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Const Team Insp Rept 50-443/85-15 on 850603-14.Violations Noted:Seismic Installation of Instrument Tubes Crossing Seismic Boundary Not Translated Into Spec & Control of quality-related Activities Inadequate
	ML20137Z900
Person / Time
Site:	Seabrook
Issue date:	09/13/1985
From:	Bettenhausen L, Cerne A, Cheung L, Eapen P, Finkel A, Jeffery Grant, Kamal Manoly, Reynolds S; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20137Z860	List: ML20137Z854; ML20137Z872; ML20137Z900;
References
	50-443-85-15, NUDOCS 8510080401
	Download: ML20137Z900 (81)
	v • d • e

U.S. NUCLEAR REGULATORY COMMISSION

Region I

Report No. 50-443/85-15

Docket No. 50-443

Construction Permit No. CPPR-135 Category A

Licensee: Public Service of New Hampshire

Post Office Box 330

Manchester, New Hampshire 03105 l

Facility Name: Seabrook Station, Unit 1

Inspection At: Seabrook, New Hampshire

Inspection Conducted: June 3-14, 1985

Inspectors: h. N .apen,ka

Dr. P. K.

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Tea 6 Leader

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A. C.

K

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M. Che ng, Reactor En

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A. E. Finkel, Lead Reactor Engineer

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Grant, Reactor Engineer

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K. A. Manoly, Lead Reactor' Engineer

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S. D. Reynolds, Lead React 6r' Engineer

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Approved By: /d 'f 8

Dr. L. H. Bet'tenhausen, Chief, Operations Date

Branch, Division of Reactor Safety

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Inspection Summary: Announced Construction Team Inspection on June 3-14, 1985

(Report Number 50-443/85-15)

Areas Inspected: Construction Site Management, Quality Assurance, Design

Change Program, Electric Systems, Instrumentation and Control, Mechanical and

Structural Systems, and Welding and Metallurgy. The inspection involved 567

hours onsite inspection by five region-based inspectors, one senior resident

inspector and one supervisor,

Results: Three violations, three unresolved items, three weaknesses and three

strengths were identified.

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Table of Contents

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Page

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1. -Persons Contacted...................................... 4

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2. Inspection Purpose & Scope ............................ 5

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3. Seabrook Station Site Management....................... 7 ,

4. Quality Assurance and Administrative Controls.......... 10

1

5. Design Change Contro1.................................. 17

6. Mechanical Components and Supports..................... 25

7. Welding and Meta 11urgy................................. 39

I 8. Instrumentation and Controls........................... 49

.' 9. Electrical Systems..................................... 60

.

j_ 10. Licensee Actions on Previous NRC Findings. . . . . . . . . . . . . . 66

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11. Unresolved Items....................................... 67

12. Management Meetings....................................

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Attachment 1 - Documents Reviewed...........................

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DETAILS

1.0 Persons Contacted

1.1 New Hampshire Yankee

.

J. Azzopardi, QA Engineer

F. Bean, Field QA Engineer i

R. Cummings, Jr., Independent Reviewer

W. Derrickson, Senior Vice President

J. DeVincentis, Director, Engineering & Licensing

T. Feigenbaum, Independent Review Team Leader

G. Gram, Director of Construction

R.'Guillette, Assistant Construction QA Manager

W. Johnson, Vice President

G. Kann, STD Test Group Manager

4

D. Maidrand, Assistant Project Manager

J. Marchi, Startup QC Supervisor ,

G. Mcdonald, Construction QA Manager !

W. Middleton, QA Staff Engineer

D. Perkins, Field QA Engineer

V. Sanchez, Licensing Engineer -

J. Singleton, Assistant QA Manager

J. Tefft, STD Project Engineer

D. Turner, Field QA Engineer

H. Wingate, Engineering '

1.2 United Engineers and Constructor (UE&C)

R. Leonard, R&QA Manager

D. McGarrigan, Project QA Manager

M. McReona, Sr. Project Engineering Manager

1.3 USNRC

R. Barkley, Reactor Engineer

H. Wescott, Resident Inspector *

The above listed personnel attended the exit meetings held on June 14,

1985. Other managers, supervisors, engineers, quality technicians and

craftsmen were also contacted during the inspection. ;

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2.0 Inspection Purpose and Scope

2.1 Introduction

On April 18, 1984, Public Service Company of New Hampshire suspended

all construction activities at Seabrook Station. The licensee reor-

ganized with project control under New Hampshire Yankee Division

management and resumed limited construction on July 23, 1984. The

.

reorganization resulted in several major changes at the site. These

changes included restructuring of the site organization, introduction

of new contractors, use of new procedures, and termination of some

existing contractors. The management control and scope of some Qua-

. '

lity Assurance activities were also changed under the new site organ-

ization.

, The NRC had several concerns in the engineering, design and

installation of electrical and instrumentation systems. These con-

cerns were identified in the NRC Systematic Appraisal of Licensee

Performance (SALP) report dated February 19, 1985.

,

2.2 Purpose & Scope of Inspection

.

The purpose of this inspection was to assess the effectiveness of the

!

construction activities resumed under the new site organization

through a multi-disciplinary review of selected portions of key safe-

ty related systems at the Seabrook Station. The selected systems

l were Safety Injection (SI), Residual Heat Removal (RHR), Heating Ven-

tilation and Air Conditioning (HVAC), and Diesel Generator Jacket

Cooling Systems.

These systems and the disciplines were selected on the basis of

reactor safety and the system's relative contribution to " Core Melt

l Probability", as stated in the licensee's Probability Safety

i

Assessment Report (PSA). The PSA report identified that the loss of

. offsite power and seismic events were the highest and the next

i highest contributors to the core melt probabilities. (It should be

l- noted that the median core melt probability for Seabrook Station, as

calculated by the licensee is only about one in 5300 years.)

Therefore, the team reviewed the electrical design features of

selected systems including those required to mitigate the conse-

quences of a loss of offsite power event. The team also reviewed

those design features of selected systems that are required to

! mitigate the consequences of a design basis seismic event.

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At the time of this inspection, several systems, including those por-

tions of the emergency core cooling systems (ECCS) within the contain-

ment, were completed and turned over to the preoperational test group.

Therefore, the team selected the safety injection (SI) system and the

residual heat removal (RHR) system, two subsystems of the ECCS, to

assess the adequacy of the engineering, design, installation, and the

effectiveness of management overview, Quality Assurance, and interface

control measures.

The adequacy of the selected systems was assessed by reviewing those

portions of SI and RHR systems within the containment. The interface

between the RHR, a low pressure system and the reactor coolant system,

.

'

a high pressure system, was reviewed for the High Pressure / Low Pres-

sure system boundary requirements. The SI system was also used to

assess the effectiveness of the newly established Piping and Piping

Support Closecut Task Team Program (PAPSCOTT). Section 6 of the

Seabrook Station Final Safety Analysis Report provided design basis

details of the SI and RHR systems. The probability risk analysis

aspects for these systems are detailed in Section 7.8 of the Seabrook

Station PSA report.

The licensee has a new contractor for the Heating, Ventilation and

Air Conditioning (HVAC) Systems. Therefore, portions of HVAC system

were selected to assess the effectiveness of the new contractor and

to assess the adequacy of the design of attending systems. Jacket

cooling water system for the diesel generator was another supporting

system' reviewed for adequacy.

The team sampled and assessed as appropriate the adequacy of the elec-

trical, instrumentation and control, mechanical, structural and metal-

lurgical features for each of the main system and their required sup-

porting systems. The adequacies of the administrative controls,

QA/QC measures, and management involvement were also reviewed.

The details of this inspection are documented in the following sections.

Specifically, Section 3 provides an assessment of the construction

management, Section 4 a review of the QA/QC and Administrative Controls,

Section 5 a review of the design change controls, Section 6 a discus-

sion of structural and mechanical design, Section 7 a discussion of

metallurgical considerations, Section 8 a review of the instrumenta-

tion and control design and Section 9 a review of the electrical

features.

The team identified three strengths and three weaknesses, three unre-

solved items and three violations. Except for the identified weakness

and violations detailed in individual sections and summarized in Ap-

pendices A and B to the cover letter for this inspection report, the

team noted a high level of management involvement in the quality and

control of the site construction activities and acceptable standards

.

for quality implementation. The overall program and its implementa-

!

tion were consistent with the licensee commitments in the final and

j preliminary safety analysis reports for the Seabrook Station.

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3.0 Seabrook Station Site Management

t

The overall site management was reviewed to assess the effectiveness and

adequacy of management overview in safety related activities.

3.1 Organization

As discussed in Section 13 of the Seabrook Final Safety Analysis

Report, the licensee has consolidated the Nuclear Production, Con-

struction, Quality Assurance and other site support activities under

the Senior Vice President who reports directly to the President of

the newly formed New Hampshire Yankee organization. Negotiations

were underway with the New Hampshire Public Utility commission to

incorporate New Hampshire Yankee Electric Corporation separate from

Public Service of New Hampshire (PSNH). Until the necessary federal

and local approvals are obtained, the New Hampshire Yankee organiza-

tion will function as a Division of PSNH. The New Hampshire Yankee

is chartered to act as the managing agent for the Seabrook Joint

Owners in the construction completion and operation of Seabrook

station.

The Seabrook construction activities are under the direct supervision

.of the Senior Vice President who is stationed at the site. Director

of Construction, Director of Engineering and Licensing, and Director

of Management Control, direct and manage construction, engineering,

and management control activities, respectively. Each of these

directors report directly to the senior Vice President. Site Nuclear

Production activities are organized under a Vice President. Quality

Assurance and Project Overview Administrative Services are organized

under another Vice President.

After the reorganization, the licensee has retained United Engineers

and Constructors (UE&C) as the key architect engineer. The number

of independent contractors, was reduced to less than five from more

than twenty prior to the reorganization. The licensee limited the

site personnel to five thousand from a pre-reorganization limit of

eight thousand. The reporting levels were reduced from eleven or

more to the current five levels.

At the time of this inspection, the site employed about 5100 person-

nel including 3000 craft, 700 engineering personnel, 400 QA/QC per-

sonnel, and other support personnel. The organization was functional

and several new programs such as Piping and Piping Support Closeout

Task Team (PAPSCOTT) were in progress. Given below are the details

of the findings in the site management area.

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8

3.2 Findings

(1) Consolidation of Site Engineering Activities

The licensee recognized the need and consolidated all the

project engineering responsibilities under the Director of

Engineering and Licensing, who ensures that the entire organiza-

tion receives consistent direction and guidance from a single

source. He interfaces with the Startup Manager, Project Con-

trols Manager, Project Construction Manager, QA Manager, NSSS

Vendor and the Architect Engineer and assures that the final

product is licensable and technically acceptable. The Director

of Engineering and Licensing was successful in coordinating the

responses from the NSSS vendor, the licensee's corporate engi-

neering office, the Architect Engineers and the site contractors

for NRC Engineering and design concerns raised during the course

of this inspection.

(2) Commitment to Quality Assurance

The licensee's commitment to quality is clearly stated and pro-

vided to the employees in the employee handbook. The site

Quality Assurance personnel were qualified and experienced in

various engineering disciplines and are capable of assessing the

adequacy of the programs audited or reviewed. The site manage-

ment was dedicated to bring in performance oriented individuals

for QA audits and inspections. Management recognizes the role

of QA and is supportive of QA functions. See Section 4 of this

report for further details of the team's assessment of site QA

activities.

(3) Communication

The site senior management holds weekly staff meetings and

attends key project meetings. The flow of information appeared

to be prompt and effective. The senior management was appraised

of technical issues, such as, pump vibration problems at startup

and installation discrepancies in pipe supports. The senior

management was concerned about the problems associated with the

reorganization and made every effort to provide factual infor-

mation to the working level site personnel promptly. In order

to expedite effective communication of information affecting

site personnel, the site management convenes regular meetings of

the top one hundred key site personnel. As a result, the

working level personnel were found to be well informed in the

day-to-day financial concerns at the site. The licensee

publishes the site newspaper, the Standard, every two weeks to

9

inform the site personnel about key issues. This publication

also highlights daily activities of selected groups onsite. For

example, the June 7,1985 issue of the Standard contained a two

page article "taking a glimpse into the day of a Seabrook

Station pipefitter" with photographs and interviews with the

pipe fitters. The morale of the Engineering, Construction, QA

and Craft personnel contacted during this inspection was

observed to be high.

(4) Allegation Resolution

Site management also realized the need for attention to employee

concerns and allegations and established an employee allegation

resolution program at the site. The allegation resolution

office is staffed with full time experienced and qualified

personnel. The available internal means of problem resolution

are well established and made known to the personnel during the

indoctrination training.

(5) Awareness of Probability Risk Analyses

The licensee has undertaken and completed a probability safety

assessment (PSA) study for the Seabrook Station. The study was

performed by a consultant (Pickard, Lowe and Garrick).

The licensee is also developing probability safety concepts to

identify root causes for failures. The licensee maintains a

dedicated staff at the corporate engineering office for the

support of PSA at all Yankee plants. Seabrook station has an

experienced full time engineer to attend matters related to PSA.

He is assisted by the corporate staff and the contractor on an

as needed basis.

(6) Initiatives to Learn from the Industry Experience

The site uses the knowledge gained from other Yankee plants and

the personnel trained and qualified at other Yankee facilities.

In addition, the site management keeps abreast of the experience

at .other construction sites through direct contacts and review

of INP0 good construction practices. Good practices are

implemented at the site. The licensee developed his schedule

for system completion based on previous experiences at other

sites. As a result, except for five subsystems, the licensee

was able to complete the first 650 subsystems as scheduled.

Problems identified in construction deficiency reports generated

from other sites are reviewed to develop and implement

measures to preclude such occurrences at the Seabrook site.

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(7) Commitment to Training

The licensee has established positive measures to assure ade-

quate training onsite. Training requirements and matrices are

established for all personnel. The training records were

readily available and current.

(8) Housekeeping

The licensee has established positive measures in housekeeping.

Procedure FGCP-8 governs the housekeeping activities at the

site. Management and Quality Assurance consider housekeeping as

an on going activity. The workers are instructed to clean work

areas each shift. Key personnel are assigned to monitor work

areas on a routine basis. In addition, QA/QC surveils and

monitors the site and issues inspection reports. As a result,

the cleanliness of the site improved substantially. Except for

isolated instances, the team found the site at a high level of

cleanliness.

Items (1) through (8) above indicate that the site management has

recognized the need for improvement in key areas and instituted

adequate measures to strengthen these areas. These measures were

working well at the time of this inspection. The team concluded that

the above are positive attributes of an effective management system

and these positive attributes collectively constitute a licensee

strength.

4.0 Quality Assurance and Administrative Controls

As documented in Section 17.1.1.1 of the Seabrook Station FSAR, the

licensee has delegated to the Yankee Atomic Electric Company (YAEC) the

responsibility for the development, execution, and administration of the

quality assurance program for construction and preoperational testing

activities. Project reorganization under New Hampshire Yankee (NHY)

management control did not affect YAEC's defined QA responsibilities.

Thus, during this inspection period, the inspector reviewed the latest

revision, dated 2/15/85, to the YAEC Seabrook Station Quality Assurance

Manual and Revision 3, dated 4/1/85, to the YAEC Field QA Group Manual and

Procedure. He specifically selected the following criteria for further

review to determine both the adequacy of programmatic controls and the

effectiveness of program implementation:

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Organization to include staffing and contractor control

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Reports to management and management involvement

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Trending of deficiencies / problems

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Corrective Action

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Surveillance activities

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QC inspection criteria

With regard to the Administrative Controls being utilized by manage-

ment at Seabrook, the inspector selected for review the following

programs, with particular interest in the new program developments

since the restart of construction under NHY management control.

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Control of contractor interfaces

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Contract procurement

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Project management of 50.55(e) evaluations and FSAR revisions

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Independent Review Team (IRT) utilization

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Piping and Pipe Support Closeout Task Team (PAPSCOTT) Program

interfaces

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Employee Allegation Resolution (EAR) Program

The details and findings for each inspection area are discussed

below:

4.1 Organization

The inspector reviewed the current organizational structure of the

project QA organization, noting its evolution thru a major change in

QA reporting lines from the contractors to the YAEC Construction QA

Manager, implemented on 3/1/84, and an organizational restructuring

of the site QA organization, effective 1/21/85. The present Seabrook

QA organization has project oriented lines of direction / control of

various internal YAEC groups (e.g.: startup QC, surveillance, audit,

and quality engineering functions). In any case, responsibility is

demonstrably vested with the YAEC Construction QA Manager, who is

stationed onsite, and with independence provided by a reporting line

for QA matters from him thru the YAEC Corporate QA management struc-

ture, to upper NHY management.

