ML20128P089

Rept of Investigation Carried Out by Ropes & Gray of Apparent False Documentation of Results of Receipt Insps at Vermont Yankee Nuclear Power Station

ML20128P089
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Issue date:	05/21/1985
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3 REPORT OF INVESTIGATION CARRIED OUT BY ROPES & GRAY OF APPARENT FALSE DOCUMENTATION OF RESULTS OF RECEIPT INSPECTIONS AT VERMONT YANKEE NUCLEAR POWER STATION l

l l l ROPES & GRAY 225 Franklin Street Boston, MA 02110 May 21, 1985 8506030457 850523 PDR ADOCK 05000271 G PDR

TABLE OF CONTENTS BACKGROUND .............................................. 1 THE METHOD OF INVESTIGATION ............................. 4 CONCLUSIONS ............................................. 6 DISCUSSION .............................................. 7 A. The Relevant Regulations, Guides, Standards, Procedures or Forms ................. 7 B. General Problems Revealed From the Investigation .............................. 13 C. Analysis of Individual RICs .................... 16

1. RICs As to Which Apparent Falsification Was Changed by NRC .......... 16 l

P.O. 14409; RIC 5/30/81 .............. 16 P.O. 16480; RIC 8/31/81 .............. 17 P.O. 18047; RIC 7/16/82 .............. 17 P.O. 22041; RIC 7/24/84 .............. 19 P.O. 22396; RIC 4/5/84 ............... 20 P.O. 22711 RIC 6/7/84 ................ 20 P.O. 22554; RIC 4/20/84 .............. 20 P.O. 22706; RIC 6/12/84 .............. 20

2. Other RICs Reviewed ....................... 21 P.O. 9706; RIC 7/15/78 ............... 21 P.O. 10269; RIC 6/20/78 .............. 21 P.O. 12259; RIC 12/13/79 ............. 22 D. Overall Analysis as to Cause of Problems .............................. 22 l REPORT OF INVESTIGATION CARRIED OUT BY ROPES & GRAY OF APPARENT FALSE DOCUMENTATION OF RESULTS OF RECEIPT INSPECTIONS AT VERMONT YANKEE NUCLEAR POWER STATION BACKGROUND During the period March 11-15, 1985, personnel from Region 1 of the United States Nuclear Regulatory Commission (NRC) conducted an unannounced safety inspection at Vermont Yankee Nuclear Power Station (VYNPS), owned and operated by Vermont Yankee Nuclear Power Corporation (Vermont Yankee).

The inspection involved three areas: (1) Receipt, Storage and Handling; (2) Procurement Program; and (3) Records Program. No violations were identified with respect to the 1

latter two areas. However, with respect to the area of I Receipt, Storage and Handling, Vermont Yankee was cited for alleged violations of NRC requirements and, in particular, for " potential falsification of receipt inspection reports".

The inspection report involved (No. 50-271/85-11) and the covering letter of transmittal (hereafter referred to and cited as "IR") are attached hereto as Attachment 1. The basis for the suggestion of potential falsification is memorialized in S 2.5 of the IR.

A review of the IR reveals the basic NRC position to have been as follows: When any items requiring quality assurance are received at VYNPS a Receipt Inspection Checklist (RIC) is filled out with respect to those items.

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,. . . . . ~ - -~

The purpose of the RIC is to document the receipt inspection done of the item. During the inspection the NRC found a number of situations where the RIC involved indicated to the NRC inspector that certain items which were subjects of the RIC had been inspected for certain attributes which could only be observed by opening the packaging in which the items of interest had arrived. A check of these items on the shelf revealed that all, or all but a few,.were still sealed in original packaging. As stated in the IR, it was the view of the NRC inspectors that:

"The inspection records indicated that without exception all received items were inspected'. In Sections III and IV of the Receipt Inspection Checklist, the receipt inspectors recorded that the attributes such as, physical damage, dimensions, workmanship and electrical insulation were inspected. As described

[ earlier in the IR], a majority of these items remaining on the shelf were in sealed packages. Inspection for such attributes through the sealed packages is impossible." IR at 7.

In particular the RICs with respect to eight particular purchase orders (POs) were listed as containing false information: Nos. 14409, 16480, 18047, 22041, 22396, 22554, 22706, 22711. -

As anticipated in the IR Covering Letter, on April 25, 1985, NRC issued a Notice of Violation and Enforcement Conference Report (hereafter referred to and cited "N/V")

which is attached hereto as Attachment 2. After discussing l

i.

the enforcement conferences and notice of violation, NRC went on to state:

"In addition, to enable NRC to determine what action, if any, should be taken with reapect to your license, you are required to submit under the provisions of 10 CFR 50.54(f), a report of your investigation into apparent false documentation concerning the results of receipt inspections; an explanation of how these incidents occurred and with whose knowledge; a determination of the cause of the falsification, including the responsible individuals; and a description of the action taken as planned to prevent recurrence of similiar incidents." N/V at 2.

Issuance of the two above-described documents received the immediate and undivided attention of the top management of Vermont Yankee. In light of the seriousness of the charges articulated and their implications,1 it was decided 1

The Atomic Energy Act $ 186, 42 U.S.C. 5 2236 utilizes the terminology " material false statement" in describing one of the grounds for which a nuclear power plant's operating license may be revoked. In 1976 the Commission held that a statement may be false under 5 286 even if it is made without knowledge of its falsity. Virginia Electric and Power Co. (North Anna Power Station, Units 1 and 2), CLI-76-22, 4 NRC 480, 486-87 (1976), affirmed sub nom. Virginia Electric and Power Co. v. NRC, 571 F.2d 1289 (4th Cir. 1978). This legal rule and distinction is not generally understood by those not familiar with NRC practice and the words

" material false statement" appearing in the press are usually surmised by the public to connote a deliberate attempt to lie. Given the careful wording of the IR

(" potential falsification", cover letter 3; " potential falsification" IR at 1, 9; " records appear to be false" IR at 8) and the N/V (" apparent false documentation",

N/V at 2) it may be that NRC is not suggesting the possibility that any erroneous statements in the RIC r 1 4

that Ropes & Gray, Vermont Yankee's outside counsel responsible for advising the company with respect to NRC matters, should be retained to conduct a thorough investigation to determine, among other things, whether any cmployee or agent of Vermont Yankee had knowingly put false information in.any receipt inspection records with an intent to deceive or in any way countenanced such activity. Ropes

& Gray was promised, and received, the complete cooperation l

of management and the employees of Vermont Yankee in this l

investigation; no request for records, information or interviews was refused or even objected to.

THE METHOD OF INVESTIGATION Upon receiving the request from Vermont Yankee to conduct the investigation, Ropes & Gray assembled a team of three lawyers from its Trial Group to conduct the investigation. The team requested and reviewed the

-fo'llowing records:

NRC Inspection Report No. 50-271/85-11 (IR),

NRC Notice of Violation and Enforcement Conference Report (N/V)

All RICs questioned by NRC in the IR All PO's giving rise to the RICs, questioned The entire PO file for these PO's, The original Vermont Yankee Administrative Procedure for Receipt Inspections and all 12 revisions thereof, Reg. Guide 1.38, Rev. 2, were deliberately made. Unfortunately, if that be the case, it is not clear and certainly the press and state officials have indicated their understanding that deliberate falsehood is what NRC is charging.

ANSI Standard N452.2-1972, Organization Charts, Vermont Yankee's Quality Assurance Manual YOQAF-1.A Previous NRC Inspection Reports Job Description of the Quality Assurance Technician Memorandum of Management Interviews of authors of questioned RICs The. Receipt Inspection Task Force Report On May 9, 1985, the Ropes & Gray team went to VYNPS.

, The team went to the area of the plant where matorisis are t

i rcceived. A briefing was given on how receipt inspections were conducted. This briefing revealed the following: All mnterials arriving at VYNPS arrive at a central location L

where Stores Department personnel first divide them into two l

cntegories (1) items requiring quality assurance, and (2) i items not requiring quality assurance. Those requiring quality assurance are held for receipt inspection as required by Administrative Procedure 08'01.

The Ropes & Gray team witnessed an actual receipt

-inspection conducted by the Quality Assurance Technician (QAT). The team then toured the warehouse and was shown

.- camples of those items that were the subject of the questioned RICs. Next, seven of the eight receipt l inspectors who had filled out questioned RICs were interviewed.2 Each interview was conducted by a single m;mber of the Ropes & Gray team one-on-one with the receipt inspector. In each case a written set of questions was

' 2 The remaining receipt inspector was interviewed by telephone on May 15, 1985.

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utilized by the interviewer. A copy of the form of questions is attached hereto as Attachment 3. The questioning in each case included additional follow up and cross-examination beyond the questions-in the form.

Thereafter, interviews were conducted of three management cmployees who were superiors of the receipt inspectors.

These latter interviews were held to ascertain whether, and to what extent, perceived deficiencies in.the receipt inspection program had been brought to the attention of cupervisory personnel.

CONCLUSIONS l'

As a result of the record review and interviews i

dascribed above and for the reasons set forth in detail in l

I the discussion below, the Ropes & Gray team reached the l'

following conclusions in this matter:

f

! 1. There is no evidence of any kind that any receipt inspector or other Vermont Yankee personnel engaged in knowingly placing false information in records or attenpted in any way to mislead any reader of RICs.

2. The various RIC forms in use throughout the relevant time frame were inadequate in many respects and contributed significantly to the difficulties cited in the IR.

3. The inadequacies of the forms were compounded by an clmost total lack of instruction to inspectors as to the mathodology to be used in filling out the form which led to l l

inconsistent treatment of the various categories listed on the form.

4. Both the RIC forms and the revisions of the Administrative Procedure of which they were part left too much room for interpretation by the individual inspector.

5. The various revisions of the Administrative Procedure applicable during the relevant time frame failed to make clear that certain inspection techniques approved by the Nuclear Regulatory Commission were permissible. As a rasult, techniques which satisfied NRC requirements were insufficient to satisfy the Administrative Procedure.

6. Management gave insufficient attention to changes baing made in the language of the RIC Form and Administrative Procedure and thus, failed to remedy the inadequacies of these documents which are the root cause of the inadequacies found in the IR.

I DISCUSSION A. The Relevant Regulations, Guides, Standards, Procedures and Forms Indispensable to understanding the problem under investigation is some knowledge of the relevant regulations, guides, standards, procedures and forms. The regulations of I

the Nuclear Regulatory Commission with respect to quality assurance are set out as a series of criteria in 10 CFR 50

App. B. Criterion VII of this regulation provides, in mnterial part, as follows: .

" Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents.

These measures shall include provisions as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of products upon delivery" (emphases added).

A Regulatory Guide issued by the USNRC Office of Standards Davelopment (Reg. Guide 1.38 - Rev. 2) " describes a method receptable to the NRC staff of complying with the Commission's regulations with regard to the quality f ensurance requirements for the packaging, shipping, l

l rsceiving, storage and handling of items for water-cooled l

nuclear power plants" Reg. Guide 1.38 at 1 (emphasis added).

The Reg. Guide further provides in material part:

"The requirements for the packaging, shipping, receiving, storage, and handling of items for water-cooled nuclear power plants that are included i in ANSI N45.2.2.-1972 . . . are acceptable to the NRC staff and [with certain supplements not here relevant]

provide an adequate basis for complying with the pertinent quality assurance requirements of Appendix B to 10 CFR Part 50 . . . ."

The reference to ANSI N45.2.2-1972 is a reference to the American National Standard Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants

-(during the Construction Phase)a ANSI N45.2.2-1972, published by The American Society of Mechanical Engineers, the relevant portion of-which is attached heret.o as Attachment 4. .

! 'The Vermont Yankee Quality Assurance Manual which is the 1Ycnkee Operational-Quality Assurance Manual, YOQAP-1.A

specifically lists as one the regulatory positions which is to be utilized and adhered to is that set forth in ANSI N45.2.2-1972 as endorsed by. Reg. Guide 1.38, Rev. 2.

~ YOQAP-1-A 5 II, Rev. 15, p. 2 (Feb. 15, 1984).

Material to this investigation are the'following provisions of ANSI N45.2.2-1972:

"5.2.2. Item Inspection. Unless the package marking prohibits unpacking,- the content of all shipments shall be visually inspected'to verify'that the specified packaging and shipping requirements have been maintained. When items are contained in~ transparent.

separate moisture-proof bags or envelopes, visual inspection'without-unpacking the contents is acceptable.

Statisical sampling methods may be used for groups of similar items ."

(Emphases added.)

a "Although ANSI N45.2.2-1972 is entitled ' Packaging,

. Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants During the Construction Phase', the requirements included in the standard are considered to be applicable during the: operation phase and should be used, when applicabic, consistent with the recommenda-tions,of this regulatory guide." Reg. Guide 1.38,

'1 C.1.d. (emphasis added).

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"Unless the completed item was inspected or examined at the source, it shall be inspected or examined at the point of receiving to verify that the following characteristics conform to the specified requirements. These inspections or examinations shall include such items as:

"(2)- Dimensions - Random visual inspection to assure that important

! dimensions conform with drawings and specifications. Examples are:

base plate mounting holes, overall external size, configuration and orientation of parts.

"(6) Electrical Insulation -

Performance of insulation -

resistance tests for motors, generators, control and power cable, to ensure conformance with specifications" (emphases added).

The relevant Administrative Procedure in this matter is Vermont Yankee's Administrative Procedure 0801 entitled

" Receipt, Inspection and Shipment of Material and Equipment", Revisions 7-11. As will be seen, one major difficulty is that the Administrative Procedure did not take cdvantage of many of the features available under ANSI

'N45.2.2-1972. Of importance to this investigation are the

-following aspects of the Administrative Procedure: None of the relevant revisions of the Administrative Procedure offirmatively allowed for the use of sampling techniques as is permitted by ANSI N45.2.2.-1972. The original Vermont-Ycnkee Administrative Procedure for Receipt and Storage of Material and Equipment issued March 10, 1972, and numbered l

2174 stated-in a note, in the words of ANSI N45.2.2.-1972:

"ctatistical sampling methods may be used for groups of ,

cimilar items." In the third revision of the procedure (AP 0801, Rev. 3) iseued October 17, 1975, this language was

. removed and it had never been reinstated.

In the original procedure issued March 10, 1972, there

-was reference to not opening packages which had markings prohibiting unpacking. This language was removed in Rsvision 5 issued August 3, 1977 (AP 0801 Rev. 5), when there was a wholesale overhaul of the form. There remained

.no reference to this concept until issuance of Revision 9 on April 13, 1981, when a note was inserted stating:

"Certain items, such as fuel channels, which are specially packaged for maximum protection during shipping and storage, and which require a thorough physical inspection prior to installation, will not be removed from their containers at receipt inspection. The appropriate sections of the Receiving Inspection Checklist will be noted " Inspection Deferred" and subsequent inspection of

" deferred" characteristics will be documented on the applicable departmental inspection form."

This note remained in the subsequent revisions.

• We were advised that the AP was originally numbered 217 and there then were issued Revisions 1 and 2 of AP 217 on September 15, 1972, and February 15, 1973, respectively. The third revision of the procedure was issued on October 17, 1975, at which time the number was changed to 0801 and it was entitled "AP 0801 Rev. 3."

Revisions 4-12 have retained the 0801 designation.

The RIC form itself has always been part of the procedure. When the procedure was originally issued in 1972 so AP 217, the RIC form was much different then it is today.

Thore were, until the major revision in 1977 (Rev. 5 AP

. 0801), a much lesser number of items to be checked and the checkoff was in boxes labeled " Accept" or " Reject".

Subsequent revisions prior to Revision 5 added a few Edditional items and split the inspection into two parts to ba.done by " Stores" and " Department Head", but retained the

" Accept" or " Reject" nomenclature.

In Revision 5 the number of items to be specifically checked was raised from 12 to 19 (some being multiple

.ccpects of what was previously one concept), the 19 items ware set out in four sections each denoted with a Roman numeral and the nomenclature " Accept" or " Reject" was changed to "Yes" or "No". This Yes-No nomenclature has been rotained to this day and is a major cause of problems. The n;w format of Revision 5 placed in Section IV the following cix aspects of the inspection: Physical properties, Dimensions, Weld Prep., Workmanship, Lubricants / Oils, and Electrical Installations. The text of the procedure provided:

"If the items have not been source inspected and accepted,Section IV of the Receiving (sic) Inspection Checklist shall be completed by the appropriate Department Head or his designee."

(Emphasis in original.)

u .. .

.. 1 . . <. .

In Revision 11 of AP 0801 issued June 17, 1982, the Ssction IV items listed above were inserted as Items 10-15 in Section III;Section IV was deleted and the above-quoted lcnguage was deleted.

To summarize then with respect to the Administrative Procedure 1and the RIC form:

1. During the entire relevant period the language of the procedure did not address the validity of ,

-utilizing sampling techniques although it had prior to October 17, 1975.

2. During the relevant period until April 13, 1981, the Procedure did not address the concept of special packaging which should not be opened; thereafter, the Procedure did cover that concept.

3. During the relevant period until June 17, 1982, the items: Physical Properties, Dimensions, Weld Prep., Workmanship, Lubricants / Oils, and Electrical Installation did not have to be checked if there had been a source inspection and acceptance.

4. During the entire period the "Yes-No" format was in effect.

B. General Problems Revealed From the Investigation The interviews of those who had filled out RICs revealed that there was no clear and consistent interpretation of what various items on the form meant. The RICs reviewed 13 -

rcveal cases where the inspector thought that "Yes" meant ccceptable with respect to one item; and "No" meant ccceptable with respect to another. See, e.g. RICs for P.O.

Nos. 9706, 16480. Also some inspectors made use of the

-comment column extensively, others did not. While most forms indicate that inspectors understood and thought that the designation "not applicable" (N/A) was an appropriate one; one inspector told the interviewer that it was his understanding "Yes" or "No" had to be checked in each-case.

The forms did not evidence any consistency as to when S:ction IV was used or not used. In some cases a cartificate of compliance was found in the P.O. Jacket and Ssetion IV was filled in; in other similar situations it was not.

The interviews revealed that in most cases no training at all was provided with a view to having the terms in the form interpreted consistently. Indeed, such training as the r;ceipt inspectors interviewed had, came either from their bcckground or simple observation of predecessors at Vermont Ycnkee.

A number of the interviewees expressed the view that the procedure and the form left much too much room for individual subjective interpretation. According to these individuals, this militated against consistency. All interviewees stated that there was no review of the RICs 14 -

once they were filled out. The inspector simply filed it with the P.O. documents.

There was inconsistency with respect to the understanding of the "special package" note. Some inspectors believed that a special protective package was n;ver to be opened. Others thought that at least one of occh item did have to be opened in order to do an inspection. In none of the challenged RICs which post dated Rsvision No. 9 did.the " inspection deferred" notation s:ppear.

With a single exception, and despite the absence of

'longuage in the procedure permitting it, all of the receipt inspectors utilized sampling as a normal method. It was justified by "past practice", " good judgment", and the fact that the procedure did not say it could not be done. It was also pointed out that ANSI N45.2.2.-1972 allows it and that no NRC personnel had ever questioned it. Several interviewees claimed that NRC inspectors had toured the Stores area a number of times and items requiring Quality Ansurance were clearly visible on shelves in sealed packages yat no complaint was made.

