ML18016A939

ASME QA Audit of Shnpp Construction, Conducted on 800915- 18 & 22

ML18016A939
Person / Time
Site:	Harris
Issue date:	10/02/1980
From:	BISSETTE L W, HALL A E, MCMANUS S CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML18016A936	List: ML18016A935 ML18016A937 ML18016A938 ML18016A939 ML18016A940 ML18016A941 ML18016A942 ML18016A943 ML18016A952 ML18016A953 ML18016A954 ML18016A956 ML18022B063
References
QAA-170-4, NUDOCS 9905050218
Download: ML18016A939 (132)

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{{#Wiki_filter:h IJ h il I\,',k ,If I I-P I I I I'ir Ik I I I form ale g~h Caroline Power n Light Company apl Company Correrpondence October 2, 1980 FILE: QAA/170-4 MEMORANDUM TO: Messrs.Sherwood H.Smith, Jr.~~onerE.E.Utley-PM': S.McManus

SUBJECT:

ASME Quality Assurance Audit of SHNPP Construction During the period September 15-18, 22, 1980, a Corporate Quality Assurance Program Audit was conducted at the SHNPP Construction Site.This was conducted by Messrs.A.E.Hall (Lead Auditor), L.W.Bissette, I.A.Johnson, and F.W.Taylor of the Corporate Nuclear Safety&Quality Assurance Audit Section.The purpose of this audit was to evaluate the SHNPP ASME Quality Assurance Program nnd to verify compliance with the implementing procedures. 'Ihe attached audit report oumnarizes the results of the audit.The completed checklist, which was used as a guide in conducting this audit, is maintained in the CNS&QAA Section files.cc: Messrs.H.R.Banks (w/a)N.J.Chinngi (w/a)A.B.Cutter (w/a)T.S.Ellemnn (w/a)G.L.Forehand (v/n)J.G.Hammond w/a TO: Mr.S.McManus FROM: J.A.Jones P.W.Howe (w/a)R.L.Mnyton, Jr.(w/a)M.A.McDuffie (w/a)R.M.Parsons (w/a)S.D.Smith (w/a)The attached audit report, QAA/170-4, hao been reviewed and io returned for placement in the CNS&QAA files with the f loving comments.rl9050502i8 990430 PDR ADQCK 050004001 P PDR As required by Audit Procedure QAAP-1, it io the responsibility of the Manager-Engineering &Construction Quality Assurance to review and investigate the audit findings;to determine and schedule appropriate corrective action, including action to prevent recurrence; nnd to respond in writing within thirty days after receipt of this report, giving results of the review nnd investigation and describing corrective action taken to resolve the findings identified in this report.In addition, provide nse as requested for Concerns Numbers 5 and 6.LWB/nohTC/tcm Attachment if l Ik,", II I ,'I"hl hhkl@l&9 4JI"l'.I'h L'lkg I Q i e r lJI., 9 IA Ipl','ki n jl I JI'I I I}hi I j I", ,I l,'JI", u ,e IIVJ I,)I, 4, 9 Il /~~5'~'l4'155J t'5 AUDIT REPORT Activity Audited: SHNPP ASME Construction Audit Report No.: QAA/170-4 Auditors: A.E.Hall-Lead Auditor L.W.Bissette I.A.Johnson F.W.Taylor Date: September 15-18&22, 1980 Persons Contacted: I I*I I I I*I I*I I*I I**I I PI I R.M.Parsons, Site Manager A.M.Lucas, Senior Resident Engineer S.Hinnant, Resident Engineer-Electrical E.E.Willett, Principal Engineer-Mechanical R.Hanford, Principal Engineer-Welding G.L.Forehand, Principal QA Specialist P, W.Howe, Vice President-Technical Services Department N.J.Chiangi, Manager-Engineering &Construction QA Section W.D.Goodman, Daniels Pro)act Manager R.H.McMillan, Daniels Assistant to Construction Manager G.M.Simpson, Principal Constxuction Inspection Specialist V.Safaxian, Welding Senior QA Specialist D.C.Wnitehcad, Receiving Senior QA Specialist F.Sheikh, Pro)act Engineer-Welding R.Patterson, Construction Engineer T.Harrington, Director of Purchasing J.S.Clements, Document Contxol Supervisor L.Denson, Materials Supervisor C, Osman, Pro)act QA Specialist T.Lcc, Senior QA Records Specialist G.White, Senior Engineer E.Harris, Prospect Engineer L.Liles, Technical Assistant II R.Jones, General Foreman J.Bradford, Pipe Fitter Foreman G.Thompson, Construction Inspection Specialist G.Daniels, QA Technician I*Attended Poataudit Meeting**Attended Preaudit Meeting"*" Attended Preaudit and Postaudit Meetings It-1 h tt C h h t.j n: t~~~I~~~~~!~~h~~~~~~~~4~~~~~~~~~~~~~~I~~~~~~~~~~~<<>>~~~~~~~~~~~~~4 4 J~~~~~~~~i~~~~~~~~!~i~~~~~~~~~~~~~~)~~~I~~~~~~~~~a~~~~~I~~I~~~~~~I~~~~~~~~~~~~~~~~>>~~~~~~~I~~~~~~~~~~~~~~~~~~~~~!~~!~~~~~~~0~~~~~~I~~~~~)~~~!!e I LL II t jt J 4 4 j t'4~t.4, f Jft J f-2-SCOPE;The audit was conducted in accordance with CP4L's Quality Assurance Audit Procedure, QAAP-1,"Procedure for Corporate and ASME QA Audits." The purpose of this audit was to review and evaluate sclccted portions of the CPAL ASME QA Program, Site QA Program/Procedures, and verify site compliance with implementing procedures. Areas/activities audited include: (1)Training and Qualification; (2)Design Control;(3)Procurement Control;(4)Document Control;(5)Receiving Inspection; (6)Handling-Cleaning and Storage;(7)Hydrostatic Tests;(8)Welding Material Control;(9)Construction Welding;(10)Inspection and Tests;(11)Nondestructive Examination; (12)Inspection and Test Equipment Control;(13)Code Data Reports and Nameplate Stamping;and (14)Housekeeping During Construction Phase.Within these areas the audit consisted of discussions with personnel, examination of records and procedures, audit team walk-through housekeeping inspection of construction site, and witness of work in progress.R ttafaRY: Within the scope of this audit, the ASME Quality Assurance Program was considered to be adequate.Two of the seven findings identified in this report are related to the ASME Program, and one of the nine concerns is related to the ASME Program.The remaining findings and concerns are against general construction activities. The inspection tour of storage and construction areas for compliance with the housekeeping requirements of ANSI-N45.2.3 indicated the storage areas to be relatively clean except for one smaller building having a rather dirty floor.The construction areas continued to have vrapping materials in numerous locations and the fabrication shops contained a variety of trash including safety cans filled with flammable material.The electrical storage sheds had heavy equipment, and materials stored overhead in an unsafe manner.As was reported in Audit QAA/170-3, there were no findings reported;therefore, no corrective actions wore required to be verified in this audit.Personnel contacted during this audit were cooperative and found to bo knovledgcablc in their areas of responsibility. Findin s and Corrective Action: During the audit the following items vere identified as nonconforming findings.These items vill require corrective action and formal response.(tea i: trait(a aafj iiticatiea ~Re uireaeat: ASNT-TC-lA (1975 Edition), Paragraph 8.5.2.c, specifi.es that for the practical examination (nondestructive examination personnel qualifications), ten different checkpoints requiring understanding of teat variables and procedural requirements should be included in the practical examination. In addition, Paragraph 9.6.1.f specifics that tho practical examination should describe the practical test ob)cct.).44(fj c tf$t-t,,(,)-':t f-t)c'7));L,Q'P;'.'tf ft't j t'jl'.3 4', (, 4 c,'t 4't fc J f't.f.tl 4)R)a R i BR.~M'ttLJ"tet utt!Jt 449,~~ttcM<% R'R~wWP~~jft~4$te~"-'a~A J~+at'uut'"au&'4 4" >ggI I J4 C J;pl~.hh P IC I 1 1 J hi$4 4 t Nonconformance: The qualification records for Norman C.Westgage, RT Level II (Daniel)practical examination record did not include ten checkpoints as required and did not describe the test object that was tested.These record nonconformances existed when the CP&L NDE Level III Examiner reviewed the record and certiEied this individual as RT Level II on 8/8/80.The auditors determined the record files for five other Lovel II personnel did meet the requirements of ASNT-TC-1A. Acknowlcd ement and Res onse: The Manager-Engineering &Construction QA stated Daniels (Greenville Office)will be contacted and requested to forward missing documents which are on file.Item 2: Procurement Control~Re ultunent:.,I Ie'ite QA Procedure CQA-24, Rev.0 (7/7/80)Procurement Control, Paragraph 7.1 requires when a vendor is disqualified/removed from Approved Suppliers List, an evaluation will be performed by the cognizant QA Specialist. The evaluation shall be documented and shall indicate if the disqualification affects orders in fabrication and any orders previously received on site.Nonconformance: 'r'rj~The auditor determined this requi.rement of the Site QA Procedure was not being implemented by Site QA.Acknowled ement and Res onse: The Si.te Principal QA Specialist implemented corrective action for the vendors removed from the Approved Suppliers List in the last six months and gave the auditor written action to prevent recurrence of this nonconformance in the future.This action was reviewed by the auditor during this audit and is closed in this audit report.Further response is not rcquircd.Item 3: Document Control~Re utteueut: ASME Code Section III, NA-4133.6 Document Control, requires"measures that shall assure that documents, including changes, are reviewed for adequacy..." NonconEormance: The auditor determined that a portion of the text of Paragraph 1.3, 10CPR21 requirements, of Site Specification 036, Revisions 1, 2, 3, and 4 which was in the original issue of the document, was inadvertently deleted in Revisions 1, 2, 3, and 4 due to typing error.This discrepancy went undetected throughout the CP&L Site construction and QA organizations. This document was a requirement on eight out of seventeen purchase orders Eor ASME Code items reviewed by the auditor. k'~~"r A$a'E V PV~Iv'g~I lJ 4 4'%p g~A,~1~6'I$1'~1%c k~I~4 q T 'Q 4 Acknowled cment and Ree once: Site management is to issue a memorandum to all site personnel responsible with document issue and revision.This memo is to bring this nonconformance to site personnel's attention and their responsibilities as to how to rcvicw a procedure/revision. ~ite I iremant: Procedure WP-112,"Control of Materials and Equipment That May Bc Harmful To Stainless Steel," requires materials that are purchased for a function that will require them to come in contact with stainless steel shall not contain more than 1000 PPM leachable halogenated compounds (including chlorides). A certificate of compliance to the above must be provided by the suppliez or sampled and tested upon receipt of the material.Nonconformance: There are no suppliers'ertification or sample test results on halogen content for the acetone being used on the site for cleaning purposes.Acknowled emcnt and Ree onse: The Senior Resident Engineer stated this item would be reviewed with Engineering and cozrective action response would be forwarded. Item 5: Receivin Ine ection Warehouse storage procedure PGD-002,"Material Maintenance Requirements During Storage for Shcaron Harris Nuclear Power Plant," requires polyethylene used in contact with safety related, seismic 1, or stainless steel equipment not to be in cxccee of 55 PPM for total leachable halogens in pigmented sheeting.Procedure WP-112,"Control of Materials and Equipmcnt That May Be Harmful To Stain'es Steel," requires that materials that are purchased for a function that will require them to come in contact with stainless steel shall not contain more than 1000 PPM halogenated compounds which are leachable. NPPED Memorandum 801022, dated 5/22/80 from L.I.Loflin to T.H.Wyllie, indicates that protective covers must not exceed 1000 PPM for total halogen and sulfur, and 200 PPM for lcachablc halogen.Nonconformance: The fire retardant vinyl received 6/4/80 has manufacturer's certification which states the total lcachable halogenated compounds including chlorides are lese than 1000 PPM.Tnie material is being used tn cover safety related and stainless steel equipment even though there is a conflict between the three documents prescribing leachable halogen limits.Acknowled emcnt and Res once: 'Ihe Site Senior Resident Engineer stated this item would be followed up with Engineering, and then they would respond with corrective action. 