.

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4.2 Overall Quality Assurance Function

The inspector reviewed a sample of recent "Seabrook Project Quality

Assurance Evaluation Reports," prepared by the YAEC Director of

Quality Assurance (Corporate) to the President and Chief Executive

Officer of PSNH, and confirmed adequate overview of the engineering

and various construction QA activities and an awareness and commun-

ication of the potential problem areas. Evidence of Project Quality

Trending of problems (primarily NCRs) by major contractor and YAEC

functional group was noted and checked not only for compliance with

the requirements of the pertinent NHY Project Procedure (i.e.: QP-1),

but also for management attention and action to correct the iden-

tified problems.

For implementation of corrective action to problems of a generic

nature, the inspector noted procedural control (i.e.: QP-2) for

Corrective Action Reports (CAR) and the assignment of responsibility

for followup. QA management also has available for their use a means

of initiating corrective action by way of Management Action Requests

(MAR) and Immediate Action Requests (IAR) where awareness and action

on the part of upper construction management is required to effect

immediate corrective measures. The inspector reviewed a sample of

MARS and IARs to evaluate the completeness of the corrective steps

taken to address the cause of the identified problems.

The inspector also sampled the surveillance checklists utilized by

YAEC QA Level II inspectors in the performance of their scheduled

surveillance activities, interviewed the YAEC Project QA Surveillance

Manager, and checked master surveillance schedules by discipline for

the timeliness of coinpleted inspections. In the instrumentation,

structural, piping, engineering, and preoperational testing areas,

the inspector confirmed the use of surveillance criteria consistent

with construction procedure requirements. The surveillance reports,

documenting coverage of a specific preoperational test (1-PT-8), were

reviewed for compliance with the applicable Test Program Instruction

criteria. The use of holdpoints by YAEC inspectors in witnessing the

conduct of 1-PT-8 was both verified and discussed in greater detail

with the YAEC Startup QA Supervisor.

The inspector specifically tracked management followup of some

specific unscheduled surveillances performed on two instrument racks

within the containment. Review of a QA Memorandum (File Q1.1.4/

YFQA-411) dated 5/28/85, revealed that while some workmanship defic-

iencies identified by the surveillances had been correctly documented

on NCRs for specific corrective action, further QA effort was in

progress to better define and scope the problem from a programmatic

standpoint so that the recommendations for corrective measures would

have more generic impact. In this regard, IEEE 336 criteria are

being evaluated as an augmentation to the existing inspection pro-

cedures and consideration is being given to extend the scope of

future inspection to beyond the safety-related installations.

13

These efforts er.emplify a strength in the Seabrook QA program in that

strong and effective corrective action appears to be directed to the

programmatic causes of the given problem, and not just to the identi-

fied deficiencies. As also with the use of the CARS, MARS, and IARs,

the Project Quality Trending program appears to be effective as both

a problem prevention and diagnostic tool and represents another

example of a Seabrook QA program strength.

4.3 Administrative Controls

In reviewing several of the licensee's management and administrative

controls, the inspector found widespread, multidisciplinary utiliza-

tion of the site Independent Review Team (IRT) to address problem

areas and concerns. He reviewed an IRT Report (IRT-015) dated

5/7/85, assessing the existing interface between the NSSS vendor and

the A/E for the Seabrook project. At a meeting with engineering

personnel to discuss generic component clearance criteria used for

design and construction guidance (reference: UE&C Technical Proced-

ure, TP-8), the involvement of the IRT in reviewing the program and

making recommendations was evident. Also, the inspector noted that

the IRT is utilized as the Technical Support Team for the Seabrook

Employee Allegation Resolution (EAR) Program, because of their inde-

pendent nature as consultants to the NHY Vice President. A close

working interface between the IRT and the YAEC QA organization also

exists and has added to the strength of the QA program.

The inspector also reviewed the current programmatic controls for the

Seabrook EAR program, initiated in 1985. He interviewed the EAR

Program Manager, reviewed the NHY program scope and the EAR Operating

Procedure, and examined a sample of the case files. Specifically

checked were EAR allegation / concern acquisition methods, the method

of keeping upper management informed of EAR activities and results,

and the way feedback is provided to both employees and EAR personnel

where corrective action within the scope of other organizations is

required. Management support of the EAR appears evident, commencing

at the NHY corporate executive level. The inspector also noted that

the IRT ' conducted an adequate audit of EAR Program on 4/16/85, the

report of which was made available for the inspector's review.

4.4 Project Controls (10 CFR 50.55(e) Reports and FSAR Changes)

With regard to project controls for 10 CFR 50.55(e) Construction

Deficiency Report (CDR) evaluation, the inspector noted that docu-

mentation requirements have been established by NHY Administrative

Site Procedure, ASP-3; UE&C Administrative Procedure, AP-48; and YAEC

Project Policy No. 27. The inspector reviewed recent guidance dated

3/20/85, disseminated by the Construction QA Manager and the Director

, . . . .

14

.

of Engineering and Licensing for use by all engineering and QA per-

sonnel in the determination of 50.55(e) reportability for identified

deficiencies. During the course of this inspection, specific NCRs

were checked for documented evidence of the licensee's evaluation of

the subject deficiencies for reportability under 10 CFR 50.55(e).

The inspector also noted that the " Action Requests for Corrective

Action" used by the EAR Program require 50.55(e) evaluations for

substantiated concerns involving safety-related material.

'

No con-

4

cerns were identified in this area.

Reporting of Construction Deficiency Reports at Seabrook is control-

led by the YAEC Licensing Office, which works with both UE&C engi-

neering and YAEC QA in the evaluation process. Another YAEC licen-

<

'

sing function is the control of FSAR changes. Amendment 54 to the

Seabrook FSAR/PSAR was submitted to the NRC Division of Licensing on

3/12/85. The inspector discussed with a YAEC Project Engineer the

overall control of FSAR revisions, specifically questioning how

removal of the Boron Injection Tank (BIT) from the ECCS piping was

being controlled from a licensing standpoint. Westinghouse is pro-

viding the supporting technical analysis for this design change.

.

Pending completion of this analysis and preparation of the necessary

documentation, affected FSAR sections will be revised and included in

a future amendment to the FSAR. By letter dated 6/13/85, the licen-

see informed the NRR Division of Licensing of their intent in regard

to removal of the BIT.

4.5 PAPSCOTT Program

l

Another recently instituted program at Seabrook is the Piping and

Pipe Support Closecut Task Team (PAPSCOTT), which provides an organ-

izational framework and guide for the completion of the ASME pipe and

pipe support systems, as-engineered, as constructed reconciliation of

ASME pipe and pipe support systems IE Bulletin 79-14 as-built review,

and ASME code stamping and documentation requirements. During dis-

cussions with the PAPSCOTT Coordinator and his QA engineer, the

inspector questioned what roles QA would play in the verification /

surveillance of the various PAPSCOTT activities. The licensee

provided a matrix of organization responsibilities for performance of

the various QA functions and the inspector had no further questions

on this issue.

However, with respect to several other verification / inspection pro-

grams, such as the TP-8 program for component clearances, the TP-10

program for structural embedment verification, and the final building

walkdowns prior to preoperational turnover, it was not clear to the

inspector how such efforts would be consolidated and coordinated as

construction is completed. NRC unresolved items (83-15-04, 84-15-01

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15

and 84-17-03) document specific questions in this area. The inspec-

tor reviewed licensee responses to these questions as documented in

YAEC Blue Sheets 66 and 85 and as provided by the PAPSCOTT program

scope. Based upon the licensee positions and actions on the indi-

vidual itens, the licensee appears to have implemented adequate

corrective actions for the individual item. However, the larger

question of how all the various inspection criteria (e.g.:

TP-8, TP-10) will be coordinated for the final building inspections

remains. As in the case of PAPSCOTT, the licensee recognized the

need for a structured approach to the final area inspection process,

given the diverse criteria which must be checked. Pending licensee

presentation of evidence of a programmatic approach to the final

building inspection, to assure all verification programs are imple-

mented as intended, this item remains unresolved (443/85-15-01).

4.6 Purchase Order Control

The inspector also examined Purchase Order 249-7, regarding the

penetration sealant contract work and Revision 4 of the Specification

249-7 on the same subject. This new contract had recently been

awarded to Brand Industrial Services, Inc. (BISCO) and the inspector

reviewed a draft copy of the BISCO QA Manual and a copy of a YAEC QA

Audit Report on BISCO. An open NRC unresolved item (84-17-04) on the

fire rating and hydrostatic head pressure requirements for certain

penetration seals was satisfactorily answered by Revision 4 to

Specification 249-7. Also, on 2/7/85, the licensee requested a

revision to the Moderate Energy Line Break (MELB) study to clarify an

inconsistency with some design criteria for penetration seal plates.

The inspector determined that based upon his review, the process

for selection of a contractor for this new sealant work appears to be

consistent with program and QA requirements.

4.7 Contractor Control and Engineering Change Authorizat!on (ECA)

Utilization

With regard to Construction Manager control of individual contractor

work, the inspector noted a UE&C Field General Construction Proced-

ure, FGCP-27, governing Contractor Interface on Released Equipment.

However, with regard to other contractor interfaces, there was no

generic document to assign responsibility for the interface process.

As an example, a design change (ECA 05/102323A) was issued to attach

an I&C support to an ASME pipe support with the pipe support struc-

tural member being strengthened by stiffener plates on either side of

the beam web. Since the UE&C I&C organization could not jurisdic-

tionally attach the stiffener plates to the pipe support (Note:

Pullman-Higgins (P-H) would be called upon to modify the ASME support

under their jurisdiction), they completed the I&C support installa-

tion, inspected, accepted, and turned it over to start-up without the

.

16

stiffener plates installed. The inspector interviewed P-H engineer-

ing and QA personnel and learned that P-H was not aware that stiff-

ener plates had to be added to their pipe supports because the pipe

support drawing had not been included as an affected drawing on the

>

Engineering Change Authorization (ECA).

This problem was discussed with construction manager, QA and

engineering personnel and procedural changes are forthcoming to

address stiffener addition, particularly where contractor interfacing

is required. The inspector informed licensee management that this

specific case of an interface control problem constituted one

example (See Paragraph 6 for other examples) of a violation of 10

CFR 50, Appendix B, Criterion I (443/85-15-02).

Also, as in the case of ECA 05/102323A, other ECAs (eg: 25/102267A)

were identified to be lacking a list of all drawings / documents

affected by the subject design change. This, along with other

examples provided in paragraphs 5 and 8 of this report, reflects a

weakness in the administrative control of design changes.

-

4.8 Independent Measurements /In-Process Work Sampling

The inspector also made independent measurements on some pipe sup-

ports within containment to verify ECA implementation, as sampled

from a design change log. He reviewed high-strength bolting criteria

for several disciplines and specifically reviewed the work being

accomplished to HVAC installation procedure, IP-21. The HVAC QA

supervisor was interviewed, NCRs and record files examined, and a

~ YAEC Audit Report of HVAC activities reviewed. UE&C QC organization

provides Level I inspection support to Pullman Construction

~~

5-

Industries (PCI) as the HVAC contractor. Since this same QC organ-

ization had provided QC to the UE&C organization which had previously

done the work, the transition of procedures, records, and program

appeared to be adequate.

4.9 Conclusions

'

Except for the weaknesses and part of a violation discussed above,

the inspector found the licensee's Quality Assurance and Administra-

tive Control measures to be conducted in accordance with the

regulatory requirements and licensee's commitments.

'

.,

w

.

17

5.0 Design Change Control

Areas of design change control reviewed during this inspection were:

--

Program for design changes per Engineering Change Authorizations

(ECA)

--

Program for design changes per Nonconformance Reports (NCR)

--

Translation of site design change controls into a new site procedure

governing in part, design changes per NCRs

--

UE&C Engineering Assurance surveillance of UE&C safety-related

activities

--

Change Document Tracking system

The above areas were inspected in relation to the RHR, Safety Injection,

and Diesel Generator (DG) Jacket Cooling Water Systems. Also, part of the

DG Jacket Cooling Water System was walked down and inspected for conform-

ance to applicable P& ids, isometrics, ECAs and NCRs. The details and

findings for each inspection area are discussed below.

5.1 Organization

UE&C, Philadelphia, provides the engineering, design, and construc-

tion management services for Seabrook Unit 1. YAEC provides project

administration, overall control of the facility design, construction

coordination, quality assurance and facility licensing. YAEC also

conducts post-construction activities, such as preoperationel test-

ing. Westinghouse Electric Corporation has furnished the nuclear

steam supply system (NSSS).

Prior to construction restM % sly 1984, numerous contractors were

involved in Seabrook cos W ,i activities. Following restart,

these activities were consliamt and UE&C was given responsibility

for the majority of remaining construction. In turn, many design and

design change responsibilities were transferred from the UE&C Home

Office in Philadelphia to the site.

5.2 Engineering Change Authorization (ECA) Program

An ECA is one of the documents used by the licensee to authorize

design changes. ECAs are used to identify, document, and control

changes and/or exceptions to drawings, specifications, calculations,

or other design documents. A Request-For-Information (RFI) can be

- . - -. - - . - . . - . - .

..

l

1

-

l

18 I

used when no change or exception to a design document is required,

but interpretation or clarification is needed. Both ECAs and RFIs

are governed by - AP-15, " Project Design Changes, Engineering Change

Authorization and Request-For-Information," and TP-23, " Supplemental

Information for Design Change and Nonconformance Disposition

Programs."

The inspector selected a sample of ECAs and reviewed them for the

following attributes:

--

adequacy of change description

--

reason /need for change

--

evidence of technical justification in ECA disposition

--

adequacy of technical justification

--

availability of calculations /other analyses

--

affect on original design intent

--

independence of reviewers and approvers / evidence of inter-

disciplinary review when required

--

identification of "affected" documents

--

involvement of Authorized Nuclear Inspector (ANI) in ASME-

tags

--

use of Limited Work Authorizations or Work Requests to perform

work on nonconforming items

--

consistency with overall program requirements of ASP-3

The NCRs reviewed and discrepancies identified by the inspector are

listed below:

82/509 No discrepancies identified.

93/1285A No discrepancies identified.

82/383 Inaccurate problem description with no additional clarifi-

cation given in the interim action disposition. Indeter-

minate status on need to evaluate for 50.55(e) reporta-

bility.

82/373 Same discrepancy as in 82/383.

74/2957 No discrepancies identified.

93/1352A No discrepancies identified.

82/513A No discrepancies identified.

82/513B No discrepancies identified.

82/513C Misclassification of valve operator. Inaccurate problem

description. Lack of technical justification evident as

part of an " accept-as-is" disposition. Inadequate and

-inaccurate justification for determination of nonreporta-

bility under 50.55(e). No traceability for RFI 99/105921A

(issued as result of NCR 82/513) back to the original

problem in 82/513. "Still Valid" information from Revision

B not included in Revision C.

82/522A No discrepancies identified.

54/5332 No discrepancies identified.

73/9609A No discrepancies identified.

73/7432A No discrepancies identified.

73/10558A Lack of technical justification evident as part of an

" accept-as-is" disposition.

74/3058A No discrepancies identified.

82/501A Lack of clarity as to classification of a safety-related

component.

93/667 Voided in error - misinterpretation of seismic design

requirements (See Section 8.4 for details).

93/666 Voided in error - misinterpretation of seismic design

requirements (See Section 8.4 for details).

74/2532B No discrepancies identified.

-

21

The inspector discussed the subject of apparent lack of technical

justification for " accept-as-is" dispositions on NCRs 82/513C and

73/10558A with the licensee. NCR 82/513C involved failure of four

safety-related control valves to completely close, and NCR 73/10558A

involved zero gap violations on a pipe support. Neither NCR dispo-

sition identified nor referenced details of the justification used.

Through further discussions with Site Engineering and Startup per-

sonnel, the inspector determined that technical justification did

exist, but not in a readily retrievable manner. This lack of evident

technical justification along with the discrepancies identified above

is in conflict with the licensee's procedure, ASP-3, and is con-

sidered part of a programmatic weakness in design change control as

discussed in Section 5.8 of this report.

5.4 Diesel Generator Jacket Cooling Water System

The Diesel Generator (DG) Jacket Cooling Water System (JCWS) main-

tains the temperature of the diesel engine within a safe operating

range under all load conditions and maintains the engine coolant

preheated during standby conditions to improve starting reliability.

