use of embedded plate and restraint installed uses four expansion bolts of undetermined length.
No design change issued for this restraint.
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't 1WS025HV Bolts installed violate minimum. edge distance requirement of_ manufacturer, i.e., minimum 5 times anchor diameter.
Based on the above observations,' work has not been accomplished in
. accordance with the construction details provided by the applicable.
' drawings.
This: failure to accomplish activities affecting quality in accord-ance with instructions or drawings is considered an item of noncom-pliance with 10 CFR 50, Appendix B, Criterion V..
(358/78-18-07)
In addition to the observations made on the above specific supports and restraints the following two general observations on were made:
The. inspector determined that the bolts installed'to date a.
have had no inspection performed to assure that the correct.
0 length bolt has been installed according to design drawings.
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The bolts de not include a length identification marker that is available from the supplier of the bolts to be inspected subsequent-to installation nor has any inspection been per-formed during installation to ascertain the use of the correct length bolts.
b.
Interviews with two pipe fitters responsible for installing the anchors indicated that the-expansion bolts have been installed without applying a torque to the specified ranges of' values as required by Design Document Control (DDC) No.
SLS-266 dated April 5, 1977.. No inspection had been provided to assure the use of a calibrated. torque wre6ch for' setting the bolts to the prescribed torque range. The torque applied to the bolt directly affects the tensile capacity of the bolt.
. Based on the above observations of installed supports and restraints
-(LY and interviews with the pipe fitters performing the installation 3, -
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of the concrete expansion anchors, Kaiser Engineer, Inc., (KEI) has not provided an inspection program to assure that anchorage of safety-related components has been installed to the~ design drawings and manufacturers minimum requirements.
.This failure to provide an inspection program to assure adequate installation of safety-related items is' considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion X.
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. Review of Procurement Documents for Concrete Expansion Anchor Bolts The inspector reviewed the procurement documents used to purchase concrete expansion anchor or bolts used for anchorage of safety-The procurement documents do not indicate related supports.
cuality assurance requirements in the space provided for such j
l requirements, The procurement agent informed the inspector that Sargent & Lundy Specification H-2174, Section 5-4.6.4 requires the use of Hilti The "Twik Belts" and does not specify any quality requirements.
supplier has therefore not submitted a QA Manual nor has KEI The procurement or CG&E performed'any QA audits of the supplier.
documents do not reference quality standards for the material supplier nor a certificate of conformance, This failure to assure that requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material and services is con-
. rf sidered an item of noncompliance with 10 CFR 50, Appendix B, 2:7 Criterion IV.
(358/76-10-09)
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Cincinn ati a
.lectric Company ATTN: Mr. Earl A. Borgmann I
Vice President Engineering l
139 East 4th Street
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Cincinnati, OH 45201
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Gentlemen:
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This refers to the inspection conducted by Messrs. I. T. Yin and E. J. Gallagher of this office on Sept; ember 28-29, 1978, of activ-1 itses at the Wm. H. Zimmer Power Station authorized by NRC Construc-tion Permit No. CPPR-88 and to the discussion of our findings with Mr. W. W. Schwiers and others of your staff at the conclusion of
^
the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
No items of noncompliance with NRC requirements were identified during the course of this inspection.
b In accordance with Section 2.790 of the NRC's " Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room, except as follows. If this report contains information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this letter, to withhold such infor-mation from public disclosure. The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared se that proprietary infctmation identified in the application is contained in an enclosure to the application.
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t Cincinnati Gas' and 2-F Electric Company OCT C 51973
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We will gladly discuss any questions you have concerning this
-inspection.
Sincerely, t.
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- Avl R. F. Beishman, Chief 1
Reactor Construction and Engineering Support Branch
Enclosure:
IE Inspection Report No. 50-358/78-22 (z t cc w/ enc 1:
Mr. J. R. Schott, Plant Superintendent Central Files Reproduction Unit NRC 20b
PDR Local'PDR NSIC TIC U. Young Park, Power Siting Commission 4
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III I
Report No. 50-358/78-22 Docket No. 50-358 License No. CPPR-88 Licensee:
Cincinnati Gas and Electric Company-139 East 4th Street Cincinnati, Ohio 45201 Facility name:
Zimmer, Unit 1 Inspection at:
Zimmer 1 Site, Moscow, Ohio
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Inspection conducted: September 28-29, 1978 kW fo 23 7d' Inspectors:
1.
. Yin 6
/0 28 78 E. J. Galla er
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. H.
,41 son, Chief
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.gineering Support Section 2
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i Inspection Summary Inspection on September 28-29, 1978 (Report No. 50-358/78-22)
Areas Inspected: Followup inspection of problem areas relative to the
{i' safety related hangers, restraints, and concrete expansion anchor bolts installation which were identified during previous RIII inspections.
The inspection involved 28 inspector-hours onsite by two NRC inspectors.
Results: No items of non.ampliance or deviations were identified.
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...______________.._____._______O
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'. ll pETAILS l'
s Persons Contacted Principal Licensee Employees l
- W. W. Schwiers, Principal QA and Standards Engineer
- J. F. Weissenberg, QA and Standardp Engineer
- B.
K. Culver, Project Manager
- D. C. Kramer, Quality Assurance Engineer Kaiser Engineer, Inc. (KEI) Employee
- R. E. Turner, QA Manager The inspector also contacted other employees and craftsmen during the inspection, including representatives of General Electric Company, and
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-Kaiser Engineers, Incorporated.
- Denotes those present at the Exit Interview.
l Licensee Action on Previously Identified Items (Closed) Unresolved Item (358/78-01): Environment qualification hydraulic snubber seals. The' inspector reviewed the subject concern and determined that no seal materials in the market to date can withstand the radiation and operation environment conditions inside the power reactor containment for 40 years of service life.
It is a common practice for the hydraulic snubber vendors to select the best seal materials available through laboratory testing and plant operating experience, and to provide service and replacement procedures in case of material deterioration identified.
The present control and selection of seal materials by the major snubber vendors are considered acceptable.
(Open) Noncompliance Item (358/78-10-01):
Inadequate specification for procuring mechanical snubbers. The inspector reviewed Supplement 5 to Specification H-2259, dated June 6, 1978, and considered it inadequate.
This was based on the fact that unit activation parameters were addressed
.but no mention of (1) the unit bleed rate of the hydraulic snubbers, and (2) equivalent load reliefing characteristics of the mechanical snubbers.
l Further, the inclusion of cold position settings for the snubbers in the S & L installation drawings will not be completed until November 1, 1978.
In addition, the inspector stated that although snubber hot position setting (HPS) is not required during installation, the HpS should be verified during system hot functional testing.
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Purchase specification (Closed) Unresolved Item (358/78-10-02):
for E-System hydraulic snubbers. The inspector reviewed S 6 L Spec. H-2897, " Hydraulic Snubbers for Reactor Recirculation and Main Steam Piping" dated April 5,1978, and consider it acceptable.
Installation of INC mechani-(Open) Noncompliance Item (358/78-10-04):
cal snubbers without adequate installation and inspection procedures.
(1) Kaiser Engineers, Inc. (KEI) Procedure The inspector reviewed:
2-126, " Installation of Mechanical Shock and Vibration Arrestors",
26,1978, and (2) KEI Procedure 2-127, " Installation Rev. O, dated July of Hydraulic Shock and Sway Arrestors", Rev. O, dated August 1, 1978, The item remains open because (1) and considered them acceptable.
the update of KEI, QACMI, M-12 has not been reviewed and approved for use, and (2) the re-inspection of the installed mechanical snubbers based on the latest procedure has not been initiated.
-(Closed) Unresolved Item (358/78-10-05): Qualification test reports for the ITT-Grinnell hydraulic snubbers. During a licensee audit of 5-7, 1978 (Audit
($.2 General Electric Company, (GE), San Jose, CA on June 12215-1 Report 78-04), the Acton Environmental Test Corporation reports (dated January 31, 1976, relative to the environmental testings) and 12215-5 (dated February 17, 1976, relative to the seismic testings) on a 2 1/2" bore by 5" stroke snubber was reviewed by the licennee and The Test Report 12215-4, dated April 21, 1976, considered acceptable.
relative to the largest snubber provided under GE Spec. 21A9422 was also reviewed and accepted by the licensee.
(Closed) Unresolved Item (358/78-10-06): E-System hydraulic snubber The inspector reviewed the technical reports qualification reports.
For details see issued by E-System and considered them acceptable.
Section I, Paragraph 2.
International Nuc1 car Safeguards (0 pen) Unresolved Item (358/78-10-07):
Corporation (INC) mechanical snubber environmental transient and per-The IRC Report No.116, " Summary of Design Data, formance tests.
Operational Characteristics and Test Results of the Mechanical Shock
(.'g 16, 1976, was reviewed by and Vibration Arrestor", Rev. 1, dated June The dynamic functional characteristics of the A. AS, D, and DS type snubbers, the preventive measures for jamming up, and the inspector.
the applicability of the general type report to the specific purchase A meeting with INC in their engineer-specification were not apparent.
ing office arranged through licensee to discuss these issues was requested by the inspector.
Inadequate indoctrination (Closed) Noncompliance Item (358/78-10-10):The inspector reviewed the trai and training records.
for installation of mechanical and hydraulic dated September 15, 1978, snubbers, and considered it acceptable..
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f Design review for safety (Open)' Unresolved Itan (358/78-18-05):The licensee performed an audit in S & L~-
related pipe suspension.
For details, see Section I, office and identified several problems.
Paragraph:1.
Functional or program Areas Inspected Functional and' program areas inspected are documented in Section 1 and Section 11 of this report.,
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SECTION I
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prepared by 1. T. Yin Reviewed by D. H. Danielson, Chief Engineering Support Section 2 l
1.
Design Review for Safety Related Pipe Suspension The adequacy of the subject matter was questioned by the inspector during an investigation on August 9-11, and 15-16,1978 (RIII Repor:
78-18).
Subsequently, the licensee performed an audit relative to the concerns at the S 6 L af fice, Chicago, on September 6-7, 1978. The inspector reviewed the Audit Report No. 78/07, and considered some of the findings to be significant.
These included:
{
a.
Insufficient implementation of document review procedures.
b.
Re-evaluation of the hangers inside the auxiliary building was scheduled for completion by September 28, 1978, c.
Re-analysis of hangers inside the containment was scheduled for completion by November 30, 1978, d.
S 6 L has not maintained a record of support design calculations.
Many of the support designs resulted in torsional stresses which were higher than the allowables.
e.
Inadequate review for Design Document Changes (DDC's).
A followup licensee audit in the same areas will be conducted
{ 1, at S 6 L office on October 16-17, 1978.
The inspector noted that he would like to observe the audit.
No items of noncompliance or deviations were identified.
2.
Review of E-System Hydraulic Snubber Qualification Test Reports During the visit, the inspector reviewed the following technical test reports submitted by the vendor to the licensee.
No problem areas were identified during the review.
a.
No.152000-600, " Test Report on Non-Metallic Seal Material for use in Snubbers", Rev. A, dated October 12, 1977..
I e.
Volume 1 of 9, " Summary Report, Product No. 152000-620, b..
. Qualification Test Report,'GE Pipe Suspension Snubber",
Rev. B, dated January 20,:1978.
Volume'2 of'9, " Administrative Data Pro-No. 152000-620,:
duction Qualification Test Report,.GE Pipe Suspension Snubber".
c.
Rev. A, dated December 8, 1977.
Volume 4 of 9, " Test Data, 20 Kip Gnubbers, No. 152000-620, d.
Qualification Test Report", GE Pipe Suspension snubber",
Rev. A, dated December 8, 1977.
Volume 6 of 9. " Test data, 50 Kip Snubber, No. 152000-620, Qualification Test Report, GE Pipe Suspension Snubber",
e.