1 i' 4'-5-Item 6: Weldin Material Control Procedure MP-03, Revision 9, dated September 5, 1980, Paragraphs 3.11 and 3.12 require the Welding Issue Room Attendant to daily check the welding rod holding ovens and to randomly check the welding rod heated portable caddies for their proper operation at the specified temperatures. The procedure requires the above checks to be recorded on Exhibit 2, Revision 6, dated August 1980.Nonconformance: The records examined showed that Revision 4, not Revision 6, of Exhibit 2 has been used to record the daily checks of oven temperatures in all three issue rooms to date.Revision 4 of Exhibit 2 did not have a format that provided a designated space for the data results of checking the heated portable caddies.There have been no records made of the issue room attendant's checking of the heated portable caddies since September 5, 1980 when the new requirement became effective. Revision 6 of Procedure HP-03, which was issued December 7, 1979, revised Exhibit 2 which made it Revision 5~There is no record of Revision 5 of Exhibit 2 having been used for recording oven temperatures by the issue room attendants since that datce Acknowled cment and Res onse: The Senior Resident Enginccr stated that the removal of Revision 4 of Exhibit 2 from the welding issue rooms has been accomplished and Revision 6 of Exhibit 2 is now required to be used for the recording of data on the ovens and portable caddies.Item 7: Nondestructive Examination For welding repairs to Code Class 3 base material, the CP&L ASME QA Manual requires the QA Welding Inspector to prepare a sketch of the repaired area as required by thc Code showing location and size of the prepared cavity, the welding material identifications, thc welding procedure, and a report of the results of examinations. For veld repairs requiring radiography, ASME Code Section III, Paragraph ND-2539 requires a sketch showing location and size of the prepared cavity.Nonconformance: A radiograph identified as SW-2Rl, Drawing 4-SW-8/2165 was reviewed during this audit.A note on the Radiographic Facamfnation Report indicated the area examined to bc a pipe wall repair.The sketch of the repaired area and the repair weld data rcport could not be located during the audit.Only the film and the request for radiography were available for review.Acknowlcd ement and Res onse: The Manager-Engineering 6 Construction QA stated work on thc pipe spool modifica-tion was not yet complete.Although the actual base material repair was complctcd, the required paperwork was not yct submitted for incorporation in the final package.I j'\'S f/"I)l.'f f", I'I'dg I ,I')I I u'.'II V s;c u V'Ig yQ'f)(,)I a)'Fi I II uu I I I (ul f(1f Cri,'n"(JI I C, P 1 qk I~'4 4 P t ~~~~~~~i'~~I 1'1~~I~~~~~~~~~~~~I~~1~~~~I~Il I~~~i I~I I I\~ti~'ll~~~~I'I'~~~H~I I~~~'~I 1~,~I~~'~~~~~I~I~'I~~I'~<~I H~~I~~~~~~I~~'~~I~lt~tl~'I I~Il~I~I~~~~~~~~It~~~~I I~~~~I I'~I~'I H~~~~~~~~~I I~I 1~I~tl~~~~I~~~t~~I~~~~~~'I~~t~~H~'~I~~'~s~~~I~~III I~~tn~I~~~~I ii1 s~it~I I~~~I~~I I I n~~~I~~I~~~~I I~I~~~~1~'~I'~~'~I~I I~~I~~t~~II~Il It~~~'I It I I I~~~'I I I I~~t tl~'~~n I I~'l~'~~~I~~'ll I~I I~ A+4't E%k,'k I a~l1 ,0 1 fl)7;Concern 6: Containment spray piping and spent fuel piping was inspected according to Proce-dure CQC-10,"Cleanness Control of Fluid Systems and Components," and released on"Conditional Release" because the external surfaces of the pipe had not been cleaned in accordance with Procedure WP-113,"Cleaning 6 Cleanliness Maintenance of ASME Section III Piping Systems." It is of concern that Procedure WP-113 was inadequate by not containing requirements for external pipe cleaning, and spent fuel piping is embedded in concrete and cannot be cleaned.The Senior Resident Engineer stated this item would be evaluated. Concern 7: The review of radiographs for weld FW-5 in line 2SI14-253-SA1, drawing 1SI1/2165-G-151 casclosed only three penetrameters. They are located in the two upper quadrants and on the dividing line between the two lower quadrants. Paragraph 9.5.4.3, NDEP-101, Revision 3, requires four penetrameters, one in each quadrant.The auditor is concerned that Procedure NDEP-101 is not in compliance with the ASME Code Section V, which requires three penetramcters be used.Concern 8: The type of dye penetrant identified on a total of 10 Liquid Penetrant Reports was SKI-HF/S.NDEP-201, Revision 2, Paragraph 6.4.a requires Magnaflux Type SKL-HP/S.The auditor verified by contacting the area Magnaflux representative that no penetrant identified"s SKI was manufactured by Magnaflux. Since several inspectors were involved with preparation of these reports, the auditor is concerned that in some cases the type of penetrant used is apparently not being verified to be the type required.Concern 9: Procedure CQA-22, Paragraph G.l requires the QA Inspector to monitor the activities in the weld material issue rooms for compliance with Procedures MP-01, MP-02, and HP-03, one of thc items to be checked is the Qualified Welders List.It is of concern that thc Checklist, Exhibit 1, completed September 16, 1980, shows thc Qualified Welders List to be dated 9/19/80 which is not thc date of issue of the list that was in effect at that time.Thc issue date of the list, which was shown as Revision 1, wns 9/10/80.It is also of concern that the checklist did not show that the inspector had noted that Revision 1 was bc used by the weld material issue room attendants. Submitted By: '.Oi Approved By I~r M.ger Corporate Nuclear Safety 6 QA Audit Section if u k ACTIVITY)SHNPP Construction Site/ASME Construction REPORT NO.AA/170-4 AUDIT PROCEDURE QAAP-1 DATE Se tember 15-19 1980 UALITY ASSURANCE AUDIT CHECK LIST AUDIT ASME Audit at SHNPP Construction Site rTOR A.E.Hall AUDITOR(S~ L.W.Bissette I.A.Johnson P.W.Taylor 1.0 2.0 CHARACTERISTICS Preaudit Meetin (7:30 a.m., 9-15-80)Trainin and uglification 1.0 The meetin was attended b site ersonnel listed in the audit re ort.The areas scheduled to be covered durin the audit vere identified. The auditor's res onsibilities as well as the site ersonnel assi nments were established. It vas agreed to conduct a dail de-briefin of each da s activities at 3:45 PM between the auditors and site mana e-ment personnel to discuss nonconformances, concerns, and ore>>ents.The ostaudit meetin was tentativelv scheduled 2~1 Nondestructive Examination Personnel Qualifications>> verify by review of records the following: Personnel performing NDE operations have current visual examinations to meet Jaeger Number l.r September 18, 1980, in the afternoon. 2.1.1 Yes, verified by review of NDE qualification record files picked at random for six 6 Level II, and two 2 Level JII personne Page 1 of 38.0 'P t C A REPORT 2.1.2 2.1.3 2.2 CHARACTERISTICS CP&L has records on file for NDE per-sonnel vhich meet the qualification requirements of SHT-TC-lA-1975. The certification of Level III NDE personnel has been by examination for technical competence as required by ASME Code NB-5521.Does CP&L have personnel records which support implenentation of Procedure TP-25 in document control?2.1.2 COMMENTS Yes, verified by review of HDE records in 2.1.1;however, the following noncon ormance was discovered. A Daniel employee, H.C.Westgate s record ile or Radiograph'c exaninat on recor.s pract ca exam nat on oes not neet t e requ rements o paragrap s...c an of ASNT-TC-lA 1975 Edition.The ractical examination does not include ten chech oints that are related to the candidates roficienc or understandin of test re uire-nents.Nor did this record describe the test iece that vas tested.In addition, this ais'sin data vas not discovered. CP&L's Level III for RT and this Level III RT exaniner certified rhis Daniel ea lo ee for RT Level II on Au ust 8.1980.The auditor verified this Daniel en lo ee has not erforned an RT because of still bein in the site orientation pro ran.This nonconformance is listed in the audit report as Finding Itea l.2 3 Does CP&L have personnel records which support implementation of Frocedure MP-11 in QA records system?2.1.3 2.2 Yes verified b review of NDE ualification record iles for tvo Level III CP&L ersonnel, C.Osman and E.Betz.Yes verified by review of training records tor Procedure TP-25 in document control.The following comment is or audit follow-up on future audits, for a nev employee s orientation it is difficult to deteraine ron recor the exact revision of document that vas reviewed.3~1 Desi n Control (AP-IX-15) Review the DCN Implementation Log, verify it is being maintained. 2.3 3.1 Yes verified b reviev of MP-11 records na nta ne y the disci line veldin engineering o ice an t e I-records in document control.This lo vas reviewed;it lists the DCHs an v en t ey are closed out.3.1-1 Select DCN's fron the Implementation Log and verify if log and DCN agree on implementation status.3.1.1 Selected folloving DCNs ron log:-ap eaente 9 3 80 er DCN.DCH had been inp emente an c ose.530-197 open.DCH vas st active.-open.DCN had been closed and was reo ened 3 28 79.It was not listed on o en DCN Re ort.Sec question 3.2 550-589 in lenented 7 29 80 er DCN.DCW had been close 560-063 void er DCN 6 2 80'CN had been nar e Page 2 of 38 4'V REPORT CHAlUCTERISTICS 3.1.1 CO%ANTS-0 3, Revis on , implemented 1 0 per DCN.cont, DCN had been c ose.