The JCWS is designed to Seismic Category I, ASME Section III, Class 3

requirements. Engine-mounted piping and associated components (not

necessarily engine-mounted) are considered part of the DG package

supplied by Colt Industries.

As part of the design change control review, segments of the DG JCWS

were walked down and inspected for conformance to applicable P& ids

(F-805019, F-202103), isometric drawings (DG-4423-01, DM-5503-04),

and ECAs and NCRs affecting those drawings. As a result of this

inspection, the inspector identified the concern regarding ECA

19/105466A as detailed in paragraph 5.2.

The inspector did bring to the licensee's attention the lack of an

ASME Code break between the Expansion Tank (ASME, C1.3) and demin-

eralization line, DM-5503-05, on P&ID F-202103 (non-ASME). The 1

licensee agreed that a Code break was required and issued ECA

02/106741 to indicate that the ASME, C1.3/non-ASME break is located

at the nozzle weld on the Expansion Tank in Train A and Train B.

The inspector identified no further discrepancies.

5.5 Design Change Control Requirements

Prior to construction restart, design changes were dispositioned per

ECAs. Following construction restart, the licensee approved the use

of NCRs for design changes. To control NCRs and their use as design

w______________-_-_-

.

22

change documents, the licensee developed and approved ASP-3, "Noncon-

formances," and revised TP-23, " Supplemental Information for Design

Change and Nonconformance Disposition Programs." The inspector

reviewed these procedures in relation to existing design change

controls of AP-15 and noted the following differences:

--

AP-15 requires all contents of a superseded ECA be included in a

revised ECA. (ASP-3 does not address this for design change

NCRs.)

--

TP-23 requires that ECAs have "affected" documents. (TP-23 does

not explicitly distinguish between design change NCRs and other

NCRs, and therefore, does not explicitly require "affected"

documents for design change NCRs.)

--

AP-15 requires that ECAs affecting an existing UE&C or contrac-

tor procedure be followed up by an Interim Procedure Change

(IPC) within five working days after the ECA is issued. (ASP-3

does not identify instances in which NCRs cannot be used for

design changes. If a design change NCR can indeed be used to

change a procedure, ASP-3 does not address the IPC requirement.)

--

AP-15 requires ECAs be incorporated into affected documents

within 180 days. (ASP-3 requires incorporation within 60 days.)

--

AP-15 requires a monthly review for unincorporated ECAs. (ASP-3

requires a quarterly review for NCR incorporation.)

The inspector discussed the above differences with the licensee. The

inspector was informed that a consistency review between AP-15 and

ASP-3 had not been completed during the development of ASP-3. How-

ever, the licensee commented that the individuals responsible for the

development of ASP-3 were individuals intimately involved with AP-15

development and implementation. Following further discussions, the

licensee initiated a review to identify all the differences between

the two procedures and evaluate the applicability of AP-15 design

change controls to ASP-3.

This lack of a consistency review to ensure that all applicable

design change control requirements of an existing site procedure

(AP-15) were incorporated into a new procedure (ASP-3), which re-

quired equivalent design change controls, is considered part of a

programmatic weakness in the licensee's administration of the design

change control program. This weakness is discussed in Section 5.8 of

this report.

The inspector identified no further discrepancies.

I

1

. - -. . _ - - - - _ _ - . - _ . . _ _-

.

-

23

,

5.6 Change Document Tracking System

'

The licensee has implementd a new tracking system for design

changes. This system, identified as Change Document Tracking (CDT),

is one subsystem of the feabrook Construction Information System

>

(CIS). Other subsystems include: Project Completion / Incomplete

Items System, Hanger Status System, and Unit Cost System. CDT allows

4

an individual to identify outstanding and historical design changes

affecting a particular drawing, specification, or other design docu-

ment because the design change documents are indexed to the design

! documents. CDT tracks design incorporation, field work completion

(for NCRs), and general design document status.

'

In order to assure the quality of the system, CDT has been developed

in a manner that prevents anyone other than the responsible data-

entry individuals from changing and/or adding to the data base. Data-

, entry and changes to the data base have been assigned to a limited

i

number of people onsite. However, retrieval of data has been made

available to anyone onsite requiring such information. CRT terminals

i are located throughout the site. In the event CDT is down, provis-

ions -have been made to continue operation using a manual logging

<

system. Also, hardcopy printouts of CDT data are maintained at all

drawing stations with updates to the printout being made on a weekly

basis.

2

Throughout this inspection, the inspector used the CDT to retrieve

data on the RHR, SI, and DG JCWS. The inspector found the system

easy to understand and use. However, the inspector did note that CDT

is still being updated with historical data. Until this historical

data has been entered into the data base and further debugging of the

system is completed, individuals cannot rely solely on CDT to provide

them with all the pertinent design change information.

The inspector identified no discrepancies.

5.7 Engineering Assurance

j In addition to YAEC's surveillance of UE&C, the onsite Engineering

Assurance (EA) group of UE&C conducts surveillances of certain UE&C

l safety-related activities, such as the use of ECAs and NCRs in rela-

tion to their procedural requirements. EA prepares a checklist

,

identifying the requirements of a particular procedure (e.g. AP-15

'

for ECAs). The checklist represents the formal surveillance report.

!

.

J

,

_ - _ _ _ _ _ _ . _ . . _ _ , .- __ _ __ _ , _ , _ . -.-_ .__ _._ -.

. _ _ _ .. _ _ . __ _ _ _ _ _ _ . _ _ _.

k

i

j< 24

!

The inspector reviewed the following surveillance reports on NCR

activities:

i

! 553 3/11/85 Postponed because of revisions being made to NCR

! program.

l 559 3/13/85 Postponed because of revisions being made to NCR

program.

588 4/18/85 No EA-identified discrepancies.

l 600 5/8/85 No EA-identified discrepancies.

! 601 5/10/85 No EA-identified discrepancies.

i

The inspector had no questions, but did note that the surveillances

i

were only administrative in nature, i.e., EA reviews items such as

timely resolution, maintenance of NCR files, and review and approval

independence. The EA surveillance does not include a review of the

technical content.

The inspector also reviewed the following EA surveillance reports on

i

ECA activities:

,

576 4/14/85 [No EA-identified discrepancies in these

586 4/18/85 surveillances.]

4

'

592 4/26/85

606 5/14/85

i 618 5/31/85

!

The inspector had no questions concerning these surveillances, and

j concluded that although the surveillance activities of the EA group

i do not include a review of the technical aspects to ECAs and NCRs,

i they do provide an additional level of review for quality assurance.

The inspector identified no discrepancies.

l

l 5.8 Conclusions

4 It is apparent that the licensee has taken positive steps in stream-

} lining the design change process, while still providing adequate

! controls, by relocating much of the Architect / Engineering staff from

the Home Office in Philadelphia to the site, and allowing certain

'

I design changes to be approved per NCRs. The licensee has also

i revised the ECA and NCR form, making them very similar to one

another, thus reducing the number of different procedural require-

l ments.

,

Although the inspector concluded that the overall design change con-

trol program is adequate, the inspector informed the licensee that a

j weakness in the administration of the program in relation to site

procedural requirements did exist as evidenced by the following

i

)

i

l

-. - - - . - - - . - - - - -- -

.

25

a. discrepancies in NCRs and ECAs, such as lack of evident tech-

nical justification for " accept-as-is" dispositions, lack of

"affected" documents being identified, and approval of inaccur-

ate problem and disposition descriptions, and

b. lack of a consistency review to ensure that all design change

control requirements of an existing site procedure (AP-15) were

reviewed ,for applicability to a new procedure (ASP-3) requiring

design change controls.

The inspector concluded that the above discrepancies could lead to

inadequate design, construction, inspection or testing, and are

representative of a programmatic weakness in the administration of

the design change control program (443/85-15-03).

6.0 Mechanical Components and Supports

This portion of inspection covered the following areas:

Piping and pipe support installations for RHR and SI Systems.

Piping and pipe support as-built reconciliation program.

Heating, ventilating and air conditioning (HVAC) systems.

Various functions and activities contributing to the design and construc-

tion of mechanical installations before the construction shutdown and

after the restart in 1984 were reviewed to determine whether acceptable

engineering practices, regulatory requirements, and licensee commitments

had been met. The details and findings for each inspection area are

discussed below.

6.1 Organization

Engineering and design activities related to piping, pipe supports

and HVAC system supports are performed by United Engineers and

Constructors (UE&C), the Architect / Engineer (A/E) of record.

Pullman Power Products (PPP) previously known as Pullman Higgins

(P-H), is responsible for the fabrication, erection, and quality

control activities related to installation of safety-related piping

and supports before the shutdown and af ter the resumption of con-

struction. As a result, installation and inspection procedures for

these activities remained unaffected by the restart. UE&C is respon-

sibile for the second level surveillance and audits of PPP activities

as well as the resolution of construction related Engineering Change

Authorizations (ECA's) and Nonconformance Reports (NCR's). The

licensee's quality assurance group provides the third level QA/QC

audits of PPP activities.

26

The licensee's walkdown of completed piping and support installations

for "as-built reconciliation" has just started. This activity is

conducted by UE&C as part of the Piping and Pipe Support Close Out

Task Team (PAPSCOTT) program.

The fabrication, erection, and quality control activities related to

HVAC duct work and support installation were performed by Hirsch-

Arkin-Hershman Fabricators (HAH) prior to the construction shutdown

in 1984. After the restart of construction, the fabrication and

erection of HVAC installations are the responsibility of Pullman

Construction Industry (PCI), while quality control activities are

being performed by UE&C.

6.2 Piping and Pipe Support Installations

The Residual Heat Removal System (RHR) piping, between the RHR

pump RH-P-8B and the cold leg of the Reactor Coolant System (RCS),

was selected to assess the level of compliance of piping and pipe

support installations with the applicable codes, standards, and

specifications. This was accomplished by a review of quality docu-

ments, examination of pipe and pipe support installations including

independent measurements of parameters such as, pipe wall thickness,

pipe ovality and pipe support weld dimensions.

Applicable sections of the documents listed in Attachment I were

reviewed in part to verify that applicable regulatory, requirements,

design basis and FSAR commitments for system components and supports,

are correctly translated into specifications, procedures, and

instructions.

The documents reviewed included specifications and procedures gover-

ning the fabrication and erection of piping and pipe supports includ-

ing concrete expansion anchors. The review also included technical

procedures governing the location of attachments to embedded plates

and attachments to building structural steel (Beam Verification

Program). Procedures used by design personnel in the preparation,

documentation and control of pipe support design calculation were

also reviewed during this inspection.

No violations were identified during this review.

However, lack of clarity and conflicting gap tolerances in Procedure

JS-IX-6 contributed to the violation discussed in item (2) of para-

graph 6.3 below.

__ _ . _ _ _ _ .

.

27 .

6.3 Verification Walkdown and Independent Measurements Inspection

A physical inspection was performed of piping and pipe support

installations on the RHR system piping between the nozzle of pump

RH-P-8B and the cold leg of the RCS. The purpose of the inspection

was to verify that installed configuration are complying to construc-

4 tion drawings and/or any field authorized changes. The verification

effort was conducted using visual inspection in addition to perform-

ing independent measurements of selected piping and support compo-

nents.

The verification of piping and pipe support installations included

the following attributes:

Checking actual configuration against support drawing, including

dimensions;

Checking directions in which hangers restrain piping and clear-

ances between pipe and hangers;

4

Checking connections to the proper structure;

Checking sizes of weld on hangers; including welded attachments

j to pipe;

,~

Checking baseplate dimensions and location of structural attach-

ment on the baseplate;

Checking baseplate bolts for tightness, edge distance, and

minimum embedment for a representative sample of anchor bolts;

Checking that restraint bleed holes are open and free from

foreign material;

Checking valve types, orientation and tagging;

Checking proper grounding of floor mounted supports;

,

Checking code data plates for shop welds; and

a Checking that movement of piping due to vibration, thermal

expansion, etc., would not likely contact other pipes, supports,

I

equipment or components.

,

Verification by independent measurements included the following

attributes:

,

1

!

A

.

28

Piping outside diameter (00) at two perpendicular axes to check

for cross section ovality;

Piping wall thickness;

Fillet weld measurements;

Dimensional verification of support structural members including

baseplates; and

Dimensional verification of valves, flanges and support location

along piping runs.

A listing of the piping systems and pipe supports examined during

this inspection is provided in Table 6-1.

Table 6-1

Listing of RHR System Piping and Supports Installations Inspected

Isometric Piping Pipe Support Independent

Drawing No. System No. Number Valve No. Measurement

RH-157-01 1-RH-157-1-601-8" 157-SH-1 8"-RH-V40 P

1-RH-157-1-601-8" 157-SG-2A S

1-RH-157-1-601-8" 157-SH-28 S

1-RH-157-1-601-8" 157-RG-3 S

1-RH-157-1-601-8" 157-RG-4

1-RH-157-1-601-8" 157-RG-5

RH-157-6-601-3/4" 1-RH-3/4"-V43

RH-157-02 1-RH-157-1-601-8" 157-SG-7 S

1-RH-157-1-601-8" MS-157-SG-10 8"-RH-V45

RH-157-03 1-RH-157-1-601-8" 157-RG-11 P

1-RH-157-1-601-8" 157-SV-16

RH-158-01 1-RH-158-2-601-8" 158-SH-8 S

1-RH-158-2-601-8" 158-SV-2

RH-158-02 1-RH-158-2-601-8" 158-SG-7

1-RH-158-2-601-8" 158-SG-4 HCV-607

RH-158-03 1-RH-158-2-601-8" 158-SG-9

1-RH-158-2-601-8" 158-RG-11

_ _ _ _ _ - _ - _ .

.

29

Table 6-1 (Continued)

Isometric Piping Pipe Support Independent

Drawing No. System No. Number Valve No. Measurement

RH-158-04 1-RH-158-4-2501-6" 158-SG-24

1-RH-158-4-2501-6" 158-SG-23

1-RH-158-4-2501-6" 158-SG-33

1-RH-158-4-2501-6" 158-A-20

158-RH-05 1-RH-158-3-2501-8" 158-SG-17 S

(M/S-275-SG-5)

1-RH-158-3-2501-8" 158-SG-16

1-RH-158-3-2501-8" 158-SG-15

158-RH-06 1-RH-158-3-2501-8" 158-SV-14 RH-8-V26

158-RH-07 1-RH-158-5-2501-6" 158-SG-25 RH-6-V29

1-RH-158-5-2501-6" 158-SG-26 RH-6-V63

1-RH-158-5-2501-6" 158-SG-28

158-RH-08 1-RH-158-5-2501-6" 158-SG-30

1-RH-158-5-2501-6" 158-SG-32

1-RH-158-5-2501-6" 158-SG-33

1-RH-158-5-2501-6" 158-RM-35

S1-203-04 1-SI-203-2-2501-10"

Notes: 1. Designations (P) and (S) for independent measurements verifica-

tion refer to piping and support respectively.

2. The correlation between pipe supports designation and loading

restraint function is tabulated below:

Type Symbol Restraint Function

D. Wt. Sesimic Transient Thermal

Anchor A X X X X

Support Hanger SH X X

Support Guide SG X X X X

Restraint Guide RG X X X

Variable Spring SV X

Snubber RM X X

_ _ _ _ _ __ ._ _ ____. _ _ __ _ _ _ _ _ _ _ _ . _ - __ _ - _ _ _ _ .

,

30

The inspector identified the following concerns: i

'

(1) Pipe Support No. 157-SH-2B is a bi-lateral box structure

restraint on a horizontal pipe run, located approximately 9'-7h"

from the RHR pump (RH-P-88) discharge. A zero clearance was i

specified between the piping and the top member of the support

structure. The support was constructed and inspected according

to the design drawing. The design temperature for the RHR Line

157 is 400 F. Upon line heatup, thermal expansion would bind

'

.

the piping to the support. This in turn will induce local com-

pressive stresses in the piping. Additionally, it will inhibit

i

the free axial movement of the line contrary to the assumptions

of the piping stress analysis.

l

The licensee was notified of this finding and was requested to ,

i

'

identify similar pipe supports for which a zero clearance was '

specified on the design drawing.

'

4

,

In a meeting conducted onsite between the NRC staff and repre-

-

sentatives from the licensee to discuss actions initiated by the

^

license in this regard, UE&C informed the staff that a survey is

being conducted on 1740 pipe supports which were designed before

the issuance of the design guidelines for pipe supports in

February of 1980. At the conclusion of this inspection the

- licensee had completed reviews for 900 supports. Of the 900

l supports reviewed by UE&C, 21 supports had zero clearance

'

The eight anchors

'

specified (8 anchors and 13 bi-laterals).

were evaluated and qualified by analysis in a study performed in 1

1984 for all anchors with specified zero clearance. Evaluation

of the thirteen bi-lateral supports will be deferred until the ;

completion of the remaining 840 ~ supports. Upon completion of t

the review, all identified supports with zero clearances will be

analyzed and corrective action, if needed, will be taken. The

licensee committed to complete this review and report the find- '

'

ings within sixty days.