'Rev. A, dated December 8, 1977.
Volume 7 of 9, " Test Data, 70 Kip Snubber, No. 152000-620, f.
Qualification. Test Report, GE Pipe Suspension Snubber",
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Rev. A, dated December 8, 1977.
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. 5-SECTION II Prepared by E. J. Gallagher.
Reviewed by R. L. Spessard, Chief Engineering Support Section 1 1.
Status of Work on Installation of Anchorage of Pipe Supports and Restraints Subsequent to the IE investigation conducted at the Zimmer plant.
on August 9-11,15-16,1978, CG6E issued a stop-vork order No. 78-02 after a number of deficiencies were identified related to the use, installation and inspection of concrete expansion anchors used to anchor safety-related pipe supports and restraints.
~ i This stop-vork order was lifted effective September 7, 1978, based on the corrective action taken, in particular,-the initia-tion of procedures for installation and inspection of expansion bolts, training of craftsmen installing the bolts, identifica-tion of quality assurance requirements for the procurement of-the product and the application of a length identification stamp on the head of each bolt using a permanent die stamp.
2.
Review of' Specification and Procedures for Installation of Concrete Expansion Anchor Bolts The-inspector reviewed the following specification and procedures being used for the installation and inspection of concrete expansion anchor bolts used for anchorage of safety-related (essential) supports and pipe restraints:
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DDC No. SLS-315 (August 31, 1978) and attached Sargent and Lundy specification entitled, " Concrete Expansion Anchors:
Installation and Inspection Procedure," Rev. 2 dated
' August 31, 1978.
b.
QACMI M-12 Rev. I entitled, " Inspection Instructions for Pipe Hangers and Support Installation."
c.
Field Construction Procedure FCP 2-128 Rev. 4 dated August 31, 1978.
l d.
QACMI M-15 Rev. I entitled, " Concrete Expansion Anchor Post-Installation Procedure".
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A The inspector was informed that QACMI M-15 will be used to inspect expansion anchor bolts installed prior to the issuance of DDC
'SLS-315 (August 31, 1978) and FCp 2-128 (August 31, 1978) and that DEC SLS-315 QACMI M-12 and FCP~2-128 will be used for the instal-lation and inspection of expansion anchor bolts installed after
-August-31, 1978.
QACMI H-15 requires an inspection to be performed on bolts installed prior to August 31, 1978, and includes ultrasonic testing to determine the 1e'ngth of the installed anchors as well'as inspecting bolt spacing, edge distance and embedment depth for all bolts and inspecting the applied torque on a frequency of one bolt per hanger.
If this one bolt is unaccept-able, the procedure requires testing of all bolts for that par-ticular hanger.
In addition, all bolts that have been saw cut i
or show excessive projection shall be checked for torque and embedment depth.
The following items relative to the specification and procedures
/
were discussed and were not able to be resolved during this inspection:
l S 6 L specification, Section 2.2.3, Table E lict e the a.
minimum testing torque requirements which are much less than the installation requirements in Table D, e.g., a 3/4 inch bolt is required to be installed to 125 to 175 foot-pounds and tested to 81 foot-pounds. The inspector requested the engineering justification for the established values. The licensee agreed to make this information available during the follow-up inspection.
b.
QACMI M-15, Rev. 1, Section 3.6 states that, " bolts installed out-of-plumb by greater than 5 sha13 be unacceptable."
S & L specification for installation does not include a tolerance or requirement for installation plumbness, h
Craf tsmen are being trained in accordance with S 6 L spec.
This requirement is under evaluation by the licensee.
j The above items are considered unresolved until the information is made available at a subsequent inspection, (358/78-22-01).
3.
Calibration of Torque Wrenches Used for Installation of Expansion Anchors S 6 L specification for concrete expansion anchors, Rev. 2, Section 2.2.1 requires torque wrenches to be used for inspection
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and to be calibrated on a weekly basis, if using snap-type torque wrenches. The inspector reviewed the records of five of the eight L
torque wrenches to be used by the crpftsmen and found the cali-bretion records to be satisfactory.
4.
Procurement Documents for Concrete Expansion Anchors The inspector reviewed' purchase requisition No. 25333 dated September 13, 1978, for concrete expansion anchor bolts manu-factured by Hilti Fastener Systems. The purchase order identified the quality assurance requirements, in particular, the requirement for the supplier to issue a certificate of conformance for material properties and a requirement for a length identifica-tion marker to be stamped on the head of each bolt.
This stamp is in the form of a letter, e.g., "L" which corresponds to a length of 4 3/8 " or "R" (6 1/4").
The inspector observed in the warehouse a supply of anchor bolts with the length identi-fication marker applied.
5.
Training of Craftsmen on the Installation of Expansion Anchors Field Construction procedure FCP 2-128, Rev 4, Section 3.1.1 requires the craft superintendent to instruct the craftsmen in accordance with' installation procedures and maintain a record log of the qualified craftsman..The inspector reviewed this log with the craf t superintendent, and he as interviewed two craf tsmen installing the anchors in the field. Discussion with these craftsmen indicated that a training session had been performed and that they were familiar with the installation requirements of the procedure. Torque wrenches were not being used as they were in for calibration.-
No items of noncompliance were identified in the above reas inspected.
Unresolved Items I
(L-Unresolved items are matters thout which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations.
One unresolved item disclosed during the inspection is discussed in Section II, Paragraph 2.
Exit Iq_tfrview The inspectors oct eith site staff representatives (denoted in the Persons Contacted paragraph) at the conclusion of the inspection on September 29, 1978.
The inspectors summarized the purpose and findings of the inspection. The licensee acknowledged the findings reported herein.
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Docket N. 50-358 j_
l Cincinnati' Gas and Elec Company-ATTN:
Mr. Earl A. Borgmann Vice President Engineering 139 East 4th Street Cincinnati, OH 45201 Gentlemen:
This refers to the investigation conducted by Messrs. J. E. Foster,
- 7. E. Vandel and H. M. Wescott of this office on September 18-22 and 28-29,19?S, of activities at the Zimmer Unit 1' construction site, authorized by SRC Construction Permit.Ro. CPPP-88, and to the dis-cussion of our findings with you, Hessrs. B. R. Culver and W. W. Schwiers and others of your staff at the conclusion'of the investigation.
This' investigation concerned allegations of inadequate materials an?
welding of cable trays, pans and fittings supplied to the Zimmer Unit I site. The enclosed copy of our investigation report identifies those areas examined during the investigation. Within these areas, the investigation consisted of a selective examination of procedures and representative records, observations, witnessing of tests, and interviews with personnel.
During this investigation, one of your activities appeared to be in noncompliance with SRC requirements, as described in the enclosed Appendix A.
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This notice is.sent to you pursuant to the provisions of
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Section 2.201 of the NRC's " Rules of Practice," Part 2, Title q
3 10 Code of Federal Regulations.
Section 2.201 requires you to submit to this office within thirty days of your receip.t' of this notice a written statement or explanation in reply [
' ?j including for each item of noncompliance: (1) corrective g
action taken and the results achieved;- (2) corrective action L to be taken to avoid further noncompidance; and (3) the date J
when full compliance will be achieved.
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In^accordance with Section 2.790 of the NRC's "Ru3es of
' Practice," Part 2, Title-10',~ Code of Federal Regulations a
. copy of this letter,-the enclosures, and your response-to this letter will be placed in the NRC's Public Document Room,
'except as follows. :If the enclosures contain information.
that-you or your contractors,believe to be proprietary, you must apply,in. writing to this office, within' twenty days of your receipt of this letter, to withhold such information from public disclosure. The application.must. include a full E
statement of the reasons for which the information is con-sidered proprietary, and should be prepared'so that proprietary information identified in the application is contained in an enclosure to the application.
l We will gladly discuss any questions you have concerning this
-inspection.
Sincerely, i
=12 R. F. Heishman, Chief Reactor Construction and Engineering Support Branch
Enclosures:
1.
Appendix A, Notice of Violation 2.
IE Investigation Rpt No. 50-358/78-21
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J. R. Schott, Plant Superintendent L h)?
Central Files j
Reproduction Unit NRC 20b PDR Local PDR NSIC TIC U. Young Park, Power Siting Commission E
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Y Appendix A NOTICE'OF VIOLATION Cincinnati Gas'and Docket No. 50-356 Electric. Company Based on the results of a NRC investigation conducted on September 18-22,-
and 28-29,~ 1978, it appears that certain of.your. activities were not conducted in full compliance with NRC requirements as noted below. This item is a deficiency.
10 CFR 50, Appendix B, Criterion IX requires, in part, that " Measures shall be established to assure that special processes, including welding...., are controlled and accomplished by qualified personnel using' qualified procedures in accordance with applicable' codes, standards, specifications, criteria, and other special requirements."
Paragraph 17.1.9.2'of the Quality Assurance Program documented in the 2PS-l'FSAR states, in part. "Special processes are accomplished and controlled by qualified personnel using qualified procedures in accordance
~
with applicable codes,Section IX of the ASME Code states that changer in essential variables to the' welding procedure specification require requalification of the procedure and welder.
Section IX further lists shielding gas and filler material size as essential variables.
I.-
Husky Products, Incorporated, Welding Procedure No. 2 QAP.107, dated October 18,-1974, Revision No. 01,' specifies that. welding grade carbon dioxide shielding gas and 0.035" diameter filler metal be used.
Contrary.to the above, the inspector determined by review of
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records that two (2) of the essential variables had been changed, For a period of approximately four (4) weeks in November and C# '
December 1974, the shielding gas mixture and the size of the filler material was changed without benefit of requalification of the procedure.
2.
In addition, two welders had made several steel TIG weldments with neither a qualified welding procedure specification nor qualification ef the welders.
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OFFICE OF I:;SPECTIOS AND ENFORCEMENT REGIOS III Report Ko. 50-358/78-21 Docket No. 50-358 License 50. CPPR-88 Licensee:
Cincinnati Gas and Electric Company 139 Last 4th Street Cincinnati, OH 45201 Facility Name: Um H. Ziraner Nuclear Power Plant i
Investigation At:
Zimmer site, Moscow, Ohio and Huskv Products, Inc.,
Florence, Kentucky Investigation Conducted:
September 18-22, and 28-29,1976
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Investiptor:
J. E. Tester, m t.
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Inspectors:
T.'E. Vandel
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Q Assistant to the Director Investigation Summary Investila_t_fons on_ September 18-22 and Sept _ ember 28-2 9, 1978 _ (Report ::o.
50-35b/7B-21)
Areas Irispectedi Review of cable trays, pans and fittings located at the Zimmer site and at the Husky Products, Inc. plant; review of activities at the Husky Products, Inc. plant; and observation of testing 6ctivity at independent test labs.
The investigations involved 143 inspector-hours by three NRC inspectors.
Re_sul t s : One item of noncompliance (a deficiency) was identified in the control of special processes (velding).
Details,Section III.
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l INTRODUCTION The Zimmer Unit I nuclear power plant, If censed to the Cincinnati Gas and Elcetric Company, is under construction near Moscow, Ohio.
Sargent and Lundy is the Architert-Engineering firm for the pInnt, which is being constructed by Raiser Engineering. The facility will utilize a Boiling Water Reactor (BWR) designed by General Elcetric Company.
l The Husky Products Division (Husky) of the Burndy Corporation has supplied electrical cable pans for the Timmer plant.
These cable pans are utilized to route both safety-related and nonsafety-related electrical cables.
REASON FOR INVESTIGATION on August 31, 1978, a copy of a letter written by Individual "A",
former Husky employee, was received at the NRC Region III (RIII) 7 a
office (Exnibit I).
This let ter expressed concerns relative to the 3
quality of electrical cable pans produced by Husky for use in the Zimmer and Clinton nuclear power plant s, and alleged the use of weak materials and improper welding in cable pan construc'; ion.