C. Analysis of Individual RICs

1. RICs As To Which Apparent Falsification Was Charged by NRC P.O. 14409; RIC 5/30/81 The items involved were solenoid valves. According to the P.O., three were delivered. NRC found all three still on the shelf. Two of the three were in solid foam containers which were still sealed. In addition, although the RIC says dimensions were checked, NRC 'in the IR states "the receipt inspector stated that a dimensional check was probably not performed." IR-at 8. Thus, the NRC charge is based upon the use of. sampling and the understanding of NRC that even the. sample was not probably in fact checked for dimensions.

In fact a dimensional check was made. The receipt inspector who stated that none was probably made was not the same one who actually did the inspection for'No. 14409. The interview with that individual revealed that he.did de a i dimension-check on the one he opened. The balance of the ctory is unique. The receipt inspector involved was the I only.one who was interviewed who did not normally use l

cimpling as a technique. However, he engaged in it in this case because he knew that the parts would never be utilized Et VYNPS. This was so because the design that permitted the volves' utilization had been superceded and the valves could not-be used in the new design configuration. To get the velves "off the floor" he filled out the RIC on the basis of cn inspection of one , solenoid valve. This is the only case fcund in the investigation where a receipt inspector knowingly deviated from his normal practice. And close questioning revealed.that he did not subjectively believe this deviation was equivalent to falsification in the circumstances.

P.O. 16480; RIC 8/31/81 The items involved were Collets and Pistons. Six were ordered _on the P.O. The NRC found all six on the shelf; five of the six were still in hermetically sealed bags. In cddition, the item " electrical insulation" was checked "Yes", although Collets and Pistons have no electrical parts. Thus, the NRC charge is based upon use of sampling cnd the fact that "the RIC indicates they had been inspected for electrical insulation which does not pertain to collets cnd pistons." IR at 9.

The interview with the receipt inspector revealed that (a) he believed that all inspections were to be done by campling based upon his background and experience; (b) that he did not believe collets and pistons were of sufficient complexity to be covered by the "special packaging" note in the procedure, therefore, a sampling inspection should be done and one was opened; and (c) that he was required to circle either yes or no in every case. With respect to a physical property that simply was not applicable to a given

' item it.was either circle "no" and create a problem or l circle "yes" on the theory that no such property being rsquired there was no problem. When the not-applicable item was in the nature of documentation, he-apparently used the tschnique of circling no and noting N/R which means "not l rsquired". He cannot remember why he did not treat

" electrical insulation" or " lubricants,and oils" the same

'wny.

P.O. 18047;-RIC 7/16/82 The item involved was agastat relays. The NRC found 47 of 47 on the shelf still in hermetically sealed bags. The IR notes-that the RIC states they were checked for dimensions and electrical insulation, IR at 8, which is impossible without unpackaging them. The IR also notes that the. receipt inspector admitted not knowing what dimensional attributes to measure.

The interview of the inspector revealed that in fact he removed no agastat relays from its package; that he believed the "special packaging". note in the procedure required this course of action; that his answers on dimensions were based

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on information on the package and that the basis for okaying electrical insulation was the fact that the accompanying cartificate of compliance stated certain tests were successfully passed and the actual test procedures were furnished as part of the documentation. (In light of the F

cortificate of compliance, it is doubtful that these L l i

4ttributes were required by the procedure to have been i 7 ' inspected as of this date in light of the prior source inspection.) 13ue receipt inspector felt he made clear the

'factithat the. inspection had not entailed opening the

. packages by: the comment opposite S III, Item 7 " Physical

'Dtmage": " Material to be insp. by maint. prior to inst. for

' internal damage." He admits that he would have done better

to'have filled in all items with "inspecti.on deferred" as

'cclied for by the special packaging note.

P.O. 22041; RIC 7/24/84 The items involved are 18 diesel generator fuel element cartridges. Of 17 still on the shelf, NRC found 16 in coaled packages. The basis of the charge apparently is stmpling'and the fact that "The QA Technician-indicated that ha.had no criteria to measure against and that a dimensional

-check was probably not performed." IR at 9. The.QAT was not the receipt inspector. The receipt inspector who did the inspection was_ interviewed telephonically. He stated Lthat~he had no real memory of this particular RIC, but

' surmised that the RIC was based upon a sample of the one package that was opened. He said that with respect to

" dimensions" if there were no drawings he understood that

'the answer was to be "Yes".

c P.O. 22396; RIC'4/5/84-P.O. 22711; RIC 6/7/84 Both of these PO's involved 90* angles, P.O. 22396 involved four boxes, of which two were found on the shelf; both sealed. P.O. 22711 involved 8 boxes, of wh'ich three of five remaining on the shelf were both sealed. The charge is based on the fact that the RICs are checked "Yes" for

' dimensions; however, "The QA Technician indicated he had no criteria to measure against and that a dimensional check was l . probably not performed. " IR at 9. The QAT did the receipt inspection in both cases.

The interview of the QAT revealed that he did make the statements attributed to him to NRC. He says in both cases ha sampled by opening and l'ooking at one box. However, the basis for the "Yes" on dimensions-was not the sample but rather.upon a comparison of.the part number on the boxes to the catalog which sets out dimensions by part number. His

! bnsis for all these actions were "past practice" and " good judgment".

l P.O. 22554; RIC 4/20/84 P.O. 22706; RIC 6/12/84 Both of these PO's involved Hilti Kwik Bolts. P.O.

22554 was for ten boxes, of which four of five remaining on the shelf were found sealed by NRC. P.O. 22706 was for

twenty boxes, all of which were still on the shelf and ccventeen of which were.still sealed. The charge is based upon the facts that

"RIC indicates these items received a L l t

I l

-dimensional check.. The QA Technician indicated he had no i i

l criteria to measure against and that a dimensional check was l probably not performe'd." IR at 9.  ;

In fact the QAT did not-perform the inspections involved

'in these RICs. An interview of the receipt inspector who filled out-these RICs reveals that in each case he' opened atnd inspected at least one box; he checked the label and ccmpared size and weight of the box to the other boxes; he physically measured bolts from the boxes opened and then F

>1oid a number of others beside the measured ones to check

'thsir dimensions.

2. Other RICs Reviewed In addition to the RICs discussed above questions were

.rcised,'though falsification charges were not made,-as to

-three other RICs. As a result these also were investigated.

P.O. 9706; RIC 7/15/78 The items involved were four solenoid valves; three of tho four on the shelf were found sealed. An interview with tho receipt inspector revealed that his practice with items like these which were not " nuclear specific" was to inspect.

by sample.which he did in this case.

P.O. 10269; RIC 6/20/78 The items involved were agastat relays. The P.O. shows l that seventeen were purchased of which seven of seven left on the shelf were found sealed by NRC. An interview of the p-

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inspector indicated that he did not have much specific I

L _ _ , _ _ _ _ . . . _ . _ . _ . - _ _ . _ . _ _

i.

-m mory of th'is.seven year old RIC. He.didesay that he would i have done the1 inspection-by sample which he believed to be '

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cppropriate and the-RIC answers would, therefore, be based Jupen the sample.

P.O.-12259; RIC 12/13/79 The items involved were-collets and pistons. A' total of five'were' ordered; three of three still on the, shelf were caalAd. The inspector recalls sampling one package and basing the RIC on that sample. He thought sampling was eppropriate and permissible.

-D. Overall Analysis as to Cause of Problems-Essentially, three' matters gave rise to the unfavorable comment that Vermont Yankee has received in this matter.-

lFirst, there was the.; essentially uniform practice of inspecting by sample. -There is little doubt that-this is

p3rmissible under'the~ ANSI standard-approved in NRC Reg.

. . Guide'1.38. The-problem is that the procedure, A.P. 0801,.

does not state that such a' method is permissible.

No reason has been ascertained as to why the language was removed which. allowed sampling of similar items and the reason is, .

in all likelihood, lost forever in history. It may well be simply an inadvertent deletion accompanied by subsequent proofreading error. It is clear that both the inspectors l -cnd the'various supervisors who oversaw the activities thought sampling was appropriate and that until 1985 NRC i

l ,

t

. - - - . . . - - . _ , . - n. ...,.---,.,--n,--,,----,- .~n,-,.--,-,-_-------.,_-_-.__,.,,,,,n,-----=nn,- .

. raised'no questi~on, as is understandable given the.

rcgulatory position in Reg. Guide 1.38.

A'second factor that caused problems was a form and procedure which was susceptible of varying interpretations accompanied by a tctal11ack of effort to engender a degree

-of consistency by appropriate training. There is no svidence that any lack of training resulted in inadequate inspections affecting safety; indeed, the evidence is all to the contrary. The lack of training did result in inconsis-tent use of the form =and the items on it.

Third! there is no doubt that the QAT admitted, and correctly so, that he was, in certain cases, without criteria in-the' area of dimensions. This is a lack of training and expertise at least on the surface. However,

.the ANSI Standard describes the dimension inspection as "randomLvisual. inspection to assure that important dimensions conform with changes and specifications." This does not connote a precise measuring procedure and yet AP 0801 and the RIC form are ambiguous and leave.the

. impression that greater precision is required.

In short, the procedure and form need a thorough

? overhaul so the paper conforms with the activity; which

'cctivity-in fact' appears to be adequate to the task and the regulatory requirements. The responsibility for this

obviously lies with management which apparently did not keep close enough surveillance over the language of the procedure end the form. The investigation revealed that the failure to overhaul.this procedure and form earlier apparently is ottributable to the fact that, given all the tasks necessary to assure that overall QA at a nuclear plant is adequate, this one simply had not the urgency other matters did (capecially in light of.the fact that all the items involved g;t reinspected before actually being used) and it had not

" worked its way to the top of the pil'e".

l ' Finally, a note on the suggestion of deliberate l

l falsification. The conclusion as to the lack of evidence of Euch activities is stated earlier. It is believed the i foregoing discussion adequately supports this conclusion.

No doubt some could argue that a good deal of the basis of l

the conclusion is,a belief in the truthfulness of answers given by interviewees. This is true. But it is always true that a determination as to human intent cannot be objectively demonstrated. One objective piece of evidence bearing on intent is the absence or existence of a motive to

, deceive. To begin with, the investigation revealed a uniform appreciation by Vermont Yankee personnel for the consequences both in economic and public health and safety terms that could flow from use of a faulty item at a nuclear facility. In addition, if any of these RICs involved an item to be rushed from the receiving dock to the reactor building to allow a start up one could surmise a motive to cheat to get the plant on line. But no RIC involved such a

a situatio' n. Given these factors it is essentially impossible

'to. construct a rational motive for any receipt inspector to attempt _to mislead people by deliberately trying to pass fculty items. 'Thus, there is a high degree of confidence

.mesociated with the conclusion as to a lack of any daliberate_ attempt, or desire, to create false records.

/ et.

ROPES & GRA

/ ^k UNITED STATES

! 4 NUCLEAR REGULATORY COMMISSION J E REGION I l 631 PARK AVENUE KING oF PRUSSIA, PENNSYLVANIA 19406 hkh(ly(( <

%s *

• APR 021985 Afb U C3 i

D:cket No. 50-271 Vermont Yankee Nuclear Power Corporation J ATTN: Mr. Warren P. Murphy Vice President and Manager of Operations RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301 G2ntlemen:

Subject:

Inspection Report No. 50-271/85-11 This refers to the routine safety inspection conducted by Mr. J. A. Prell of this' office on March 11-15, 1985, at the Vermont Yankee Nuclear Power Station, Vernon, Vermont, of activities authorized by NRC License No. DPR-28 and to the discussions of our findings held by Mr. Prell with Mr. D. Reid of your staff at the conclusion of the inspection.

Areas examined during this inspection are described in the NRC Region I Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

Based on the results of this inspection, it appears that some of your activ-ities were not conducted in full compliance with NRC requirements. These ap-parent violations involve the lack of a receipt inspection and storage program for safety-related material and the potential falsification of receipt inspec-tion reports. The details of these violations are include N W attached report (see Section 2.5). We are considering these items for appropriate enforcement action and will be addressing them later in separate correspondence.

An enforcement conference is scheduled for April 11, 1985, to discuss this catter. At this meeting, you are requested to discuss your understanding of the circumstances which led to these problems and the corrective actions you have taken or plan to take to prevent future recurrence of such problems.

No reply to this letter is required. Your cooperation with us in this matter is appreciated.

Sincerely, Oh2k'l 5 Stewart D. Ebneter, Director Division of Reactor Safety

Enclosure:

NRC Region I Inspection Report Number 50-271/85-11 i

-Vermont Yankee NuclearfPower Corp. 2 cc w'/enc 1:

R. W. Capstick, Licensing Engineer W. F. Conway,. President and Chief Executive Officer J. P. Pe11etter,'P.lant Manager Donald Hunter, Vice President Cort Richardson, Vermont Public Interest Research Group, Inc.

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-Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

- NRC Resident Inspector

~ State of New Hampshire State of Vermont

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U.S. NUCLEAR REGULATORY COMMISSION Region I Report No. 50-271/85-11 Docket No. 50-271 License No. DpR-28 f Licensee: Vermont Yankee Nuclear Power Corporation

.RD5 Box 169 Ferry Road Brattleboro, Vermont 05301 Facility Name: Vermont Yankee Nuclear power Station Inspection At: Vernon, Vermont Inspection Conducted: March 11-15, 1985 Inspectors: h.f J- 21-W J.grell,ReactorEngineer date h, /st) 2- 3 9 -8f Oliveira/~ReactorEngineer date Approved By: M h[d) - Mdated5-Dr. P. K. Eapen, Acting Chief, QA Section Division of Reactor Safety Inspection Summary: Routine Unannounced Inspection Conducted March 11-15, 1985 (Report Number 50-271/85-11)

Areas Inspected: Quality records storage program, procurement program, and r;ceipt, storage and handling program for safety-related items. The inspection involved 75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> onsite by two region based inspectors.

Results: Violations (inadequate receipt inspection and potential falsification of receipt inspection records paragraph 2.5) were identified in the receipt, storage and handling program for safety-related material.

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. DETAILS

1. Persons Contacted J. Babbitt, Security Supervisor D. Bauer, Assessment Engineer L. Bozek, Senior Engineer, Operations Quality Group (0QG), Yankee Atomic Electric Company (YAEC)

F. Burger, Quality Assurance (QA) Coordinator R. Butterfield, Operations Technical Assistant

• J. Desilets, Operations Department Supervisor

• P. Donnelly, Technical Services Superintendent (Acting)

D. Dyer, 0QG Engineer, YAEC

• C. Falkner, Document Control Coordinator J. Granfrancesco, Maintenance Supervisor

• G. Gilmore, Storekeeper W. Limberger, Senior Engineer, Operations

• R. Martin, Quality Design and Procurement Supervisor, YAEC D. McElwee, Equipment Qualification (EQ) Coordinator.

• R. Milligan, Administrative Supervisor C. Perrevecchio, QA Technician W. Peterson, 00A and Engineering' Group (EG) Supervisor, YAEC

. J. Pelletier, Plant Manager

• D. Pike, OQG Supervisor, YAEC

• D. Reid, Operations Superintendent 2.0 Receipt, Storage and Handling 2.1 References / Requirements

1. 10 CFR 50, Appendix B.

2. ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants.

3. ANS 3.2/ ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.

4. Vermont Yankee Final Safety Analysis Report, Appendix D.

5. Yankee Operational Quality Assurance Program, YOQAP-1-A, Opera-tional Quality Assurance Manual.

6. Administrative Procedure (AP)-0801, Revision 12, Receipt, In-spection and Shipment of Material and Equipment.

7. Ap-0802, Revision 7, Identification and Control of Ma erials, Parts and Components.

8. AP-0803, Revision 8, Storage of Materials and Equipment.

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9. AP-0806, Revision 1, Issuing and Returning of Material, Parts and Components.

10. AP-6021, Revision 8, Nonconformarce Reports.

11. ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel.

- 2.2 Program Review The inspector reviewed the documents listed in Section 2.1 and deter-mined that the licensee had established a receipt, storage, and hand-ling program for safety-related material which:

Provided for receipt inspection of all incoming safety-related materials and supplies. Reference 6 of Section 2.1 establishes the licensee's practices for receipt and inspection of material.

Identified qualified vendors who may supply safety-related items which are supported solely by a certification of conformance.

Required that received materials be examined for conformunce with rtquirements specified in the purchase order.

Provided for documentation of receipt inspection and storage of receipt inspection records.

Prorided controls for tagging and marking of acceptable and nonconforming items.

Established controls for the disposition and documentation of nonconforming items.

Established controls for the conditional release of nonconform-ing items.

Established responsibilities for each aspect of the program.

E'stablished controls for shelf-life components.

Provided for periodic inspections of the storage areas.

2.3 Program Imolementation Implementation review of the program included the following:

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4 Tours of the warehouse. Tags were used to segregate safety-related items from nonsafety-related items. All items but one (P.O.13068) were properly stored, identified, and segregated.

Upon identification by the inspector, the licensee removed the P.O.13068 ites from the shelf for proper tagging. The inspec-tor found no indication of water leakage or rodent damage.

Verification that access controls exist which limit entrance to the warehouse.

Verification that hazardous materials were stored away from safety-related items. Flammables and other hazardous chemicals were stored in enclosed metal cabinets.

Verification .that safety-related items were stored at their pro-per storage level or better. The warehouse is a Level B storage area. All items inspected were classified as Level B or lower.

t A tour of the QC Hold area and verification that the licensee's program for nonconforming items was being properly implemented.

Review of the following completed safety-related purchase order packages and verification that receipt inspections had been recorded and documented.

P.O. Number Descriotion 14409 Solenoid Valves 9706 Diesel Air Start Components 22396 Ninety Degree Angles 22711 Spring Nuts and Ninety Degree Angles 22554 Bolts 12259 Collets and Pistons 16480 Collets and Pistons -

19358 IRM 22041 0.G. Fuel Element Cartridge 21945 Agastat Relays 22474 120 Vac Relay 10269 Time Delay Relays 18047 Agastat Relays 22706 Bolts 13068 125 Vdc Coil Control In addition, the inspector held discussions with the Instrumentation and Control (I&C) and Maintenance Department Heads, the plant Manager and his staff and stores persennel regarding the effectiveness of the receipt, storage and handling program.

if 5 2.4 QA/QC Interface The annual QA audit of this area, VY-84-08, " Procurement and Material Control," conducted by Yankee Atomic Electric Company (YAEC) was reviewed. One facet of this audit covered the training / qualification of plant personnel performing receipt inspections on safety-related material. Results of this audit are discussed in Section 2.5 below.

2.5 Findings

During the tours of the warehouse, the inspector viewed the as-stored conditions for those items received under purchase orders identified in paragraph 2.3. A majority of the items received under eleven of

-these purchase orders were not opened by the receipt inspectors.

.These items were still packaged in their non-transparent sealed ship-ping boxes or envelopes.

