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{{Adams | |||
| number = ML20137Z900 | |||
| issue date = 09/13/1985 | |||
| title = 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 | |||
| author name = Bettenhausen L, Cerne A, Cheung L, Eapen P, Finkel A, Grant J, Manoly K, Reynolds S | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000443 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-443-85-15, NUDOCS 8510080401 | |||
| package number = ML20137Z860 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 81 | |||
}} | |||
See also: [[see also::IR 05000443/1985015]] | |||
=Text= | |||
{{#Wiki_filter: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. | |||
/14vt | |||
Tea 6 Leader | |||
&'Date3/8' | |||
A. C. | |||
K | |||
rne, Assistant eam Leader (SRI) | |||
ek/w | |||
'[ Tite | |||
(fhY | |||
M. Che ng, Reactor En | |||
' | |||
L | |||
r | |||
m | |||
T | |||
' Date | |||
Gt'W | |||
A. E. Finkel, Lead Reactor Engineer | |||
rhihr | |||
/ Date | |||
J | |||
4 M.3n. har | |||
Grant, Reactor Engineer | |||
sl1+lsr | |||
, | |||
Date | |||
hWW | |||
K. A. Manoly, Lead Reactor' Engineer | |||
Y?//df | |||
Date | |||
&O . | |||
S. D. Reynolds, Lead React 6r' Engineer | |||
YK Date | |||
8l | |||
Approved By: /d 'f 8 | |||
Dr. L. H. Bet'tenhausen, Chief, Operations Date | |||
Branch, Division of Reactor Safety | |||
gno"es$$h | |||
G | |||
2 | |||
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. | |||
. | |||
o | |||
. , . . . -. ~ . . - - . - . _ - - - . _ - . . . _ = - _ - _ _ - _ - . _ -_- - | |||
t | |||
. | |||
1 | |||
Table of Contents | |||
b | |||
Page | |||
. | |||
1. -Persons Contacted...................................... 4 | |||
J | |||
2. Inspection Purpose & Scope ............................ 5 | |||
' | |||
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 | |||
, | |||
11. Unresolved Items....................................... 67 | |||
12. Management Meetings.................................... | |||
' | |||
67 | |||
Attachment 1 - Documents Reviewed........................... | |||
; | |||
f | |||
l | |||
, | |||
_ . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . . - . _ _ _ | |||
-_ _ .- . -. - _ -- .- . _ _ _ . . .. . .-- - -. . _ - - - . - | |||
. | |||
I | |||
, | |||
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. ; | |||
! | |||
i | |||
, | |||
i | |||
( | |||
_. _ _ . , ._._ . _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ __ | |||
_- _ - . . - . - . - _-- - - - - . | |||
5 | |||
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. | |||
; | |||
i | |||
1 | |||
4 | |||
-_ .- _ _ _ _ _ . . . _ . . , | |||
- | |||
- . . ~ - ._, - _ , - - _ _ _ . _ , . _ . . _ . _ - _ .- - - . - _ _ . - - - - | |||
6 | |||
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. | |||
; | |||
, , _ __ . .__- - | |||
_ _ | |||
L | |||
. | |||
I 7 | |||
L | |||
~ | |||
, | |||
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. | |||
-- . .--_ - - - . _-. -. _ . - _ -. | |||
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. | |||
_ | |||
. - _ _ _ _ _ | |||
10 | |||
(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: | |||
-- | |||
Organization to include staffing and contractor control | |||
l | |||
_ | |||
l | |||
l 11 | |||
! | |||
, | |||
-- | |||
Reports to management and management involvement | |||
-- | |||
Trending of deficiencies / problems | |||
-- | |||
Corrective Action | |||
-- | |||
Surveillance activities | |||
-- | |||
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. | |||
-- | |||
Control of contractor interfaces | |||
-- | |||
Contract procurement | |||
-- | |||
Project management of 50.55(e) evaluations and FSAR revisions | |||
-- | |||
Independent Review Team (IRT) utilization | |||
-- | |||
Piping and Pipe Support Closeout Task Team (PAPSCOTT) Program | |||
interfaces | |||
-- | |||
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. | |||
. | |||
12 | |||
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 | |||
o | |||
- _ _ _ _ - - - - ,_.- -~, -. . - - - . - - - _, . . , , . - - , _ _ _ , . , -- ._. -,- ,. | |||
r | |||
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 | |||
l | |||
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- | |||
related items | |||
-- | |||
implementation of ECA disposition | |||
-- | |||
consistency with overall program requirements of AP-15 | |||
The ECAs reviewed and discrepancies identified by the inspector are | |||
listed below: | |||
19/105466A No calculation referenced. (Drawing must be retrieved | |||
before calculations can be identified.) No reason | |||
given in disposition as to why flex hoses in a line | |||
being evaluated for upgrading to ASME, Class 3 were | |||
not or need not be evaluated. | |||
08/105713A Incorrect drawing " note" referenced - minor revision | |||
needed to correct ECA. | |||
73/3605A/B No discrepancies identified. | |||
. | |||
73/3552A No calculations referenced. | |||
73/7226A TP-8 violations - Program requires dispositioning per | |||
an RFI when no design changes are made. | |||
73/3836A No discrepancies identified. | |||
19/104048A Support drawing not listed as an "6ffected" document. | |||
99/101560B No discrepancies identified. | |||
05/102323A Support drawing not listed as an "affected" document. | |||