An ARC investigation was initiated into these allegations.
SJ3tuRY OF FACTS Individaul "A" was contacted by RIII personnel on September 8, 1976, and his concerns were discussed in general.
These concerns related to the use of lou strength materials and improper welding as contained in the letter attached as Exhibit 1.
During September 16-20, 1978, RIII inspector visually inspected electrical cable pans at the Zimmer site, and found the velding of the pans to be acceptable.
Site personnel agreed to have samples of
'j the cable pan meterials tested for material strength, and to have j
sections of cable pan destructively tested to determine the strength of the welds. Cable pans to be tested were then selected at random (by SRC and Utility representatives).
Cable tray sampics selected were tensile tested, with the tests witnessed by an Rill inspector. All of the samples tested were found to exceed the specified yield point (t es t results attached as Exhibit V).
Destructive testiag of welds was performed on a sample of the cable pans at the Zimmer site, also witnessed by Rill personnel. These tests indicated that the welds were of acceptable strength and size according to American Mc1 ding Society criteria. wma
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g He indicated ths.t Individual "A" was interviewed by 'R111 personnel.
the use of low strength material was a one-time occurrence which took placefduring the' manufacture of cable pans for the Zimmer plant.
Individaul "A" stated that a shipment of. steel.was found to be of-for low strength, and the decision was made to use the shipment "f it t ings" (curved sections of' cable pan) only, but the shipment was not properly segregated. The shipment was inadvertently used in the
. production of straight sections of cable pan, he indicated.
k
-Individual "A" was critical of the manual welding performed by Hus yHe welders, and the welding certification program conducted by Husky.
the Husky welders had dif ficulty. in passing the certifi-indicated that cation tests,'and welded differently during the test than'in production welding.
the Clinton In addition, comments were received which related to work at plant, and are covered in a separate report (IE report No. 50-461/78-06)..
RIII personnel made two visits to the Husky f acility in Florence.
~
During plant visits, the manufacturing areas were' toured, s.
work in progress was observed, pertinent records were reviewed, and
. r, interviews were held with Husky personnel.
Records reviewed, and interviews held with Husky personnel indicated that Husky welders had been qualified as required by the American Society of Mechanical Engineers Code for Boilers and Pressure Vessels,Section IX (ASME.Section IX). No.information relative to the use of
~
low strength materials could be developed.
On September' 22,1978, R111 personnel visited the Union Testing and Research Laboratory, where material samples had been te,sted for Husky Records relating during production of cable pans for the Zimmer plant.
1974-1976 inclusive to all tests of material for Husky for the years None of the test reports reflected that materials to were reviewed.
be used in the Zimmer plant cable pans did not meet the specified l '([. i yield strength requirements.
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During a second visit to the Husky f acility, signed statements were The personnel interviewed obtained f rom three Husky employees.
indicated that they had no knowledge of any low strength materials (See being used in construction of cable pans for the Zimmer site.
Exhibits II, III and IV).
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L During document' review, it was found that the shielding gas and diameter of the filler material utilized for the welding process differed from the qualified welding procedure for a period of approximately four weeks. This is in noncomformance with ASME Section IX in that a variable of the welding process was changed without subsequent requali-fication of the welding procedure and welders.
Husky personnel stated that they would have their welding procedure qualified with the alternate shielding gas and filler material, to demonstrate that the quality of the welds was not affected by the changes in weld procedure.
Later contacts with Husky personne~
indicated that some manual welding had been performed prior tc-procedure qualification.
CONCLUSIONS 1.
- o evidence was developed that low strength material had been utilized in fabrication of electrical cable pans for the Zimmer f.
plant.
2.
Materials and welding for cable pans supplied by Husky to th(
Zimner plant were tested and found to be acceptable.
3.
Welder certification had been performed as required by'Section IX of the ASME Boiler and Pressure Vessel Code.
4.
Welding wire and shield gas were not as specified in the qualified welding procedure for a period in 1974.
In addition, two welders perforr:ed welding without benefit of prior. qualification. This is in nonconformance with 10 CFR 50, Appendix B, Criterion IX and Section IX of the ASME code.
(See DetailsSection III).
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4 DETAILS I
Section 1 Prepared by J. E. Foster Reviewed by C. E. Norelius Assistant to the Director 1.
Personnel Contacted Cincinnati Cas and Electric Company E. A. Borgman, Vice President B. K. Culver, Project Manager R. P. Ehas, Quality Assurance and Standards Engineer D. C. Kramer, Quality Assurance and Standards Engineer J. R. Schott, Station Superintendent
^'
W. W. Schweirs, Principal Quality Assurance and Standards Engineer
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W. D. Waymire, General Engineering Department Kaiser Engineers, Inc.
R. Turner, Quality Assurance Manager hushv Products Fred L. Banta, Engineering R6D Manager Don Dietrich, Tool Engineer Clare F. Duncan, Ouality Control Manager Ronald C. Johnson, Production Foremen Randy Pratt, Industrial Engineer Ken Rigley, Welding Operator Duane Ring, President Barry Schuster, Utilities Market Manager i$
The William Powell Co. (Union Testing and Research Laboratory)
Steven L. Fogle, Assistant Manager of Laboratory Edwin E. Winterfeldt, Corp. Manager of Quality Ascurance Individuals Individuals "A" through "J" m_-._,,
- ge' Sargent and Lundy M. E. Schuster Cincinnati post-Enquirer Douglas Starr, Staff Reporter i
il et eut t Research Associates L. J. Fritz, Material Testing Supervisor R. E. Duvall. Testing Technician FyS Machining Services, Inc.
J. Fost er, president 2.
SCOPE and CHRONOLOGY This investigation centered on the allegations provided by Individual l
"A", relative to the use of low strength materials and improper velding by Husky. This report covers those allegations and inspections which pertain to the Zimmer Unit 1 plant. Allegations made which pertain to the Clinton 1 plant will be reported in a separate report.
On August 31, 1978, a cory of a letter by Individual "A" was received at RIII.
On September 8,1978, Individual "A" was contacted by RIII personnel.
During September 19-20, 1978, inspections were made at Clinton ant Zimmer.
On September 20, 1976, Individual "A" was interviewed by RIII personnel.
cip During September 20-22, 27-29, 1978, RIII persennel visited the Husky facility.
On September 21, 1978, Individual "A" was contacted by telephone.
On September 22, 1978, RIII personnel visited the Union Test Lab.
l On September 25. 1978, a second letter f rom Individual "A" was received at RIII (Exhibit VII).
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On. September 27, 1978, Individua1'"A" was re-interviewed by R111 personnel.
During September 27-29, RIII personnel visited the Husky facility.
On September. 28, 1978, test s were performed on cable pans f rom the Zimmer site.
On September 29, 1978, Rill personnel visited 11odern Welding and Sheet Metal.
3.
Initial Contact with Individual "A" On September 6,1978 R111 personnel contacted Individual "A" by telephone. Individual "A" indicated that he had been the Manager of Industrial Engineering for tne Husky Products Company.
He stated that he had worked for the company approximately five years, but was laid off on August 4, 1976.
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Individual "A"'s concerns, as delineated in his letter of August 16 197e, vere discussed in general terms.
4 Interview of Individual "A" On September 20, 1976, Individual "A" was interviewed by RIII personnel.
Individual "A" indicated that the order for cable pans for tne Zimmer plant was the first contract for which l
Husky had to meet nuclear requirements.
He stated that these I
requirement s included a special design requiring vrap-around splice platts, and pan side rails made f rom material with a minicur tensile strength of 35,000 pounds per square inch.
Individual "A" stated t ha t for the Zimmer project, Husky procured steel from the Central Steel Company or J6L steel, purchasing commercial quality steel, and then testing the steel to see that it met the minimum strength requirements.
The steel supplier
)
JR;i would take a " master" coil, and slit it into six (on the average) production coils for Husky usage.
Samples would be taken from i
the steel when it arrived at Husky, and the shipment would be j
placed on hold until the results of the tests were received.
i Individua3 "A" indicated that these material tests had been per-formed by the Powell Valve Company test lab in Cincinneti (The Union Testing and Research Laboratory). l 1
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a Individual "A" stated that it was found that commercial quality steel varied in strength, and that one shipment was found to be cd low tensile strength steel.
He stated that Individual "B" made the decision to use this low st rength steel in " fittings" or curved sections of cable pan, where strength is not crucial, and that a memo to this effect had been written.
Individual "A" stated that on approximately February 10, 1976, he found that the lor tensile strength material mentioned had not been properly secrepated, and had inadvertently been made into straight sections of electrical cable pan.
Individual "A" indicated that he had informed Individual "D" that the low strength meterial had been used to manufacture cable pan.
and produced a handwritten note (see Exhibit VI) which he indicatec had been given to individual "D".
He also indicated that he had informed Individuals "B", "C", "G",
and "I" that this had happened.
He stated that this one-time occurrence had been the subject of discussion among Husky personnel for several years.
Individual "A" stated that the manual welds used to manufacture
's fittings were poorly done, and that the welder certification program was a " farce".
He stated that welders who were to work on cable pans for the Zimmer contract were required to pass a qualification test as required by Section IX of the ASMI Code.
When initially tested by Gladstone Laboratories, he said, the welders could not pass the qualification test, and generally succeeded in passing the test after multiple attempts.
Individua3 "A" stated that the welders did not perform their production welding any differently after passing the welder certification test.
2ndividual "A" ind2cated that several knowledgeable people had been critical of the welding performed by Husky welders, including Individual "J" (whose report is attached as part of Exhibit 1).
Individual "A" indicated that Individual "J" would have no part of training Husky welders unless they attended the full training course that his welding school provided, u4E RIII personnel advised Individual "A" that the technical specifi-cation for the cable pans to be used in the Zimmer plant (specifi-cation 3-2199, Division 2, Section 202.1) required that the meterials be of a minimum yie_1__d strength of 30,000 pounds per square inch (yield strength is usually less than tensile strength).
The comment i
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4' regarding 35,000 lb/ square inch tensile strength is incc rrect.
Individual "A" was also advised that the specification would not allow the use of low strength material for cable pan fittings.
5.
Investigation at Husky Products Durinp September 20-22,1978. R111 personnel visited the Husky Products f acility in Florence, Kentucky.
Discussion with Husky personnel indicated that, due to the special design of cable pans for the Zimmer contract, steel rolls utilized in their construction were of unique size (7.7 and 5.7 inch wide rolls) not used for any other contract. -As such, it was indicated, the 14 and 22 gauge material for the Zimmer contract could be easily traced through the receipt, testing, and manufacturing process, and such documentation could be identifsed by Husky Order No. 3995.
RIII personnel toured the Husky facility, observed the fabrication of sections of electrical cable pan, and inspected equipment utilized in the forming and welding processes.
Storage and receipt inspection procedures were also reviewed.
Husky personnel indicated that they had no knowledge of any lou strength steel being received or utilized by Husky for any contract.
It was indicated that during 1974-1976, Husky purchased commercial quality steel, and then took samples from the material, which would be placed on hold until testing indicated that it met the contract requirements. Husky personnel stated that they had experienced some problems with low strength aluminum, and some, steel had been returned to the vendor for roll flaws, but no 14 or 22 gauge steel had been found to be of low yield strength.
Husky personnel stated that no decision had been cade to use low strength material on cable pan fittings on the Zimmer contract or j
j any other contracts.
Husky personnel did indicate that half of one shipment of coiled j
steel had been returned to the vendor for coil defects known as
" coil breaks". They stated that the coil breaks do not affect the strength of the material, but cause problems during manufacture, and detract from the visual appearance of finished products. Tuo Husky of ficials not ed that it was possible that it was decided to use rolls with coil breaks for fittings, as the coil breaks could I
I be cut out during the manufacturing process.
However, none of the individuals interviewed recalled such a decision.