Table 1 is a summary of the inspector's observations for the items received under the eleven purchase orders. -

Table 1 Items No. of No. of Indicated P.O. No. No. of Items Items as being Date of No. and Kind of Items Still Possibly Receipt Inspection Items Received on Shelf

• Sealed Inspected Insoected 14409/ 3-Solenoid Valves 3 2 1 Valves #1, 5/30/81 2-Repair Kits 2 0 2 2, 3 Solenoid Valve and Kits 9706/ 4-3-way Solenoid 4 3 1 Valves, 7/15/78 Valves elbows, 4-Norgram Air Filters 3 3 1 filters 12-Air Filter 4 4 8 (all items Elements on P.O.)

-16480/ 6-Collets and Pistons 6 6** O Spares (all 8/31/81 items on shipping receipt 218-108035)

6 Items No. of No. of Indicated P.O. No. No. of Items Items as being Dnte of No. and Kind of Items Still Possibly Receipt Inspection Items Received on_ Shelf

• Sealed Insoected Inspected 12259/' 5-Collets and Pistons 3 3 2 Collet and 12/31/79 Piston (all 11tems on shipping receipt) 10269/. 17-Different Time 7 7 10 All relays 6/20/78 Delay Relays en P0 18047/- 51-Different Relays 47 47 4 All relays 7/16/82 indicated on packing list 22041/ 18-Fuel Filter 17 16 2 All items 7/24/84 Cartridges 2/ box indicated on package list 22396/ 100-Ninety degree 2 boxes 2 boxes 2 boxes All items 4/5/84 Angles 25/ box indicated in shipping order

-22554/ 10 boxes-3/8" x 5 boxes 4 boxes 6 boxes All items 4/20/84 2 3/4" bolts on P0 22706/ 20 boxes-3/8" x 20 boxes 17 boxes 3 boxes All items

-6/12/84 2 3/4" bolts indicated on shipping order 22711/ 8 boxes-Ninety 5 boxes 3 boxes 5 boxes All items

~6/7/84 degree angles indicated 25/ box on shipping order 15 boxes-3/8" Spring 11 boxes 10 boxes 5 boxes All items Nuts 100/ box indicated on shipping order 4

• Missing items presumably were issued for use into the plant.

One item stored in an hermetically sealed aluminum envelope appeared to l have been torn while in storage.

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7 The inspector reviewed the receipt inspection records for the above purchase orders. The inspection records indicated that without ex-ception all received items were inspected. In Sections III and IV of the Receipt Inspection Checklist, the receipt inspectors recorded that the attributes such as, physical damage, dimensions, workmanship and electrical insulation were inspected. As described in Table 1, a majority of those items remaining on the shelf were in sealed pack-ages. Inspection for such attributes through the sealed packages is impossible. The eleven identified Receipt Inspection Checklists l covered a span of six years (1978-1984) and were signed by eight dif-ferent individuals: four Department Heads, one Department Head des-ignee, two QA Technicians and one Storekeeper. All Receipt Inspec-tion Checklists since 1982 were signed off by the QA Technician or the Storekeeper.

Further inquiry resulted in these additional findings and conclus- -

ions:

(1) Inadequate Receipt Inspection Procedures The inspec~ tor's review of the above purchase orders indicated that the inspection efforts varied significant.ly from person to person. For example, all of the inspection activities required on the receipt inspection checklist (RIC) for P014409 were not performed because the receipt inspector knew that the components received under this P0 would never be used at the facility.

However, the licensee failed to tag these components to identify this fact. Additionally, these components were not segregated from other stored safety-related items.

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For P.O. 22041 and P.O.18047 a sampling inspection was thought by the licensee to be adequate to accept all the components re-t ceived under a given P.O. However, the licensee procedures and l

specific procurement documents neither endorsed acceptance of received goods by sampling inspections nor provided specific guidance for determining the appropriate sampling plan.

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These observations indicate that the licensee program failed to establish acceptable procedures for receipt inspection.

(2) Inadequate Personnel Training, Guidance and Tools

, Prior to February 1~,1982, all receipt inspections were conduc-ted and signed off by the cognizant Department Head. After February 1,1982, a new position, QA Technician, was created to be responsible for all receipt inspections. The licensee's full time QA Technician stated to the inspector that he did not re-ceive any formal training in receipt inspections. As stated in YOQAP-1-A, the licensee has taken exception to the qualification

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requirements of ANSI.N45.2.6 for this position. Licensee admin-istrative procedures related .to receipt inspection provide lit-tle or no inspection guidance. Procedures governing inspections of' items for physical damage, physical . properties, dimensions, weld. preparations, workmanship, lubricants and oils, and elec-trical insulation do not exist. The licensee has established some guidance for such receipt inspection attributes as iden-tification . -and marking, documentation, protective covers and seals, coatings and preservatives, inert gas blankets, -desic-cants, and cleanliness. However, in most cases,sthe established-guidance was inadequate since it only addressed packaging, transportation and classification level requirements. The in-spectors also ' determined through questioning of the QA Tech-nician that the only tools available for dimensional inspections.

were a tape measure and a steel ruler.

Because of this apparent lack of tools, training and written.

guidance, 'the receiving inspector did not perform the required inspections although he documented on the Receipt Inspection Checklist that he did.

Given below are five examples where the receipt inspector docu-mented that he had inspected those attributes on the RIC but in

, fact he had 'not performed the inspections. These five records appear to be false.

Attributes Which Were Indicated P. O. Number as Being Inspected But Were Not 16480 Electrical Insulation 1 14409 Dimensions 18047 Dimensions, Electrical Insulation 22396 Dimensions 22711 Dimensions Notes: P.O. 16480 did not have any electrical parts. In P.O.

14409 the receipt inspector stated that a dimensional check was probably not performed. In P.O. numbers 18047, 22396 and 22711, the receipt inspector stated he did not know what dimensional or electrical attributes to measure or inspect.

(3) Ineffective QA Audits In YAEC audit VY-84-08, the training and qualifications of plant 1 personnel were audited. Under the " Assessment of the Effective-ness of the. Activities Audited", the conclusion was made that

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these personnel were " highly knowledgeable of the procedural requirements". This appears to contradict the NRC findings and raises questions as to the effectiveness of the audit.

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In addition, the audit report did not reflect a review of stored items and storage conditions.

1 (4) Inadequate Preventive Maintenance Program for Items in Storage The licensee ~ has not established a preventive maintenance (PM) program for safety related items stored in the warehouse as re-quired . by 10 CFR 50, Appendix B and ANSI N45.2.2. Purchase

-orders did not require PM int wmation from the vendor. Although the licensee has implemented a good PM -program for stored rota-ting electrical equipment, tu re is no evidence that PM is being performed for items stored M inert gas or with desiccants. As '

an example, P0 10269, received on March 16, 1978, had the fol-lowing notation stamped on the nontransparent hermetically sealed envelopes " Storage Inspection: check container upon re-ceipt .for damage / loss of vacuum. Examine contents in 3 year intervals of packaging." The contents were still sealed in the manufacturers sealed envelope s'x years after receipt.

(5) Accarent Falsification of Inspection Records It appears that the present licensee program is canducive to falsification of receipt inspection records. The ~receT;Fr in-spector or his c1 ternate is the only individual who presently signs the receipt inspection; there is no ' management review.

Prior to 1982, management personnel signed receipt records as noted in paragraph 2.5(2). Examples of P0's which contained false information are:

P0 No. Accarent Falsification 14409 RIC indicates solenoid valve Serial Numbers 1, 2, and 3 were inspected. Inspector found Serial Numbers 2 and 3 still packaged inside solid foam containers.

16480 RIC indicates that .the 6 collets and pistons had been l-inspected. The inspector found all 6 in their her-metically sealed bags. In addition, the RIC indicates they had been inspected for electrical insulation which does not pertair to collets and pistons.

18047 RIC indicates relays were dimensionally checked. The QA Technician stated he did not know what dimensional attributes to measure.

- 22041 RIC indicates these items received a dimensional

- 22596. check. The QA Technician indicated he had no 22554 criteria to measure against and that a dimensional 22706 check was probably not performed.

22711 b- i . i- - -

10 Items (1) through (4) above indicate a programmatic breakdown of re-ceipt inspections. They collectively appear to be a violation.

Item (5) also appears to be a violation resulting from the falsifica-tion of receipt inspection records.

2.6 Management Meetings The inspectors met with the Plant Manager and his staff to discuss these findings on March 14, 1985.

At that time, the inspector asked the licensee five questions NRC Region I management sought answers to. They were:

1. "What was the basis for apparently not inspecting all items?"

2. "Why doesn't the documentation accurately reflect what the in-spection covered?"

3. "Where are the missing items?"

4. "What guarantees can the licensee provide to the NRC that these

, missing items are performing taeir intended function?"

5. "Why wasn't this programmatic breakdown identified by super-vision or QA?"

That evening, licensee management informed the NRC that the following immediate actions had been taken.

1. Stores had removed all the identified items from the warehouse and placed them into the QC Hold area.

2. Until further notice, all safety related materials were to be receipt inspected against the RIC and documented prior to being released.to the plant.

3. Engineering would be requested to review the receipt inspections conducted for the identified items along with their known or likely installations and make an engineering safety evaluation of placing these items into service without an adequate receipt inspection.

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2.7 Summary of the Licensee's Findings in Receipt Inspections On March 15, 1985, after the NRC inspector made known his findings, the licensee provided a copy of an internal memorandum dated February 22, 1985, entitled " Meeting to Develop Recommendations for Enhance-ment of Receipt Inspection" VY885/74. This memorandum was addressed to the Vice President and Manager of Operations and summarized a January 11, 1985, meeting between Yankee Nuclear Services Division (YNSD) QA, VY Corporate, ar.d VY Plant personnel regarding the ade-

, quacy of the current VY receipt inspection function. The following l weaknesses were identified in the memorandum:

"1. Receipt inspectors sign for acceptance of dimensional character-istics and conformance to drawings and specifications, but do not actually measure dimensions nor, in most cases, compare received items to applicable documentation other than the pur-chase order and the vendor's C of C. Supporting documentation is not readily available.

2. Receipt inspectors have received no hands-on technical training in the techniques of mechanical and visual inspection of mate-rials, parts, and components.

3. Receipt inspectors do not have the equipment necessary to per-form even minimum dimensional inspection of received items.

4. Too much faith is placed upon the vendor's C of C as ensuring the adequacy of purchas2d items.

l 5. Resolution of problems identified at receipt inspection (other than those documented in non-conformance reports) may be subject to the " pressures of production", since the only source resolu-tion is the Ordering Department.

6. Receipt inspection has been treated as a "part-time" duty of the stores QA technician, which promotes superficiality of inspec-tion due to the pressure of other priorities."

This memorandum proposed several corrective actions to resolve the i

above weaknesses. These actions were undergoing VY management review at the time of this inspection.

3.0 Procurement program 3.1 References / Requirements

1. 10 CFR 50, Appendix B, Criteria IV and VII.

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2. ANSI N45.2.13-1976, Quality Assurance Requirements .for Control of Procurement of Items and Services for Nuclear Power Plants.

3. ANS 3.2/ ANSI N18.7-1976, Administrative Controls and Quality I Assurance for the Operational Phase of Nuclear Power Plants.

4. Yankee Operational Quality Assurance Program Y00AP-1-A, Opera-tional Quality Assurance Manual.

5. Vermont Yankee Final Safety Analysis Report, Appendix D.

6. AP-0800, Revision 10, Material and Service Procurement.

7. AP-6020, Revision 10, Material and Service Purchase Approval.

8. Yankee Atomic Electric Company Approved Vendor List, Revision 16.

3.2 Program Review -

The inspector reviewed the documents listed in Section 3.1 and deter-mined that the licensee had established a procurement pregram for safety related replacement items which included the following:

Only approved and qualified suppliers were used for supplying safety-related items.

Procurement precedures were developed in accordance with ANSI N45.2.13-1976.

Responsibilities were identified for initiation, review, and approval of procurement documents.

Purchase and receipt records for safety-related items were re-tained and maintained in accordance with established require-

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ments.

The engineering organization performed technical and quality evaluations of all purchase requisitions.

Quality Assurance (QA) performed overview of the above activ-ities.

Controls were established for making changes to procurement documents.

13 3.3. Program Implementation The ~ inspector selected the following purchase orders for safety-related items to ascertain whether procurement activities were con-ducted in accordance with programmatic and QA requirements.

Purchase Order Number Description 22124 UV Sensor Tube Module 22146 RCIC Trip Throttle Valve 22173 Containment Monitors 22271 EQ ASCO Solenoids 22179 3/4" Swing Check Valves for Diesel Air Start 22395 Reactor Feedwater Nozzle Mockup

=22378 ASCO Pressure Switch 22474 Agastat Relays 22592 Diesel Generator ASCO Valves and Repair Kit 22673 710 DU Spare Parts Kit for Analog.

' Trip System

22684 SNB Motor and Operator for V23-15 22738 Gaskets and Disc for RCIC Valve 0-Ring Kits

23021 23261 125 Hp. Motor for Cooling Tower .

23263 Gasket Material for QA MOV's 23616 Limit Switches and Gaskets The inspector verified that the vendors for the above purchase orders l were on the Approved Vendors List; that QA and Engineering had re-l viewed the' purchase requisitions; and that the requisitions refer-l enced the appropriate codes, standards, Part 21, shelf-life, and L Certificate of Confor.mance requirements.

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-3.4 Findings No violations were identified.

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1 4.0 Records Program

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4.1' Requirements / References

1. 10 CFR 50, Appendix B.

2. Technical Specification Section 6.6.

3. 'F5AR Section 1.9, Quality Assurance Program.-

4. ANSI N45.2.9-1974.

5. ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.

6. YOQAP-1-A, Revision 15, 0perational Quality Assurance Manual.

7. Administrative Procedure (AP) 0834, Revision 11, Plant Record Retention.

8. AP 6502, Revision 11, Drawings and Aperture Cards.

9. AP 6805, Revision 8, Document Control.

10. _ AP. 6806, Revision 5, Transfer of Quality Assurance Records to

. Document Control Center.

11. AP 6508, Revision 3, Record Disposition.

4.2 Program Review The inspector reviewed the licensee's Quality Assurance records stor-age program. This program was established to meet the requirements of the documents referenced in paragraph 2.1. The licensee's proced-ures adequately identified the records required to be maintained.

All records required to be maintained by the Technical _ Specifications are identified and tracked in the licensee's Departmental Record Type

! List. Responsibilities and controls for storage and filing, .trans-fer, retention, maintenance and disposition of records are also iden-l tified and assigned in the licensee's procedures.

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15 4'.3'1 Program Implementation The inspector verified the implementation of the record storage pro-grams-in AP 0834 and AP'6806 by tours of several departmental storage i areas and the s storage vault. The designated record clerks /custod- l ians:

_(1) readily retrieved -any records requested, including microfilm records located in specific areas throughout the plant.

(2) - controlled the receipt and verification of records including changes and supplemental information. The inspector reviewed the Records Receiving Checklist for the Health Physics . Depart-ment cand the Stores and Purchasing Department. These records

'had been submitted for microfilming.

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(3) controlled the access to files and the accountability of

-records.

(4) .were knowledgeable of the retention requirements and the dis-position of records.

When the records personnel were not sure of the record retention per-

'fods, especially for the record's not covered by regulat.ory require-ments.or ANSI N45.2.9, they consulted the applicable department heads for answers. Furthermore, AP 6808 requires the signature of a de-partment head for the destruction of any. records regardles: of the-retention period. For example, the inspector noted that the Reactor Engineering Department Head signed the Records Disposition Form to have the Nuclear Engineering Conference Reports for 1976-1981 de-stroyed. Likewise, the Training Department Head requested that cer-tain outdated records be- returned to him after they were niterofilmed.

The storage vault was inspected. This vault met the requirements of a single storage facility discussed in ANSI N45.2.9, Paragraph 5.6.

L The temperature 'and humidity (72*F and 50%) was within the range indicated in AP 0834 (68"F-75*F and 30-55%). Temperature / humidity information was recorded ' monthly on Form 0834.02. Access to- the vault is controlled - by the Administrative - Supervisor, the Document

-Control' Coordinator 'or .her assistant. The permanent records in the

. vault include the Health Physics logs, Chemistry logs, radiographs, and ' strip charts. The strip charts, ' after a year, are sent to a vault in Iron Mountain, New York.

The inspector randomly selected the following records for review:

16 Health Physics Log Bcok (8/12/79 through 12/10/79)

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Chemistry Log Book (8/10/72 through 10/26/72)

Radiographs RHR 3BF6 (2/17/71)

MS 10 F5 (1/11/71)

Core Spray (12/30/69 and 4/11/71)

ReactorRecirc(6/17/76) '

The inspector also verified that the drawings received by Document Control Center (DCC) from YAEC were in agreement with the transmittal documents; that the drawings were properly distributed; and that the microfilm for these drawings was properly filed. Specifically, the inspector verified that the drawing revisions of an Engineering De-sign Change Request (EDCR 84-13) and a Plant Design Change Request (PDCR 84-01) from Engineering Support were in agreement with the Master Point Index.

The following records were reviewed to verify proper implementation of the program:

Reportable Occurrences related to Information Notices (IN),

Generic Letters, Inspection Reports (IR), and Licenses Event Reports (LERs).

IN 85-09, IN 85-10, IN 85-11 IN 85-04, IN 84-81, IN 84-79 and IN 84-78 Generic Letter 84-24 and LERs 84-12, 84-13, 84-14, 84-15 and 85-01 IR 84-23, Licensee is preparing reply to open items 84 02 and 84-23-04 I&C calibrdisr. records for a Decade Box, Voltmeter, and Poten-tiometer.

Surveillance test record of a Standby Gas Treatment System.

Operational logs and records such as: Operator Round Sheet; Auxiliary Operator Round Sheet; Sump Timer Data Sheet; and Meter Data Sheet.

Reactor Engineering records such as: Fuel Receiving Super-visor's Checklist; Fuel Container Checklist; and Special/ Spent Nuclear Material (SNM) Transfer Form.

17 Maintenance Inspection Reports for MR 84-2260, 2247, and 2169.

Inservice Inspection (ISI) for 1983: ISI Insulation Removal and Replacement package; and 1983 Vermont Yankee Work Plan.

DCC records such as Drawing Status Revision Report and Master Print.Index. The inspector and DCC assistant randomly selected twenty drawings from the print index of 17,900 drawings and verified that these drawings were microfilmed.

Equipment Qualifications (EQ) records for Level Transmitter LT 2-3-72A (MR 85-0411), and Pressure Transmitter PT 2-3-520.

MR 84-0263, Reactor Building Closed Cooling Water Pump and MR 84-1757, Emergency Core Cooling System Battery Charger.

4.4 OA/QC Interface Involving Records The annual YAEC audit (VY 84-13) of Document Control, which included records, was conducted in October 1984. The audit report was issued on November 21, 1984. The plant's response, which was adequate and timely was sent tc the Manager of Operations on January 3,1985 for his review and approval. Operational QA (0QA) only retains the latest YAEC QA Audit. Plant Audit reports are maintained at YAEC, Framingham, Massachusetts. The inspector also reviewed OQA Inspection Checklists 84-12, 84-16, 84-32, 83-35, 83-50, and 85-16.