! The design and installation of bi-lateral pipe restraints with l

'

zero clearance is a violation of ASME Section III, Subsection NC '

3624.1(c) which requires that hangers and supports to be

designed to permit expansion and contraction of the piping

between anchors. It is also in violation of Section 3.5.7.1 of

,

UE&C Specification 9763-006-248-51 for the assembly and erection

i of piping and mechanical equipment, which requires all hanger

1 installations to accommodate for thermal growth. The above l

)

identified concerns are contrary to the requirements of 10 CFR !

50, Appendix B, Criterion I and UE&C Procedure QA-1 in that UE&C

as A/E did not assure the control of quality related activities

j relative to design. This finding along with the concerns iden-

'

tified in paragraph 4.7 and item 2 below collectively constitue a i

violation. (443/85-15-04)

,

5

1

<

- - - . . - - - _-- -- - .-_- . . - - - - _ - - _ _ _ . -

l

I

.

i 31

,

(2) Pipe Support No.157-SG-17 is a bi-lateral restraint on a

. horizontal run of the RHR piping. The support drawing ;

i specifies a 1/16" clearance between the piping and the top

. member of the support structure. However, the support was

i

found to be installed with zero clearance. A review of the

requirements for pipe gaps in Section 11.3.1 of (PPP) Pro-

I.

cedure JS-IX-6, and further discussions with UE&C and (PPP)

l personnel, indicated that the requirements for clearances

!

in the installation and inspection of pipe hangers were i

being interpreted differently by different organizations i

l- such that supports with specified clearances were accepted l

as long as a minimal clearance existed during fit-up. This

l was attributed to the vagueness and contradiction in the

requirements of the above procedure. The licensee was

! requested to evaluate the identified deficiency and its ,

!

^

cause, in addition to the identification of other supports '

which are installed and inspected with similar clearance

problem. Results of the licensee's evaluation are expected

within sixty days. !

i This is also another example of a violation of the requirements

in ASME Section III, Specification 345-51, Criterion I of

i Appendix 8 to 10 CFR 50 and UE&C Procedure QA-1 in that UE&C as

discussed in item 1 above. This is the third example for the

,

violation discussed in item 1 above. (443/85-15-05) -

6.4 Review of Design Activities i

4

Review of design activities was performed by auditing pipe support

design calculations for the RHR and SI system piping. Specifically,

, M/S 275-SG-5: Multiple pipe support which includes the support for

'

RHR piping 158-SG-17 and !

M/S 236-A-5 and M/S 236-5-236-RG-3 for SI line No. 236-1-601-2".

! were reviewed to verify that the calculations were performed accor-

ding to administrative engineering and design procedures and that

j they meet the regulatory requirements.

In addition, a review was performed of various Engineering Change

i Authorizations (ECAs) which addressed piping an1 support installa-

.

tions for the RHR piping line #157 and 158. The review was intended

I

to assess the cause of the change or deviation from the design draw-

4

ing and the technical adequacy of the engineering resolutions or

alternatives provided. The reports reviewed are listed below in

j Table 6-2 along with the particular component or support affected.

,

j

l

I L

i

i t

. - _ _ _ _ . . _ ___ _ ._

.

32

i

Table 6-2

ECAs Reviewed for RH-157 and RH-158 Piping

Document Component Affected

--

ECA 25/100060-B 158-RM-31(Support)

--

ECA 25/105013-A 158-RM-18 (Support)

--

ECA 735131-A 157-RG-8 (Support)

--

ECA 25/8298-A 2487-SG-205 (Support)

--

ECA 192552-A RH-155-2-601-8" & RH-158-2-601-8"

--

ECA 25/101235-B Spec. 18-17, 248-43 & 46-1

--

DCN 08/0669-B 202-RM-15, 201-RM-15, 203-RM-15 and

204-RM-15(Support)

155-RM-31, 158-RM-35, 163-RM-12 and

162-RM-13 (Support)

--

ECA 191458-A FWO409 on RH-158-4-2501-6"

--

ECA 253525-A 158-SG-23(RHR-Support)

, --

ECA 252994-A 157-SG-13 and 157-SG-14 (Supports)

--

ECA 252363-C 158-SG-33(Support)

--

ECA 250150-A 157-SG-2A and SH-2B (Supports)

The inspector identified the following concerns:

The review of design calculations for pipe support No. 158-SG-17

(included with M/S 275-SG-5), indicated that the calculations for the

weld design, between part No. 4 (tube steel) and part No. 14 (channel

section), were not performed, though it was specified on the design

drawing.

Upon discussion of this finding with UE&C design personnel, it was

evident that the requirement for documenting the design assumptions

was not always adhered to, as required by the General Engineering

Design Procedure (GEP-0005), and the Administrative Procedure (AP-22)

for design calculations.

The licensee acknowledged the need for training for the pipe support

design engineers to emphasize the requirements for design control as

described in UE&C Procedures AP-22 and Procedure PSG-1-3001 for

preparation, documentation and control of pipe support calculations.

The licensee agreed to complete the required training by August 15,

1985. This item is unresolved pending the licensee's evaluation of

the identified calculation deficiency and completion of the proposed

'

training (443/8575-06).

i

-

. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _

.

33

.

6.5 Piping and Pipe Support As-Built Reconciliation Program

A review of the piping and pipe support as-built reconciliation pro-

gram was performed during this inspection. This activity is being

conducted by the Pipe and Pipe Support Close Out Task Team (PAPSCOTT).

The charter of the PAPSCOTT program is threefold:

--

Reconcile as-built piping and pipe support installations

--

Complete piping preoperational thermal / vibration testing

--

Closecut of the above tasks to support the commercial operation

date

The program is headed by a task team coordinator, who is assisted by

an independent review team. The various disciplines contributing to

this ef fort are headed by a sub-task team coordinator. These activ-

ities include: balance of plant (80P); NSS reconciliation; NSSS

tFermal/ vibration; safe team; B0P vibration; construction; QA/AI;

startup; and planning / scheduling.

A flow chart (Figure 6-1) identifies the major steps and sub-

programs contributing to the PAPSCOTT effort which are required to

support the ASME system hardware completion and documentation close-

out for plant licensing.

The various steps and procedures required for the execution and

completion of each sub-task in the above chart are identified in a

memorandum from the PAPSCOTT task coordinator. Some of those pro-

cedures were reviewed in the course of this inspection, with partic-

ular emphasis on those procedures pertaining to the reconciliation

and analysis of as-built piping and support installations. The pro-

cedures reviewed are listed in Attachment 1 of this report.

The staff also reviewed a PAPSCOTT program status report which

included charts identifying the starting data, percentage completion

and planned completion date of the various activities in this

program.

6.6 _ Review of ASME System Field Data Completion Program

The inspector conducted a sample review of the on going effort by

UE&C's team for the ASME system field data program. The team con-

sists of sixteen members who are performing and coordinating the

walkdowns and draf ting of as constructed configurations. The team

activities started a few months prior to this inspection. Since many

of the pipe support installations are at various degrees of comple-

tion or had not received a final QC inspection, the as-built

isometrics are being prepared and marked as preliminary pending the

completion of QC inspections (QAC).

- _ _ _ _ ___

.

FIGURE 6-1 ASME COMPLETION PROGRAM FLOW CNART

l

.

i

.i

I

' AS-ENGINEERED

j ANALYSIS / REDESIGN

1

i s u

!

.o

INITIAL DESIGN m INSTALLATION

,

I

i y

I

AS-CONSTRUCTED INSTALLER "NA"

'

RECONCILIATION s AS-CONSTRUCTED m N-5 CODE DATA

i SCOPE DEFINITION

'

PROGRAM

'

REPORTS $

! t

-

.,

i

J

"N"

p N-5 CODE

f DATA REPORTS

'

RECONCILIATION , ,

AS-BUILT / CHANCE m RECONCILIATION

' ANALYSIS

i CONTROL PROGRAM

N-3 CODE

DATA REPORT

_

'

A

e

!

I

'

. _ ..

_ ___ _ _

35

The licensee's field team activities are conducted according to pro-

cedures FAEP-1, TP-26, and TP-27.

A review of three reconciliation piping packages for the safety

injection system was performed during this inspection. Each package

contains a preliminary piping isometric drawing, marked up field

verified drawing by Pullman and applicable ECA's and NCR's.

The reconciliation packages reviewed included model 511.55, model

515.20 and model 515.40.

In addition, a walkdown was conducted by the staff to verify the

conformance of as-built configurations of piping and support systems

in the above models to the reconciliation drawings. Table 6-3 iden-

tifies these piping systems by isometric numbers and related supports

inspected.

Table 6-3

Piping Systems and Supports Inspected

Piping Isometric No. Support No.

511.55 263-SG-3

511.55 263-RG-4

511.55 263-RG-5

515.20 M/S 236-RG-2

515.20 M/S 236-A-5

515.20 236-SG-7

515.40 M/S238-SG-3

515.40 238-RG-2

515.40 238-SG-7

No violations were identified.

6.7 Safety Related Heating, Ventilation, and Air Conditioning Systems

(HVAC)

The HVAC activities performed by HAH fabricators prior to the shut-

down in 1984, and those performed by PCI after the restart were

reviewed to determine the adequacy of HVAC systems completed and

accepted by QC.

.

36

Applicable sections of the documents relating to the fabrication,

installation and inspection of HVAC duct, equipment and supports were

reviewed in part to verify that applicable regulatory requirements,

design basis, and FSAR comments for HVAC safety related systems are

correctly translated into specifications, procedures and instruc-

tions. The documents reviewed are listed in Attachment 1 of this

report.

No violations were identified during this review.

6.8 Walkdown Inspection of HVAC Ductwork, Equipment and Support

Installations

The inspection included visual and physical examination as well as

independent measurements. The verification of HVAC system instal-

lations included the following attributes:

Checking actual configuration against component support

drawings, including dimensions;

Checking directions in which hangers restrain ductwork and

maximum clearances between ductwall and hangers;

Checking connections to the proper structure;

Checking sizes of weld on hangers and ductwork welded stiffeners

and joints;

Checking baseplate dimensions and location of structural attach-

ments on the baseplate;

Checking baseplate bolts for tightness, edge distance, and

minimum bolt embedment for a representative sample of anchor

bolts;

Checking duckwork for uniformity of cross section and freedom of

holes, dents and wrinkles;

Checking for proper structural member sizes and bolt identifica-

tion on hangers; and

Checking for tolerance and gaps between hanger baseplates and

concrete wall.

The HVAC system ccmponents and support installations inspected are

tabulated in Table 6-4 including the location of the installations

and applicable drawing numbers.

No violations were identified.

_ _ - _ _ _ _ _ _ _ _ _ _ __ -

- - ..- . . ... ._ - .- . . . -

,

i

!

37

Table 6-4 HVAC System Installations Inspected

i Component

FabricatorlType [ Component No.l Location IDrawing No. ;

,

HAH l Fan Support lFN-20-33 l Control Bldg. I SM-604094 l

i l l lEl 50' - 0" l ,

i HAH l Duct Support lFN-33-34 l Control Bldg. l l

, l l lEl 21' - 6" l 604094 l

HAH l Duct Support lFN-22-59 l Control Bldg. l Fab. Dwg. # l

.,

l l lEl 50' - 0" [FN-22-59 1

HAH l Duct Support lFN-22-60 l Control Bldg. l Fab. Dwg. # l

l l lEl 50' - 0" l 22-60 l

HAH l Duct Support lFN-22-57 l Control Bldg. l Fab. Dwg. # l

lEl 50' - 0"

'

l l l 22-57 l

.

PCI l Duct Support lEAH-FN-69-2 lM.S. & F.W. I SM-604601.3 l

l l IEl. 3' - 0" l l

PCI l Fan Support lEAH-69 lM.S. & F.W. 1 SM-604078-3 & l ;

,

l l IE1. 3' - 0" l ECA # 0680248A l

i

, PCI l Duct Support lEAH-FN-68-2 lM.S. & F.W. l SM-604601-3 & l

'

i l l lE1. 3' - 0" l ECA #0105576A l

) PCI l Duct Support lEAH-FN-69-1 lM.S. & F.W. l 604078-3 l

]

t

l l lEl 3' - 0" l l

PCI l Fan Support IFN-47A-478 l Containment l SM-604141-1 1

4 l .1 lEFW, El. 27' - 0"l l

3 PCI l Duct Support lFN-68-3 lM.S. & F.W. l SM-604078-3 l

9 l l 1 El. 3' - 0" l l

<

! PCI l Duct Support lFN-1-98 l Containment l SM-604-132-4 l

j l l l E1.(-) 26' - 0" l l (

) PCI l Duct Support lFN-1-97 l Containment l SM-604-132-4 l

j l l lEl (-) 26' - 0" l l

I

6.9 QA/QC Involvement in Piping, Supports and HVAC Activities

The licensee's audits for UE&C and other contractors activities in

+ the area of piping, pipe supports and HVAC were reviewed.

J

The licensee's audits are conducted and reported according to the

i requirements of the General Audit Procedure No. 9.1 of the Seabrook

,

'

Station QA manual and Section Q-119 of the Construction Quality

Assurance Guidelines (CQA).

\

!

-

!

4

.

38

The licensee conducts four audits annually at UFLC corporate office

in any discipline of engineering. Site audits are conducted once a

year for every engineering discipline. These audits focused on the

following procedures which implemented ANSI 45.2.11 requirements at

the site.

9763-PSG-1-3001 - Preparation, Documentation and Control of Pipe

Support Calculations

GEOP-0005 - General Engineering Design Procedure

AP-15: Admin. Procedure for Design Change

AP-22- Admin. Procedure for Preparation of Calculation

AP-54: Admin. Procedure for Verification of Calculations

The following licensee audit reports were selected for review:

1. YAEC Seabrook audit report No. SA799CS332 on 1/16-25/1984 of HAH

on site activities, in the area of QA program, procurement

document control, instructions and procedures. The audit

identified four deficiencies which were subsequently resolved.

2. YAEC Seabrook Audit Report No. SA810CS341 or 2/15-22/84 on site

and HAH office in Philadelphia. The audit covered HAH QA pro-

gram concerning the identification and control of materials,

parts, and components. Three deficiencies were identified in

this audit.

3. YAEC Seabrook audit report No. SA838CS363 on 6/26/84 of HAH at

Seabrook station. The audit covered QA records and open SSCA

items from previous audits. No deficiencies were observed.

HAH's QA program at the time of the audit was limited to the

review and turnover of quality assurance records.

4. YAEC Seabrook audit report No. SA870VE029 was conducted at UE&C

home office on 11/13-16/84 to review of the beam verification

program. Thirteen deficiencies were identified during this

review. Attached to the audit report was UE&C's response to the

audit findings. As a result of this audit, a technical repre-

sentative from YAEC was stationed at UE&C corporate office for

several weeks to follow-up on the implementation of this

program.

i

39

5. YAEC Seabrook audit report No. SA888UE030 at UE&C corporate

office on 1/28 to 2/1/85. The audit was conducted to verify the

adequacy and the level of compliance to the established quality

assurance program in design control, control of purchased mate-

rial, and equipment and services in the instrumentation / control,

and electrical discipline.

The audit identified three deficiencies and two observations and

closed out thirteen findings from previous inspections. The

licensee's conclusion from this audit was that UE&C was ade-

quately implementing their QA program and engineering services

for Seabrook project.

6. YAEC Seabrook audit report no. SA905UE031 at UE&C office on

4/22-26/85. The audit covered design control, procurement

document control, audits, ' inspections, control of measuring and

test equipment, handling, storage and shipment. The design

portion of the audit covered HVAC and pipe support system. In

the design control area, ten calculation sets were reviewed for

pipe supports in addition to eleven calculation sets for HVAC

systems. One deficiency was identified in the pipe support

area, and two in the HVAC.

No violations were identified.

7. Welding and Metallurgy

The objective of this portion of the inspection was to determine the

licensee effectiveness and program adequacy in controlling and performing

welding activities in accordance with design requirements, SAR commit-

ments, and applicable codes, specifications, and procedures. The effect

of recent organizational changes in the welding effort was also reviewed.