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A review of the Zimmer contract file indicated that part of a shipment of 14 gauge steel for the Zimmer contract had been returned to the vendor for having " bad waves" (improper winding of the steel which would cause manufacturing problems) Additionally, a steel shipment received on February 10, 1976, was found to be.002 inches too thich, and was accepted.
RIII personnel reviewed documents relative to receipt of materials, shipment of materials to the Zimmer site, production records covering Zimmer cable pans manufactured during 3976, returned shipments of roll steel, correspondence with steel vendors concerning coil breaks, discrepancy reports, and internal memoranda. None of the documents reviewed indicated that unacceptable materials had been utilized by Husky.
RIII personnel also reviewed welding procedure and welder qualification documentation.
It was found that manual welding for the Zimmer plant was performed using a Metal Inert Gas (MIG) procedure, and steel filler wire, using
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semi-automatic equipment.
On this type of equipment, welding para-p meters are set on the welding machine, and the utider p9sitions the welding gun and pulls a trigger. The equipment then operates automatically, controlling shielding gas flow, electric current, filler wire feed rate, and time of the weld. Manual welding was performed on " fittings" (curved sections of cable pan) only, with the bulk of cable pan being straight sections welded by automatic resistance welding equipment.
Ke] ding records reviewed met the requirements of the American Society of Mechanical Engineers Boiler and Pressure Yessel Code.
i Section IX (ASME Section IX), which was imposed'on Husky by its inclusion in their Quality Assurance Manual.
ASSE Section IX prescribes methods and procedures to be followed in welding procedure and welder qualification.
Individaul "A"'s comment L{';
that the Husky welders did not qualify in the same manner as the) produced welds is correct, but is in confermance with ASME recuire-ments. Qualification was performed to a butt veld procedure, per the requirements of ASME Section IX, and production welds were l
spot welds.
6.
Visit to Union Testing and Research Laboratory On September 22, 1978, RIII representatives visited the Union Testing and Research Laboratory, a division of the William Powell Company i
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powell personnel indicated that they had performed material tests for Husky during the years 1974-1976, and followed the procedure j
of calling the company and informing them of the test results from j
handwritten f orms, then typing the test forms and sending a copy l
to Husky f or their records.
1974-1976.
R111 personnel reviewed powell files for Husky covering All test reports reviewed indicated 14 and 22 gauge steel var tested and found to be in excess of 30,000 pounds per square inch yield strength. Typical values for such material ranged fror 33,000 to 40,000 pounds per square inch. Records for the years 1975 and 1976 indicated one test of.16 gauge steel was tested ur.d to have 29,400 lbs/ square inch yield, and one sample of aluminum was tested and found to have 15,650 lbs/ square inch yield strength, powell personnnel stated that they did not recall any 14 or 22 gauge steel which they had tested which did not exceed 30,000 lbs/ square inch yield strength. They indicated that this was typical of la and 22 gauge steel, and that steel vendors have no E.
difficulty producing such material.
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7.
Contact with Individual "A" individual "A" was contacted by telephone by the RIII investigator on September 21, 1976, and asked to provide additional detail re-garding his alleged discovery of the use of low strength material.
Individual "A" stated that he had been aware of the existence of low strength material through receipt of inspection reports which had been routed through his office.
He stated that some of the material was marked " return to vender", and some of it was marked "use for fittings only - segregate".
He indicated that he was in the Husky material storage area on Tebruary 10, 1976, and asked a worker where the Zimmer low strength material was stored. The worker did nr:
know what he was talking about, Individual "A" said, and he asked the worker's supervisor the same question, with similar results.
Individual "A" stated that he then advised Individual "B" of the occurrence, and wrote the note attached as Exhibit VI to Individual JJ "D".
He indicated that Individual "D" went to look into the matter, and later returned the note with a verbal comment to " forget it".
Individual "A" commented that he had not actually read the written he understood that specification for the Zimmer cable pans, but the specification required material with a minimum tensile strength of 35,000 lbs. per square inch. He was again advised of the actual specification requirements 4
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8.
Contact with Individual "J" Individual "J", of the Technicron School of Welding, was contacted by_the Rill investigator on September 7, 1978.
Individual "J" indicated that his school utilized Gladstone Labora-tories-(Gladstone) to certify his welders, and that when Husky welders had difficulty passing weld certification tests, Gladstone had recommended him to Husky.
Individual "J" stated that he did not remember all of the details of his review of Hosky, but he recalled that most but not all of their problems involved the welding of aluminum.
He indicated that he had fewer concerns relative to steel welding. He stated that he had looked at Husky f rom the viewpoint of a consultant, with a view towards training their welders at his school.
Individual "J" indicated that he had not refused to train welders from Husky, but he had wanted the welders to take the entire training (f
course which his school offerred.
He stated that Husky management ffs '
only wanted their welders to be schooled in the two weld procedures (MIG and TIG) which they utilized.
Individual "J" indicated that he did have some reservations that the older Husky welders would not benefit from training at his school.
During the discussion Individual "J" indicated that he was not aware that his report had been attached to Individual "A"'s letter.
He l
indicated that Individual "A" had not contacted him, and that he had not been in contact with the Husky company since the date of his report.
9.
Interview with Individual "A" on September 27, 1978 Individual "A" was interviewed on September 27, 1976, and discussions were held on the progress of the NRC investigation.
Individual "A" was advised that no evidence of low strength material
.Y-had been developed, and was requested to provide any additional I
information which would aid in the investigation.
Individual "A" indicated t hat in early 1975 prior to the shipment of low strength steel which was inadvertently used for cable pans, another riipment had been tested, found to be of low strength material, and was properly returned to the vendor.
He stated that he believed that the.
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shipment which'was improperly utilized was a small shipment, possibly of six coils of steel, which was delivered during the months of i
December 1975 or January 1976.
i Individual "A" indicated t hat he had also recalled an occurrence in liovember 1975, when Husky sent Zimmer material to ?lodern Welding,and Sheet Metal (Modern), a specialty welding firm which did not have welders qualified to ASME Section IX at the time.
Individual "A" stated that this was done because the Husky plant was on strike, an?
the company felt that they had to meet their contract to supply the cable pans. He stated that the order comprised over 100 pieces of i
equipment. of three-piece construction.
He indicated his understanding that the welders for Modern were not qualified to ASMI Section IX until sometime in 1976.
Individual "A" provided the R1ll investigators with the name and t elephone number of a f ormer Husky employee who, it was indicated, migh; have some recollection of the alleged use of low strength material during manufacture of equipment for the Zimmer plant.
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10.
Contact with Individual "D" Individual "D" was contacted by the RIII investigator on September 29, 1976.
Individual "D" was questioned as to his knowledge of the use of low strength materials in the fabrication of cable pans for the Zimrer plant. He stated that he did not recall the use of any Io. strength material on any of the Husky nuclear contracts.
He indicated that he did not believe hat anyone at Husky would knowingly allow such an occurrencc. especially those in the Quality Control department.
The scenario of the discovery of the use of the low strength material as described by Individual "A" was discussed with Individual "D",
and the note allegedly sent t o him was read.
Individual "D" stated that he had na recollection of any such note, and indicated that it would be unusuc1 for him to return such a note without some kind of written h3[
connent, as he disliked verbal communications.
Individual "D" recalled occurrences where shipments of steel were found to have various problems such as excessive oil, roll problems such as ripples or twists, or were rejected because of steel thickness variations, he indicated that he also recalled the incidence of some 1 i p ewn,.,
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Iow strength aluminum, and steel pre-galvanized with an aluminum-zinc coating which was banned from inclusion in the Zimmer equipment.
He stated that the aluminum-zinc coated material (Galvelume) was to be made into cable pan covers, but Husky personnel recognized that the 1.6L aluminum content of the coating was undesirable due to its l
'large surface area, and a program was set up to insure that no Glavalume pan covers were shipped to the Zimmer site.
Individual "D" indicated that on at least one occasion, covers were inadvertently f abricated of this material, were identified, and had to be re-fabricated 11.
Visi: to Husky products durine SepterSer 27-29, 1978 RIII personnel visited the Husky facility during September 27-29, 1978.
During this visit, documentation related to welder qualification test-ing, production records, material tests, deficiency reports, internal memoranda of the Industrial Engineering section, and weld procedure qualifications were reviewed.
Interviews were held with Husc.y personnel, and three signed statements were obtained.
(See exhibits II, III and-IV).
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None of the documents reviewed, and none of the statements received during interviews indicated that Iow strength materials had been utilized during manufacture of the Zimmer plant cable pans.
Welding certification was reviewed as pertaining to welding procedure and welder qualification to Section IX of the ASMI Boiler and Fressure Vessel Code. Wolder qualification records and welder qualification test pieces (stored at Husky) were considered acceptable.
Records indicated that welders had made several qualification attempts in many cases.
This is acceptable under ASMI Section IX.
During document reviews at Husky, it was found that the welding procedure for manual welding on Zimmer equipment had been qualified using carbon dioxide shielding gas and.035 inch diameter filler material, but a mixture of shielding gas and.045 inch diameter filler material had been utilized for the period of November 14 -
December 3, 1974. The is in nonconformance with ASMI Section IX.
which required requalification of the welding procedure when these variables were changed.
12.
Interview with Individual "E" Individual "E", Husky Purchasing Agent, was interviewed by RIII personnel on September 28, 1978, at Husky.
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. Individual "E" stated that to his knowledge, Husky had not nor returned any steel which did not meet the appropriate yieli strength requirements. He stated that since the steel that was purchased during the manufacture of the Zimmer equipment was purchased l
to commercial steel specifications, and then tested, it would not
.have been returned if it did not meet the minimum strength require-So minimum strength requirements are imposed on the steel ments.
vendor when commercial grade steel is purchased.
Individual "E" stated that flat stock steel was purchased and con-trolled in the same fashion as roll stock 1.e., to commmerical grade it met the minimum requirements, and then tested to insure that strength requirements.
Individual "E" stated that the Central Steel Company had supplied all-of the 14 gauge steel utilized for the Zimmer cable pans.
- 13. Eisit to Modern Welding and Sheet Metal On Septemeber 29, 1978, RIII representatives visited the Modern t
. 13 /
Welding and Sheet Metal Company.
Discussions were held with Individual "T", one of the managers for the firm. Individual "F" indicated that the majority of the work that his firm does for Husky is specialty welding of seperators, He indicated that junction boxes, cable bus, and aluminum welding.
of his knowledge, his firm had not performed any welding to the best on cable pans for Husky at any time.
Individual "T" was requested to review his files for work performed for Husky for the years 1975 and 1976, with attention to any work on electrical cable pans.
Individual "T" stated'that he could not find any orders concerning electrical cable pans, and the Husky found identification number (3995) for-the Zimmer project was not in his reviev of his files.
On October 12, 1978, the RIII investigator contacted Individual "r"
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and requested that he again review his files, and provide the NRC S"
with information as to any products manufactured for Husky during November, 1975.
Individual "F" provided this information, which indicated that tap boxes and cable separators had been fabricated by his firm for Husky, but no work had been done on cable pans, and none of the Husky tags applied to the work had referenced the Zimmer identification number.
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1 14 Contact with Individual "C" Individual "A" had advised R111 personnel that Individual "G" might
' have information concerning the use of low strength material in the Zimmer equipment. This individual was contacted by the P.III~investi-gator on October 5, 1978.
Individual "G" stated that he had been in the hospital during time He indicated period of the alleged use of low strength materials.
that he had no knowledge of such an occurrence, and that he had not heard anyone at the Husky plant discuss such an occurrence while he was employed there (his employment terminated in February, 1978).
15.
Contact _with Individual "H" Individual "H", an employee of Hobart Welding who had acted as a consultant to Husky on welding and welding qualification, was contacted
~
on September 29, 1978.