These checklists conformed to ANSI N45.2.9 requirements.

4.5 Findings

No violations were identified.

5.0 Exit Meeting The inspectors met with the Plant Manager's designee and other staff mem-bers denoted in Paragraph I on March 15, 1985, to summarize the scope and findings of the inspection. These representatives acknowledged the in-spector's findings. See paragraph 2.6 for details of other management meetings.

At no time during the inspection was written material provided to the licensee by the inspectors.

1

uNirso STATES .

ATTACHMENT 2

1. a a%g*, NUCLEAR REGULATORY COMMISSION

.[- k REGION t U f $31 PARK AVENUE '

Kino or enuss:A PENMsYl.VANI A 19404 o....

APR 2 5 tace D:cket No. 50-271 pggg.

VEE 10hTYEXEE UCENSits Vermont Yankee Nuclear Power Corporation ATTN: Mr. Warren P. Murphy

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Vice President and Manager of Operations -

RD #5, Box.169

.Forry Road MPR E R W

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Brattleboro, Vermont 05301 Gentlemen:

Subject:

Notice of Violation and Enforcement Conference Report On April 11, 1985, an enforcement conference was held in the NRC Region I office with you and members of your staff to discuss our concerns regarding deficiencies

.in the quality assurance program relating to the receipt inspection and storage of safety-related material. A report of the conference is enclosed.

~

These con-cerns were identified by the NRC during an inspection conducted on March 11-15, 1985, and were documented in NRC Inspection Report 50-271/85-11, forwarded to you by letter dated April 2,1985.

.'Specifically, these concerns involve: (1) failure to provide adequate instruc-tions for inspecting safety-related material upon receipt and for storing of safety-related material; and (2) failures to correctly document the results of certain inspection attributes of received safety-related material at the fact-

-lity. The first concern is set forth as a violation in Appendix A 'to this let-ter. Although this violation is classified as Severity Level IV in accordance with the NRC Enforcement Policy, 10 CFR Part 2, Appendix C published in 49 FR 8583 (March 8, 1984), it together with the other findings of Inspection Report 50-271/85-11 are of particular concern to the NRC because they represent a breakdown in management control of that portion of the quality assurance program rigarding receipt inspection and storage.

Furthermore, this represents the third breakdown in management control of a por-tion of the quality assurance program in the past two years. The two previous concerns involved: (1) twelve problems in the quality assurance program were identified in NRC Inspection Report 50-271/83-22; these problems indicated that the quality assurance staffing level was inadequate and the program was too nar-row in its scope and coverage; and (2) a failure was identified in NRC Inspec-tion Report No. 50-271/84-23 where non-metallic spare parts purchased between 1975 and 1983 were not included in the recently established shelf-life control program. We are therefore emphasizino that any further breakdown of the cuality assurance program could lead to escalated enforcement action.

i

-Varmont Yankee Nuclear Powar Corp. 2 We also have a concern with respect to the manner in which your staff dealt with the NRC inspector in this most recent inspection. Apparently, ,the admin-istrative supervisor was aware as early as January 1985 that your receiving inspection practices were not in compliance with NRC requirements but he chose to remain silent during the inspection in this very area. When the inspection was essentially over plant. management first attempted to mitigate the NRC findings on the premise that your staff had already identified the problems.

We rely on licensees to provide us with factual and timely information related to plant activities and expect your staff to fully inform NRC inspectors of known problems in the course of inspections and not wait to see if an NRC

, inspector happens to identify a known problem on his own.

You are required to respond to the enclosed Notice of Violation and you should

, follow the instructions therein. In your response, you should also describe the actions you have taken or planned to ,(11 assure that the adequacy of safety-related material received, stored or installed at the plant has not been affect-ed by the deficiencies in the receipt inspection and storage program, and [21 2 improve the effectiveness of your QA program implementing procedures and their administration.

In addition, to enable NRC to determine what actions, if any, should be taken with respect to your license, you are required to submit under the provisions of 10 CFR 50.54(f), 'a report of your investigation into apparent false documan-tation concerning the results of receipt inspections; an explanation of how these incidents occurred and with whose knowledge; a determination of the causes of the falsification, including the responsible individuals; and a description of the actions taken or planned.to prevent recurrence of similar incidents.

Your written reply to this letter and the results of future inspections will be considered in determining whether further enforcement action is appropriate.

We will examine closely your response to this letter and the enclosed Notice of Violation to assure that the proposed actions are adequate to preclude future breakdowns in QA program implementation.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed.in the NRC Public Document Room.

The responses directed by this letter and the enclosed Notice are not subject to'the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, Thomas E. Murley Regional Administrator

Enclosures:

1. Appendix A, Notice of Violation

2. Report of Enforcement Conference

. -- - ---- l

' Vermont-Yankee Nuclear Power Corp. 3 cc:

Re W. Capstick, Licensing Engineer W. F. Conway, President and Chief Executive Officer J. P. Pe11etter, Plant Manager D. Hunter, Vice President..

C. Richardson,~ Vermont Public Interest Research Group, Inc.

Pubite Document Room (POR) local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident. Inspector State of New Hampshire State of Vermont

APPENDIX A NOTICE OF VIOLATION Vermont Yankee (VY) Nuclear Power Corporation Docket No. 50-271 License No. DPR-28 As a result of the inspection conducted on March 11-15, 1985, documented in In-spection Report 50-271/85-11, and in accordance with the NRC Enforcement Policy

~(10 CFR 2, Appendix C), the following violation was identified:

10 CFR 50, Appendix B, Criterion VII states in part: " Measures shall be esta-blished to assure that purchased material, equipment ... whether purchased di-rectly or through contractors and subcontractors conform to the procurement documents. These measures shall include provision, as appropriate, for ...

examination of products upon delivery." Additionally, 10 CFR 50, Appendix B, Criterion XIII states in part: " Measures shall be established to control the

... storage, ... and preservation of material and equipment in accordance with work and inspection instructions to prevent ... deterioration."

Paragraph C.I.f of Section VII, of the Yankee Operational Quality Assurance Ma-nual, YOQAP-1-A, states: " Satisfaction of this criterion (VII) shall be assured through ... receipt inspection of vendor furnished material to assure ... mate-rial and documentation are inspected in accordance with predetermined instruc-tions and are determined acceptable prior to use." Paragraph C.1.b of Section XIII of YOQAP-1-A states: " Satisfaction of this criterion (XIII) shall be as-sured through the ... preparation of instructions in accordance with design and specification requirements which control the ... storage ... of safety classi-fied materials ... to preclude ... deterioration by environmental conditions such as temperature or humidity."

Contrary to the above, as of March 15, 1985, VY implementing procedures AP-0801 and AP-0803 were' inadequate in that these procedures: (1) failed to provide sufficient predetermined instructions which resulted in incomplete, careless and nonrepresentative receipt inspections as exemplified by receipt inspection reports for solenoid valves (P014409, P0 9706), collets and pistons (P016480, PO I??c9h relays (PO 10269, P018047), Diesel Generator Fuel Filter cartridges (P0 22041), ninety degree angles (P0 22396, PO 22711) and Kwik bolts (PO 22554, PO 22706); (2) failed to define preventive maintenance requirements for the storage of safety classified materials to preclude deterioration by environ-mental conditions such as temperature and humidity and as exemplified by PO 10269 whose items had not been examined for six years although the manufacturer recommended examinations at three year intervals.

This is a Severity Level IV Violation (Supplement I).

Appendix A 6 Pursuant to the provisions of 10 CFR 2.201, Vermont Yankee Nuclear Power Cor-poration is hereby required to submit to this office within thirty days of the date of the letter which transmitted this notice a written statement or explana-

ticn in reply, including

(1) the corrective steps which have been taken and tha results achieved, (2). corrective steps which will be taken to avoid further violations, and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time.

U.S. NUCLEAR REGULATORY COMMISSION REGION I Enforcement Conference Rep' ort No.50-271/85-15 Docket No. 50-271 License No. DPR-28 Licensee: Verm_ont Yankee Nuclear Power Corporation RO 5, Box 169 Ferry Road, Brattleboro, Vermont 05301 Facility Name Vermont Yankee Nuclear Power Station Meeting at: King of Prussia, Pennsylvania Me: ting conducted: April 11, 1985 NRC Personnel: d kcMa A.3/[JI" o' ate signed pJ. Frell, Reactor / Engineer Approved by: .N. E d A #!J 7/f/f" eate ' signed Dr. 7.K. Eapin, Acting Chief, QA Section, Operations Branch, DRS Enforcement Conference Summary:

An Enforcement Conference was held on April 11, 1985 to discuss the concerns associated with an inadequate receipt inspection and storage program and

~

inaccurate and misleading receipt inspection reports. The licensee discussed 4 i ' the actions taken to address these concerns.

2 DETAILS

1. Vermont Yankee Nuclear Power Company

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W. Murphy, Vice Prest' dent and Manager of Operations J. Pelletier, Plant Manager R. Milligan, Administrative Supervisor W. Limberger, Senior Engineer, Operations Support Yankee Atomic Electric Company

- W. Peterson, Manager, Audit and Engineering Nuclear Regulatory Commission T. Murley, Regional Administrator J. Allan, Deputy Regional Administrator S. Ebneter, Director, Division of Reactor Safety R. Starostocki, Director, Division of Reactor Projects W. Kane, Deputy Director, Division of Reactor Projects L. Bettenhausen, Branch Chief, Operations Branch L. Tripp, Section Chief, Reactor Projects Section #3A P. Eapen, Acting Chief, Quality Assurance Section W. Raymond, Senior Resident Inspector D. Holody, Enforcement Specialist G. Meyer, Project Engineer J. Prell, Reactor Engineer

2. BACKGROUND NRC inspection 50-271/85-11 was conducted to review the licensee's quality records storage, procurement, and receipt, storage and handling programs for safety-related material. The following concerns were identified with-in the receipt inspection and storage program:

a) Inadequate receipt inspections of safety-related material were con-ducted because of inadequate procedures.

b) Receipt inspectors were not provided with adequate training,' tools, or guidance needed to perform their duties, c) A QA audit was of questionable effectiveness since it came to an opposite conclusion from the NRC inspection.

d) The preventive maintenance program for stored items was inadequate.

e) . Receipt inspection reports failed to accurately document the charac-teristics inspected.

3 Details of this inspection are provided in NRC Inspection Report No.

50-271/85-11.

3. DISCUSSION The NRC staff requested the licensee's representatives to comment upon the inspection report and to discuss the actions planned or taken to address the NRC identified concerns.

The Itcensee's representatives provided the following information:

a) The licensee acknowledged that their procedures for receipt inspections were inadequate in that they lacked specificity and provided no guid-ance for sampling inspections. The licensee stated that at least one item of each identified purchase order was inspected. Based on this sample inspection the inspector signed off the Receipt Inspection Checklist for those items as being acceptable. In light of the NRC inspector's findings, a special task force was formed on March 16, 1985, to evaluate the effects of an inadequate receipt inspection program on materials already placed in the plant and to make recom-

'mandations by May 1, 1985, for improving'the receipt inspection pro-gram, b) The licensee took exception to the statement that a receipt inspector had not received any training for his duties. Copies of tests taken by the receipt inspector in 1982 were produced. The licensee acknow-ledged that this training was weak in that it did not address all re-ceipt inspection characteristics. The licensee also took exception to the statement that this receipt inspector did not have any tools for making dimensional measurements. . Administrative Procedure AP-0801 states that the receipt inspector may request support from the appro-priate Department Head in matters requiring detailed technical review and that when calibrated measuring or test equipment is needed for receipt inspections, it will be provided by the Maintenance or I/C Departments. The licensee did acknowledge that the receipt inspector may not have used these services or tools.

c) The licensee stated that the QA audit referred to in the NRC Inspec-tion Report 50-271/85-11 was designed to ascertain the degree of ad-herence to existing procedures. The audit was designed neither to determine the adequacy of these procedures nor the accuracy of the Receipt Inspection Checklists. Within this framework, the licensee felt that the audit was effective but did acknowledge that there was room for improvement in the audit program.

d) The licensee acknowledged that there were shortcomings in their pre-ventive maintenance program for items stored with desiccants and thac

, .the task force would be making recommendations for improvement in this area.

r 4

e) The licensee stated that there was never any deliberate intent by management or the receipt inspector to deceive when filling out the receipt inspection reports. Instead, inaccuracies discovered by the NRC in these reports merely indicate the individual receipt inspectors' understanding and implications of the receipt inspection function at that time.

4. ENFORCEMENT ACTION Refer to Appendix A of the transmittal letter to this report.

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ATTACHMEI1T 3 QUESTIONS FOR INSPECTORS Name?

Agc?

l.

Present home address?

l Prcsont business address?

l Pr0sent title?

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l D0ccription of duties and responsibilities in present pocition?

Educational background?

Any other formal training?

J f

When first employed by Vermont Yankee?

Summarize (chronologically) your employment history with V0rmont Yankee (including a brief description of duties and responsibilities in each position)?

Fccusing on your involvement in the receipt inspection process and tho signing of " Receipt Inspection Checklists" (RICs):

1. When were you involved, and for how long?

2. What was your position or title at that time?

3. What were your general duties and responsibilities in this capacity?

4. What were your specific duties and responsibilities with respect to the receipt inspection process?

5. Who was your immediate superior?

6. Did you report to anyone else?

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7. Did anyone report to you?

. 8. What was your understanding of the " chain of command" with respect to the receipt inspection process?

9. What, if any, in-service training were you given prior to or during your service as a receipt inspector?

10. What, if any, other qualifications did you have for this position?

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11. What tools or equipment were you given to carry out your duties and responsibilities as a receipt inspector?

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1 With respect to your inspection of incoming goods (and completion and signing of RIC's), do you recall who first explained to you how this process should be performed?

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[SHOW INSPECTOR COPY OF QUESTIONED RIC SIGNED BY HIM.]

With respect to the particular RIC before you,

1. (QUIZ GENERALLY RE NRC STATED DEFECT 7]

2. What was the basis for each circled choice in Sections III and IV (when package not opened)?

3. Who directed, advised, or approved this method of inspection?

4. Was this your customary practice?

S. How long did you use this method of inspection? '

s l-

6. Did you ever ghange inspection methods?

l If so, how, when and why?

7. Other comments orq'uestions . . .

[SHOW INSPECTOR COPY OF PROCEDURE HANDOUT THEN IN EFFECT.]

Have you seen this document before?

9 When did you first see it?

Did the information contained in the document have any b aring upon the inspection process which you employed?

t m ai om im i sm oom o

Io there a particular section or passage which you relied upon to justify your method of inspection?

Did you ever complain or comment to anyone about the RIC ferms?

Did you feel the RIC forms were adequate?

Did you ever complain or comment to anyone about the procedure handout?

Explain your participation, if any, in the present NRC investigation?

Explain your participation, if any, in other similar NRC investigations?

I

N, . ATTACHMENT 4 AMERICAN N ATION AL STANDARD REACTOR PLANTS AND THEIR M AINTEN ANCE Packaging, Shipping, Receiving, Storage and Handling of items for Nuclear Power Plants

/

i During tne Construction. P,ase)j ANSI N45.2.2 - 1972 i

SECRETARIAT THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS l

l PUillSHED BY THE AMERICAN S O CIE T Y OF MECHANICAL ENGINEERS United Engineering Center 345 East 47th Street New York, N. Y.10017

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Any part of this standmt nary be quoted. Oedit lines shondd read: "Extnocted )>one -

Anmerican National Standant Phackagmg, Shipping. Receiving. Stontge and Handlig of -

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Items for Nuclear Pbwer Plants, (Durmt the Construction Phase) ANSIN43.2.21972, = -

with the permassion of the pubusher,17te Amerscas Society of Mechament Engineers, United E.4. .'..,., Center,343 East 47th Street, New York, N. Y.10017. "

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Printed in U.S.A.

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,1 FOREWORD (

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This standard deals with the care and inspection of material, equipment and components, hereafter d referred to as items, from the time they have been released for packaging at the end of manufacturing until they have been placed in their final designated location la the generating station. De standard was de.

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veloped under g 1- % of no American Society of Mechanical Enginsen (ASME) m an effort by the aE Americes National Standards Committee N45 as Reactor Plants and Deir Maintanaam his committee has been chartend to pmmote the d..i; of standards for the locados, design, construction, and Y

1 maintenance of nuclear reactors and plants embodying nuciser reactors, including equipment, methods, and components speciacally for this purpose. g In May of 1969 the N45 Committee established an ad hoc Committee (N45-3.2) on Packaging, Shipping, Receiving, Storage and Handling of Equipment. He purpose of this committee was to propero a standard E

for seneral ladustry use that would define the requirements foe these activities so as to assure attainment of dlii quality construction. The ad hoc committee was composed of representatives of key segments of the 4 nuclear industry, inchiding utilities, reactor suppliers, constmetica contractors, component manufacturers, and conmitants. O j

The properation of material for this standard was initiated with the intent that appropriate requirements would be included in the ASME Boiler and Pressure Vessel Code. Subsequent to these efforta, it was .

decided that the requirements would be prepared as a separate American National standard. De initial draft of this standard was prepared in February 1970. Since then revnions have been mrds to reflect ]

comments received from committee members, other ad hoc committees of N45, and selected individuala from the nuclear industry and the United States Atomic Energy Commission.The standard contained hetein M&

was developed from this activity.

In April of 1970 the N45 Committee established a subcommittee N45 3.0 to guide the preparation of am nuclear quality assurance standards. His subcommittee is responsible for establishing guidelines and policy 'O to govern the scope and content of various standards, monitoring the status of standards in process, recom- Zi mending preparation of additional standards, and final approval of standards prior to their submittal to the N45 Committee for balloting. Working with the N45 3.0 Subcommittee and concurrently with the develop.

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=g ment of this standard by the N45 3.2 ad hoc committee,other ad hoc committees of N45 developed a series "!

of standards that set forth both general and detailed technical provisions for certain activities to assure l quality during the construction phase of nuclear power plants. These standards include the general quality assurance program requirements and provisions for cleaning, instrumentation and electrical work, house-i keeping, civil, structural, and mechanical work; qualifications of quality assurance personnel; and other quality assurance practices.

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In October 1972 the N45 3 Subcommittee was renamed N45 2, and Work Group N45 3.2 was renamed N45-2.2. 2 -

At the time of issue of this standard the following other N45 quality assurance standards were in prepa-ration orissued:

N

l. N45.2, Quality Assurance Requirements for Nuclear Power Plants.

2 -

2. N45.2.1, Cleaning of Fluid Systems and Associated Components Daring the Construction Phase of '-

Nuclear Powr Plants.

j 3. N45.2.3, Housekeeping During the Construction Phase of Nuclear Power Plants.

4. N45.2.4, Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equip-ment During the Construction of Nuclear Power Generating Station. 9 i

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5. N45.2.5, Construction Phase Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel for Nuclear Power Plants.

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6. N45.2.6, Quahfication of Inspection, Exanunation, and Testing Personnel for the Construction Phase

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7. N45.2.3,Instauntion,laspection, and Testias Raisiransats for Mechanical Equipment DuringCon.

(N-struction of Nuclear Power Plants.