Work in progress, completed work, records of completed work, and welding

procedure specification documents were reviewed. An additional objective

was to determine if the personnel involved in welding engineering, welding

and inspection activities were adequately trained and qualified to perform

their duties in accordance with the applicable requirements. Welding

activities related to the fabrication of American Society of Mechanical

Engineers (ASME) piping for portions of the RHR and SI systems, various

types of structural supports for the RHR and SI Systems and HVAC duct work

were reviewed. These activities were conducted in accordance with ASME

Section (SC) III NB, NC, and NF; B31.1; AWS D1.1, and AWS 09.1 Codes.

Completed work package documentation reviews included weld history

records, NDE inspection records and appitcable non-conformance reports

(NCR's). Welder serial numbers were obtained from visual inspection of

welds and weld history records. Qualification records for these welders

were reviewed for conformance to the applicable codes.

..

.

40

Welding conducted by Pullman-Higgins, PCI and HAH was inspected. Generic

issues important to structural welding, such as, verbatim compliance to

D1.1, qualification tests for flare bevel welds, and preheat were re-

viewed. The UE&C adoption program for Pullman-Higgins ANSI B31.1 welding

procedure specifications (WPS), procedure qualification records (PQR), and

welder performance qualification (WPQ) records was reviewed. The details

and findings for each of the inspection areas are described below:

7.1 Organization

Installation, welding, NDE, and QC inspection of piping is performed

by Pullman-Higgins with second level inspection and QA by UE&C.

Installation and welding of HVAC ducts and supports is performed by

PCI with QA/QC coverage by UE&C and QA surveillance by the licensee.

7.2 General Welding Review

The inspector reviewed the following documents related to the walk-

down inspection. (Field welding by Pullman-Higgins)

Welding package for RH-158-01 (Class 2) which included the

following:

- Field welds F101 through F109 (including repair welds on

F101 and F106), F111, F111R1, and F112

- NCR's 6567, 7005, 1119, and 1574.

- Applicable ANI Sign o'fs were noted

8 welders WPQ records were reviewed.

Welding package for RH-158-03 (Class 2) which included the

,

following:

- Field welds F302, 302, 303

- NCR 4710

WPQ records of one welder

Welding package for RH-158-08 (Class 1) including the following:

- Field welds R801 through 805 including repair weld 803R1

- NCR's 2456, 3589, 2545, 4997, and 4930 which included

records damaged by fire

.

41

- Verified certified material test reports for the following:

Consumable insert AT464107, 3/32" diameter E316 filler

metal Heats A, C&D-4237T316

- Filler metal purchase order documents for P0's 27707 and

10219

Three welders WPQ records were reviewed.

The documents reviewed met quality program and codes and standards

requirements.

The inspector reviewed the UE&C program for filler metal control and

conducted an inspection of two filler metal issue stations and the

warehouse storage area for filler metals. Portable electrode ovens

are properly employed for hygroscopic electrodes. Review of FGGP-17

indicated that UE&C recently changed the requirement for discarding

electrode stubs to permit them to be discarded in more conveniently

lccated recepticles than at the filler metal distribution centers.

The inspector found a few electrode stubs on the floor adjacent to

the pressurizer relief tank. This is considered to be an isolated

case as the inspectors found no other improperly discarded stubs

during the two week period of this inspection.

Inspection of the filler metal distribution (issue) stations indi-

cated that the filler metals were properly identified (with AWS/ASME

designations), filler metal heat numbers were maintained, storage

ovens were at proper temperature, thermometers were properly cali-

brated and the filler metal issue QAE personnel were fully knowledge-

able of their functions. The warehouse storage area inspected indi-

cated the filler metals to be properly stored and identified. How-

ever, one filler metal (utilized for balance of plant welding) was

identified by its commercial designation rather than by AWS/ASME

designation. Review of the applicable WPS showed that both designa-

tions were indicated thus minimizing the adverse effect of using the

commercial designation.

The filler metal control system met licensee quality requirements and

met or exceeded minimum codes and standards requirements.

The following filler metal certified material test reports (CMTRS)

were reviewed.

42

Filler Metal Size Heat Lot Manufacturer

E70T-1 0.045 50573 -

Alloy Rods

E70S-2 1/8"x5/32" 421N3602 -

Consumable insert

(SANDVIK)

E70S-3 0.035 3101 -

RAC0

E70S-3 0.045 3101 -

RAC0

ERNiCrMo-3 3/32" NX96C2AK -

HAPD

ER316L 3/32" C4735T316L -

ARCOS

ERCuAt-A2 3/32" G5739 FMK-1 AMPC0

ERCuAt-A2 1/16" V9719 CYM-2 AMPC0

E70S-2 1/8" 065433 LINDE

E308L-16 1/8" -

11097-1 SANDVIK

E308L-16 3/32" -

50348-1 SANDVIK

E309L-16 1/8" -

90147-1 SANDVIK

E309L-16 3/32" -

90110-1 SANDVIK

The material reviewed met applicable Codes and Standards requirements

and purchase order requirements.

No violations were identified.

(1) Performance Qualification

Welding qualification records of P-H welders and PCI welders

were reviewed. Included were welders qualified to ASME SCIX,

AWS D1.1 and AWS 09.1 requirements. The inspector also observed

a welder qualification test including cleaning, fitup, stencil-

ing identification, welding, visual inspection, removal of bend

specimens, bending, and visual inspection of bend results for a

special PCI flux cored arc welding (FCAW) performance qualifica-

tion required by DR 52-5137-A. The inspector also observed a

standard D1.1 new hire PCI welder performance qualification test

and the bending of the test assembly.

Review of PCI qualification records indicated deficiencies in

the methods used to record the actual thickness welded and the

" mode of metal transfer" for short-circuiting gas metal arc

welding (GMAW-S) welders.

Review of the PCI welder performance and UE&C welder performance

program indicated that neither had an independent QC verifica-

tion of the results of destructive or non-destructive tests nor

an additional QC sign off of the performance qualification

records, however, independence in the examination of performance

qualification test plates is not an ASME Code requirement.

_ _ _ _ . .- _ - - . . - .

d

43

The qualification recordkeeping meets the requirements of UE&C

FWP-2 paragraph 3.6. UE&C provides QC surveillance inspection

in the P-H and PCI welder performance area and the licensee

performs QA surveillance audits on these activities.

The inspector reviewed the system used by PCI for indoctrination

training (S-FWP1.1/9.1) of new welders and found it to be an

"

acceptable method for the purpose intended.

During review of the P-H welder qualification records it became

apparent that P-H is utilizing the interpretation of SCIX QW

404.28 for gas tungsten arc welding (GTAW) which indicates that

qualification with any F6 filler metal qualifies for any other

F6 filler metal including consumable inserts (QW 404.22 still

applies). Discussions with UE&C and the licensee confirmed that

this is considered a site wide position. UE&C stated that

although F numbers are not listed in SFA 5.30, they purchase

consumable inserts to both SFA 5.30 and the applicable SFA5.9 or

SFA 5.18 specifications for chemistry which establishes an F

i

number. The inspector indicated that this position met SCIX

requirements as clarified by interpretations and was a judge-

4'

mental engineering position. The licensee and UE&C committed

that they would write a letter clarifying this position to avoid

! future confusion on this issue.

3

During the course of this inspection, DR-52-5137-A was written

on the use of an unqualified procedure and welder by PCI. This

was identified by the licensee. The inspector attended tech-

l, nical meetings where the resolution of this problem was dis-

!

cussed. It was determined that removal and re welding was less

'

satisfactory than an after-the-fact qualification of the pro-

cedure and welder. The inspector found the engineering solution

to the problem to be acceptable. See paragraph 7.4 for the

corrective actions taken by the licensee in this regard.

3

The welder qualification programs met requirements except as

specifically noted.

No violations were identified.

(2) Preheat

In the course of the review of welding specifications and pro-

cedures it was noted that there is a plethora of preheat rules

for welding similar structural type configurations (ASME SCIII

NF, 831.1 and D1.1). This necessitated a further study.

The UE&C general rules for preheat are specified in FWP-18 Para-

graph 5.2.6.1 which states that preheat shall be in accordance

i

with the applicable WPS and 5.2.6.3. Paragraph 5.2.6.3 states

that preheat shall be the highest temperature required for the

material (s) or material thickness (es) being joined.

l

_ _ _ _ _ _ _ . _ . . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ - - _ , _ _ . _ . _ _ _ . _ _ _ _ _ _ _ _ , _ ..__

.

44

UE&C FWP-43 Rev. O specifies the preheat requirements for pip-

ing, components and support welds fabricated in accordance with

ASME SC III and ANSI B31.1. Paragraph 4.4.4 of FWP-43 indicates

the preheat shall be the highest temperature for the materials

or material thicknesses being joined. This document also

directly reproduces the applicable sections of the ASME and ANSI

B31.1 codes, Although these codes are not explicit, the signif-

icant UE&C Ularification statement is that the preheat is based

on the thicker material joined. Review of the materials uti-

lized for fabrication indicated that there were essentially no

materials utilized which exceeded the 0.3% carbon level refer-

enced in the ASME and B31.1 codes. The thickest and most highly

restrained joints welded are fabricated to AWS D1.1 (which

clearly indicates that preheat is based on the thickest member

being joined). Review of typical WPS and weld data packages

indicates that preheat is correctly and conservatively addressed

on both a " Codes and Standards" basis and on the more important

engineering (metallurgical) basis even though the code reference

documents are not explicit, at times confusing, and in some

cases not conservative.

No violations were identified.

(3) Welding QA

The inspector reviewed a rough draft copy of the licensee's QA

audit of PCI (#SA916CS426) conducted May 28-31, 1985. As cur-

rently written this audit will indicate 9 deficiencies and 2

, observations. The deficiencies were in material storage, mate-

'

rial traceability, document control and distribution, inadequate

parameters for " pin" welding, and inadequate control of charge

sheets. Actions are being taken to recti fy these problem

areas.

Also reviewed were the following YAEC Field Quality Assurance

Surveillance Reports:

-

Date IMS# l

.x

4/10/85 E-01-13-01: PCI Welder Qualification

5/24/85 H-09-13-09: PCI Support Welding

5/14-16/85 H-09-13-09: PCI Compliance to S-FWP-1.1/9.1

., 5/16-17/85 G-07-02-13: In process welding of supports (PCI)

'(

5/8-9/85 G-07-04-13: Compliance to procedures (PCI)

- - _ -

1

I

i

45

5/2-3/85 H-09-13-09: Compliance to S-FWP-1.1/9.1 (PCI)

4/23-25/85 H-09-13-09: Compliance to S-FWP-1.1/9.1 (PCI)

4/30/85 Q-03-02-09: Huck Fastener Installation (PCI)

4/19/85 H-09-13-09: Review of documents (PCI)

The audits indicated thorough QA surveillance of PCI activities. '

UE&C will use the authority of B31.1 paragraph 127.5.3 to utt-

lize (adopt) Pullman-Higgins B31.1 welding procedures, welding

procedure qualifications; and welder performance qualifications.

As this is not permitted in ASME SCIX this will be limited to

831.1 welding. This system meets the licensee's approval as

required in 127.5.3.A. The inspector reviewed many of the

" adopted" procedures. Those procedures reviewed are listed in

Attachment 1.

No violations were identified.

(4) D1.1 Welding

There are a number of specific areas where there have been con-

flicts between the general commitment to 01.1 and actual prac-

tices at many specific locations. The inspector investigated

many of these areas to obtain the licensee's and UE&C's posi-

tion. The licensee's positions in the inspected areas are

summarized below:

UE&C follows 01.1 paragraph 6.5.6 and requires a distin-

guishing mark (by the QC Inspector) on joints inspected

(even though quality system recordkeeping documents exist

which would meet the intent of the requirement).

The use of materials not specifically listed in 01.1 Table

4.1.1 are handled by appropriate Request For Information

(RFI) and Engineering Change Authority (ECA) documents

which meets the " Engineer's" approval requirement. ,

'

UE&C has conducted welding tests to veri fy that actual

throat dimensions meet engineering assumptions for flare

i bevel joints in accordance with the intent of 01.1 para-

graph 2.3.1.4

*

Welding processes not specifically approved as pre qual-

ified in D1.1 paragraph 1.3.1 (e.g. - GTAW) have been

qualified by tests in accordance with D1.1 paragranh 5.2

rules.

.

l

. - _ . , -, , , , _ . . . . - _ _ , . ~ - . . _ _ . . , . _ _ _ . , ,. . . , , . _ , . . - . , _ _ . _ _ . . _ _,-._,__._,,_,,-_._.m.-, ,- - . , _ _ , . _ _ - ,

I

46

The utilization of ASME SCIX procedures and performance

qualifications permitted by D1.1 paragraph 5.2 are author-

ized in FWP documents.

Prior to general adoption of the AWS A2.4 welding symbology

required by D1.1 paragraph 1.5, UE&C utilized their own

welding symbol interpretation document j'nd clarified spec-

ific problem areas in ECA documents. .

In order to always meet the maximum undercut rules regard-

less of direction of the application of stress UE&C adopted

a zero undercut rule

Where the minimum fillet size rules of Table 2.7 and the

size of individual pass rules of paragraph 2.7.1 were not

desired, UE&C conducted extensive welding qualification

tests to provide engineering justification for their

practices

Where partial penetration joints with included angles of

less than 45 were employed, UE&C conducted qualification

tests to justify the engineering assumptions for effective

throats.

For highly restrained joints, specific bead sequence de-

tails were utilized to provide explicit " directions to the

welders."

The following documents related to modifications or clarifica-

tions of AWS D1.1 welding requirements were reviewed:

RFI 5933188 - welding of ASTM: A108 rods and studs to A36

plates

ECA 5930968 - clarification of flare bevel site rules

RFI 593602A - welding of ASTM:A120 materials

RFI 5937108 - use of partial penetration joint rules for

skewed angles

ECA 59004807C - Reinforcement requirements for skewed "T"

joints

ECA 594810A - Prequalification of seal welds

The licensee stated that upon NRR approval of the Nuclear Con-

struction Issues Group (NCIG) Visual Weld Acceptance Criteria

(VWAC) document NCIG-01 they would review the document for

47

applicability at Seabrook, conduct specific training for QC

inspectors, request an FSAR change authorization, and utilize

the document for inspection of D1.1 welds.

No violations were identified.

7.3 HVAC Welding

(1) Visual Inspection of HAH HVAC Weldments

Approximately 337 HVAC completed duct support welds made by HAH

were visually inspected for compliance to drawings, welding

specifications, HAH QP-3 and AWS D1.1 inspection criteria. Minor

spatter and surface slag was noted on two welds where the geo-

metry would tend to cause magnetic arc blow problems. There

were a few minor irregularities in weld size for less than 10%

of the length. It was obvious that the zinc had been removed

from galvanized structural shapes prior to welding and re-

painted with zinc rich paint. On some of the " plate to floor

embedments there was minor edge melting. The weld irregular-

ities were not sufficient to render any of the welds rejectable

and the general weld quality was acceptable.

The supports inspected were RN20-33 and FN22-57.

No violations were identified.

(2) PCI HVAC Welding Program

The inspector reviewed the PCI program for HVAC duct and support

welding. PCI is responsible for welding procedure qualification

and welding fabrication and UE&C has engineering and QC respon-

sibility. The scope of the PCI work is limited to sheet metal

welding to AWS D9.1 and structural support welding to AWS D1.1.

The stiffeners to duct welds are in accordance with D9.1. Most

of the D1.1 joints use pre qualified procedure rules whereas the

D9.1 requires visually inspected procedure qualification test

assemblies. The welders are qualified to 09.1 and D1.1 as

applicable. UE&C utilizes the effective throat penalties (where

applicable) required by D1.1 in their design assumptions. D1.1

pre qualified joint geometries are utilized in the WPS docu-

ments, however, the AWS letter designations for the joint con-

figurations are not used in the drawings or in the WPS docu-

ments. The PCI general welding Procedure S-FWP-1.1/9.1 is

written to meet the requirements of UE&C WS-3.

No violations were identified.

.

48

(3) Visual Inspection of PCI HVAC Welding

PCI HVAC welding was visually inspected by a random selection of

current work in progress with D9.1 and D1.1 welding utilizing

the GMAW-S and shielded metal arc welding (SMAW) processes. The

inspector observed joint preparation, tack welding to obtain

proper root opening on square butt duct welds, GMAW-S duct weld-

ing, and SMAW support fillet welding. Duct welding was observed

in the fabrication shop and in the power plant. The welding

parameters observed for GMAW-S welding were in the range uti-

lized for procedure qualification tests. Completed single sided

square butt joint GMAW-S welds were inspected visually on the

inside (root) of the duct and showed complete fusion. As dis-

cussed in paragraph 7.3.4 welder qualification test assembly

welding and testing was witnessed. Welder qualification records

for PCI HVAC welding were also reviewed.