. . __ _ - . _. _ _. _._. _.- | |||
r | |||
. | |||
19 | |||
The inspector discussed the disposition of ECA 19/105466A with | |||
licensee representatives to determine why flex hoses, which are part | |||
of upgraded lines on the DG Jacket Cooling Water System, were not | |||
included in the analysis leading to the ECA disposition. The | |||
inspector was informed that these flex hoses were supplied by the DG | |||
vendor (Colt) and had been manufactured to standards which were | |||
equivalent to ASME Section III, Class 3 requirements. The inspector | |||
reviewed SER Section 9.5 and determined that NRR had accepted the | |||
design of the DG engine-mounted cooling water piping and associated | |||
components as being equivalent in design to ASME, C1.3 requirements. | |||
The flex hoses in question are part of the vendor-supplied DG asso- | |||
ciated components. The inspector agreed that because the affected | |||
lines were being upgraded to ASME, C1.3 and the flex hoses had | |||
already been accepted as being equivalent to ASME C1.3, the flex | |||
hoses need not be part of the analysis. (See Section 5.4.) The | |||
inspector had no further questions concerning this issue. | |||
The inspector concluded that the discrepancies identified above | |||
(except for the flex hose concern) are in conflict with the licen- | |||
see's procedure, AP-15, and are considered part of a programmatic | |||
weakness in design change control, as discussed in Section 5.8 of | |||
this report. | |||
5.3 Design Changes per Nonconformance Report (NCR) Program | |||
Following. construction restart, the licensee approved the use of NCRs | |||
for authorizing design changes. ASP-3, "Nonconformances," was | |||
approved as the site method for initiating, dispositioning, control- | |||
ling, and completing field work pertaining to a nonconforming condi- | |||
tion. QA-15, " Nonconforming Material, Parts, or Components," governs | |||
UE&C's use of NCRs. Both ASP-3 and QA-15 require the dispositioned | |||
nonconforming condition to result in a document that provides all the | |||
required verified technical information necessary for implementation. | |||
. | |||
Two of four possible dispositions for an NCR are " accept-as-is" and | |||
" repair," both of which involve deviations from the original design. | |||
NCRs dispositioned as such require design change controls similar to | |||
those placed on ECAs. To determine whether such controls were being | |||
implemented, the inspector selected a sample of NCRs and reviewed | |||
them for the following attributes: | |||
-- | |||
description adequacy for the nonconforming condition | |||
-- | |||
evidence of technical justification in the NCR disposition | |||
-- | |||
adequacy of technical justification | |||
-- | |||
availability of calculations / analyses | |||
-- | |||
affect on original design intent | |||
4 | |||
20 | |||
-- | |||
independence' of reviewers and approvers / evidence of inter- | |||
disciplinary review when required | |||
-- | |||
identification of "affected" documents | |||
-- | |||
involvement of ANI in ASME-related items | |||
-- | |||
identification of nonconforming items in the field via " HOLD" | |||
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 | |||
i | |||
) | |||
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 | |||
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 | |||
l | |||
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 | |||
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 | |||
l | |||
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 | |||
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 | |||
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 | |||
l | |||
l | |||
l | |||
63 | |||
l | |||
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 | |||
}} |
Latest revision as of 17:27, 30 June 2020
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: |
References | |
50-443-85-15, NUDOCS 8510080401 | |
Download: ML20137Z900 (81) | |
See also: IR 05000443/1985015
Text
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.
/14vt
Tea 6 Leader
&'Date3/8'
A. C.
K
rne, Assistant eam Leader (SRI)
ek/w
'[ Tite
(fhY
M. Che ng, Reactor En
'
L
r
m
T
' Date
Gt'W
A. E. Finkel, Lead Reactor Engineer
rhihr
/ Date
J
4 M.3n. har
Grant, Reactor Engineer
sl1+lsr
,
Date
hWW
K. A. Manoly, Lead Reactor' Engineer
Y?//df
Date
&O .
S. D. Reynolds, Lead React 6r' Engineer
YK Date
8l
Approved By: /d 'f 8
Dr. L. H. Bet'tenhausen, Chief, Operations Date
Branch, Division of Reactor Safety
gno"es$$h
G
2
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.
.
o
. , . . . -. ~ . . - - . - . _ - - - . _ - . . . _ = - _ - _ _ - _ - . _ -_- -
t
.
1
Table of Contents
b
Page
.
1. -Persons Contacted...................................... 4
J
2. Inspection Purpose & Scope ............................ 5
'
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
,
11. Unresolved Items....................................... 67
12. Management Meetings....................................
'
67
Attachment 1 - Documents Reviewed...........................
f
l
,
_ . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . . - . _ _ _
-_ _ .- . -. - _ -- .- . _ _ _ . . .. . .-- - -. . _ - - - . -
.