8. N45.2.9, Requiremens for Quality Asestance Records for Nuclear Power Plants. -

9. N45.2.10, Densition of Terras. -

10. N45.2.!!, Quality Asurance Requirussets for the Dody of Nuclear Power Plants. -

!!. N45.2.12, Quality Assirance Program Auditing Requirunents for Nuclear Power Plants.

12. N45.2.13, Supplementary Quality Assurance Requirements for Properation of h. ..t Docu. -

meets for Nuclear Power Plants.

13. N45.2.14, Supplementary Quality Assursace Requirements During the Manufacture of Class IE In.

strumentation and Electric Equipment for Nuciser Power Generating Stations. -

Sugestions for improvement gained la the use of this standerd will be welcome. They aamid be seat to the Secessary Amedcan National Standards re= N45, 'the Amedcan Society of mehamleal En.

glaces, United Enginsedes Center,345 East 47 Staet, New Yodt, New York 10017. -

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--l AMERICAN NATIONAL STANDARDS COMMITTEE N45' Reactor Mants and Their Maintenance dZj

-i OFFICERS <

W. M.Jasmo, Chedrmee Regw Ces, WeeOedresse m

J. C. Russ, Secretary Q-COMMITTEE PERSONNEL y

AMERICAN FEDERATION OF LABOR AND CONGRESS OF INDUSTRIAL ORGANIZA110NS

7. #. .mosa, latemodensi Brotheshoed of Electdcal Workass. WasMasses, D.C.

l AniERICAN NUCLEAR SOQETY '

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J.1 Messe, hgka== Bactde CE - '. Mttsburgh, Pennsylvenis s Aunav'a86 SOQETY OF QVIL ENGNEERS -q l

A A Feswee, Ehesse Servisen, New York, New Yosk C 1 Ameest, Alessnese, Stone and Weteest Eaglesestas Corporaties, Boston, M-=== h===tes j

l a wreerau SOGETY OF MECHANICAI, ENGINEERS. THE '

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E. C. asiler, Casesnoewealth Edson Company, Odcase. IEinois -

V. A moyer, Phaga Hectdc Cosnpeny, F>aaWa Pennsylvania i N. F. Aust, EschtelC -- - n San Frandsso,Califondau w.m. Jesus, cassess,IEhecie ' -

A m. usenne, Generet necins Company, San Joes, Califonda AMERICAN WELDING SOCETY f -

C. A. Aresse, Altessam.Downess Grove,IEinoisL ATOMICINDUSTRIAL FORUM,INC,

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l D. W. Monopomwy, Babcock and WIIcox, Lynchburg, Virginia i

EDESON ELECTRIC INSTITUTE - ELECTRIC UGHT AND FOWER GROUP  !

M. W. Osmeer, Conectidated Edisonra p==y of New York,Incoryctsted, New York, New York l K.P. Aust/s, Altsanas,Seuthern California Edison Company,IAs Angstes,f.alifoenia 5=

! G. A Okee, Alternam, Edison Doctne Imedente, New York, New York i

HEALDI PHYSICS SOCETY 5 --

T.J. awneer, Oak Ridge National Laboretssy, Oak Ridge Tennessee INSMTUTE OF ELECTRICAL AND ELECTRONICS ENGINEERS M. Geen, Amedcan Doctric Power Corporados. New York, New York

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J. C. Muse, General Doctdc Compesy, San Jose, Califomia -

INSTRUMENT SOCETY OF AMERICA M. C. Capodsed, Doudee United Nuclear Incorporated, RicMand, W6shington d

T.M. Casmser, Alissmass Dasglas United Nucieer Incorporated, Rachland, Washinstes -

MANUFAC1URINGCHEMIST3* ASSOCIA110N, INCORPORATED Joe uns.o.serey Nacie.r Commy, n.ne e, W.mMagio.

NUCLEAR ENERGY PROPERTY INSURANCE ASSOCIATION 5 A. 7. apr, Nedser Emery Property lamarance Associados, Hartford. Conneencut F.13mesone. Alemate, Nuclear Enery Property Innstance Associados, Hartford,Connecdcut I -

FUBUC HEALTH SERVICE J. E.Martie, U.S. Department of Environmental Protecnon Agency, Rockville. Maryland E. D. Nanmaruf. Alismate, U.S. Dept. of Envir Jamental Protecdon Agency, Rockvtile, Maryland 3 TRAVELERS INSURANCE COMPANY,1HE F. W. Cansdur, The Travelers Inarance Company, Hartford. Connecticut M

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UNDERWRtTERE'LABORAltNtIES ',

L. N. Mosw Underwritess' ' f r Aincorporated,Odcago,IEtaois-U1 ATORACINERGY Crete:ON Aawans asset, US Atosmis Emery ca==aada= WesWagten. DA -

f.C. Case, U1 Atensis Emery ca==a-d== Washinston, DA

7. 4 See, DMales et Opereelonel Safety U1 Atosmic Emery ca== dada = WasMagsce, DA INDIVIDUAL MEMBERS Asser cue, Yanhas Atosals Doctric Casapesy, Westboro, Wa===eh===tte  :' .

O. L. Leone, Sassent & Landr. Chicago, Diinois Nuredd LJanseneerser, Musener Devealen, Casabestion Eagleesdag, lacorpersend, Windeer, Connecticut

t. M. AAmeser, MPR Assesdates,lacorperseed, WesWaston, DA --

Seheessumitges on Nualeer Qisality Assuranse Standards (N484

& A. ammano, castrinse, asshtml Corp., San Francisme, Califossie 4 E Asessurusso, Oak Ridge Nationsi Leh., Oak Ridge, Tisanessee A.1 auts, Pesias Gee & Doctris Co., Sea Francisco, Califoamie.

G. assue, terms & Rae, OradeE, New Jeresy A. awnede,3 tone & Watsaar Emps. Corp., Beseen, Maaaach===ena

18. Cadsee, Westhsponse Doctris Ca. Mttsbur$. Pumasrivsmis A. N. Ossdebos, Tammessee Valley Aas thosity, Kaouves, Tammense A. L. Oradr, Debe Perser Co., Charlotte, South Cesotas M. F. Ostui, Sebeeck & WEcox, Lynchberg, Vir$ sis E F. Forgenes, Ook Ridge Netland Leh., Ook Ridge;Tsumssme 4 E Mmeones, Wcilmshomas Destds Cork PWR SFsames Dee, Mttsburgh, Ptensylvemis a r. Mumner, The Raiph ht. Passens Co., New Yesk, New Yedt 4 N. Mises, Behseek & WEsea, Lynchburg, VirWeis nt F. Medessnee, Tsmeessee VeBoy Anthestty, Kneaves Temmenbas F.

• KMper, Weselsdouse Doctric Corp., Mttsburgh, Pennsytremia r M. E. Lasssses, U1 Atmeic Emery Come= dada =, Div. of Reacter Developenent & Tecteology Washington, DA D. G. Emer, Generd Doctdc Co., Ses Jose, Califonsis

• M. Asservuse, UA Atoads Enery ca==nada= Div. of Reester Stenderde, WM DC G. W. 3sedereery, Stome & Wetener Engineestas Corp., Rossen, u====ch==tte K. 4. asurer, consansers Power Cosapeny, Jacksam, Michismo 4 needer, Cossbestion Enyneering. Windsor, Connecticut D. S. Messer, Tennessee Valley Authority, Knoxville, Tennessee The Ad Hoe Cornenittee on PACKAGING, SHIPPING, RECEIVING, STORAGE & HANDLING OP EQUIPMENT inchaded the following personnel in the _._ .a of tNs standard.

A W. Neueno#, CWrrnes, Wesdagaan== Doctdc Corp., Mttstmgh, Pennsylvania

1. . D. EsAsrW, Secretary, Stone & Webster Engrg. Corp., Boston, Massachusetts W. Fasme, Babcock & WEcos Co., Seneca, South Caroline --'

L. A. Nerenne, Baltimore ces & Deerde Co., Balthmore, Maryland 4 M. Aserness, Niagem Mohawk Power Corp., Beftslo,New Yort

• m. O'Grusy, Phandelphia Doctde Ca, Pt,and.apad= rennsytremie

.7. O. masse, PeWie Servtos Doctric & Gas Co., Newart New Jersey W. #, Seefame, C====I Doctric Co., Sem Jose, California Vi

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TA8LE OF CONTENTS e

-"A SECTION PAGE -

1 INTRODUCTION E

.4 1.1 Scope...................................................... I 2 g

1.2 Applicabili ty . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I E

1.3 Responsibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 1.4 Dennitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i g -

1.5 Referenced Documen ts. . . ; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 7

_4_

2 GENERAL REQUIREMENTS g

2.1 Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 __

2.2 Procedures and 1- GMas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 s 2.3 Resul ts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3 2.4 Personnel Qualifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Ts 2.5 Measuring and Test Equipment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 4 2.6 Hcusekee' ; 3. . . . . . . . . . ................................... 3 3 2.7 Classifica.ui of items. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 =

9 3 PACKAGING 4

3.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2, 3.2 I.svels of Packaging. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 =

- 3.3 Cle anin g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 -

3.4 Me thods of Preservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 a 3.5 Caps, Plugs, Tapes, and Adhesives'. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.6 Barrier and Wrsp Material and Desiccants . . . . . . . . . . . . . . . . . . . . . . . . . . 6  %

_m 3.7 Contamers, Crsting and Skids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.8 Cushioning, Blocking. Bracmg and Anchoring. . . . . . . . . . . . . . . . . . . . . . . 7 9

3.9 Ma rkin g. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3

JEI a

4 SHIPPING S_

4.1 Ge neral . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 4.2 Transportation Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 M

N_ _

4.3 Precautions During Loading and Transit . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 -E 4.4 Identification and Marking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 4.5 Shipments From Countries Outside United States . . . . . . . . . . . . . . . . . . . 8

]

=-g 4.6 Nuclear Material Shipments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 M

.g 5 RECEIVING _i2 A

5.1 Gene ral . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 5.2 Receiving Inspection Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 m

5.3 Disposition of Received items. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 d

5.4 Status Indicating System. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 6 m

=

5.5 Correction of Nonconformances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 -

5.6 M arkin g. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0 2

5.7 Documen ta tion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 P

-==

vii = -

M w

TABLE OF CONTENTS (Cont'd) .

SECTION PAGE e STORAGE 6.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 6.2 Storage Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 1 6.3 Storage hthods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 1

~

6.4 Control of items in Storage. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 6.5 Rernovel of items from Storage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 6.6 Storags Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 7 HANOUNG 7.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 7.2 hthods and Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 7.3 Hoisting Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 7.4 Inspection of Equipment and Riging. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 7.5 Personnel . . . . . . . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 -

8 R ECORD8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 9 AMERICAN NATIONAL STANDARDS REFERRED TO IN THIS.

DOCUME NT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 r.

APPENOl X . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 r

D

men una.u-tm

=T .

s . .

PACKAGING, SHIPPfNG, RECEIVING, STORAGE AND HANDLING OF ITEMS FOR &

NUCLEAR POWER Pt ANTS

- - to.ia,m.c w

1. INTRODUCTION .

for establishing the applicable requimments for the actMties comed by this standed shot be identified 1.1 Seeps and the scope of their respondbelties shaE be This standard deSass .-

- ts for pack, documated. The work of establishing practices and aging, shipping, receMas, stornes, and handung og Procedums and guiding the moonross in terms of unclear power plant items. These items Pasonnel, equipment and services necemy to inn, incinde the perm of structures, sy mma, and Pi ement the s7' i of this standard may be components whose sadsfactory puformance delegated to other organiassions and sack daiegation -

is requked for the plant to operate reliably, also shat be documented. Hower, it is the se to prevent accidents that could cause undue sponsihiuty of each agsnization paforums wak.

risk to the health and safety of the public, camd by this standard to comgdy with the pro >'

or to mitigste the consequences of such ac. cedes and instructions innsed for the protect and to-cidents if they were to occur. The requirements conform to the requirements of this standard sp.

stated herein deal with the protection and contrag pucable to his wak.

necessary to assure that the requisite quality of those The following shau be und as a pide in de.

Important parts of the plant are preserved from the termining those responsibilities which shsE be es.

time items as fabricated until they are incorporated tablished and documented:

la the plant.

1. n ine. tion of items (protection level)

This standard is intended to be used la con- 2. Packaging desipiand methods junction with ANSI N45.2, Quality Assurance Pro- 3. Shipping requirements and methods -

grara Requirements for Nuclear Power Plants. The 4. Receiving squirements and methods requirements may also be extended to other ap- 5. Storage sev'..... eats and procedures propriate parts of rauclear power plants when speci- 6. Handling requirements and procedures fledin contract documents. 7. Records 1.2 Applicability 1.4 Definitions

.y. sv

-, r - - --

?

.4 The foHowing definitions are provided to as.

~. '

_ 1 u ,4 ..1_ z " --

sure a uniform understanding of select terms as they

. _- . _ . . _ m o. =- = rm .- . . ~ - are used in this standard.

= '- -

.' s

^ edissuesseinsuksession4+of- Barrier - A flexible material designed to with-M The extent to which the individual re- stand the penetration of water, water vapor, pense, or q=i its of this standard shall apply wiB depend harmful gases.

upon the natore and scope of the work to be per-formed and the importance of the item or service in. Carter- The transioiing agency.

volved.1he requirements are intended to assure that the quality of items is not degraded as a result of Cassiffcarion - The orgaruzation of items ac-

.PP i ng, mcorvms, stwage, and kdung cording to their susceptibility to damage during

• • ~- _

shipping, receiving and storage only. It dots not re-

- ~~

1.3 7,-

late to the function of the item in the com.

" t; pleted system.

The or Md or orgarnzations responsible Documenterion - Any written or pictorialin-I

PACKAGING, SHIPPING.RiCilVING. STORAGE ANO HANOUNG OP ITEtAS POR NUCt. TAR POWER PLANTE (Dwtas me censowesen Phemet ANSS W e dos describing, deGnies, specifying, sporting, f

Other terms and their definitions are con.

or cadfying actMties, sequimments, procedures or tained in ANSI N45.2.10.

results. .

pynende Loed Test - A test to demonstrate 1.3 Refonneed Desumene -

the abdity of hoisting equipment to safely handle its rated load by esercising the equipment througli ver*

Othu documents that are required to be in.

tical and horizontal movement along itslines of travel, cluded as a part of this Standard are either identified using aloed of specified weight. at the point of reference or described in Section 9 of -

this Standard.1hs issue or edition of the referenced

- The act of phyncany movingitems document that is required will be specified either at a macidowy, not including the point of reference or in Section 9 of this standard, transport modes.

Item - Any level of unit assembly, including 2. OgNgMAL RgGUIRgadgNTF sysum, abeysum, M,Pt,% w .

This section contains i: J  :- that are to .. t Ik- ,L.. - _e - A deficiency incharacter. be fulfilled by the organization or crysikada== re. ~

spoemble for performing any sepasst of work lede, documentation, or proceshire which renders the described in Sections 3 througit g of this amaderd.

quauty of an itent = ---f " or indeterminate.

Ezasopies of nonconformanos include: physical de. Measures shat be ==ahM=had and impl=maanted facts, test fallarse, incorrect or laad"P'am documen- for the packaging, shipping, receMag, storage and tation, and deviation from prescribed proossdag, handling of specified items to be '= y--2 la the '

inspection or test proceduses. - -

nuclear power plant, and for the '- . r-- , ex-a..da== testing and dar=amatation to verify con..

7behage - The shipping container plus the formance to specined s: . ' ~-

contents of the container.

7beAsse (Auft - Any ammamhly of mech aces 2.1 Mannist and/or electrical mmponents and parts which can b* The specific items. to be governed by this ' 1 disassembled without destroyag the integrity of the standard shau be identified. Planning shaR take into -

individual parts. account the need for the preparation and control of

. ~

Receiving - To take delivery of material at tlw pig"/ and work instmetions as necessary to constmetion site or other location designated by the comidy with specified ratoironwats. Planning shau .

purchaser. Include a review of the design specifications and Storage - The act of holding items at the con. dra% for the items mmed by tids standard to struction n.ts or in an area other than its permanent assure that packaging, shipping, recerving, storage, and handling activities have been incorporated and location in the ident.

that they can be accomplished as specified.

Storage Faceries - Warehouse or yard ares designated and prepared for holding ofitems.

2.2 Proemiurn and Insoundens 7hmsit Carrier (Open) - Trucks, Traders, Rail.

Procedures and instructions shall be generated, road cars, Berges. Aircraft, or Ships which do not pm.

vide protection ofitems from the environment. used, and maintamed current; these shau contain sufficient detan to provide for the listed items (see Deudt Grrder (Ciceed) - Trucks, Traders, Rau.

road cars, Berges, Aircraft or Ships which do provide Subsection 2.1 of this Standard) a basis for ~M design, shipping requirements, i-..-,, storage and protection ofiteses fross the environment by nature handling procedures, implementation thereof, and of their inherent dodge. Inspection,in accordmaca with this standard.

• 7heupersadow Mode- A methodidentified by the conveyance used for L y4ation ofitems and 2.3 Ramia includes any motor vehicles, ships, railroad cars, or Inspection and test resdits shall be documented aircraft. Each cargo carrying body (trailer, van, box. In a suitable test report or data sheet. Each report car, etc.)is a separate vehicle. shall identify the item to which it applies, the pro.

16hgr - A flexible material, formed around the cedures or instruction followed in performmg the 4-item or packass to exclude dirt and to fac31 tate task and the identification of the following:

handling, marking orlabeling. (1) Conditions encountered which were not 2 -

- - _ - _ _ . _ - - - _ - - - - - - - - - - - - -- ~

"!il!

h2

==

5 PACKAGING.aHIPPING. RECilVING.STORAGg ANO MANOt.ING OF ITEMB POR NUCLEAR POWEM PLANTS (DuHae me Censwwesen Ptrem> ANSI N48.12 1gn =

m andcipated, i.e., nag nonconformance. tural steel are classified as level D, the degree of pro.