Individual "H", indicated that his first contact with Husky was approximately five years ago, and that Ind:.vidual "I" had been trained in the Hobart school. He stated tlat Husky had long been involved in welder qualification and in upgrsding their welding.
Individual "H" advised that five or six years ago, the Husky-welders did have some welding problems, and that they did acceptable welding on the production line, but made poor qualification test pieces.
Individual "H" stated that he believed that Husky _had a good progra for welding qualification testing, and had used the nrogram to
" weed out" the poorer welders.
16.
Discussions with Individual "A" Several telephone discussions were held with Individual "A" concerning the findings of the investigation.
Individual "A" expressed dis-satisf action with the findings of the investigation, and provided additional allegations concerning Husky.
Individual "A" stated that the Husky velders had not qualified on both the vertical and horizontal welding positions, and had performed vertical velding during cable pan manuf acture.
Individual "A" indicated that he felt that the Husky welds had been required to be of pressure vessel quality. He was advised that the specification had not required welds of pressure vessel quality.
l Welds of pressure vessel quality require non-destructive examination i '-
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1 such as magnetic particle, radiographic, Idquid penetrant, E
or L
ultrasonic testing, as a verification of their quality, and no such inspections were required.
Individual "A" also indicated that he felt that the company had not met all of the requirements of Code of Federal Regulations, Title 10, Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power l
Plants (a copy of this regulation had been provided to him by RIII personnel). Rill personnel explained that all of the requirements of this regulation were imposed on utilities, but the provisions of the Husky Quality Assurance Manual were the requirement imposed on Husky after approval of the manual by utility representatives.
17.
Contact with Husky Personnel Telephone contacts with Husky personnel indicated that some cable channels had been f abricated by Modern, with the order being proces-sed during November, 1975, and completed in later months.
Husky personnel indicated that this material was for another nuclear power plant, and was fabricated prior to the particluar utility's k.
imposition of a requirement for work done by welders qualified to 7
Section IX of the ASME Code.
Husky personnel also indicated that virtually all of their velding was done in the horizontal welding position, and t. hey did not recall any pieces for the Zimmer contract which necessitated vertical welding.
A review of Husky welder certifications for the horizontal and vertical positions indicated that one Husky welder was not qualified in the MIG procedure vertical (3C) welding position.
Welders previously indicated by Husky personnel,as having produced the majority of the Manual MIG welding for the Zimmer project (at work center 35) were recorded as having been qualified in both horizontal (2G) and vertical (3C) positions.
Qualification to the "3G" vertical position also qualified 'a welder to perform. flat (IG) welding per ASME Section IX.
~:
18.
Contacts with Husky Personnel Telephone discussions with Husky personnel on October 24, and 29, 1978, provided additional information on low strength aluminum materials.
Husky personnel indicated that aluminum materials were ordered to 6063T6 requirements, which include a minimum 30,000 lbs. per square inch yield strength (as shown by mill certificates). They stated that a shipment of the material was thought to be of low 1 ns,y p*3. ps...
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4 strength, and sample test pieces sent to their test lab confirmed that the material was below requirements. Husky personnel indicated l
that as a result of this, the entire lot of material was returned to l
the vendor, and the balance of their orders with the vendor were l
cancelled.
Husky personnel stated that the rejections of this material occurred i
in October and November 1977, with the original discrepancy report being generated:in September of=1977. They stated that'in January 197d, representatives of
- he vendor visited the Husky f acility and j
dir. cussed the problem.
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Section 11
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Prepared by T. E. Vandel I
Reviewed by D. W. Hayes, Chief f
ProjectsSection I
1.
Site Review Activities The following Zimmer site activities were performed by the inspector relative to the allegations regarding inadequate material and welding of Husky Products, Inc. (Husky) cable trays, pans and fittings:
a.
A review was conducted of the licensee source evaluation, surveillance and auditing activities performed regarding Husky.
It was established that the licensee program for vendor evaluation and auditing had been accomplished it.
that the Husky Quality Assurance program and Welding procedures had been reviewed and approved by licensee representatives. Additionally, an audit by the licensee (I_'
was performed of the implementation of the program at the l
Husky plant prior to start of fabrication.
In response to questioning, the inspector was informed that no source inspection of material was done prior to shipment since the material uas readily amenable to inspection upon receipt at the site.
It was added that the material was considered so standard and unsophisticated as to not warrant shop inspection.
b.
In review of the cable trays, pans and fittings on site, it was established that essentially all of the material has been installed and indeed have been filled with cables.
During visual inspection of the installed trays no faulty or inadequate trays were identified.
In discussions with the licensee representatives regarding the difficulty
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of visual inspection of welds now covered by galvanizing, (ut it was concluded that testing of selected random samples of material would be a more meaningful test. Therefore, the following list of samples, randomly selected by the licensee representative and the NRC inspectors, was picked for testing by either tension pull tests (yield strength) or by weld tear testing or both.
Type P.O. Number Stock Number Te.nt s Components Straight tray 18" 7070-27655 55M1-18-144 Two yields, one tear Straight tray 24" 7070-27303 55M1-24-144 One yield, two tear.
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O Fitting 7070-27223 55N1-12-H30 One yie?d, one tear Straight tray 24" Route //1276K 55M1-24-144 One yield, (f rom cont rol rooin) (P.O. unknown) one tear Fitting 7070-27655 55N1-24-vl90 -12 One yield one tear Fitting 7070-28009 55N1-24-V130 -12 One yield *
- No tear test was considered necessary since the fitting had inadvertently been torn during handling and the results of those weld tears showed adequate welding.
It was further agreed that the yield strength testing would be done by an independent testing laboratory in accordance to ASTM standard E-8 Tension Testing of Metallic Materials and that the minimum strength acceptance criteria will be the S&L specification H-2399 requirement of paragraph 202.1; i.e.,
yield strength to (4,
be a minimum of 30,000 psi.
In addition, the weld tear tests would also be done by an independent facility and that the acceptability of the welds would be judged as outlined in AUS standard C-1.3.
2.
Witness of Testing The inspector witnessed the following testing at independent labora-tories of the samples previously selected at the site.
Yield strength testing was conducted on September 28, 1978, at a.
Meteut Research Associates facility. The inspector reviewed the qualifications of the operator, the calibration and adequacy of the testing machine and the QA program standards of the facility and considered then to be acceptable for the test.
It was further learned that the tensile specimens had been prepared in accordance with the ASTM E-8.
The results of the tests are as follows.
g Metcut Site Sample Yield Strength Ultimate Percent Number Number.
Founds per Strength Eloncation Square inch T-2 1162 1276M 40,700 48,100 34.9 T-2 1163 55S112-H30 42,600 47,800 30.7 T-2 1164 55H24VI90-12 43,100 48,900 28.3 T-2 1165 55N1-24VI30-12 42,400 47,600 32.6 T-2 1166 55M1-24-144 42,100 44,700 33.0 T-2 1167 55M1-18-144(no. 1) 42,200 44,900 30.4 T-2 1168 55M1-18-144(No. 2) 41,400 44,800 33.7 i
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As'can be noted from the table above, the yield strength values were well above the minimum yield value of 30,000 psi and there-fore all test samples were deemed acceptable, b.
Also on September 28, 1978, the veld tear tests of the resistance spot welds, were witnessed by the NRC inspector at the T&S Machine
. Company, located in Moscow, Ohio.
A test rig had been assembled whereby the test assembly was anchored to the floor and by use of a fork lift truck the assembly was pulled apart at the welds (side panels to tray bottom welds).
-The test method performed adequately with the following results established.
Site Sample Mumber Number of Welds in Results of Tear Test Testing 55M1-24-144 (:a. 1) five Acceptable welds 55M1-24-144 (No. 2) three Acceptable velds
,a.: s 55M1-24-144 (:ote 1) three Acceptable velds MK 1276K 55M1-24-144 three Acceptable velds 1
55.;]-12-h30 fitting seven One weld had a reduced spot section, see ::ote 2 55::1-24V190 -12 fit ting eight Two velds had a reduced spot, see Note 2 55M1-18-144 three Acceptable welds Note 1: An additional test assembly, available for test in addition to the two planned to be tested, was also tested for a?
a total of seven test assemblies tested.
a Note 2:
The reduced spot section welds were subsequently measured and found to be adequate per the minimum size specified in AUS C-1.1.
A total of seven test assemblies were tested with a total of 32 welds being tested. All welds were determined to be adequate with three spots being evaluated as being accepturle to AWS C-1.1.
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., *o Section III Prepared by H. M. Wescott Reviewed by D. W. Hayes, Chief Projects Branch 1
1.
Review of Welding Requirements and Observation of Installed Cable Trav The inspector reviewed selected documents and made observations of safety related cable tray and fittings, as follows:
a.
Review of Sargent and Lundy specification H-2199, dated March 16, 1973, Revised July 17, 1973, titled, " Specification for Cable Pans".
b.
Review of NEMA Standard YEl-1971 used in conjunction with the specification.
1
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c.
Review of the Husky Products, Inc. Quality Control Manual,Section IX " Cont rol of Special Processes", issue date December 18, 1974, revised January 15, 1975.
d.
Review of Wr H. Zimmer Unit 1 " Documentation Check Lists" (Form QAS-106).
e.
Review of certificates of compliance.
f.
Review of Galvanizing Inspection reports.
p.
Review of We E. Zimmer receiving inspection plans (KEI Form 30 QA-8),
b.
Observations made of cable tray installed and in storage area.
d.
Participated in selection of randomly selected cable tray and j
fit tings to be tested for minimum yield strength and
]
weldrent strength tests.
1 i
i 2.
Review of Welding Procedures, Qualifications and Observations at Burndy/ Husky
)
I The inspector reviewed welding procedure specifications, procedure f
qualifications records, welder performance qualifications, and selected documents pertaining to safety related cable tray and fittings, as follows:
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Review of all valder qualifications.
b.
Review of Welding Procedure specification QAP-107, Welding Procedure No. 2 " Manual Gas Metal Arc Welding Process,"
effective date October 18, 1974, Revision No. 01.
c.
Review of QAP 104 " Procedure for Inspection of Resistance Spor Welding", effective date August 18, 1974, Revision "o.
01.
d.
Review of inter-office correspondence concerning welding, that indicated QAP-107 should be requalified to' reflect changes in essential variables.
e.
Discussion with management and shop personnel.
f.
Observations made in the shop area of fabrication in progress.
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g.
Review of in process inspection records, f'y o
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Review of a Burndy/ Husky memorandum from the Husky welding engineer dated November 14, 1974. Subj ec t " Welder Performance Qualification" indicated that a 75% argon and 25% carbon dioxide shielding gas mixture and.045 filler material was substituted for the welding grade carbon dioxide shielding gas and 0.35 filler material that was specified in QAP-107 ")bnual Gas Metal Arc Welding Process", dated October 18, 1974, Revision No. 01.
The memo f urther stated that, "The ASME Section says that if this occurs, the procedure must be requalified along with the performance tests.
(Section QW 281. 2, QW 281. 3 and QW 281.4)".
An Inter-office letter dated December 3, 1974, stated that the argon /
carbon ' dioxide gas mixture would be used until the supply was exhausted at which time the welding grade carbon dioxide would be used.
i The argon / carbon dioxide shielding gas mixture was used for approximately four weeks with no requalification of the welding procedure specification and welders.
Husky management personnel indicated that QAP-107 would be requalified using the 75% argon and 25E gas mixture using the.045 filler material.
(
This is considered to be an item of noncompliance to 10 CTR, Part 50 Appendix B, Criter. ion IX.
(50-258/78-21-02)
Subsequent to the investigation telephone contacts with Husky personnel by the investigation specialist established that steel TIG welding had been performed on cable tray prior to qualification of the welding procedure specification by two welders that had not qualified for the process. Husky personnel were requested to review the qualification records of thc personnel who had performed the welding and inform RIII of the results of their review.