-1 open.DCN was sti active.Page 2a oE 3S REPORT L';s I 3.2 CHARACTERISTICS Verify the Document Control Supervisor is preparing a report biweekly for each Area Engineer vhich lists FCR's and DCN's over 30 days old which have not been closed out.3.2 COKKHTS Procedure AP-I-vi"information onl" re or o over 30 da s old as re u En ineer.He has not re uested v si Document control is maintainin a curren co status.It was noted that reo e ed D N on the list.As reo ene DCNs ma o Document Control Sucervisor is avin~II~'he>c 7 c-j,<<c 3.3 3.4 Verify comments vere indicated on report by Area Engineer.Select actions indicated taken by DCN and verify they were accomplished. 3.3 3.4 Counts were on the last list issued 8 15 80.Selected items that had been im lemented under DCN 530-223 re uired Ber er Pa rso a C-1-286-1<<CT-14-38 to be revised.Drawin ha revised.The other DCNs 550-589.560-063 650-403 and 650-130 re uired work to be done accordin to DCN and drawin s to be revised later.Work in field was not verified.4.1 Yes verified b review of site urchase orders for 4.0 Procurement Control 4.2&seventeen PO s in 4.7.4.3 4.1 Are the proper designated QA Specialist or the Specialist's designee reviewing site purchase requisitions and purchase orders?(Ref.CQA-24, 4.2)I A/<<<<4 4.3 Is the review of the purchase requisi-tions properly documented' Are the proper gA requirements included on the purchase requisitions? Page 3 of 38 C I l'I'I 4 I:0 I I IX~'~~~~~~~~~~~~~~~'~~~~~~'5~~~~~~I~~~~1~~'~~I~~~'~~~~~~~~~'~~~~~'I~~~~~~~~~~1'~~'~~~~~~~~~t'~~~'.~~I~~~~~~~~~~~~~k~~~~~: o'~~~i l~~~~~k~~~~I~~~~'I k~[~~~~~~~~'~k'~~~~'~~~'~~~~~~~~~~~I~~~~I:~I~~~k~I~~~~~~I~~~~'1~~I o~~~~~~I~k~~~k~~~~~4~~~~~~I~~~~~~~k~~~ 4 r ~~3~~\~~~~~~C~~J I o~~~~ li I CI'I tR REPOBT 4.10 4.11 CRQtACTERISTICS Do the requisitions for ASME Code items contain the requirements that it shall be manufactured/supplied to CP&L approved Vendor's+L program?(Ref.AP-XII-1, 4.1.2,5j>~~ Has the Site Nanager approved all requisitions? {Raf.AP-XII-l, 4.7)CO?0KNTS 4.10&Yes verified b review of files in 4.7 above.4.11 4.12 Yes vendor documents are sent to site disci line en i eer who coordinates review and a roval of vendor documents. 4.13 Yes verified b auditors reviewin warehou w files of site PO(s)and Ebasco PO(s.The auditors'erned a few files do not contain all the PO chan e ordor su lements, such as PO H-27369 and Ebasco PO s 435018 and 435092.This a ears in the audit re ort as Concern 4.12 Are vendor documents requiring reviev and approval by CP&L, receivinp, the proper reviev and approval?(Ref.AP-XII-l, 4.9)Yes, issued by attachment of Procedure AP-XIII<<03 as Exhibit 5 by document control..1.1 Yes, see.1 above.4.13 Are procurement documents being filed as required by Procedure AP-XIII-1, by the warehouse unit?Has the resident engineer unit compiled a list of known items/materials which are sub)ect to a defined shelf life expiration'?(Ref.AP-XIII-3, 4.1.1)4.14.1 Is this list controlled and distributed by document control'?(Ref.AP-XIII-3, 4.2)Page 5 of 3g 1 U 0 l C 0 C S g'4r REPORT 4.15 5.1 5.2 QQ04CTERISTICS Has QA performed the necessary receiving inspection and review of Vendors QA docunentation as required2 (Ref.AP-XIII-3, 4.6)e Document Control Is a document control log being properly maintained for holders of CQA/CQC procedures/manuals?(Ref.CQA-2, 8.3)Are procedure deviations approved by the designer where the designer is required to approve the procedure and its revisions7 (Ref.CQA-2, 6.4.1, 7.0, and 8.1.3)5.1 5.3.4 COUNTS Yes verified b revie~of A Vault record files for receivin ins ection and vendor documents for PO s listed in 4.5.Yes verified b review of A document control lo s in A record vault for C A C and C I s rocedures manuals.Yes however ara ra h 7.2 of Procedure COAM"Envision 4 9-9-80 states the" A rocedure deviation notice is not ermitted for the A rocedures that re uire the desi er s a roval.Yes verified b review of the A deviation notice lo records in A office.The su erseded A documents are rubber stan ed with wording,"For Information Onl (4.7.i+i.(t'>>P Is a QA deviation notice log being maintained as required7 (Ref.CQA-2, 7.4.1)5.4 How are docunents marked to indicate that they are now a working document, when they are to be retained as a historical issue?(Ref.CQA-2, 10.2)Page 6 of 38 N h l I ~~~~~I~~'~~~.I;~~'~\~~~.~~~~~~~~~'~~.%W,,J~~~~~'~~~l~~~~~~~~~~': 4~~: '~~~~'~~S~I 4~I~~~l I~~~o~: I'~~~~'~~~'~~~~~'~l~~~~~~~~~~'~~~I~~\~~~~'~~~~I~~~I~~~i~~~I.:~~'1~~~0~~~~S I'~~ll~ll~~~ ~p k y I V n A REPORT.M QAA/170-4 o 5.10 4 6.0 C..6.1~j, 6.2=*'-'*'.3 6.3.1 0 6.3.2 6.4';J CHARACTERISTICS Verify by record review that FCR/PW(s)are being properly processed, signed, and distributed.(Ref.AP-IX-5)i ggC',0" Re" eivin Ins ection AP-XIII&2 Verify that a Daily Dock Report is prepared.Have Material Receiving personnel been designated by the Materials Supervisor' Select received items and verify the folloving: Documentation identifies vendor and purchase order number.Copy of purchase order is maintained by warehouse. Inspect rigging used by varehouse unit and verify it is not frayed, worn or otherwise deteriorated. COMMENTS control.6.1 This document is roduced dail wo i ur ose is to inform various individuals a what items have been received.Co ies ar mornin after item is received.6.2 Yes a ersonnel list identifies the warehouse and their classification. Exam lesof receivin e o are Material Control Technician and Warehouse R 6.3 Selected the follovin urchase orders: 435018 435116 435234 435174 435018 435092 435116 4 2 4 and 435174.6,3.1 Documents do identif the PO number and the vendors.6.4 Looked at ri in used in varehouse. It is maintained in locked boxes and controlled b Millvri ht.The ri in is color-coded to indicate ins ection.All ri in looked at was ade uate.6.3.2 Co ies of urchase orders vere in the folder however there vas no assurance that all C 0 of the PO were in the file or that the C 0 for the item received vas in the acka e.This is in the audit re ort as art of Concern 82.~~4'C/~C" m A~'4 w1~-" gf Page 8 of 38 0- "e g 6'gb;<) REPORT Qh+170-4 6.5 CHARACTERISTICS Have personnel been authorized to operate equipment assigned to warehouse unit?6.5 6.6 COHMEHTS Yes memorandum dated 4 30/80 from L.Denson i ersonnel authorized to o erato material a d I for warehouse o erations.Yes Procedure AP-XIII-03 Exhibit 5.Revision 2 8/79"Shelf Life for Plant Material In Mare 6.6 6.F 1~AP-XIEI't Has the Resident Engineer provided written instructions for providing warehouse personnel guidance in determining materials which have defined shelf life7 Are materials with shelf life clearly marked7 6.6.1 Yes this is either b bein on manufacturer~ o in b warehouse ersonnel on a label.This was c.r fi as to bein done.6.6.2 Yes, items are stored so older items are in front and on lower shelves of warehouse. This is verified b nonthl ins ections.A notification is issued five workin da s rior to ex iration date of the item.This was verified.6.6.3 The Shelf Life Data Re ort is made for each batch of each purchase order.It identifies date received and ex iration date.This was verified (exam le PO 435172, batch 9085.6.7.1 The followin urchase orders were selected: 6.6.2 Are they stored to facilitate issuing on first in, first out basis2 0 at 3-8-3-18, 1 07 at 12-8-4, 435031 at 3-C6-23, 032 at 3-C-20, and 162065 at 12-C-7.Has the Materials Supervisor established a monthly inspection program for materials with defined shelf life7 6.7 Review the Equipment Maintenance Log and verify the following: 6.7.1 Log indicates description and location oi item.1 I A Page 9 of 38 I, 4;'lt l 4~,a~I l I l I 1M a ipse, REPORT-9).QAA/170%CHARACTERISTICS COMMENTS 6.7.2 Log indicates maintenance required, calibration required and individual perforning maintenance initials logo tenance re uirements indicated and an attac ed ma instruction sheet.The workin co v of the nainte a o is indicated b the individual vho erforms the nai tena startin in October 80.It is to be attached to ori ina when e ui ment is turned over to construction 6.8 Does the MaterM.Capqrvisor or his designee conduct periodic in-storage inspections or required maintenance? {on required maintenance) fv 6.9 AP-XIII-07 PGD-002 Are the Maintenance Log Porms signed by discipline engineer7 a is was verified b r view of lo.The are actuallv c ed dail but o 1 recorded weekly.eviewed h fol owi i ms a d t eir au es all i dicated o s'62 4 1 14 and 200 0 6.10 Are items with nitrogen pressure checked veekly7 i was verified review of lo for follovin items: or V~.Head a 0118-Reactor Ve 2.1 t e vessel a d t e head have desiccant exce t for 6.10.1 6.11 6.12 Verify items vith gauge have at least 1 psig indicated. Are items vith desiccant checkedmonthly Are rotors{5 hp and up)meggered vithin 28 days of receipt7 6.12 o rol w ich is checked eve months.e instructio s re uired the anel to be ins ected and afrer 6 months make evaluation to determine if unit i deterioratin .Desiccant was laced in unit rior to 6 no ths and evaluation vas not made.Evaluation was made and maintenance ersonnel were told durin audit to remove desiccant. Yes reviewed records for the followin POs: 162082 162086 and 435008.Date of recei t and first me ,erin indicated on maintenance lo NOTE: A Mestin house letter to E.Pelton dated 9 3 80 stated strokin and reasin of motor-o crated valves should be discontinued. Mere concerned that grease could ct in the motor and that valve vas being actuated dry.Maintenance ersonnel (Harr Caster stated he also stoppe this maintenance on Ebasco urchased motor-operated valves.Page 10 of 38 f a p! P,'l h~gh REPORT!UhL CHARACTERISTICS COMHENTS e a no ocuuente nstructions to do this.The disci line (cont.eng neer stated he oruarded instructions on Ebesco valves, ut apparent y t ey di not get to Caster.This is in the au t report as Concern 4.'~c:W>>"<<>Q-'>x C p D.*0 c (~~t-.~-'~~mc<<~'jQ-Alga, Page 10a of 38 PC-.'A 1 I l<r, I~I~g~~~I~~~~~~o'I~~I~~~~I~I~'~~I~~~~~~'~~~~~~~t~~~~~~~~~'I I I~~f rI~\~t~~~~~r~~'~~'~~r~~~~~~'~~~'~~~~~~1~~~~~~~~~~~~4~'I r 4~~~r~I~~II~~~~t~~~'~~ d I L.4 l A ~~'~~~'~N'4~~~~~~~~~~n 1~~'C 1~~~~~~~~~C~~~~'~~C I I~~~~'~~~~~~~~~~~'~~~~~~'1'~~I Il I~I e~'I~~'~<<I~I'~:~~~~~~~~~~~~j~I'\~~~~~1~ REPORT HO.QAA/170-4 QUGVSTERISTICS 7.5.3 Fora QA-3 indicates maintenance is performed. COKRHTS 7.5.3 Reviewed A-3 forms R-529 (3/7/80-Maintenance of Motor Control Valves R-518 2/22/80)-Maintenance of Motor Control Valves R-615 5/14/80 Maintenance on RHR Pum Motor R-690 8/15/80 Maintenance on Hoist of Brid e Crane R-654 6/ll/80-Maintenance on Safet In ection Pua s and R-607 (5 12 80 and R-711 (8 28 80)-Maintenance Surveillance 7.6+CC~XG;-~.Select completed Cleanliness Inspection Check Lists (Fora QA-10)and verify the following: Form was correctly documented7