(2) Identity ofinspector or tester. tection and control over the reactor vessel should C (3) Campistion date. exceed that of the structural steel, w eim _C Test reports and data sheets shau include an - ____ ,, j 1 ] ] j,- [ , p '"' -

1 ,

evaluadon of the acceptability of W-As and test _

, , g ,

- ^-

-;g results and provide for identifying the individual who "- -- . . r performed the evaluadon.

t manufacturer's documented standard or i" mmimum requ:rements shall be considered when _

dasafying the items. Items, once classified, shan be 2.4 Perecomel Qualincedons restdcted to the level or high'r for each of the peck. =5 D088 Pannel g, perfe * -ga=, ex. .ging, shipping, recetving, stoaags and handling opera. =

lminados or testing acekettise abhe job' site shall b* tions. Items shau not be classiiW &cw eg to the '

T'mHAnd in accordance welQH5.2.6, Off-site inspec. ,egtdroments of one level, then M dippd, tion, namiention or tesdng shall be audited and received, cered or han nad esw,Lg to a level of -M monitomt by personnet who are ginHAad in ac" lower grade. Any packap unit or ===-hly made up -A cordance wt* N45.2.6. of items of different levels shaR be clandfled to the _

highest level designated for any of the s.y Gw 2.5 Messestas and Test Egulpment. parts. If the unit is "- w,a a level dan be in- E 2.5.1 Selection. Inspection, enminadon, and dicated for each part. When the unit cannet be y tesdag equipament utaized to implement the require. physicaDy Me==== hied, special mies are contained herein.

monts of this standard shall be selected to have ac, _

Items covered by this standard shaR be categoe- -sg curacy and tolerance sufficient to determine coo.

formance to spectfied requirements. ized under the foDowinglevels:  ;

2.5.2 Calibration and Control. As appropriate, 2.7.1 Leved A - Itens classified to level A are those that are exceptionaHy sensitive to environ-3 a

measuring and test egdpmaat shall be adjusted and mental conditions and regdre special meness for -==

calibrated at presenbed intervals against certified equipment having known valid relationships to na. Protection from one or more of the foHowing efracts: 1 tionally i+ ---hi standards. lf no national standards temperatures outside required limits, sudden tem. -li exists, the basis for calibration shall be documented. Perature changes, humidity and vapors, gravitational __ -

Records shat be maintained and equipment suitably (g) forces, physical damap and airborne contamma-marked to indicate calibration status.

ti n (e.g. rain, snow, dust, dirt, salt spray, fumes). M Re following shall be used as a guide for 6 2.8 W ^ , .; classfying items intended for this level A**=*stion: ] -

In job. site areas, facilities, and environments (1) SPecial electronic equipment and instru.

mentanon. =

where pachsing, slupping, receiving, storap and -"

handling of items is performed in accordance with (2) Special matenals, such as chenucals that are the requiretrents of this standard, the housekeepmg sensitive to environment. q (3) Special nuclear material (fuel) and sources. q requuements shall be in accordance with N45.2.3.

he requirements of the AEC fuel license N and conditions and other governmental 2.7 Clasernsethon of items =

agencies shall be met.

Re requirements for activities covered by this S l

l standard (a-dr=-'ai shippmg, recetyms, storage and 2.7.2 t.evel B - Items classified to level B are d handling) ase divided into four levels with respect to those tnat are senstrve to environmental conditions -i

{

l protactive asesures to prevent damage, deterioration and require measures for protection from the effects of temperature extremes, humidity and vapors, g

]

4 l or contame== tion of the items, based upon the im.

portant physical charactenstics and not upon the im.

f rees physical damage and airborne contammation a portant functional characteristic of the item with and should not require special protection required _-

respect to safety, reliability and operation. It should for level A items. --

2 be recosmzad, however, that within the scope of each he fo'. lowing shall be used as a guide for level there may be a rany of controls and that the detailed requirements for an item are dependent on clasnfying items mien,!ed for tius level clasafication; g m

tk traportance of the item to safety or reliability. (1) Instrumentation For exampia even though a reactor vessel and stmc. (2) Electncal penetrauons =!!

5 3

-5 Mil d

-a y

PACKAGING. SHIPPING.MECEIVING STOMAGE AND HANOLING OF ITEaA5 POR NUCt. EAR POWER PLANTS 1Dwtes the Canameteen 8%e'd ANSI M48.2.2 1372 (3) Batteries 3. PACKAGING (4) Welding electrode and wire --

(5) Controlrod drives 3.1 General (6) Motor control centers, switchesar and con.

l'*IP88808 This section contains the requirements for (7) Motors and generators peckaging of items for protection against corrosion coritamination, physical damage or any effect which (8) Precimon machined parts (9) Erection spares, such as saskets,"O'* rings would lower the quality or cause the item to (10) Airhandlingfilters deteriorate during the time it is shipped, handled and (II) Computers stored. The degree of protection specified will vary according to storage conditions and duration, ship. I i

ping environment, and handling conditions. ,

l 2.7.3 Level C - Items classified to level C are Implementation of this packaging section is those that require protection from exposure to the accomplished by identifying the item and the ap.

environment, airborne contaminants, 3 forces and propriate packaging level, and then applying the ap.

physical damage. Protection from water vapor and propriate criteria contained herein concerning clean-condensation is not so important as that for f.evel B ing, preservatives, deaccants, inert gas blankets, items. cushioning, caps and plugs, barrier and wrapping The followmg shall be used as a guide for materials, tapes, blocking and bracing, containers,

, c!assifying items intended for this level classification. marking, other quality assurance provisions and documentation. Appendix A 3 contains additional -

(1) Pumpe requirements generally not availabic in other docu-(2) h ments. These requirements are a mandatory part of -

this standard.

(3) Fluid filters (4) Reactorinternals (5) Compassers 3.2' Levels of Paskasing (6) Amdiary Turbines -

(7) Instrument cable The packaging mquinnwnts are based on the (8) Refueling equipment Protection the items should receive during sidppms, -

(9) 1hermalinsulation handling, and storage. The requirements of this (10) Fans and blowers standard are intended to be in addition to industry (11) Cement classifications or tariff rules for rail, truck, air and -

water shipments and regulatory agency rules already established in the transportation industry and in no 2.7.4 t evel D - !! ems classified to level D are way are they intended to reduce the muumum stand.

diose that are less sensitive to the environment than ards established by these regulatory apacy rules.

level C. These items require protection against the The following packaging criteria are divided elements airborn contamination, and physical damage. into four levels corresponding to the catesones of The following shall be used as a guide for Subsection 2.7 of this Standard.

classifying items intended for this level classification. O 3.2.1 Level A Items. (See paragraph 2.7.1).

Level A items require the highest degree of protection -

(1) Tanks and shall conform to the following criteria: -

(2) Heat exchangers and parts (1) Package design requirements are for extra-(3) Accumuletors ordinary environmental protection to avoid m (4) Demoneralizers the deleterious effects of shock and vibra-(5) Reactor vessel tion, to control temperature or humidity (6) Evaporators within specified limits, or for any other (7) Steam generators special requirements.

(8) Pressurizer (2) Items shall have been inspected for clean-(9) Piping ness immediately before packaging. Dirt, oil (10) Electrical cable residue, metal chips or other form of con- C (11) Structuralitems tamination shall have been removed by ap.

(12) Reinforcing steel proved cleaning methods. Any entrapped (13) Aggregates water shall have been removed.

4 -

P ACK AGI NG. 3 HIPPING. R E CElVI NG. 3 TOR AG E AND HANDLING OF ITEhes POR NUCt.EAM POwgR PLANTS tourlag me conewwetten Phame6 ANSI N45.2.2-tg72 (3) Items which are not Immediately packard not penetrate to the item.

shag be protected from contamination. (3) Items subject to detrimental corrosion, (4) AB items shall be packapd with a barrier either internal or external,shau be suitably (see Subsection 3.6 of this Standard) no protected.

that water vapor, salt air, dust, dirt and 3.2.4 other forms of contarmaation do not pene- Lowl D Items. (See paragraph 2.7.4)

Level D items require protection from physical and trate the packap. -

(5) Items shall be packapd in containers or mechanical damap.The foHowingcriteria shall apply:

crates (see Subsection 3.7 of this standard). (1) Items, just before packaging, shall have (6) Items which can be damaged by con. been inspected for cleanness according to densation trapped within the packap shall the requirements a-N in the r c.nas be packaged with approwd desiccant (see document. Dirt, oil residue, metal chips or paragraph 3.6.3) Indde the sealed water. other forms of contamination shan han vaporproof barrier or by an equivalent been removed by approved cleaning meth-method (for example, see paragraph 3.6.2). ods. Any entrapped water shaR have been (7) All openings into items shau be capped, removed.

plugyd or sealed (see Subsection 3.5 of (2) AB opening into items shaR be capped, of this standard). Weld end preparations plugged and sealed (see Subsection 3.5 of shan be protected against corrosion and this standard). Weld end preparations shan physical damage. be y,ated frons corrosion and physical (8) Items pecked in containers shall be blocked, damap.

anchored, braced and/or M'-a-f (see (3) Items subject to detrimental correalon, Subsection 3.8 of this standard) to prevent- either intamal or external, shall be suitaldF physical damage to the item or barrier. protected.

(9) Items and their containers shall be identi- (4) Items packed in containers shan be blocked, Ged by marking (see Subsection 3.9 of this braced and/or cushioned to prevent physical standard). damay (see Subsectiour 3.8 of this Stand-3.2.2 Level B ltems. (See paragraph 2.7.2) ard).

IAvel B items require a high degree of protection and (5) Items such as aggrepts and reinforemg the packap shan be designed to avoid the deleterious stal shan be asitably protected against efTects of shock, vibration, physical damap, water detdmentalcontarninedca w h vapor, pait spray, condensation and weather during (6) The identity of the item shaR be main-shipping, handling and storay. This packaging shau tained by marking (see Subsectka 3.9 of be equivalent to that for-Ievel A except that the ex. this standard) m other appropdata means-tremes of parapaph 3.2.1 (1) need not apply. Ievel B 3.3 ceaning items such as control panels or umilar specialitems Cleaning includes the preparation ofitems for may be slupped with a muumum of protection when preservation or packaging, or both, to mmmuze the transported in a fully enclosed furniture type van requirements for site cleaning. Items shall be in-with special suspension, provided the shipment goes spected for cleanness immediately before packasing through to destination in the original vehicle and accordins to the cleaning,reouirements specified m Level B storage facilities are available at the site.

the purchase document. Any dirt, oil residue, metal chips or other forms of contamination shall be re-3.2.3 Level C ltems. (See paragraph 2.7.3) moved by documented cleaning methods. Any en-IAvel C items require protection from exposure to trapped water shall be removed. Any item wtuch is salt spray, rain, dust, dirt, and other airborne and not immediately packapd shan be protected from windblown contaminants. Protection from water further contammation. (See Appendix section A3.3 vapor and condensation is less important than for for additional requirements.)

level B items. The following criteria shall apply:

3A WM M hetion (1) Criteria (2) (3) (5) (7) (8) and (9) for level A items (see paragraph 3.2.1) shall items subject to deleterious corrosion shan be apply to Ievel C items. protected by using either contact preservatives, inert (2) Items shall be packapd with a waterproof gas blankets, or vapor. proof barriers with desecants.

enclosure so that water, salt spray, dust, (See Subsection 3.6 of this standard for vaporproof dirt, and other forms of contamination do barriers and desiccants.)

5

h PACKAGINO. SHIPPthvG. RECElvt NG. STOR AGE AND HANOUNG OF ITnas FOR NUCt. EAR POWER Pt. ANTS (owas = caanutwa mee6 ANSI N48.2.2-1372 14.1 Contse Preservatives. Contact preserva- itic stainless steels, shall be noncorrosive, shall not tives are compounds applied to bare metal surfaces to readily support combustion and shall not be other.

prevent narface corromon during shippmg and storage wise harmful to the item packapd. Vaporproof and pnerally require removal prior to installation. barrier materials used with desiccants constitutes (See Appendix section A3.4.I for additional require- another preservation system (see Subsection 3.4 of ments.) this standard); it protects against potential damage 14.2 Inert Gas Blankets. Purging and pressur-izing the interior of an item or its container or both 16.1 Water-proof Barrier Maserial. Waterproof '

with a dry inert gas provides a means of preventing barrier material shau be resistant to grease and water; moisture or corroerve atmospheres from acting on it shall protect items from airborne and windblown sensitive bare metal airfaces or other matenals. The soils, item or its contamer shall be either evacuated prior to filling with the inert gas or adequately putyd with 16.2 Vapor 8arrier Meterial. Vaporproof bar-the same gas price to applying the gas blanket. rier materials shau be sealable and the edy of the (See Appendix section A3.4.2 for additional re- banter which normaDy will be opened at destination quirements.) shau be of sufficient area to permit at least two subsequent sealing operations. (See Appendtx A3.6.2 E Cape, Phags. Tapes, and h for additional requirements). -

16.3 Desaccants. Desecants may be used with-These items shall be of materials which enable them to perform their intended function adequately in a uporproof banier when condensadon a high without causing deleterious effects on items or sys- humidity could damage an item by corrosion, mold, tems opundon.

or mildew. (See Appendix A3.6.3 for additional re-quirements).

15.1 Caps and Plugs. Caps and plugs shall be used to seal openms: in items having sensitive in-ternal surfaces, and to protect threads and weld end preparations. (See Appendix section A3.5.1 for ad- 17 Contamrs Crating and Skids -

ditional requirements.) 3.7.1 Containers. Containers are used when 15.2 Tapes and Adhesives. Pressure sensitive, maximum protection for the item or its barrier is re- -

removable, tape should be used in lieu of adhesives quired. Domestic types used shau be beted to:

in contact with bare metal surfaces. Tapes or ad- (1) Clested, sheathed boxes (500 lb maximum hesrves which could have damaging effects on the net weight). ~

Item or system shall not be used. Tapes near a weld (2) Nailed wood boxes.

shall be removed completely immediately prior to (3) Wood. cleated solid fiberboard boxes.

performing a weld or closure. Tapes used for identi- (4) F berboard boxes (120 lb maximum net fication rather than sealing which are not near a weight. See Appendix A3.7.1 for additional welding operation may remam until system testing. requirements).

(See Appendix section A3.5.2 for additional require- (5) Metal or fiber drums.

mnts.) (6) Crates (see paragraph 3.7.2).

(7) Wire bound boxes (200 lb maximum net 18 Barr6er and Wrap Meterials and Deelecents weight).

(8) Other specially designed contamers for A barrier generaDy is a flexible material de-signed to withstand the penetration of water, water 'F****I '9"'P""

vapor, grease, or h=nnful gasse. A wrap is a flexible Cleated boxes in excess of 50!b shau be bound material, formed around the item or package to ex. with steel strappmg or equivalent around the con-clude dirt and to facilitate handling, marking or tainer at not less than two places. (See Appendix labeling. Matenal thickness shall be selected on the A3.7.1 for additional requirements.)

basis of type, size and weight of equipment or item to be protected, such that the barrier or wrap will not 3.7.2 Crates and Skids. Crates and skids shall casdy be damapd by puncture, abrasion, weathering, be used for equipment m excess of 500lb. Skids and crackmg, temperature extremes, wind conditions, and runners shall be used on boxes with a gross weight of the like. Barrier and wrap matenals shall be non- 100 lb or more, allowing a minimum floor clearance halognated when used in direct contact with austen- for forklift tines as provided by 4 inch lumber.

6

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PACKAGING. gHt PP1NG. RECEIVING. 5 TOR AGE AN D __

MANOUNG OF ITEh48 FOR NUCt. EAR POWER Pt. ANTS tDurme the h w ANSI N44.1.2-1972 m w

3.8 Cushioning, Steeldne, Greeing and ^ M4 4.2 Transportenen Requirements j

! 3,8.1 Cushioning. Cushioning shall be used where protection from shock and vibration is re.

4.2.1 Open Carriers. For shipment on open canien where items may be exposed to adverse s -

quired; the cushioning materials shall have sufficient environmental conditions, the following shall apply:  %

strength to perform this function. (See Appendix AJ.8.1 for additionai requirements.)

(1) level A, 8, and C items shall be covered for protection from environmental con.

Y E 3.8.2 Blocking and Bracing. Blocking and ditions. Tarpaulins, when used, shall be fire A.

bracing used for protection of the load to be sup. retardant; a:d they shall be installed in a

'e_n ported, shall be compatible with the size, shape, and manner to provide drainap and to msure -g strength of bearing areas of the shipment. The air circulation to prevent condensation. O blocking and bracing used to prevent item move. (2) Barrier and wrapping materials (see Sub.

• ment shall withstand thrust and impact applied in section 3.6 of this standard) subject to ]

any direction. mahs and bracing used in direct transportation damap shall be covered i-contact with the item being blocked shall not have a with waterproof shrouds such as tarpaulins. -\

corroadve effect on the item. so that they are not exposed directly to the -

'"'I'""'"'"'-

3.8.3 Anchonne. Anchoring of the item with. -

in a crate or on a sidd shall adequately fasten the 4.2.2 Closed Carners. For shipment on closed 5 Item during shipment and protect the item from carriers the following shan apply: --

Potential damage due to rough hand!!ng.To facilitate disassembly and minirnize damap when removing (1) When level A, B, and C items cannot be ~

E container contents, bolting is preferred. (See Ap. adequa@ protected 6n weather a en. -

pendix A3.8.3 for additional requirements.) Tem. vironmen on OPen carriers, closed carriers -

g Porary cualda-ig, blocking, bracmg or anchoring --

placed within an item for shipping protection that (2) Use of fuHY enclosed furniture vans is recannwnded h shipping large hte

=

w must be removed prior to operation of the item shan be identified by warnmgs placed in a con. inms mch as contml A --

spicuous manner to effect proper removal of the 4.2.3 Special Shipments. Items that exceed =l packing material. established weight or size limitations for railroads or 'E 3.9 Meridng highways, or require special handling should be q given additional conaderation in the following areas: a To maintain proper identification and instrue. (1) The type of bracing and tie down rnethods $

tions or both during shipping, receiving and storay, to be used with the rnode of transportation ==

and to provide for identification after the outside of selected for special shipments shall be ._ ;;

the contsiner has been removed, tne item and the specified. _

outside of containers shaB be marked. (See Ap. (2) "NO HUMPING" shall be specified on rail 6 pendix 3.9 for additional requien.e ts.) shiprnents of these items, and "NO HUMP.

ING" signs shall be prominently displayed.

5 7

l 4. SHIPPING * * * * * " I '"' "

l specified on shipments of heavy or rela- ____

l g tively lary items incorporating delicate -I factory installed instrumentation. Meters, --_

This section covers the requirements for loading when specified, shall be installed prior to ,

and shipment of items as defined in Subsection 2.7 loading (to record any rough handling cf this standard. Described are environmental pro- during loading). Procedures shau be estab. -2 tection during transit, procedures to mimmize damsp lished to interpret recorded data, and to Q in transit, precaution required when handling items thoroughly check the integrity of an item M during loading and transit, and identification and in. when there is evidence of rough handling. Z_'

spection on overseas shipments.

The mode of transportation used shall be con.

A notice that impact recording meters are 7 being used shall be prommently displayed. 5 sistent with the protection clasafication of the item Special recording meters with operating -!E (see Subsection 2.7 of this standard) and with the time limits greater than the expected transit 72 packaging methods employed (see Subsection 3.2 of g

l this standard).

time shall be specified or, if the expected transit time exceeds the operating time 7 7

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PACS (AGINO. SHIPPING. RECEIVING. STOR AGE AN D

']1 HANOt.ING OP ITEMS FOR NUCt. EAR POwtR Pt. ANTS IDWas me canem,eeen Pneemt ANSI N46.2.2-t972 4

9 M

i) limit of the recorders being used, pro- all peckaps, sidds or protectim cowring shan be -

I visions shall be made to service the meters maintained in accordance with Subsection 3.9 of N il during transit.

(4) The use of " Escorts" may be specified to this standard. M

'Rd EP accompany shipments,when additional sure 4B Shipments From Countries outsideUnited States "

veiBance is required during transit of certain n

(5) special ship.nents, the conveyance used

for transport shau be certilled to be strue. ments sreinvolved cargo fa all be avoided unless necessary due to physical dimensions. 2 loodas, en r d g Shipments utilizing approwd watertight contamers

unloading. Prior to shipment the route **I *** * *" **I* -

shall have been investigated to assure safe i traadt.