Husky personnel informed RIII of the review by telephone, and followed with written notification dated November 10, 1978.
The Husky review indicated that the two welders had performed TIG welding on equipment for the Zimmer plant prior to the welding procedure qualification for the TIG process.
.~e.
The steel TIG welding procedure was qualified on August 26, 1975, by one of the two welders. The second welder was qualified to the pro-cedure on March 10, 1976.
Both welders had made several steel TIG welds prior to being qualified.
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These conditions were contrary to 10 CFR 50, Appendix B, Criterion IX of the ASMI Code.
(358/78-21-01)
Exit Interview The inspectors and the Chief, Reactor Construction and Engineering Support i
Branch, met with licensee representatives noted in Details Section 1<,
i under Personnel Contacted, at CG6E Co. on September 22, 1978. The inspectors summarized the scope and findings of the investigation and the licensee acknowledges the findings.
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Attachments:
Exhibits I through Y11 I
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August 18, 1973 Public Interest Resenreb Group 2DDD P Street N. W.
Washingten, D. C. 20036 Attention: It. John Abbotts Detr it. Abbotts:
I a.1 vriting this as a for=er e:'ployee of Jbsky Preducte Inc. of Flerence, Kentucky to report serious and deliberate non-craferaanee to 10 CEP. 50 Na ] ear Esquireients and Engineering Spe:ificaticns breed en the e.bove.
require.tects. Te utke it even verse they send out ceterized Certificates f.y of Ce:pliacce with the full kncvisdge they are falso.
1 \\0;-
In May of this year I had e:casien to sisit the Zimmer Nuclear Containment area and to see the s uloun control areas and in particular to see Ebsky
.o ceble trays in pesitten and many filled with the cables.
Sin:e this visit I have been disturbed by two aspects of P.asky's ce -est.
formar. e, particularly as they relate to the esfe opsratien of thie plar.t after ecxpletien of construction.
Inese two iaportant aspects are as fellevs:
- 1. Use of inferict and weak materiti cempletelyeutdfspecifications.
- 2. Itaye velded by iceospetent velders with every type veld defe:t present in every tray. assembly.
f' y.:
Tne folicaing 11]ustrates thess two sspects in more detail. They are related to the Zix.er job specifict117 vhich was the original job with the 10 CTP 50 requirements. On this job flagrant and serioue non-confer 2-an:e e:carred and with this se a pattern it has o :urred on all subsequent jobs.
FMTE:.IAir All tray is designed utth a Ican capacity Whieb incluiss a safety facter.
The tensile dength of the side rails largely determices this capacity.
Oc the Zimmer job the tensile strength cf the side rail naterial was te be in excess of 35,000 pourds. Hasky received and tested material as les as
$8,000 pounds and a considerable Atount in the rance of 20 te 23,000 pennin.
Some was rejected, eoss accepted en the basis it vould be ueed for fittings where strength is met as critiet1.
Exhibit I Page 1 of 7 c, p.
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N Instead the material vae not kept s"Farate and thus many very ves'd elda rails wore made up into leng straight assemblies. After finding out that coston till eteel varied se videly in tensile strengtn ne more testing vne done so that they cea]d ressin " unaware" of this condition. Incidentally eets testing of T-6 aluminus vae ales performed and a vide ramte of tensile strength was (1se found. This was aise ignored as above. What this adds upts is that Hasky hee built tray that will not carry the rated lead ever. with safety facter toeluded.
~.
VELDP:3:
Tne Zinmer job was the first job requiring the use of Certified veldere in ordar to insare coed velds. Fbsky centracted with Gladetene Laboratories of Cincinnati to set up a welder certification program. Tney did this and then tested all the velders. Without exception they failed the tests nieerably.
HJsky then called in varieas velding Engineers Lnd Fr. Ind "J"
ef Tech-nicron Scheel of Welding in Cincinnati who submitted a written report of findiccs. A copy of his report is attached. In general all the veld Engineere concurred with Mr. Ind. "J" repert. Fr. Ind. "J" was asked if he eccid f,;
or veuld train the velders. He reftsed, stating that it la very diffleult, Q]k if net nearly impsseitle to untrain people first, then try to retrain,
~
than it de to start fresh with a pereen having ne prior velding knowledge er experience.
Fbeky then proceeded te vort. en their own in crash programs in which the veldore finally velded one piece whdeh would pass a bend test. This veider taen beeaae " Certified" by lbsky. Bewever., what is critically important is t.iat nething eccurred to the quality of the predaction velde! In fact it remains to date in the saae etd state as Fb. Ind. "J"s findings dated Octeber 3?,1974. Just a few veeir age one relier was " tested" over 6; tisce before he finally nais a test piece which vas only narginti;y acceptable. Nov he is a H;ekv " Certified" weldor!
Starting in Jaly and continuing this month a new type of non-cenferaanse is presently in procese on the Clinten jeb. Fittings are being Mig eyot veldei contrary to specific Engineering requirements. In addition Alu inua Bronze filler rod ie being used with full knowledge that alntinus is not permitted in the containment area. Even verse the position of the epon de in oath a nanner the veld is less than 35% effective!
Substantiation of all these charges can be accomplished thru er. amination of Rasky documents in relation to Vaterial and to the Welders by the records, visual p>2iination er the velds and by rotesting the so called " Certified" velders by a co rretent Welding Engineer. Visual inspection of the Clinten fittinge vill substantiate the charges eutlined.
Exhibit I Page 2 of 7 1
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3, k' hat disturLs me even more than the actual incidente described is the fact se many top manaEement people see nothing vreng in all these actier.e.
So little rea.1 concern de shewn to producing a traly quality product within the specification. This shrald becese even more particularly so when naclear safety is directly imelved.
Years truly, Individual "A" Distribution as felleve:
Engir.eering Ce:panies that may er may not be esteermed.
Ebtses United Engineers ard Cor.structore
~D Be:htol Corp.
Bre n & Root
- g. -
Sargent & I/2ndy Stone & k'ebster Bla:k & Vesteh Tnis say not be eczplete, however to tha best of my kne. ledge it is.
Government Aconcies:
Nuclear F.egulatory Canissier, Cengree sione.1 Joint Ater.ie Energy Ceuittee Private Group:
PJblic Interest Eeces.rch G cup Exhibit I Page 3 of 7 1
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yeport of the rindings at Husky. Products Incorporated on October 30, 1974 Submit'ted by:
Technichron Inc., sch'ool'of Welding It was generally found that the reason your company has had difficulty that while some of your in certif yir;g your weldors is due to the f act een are gun 11f sed weldors, they suf f er f rom the ills of an cr.ip3oyec that is offering an incentive program.
In order for nn eepJoyee of yeur company to meet his required production, level, by the incentive program it was f ound that their welding plus benef j t et n;>iumom output allowabic,'vhich is just below the
[$[ -
of blowing holes in the parent metal. This condition creates jeproper r.achines were set
'pnint
- 4.. '
we) ding nethods, and instead of establishing good welding, you have a 1hese extreme emperage settir.;s situat$on cf b3ncting the metal together.
a)so n.ske it necessary to use higher gas flow in order to control the This has to be extremely cestly to your company.
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because of the conditions that exist '(wc3 ding machine settinc.s and gar fJewr) it was observed thct ieproper welding is a commen occurence et lluchy Products. The welds are not structurally sound.
Aluminum Weldinc:
A31 the' welds have craters and it was observed that most of these cratcra chaw the commen condition known as " crater cracking".
It was further observed that there were many welds that had both cracking These conditions are conditfuns in the weld as well as the crater.
prima:3)> cause) by the extremely high amperagen und gas coverar.e.
Your wclder s cre running extremely hot welds due to speed and thus t.'
Ibc high gas flows you have rar.id cooling conditions and cracking.
-(while costly) niso causes rapid cooling and thus cracking.
the veldors in your aluminum weldies Generally it was observed that areas had nood welding techniques however lock knowledge in setting up the proper welding conditions before welding.
s Exhibit I Page 4 of 7 b.
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These s>en 14. eked the iollowing knowledge:
1..
Settini,; the velding machine 2.-
Setting the proper gas flow 3.
lialling the tungsten rether then pointing it 4.
Controlling, the weld to prevent ersters 5.
Cleaning the parent metal before velding Stect Veldig:
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rour r,cn were observed fu the stec) weldinr, arras. One enn had the knowledr,e of proper nachine and gas flow settint,s however he lacked t he veldjnt t ethniquen. This man uns one of you oldest welders.
Thu other three ca. had very lit tle knnuledr.c about proper settings and one of the three locked the prorer velding techniques. Thi s tr.an una ynor oldest employee in your weldinp, department. /pfu it van a; par s nt that all conditions existed to turn ou: maxime, production.
/an Jon", as you have there enndttinon you will iind thnt tertif ying velder:.
is p,oint to Le ext remcly dif ficult. Wher obaciving several of the tett coup'vc run by yout weldors it was f ound that the follo.ifnp conditions njr,ted:
1.
Crystallitations of the veld 2.
Porosity
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Fcncttation that exceeded 100:
4 Undercut 5.
Weaking of potent metal in the heat elietted tone All ti.e conditf uns are created directly by running too high of amperages, too high of t.nc flows, and dirty retal.
Exhibit I Fage 5 of 7 d
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Other Observations:
1.
The using of fans in the velding areas is common practice. This condition causes the gas shield to be blevn away, thus causity, porosity in the welds. This is another reason for the high ges ~ficN ' pressures which is costly since larger volumes of gas,are used then necessary.
2 2.
It was noted that Argon /CO mix was being used in your M.I.C. welding operations on steel. This again is costly because CO2 youldbeadequatefor your operation. StgaightCD costs about 1/6 of what 75/25 Argon /c0 ix costs.
3.
Many of your employees do not use eye protection or face protection.
I'c certain you must have
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f requently absenteeism due to cyc flash injuries.
4.
b'o use of safety glasses in the entire Flor.t.
~
b' elders most wear safety ginnnes under their velding hood.
(An OSILA Standard).
5.
The plant is not in coeplinnce with OSHA Stcndards.
This could cause extreme hardship in the future especially if you have a severe injury of one of your c: ployees.
Suggetion:
llu: sty' Products Inc., shculd consider a training progra:t for thoses individuc1s enployed in their welding department. This program should earphat,1ze velding methods as well es welding techniques.
PW Any success arising f rom this training program is highly questionable, since proper welding tiethods and techniques vould cut production. The present attitude in your welding department is quantity not quality.
Sound certified quality welds will definitely reduce quantity, h0vever -
the savings in cost of materials will most likely imireve or equalize profits.
Exhibit I Page 6 of 7 O...
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t, l'am submitting this report with the intension of creating many constructive' suggestions and have no intension to sound like I ar..
being critical. You. realized you had none: concerns or you would have never contacted TechnJchron in the first pInce. Therefore,.
- 1. siticerely hope that I have been %f service to your con.pany and
. that vc r.:.y cerve you cEsin in the future.
Thank you.
Respectively Submftted Individual "J" gg '.
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- Technichron School of k'eldini, a
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Exhibit I Page 7 of 7 1
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l make the following written voluntary I, Individual "B"
l-statement to James Foster who has identified himself to me as an investigation specialist of the Nuclear I
Regulatory Commission.
I understand that I do not have to make a statement and that any statement I do make may be used in legal proceedings.
I have no knowledge of low yield strength steel, below 30,000 lbs. per square inch, having been present at thtt Husky Products Plant nor of such material having been utilized in the production of cable pans for the Zimmer 4
Nuclear Power Plant.
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I have read the preceding statement consisting of It is one page and made corrections where necessary.
a true representation.
Individual "3"
Signed "h h
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Exhibit II
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4 I, Individual "c"
, make the following written voluntary statement to James roster who has identified himself to me as an investigation specialist of the Nuclear Regulatory Commission.