7.6 vhich

is to be erfoxaed uarterl b schedule.Ins ection of Containment S ra (386'lev.) Cl-286-1-CT-3-3 vas for visual ins ection of internal onl.The were conditional acce ted.DDR 368 dated 2 21 80 on cleanin and cleanliness maintenance of safet-related i in s stems states lines spent fuel and containment spra had not been cleaned in accordance with MP-113.The audit report covers this area as Concern 6 since the procedure was not adequate 7.6.2 Documentation on cleaning agent indi-cates it is acceptable. to cover cleaning of the pipe external and t e spent tue i in is now embedded in concrete.7.6.1 The QA-10 ora vas correct y ocuaente 7.6.3 If check list indicates unsatisfactory, verify hold tag has been issued.7.6.2 Acetone is used to clean pipe.roce ure-requ res certification of com liance or test results of materials at will come in contact with stainless steel.There vas o evidence of such documents for acetone bean used.This e audit re ort as Findin 04.7.6.4 8 On items vhere check list indicates conditional acceptance, verify iten is tagged accordingly. Hold Ta 444 issued b DDR-368 on ISO-1-SF-2 Service Mater Pi e outside not cleaned it has been installed in concrete). a so Hold Ta 449 b'DR-368 on IS0-1-SP-4. 8.0 H drostatic Tests 7 6.4 Items on conditional release are containment s ra and the are insralled in done and could not be reached for verification. The Conditional Release Lo indicated Conditional Release Ta s'04 throu h 026 are assi ned to s ool ieces of this s stem for clean inside only.+CC-22 8.1 Reviewed A-26 for 3-SM-14 si ned b Loving on 10 31 79, 8.1 Reviev Hydrostatic Test Records (Form QA-26)and verify it is signed by QA Specialist. 2 e 2 a d I-SW-132 si ned b Page 13 of 38 CHARACTERISTICS 188 si 3"SM-15-Lowest Comnonent 198.75 si teated at ee (no 5>'h.dtt."-'g REPORT e COMMENTS 8.1.1 Yes 3-SW-14-Lowest Com onent 198.75 si tested a~.t.a'.rs eav~t.~'h v 8.2'-~tv Verify pressureage used had a range of not less than 1 1/2 times nor more than four times the test pressure.MP-115 8.3 Are tests witnessed by ANI, and E6C QA Inspector? 8.3.1 Mas pressure gauge calibrated2 8.4 Are pressure boundaries defined?9.0 Meldin Haterial Control 9.1 Does the Material Control gA Specialist monitor material issuance activitics7 (CJA-B, para.4.2)8.1.1 Is test pressure less than maximum permissible pressure of lowest component? 188 si and 1-SF-132-Lowest Con onent 198.75 si~~d at 188 si.8.2 For tests identified in uestion B.ll au es CP6L 06 and CP6L 87 were used and their ran e of 0-300 i ww>>within ran e.8,3 Yes verified b review of records for H dro of S stem identified in uestion 8.11.3-SM-14 J.A.Kremcr A and HacSorle ANI 3-SM-15 Daniels~A and Given AlK and 1-SF-132 Kremer A and Given ANI.8.4 Yes, 3-SM-14, Service Water from Yard 4-SW-3-2 throu 4-SW-3-9, 3"SM"15, Service Water from Yard 4-SM>>4-2 throu h 4-SM-4-9,'nd 1-SF-132, Spent Fuel 3-SF-12-171-SB 1 and 4.the ins ectors have been monitorin material issuance ehesh iists vere evsmieed for the same cried.It va~sot d that the ins ectors have been showin the date of e iration of the alified Weldin List which is ublished everv two weeks instead of showin the date the list was ublished.In addition the check list for 9/16/80 shows no record of the ualified Welders List as bein Revision 1 which was dated 9/10/80.This is written in the audit re ort as Concern P9.8.3.1 Yes, 3-SW-14 test erformed 10 30 79 and ua e calibrated 10 29 79, 3-SW-15 erformed 12 28 79, and ua e calibrated 12 28 79, and 1-SF-132 erformed ll 8 79 and ua e calibrated ll 5 79.vrs t'o'e I ttd to 0 e Page 3 4 of 38 p REPORT QAA/170-4 CEGUKTERISTICS COHHEHTS 9.2 Do the Material Control QC Inspectors nake reports of conditions found when performing inspections'?(CQA-S, para.4.3)9.3 I fo io o r ll u Four ins ectors, Robin G oves David Holler Barbara Hove and Malt Le et, werc ualified as shovn b tlnir certifications. 9.3 Are the material Control QC Inspectors trained and qualified in accordance vith Procedure CQA-12 (CQAW, para.5.0)Reported items found durin ins ections vere written u on RIRs or DDRs and data shoved the nonconformances to have been resolved.9.4 9.4'Are actions initiated to correct unsatis factory conditions found by the QC Inspectors2 (CQA-8, para.6.1)Are the unsatisfacotry conditions shown on a Quality Control Pield Report, Porm QA-3, and forwarded to the QA Specialist (CQA-S, para.6.1)9..1 The reports and nonconfornances have been revieved b the QA Specialist. 9..2 The items required to be erforaed were examined and re orted on except or Item 1.1 of the in-house record fora callin or a rev ev o the material re uisition foras to assure that they vere corn letel filled out.For the months of June, July, and August 1980, this data vas not vritten on t e-ouse orm nor was it recorded on the QA-3 forn.Dur ng t e au t, t e in-house forn vas revised to nake it morc spec c a out enter ng data required by the procedure. s was a co~nt ssue to uring one o t e dai y e r e ngs.G.z Do the Quality Control Field Reports, Fora QA-3, show verification of those items required in Procedure CQA-S, para.6.12 extra proce ure as een wr tten y A Rece v ng to cover t e s e i e inspect ons per ormed.Records show t at t ese nspect ons are being per orme when requ re 9'Do the Quality Control Field Reports, Porn QA-3, shov that reviews required by Procedure CQA-8, paragraph 6.2 have been perforned2 Page 1$of 38 I1 C 4 g'R ll,~'U Y II l 4 I-f i:~l i gc 5 Cw~r*ti D REPORT 9.6 9.7 9.8 9.9 9.11 (2UQRCTERISTICS Is the material issue area arranged so as to minimize unauthorized access to storage areas?(AP-XIII-S, para.3.2)Are QA Hold it~~for rework on requisitions that clcinrly indicate the item is to be reworked and QA approval is noted on the requisition2 (AP-XIII-S, para.3.4)Is a list of individuals authorized to sign the warehouse requisition (for receipt of material)maintained7 (AP-XIII-S, para.3.5)Are the requisitions for material signed in the proper space by an authorized individual7 (AP-XIII-S, para.4.2)Has the warehouseman signed the warehous requisition in the Received space?(AP-XIII-8, para.4.5)Have the warehouse requisitions used for permanent plant equipment been forwarded to the warehouse office for filing in the"Master" Numerical Rile folder of the purchase order on which the item was purchased7 (AP-XIII-8, para.4,6.1)9.6 Weldin materials are two ke s availab CORKRZS 9.7 Ten rework re uisi io found to contain the rework s ate si ature.9.8 The list of authorized erso maintained. 9.9 A roximatel 100 re uisi io w r am to be si ed correctlv. 9-ll The ermanent e ui ment re uisitio s are fi re uired.9.10 A roximatel 100 re uisitions were exami ed-a a ualified warehouseman had si ned the documents. Page 16 of 38 V'lt r')'oq REPORT QLhRACTERISTICS COMMENTS 9.12 Materials are stored on warehouse shelves or on allcts.9.12 Are all welding materials stored in dry storage areas on devices to keep the material from being in direct contact wit the floor7 (MP-3, para.3.4)9.13 No material was found on the floor.The materials used for field weldin are stored in the issue roons.The naterial used for welder trainin and weldia rocedure ualifications are kent in the Meldin School lockers.gC I x a 9.13 Is all of the weld material requisitions from the warehouse release storage area stored in a Meld Material Issue Roon7 (MP-3, para.3.6.1 and 3..6.5)9.14 Is the Veld Haterial Issue Roon under the direct supervision of the Discipline Engineer-Metallurgy/Melding or his designee'?(HP-3, para.3.6.5)9.15 Are all unused backing rings issued for field use returned to the Meld Haterial Issue Room at the end of each shift of work7 (MP-3, para.3.6.5)>.16 Are the E7018 low hydrogen electrodes being handled as required in Procedure MP-3, paragraph 3.9'7 9.16.1 Are the 300 series and Inconel materials being rebaked at 375-425 P.for one hour7 (MP-3, para.3.11)9.14 Yes.9.15 Those items not used are returned to the Material Issue Roon and noted on the material re uisition.9.16 The rocedure re ulrc-ents are bein erforned.9.16.1 All bakin of weldin electrodes, includin rebakin.has been erforned as re uired b the rocedure.Rebaked electrodes are di ed in red aint on their bare ends.The rebaked electrodes are issued onl on non-work Page 17 of 38 1, , 5'y.r A 4~~<'serial number (see CQA-14 aalu%>~~+) 7 (CQA-18, para.5.3.2)Y Does the Principal QA Specialist forward the completed code form to the ANI for review and certification2 (CQA-18, para.5.4)%hen the code form is properly certified is the fabrication package properly marked and filed in QA Records'(CQA-18, para 5.6)Do he QA Inspectors mcnitor the activities on a weekly basis listed in Procedure CQA-20, paragraph 6.22 Do the QA Inspectors review randomly selected and specifically selected records, on a monthly basis, to verify compliance with drawings, specifications and procedures the activities listed in Procedure CQA-20, paragraph 6.3.27 is se t to Pete Cook who t es a final NPP-S and submits the form with the acka e for he Pr A S ecialist's si ature and assi~nt of Natio Bo rd Serial numbers as re uired.10.3.1 The five acka es in A R cor re uired.10.3.2 Yes all five com leted fabricatio a k in A Records.10.4 A records show the ins ection of CBI work bei do recentl on a tsu-week basis due to the lack of wor CBI durin June Jul and Au ust.10.4.1 A records show monthl surveillance of the contractors'ecords re orts drawin s and s ecifications. Q g,r~+C~W~~Page~2 of 38 tl'4l a r F~f I p, I'Op'J I~'" N '8 I kl~I I~'~~~~ls.s~I~I~'~~~~~'~~~~~~~~I~~~~~s~~~I~S~~'~s~~s S'~~~~~~s s I+~s~~~I~~~~s~~~I~~~~~'~~~~~I'~~~~~~~~~~s~~~~~ss~~sssl'~~I~'I'..s I~~~Sl s~~~~s I~~~~~~~~I~I~I~'~~I~~~~s~~~I~s~~~~s~'~~~I~'~~s~I sl I~s~~~~~~~'~~~~~~~'s I'~~~ ~~4 7I Il g cr\P~y ~:~~I I~H r~~~~~~~I~'~~~~or~~I~~~~~~I..o 5~'~'~~~'~~~~~5'~H~'~~~~'5~~~'~.I~5~~~~'~~~'~~'o~~~~~~~o~~~~~~~~~~~~~I'5~'~H~~', H'~~~I~',~~~Io~~5 5~~'~~'5~~~~~5~~~~~~~~~~I'~~~~~~~I'~r 5 I'~~~5~'~ t A J,II k t ~~~~~'~~~~~I i~I~~~~~~I~I I~~~~4~I~'I I'~~~~~~'~~~<<~~I I~~~~~~~~~~~~~'~~~'~~'~'~I'~~~~~ E 1:1~>xi~~~~I I~~I I5~~I~I~I f~I'.~~'~~I~'~~~I I'~~~~Lf~~~~~~~f~~I~~~'r~~I f~~~~f~~~~~~~~~~'I~~~~~~~I'~~.~'~I~-~~~~~~~.~I~~~.~~~~~~~f~'~'~~g~~~~~~~~~'~~~~~~~~$'~~'~'I' REPOM/A@170-4 ll.l.l U..3 CHARACTERISTICS When the Construction Inspector detects a discrepancy on a pressure retaining boundary, does he report this to the Principal gA Specialist.(TP-24, para.3.5)Does the Construction Inspector maintain a marked-up copy of the Fbasco piping draving indicating the lines he has inspected?(TP-24, para.4.4)Has the Safety Superintendent ensured that adequate warnings and safety notices appropriate to the activity are posted?(TP-24, para.4.7)COMMENTS 11.1.1 He would but no occurrence of noted.11.2 Marked-u co ies are bein used o i d lines the ins ector has examined.r v-1-5-9 13641556-2 4 ver exam 11.3 The Safet Su erintendent vas unavare of'o'.'for his erformance in Procedure TP-24.H do>have a dail meetin vith the Weldin and Constru io Su ervisors to discuss roblems of safet for e work.11.4 The re uirement for uarterl reviews has been del ted as a result of the findin in Audit AA/81-13 when Procedure TP-28 was revised.The re uirements in TP-24 are in rocess of bein deleted likewise.11.4 Has the Construction Inspector made quarterly reviews of the Equipment Maintenance Log and quarterly checks of equipment installed and documented these checks by initialling the"maintenance performed" section of the Equipment Maintenance Logg (TP-24, para.4.9)12.0 Nondestructive Examination (IX)12.1 Radiographic Examination (NDEP-101, Rev.3)Page 25 of 38 -A~qp+Km REPORT COMMENTS CHA1VLCTERISTICS 12.1.1 The followin velds were selected for review: 12.1.1 12.1.1.1 12.1.1.2 Select welds examined with radiography and verify the following: Personnel who performed radiography vere qualified in accordance with NDEP-10.Pentremeters used are in accordance vith paragraph 6.5.SW-2 Rl Line 3SW-8-165-SB4 Dw.4-SW-8: Ctmt.S ra FW-199R1 Dw.1CT9 Line 2CT6-62-SB-1; Ctmt.S ra FW-187 Dw.1CT8, Line 2CT8-15-SPl; Ctmt S ra FW-199, Dw.1CT9 Line 2CT6-62-SBl; Ctmt.S ra FW-156, Dv.1CT3 Line 2CT4-59-SAl; Ctmt.S ra FW-34A Dv.1CTll, Line 2CT-12-39Al Safet In ection FW-5, Dw.1SI1, Line 2SI14-253-SAl. 12.1.1.1 Radio ra hers involved with the above welds: B.Baty, D.Jacobs, A.M ers, J.Toomer, V.Phun , M.Ferretti, and P.West were verified to be ualified.Identification and marking are in accor-dance vith paragraph 8.12.1.1.2 Penetrameters used on the above welds were in accordance with ara ra h 6.5, A concern with the number use v en examinin one weld is discussed in quest on...o this checklist. 