4.5.2 Inspection at Point of Shipment. For special shipments, items shall be inspected to insure M_  ?

integrity of packaging or protective enciceares after =

4.3 Preenetione Dwing Landne and Transit beingloaded aboard ship.

2 4.3.1 Loading. The weight, lifting points, or center of pavity indicated on the crate, skid, or 4.5.3 Inspection at Port of Entry. For special E shipments, items aball be inspected to insure integrity g

!_ packass by the shipper (see Subsection 3.9 of this of packaging or protective earla==res when items are  ;;- -

standard) shall be utilized to insure proper handling offloaded at the port of entry.

during loeding, transfer between carriers, and un- 4 loading (see Section 7 of this standard). 4.5.4 Identification and Markings. Identifica - N hW p Ad foHow $s outhned' -

4.3.2 Rigyng. Carbon steel rigging equipment in Subsection 3.9 of this Standard. The Englists-shall not come in direct contact with stainless steel languay and avoerdupois weight shall be used for au g

except when attached to lifting lup, eyes, or pads,in identification and maridag. Duplicate maridags and

-3 order to avoid surface damap.

q identillcation in other lanpages or weight systems - N 4.3.3 HandlingPrecautions. Allaustenitiestnin- **I

• lees ttaal and nicket bene alloy materials shall ha 4.5.5 Transportation Requirements. Require-handled in such a manner that they are not in con. ments outlined in Subsection 4.2 (Transportation) a tact with lead, r.ine, copper, mercury, or other low and in Section 7 of this Standard shau be followed I

meitleg elements, aHoys, or halopnated material. 6 where applicable.

g 4.3.4 Package / Preservative Costings. Packaps and/or preservative coatings shdl be visually in. 4.6 Nuclear Meeprial Shipments M

_g spected after loading, and damaged areas repaired Special nuclear material and sources shall be prior to shipment. Items shipped with desiccants shah be inspected after loading to assure that sealed shipped as specified in the AEC fuellicense and by areas are intact.

other regulatory apncies.

g._

4.3.5 Sealed Openings. Sealed Openmes shall be visually inspected after loading to assure closures 5. RECEIVING A are intact. Materials used for ressaling shall be in g -

accordance with Section 3 of this standard. 5.1 General q 4.3.6 Stacking. Written instructions coverms This section contains requirements that are to -1!!E the location and =*=cidaglimits of the crates or boxes on the transport whicle shall be specified; these be fulfilled by the orgaruzation or orgamsations re-sponsible for the receiving of items. Receiving starts E-should be marked on the container, when the items arrive at a storage facility or construe.

'I " * " d '#8 '"n "

4.3.7 Theft and Vandalism. Precautions shall Procedures, inspections, markm. PacWg. and Inchaded am be taken to miaimize the possibility of theft and g, identification vandalism during shipment ofitems. documentation prior to placing the item m storage or M

directly in its ilnal location. Shipping damap claims.

4.4 Idensf 'sasiese and Merking tr888f*f f *Mrdi ,Pfinancial responnbility and =ni=

contractual obligations are commercial obligations -6 ,

Identification and markings on the outside of which are not included in the scope of this Standard. -*=

y 6

J 4_i

.J PACKAGING,SHIPPl% RSCSIVtIte.5TORAGE A88EF ggg,

, HA40SLaseSOFITEnds POR NUCt.1AR POWER Pt. ANTS (Dwtae the ceaewuswee emese6

= that conting and preservatives are applied 5.2 Rossising lesposaien Respurements E2.1 Shipsang Damage lnspection. Preliminary in accordance with specifications, purchase dn a mandacte instrucdons, visual inspecdos or examination shau be performed r prior to unloading to determine if any damage oc- (5) Inert Gas Blenket - Verification that the curred during shippeg. Observations for unusual mert gas blanket pressure is within the ac-ceptable limits.

conditions shallinclude:

(6) Desiccert - Verification that the desiccant (1) Fire - Charred paper, wood or paint, m.

• s not saturated, as indicated through the dicating exposure to fire or high tempera- use of humidity indicators. Desiccants shall ture. be regmerated or replaced as necessary in (2) f.xcessire Exposuse - Weather beaten, fray- accordance with specialinstructions.

ed, rusted, or stained containers indicating (7) Mtysical Domese - Visual inspection to as.

Prolonyd exposure during transit. sure that parts of items are not broken, (3) Environmentaf Damese - Water or oil cracked, missing, deformed or maaligned marks, damp conditinns, dirty areas, o' and rotating parts turn without binding.

salt f9a (indicating exposure to sea water Accessible internal and external areas shall or winter rood salt chemicals). be free of detrimental gouges, dents, (4) 73e Domse FeiAue - Sinifted, broken, loans scratches and burns.

or twisted shipping ties, and wom material (8) Caminess - Visual inspecdos to assure under ties, indicating improper blocking and that accesabler internal and external areas tie down during shipment. are within the specificados yta . 4 (5) Rough #merg - Splintered, torn, or for dirt, sou, mill scale, weld splatter, od crushed containers indicating improper grease, or stains. If inspecdos for h, handling. Review of impact recording in- was performed prior to sealing and ship strument readings. ping, and inspection upon receipt indicatae 12.2 Item inspection. Unless the package that there has been no penetration of the marking prohibits unpacking, the content of alt ship, sealed boundary, then-inspection for in-ments shall be visually Inspectea to venty that the ternal cleanness is optional, specmed packaging and shippmg requirements have Unless the completed item was IWM or ex.

been amntained. When items are contained in trans- amined at the source, it shah be inspected or ex.

parent separate moisture. proof bap or envelopes, amined at the point of receiving to verify that the visual 'nspection without unpacking the contents is following characteristics conform to the specified acceptable. Statistical sampling methods may be used requirements. These inspections or exammations shall for groups of amtlar items. Care shall be taken to include such items as:.

avoid contammation of the items during inspection. (1) Mrpical N -h that phyd-The inspections shall be perTormed in an ares cal properties conform to the specified re-equivalent to the level of storage requirement for the quirements and that chemical and physical item (see Section 6 of this standard). These inspec-test reports, if required, meet the require-tions and examinations shan include the following as appropriate: g , ,

(1) /dentiffunos and Marking. Verification assure that impuaant almennons cormmn that identification arid markinp are in ac- wita drawiny and specifications. Examples cordance with applicable codes, specifica- are: ease pmfe mounttng holes, oversa 4x-tions, purchase orders, drawing, and this ternah nmanc configussaios aus.ortsstatica-standard. os pertas.

(2) Manufacaning Documenterion - Assurance (3) Werd heparerfons - Random venfication c that the item received was fabricated, tested that weld preparations are in accordance and mspected prior to shipment in ac- with applicable drawings and specifications.

cordance with applicable code, specifica- (4) Workmanship - Visual inspection of ac-tion, purchase order and/or drawings. cessible areas to assure that the workrran-(3) hosection Covers med Seefs - Visual in- ship ts satisfactory to meet the intent of -

spection to assure that covers and seals the requirements.

meet their intended function. (5) Lubncants and Oils - Venfication of pres-(4) Coervrrr and heserrenres - Verification ence of proper lubricants and ods, if re-

PACKAGING, SHIPPtNG. RECEIVING, $70 RAGE ANO HAMOufte Gd'ITDAB POR NUCLEAR POWER Pt.AMTSHtNeme me ceaewvetion ens ) AN38 Nd8.2.2-1yrt quired, try either specincation, purchase correction of the nonconformance. When tags are order, or manufacturers' instructions.

used the stock shall be made from material which (6) E!aemiced Insuladoso - Performance of in- wd! not deteriorate during storage; tags shall be station resistance testa for motors, genera- securely afRxed to the items and displayed in an ares tors, control and power cable, to ensure that is readily accessible. The stock used shaR not be conformana with specifications. deleterious to the item.

p -

12.3 Special Inspection - Where receiving in-spection in addition to that described above is re- 15 Coneeen of ' ~ , - ---

quired, the "Special !nspection" procedure. complete with Mwaantation instructions, shall be attached Items designated nonconforming or unaccept.

able for installation or use shall be corrected unng t3 the item or contamer (see Section 3 of this authonzed procedures, to meet specified require-standard); this is in addition to the copy sent ments, or accepted "As is". If this is not possible, the through normal channela. The specialinspection shall

~

item shall be scrapped or otherwise discarded.

be performed and the results of the inspection shall be docunwnd 5.5.1 Reinspection - Items that have been corrected shall be W.+cted. The area ofinspection g g, may be confined to the area of the nonconformance.

5.3.1 Acceptable - Containers and items in- When it has been determined that the corrected item is satisfactory, the status of the item as spected or exammed and found in conformance with specified requirements shall be identifled u ac- denoted by the system shaB be changed to ac-ceptable. An appropriate entry shall be made in the ceptable in accordance with the status indicating sys-w.um,etation after acceptance is determined.

tem .mykyM (see Subsection 5.4 of this standard) and placed in a storage area for acceptable items or 5.8 Merking moved to the final location for installation or use.

13.2 Nonconforming - Items which do not Required markmg shall be verified to provide conform to the specified requkements shall be pos tive identification during receiving, storage, and identified as nonconforming in accordance with the instaBation. Items not properly identifled at receiving system employed (see Subsection 5.4 of this stand" may be marked using the method in the appendix '

(see Appendix A 3.9 of this standard).

ard) and when practical the item shall be placed in a ..-

Changing, correcting or any other marking on segregated storage area or removed from the project Code Stamp name plate is prohibited, unless author-Kte to prevent inadvertent installation or use.

ized by the manufacturer whose serial number is 13.3 Conditional Release - If the noncon- applied.

formance which caused the item to be clasuiled

" unacceptable" can be corrected after installation, SJ Documentake, the item may be released for installation on a con-A wntten record of the receiving inspection, ditional release basis. A statement documenting package identification, taggmg, corrective actions, and the authority and technical justification for the con- justification for conditional acceptance shall be pre-ditional release of the item for installation shall be pared. These records shall be made a part of the prepared, and made part of the documentation. permanent records provided for in Section 8 of this standard.

LO Stense indlesting System l

A system or method for identifying the status .

of items (e.g. an inventory system, taggmg, labeing. 6. STORAGE color code) shau be employed that clearly indicates whether items are acceptable or unacceptable for in- 6A General stallation. A controued phyncal separation is an ac- 6.1.1 Scope. This section contains require-ceptable equivalent method. The system shall in- ments that are to be fulfilled by the organization re.

dicate the date the item was placed in the acceptable sponuble for performmg the storage of items. Levels or unacceptable instaBation status. The use of the sys. and methods of storage necessary are def'med to tem shall be regulated by the Quality Control pro- nummtze the possibdity of damage or lowenng of gram. The system shall provide for the conditional re- quality due to corronon.contammation detenorsuon lease of items for installation pending subsequent or phyncal damage from the time an item is stored 10

.. . . - ~ . . . .. _ . .. .. __ .. . _ _

Rm eum m

m m

- -t PACK AGING. SHIPPING RECEIVING. STOR AGE ANO HANCLING OF ITEMS FOR NUCLE AR POWER PLANT 3 touring tne Construction Phase) ANSI N45.2.2-1972 ,

upon receipt until the time the item is removed from storage areas yh ' be contro"ed and limited only to ___

storage and placed in its final location. personnel designated by the responsible organization. g 6.1.2 Levels of Storage. Environmental con- 6.2.2 Cleanliness and Housekeeping Practi,ces. U]

ditions for items classified as Levels A, B, C, and D, Cleanliness and good housekeeping practices'sha14be w enforgeLit, all times in the storage areas. The storage ~

4 described in Subsection 2.7 of this Standard shalf meet requirements as described in the following areas gh211)be cleaned as required to avoid the ac-paragraphs:

cumulation of trash, discarded packaging materials g (1) Level A items UGI be stored under special and other detrimental soil. A*

conditions similar' to those described for 6.2.3 Fire Protection. Fire protection com- -

mensurate with the ype of storage area and the -==

12 vel B iterns but with additional require-ments such as temperature and humidity material involved shjal be provided and maintained. _q control within specified limits, a ventilation 6.2.4 Storage of Food and Associated items. hi system with filters to provide an atmos- The use or storage of food, dnnks and salt tablet _-"

phere free of dust and harmful vapors, and dispensers in any storage area any other appropnat: requirements. w.- sh.dl h be permitted. g 6.2.5 Measu s to Prevent Entrance of Ani- ,

(2) Level B items shall$be stored within a fire mais. Measures shal be taken to prevent the entrance -

resistant, tear resistant, weathertight, and -

well ventilated buildingjor equivalent en. of rodents and'5 er animals into indoor storage closure. Precautions shan be taken against areas or equipment to minimize possible contamina- g vandalism. This area shd be situated and tion and mechanical damage to stored material. g constructed so that it will not be subject to -=

flooding; the floor'shalfbe payed or equal, -'

and well drained. Items sh4ll)e placed on pallets or shormg to permit ur circulation. 6.3 Storage Methods

==

The area shail(bc provided with uniform St rage methods and proceduresgs comply heating 2nd-~ temperature control or its with the requirements described in hie ollowing q equivalent to prevent condensation and corrosion. Mimmum temperature"sEQe paragraphs. ]

40 F and maximum temperature sh.dl.be 6.3.1 Ready Access to Stored items. Allitems T

140 F or less if so stipulated by a manu- Mbe stored in such a manner as to permit ready 5

facturer. access for inspection or maintenance without ex- 9 (3) Level C items h be stored indoors or cessive handling, to minimize nsk of damage.

r equivalent with all provisions and require- 6.3>2 Arrangement of items. Items stacked for __--

ments as set forth in Level B items except be arranged so that racks, cribb.mg or 5' f*E' -

l that heat and temperature control is not crates are ating the full weight without distoruon l required. f the item.

l (4) Level D items may be stored outdoors in an area marked and designated for storage, 6.3.3 Storage of Hazardous Material. Hazard- _

4 which is well dramed, preferably gravel ous chemicals, pami solvents, and other materials i co"ered or paved and reasonab!y removed of a itke nature be stored in well ventilated ]9 from the actual construction area and areas which are nli m close proxinuty to important f trafTtc so that possibility of damage from nuclear plant items.

l d

l 4t ction equipment is mimnuzed. Items shall be stored on enbbmg or equivalent t tamers .

)

6. .L dentification. All items and their con-be piamly marked so that they are ]

anow for air circulation and to avoid trap- iNnEtted without excessive handling, or un- c6 eas --

pmg watu. necessary operung of crates and boxes.

6.3.5 Coverings. Weatherproof covering, whe 6.2 Storage Areas -

used for outdoor storage, shai/ bed, . e-resistant type Pen. o dic mspections Y ' be performed t of sheeung or tarpaulms. They h:2 e placed so as to E assure that storwe areas are bemg maintamed in ac- provide dr un age and to msure ir circulanon to 7 cordance with these requirements. ine housekeepmg mmi ize condensation. They shd be tied down to E requirements be m accordance with N45.2.^ prevent motsture from entenng laps and to protect E "'

6.2.1 Access to Storage A re as. Access to the coverings from wmd damage. =

11 de M

M

PACKAGING, SHIPPING RECEIVING. STORAGE AND HANDLING OF ITEbeS FOR NUCt. EAR POWER Pt. ANTS (ourine ene conevruction ensee) ANSI N46.2.2-1372 g,4 CestusmHulettsbassesy (7) The shafts of rotating eWua shad be.

Control of items in storage is described in the r tated on a periodic basis. The degree of fouowm8 Paragraphs. tum shall be established so that the parts receive a coating of lubrication where ap.

6.4.1 Inspections and Examinations. Inspec- plicable, and so that the shaft does not i

tions and examinations shall be performed and come to rest in a previous position. (90 deg.

documented on a periodic basis to assure that the and 450 deg. rotations are examples.)

integnty of the item and its container as provided for (8) Other maintenance requirements specified under Section 3 of this standard is being maintained. by the manufacturer's instruction for the Deficiencies noted shall be corrected and documented. item shan be performed .

The characteristics vertfled during this inspection or .

exammation shau inc ude such items as: 6.4.3 Post Fire Evaluation. In the event a fire should occur in the storage area or at any time, each (1) Identification and marking (see Subsection item known to have been heated to an ambient 3.9 of this Standard). temperature of over 150 F or subjected to smoke (2) Protective covers and seals (see Subsectiort contamination than be withheld from installation or 3.9 of this standard). use until it has been thoroughly examined and the (3) Coatings and preservatives (see paragraph 3.4.1).

item has been verified to be in conformance with specified requaements.

(4) Desiccants and inert gas blankets (see para-graph 3.6.3 and 3.4.2). 6.5 Removed of Isome from Storego ,

(5) Physical damage. Only items which have been inspected and are (6) Cleanness, considered acceptable for installation or use in ac-cordance with the receiving tnspection procedure 6.4.2 Care of items. Care of items in storage shall be removed from storage for installation or use.

shall be exerased in accordance with the followins (See Section 5 of this standard.) Items released from ,

Requirements for proper maintenance dunng storsy storage and placed in their final locations within the shan be documented and written procedures or in- power plant, shall be inspected and cared for in structions shall be established. accordance with the requirements of Section 6 of this (1) Items m storage shall have all covers, caps, standard, and other applicable standards.

plugs or other closures intact. Methods 6.6 Storage Records used to seal openmgs shall be in ac-cordance with Section 3 of this standard'. Wntten records shall be prepared that include such pertinent information as storage location, in-Covers removed for intemal access at any time for any reason shall be immediately spection results, protection, and personnel access. S replaced and resealed after completion of the purpose for removal. 7. HANDLING -

(2) Temporary preservatives shall be left intact 7.1 cenerse dunng storage. Should reapplication of This section contams requirements that are to -

preservatives be required at the site, only  ;

those previously approved shall be used.

be fulfilled by the organizations responsible for (3) Items pressunzed with inert gas shall be handhng items. This section covers the requirements '

for the handling of items in Subsection 2.7 of this morutored at such a frequency as to msure  :

that the gas pressure is maintained withm standard utilizmg appropnate equipment in accord- -

specified limits dunng storage. Desiccant ance with methods and procedures specified to -

humidity indicators shall also be monitored mmirmze damage and preserve the quality of the j and desiccants shall be changed or re- item and contamer. '

[

=

processed when specified. 7.2 Methods and Procedures (4) Instrumentation racks shall be energized as Detailed handhng mstructions and procedures specified by the manufacturer. shall be prepared for all items that require special _

(5) Space heaters enclosed tn electncal items handling mstructions because of weight, size, suscep- 4 shall be energized. tibility to shock damage. high nti ductdity transition (6) Rotatmg electncal equipment shall be given temperatures, or any other condiuons that warrant j insulacon resistance tests on a scheduled special mstructions. Such mstructions or procedures -

basis, shall be made available pnor to the time the item is to 12 9

2 L _ _ _ . __ _ _ _ _ _ _ _ _

PACKAG3NG, SHIPPING. RECflVING, STORAGE AND ANSI 6 m HANOLING OF ITEMS FOR NUCLEAR POWER Pt ANT 5 (Durtae tne caneerwe6en Phase 6 be handled and shat Wye weights, sling locations, 7.4.2 Hoisting equipment that does not meet balance points, methods of attachment, maximum manufacturer's specifications shall not be used.

hoist line speeds and other pertinent features to be 7.4.3 Equipment and rigging shaR be kept -

considend as necamery fa safe handung, clean and free of contaminants that are detztmental Items not specif1caDy covered above shau be to the material being handled-handled in accordance with sound material handling practices. 7.4.4 Rigsms items such as hooks, shackles, and turnbuckles that appear to have yielded or are 7.3 Hoiedng Espsiement distorted shau not be used.