(4) Review of PCI Welding Procedure Specifications (WPS)

The inspector reviewed PCI shop and field WPS documents for HVAC

sheet metal and support welding to meet AWS D9.1 and AWS D1.1

respectively. The thicknesses of duct welded are heavy, 10 gage

(0.135") and almost are out of the sheet metal range.

Review of GMAW-S WPS procedures indicated that the voltage and

amperage ranges specified exceeded that for legitimate usage of

short-circuiting metal transfer mode and normal recommended

ranges (e.g. AWS Handbook Sixth Edition Section 2, page 23.34).

The GMAW-S WPS also indicated that they were qualified according

to 09.1 to 2T based on welding 3/8" plate (Weld has to pass

visual inspection. No destructive testing required by D9.1). ,

The inspector discussed the lack of technical merit of the wide

amperage / voltage range and the WPS documents which indicated

qualification to 3/4" for a process known for its lack of fusion

defects. The inspector requested a demonstration of the GMAW-S

process at approximately 225 amps and 25 volts. This demonstra-

tion showed that the mode of metal transfer was not by short

circuiting but rather by pinch-off spray and the welding condi-

tions were unmanageable for out of position welding.

UE&C Welding QA and the licensee committed to write a letter to

PCI clarifying that the GMAW-S processes are not permitted for

site usage over 3/8" thickness and that the welding parameters

are limited to the true short arc range (the D9.1 PQR amperage

ranges). The action taken by UE&C shows good engineering prac-

tice exceeding minimum code requirements as AWSD9.1 does not

prohibit qualification to 2T and permits test assemblies for

qualification to be examined by visual methods only.

- _ - - .. - - _ -

49

,

7.4 Weaknesses in PCI Welding Program

i The combination of DR 52-5137-A on use of an unqualified procedure

and welder; deficiencies found in reviews of welder performance

documentation related to " mode of metal transfer" and recording of

actual thicknesses of test assemblies welded; and range of thickness

and electrical variables in D9.1 GMAW-S procedures indicates a weak-

nesses in the PCI welding program. As the licensee has taken appro-

priate action to resolve the DR, committed to correct the errors in

the performance qualification records, and committed to write clar-

'

ification letters to restrict thickness and welding parameters to

meet good engineering practice, this area will be considered a weak-

ness. (443/85-15-07)

7.5 Strength in UE&C Welding Program

4

The UE&C Welding Engineering and Welding QA initiative in following

prudent engineering judgement and criteria exceeding minimum " Codes

and Standards" requirements in areas, where " Codes and Standards"

rules show lack of conservatism, results in improved quality. This

is considered a strength in the program. A few examples follow:

continued use of portable electrode ovens has resulted in

negligible instances of heat affected zone underbead cracking.

institution of fillet gap rules for NF supports (JS-IX-6

paragraph 8.8.1)

zero undercut rules for D1.1 welding

clear definition of preheat rules based on maximum thicknesses

= special testing conducted for single and multiple pass 3/32"

electrode welds on varying thicknesses for D1.1 welding

QC identifying symbols on D1.1 weld joints

detailed tests on flare bevel joints

D1.1 areas which experiences have shown to require clarification

or modification have been well addressed on an engineering

basis.

8.0 Instrumentation & Control Construction

8.1 Organization

To assess the adequacy of the Instrumentation and Control design and

installation activities, the flow and pressure instrument systems for

,

e- # - .-~, --_-- .,-- _,,. -,m-w.- - - - - - , . - - - - - . - . , - - , - - - - ,

. .. _- . - .__

50

the Safety Injection and RHR System were reviewed. Design specifica-

tions and installation procedures were reviewed. Instrument instal-

lations and instrument cable routing activities were observed and

QC inspections were witnessed, and QA audit records were reviewed.

Independent measurements were also performed to verify the conform-

ance of the installed equipment with the design specifications.

New Hampshire Yankee has delegated the engineering and construction

of the I&C systems to United Engineers and Constructors. At con-

struction restart, UE&C assumed the installation and QC inspection

functions of the instruments and instrument cables from Johnson

Control Inc. At the time of this inspection, there were 230 instal-

lation craftsman and 36 QC inspectors at the construction site to

perform the instrument installations and inspection activities. New

Hampshire Yankee provided QA surveillance and QA audits for the I&C

installation activities performed by UE&C.

The details and findings for each of the inspection areas are

discussed below:

8.2 I&C Procedures

The inspector reviewed the I&C installation procedures and related

documents provided in Attachment 1 of this report to ascertain that

NRC requirements and FSAR commitments were properly translated into

the procedures for adequate control and installation of instrument

components and associated items, and that the procedures covered

special handling, installation and maintenance requirements, includ-

ing those pertaining to seismic supports for instruments and impulse

lines, preservation of internal cleanliness, and maintenance of

component qualification requirements.

In reviewing the installation documents the inspector noticed that no

seismic installation criteria ( for Design Basis Earthquake) were

established in the licensee's instrument installation specification

and installation procedures for instrument impulse lines across the

interface of seismic buildings. There were no attributes for the QC

inspectors to verify the adequacy of these seismic installations.

In July 21, 1984, when Johnson Control Inc. was performing the

,

instrument installation, ECA 051383A was issued for the expansion

joint installation of seismic instrument tubing in the East and West

'

Mainsteam and Feedwater Pipe Chase areas. However, this ECA was

never incorporated into the installation specification or procedures

to cover other areas.

A meeting was held on June 13, 1985, to discuss this deficiency. The

meeting was attended by personnel from the New Hampshire Yankee, UE&C

and NRC. In the meeting the licensee stated that the following

corrective actions will be taken by July 1, 1985:

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

I

.

51

(a) Walk down all seismic buildings and review of all building-to-

building instrument tubing installation for sei:mic anchor

displacement (SAD) consideration.

(b) Analyze any installations for which adequacy cannot be

confirmed.

(c) Revise installation specification 46-1 to add SAD requirements.

(d) Revise installation procedures FIP-18 and FIP-34 so that QC

inspectors can verify that SAD was considered in design.

(e) Conduct formal training of SAD requirements. i

The licensee was informed that the above failure to establish and

implement seismic design criteria for instrument tubing was contrary

to the design specification requirements of Criterion III of 10 CFR

50, Appendix 8. This is a violation. (443/85-15-08)

8.3 Instrument Installation - Work Observation

The inspector examined the completed installation of pressure and

flow instruments, and pneumatic control valves in the Safety Injec-

tion System and Residual Heat Removal System.

Location, configuration and installation (including mounting and

anchoring) were according to the latest approved design or construc-

tion specifications and drawings.

Specified instrument components and associated items had been used.

Components had been correctly and permanently identified. Cleanli-

ness requirements had been maintained or otherwise satisfied. In-

stalled equipment was adequately protected from adjacent construction

activities and protective coatings, plugs, bushings, and other mate-

rials had been used as specified. Nonconforming components or con-

ditions had been identified and controlled in accordance with

approved procedures. Appropriate heat numbers were shown on the flow

elements, and the numbers corresponded to the numbers in the original

purchase order.

The following instruments were examined:

a) SI-FE-918, 922 - Safety injection flow elements, (Reg. Guide

1.97 items),

b) RH-FE-610, 611 - Residual heat removal flow elements, (safety-

related).

c) SI-FT-918, 922 - Safety injection flow transmitters (Reg. Guide

1.97 items, seismic Category ).

!

)

i

]

. -- . . . - -- - - - _ . . .

52

d) RH-FIS-610, 611 - Residual heat removal flow indicating

switches, (safety related).

e) RH-FE-618, 619 - Residual heat removal flow element, (Reg. Guide

1

1.97 items).

f) RH-FT-618, 619 - Residual heat removal flow transmitters (Reg.

Guide 1.97 items).

g) RH-FCV-618, 619 - Residual heat removal HX bypass control valves

(position indication portions are safety related).

8.4 Incorrectly Voided NCR's

The inspector noticed that for flow transmitter SI-FT-918, the high

pressure sensing line had an unclamped (seismic clamp) length of 92

inches in a 7 bend configuration, and the low pressure sensing line

'

had an unclamped length of 89 inches, also in a 7 bend configuration.

,

Similar conditions were observed for flow transmitter SI-FT-922,

except that the unclamped lengths were shorter, about 60 inches.

Upon further investigation, the inspector found that these problems

, had been identified by the I&C QC inspector and documented in NCR's

i

93/667 and 93/666 respectively, all dated November 19, 1984. How-

ever, these NCR's were not processed because they were voided by the

lead QC inspector on November 21, 1984, due to his misinterpretation

of seismic requirements. The licensee was informed that the above ,

,

improper disposition of the NCRs was contrary to the procedure adher-

<

ence requirements of 10 CFR 50, Appendix B, Criterion V.

The lead QC inspector assumed that this non IE and non ASME tubing

was not safety-related and did not recognize the need for conducting

the tube support activities under safety-related requirements for the

protection of other vital safety-related components in the immediate

vicinity and paragraph 5.1.6.2 of Seabrock Administrative procedure

No. ASP-3 "Nonconformance," Revision 2 dated May 15, 1985. This is a

violation. (443/85-15-09)

8.5 Negatively Sloped Instrument Tubing

The inspector noticed that for flow transmitter RH-FT-618. both the

high and low pressure impulse lines sloped upward at 3 angle from

<

the source (pipe tap) to the root valves and 6 inches beyond the root

valves to the flexible hose connection (a total of approximately

18 inches). This condition was identified by the I&C QC inspector

and documented in NCR No. 93/489 item #1 on September 28, 1984. The '

disposition for this item was " accept as is" without providing appro-

priate engineering evaluation. The high point in this case is not

the root valve, but 6 inches beyond the root valve.

l

1

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

.

53

The Architect / Engineer performed a calculation (SM #12346A0 on

June 14, 1985, which provided additional justification for this NCR.

This calculation indicated that the possible error caused by air

bubbles would be less than 0.1% full scale. The inspector reviewed

the calculation and found it to be acceptable.

8.6 Maximum Slope On Instrument Tubing

I&C QC inspection attribute #9 on instrument tubing installations

directs the QC inspectors to paragraph 5.9.1.2 of installation pro-

cedure FIP-34, Revision 3 for tubing slope requirements. Paragraph

5.9.1.2 of F1P-34 requires the installed instrument tubing to be

sloped between a minimum of is inch per foot and a maximum of 2 inches

per foot. On June 6, 1985, the inspector noticed that there were

sections of installed instrument tubing for SI-F15-610 and 611 (4

sections, each about 3 inches long) sloped approximately 5 inches per

foot. These were not reported by the QC inspector. Subsequently the

inspector discussed the maximum slope requirements with four more I&C

QC inspectors. Two QC inspectors stated that this should be docu-

mented in the NCR and let the engineer make the disposition. The

third QC inspector was not quite sure about this requirement and the

fourth QC inspector stated that this would not be a requirement and

can be disregarded.

This concern was brought to the attention of the licensee's manage-

ment on June 7, 1985. The I&C QC supervisor met with the NRC

inspector on June 11, 1985, to discuss the 2"/f t. maximum require-

ment. He stated that ECA #761215B was issued on February 6,1984

permitting the instrument tubing installation personnel to use tubing

bent at approximately 45 , which was the case for the 4 sections

identified by the NRC inspector. This ECA contradicted the statement

specified in paragraph 5.9.1.2 of FIP-34, and caused much confusion

to the installation craftsmen and QC inspectors.

The licensee issued ECA 05/106137A on June 10, 1985, deleting the

2"/ft. maximum slope requirement. A copy of this ECA was not avail-

able to the NRC inspector until June 14, 1985.

The licensee, trained the I&C QC inspectors in this ECA during the

week of June 10, 1985. The I&C installation craftsmen were instructed

in this regard by July 15, 1985.

The licensee was informed that this will be identified as a weakness

in the instrumentation tubing installation program. (50-443/85-15-10)

I

1

)

54

8.7 Instrument Cable Installation And Termination

The inspector observed work performance pertaining to the installa-

tion of instrument cables and terminations to determine whether the

requirements of the applicable specifications, instructions and pro-

cedures are being met in areas relating to the material type, size,

routing, support, termination and separation.

Items examined for this determination included:

a) Instrument cable routing and termination from flow switches

(RH-FIS-610, 611) in the RHR Equipment Vault at Elevation -61'

to the Control Room.

b) UE&C DWG 9763-M-310887 SH. B55c " Cable Schematic for Miniflow

Isolation Valve FCV-610" Rev. 5 dated October 28, 1983.

c) UE&C Cable routing sheets - F20-532 and F20-SK8 dated

September 25, 1984.

d) UE&C termination sheets for cables F20-SK8 dated January 17, ,

1985 and F20-S32 dated January 15, 1985.

e) Rework record WR RH-0155 for re-roating and re-terminating

cables due to relocation of RH-FIS-610 & 611, dated May 24,

1985.

No unacceptable conditions were identified in tnese areas.

8.8 Independent Measurements

The inspector performed independent measurements to veri fy the

installation data for instruments and instrument cables. For the

instruments installations identified in paragraph b) above, the

inspector measured the slopes, distances between seismic clamps and

bending radii for the instrument impulse lines, verified the correct-

ness of the instrument valve flow directions, and the instrument

mounting configurations. For the instrument cables and terminations

identified in paragraph c) above, the inspector verified that the

distances between redundant cables met the separation criteria, and

that adeouate slack was provided when cables were terminated.

8.9 Store Room Tour

The inspector toured the I&C storage areas and reviewed the storage

activities and conditions of safety related instruments.

The components were stored in proper storage level designation and

the components were properly identified. The storage conditions were

controlled as specified and the nonconforming items placed in storage

were identified and segregated.

.- _ -. -- . . ._ _ _ - -.- - - _ .

-

,

55

The I&C storage area was located in the Gage and Calibration Build-

i ing. The Gage Facility Supervisor was in charge of the storage. It

was designated as Level B storage. All safety related items carried

green release tags and were segregated from non-safety related items.

The storage conditions of the following safety-related instruments

were observed:

1-SI-FY-2441, 2446, 2456 and 1-22SP-FY-0853 (all were ASCO solenoid

valves Model NP-831654E, 125VOC).

1-SI-PT-2576, Rosemount Pressure Transmitter

2-RH-FIS-610, ITT Barton Differential Pressure Switch, (range:

,

0-73.2" W.G.)

1-CS-PI-9400, P98A,B Discharge Header Pressure Indicator, (Sigma

International Instrument Model # 9-1151-2025)

i

The inspector verified that these instruments were stored properly.

No unacceptable conditions were identified.

8.10 Westinghouse Document Reviews

The inspector reviewed Westinghouse procurement specifications and '

'

purchase orders and determined that Westinghouse supplied instruments

met the design requirements.

The following Westinghouse documents were reviewed:

(1) Westinghouse Specification Sheet No. 03810 for flow elements

RH-FE-610 & 611; RH-FE-618, 619; RH-FE-918, 922, Revision 12,

, dated August 13, 1984.

(2) Westinghouse P.O. #546-CMT-280215-BM dated March 24, 1980 to

Vickery Sims Inc. for flow elements identified in (1) above.

.

(3) Westinghouse Specification Sheet No. 01412 for flow transmitters

4

SI-FT-918, 922, Revision 20 dated April 24, 1985.

(4) Westinghouse P.O. No. 546-CMT-423447-BN dated October 29, 1980,

to Veritract Inc. for item (3) above.

(5) Westinghouse Specification Sheet No. 04631 for Flow Switches

RH-FIS-610, 611.

4

- ----'

-,--_----m- --,,,-~r -e---.r,-,-- r -

---w+-m--r v.----w -

---r w.mwe- iry -- -

_. . __ . - - _ - --

i

1 .

56

(6) Westinghouse P.O. No. 546-CLP-488926-BN to ITT Barton Inc. dated

i January 18, 1984 for item (5) above.

! (7) Westinghouse Specification Sheet No.11412 for flow transmitters

RH-FT-618, 619.

'

(8) Westinghouse P.O. No. 546-AMC-401660-BN to ITT Barton Inc. dated

September 3, 1980 and P.O. change notice 546-CLP-401662-BN dated

March 6, 1981 for item (7) above.

(9) Westinghouse P.O. No. 546-CCF-207624-BN to Fisher Control Co.

for control valves FCV-618, 619 (8-BA74R) and HCV-606, 607

(8-BA740) dated September 25, 1974, and P.O. change Notice No.