12.1.1.4 Radiographic technique is in accordance with paragraph 9.12.1.1.5 Exposure technique is in accordance with paragraph 10.12.1.1.3 Identification and marking vere as requ re 12.1.1.4 Radio raphic technique use or a we s except atety In ection FW-5, Dwg.1SI1, Line SIl--was accepta e.Three penetrameters as allove y A ME Co e ecr.on i of four as re uired b NDEP-101 were used.This o o is included in the audit re ort as Concern 07.Personnel vho interpret radiographs are qualified in accordance vith NDEP-10, techni ue used was acce table and in accordance a a ra h 10.Inter reters: P.West E.Bets V.Phun , J.Toomer, and B Bat were verified to be ualified.12.1.1.7 Radiographic examinations are reported as required by paragraph 14..1.7 Examinations were re orted on the forms re uired b ara ra h 14.Page 26 of 38 I'I'I 1 V A I REPORT LO.AA 170%ClQQUETERISTICS COMMENTS 12.l.1.8 Have a formal ALARA program and imple-menting procedure been developed? Safet Manual has been revised to include references to the re uirements. 12.2.1 The follovin items examined b PT were selected: 12.2 12.2.1 12.2.1.1 Liquid Penetrant Egestion (NDEP-201, Rev.2)Select items examined by liquid pene-trant examination and verify the following: Personnel vho performed the PT are qualified in accordance vith NDEP-10.Ctnt.S ra FW-866 Dv.2165-G-103' ent h.l Pool Liner Dw.SK-AG-0152 Main Steam FW-286'2165-&067 Main Stean FW-283, Dv.1-M-30 Ctmt.S ra SW-2&-3 Dv.1CT3;Main Steam FW-287, Dv.A3-261-MS-177'ain Stean FW-282, Dv.A3-261-MS-65 and Fuel Pool Liner Dv.ALFAB 596-SHl.12.2.1.1 Personnel vho erforned the PT: D.Jacobs, P.West, V.Phun , B.Bat vere verified to be ualified.12.2.1.2 Materials indicated on the PT re orts vere in accordance ~with re uirements, except SKI t e dye penetrant was 12.2.1.2 Materials used for PT are in accordance with paragraph 6'.12.2.1.3 Area of examination is as required by paragraph 8.0.2.2.1.4 Preparation of surfaces to be examined is in accordance vith paragraph 9.recorded on ten of the reports revieved.The auditor verified b contacting the area Ma naflux Re resentative that no dye penetrant identified as type SKI vas manufactured by Magnaflux. The correct designation is SKL.This con t on is included in the audit report as Concern 12.2.1.3 Review of the ro orts identified in Iten 12.2.1 indicated 12.2.1.4 that the PT examinations vere erformed in accordance and with NDEP-201.12.2.1.5 12.2.1.5 Application of penetrant is in accor-dance with paragraph 10 and 11.Page 27 of 38 C g f 4w ta hid~>I f REPORT CH QtACTERISTICS COMMBiTS 12.2.1.6 Drying of surfaces after removal of excess penetrant is in accordance with paragraph 12.12.2.1.7 12.2.1.8 12.2.1.9 indicated that the PT examinations were erformed in accordance with NDEP-201.12.2.1.7 Application of deve1opor is in accor-dance with paragraph 13.12.2.1.10 The re orts reviewed were on the correct form and did contain the re uired information. 12.2.1.11 Personnel who erformed the tests inta rated the results the were verified to be ualified;the are identified in Item 12.2.1.1 above.~2.2.1.8 Interpretation of indications is in accordance with paragraph 14 and 15.12.2.1.12 No examinations involvin non-standard tern eratures have been made.12.2.1.9 Cleaning after examination is in accordance with paragraph 16.12.2.1.10 Reporting is in accordance with para-graph 19..2.1.11 Personnel who interpret PT are qualified in accordance with NDEP-10.12.2.1.12 Qualification of procedures for non-standard temperatures is in accordance with Attachment A.Page 28 of 38 Il~~I'~~~~I~I I'I~~~~I I I I~I~~~~~~~~I~~~'~~~~~~0~~I~~~~~I'~~I~O,N'~~I I~~~~~~~~Il I~~W~~~'~~I~~~~~~~ C*'I ~~~~~~~I~I~~[e.~~'ll 11'I~~I~~~~4~~4~~~~~s I A'~~tl~~~~~,~~~I I I~~I~~~~~~~~~~~~~~~~~I~~~ 0 I'c 4 y PS h" REPORT CHARACTERISTICS 12.3.1.8 Personnel who interpret MT are qualified as required by NDEP-10.12.3.1.8 12.4 COK9ÃZS Inter reters were veri ie as qua i e;t ey are identified in Item 12.3.1.2 above.ho UT has been nerformed on Code items.12.4 Ultrasonic Examination (NDEP-402, Rev.0)12.4.1 Select velds examined with UT and verify the following: -2.4.1.1 Personnel who performed the examination are qualified as required by paragraph 4 12.4.1.2 Equipment used is in accordance vith paragraph 5.12.4.1.3 Technique used is in accordance with paragraph 6.Calibration of the test system is in accordance vith paragraph 7.12.4.1.5 Examination is in accordance with paragraph 8.12.4.1.6 Examinations are reported as required by paragraph 14.Page 30 of 38 C I 3 7~5+'V.--, t-~, 1 C J (j*p 4 1 (1 A REPORT MO.QAAI 170-4 CHARACTERISTICS 13.0 Ins ection and Test ui ment Control XII 13.1 13.1.1 Calibration of Pilm Densitometers ((g1-101.1, Rev.2)Are the following calibrated in accor-dance with paragraph 3.17 ,.1.1.1 MacBeth TD-504 Densitometer. ~~13.1.2 Are periodic tests performed with the density calibration strip as required by paragraph 3.1.97 13.1.3 Is comparison of the reference and vorking strips made each week as Q required by paragraph 3.2.32 13.1.1.2 X-Rite Company Model 201 Densitometer 13.1.1.2 13.1.2 13.1.3 13.2.1 COMMENTS The MacBeth TD-504 Densitometer in the Film Viewin Room CPAL 804556A vas serviced and cali-brated b Chieffe Electronics Southeast November 12 1979.MacBeth TD-504 CP6L 801172A has been out of service since 5-21-80.The X-Rite Com an Model 201 CPAL 804550A is bein used at another site.Yes tests are erformed dail with the calibration stri.Ycs a lo of the weekl corn arisons is maintained for CPSL 804556A.Certifications for the enetrameters obtained b P.O.H26407 vere revieved.13.2 Field Calibration Check of Radiographic Penetrameters (QCI-101.2, Rev.0)13.2.1 Verify penetrameters are purchased with certifications of calibration traceable to NBS.(Para.4.1)C V Page 32 of 38 t t A f 0 7 p'a REPORT 13.2.2 CHARACTERISTICS Are penetrameters identified with a traceable nu~ber and entered in a log bookl (Para.4.2)13.2.2 13.2.3 CO%ANTS Yes numbers enetrameters numbered 165-174 have o issued.The annual check was verified b reviev of h o in which the checks vere recorded.13.2-3 Verify penetra"etero ara checked for thickness and essential hold size on an annual basis.(Para.4.3)13.2.4.1 13.2.4'13.2.4.3 13.2.4.4 Yes use of the 4 items was verified with ersonnel res onsible for the an a e 13.2.4 Are the folloving used to make the annual check: (Para.4.4)13.2.5 Gau e blocks used are obtained from Rober H 8 Calibration S cialis.e ra a e o are the lates with test holes provided wi 3 Kwik Chek devices CP6L 804548A 80454 A an 13.2.4.1 Outside micrometer 804546A.e ho e sizes in hose es.1~at were certified whe.he Rwik C k d vi s w.urchased.13.2.4.2 Quick check hole gauge 13.2.4.3 Calibrated gauge blocks.2.4.4 Calibrated traceable hole gauge~~~13.2.5 Verify the traceable hole gauges and gauge blocks are calibrated annually.(Para'.5)Page 33 of 38 P gt kp I-7w.&'-'~..O~ z,~~+>;+~$6'@~~>,+~'4 REPOQX IU-QQQVLCTERISTICS Welding Equipment Control (NP-9, Rev.5 13.3.1 Verify that operational checks are performed on weldiqg machines at inter-vals not to exc ee months.(Para.3.8)Wf~3 2 Are machines tagged to indicate per-formance of operational checks'(Para.3.2)13.3.3 Does M/E maintain an up-to>>date record of operational checks7 (Para.3.2)13.3.2 13.3.3 13.3.4 13.3.5 COMMEHTS checks st least eve months was verified b checkin the followin weldin machines: W-118 W-488 W-82 W-121 W-159 W-377 W 37-6 W 467-W 37-6 W-455 W-456 II 23-0 W 40-0 II 34-9 3-347.Yes all the machines identified above.'a ed exce t W-82.This machine was re orteB~to'* Yes M/E receives co ies of maintenance re orts and maintains a lo of weldin e ui ment.Yes this was verified b review of maintenance records for the followin e ui ment: Miller Rectifiers W-361 and W-143 Hobart Rectifier W-313 Miller Gasoline Generator W-73 Lincoln Rectifier W-237A Westin house Grid W-250 and Hobart Rectifier W-301.Yes co ies of these re orts are maintained b M ED e@~i+~gg>74k@gjj~g 13.3.4 Are machines requiring repair tagged and removed from service7 (Para.3,3)13.3.6 Yes co ies of the maintenance re orts are maintained in Document Control.w 3~5 13.3.6 Is a Welding Machine Maintenance Report prepared for machines requiring repair7 (Para.3.3)Are records of welding machine opera-tional checks maintained in Document Control7 (Para.3.9)*Machine W-82 had been taken out of service and was awaitin repair.Page 34 of 38 OS~6P 4 5*~+~<<d0 /~,;<~V-$4' REPORT.D).QAA/170-4 14.0 14.1 14.1.1 QDBACIERISTICS Code Data Re orts and Name late Stem in XVII Application and Control of"N" Stamps (CQA-14, Rev.0).-~++~7g Verify the".H".atcajs are stored in a locked drawer or cabinet.(Para.5.1.2)14 COHHEHTS Onl seven orifice lates and 1 modification to a 8 ool iece have been stem ed.These items are not considered to be t ical exam les of items to be stem ed therefore re orts and stem in will be audited as soon as more t ical items are stem ed.14.1.2 Verify that documentation required to sbov compliance with the Code is on site prior to application of the"H" stamps.(Para.5.2)14.1.3 Do nameplates contain the information required by paragraph 6.17 14.1.4 Verify application of appropriate"N" type symbols is in accordance with paragraph 6.2.14.1.5 Is preparation of Code data reports in accordance with paragraph 6.32 14.1.6 Is an"N" stamp log maintained as required by paragraph 6.47 Page 35 of 38 h h~' EFFORT QIAItACTERISTICS COHMENTS 14.1~7 Are Code data reports certified by the ANI prior to application of"N" stamps'Para. 7.3)14.1.8 Are locations o&g~~A nameplates indicated on thm appropriate isometric drawfng7 (Para.7.4.3)14.2 Assignment and Control of National Board Serial Numbers (CQA-15, Rev.0)14.2.1 Are numbers assigned in accordance with paragraph 5.12 14.2.2 Is placement of numbers as required by paragraph 5.22 4.2.3~~Are numbers recorded in a log as required by paragraph 6.17 14.2.4 Are Code data forms submitted in accordance with paragraph 6.37 Page 36 of 3S 'I CHARACTERISTICS housekee in ins ections.15.1.1 14.3 Preparation and Submittal of ASME Code Data Reports (C+-16, Rev.0)rREPORT CORGKZS 15 Yes verified b review of documented recor s f 14.3.1 Are reports prepared for fabrication or modification of,--q~>>fh+ aubassemblies as required by pm'<~~~.~~'l.l?I 1302 Q Are reports prepared for piping system or subsystem installation as required by paragraph 6.2?14-3.3 Are reports prepared for the nuclear power plant unit as required by para-graph 6.3?15.0 Housekee in 15.1.1 Are gA Inspection personnel performing the walk-through inspections assigned them and are they alert to the specific requirements listed in Procedure CQA-3, paragraphs 7.3 and 7.4?Are the records created by the gA Inspectors in 15.1 above reviewed for compliance by the Principal QA Specialist or his designee?(CgA-3, paragraph 7.5)Page 37 of 38 V]~W A'7 C F. I,'~4 I r REPORT 15.2 CHARACTERISTICS Are documented reports of housekeeping inspections in the warehouse and material storage areas being completed by the Materials Supervisorl (AP-VII-6, paragraph 3.4)15.2 15.3 15.4 COUNTS No this ia not e n concerned that Procedure AP-VII-06 are re h is an error in the wa it is stated.The refer n to Procedure AP-IX-02 robabl should be for control and distribution of Housekee in re.o This a ears in the audit re ort as Co Yes the zones are listed on a char b'o a.a res onsible suocrintendent res onsible o s i Is housekeeping in the Document Control Area being done as required in Proce-dure AP-IX-22 (AP-VII, para.3.5)15 4.1 ins ector and A Ins ec or.Yes verified b review of ousekee i I s records.15.4 Are Superintendents designated as responsible for the housekeeping zones as listed in Appendices A through E of Procedure AP-VII-6, paragraph 3.67 16.0 M ins Site A Mana eaent and the auditors were conducted at the end of each audit da to re ort and discuss an nonconformances concerns and co~eats observed b the auditors.The ostaudit aeetin was held at the conclusion of 15.4.1 16.0 Postaudit Meetin Are the above designated Superintendents maintaining the specified housekeeping conditions in their assigned areas'These areas, designated by drawing SS/K-G-5008, are to be inspected for cleanliness)(AP-VII-6, para.4.3)the scheduled audit to resent and discuss the nonconformance and concerns which were to be included in the audit report.Site mana eaent personnel at the ostaudit meetin indicated that they understood the items resented and their responses were iven to all items presented. Attendees o the postaudit meetin axe listed in the audit rcport.c k 4'I 4 Page 38 of 38 1 1 b\'I C'P r oem 244 QgwIl, Cerollnrs Power a Llglsl Compony Cnmpeny Correspondence Pile: QAA/170-4 MEMORANDUM TO: Mr.S.McManus FROM: A.E.Hall