I
,
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. ;
!
i
,
i
(
_. _ _ . , ._._ . _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ __
_- _ - . . - . - . - _-- - - - - .
5
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.
i
1
4
-_ .- _ _ _ _ _ . . . _ . . ,
-
- . . ~ - ._, - _ , - - _ _ _ . _ , . _ . . _ . _ - _ .- - - . - _ _ . - - - -
6
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.
, , _ __ . .__- -
_ _
L
.
I 7
L
~
,
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.
-- . .--_ - - - . _-. -. _ . - _ -.
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.
_
. - _ _ _ _ _
10
(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:
--
Organization to include staffing and contractor control
l
_
l
l 11
!
,
--
Reports to management and management involvement
--
Trending of deficiencies / problems
--
Corrective Action
--
Surveillance activities
--
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.
--
Control of contractor interfaces
--
Contract procurement
--
Project management of 50.55(e) evaluations and FSAR revisions
--
Independent Review Team (IRT) utilization
--
Piping and Pipe Support Closeout Task Team (PAPSCOTT) Program
interfaces
--
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.
.
12
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
o
- _ _ _ _ - - - - ,_.- -~, -. . - - - . - - - _, . . , , . - - , _ _ _ , . , -- ._. -,- ,.
r
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
l
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-
related items
--
implementation of ECA disposition
--
consistency with overall program requirements of AP-15
The ECAs reviewed and discrepancies identified by the inspector are
listed below:
19/105466A No calculation referenced. (Drawing must be retrieved
before calculations can be identified.) No reason
given in disposition as to why flex hoses in a line
being evaluated for upgrading to ASME, Class 3 were
not or need not be evaluated.
08/105713A Incorrect drawing " note" referenced - minor revision
needed to correct ECA.
73/3605A/B No discrepancies identified.
.
73/3552A No calculations referenced.
73/7226A TP-8 violations - Program requires dispositioning per
an RFI when no design changes are made.
73/3836A No discrepancies identified.
19/104048A Support drawing not listed as an "6ffected" document.
99/101560B No discrepancies identified.
05/102323A Support drawing not listed as an "affected" document.
. . __ _ - . _. _ _. _._. _.-
r
.
19
The inspector discussed the disposition of ECA 19/105466A with
licensee representatives to determine why flex hoses, which are part
of upgraded lines on the DG Jacket Cooling Water System, were not
included in the analysis leading to the ECA disposition. The
inspector was informed that these flex hoses were supplied by the DG
vendor (Colt) and had been manufactured to standards which were
equivalent to ASME Section III, Class 3 requirements. The inspector
reviewed SER Section 9.5 and determined that NRR had accepted the
design of the DG engine-mounted cooling water piping and associated
components as being equivalent in design to ASME, C1.3 requirements.
The flex hoses in question are part of the vendor-supplied DG asso-
ciated components. The inspector agreed that because the affected
lines were being upgraded to ASME, C1.3 and the flex hoses had
already been accepted as being equivalent to ASME C1.3, the flex
hoses need not be part of the analysis. (See Section 5.4.) The
inspector had no further questions concerning this issue.
The inspector concluded that the discrepancies identified above
(except for the flex hose concern) are in conflict with the licen-
see's procedure, AP-15, and are considered part of a programmatic
weakness in design change control, as discussed in Section 5.8 of
this report.
5.3 Design Changes per Nonconformance Report (NCR) Program
Following. construction restart, the licensee approved the use of NCRs
for authorizing design changes. ASP-3, "Nonconformances," was
approved as the site method for initiating, dispositioning, control-
ling, and completing field work pertaining to a nonconforming condi-
tion. QA-15, " Nonconforming Material, Parts, or Components," governs
UE&C's use of NCRs. Both ASP-3 and QA-15 require the dispositioned
nonconforming condition to result in a document that provides all the
required verified technical information necessary for implementation.
.
Two of four possible dispositions for an NCR are " accept-as-is" and
" repair," both of which involve deviations from the original design.
NCRs dispositioned as such require design change controls similar to
those placed on ECAs. To determine whether such controls were being
implemented, the inspector selected a sample of NCRs and reviewed
them for the following attributes:
--
description adequacy for the nonconforming condition
--
evidence of technical justification in the NCR disposition
--
adequacy of technical justification
--
availability of calculations / analyses
--
affect on original design intent
4
20
--
independence' of reviewers and approvers / evidence of inter-
disciplinary review when required
--
identification of "affected" documents
--
involvement of ANI in ASME-related items
--
identification of nonconforming items in the field via " HOLD"
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
i
)
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
_ _ _ _ _ __ ._ _ ____. _ _ __ _ _ _ _ _ _ _ _ . _ - __ _ - _ _ _ _ .
,
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
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
l
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:
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:
- 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
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
- 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
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
l
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
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
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
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
l
l
l
63
l
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.
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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
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.
-
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. . __ _.. _ . _ _ _ _ _ . __ _ _ _ _ . - - - _ __
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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
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_
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
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
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
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