'

546-CCF-207624-BN dated August 10, 1976, No. 546-CCK-207624-BN

dated November 11, 1982, No. 546-CCJ-207624-BN dated

'

December 18, 1984.

Within the scope of this review, no unacceptable conditions were

identified.

8.11 QA Audit Records Reviews

The inspector reviewed the QA audit records and audit schedules on

I&C installation activities performed by UE&C and (previously) by

Johnson Control Inc.

The audits were performed in accordance with Seabrook QA manual

Section 9.1 " General Audit Procedures" Revision 10, dated

February 15, 1985 and the established schedules and plans.

Audit records were sufficient to verify that the intended purpose and

i scope of audits were achieved.

Audit findings had been reported in sufficient detail to permit a

meaningful assessment by those responsible for corrective action,

final disposition and trending.

UE&C had taken proper and timely followup action on those matters in

need of correction.

Items examined in this determination included QA audit schedule for

1985 dated December 13, 1984, and schedule for 1984 dated July 9,

,

1984 and the audit reports listed below.

,

t

4

- - - - ,- ---,----y,,-wr -

,--,.------.----y.------,---,y --------m--

. - - - - , , . --e----.- , , ~ - - - - - - - - _

-. .. . . - . . ._- .._ _-._

-- ..-

>

.

57

Audit Report No. Audit Dates Findings

SA836CS362 June 19-29, 1984 22 deficiencies

1 observation

SA847CS372 August 14-21, 1984 6 deficiencies

,

2 observations

SA857CS381 September 19 - 22 deficiencies

October 12, 1984 2 observations

SA859CS382 October 17-29, 1984 6 deficiencies

, 2 observations

i

,

SA871CS390 November 13-29, 1984 3 deficiencies

i 2 observations

< SA876CS394 December 11-20, 1984 3 deficiencies

SA897CS410 March 11-15, 1985 1 deficiency

1 observation

4

The excess number of deficiencies in the second half of 1984 arose

from the transfer of the I&C installation responsibility from Johnson

Cor, trol s Inc. to UE&C. Most of the deficiencies identified were in

the instrument tubing areas, especially the sloping requirement. All

! except seven of the deficiencies and observations were resolved and

accepted by QA. The seven unresolved items had been responded to

and, according to the I&C QC supervisor, will be resolved soon.

The I&C QA audits were thorough, and the audit reports were docu-

mented in a logical manner. The licensee has been informed that this

1 was a strength in their QA program. (See Paragraph 4 for an overall

assessment of the QA/QC activities).

8.12 Nonconformance Report Reviews

The inspector reviewed a selected sample of eight nonconformance

reports.

(

The records were legible, complete and properly reviewed by qualified

>

personnel. The records were properly identified, stored, and can be

retrieved in a reasonable time. The reports included proper resolu-

tion and adequate justification was provided for accept-as-is

,

disposition.

4

l

.

I

1

. . . . - - - - , - . , . - . , . . , , -. . . , , , . - _ - _ . , . . - . , . - - - - . . - - - , ,--,,.---.-,e.-.---

.

- ._ -. .- . - - . . . = _ - -= _ ._ . . . . . . - .-.

!

,

58

The following nonconformance reports were reviewed

(1) NCR No. 93/1351A " Tubing overspan on 1-RH-FIS-610" dated

i May 22, 1985

(2) NCR No. 93/1365A " Work performed on CS-FT/FIS-7326 without work

j package, ASME Class 2 lines" dated May 24, 1985

(3) NCR No. 93/760 " Safety related instruments CS-FT-7325 & 7326

released and installed without generating FMR" dated

December 24, 1984.

(4) NCR No. 93/759 " Welding material issued on WMR No.10284 not 2A

3 verified prior to issue" dated December 27, 1984.

(5) NCR No. 93/732 " Flex hose supporting problem" dated December 14,

i 1984

'.

(6) NCR No. 93/730 " Instrument tubing weld problems, eight items"

dated December 14, 1984.

! (7) NCR No. 93/587 " Instrument tubing weld GR-316 weld wire Vs GR

i 316L weld wire"

!

,

, (8) 93/654A " Source Connection movements not listed in TP-5 for BIP

,

SI-1-5" dated November 20, 1984.

1

< Within the scope of this review, no unacceptable conditions were

identified. (See paragraph 5 for an overall assessment of the site

'

NCR program).

8.13 Receipt Inspection Record Reviews

The inspector selected seven receipt inspection records for review.

The documents properly and uniquely identified received instruments

and associated items. Applicable specification (regarding size,

type, material, etc) of received items were met or otherwise noted.

The instruments.and associated items were received in accordance with

Procedure FGCP-3 " Receiving and Inspection of Items" Revision 10,

dated May 6, 1985.

The following receipt inspection reports were reviewed:

(1) RIR No. 7046 for P.O. No. 9763-252-16

Date received: November 8, 1982

Items received: 30 ITT Barton pressure and differential pressure

indicating switches

l

1

. - _ _ _ . _ . -- -. _ . _ _ _ _ _ _ . . - . .

,

't

.

59

4

(2) RIR No. 6992 for P.O. No. 9763-252-16

Date received: October 27, 1982

Items received: 4 ITT Barton differential pressure switches

1

(3) RIR No. 8370 for P.O. No. 9763-252-16

Date received: February 14, 1984

1

Items received: 4 ITT Barton differential pressure switches

(4) RIR No. 10371 for P.O. No. 9763-NSS 0325

, Date received: August 22, 1094

4 Items received: 2 Westin5 ause supplied temperature elements

(5) RIR No. 10515 for P.O. No. NSS 325

Date received: October 26, 1984

Items received: 8 Westinghouse Supplied RTD's

(6) RIR No. 10368 for P.O. No. NSS0325

Date received: August 13, 1984

Items received: 7 Westinghouse supplied differential pressure

transmitters

1

(7) RIR No. 11222 for P.O. No. NSS0325

Date received: May 28, 1985

Items received: One Westinghouse supplied pressure transmitter

'

Within the scope of this review, no unacceptable conditions were

identified.

t

8.14 Personnel Qualification Record Reviews

The inspector reviewed the qualification records of five randomly

selected I&C QC inspectors.

i

The personnel qualification records meet the requirements of ANSI

N45.2.6, 1978 and were being maintained in a current status. The

records were sufficient to reasonably support qualification in terms

of certification, experience, proficiency, training and testing.

The fiv:: inspectors reviewed were all certified as Level II inspec-

tor > in d:fferent I&C areas. Each file reviewed contained vision

examination report, resume, certificates, and training records.

Within the scope of this review, no unacceptable conditions were

,

identified.

I

i

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

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

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

_

. _ _ .

l

.

60

'

9.0 Electrical Systems and Components

1

In order to . verify the adequacy of the installed electrical system and

'

components, the team selected the electrical systems associated with the

Safety Injection mode of ECCS. The inspectors verified the installation

of equipment from the 4160 volt bus, switchgear, motor control centers,

'

cables, and raceways to the valve operators.

Additionally, the quality assurance program for governing electrical

installation, inspection and testing activities was also reviewed. Details

for each inspection area are discussed below:

9.1 Organization

United Engineers and Constructors (UE&C) provides the engineering,

construction and inspection function for the field installation of

I

the electrical equipment.

i 9.2 Electrical System Review

The electrical system for the Safety Injection components is powered

from the A and B Trains. The B train was selected for this inspec-

tion.

! The B train 480 volt power is supplied from the 621 Motor Control

Center (MCC). The inspector verified and traced the following

eq ui pn.en t.

f

Power Source Cable No. To

4KV SWGR-6 RHR A77-M-12 RESID HT RMVL

EDE SWG-6 Cubicle 11 (3/c 4/0) Pump B

RH-P-8B

4KV SWGR-6 SI P-6B A76-M10 Safety Injection

EDE SWG-6 (3/c 4/0) Pump B SI-P-6B

k MCC -E621 SI-VIII B47-V43 SI Pump Cross

'

EDE-MCC E621 (3/c 12) Connect Val. ;

SI-VIII

MCC-E522 SI-V114 B49-V50 SI PP To Cold Leg

EDE-MCC-E522 (3/c 12) ISO Val. SI-V114

1

MCC-E621 RH-FCV-611 B63-V24 RHR P8B Minimum

l EDE-MCC-E621 (3/c 12) Flow Val . RH-FCV-611

<

MCC-E622 RH-Val 32 B58-V51 RH E 9A&B

l EDE-MCC-E622 (3/c 12) RH-Val 32

,

--- ._.-, ._ _ _ - , _ , . _ - . . _ , - - . _.---_.-._.. _ --_ _ _,_ , , _ _-. ---, - ..- ..__ _ , _. - ., - ___ _ ,_

. - - - = - - . . . . . - - - - - - - .. -- . _---. - - - - __ .

i

61

]

Power Source Cable No. To

. MCC-E621 RC Val 87 B61-1-124 ?EN 24 480V MED

! EDE-MCC-E621 (3/c 12) EDE-MM-100

! MCC-E521 RC88 B62-H19 PEN 19 4euv MED PWR

} EDE-MCC-E521 (3/c 12) EDE-MM-95

MCC-E622 RH Val 26 B65-V48/1 RH E-938 Control

EDE-MCC-E622 (3/c 8) ISOL RH-V26

! PEN 15 480V MED H15-V40 ACCUM TK 9B

PWR EDE-MM-91 (3/c 4) Outlet ISOL SIV-17

'

PEN 19 480V MED H-19-V28 RC-E-110 RHR

PWR EDE-MM-95 (3/c 12) ISO Val 2 RC-V88

l 4KV SWGR-6-P-6B A76-F10/1 MCM Zone AF1,

. EDE SWG6, Cubicle-10 (1P/16) AF2

4KV SWGR-6 RHR A77-F20 MCB Zone BF1,

P-8B EDE-SWG 6, (IP/16) BF2 3

^

4KV SWGR-6 P-6B A76-F10/2 MCB Zone AF1, DF2

EDE-SWG-6, (4/c 19)

j The cable pull confirm slips for each cable listed identified the

i following information.

t

--

Date Cable Pulled

,

--

Feet Cut

--

Cable Reel

--

Cable Size

--

Reel Tag No, and

t

--

Routing

,

In each of the above items, the inspector verified that, quality

control records for equipment, installation raceways, cable testing,

f

and termination were complete and accepted by the responsible quality

organization. In many cases the above equipment was installed and

turned over to the start-up and test organization. Preventive main-

tenance for the various equipment in the Safety Injection system is

,

'

under the control the start-up and test organization.

i

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

62

Throughout the Safety Injection mode of the ECCS system, the inspec-

tor noted that the installed electrical and instrumentation equipment

were adequately protected from dirt, in accordance with the

licensee's requirements. This is an improvement from previous NRC

inspection findings.

No violations were identified.

9.3 Quality Control Records - Electrical Equipment

The inspector reviewed the quality control installation records for

the following equipment.

--

4160 volt Switchgear

--

480 volt Motor Control Centers

--

Centrifugal Charging Pumps (Drawing 9763-M-503335)

--

Refueling Water Storage Tank Suction Valves Drawing 9763-M-

503335)

--

Charging Pump Miniflow Valves (Drawing 9763-M-503337)

--

Safety Injection Pumps (Drawing 9763-M-503900), and

--

Residual Heat Removal Pumps (Drawing 9763-M-503761)

The records for the above equipment were complete, outstanding items

closed and acceptance of the data signed by the quality department.

No violations were identified.

9.4 Raceway and Cable Installation

The inspector reviewed the records for the raceway installations and

verified by inspection that the raceways from the 4160 volt switch-

gear (B Train) to the 480 volt Motor Control Center (MCC-621) were

installed per the drawings.

The inspector traced the cables from the 4160 volt switchgear, 480

Volt MCC, to the B Train components listed in paragraph 9.3.2. Using

the cable pull tickets and walking the raceway system, the inspector

verified that the cables were in the assigned raceways and were

located as listed on the pull tickets.

No violations were identified.

>

l

63

l

9.5 Nonconformance Reports (NCR's) in Electrical Area

The inspector reviewed and verified that the nonconformance reports

in the electrical area were reviewed by management, closed in a

reasonable time, action was complete and closed in the licensee

tracking system.

The inspector selected NCR's pertaining to the Safety-Injection mode

of the ECCS system. NCR 82-509A issued on April 7, 1985, discussed a ]

vibration problem in the 1-RH-P-8B pump-motor.

On December 9,1984, the licensee's tests yielded vibrations within

specifications for the RH-P-8B pump motor at the (29.85 Hz) and (1791

RPM). On March 26, 1985 with water temperature at 125 F and a flow

of 640 gpm, the tests yielded vibrations in excess of specifications.

During this inspection, the licensee was performing additional tests

to determine the cause of the excess vibration level for testing of

the RH-P-8B pump motor. The inspector witnessed the following test

on the pump-motor system.

These tests were conducted jointly with the start-up and test depart-

ment and Westinghouse. The water temperature was maintained at 125 F

for the flow rate. The test yielded vibration levels within specif-

ication.

During a previous inspection of the PH-P-8B installation, the licen-

see identified that the bolts mounting the pump-motor to its seismic

supports experienced binding. Correcting this condition may have

corrected the vibration problem. To assure that the vibration prob-

lem has been completely eliminated the licensee plans to monitor the

PH-P-8B pump-motor during the Hot Functional testing program. This

item will be tracked in the licensee's NCR system and be monitored

during the test program.

No violations were identified. i

9.6 Quality Control Inspection Reports (QCIRs)

The inspector selected quality control inspection reports of Train 8

of the Safety Injection for review. The attributes inspected were

as follows:

--

Installation Documents

--

Identification

--

Physical Integrity

--

Connectors (Type)

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

_ . . - - . - . . ._ - . .. -

!

4

a

64

l

,

--

Separation

--

Cleanliness

--

Leak i

--

Grounding I

"

--

Buswork

--

Protective Devices

For selected QCIRs, the inspector verified that the attributes used

by the quality control electrical inspectors were acceptable and in

accordance with the program documentation and training program. The

, inspector also verified that closed QCIRs were reviewed and accepted

by the quality control organization.

No violations were identified.

'

9.7 Quality Assurance Audits in Electrical Area

The inspector verified that audits and surveillances of the elec-

trical program were performed by the licensee and United Engineers

4

and Constructors (UE&C).

UE&C performed both internal and external audits as described in

their quality assurance procedure QA-18, Revision 9, Dated February

28, 1985. The inspector selected the licensee audit of January 23,

1985, No.5B-18800. The scope of the audit encompassed 10 CFR 50,

Appendix B, Criteria II (QA Program), Criterion V (Instructions,

Procedures and Drawings), Criterion VI (Document Control), and

Criterion XI (Test Control). The audit report identified previous

audit findings that were open and carried them in the audit system as

open items if they could not be closed. New items were identified

and corrective action assigned with a number being assigned for

follow-up action.

The licensees quality assurance organization follows outstanding

i items until closed. The inspector reviewed corrective action for 25

closed items. For twenty of these items, the corrective actions were

, adequate to correct the identified problems. The 5 remaining items

involved long term corrective actions and were not completed at the

time of this inspection.

<

No violations were identified.

j

f

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

l

.

65 j

9.8 NRC Systematic Assessment of Licensee Performance (SALP)

Assessing the NRC's findings in SALP report, 50-443/85-99, April

1985, the licensee established an Independent Review Team (IRT) to

address and correct the cause of the problem. The licensee issued an

IRT status report of the 12 SALP items with schedule dates for com-

pletion of the task. The management overview of the NRC SALP con-

cerns is a positive approach taken by this licensee to control areas

of concern within their design. These 12 items are being tracked in

the IRT report. Item 10, "I&C Tubing slope" was closed. This

subject is discussed in Section 8 of this report.

No violations were identified.

9.9 Physical Independence of Electric Systems

During a review of the Final Safety Analysis Report (FSAR) it was ,

noted that the licensee did not endorse IEEE Standard Criteria for !

Independence of Class 1E Equipment and Circuits, IEEE 384-1974. In

'

Appendix 8A of the FSAR titled " Attachment C to AEC letter dated

December 14, 1973 " Physical Independence of Electric Systems" the

licensee presented their plan for compliance with IEEE-384 and

Regulatory Guide 1.75 (Revision 2).

NRC acceptance of the licensee approach to compliance with Regulatory

Guide 1.72 (Revision 2) and IEEE 384-1974 is stated in the Safety

Evaluation Report (SER) dated March 1983, NUREG 0896.