SUBJECT:

Resolution of Audit Pindingo, QAA/170-4 ASME Audit of SHNPP Construction March 5, 1981 r (',, ,nh.'!h o h (h4'y+'h'hI'h.h l..t ie h)-'i J'~ph h, h-" l o)'h j~The corrective actions taken to resolve Finding Items 1, 2, 3, 4, 5, 6, and 7 vere audited during Audit QAA/170-5, and these findings have been satisfactorily resolved by those audits.In addition, the response to Concern Noo.5 and 6 were audited during Audit QAA/170-5. This response to Concern No.5 satisfactorily resolved this concern.The response to Concern No.6 is still open as unresolved and is being carried forward as Concern No.1 in Audit Report QAP/170-5. Concurrence: S.McManus Mana Corporate Nuc ear Sa y&Quality Assurance Audit AH/vcH1 cc: Mr.N.J.Chiangi Dr.T.S.Elleman Mr.G.L.Forehand Mr.P.W.Hove Mr.R.M.Parsons Mr.S.D.Smith Mr.T.H.Wyllie Summary: Finding Items 1, 2, 3, 4, 5, 6, and 7 plus Concern No.5 are closed by report and audit.Concern No.6 is now Concern No.1 in Audit Report QAA/170-5. This audit is hereby closed.hh (;hi h hh h 1 1(c~,O'""'(: , (v t".r h (gh c,~fli i I i O p"',,~i f~e'g O, tf)e I o 7 t'I g<'1I ,J A g, VtWig'V4 ~I I~I I I~~IX~'~~~'~~I I'~~~~I~'~I H~~~4 I~0 H~~~'I~~~t~~~~~~I~'~~~~~~~~'~'H~~~~~~~I~~~~~H~~~~~~I H I~~~I~~~\I~H H I~tp I~~'~~~~HH~~~~~~~~~~I I~~~II~~H I~~'~~~~~'I~~~I~~~~I~~I H I~~~~~I I~ kg C, p~Jgt II t<<t 1 I loim 2aa Company Correapondence Caroana Power 8 Light Company Docembor'12, 1980 F145 gg 4~ro PEG l9pi)DECEIVED, 5 CP.g (a CHSg,gAA g'-"a" s>~,~'ile: SH A-2/2 QA-1995 MB/ORANDUM TO: Mr.S.McManus FROM: N.J.Chiangi

SUBJECT:

Follow-Up Response to Corporato Audit QAA/170-4 Tho Corporate Audit Report QAA/170-4 for audit of the Harris Project ASME activities during Septembor 15-18, 22, 1980, listed six (6)findings and two (2)concerns roquiring formal response.Based on our previous response (reference letter QA-1917 dated October 31, 1980)and tho attached, with the exception of Concern f36, it is considorod that corrective action for each of the items is satisfactory and tho items should be closed.Corroctive action for Concern 86 is incomplete. Please lot mo know if you nood any additional information. Gt.F/lm A t tachment ceo Mrs Ro Mr.P.N'.S.Mr.T.Mr.G.M.Parsons (w/a)H.Howe (w/a)D.Smith (w/a)H.Myllie (w/a)t.Forehand (w/a) I yr 4 l',p,'L I il'V n*I pg L~o t, e C ll I 1, Ill I j'Rl R'"~IRI 1 t Ill,I Q't'NR.',,'j, Prt, ((iR"t RR ," i'Rg'i.<RRItfll~~t QUALITY ASSURANCE AUDIT QAA/JQ4 Follow-Up Response to Find1nga Finding 83: ASME Code Section III, NA-4133.6 Document Control, requires"measures that shall assure that documents, including changes, are r eviewod for adequacy..." The auditor dotermined that a portion of the text of Paragraph 1.3, 10CFR21 requirements, of Site Spocification 036, Revisions 1, 2, 3, and 4 which wao in the or1ginal issue of the document, was inadvertently deleted in Revisions 1, 2r 3, and 4 duo to typing error.This discrepancy went undetected throughout the CPAL Site construction and QA organizations. This document was a requirement on eight out of seventeen purchase orders for ASME Code items reviewed by the auditor.Corrective Action: The Senior Resident Engineer generated and distributed a memorandum (refer ence nemorandum MS-7687 dated September 18, 1980)to all supervisors alerting them to the particular problem and the general responsibilities involved.Site Specification 036 was revised on November 28, 1980 incorporating the missing paragraphs. A change order wao written to purchase order numbers 28261 and 28910 to iosuo and impose the requirements of rev1sion 6 to Site Specification 036 on the vendors.~FKRRIRin RR4: Procedure WP-112,"Control of Mater1als and Equipment That May Be Harmful To Stainless Steel," requires naterials that are purchased for a function that will require them to come in contact with stainless steel shall not;contain moro than 1000-PPM leachable halogenated compounds (including chlorides), A certificate of compliance to Cho above must be pr'ovided by the supplier or sampled and tested upon receipt of the matorial.There are no suppliers'ertification or sample test results on halogen content for the acetone being used on the site for cleaning purposes.Corrective Action: A represorrtative sample of acetone in use on t;he sito wao sent to the CPAL laboratory for analysis and tho results woro completed on November 3, 1980.The lab results of tho sample indicato 0.1 PPM of total leachable halogen com-pounds (including chlorides) which is consider'ably leos than the 1000 PPM allowed in procedure WP-112.When lots and/or batches of acetone are procured in the future moro awareness will be applied in assuring that a cer tificate of complianco is obtained from the supplier or the material is sampled and tested upon receipt.I'I (t R I:I.1 RR;.,igr-'.:.,; RIIR<<1 11 1",1 1'l.l II Cj I I , 1-'I,'RR',l p Rr R~'I'I (R R.RXR',';1't'R~ (41 I\(F I r r (h E I (I I 1(t tr I (.,5," Ih I~.i I (t r r'I lh'i, I't h, t (t, I'5 ASME Quality Asouro,~Audit QAA/170-4 Follow-Up Response.Qindings Pago Two~F(nd(tt 55: War'chouse st;orage procedure PGD-002,"Material Maintenance Requirements During Storago for Shearon Harris Nuclear Power Plant," requires polyethyleno used in contact with safety related, seismic 1, or stainless steel equipment not to be in excess of 55 PPM for total leachablo halogens in pigmented sheeting.Pr'-ceduro WP-112,"Control of Materials and Equ1pment They May Be Harmful to Stainless Steel," requires that materials that are purchased for a function that will require them to come in contact with stainless steel shall not contain more than 1000 PPM halogenated compounds which are leachable. NPPED Memorandum 801022, dated 5/22/80 fr om L.I.Loflin to T.H.Wyllie, indicates that protective covers must not oxceod 1000 PPM for total halogen and sulfur, and 200 PPM for leachable halogen.The f1re retardant vinyl received 6/4/80 has manufacturer's certification which states the total leachable halogenated compounds including chlorides are less than 1000 PPM.This material is being used to cover safety related and stainless stool equipment even though thero is a conflict bet;ween the three documents prescribing leachablo halogen limits.Corrective Action: Work procedure WP-112 was revised on October 7, 1980, to reflect correct levels of acceptable limits of halogens.Procedure gener ated document;PGD-002 was revised on October 30, 1980, and halogen limit criteria hao been eliminated from this document.PGD-002 now references halogen limit criteria back to procedure WP-1)2.~Find(n 57: For welding repairs to Code Class 3 base material, tho CPAL ASME QA Manual requires the QA Welding Inspector to pt'epare a sketch of the repaired area as required by the Code showing location and sizo of the preparod cavity, the welding material identifications, tho weld1ng procedure, and a report of the results of examinations. For weld repairs requiring radiography, ASME Code Section III, Paragraph ND-2539 requires a sketch showing location and size of the prepared cavity.A radiograph identified as SW-2R1, Drawing 4-SW-8/2165 wao reviewed dur ing this audit.A noto on the Radiographic Examination Report ind1cated the area examined to be a pipe wall repair.The sketch of the repaired area and the repair weld data roport rould not bo located during the audit.Only the film and the request for radiogr+hy wero available for roview.Corrective Action: As stated in the initial formal response investigation of the problem was revealed: (1)The repair was incorrectly identified as a repair to shop wold 2.In actuality, the repair was a base metal repair on piece number 4-SW-8-5(l) adjacent to shop weld 2.'('t'Fl t 5'i(."5(d"~ r (t((F'I Fr-,*h('P 5<<,(':g','0, h ri t t i,l'(I'(t.I h".(", 5 C: Q rt I htW, (~t', (I, r h(t 1'" I'g Ir C,~hr o jl I I".I I*.(1i(' /~'4 I t'I l y (V-I,(J C'l I V, 4 I 4 V h qt 1;~A p%l~'V g ,t Cg VU n I'I>>I',E(,(, IV I.(('E'>>I', I*.r~I)III (,'I I (Y',l.e ASME Quality Assur.~Audi,t QAA/170-4 Follow-Vp Response Q<<indings Pago Three (2)The dofect was discovered visually by craft personnel. The area in quostion was excavatod by grinding without notifying QA;thus no DDR was written at that time.(3)The repair MDR was procossed and the repair was completed without the necessary"skotch" of the excavated area.QA failed to note this problem and a DDR was not issued as required.The repair MDR has been corrocted by identifying the repair ed area as a base metal repair to piece number 4-SM-8-5(1). A"skotch" of the repair area has been prepared from the radiographic"skin" issued by tho QA NDE group and was inserted in the repair package.The excavat1on depth of the area repaired was determined in an 1nterview with the welder who actually performed the repair (reference memorandum from F.Shaikh to V.Safarian dated 12/3/80).Craft personnel have been instructed to coordinate repair work with QA per-sonnel to adequately ensure ovaluation and documentation of work prior to any future repair work anticipated to be done (reference memorandum from D.Timberlake to D.Turner dated 12/9/60, sub)oct is DDR-483).QA personnel have beon instructed to check DDR and/or NCR files upon receiving a NDE Request or Repair MDR to ensure that base metal defects and/or damage are properly identified, documented and controlled (reference memorandum from V.Safarian to QA Melding per'sonnel dated 12/10/80). Deficiency and Disposition Report number DDR-483 was issued to facilitate resolution of the audit identified nonconforming condition. The sub)ect DDR was closed on December 10, 1980, based on the aforementioned completed action.Concern P5: NPPED Memorandum 79462, dated 3/12/79, indicates that for duct tape that Mestinghouso reconnnends chlor1de content of tapo not to exceed 15 PPH.NPPED recommends that duct tape purchased with actual chloride content of 20.9 PPM bo used, NPPED Memor andum 801022, dated 5/29/80, states higher halogen content can bo used if tape res1due is removed prior to startup (heating up of equipment). Procedure MP-12 revis1on number 3 is in review and approval cycle;this revision will roquire all tape rosidue to bo removed prior to operation heat-up.lt is of concern that stainless steel pipe that has been embedded may not have tape residuo removed in areas that are covored over with concrete.Corrective Action: NPPED has evaluated the potential effects of leaving tape residue on stainless steel pipo which is embedded (NPPED memorandum 801320, dated December 12, 1980$.Plant design criteria restrict piping embedded in concrete to a maximum of 150 F operating temperature. This temperature is well below conditions which would cause concern relatod to failuro of piping from tho effects of contaminates on the external surface.Ef'I,, I*<<y, IQ>>(rh ,*'1'.(E I I'I ,VI,, 1*I h f v I I (hr>>E I I 4'II'l,'g*I jr (f~I I ,I.*f%I I>>>>,I IU U I(II I I U>>I(I 1-U I',f U Il\I '4'I IP i Il f",ii , 4 I a rlI.I r 4~'44 4'I e Ir'rr>4>'4, hl II 441',(r, II 4 41'Ar 4'If I ,I ,I'r 4 il ASME Quality Assurr o Audit QAA/170-4 Follow-Up Hosponso~, indings Page Four Concorn d6: Containmont spray piping and spent fuol piping was inspected according to Procedure CQC-10,"Cleannoss Control of Fluid Systems and Components," and released on"Conditional Holoase" because tho oxtornal surfaces of the pipe had not been cloaned in accordance with Proceduro MP-113,"Cleaning 5 Closn-liness Maintenance of ASME Section XXX Piping Systems." Xt is of concorn that Procedure WF-113 was inadoquate by not containing re-quirements for external pipo cloaning, and spent fuel piping is embedded in concrete and cannot be cleaned.Corrective Action: The piping in question was released on a Cleanness Conditional Accept because no exterior cleannoss criteria was addresse<~n liF-113.Tho"conditional release: was used as a vehicle to flag the potontial problem without stopping work associatod with tho piping.WF-113 is being revised to include a statement to address piping exterior cleanness requirements as well as other QA concerns.when this procedure revision is approved and issued, the"conditional release" will be closed.Anticipated date for completion of the above action is January 16, 1981.h'+41 I>I 4 y Irl I>4'I 4 1 14 rl I~,.'k~, s,-4 p,:.'h.r,.4 4, Iihh)ar-'4~IE"('4i', ,,j 4 h 1 I ,J I'4 ,->rr, rg.I ,>a e Csrollnss power a Light Comprsny Company Correspondence November 6, 1980 FILE: QAA/170-4 MEMORANDUM TO: Mr.S.McManus FROM: A.E.Hall