I understand that I do not have to make a statement and that any statement I do make may be used in legal proceedings.
I have no knowledge of low yield strength steel, below 30,000 lbs. per square inch, having been present at the Husky Products Plant nor of such material having been utilized in the production of cable. pans for the Zimmer Nuclear Power Plant.
Q*
I have. read the preceding state:nent consisting of
.one page and made corrections where necessary.
It is a true representation.
Signed, Indiyi dg,"C" f-A$~ l8 Date ff Witness f
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Individual "1" make the following voluntary written statement to James E. Foster, who has identified himself to me as an Investigation l
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Specialist of the Nuclear Regulatory Commission.
I understand that I do not have to make a statement, and any statement that I do make ma:.
be used in legal proceedings.
I am presently employed by Husky Products (as) an Industrial Engineer.
To the best of my knowledge, no low yield point material has ever 4
been utilized in the manufacture of equipment for the Zimmer Nuclear 4.'
Power Plant Unit 1.
I have been directly involved with the in-house welder certification program since its inception. This program has been properly conducted, and follows the provisions of ASNE Section IX for welder certification.
I did not object to my participation in this program, but had to become knowledgeable in welding before becoming centrally invelvea in the program.
I feel that welder certification has been honestly conducted.
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k'elding procedures and welders have not been re-qualified when veld
'r shield gas or gas mixtures have been changed.
I pointed out to Individual "A" that this had not been done. After 3-4 weeks Husky started using CO2 gas strictly as the procedure calls for.
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I Individual "I" I the Aluminum-Bronze MIC spot weld process had not I was aware that I felt that these q' qualifications been qualified as to process or welders.
necessary, as the process is similar to resistance welding in were not that it is semi-automatic. The welding parameters are set, and the welder only airos the welding gun.
j-I have read this voluntary statement, consisting of two (2) pages, 5
- t.,
It is a true representation.
and made corrections where necessary.
Witness:
3,e# c r_ vesten o/?R/79 Signed Individual "1" 9/28/78 Harvey M. Wescott 9/28/75 Date Exhibit IV l
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Report No.
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Bert S ecimens Mamf= rms-e+ to P
Tensile Testing of ( 7)
Sheet Mwest-Dr:rwing-N o.
. $ '.,147 b_ / [
(6/,C Nominal Gage Section:
C.u V (7.5c
/( 2.#'O M. 'T,
Temperature:
Strain Rate through 0,2% Yield:
O,003 in. /in. / min.
OO[
in. / min.
Head Rate thence to Failure:
.02%
O ccp U. T 5.
Y po,,J-Elong.
h MRAI Spec.
(ksi)
(ks)
(ksi)
(%)
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No.
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'3f f2 c D Page Laboratory Technician of
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Text:
Individual "D"*
2-10-76 Low tensile Zimmer i
strinEers mixed in stores and l
now being used I
for straights' Individual "A"
Returned with verbal reply to " forget it" I
f 2-10-76.
Exhibit VI I
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Sep,. aber 20, 1978 Esky manufactures Cable Trays teNEv.A Standards as per a catalog as a l
4 cowrcial item. It also manufactures modifications of Standa.rd items nnd specials to a cuetomers' specifications.
t Ziners were. special in 4 important ways as follove.:
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- 1. They rcquired special vrap around splice plates with different belt l
holes to strengthen tnt joints vnere *2 trays come together.
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- 2. Tney specified side rail material to have a minin tensile structs of 35,000 poands.
~
- 3. Welding was to be Mig Welded in accordance with AST: Section 9 and te be performed by certified weldert.
- 4. All pertinent records relative to Quality are to be retained on long term retention basis.
In respect to the velding this mee.nt that the velde were to have a qutlity level equal to that required for beilers and presstre 7ess us. Tnese were te be top quslity velds with goed fusien, structurally sound and with mininrr y
p, of defects. There vere to be velded by qualified velders certified as such is i
.thru testing as called cut in Section 9 er ASME.
Leky velders are ceipeter.t to preduce co.nereie.1 type velds for an ordinary comercial predaet where de ects and lack of fusien is acceptable. This is c
the type of veld done dail) on our cenercial verk. We have Incentive Standard:
en this verk and ou veldors er.rn frei 160 to 200% day in and day out. This de the type velding described in Mr. Ind. "J"s report.
Testing of our walkrs established their incompetence te preduce quality velds at pressure vessel standards. m sky worked with the veldere until they made one goed piece which ve21d pass a bend test. The velder is t' hen certified and then goes rignt back te productien tr.aking comercial Lype veids fer Incentive which is tne only t,qe veld ever meda. O.2tside of taking this ens tant piece they have no production experience in this type veld. hsed on their difficulty in passing the test they need considerably acre training, fol3oced with ac' uni production experience. befere they can be ecipetent te produce a high quality type of weld.
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'valitj veloing would greatly increase the manufacturing cost, partienlarly if we changed all velding to become quality type. A second alternative weald be to produce quality velds when required on nuclear work and coaercial gaality on,all other verk. Esky's decision vis to certify the veldors but produce enly the normal ce n ercial type velds en n11 verk. Vt.veuld tell peeple ve veld to Section 9 of ASME vith certified veldors. This has never chcnged.
We have never made any effort to produce pressure vessel quality velds.
Exhibit VII Page 1 of 2 SEP 251978
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Tnie was done en the Zimmer job and was incorporated into the Quality CentrsI Hanual that Hasky Welding is in confern.ance with ASMS section 9 and tne veld:
are made by certified velders. This is misleading in that people think thst they vill get quality velds. Inctead everybedy gets oe.tnercial quality velds made by a volder who once made cr;c quality veld piece. On this basis Hacky has secured additional naclear work.
The top Fanagers of Hasky are en a benue setup. Anything that adde cost subtracts frei profit which in turn redaces their bonus. To produce nuality would be very expensive and veuld reduce their bonus. It is entirely possible the decision not to produce the specified quality velds vae bseed entirely en the cost required to de ee. The reason given to me ar,d my people was, "that it is completely unnecessary.
Individual "A"
Se pt embe r 22, 1976
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Page 2 of 2 J
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UNITE D sT ATE S -
g NUCL E AR REGULATORY COMMISSION
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' Docket No. 50-358 m
.n-Cincinnat:L Gas and Electric.
Company-ATTN:
Mr. Earl A. Borgmann L
.Vice. President Engineering Services -
and Electric Production 139 East 4th-Street
' OH 45201 Cincinnati, l
Gentlemen:
1 Tids lefsis 'to ths inspection conducted by Mr.1. T. Yin of this effice on Nevember'16-17, 1978, of activities at the' j.,
.Wm..H. Zimmer Power Station authorized by NRC Construction Permit.50. CPPR-66 and to the discussion of -our. findings with
'Mr. B. K. Culver and others of your staff at the conclusion l
of the inspection. This also refers to the investigation and 1
inspection conducted by Mr. 1. T. Yin on' November 21,'1978..at Sargent and 1. undy Engineers office in Chicago, relative'to the document control provisions for pipe stress reports.
The'en' closed copy of our inspection report identifies' areas
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exandned during the inspection.
Within these areas,,the inspection consisted of a selective examination of procedures and representative records,, observations, and interviews with personnel, j
During'this inspection, certain of your activities appeared to be in nonecmp} dance with NRC requirements, as described in the enclosed Appendix A.
.This notice is'sent to you pursuant to the provisions of l
.Section 2.201 of the NRC's " Rules of Practice," Part 2, Title l
7 10 Code of Federal Regulations.
Section 2.201 requires you to' submit to this office within thirty days of your receipt of'this notice a written statement or explanation in reply, including for each item of noncompliance: (1) corrective action taken and the results achieved;.(2) corrective' action
.to..be taken to avoid further noncompliance; and (3) the date when full compliance vill be achieved.
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2-MAN O 3 i:...
=p Cincinnati Gas and.
1 Llectric Company
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.In accordance with Section 2.790 of the NRC's Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this-letter, the enclosures, and your response to this latter will be placed in the NRC's Public Document Room, except as follows. If the enclosures contaf n information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this letter, to withhold such information from public disclosure. The application must include a full. statement of the reasons for which'the inforv.ation is' con-sidered proprietary, and should be prepared.so that proprietary information identified in the application is contained in an enclosure to the application.
We vill gladly discuss any questions you have concerning this j
inspection.
Sincerely, I
R. F. Beishman, Chief Reactor Construction and j.
Engineering Support Branch I
Enclosures:
1.
Appendix A, Notice of Violation 2.
IE Inspartion Report 1;o. FJ-355/ 76-27 l
cc w/encIs:
Mr. J. R. Schott, Plant l
Superintendent Central Files 9 pre hetinn Unit NRC 20 PDR Local PDR 1: SIC TIC ii. Young Park, Power Siting
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Appendix A NOTICE OF VI01.ATION
- Docket No.'50-358 Cincinnati Gas'and-Electric Company Based on' the results of an NRC inspection conducted on November 16-17, and.21, 1978,'it appears that certain of your activities were not con-ducted in full compliance with NRC requirements as noted below.
The item is an infraction.
10 CFR 50, Appendix B,' Criterion Vill requires, in part, that. measures
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shall'he established for identification and control of materials, parts and components. _-These measures shall assure,that identification of-the item is maintained by heat number, part number, serial number, or other appropriate means, either on the item or on records traceable to the item, as required throughout fabrication, erection, installation, and use of the item. Paragraph 17.1.8.2 of the FSAR crates, " Essential materials, parts, and components... bear identification as to heat number,'part number,... and complete traceability exists between
- the iten and quality control records."
Contrary to the above, among the six hangers and restrafnts observed and the records reviewed by the inspector, two rigid supports velded to ' essential piping did not have heat numbers for material and weld filler metal nor did they have velders' identifications.
One other rigid seismic restraint having the_ similar noncompliance was iden-tified recently by the KE1 QC inspector.
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U.S. NUCLEAR REGULATORY COMMISSION j
OFFICE OF INSPECTION AND ENFOPCLMEST
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REGION 111
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R'eport No. 50-358/78-27
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Docket Ne. 50-356 License No. CPPR-ES Licensee:
Cincinnati Gas and Electric Company 139 East 4th Street Cincinnati, OH 45201 Facility Kate:
Un. 11. Zimmer Power Station, Unit 1 Inspection At:
Un. H. Zinmer 1 Site, Moscow, Ohio; and Sargent and Lundy Office, Chicago Inspectien Conducted: November 16-17 and 21, 1978 sh h 2 [ @,..
Inspector ' 'I. T. Yin
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Eeviewed By:[ vD. A D nfe(ls Chief
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Engineering Support Section 2 Inspcetien Sur.rary Inspection on November 16-17 and 21, 1978 (Report No. 50-355/75-27)
Areas Inspected:
Inspection of safety-related hcngers and restraints a'nd decurent control provision for pipe stress calculattens and reperts
. including:
(1) Review of welding and NDE procedures, (2) Obnivatien ei veld contrel and performance, (3) Review of welding.and raterial records, (4) Observation of hanger component outdoor sterage, and (5)
Review cf decurent centrol measures for pipe stress analyses.
Ine inspection involved a total of 13 inspector-hours onsite, and 5 inspec-tor-hours at the Sargent and Lundy offices by one NRC inspector.
Fesults: Of the five areas inspected, no apparent iters of nonce pliance were identified in four areas; one item of noncompliance was ider..ified
- in one area (Inf raction - rigid supports velded to essential piping were without r.aterial and welder's identification - Paragraph 3.d).
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0 DETAILS l
t Persons Contacted Inspection on Site During November 16-17, 1978 2
Principal' Licensee Employees (CG6E)
- B.