AG equipment for handung items shau be used 3 and maintained in accordance with the fouowing:

1he responsible organisation shaR determine 7.3.1 Hoisting equipment used for handling 6at 6e in openths maurh!

shaE be certified by the manufacturer. The certifica- hadHng $pt us w..W ad how h dos shaR indicate se vanous paranstors fw es strated satisfactory abatty in operedng similar Efting maxhnum load to be handled.

7.3.2 Hoisting equipment shan not be loaded beyond its rated load, as certified by the manufac- S. RECORDS turer, except for test purposes.

Record copies of ea==piaamd procedores; re- .. .

7.3.3 The requirements of ANSI B30.2.0' p a u , W M M m et W Safety Standard for Overhead and Gantry Cranes, huon recada, as devhdon or excepdes rem ANSI B30.5, Safety Standard for Crawler,- Loco-  % ud inspecdon trad ==h records shaR be motive and Truck Cranes, ANSI B30.6, Safety prepued a @A by &is standuCIhese records Staedrd for Derricks, and ANSI AIO.5, Safety Re-quirements for Material Hoists shall be foDowed.

&a5 be M M oser # recadsursquired by code, standard,specsfication or project procedures.

7.3.4 For speciallifts, hoisting ap4.. st may be re rated, or modified and re. rated, upon appraal 9. AMERICAN NATIONAL STANDARDS REFER-by the manufacturer or if the manufacturer's speci- RED TO IN THIS DOCUMENT fications are not available, the limitations assigned to the equipment shau be based on the determinations When the foGowing standards referred to in this cf a quallfled engineer competent in this field and dar==naat are superseded by a revision apprmed by

~

such determination shall be documented and re- the American National Standards lastitute, the re-corded appropriately. Re-rated equipment shall be vision shall apply:

given a dynamic load test over the fuD rense of th' N45.2 Quality Assurance Program Require-lift using a test weight at least equal to the oft weignt. ments for Nuclear Power Plants A dynamic test includes raising, lowenng and trav- *N45.2.3 Housekecping During the Construc-ersmg the load in contrast to a static test where the tion Pham of Nucien Power Plants test weight may be increased incrementally with

'N45.2.6 Qualifications of Quality Assurance no movement.

Personnel for the Construction Phase of Nuclear Power Plants 7.4 Inspection of Equipment and Rigging .N45.2.10 Quality Assurance Terms and An inspection program shall be established for Definitions equipment and rigging. A system shall be estab- M H 6.1 Pictorial Marldngs for Handling of lished that wiR indicate acceptability of all equip. Goods ment and rigging after each inspection. This system B30.2.0 Safety Code for Overhead and shall specify control of nonconforming lifting equp Gant y Crana ment. Periodic inspections shall be supplemented B30.5 Safety Code for Crawler, Loco-mo ive, an ck Cranes with special visual and non. destructive exammations ty and dynamic load tests prior to handling of items A10.5 Safety Rweduswsts for Material desenbed in Subsection 7.2 of this standard. . .

Hoints

• These standards age being approved by the Ainerkan 7.4.1 Rigging that is frayed, worn or other. National Standards Instiruts and they shoeld be senGabis wise detenorated shall not be used,

~

earty ta 1973.

13

u. _ _ _ _

ANSI N48.2.2.t972 i

i APPENDIX A

A3 ' PACKAGING shall require a neutral-grease proof pro.

The following are additional minimum require- tective wrap when packapd.

rnents to be used with the rules of Section 3. of (3) The procedure for applying contact pre.

N45.2.2: "PA-w~ Shipping, Receiving, Storage sensum shall not m uin h=-nbly of and Handling of'Ite ns for Nuc!aar Power Plants"

[ite at j m removal. An excepdon would be for tons term storage protection to be agreed upon Specific cleaning procedures are considered to by the owner, buyer and manufacturer.

be part of the manufacturing specifications. m foi- (4) h method of' contact preservative re-lowing general criteria shall apply: moval shall be --:rFM with approved (1) The cleaning process including clesning s lvents and wiping cloths or by flushing compounds chosen shall in no way damage internal cavides with hts which an h item dudng ching or mWt not deleterious to the item or other inter-service when considering the composition, _

c nnecung rnatedal.Howem,punnadm surface finish, complexity or other inherent for inaccessible inside surfaces of pumps, valves and pipe for systems containing m-features or other interface e%..a.t after actor coolant water shall be indicated to facilltate touch.up.

(2) h cleaning process or processes chosen (5) ne name of the preservative used shall be shall remove loose mill and heat scale, oil, '

the water flushable type.

rust, grease, paint, welding fluxes, chalk, (6) When motors, pumps, turbines, etc., are abrasives, carbon deposits, coatings usad for shipped with oil resenoirs and bearings nondestructive testing processes and other cavities filled with presonative oil, the item contam:nants which would render ineffec- shall be so tagyd and instructions for -

tive the method of presenstion snd psck- draining, flushing, refilling and periodic aging, or other specified requirements. rotation shall be included with the item.

(3) Item surfaces after cleaning shall be free (7) When it is anticipated that the item might of cleaning media, such as aluminum oxide, require an extended storage period, six (6) silica, grit, lint, chemical cleaning residue, months or lonpr, a preservative needed for petroleum solvent residue, etc. the long term protection of the item shall be applied or arrangements shall be made (4) After cleaning, the item shall be protected to periodically reapply the preservatives.

from contammation until preservation or packaging is complete. A3.4.2 Inert Gas Blankets. When inert gas blankets are used, the followmg criteria shall apply:

A3.4.1 Contact Preservatrves. He following criteria shall be used when considering the type of (1) Inert gas blankets shall be used only when contact preservadve to be used. the exterior shell of the item or its con-tainer can be tightly sealed to form a leak-(1) h contact preservative shall be com- proof barrier.

petible with the matenal on which it is (2) Only a commercial grade of dry, oil free, applied. inert gas shall be used.

(2) Contact preservatives which are nondrying (3) Provisions shall be made for measuiing and maintairung the blanket pressure within the NOTE: 'The perseraph numbers contamed herem are required range within eacti pressurized oot sagaenest tut correspond to the respectrve Purged item or container. Closures and seals parasraph of section 3 of this standard where they shall be tightly secured so that the absolute are referenced. (by mass) pressure after final sealis main.

14

PACKAGING, SHIPPING. REC 81VI NG, STOR AGE AND HANDUNG OF ITEa5 POR NUCLEAR POWER PLANTS tDudas the Consemenen Phase 6 ANN Nhtm tainee foe 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without adding gas, (c) Starch, silicone and epoxy type me.

prior to shipping the item from the manu- terial may be used for tape adhesins

( facturer's plant. (2) When contacting other surfaces and E (4) De item or container shall be marked in tainers:

bold letters cautioning that an inert ps (a) Tapes and adhesins used to seal non.

blanket has been used. The required pres.

austenitic materials or containers are sure range also shall be marked on the not subject to the above restrictions.

Item or container. (b) Tape shall be impervious to water and A3.5.1 Cape and Plugs. Cape and plup shall not subject to crecidag or drying out if conforra to the fo8owing criteria: expond to sunlight, host or cold.

(3) Tapes should be brightly colored to (1) Nonmetallic plus and caps shaR be brightly clude theirlosslato a systeen, colored. Clear plastic closures are not to be used except when specined for a special A3.6.2 Vepor Barrier Maesrist. When maxi.

purpoes; for example, as a window for smara vapor protection is required, barrier material humidity indicator cards. Special attention shau not the maximum water vapor tr%

shall be given la the control of these rate of 0.05 grams per 100 square inches per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> closures. per ASD4 E96 Tests for Water Vapor Transnission (2) Metatue plugs and cape contacting metal Of Materials In Sheet Form, Procedue E and shall be erfsons shaE act casa pivenic corrosion packaged with as _,r.d dulacant. De barrier at the contact areas. Gasketing or other rnsterial should be bridtly colond to prsdude loss nonrnstalue materials used in conlunctica within a system. ,

, with metalus caps or play shall exhibit no ' ' A3.6.3 Desloesnts. Desiccasts shat consist of (3) Simplicity of inspection, and 9 I*'

"hydrating

" '0 ""'***'.

agentsDe following criteria apply when removal without damage to the item M they are used.

be considered.

(4) Provisions shall be made to preclude the (1) When used with susteestic stainless stseis, plus or cap from falling into or being the desiccant and the beg material shad not pushed into the opening after its instal. ,

haw a halogen content over 0.255. De lation. desiccant beg shall be made of puncture, (5) Plup or caps shall be secured with tape (see tear and burst resistant meterial parayaph A3.5.2 of this Appendix) or (2) De reac4vation temperature and time shall other means sa necessary to prewnt ac. be marked on the desiccant container.

cidental removal. (3) Camsters used to contain deslocanta shall be (6) AH plup and caps shall be clean and free of placed so as to cause no deleterious effects visible contamination such as, but not such as galvanic corromon, own when the limited to dust, dirt, stains, rust, discolora. desiccant has reached its absorptive capacity tion or scale, for water vapor.

(7) Plugs and caps used in contact with austen. (4) Desiccant bsp and canisters, when used, itic stainless steel shall be made from non. shall be secured to prewat movement,rup.

halogenated materials or stainless steel. ture of the bay, or damage to the item hesives orm t the o wing  : I}

(1) Whos contacting sustenitic stainless steel De included air volurne within the flexible and nicket ahoy surfaces: barrier shall be kept to a mmimum.

(a) De haloyn and m.lfur contents of (6) Items winch contain h=6 mat shall han all tapes should not be in excess of 0.10% opening securely realed. When flany con.

by weight each.Paperbacked (maskmg) nections are a part of the barriers,0rinp tape shan not be used. or gaskets shall be used with all bolts in (b) Upon removal of tape, all residual ad. place and tightened sufficiently to insure a hesive shan be removed by a non. water.vaporproof seat. Weld end prepara.

halogenated solwnt (acetone, alcohol tions, after capping, shaR be covered with a or equal) wiping. water. vapor proof seal 15

P ar1r atu MG, SHIPPING, M ECEIVI NG, 3 TOR AG E AND HANOUNG OF ITanaB POR NUCt. EAR POWER Pt. ANTS (Dwine me Censowesen Nee) ANN N4a.2.2 1972 (7) Packages and items containing desiccant box, (Outer flaps meet, far flaps and shan be marked. The total number of outer flaps are of equallength).

separate begs and/or containers in the (3) Fiberboard boxes shau be securely closed package shall be indicated. with a water resistant adhesive apphed to (8) The minknum quantity of d**e=at for the entire area of contact between the flaps.

use in each package shall be determined in All seams, and joints shall be further sealed accordance with Formula I or Formula II, with not less than two inch wide, water as applicable. resistant tape.

Formula I: To determine mmimum of desic- (4) Boxes shall be strapped with pressure-cant for use with other than sealed rigid sensitive remforced tape, length-wise (top, l metal barrier: bottom and ends), girthwide (top, bottom U= 1.6A plus XD. and sides) and hortzoital sides and ends.

Formuis ll: To determine minimum units of (5) Wood cleating on fiberboard boxes shall be desiccent for use within sealed rigid metal fabricated from sound, well eensoned barrier: lumber.

U= KV plus XD.

In the above formulas. A3.8.1 Cushioning. Selection of cushioning A= Areas of barrier in square feet materials shan be based on the following:

U= Number of units

• of desiccant to be used (1) It shau exhibit no corrosive effect when in

• A desiccant unit is that quantity of da*e=at, contact with the item being cushioned.

as received, which will absorb at equilibrium (2) It shan have low moisture content and ex-with air at 25 C at least the fonowing quanti- hibit low rnoisture absorption properties; <

ties of water vapor: 3.00 grams at 20% relative or if the cushioning material has some humidity and 6.00 grams at 40% relative moisture absorbing capacity, the item shan humidity, be protected with a watervepor-proof D= Pounds of dunnage (other than metal) barrier. ,

within barrier (3) It shall have negligible dusting character-K= 0.0007 whenvolume is given in cubic inches istics.

K= 1.2 when volume is given in cubic feet (4) It shall ::ot readily support combustion.

V= Volume within barrier in cubic inches or felt, cellulosic material (including A3.8.3 Ar.cM,,g. When bolts are used for X= f anchorms the foHowing criteria shah apply.

wood) and other material not categortzed below (1) If precision bolt holes in the item are used X= 6 for bound fibers (animal hair, synthetic for anchoring, precaution shall be taken to fiber or vegetable fiber bound with rubber) insure that p operly fitting bolts of the X= 2 for glass fiber correct dimennon and charactensues are Xa 0.5 for synthetic foams and rubber used to prevent mamng or elongnuon of (9) A humidity indicator shall be included in the holes. '. .

every water-vaporproof envelope containing (2) Holes bored through containers or munt-desiccant. As appheable, the indicator shall ing bases shall provide a snug fit.

be located behind inspection windows or (3) When mounting items to container bases immediately within the closing edge, face, equippeo with skids, bolts shau be ex-or cover of the barrier, and as far as tended through the skids whenever prac-practical from the nearest unit of desiccant. tical. In such instances counterenkmg of the bolt in the sliding surface of the skid is A3.7.1 Fiberboerd Boxes. "Ihe following crt-necessary.

teria apply for fiberboard boxes used as exterior (4) Washers shall be used under the nuts to containem decrease the possibility of the bolt pulling (1) Boxes shan be weather. resistant fiberboard through the wood. .-

preferably from the following grade types (5) Nuts shall be properly torqued. To prevent (or compilance symbol) V2 s, V3 s. or theu loosening during slupment. lock nuts, V3 c. (Federal Specification PPP-B 636.) lock washers, cotter pins, or staking shall be (2) Box style shan be RSC - Regular slotted emploved.

16

....q p ,rJ l7 7' 'l I

- Tf l4 f'" N "

E 1'.

,um i

Pact (AGING, SHIPPING,MECilVING, STORAGE AND  ;

HANOUNG OF ITEks8 POR NUCl. EAR POWEM Pt ANTS tDwas tw Catmet* M ANSI PHS.2.2-1972 -

A 3,g w pays or in pictorial marking a eu.,

'5-i 2==

Items shat be marked to preserve identity in .

t m"

,, an G accordanos with the fouowhis criW symbols) or ANSI MH6.1. d

. (1) Ther specified identification shan be (3) References to weights shall be in avoir. O stamped, etched, stenciled or otherwis*

marked on the item or on tap to be affixed dupois units. Duplicate marking in other systems may also be indicated.

$y securely to the item in plain, unobstructed (4) Container markings shall be applied with view, When metal stamps are employed, low 3 waterproofink or paint in characters no less -g stress rounded bottom type stamps shall be than 3/4 inch high, container size per-used when the itern proper is marked. When mitting.

g -

vibrating merking tools are used they shall (5) Where tap or labels are used, they shall be be fitted with a carbide marking tip of affixed to the container using a waterproof

• equivalent and shall be designed to preld* adhesive, tacks where practical, or a cor-a rounded E,ME not to exceed 0.010 ,,,go, ,,,i, ,,g ,g,,,

inches in depth. Etching shall not be used (6) Container marking shall include the foGow- ,

on nickel aBoys or on weld areas or send-timed areas of stainless steel. Electric ars ing infonnstion:

(a) Destination m q

marking pencils shaR not be used-(b) Return address  !

(2) The marking absE not be doisensions to the material nor vloises any other section (c) Packene numbers showing the parchase

~ J order number,fo8 owed by the package 1 of this standerd. number and the total number of peck, 2 (3) When tap are employed, they absil. be of a ,,,, -

material which wiu retain the marking, - ,

withesand weathering deterioration, and (d) Materialidentification number (e) Handlinginstructions-Fragile, Center i

e other nonnat shipping and handling effects and shat not be detrissatal to the item.

of Gravity, Keep Dry This Side Up, Sung Here, Do Not. Fm ***'8d==

G *

(4) The Endinit language shaR be used. Dupli- limitations as appropriate. 3 cate maridag may be made in other (f) Weight of package (in excess of 100 -a langinagne-(5) References to weights shaR be in avoir-pounds). 4 dupois, units. Dupucate marking ist other (g) Special Instmctions. Desiccant Inside, Special Iar-*=. Storay, Unpacking systems may also be indicated.

Restrictions, etc.as appropriate. 5 Maridsp on the outside container shall be in i2E accordance with the foBowing crie Marking of items not within a container, such --;

(1) Container markiny shaR appear on a mini- as pipe, tanks and heat exchanprs, shan exhibit --

mum of two sides of the contamer, prefer- specified information in a location which is in plain -4 ably on one side and oce end. unobstructed view, but not directly applied to bare _

(2) The English language shaR be used. Dupli- austenitic stainless steel and nickel alloy metal sur- 9 cate marking mey be made in other lan- faces of the item. _h C

_4 2 w

N e ii 17 g

4 =

=-

ANSI N45.2.3(s)- 1973 A .

ADOENDA --

l' TO ANSI N45.3.31973 (R 1978)

Neussimaging Dudag the ceasemenien Pham of Musiser ptwer rises f

i l2

• 3 - Asahspersyuest22J asM

'] N Proesetien and Prevenaien. Equipessa und ha-8#**does for the suonsesion fman,andpmendesor, J damass by the det be prodied in assoidenes with

. the segehousemes of the NFPA National Phe Codes. -

_ h or lastressions for the praesseios sher in- *

ciuds proshions for fighthe fkesinvolving the ass of , . ;.

availabis M fhe deparemmass, trohed projses --

brigades, and othess. Ptooedness or lastrusdoms shsE I Jaciuds pinas for puerhion ofwetersuppges,hym

~~ sedmidem, acess for the a heng, s and den.

tribettom of % and fhe fighthg equip.

.=88 Fla semainees dudas and imunediassey foi.

Jewing opuntions such as welding and heat teeths shall be provkled when amaserials me laceaed such that

~H* " i GYing spada, weld speteer, or exosenho heat sesulting froma the opsetion could cause m ,

'with muniting damass to items of the ancisar plant.

Tim Protection facetime sher be la selos loginning with the initial seassa of psamanset construction.

h plasming shal be conducted as a.: ' __t of the fire proess:he FE-::t or lastructions which shall incinde em of confined areas.

MS STANDAdRD, INCLUDING THE A30VE ADDENDA, WAS REAFFIRAIED

-. FEBRUARY 18,1978 Puemmes me:

1!INE Ah4GRICAN SOCIETY OF RAECHANICAt. ENGINEERS United Ensincering Center 348 E.4 hen serese NeueYorts.NY 10017

_ . . . . . . . .