SUBJECT:

Resolution of Audit Findings, QAA/170-4 ASME QA Audit of SHNPP Construction

REFERENCE:

E&CQA Letter QA-1917&Attachments, Dated October 31, 1980 The referenced letter QA-1917, dated October 31, 1980, copy attached with the E&CQA response to Audit QAA/170-4 has been evaluated with the following results.The responses for finding Items 1 and 6 are considered as action taken to resolve theoe items and these finding items are hereby closed by report.The remaining responses to Finding Items 3, 4, 5, and 7 are not sufficient to close these items, due to the response action being incomplete or unacceptable as discussed below.memorandum MS-7687, dated September 18, 1980 ao record of this action taken.When we are notified the date that thc opecification is corrected and redistributed, we will close this item by report.completion of action stated.In addition, the response does not state what prevcntativc action is being taken to preclude a recurrence of this nonconformance. The closing of this item is delayed until preventative action response is received.because it does not state a target date for completion. When we notified the action is complete and the date, we will close this item by report.neceooary to complete DDR-483 is open or closed, nor if the DDR-483 condition io acceptable to the ANI.The preventative action reoponoe does not state how it is to be accomplished, a target date for completion, or if this action is to be documented. The closing of this item is delayed until additional response is received.The above evaluations of corrective actionresponse outlines additional response requested. It is requested this additional response be supplied by thc Manager-Enginccring &Construction Quality Assurance to close these finding itemo. I Vj.t'IL 4'X$t i l<<:A'r"-tt.fd','.;ig"!r t ,'4 yvrP', r p f I.rr'td t'<ff jr 0<<grrrtr ft'r u-;r*fy t'ff r-'tl ln J'dt tp"'I oj f s t November 6, 1980 Mr, S, McManus The corrective action rcsponsc to thc audit report concerns 85 and N6 does not indicate if these responses are engineering technical evaluations as requested by the QAA/170-4 Audit Report.The response for concern 86 raises additional unanswered questions. Why was this piping released on a"conditional release" based on NP-113, when this procedure did not have external cleanliness requirements'ow was this conditional release resolved?2~At present these two concerns will remain unresolved, until additional rcsponsl is received.~Suaaaa: Finding Itasn 1 6 6 ara nisse by report;Finding Iten I uas previously closed by report and audit, and Pinding Items 3, 46 5, and 7 remain open.In addition, Concerns 85 and P6 remain unresolved. yg r t ALH/t cmH2 a, Mr.R*M.Parsons Mr.S.D.Smith Mr.T.H.Wyllie J.Chiangi S.E13.eman L.Porehand M.Howe cc: Mr.N.Dr.Ts Mr.G.Mr.P.S.McManus-Manager Corporate Nuclear Safety 6 Quality Assurance Audit t't r Concur t n'rf I'ls*r ,r 4'tri r tr s t;1 0 II t u I~2 I r I y 2 t t P pg '{n>>II 0 I>>{LI'>>ro<>>>>I 2aa Company Corras pondonce C&%II lgCarol(no Powor a Ltghl Company October 3'I, 1980~g3~6'6@~gOV1980 gECElVE5.~C P.&d CNSAgl%~.d Z;:<" File: SH A-2/2 QA-1917 1h I MEMORANDUM TO: Mr.S.McManus FROM: N.J.Chiangi

SUBJECT:

Corporate Audit QAA/170-4 V>>I I'he Corporate Audit Roport QAA/170-4 for audit of the Harris proJect ASME activities during September 15 18a 22r 1980r listed six (6)findings and two (2)concerns requiring formal response.Tho attached describos the action taken or being taken to resolve the reported findings.I'I I.I{K i I ,{I I.I{{I>>I'I" I,'he intonded correctivo action for findirgs 3, 4, 5 and 7 is con-sidered satisfactory and should be adequate for closing thoso items when complete.Please let me know if you need additional informat;ion. 0LF/lm At;tachment cc: Mr.P.Mr.R.Mr.S.Mr.T.Mr.G.H.Howo (w/a)M.Parsons (w/a)D.Smith (w/a)H.Myllie (w/a)L.Forehand (w/a).~l't r K r Based on tno attached, corroctivo action for findings 1 and 6;and concorns 5 and 6 is considered satisfactory and those items should be closed.>>p 1{,I II,',I n., I p.I'L)0{L h>>,{{{{h{I'-, fg'I>>).o>>.Ih p 1 Q{I'i>>r>>LI IK-'-9,>>I~C'K'i{'-"I 5K hh>>{L Ka>>K' <~r)t 4)'i d t't'QUALITY ASSURANCE AUDIT QAAI~'4 Response to Findings~Fdndln dl: ASNT-TC-lA (1975 Edition), Paragraph 8.5,2.c, specifies that for the practical examination (nondestructive examination personnel qualifications), ten different checkpoints requiring under standing o('.test variables and procedural requirements should be included in the practical examination. In additiond Paragr'aph 9.6.l.f specifies that the practical examination should describe the pr actical test object.The quali.ication records for Norman C.Westgate, RT Level II (Daniel)practical examination record did not include ten checkpoints as required and did not describe the test object that was tested.These record nonconformances existed when the CPAL NDE Level III Examiner reviewed the record and certified this individual as RT Level II on 8/8/80.The auditors determined the record files for five other Level II personnel did meet the requirements of ASNT-TC-1A. Corrective Action: '3 The identified practical examination for Norman Westgate was determined to be deficient insofar as the record did not include ten checkpoints or describe the object that was tested.Mr.Westgate was reexamined by a CPAL Level III Radiographer, completing the deficient portion of the practical examination. A new certification was issued on October 3, 1980, and the grade point average was readjusted accordingly. It should be noted that Mr.Westgate was not the radiographer of record on any production radiography prior to issue of the new certification. In the future, more emphasis will be exercised in reviewing qualification packages for new NDE contract personnel. Finding 82: Item closed in audit report.~Fdndln dl: ASME Code Section III, NA<<4133.6 Docun:ent Control, requires"measures that shall assure that documents, including changes, are reviewed for adequacy..." The auditor determined that a portion of the text of Paragraph 1.3, 10CFR21 requirements, of Site Specification 036, Revisions 1, 2, 3, and 4 which was in the original issue of the document, was inadvertently deleted in Revisions 1, 2F 3, and 4 due to typing error'.This discrepancy went undetected throughout the CPAL Site construction and QA organizations. This document was a requirement on eight out of rroventeen purchase orders for ASME Code items reviewed by the auditor.Corrective Action: The Senior Resident Engineer generated and distributed a memorandum (MS-7687 dated September 18, 1980)to all supervisors alerting them to the particular problem and the general responsibilities involved.Site Specification 036 is anticipated to be revised to incorporate the missing paragraphs by wolomher 16, lq80.This revised site specification will beincorporated into outstanding purchase orders written against Site Specification 036..'.<,~+~tiffs drag 0 l'I r L~l h t'~>lg 4"~p 1l U 0(l S' 44 0 (t I Iel lg'I 11, I, L V I I I~')I-f4 te 1 r Le L4 Vl I d'h 14"1.'~5 ASME aUALITY ASSURANCE AUDIT QAA/170-4 Response to Findin8~Page Two F4~ed 4II II 4: Procedure WP-112,"Control of Materials and Equipment That May Be Harmful To Stainless Steel," requires materials that are purchased for a function that will require them to come in contact with stainless steel shall not contain more than 1000 PPM leachable halogenated compounds (including chlorides) ~A certificate of compliance to the above must be provided by the supplier or sampled and tested upon receipt of the material.There are no suppliers'ertification or sample test results on halogen content for the acetone being used on the site for cleaning purposes.Corrective Action: A sample of acetone in use on the site has been sent to the CPAL laboratory for analysis.Once the halogen content.has been determined PPCD and NPPED will nake a determination of acceptability. Corrective and preventative action will , be formulated based on results of the laboratory testing.]l)I ee , I Finding fl5: Warehouse storage procedure PGD-002,"Material Mainterance Requirements During Storage for Shearon Harris Nuclear Power Plant," requires polyethylene used in contact with safety related, seismic 1, or'tainless steel equipment not to be in excess of 55 PPM for total leachable halogens in pigmented sheeting.Procedure WP-112,"Control of Materials and Equipment Thay May Be Harmful To Stainless Steel," requires that materials that are purchased for a function that will require them to come in contact with stainless steel shall not contain more than 1000 PPM halogcnated compounds which are leachable. NPPED Memorandum 801022, dated 5/22/80 from L.I.Loflin to T.H.Wyllie, indicates that protective covers must not exceed 1000 YPM for total halogen and sulfur, and 200 PPM for leachable halogen.The fire retardant vinyl received 6/4/80 has manufacturer's certification which states the total leachable halogenated compounds including chlorides are less than 1000 PPM, This material ia being used to cover safety related and stainless teel equipment even though there is a conflict between the three documents prescribing leachable halogen limits.Corrective Action: Work procedure WP-112 is in process of being revised to reflect correct levels of acceptable limits of halogens.Procedure generated document PGD-002 is being reissued to reference halogen limits established in WP-112.This action, once complete, should eliminate further conflict on the prescribed leachable halogen limits.hd M V 4~.Q, w'I 4,e'+~VV'/h e'ei I I.I I I', eg e'0'1 I, r'414.e'r'.I lid 4I='"rgb", 1 4II I, el IV'e I I 1*4'I E\g1 T<, ll,~pl~"X' ASME QUALITY ASSURA'"+AUDIT QAA/170 4 Response to Finding ,'age Three~FEndEII il6: Procedure lF-03E Revision 9, dated September 5, 1980, Paragraphs 3.11 and 3.12 require the Molding Issue Room Attendant to daily check the welding rod holding ovens to randomly check the welding rod heated portable caddies for their proper operation at the specified temperatures. The procedure requires the above checks to be recorded on Exhibit 2, Revision 6, dated August 1980.The records examined showed that Revision 4, not Revision 6, of Exhibit 2 has been used to record the daily checks of oven temperatures in all three issue r ooms to date.Revision 4 of Exhibit 2 did not have a format that provided a desi~ated space for the data results of checking the heated portable caddies.There have been no records made of the issue room attendant's checking of the heated portable caddies since September 5, 1980 when the new requirement became effective. Revision 6 of Procedure MP-03, which was issued December 7, 1979, revised Exhibit 2 which made it Revision 5.There is no record of Revision 5 of Exhibit 2 having been used for recording oven temperatures by the issue room attendants since that date.Corrective Action: Corrective Action has been taken and all temperature recordings that were recorded on revision 4 have been transferred and recorded on revision 5 back to effective date of December 7, 1979, with a statement and date attached to each sheet indicating it was transferred from revision 4.All temperature recordings that were required an revision 6 have also been transferred from revision 4 to revision 6 back to effective date of September 5, 1980.A statement and date was attached to each sheet showing the change.Metallurgy/Welding Unit personnel have been cautioned about failing to destroy superceded and absolete forms.Measures were taken to ensure that all forms now in use are in compliance with the latest applicable procedures. FEECEntJ JJE: For welding repairs to Code Class 3 base materxal, the CP&L ASME QA Manual requires the QA Welding Inspector to prepare a sketch of the repaired area as required by the Code showing location and size of the prepared cavity, the welding material identifications, the welding procedure, and a report of the results of examinations. For weld repairs requir ing r adiography, ASME Code Section III, Paragraph ND-2539 requires a sketch showing location and size of the prepared cavity.A radiograph identified as SW-2R1, Drawing 4-SW-8/2165 was reviewed during this audit.A note on t'h e Radiographic Examination Report indicated the area examined to be a pipe wall repair.The sketch of the repaired area and the repair weld data report could not be located during the audit.Only the film and the request for raciography were available for review. /J k A l]C Qr 1~.wf iPl l vt ()4 Wl'E'1 I 6 P 4 ig k, 3' t ASME QVALXTY ASSVRP"'CE AUDIT QAA/170-4 Response to Findi Page Four 1 Corrective Action: Investigation of the problem revealed: J d (1)The repair wao incorrectly indentified as a repair to shop weld 2.In actuality, the repair was a base metal repair on piece number 4-SW-8-5(l) adjacent to shop weld 2.(2)The defect was discovered visually by craft personnel. The area in quest;ion was excavated by grinding without notifying QA;thus no DDR was written at this time.(li.lk).0 ,)d I.Concern l)5: (l ld ('i it'ilt NPPED Memorandum 79462, dated 3/12/79, indicateo that for duct tape that Westinghouse r ecoomrends chloride content of tape not to exceed 15 PPM.NPPED recommends that duct tape purchased with actual chloride cont:ent of 20.9 PPM be used.NPPED Memorandum 801022, dated 5/29/80, states higher halogen content can be used if tape residue is removed prior to startuo (heating up of equipment). Procedure WP-12 revision number 3 io in review and approval cycle;this revision will require all tape residue to be removed prior to operation heat-up.Zt is of concern that stainleos steel pipe that has been embedded may not have tape residue removed in areas that are covered over with concrete.(3)The repair WDR was processed and the repair was completed without the necessary"sketch" of the excavated area.QA failed to note this problem and a DDR was not issued as required.The repair WDR has been corrected by identifying the repaired area as a base metal repair to piece number 4-SW-8-5(l). A"sketch" of the repaired l.area has been prepared from the radiographic"skin"t issued by the QA NDE group.This sketch shows all dimensions with KIre exception of the depth of the excavated area.DDR-483 has been issued to facilitate resolution of the nonconforming condition.~~ed~- >>r 0%6'4Individuals responoible for the review and issue of Repair WDR's have been;alerted to the errors exemplified by this incident and have been instructed to ensure the required sketches of the excavations have been made prior to-release for repairs.They have also been instructed to insert the DDR number in the Instructions section of Repair WDR's issued for base metal repairs.'ield welding personnel have been instructed to coordinate with OA prior to~ny weld repairs.JJ l'll I ,.l t t JJI.J)dr('J,: r ,(r*0 r r'l"" r (J g Pfi",.ri lk+l l 0 h)h b k ly y I 9 1 4 S ('I l ASME QUALITY ASSURANCE AUDIT QAA/170-4 Responso to Ffndfn~~Pago Five Corrective Action: NPPED has stated that there is no problem if tape residues were Sot removed from embedded pipo as operating temperatures will not exceed 200 F.This is well below the critical temperature where halogens could produce doleterfous consequences. Concern 86: Containment spray piping and spent fuol piping was inspected according to Proce-dure CQC-10,"Cleanness Control of Fluid Systems and Compononts," and released on"Conditional Release" bocause tho external surfaces of the pipe had not been cleaned fn accordanco with Procedure WP-113,"Cleaning 4 Cleanliness lhintenanco of AS~K Section III Piping Systems." It fs of concern that Procedure WP-113 was inadequate by not containing requirements for external pipe cleaning, and spent fuel piping is embedded fn concrete and cannot be cleaned.Corrective Action: Work procedure WP-113 does not have any external cleanliness requirements. There fs no known requirement for any external cleanliness contained fn any of CP4L commitments. The only on-site requirement fs the removal of items on the surface of stainless steel to a visual level of cleanliness (reference WP-112).~~-~~l q,(~q)Jl ie'v'JJ-~C 20%GJ'I J C'&jan 4~q~Ci.1> I~e'I form 244 g~p, Carolina Power 5 Light Compr)ny Company Corrcrpondenco October 2, 1980 FILE: QAA/170-4 MEMORANDUM TO: Mr.S.McManus FROM: A.E.Hall

SUBJECT:

ASME Quality Assurance Audit of SHNPP Construction

REFERENCE:

Letter SH A-2/2, dated September 18, 1980 The referenced letter SH A-2/2, dated September 18, 1980, with E&C QA response to Audit QAA/170-4, Finding Item No.2 has been evaluated and verified as corrected during the audit.The response for Finding Item No.2 is considered as action to resolve this item and is hereby closed by repor t/audit.Summary: Finding Item No.2 is closed by report/audit. Finding Items 1, 3, 4, 5, 6, and 7 remain open.AEH:pn Attachment cc: Mr.N.J.Chiangi Mr.G.L.Forehand Mr.P.W.Howe Mr.R.M.Parsons Mr.Sheldon D.Smith Mr.T.H.Wyllie CONCURR.Mc nus-nager Cor porat Nuclear Sa f ety&Quality Assurance Audit Wr I'f ff'it If~I I'n t Ig Pg O.4, Cm 4 44 4 i,:~,,'4 4,.(f,.-"p 4 4 r4)(1>'4'!4 JL 4 4'4.f 4'4'i, j ya, (j C r4,: rncm 244 Company Correaponrhnor File: SH A-2/2 (170-4)Carotlno Power a Ltght Compony P, 0.Box 101, New Hill, N.C, 27562 September 18, 1980 P(o9 MEMORANDUM TO: Mr.A.Hall, Lead Auditor FROM: G.L.Forehand

SUBJECT:

Evaluations Related to Disqualified Vendors GLF: jp cc: Mr.N.J.ChianEi Mr.D.A.McGaw Mr, D.C.Whitehead To prevent failure to perform evaluations as required by procedure CQA-24, ParaEraph 7.1, the E&C QA Vendor Surveillance Unit will notify the site QA Unit by memorandum of vendors removed from the Approved Suppliers List and the reason for removal.(C4)4 4 ,"-:, C H'4 ,.o"~<<'4 4')4t 4jL'QS'4,~4 ,,44 q~44'>p444 n-,n','>>Q'I'n-,-4 C'-49 4**C r 4 44 ,C (..n (k 4 Cl r,.4 I r 4.4>r4..4 hi J r"l I ,h>>, ,I s 1 1 I 0 ~~~~~~~~~~~~~~~~~~t 0~~'~~~'t~~~t~~~~~~~'~4'~~~~~~~~I~~~~~~~~~'~~~1~~~~~~~~~~~~~ 0 II e'I POWCR Pl ANT CONSTRUCT QOHPUTATI N CHKCT Er~-BY OAm SHEETS OF~EH[ID.BY DATE DEPT.SUBJECT F LL}fLt:$7picA7i m7 f Cl gg<i"5'i k>CFFCcv~I)EaBAA DAO.IEBO'A'DEC Q't~~f8%.f/<c<.8 AVPlp+OlrEC J AEPfg MPtf.CP H-ZHX,5$CCRC,l 4) to Serial: HNP-99-069 Representative Quality Assurance Audits of the Site Construction Program I, k,'4 p u ll0 lI II~Sk form 244 Carolina Power 8 l.loni Company I kr J Company Covospondonco File: QAA/170-1 February 21, 1979, MEMORANDUM TO: Mr, S.D.Smith FROM: S.McManus

SUBJECT:

Quality Assurance Audit of ASME Quality Assurance at SHNPP Construction Site I'I 111 I,'Ik.r k II l.It is current'ly planned to conduct a Quality Assurance Audit of ASME Quality Assurance at SHNPP Construction Site on March 19-23, 1979.This audit will be conducted in accordance with Quality Assurance Audit Procedure QAAP-1,"Procedure for Quality Assurance Audit as Required by CPbL Corporate QA Program" and the CPbL ASME QA Manual.The attached audit agenda/plan defines the scope and primary areas of the audit.The lead auditor will be Mr.A.E.Hall.The Manager'Engineering b Construction Quality Assurance should regard this memorandum and attached audit agenda/plan as official notification of-the audit.SM:AEH:jwjWl J.Chiangi (w/a)L.Forehand (w/a)B.Kincaid (w/a)M.Parsons (w/a)F.Thompson.Jr, (w/a){{, Wyllie (w/a)If there are any questions concerning this audit, please contact me.A ic'W I/Attachment k"v, cc: Messrs.N.G.I~R.I M.T.k!'I'I~.C f, I,, I I"!kkr,'w,{'r k tg II AUDZT AGCNDA PLAN Activity: Quality Assurance Audit of ASME Quality Assurance at SHNPP Construction Site Audit Schedule Date: March 19-23, 1979 Auditors: A.E.Hall-Lead Auditor L.W.Disscttc F.W.Taylor I.A.Johnson Requirements: (1)CP&L ASME QA Manual (2)ASME Code (3)SHNPP PSAR Applicable Document's: (1)E&C Qh Manual of Procedures (2)SHNPP Construction Procedures (3)SHNPP Specifications Agenda: 1.0 2.0 3.0 4.0 5,0 6.0 7.0 8.0 9.0 10.0 11.0 12.0 13.0 Preaudit Meeting (8:15 a.m., 3/19/79)ASME/Document Control.Site Procurement -ASME Items Receiving Inspection -ASME Items Process Control Welding Control Heat Treating Calibration of Equipment b Tools/ASME Znspection b Test (Welding b Hydro)Nondestructive Testing ASME QA Records Containmcnt Construction (ACI-359)Post Audit Meeting Audit Report No.: QAA/170-1 QAA Procedure No.: QAAP-1}}