K. Culver, Project Manager K. W. Schwiers, Principal QA and Standards Engineer
- J. T. Keissenberg, QA and Standards Engineer
- R. 1. Wood, QA and Standards Engineer
- J. B. Vorderbrueggen, Ranger Engineer Kaiser Engineer, Inc. (KEI)
- R.
Marshall, Project Fbnager R.
E, Turner. QA Manager
- M. G. Tranchuk, Mechanical QA Engineer K. T. Shinkle, Hanger and Mechanical Inspector t
In.estigation and Inspection at Sargent and Lundy Office, Chicego on November 21, 1978 Licensee Representative (CG6E)
- U. W. 'Schwiers, Principal QA and Standards Engineer Sargent and Lundy Engineers (56L)
- E. B. Branch, Head, Engineering Mechanics Division (EMDi
- J.
B.'Adee, Jr., QA Coordinator S. Kurka, Senior Structural Project Engineer J. M. McLaughlin, Assistant Manager, Structural Department
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- o!. I. Kitz, Section Superviosr, EMD
- E.
J. Pruski, Project Manager
- T,.
T. Scheibel, Proj ect Director S. C. Carlsen, Mechanical Project Enginter R. P. Pauliukonis, Administrator. EMD A. P. Gillis,. Senior QA Coordinator
- H. 51 Taylor, Assictant Head, QA Division
- W. G. Hegener, Manager, Mechanical Department l'SSRC Region I
~A.
S. Pasano, Reactor Inspector
- denotes those present at site Exit Interview on November 17, 1976.
- denotes those present at site Exit Interview on November 21, 1976.
4
,4 Licensee Action on Previously Identified Items (open) Noncompliance It em (358/78-16-01): Inadequate hanger, snubber, and restraint inspection program.
The details of the problem areas observed are recorded in RIII Report No. 78-18,Section II, Paragraph I.
puring this inspection samples of the KE1 " construction Inspection Plan Daily Vork Sheet, Inprocess Inspection", and the CG&E " Mechanical Construction Test Procedure" MC-5 entitled " Pipe Support Final Inspec-tion," Revision 0, dated September 5, 1978, were reviewed by the inspector and are considered unacceptable based on the following findings:
1.
The inprocess inspection checklist relative to the specific' inspection areas was not prepared and approved by supervision or engineering.
2.
No requirements for documenting deviations if they are not within specific acceptance tolerance.
3.
Inspections that should be carried out during inprocess instpl-lations to. ensure timely corrections and prevent recurrence vere placed in final inspection period when adjustment of i
components are required prior to testing and operations.
Functional or Program Areas Inspected 1.
Review of Meldinc and KDE Procedures for Hangers and Restraints The f ellowing procedures f rom the Kaiser Engineers, Inc. (KEI)
Special Process Procedure Manual (SPPM) were reviewed by the ins}ecter relative to the velding and NDE verk for hangers and restraints.
a.
SPPM No. 3.1.51, " Shielded Metal Arc, AWS Carbon Steel to Carbon Steel Structural Shapes Charpy Tested A-5SE Gr. B (As rolled)", dated February 17, 1975.. This procedure was qualified on January 24, 1975.
o.
SPPM So. 4.6, R.3," Visual Examination", dated May 23, 1975.
c.
SPPM Ko. 3.3, R.4, " Welding Piller Materials Control Procedure", dated April 9, 1975.
No items of noncompliance or deviations were identified.
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2.
Observation of Weld Controls and Performance The inspector observed the veld filler metal issuancs a.
station east of the reactor building.
Items reviewe'd l
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in'cluded calibration of electrode holding oven, control of portable heated containers, segregation of electrodes by type and size, and certifications of electrodes.
f b.
The inspector observed the finished shop and field welds ic T-on hangers and snubbers number 1WSO445R, 1WR091SR, c
~T1WR214HR, IWR200HR, and IWS311HA.
No rejectable veld surface conditions had been identified.
No items of noncomp2 dance or deviations were identified.
3.
Review of Welding and Material Records Selective areas of weld filler metel and attachment hanger materials for the following items were reviewed by the inspector for certification of compliance.
a.
Snubber IV504 SE:
The heat number on the pipe attachment, a section of S"'
sch. 40 pipe, is 31565.
It was shop welded to line IWS15AIS.
b.
Rigid Restraint 1WR091SR:
The heat number on the pipe attachment is 252661, shop welded to line 1WR03A14 c.
An:hcr IWS311EA:
The heat numbers on the shear lugs are 69D782 and 71A0SS.
The material certification, including tensile testing and chemical analysis for Heat No. 69D752, was reviewed by the inspector.
d.
Rigid Supports 1WR200HR, and 1WR214ER:
The heat numbers for the rigid support pipe members welded to the Closed Cooling System lines 1RR06A14
'and IWR07A14 designated as pipe class "C" and seismic class "B" essential components were not available.
Turther, the heat numbers for the veld filler metal and welders' identification were not marked on the supports or recorded in the installation documents.
Rigid Seismic Restraints 1FC0375R:
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c.
There were no heat numbers on t'he eight shear lugs.
Noncor.pliance Report No. E 1445, dated November 8, 1976, was written to document this.
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-The lack of centrol and identification of safety related materials as described in item d above is an apparent item of noncompliance identified in Appendix A.
(358/78-27-01).
Except as noted, no items of noncompliance or deviations were 3
identified.
F F-4.
Observation of Hanger Component Outdoor Storage The condition of components for hangers and restraints stored outdoors at the laydown area, east of the reactor buildings, j
was considered questionabic.
Rust was observed at the ball.
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bushing coated structural members.
Components were observed j
off the dunnage on the sandy soil.
A Sonconformance Report,
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No. E-851 identified piping storage problems at the same area on October 10, 1977.
This report was still open.
The inspector i
stated that he had concerns relative to:
(1) the acceptability
)
of the rusty and frozen bushings which may require close gap clearance, and (2) the timely resolution of noncomformances.
This is an unresolved item pending more in-depth inspection durine a future visit.
(358/78-27-02) j I
1 No items of noncompliance or deviations were identified.
J 5.
SL1. Pipe Stress Report Document Control The inspecter r'eceived a telephene call on October 17, 1978, frem an individual who alleged that the control for documentation of the stress reports was not adequate.
The inspector performed investigations relative to the subject matter on November 21, 1976, at the ESL office, Chicago. With the exception'of.one specific probler relative to the engineer not keeping an up-to-date proce-dure, no apparent problems were identified during the investigation and inspection.
Arees Inspected:
a.
Procedures Review The following manual procedures were reviewed by the inspector:
(1)
S&L Organization Manual - Section 2H, dated October 15; 1978,'a description of functional authirit,ies and reporting responsibilities.
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(2) S6L Organization Position Description Manual
.Section 2H, dated October 15, 1976.
This se.ction included l
responsibilities of Mechanical Department, Engineering Mechanics Division (EMD), the division that is respon-sible for piping analysis and issuance of stress reports.
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Specific job descriptions within EMD reviewed included lb l
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@p System Analysis Supervisor, Project Engineer, Piping Engineer, and Engineering Analyst.
(3)
EMD Technical Procedure No. 11, " Standard EMD Checklist for Piping System Stress Report",
Revision 3, dated July 3, 1976.
This procedure included Group QA procedure GQ - 3.05, Design Calculation Requirements.
(4)
EMD Administrative Procedure No. 5, " procedure f or Filing Reports, Memoranda, and Analyses",
Revision 2, dated December 7, 1976.
(5)
EMD Administrative Procedure No. 6, "EMD Report Number Assignment", Revisien 1, approved on Decerbe r IS,197 6.
b.
Review of S6L Audits The following 56E internal audit reports, including ccrrective actions, were reviewed by the inspector:
(31 Repert en Internal Audit 50. 23 perforced on April 1, 2, and 5, 1976, relative to personn.el Corpliance Vith procedures for defist. CaICulatiCn, system and structure design review, and,QA docunen-tatien.
(2) Repcrt on Internal Audit ';r. G-17 perforced on j
September 30, 1976, relative to persennel compliance with QA decurentatien requirements.
(3)
Report on Internal Audit No. G-39 perforced on j
~ October 24, 1977, relative to personnel cocpliance with QA procedures and department standards.
(4)
Report on Internal Audit 50. 31 perforced on April 14, 14, 18 and 19, 1977, relative to persennel compliance with procedures for design calculations, E
and system design reviews.
(5) Report on Internal Audit No. G-59 performed on,
June 2E-30, 1976, relative to personnel compliance with various department standards..
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1 (6) Report on International Audit No. 41 performed after problems' identified at the site in August, 1978, relative to the adequecies of hanger component design.
Areas audited included work implementation of the following QA procedures:
3 7
x jg' GQ - 3,04 Design Criteria GQ - 3.07 56L Drawings GQ - 3.08 Design Calculation l
GQ
-4.01 Procurement Specification (7) QA Division Corrective Action Reports (CAR)
CAR 66, dated June 10, 1977 CAR 67, dated June 10, 1977 CAR 93, dated October 22, 1976 (6)
Reports on Internal Resudits
. No. 31.1, dated July 15 and 21, 1977 for CAR No.
66, 67, 65 and 69.
No. 17.1, dated November 26, 1976 for CAR No. 93.
c.
Review of Stress Reports The status of stress reports is controlled by card index files with computer printout updates as verk tool and reference.
Three approved stress reports selected at random were reviewed by the inspector in the area.of docu-ment control.
(1)
EM?-4130-WR-09, "Reac tor building Closed' Cooling Wat er",
dated November 22, 1977.
(2)
EMD-4130-HD-6, "Fror Second Stage RETR Drain Tank te Condensor HD-6", Revision 1, dated June 12, 1978.
The above two reports were signed off by the qualified preparer and reviewer and approved by the supervisor.
QA calculation checklist was included and signed-off.
Computer printout configuration, code commitments, and ref erence drawing number were included in the report.
The computer program used is PIPSYS 09.5.065-3.4, dated September 8, 1977.
The load combination data appeared
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to be complete.
(3) Report on "10-inch Containment Spray Header (Upfer),
Run 5"..
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RH-05-TH-3,-Revision 2,' dated: September 27, 1973.
' RH-05-SE-2, ' dated September - 27, 1973.
Rh-05-WT-2,' dated March 30, 1973.
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Although no calculation' checklist was. included in the.
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ble because'_,.
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=above reports,- it was considered acceptathe calculations were p
'lishment of such'a requirement.
The reports includeL system, configuration.
The load combination for primary:
and secondary stresses appeared to be in order; The
-l code requirements were stated in the reports, y
d, Staff Interview The inspector interviewed the Engineering Analyst (EA) who reviewed the reports EMD-4130-WR-09, and EMD-4130-ED-6.
The latest revision of the procedure for; reviewing stress inTprocession of the EA, even though
-calculations-was not the Interoffice Memorandum of July. 24, 1978,-from the Head, to EMD to the staff specifically stated that EMD JTechnical prncedure No. 11, Revision 3, approved on-July 3, The 1978, should be maintained and used by~the Staff.
inspectors,cancern included: _ -(1) the outdated EMD Procedure No.:ll, date5 September 6, 1977, was'not removed from the EA's locatir n, (2)_the EA's' apparent unawareness of the procedure spdating, and (3) the EA's difficulty.in retrieving, the. required procedures.
This is an unresolved item.
(35S/78-27-03)~
So= items of. noncompliance or deviations'were identifiede Unreselved Iters-Unresolved items are matters about which more information is requirsd in l
order to ascertain whether they are acceptable items, items of nonco -
Two unresolved items disclosed during the.inspec-pliance or deviations.
tion are discussed in Paragraph 4'and 5.d.
Exit Interview
' The inspector met with licensee representatives (denoted in the Persons Contacted parag'raph) at the conclusion of the inspection on November 17 The' inspector' sum =arized the purpose and findings of the and 21,.1978. The licensee acknowledged the' findings reported herein.
- in spe c tion.
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