The inspector had no further questions in this area. ,

9.10 Failure of Limitorque Motor-Operated Valves Resulting From Incorrect

Installation of Pinion Gear

An inspection of the Limitorque operator revealed that the pinion

gear had been installed in a reversed position. This reversed

installation resulted in approximately one-third (1/3) of the normal

gear mesh surface and the wearing away of the portion of the pinion

gear teeth that were in contact with the shaft drive gear.

The licensee has assigned a special test procedure No. GT-E-113 to

review all safety related MOV. The purpose of this procedure is to

inspect for 10 CFR 50.55e deficiencies as well as Information Notices

such as 85-22.

This item is unresolved pending NRC review of the scope of GT-E-113

and the results of the inspection and corrective action taken to

resolve identified problems. (443/85-15-11)

,

- - - . _ - , w -, .w.--, .-_,,--w.m_,--,,-..--.,,e. -

. , , - - . , an - - . , . _ . - , , , - - , - --,v,-- -n.,,-n,,y,-

.

66

9.11 Conclusion

The licensee has established various management tracking systems

which are evaluating the electrical tasks that are being performed by

UE&C under their update work scope. The systems are audited by

management and it appears that timely corrective action is being

taken. The cleanliness and operation of electrical equipment is

improving. Management attention and actions are evident in this area

and there was a noticeable improvement in the electrical hardware.

No violations were identified.

10. Licensee Actions on Previous NRC Findings

(Closed) Construction Deficiency Report 83-00-18

The deficiency involved the failure of Ten Gould molded case circuit

breakers (40 AMP Trip, Model HE3M040) to pass the instantaneous overcur-

rent trip test. The acceptance criteria of this test are based on the

manufacturer's time-current curves.

ITE Electrical Products (Division of Seimans Allis), which is Gould's

sub-supplier for these breakers stated that there was a discrepancy in the

magnetic trip range between the published engineering data (time-current

curves) and manufacturing data. Manufacturing data indicates that the

trip range for this type breaker is 600 to 1000 amperes; whercar, the

publisred time-current curve indicates 400 to 700 amperes.

The subject breakers were tested successfully at ITE factory when tested

to the manufacturing data curve, but failed at the Seabrook site wheri

tested to the published time current curve.

As part of the corrective action, Gould agreed to replace all circuit

breakers identified by the licensee as stated in licensee's letter of June

3, 1985, No. SBN-810, review purchase orders to assure that class 1E

requirements are clearly specified test all class IE circuit breakers,

prior to shipment, to the requirements of NEMA AB-2, and issue test docu-

ments for each test circuit breaker.

During this inspection period the licensee informed the inspector that

Gould has performed testing on replacement circuit breakers.

This item is closed.

,.

67

11. Unresolved Items and Program Weaknesses

Unresclved items are matters about which more information is required to

ascertain if it is acceptable, a violation, or a deviation. Unresolved

items are discussed in paragraphs 4.5, 6.4 and 9.10.

A program weakness represents a condition which, if left uncorrected,

could lead to problems and/or contribute to the violation of a regulatory

requirement. Program weaknesses are discussed in paragraphs 5.8, 7.4 and

8.6.

12. Management Meeting

An entrance meeting was conducted on June 3, 1985 to discuss the scope and

details of this inspection. Management was informed of the findings on a

daily basis. A mini-exit was conducted on June 7, 1985 to provide the

status and to discuss the findings from the first half of the inspection.

The inspector met with licensee representatives (denoted in paragraph 1.0)

at the conclusion of the inspection on June 14, 1985 at the construction

site.

The inspector summarized the scope of the inspection, the inspection

findings and confirmed with the licensee that the documents reviewed by

the team did not contain any proprietary information. The licensee agreed

that the inspection report may be placed in the Public Document Room

without prior licensee review for proprietary information (10 CFR 2.790).

At no time during this inspection was written material provided to the

licensee by the team.

l

,

ATTACHMENT 1

Documents Reviewed

I QA and Administrative Controls

Item No. Docu.nent No. Revision Document Title / Subject

1 QP-1 00 Project Quality Trending

2 QP-2 00 Corrective Action

3 IRT-015 NSSS Interface

4

Guidance - 10 CFR 50.55(e):

Construction Deficiency

Reporting

5 10 Quality Assurance Manual

6 SA926 BI001 Seabrook Audit Report

7 04 Moderate Energy Line Break

Study

8 IP-21 Fabrication, Installation &

Erection of HVAC Duct

Equipment and Supports

9 SA916 CS546 Seabrook Audit Report

10 Employee Allegation

Resolution Program

Operating Procedure

11 FIP-24 00 Release Equipment for Other

Phases of Construction

12 FEP-202 00 Raceway, Cable, Termination

Slip Handling

13 FEP-209 00 Field Modification of

Equipment

14 QAM 24 Quality Assurance Manual for

Seabrook Station

Attachment 1 2

15 QAM 03 Field Quality Assurance

Group Manual and Procedure

16 RPRT February 1985 Seabrook Trend

Analysis Report

i

+

1

-

i

_ _ _ _ , _ _ _ . , , _ , _

.

-

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

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

!

7

Attachment 1 3

II Design Change Control

Item No. Document No. Revision Document Title / Subject

1 ASP-3 02 Nonconformances

2 GEDP-0032 Control, Evaluation and

Implementation of Design

Changes

3 GEDP-0033 Control, Evaluation and

Implementation of Review

Comments on Design Documents

4 TP-23 04 " Project Reference Manual,"

Supplemental Information

for Design Change and

Nonconformances Disposition

Program

5 AP-15 22 Changes to Project Documents, '

Engineering Change

Authorizations (ECAs), and ,

Requests-for-Information

(RFI)

6 AP-10 08 Design Change Notice ~(DCN)

and Budget and Expense

Revision (BER)

7 AP-39 06 As-Constructed Engineering

Document Program (As-Built)

8 FGCP-40 00 System Completion Interface

9 FGCP-31 01 Area Interfacing ,

10 QA-15 12 Nonconforming Material,

Parts or Components

11 QA-1 15 Reliability and Quality

Assurance Responsibilities

and Organization

!

_

Attachment 1 4

III Piping and Supports

Item No. Document No. Revision Document Title / Subject

1 JS-IX-6 15 Installation and Inspection

of ASME III (Pullman Power

Products) Pipe Supports

2 FPP-2 0 Field Piping Procedure No. 2

ASME Pipe Installation

(UE&C)

3 FPP-3 0 Field Piping Procedure No. 3

ASME Support Installation

Procedure (UE&C)

4 9763-006-248-51 8 Specification for Assembly

and Erection of Piping and

Mechanical Equipment for

Seabrook Station Units 1/2

5 AP-39 6 As-Constructed Engineering

Document Program (As-Built)

6 9763-PSG-1-3001 1 Preparation, Documentation

and Control of Pipe Support

Calculations

7 GEDP-0005 4 General Engineering Design

Procedures

8 9763-006-18-17 4 Installation of Concrete

Expansion Anchors (UE&C)

9 IX-1 18 Hilti Installation and

Inspection

10 FGCP-35 2 Hilti Installation and

Inspection Procedure (UE&C)

11 TP-10 7 Technical Procedure for Loca-

tion of Attachments to

Embedded Plates

12 TP-16 2 Technical Procedure for Beam

Verification Program

,

_

h

Attachment 1 5

t

Item No. Document No. Revision Document Title / Subject

13 AP-22 Administrative Procedure for

Calculations

14 PSDG 1 Pipe Support Design Guide-

lines

.

4

Attachment 1 6

IV HVAC

Item No. Document No. Revision Document Title / Subject

1 CP-2 2 HVAC Installation and Erec-

tion Procedure (HAH

Fabricators, Inc.)

2 QP-2 2 Inspection Procedure of HVAC

Duct and Support Installa-

tions

3 IP-20 0 Fabrication, Installation and

Inspection of HVAC Duct,

Equipment and Supports (PCI)

4 IP-21 0 Site Fabrication, Installa-

tion and Inspection of HVAC

Duct, Equipment and Supports

Attachment 1 7

V PAPSCOTT

Item No. Document No. Revision Document Title / Subject

1 FAEP-1 0 ASME Field Data Completion

Program for Piping and Pipe

Systems

2 TP-26 2 As-Constructed Requirements

of Piping Systems

3 TP-27 1 As-Constructed Program

Requirements of Westinghouse

Electric Responsible Systems

4 TP-33 1 As-Constructed Verification

Progrtm for ASME Pipe and

Pipe Supports

5 PGL-7 As-Constructed Piping System

Stress Reconciliation and

Calculation Close-Out Program

6 FACP-16 0 Engineering Certification

Program

..

y - , -.. -

_

Attachment 1 8 ,

VI Welding

Item No. Document No. Revision Document Title / Subject

l' UE&C QCP-10-10- 0 ASME Visual Weld Inspection

Procedure

2 UE&C 9763-006-248-1 9 Shop Fabrication of Piping

3 QCP-10.9 0

4' UE&C 9763-006-248-1 9 Shop Fabrication of Pipe

NHY - Interim Boric Program

for Post-Cat, Pre-System &

Stamping

Components - Not Final Signed

Document

5 SA916CS426 YAEC Audit SA916CS426 on PCI

6 52-5137-A Use of Incorrect and Unqual-

ified Welding on PCI Damper

7 SB-17615 B31.1 Qualification of Weld-

T.F.A.12.2.1 ing Procedure and Performance

Qualification (Transfer of

Pullman Procedures to UE&C

Per Para, 127.5)

8 FWP-18 0 IPC-2 to FWP-18 Para. 5.2.6

(Preheat)

9 FWP-25 0 P8 to P8 WPS

10 S-FWP-1.1/9.1 0 Para. IV.4 (Preheat) in Gen.

Weld Procedure (PCI)

11 S-FWP-301- 0 D1.1/9.1 > 1/8" Carbon Steel

Welding

12 FWP-43 0 UE&C Preheat and PWHT

13 A-6 0 FCAW

14 QP-3 1 HAH, Weld Inspection

Procedure

Attachment 1 9

Item No. Document No. Revision Document Title / Subject

15 WP-32 0 P8 to P45 (GTAW)

16 WP-33 0 PQR-348 (Pullman) for WP-32

17 WP-34 0 P43 to P43 (GTAW/SHAW) (831.1)

18 WP-35 0 PQR-39 (UE&C) for WP-33

19 WP-28 0 WPS-G-45-45 (GTAW) (B31.1)

20 WP-29 0 PQR-510 for WP-28 (Pullman)

21 WP-19 0 P34 to P34 GTAW (831.1)

22 WP-20 0 PQR-509 for WP-19 (Pullman)

23 WP-21 0 P35 to P35 GTAW (B31.1)

24 WP-22 0 PQR-512 for WP-21 (Pullman)

25 WP-23 0 P1 to P5 (GTAW/SHAW) (B31.1)

26 WP-24 0 PQR-350 for WP-23 (Pullman)

27 WP-25 0 P1 to P1 GTAW/SHAW (B31.1)

28 WP-26 0 PQR-004A for WP-25 (Pullman)

29 WP-27 0 PQR-004B for WP-25 (Pullman)

30 FWP-18 0 General Welding Requirements

and IPC2 & IPC3

31 WP-17 0 PI W/P43 Butter to P5

32 WP-14 0 P5 to P5 GTAW/SHAW (831.1)

33 WP-16 0 PQR-208A (w/PWHT) for WP-14

(Pullman)

34 WP-15 0 PQR-208D (w/o PWHT) for WP-14

(Pullman)

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Attachment 1 10

Item No. Document No. Revision Document Title / Subject

35 WP-11 0 P5 to P5 GTAW/SHAW (B31.11)

36 WP-12 0 PQR-206.1 w/PWHT for WP-11

(Pullman)

37 WP-13 0 PQR-218 w/o PWHT for WP-11

(Pullman)

38 WP-8 0 P1 to P45 GTAW (B31.1)

39 WP-9 0 PQR for WP-8 (Pullman)

40 WP-3 Non-ASME Process Control

Sheet Continue Applies tc

B31.1 (not AWS)

41 FWP-1 IPC2 IPC2, Rev. 1 Para. 5.6

Rev. 1 (Permission for Transfer of

B31.1 Procedures to UE&C

from Pullman)

42 WP-6 0 P1 to P1 GTAW/SHAb (831.1)

43 WP-4 0 PQR-048A (w/o PWPI) for WP-6

(Pullman)

44 WP-5 0 PQR-0488 *w/PWHT) for WP-6

(Pullman)

45 S-SWP-300 0 (PCI) GMAW-S

46 S-FWP-300 0 (PCI) GMAW-S

47 S-SWP-301 0 (PCI) SMAW

48 S-FWP-301 0 (PCI) SMAW

49 S-SWP-304 0 (PCI) GMAW-S (Stainless)

50 S-FWP-304 0 (PCI) GMAW-S (Stainless)

51 S-SWP-305A 0 (PCI) FCAW w/E71T11

52 S-FWP-1.1/9.1 0 (PCI) General Welding

Procedure

Attachment 1 11

VII Instrumentation and Control

. Item No. Document No. Revision Document Title / Subject i

1 F1P-34 3 General Installation of

Instrumentation Systems

2 FGCP-7 9 Control and Calibration of

Measuring and Test

. Equipment

3 FGCP-3 10 Receiving and Inspection of

Items

4 TP-8 7 Technical Procedure for

Separation Criteria

5 FGCP-6 4 Preventive Maintenance and

Minimum Storage Requirements

for In-Place Storage of

Permanent Plant Equipment

6 9763-F-805008 13 Residual Heat Removal System

P&ID

7 9763-F-805010 15 Safety Injection System High

Head P&ID

8 FIP-18 3 NSR Installation / Inspection ,

Procedure / Seismic

9 FIP-30 3 Work Package Program

10 9763-006-46-1 9 Specification for Instrumen-

tation Installations

11 RH-I-1-TH-003-5 0 Component Installation for

RH-FIS-611, RHR Equipment

Vault (South) El-61'-0"

12 QA Manual 7 Control of Purchased Material,

Section 5.1 Equipment and Service

13 QA Manual 10 General Audit Procedures

Section 9.1

Attachment 1 12

Item No. Document No. Revision Document Title / Subject

14 95527 1 Westinghouse Equipment Spec-

ification " Class 1E Instru-

ment Design and Test

Requirements"

15 2333D56 3 Westinghouse Drawing " Safety

Class 1E AP Indicator with

Switches Model #581"

16 955286 0 Westinghouse Equipment Spec-

ification " Pressure and Diff.

Pressure Transmitters"

17 953096 2 Westinghouse Design Specif-

ication "ASME Class 2 and

Class 3 Butterfly Valves"

Attachment 1 13

VIII Electrical

i

Item No. Document No. Revision Document Title / Subject

1 FEP-504 1 Installation and Inspection

of Cable Site Training

2 FEP-518 1 Compilation of Quality Records

Generated in Support of

Safety / Seismic /IE Installa-

tions

3 FEP-51.9 0 Installation of Safety and

Non-Safety Electrical

Equipment

4 FEP-505 0 Testing of Cable Terminations

5 QA-18 9 QA Audits for Seabrook Station

6 RG-1.30-1972 QA Requirements for the

Installation, Inspection &

Testing of Instrumentation

and Electric Equipment

7 RG-1.53-1973 Application of the Single-

Failure Criterion to Nuclear

Power Plant Protection

Systems

8 RG-1.75 2 Physical Infependence of

Electrical System

9 E1CSB18 Application of the Single

Failure Criteria to Manually

Controlle'] Electrically-

Operated Valves

10 E1CSB27 Design Criteria for Thermal

Overload Protection for

Motors of Motor-Operated

Valves

11 IEEE STD-308-1971 Standard Criteria for Class

IE Electrical Systems for

Nuclear Power Generating

Stations

,

c

Attachment 1 14

Item No. Document No. Revision Document Title / Subject

12 IEEE STD-323-1974 Standard for Qualifying Class

IE Equipment for Nuclear

Power Generating Stations

13 IEEE STD-324-1971 Trial Use for Type Tests of

Continuous Duty Class 1

Motor Installed Inside the

Containment of Nuclear

Power Generating Stations

14 IEEE STD-336-1971 Installation, Inspection and

Testing Requirements for

Instrumentation and Electric

Equipment During the

Construction of Nuclear Power

Generating Stations

15 IEEE STD-344-1975 Guide for Seismic Qualifica-

tion of Class 1 Electric

Equipment for Nuclear Power

Generating Stations

16 ASP-3 1 Site Training

17 FSAR Amendments 47, 52 and

55, Sections 1.8 and 8.0

18 Topical Report Quality Assurance Program

UEC-TR-002

19 0QA XVIII-2 20 Audit Report, January 22, 1985

l

j

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